Samling Group

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 has a Responsible Forest Management Policy who's responsibility covers various social and environmental issues. However, it is unclear if applies to all suppliers.

3. High-level position of responsibility for sustainability?

Chief Operating Officer, Chief Forester and Sustainability Head are the persons who have high-level positions of responsibility for sustainability.

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

This indicator is disabled as the company reports that it is not publicly listed and does not have a board of directors.

5. Reports gender balance of senior management team?

3 - The company has three women on its senior management team.

6. Reports gender balance of board members?

This indicator is disabled as the company reports that it is not publicly listed and does not have a board of directors.

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

[Externally verified] The company is a member of Borneo Forestry Cooperative (BFC) and CEO Action Network.

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

The company reports collaboration with stakeholders such as WWF-Malaysia, FORMADAT (Native Committee), and Nottingham University (Malaysia Campus) for riverbank restoration. It also partnered with various governments to provide vocational health and safety training to employees and worked with the Malaysian Nature Society to conduct a study on the presence of hornbills in Ravenscourt FMU.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2022.

10. Reports through standardised reporting systems?

The company's subsidiary Lingui Group has published its latest Sustainability Report 2022, which aligns with GRI standards.

11. Climate risks assessment available?

The company publishes a climate risk assessment which includes details of the actual, and potential impact of climate change, metrics, targets and climate change responsibility. However, it is self-reported.

12. Natural capital assessment available?

13. Lists countries and operations?

Malaysia (upstream & downstream), Guyana (downstream), China (downstream), and Russia (downstream).

14. Lists countries sourcing from?

The company reports that besides Malaysia it also sources from China, Vietnam, Indonesia, Brazil, Russia, and Guyana.

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

1108020 - The company has 1,108,025 ha of the total land area managed/controlled for forestry.

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

320833 - The company states that it has 320,833 ha of natural forests designated for timber production.

17. Total area of forest plantation (ha)?

67500 - The company reports 67,500 ha of forest plantations.

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

This indicator is disabled as the company reports that it is not a producer with scheme smallholders/outgrowers.

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

30000 - The company reports that the unplanted area is 30,000 ha (as of 2021).

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

226537 - The company reports that it has 226,537 ha of conservation and protected area. However, the data is between two to five years old.

21. Area of Intact Forest Landscape (ha)?

114173 - The company reports 114,173 ha as the area of Intact Forest Landscape. However, the information is between two to five years old.

22. Number of Forest Management Units (FMUs)?

8 - The company reports that it has eight Forest Management Units (FMUs) and five Licenses for Planted Forest (LPFs) under ITP.

23. Maps of forest management units (FMUs)?

Maps for some of the company's FMUs are reported directly and via Global Forest Watch. However, this information does not cover the company's entire operations.

24. Forest management plans available for all FMUs?

The company has reported forest management plans for six FMUs only.

25. Monitoring of forest management plan implementation available?

The company has published forest management monitoring plans for six FMUs and five LPFs only.

26. 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 does not operate in a country currently covered by Open Timber Portal.

27. 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 does not operate in a country currently covered by Open Timber Portal.

28. 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 does not operate in a country currently covered by Open Timber Portal.

29. Maps of all third-party supplying FMUs?

30. Number of company owned sawmills?

2 - The company reports that it has 2 sawmills, one sawmill in Malaysia and the other in Guyana respectively.

31. Names and locations of company owned sawmills?

The coordinates and locations of both mills are published by the company.

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

This indicator is disabled as the company reports that it does not own any 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 any 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 reports that 73% of sourcing by company-owned sawmills comes from company-owned operations and the rest from third-party supplies. However, the information is between two to five years old.

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 any pulp or paper mills.

36. Number of third party supplying mills?

19 - The company has 19 third-party supplying mills as of 2021.

37. 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?

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) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). 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.

40. Percentage of supply traceable to country of harvest?

100 - The company reports that 100% of the supply is traceable to the country of of origin.

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) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). 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. The company also states that it traces logs to FMU level through Sarawak government procedures which mandate the issue of log removal passes.

42. Percentage of supply traceable to FMU level?

The company states that all sawmill supplies are traceable to the FMU level. However, it also operates mills in Russia and Guyana. Hence, the overall supply traceability to the FMU level is unclear.

