Olam International

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

The company has a 'Declaration of Commitment' and 'Living Landscapes Policy' which covers the sustainability commitments of the company across its timber operations.

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

The company has a supplier code in place which covers all suppliers.

3. High-level position of responsibility for sustainability?

Chief Sustainability Officer: Roel Van Poppel, and Global Head of Sustainability Impact: Dr Christopher Stewart.

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

Mr. Ajai Puri is the chair of the company's Sustainability Committee.

5. Reports gender balance of senior management team?

6. Reports gender balance of board members?

1 - The company reports 10 members as a part of its board, of which one member is a female. Data as of 2023.

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] The company is a member of FSC, PEFC, UNGC, ATIBT, STTC, HCVRN, Capitals Coalition and CBFP.

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

The company reports multiple collaborations with stakeholders, some of which include collaborating with Nature+, Gembloux Agro-Bio Tech, the University of Liège, and Cornell University for wildlife management where acoustic sensors, environmental DNA analysis, and camera traps monitor wildlife activity and habitat use across the company concessions, informing operational strategy adjustments to minimise environmental impact, partnering with the Wildlife Conservation Society (WCS) and the Ministry of Forest Economy (MEF) of the Republic of Congo to protect wildlife around NouabaléNdoki National Park.

9. Sustainability report published within last two years?

The company has published an integrated annual report covering the year 2024. The company has also published a separate sustainability information document for 2024.

10. Reports through standardised reporting systems?

The company has submitted CDP questionnaires for forests, climate change, and water security in 2023. Additionally, the company's latest annual report is prepared in accordance with the GRI 1: Foundation 2021 requirements.

11. Climate risks assessment available?

The company has disclosed a summary of the risks and opportunities for the company as per the TCFD. However, the information reported is not externally verified.

12. Natural capital assessment available?

The company identifies and quantifies some of its natural capital dependencies in its 2022 annual report. However, the company has not quantified the value of these dependencies and set out how it will act upon and apply the results of the assessment.

13. Lists countries and operations?

Republic of Congo (forest concessions and production facilities under CIB).

14. Lists countries sourcing from?

Gabon.

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

2100000 - The company reports it operates 2.1 million hectares (ha) of natural forest concessions in the Republic of Congo. Approximate figures are reported by the company.

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

1354400 - The company operates 1,354,400 ha of production area for forestry across its four FMUs, however, this information is spread out in different places and therefore, complicated to calculate.

17. Total area of forest plantation (ha)?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

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

This indicator is disabled as the company reports that it is not a producer with scheme smallholders/outgrowers.

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

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

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

433699 - The company owns 433,699 ha of conservation set-asides, including HCV areas, across its four FMUs. However, this information is from 2018 and is over five years old now.

21. Area of Intact Forest Landscape (ha)?

377922 - The company does not report information on the area of Intact Forest Landscape, however, external sources suggest that the company has at least 3,77,922 ha of IFL. It is unclear if this information covers the company's entire operations.

22. Number of Forest Management Units (FMUs)?

4 - The company reports it has four FMUs, all in the Republic of Congo: Pokola, Loundoungou-Toukoulaka, Kabo, and Mimbeli- Ibenga. It also controls Pikounda concession in RoC, but this is set aside as part of a REDD+ project.

23. Maps of forest management units (FMUs)?

The company publishes maps for the Pokola, Loundoungou-Toukoulaka, Kabo, and Mimbeli-Ibenga concessions. The concession maps are also available on the OTP, GFW, and Forest Atlas databases.

24. Forest management plans available for all FMUs?

The forest management plans for all FMUs of the company are available on the company website and the OTP database.

25. Monitoring of forest management plan implementation available?

[Externally verified] The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (100%).

