Suzano SA

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

The company has published multiple policies covering a range of social and environmental criteria which covers all operations.

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

Only some of the companies policies apply to suppliers.

3. High-level position of responsibility for sustainability?

The company reports it has an executive officer of sustainability who is not a member of the board.

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

0 - The company reports it has 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 seven members in the senior management/executive team, however, the gender balance is not directly reported by the company.

6. Percentage or number of women board members?

2 - The company reports it has two women board members in its Board of ten members.

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 and Natural Capital Coalition.

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

The company has reported various projects, methodologies, and initiatives in collaboration with stakeholders such as the Alliance for the Restoration of the Amazon, project with The Nature Conservancy (TNC), Wastewater Treatment Plant (WWTP) at the Limeira unit (São Paulo state), which led to improvements in efficiency to reduce negative environmental or social outcomes associated with timber and pulp production.

9. Sustainability report published within last two years?

The company includes sustainability reporting within its annual report.

10. Reports through standardised reporting systems?

The company has prepared its 2021 report in accordance with the GRI Standards.

11. Climate risks assessment available?

The company only publishes a summary of climate risks.

12. Natural capital assessment available?

13. Lists countries and operations?

The company has five forest management units in Brazil and has global distribution centers. It operates 12 mills.

14. Lists countries sourcing from?

The company only mentions the total number of suppliers, however, the location of its suppliers is 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)?

1441720 - The company has reported the total area planted by Suzano SA to be 1,441,724.93 ha in 2021.

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

114053 - The company reports a total planting area within outgrower schemes.

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

126005 - The company reports an area of 126,005 ha as 'planted and available' in 2020. However as this figure includes 'planted' area it is not clear what the total area available for planting is.

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

105771 - The company reports a total area within its conservation units of 105,770.51 ha.

20. Area of Intact Forest Landscape (ha)?

21. Number of Forest Management Units (FMUs)?

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

22. Maps of forest management units (FMUs)?

The FSC reports of the company mention the coordinates for three FMUs out of the total five FMUs. However, the estate boundaries are not reported.

23. Forest management plans available for all FMUs?

The forest management plans for the year 2020 are available for all Forest Management Units of the company on its website.

24. Monitoring of forest management plan implementation available?

[Externally verified] The monitoring of forest management plan implementation is available throughout 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 does not own sawmills.

30. Names and locations of company owned sawmills?

This indicator is disabled as the company reports that it does not own sawmills.

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

12 - The company reports it owns 12 mills in its Annual Report.

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

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

This indicator is disabled as the company reports that it does not own sawmills.

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

35. Number of third party supplying mills?

The company has reported its total critical suppliers to be 11,358 whereas active suppliers make up a total of 30,015. Figures for 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 third parties?

38. Procedures to trace raw materials to country of harvest?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) 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.

39. Percentage of supply traceable to country of harvest?

100 - The company has reported that 100% of its supply is of 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 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.

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?

The company has made an unclear statement of having 100% percent of supply verified by third parties as being legally compliant, however, it fails to report on the legality verification system used.

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

76.71% - The company reports that 76.71% of its total 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 the volume of own and third-party wood that is certified under FSC and PEFC but does not report this as a percentage.

46. Percentage area (ha) FSC FM certified?

67% - The company reports that 76.71% of its operational area is FSC FM certified, however, it has been reported collectively with the landbank certified under PEFC. Based on FSC certificates and the company's reported landbank of 2.4 million ha, the company has 67% of its landbank FSC 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 commits to only source wood/wood fibre that meets FSC Controlled Wood and PEFC Controlled Sources requirements.

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

The company reports the figure collectively for both PEFC and FSC Certification.

51. Commitment to zero conversion of natural ecosystems?

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

53. Commitment to zero deforestation?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded based on the company s FSC certification/FSC membership. The company also reports its commitment to zero deforestation through its Zero Deforestation Positioning Report. It also reports a standalone report as Zero Deforestation Positioning which is available on the website.

54. Commitment to zero deforestation applies to all suppliers?

The company only provides a commitment to no deforestation for its own operations.

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

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

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

The company specifies how deforestation and/or ecosystem conversion is being monitored, including the extent of the area monitored and the timeframe but the information is not externally verified.