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

The company commits to achieve 100% legality for natural forests by 2022 and plantations by 2025 using PEFC-endorsed MTCS or under STLVS.

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

71% - 71% of the total area of natural forest and industrial tree plantations was verified as being legally compliant by PEFC-endorsed MTCS or under STLVS.

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

The company reports that it only sources wood that is PEFC certified.

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

100% - The company reports that all supply in 2023/2024 was verified as being in legal compliance by a third party.

47. Percentage area (ha) FSC FM certified?

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

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

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

The company commits to only source from FSC-CW, PEFC-FM, and PEFC-CS.

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

787192 (71%) - The company reports that 71% (787,192 ha) area of its concessions are PEFC-certified.

52. Commitment to zero conversion of natural ecosystems?

The company commits to zero conversion of undisturbed natural ecosystems. However, it is unclear if it covers all ecosystems.

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

The company's commitment to zero conversion of undisturbed natural ecosystems also applies to its suppliers. However, it is unclear if it covers all suppliers.

54. Commitment to zero deforestation?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to zero deforestation in its own reporting. However, the commitment was made after 1 Jan 2020.

55. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation, however the commitment was made after January 2020. Also, it does not cover 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 V3-0). 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 states that it monitors deforestation via GIS satellite imagery (Sentinel-3) covering 1.06 million ha, monthly patrols on foot, and intelligence gathering by community liaison officers during local community visits. The company also reports that it detected 168 cases of encroachment activities in its operation areas between 2020 and 2023.

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?

0 (0%) - The company reports that it recorded zero illegal deforestation in 2019. However, the information is between two to five years old.

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

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

The company commits to restoring degraded areas resulting from its forest operations from 2020 onwards.

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

64. Implementing a landscape or jurisdictional level approach?

[Externally verified] Points for external verification have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018). 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 PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria. The company has also identified some rare, threatened, and endangered species in the public summaries of its FMUs and ITPs. However, in maximum, it is not in reference to the international or national system of species classification.

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

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. The company also reports planting 3.4 million trees in 2022.

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

The company commits to no hunting of all species 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 of all species also applies to its suppliers. However, it is unclear if it covers 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 protecting the natural ecosystems and plantations under its management from illegal activities applies to its suppliers. However, it is unclear if it covers all suppliers.

73. Evidence of protecting forest areas from illegal activities?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. The company also reports shreds of evidence of forest protection such as 3rd party annual surveillance, signage, regular patrolling, and inspection of satellite imagery.

74. Commitment to no use of genetically modified organisms?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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

The company's commitment to no use of genetically modified organisms applies to its suppliers. However, it is unclear if it covers 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 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to conducting High Conservation Value (HCV) assessments in its own reporting.

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

The company's commitment to conducting High Conservation Value (HCV) assessments applies to its suppliers. However, it is unclear if it covers all suppliers.

78. High Conservation Value (HCV) assessments available?

[Externally verified] The company publishes High Conservation Value (HCV) assessments in some public summaries of FMUs and ITPs. It does not cover all operations but the information is externally verified by WWF.

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

[Externally verified] The company has reported High Conservation Value (HCV) management and monitoring plans in public summaries of FMUs and ITPs. It does not cover all operations but the information is externally verified by WWF.

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

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 does not produce wood/wood fibre OR only has natural forest operations OR has not undertaken any new planting since January 2015.

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 does not produce wood/wood fibre OR only has natural forest operations OR has not undertaken any new planting since April 2015 OR if all new planting has been undertaken since November 2017 and has been covered under combined HCV-HCS assessments.

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

The company only commits to conducting environmental impact assessments.

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

The company's commitment to conducting environmental impact assessments applies to its suppliers. However, it is unclear if it covers all the suppliers.

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

[Externally verified] The company has published its social and environmental impact assessments in the public summaries of FMUs and ITPs. The environmental impact assessments (EIA) are externally verified by the Natural Resources and Environment Board (NREB), however not all assessments contain management and monitoring plans.

87. 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 does not operate in a country currently covered by Open Timber Portal.

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

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

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

2714 (8.6%) - The company reports 2,714 ha of planted area on peat. Data as of 2024.

