Precious Woods Holding AG

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

The company reports its commitment to all aspects of sustainability on its website and in its sustainability report. These commitments cover multiple dimensions of sustainability across the company's operations covering both social and environmental issues.

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

The company's commitment to all aspects of sustainability applies to all its direct and third-party suppliers.

3. High-level position of responsibility for sustainability?

Chief Executive Officer.

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

The company reports that the responsibility for all questions of sustainability is with the Board of Directors of the company.

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

0 - Data as of 2019.

6. Percentage or number of women board members?

1 - Data as of 2019.

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] FSC, CBFP, ATIBT, STTC.

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

The company states it works with multiple stakeholders, this includes working with universities (University of Science and Technology of Masuku (USTM), the Federal University of Amazonas (UFAM), Gembloux Agro-Bio Tech (ULiège), Nature+, and the Bern University of Applied Sciences (BFH-HAFL)) for researching new solutions in improving sustainable forest management, partnering with conservation justice against illegal hunting in the buffer zones of the company concessions.

9. Sustainability report published within last two years?

Sustainability report for 2019 is published on the company website.

10. Reports through standardised reporting systems?

The company has submitted CDP forest questionnaires for the years 2017, 2018, 2019 and 2020.

11. Climate risks assessment available?

The company has conducted and published an assessment of climate-related risks, however the assessment is not externally verified.

12. Natural capital assessment available?

13. Lists countries and operations?

Brazil (forest concessions, sawmill, production facilities), Gabon (forest concessions, sawmills, veneer plant).

14. Lists countries sourcing from?

The company reports sourcing from its own concessions in Brazil and Gabon. Traded timber products come exclusively from France and Belgium.

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

1,103,520 - Brazil- 506,697 ha, Gabon- 596,824 ha.

16. Total area of forest plantation (ha)?

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

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

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

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

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

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

93,093 - Gabon- 37,488 ha and Amazon- 55,605 ha.

20. Area of Intact Forest Landscape (ha)?

242,376 - Figure reported in 2020.

21. Number of Forest Management Units (FMUs)?

4 - The company has 3 FMUs in Gabon and 1 FMU in Brazil.

22. Maps of forest management units (FMUs)?

The maps of all FMUs are available in the forest management plans of MIL and CEB.

23. Forest management plans available for all FMUs?

The forest management plans are available for all FMUs of the company.

24. Monitoring of forest management plan implementation available?

[Externally verified] The monitoring of forest management plan implementation is available in the FSC reports of the company.

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

[Externally verified] This indicator is disabled as company operates only in Gabon out of the countries covered by Open Timber Portal. At the time of assessment OTP Gabon was not fully operational and therefore was not included in this year's SPOTT assessment.

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

[Externally verified] This indicator is disabled as company operates only in Gabon out of the countries covered by Open Timber Portal. At the time of assessment OTP Gabon was not fully operational and therefore was not included in this year's SPOTT assessment.

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

[Externally verified] This indicator is disabled as company operates only in Gabon out of the countries covered by Open Timber Portal. At the time of assessment OTP Gabon was not fully operational and therefore was not included in this year's SPOTT assessment.

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

All supply to own mills was sourced from the company's own operations in 2020.

29. Number of company owned sawmills?

4 - The company owns three sawmills in Gabon and one sawmill in Brazil.

30. Names and locations of company owned sawmills?

The names and locations of all company owned sawmills are directly linked on the company website.

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

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

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

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

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

The company reports to process only wood harvested in its own certified forests.

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

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

35. Number of third party supplying mills?

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

The company also has its own process to trace raw materials to country of harvest and details of process are available in its sustainability report.

39. Percentage of supply traceable to country of harvest?

100 - The company reports to apply its CoC system to its whole supply chain.

40. Procedures to trace raw materials to FMU level?

The company has its own process to trace raw materials to FMU level and details of process are available in its sustainability report.

41. Percentage of supply traceable to FMU level?

100%.

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

The company is already 100% FSC (1997,2008,2009) and PEFC (2017, 2018) certified.

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

100% - 875,128.27 ha- FSC certified (100% of the operational area).

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

The company states that 100% of traded timber is PEFC and FSC-CoC certified.

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

100% - The company states that 100% of traded and processed timber was PEFC FM/CoC or Controlled Sources verified in 2020.

46. Percentage area (ha) FSC FM certified?

100% - 875,128.27 ha.

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

The company reports that all of its forest operations are already 100% FSC FM certified.

