Samling Group

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

The company has a Responsible Forest Management Policy that applies to all its operations.

2. Sustainable forestry policy or commitment 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 privately owned and/or does not have a Board of Directors.

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

3 - The company states that it has three women in its senior management team.

6. Percentage or number of women board members?

This indicator is disabled as the company reports that it is privately owned and/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?

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

The company states it collaborates with WWF, ITTO, and Heart of Borneo, but gives no examples of activities.

9. Sustainability report published within last two years?

10. Reports through standardised reporting systems?

11. Climate risks assessment available?

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 states it sources from China, Vietnam and Indonesia, however it is unclear if this covers all countries the company sources from.

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

726152 - The company reports it has a total of 1,145,392 ha area 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 (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 approximately 30,000 ha area unplanted.

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

226537 - The company reports that "as of 21 May 2021 there were 226,537 ha HCV, conservation and protected area within our licence 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 reports it has 10 FMUs and it also operates six Licences for Planted Forest (LPF) in Sarawak.

22. Maps of forest management units (FMUs)?

Some of the company's concession maps are available on GFW.

23. Forest management plans available for all FMUs?

The company has only provided the Forest Management Plans for its certified areas in Sarawak region.

24. Monitoring of forest management plan implementation available?

Points for external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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?

The company reports that it one active sawmill in Bintulu and one inactive sawmill in Miri however it is unclear if this covers all mills as the company reports 'downstream' operations in Russia and Guyana.

30. Names and locations of company owned sawmills?

The company has provided the coordinates and addresses of its all sawmills in Sarawak only.

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

This indicator is disabled as the company reports that it doesn't 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 doesn't own pulp or paper mills.

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

The company's sawmills in Sarawak source 46.9% of its supply from its own FMUs. However, it is unclear if this covers all of the supply.

34. Reports total volumes (or percentages) sourced by company-owned pulp and paper mills that come from company's own operations and/or third-parties?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

35. Number of third party supplying mills?

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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). As the Standard's requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC CoC certification.

39. Percentage of supply traceable to country of harvest?

100 - The company states that '""one of our mills imports logs from other countries for processing"".

40. Procedures to trace raw materials to FMU level?

The company state that ""100% of log production is traceable to FMU level thru 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". The company used a Log Tracking System to ensure all supply is traceable to FMU, mill and specific tree. However, the company also owns mills in Russia and Guyana and so it is unclear what the overall precentage traceable to FMUs is.

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 forest by 2022 and for plantations by 2025.

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

56% - The company states that 56.3% of its total area of natural forest and industrial tree plantation is 3rd party verified as 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?

67% - The company reports that in 2020, 66.6% of the Group's round log volume traded/processed was certified as PEFC/MTCS-FMC, FSC-CW/COC or STLVS.

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)?

398191 (20%) - The company reports that 241,056 ha of natural forest and 39,666 ha plantation are PEFC certified out of a total landbank of 1,425,015 ha.

51. Commitment to zero deforestation or zero conversion of natural ecosystems?

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

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification.

53. Criteria and cut-off date for defining deforestation?

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

54. Evidence of monitoring deforestation?

55. Evidence of monitoring deforestation in supplier operations?

56. Amount of illegal/non-compliant deforestation recorded?

0 (0%) - The company reports zero illegal deforestation in 2019.

57. Amount of illegal/non-compliant deforestation recorded in supplier operations?

58. Commitment to restoration of non-compliant 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.

59. Commitment to restoration of non-compliant deforestation/conversion applies to all suppliers?

60. Implementing a landscape or jurisdictional level approach?

Points for external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

61. Commitment to biodiversity conservation?

The company has provided a commitment to biodiversity conservation.

62. Commitment to biodiversity conservation applies to all suppliers?

The company has provided a commitment to biodiversity conservation that applies to all its suppliers.

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

The company has identified a species of conservation concern, disclosed in the public summaries. Points for external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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

Points for external verification have been awarded on the basis of the company's PEFC certified landbank/volume. In addition, the Company states that it has identified and protected river buffer zones and carried out regular patrols inside FMUs.

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

The company is committed to no hunting in its operational areas.

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

The company has provided the commitment to no hunting that applies to all its suppliers.

67. Commitment to protect forest areas from illegal activities?

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

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

69. Evidence of protecting forest areas from illegal activities?

Points for external verification have been awarded on the basis of the company's PEFC certified landbank/volume.

70. Commitment to no use of genetically modified organisms?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership. The company also makes this commitment in its Responsible Forest Management Policy.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification.

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

The company has its own commitment and also makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership.

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

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

74. 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.

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

[Externally verified] The company has provided the HCV management and monitoring plans in the Forest Management Plans and are reviewed by stakeholders including the Sarawak Forestry department & WWF. However, the management plans are only available for some of the company's operations.

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

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

78. High Carbon Stock (HCS) assessments available?

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

The company is committed to conduct social and environmental impact assessments.

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

81. 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.

82. 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.

