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Priceworth International

Timber and pulp assessment
  • Latest update: August 2022
  • Next scheduled: July 2023

Show media reports (6) Show ESG scores Show supply chain scores Modify score weighting
  • About this company:

    Established in 1992, Priceworth International is an investment

  • Market cap:
    14,896,207 USD
  • Thomson Reuters ticker:
    PWPB.KL
  • Bloomberg ticker:
    PWP MK Equity
  • ISIN:
    MYL7123OO002
  • Website:

Company assessment: Priceworth International – August 2022

Assessment date:

Score by disclosure type:

Total: 7.5% 12.75 / 171
  • Organisation: 6.5 / 37 17.6%
  • Policy: 3 / 76 4%
  • Practice: 3.3 / 58 5.6%
  • Self-reported: 0.8 / 58 1.3%
  • External: 0 / 58 0%
  • Certified: 2.5 / 58 4.3%
  • Sustainability policy and leadership Sustainability policy and leadership
    2 / 12 16.7%
    • Organisation: 2 / 6 33.3%
    • Policy: 0 / 2 0%
    • Practice: 0 / 4 0%
    • Self-reported: 0 / 4 0%
    • External: 0 / 4 0%
    • Certified: 0 / 4 0%
    • N
      0 / 1

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

    • N
      0 / 1

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

    • P
      0.5 / 1

      3. High-level position of responsibility for sustainability?

      The company has reported head of operation of sustainable forest management of the group.

    • N
      0 / 1

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

      The company's one of the subsidiary "Maxland Sdn Bhd" director is the head of operation of Sustainable Forest Management of the Group. Hence no points were awarded.

    • P
      0.5 / 1

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

      0 - The company explicitly reports on the genders of four "key" senior management team members in its 2021 Annual Report, reporting no woman.

    • Y
      1 / 1

      6. Percentage or number of women board members?

      0 - The company explicitly reports on the genders of board members in its 2021 Annual Report and its webpage. It shows there are no women on the board.

    • N
      0 / 1

      7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with timber and pulp production?

    • N
      0 / 1

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

    • N
      0 / 1

      9. Sustainability report published within last two years?

    • N
      0 / 1

      10. Reports through standardised reporting systems?

    • N
      0 / 1

      11. Climate risks assessment available?

    • N
      0 / 1

      12. Natural capital assessment available?

  • Landbank, maps and traceability Landbank, maps and traceability
    2.5 / 23 10.9%
    • Organisation: 2.5 / 18 13.9%
    • Policy: 0 / 2 0%
    • Practice: 0 / 3 0%
    • Self-reported: 0 / 3 0%
    • External: 0 / 3 0%
    • Certified: 0 / 3 0%
    • Y
      1 / 1

      13. Lists countries and operations?

      The company's main country of operation is Malaysia and major factories located in Sandakan, Sabah.

    • N
      0 / 1

      14. Lists countries sourcing from?

    • N
      0 / 1

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

      The company reports that it has 27,900 ha of FMU under the sustainable Forest Management (SFM) authority.

    • N
      0 / 1

      16. Total area of forest plantation (ha)?

      The company reports it has 27,900 ha of FMU under the sustainable Forest Management (SFM) authority.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      20. Area of Intact Forest Landscape (ha)?

    • P
      0.5 / 1

      21. Number of Forest Management Units (FMUs)?

      2 - The company has two FMUs called FMU 17 and FMU 16 however, it is unclear whether it represents all of company's FMUs.

    • N
      0 / 1

      22. Maps of forest management units (FMUs)?

    • N
      0 / 1

      23. Forest management plans available for all FMUs?

    • N
      0 / 1

      24. Monitoring of forest management plan implementation available?

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

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

    • N
      0 / 1

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

    • Y
      1 / 1

      29. Number of company owned sawmills?

      4 - The company has reported 4 sawmill in its list of properties.

    • N
      0 / 1

      30. Names and locations of company owned sawmills?

      The company has provided addresses of all the sawmills however, the addresses are not specific enough to allow the location of the mills to be found online. Hence, no points were awarded.

    • 31. 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.

    • 32. 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.

    • N
      0 / 1

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

    • 34. 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.

    • N
      0 / 1

      35. Number of third party supplying mills?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      39. Percentage of supply traceable to country of harvest?