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

0% - The company's only third party supply comes from trading operations, 0% was FSC FM certified in 2020.

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

The company reports to trade only timber and timber products of third parties that are either FSC or PEFC certified.

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

This indicator is disabled as the company is either 100% FSC FM certified or is >75% certified and has a commitment to achieve 100% within 5 years.

51. Commitment to zero deforestation or zero conversion of natural ecosystems?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company s FSC certification/FSC membership. The company also reports its own commitment to zero deforestation in its sustainability report.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification. The company's own commitment to zero deforestation applies to all its suppliers.

53. Criteria and cut-off date for defining deforestation?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and the PEFC International Standard (PEFC ST 1003:2010). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and the company's PEFC certified landbank (100%).

54. Evidence of monitoring deforestation?

The company has evidence on deforestation monitoring mentioned in the forest management plans of CEB and MIL as well as in its sustainability report. However, the information is not externally verified.

55. Evidence of monitoring deforestation in supplier operations?

56. Amount of illegal/non-compliant deforestation recorded?

0 (0%) - For 2019, zero deforestation is recorded from company's own operations or third party operations within its concessions.

57. Amount of illegal/non-compliant deforestation recorded in supplier operations?

58. Commitment to restoration of non-compliant deforestation/conversion?

The company reports its commitment to restoration of non-compliant deforestation and mentions that after 2009, no non-compliant deforestation or conversion should occur in its operations.

59. Commitment to restoration of non-compliant deforestation/conversion applies to all suppliers?

Suppliers must restore non-compliant deforestation or conversion if it happened after 2018.

60. Implementing a landscape or jurisdictional level approach?

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator. The company also reports that a convention has been elaborated between the government, the NGO Conservation Justice and itself aiming to implement a joint action plan for fauna conservation and anti-poaching measures in the landscape spanning the Ivindo National Parc and the company concession area.

61. Commitment to biodiversity conservation?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN) and through the PEFC International Standard (PEFC ST 1003:2010). Full points have therefore been awarded on the basis of the company's FSC and PEFC certified landbank (100%). The company also reports its own commitment to biodiversity conservation.

62. Commitment to biodiversity conservation applies to all suppliers?

The company's own commitment to biodiversity conservation applies to all suppliers.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator. The company also reports that it commits to biodiversity conservation which unambiguously includes the protection of flora and fauna covered by national and international law, such as CITES. However, a clear list of species identified as per the international/national system is not available.

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

Points for external verification have been awarded on the basis of the company's FSC/PEFC certified landbank/volume.

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

The company reports its commitment to sustainable hunting of species.

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

The company's commitment to sustainable hunting of species applies to all suppliers.

67. Commitment to protect forest areas from illegal activities?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN) and through the PEFC International Standard (PEFC ST 1003:2010). Full points have therefore been awarded on the basis of the company's FSC and PEFC certified landbank (100%).

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

The company has published this commitment.

69. Evidence of protecting forest areas from illegal activities?

Points for external verification have been awarded on the basis of the company's FSC/PEFC certified landbank/volume.

70. 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.

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

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

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership. The company also reports its own commitment to conduct High Conservation Value (HCV) assessments.

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

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

74. High Conservation Value (HCV) assessments available?

The High Conservation Value (HCV) assessments are available for all of the company's concessions. However, the assessments are not externally verified.

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

The management and monitoring plans are available in the HCV assessments of the company concessions. However, the assessments are not externally verified.

76. 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.

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

The company commits suppliers to protect High Carbon Stocks but does not specify the HCS Approach specifically.

78. High Carbon Stock (HCS) assessments available?

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN) and through the PEFC International Standard (PEFC ST 1003:2010). Full points have therefore been awarded on the basis of the company's FSC and PEFC certified landbank (100%).

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

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

The SEIAs and associated management plans are available as a part of forest management plan for company's operations in Gabon. However, the forest management plan is not externally verified.

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

This indicator is disabled as company operates only in Gabon out of the countries covered by Open Timber Portal. At the time of assessment OTP Gabon was not fully operational and therefore was not included in this year's SPOTT assessment.

83. 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.

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

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

The company reports to have no landbank on peat in 2020.

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

This indicator is disabled as the company operates in natural forest only and has reported the area of peat in its landbank in the last two years.

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

The company reports its commitment to best management practices for soils and peat on its website.

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

The company reports that its commitment to best management practices for soils and peat applies to all suppliers.

