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 expects its suppliers to comply with commitments published in the sustainable forestry policy. However, it is unclear if it applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has Chief Operating Officer, Chief Forester and Sustainability Officer having high-level position 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 either privately owned or does not have a Board of Directors.

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

3 - The company has reported that it has three women on the senior management team.

6. Percentage or number of women board members?

This indicator is disabled as the company reports that it is either privately owned or 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 the Borneo Forestry Cooperative. This is externally verified.

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

The company has contributed to a review of the PEFC Endorsed MTCS's MC&I SFM standard, it sits on Sarawak Timber Association committees assisting stakeholders with certification and developing Occupational Safety and Health forestry programme for the industry, and it also collaborates with WWF on a river bank restoration project.

9. Sustainability report published within last two years?

The subsidiary Lingui Group's latest sustainability report was published in 2020, it is a long-standing member of the Samling Group that exclusively covers the company's timber activities and operations.

10. Reports through standardised reporting systems?

The subsidiary Lingui Group's latest sustainability report was published in 2020, it is a long-standing member of the Samling Group that exclusively covers the company's timber activities and operations and follows GRI standards while reporting its sustainability performance. However, only partial points were awarded as the report is published by the subsidiary.

11. Climate risks assessment available?

The company has published a climate risk assessment. The assessment is not externally verified.

12. Natural capital assessment available?

13. Lists countries and operations?

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

14. Lists countries sourcing from?

The company sources from Malaysia, China, Vietnam, Indonesia, Brazil, Russia and Guyana.

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

726152 - The company reports it has a total area of 1,145,392 ha out of which 726,152 ha is operable (as of 29 May 2020).

16. Total area of forest plantation (ha)?

32643 - The total planted area is 32,643 ha and the company has no outgrower schemes.

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

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

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

30000 - The company reports it has an approximately 30,000 ha area unplanted (as of June 2021).

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

226537 - The company reports having 226,537 ha as HCV, conservation area, and the protected area within its license areas.

20. Area of Intact Forest Landscape (ha)?

This indicator is disabled as the company has reported or informed ZSL that it doesn't have any intact forest landscapes within its landbank.

21. Number of Forest Management Units (FMUs)?

10 - The company has 10 Forest Management Units (FMUs) and operates six Licenses for Planted Forest (LPFs) in Sarawak.

22. Maps of forest management units (FMUs)?

Some of the company's concession maps are available on Global Forest Watch (GFW) and maps of three of the FMUs are available in their respective public summaries. Partial points were awarded as it is unclear if this covers all estates.

23. Forest management plans available for all FMUs?

Forest Management Plans for only three Forest Management Units (FMUs) are available on the website.

24. Monitoring of forest management plan implementation available?

The company reports that all FMUs & LPFs are required to have quarterly EMRs and monitoring information is available for three FMPs only. It is unclear whether these three FMUs cover all FMUs or only certified areas. Hence awarded only partial points.

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.

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

29. Number of company owned sawmills?

2 - In 2022, the company reports it operates one sawmill in Malaysia and one in Guyana that is currently not operating.

30. Names and locations of company owned sawmills?

The company has provided the coordinates and addresses of both its mills.

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.

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

In 2022, 73% of supply to the company's only operating mill is from its own operations.

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.

35. Number of third party supplying mills?

19 - In 2021, the company had 19 third-party supplying mills.

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

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

38. 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 fully meet the SPOTT scoring criteria.

39. Percentage of supply traceable to country of harvest?

100 - The company claims 100% traceability to the country of harvest as all sourcing is within the country of processing.

40. Procedures to trace raw materials to FMU level?

The company reports having 100% of log production traceable to the FMU level through Sarawak government procedures which mandate the issue of log Removal Passes.

41. Percentage of supply traceable to FMU level?

The company states that "100% of log production is traceable to FMU level thru Sarawak government procedures which mandate the issue of log Removal Passes". However, the company also owns mills in Russia and Guyana and so it is unclear what is the overall percentage traceable to FMUs.

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

The company states that it will achieve 100% third-party legality verification for natural forests by 2022 and plantations by 2025.

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

56.3% - The company states that 56.3% of its total area of natural forest and industrial tree plantation is third-party verified as a legal source, either under STLVS or PEFC/MTCS.

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

The company states that its natural forests will be certified by 2022. However, no time-bound plan to source only wood/wood fibre that is in legal compliance verified by a third party is disclosed.

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

66.6% - The company reports 66.6% of the Group's round log volume traded/processed to be certified as PEFC/MTCS-FMC, FSC-CW/COC, or STLVS in 2020.

46. Percentage area (ha) FSC FM certified?

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

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

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

The company's commitment to source from FSC-CW, PEFC-FM and PEFC-CS areas only applies to logs sourced from plantations.

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

398731 (29.5%) - The company reports that 358,592 ha of natural forest and 40,139 ha of plantation are PEFC certified out of a total landbank of 1,350,584 ha.

