Veracel

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

The company has publishes periodic sustainability report but has a generic management policy and not specific to sustainable forest policy.

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

3. High-level position of responsibility for sustainability?

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

Chief Sustainability and Corporate Relations Officer is a member of the board with responsibility for sustainability.

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

0 - The sustainability report 2019 mentions that there are no women in the senior management team.

6. Percentage or number of women board members?

0 - There are no women in board member.

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 and PEFC member.

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

Participant in WWF's New Generation Plantation Platform.

9. Sustainability report published within last two years?

Sustainability report for 2019 is available.

10. Reports through standardised reporting systems?

Report prepared in accordance with GRI standards and published on GRI database.

11. Climate risks assessment available?

12. Natural capital assessment available?

13. Lists countries and operations?

Brazil- Plantation and Production facilities.

14. Lists countries sourcing from?

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

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)?

87,556 - Data as of 2020.

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

22,584 - Area within Forest Producer Program. Data as of 2020.

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

10,090 - Data as of 2018.

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

99,666 - Data as of 2020.

20. Area of Intact Forest Landscape (ha)?

21. Number of Forest Management Units (FMUs)?

1 - Data as of 2021.

22. Maps of forest management units (FMUs)?

The company has a static map of its FMU, however it is not georeferenced.

23. Forest management plans available for all FMUs?

Summary of the Management Plan publicly available.

24. Monitoring of forest management plan implementation available?

Points for external verification have been awarded on the basis of the company's FSC certification. As the P&Cs do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator. The company's FMP also shows examples of monitoring from 2018, however, it is not externally verified.

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

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

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

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

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

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

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

29. Number of company owned sawmills?

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

30. Names and locations of company owned sawmills?

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

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

1 - Company reports number of pulp and paper mills owned.

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

Name and address of mill available.

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

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

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

The company reports to source 25% of raw material for pulp production from 97 members of Forestry Producer Program.

35. Number of third party supplying mills?

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

This indicator is disabled as the company reports that it doesn't source from supplying mills.

37. Reports total volume (or percentages) sourced from third-party supplying mills that come from the supplying mills' own operations and/or third parties?

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

The company has FSC/Cerflor CoC certification and states to use the FSC/Cerflor due diligence system and controlled wood criteria for non-certified supply to trace all raw materials to the origin.

39. Percentage of supply traceable to country of harvest?

100 - The company has FSC/Cerflor CoC certification and states to use the FSC/Cerflor due diligence system and controlled wood criteria for non-certified supply to trace all raw materials to the origin.

40. Procedures to trace raw materials to FMU level?

The company has FSC/Cerflor CoC certification and states to use the FSC/Cerflor due diligence system and controlled wood criteria for non-certified supply to trace all raw materials to the origin.

41. Percentage of supply traceable to FMU level?

The company has FSC/Cerflor CoC certification and states to use the FSC/Cerflor due diligence system and controlled wood criteria for non-certified supply to trace all raw materials to the origin.

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

The company's FMU is 100% FSC verified.

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

100% - The company's only FMU is 100% FSC certified.

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

The company commits to only source wood that is either FSC or Cerflor certified or fulfil the FSC Controlled Wood however it is unclear if the non-FSC/PEFC certified part of the wood supply is FSC CW certified or the company checks the criteria itself, therefore not externally 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?

46. Percentage area (ha) FSC FM certified?

100% - All of the company's 198.050,38 ha landbank is FSC certified.

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

The company's only FMU is 100% FSC certified.

48. Percentage of wood/wood fibre supply (tonnes) from all suppliers that comes from FSC FM certified areas?

The Company has contracts with forest producers under the Forestry Producer Program (PPF) program but the company has not reported on the percentage of supply that comes from FSC FM certified areas of PPF program or any independent suppliers.

49. Commitment to source only wood/wood fibre that meets FSC Controlled Wood and/or PEFC Controlled Sources requirements?

Veracel's Wood Purchase Policy commits to source wood to meet FSC CW or PEFC controlled source.

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

This indicator is disabled as the company is either 100% FSC FM certified or is >75% certified and has a commitment to achieve 100% within 5 years.

