Sumitomo Forestry

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

The company commits to the multiple dimensions of sustainability covering both social and environmental issues through its code of conduct.

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

The company's commitment to multiple dimensions of sustainability covering both social and environmental issues also applies to its suppliers.

3. High-level position of responsibility for sustainability?

The company has an Environmental Management Officer who is the General Manager of the Sustainability Department.

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

The company's sustainability committee consists of a President and Representative Director who has responsibility for sustainability.

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

2 - The company has 2 women in its executive officer team.

6. Percentage or number of women board members?

2 - The company reports that it has two women on its 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 UNGC and WBCSD.

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

The company reports that it works together with everyone at NPOs and NGOs to confront social and environmental challenges such as biodiversity and regional development. It has also collaborated with the government for contributing to reforestation and has teamed up with the Japan International Cooperation Agency (JICA) to engage in forest management activities with Dien Bien Province in Vietnam, including forest conservation and planting of deforested areas.

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 report has been prepared in accordance with GRI standards and has also submitted the Forest, Climate Change and Water Security CDP Questionnaire for the year 2022.

11. Climate risks assessment available?

The company reports a climate risk assessment which includes actual, and potential impacts of climate change on the company, metrics, targets and processes used to assess or manage climate risks and responsibilities. However, the information is not externally verified.

12. Natural capital assessment available?

The company has identified dependencies on natural capital, but has not quantified it or has not set actions.

13. Lists countries and operations?

Log Harvesting- New Zealand, Papua, New Guinea, and Indonesia; Processing- New Zealand, Indonesia, Vietnam, and Japan.

14. Lists countries sourcing from?

The company reports region-wise data on the percentage of sourcing supply i.e. Europe 31.7%, Oceania 17.1%, South East Asia 23.1%, East Asia 6.3%, South America 5.6%, Russia 0.7% and North America 15.6%. However, country-wise data was not reported.

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

281224 - The company reports the total area of natural forest designated for wood/wood fibre production as 20,799 ha, the total area of forest plantation as 251,577 ha, and the area of plantation within outgrower schemes as 8,848 ha. Partial points have been awarded as the total has been calculated from various approximate figures.

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

20799 - The company has not reported an overall figure for all of its natural forests designated for wood/wood fibre production. Partial points have been awarded as the total has been calculated from various approximate figures.

17. Total area of forest plantation (ha)?

251577 - The company has not reported an overall figure for all of its forest plantations. Partial points have been awarded as the total has been calculated from various approximate figures.

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

8848 - The company reports that it has 8,848 ha of natural forest within outgrower schemes.

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

0

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

The company reports that protected areas account for over 20% of its operating land. However, no clear figures were reported.

21. Area of Intact Forest Landscape (ha)?

0

22. Number of Forest Management Units (FMUs)?

7 - The company reports that it has a total of 7 FMUs, three under Open Bay Timber Ltd and four under Tasman Pine Forests Ltd. However, it is unclear if it covers all operations.

23. Maps of forest management units (FMUs)?

The company only reports a static map of FMUs located within the Tasman Pine Forests Ltd. However, it is unclear if this information covers the company's entire operations.

24. Forest management plans available for all FMUs?

The company has reported forest management plans for some but not all FMUs.

25. Monitoring of forest management plan implementation available?

[Externally verified] The company has a monitoring plan only for some forest management plans.

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 doesn't operate in a geography 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 doesn't operate in a geography 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 doesn't operate in a geography currently covered by Open Timber Portal.

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

30. Number of company owned sawmills?

1 - The company has 1 sawmill. However, it is unclear if this information covers the company's entire operations.

31. Names and locations of company owned sawmills?

The company reports the name and location of only1 sawmill. However, it is unclear if this information covers the company's entire operations.

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

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

33. Names and locations of company-owned pulp and paper mills?

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

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

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

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

36. Number of third party supplying mills?

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 reports that it has a due diligence procedure to trace raw materials to the country of origin.

40. Percentage of supply traceable to country of harvest?

41. Procedures to trace raw materials to FMU level?

The company reports the procedures to trace raw materials to the FMU level.

42. Percentage of supply traceable to FMU level?

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

The company reports that approximately 48,000 ha forests in Japan are 100% SGEC (Sustainable Green Ecosystem Council) certified. However, no time-bound targets for overseas plantations could be found.

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

[Externally verified] 82.75% - The company has reported the total percentage of areas verified as being in legal compliance by a third party (SGEC, FSC FM/COC, CW/FM, and PHPL certified). Data as of 2021.

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

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

The company reports that 97.8% of wood supply was categorised by the company as sustainable. However, the company's definition of 'sustainable' wood does not confirm that it has been verified as being in legal compliance by a third party.