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

[Externally verified] The company has provided all valid legal documents to Open Timber Portal on use right for all of its concessions. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

[Externally verified] The company has provided 18/20 valid legal documents to Open Timber Portal on forest management. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

[Externally verified] The company has provided 5/26 valid legal documents to the Open Timber Portal on timber harvesting. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

29. Maps of all third-party supplying FMUs?

30. Number of company owned sawmills?

5 - The company reports that it owns five sawmills. However, the information reported is from June 2023 and is over two years old now.

31. Names and locations of company owned sawmills?

The company provides maps for five sawmills located in two different locations. In its latest annual report, the company also mentions the expansion of saw milling operations in the Republic of Congo, however, no clear information on the updated number of total sawmills or their geo-referenced maps is reported.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

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

The company's sawmills source entirely from its own concessions. However, the information reported is from June 2023 and is over 2 years old now.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

36. Number of third party supplying mills?

This indicator is disabled as the company reports that it does not source from third-party supplying mills.

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

This indicator is disabled as the company reports that it does not source from 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?

This indicator is disabled as the company reports that it does not source from third-party supplying mills.

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

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 full meet the SPOTT scoring criteria.

40. Percentage of supply traceable to country of harvest?

The company states that 100% of its supply is FSC COC certified, however, this information is from June 2023 and is over two years old now.

41. Procedures to trace raw materials to FMU level?

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 full meet the SPOTT scoring criteria.

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 is 100% FSC FM certified since 2020.

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

100% - 1,922,055 ha is verified as being legally compliant with the FSC FM certification standard.

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

The company reports it is committed to purchasing exclusively FSC® certified materials from third-party sources.

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

The company reports that all its supply in 2023 was FSC COC certified. However, the information reported is from June 2023 and is over two years old now.

47. Percentage area (ha) FSC FM certified?

100% - The company's concessions are 100% FSC FM-certified as of 2024.

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

The company's concessions are already 100% FSC FM certified since 2020.

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)?

This indicator is disabled as the company reports that it does not produce wood/wood fibre OR does not operate in a country with a PEFC-endorsed SFM standard.

52. Commitment to zero conversion of natural ecosystems?

The company only commits to no conversion of specific ecosystems.

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

The company commits all suppliers to zero conversion of all natural ecosystems.

54. Commitment to zero deforestation?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

55. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to no development in High Conservation Value (HCV), High Carbon Stock (HCS) and peatland areas.

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

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 (100%).

57. Criteria and cut-off date for defining deforestation and/or ecosystem conversion in supplier operations?

The company defines deforestation for suppliers as prohibiting deforestation of legally Protected Areas, critical habitats (as defined by the International Finance Corporation Performance Standards), nationally recognised conservation priorities, or other high conservation value' areas. However, a cut-off date beyond which deforestation will not be accepted in supplier operations is not reported.

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

The company reports that remote sensing monitoring has been carried out regularly since 2016 in all its concessions by the Global Forest Watch GLAD alert system. However, the information reported is not externally verified.

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

The company reports it performs deforestation risk assessments using google earth and global forest watch, however only limited details are provided.

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

0 (0%) - The company reports that no loss of tree cover due to illegal activities was observed in 2023 in its operations. However, a cut-off date beyond which deforestation will not be accepted is not reported.

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?

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's FSC FM certification (FSC-STD-01-001 V5-2 EN). As the Standard does not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded. The company reports information on its participation in DYNAFAC, a collective of organisations that monitor forest dynamics and work to improve forest management plans, further strengthening sustainable forest management. However, the reporting is limited and not externally verified.

65. Biodiversity policy?

The company only reports that it adopts a landscape-level and ecosystem approach, aiming to achieve a positive impact on biodiversity conservation and ecosystem services such as water regulation, soil health, and erosion control, which is implemented through internationally recognised tools and guidance. This includes supporting and promoting the high conservation value (HCV) concept and encouraging the use of Critical Habitat and Natural Habitat. However, this does not constitute a biodiversity policy and does not include a specific time-bound target on protecting biodiversity.