51. Commitment to zero deforestation or zero conversion of natural ecosystems?

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

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

The company states in its ?Wood Purchase Policy' that no wood will be sourced from "natural forest that has been converted into non- forest use or plantation forests".

53. Criteria and cut-off date for defining deforestation?

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

54. Evidence of monitoring deforestation?

[Externally verified] The company monitors vegetation cover and land use on its area via an initiative by ?The BioAtlantic Institute (IBIO)' which is updated every three years. Monitoring includes satellite images and on-site verifications.

55. Evidence of monitoring deforestation in supplier operations?

56. Amount of illegal/non-compliant deforestation recorded?

0 - The company states no forest loss was recorded in its managed area from 2013 to 2018. As data is more than two years old full points cannot be awarded.

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

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

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

60. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company does landscape management with Atlantic Forest Program.

61. Commitment to biodiversity conservation?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

62. Commitment to biodiversity conservation applies to all suppliers?

Applies to producers under PPF program.

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

[Externally verified] Company monitors High Conservation Value Areas (AAVC) and identified species under certain categories of IUCN.

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

Points for external verification have been awarded on the basis of the company's FSC/PEFC certified landbank/volume (whichever is highest).

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

The company practices joint efforts to combat hunting but no formal commitment available. The company also makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). As the P&Cs do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

67. Commitment to protect forest areas from illegal activities?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

69. Evidence of protecting forest areas from illegal activities?

Points for external verification have been awarded on the basis of the company's FSC/PEFC certified landbank/volume (whichever is highest).

70. Commitment to no use of genetically modified organisms?

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

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

Company states not purchasing raw material from unacceptable or controversial sources like wood harvested from genetically modified trees.

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

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

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

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

74. High Conservation Value (HCV) assessments available?

[Externally verified] A HCV summary is available, and a basic summary is available in the company's FSC audit report.

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

HCV area monitored but information is not externally verified.

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

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

78. High Carbon Stock (HCS) assessments available?

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

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

[Externally verified] Summary of SEIAs is available but but do not have management plan.

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

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

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

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

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

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

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

The company has detailed the best management practices and company states no landbank on peat. The company also makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded for this indicator on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

The company's Best management practices states 'The water and soil monitoring is carried out in its own as well as lands owned by Produtor Florestal program's members.' But no clear commitment to best management practices for soils and peat applying to all suppliers.

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

The company reports that it does not have operations on peatland. Points for external verification have been awarded on the basis of the company's FSC certified landbank/volume.

90. Commitment to reduced impact logging?

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

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

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

92. Evidence of implementing reduced impact logging practices?

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

93. Commitment to zero burning?

The company has no direct commitment to zero burning but reports through the Management plan to prevent and fight forest fires.

94. Commitment to zero burning applies to all suppliers?

95. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's PEFC certification.

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

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

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

99. GHG emissions intensity?

100. GHG emissions from land use change?

101. Progress towards commitment to reduce GHG emissions intensity?

102. Methodology used to calculate GHG emissions?

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

Company committed reduce to water use for pulp production from 25m³/tsa to 22.5m³/tsa by 2020 and in 2019 it was 22m³/tsa. A new goal in 2021 has been set to stay below 22 m³.

104. Water use intensity?

22.2 - Figure as of 2020.

105. Progress towards commitment on water use intensity?

The company reported 22.2m³/tsa in 2019 and 2020, which is consistent with the target to stay below 22.5.

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

The company conducted water monitoring until 2017, the results showed that the river water quality had met the Conama's requirements (Conama Resolution 357, of March 17, 2005, Class II) for human consumption. Water monitoring continues but it is not clear if levels remain within legal limits or if there is a timebound commitment to improve BOD and COD levels.

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

The company reports an improvement in BOD and COD over time.

108. Treatment of pulp and paper mill effluent?

Company states that the Effluent Treatment Station (ETE) has efficiency of organic load removal (over 98%) and provides figures for each method used to recycle waste.

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

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

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

111. Commitment to protect natural waterways through buffer zones?

Company shows concern about the effects of planted forest management on water and that waterways will be avoided and protected.