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

The company reports that it does not have operations on peatland. Points for external verification have been awarded on the basis of the company's FSC certified landbank/volume.

90. Commitment to reduced impact logging?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). 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 on its website.

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

The company's commitment to reduced impact logging applies to all suppliers.

92. Evidence of implementing reduced impact logging practices?

Points for external verification have been awarded on the basis of the company's FSC certified landbank/volume. The company also reports evidence of implementing reduced impact logging practices in its forest management plans.

93. Commitment to zero burning?

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

94. Commitment to zero burning applies to all suppliers?

The company has published this commitment.

95. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's PEFC certification. However, certificates stating the area covered by certification are not available, therefore additional points cannot be awarded. The company also reports evidence of fire monitoring and management in its sustainability report.

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

15 - For 2019, the company reports 11 slash and burn fires in its operations in Brazil and 4 slash and burn fires in its operations in Gabon. Zero natural wildfires were recorded.

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

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

The company aims to keep its overall intensity below 0.07 tC/m3/year over the coming 10 years.

99. GHG emissions intensity?

The company reports the CO2 emission figure for 2019 as 0.067 tCO2/m3.

100. GHG emissions from land use change?

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

101. Progress towards commitment to reduce GHG emissions intensity?

The company's GHG emissions intensity for 2019 is reported as 0.067 tCO2/m3 which is already below the target intensity of 0.07 tC/m3/year. However, this information is not externally verified.

102. Methodology used to calculate GHG emissions?

The company reports that its CO2 emission is calculated annually using the classification of the World Resources Institute (WRI).

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

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

104. Water use intensity?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

105. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

106. Time-bound commitment to improve water quality (BOD and COD)?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

107. Progress towards commitment on water quality (BOD and COD)?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

108. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

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

The company reports that run-off from its production sites in Brazil and Gabon are directed to clarifying basins for treatment. Evidence is not externally verified.

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

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

111. Commitment to protect natural waterways through buffer zones?

The company reports that all watercourses and their banks are protected as environmentally valuable zones and remain under permanent protection.

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

[Externally verified] The implementation of commitment to protect natural waterways through buffer zones is reported in the FSC reports of the company.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). 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 minimise the use of chemicals, including pesticides and chemical fertilisers on its website and in its sustainability report.

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

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

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

116. 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-POL-01-004 V2-0 EN) and through the PEFC International Standard (PEFC ST 1003:2010). Full points have therefore been awarded on the basis of the company's FSC and PEFC certified landbank (100%). The company also reports its own commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides on its website.

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

The company has published this commitment.

118. 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-POL-01-004 V2-0 EN). 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 chemicals listed under the Stockholm Convention and Rotterdam Convention on its website.

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

The company has published this commitment.

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

The chemical usage figures of the company are reported in its FSC reports.

121. Implementation of commitment to reduce chemical usage?

Points for external verification have been awarded on the basis of the company's FSC certified landbank/volume.

122. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's FSC certified landbank/volume. The company also mentions in its sustainability report that it is compulsory for them under PEFC and FSC certification to develop and apply IPM.

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

[Externally verified] The company has a waste management plan in place for its concessions and the details of it are available in the forest management plans and FSC reports of the company.

124. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership. The company also reports its own commitment to the Universal Declaration of Human Rights on its website.

125. Commitment to human rights applies to all suppliers?

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

126. Progress on human rights commitment ?

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and PEFC International Standard (PEFC ST 1003:2010). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and the company's PEFC certified landbank (100%). The company also reports its commitment to respect indigenous and local communities' rights on its website.

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

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN) and through the PEFC International Standard (PEFC ST 1003:2010). Full points have therefore been awarded on the basis of the company's FSC and PEFC certified landbank (100%). The company also reports its own commitment to respect legal and customary land tenure rights on its website.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (100%).

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

The company reports its commitment to free, prior and informed consent (FPIC) in its sustainability report and on its website.

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

The company's commitment to free, prior and informed consent (FPIC) applies to all its suppliers.

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

The details of free, prior and informed consent (FPIC) process is available in the latest sustainability report of the company.

134. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The examples of local stakeholder engagement to prevent conflicts are available in the company's sustainability report as well as FSC audit reports.

135. Details of process for addressing land conflicts available?

The details of process for addressing land conflicts available are available in the latest sustainability report of the company.

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

The company reports information on the inclusion of women across forestry operations, including addressing barriers faced in its latest sustainability report. However, this information is not externally verified.

