Woodbois

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 has a 'Reforestation and Sustainability Manager'- Mr. Macedo Uachuacho in Mozambique and ESG manager- Mr. Richard Feteke in Gabon.

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

0 - Mr. Hadi Ghossein oversees the company's sustainability practices on a day-to-day basis and is a member of the board.

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

The company reports 31% women comprise of its senior management as of 2020.

6. Percentage or number of women board members?

The company reports that 20% of board members were women in 2020.

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] ATIBT, CBFP.

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

The company reports collaboration with DiginexESG, for monitoring and validation of the company's 2019 and 2020 ESG disclosures in line with the Global Reporting Initiative (GRI) Standards. The company also has created a 'Traceability Assessment Guide (TAG)' in collaboration with the 'Smurfit Business School'.

9. Sustainability report published within last two years?

The company published an integrated report in 2022 covering 2021.

10. Reports through standardised reporting systems?

The company's integrated report 2021 refers to Global Reporting Initiative (GRI), however, the GRI standard (i.e. core or comprehensive option) that was used to prepare the report is not mentioned.

11. Climate risks assessment available?

The company only reports information on developing a complete climate change risk assessment. However, no assessment is publicly available yet.

12. Natural capital assessment available?

The company only reports information on developing a 'Natural Capital Assessment' based on the protocol provided by the 'Natural Capital Coalition'. However, no assessment is publicly available yet.

13. Lists countries and operations?

The company has forest concessions and timber production facilities in Gabon and Mozambique.

14. Lists countries sourcing from?

The company reports that it mainly sources and trades products from African nations.

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

337460 - The company owns 405,816 ha of natural forest concessions in Gabon and Mozambique, among which 337,459.50 ha (83%) are operational forests. Data as of December 2020.

16. Total area of forest plantation (ha)?

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

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

This indicator is disabled as the company reports that it does not source from outgrower smallholder suppliers.

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

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

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

16232.6 - The company reports that 16,232.60 ha or 4% of its concessions are conservation areas. Data as of December 2020.

20. 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.

21. Number of Forest Management Units (FMUs)?

2 - The company reports that it has two Forest Management Units.

22. Maps of forest management units (FMUs)?

Maps of the company's concessions in Gabon are available on the Open Timber Portal (Lynn Timber) and maps of the company concessions in Mozambique are published on the company website.

23. Forest management plans available for all FMUs?

The forest management plan is only available for company's Gabon concessions. A management plan for company's concessions in Mozambique is not publicly available.

24. Monitoring of forest management plan implementation available?

Limited monitoring details are available for the company's management plan for Gabon concessions. The management plan and monitoring information for the company's Mozambique operations is not available.

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

[Externally verified] The company has provided 50% valid legal documents to Open Timber Portal on use right. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

[Externally verified] The company has provided 33% valid legal documents to Open Timber Portal on forest management. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

[Externally verified] The company has provided 20% valid legal documents to Open Timber Portal on timber harvesting. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

29. Number of company owned sawmills?

2 - The company owns one sawmill in Gabon and one sawmill in Mozambique.

30. Names and locations of company owned sawmills?

The company reports the details of its sawmills in Gabon and Mozambique along with their coordinates in its sustainability report.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

The company states all logs processed in company's sawmills are from the its own operations. Evidence as of 2020.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

35. Number of third party supplying mills?

42 - The company reports the total number of supplying sawmills as 42. Data as of December 2020.

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

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

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

The company reports it has a process in place for the tracing of both raw material and the processed timber it supplies back to the country of harvest.

39. Percentage of supply traceable to country of harvest?

100 - The company reports that 100% of its third party timber supply is traceable.

40. Procedures to trace raw materials to FMU level?

The company uses the same procedure to trace the raw materials to FMU level and country of harvest.

41. Percentage of supply traceable to FMU level?

The company reports that 100% of its third-party supply is traceable (documents regarding country of origin and FMU are provided). Data as of December 2020.

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

The company commits to achieve 100% legality of FMU's by 2029 using FSC verification.

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

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 legally verified wood by 2029 using FSC verification.

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?

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

The company commits to become 100% FSC FM certified by 2029.

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

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

The company reports that within next ten years, it is committed to only source wood/wood fibre that meets FSC Controlled Wood requirements.

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

51. Commitment to zero conversion of natural ecosystems?

The company commits to zero conversion of natural ecosystems.

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

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

53. Commitment to zero deforestation?

The company commits to zero deforestation and zero conversion of all natural ecosystems.

54. Commitment to zero deforestation applies to all suppliers?

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

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

The company reports no deforestation of natural forests, IFL's and HCV's. Deforestation of these forests has not been accepted since January 2020.

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

The company reports that in 2019, it began using Global Forest Watch to monitor deforestation in its concession areas. However, evidence does not state how often deforestation is monitored.

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

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

0 (0%) - In 2020, the company reported that no deforestation had occurred in its operational area since January 2020.

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

60. Commitment to restoration of deforestation/conversion?

The company commits to restore ecosystems to their prior condition in cases of conversion within its own operations.

