Oji Holdings Corp

1. Sustainable forestry policy or commitment for all its operations?

The company has an Environmental Charter and Environmental Action Program Plan as well as a society webpage for environmental and social commitments. A separate 'Sustainable Forest Management Policy' is also published by the company in April 2022.

2. Sustainable forestry policy or commitment applies to all suppliers?

The company has separate procurement policies and guidelines that cover the same topics as company's own policies for sustainability.

3. High-level position of responsibility for sustainability?

Environmental Management Officer.

4. One or more members within the board of the company have responsibility for sustainability?

0 - The company reports it has a sustainability committee chaired by the representative director of the board (President and Group CEO).

5. Percentage or number of women in senior management team?

0 - The company reports no females as a part of its corporate officers.

6. Percentage or number of women board members?

2 - The company reports a total of 12 members as a part of its board out of which two members are female.

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with timber and pulp production?

[Externally verified] Signatory of UNGC.

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with timber and pulp production?

The company states it participates in committees that address climate change, forest conservation and reduction of environmental burdens, but limited details are given.

9. Sustainability report published within last two years?

Sustainability reporting is done as a part of the company's integrated report 2021.

10. Reports through standardised reporting systems?

The company has submitted to CDP for Forests, Climate Change & Water Security in 2021.

11. Climate risks assessment available?

The company has conducted and published a climate risk assessment. However, the assessment is not externally verified.

12. Natural capital assessment available?

13. Lists countries and operations?

Countries and operations are disclosed in the company's integrated report 2021.

14. Lists countries sourcing from?

This indicator is disabled as the company reports that it does not trade wood/wood fibre.

15. Total area of natural forest designated for wood/wood fibre production (ha)?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

16. Total area of forest plantation (ha)?

446000 - The company has 446,000 ha of plantation forest as of March 2021.

17. Area of plantation/natural forest within outgrower schemes (ha)?

This indicator is disabled as the company reports that it does not source from outgrower smallholder suppliers.

18. Unplanted (areas designated for future development as plantation forest) (ha)?

19. Conservation set-aside area, including HCV area (ha)?

129000 - The company has 129,000 ha of conservation forests as of March 2021.

20. Area of Intact Forest Landscape (ha)?

21. Number of Forest Management Units (FMUs)?

The company reports information on 10 FMUs controlled by it overseas. However, information on number of FMUs owned by the company in Japan is not reported. Also, its unclear if these 10 FMUs cover all of the company's operations overseas.

22. Maps of forest management units (FMUs)?

23. Forest management plans available for all FMUs?

Forest Management Plan is available for only one of the company's subsidiaries, however, this does not cover all of the company's operations.

24. Monitoring of forest management plan implementation available?

25. Company has provided valid legal documents to Open Timber Portal on use right (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

26. Company has provided valid legal documents to Open Timber Portal on forest management (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

27. Company has provided valid legal documents to Open Timber Portal on timber harvesting (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

28. Names and locations of all third-party supplying FMUs?

29. Number of company owned sawmills?

The company has at least two sawmills, however the information is undated.

30. Names and locations of company owned sawmills?

The company only provides static image files showing two sawmills. It is not possible to determine their exact location using these maps, and it is also unclear whether these represent all company sawmills. It is also undated.

31. Number of company-owned pulp and paper mills?

The company lists five paper mills associated with Oji Paper, three pulp mills associated with Oji Fibre Solutions and one pulp mill with Pan Pac. However, it is unclear if this information covers all of the company's pulp and paper mills.

32. Names and locations of company-owned pulp and paper mills?

Locations of five paper mills are provided, however the data is undated.

33. Reports total volumes (or percentages) sourced by company-owned sawmills that come from company's own operations and third-parties?

34. Reports total volumes (or percentages) sourced by company-owned pulp and paper mills that come from company's own operations and third-parties?

The company reports information on sourcing done by four of its manufacturing facilities in 2020. The traceability information is externally verified by SGS, however, this does not cover all of the company's supply.

35. Number of third party supplying mills?

The company reports that it received 455 traceability reports from domestic woodchip suppliers, 171 reports on each shipment from overseas woodchip suppliers and 378 reports from pulp suppliers for the fiscal year 2020. However, it is unclear if this refers to supplying mills specifically.

36. Names and locations of all third party supplying mills?

37. Reports total volume (or percentages) sourced from third-party supplying mills that come from the supplying mills' own operations and third parties?

38. Procedures to trace raw materials to country of harvest?

The company has procurement guidelines that commit to traceability back to the forest.

39. Percentage of supply traceable to country of harvest?

40. Procedures to trace raw materials to FMU level?

The company has procurement guidelines that commit to traceability back to the forest.

