Toba Pulp Lestari

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

The company has published a sustainable forestry policy which covers all operations.

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

The company has published a sustainable forestry policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company reports that Ignatius (Member of the Board of Commissioners) and Venkateshwarlu (Member of the Board of Directors/Managing Director) hold the high-level positions of responsibility for sustainability.

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

The company reports that members of the Board of Commissioners and Board of Directors have the responsibility to oversee the economic sustainability strategy.

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

4 - The company reports a total of 4 (7%) women in the senior management team.

6. Percentage or number of women board members?

0 - The company reports zero females on the board of directors in 2022.

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 reports that it is a member of APHI and APKI.

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

The company collaborates with various stakeholders to reduce negative environmental or social outcomes associated with timber and pulp production, such as improving school facilities and infrastructure, clean water piping, road drainage construction, construction of village offices, health services, and environmental programs.

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 sustainability report has been prepared in accordance with the Global Reporting Initiative (GRI) Standards.

11. Climate risks assessment available?

The company publishes a climate risk assessment. However, it does not include actual, potential impacts of climate change, targets and processes used to assess or manage climate risk. This is also self-reported information.

12. Natural capital assessment available?

13. Lists countries and operations?

Headquarters(Indonesia), Operations (China, Taiwan, and Vietnam).

14. Lists countries sourcing from?

This indicator is disabled as the company reports that it does not trade wood/wood fibre.

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

268634 - The company reports the total land area managed or controlled for forestry as 268,634 ha.

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

167912 - The company reports the total area of natural forest designated for wood/wood fibre production as 167,912 ha.

17. Total area of forest plantation (ha)?

45075 - The company reports a plantation area of 70,074 ha of which 45,075 ha is planted. The planted area excludes outgrower scheme area.

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

8775 - The company reports 8,775 ha of areas of plantation/natural forest within outgrower schemes.

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

4894 - The company reports 4,894 ha of unplanted areas.

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

64573 - The company reports that that it has 64,573 ha of conservation area, including protected areas, protected forest areas, and HCV areas.

21. Area of Intact Forest Landscape (ha)?

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

22. Number of Forest Management Units (FMUs)?

5 - The company reports that it has five forest management units.

23. Maps of forest management units (FMUs)?

The company publishes names and geo-referenced maps of all five FMUs, includingg estate boundaries.

24. Forest management plans available for all FMUs?

The company publishes a forest management plan which applies to all FMUs.

25. Monitoring of forest management plan implementation available?

The company reports monitoring of forest management plans. However, the information is self-reported.

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?

The company reports names (Garingging and Sei Kabaro) and locations of the third-party supplying Forest Management Units (FMUs).

30. Number of company owned sawmills?

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

31. Names and locations of company owned sawmills?

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

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

1 - The company reports one mill in Indonesia.

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

The company reports the name and geo-referenced map of the company-owned pulp and paper mill.

34. 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.

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

The company reports 198,429 tons of production in 2022 and also states that 100% of the product comes from its own mill and does not have any third parties that supply pulp to the mill.

36. Number of third party supplying mills?

This indicator is disabled as the company reports that it does not source from supplying mills.

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

This indicator is disabled as the company reports that it does not source from 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?

This indicator is disabled as the company reports that it does not source from supplying mills.

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

The company reports detailed procedures to trace raw materials to the country of harvest.

40. Percentage of supply traceable to country of harvest?

100 - The company reports that 100% of the product comes from its own mill.

41. Procedures to trace raw materials to FMU level?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria.

42. Percentage of supply traceable to FMU level?

The company ensures that all raw materials have undergone documentation and come from traceable sources.

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

The company is 100% legality verified by SVLK.

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

[Externally verified] 80% - The company reports the total landbank area as 167,912 ha and the PEFC-certified area as 137,735 ha.

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?

97.13% - The company reports that 97.13% of all wood/ wood fibre supply is verified as being in legal compliance by a third party.

47. Percentage area (ha) FSC FM certified?

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)?

137735 (82%) - The company reports the total landbank area as 167,912 ha and the PEFC-certified area as 137,735 ha.

52. Commitment to zero conversion of natural ecosystems?

The company commits to zero conversion of natural ecosystems.

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

The company commits all suppliers to zero conversion of all natural ecosystems.

54. Commitment to zero deforestation?

The company commits to zero conversion of all natural ecosystems.

55. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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

The company defines deforestation as removal of HCV and HCS areas and specifies any deforestation or conversion past 30 June 2014 will not be accepted.

