Rougier SA

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

2. Sustainability policy or commitment applies to direct and third-party suppliers?

3. High-level position of responsibility for sustainability?

Group CSR Director.

4. Sustainability report published within last two years?

5. Member of multiple industry schemes or other external initiatives to improve forest management or transparency?

FSC, WWF-GFTN, ATIBT, European Coalition for Sustainable Tropical Timber (STTC).

6. Activities with government, NGOs or academic institutions to improve the sustainability of forest products?

The company has a project with WWF to work on sustainable forest management and has partnerships with WCS and ZSL focused on wildlife management.

7. Lists countries and operations?

Natural forests and plantations in Gabon, Cameroon, Republic of Congo, Central African Republic; distribution.

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

2340000

9. Total area of forest plantation (ha)?

20000 - 14,000 ha current plantations of 30 to 55-year old okoume trees. These plantations are scheduled to be harvested over 20 years and replaced with clonal teak. The company plans to extend the plantation areas on 'degraded secondary forest' to reach a total planted surface of at least 20,000 ha. Data is more than five years old (2011).

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

This indicator is disabled as the company's reporting broadly suggests that it does not source wood/wood fibre from outgrowers. Please note that ZSL has been unable to confirm this.

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

6500 - The company plans to plant 6500 ha of 'degraded secondary forest' with Okume and Teak. Data is more than five years old (2011).

12. Conservation set-aside and/or HCV area (ha)?

13. Area of Intact Forest Landscape (ha)?

14. Number of Forest Management Units (FMUs)?

11

15. Maps of forest management units (FMUs)?

Interactive map available of all concessions and mills available via company website, but not georeferenced. Georeferenced maps for some concessions available via WRI Global Forest Watch.

16. Forest management plans available for all FMUs?

Forest management plans available for active FMUs. The company report that a Forest Management Plan is under development for PEA 191 Rougier Central African Republic.

17. Monitoring of forest management plan implementation?

18. Number of company owned pulp and paper mills?

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

19. Maps or addresses of company owned pulp and paper mills?

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

20. Number of company owned sawmills?

6

21. Maps or addresses of company owned sawmills?

The company only provides a static map of its concessions.

22. Commitment to zero conversion of natural forest?

23. Zero conversion commitment applies to outgrower scheme and independent suppliers?

24. Commitment to minimise the impact of logging roads?

25. Commitment to protect forest areas from illegal activities?

26. Evidence of monitoring deforestation?

The monitoring of forest extent and condition is covered by FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded for this indicator on the basis of the company's FSC certified landbank, which stands at 877,000ha (37.5% of total operational area).

27. Amount of deforestation recorded?

28. Commitment to biodiversity conservation?

29. Commitment to set aside areas for conservation?

30. Examples of habitat management and/or habitat restoration of set-aside areas?

The management and restoration of habitat is covered by FSC Principles and Criteria. Full points have therefore been awarded for this indicator on the basis of the companies FSC certified landbank, which stands at 1,163,000 ha (49.7% of total operational area).

31. Implementing a landscape-level approach to biodiversity conservation?

The maintenance and restoration of appropriate landscape values, including environmental and economic resilience is covered by FSC Principles and Criteria - although this commitment does not extend to active engagement with stakeholders outside of the Forest Management Unit. Half points have therefore been awarded for this indicator on the basis of the companies FSC certified landbank, which stands at 1,163,000 ha (49.7% of total operational area).

32. Commitment to protect species of conservation concern, referencing international or national system of species classification?

The company does not provide a clear reference to a system of classification.

33. Commitment to sustainably manage the use of non-timber forest products (NTFPs)?

The company commits to the responsible management of non-timber forest product and the mapping of NTFPs in the context of forest management plans, but does not refer to needs or rights of local communities.

34. Commitment not to use genetically modified organisms?

The company has committed to not be directly or indirectly involved in the introduction of genetically modified organisms in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004).

35. Commitment to only use alien species where impacts can be controlled?

36. Examples of species conservation activities?

The company has undertaken awareness raising of wildlife issues among communities, anti-poaching activities, the monitoring of wildlife inventories, and has adopted the SMART approach.

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

The company does not have a direct commitment to conduct HCV assessments across all of its operations. However, the company has committed to not be directly or indirectly involved in the destruction of High Conservation Values in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004). For this half points are awarded.

38. HCV commitment applies to outgrower scheme and independent suppliers?

The company has committed to not be directly or indirectly involved in the destruction of High Conservation Values in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004). For this half points are awarded.

39. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS)?

No information found in publicly available sources.

40. High Conservation Value (HCV) assessments available?

HCV assessments available in public summaries of the FSC concession management plans. These do not cover all of the companies operations.

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

HCV monitoring activities included in the FSC concession management plans. These do not cover all of the companies operations.

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

43. High Carbon Stock (HCS) assessments available?

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

The company has a commitment to conduct Environmental and Social Impact Assessments (ESIA) as required by forestry administrations. It is not clear whether this commitment applies to all development and planting.

45. Social and environmental impact assessments (SEIAs) available?

The company has public summaries of Forest Management Plans which contain information about HCV assessments and Social and Environmental impact assessments.

46. Commitment to best management practices for soils and/or peat?

47. Commitment to reduced impact logging?

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

49. Commitment on peatland planting applies to outgrower scheme and independent suppliers?

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

This indicator is disabled as the company does not have plantations on peat.

51. Evidence of best management practices for soils and/or peat?

The company provides examples of best management practices for soils and has confirmed that they do not operate plantations on peatland.