47. Percentage area (ha) FSC FM certified?

17.86% - The company reports that Open Bay Timber (OBT) has 12,854 ha of FSC-FM-certified area and Tasman Pine Forest (TPF) has 36,599 ha of FSC-FM-certified area out of a total managed area of 276,892 ha.

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?

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

47736 (17.23%) - The company reports that 47,736 ha of the area is SGEC-certified out of the total managed area of 276,892 ha.

52. Commitment to zero conversion of natural ecosystems?

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

54. Commitment to zero deforestation?

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

55. Commitment to zero deforestation applies to all suppliers?

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

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

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

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

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?

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?

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 making this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2 EN) and the PEFC International Standard (PEFC ST 1003:2018). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC/PEFC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

65. Biodiversity policy?

The company commits to the conservation of biodiversity. However, it is unclear if this commitment applies to all forestry operations.

66. Biodiversity policy applies to all suppliers?

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

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements do not fully meet the SPOTT indicator criteria. The company also states that it has a Red Data Book which includes flora and fauna at threat of extinction which may exist in company-owned forests.

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria.

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

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

71. Commitment to protect forest areas from illegal activities?

The company has a commitment to prevent illegal logging. However, it does not commit to protecting forest areas from other illegal activities.

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

The company's commitment to preventing illegal logging also applies to suppliers. However, it does not commit to protecting forest areas from other illegal activities.

73. Evidence of protecting forest areas from illegal activities?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria.

74. 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.

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

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to conducting High Conservation Value assessments in its reporting.

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

78. High Conservation Value (HCV) assessments available?

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

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

The company commits to apply the HCS Approach, as defined by the HCS Approach Toolkit.

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

82. High Carbon Stock (HCS) assessments available?

83. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

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

The company makes this commitment through SVLK certification requirements. Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria.

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

86. Social and environmental impact assessments (SEIAs) available, and associated 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 doesn't operate in a geography 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)?

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

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

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

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

Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certification as the requirements do not fully meet the SPOTT indicator criteria. The company states that it has also continued to develop the infrastructure technology necessary to manage peatlands since launching the business. It aims to establish management technology that can be broadly expanded in rainforest peatlands throughout Indonesia and the rest of the world.

95. Commitment to reduced impact logging?

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

97. Evidence of implementing reduced impact logging practices?

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

98. Commitment to zero burning?

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 states that it is working with various agencies to continuously conduct awareness-raising activities about fire in the local community, provide training and constructed a fire belt that was six meters in width and 20 km in total length.

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

0 - The company only states that it has recorded zero cases of fire in one of its subsidiaries. However, no information on fire in the company's FMU could be found.

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

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

The company commits to reducing GHG emissions (Scope 1 and 2) by 21% by 2030. However, the target is not intensity-based.

104. GHG emissions intensity?

The company reports a GHG emission intensity of 10,206,000 t/CO2e in 2021. However, it is unclear if it covers all forestry operations.

105. GHG emissions from land use change in company's own operations (scope 1)?

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

107. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company has reported the GHG emission intensity for 2019 (369,785), 2020 (370,526), and 2021 (370,772). However, the intensity figures have not improved from the previous year. The information is externally verified by KPMG.

108. Methodology used to calculate GHG emissions?

The company uses the GHG Protocol methodology to calculate GHG emissions.

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

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

110. Water use intensity?

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

111. Progress towards commitment on water use intensity?

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

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

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

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

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

114. Treatment of pulp and paper mill effluent?

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

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

[Externally verified] The company reports that it treats wastewater biologically to control the amount of water necessary for the dilution of factory wastewater. This information is externally verified by KPMG.

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

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

117. Commitment to protect natural waterways through buffer zones?

The company has a riparian management manual for the preservation of natural waterways. However, it does not cover all operations.

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

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

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

The company commits to minimise the use of chemicals but does not mention chemical fertilisers or pesticides.

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

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

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

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

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

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

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

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

The company has provided a list of chemicals used in Japan and overseas plants. However, it is unclear if this information covers all operations.

127. Implementation of commitment to minimise inorganic fertiliser usage?

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

128. Integrated Pest Management (IPM) approach?

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

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

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements do not fully meet the SPOTT indicator criteria. The company also reports that it has established a set of industrial waste management regulations covering appropriate disposal, reduction, recycling and reuse of industrial, as well as manufacturing regulations stipulating standards essential for production activities.

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to respecting human rights with reference to the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work.