66. Biodiversity policy applies to all suppliers?

The company only reports that it adopts a landscape-level and ecosystem approach, aiming to positively impact biodiversity conservation and ecosystem services such as water regulation, soil health, and erosion control, which is implemented through internationally recognised tools and guidance. This includes supporting and promoting the high conservation value (HCV) concept and encouraging the use of Critical Habitat and Natural Habitat. However, this does not constitute a biodiversity policy and does not include a specific time-bound target on protecting biodiversity.

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 certification (FSC-STD-01-001 V5-2) 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 and CITES system of species classification. However, own reporting 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 certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. In March 2023, the company announced a major conservation milestone - Djéké Triangle, a 9,500-hectare forest area in its concession, was integrated into the Nouabalé-Ndoki National Park through collaborative efforts with the Congolese government and the Wildlife Conservation Society (WCS).

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (100%). The company's reporting mentions an unclear commitment to tackling poaching and protecting endangered animals with the help of eco guards.

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 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 (100%). The company also reports its own commitment to protect forest areas from illegal activities.

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

The company commits suppliers to protect the natural ecosystems and plantations under their management from illegal activities.

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 certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. The company's partnership with the Wildlife Conservation Society (WCS) and the Congolese government supports the employment of eco-guards, community liaisons and technicians to prevent illegal logging and poaching of animals, and it has been involved in identifying and expanding 'crucial' forest areas for protection.

74. Commitment to no use of genetically modified organisms?

This indicator is disabled as the company reports that it only sources wood/wood fibre from natural forests.

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 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its commitment to conducting High Conservation Value (HCV) assessments.

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

The company commits all suppliers to conduct HCV assessments.

78. High Conservation Value (HCV) assessments available?

The HCV assessments for all concessions of the company are available, however, these assessments are not externally verified.

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

The HCV assessments of all company concessions are available which cover management and monitoring information, however, these assessments are not externally verified.

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

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

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

The company commits all suppliers to apply the HCS Approach, as defined by the HCS Approach Toolkit.

82. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company does not produce wood/wood fibre OR only has natural forest operations OR has not undertaken any new planting since January 2015.

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

This indicator is disabled as the company does not produce wood/wood fibre OR only has natural forest operations OR has not undertaken any new planting since April 2015 OR if all new planting has been undertaken since November 2017 and has been covered under combined HCV-HCS assessments.

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

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 (100%). The company also reports its own commitment to conduct social and environmental impact assessments (SEIAs).

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

The company commits all suppliers to conduct social and environmental impact assessments.

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

[Externally verified] The SEIAs for all company concessions are available on OTP.

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

[Externally verified] The company has provided all valid legal documents to Open Timber Portal on impact assessments. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

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

The company commits its suppliers to 'no conversion or degradation of peatlands of any depth'.

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?

The company commits to best management practices for soils and peat.

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

The company commits all suppliers to best management practices for peat only.

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 percent of company landbank certified by FSC.

95. Commitment to reduced impact logging?

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 (100%). The company also reports its own commitment to reduced impact logging.

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

97. Evidence of implementing reduced impact logging practices?

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. The company's reporting mentions implementing reduced impact logging practices, which includes planning of skidding trails, reducing the impact of logging on the forest as a whole.

98. Commitment to zero burning?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

99. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

100. Evidence of fire monitoring and management?

[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.

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 is committed to reducing its GHG emissions from baseline year 2022 which includes reducing energy and industry emissions (Scope 1, 2 and 3 GHG emissions) by 42% by 2030 and reducing forest, land and agriculture (FLAG) emissions (Scope 1 and 3 GHG emissions) by 30.3% by 2030.

104. GHG emissions intensity?

The company reports GHG emissions intensity for Scope 1 and 2 in relation to its processing operations and states that it has improved its year-on-year GHG efficiency by 17% from 0.13 tCO2e/ MT in FY23 to 0.11 tCO2e/ MT in FY24. However, it is unclear if this information is specific to the company's forestry operations.

