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 the sustainability commitments of the company for 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 Corporate Responsibility and Sustainability Committee (CRSC).

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

6. Percentage or number of women board members?

1 - The company reports one female member within its board of directors. Gender balance is not directly reported by the company, but is calculated from staff profiles/photos.

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 which include the renewal of its partnership agreement with the Ministry of Forest Economy (MEF) and the Wildlife Conservation Society (WCS) to protect the wildlife around the Nouabal?-Ndoki National Park in northern Congo and the collaborative project 'Access to Medical Clinic for Indigenous Communities' in partnership with C.F. Martin & Co since 2019. The company is also involved in 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 2022.

10. Reports through standardised reporting systems?

The company has submitted CDP questionnaires for forests, climate change, and water security in 2022.

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.

13. Lists countries and operations?

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

14. Lists countries sourcing from?

The company sources 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 land 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 produces wood/wood fibre from natural forests.

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

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

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

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

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

429331 - The company owns 429,331 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)?

475618 - The company does not report information on the area of Intact Forest Landscape, however, external sources suggest that the company has at least 475,618 ha of IFL. It is unclear if this information covers all operations of the company.

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.

24. Forest management plans available for all FMUs?

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

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

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 9 out of the 9 total legal documents required by Open Timber Portal on use right. 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 out of the 19 total legal documents required by 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 out of the 11 total legal documents required by 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. Names and locations of all third-party supplying FMUs?

30. Number of company owned sawmills?

5 - The company reports that it owns 5 sawmills, in 3 different sites.

31. Names and locations of company owned sawmills?

The company provides maps for the 3 locations of its 5 sawmills.

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

This indicator is disabled as the company reports that it does not own 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 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 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 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 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 supplying 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?

[Externally verified] 100% - The company's concessions are 100% FSC FM certified.

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

The company only sources wood that is FSC CoC certified.

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

100% of supply comes from CoC certified suppliers.

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)?

52. Commitment to zero conversion of natural ecosystems?

The company reports commitment to no conversion of only certain ecosystems. A clear commitment to no conversion of all natural ecosystems is not reported by the company.

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 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its own commitment to no deforestation.

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.

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

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

The company's own reporting for suppliers only mentions prohibiting deforestation of legally Protected Areas, critical habitats (as defined by the International Finance Corporation Performance Standards), nationally-recognized 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 it does regular checks and monitoring by remote sensing in all its concessions since 2016 by the GFW 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 2021 in its operations, however, the company has not reported a cut-off date.

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

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

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, a clear policy with a time-bound target on protecting biodiversity is not reported by the company.

66. Biodiversity policy applies to all suppliers?

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. This applies to all suppliers, however, a clear policy with a time-bound target on protecting biodiversity is not reported by the company.

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 not been awarded as the percentage of area certified by FSC cannot be calculated due to approximate figures reported by the company on its total landbank. The company's own reporting mentions working on the Goualougo Triangle Ape Project with the Wildlife Conservation Society (WCS) and the government that focuses on three of the major factors believed most important in influencing the long-term sustainability of their habitat: applied conservation research, responsible forest management, and capacity building.

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

The company reports an unclear commitment that mentions 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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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

The company commits its suppliers to unacceptable land use practices which include illegal activities, and respecting legally protected areas, or internationally recognised areas.

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 not been awarded as the percentage of area certified by FSC cannot be calculated due to approximate figures reported by the company on its total landbank. The company also reports information on its collaboration with the Wildlife Conservation Society (WCS) and the Ministry of Forest Economy (MEF) to protect the rich biodiversity of the adjacent Nouabale Ndoki National Park, with the partnership recording 2,399 eco-patrol days in 2022, intercepting illegal snares and trade in ivory, pangolins, parrots, and more, and conducting anti-poaching awareness-raising activities in local communities.

74. Commitment to no use of genetically modified organisms?

This indicator is disabled as the company reports that it only produces 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 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its own commitment to 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.

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?

Management and monitoring information is available for all of the company's concessions, 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 produces wood/wood fibre from natural forests.

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 reports that it only produces wood/wood fibre from natural forests.

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 reports that it only produces wood/wood fibre from natural forests.

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

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 concessions are available on the 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 8 out of the 11 total legal documents required by 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 produces wood/wood fibre from natural forests.

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's living landscape policy commits its suppliers to conserve forests and other natural habitats with high levels of biomass or organic carbon, but a clear commitment regarding best management practices on soils that applies to suppliers is not reported by the company.

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 not been awarded as the percentage of area certified by FSC cannot be calculated due to approximate figures reported by the company on its total landbank.

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

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 not been awarded as the percentage of area certified by FSC cannot be calculated due to approximate figures reported by the company on its total landbank. The company also reports evidence of implementing reduced impact logging practices.