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

This indicator is disabled as company operates only in Gabon out of the countries covered by Open Timber Portal. At the time of assessment OTP Gabon was not fully operational and therefore was not included in this year's SPOTT assessment.

138. 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-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (100%).

139. Commitment to provide essential community services and facilities ?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). 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 provide essential community services and facilities on its website.

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

Points for external verification have been awarded on the basis of the company's FSC certified landbank/volume.

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

The company reports its commitment to provide work opportunities for local communities in its latest sustainability report and on its website.

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

This indicator is disabled as company operates only in Gabon out of the countries covered by Open Timber Portal. At the time of assessment OTP Gabon was not fully operational and therefore was not included in this year's SPOTT assessment.

143. 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) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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

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

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

The company's commitment to eliminate gender related discrimination with regards to employment applies to all suppliers.

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

149. Percentage or number of temporary employees?

This indicator is disabled as the company has informed ZSL that it doesn't have temporary employees.

150. Percentage or number of women employees?

144 (10%) - Data as of 2019.

151. Commitment to pay at least minimum wage?

The company reports that payment of minimum wages is a non-negotiable part of its business ethics.

152. Commitment to pay at least minimum wage applies to all suppliers?

The company's commitment to pay at least minimum wage applies to all suppliers.

153. Progress on commitment to pay at least minimum wage?

The company reports legal minimum wage for Gabon and Brazil as ? 229 and ? 221, respectively and the company minimum wage for Gabon and Brazil as ? 252 and ? 231, respectively. However, this information is not externally verified.

154. Reporting of salary by gender?

The company reports legal minimum wage for men and women in Gabon and Brazil as ? 228.67 and ? 222.41, respectively and the company minimum wage for men and women in Gabon and Brazil as ? 228.67 and ? 232.15, respectively. However, this data is for 2018 and now between two and five years old.

155. Commitment to address occupational health and safety?

The company reports its commitment to the ILO Code of Practice on Safety and Health in Forestry Work.

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

The company publishes this commitment but does not reference the ILO Code of Practice on Safety and Health in Forestry Work. The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

157. Provision of personal protective equipment and related training?

[Externally verified] The information on provision of personal protective equipment and related training is reported in the FSC reports of the company.

158. Time lost due to work-based injuries?

128 - The company reports 128 accidents and an accident rate of 8.5% for 2019.

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

0 - Fatal accidents at work (2019).

160. Commitment to support smallholders?

This indicator is disabled as the company reports that it doesn't source wood/wood fibre from smallholders.

161. 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.

162. 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.

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

The company has its own timber procurement policy in place which is used to prioritise, assess and/or engage suppliers on compliance with company's policy and/or legal requirements.

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

Suppliers are assessed annually on compliance; in 2020 all suppliers were deemed to be compliant with the company's procurement policy.

165. Suspension or exclusion criteria for suppliers?

The company states the suspension criteria for suppliers in its timber and procurement policy.

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

In 2020, all suppliers were deemed to be compliant with sourcing commitments via an annual assessment.

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

The company reports that it only sources FSC or PEFC certified wood from third parties for trading purpose. The volume of 100% PEFC certified wood sourced from third parties in 2019 is reported as 15,857m3 of logs and 119 m3 of sawn wood. Partial points have been awarded as the information is not externally verified.

168. Commitment to ethical conduct and prohibition of corruption?

The company reports its commitment to ethical conduct and prohibition of corruption in its business ethics guideline document as well as in its sustainability report.

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

The company reports that its suppliers are obliged to conduct ethically and exclude any type of corruption.

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

The business ethics guideline of the company has limited details provided in concern of the company's commitment to ethical conduct and prohibition of corruption. The guideline only mentions about having a dedicated team who are responsible for implementation of this commitment. However, details on actions taken are not reported.

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

[Externally verified] This indicator is disabled as company operates only in Gabon out of the countries covered by Open Timber Portal. At the time of assessment OTP Gabon was not fully operational and therefore was not included in this year's SPOTT assessment.

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

The company's tax policy is available on its website.

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

This indicator is disabled as company operates only in Gabon out of the countries covered by Open Timber Portal. At the time of assessment OTP Gabon was not fully operational and therefore was not included in this year's SPOTT assessment.

174. Whistleblowing procedure?

The company reports the details of its whistleblowing procedure in its sustainability report.

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

The company has its own grievance system open to all stakeholders.

176. Details of complaints and grievances disclosed?