52. Commitment to zero burning?

53. Commitment to zero burning applies to outgrower scheme and independent suppliers?

54. Evidence of management and monitoring fires?

The company states it positions containers with sand or sawdust at strategic locations to prevent the spread of fires. No evidence of fire monitoring activities could be identified.

55. Details/number of hotspots/fires in FMUs controlled by the company?

56. Time-bound commitment to reduce GHG emissions intensity?

57. Progress towards reducing GHG emission intensity?

58. Report GHG emissions from land use change?

59. Methodology used to calculate GHG emissions?

60. Time-bound commitment to improve water quality?

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

61. Progress towards commitment on water quality?

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

62. Protection of natural waterways through buffer zones?

The summaries of forest management plans made available by the company (for FSC certified concessions) show that buffer zones are in place to protect natural waterways.

63. Evidence of treatment of pulp and paper mill effluent?

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

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

The company controls run-off, but no evidence could be found of wastewater treatment.

65. Time-bound commitment to improve water use?

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

66. Progress towards commitment on water use?

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

67. Commitment to eliminate chlorine and chlorine compounds for bleaching?

This indicator is disabled as the company does not produce pulp or paper.

68. Evidence of minimising or recycling solid waste produced during sawmilling processes?

The company implements sorting practices to reduce pollution, but no specific information is provided on the minimisation of wood waste.

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

70. No use of World Health Organisation (WHO) Class 1A and 1B pesticides?

71. No use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

72. Integrated Pest Management (IPM) approach?

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

74. Commitment to human rights, referencing the UN Declaration of Human Rights or UN Guiding Principles on Business and Human Rights?

The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which defines human rights as those established through the UN Declaration of Human Rights.

75. Commitment to human rights applies to outgrower scheme and independent suppliers?

The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which defines human rights as those established through the UN Declaration of Human Rights.

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

The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations, and commits to respecting the customary rights of indigenous people. This commitment is also made through the FSC Policy for Association (FSC-POL-01-004), which encompasses the rights of Indigenous and Tribal Peoples as established by the ILO Convention 169.

77. Commitment to respect legal and customary property rights?

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

The company states that it involves local populations and indigenous peoples in the whole decision-making process, and allows them to express their free consent in the form of memoranda of understanding. However, this does not amount to a full commitment to FPIC across the company's operations.

79. FPIC commitment applies to independent suppliers?

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

The company describes its participatory process for engaging with local and indigenous populations, but this falls short of describing a full FPIC process.

81. Details of process for addressing land conflicts available?

82. Commitment to mitigate impacts on food security?

83. Commitment to provide essential community services and facilities?

The company provides access to education and health/food security through schools, health centers and subsidised shops.

84. Commitment to respect all workers' rights?

85. Reference to Fundamental ILO Conventions?

The company has committed to not be directly or indirectly involved in the violation of any of the ILO Core Conventions. This commitment is made through the FSC Policy for Association (FSC-POL-01-004).

86. Total number of employees?

2989

87. Percentage or number of temporary employees?

88. Percentage or number of women employees?

9% - Data as of 2016.

89. Commitment to pay minimum wage?

90. Commitment to address occupational health and safety, referencing the ILO Code of Practice on Safety and Health in Forestry Work?

The company state that they have set up health and safety committees to improve working conditions and commits to respecting workers' rights as set out by ILO principles.

91. Time lost due to work-based injuries?

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

93. Provision of personal protective equipment and related training?

Reference made to health and safety training programmes. No commitment to provide appropriate PPE equipment could be identified.

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

1749000 (86.8%) - The company report that in 2016 1,163,000 ha was under FSC 100% certification (Gabon and Cameroon) and 586,000 ha VLC certified (Republic of Congo). The company also state that they 'responsibly source' timber from 265,000 ha in the Djoum area of Cameroon. ZSL was unable to ascertain whether this area is verified as being in legal compliance, although the company claim to be 100% legality verified in their 2016 annual report.

95. Percentage wood/wood fibre supply verified as being in legal compliance by a third party?

96. Time-bound plan for achieving 100% FSC FM certification of FMUs?

2024 - The company has committed to fully FSC-certify its landbank within seven years (by 2024). Target not within five years.

97. Commitment to source only wood/wood fibre that meets FSC Controlled Wood requirements?

98. Percentage area (ha) FSC FM certified?

877000 (37.5%) - Figure is for operations in Gabon only. Excluding new concessions awarded but not in operation in 2016 (270,000 ha in CAR) and operations in Cameroon as FSC FM certification has expired in March 2018 and was not renewed.

99. Percentage of wood/wood fibre supply from outgrower scheme and/or independent suppliers that is FSC FM certified?

100. Percentage area (ha) PEFC certified?

The indicator has been disabled as the company operates in a county with no PEFC-endorsed SFM standard.

101. Programme to support outgrower scheme smallholders?

This indicator is disabled as the company's reporting broadly suggests that it does not source wood/wood fibre from outgrowers. Please note that ZSL has been unable to confirm this.

102. Percentage of outgrower scheme smallholders involved in programme?

This indicator is disabled as the company's reporting broadly suggests that it does not source wood/wood fibre from outgrowers. Please note that ZSL has been unable to confirm this.

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

104. Suspension or exclusion criteria for suppliers?

105. Percentage of suppliers assessed and/or engaged on compliance with company requirements?

106. Commitment to ethical conduct and prohibition of corruption?

107. Whistleblowing procedure?

108. Own grievance or complaints system?

109. Grievance or complaints system is accessible to internal and external stakeholders?

110. Details of grievances disclosed?