51. Commitment to zero conversion of natural ecosystems?

The company commits only to zero clearing of natural, undisturbed ecosystems. However, the commitment does not cover all natural ecosystems. Hence awarded only partial points.

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

The company expects its suppliers to commit to zero conversion of undisturbed natural ecosystems. However, it is unclear if the commitment covers all the suppliers. Hence awarded only partial points.

53. 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/membership.

54. Commitment to zero deforestation applies to all suppliers?

The company expects its suppliers to commit to zero deforestation. However, it is unclear if the commitment covers all the suppliers, and also the commitment was made after January 2020. Hence awarded only partial points.

55. 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 certification/membership.

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

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

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

0 (0%) - The company reports zero illegal deforestation in 2019. Data between two and five years old.

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

The company does not clearly report the amount of deforestation or ecosystem conversion recorded in supplier operations. Hence no points were awarded.

60. Commitment to restoration of deforestation/conversion?

The company only states that it is working with Sarawak Forestry Dept (FDS) in Forest Landscape Restoration and does not provide a clear commitment and cut-off date to the restoration of non-compliant deforestation.

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

62. Implementing a landscape or jurisdictional level approach?

[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.

63. Biodiversity policy?

The company only has a general statement that commits to biodiversity protection with no detail given on scope. Hence no points were awarded.

64. Biodiversity policy applies to all suppliers?

The company only has a general statement that it expects its suppliers to commit to biodiversity protection with no detail given on scope. Hence no points were awarded.

65. 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.

66. 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.

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

The company commits to no hunting of all species in its operations.

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

The company's commitment to no hunting applies to all its suppliers.

69. Commitment to protect forest areas from illegal activities?

The company is committed to protect its forest area from illegal activities.

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

The company expects its suppliers to commit to protecting forest areas from illegal activities. However, it is unclear if the commitment covers all the suppliers. Hence awarded only partial points.

71. 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.

72. Commitment to no use of genetically modified organisms?

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/membership. The company also commits to no use of genetically modified organisms in its own reporting.

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

FSC Policy for Association, PEFC International Chain of Custody Standard, and several others.

74. 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/membership. The company also has a commitment to conducting High Conservation Value (HCV) assessments in its own reporting.

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

The company expects its suppliers to commit to conduct High Conservation Value (HCV) assessments. However, it is unclear if the commitment covers all the suppliers. Hence awarded only partial points.

76. High Conservation Value (HCV) assessments available?

The company discloses three HCV assessments in six FMPs available on the website. Assessments do not cover all of the company's operations.

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

[Externally verified] The company has provided HCV management and monitoring plans in its Forest Management Plans. However, the management plans are only available for some of the company's operations.

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

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

80. High Carbon Stock (HCS) assessments available?

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

81. 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.

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

The company commits to conducting social and environmental impact assessments (SEIAs).

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

The company expects its suppliers to commit to conducting environmental impact assessments. However, it is unclear if the commitment covers all the suppliers. Hence awarded only partial points.

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

[Externally verified] The company incorporated findings of the social and environmental impact assessments in the forest management plans summaries. The environmental impact assessments (EIA) are undertaken by the Natural Resources and Environment Board (NREB) approved 3rd parties under a scope approved by the NREB.

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.

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

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

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

3344 (10%) - The company reports 3,344 ha planted areas on peat (as of June 2020).

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

The company's landbank on peat has not increased since June 2019. The company has reported the same area planted on peat in the most recent figure for June 2020. It is not externally verified. Hence awarded only partial points.

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

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

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

The company expects its suppliers to commit to best management practices for soils and peat. However, it is unclear if the commitment covers all the suppliers. Hence awarded only partial points.

92. 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.

93. Commitment to reduced impact logging?

The company commits to reduced impact logging.

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

95. Evidence of implementing reduced impact logging practices?

The company state that RIL harvesting techniques are mandatory and permission to enter Coupe will not be issued unless all RIL conditions havebeen complied with e.g. 100% enumeration & tagging of trees to be harvested. Plantation harvesting is yarder-based. However, the information is not externally verified.

96. Commitment to zero burning?

The company has provided a commitment to zero burning. However, it does not cover all company's operations.

97. Commitment to zero burning applies to all suppliers?

98. 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.

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

0 - The company recorded no account of fire in the year 2020.

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

The company reported zero fires in its major supplier's operations. However, this does not cover all of the company's suppliers.

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

102. GHG emissions intensity?

The company reports an average GHG intensity of 57kg CO2e/m3 for its natural forest operations and 29kg CO2e/m3 for its plantation operations. However, the scope of this reporting is unclear. The information is between two and five years old. Hence awarded only partial points.

103. GHG emissions from land use change?

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

104. Progress towards commitment to reduce GHG emissions intensity?

105. Methodology used to calculate GHG emissions?

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.

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.

