Suzano SA

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

The company has policies on Social Responsibility, Health and Safety, Environment and Quality. The company's Policy on Climate Change is not publicly available.

2. Sustainability policy or commitment applies to all sourcing?

The company has a Supplier Relations Policy however it only states that it prioritises suppliers that are aligned with its policies.

3. High-level position of responsibility for sustainability?

Sustainability and Strategy Committee that advises the Board of Directors.

4. One or more board members have responsibility for sustainability?

5. Percentage or number of women board members?

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

7. Sustainability report published within last two years?

2017

8. Member of multiple industry schemes or other external initiatives to improve forest management or transparency?

PEFC, FSC, UNGC, GRI, Atlantic Forest Restoration Pact, Brazilian Coalition on Climate, Forests and Agriculture.

9. Activities with government, NGOs or academic institutions to improve the sustainability of forest products?

The Forests Dialogue, Forest Forum, conservation NGOs (WWF, The Nature Conservancy, FoE Brazil, Pact to Restore the Atlantic Forest and others), and research institutions.

10. Climate risks assessment available?

11. Natural capital assessment available?

12. Lists countries and operations?

Brazil (São Paulo, Bahia, Espírito Santo, Minas Gerais, Piauí, Tocantins, Pará and Maranhão); Fibria – Brazil (Espírito Santo, Bahia, Mato Grosso do Sul, Minas Gerais, São Paulo, Rio de Janeiro, and Rio Grande do Sul).

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

This indicator is disabled as the company has informed ZSL that it only produces wood/wood fibre from plantation forests.

14. Total area of forest plantation (ha)?

1266920 - Figure represents plantation area of Suzano (610,922 ha) and Fibria (656,000 ha) before merger as reported in 2017 Sustainability Reports.

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

63947 - No information is provided on the area of plantation within outgrower scheme for Fibria.

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

102570 - The company reports some figures but these do not cover the whole of its operations.

17. Conservation set-aside and/or HCV area (ha)?

912168

18. Area of Intact Forest Landscape (ha)?

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

19. Number of Forest Management Units (FMUs)?

3 - Suzano has three FMUs.
Fibria does not clearly state number of FMUs. It reports four industrial units.

20. Maps of forest management units (FMUs)?

The company presents static maps in its 2017 forest management plans. Geo-referenced maps (e.g. shapefile or KML) could not be identified.

21. Forest management plans available for all FMUs?

FMP available for three units of Suzano and one unit of Fibria, however it is unclear if these cover all operations.

22. Monitoring of forest management plan implementation?

There are some monitoring plans available however it is unclear if these cover all operations.

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

This indicator is disabled as the company's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this.

24. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this.

25. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this.

26. Number of company owned pulp and paper mills?

12

27. Maps or addresses of company owned pulp and paper mills?

Location/address for Fibria's second mill in Tres Lagoas cannot be traced.

28. Number of company owned sawmills?

This indicator is disabled as the company has informed ZSL that it doesn't own sawmills.

29. Maps or addresses of company owned sawmills?

This indicator is disabled as the company has informed ZSL that it doesn't own sawmills.

30. Number of supplier mills?

31. Maps or addresses of supplier mills?

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

The company has CoC certification which only covers traceability for the certified portion of its supply.

33. Procedures to trace raw materials to FMU level?

The company has CoC certification which only covers traceability for the certified portion of its supply.

34. Percentage of supply traceable to country level (above 80%)?

35. Percentage of supply traceable to FMU level (above 75%)?

36. Commitment to zero conversion of natural forest?

37. Zero conversion commitment applies to all sourcing?

38. Commitment to minimise the impact of logging roads?

This indicator is disabled as the company has informed ZSL that it only produces wood/wood fibre from plantation forests.

39. Commitment to protect forest areas from illegal activities?

40. Evidence of monitoring deforestation?

41. Amount of deforestation recorded?

42. Commitment to biodiversity conservation?

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

44. Implementing a landscape-level approach to biodiversity conservation?

Landscape management through a partnership with The Nature Conservancy (TNC) to restore the springs of the Mucuri river; 3-year partnership with WWF to develop strategies and best practices for restoration at the landscape level.

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

46. Commitment to sustainably manage the use of non-timber forest products (NTFPs)?

This indicator is disabled as the company has informed ZSL that it only produces wood/wood fibre from plantation forests.