41. Percentage of supply traceable to FMU level?

42. Time-bound plan for achieving 100% third-party legality verification of FMUs or achieved?

The company has a target to increasing the forest certification acquisition rates by 2030, but does not specify to 100%.

43. Percentage area (ha) verified as being in legal compliance by a third party?

55% - The company has a total landbank of 575,000 ha, which comprises 188,000 ha company-owned production forests in Japan, 258,000 ha of overseas production forests and 129,000 ha of overseas conservation forests. The percentage of certified forest has been calculated to include only FMUs where the certified area (ha) is available on FSC/PEFC databases or the FSC/PEFC certificates/audit reports are publicly available. Some certified FMUs have therefore been excluded from the calculation.

44. Time-bound plan to source only wood/wood fibre that is in legal compliance verified by a third party?

45. Percentage of all wood/wood fibre supply traded/processed verified as being in legal compliance by a third party?

46. Percentage area (ha) FSC FM certified?

55.34% - The company's FSC FM certified area is 318,258.67 ha.

47. Time-bound plan for achieving 100% FSC FM certification of FMUs or achieved 100% FSC-certification of FMUs?

48. Percentage of wood/wood fibre supply (tonnes) from all suppliers that comes from FSC FM certified areas?

49. Commitment to source only wood/wood fibre that meets FSC Controlled Wood and/or PEFC Controlled Sources requirements?

50. Percentage area (ha) PEFC certified (excluding FSC certified area)?

The company has PEFC certified FMU's but the total area covered by these certificates is not publically available.

51. Commitment to zero conversion of natural ecosystems?

52. Commitment to zero conversion of natural ecosystems applies to all suppliers?

53. Commitment to zero deforestation?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

54. Commitment to zero deforestation applies to all suppliers?

55. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's certification/membership.

56. Evidence of monitoring deforestation and/or ecosystem conversion?

57. Evidence of monitoring deforestation and/or ecosystem conversion in supplier operations?

58. Amount of deforestation and/or ecosystem conversion recorded in own operations since cut-off date?

59. Amount of deforestation and/or ecosystem conversion recorded in supplier operations since cut-off date?

60. Commitment to restoration of deforestation/conversion?

The company commits to restoration in the 2020 Environmental Action Plan but does not include a cut-off date and the commitment itself is unclear.

61. Commitment to restoration of deforestation/conversion applies to all suppliers?

62. Implementing a landscape or jurisdictional level approach?

[Externally verified] Points for external verification have been awarded on the basis of the company making this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2 EN) and the PEFC International Standard (PEFC ST 1003:2018). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC/PEFC certified landbank.

63. Biodiversity policy?

The company reports information on its multiple initiatives for biodiversity conservation. However, a measurable time-bound target is not reported.

64. Biodiversity policy applies to all suppliers?

65. Identified species of conservation concern, referencing international or national system of species classification?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements do not fully meet the SPOTT indicator criteria. The company has also identified species of conservation concern, referencing the IUCN red list, however, the information reported is not externally verified.

66. Examples of species and/or habitat conservation management?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria. The company also reports its own information on species and habitat conservation management.

67. Commitment to no hunting or only sustainable hunting of species?

68. Commitment to no hunting or only sustainable hunting of species applies to all suppliers?

69. Commitment to protect forest areas from illegal activities?

The company's 'Procurement Policy' specifies a commitment to no illegal logging, but no other illegal activities are mentioned.

70. Commitment to protect forest areas from illegal activities applies to all suppliers?

All suppliers are subject to the company's 'Procurement Policy' which specifies a commitment to no illegal logging, but no other illegal activities are mentioned.

71. Evidence of protecting forest areas from illegal activities?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria.

72. Commitment to no use of genetically modified organisms?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its own commitment to avoidance of GMO wood.

73. Commitment to no use of genetically modified organisms applies to all suppliers?

The company's commitment to no use of genetically modified organisms applies to all suppliers.

74. Commitment to conduct High Conservation Value (HCV) assessments?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

75. Commitment to conduct High Conservation Value (HCV) assessments applies to all suppliers?

76. High Conservation Value (HCV) assessments available?

77. High Conservation Value (HCV) management and monitoring plans available?

78. Commitment to the High Carbon Stock (HCS) Approach?

79. Commitment to the High Carbon Stock (HCS) Approach applies to all suppliers?

80. High Carbon Stock (HCS) assessments available?

81. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

82. Commitment to conduct social and environmental impact assessments (SEIAs)?

83. Commitment to conduct social and environmental impact assessments (SEIAs) applies to all suppliers?

84. Social and environmental impact assessments (SEIAs) available, and associated management and monitoring plans?

85. Company has provided valid legal documents to Open Timber Portal on impact assessments (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