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

The company's commitment to restoration of non-compliant deforestation applies to all its suppliers, however, a cut-off date beyond which deforestation or conversion would not be accepted is not reported.

62. Implementing a landscape or jurisdictional level approach?

The company only commits to implementing a landscape-level approach to preserve animal habitats and biodiversity. However, examples of the commitment could not be found.

63. Biodiversity policy?

64. Biodiversity policy applies to all suppliers?

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

The company has identified species of conservation concern, referencing IUCN system of species classification. However, the information reported is not externally verified.

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

The company only reports one example of its reforestation project in Mozambique to rehabilitate degraded land after its abandonment by local farmers using slash-and-burn by planting native species.

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

The company commits to only allow sustainable hunting of species by local communities for subsistence purposes in its operations.

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

The company commits all suppliers to only allow sustainable hunting of species by local communities for subsistence purposes in their operations.

69. Commitment to protect forest areas from illegal activities?

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

70. 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.

71. Evidence of protecting forest areas from illegal activities?

The company reports limited information which includes closing of roads after harvesting to prevent poaching and illegal settlements.

72. Commitment to no use of genetically modified organisms?

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

73. 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.

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

The company commits to conduct HCV assessments.

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

The company commits all suppliers to conduct HCV assessments.

76. High Conservation Value (HCV) assessments available?

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

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

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

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

The company reports to adopt the High Carbon Stock approach to any future potential plantation timber suppliers.

80. High Carbon Stock (HCS) assessments available?

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

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

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

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

The company commits to conduct social and environmental impact assessments.

83. 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.

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

The social and environmental impact assessment (SEIA) along with the associated management and monitoring plan is available for the company's Gabon concession. However, this assessment is not externally verified.

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

[Externally verified] The company has provided 33% valid legal documents to Open Timber Portal on impact assessments. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

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

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

The company only commits its suppliers to not plant on peatland, however, the depth of peatland is not specified in the commitment.

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

0 (0%) - The company reports that as of 2020, it does not have any peatland area in its landbank.

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

This indicator is disabled as the company reports that it does not have landbank on peat.

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

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

91. 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.

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

The company reports one example of best management practices for soils (reducing impact of logging roads). The company has no landbank on peat, so examples for peat soils are not required for scoring. Information is not externally verified.

93. 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.

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

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

95. Evidence of implementing reduced impact logging practices?

The company reports examples of minimising impacts of logging roads and other reduced impact logging practices in its latest integrated report. However, this information is not externally verified.

96. Commitment to zero burning?

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

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

98. Evidence of fire monitoring and management?

The company reports using Global Forest Watch data to monitor forest fires and has a proactive three-pronged approach – effective weed control, firebreak construction and ringhoed trees as a preventative measure to fight fires. However, information on management of reported fires is not reported by the company.

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

0 (0%) - The company reports zero fires in its FMUs in 2020.

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

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

The company reports that it is committed to creating net zero CO² emissions from its combined activities and aims to achieve a balance between the greenhouse gases it produces and the amount it is able to sequester from the atmosphere by 2030.

102. GHG emissions intensity?

The company reports the GHG emissions intensity figures for 2020 as 0.10 tCO2/m3 for logs and 0.20 tCO2/m³ for timber.

103. GHG emissions from land use change?

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

104. Progress towards commitment to reduce GHG emissions intensity?

The company reports GHG emission intensity for 2020 (0.10 tCO2/m3 for logs and 0.20 tCO2/m³ for timber) and 2021 (0.095 tCO2/m3 for logs and 0.16 tCO2/m³ for timber). Figures are not externally verified.

105. Methodology used to calculate GHG emissions?

The company reports that it calculates GHG emissions from "Wood Products Manufacturing Facilities Workbook Version 1.0".

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

107. Water use intensity?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

108. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

111. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

The company reports it does not currently use water for industrial purposes at its sawmill, it has irrigation in place to control rain run-off, it also collects grey water for use.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

114. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways using buffer zones.

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

A map of buffer zones has been self-reported.

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

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

117. 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.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

119. 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.

120. 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.

121. 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.

122. 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.

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

The company states that it used no chemicals in its operations in 2020.

124. Implementation of commitment to reduce chemical usage?

The company reports that it doesn't use chemicals in any forestry, sawmill or veneer operations, including pesticides and chemical fertilisers. The company reports to have used '0' chemicals and pesticides in 2019 and 2020. However, this information is not externally verified.

125. Integrated Pest Management (IPM) approach?

The company reports that it doesn't use chemicals in any forestry, sawmill or veneer operations, including pesticides and chemical fertilisers. To capture and dispose of pests, it uses an integrated management approach with non-chemical devices. However, this information is not externally verified.

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

[Externally verified] The company reports multiple examples of waste management. An externally verified report verifies the existence of a waste management system but gives no detail on the system in place.

127. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

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

129. Progress on human rights commitment ?

The company reports that in the second half of 2020, it began providing educational training around issues such as human and workers rights and in 2021, the company further formalized this process by hiring a dedicated ESG manager (Richard Feteke) in Gabon who will supervise this initiative. However, the information reported is not externally verified.

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

The company commits to the UN Declaration on the Rights of Indigenous Peoples.