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

The company doesn't specify the methodology to monitor deforestation and/or ecosystem conversion in supplier operations, the timeframe is also unclear. Although it states its compliance with monitoring of illegal deforestation in its wood supply and supply chain and the information is not externally verified.

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

0 (0%) - The company reports zero deforestation in 2020 in its eucalyptus plantation areas.

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

60. Commitment to restoration of deforestation/conversion?

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

62. 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.

63. Biodiversity policy?

The company only provides a commitment to the protection and conservation of biodiversity with no targets and no details given on the scope.

64. Biodiversity policy applies to all suppliers?

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

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's 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.

66. 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.

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

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

69. Commitment to protect forest areas from illegal activities?

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

71. 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.

72. Commitment to no use of genetically modified organisms?

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

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

The company has multiple certifications some of which are, ISEGA, Management Certification, CERFLOR & FSC.

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

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

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

76. High Conservation Value (HCV) assessments available?

The company has reported its HCV assessments in its Forest Management Plans for all the FMUs of the company. Public summaries are also reported by the company for the FMUs respectively. The statement assessments are however not externally verified.

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

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

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

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

80. High Carbon Stock (HCS) assessments available?

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

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

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

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

The company has reported the social and environmental impact assessments (SEIAs), associated management, and monitoring plans in the Forest Management Plans for all FMUs of the company. However, these assessments are not externally verified.

85. Company has provided valid legal documents to Open Timber Portal on impact assessments (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

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

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

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

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

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

92. 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) as the requirements do not fully meet the SPOTT indicator criteria.

93. Commitment to reduced impact logging?

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

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

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

95. Evidence of implementing reduced impact logging practices?

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

96. Commitment to zero burning?

97. Commitment to zero burning applies to all suppliers?

98. Evidence of fire monitoring and management?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. However, additional points cannot be awarded as a percentage of landbank certified by PEFC cannot be calculated.

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

7830 - The company has reported the total number of fires in its operations in 2020.

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

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

The company reports a target to reduce the intensity of greenhouse gas emissions by 9.7% by 2025. Goal is aligned with the roadmap of the Long-Term Goal for Emissions: reduce specific emissions by 15% (Scope 1 and 2 emissions) by 2030.

102. GHG emissions intensity?

The company reports GHG emissions intensity, in t of CO₂ equivalent/ton of product as 0.1995.

103. GHG emissions from land use change?

104. Progress towards commitment to reduce GHG emissions intensity?

The company reports its progress towards the commitment to reduce GHG emissions: 2018: 0.4, 2019: 0.3369, and 2020: 0.3295.This shows progress towards the company's commitment to reduce GHG emissions intensity, however, this information is not externally verified.

105. 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).

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

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

107. Water use intensity?

Specific water consumption in all its industrial operations has been reported by the company however it is not clear if the figures are based on water use intensity.

108. Progress towards commitment on water use intensity?

The company reports an improvement in water consumption but the figures are not clearly in relation to water use intensity.

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

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

The company has reported the progress on both the parameters (BOD & COD), however, the figures do not cover overall operations and are also not improving and the information is not externally verified.

111. Treatment of pulp and paper mill effluent?

The company has reported the treatment of pulp and paper mill effluent. Not externally verified.

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

This indicator is disabled as the company reports that it does not own sawmills.

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

114. Commitment to protect natural waterways through buffer zones?

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

The company is FSC FM Certified, however, the extent of certification is reported collectively by the company, hence additional points cannot be awarded. Full points are awarded based on FSC FM Certification only.

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

The company has an objective to reduce chemicals but does not refer to both pesticides and fertilisers.

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

118. 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 of the cellulose pulp washing process, thus reducing the 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.

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

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

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

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

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

The company reports a list of chemicals used for its three FMUs in its FSC FM/CoC Reports.

124. Implementation of commitment to reduce chemical usage?

Comprehensive, externally verified points have been awarded based on the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points could not be awarded as the percentage of company landbank certified by FSC is collectively reported with PEFC Certified landbank by the company.

125. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded based on the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points could not be awarded as the percentage of company landbank certified by FSC is collectively reported with PEFC Certified landbank by the company.

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

[Externally verified] The company has reported its waste management system in its annual report 2020 and this report is externally verified by Bureau Veritas.

127. Commitment to human rights?

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

128. Commitment to human rights applies to all suppliers?

The company has a commitment to human rights that applies to all suppliers.