47. Commitment not to use genetically modified organisms?

The company has committed to not be directly or indirectly involved in the introduction of genetically modified organisms in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004). However, it is important to note that FuturaGene, a subsidiary of pulp and paper company Suzano, has received approval for the commercial use of genetically engineered eucalyptus trees. A 2016 Sustainalytics report states on the issue: "Suzano has demonstrated that they are undertaking a comprehensive engagement process with relevant stakeholders to address concerns around the use of GM plants. These stakeholders include the FSC, PEFC, non-governmental organizations, and all other relevant stakeholders in the sector, including sector specific bodies and other companies".

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

The company does not have a direct commitment to conduct HCV assessments across all of its operations. However, the company has committed to not be directly or indirectly involved in the destruction of High Conservation Values in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004). For this half points are awarded.

49. HCV commitment applies to all sourcing?

The company has a commitment to only source wood/wood fibre that meets FSC Controlled Wood requirements which includes not sourcing wood from forests with a high conservation value.

50. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS)?

This indicator is disabled until sufficient number of HCV ALS licensed assessors are available for the location where the company operates.

51. High Conservation Value (HCV) assessments available?

All HCV assessments are available: Unidade Florestal Sao Paulo (SP), Unidade Florestal Bahia (BA), Unidade Florestal Maranhao (MA), however no such assessment is available for Fibria's HCV areas.

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

All HCV M&M are available: Unidade Florestal Sao Paulo (SP), Unidade Florestal Bahia (BA), Unidade Florestal Maranhao (MA), however no such assessment is available for Fibria's HCV areas.

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

54. High Carbon Stock (HCS) assessments available?

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

The company has commitment to SEIA in its forest management plans however it is unclear if all FMPs are available.

56. Social and environmental impact assessments (SEIAs) available?

57. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this.

58. Commitment to best management practices for soils and/or peat?

59. Commitment to reduced impact logging?

This indicator is disabled as the company has informed ZSL that it only produces wood/wood fibre from plantation forests.

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

This indicator is disabled as the company has informed ZSL that it doesn't have landbank on peat.

61. Commitment on peatland planting applies to all sourcing?

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

This indicator is disabled as the company has informed ZSL that it doesn't have landbank on peat.

63. Evidence of best management practices for soils and/or peat?

64. Commitment to zero burning?

The company states that it does not practice burning in its eucalyptus cutting and harvesting process, but does not have a clear commitment.

65. Commitment to zero burning applies to all sourcing?

66. Evidence of management and monitoring fires?

The company has a forest fire prevention program that engages employees and local communities. The company also reports that it owns watchtowers and a camera monitoring system. In order to reduce response time to fire alarms, in 2017, Fibria installed 50 towers in the units of Três Lagoas (Mato Grosso do Sul state) and Aracruz (Espírito Santo state).

67. Details/number of hotspots/fires in FMUs controlled by the company?

68. Time-bound commitment to reduce GHG emissions intensity?

The company only has a vague commitment to reduce GHG emissions.

69. Progress towards reducing GHG emission intensity?

0.2 - The company reports its emissions intensity decreased by 8.37% between 2015 and 2017. However, the company has no time-bound target in place.

70. Report GHG emissions from land use change?

71. Methodology used to calculate GHG emissions?

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

The company has BOD targets for all of its mills for 2018, however, no targets are provided to improve COD.

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

The company reports only BOD figures for each of its mills in 2017.

74. Commitment to protection of natural waterways through buffer zones?

The company states "We respect freshwater body protection laws, maintaining a 50-meter strip around springs and a 30-meter strip around waterways".

75. Evidence of treatment of pulp and paper mill effluent?

The company reports that at all industrial sites effluents are treated by the company's own wastewater treatment plants, including primary treatment (physical) and secondary treatment (biological).

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

This indicator is disabled as the company has informed ZSL that it doesn't own sawmills.

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

The company has water consumption targets for all of its five mills for 2018. Fibria also has time-bound water reduction targets.

78. Progress towards commitment on water use intensity?

1.3% - The company reports water usage figures for each of its mills and states that its water consumption was 1.3% lower than in the previous year.

79. Commitment to eliminate chlorine and chlorine compounds for bleaching?

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

The company mentions that it uses techniques to reduce the use of agrochemicals, but does not have clear commitment.