131. Commitment to human rights applies to all suppliers?

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

132. Progress on human rights commitment ?

[Externally verified] The company conducts an internal sustainability survey every year at each of the group companies to review the sustainability initiatives including human rights. It also provides training to 11,760 employees and created an impact analysis map for its supply chain. Information is externally verified.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to respecting the rights of indigenous and local people. However, it does not refer to the UN Declaration on the Rights of Indigenous Peoples or to the ILO Indigenous and Tribal Peoples Convention.

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

The company's commitment to respecting indigenous and local communities' rights also applies to its suppliers.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0) AND SVLK. 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 certification and SVLK certification.

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

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

The company commits to free, prior, and informed consent.

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

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

140. Examples of local stakeholder engagement to prevent conflicts?

The company reports that it has engaged with NGOs and other external stakeholders to engage in local feedback sessions and implement local grievance mechanisms. Partial points have been awarded as information is limited and not externally verified.

141. Details of process for addressing land conflicts available?

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

The company states that it empowers women by promoting the involvement of female employees, supporting the workstyles, appointing women to managerial posts, and mentoring system to encourage growth. However, information is limited and not externally verified.

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 doesn't operate in a geography currently covered by Open Timber Portal.

144. Commitment to enable 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 the community.

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC. The company also reports that its subsidiary Open Bay Timber (OBT) has constructed roads and bridges, operates medical clinics and community marketplaces for residents and employees, collaborates in the construction of schools and works in numerous other ways to further stimulate the local economy and community.

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

The company reports that it provides business/work opportunities for local communities. However, no clear commitment could be found.

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 doesn't operate in a geography 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 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to this in its own reporting.

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

The company commits suppliers to Fundamental ILO Conventions and Free and Fair Labour Principles.

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by either FSC or PEFC, whichever is highest.

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's commitment to eliminating gender-related discrimination with regard to employment applies to all suppliers.

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

[Externally verified] The company provides training to employees on preventing discrimination and harassment and having a complaints system that specifically includes gender discrimination or harassment. In 2021, 11,760 employees took training classes.This information is externally verified.

155. Percentage or number of temporary employees?

4688 (21.4%) - The company reports the number of temporary employees as 4,688.

156. Percentage or number of women employees?

23.1% - The company has reported the percentage of female employees (non-consolidated) within the company (23.1%), in subsidiary companies (domestic subsidiary) in Japan (34.6%) and subsidiary companies overseas (28.2%) for 2022.

157. Commitment to pay a living wage?

The company only commits to paying minimum wages. However, no information on living wage could be found.

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

The company only commits to minimum wages that apply to all suppliers.

159. Progress on commitment to pay a living wage?

160. Reporting of salary by gender?

The company reports average annual salary by gender (non-consolidated). However, it does not cover all operations.

161. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) 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 has its own commitment to address occupational health and safety. However, no reference to the ILO Code of Practice on Safety and Health in Forestry Work was found.

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 percent of company landbank certified by PEFC.

164. Time lost due to work-based injuries?

0.19 - The company reports a lost-time injury frequency rate as 0.19 (Non-Consolidated). However, it is unclear if it covers all operations.

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

2 - The company reports 2 occupational injuries in 2021. However, it is unclear if this covers all operations.

166. Commitment to support smallholders?

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

[Externally verified] The company reports that it helps local communities to achieve FSC certification and provided 540,000 free seedlings in the fiscal year 2021. However, the information is limited and externally verified.

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

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

The company reports that it carries out due diligence on timber procurement to ensure that the procurement is performed in a sustainable manner.

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

100% - The company reports that all its timber suppliers were surveyed in 2021. However, the information is self-reported.

171. Suspension or exclusion criteria for suppliers?

The company reports suspending contracts with suppliers who did not meet the procurement standards and whose sustainability could not be confirmed through repeated dialogues.

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

The company had a target for 2021 to achieve its goal of handling 100% sustainable timber and timber products to contribute to halting deforestation. However, clear KPIs/milestones were not reported.

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

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and prohibition of corruption.

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

The company commitment to ethical conduct and prohibition of corruption applies to all suppliers.

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

The company states that it provides training, introduced common tools such as a sales commission checklist to help prevent bribery, and conducts appropriate due diligence of new business partners on corruption status. However, 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 doesn't operate in a geography currently covered by Open Timber Portal.

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

The company has reported its tax strategy. However, only limited details 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 doesn't operate in a geography currently covered by Open Timber Portal.

180. Whistleblowing procedure?

The company has a whistleblowing mechanism but does not provide a flowchart or clear description of the steps taken.

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

The company has a grievance mechanisms across its operations which is accessible to both internal and external stakeholders.

182. Details of complaints and grievances disclosed?