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

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

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

107. Progress towards commitment to reduce GHG emissions intensity?

The company reports GHG emission intensity (Scope 1 and 2) for its own processing operations and states that it has improved its year-on-year GHG efficiency by 17%, from 0.13 tCO2e/ MT in FY23 to 0.11 tCO2e/ MT in FY24. However, it is unclear if this information is specific to the company's forestry operations.

108. Methodology used to calculate GHG emissions?

The company reports using the Greenhouse Gas Protocol Standard to calculate GHG emissions.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

110. Water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

111. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

114. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

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

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

117. Commitment to protect natural waterways through buffer zones?

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 (100%). The company also reports its commitment to protecting natural waterways through buffer zones.

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

[Externally verified] 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?

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 (100%). The company's reporting only mentions a commitment to minimise the use of chemicals.

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

The company commits all suppliers to minimise the use of chemical fertilisers and pesticides.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

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 (100%). The company also reports its 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?

The company commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

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 (100%).

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

The company commits all suppliers to not use Stockholm and Rotterdam Convention chemicals.

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 percent 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 certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. The company's reporting states that it aims to reduce the amount of waste produced, along with increasing reuse, recycling and resource efficiency. To reduce waste output, the company re-uses biomass waste as fuel at its processing facilities across global operational sites which includes wood. Information is limited and not externally verified.

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company is also a signatory to the UN Global Compact.

131. Commitment to human rights applies to all suppliers?

The company's commitment for suppliers to respect human rights does not reference the Universal Declaration of Human Rights or its equivalent.

132. Progress on human rights commitment ?

In 2021, the company commissioned Wageningen University & Research to conduct a human rights risk assessment across its supply chains, focusing on eight human rights principles. In 2024, these risk scores were updated in collaboration with WUR and other partners to create a unified risk understanding for various companies across different country commodities. Additionally, in 2024, as a result of audits and inspections, the company identified five human rights-related cases. However, the information reported is not externally verified.

133. Commitment to respect Indigenous Peoples' and local communities' rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company's reporting only mentions a commitment to indigenous and local communities' rights without referencing the UN Declaration/ILO Convention.

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

The company only commits suppliers to respect local communities and indigenous rights in relation to land tenure. The commitment does not reference the UN Declaration/ILO convention.

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

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 (100%). The company also reports its commitment to respecting legal and customary land tenure rights.

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

The company commits all suppliers to respect legal and customary land tenure rights.

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

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 (100%). The company also reports its own commitment to free, prior and informed consent (FPIC).

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

The company commits all suppliers to free, prior and informed consent (FPIC).

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

The company has published a guidance document on FPIC that details the company's FPIC process.

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. The company's reporting states that it engages regularly with communities to implement social contracts for their benefit and address any grievances. It also reports organising meetings each year with local communities and Indigenous peoples (IP), and its social team has several IP communicators who act as relays for the aspirations and complaints of their community. However, the reporting is not externally verified.

141. Details of process for addressing land conflicts available?

The company has published a procedure for handling land complaints within its grievance procedure, however it does not publish a separate land conflicts policy.

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

The company reports multiple examples of supporting women, some of which include the launching of Crown Flour Angels (CFA) Baking Academy in Abuja, a development programme designed to empower women with practical baking skills, and establishing "Home Maker to Home Builder" initiative to improve the economic prospects of rural women in Congo. Evidence is not externally verified.

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

[Externally verified] The company has provided 5/12 valid legal documents to Open Timber Portal on population rights. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

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 (100%).

145. 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 (100%). The company also reports its commitment to providing essential community services and facilities.

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 percent of company landbank certified by FSC.

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

The company reports a commitment to providing employment opportunities for local communities where it operates.

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

[Externally verified] The company has provided all valid legal documents to Open Timber Portal on labour regulations. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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

The company only commits suppliers to some ILO conventions.

