Oji Holdings Corp

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

The company has published a sustainable forestry policy which covers all operations.

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

The company has separate procurement policies and guidelines that cover sustainability requirements for suppliers.

3. High-level position of responsibility for sustainability?

Secretariat: Corporate Sustainability Department.

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

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

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

0 - The company reports no females as part of its corporate officers. Data as of 2021.

6. Percentage or number of women board members?

2 - The company reports that 2 of its 12 directors are women.

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 reports multiple collaborations with governments, institutions, and NGOs which include joining the 30by30 Alliance for Biodiversity which aims to 'protect at least 30% of land and sea by 2030 and a collaboration with Mount Apoi Restoration Committee' for conservation activities for endangered alpine plants.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2022, covering the years 2021 and 2022 (April 2021 to March 2022).

10. Reports through standardised reporting systems?

The company has submitted CDP questionnaires for Forests, Climate Change & Water Security in 2022.

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?

The company manages plantations in New Zealand, Brazil, Australia, Indonesia and Vietnam. Processing facilities are in China, Vietnam, Brazil, Australia, Japan and New Zealand.

14. Lists countries sourcing from?

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

15. Total land area managed/controlled for forestry (ha)?

572701 - The company manages a total of 572,701 ha of forest concessions. Data as of March 2022.

16. 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.

17. Total area of forest plantation (ha)?

432520 - The company has 432,520 ha of production forests as of March 2022. Figures exclude outgrower scheme areas.

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

0

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

0

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

140181 - The company has 140,181 ha of conservation forests as of March 2022.

21. Area of Intact Forest Landscape (ha)?

0

22. Number of Forest Management Units (FMUs)?

10 - The company reports information on 10 FMUs in six countries. However, it is not clear if this covers all of the company's operations.

23. Maps of forest management units (FMUs)?

Only static image files without coordinates are available for some FMUs of the company in their respective FSC annual audit reports.

24. Forest management plans available for all FMUs?

Forest management plans and summaries are only available for some FMUs.

25. Monitoring of forest management plan implementation available?

The monitoring of forest management plan implementation is only available for one FMU.

26. 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.

27. 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.

28. 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.

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

30. Number of company owned sawmills?

2 - The company has at least two sawmills, however, only information on one sawmill is reported.

31. Names and locations of company owned sawmills?

The name and location of only one sawmill is disclosed by the company.

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

9 - 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.

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

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

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

35. 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 sourcing information for 4 of its manufacturing facilities in 2021. The traceability information is externally verified by SGS, however, this does not cover all of the company's supply.

36. Number of third party supplying mills?

The company reports that it received 467 traceability reports from domestic woodchip suppliers, 305 reports on each shipment from overseas woodchip suppliers, and 59 reports from pulp suppliers for the fiscal year 2021. However, it is unclear if this refers to supplying mills specifically.

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

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

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

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

40. Percentage of supply traceable to country of harvest?

41. Procedures to trace raw materials to FMU level?

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

42. Percentage of supply traceable to FMU level?

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

The company commits to achieving 100% legality of FMUs by 2030 using PEFC and/or FSC verification.

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

[Externally verified] 74.12% - The company has a total landbank of 572,701 ha, which comprises 432,520 ha of company-owned production forests in Japan and overseas and 140,181 ha of conservation forests. The percentage of certified forests 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.

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

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

47. Percentage area (ha) FSC FM certified?

74.12% - The company's FSC FM-certified area is 424,525.74 ha.

48. Time-bound plan for achieving 100% FSC FM certification of FMUs within 10 years?

The company commits to achieving a 100% forest certification acquisition rate by 2030. However, the commitment does not specify the verification system.

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

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

51. 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.

52. Commitment to zero conversion of natural ecosystems?

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

54. 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.

55. Commitment to zero deforestation applies to all suppliers?

56. 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 partial FSC FM or CoC certification.

57. Criteria and cut-off date for defining deforestation in supplier operations?

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

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

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

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

62. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

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.

63. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

64. 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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

65. Biodiversity policy?

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

66. Biodiversity policy applies to all suppliers?

67. 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 IUCN red list, however, the information reported is not externally verified.