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

The company practices the allocation of legal reserves by hydrographic basin (e.g. RPPN), but SOP's are not available. Points for external verification have been awarded on the basis of the company's FSC certification. As the P&Cs do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

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

The company reports chemical usage per hectare as well as list of chemicals used.

121. Implementation of commitment to reduce chemical usage?

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

122. Integrated Pest Management (IPM) approach?

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

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

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

124. Commitment to human rights?

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

125. Commitment to human rights applies to all suppliers?

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

126. Progress on human rights commitment ?

[Externally verified] In 2019, there were 501.26 hours of training in Human Rights were logged for a total of 602 employees.

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

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

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

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

The company makes this commitment through the FSC Policy for Association and PEFC policy.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). As the P&Cs do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

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

134. Examples of local stakeholder engagement to prevent conflicts?

Points for external verification have been awarded on the basis of the company's FSC certification. The company also provides multiple examples of stakeholder engagement to prevent/resolve conflicts are available.

135. Details of process for addressing land conflicts available?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). As the P&Cs do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

The company supports women in nursery and forestry activities. A collective agreement signed with Union of Rural Workers of Eunápolis establishes a period of leave of up to 8 months for pregnant women and in periods of breastfeeding and / or relocation of function.

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

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

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

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

139. Commitment to provide essential community services and facilities ?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

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

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

The company commits to provide business/work opportunities to local communities along with along with PPF program (outgrower scheme).

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

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

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification.

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

[Externally verified] The company reports the trainings to the employees and strengthening the culture of Code of Conduct.

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

The company with its code of Conduct commits to prevent any type of discrimination.

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

The company through its Code of conduct states to eliminate gender discrimination and it applies to suppliers.

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

Company conducts Internal audits and compliance area to handle cases related to discrimination.

149. Percentage or number of temporary employees?

This indicator is disabled as the company has informed ZSL that it doesn't have temporary employees.

150. Percentage or number of women employees?

264 (8.27%) - As per GRI indicator the company and its third party collaborators have 264 female employees.

151. Commitment to pay at least minimum wage?

Lowest salary (in R$) paid in 2018 is 20.02% and in 2019 it was 15.28% higher than the local minimum wage.

152. Commitment to pay at least minimum wage applies to all suppliers?

153. Progress on commitment to pay at least minimum wage?

The company reports that the lowest salary paid by Veracel was 15.38% higher than the local minimum wage in 2020.

154. Reporting of salary by gender?

The company reports the pay for apprentices by gender.

155. Commitment to address occupational health and safety?

The company commits to health and safety but does not refer to ILO Code of Practice on Safety and Health in Forestry Work. The company also makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). As the P&Cs do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

Company in its Management Plan states Occupational health and safety Management program serves self-employed workers and service providers service. The company also makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004). As the Standard's requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC CoC certification.

157. Provision of personal protective equipment and related training?

Company includes initiatives for Personal Protective Equipment (PPE). Points for external verification have been awarded on the basis of the company's FSC certification. As the P&Cs do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

158. Time lost due to work-based injuries?

121 - Lost days due to injury, data for 2020.

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

0 - The company reports ?0' fatalities as a result of work-based accidents for the year 2018.

160. Commitment to support smallholders?

Company supports smallholder/ farmers through Forest Producer Program.

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

[Externally verified] Forest Producer Program (PPF).

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

97 - As of 2018, the company's Forest Producer Program comprised of 97 producers.

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

The company describes the tools or method that the company uses to prioritise.

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

30 - In 2020, 30 suppliers were evaluated in audits, however it is not clear if these suppliers supply wood/wood pulp to the company or are contractors within the company's operations.

165. Suspension or exclusion criteria for suppliers?

The company takes disciplinary measures by warning, suspension and dismissal.

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

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

168. Commitment to ethical conduct and prohibition of corruption?

Company has a strong commitment towards ethical conduct and prohibition of corruption.

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

Company's code of conduct applies to suppliers.

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

The company conducted training or communication actions in anti-corruption policies and procedures in 2020.

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

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

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

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

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

174. Whistleblowing procedure?

The company has an anonymous reporting line managed by a third party.

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

The company has a complaint and grievance system.

176. Details of complaints and grievances disclosed?

The company only reports broad details of grievances received and does not publish specific details for individual cases.