Suzano SA

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

The company has different policies which cover multiple commitments of sustainability across the company's operations covering both social and environmental issues.

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

Only few of the commitments reported by the company for sustainability apply to its suppliers.

3. High-level position of responsibility for sustainability?

The company reports to have a chief sustainability officer who is not a member of board.

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

The company reports to have 10 board members out of which 3 members have a role in the Sustainability and Strategy Committee of the company.

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

0 - The company reports 7 members in the senior management/executive team but the gender balance is not directly reported by the company.

6. Percentage or number of women board members?

2 - The company reports 10 members in the board of directors out of which two are women.

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] FSC, PEFC, UNGC. The company also reports the different membership of associations on its website.

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

Alliance for the Restoration of the Amazon, Project with The Nature Conservancy (TNC) which involves environmental education efforts and activities to qualify local producers, such as the restoration of springs and support for government preservation policies, With the Laboratory of Ecology and Forest Restoration and the Laboratory of Tropical Forestry, both from the University of São Paulo (USP), located in Piracicaba (São Paulo state), the company has maintained a technical partnership since the beginning of its Restoration Program, in the 1990s, seeking to improve methodologies, partnerships to work on the selection of species and other issues of relevance to the management of the topic.

9. Sustainability report published within last two years?

Sustainability Report for 2019 is published by the company.

10. Reports through standardised reporting systems?

The company has prepared the Sustainability Report 2019 in accordance with the GRI standards and the same is published on the GRI database.

11. Climate risks assessment available?

The company reports that it is committed to reporting its practices and indicators in line with the recommendations of the TCFD and to continue advancing on this path.

12. Natural capital assessment available?

13. Lists countries and operations?

The company lists the countries and operations on its website.

14. Lists countries sourcing from?

The company only mentions that domestic suppliers come from all states in Brazil, while international suppliers include suppliers from all continents. The countries of sourcing from international suppliers are not reported.

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

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

16. Total area of forest plantation (ha)?

1,875,700 - The company has reported the area of plantation as 1,875,701 ha on its website. Data as of 2019.

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

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

133,539 - The company reports total areas for development by type of land use as 133,538.7ha.

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

956,488 - The company reports the total conservation area as 898,488 ha on its indicators webpage and total HCV area as 58,000 ha in the Sustainability Report 2019.

20. Area of Intact Forest Landscape (ha)?

21. Number of Forest Management Units (FMUs)?

5 - The company's website and FSC database report 5 FMUs.

22. Maps of forest management units (FMUs)?

The company mentions the shapefile for its forest base with names and the FSC reports of the company mention the coordinates for 3 FMU's out of the total 5 FMU's. However, the estate boundaries are not reported.

23. Forest management plans available for all FMUs?

The forest management plans are available for all Forest Management Units of the company.

24. Monitoring of forest management plan implementation available?

[Externally verified] The monitoring of forest management plan implementation is available throughout the FSC reports and the forest management plans of the respective FMUs of the company.

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?

This indicator is disabled as the company reports that it doesn't own sawmills.

30. Names and locations of company owned sawmills?

This indicator is disabled as the company reports that it doesn't own sawmills.

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

8 - The company reports to own 10 mills in total out of which 8 mills are dedicated to pulp and paper.

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

The company reports the names and locations (in shapefile of Brazil) of all pulp and paper mills.

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

This indicator is disabled as the company reports that it doesn't own sawmills.

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?

35. Number of third party supplying mills?

The company reports that in 2019 it had 10,255 suppliers, while in its database, there were 35,964 registered suppliers. Both figures consider headquarters and branch. These numbers include international suppliers, individuals, legal entities, landowners, public agencies, carriers, among others. Separate figures of supplying mills are not reported.

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/or 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) 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.

39. Percentage of supply traceable to country of harvest?

100 - The company reports that 100% of its products are with traceable origin.

40. Procedures to trace raw materials to FMU level?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004) 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.

41. Percentage of supply traceable to FMU level?

The company states that 100% of wood from supplying factories/operations is traceable to the level of forest management unit.

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

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

87.22% - The company reports that 87.22% of its operational area is FSC and PEFC/CERFLOR certified.

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

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

The company reports that 100% of its wood supply for all units is verified by third parties to be in legal compliance, but the verification system is not reported.

46. Percentage area (ha) FSC FM certified?

87.22% - The company reports that 87.22% of its operational area is 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 reports that 100% of the wood used in the production process is controlled and mentions to prevent sourcing and supply from Illegally harvested wood, wood harvested in violation of traditional and human rights, wood harvested in forests where high conservation values are threatened by management activities, wood harvested in forests being converted to plantations or non-forest use and wood from forests in which genetically modified trees are planted.