86. Commitment to no planting on peat of any depth?

87. Commitment to no planting on peat of any depth applies to all suppliers?

88. Landbank or planted area on peat (ha)?

89. Implementation of commitment to no planting on peat of any depth?

90. Commitment to best management practices for soils and peat?

91. Commitment to best management practices for soils and peat applies to all suppliers?

92. Evidence of best management practices for soils and peat?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank.

93. Commitment to reduced impact logging?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

94. Commitment to reduced impact logging applies to all suppliers?

95. Evidence of implementing reduced impact logging practices?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

96. Commitment to zero burning?

97. Commitment to zero burning applies to all suppliers?

98. Evidence of fire monitoring and management?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have not been awarded as the area of PEFC certified FMUs could not be verified using publicly available information. The company's own reporting only covers information on fire monitoring systems implemented by its unit-CENIBRA.

99. Details/number of hotspots/fires in company FMUs?

100. Details/number of hotspots/fires in suppliers operations?

101. Time-bound commitment to reduce greenhouse gas (GHG) emissions intensity?

The company reports it aims to reduce GHG emissions by at least 70% or more by FY2030 compared to FY2018.

102. GHG emissions intensity?

The company reports scope 1 + 2 emissions intensity as 5.489 (t-CO2e/ Sales million yen) in 2020.

103. GHG emissions from land use change?

104. Progress towards commitment to reduce GHG emissions intensity?

The company achieved a 5.4% reduction in GHG emissions intensity in FY2020 compared with FY2013. However, this information is not externally verified.

105. Methodology used to calculate GHG emissions?

The company reports that Japanese operations calculations are based on the 'Act on the Rational Use of Energy' and the 'Act on Promotion of Global Warming Counter measured', while for overseas operations calculations are based on the IPCC GHG Protocol.

106. Time-bound commitment to improve water use intensity?

The company only commits to reduce water consumption intensity (unit per production) by 6% or more compared to FY2018. However, a target year is not reported by the company.

107. Water use intensity?

49.3 - The company reports water use intensity as 49.3 m3/ production ton in FY2020.

108. Progress towards commitment on water use intensity?

The company reports water intensity figures from 2016 to 2020, however water intensity increased between 2018 and 2020. Also, the information is not externally verified.

109. Time-bound commitment to improve water quality (BOD or COD)?

The company reported a BOD target for FY2020 as 5.08 or less and a COD target for FY2020 as 23.01 or less. However, both of these targets were not met by the company in FY2020 but the BOD and COD levels of the company are within the regulatory limits set by the government.

110. Progress towards commitment on water quality (BOD or COD)?

The company reports BOD and COD figures from 2016 to 2020, but the figures show no improvement between 2018 and 2020. However, the figures reported for FY2020 are still under the regulatory limits set by the government. The information reported is not externally verified.

111. Treatment of pulp and paper mill effluent?

The company states it treats wastewater from its pulp and paper business.

112. Evidence of sawmill run-off containment and wastewater treatment?

113. Proportion of processing facilities with closed-loop water treatment system?

114. Commitment to protect natural waterways through buffer zones?

115. Implementation of commitment to protect natural waterways through buffer zones?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percentage of company landbank certified by FSC.

116. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?

117. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers, applies to all suppliers?

118. Evidence of eliminating chlorine and chlorine compounds for bleaching?

119. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides?

120. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers?

121. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

122. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers?

123. Chemical usage per ha or list of chemicals used?

The summary audit reports of the company's FSC certified areas contain lists of pesticides used however these do not cover the company's whole operations.

124. Implementation of commitment to reduce chemical usage?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percentage of company landbank certified by FSC.

125. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percentage of company landbank certified by FSC.

126. Waste management system in place to avoid negative impacts?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements do not fully meet the SPOTT indicator criteria.

127. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports it supports and respects international norms such as the International Bill of Human Rights (the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights) and the ILO Declaration on Fundamental Principles and Rights at Work, based on the United Nations Guiding Principles on Business and Human Rights.

128. Commitment to human rights applies to all suppliers?

The company's own commitment for suppliers only mentions protection of human rights and labour rights, but does not reference the Universal Declaration of Human Rights or equivalent.

129. Progress on human rights commitment ?

The company reports that since the formulation of its 'Human Rights Policy' in August 2020, 165 people have completed human rights education as part of new general manager training and new manager training. Furthermore, it has also prepared the handbook on policy, which gives information centered on human rights, such as the background on the need for corporate efforts to respect human rights, internationally recognised human rights, and the Sustainable Development Goals (SDGs). The company also mentions that in FY2021 it will continue to provide training while also conducting video-based human rights education. However, none of the information reported is externally verified.