    • N
      0 / 1

      40. Procedures to trace raw materials to FMU level?

    • N
      0 / 1

      41. Percentage of supply traceable to FMU level?

  • Certification standards Certification standards
    0 / 9 0%
    • Organisation: 0 / 0 0%
    • Policy: 0 / 4 0%
    • Practice: 0 / 5 0%
    • Self-reported: 0 / 5 0%
    • External: 0 / 5 0%
    • Certified: 0 / 5 0%
    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      46. Percentage area (ha) FSC FM certified?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

  • Deforestation and biodiversity Deforestation and biodiversity
    0.5 / 25 2%
    • Organisation: 0 / 2 0%
    • Policy: 0 / 15 0%
    • Practice: 0.5 / 8 6.3%
    • Self-reported: 0 / 8 0%
    • External: 0 / 8 0%
    • Certified: 0.5 / 8 6.3%
    • N
      0 / 1

      51. Commitment to zero conversion of natural ecosystems?

    • N
      0 / 1

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

    • N
      0 / 1

      53. Commitment to zero deforestation?

    • N
      0 / 1

      54. Commitment to zero deforestation applies to all suppliers?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      60. Commitment to restoration of deforestation/conversion?

    • N
      0 / 1

      61. Commitment to restoration of deforestation/conversion applies to all suppliers?

    • N
      0 / 1

      62. Implementing a landscape or jurisdictional level approach?

    • N
      0 / 1

      63. Biodiversity policy?

    • N
      0 / 1

      64. Biodiversity policy applies to all suppliers?

    • N
      0 / 1

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

    • N
      0 / 2

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

    • N
      0 / 1

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

      The company reports that in Sustainable Forest Management Area ("SFMLA") they protect forests from illegal hunting. However, no commitment was found. Hence no points were awarded.

    • N
      0 / 1

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

    • N
      0 / 1

      69. Commitment to protect forest areas from illegal activities?

      The company states that it protects Sustainable Forest Management Area ("SFMLA") from illegal logging, forest fire, and illegal hunting. However, no commitment was found. Hence no points were awarded.

    • N
      0 / 1

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

    • P
      0.5 / 2

      71. Evidence of protecting forest areas from illegal activities?

      The company states that it protects Sustainable Forest Management Area ("SFMLA") by monitoring forest encroachment, illegal logging, forest fire, and illegal hunting.

    • N
      0 / 1

      72. Commitment to no use of genetically modified organisms?

    • N
      0 / 1

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

  • HCV, HCS and impact assessments HCV, HCS and impact assessments
    0 / 11 0%
    • Organisation: 0 / 0 0%
    • Policy: 0 / 6 0%
    • Practice: 0 / 5 0%
    • Self-reported: 0 / 5 0%
    • External: 0 / 5 0%
    • Certified: 0 / 5 0%
    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      76. High Conservation Value (HCV) assessments available?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      80. High Carbon Stock (HCS) assessments available?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

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

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

  • Soils, fire and GHG emissions Soils, fire and GHG emissions
    2.25 / 23 9.8%
    • Organisation: 0 / 5 0%
    • Policy: 1 / 10 10%
    • Practice: 1.3 / 8 15.6%
    • Self-reported: 0 / 8 0%
    • External: 0 / 8 0%
    • Certified: 1.3 / 8 15.6%
    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 2

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

    • Y
      1 / 1

      93. Commitment to reduced impact logging?

      The company has commitment to reduced impact logging.

    • N
      0 / 1

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

    • P
      0.75 / 2

      95. Evidence of implementing reduced impact logging practices?

      The company has given an example that Reduced Impact Logging (RIL) reduces logging damage to future crop trees which help to regenerate forest naturally before the next harvesting cycle.

    • N
      0 / 1

      96. Commitment to zero burning?

    • N
      0 / 1

      97. Commitment to zero burning applies to all suppliers?

    • P
      0.5 / 2

      98. Evidence of fire monitoring and management?

      The company states that it monitors forest fires in its sustainable forest management areas, however no other details are reported.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      102. GHG emissions intensity?

    • N
      0 / 1

      103. GHG emissions from land use change?

    • N
      0 / 1

      104. Progress towards commitment to reduce GHG emissions intensity?

    • N
      0 / 1

      105. Methodology used to calculate GHG emissions?

  • Water, chemical and pest management Water, chemical and pest management
    0.75 / 16 4.7%
    • Organisation: 0 / 1 0%
    • Policy: 0 / 7 0%
    • Practice: 0.8 / 8 9.4%
    • Self-reported: 0.8 / 8 9.4%
    • External: 0 / 8 0%
    • Certified: 0 / 8 0%
    • 106. 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.

    • 107. Water use intensity?

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

    • 108. Progress towards commitment on water use intensity?

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

    • 109. 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.

    • 110. 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.

    • 111. Treatment of pulp and paper mill effluent?

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

    • N
      0 / 1

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

    • 113. 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.