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

The company has reported a reduction in its planted area from 3,324 ha in June 2022 to 2,714 ha in June 2024. However, the information is not externally-verified.

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

The company commits to best management practices for soils and peat.

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

The company's commitment to best management practices for soils and peat applies to its suppliers. However, it is unclear if the commitment covers all the 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 PEFC FM certification (PEFC ST 1003:2018) 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?

The company commits suppliers to Reduced Impact Logging (RIL) techniques. However, it is unclear if it covers all suppliers.

97. Evidence of implementing reduced impact logging practices?

Limited, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria. The company also reports that RIL harvesting techniques are mandatory, and permission to enter the coupe will not be issued unless all RIL conditions have been complied with.

98. Commitment to zero burning?

The company commits to zero burning in public summaries of some ITPs. However, it does not cover all operations.

99. Commitment to zero burning applies to all suppliers?

100. Evidence of fire monitoring and management?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC. The company also reports that it provides fire-fighting training to its employees.

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

0 (0%) - The company states that it has recorded zero cases of fire in 2021.

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

0 (0%) - The company has recorded zero cases of fire in its major supplier's operations. However, it does not cover all suppliers.

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

104. GHG emissions intensity?

The company reports that in 2022, its GHG emissions intensity was 0.10 tCO2eq/m3. This figure includes scope 1 and scope 2 emissions.

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 has natural-forest based operations OR does not produce wood/wood fibre.

106. GHG emissions from land use change in supplier operations (scope 3)?

107. Progress towards commitment to reduce GHG emissions intensity?

The company reports that its GHG emissions intensity, reported as tCO2eq/m3 timber product output, has decreased from 0.10 in 2022 to 0.09 in 2023.

108. Methodology used to calculate GHG emissions?

The company uses the GHG Protocol Corporate Accounting Reporting Standard to calculate GHG emissions.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

110. Water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

111. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

114. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

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

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

117. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways using buffer zones.

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

The company publishes maps of the buffer zones located inside FMUs and ITPs. The information is externally verified by the Natural Resources and Environment Board (NREB).

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

The company commits to minimise the use of chemical fertilisers and pesticides.

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

The company commits only some suppliers to minimise the use of chemical fertilisers and pesticides.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

The company commits to not use World Health Organisation (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 commits only some suppliers to no use of World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits to not use Stockholm and Rotterdam Convention chemicals.

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

The company's commitment to not use of Stockholm and Rotterdam Convention chemicals applies to its suppliers. However, it is unclear if it covers all the suppliers.

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

The company reports the average rate of herbicide application as 5.8l/ha (glyphosate) and 96.9g/ha (metsulfuron) and for fertilisers as 81.8 kg/ha (Data as of 2021).

127. Implementation of commitment to minimise inorganic fertiliser usage?

128. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC. The company also reports that it commissioned an integrated pest management approach in some of its LPFs in 2022.

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 PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria. The company also reports that it complies with the disposal requirements for scheduled wastes under Environmental Quality (Scheduled Waste) Regulations 2005. Waste items generated from individual operating units that are classified under scheduled waste are contained in labelled containers and stored in the designated scheduled waste storehouse. However, the information is between two to five years old.

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to human rights in its Human Rights Policy.

131. Commitment to human rights applies to all suppliers?

The company commits all suppliers to the Universal Declaration of Human Rights.

132. Progress on human rights commitment ?

The company reports that it conducted an awareness programme on Human Rights Policy in 2021 and 2022. However, the information is self-reported and between two to five years old.

133. Commitment to respect Indigenous Peoples' and local communities' rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to respecting Indigenous and local communities' rights in its own reporting.

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

The company commits all suppliers to the UN Declaration on the Rights of Indigenous Peoples.

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

The company commits to respect legal and customary land tenure rights.

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

The company commits all suppliers to respect legal and customary land tenure rights.

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

The company commits to respecting free, prior, and informed consent (FPIC) across all operations.

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

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

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

The company provides limited details of its FPIC process.

140. Examples of local stakeholder engagement to prevent conflicts?

The company reports having a dedicated native liaison team and "Community Relationship Committees" with responsibility for community engagement. However, no further detail could be found.