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 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. The company's reporting states that labour risks are assessed as a part of the company's human and labour rights due diligence process.

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

The company reports a commitment to eliminate gender related discrimination with regards to employment.

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

The company commits its suppliers to eliminate gender-related discrimination with regard to employment.

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

[Externally verified] Limited, externally verified points have been awarded on the basis that the company's landbank is 100% FSC FM certified (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

155. Percentage or number of temporary employees?

52019 (57%) - The company reports 57% of seasonal, casual, temporary, and contract employees. Data as of 2024.

156. Reports gender balance of employees?

10939 (28%) - The company reports 28% of women as a part of its primary and secondary workforce in 2024.

157. Commitment to pay a living wage?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (100%). The company's own commitment only mentions paying minimum wage.

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

The company only commits its suppliers to pay their employees at least the minimum wage.

159. Progress on commitment to pay a living wage?

[Externally verified] Limited, externally verified points have been awarded on the basis the company's landbank is either 100% or 75% (and a further commitment to be 100% certified within 5 years) FSC FM certified (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. The company's reporting only states that following its living wage gap baselining activity, in partnership with Social Accountability International and the Anker Research Institute, the company continues to progress its internal roadmap to help close these gaps.

160. Reporting of salary by gender?

161. Commitment to address occupational health and safety?

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 (100%). The company's commitment to addressing occupational health and safety 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 FSC FM certification (FSC-STD-01-001 V5-2 and FSC-STD-60-004) 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 also provides evidence of PPE use and states that colleagues are provided with the correct PPE in relation to their job and are trained on how to use it.

164. Time lost due to work-based injuries?

0.19 - The company reports the Lost Time Injury Frequency rate (LTIFR) for the whole group as 0.19 in 2024.

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

10 - The company reported 10 fatalities in 2024 across all its operations.

166. Commitment to support smallholders?

This indicator is disabled as the company reports that it does not have smallholder suppliers.

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

This indicator is disabled as the company reports that it does not have smallholder suppliers.

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

This indicator is disabled as the company reports that it does not have smallholder suppliers.

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

The company has described the process through which it will assess its suppliers on compliance with its policies and mentions establishing a time-bound plan with its suppliers to address the issue and where necessary remediate material negative impacts of non-compliance.

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

171. 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 full meet the SPOTT scoring criteria. The company's own reporting mentions establishing a time-bound plan with its suppliers to address the issue and where necessary remediate material negative impacts of non-compliance and states that it will disengage from suppliers who are unable to demonstrate positive steps to eliminate unacceptable practices in a time-bound manner. However, no timeframe for actions is reported.

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

173. Proportion of supply from suppliers that is verified as deforestation and/or conversion-free (DCF)?

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and the prohibition of corruption.

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

The company commits all suppliers to ethical conduct and prohibition of corruption.

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

The company states that all employees are routinely required to undergo annual online training to familiarise themselves with the Anti-Bribery and Corruption Policy. The completion of training is tracked and monitored by relevant ethical business and legal compliance teams. Throughout 2024, the company had one confirmed case of corruption and stated that there were zero confirmed incidents of employees being dismissed for 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)?

[Externally verified] The company has provided all valid legal documents to Open Timber Portal on legal registration. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

The company states that the Global Head for Tax, as part of the audit committee, is responsible for the company's tax strategy. However, the company has not published information on its tax strategy or policy.

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

[Externally verified] The company has provided 11/14 valid legal documents to Open Timber Portal on taxes, fees and royalties. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

180. Whistleblowing procedure?

The company has a whistleblowing procedure which includes a flowchart of steps taken by the company and states how whistleblowers can report unethical conduct and how they are protected.

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

The company provides information on its grievance system which is open to all stakeholders.

182. Details of complaints and grievances disclosed?

The company has provided a grievance monitoring log that details the date, status, action taken and issues. The grievances reported are for the company's forestry concessions.