68. 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. Additional points have been awarded according to the percentage of company landbank certified by FSC. The company also reports its own information on species and habitat conservation management.

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

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

71. 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.

72. 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.

73. 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. Additional points have been awarded according to the percentage of company landbank certified by FSC.

74. 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 the avoidance of genetically modified wood.

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

The company commits all suppliers to not use genetically modified organisms or transgenic species.

76. 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.

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

78. High Conservation Value (HCV) assessments available?

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

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

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

82. High Carbon Stock (HCS) assessments available?

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

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

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

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

87. 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.

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

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

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

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

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

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

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

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. Additional points have been awarded according to the percentage of company landbank certified by FSC. The company's own reporting only covers information on developing subsoiling activities before planting seedlings, enhancing regular rainwater infiltration into soil that has been compacted by the activity of heavy machinery in its own forests to contribute to the recovery of underground water retention in compacted pasture lands, as well as the prevention of erosion.

95. Commitment to reduced impact logging?

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

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

97. Evidence of implementing reduced impact logging practices?

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

98. Commitment to zero burning?

99. Commitment to zero burning applies to all suppliers?

100. 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 percentage of company landbank certified by PEFC is unclear. The company's own reporting only covers information on fire monitoring systems implemented by its unit CENIBRA.

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

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

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

The company commits to reducing GHG emissions intensity (scope 1 and scope 2) by 70% by FY2030 and net zero by FY2050.

104. GHG emissions intensity?

The company reports scope 1 + 2 GHG emissions intensity as 0.506 (tCO2e/ t-production) in 2021.

105. GHG emissions from land use change in company's own operations (scope 1)?

The company reports scope 1 emission figures, however, a separate figure including only land use change emissions is not reported by the company.

106. GHG emissions from land use change in supplier operations (scope 3)?

The company reports scope 3 GHG emissions figures in supplier operations, however, the figures reported are not specific to forestry operations.

107. Progress towards commitment to reduce GHG emissions intensity?

The company achieved an 11.3% reduction in GHG emissions Intensity in FY2021 (5.17(t-CO2e/ Sales million yen)) compared with FY2018 (5.052 (t-CO2e/ Sales million yen). However, the information reported is not externally verified.

108. Methodology used to calculate GHG emissions?

The company reports that the calculations for its Japanese operations are based on the 'Act on the Rational Use of Energy' and the 'Act on Promotion of Global Warming Counter measures', while overseas operations calculations are based on the Greenhouse Gas Protocol Initiative.

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

The company commits to reducing water intake intensity by 6% or more from FY2018 (0.48) in FY2030.

110. Water use intensity?

47.5 - The company reports water use intensity as 47.5(m3/ t-production) in FY2021.

111. Progress towards commitment on water use intensity?

The company reports water intake intensity figures in 2020 (49.3 (m3/ t-production)) and 2021 (47.5(m3/ t-production)), showing that intensity has improved in 2021. However, the information is not externally verified.

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

The BOD and COD levels of the company are within the regulatory limits set by the government.

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

The company reports BOD and COD figures from 2018 to 2021 and the figures are under the regulatory limits set by the government. However, the information reported is not externally verified.

114. Treatment of pulp and paper mill effluent?

The company states it treats wastewater from its pulp and paper business. However, the information reported is not externally verified.

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

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

117. Commitment to protect natural waterways through buffer zones?

118. 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.

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

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

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

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

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

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

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

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

127. Implementation of commitment to minimise inorganic fertiliser 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 percent of company landbank certified by FSC.

128. 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.

129. 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. The company also has its own waste management system in place.

130. 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 its own commitment to support and respect 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.

131. Commitment to human rights applies to all suppliers?

The company's own commitment to suppliers only mentions the protection of human rights and labor rights but does not refer to the Universal Declaration of Human Rights or its equivalent.

132. Progress on human rights commitment ?

The company reports it conducts 'human rights due diligence' to identify, prevent, mitigate, remedy, and disclose negative human rights impacts related to corporate activities. In addition to human rights education at management training sessions (161 participants), the company has significantly expanded the number of employees receiving human rights education, including group managers taking the Diversity Management Web-based Training, which focuses on business and human rights (2,479 participants). However, the information reported is not externally verified.