129. Progress on human rights commitment ?

The company states that it gave 438,210.00 hours of training to employees on human rights in 2021. The information is not externally verified.

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

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

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

The company reports its commitment to indigenous and local communities' rights applies to all suppliers.

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

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

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

Full points are awarded due to the company's FSC FM/COC and PEFC Chain of custody certification.

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

The company makes a commitment to FPIC.

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

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

137. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] Limited, 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 do not fully meet the SPOTT indicator criteria.

138. Details of process for addressing land conflicts available?

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

140. Company has provided valid legal documents to Open Timber Portal on population rights (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

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

142. Commitment to provide essential community services and facilities ?

The company provides multiple examples of providing essential community services, however, no explicit commitment found.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank.

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

The company reports details on number of employees hired from local communities but does not report a direct commitment to provide business or work opportunities for local communities.

145. Company has provided valid legal documents to Open Timber Portal on labour regulations (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

146. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

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

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

The company is committed to all Fundamental ILO Conventions or Free and Fair Labour Principles that apply to all suppliers.

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

Comprehensive, externally verified points have been awarded on the basis of the company's 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 percentage of company landbank certified by either FSC or PEFC, whichever is highest.

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

The company is committed to eliminate gender-related discrimination with regard to employment.

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

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

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

[Externally verified] Progress on the commitment to eliminate gender-related discrimination concerning employment has been reported by citing actions taken to implement its gender policies. This information is externally verified by Bureau Veritas.

152. Percentage or number of temporary employees?

0 (0%) - The number of temporary employees is reported by the company on the website as 0.

153. Percentage or number of women employees?

2277 (15.3%) - The company reports having 2,277 women employees out of 14,892 employees for one of the company's operations. However, it is unclear if this covers all operations of the company, hence, partial points awarded.

154. Commitment to pay a living wage?

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

156. Progress on commitment to pay a living wage?

100% - The company reports the ratios of standard entry-level wage compared to the local minimum wage for all its units as per GRI guidelines. However, this information is not externally verified.

157. Reporting of salary by gender?

90% - The company reports the ratio of basic salary and remuneration of women to men in line with GRI reporting, however, it is unclear if the data includes all employees.

158. 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. Also the company has a health and safety policy but does not refer to the ILO conventions.

159. 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.

160. Provision of personal protective equipment and related training?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points could not be awarded according to the percentage of company landbank certified by PEFC as it is reported collectively with FSC certified landbank. Also, the company provides PPE to its employees but the information is not externally verified.

161. Time lost due to work-based injuries?

1.01 - Lost time frequency rate and the number of lost-time injuries for all its departments including its forestry department have been reported by the company.

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

0 - The company reports 0 fatalities as a result of work related injury in its forestry operations.

163. Commitment to support smallholders?

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

[Externally verified] The company has started the Semear Program (Bahia state), and Integrated Supplier Development and Qualification Program (Espírito Santo state). This information is externally verified by Bureau Veritas.

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

177 - The company reports that 177 local suppliers were involved in the Semear Program in 2020. The information is not externally verified.

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

The process used to prioritise, assess and/or engage suppliers on compliance with the company's policy and/or legal requirements is reported by the company but it doesn't cover the three key elements of a due diligence system i.e. information gathering, risk assessment, and risk mitigation.

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

100% - 100% of the company's wood suppliers are evaluated and hired in accordance with company requirements. However, this information is not externally verified.

168. Suspension or exclusion criteria for suppliers?

The company reports the screening criteria of its suppliers conducting monthly monitoring (Control of Ancillary Obligations) with the timeframe for actions.

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

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

171. Commitment to ethical conduct and prohibition of corruption?

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

172. 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.

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

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

174. Company has provided valid legal documents to Open Timber Portal on legal registration (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

There is no tax policy by the company, however, discloses its management approach to tax payments to governments.

176. Company has provided valid legal documents to Open Timber Portal on taxes, fees and royalties (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

177. Whistleblowing procedure?

The company reports having a whistleblowing channel and disciplinary measures policy that details the procedures followed for whistleblower protection.

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

The company has its own grievance or complaints system that is accessible to both internal and external stakeholders.

179. Details of complaints and grievances disclosed?

The company only provides a summary table on the number and complaint category reported.