    • N
      0 / 1

      114. Commitment to protect natural waterways through buffer zones?

    • N
      0 / 2

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • 118. 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.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 2

      124. Implementation of commitment to reduce chemical usage?

    • N
      0 / 2

      125. Integrated Pest Management (IPM) approach?

    • P
      0.75 / 1

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

      The company clearly has a waste management system in place that covers various aspects of timber production and processing to ensure waste storage, treatment, and disposal practices.

  • Community, land and labour rights Community, land and labour rights
    3.75 / 37 10.1%
    • Organisation: 2 / 5 40%
    • Policy: 1 / 21 4.8%
    • Practice: 0.8 / 11 6.8%
    • Self-reported: 0 / 11 0%
    • External: 0 / 11 0%
    • Certified: 0.8 / 11 6.8%
    • N
      0 / 1

      127. Commitment to human rights?

    • N
      0 / 1

      128. Commitment to human rights applies to all suppliers?

    • N
      0 / 1

      129. Progress on human rights commitment ?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      137. Examples of local stakeholder engagement to prevent conflicts?

    • N
      0 / 1

      138. Details of process for addressing land conflicts available?

    • N
      0 / 1

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

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

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

    • N
      0 / 1

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

    • N
      0 / 1

      142. Commitment to provide essential community services and facilities ?

    • P
      0.75 / 2

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

      The company reports about maintaining two main steel and concrete bridges of 80 meters long each and also maintaining infrastructures that are important access for the thousands of villagers in the nearby village areas. However, information is self-reported. Hence awarded only partial points.

    • P
      0.5 / 1

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

      The company provided employment opportunities and necessary training to the local villagers with an aim to eventually improve their livelihood and living standard. However, commitment is unclear, hence awarded only partial points.

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

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

    • N
      0 / 1

      146. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

    • N
      0 / 1

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

    • N
      0 / 2

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      152. Percentage or number of temporary employees?

    • N
      0 / 1

      153. Percentage or number of women employees?

    • N
      0 / 1

      154. Commitment to pay a living wage?

    • N
      0 / 1

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

    • N
      0 / 1

      156. Progress on commitment to pay a living wage?

    • N
      0 / 1

      157. Reporting of salary by gender?

    • P
      0.5 / 1

      158. Commitment to address occupational health and safety?

      The company has the responsibility to provide and maintain a safe and healthy working environment for all its employees. However, no reference to the ILO Code was found, hence awarded only partial points.

    • N
      0 / 1

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

    • N
      0 / 2

      160. Provision of personal protective equipment and related training?

    • Y
      1 / 1

      161. Time lost due to work-based injuries?

      The company clearly reports that there have been no workplace incidents for the financial period.

    • Y
      1 / 1

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

      The company clearly reports that there have been no workplace incidents for the financial period.

  • Smallholders and suppliers Smallholders and suppliers
    0 / 8 0%
    • Organisation: 0 / 0 0%
    • Policy: 0 / 4 0%
    • Practice: 0 / 4 0%
    • Self-reported: 0 / 4 0%
    • External: 0 / 4 0%
    • Certified: 0 / 4 0%
    • N
      0 / 1

      163. Commitment to support smallholders?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      168. Suspension or exclusion criteria for suppliers?

    • N
      0 / 1

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

    • N
      0 / 1

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

  • Governance and grievances Governance and grievances
    1 / 7 14.3%
    • Organisation: 0 / 0 0%
    • Policy: 1 / 5 20%
    • Practice: 0 / 2 0%
    • Self-reported: 0 / 2 0%
    • External: 0 / 2 0%
    • Certified: 0 / 2 0%
    • P
      0.5 / 1

      171. Commitment to ethical conduct and prohibition of corruption?

      The Group had adopted the ABAC Policy to incorporate the policy and procedures on anti-corruption. However, the Company did not make available its Code of Ethics and Conduct on its website. Hence awarded only partial points.

    • N
      0 / 1

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

    • N
      0 / 1

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

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

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

    • N
      0 / 1

      175. Disclosure of the company’s management approach to tax and payments to governments?

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

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

    • P
      0.5 / 1

      177. Whistleblowing procedure?

      The company has in place a Whistle Blowing Policy. However, details on the procedure are not given, hence awarded only partial points.

    • N
      0 / 1

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

    • N
      0 / 1

      179. Details of complaints and grievances disclosed?

Media monitor: Priceworth International

SPOTT monitors global media sources for coverage of assessed companies. The media monitor gathers reports about specific activities related to the assessment indicator categories. ZSL does not assess or score the validity of media coverage, but users can explore the media monitor to provide context on implementation, and infer risks associated with reported operations on the ground.

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