Rougier SA

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

The company has published a sustainable forestry policy which covers all operations.

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

The company reports a separate and more limited set of commitments to its third-party suppliers, with no reference to sustainability.

3. High-level position of responsibility for sustainability?

The company reports having a group level CSR contact person, but no clear information on responsibility for sustainability and information is undated.

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

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

0 - The company reports that 23% of group managers are women (as of 2022).

6. Percentage or number of women board members?

0 - None of the six board members are woman (as of 2022).

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, ATIBT, STTC.

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

9. Sustainability report published within last two years?

The company has not published a sustainability report within the last two years.

10. Reports through standardised reporting systems?

The company does not report through a standardised reporting system.

11. Climate risks assessment available?

The company has not reported an assessment of climate-related risks beyond a general acknowledgement of risks related to climate, economic conditions and political issues.

12. Natural capital assessment available?

The company does not have a natural capital assessment available.

13. Lists countries and operations?

The company has processing and producing operations in both Gabon and the Republic of Congo.

14. Lists countries sourcing from?

The company does not provide a list of countries that it sources from.

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

1500000 - The company reports that it operates more than 1.5 million hectares of forest concessions spread across the Congo Basin. Partial points awarded for approximate figures.

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

1482160 - The company reports 1,482,155 ha of natural forest designated for wood/wood fibre production. The company claims that 100% of this area is verified by third parties (FSC and VLC).

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)?

0 - The company does not report on its area of plantation/natural forest within outgrower schemes.

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)?

24883 - The company reports a total of 47,744 ha of protected areas across their Gabonese concessions, however the figures for two FMUs are undated and therefore 22,911 ha could not be counted in the total. Additionally, no figures published in the last five years could be found for the company's Congo operations.

21. Area of Intact Forest Landscape (ha)?

119572 - Figures were found for three FMUs (CFAD of l'Ogoou?-Ivindo at Ivindo, CFAD de L?k?, and CFAD du Haut-Abanga) and added together. Figures for the company's two other FMUs could not be found.

22. Number of Forest Management Units (FMUs)?

5 - The company has five FMUs, four in Gabon and one in Republic of Congo.

23. Maps of forest management units (FMUs)?

The company publishes its forest management plan containing maps of all 5 FMUs and has some FMUs mapped on Global Forest Watch and Open Timber Portal.

24. Forest management plans available for all FMUs?

The company provides forest management plans for all FMUs.

25. Monitoring of forest management plan implementation available?

[Externally verified] Monitoring reports can be found for four FMPs on the FSC website. Points for external verification have been awarded on the basis of the company's FSC certification. As the P&Cs do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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 13 out of the 16 total valid legal documents required by the OTP 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 9 out of the 14 total valid legal documents required by the OTP 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 2 out of the 18 total valid legal documents required by the OTP 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?

The company does not disclose the names and locations of all third-party supplying FMUs.

30. Number of company owned sawmills?

3 - The company reports to have three sawmills, however the figure is undated and therefore points cannot be awarded.

31. Names and locations of company owned sawmills?

Locations for sawmills are given on the website but only at the provincial level; no coordinates, addresses or referenced maps could be found.

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 does not clearly report the total volume (or percentage) of wood sourced by company-owned sawmills that come from company-owned operations and third parties.

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?

The company does not report the number of third-party supplying mills.

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

The company does not report the names and locations of all third party supplying mills.

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

The company does not report the total volume (or percentages) sourced from third-party supplying mills that come from the supplying mills' own operations and/or third parties.

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

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria.

40. Percentage of supply traceable to country of harvest?

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?

The company does not report on the percentage of supply traceable to FMU level.

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

The company commits to achieve 100% legality of FMU's by 2024 using FSC verification.

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

[Externally verified] 60% - 895,825 ha of the company's 1,482,155 ha landbank is 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 does not report time-bound plan to source only wood/wood fibre that is in legal compliance verified by a third party.

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

The company has FSC COC certificates for operations in Gabon, but not for its operations in Republic of Congo. An accurate percentage could not be calculated.

47. Percentage area (ha) FSC FM certified?

60% - 895,825 ha of the company's 1,482,155 ha landbank is FSC FM certified.

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

The company commits to become 100% FSC FM certified by 2024.

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

The company does not report the percentage of wood/wood fibre supply 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?

The company does not report a 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)?

The company does not report on percentage area that is PEFC certified.

52. Commitment to zero conversion of natural ecosystems?

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

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.

55. Commitment to zero deforestation applies to all suppliers?

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's partial FSC FM or CoC certification.

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

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

The company does not report evidence of monitoring deforestation.

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 does not report on the amount of illegal/non-compliant deforestation.

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

The company does not report on the amount of illegal/non-compliant deforestation in supplier operations.

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

The company does not report a commitment to restoration of non-compliant deforestation/conversion.

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

The company does not report a commitment to restoration of non-compliant deforestation/conversion that applies to all suppliers.

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.

65. Biodiversity policy?

66. Biodiversity policy applies to all suppliers?

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.

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.

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

The company commits to only allow sustainable hunting of species by local communities for subsistence purposes in its operations.