130. Commitment to respect indigenous and local communities' rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports it affirms the United Nations Declaration on the Rights of Indigenous Peoples.

131. Commitment to indigenous and local communities' rights applies to all suppliers?

132. Commitment to respect legal and customary land tenure rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's certification/membership.

133. Commitment to legal and customary land rights applies to all suppliers?

134. Commitment to free, prior and informed consent (FPIC)?

The company reports it affirms the United Nations Declaration on the Rights of Indigenous Peoples and Free, Prior and Informed Consent (FPIC).

135. Commitment to free, prior and informed consent (FPIC) applies to all suppliers?

136. Details of free, prior and informed consent (FPIC) process available?

137. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

138. Details of process for addressing land conflicts available?

139. Supports the inclusion of women across forestry operations, including addressing barriers faced?

140. Company has provided valid legal documents to Open Timber Portal on population rights (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

141. Commitment to enable sustainable use of non-timber forest products (NTFPs) by local communities?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

142. Commitment to provide essential community services and facilities ?

The company reports its commitment to provide essential community services and facilities.

143. Progress on commitment to provide essential community services and facilities?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank. The company also reports information on the services provided to the community.

144. Commitment to provide business/work opportunities for local communities?

145. Company has provided valid legal documents to Open Timber Portal on labour regulations (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

146. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its own commitment to support and respect the ILO Declaration on Fundamental Principles and Rights at Work.

147. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies to all suppliers?

148. Progress on commitment to respect all workers' rights?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by either FSC or PEFC, whichever is highest. The company also reports limited information on its commitment to respect all workers' rights.

149. Commitment to eliminate gender related discrimination with regards to employment?

The company reports an unclear commitment.

150. Commitment to eliminate gender related discrimination with regards to employment applies to all suppliers?

151. Progress on commitment to eliminate gender related discrimination with regards to employment?

152. Percentage or number of temporary employees?

2335 (6.47%) - The company reports on employment as a part of its ESG data disclosure. The figures reported are for March 2021.

153. Percentage or number of women employees?

18.61% - The company reports on employment as part of its ESG data disclosure. The figures reported are for March 2021.

154. Commitment to pay a living wage?

155. Commitment to pay a living wage applies to all suplliers?

The company only commits its suppliers to ensure payment of above-minimum wage.

156. Progress on commitment to pay a living wage?

157. Reporting of salary by gender?

158. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification. The company also reports a commitment to address occupational health and safety, however, the commitment does not reference the ILO Code of Practice on Safety and Health in Forestry Work.

159. Commitment to address occupational health and safety applies to all suppliers?

The company commits its suppliers to address occupational health and safety, however, the commitment does not reference the ILO Code of Practice on Safety and Health in Forestry Work.

160. Provision of personal protective equipment and related training?

Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

161. Time lost due to work-based injuries?

0.8 - Lost time injury frequency rate in 2020.

162. Number of fatalities as a result of work-based accidents?

1 - The company reports one fatality in 2020.

163. Commitment to support smallholders?

164. Programme to support outgrower scheme and/or independent smallholders?

165. Number or percentage of outgrower scheme and/or independent smallholders involved in programme?

166. Process used to prioritise, assess and/or engage suppliers on compliance with company's policy and/or legal requirements?

All suppliers of the company are subject to the company's 'Partnership Procurement Policy' and 'Wood Raw Material Procurement Guidelines'.

167. Number or percentage of suppliers assessed and/or engaged on compliance with company's policy and/or legal requirements?

[Externally verified] Traceability information for four units of the company is available for 2020. However, it is unclear if this covers all operations of the company. This report is externally verified by SGS.

168. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1). Partial points have been awarded as the requirements do not fully meet the SPOTT scoring criteria.

169. Timebound action plans (including Key Performance Indicators) for suppliers to be in compliance with timber and pulp sourcing commitments?

170. Proportion of direct and indirect supply that comes from FMUs which are compliant with timber and pulp sourcing policies?

171. Commitment to ethical conduct and prohibition of corruption?

The company reports its commitment to ethical conduct and prohibition of corruption through its 'Behaviour Standard'.

172. Commitment to ethical conduct and prohibition of corruption applies to all suppliers?

173. Progress on commitment to ethical conduct and prohibition of corruption?

The company reports it has an anti-corruption initiatives in place. However, the information provided is very limited.

174. Company has provided valid legal documents to Open Timber Portal on legal registration (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

175. Disclosure of the company’s management approach to tax and payments to governments?

176. Company has provided valid legal documents to Open Timber Portal on taxes, fees and royalties (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

177. Whistleblowing procedure?

The company has a whistleblowing procedure.

178. Own grievance or complaints system open to all stakeholders?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

179. Details of complaints and grievances disclosed?