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

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. The company also reports its own commitment to zero deforestation in its corporate presentation.

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 deforestation in 2019 in its eucalyptus plantation areas.

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

58. Commitment to restoration of non-compliant deforestation/conversion?

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

60. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company reports multiple landscape restoration activities in its sustainability report and this report is externally verified by Bureau Veritas.

61. Commitment to biodiversity conservation?

The company reports its commitment to biodiversity conservation.

62. Commitment to biodiversity conservation applies to all suppliers?

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

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator. The company has also identified species of conservation concern, referencing the IUCN system of species classification and the same is published on the company website.

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

Points for external verification have been awarded on the basis of the company's FSC/PEFC certified landbank/volume. The examples of habitat conservation are also reported by the company on its indicator webpage.

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

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

67. Commitment to protect forest areas 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 FSC/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.

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 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 HCV assessments are available in the forest management plans of all FMUs of the company. However, these assessments are not externally verified.

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

The High Conservation Value management and monitoring plans are available in the forest management plans of all FMUs of the company. However, this information is not externally verified.

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)?

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?

The social and environmental impact assessments (SEIAs), associated management and monitoring plans are available for all FMUs of the company. However, these assessments are not externally verified.

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)?

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

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

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

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

Points for external verification have been awarded on the basis of the company's FSC certification. As the P&Cs do not fully meet the SPOTT indicator criteria with regards to peatlands, limited, externally verified points have therefore been awarded for this indicator. The company also reports examples of best management practices for soil in its sustainability report.

90. Commitment to reduced impact logging?

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

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

This indicator is disabled as the company reports to only source from plantations.

92. Evidence of implementing reduced impact logging practices?

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

93. Commitment to zero burning?

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. The company also reports own evidence on fire monitoring and management in its sustainability report.

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

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

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

The company reports to reduce its emissions intensity to 0.190 tCO2e/ton (-10.9%) by 2025 and to 0.181 tCO2e/ton (-15%) by 2030.

99. GHG emissions intensity?

The company reports GHG emissions intensity, in t of CO? equivalent/ton of product as 0.3369.

100. GHG emissions from land use change?

101. Progress towards commitment to reduce GHG emissions intensity?

The company's 2018 GHG emissions intensity figure was 0.4 and for 2019 the GHG emissions intensity figure is reported as 0.3369. This shows progress towards company's commitment to reduce GHG emissions intensity, however, this information is not externally verified.

102. Methodology used to calculate GHG emissions?

The Greenhouse Gas Protocol: the Corporate Accounting and Reporting Standard, WRI & WBCSD (2004), guides, guidelines and calculation tools of the Brazilian GHG Protocol Program (PBGHGP) of FGV (2020), 2006 IPCC Guidelines for National Greenhouse Gas Inventories, IPCC (2006), Calculation Tools for Estimating Greenhouse Gas Emissions from Pulp and Paper Mills, NCASI (2005).

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

The company reports to reach water withdrawal limits of 25.3 m3 per ton of product (pulp and paper) in the next 10 years (2030).

104. Water use intensity?

The company reports the figures for specific water consumption in all its industrial operations.

105. Progress towards commitment on water use intensity?

The company only reports the water use intensity figures for 2019, therefore it is difficult to determine the company's progress towards commitment on water use intensity.

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

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

The company reports 2018 BOD and COD figures for only for one of its operations before the merging process. For 2019, BOD and COD figures are available for all units, however, the company has not reported a target for improving BOD and COD.

108. Treatment of pulp and paper mill effluent?

The company reports information on effluent treatments from mills on its website, however, the information is not externally verified.

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

This indicator is disabled as the company reports that it doesn't own sawmills.

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

111. Commitment to protect natural waterways through buffer zones?

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

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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

The company only mentions that it works in the search for process efficiency, with the objective of reducing the consumption of water, energy, chemicals and waste generation through the closing of circuit and the reuse of materials.

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

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

The company reports that a DD-Washer was installed in its Imperatriz unit and there was an increase in the efficiency cellulose pulp washing process, thus reducing consumption of chemicals, such as chlorine dioxide, in the bleaching stage of the pulp. Consumption of chlorine dioxide reduced from approximately 11.3 kg/ton to 10 kg/ton per day. However, this information is reported for only one of the company units and also it is now between two and five years old.

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

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

118. Commitment 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?

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

The FSC reports of some FMUs of the company reports the list of chemicals used.