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

The company defines deforestation as the removal of protected forested areas and protected forested peatlands and specifies any deforestation or conversion past 2014 will not be accepted.

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

The company has a land cover change (LCC) detection procedure to identify land cover changes to prevent deforestation (encroachment). Additionally, in 2022, it has consistently monitored all of its operational areas with the result that 100% of the area has been monitored. Since the cut-off date of 2014 and till now there has never been a deforestation in the company's operations. However, this information is self-reported.

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

The company reports monitoring procedures such as forest protection patrols that have a high vulnerability to collecting data and investigating cases of illegal logging or encorachment. It also reports that in 2022, forest security monitoring activities are carried out that show no cases of deforestation or land conversion occurred since 2014. However, this information is self-reported.

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?

0 (0%) - The company states that no cases of deforestation or land conversion have occurred since 2014 in the supplier's concession. However, this information does not cover all supplier's operations.

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's PEFC FM certification (PEFC ST 1003:2018). As the Standard does not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded.

65. Biodiversity policy?

The company has published a biodiversity policy which details timebound targets on protecting biodiversity.

66. Biodiversity policy applies to all suppliers?

The company has published a biodiversity policy which applies to all suppliers, covers multiple dimensions of biodiversity protection and extends beyond HCV/HCS/set-asides.

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 PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria. In addition, the company has identified species of conservation concern based on the Indonesian National Regulations, International Union for Conservation of Nature (IUCN), and Appendices Cites. However, this information is self-reported.

68. Examples of species and/or habitat conservation 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.

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

The company commits to no hunting of all species in its operations.

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

The company commits all suppliers to no hunting of all species in their operations.

71. Commitment to protect forest areas from illegal activities?

The company commits to protect the natural ecosystems and plantations under its management from illegal activities.

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

The company commits suppliers to protect the natural ecosystems and plantations under their management from 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 PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria.

74. Commitment to no use of genetically modified organisms?

The company commits to not use genetically modified organisms or transgenic species.

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

The company commits all suppliers to not use genetically modified organisms or transgenic species.

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

The company commits to conduct HCV assessments.

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

The company commits all suppliers to conduct HCV assessments.

78. High Conservation Value (HCV) assessments available?

[Externally verified] The company publishes 4 HCV assessments on the external site of HCVRN.

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

The company has published High Conservation Value (HCV) management and monitoring plan report. However, the information is self-reported.

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?

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

82. High Carbon Stock (HCS) assessments available?

[Externally verified] The company publishes the HCS assessment reports on the HCSA website.

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

[Externally verified] The company publishes peer-review reports on the HCSA website.

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

The company commits to conduct social and environmental impact assessments.

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

The company commits all suppliers to conduct social and environmental impact assessments.

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

The company publishes social and environmental impact assessments (SEIAs) management and monitoring plans. However, the information is limited and self-reported.

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?

The company commits to no planting on peat of any depth.

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

The company commits all suppliers to no planting on peat of any depth.

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

467 - The company reports the peatland area as 467 ha.

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

The company's peatland area has not increased since 2021 i.e. 467 ha. However, the information is not externally verified.

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

The company commits to best management practices for soils and peat.

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

The company commits all suppliers to best management practices for soils and peat.

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

Limited, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria.

95. Commitment to reduced impact logging?

The company commits to Reduced Impact Logging (RIL) and specifically mentions minimising the impact of logging roads along with other RIL practices.

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

The company commits all suppliers to reduced impact logging.

97. Evidence of implementing reduced impact logging practices?

Limited, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria. Additionally, the company reports the implementation of two main programs to reduce impact logging. However, this information is self-reported.

98. Commitment to zero burning?

The company commits to zero burning.

99. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

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 reports fire monitoring and management procedures such as conducting fire drills and daily monitoring of hotspots in all its operational locations (including suppliers) by using AQUA, NOAA, TERRA, and SNPP satellites which are accessed from Lembaga Penerbangan dan Antariksa Nasional (LAPAN) and Karhutla Monitoring System of Sipongi.

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

5 - The company has identified 24 hotspots and 5 land fire incidents in 2022.

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

0 (0%) - In 2022, the company reports 0 fire incidents in suppliers operations.

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

The company commits to reducing its GHG emissions Intensity by 0.5% annually and achieved its target of maintaining GHG emissions of less than 0.5% for 2020. However, this information does not include scope 1 and 2 emissions.

104. GHG emissions intensity?

The company reports its GHG emissions intensity as 0.28 (ton CO2/ton Pulp) in 2021. However, this data is unclear if it covers the company's all 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?