81. No use of World Health Organisation (WHO) Class 1A and 1B pesticides?

82. No use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

83. Integrated Pest Management (IPM) approach?

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

The company has mentioned usage of main pulp-production chemical components for their Imperatriz unit – chlorine dioxide, caustic soda (sodium hydroxide) and sulfuric acid.However, no information available for other units. Also, the latest FSC audit reports of Fibria has reported pesticides usage for three FMUs.

85. Commitment to human rights, referencing the UN Declaration on Human Rights or UN Guiding Principles on Business and Human Rights?

The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which defines human rights as those established through the UN Declaration of Human Rights.
Fibria also has a detailed human rights policy based on UDHR and HNGP.

86. Commitment to human rights applies to all sourcing?

The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which defines human rights as those established through the UN Declaration of Human Rights.

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

The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which encompasses the rights of Indigenous and Tribal Peoples as established by the ILO Convention 169.

88. Commitment to respect legal and customary property rights?

The company has committed to not be directly or indirectly involved in the violation of traditional rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which encompasses customary rights.

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

90. FPIC commitment applies to independent suppliers?

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

92. Examples of local stakeholder engagement to prevent conflicts?

The company has discussed various tools that it uses for local engagement and socio-environmental agents responsible for maintaining relations and operational dialogue with local communities.

93. Details of process for addressing land conflicts available?

94. Commitment to support the inclusion of women across forestry operations, including addressing barriers faced?

95. Commitment to provide essential community services and facilities?

96. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this.

97. Commitment to respect all workers' rights?

98. Reference to Fundamental ILO Conventions?

The company has committed to not be directly or indirectly involved in the violation of any of the ILO Core Conventions. This commitment is made through the FSC Policy for Association (FSC-POL-01-004).

99. Commitment to eliminate gender related discrimination with regards to employment and occupation?

100. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this.

101. Percentage or number of temporary employees?

77 (0.95%)

102. Percentage or number of women employees?

3594

103. Payment of minimum wage?

The company reports that the variation between the lowest salary paid and the national minimum wage was +30% (up from +11.5% in 2016).

104. Reporting of salary by gender?

The company reports on ratio of women’s compensation to men’s compensation by position level in 2017, however, it is not clear whether the temporary employees are included or not.

105. Commitment to address occupational health and safety, referencing the ILO Code of Practice on Safety and Health in Forestry Work?

106. Time lost due to work-based injuries?

12.44 - Rate of lost workdays among employees at Suzano. Fibria reports accidents per million km driven in wood transport which is not included in the number.

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

2 - Including one accident at Fibria.

108. Provision of personal protective equipment and related training?

Fibria does not mention providing PPE.

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

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

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

705335 (83.64%)

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

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

114. Commitment to source only wood/wood fibre that meets FSC Controlled Wood requirements?

115. Percentage area (ha) FSC FM certified?

705335 (83.64%)

116. Percentage of wood/wood fibre supply from outgrower scheme and/or independent suppliers that is FSC FM certified?

117. Percentage of all wood/wood fibre supply traded/processed that are FSC certified (above 75%)?

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

119. Programme to support outgrower scheme smallholders?

Forestry Partner Program: Technical support, seedlings, fertilisers and ant controls, monitoring. Environmental assessment of partners.

120. Percentage of outgrower scheme smallholders involved in programme?

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

Supplier Registration Governance project to strategically evaluate these stakeholders, including an online record-management platform which is publicly accessible. The company also requires its "business partners to adopt engagement policies in the areas of occupational health and safety, compliance with labor laws, social and environmental practices and respect for human rights". In addition the supplier assessment programme covers Quality, Safety and Environment.

122. The company has a Due Diligence System (DDS)?

123. Suspension or exclusion criteria for suppliers?

The company has developed a Supplier Performance Index to evaluate their suppliers in line with various criteria. Companies which do not score well are rejected.

124. Percentage of suppliers assessed and/or engaged on compliance with company requirements?

66% - The company states that 66% of suppliers went through the analysis process for environmental criteria. As a result of the evaluation, action plans were made for six suppliers in regards to improving their environmental impact.
Fibria does not report on the same.

125. Commitment to ethical conduct and prohibition of corruption?

126. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this.

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

Only Fibria has a tax directive.

128. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this.

129. Whistleblowing procedure?

The company has an Ombudsman and states that issues can be reported anonymously, however no process is provided on how the received reports are processed.

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

131. Details of grievances disclosed?