141. Details of process for addressing land conflicts available?

The company reports a series of steps taken to resolve land conflicts.

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)?

This indicator is disabled as the company reports that it does not operate in a country currently covered by Open Timber Portal.

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

The company commits to enabling the sustainable use of non-timber forest products (NTFPs) by local communities.

145. Commitment to provide essential community services and facilities ?

The company commits to providing essential services and facilities to communities.

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

The company reports providing essential services to local communities, including establishing a clinic and distributing food. Additionally, it donated a bio-safety cabinet to a hospital and extended aid to victims of fires. However, most of the information provided is self-reported and between two to five years old.

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

The company commits to providing business/work opportunities for local communities.

148. 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 does not operate in a country currently covered by Open Timber Portal.

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 V3-0). 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?

The company commits all suppliers to three Fundamental ILO Conventions only.

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

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC.

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

The company commits to eliminating gender-related discrimination with regard to employment.

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

The company commits all suppliers to eliminate gender-related discrimination with regard to employment.

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

The company reports that it provides training to supervisors, line managers, management and any other designated staff (i.e. HR) to manage overall activities like employee feedback, grievances and harassment cases when they occur. However, the information is self-reported and between two to five years old.

155. Percentage or number of temporary employees?

This indicator is disabled as the company reports that it does not have any temporary employees OR only trades wood/wood fibre.

156. Reports gender balance of employees?

29% - The company reports that it has 29% of women employees (Data as of 2023).

157. Commitment to pay a living wage?

The company only commits to paying minimum wage.

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

The company's commitment to paying minimum wage applies to all suppliers.

159. Progress on commitment to pay a living wage?

The company reports that the average wage of all workers in its Sarawak downstream operations and Refor nurseries and offices is 17% and 5% above the current level required by the Minimum Wage Order 2020 respectively. However, this does not cover all employees and information is self-reported.

160. Reporting of salary by gender?

The company reports the percentage of salaries and wages of women supervisors and workers working in upstream and downstream operations with respect to their male counterparts. However, the information does not cover all operations and is between two to five years old.

161. Commitment to address occupational health and safety?

The company commits to addressing health and safety at work in reference to the ILO Code of Practice on Safety and Health in Forestry work.

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

163. Provision of personal protective equipment and related training?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percentage of company landbank certified by PEFC. The company also states that it provides personal protective equipment (PPE) related training to its workforce.

164. Time lost due to work-based injuries?

0.03 - The company reports its 2023 lost time injury rate as 0,03% of total man hours worked.

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

0 - The company reports that it recorded zero cases of fatalities as a result of work-based accidents in 2020, 2021, and 2022.

166. Commitment to support smallholders?

This indicator is disabled as the company reports that it does not have smallholder suppliers.

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

This indicator is disabled as the company does not source from smallholder suppliers.

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

This indicator is disabled as the company does not source from smallholder suppliers.

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

The company describes the process used to assess and engage suppliers on compliance with its policies. However, only limited details are available.

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

100% - The company reports that in 2022, 100% of its suppliers were assessed internally by its timber procurement PIC on compliance with company and legal requirements. However, this information is not externally verified.

171. Suspension or exclusion criteria for suppliers?

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

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

173. Proportion of supply from suppliers that is verified as deforestation and/or conversion-free (DCF)?

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and prohibition of corruption.

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

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

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

The company reports that it organised an awareness programme on Anti-Bribery Anti-Corruption Policy in 2021 and April 2022. It has also established an internal system to report, investigate, address, and stop any occurrence of corruption, misdeeds, and other unlawful activities that go against its business ethics, as the company has a zero-tolerance policy for such matters. The information is not externally verified.

177. 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 does not operate in a country currently covered by Open Timber Portal.

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

The company reports that the group tax department headed by a group tax officer is responsible for the management of tax. However, no tax strategy or policy could be found.

179. 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 does not operate in a country currently covered by Open Timber Portal.

180. Whistleblowing procedure?

The company has its whistleblowing policy which includes ways how whistleblowers can report unethical conduct and how they are protected.

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

The company has a grievance or complaints system which is open to all stakeholders.

182. Details of complaints and grievances disclosed?