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?

Dr. Christopher Stewart, Global Head of CR&S; Julie Greene, Chief Sustainability Officer (CSO); and, Gerard Manley, CSO are the heads of the company's Corporate Responsibility and Sustainability Committee (CRSC).

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

Mr. Nihal Vijaya Devadas Kaviratne CBE 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, TFA, 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 Djéké Triangle, a 9,500 hectares forest area in the company's concession which was integrated into the Nouabalé-Ndoki National Park through a collaboration with the Congolese government and the Wildlife Conservation Society (WCS). The company also reports collaboration with Nature+, a non-profit organisation focused on sustainable management of African forest ecosystems. The company is also developing the regional standard for PEFC in the Congo Basin.

9. Sustainability report published within last two years?

The company has published an integrated annual report covering the year 2023. The company has also published a separate sustainability information document for 2023.

10. Reports through standardised reporting systems?

The company has submitted CDP questionnaires for forests, climate change, and water security in 2023.

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)?

1829520 - The company operates 1,829,525 ha of land for forestry across its four FMUs, however, this information is spread out in different places and therefore complicated to calculate.

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

1395830 - The company operates 1,395,826 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 spread out in different places and therefore complicated to calculate.

21. Area of Intact Forest Landscape (ha)?

402107 - The company does not report information on the area of Intact Forest Landscape, however, external sources suggest that the company has at least 402,107 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)?

Maps for Pokola, Loundoungou-Toukoulaka, Kabo, and Mimbeli- Ibenga concessions are published by the company. The concession maps are also available on the OTP and Forest Atlas database.

24. Forest management plans available for all FMUs?

Forest management plans are available for all of the company's FMUs.

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 15/19 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 4/8 of 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.

31. Names and locations of company owned sawmills?

The company provides maps for all its sawmills located in two different locations.

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.

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 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 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 mills.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified.

40. Percentage of supply traceable to country of harvest?

100 - The company makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified.

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 that all supply in 2023 was FSC CoC certified.

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

100% - All supply in 2023 was FSC COC certified.

47. Percentage area (ha) FSC FM certified?

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

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 is 100% FSC FM certified.

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 makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified. The company also commits all suppliers to no deforestation.

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 in supplier operations?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Partial points have been awarded for this indicator as 100% of the company's Timber & Pulp supply is FSC CoC certified but the certification requirements do not fully meet the SPOTT indicator criteria. The company's own reporting for suppliers mentions 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 is not reported.

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

The company reports that remote sensing monitoring has been carried out since 2016 on 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?

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

The company reports that no loss of tree cover due to illegal activities was observed in 2022 in its operations. However, the amount of deforestation recorded since the cut-off date 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 playing a vital role in RoC's Emission Reductions Programme under the Forest Carbon Partnership Facility (FCPF), under which it works in partnership with the government to implement RoC's National REDD+2 Strategy. However, own 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. Additional points have been awarded according to the percentage of company landbank certified by FSC. In March 2023, the company announced a major conservation milestone - Djéké Triangle, a 9,500 hectares 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. Additional points have been awarded according to the percent of company landbank certified by FSC. 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. It has successfully removed 4,500 metal traps and released 86 seized animals alive, 'fortifying the preservation of Congo's wildlife and biodiversity'.

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 makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified. The company also commits all suppliers to not using wood derived from GMOs.

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 makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified. The company also commits suppliers to conduct High Conservation Value (HCV) assessments in its own reporting.

78. High Conservation Value (HCV) assessments available?

The HCV assessments of all company concessions 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 three of the company's 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.

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?

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 GHG emissions by 50% both in its operations and company-managed farmer programs by 2030. However, the commitment does not explicitly include Scope 1 and Scope 2 emissions.

104. GHG emissions intensity?

The company reports emissions intensity for Scope 1 and 2 in relation to its processing operations, it has maintained its year-on-year GHG efficiency at 0.13 MT CO2e/MT of product in 2023. 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 emissions intensity (Scope 1 and 2) for its own processing operations as 0.12 in 2021 and 0.13 MT CO2 e/MT of product in 2022 and 2023. The intensity has not improved since 2021 and it is also unclear if this information is specific to the company's forestry operations.

108. Methodology used to calculate GHG emissions?

The company reports using the GHG Protocol Corporate Accounting 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 OR only trades wood/wood fibre.

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 own commitment to protecting 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?

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 own 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 own 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.

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 a signatory to the UN Global Compact.

131. Commitment to human rights applies to all suppliers?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified. 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 ?

The company reports it carries out due diligence by assessing human rights risk at the country and industry sector level across eight different themes, using a methodology developed by Wageningen University's Research (WUR). The company also reports information on the number of employees who received training on human rights in 2023. 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 makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified. The company's reporting for suppliers only mentions a commitment to respect local communities and Indigenous rights in relation to land tenure.

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 respect 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 also reports organising meetings each year with local communities and Indigenous peoples (IP). Its social team has several IP communicators who act as relays for the aspirations and complaints of their community. However, own reporting is not externally verified.

141. Details of process for addressing land conflicts available?

The company has published a procedure for handling complaints, including conflicts related to the implementation of management plans, divergences in the interpretation of legal texts, crimes against the agricultural or commercial activities of a resident of the concessions, environmental degradation, permanent nuisances or disruptions related to the work carried out by the company, and compensatory measures deemed inadequate by stakeholders.

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

[Externally verified] The company launched Project MaC - 'Menagere a Constructive' or 'Home Maker to Home Builder' in 2021 which allows women in the north of the Republic of Congo to develop skills for constructing wooden houses, enabling them to secure roles with the company. This information is externally verified by International Women's Day, however, it's over two years old now. The company also reports multiple other examples of supporting women, however, these examples are 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 8/10 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 own 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 1/7 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 makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified. The company's commitment for suppliers only covers five+ 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 it has integrated human and labour rights due diligence processes and procedures throughout its operations and supply chains and mentions that its employees received training on labour rights in 2023.

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 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 17,031 employees received training on sexual harassment in 2023.

155. Percentage or number of temporary employees?

53815 (58%) - The company reports 58% of seasonal, casual, temporary, and contract employees. Data as of 2023.

156. Reports gender balance of employees?

24444 (26%) - The company reports 26% of women as a part of its primary and secondary workforce (contract, seasonal, and, temporary roles as well as casual day workers) in 2023.

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.

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 own reporting 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 makes this commitment through the FSC Principles and Criteria (FSC-STD-40-004 V3-1). Partial points have been awarded for this indicator as 100% of the company's wood/wood fibre supply is FSC certified but the certification requirements do not fully meet the SPOTT indicator criteria. The company also 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?

Limited, externally verified points have been awarded on the basis of the company's FSC Chain of Custody (FSC-STD-40-004 V3-1) and FSC FM (FSC-STD-01-001 V5-2) certifications as the requirements do not fully meet the SPOTT indicator criteria.

164. Time lost due to work-based injuries?

0.21 - The company reports the Lost Time Injury Frequency rate (LTIFR) for the whole group as 0.21 in 2023.

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

16 - The company reported 16 fatalities in 2023 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 does not source from smallholder suppliers.

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded for this indicator as 100% of the company's wood/woodfibre supply is FSC COC certified.

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 the Ethical Business Programme (EBP) and Legal Compliance Team. Throughout 2023, the company had one confirmed case of corruption and states that there were no confirmed incidents of employees being dismissed for corruption, and there were no public legal cases regarding corruption brought against the company or its employees. 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 10/14 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, and issues. The grievances reported are for the company's forestry concessions.