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

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

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

3344 - The company reports 3,344 ha planted area on peat.

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

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

The company makes this commitment.

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

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

[Externally verified] The company state that "In our tree plantations, slopes of 35o and more are not planted and are designated as Special Management Zones (SMZ) and set aside for protection as conservation areas".

90. Commitment to reduced impact logging?

The company is committed to reduce the impact logging.

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

92. Evidence of implementing reduced impact logging practices?

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

93. Commitment to zero burning?

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

94. Commitment to zero burning applies to all suppliers?

95. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's PEFC certification.

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

0 - The company states that in 2019 there were no fires recorded in the natural forest area. However, in ITP several minor fires were recorded. Out of them, one fire incident causes a loss of 21.3 ha of the planted area. In 2020, no fires were recorded.

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

The company reported 0 fires in its major supplier's operations, however this does not cover all of the company's suppliers.

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

99. 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 and whether it only covers transport emissions is unclear.

100. GHG emissions from land use change?

101. Progress towards commitment to reduce GHG emissions intensity?

102. Methodology used to calculate GHG emissions?

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

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

104. Water use intensity?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

105. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

106. Time-bound commitment to improve water quality (BOD and COD)?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

107. Progress towards commitment on water quality (BOD and COD)?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

108. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

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

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

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

111. Commitment to protect natural waterways through buffer zones?

The company is committed to protect natural waterways through buffer zones.

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

The company states that 100% as River Buffer Zones are mandatory & specified in the EIA and are monitored by Third-party CB surveillance audits, mandatory EMRs, or ECAs. However, no document for the third-party verification could be found.

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

The company has an explicit commitment to minimise the use of pesticides within the company's operation.

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

The company has an explicit commitment to minimise the use of pesticides that applies to all its suppliers.

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

This indicator is disabled as the company reports that it doesn't own pulp or paper mills.

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

The company is committed to no use of World Health Organisation (WHO) Class 1A and 1B pesticides in its operations.

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

The company is committed to no use of World Health Organisation (WHO) Class 1A and 1B pesticides that apply to all its suppliers.

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

The company is committed to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention.

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

The company is committed to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention that applies to all its suppliers.

120. 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 for fertiliser was 81.8 kg/ha.

121. Implementation of commitment to reduce chemical usage?

122. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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

Points for external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

124. Commitment to human rights?

The company has its own commitment and also makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership.

125. Commitment to human rights applies to all suppliers?

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

126. Progress on human rights commitment ?

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

The company has its own commitment and also makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership.

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

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

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

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

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

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's PEFC CoC certification.

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

The company has provided the commitment to Free, prior, and informed consent is respected across all its operations.

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

The company has provided the commitment to Free, prior, and informed consent is respected across all its operations as well as its suppliers.

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

134. 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 futher details are given.

135. Details of process for addressing land conflicts available?

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

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

137. 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.

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

The company has a commitment to enable sustainable use of non-timber products by local communities (NTFPs).

139. Commitment to provide essential community services and facilities ?

The company is committed to provide essential community services and facilities to the local people where they operate.

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

The company has provided multiple examples of facilities and/or services that have been provided to communities such as generated set and wiring for electricity, water pipes, or mini-hydro dam for water, site leveling for agriculture, and provide financial assistance and transportation arrangement for the Schools. However, the information is not externally verified.

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

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

142. 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.

143. 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) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification.

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

Points for external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

146. 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.

147. 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.

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

The company provides training to its employees and also has a communication and complaints system that specifically includes gender discrimination or harassment. However, the information is not externally verified.

149. Percentage or number of temporary employees?

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

150. Percentage or number of women employees?

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

151. Commitment to pay at least minimum wage?

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

152. Commitment to pay at least minimum wage applies to all suppliers?

153. Progress on commitment to pay at least minimum 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 Refor nurseries and offices was 10.5% above the minimum wage but this does not cover all employees.

154. 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.

155. 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.

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

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). 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.

157. Provision of personal protective equipment and related training?

Points for external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

158. Time lost due to work-based injuries?

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

159. 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.

160. Commitment to support smallholders?

This indicator is disabled as the company reports that it doesn't source wood/wood fibre from smallholders.

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

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

162. Percentage of outgrower scheme and/or independent smallholders involved in programme?

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

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

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

165. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004). As the Standard's requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC CoC certification.

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

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

168. Commitment to ethical conduct and prohibition of corruption?

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

169. 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.

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

The company states that "Shearn Delamore, a well known Malaysian law firm, conductied webinars re Anti-Corruption & Anti-Bribery Laws on the 21 July 2020 & 19 Aug 2020".

171. 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.

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

173. 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.

174. Whistleblowing procedure?

The company has a whistle-blowing policy in place in which the company provides a secured whistleblowing channel and also how they safeguard the informant.

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

The company has provided its grievance process on its webpage by the flowchart. However, it is not clear how a grievance form is made available to internal and external stakeholders.

176. Details of complaints and grievances disclosed?