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

The company commits all suppliers to the UN Declaration on the Rights of Indigenous Peoples.

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

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

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

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

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

The company reports commitment to free, prior and informed consent (FPIC).

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

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

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

The details of free, prior and informed consent (FPIC) process is available.

137. Examples of local stakeholder engagement to prevent conflicts?

The company reports that its teams are actively engaged in community consultations to ensure it respects local customs and its contributions have meaningful value. The company is also financially contributing to the development of villages SaintMartin and Mboukou. However, the information reported is not externally verified.

138. Details of process for addressing land conflicts available?

The company has published its process for addressing land conflicts.

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

The company supports the inclusion of women across forestry operations and reports multiple examples for inclusion of women in the forestry operations. However, this information is not externally verified.

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

Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance here: http://www.opentimberportal.org/operators.

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

The company commits to enabling sustainable use of non-timber forest products (NTFPs) by local communities.

142. Commitment to provide essential community services and facilities ?

The company commits to provide essential community services and facilities.

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

The company reports building a road, providing tools and equipment, restoring land and donating to funds for local communities. Information is not externally verified.

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

The company commits to provide business and work opportunities for local communities.

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

[Externally verified] The company has provided 33% valid legal documents to Open Timber Portal on labour regulations. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

The company commits to the Fundamental ILO Core Conventions.

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

The company commits its suppliers to the Fundamental ILO Core Conventions.

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

The company reports that in 2020, it began providing educational training around issues such as human and workers rights. In 2021, the company further formalized this process by hiring a dedicated ESG manager (Richard Feteke) in Gabon who will supervise this initiative. However, the information reported is not externally verified.

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

The company commits to eliminate gender related discrimination with regards to employment.

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

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

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

The company reports that in 2020, it began providing educational training around issues such as eliminating gender inequality within its workforce. In 2021, the company further formalized this process by hiring a dedicated ESG manager (Richard Feteke) in Gabon who will supervise this initiative. However, the information reported is not externally verified.

152. Percentage or number of temporary employees?

205 (79.15%) - In 2020, 79.15% of workers in processing facilities in Gabon and Mozambique were temporary. Figures are not reported for the rest of operations.

153. Percentage or number of women employees?

43 (16%) - Figures as of 2020.

154. Commitment to pay a living wage?

The company reports its commitment to pay at least minimum wage. However, a commitment to pay living wage is not reported by the company.

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

The company commits its suppliers to pay at least minimum wage. However, a commitment to pay living wage is not reported by the company.

156. Progress on commitment to pay a living wage?

49% - The company states that employees are paid 49% above the minimum wage but does not state the local minimum or living wage or entry level wage paid by the company. Information is not externally verified.

157. Reporting of salary by gender?

The company reports that it pays female employees the equivalent of 81% of a male employee's salary in Gabon and Mozambique, which is above the national average as per the 'Gender Gap Africa'.

158. Commitment to address occupational health and safety?

The company commits to address health and safety, referencing the ILO Code of Practice on Safety and Health in Forestry Work.

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

The company commits its suppliers to address health and safety, referencing the ILO Code of Practice on Safety and Health in Forestry Work.

160. Provision of personal protective equipment and related training?

The company reports evidence that it provides personal protective equipment (PPE) and related training to its employees. Only evidence PPE is used is externally verified via an audit.

161. Time lost due to work-based injuries?

9.25 - The company reports a 'Total Recordable Injury Frequency Rate (TRIFR)' of 9.25% in 2020.

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

0 - The company reported zero fatalities in the workplace for 2020.

163. Commitment to support smallholders?

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

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

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

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

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

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

The company has a due diligence process inspired by EUTR/FLEGT to assess all its suppliers on compliance with company's policy and legal requirements.

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

The company reports that it only sources forest products from partners that have succeeded in passing due diligence processes for legal and responsible forest product sourcing and that suppliers are assessed regularly. However, it also has a target for all suppliers to be compliant with sourcing policies by 2030 - this implies not all suppliers are currently compliant with requirements and the number of suppliers assessed/and or engaged on compliance has not been reported.

168. Suspension or exclusion criteria for suppliers?

The company reports that if third-party suppliers do not meet its selection criteria, they are placed on an exclusion list which forbids its traders from conducting business with them. However, the selection criteria and steps taken before exclusion/timeframes for action have not been reported.

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

The company has published a target of the year 2030 for all suppliers to be in compliance with timber and pulp sourcing commitments but no KPIs or milestones have been reported.

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

171. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and prohibition of corruption.

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

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

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

The company reports that in 2020, it began providing educational training around issues such as ethical conduct. In 2021, the company further formalized this process by hiring a dedicated ESG manager (Richard Feteke) in Gabon who will supervise this initiative. However, the information reported is not externally verified.

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

[Externally verified] The company has provided 100% valid legal documents to Open Timber Portal on legal registration. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

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

Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance here: http://www.opentimberportal.org/operators.

177. Whistleblowing procedure?

The company reports its whistleblowing procedure including how whistleblowers are protected in its latest integrity report.

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

The company has its own grievance system that is open to all stakeholders.

179. Details of complaints and grievances disclosed?