114. Commitment to protect natural waterways through buffer zones?

The company commits to protecting natural waterways through buffer zones.

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

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

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

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

The company expects its suppliers to commit to minimising the use of chemicals, including pesticides and chemical fertilisers. However, it is unclear if the commitment covers all the suppliers. Hence awarded only partial points.

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.

119. 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.

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

The company expects its suppliers to commit to no use of World Health Organisation (WHO) Class 1A and 1B pesticides. However, it is unclear if the commitment covers all the suppliers. Hence awarded only partial points.

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

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

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

The company expects its suppliers to commit to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention. However, it is unclear if the commitment covers all the suppliers. Hence awarded only partial points.

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

The company reports in 2020 the average rate of herbicide application was 5.8l/ha (glyphosate) and 96.9g/ha (metsulfuron), and 81.8 kg/ha for fertiliser.

124. Implementation of commitment to reduce chemical usage?

125. 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.

126. 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 has reported that it also has a waste management system in place but only for certain operations.

127. 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/membership. The company also has an explicit human rights policy.

128. Commitment to human rights applies to all suppliers?

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

129. Progress on human rights commitment ?

The company reports it conducted training on the human rights policy in 2021 and 2022. Information is not externally verified.

130. 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/membership.

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

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

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

The company is committed to respecting legal and customary land tenure rights.

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

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

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

The company's commitment to free, prior, and informed consent is respected across all its operations.

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

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

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

137. Examples of local stakeholder engagement to prevent conflicts?

The company states it has a dedicated native liaison team with responsibility for community engagement but no further details are available.

138. Details of process for addressing land conflicts available?

The company has an engagement and consultation process in place to resolve conflicts and disputes in communities and the grievance procedure addresses land conflict issues.

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.

141. 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.

142. Commitment to provide essential community services and facilities ?

The company commits to contributing to local communities in a variety of ways including providing for their most basic needs – electricity, water, food, education, and infrastructure.

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

The company reports multiple examples of facilities to provide for their most basic needs – electricity, clean water, and building materials for homes, schools, and places of worship.

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

The company is committed to providing work opportunities for local communities.

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.

146. 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/membership.

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

148. 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.

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

The company has an explicit commitment to eliminate gender-related discrimination with regard to employment.

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

The company has a commitment to eliminate gender-related discrimination with regards to employment that applies to all its suppliers.

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

The company claims to provide training for supervisors, line managers, management, and any other designated staff to manage employee feedback, grievance, as well as handle harassment cases when they occur. However, the information is not externally verified.

152. Percentage or number of temporary employees?

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

153. Percentage or number of women employees?

29% - The company reports women employees represent 29% of the Group's worldwide timber-based workforce.

154. Commitment to pay a living wage?

The company states that there is a Minimum Wage Order in Malaysia and that both Guyana and Russia have similar legislation with which the company complies. However, no such commitment for the company's operations in China could be found.

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

156. Progress on commitment to pay a living wage?

The company reports that the average wage of all workers in its Sarawak downstream operations is 18.3% above the current level required by the Minimum Wage Order 2020 and the average wage in reform nurseries and offices were 10.5% above the minimum wage but this does not cover all employees.

157. Reporting of salary by gender?

The company states salaries of female supervisors in our Sarawak downstream operations are 93.8% of the level of their male counterparts and the wages of female workers in our Sarawak downstream operations are 88.8% of the level of their male counterparts. However, it is unclear if this covers all operations.

158. Commitment to address occupational health and safety?

The company has a commitment to address health and safety at work, referencing the ILO Code of Practice on Safety and Health in Forestry work.

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

160. 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.

161. Time lost due to work-based injuries?

217 - The company reports lost time due to work based injuries in forestry operations in 2020 as 217/1,000,000 man hours.

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

0 - The company reports that there were zero fatalities in its forestry operations in 2020.

163. Commitment to support smallholders?

This indicator is disabled as the company reports that it does not source wood/wood fibre from smallholders.

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

This indicator is disabled as the company reports that it does not source wood/wood fibre from smallholders.

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

This indicator is disabled as the company reports that it does not source wood/wood fibre from smallholders.

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

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

168. 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.

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

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

171. Commitment to ethical conduct and prohibition of corruption?

The company has an explicit commitment to ethical conduct and the prohibition of corruption.

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

The company has an explicit commitment to ethical conduct and the prohibition of corruption that applies to all its suppliers.

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

The company states that training on its anti-bribery policy was conducted in 2021 and 2022 but limited detail is given. Information is not externally verified.

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.

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

The company discloses who is responsible for its management of tax but no tax strategy or policy is available.

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.

177. Whistleblowing procedure?

The company has a whistleblowing policy in place in which the company provides a secured whistleblowing channel and also details how it safeguards the informant.

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

The company has provided its grievance process flowchart on its webpage and a conflict resolution process open to all stakeholders.

179. Details of complaints and grievances disclosed?