98. Commitment to zero burning?

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

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/or Scope 2 emissions.

104. GHG emissions intensity?

The company reports GHG emission intensity as 0.13 MT CO2 e/MT of product in 2022. However, it is unclear if this 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 produces wood/wood fibre from plantations.

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. The intensity has increased in 2021 and it is also unclear if this information is specific to the forestry operations of the company.

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 pulp or paper mills.

110. Water use intensity?

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

111. Progress towards commitment on water use intensity?

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

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

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

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

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

114. Treatment of pulp and paper mill effluent?

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

117. Commitment to protect natural waterways through buffer zones?

The company commits 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 not been awarded as the percentage of area certified by FSC cannot be calculated due to approximate figures reported by the company on its total landbank.

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

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 pesticides only.

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

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

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

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

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 not been awarded as the percentage of area certified by FSC cannot be calculated due to approximate figures reported by the company on its total landbank.

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 not been awarded as the percentage of area certified by FSC cannot be calculated due to approximate figures reported by the company on its total landbank.

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 V2-0). 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.

132. Progress on human rights commitment ?

The company provides multiple pieces of evidence on actions taken to implement its human rights policies which include giving training to employees on its human rights policies as well conducting human rights assessments. However, the information reported is not externally verified.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company's own reporting only mentions a commitment to indigenous and local communities rights, without reference to the UN Declaration/ILO Convention.

134. Commitment to indigenous 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.

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) and PEFC International Standard (PEFC ST 1003:2018). Full points have therefore been awarded on the basis of the company's FSC and PEFC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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 reports commitment to free, prior, and informed consent (FPIC).

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

The company commits its 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 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 has also published a procedure for handling complaints against the company, however, it is not externally verified.

141. Details of process for addressing land conflicts available?

The company has published a procedure for handling complaints against the company which includes 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.

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 6 out of the 12 total legal documents required by 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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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

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 not been awarded as the percentage of area certified by FSC cannot be calculated due to approximate figures reported by the company on its total landbank.

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

The company reports a commitment to providing business/work 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 5 out of the 7 total legal documents required by 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 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its own commitment to all Fundamental ILO Conventions; referring to ILO number and to the same language as the title.

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.

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 not been awarded as the percentage of area certified by FSC cannot be calculated due to approximate figures reported by the company on its total landbank. The company also reports multiple pieces of evidence for progress on the commitment to respect all workers' rights, which include providing training on workers' rights, assessment by the internal audit team, following a risk-based approach to the implementation of its policies in own operations.

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

The company reports 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] The company only reports information on its progress in its commitment to eliminating gender-related discrimination, which includes raising awareness on preventing discrimination and harassment in the workplace. Since June 2021, the company has rolled out a compliance course in a phased manner to create an understanding of acceptable and unacceptable behaviours in an inclusive workplace and the potential reputational and leadership risks. However, limited details are provided. 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.

155. Percentage or number of temporary employees?

51151 (58%) - The company reports 58% of seasonal, casual, temporary, and contract employees. Data as of 2022.

156. Percentage or number of women employees?

30229 (34%) - The company reports 34% of women as a part of its primary and secondary workforce (contract, seasonal, and, temporary roles as well as casual day workers) in 2022.

157. Commitment to pay a living wage?

The company only reports commitment to paying minimum wage.

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

The company commits its suppliers to pay their employees wages not lower than the minimum wage established by the law or by a competent authority for this type of work in the locality, whichever is higher.

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

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?

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?

0.39 - The company reports the Lost Time Injury Frequency rate (LTIFR) for the whole group (Tier 1, 2, 3, and 4) as 0.39 in its ESG report and 0.41 in its annual report for 2022. Contradictory information is reported in the same reporting period.

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

15 - The company reports 15 fatalities in 2022 across all its operations.

166. Commitment to support smallholders?

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

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

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

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

Limited details are provided and they do not cover all three key elements of a due diligence system.

170. Number or percentage of 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 the suspension criteria, however, timeframes for action or steps taken are not provided.

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 certified.

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

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and prohibition of corruption.

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

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

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

The company reports it has an Ethical Business Programme (EBP) which includes policies relating to Bribery and Corruption. All employees are required to undergo online training to familiarise themselves with the ABC Policy and the completion of the training is tracked and monitored by the Head of Ethics and Compliance. In 2022, all employees within the group completed the anti-bribery and corruption training. 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 3 out of the 4 total legal documents required by 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.

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 1 out of the 15 total legal documents required by 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 including a flowchart of steps taken by the company, including how whistleblowers can report unethical conduct and how they are protected.

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

The company provides information on its grievance or complaint 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.