The company reports its GHG emission intensity for 2020 as 0.24 (ton CO2/ton Pulp) and 2021 as 0.28 (ton CO2/ton Pulp). The reported figures show that intensity has not improved from the previous year. This is self-reported information.

108. Methodology used to calculate GHG emissions?

The company reports that the methodology used in GHG calculations is based on the 2006 International Panel on Climate Change (IPCC) Guideline and the Greenhouse Gas inventory report of the Indonesian Ministry of Environment.

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

The company has a commitment to improving water use intensity. However, it is not time-bound.

110. Water use intensity?

60.77 - The company reports water usage intensity as 60.77 (m3/ton Pulp) in 2022.

111. Progress towards commitment on water use intensity?

The company reports water use intensity for 2022 as 60.77 (m3/ton Pulp) and for 2021 as 56.53 (m3/ton Pulp). The intensity data is not improving in the last two years. This is self-reported information.

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

The company commits to maintaining (BOD and COD) levels within legal limits.

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

The company reports BOD and COD levels for 2022 as (41 and 97) and 2021 as (47 and 98). The reported figures show an improvement and also are within specified legal limits However, this information is self-reported.

114. Treatment of pulp and paper mill effluent?

The company reports detailed treatment of pulp and paper mill effluent. It involves physical processes (screening, deposition, temperature reduction), biological processes (activated sludge process) and minor chemical processes (floc formation, pH adjustment). This effluent treatment is controlled by Distributed Control System (DCS), online wastewater quality analysers, and 24-hour laboratory control. However, this information is self-reported.

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

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

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

The company reports that its Mill Water Treatment Plant is designed with Cooling Tower that utilises return process water. However, this information is self-reported.

117. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways using buffer zones.

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

Limited, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria.

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

The company commits to minimise the use of chemical fertilisers and pesticides.

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

The company commits all suppliers to minimise the use of chemical fertilisers and pesticides.

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

The company reports that it only uses chlorine dioxide compounds (ClO2) that are more environmentally friendly in the pulp bleaching process. The company reports that it has implemented TCF technology however, In 2022, ClO2 consumption slightly increased by around 0.48% compared to 2021.The information is not externally verified.

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

The company commits to not use 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?

The company commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits to not use Stockholm and Rotterdam Convention chemicals.

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

The company commits all suppliers to not use Stockholm and Rotterdam Convention chemicals.

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

The company reports a list of industry-approved chemicals that are used in forestry operations.

127. Implementation of commitment to minimise inorganic fertiliser usage?

The company states that it seeks to minimise or avoid the use of chemical pesticides and other materials (i.e. fertilisers). It also implements documented procedures to minimise inorganic fertiliser usage. However, the information is limited and self-reported.

128. Integrated Pest Management (IPM) approach?

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. In addition, the company reports its Integrated Pest Management (IPM) approach and reduction of pesticides to control pests in Eucalyptus trees. However, this information is self-reported.

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 PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria. The company also has a waste management system in place to avoid negative impacts. However, the information is self-reported.

130. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

131. Commitment to human rights applies to all suppliers?

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

132. Progress on human rights commitment ?

The company conducts training on the Code of Ethics to educate employees regarding human rights policies. The company states that all its employees are following this training to increase awareness. However, this information is limited and self-reported.

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

The company commits to respecting indigenous and local communities' rights. However, it does not refer to the UN Declaration/ILO Convention.

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

The company's commitment to respecting indigenous and local communities rights applies to all suppliers. However, it does not refer to the UN Declaration/ILO Convention.

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

The company commits to respecting the legal rights of indigenous peoples and local communities. However, this information is unclear if it covers the customary land tenure rights.

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

The company's commitment to respecting the legal rights of indigenous peoples and local communities applies to all suppliers. However, this information is unclear if it covers the customary land tenure rights.

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

The company commits to respecting free, prior and informed consent (FPIC).

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

The company's commitment to respecting free, prior and informed consent (FPIC) applies to all suppliers.

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

The company reports details of the free, prior and informed consent (FPIC) process in the form of a flowchart.

140. Examples of local stakeholder engagement to prevent conflicts?

The company reports that It has conducted interviews with relevant stakeholders to identify and verify community background and land rights claims and set up a goal to establish Kelompok Tani Hutan (KTH) for the respective community to improve its economy. However, this information is two to five years old and self-reported.

141. Details of process for addressing land conflicts available?

The company reports details of the process for addressing land conflicts.