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

The company's commitment to no hunting or only sustainable hunting of species is not reported to apply to all suppliers.

71. Commitment to protect forest areas from illegal activities?

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

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

The company's commitment to protect forest areas from illegal activities is not reported to apply to all suppliers.

73. Evidence of protecting forest areas from illegal activities?

The company reports on the number of indications of illegal activity monitored for the whole year but does not provide examples of how it protects forest areas from unauthorised or illegal activities. 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.

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?

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.

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

78. High Conservation Value (HCV) assessments available?

[Externally verified] The company has provided HCV summaries for four out of five FMUs. Reporting does not cover the whole of the company's operations, therefore only partial points can be awarded.

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

[Externally verified] The company has provided HCV management and monitoring plans for four out five FMUs. Reporting does not cover the whole of the company's operations, therefore only partial points can be awarded.

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?

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 reports a commitment to conduct Social and Environmental Impact Assessments (SEIAs), however, it is not clear whether this commitment applies to all of the company's operations.

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

The company does not report a commitment to conduct Social and Environmental Assessments (SEIAs) that applies to all suppliers.

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

[Externally verified] The company demonstrates environmental and social considerations for local communities in its Forest Management Plans (FMPs), however these are not comprehensive assessments and, therefore, full points cannot be awarded.

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 3 of the 12 total valid 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 does not report that its commitment to no planting on peat of any depth applies to all suppliers.

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 does not report its commitment to best management practices for soils and peat applying to all suppliers.

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.

95. Commitment to reduced impact logging?

The company commits to Reduced Impact Logging (RIL) and specifically mentions minimising the impact of logging roads along with other RIL practices.

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

97. Evidence of implementing reduced impact logging practices?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

98. Commitment to zero burning?

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

99. Commitment to zero burning applies to all suppliers?

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?

The company does not report on details/number of hotspots/fires in company FMUs.

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

The company does not report details/number of hotspots/fires in suppliers operations.

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

The company does not report a time-bound commitment to reduce GHG emissions intensity.

104. GHG emissions intensity?

The company does not report GHG emissions intensity.

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 does not report progress towards commitment to reduce GHG emissions intensity.

108. Methodology used to calculate GHG emissions?

The company does not report a methodology used 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?

The company reports on waste treatment but no specific reference to wastewater is made. Data is between two and five years old, therefore full points cannot be awarded.

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 does not report a commitment to protect natural waterways through buffer zones.

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

Points for external verification have been awarded on the basis of the company's FSC certification. As the P&Cs do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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

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

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 does not report a commitment to no use of WHO Class 1A and 1B pesticides.

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

The company does not report a commitment to no use of WHO Class 1A and 1B pesticides that applies to all its suppliers.

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

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

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

The company does not reports chemical usage per ha or list of chemicals used.

127. Implementation of commitment to minimise inorganic fertiliser usage?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

128. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

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

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

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification.

131. Commitment to human rights applies to all suppliers?

132. Progress on human rights commitment ?

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.

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

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's partial FSC FM or CoC certification.

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

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

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

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

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.

141. Details of process for addressing land conflicts available?

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

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 3 of the 18 total valid 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 reports that it identifies NTFPs that are important to the local population and supports 'channels to capitalise on NTFPs'. No reference is made to the sustainable use of these products by local communities, or the needs and/or rights of local communities and indigenous people. Partial points have been awarded.

145. Commitment to provide essential community services and facilities ?

The company reports a commitment to provide essential community services and facilities including 'safety, hygiene, housing, education, food and nutrition and health'.

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

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

The company commits to promote local employment.

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 6 of the 13 total valid 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.

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

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

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

The company does not report a commitment to eliminate gender related discrimination with regards to employment.

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

The company does not report a commitment to eliminate gender related discrimination with regards to employment.

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

155. Percentage or number of temporary employees?

483 (37%) - In 2022, the company reported that 37% of its employees had fix-termed contracts, out of the total 1,301 employees.

156. Percentage or number of women employees?

95 (7%) - In 2022, the company reported 7% of its employees were women. The company reports a total of 1,301 employees, including 95 women.

157. Commitment to pay a living wage?

The company does not report a commitment to pay at least minimum wage.

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

159. Progress on commitment to pay a living wage?

The company does not report a commitment to pay at least minimum wage.

160. Reporting of salary by gender?

161. Commitment to address occupational health and safety?

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.

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

163. Provision of personal protective equipment and related training?

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.

164. Time lost due to work-based injuries?

The company does not report on time lost due to work-based injuries.

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

The company does not report on fatalities as a result of work-based accidents.

166. Commitment to support smallholders?

The company does not report a commitment to support smallholders.

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

The company does not report a programme to support outgrower scheme and/or independent smallholders.

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

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

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?

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

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 does not report a commitment to ethical conduct and prohibition of corruption.

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

The company does not report a commitment to ethical conduct and prohibition of corruption that applies to all suppliers.

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

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 6 of the 6 total valid 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?

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 3 of the 7 total valid 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 does not report on its whistleblowing procedure.

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

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.

182. Details of complaints and grievances disclosed?