121. Implementation of commitment to reduce chemical usage?

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

122. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's FSC certified landbank/volume. The company also details information on Integrated Pest Management in its sustainability report and on its website.

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

[Externally verified] The company reports its waste management system in its sustainability report and this report is externally verified by Bureau Veritas.

124. Commitment to human rights?

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 reports its own commitment to human rights principles as part of being UN Global Compact signatories.

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. The company's own commitment to human rights applies to all suppliers.

126. Progress on human rights commitment ?

The company reports the information on employee training on human rights policies and procedures on its website. However, this information is not externally verified.

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

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.

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 reports that in the engagement process with indigenous communities, which is guided by its Relationship Management Guide, the company recognizes that their customs, social organization, language, beliefs and traditions are legally recognized, as well as their original rights over the lands they traditionally occupy.

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)?

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

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

134. Examples of local stakeholder engagement to prevent conflicts?

Points for external verification have been awarded on the basis of the company's FSC certification. As the P&Cs do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator. The company also reports multiple examples on local stakeholder engagement to prevent conflicts on its website.

135. Details of process for addressing land conflicts available?

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?

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

139. Commitment to provide essential community services and facilities ?

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

Points for external verification have been awarded on the basis of the company's FSC certified landbank/volume. The company also reports multiple examples of facilities and services that have been provided to communities on its website.

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

The company has not reported direct commitment to provide business or work opportunities for local communities but it reports details on number of employees hired from 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. The company also reports commitment to all of the ILO conventions in its commitment to legal and socio-environmental responsibility standards document.

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. Company's own commitment to all ILO core conventions applies to all suppliers.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications 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 reports its commitment to eliminate gender related discrimination with regards to employment in its code of conduct policy.

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

The company's commitment to eliminate gender related discrimination with regards to employment applies to all suppliers.

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

[Externally verified] The company states to have a plural program in place which promotes non-discrimination in the workplace along with fostering a culture of valuing diversity and encouraging inclusion in the company. This information is externally verified by Bureau Veritas.

149. Percentage or number of temporary employees?

9 (0.1%) - The company reports to have 9 temporary employees out of 13021 employees for one of its operations. However, it is unclear if this covers all operations of the company as the total number of employees is reported as 36547 in company's sustainability report.

150. Percentage or number of women employees?

1,901 (14.6%) - The company reports to have 1901 women employees out of 13021 employees for one of the company's operations. However, it is unclear if this covers all operations of the company as total number of employees is reported as 36547 in the company's sustainability report.

151. Commitment to pay at least minimum wage?

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 the ratios of standard entry level wage compared to local minimum wage for all its units as per GRI guidelines. However, this information is not externally verified.

154. Reporting of salary by gender?

The company reports the ratio of basic salary and remuneration of women to men in line with GRI reporting, however it is unclear if this includes temporary employees.

155. Commitment to address occupational health and safety?

The company reports commitment to safety, health and quality of life, however the commitment does not refer to 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's commitment to safety, health and quality of life applies to all suppliers, however the commitment does not refer to ILO Code of Practice on Safety and Health in Forestry Work.

157. Provision of personal protective equipment and related training?

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications 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 frequency rate and number of lost time injuries for all its departments including its forestry department.

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

1 - The company reports 1 fatality as a result of work related injury in its forestry operations.

160. Commitment to support smallholders?

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

[Externally verified] Supplier Development and Qualification Program (Mato Grosso do Sul state), Integrated Supplier Development and Qualification Program (Espírito Santo state), Development of local partners (Bahia state). This information is externally verified by Bureau Veritas.

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

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

The company reports the process used to engage suppliers as per company's legal requirements. However, the process does not cover all three key elements of a due diligence system.

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

100% - The company reports that 100% of its wood suppliers are evaluated and hired in accordance with company requirements. However, this information is not externally verified.

165. Suspension or exclusion criteria for suppliers?

The company reports to have a supplier performance assessment system, however the information on steps taken or time frames for action in case of rejected suppliers is not reported.

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 reports its commitment to ethical conduct and prohibition of corruption through its anti-corruption policy.

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

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

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

The company reports having a anti-corruption management area and also reports provision of training to employees on anti-corruption policies. However, this information is not externally verified.

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?

The company discloses its management approach to tax payments to governments but there is no tax policy publicly available.

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 reports to have a whistle bowling channel and disciplinary measures policy that details the procedures followed for whistle bowling. However, this policy is not publicly available.

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

The company reports to have an ombudsman channel for reporting complaints and grievances. This channel is open to all stakeholders.

176. Details of complaints and grievances disclosed?

The company only provides a summary table on number and types of grievances reported.