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

The company provides opportunities for women to participate in the forestry sector, such as involving women in nursery activities, environmental management, planting timber production and research. However, it does not address the barriers faced by women. This is also self-reported information.

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?

The company commits to enabling the 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 local communities.

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

The company reports progress on the commitment to provide essential community services and facilities such as the construction of village roads and houses of worship, providing educational institutions and clean water facilities as well as support in training, research and material assistance to its communities. However, this information is self-reported.

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

The company commits to providing business/work opportunities for local communities.

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 commits to Fundamental ILO Conventions.

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

The company commits to Fundamental ILO Conventions that apply to all suppliers.

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

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 provides workers with wages that are above the Minimum Wage (UMK) set annually by the local regulators, including the workers in PJS Health and BPJS Employment (social security insurance) programs under applicable national regulations.

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

The company commits to eliminating gender-related discrimination in employment.

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

The company commits to eliminating gender-related discrimination in employment that applies to all suppliers.

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

The company conducts training on the code of ethics to educate employees regarding gender discrimination and also reports that it does not tolerate any form of workplace bullying, harassment and violence. However, the information is limited and self-reported.

155. Percentage or number of temporary employees?

69 (6%) - The company reports that it has 69 (6%) temporary employees in 2022.

156. Percentage or number of women employees?

165 (13.32%) - The company reported 165 women employees in 2022.

157. Commitment to pay a living wage?

The company commits to pay a living wage to employees in accordance with government regulations in the Governor of North Sumatra Decree Number 188.44/779/KPTS/2021.

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

The company's commitment to pay a living wage to employees applies to all suppliers.

159. Progress on commitment to pay a living wage?

160. Reporting of salary by gender?

The company reports the ratio of basic salary and remuneration data based on gender. However, the information is unclear if it covers the company's all operations.

161. Commitment to address occupational health and safety?

The company commits to addressing occupational health and safety in reference to the ILO Code of Practice on Safety and Health in Forestry Work.

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

The company commits to addressing occupational health and safety which 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. In addition, the company reports that it provides PPE and related training to all employees.

164. Time lost due to work-based injuries?

0.19 - The company reports a lost time injury rate of 0.19 in fiber operation and 0 in mill operation.

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

0 - The company reports that in 2022, no fatalities occurred across its mill and fiber operations.

166. Commitment to support smallholders?

The company commits to support smallholders.

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

The company has PKR (Perkebunan Kayu Rakyat) Program which provides wood for production to the communities. The company also provides assistance to Bandar Manik village to increase knowledge in farming using the Jajar Legowo method. In 2022, coffee farmers from Sihaporas were assisted by the company's team in the coffee school program. However, the information is self-reported.

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

2021 - The company reports that in 2022 it had 2021 members with a land area of 8775 ha. This information is self-reported.

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

The company has a tool called Sustainable Supply Chain Assessment (SSCA) that is used for assessing the suppliers. It covers the elements of a due diligence system (such as information gathering from the supplier, risk assessment of their operations, and risk mitigation).

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

208 (94.98%) - The company reports that 219 suppliers were assessed/evaluated out of which 208 (94.98%) suppliers were found to have complied with company/government regulations/policies in 2022. However, the information is self-reported.

171. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria. The company also states suspension criteria in its own reporting. However, the time frame is unclear.

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

The company reports that it gets its wood supply through the Perkebunan Kayu Rakyat (PKR) program and continues to strive to make all of its wood supplies VLK certified. However, it does not report time-bound action plans for suppliers to comply with timber and pulp sourcing commitments.

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

The company reports that 219 suppliers were assessed/evaluated out of which 208 (94.98%) suppliers were found to have complied with company/government regulations/policies in 2022. However, the information is unclear for the process of assessment compilation, and it does not report the proportion of supply that is deemed compliant. The information is not externally verified.

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and the prohibition of corruption.

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

The company commits all suppliers to ethical conduct and the prohibition of corruption.

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

The company reports that it conducts training on ethics and anti-corruption policy. It also states that anti-corruption procedures are communicated through an agreement such as Surat Perjanjian Kerja - SPK. However, the information is self-reported.

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?

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 procedure including a flowchart or clear description of steps taken and how whistleblowers can report unethical conduct and how they are protected.

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

The company has its own grievance mechanisms which are open to all stakeholders.

182. Details of complaints and grievances disclosed?

The company received 32 complaints in 2022 out of which 26 have been resolved, 1 in progress and 7 were identified as invalid.