133. 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 its own commitment to a?rm the United Nations Declaration on the Rights of Indigenous Peoples.

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

135. 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 partial FSC FM or CoC certification.

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

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

The company reports its own commitment to affirm Free, Prior, and Informed Consent (FPIC).

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

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

140. 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.

141. Details of process for addressing land conflicts available?

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

The company only provides limited information on supporting the inclusion of women, which includes providing training such as career-building training for employees on the generalist track to pre-management male and female employees on the generalist track, aiming at fostering employees without gender gaps.

143. 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.

144. 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.

145. Commitment to provide essential community services and facilities ?

The company reports a commitment to contribute to maintaining or enhancing local communities' social and economic well-being.

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

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. The company also reports its own progress on commitment to providing essential community services and facilities.

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

148. 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.

149. 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.

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

151. 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 FSC. The company's own reporting provides limited information which includes holding regular meetings of labor-management committees throughout the group, in-house companies, and in-house offices to share management information and discuss issues in order to build sound labor-management relations.

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

The company only commits to the elimination of discrimination in respect of employment and occupation. A clear commitment to prevent employment and/or occupation-related discrimination based on gender is not reported.

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

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

The company reports having a 'Corporate Ethics Helpline' which receives a report on suspected harassment, followed by a thorough investigation, including interviews with the persons concerned and the person to whom the report was made, to determine the facts. The company has also established 'Harassment Prevention Regulations' in its employment regulations. However, the information on progress in preventing discrimination is not reported.

155. Percentage or number of temporary employees?

2467 (6.47%) - The company reports on employment as a part of its ESG data disclosure. Data as of March 2022.

156. Percentage or number of women employees?

18.66% - The company reports on employment as part of its ESG data disclosure. Data as of March 2022.

157. Commitment to pay a living wage?

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

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

159. Progress on commitment to pay a living wage?

160. Reporting of salary by gender?

161. 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 its own 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.

162. 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.

163. Provision of personal protective equipment and related training?

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 percentage of company landbank certified by PEFC is unclear. The company's own reporting only covers information on providing safety and health education for workers in charge of dangerous or harmful work including dangerous chemicals in its operations in Japan.

164. Time lost due to work-based injuries?

0.97 - Lost time injury frequency rate in 2021.

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

0 - The company reports no fatalities in 2021.

166. Commitment to support smallholders?

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

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

169. 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'.

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

[Externally verified] 682 - Traceability information for four units of the company (covering 861 suppliers) is available for 2021, however, it is unclear if this covers all operations of the company. This report is externally verified by SGS. Additionally, the company's own reporting only mentions conducting sustainability surveys for main suppliers which covered 682 suppliers in 2021.

171. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not fully meet the SPOTT scoring criteria. The company's own reporting mentions engaging in dialogue with suppliers and requesting improvements if the source or forest management status of the purchased wood is unknown or the wood does not conform to the procurement guidelines and states that it will not source from suppliers who do not make improvements as per their wood procurement guidelines. However, the timeframe for actions is not provided.

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

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

The company reports that in FY2021, it procured 4,429 kBDT (bone dry tons) of woodchips in Japan and overseas and 162 kADT (air dry tons) of market pulp, and obtained traceability reports from all the suppliers and confirmed with a third-party organization that the procurement was in accordance with the Wood Raw Material Procurement Guidelines. However, the traceability reports available do not confirm this data on volume and only cover four units of the company.

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and prohibition of corruption.

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

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

The company reports its 'Corporate Compliance Department' ensures that employees and external parties are informed about the company's anti-corruption initiatives. The company also provides training in regions where there is a possibility that bribery may occur and states that in FY2021, there were no employee terminations resulting from violations of the anti-corruption policy and no penalty charges, surcharges, or settlement money related to corruption. However, the information reported is not externally verified.

177. 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.

178. Disclosure of the company's management approach to tax and payments to governments?

179. 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.

180. Whistleblowing procedure?

The company has a whistleblowing procedure in place including a flowchart on steps taken by the company, including how whistleblowers can report unethical conduct and how they are protected.

181. 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 and PEFC CoC certification.

182. Details of complaints and grievances disclosed?