WTK Holdings

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

The company provides sustainability commitments of the company in its 2022 Annual Report.

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

3. High-level position of responsibility for sustainability?

The company has a Board Risk Management Committee ("BRMC") which is supported by a Group Sustainability Committee ("GSC"), headed by the Managing Director. Other members of the GSC include executive directors, the chief financial officer, and key personnel from various operating units.

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

The company has a 'Group Sustainability Committee (GSC)' which is headed by the 'Managing Director' (member of the board).

5. Reports gender balance of senior management team?

0 - The company reports it has no women in its key senior management team. Data as of 2022.

6. Reports gender balance of board members?

2 - The company currently has two (2) female directors and five (5) male directors, which represents 29% of women directors. Data as of 2022.

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with timber and pulp production?

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

The company reports the engagement approach with different stakeholder groups along with area of interest, however, does not report actions taken (or planned) to reduce negative environmental or social outcomes.

9. Sustainability report published within last two years?

The company published an integrated annual sustainability report in 2023 covering the year 2022.

10. Reports through standardised reporting systems?

11. Climate risks assessment available?

12. Natural capital assessment available?

13. Lists countries and operations?

Malaysia (Sarawak)- timber concessions, and timber processing operations.

14. Lists countries sourcing from?

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

462000 - The company reports it has seven logging licenses with concession areas of approximately 400,000 ha and two licenses for planted forests (LPFs) with concession areas of approximately 62,000 ha. Approximate figures are reported by the company.

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

17. Total area of forest plantation (ha)?

62000 - GFW reflects 10 LPFs with a total area of 211,504 ha and the company reports it has two licenses for planted forests (LPFs) with concession areas of approximately 62,000 ha. Contradictory figures are reported and the company's own reporting is approximate and unclear if covering all areas under forest plantation.

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

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

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

21. Area of Intact Forest Landscape (ha)?

22. Number of Forest Management Units (FMUs)?

18 - Global Forest Watch data reports information on 10 licenses for Planted Forests (LPFs) and 8 logging concessions. However, it is unclear if this covers the company's entire operations.

23. Maps of forest management units (FMUs)?

Maps for ten licenses for Planted Forests (LPFs) and eight logging concessions are reported via Global Forest Watch. However, it is unclear if this covers the company's entire operations.

24. Forest management plans available for all FMUs?

FM plans are only available for some of the company's FMUs.

25. Monitoring of forest management plan implementation available?

[Externally verified] Monitoring of forest management plan implementation is available for two of the company's FMUs. Evidence is externally verified by PEFC and SIRIM.

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 does not operate in a country 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 does not operate in a country 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 does not operate in a country currently covered by Open Timber Portal.

29. Maps of all third-party supplying FMUs?

30. Number of company owned sawmills?

4 - The company reports information on four sawmills within its list of properties in 2022.

31. Names and locations of company owned sawmills?

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

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

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

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

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

35. 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 any pulp or paper mills.

36. Number of third party supplying mills?

37. Names and locations of all third party 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?

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

The company reports that its timber harvesting and plywood manufacturing operations comply with the Sarawak Timber Legality Verification System ("STLVS") and that it has achieved 100% traceability of the supply of logs, from the various licensed areas to the plywood mills of the company's downstream operations. However, it is unclear if the licensed area refers to the company's own operations or that of third-party suppliers.

40. Percentage of supply traceable to country of harvest?

41. Procedures to trace raw materials to FMU level?

42. Percentage of supply traceable to FMU level?

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

The company obtained the Forest Management Certification under the Malaysian Timber Certification Scheme (endorsed by the PEFC) for its FMU- Entulu - Melatai in the year 2020 and for FMU- Mengiong-Gaat in November 2022. The company also reports that its timber harvesting and plywood manufacturing operations comply with the Sarawak Timber Legality Verification System ("STLVS") certification by the Sarawak State Government. However, it is unclear if these certifications cover 100% of the company's operations.

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

The company has 55,112 ha of land certified under PEFC FM for its FMU- Entulu-Melatai and 36,091 ha for its FMU-Mengiong-Gaat. However, the company only reports approximate figures of its total landbank so the PEFC certified cannot be calculated.

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?

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)?

91203 - The company has 55,112 ha of land certified under PEFC FM for its FMU- Entulu-Melatai and 36,091 ha for its FMU-Mengiong-Gaat. However, the company only reports approximate figures of its total landbank so the PEFC certified cannot be calculated.

52. Commitment to zero conversion of natural ecosystems?

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

54. Commitment to zero deforestation?

55. Commitment to zero deforestation applies to all suppliers?

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

The company only reports that as part of its effort to protect the identified HCV areas, these HCV areas are maintained from development. However, the company does not report clearer criteria and cut-off date for defining deforestation.

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

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

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

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?

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 reports a clear scope on protecting biodiversity, however, no measurable time-bound target or commitment is reported.

66. Biodiversity policy applies to all suppliers?

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.

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. Additional points have not been awarded as the company reports approximate figures on its total landbank due to which the percentage of company landbank certified by PEFC cannot be calculated.

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

The company reports enforcing a 'no hunting policy', however, a clear commitment to no hunting of all species is not reported by the company.

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

71. Commitment to protect forest areas from illegal activities?

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

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. Additional points have not been awarded as the company reports approximate figures on its total landbank due to which the percentage of company landbank certified by PEFC cannot be calculated. The company's own reporting only mentions carrying out security patrolling and periodic monitoring to control illegal hunting.

74. Commitment to no use of genetically modified organisms?

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

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?

78. High Conservation Value (HCV) assessments available?

The HCV summaries are only available for some of the company's FMUs.

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

Summaries of management and monitoring recommendations for HCV areas are available for some of the company's FMUs.

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

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

82. High Carbon Stock (HCS) assessments available?

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

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?

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

The SEIAs for three FMUs are publicly available, however, with very limited or no details on management and monitoring plans.

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 does not operate in a country currently covered by Open Timber Portal.

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

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

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

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

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

The company commits to best management practices for peat only.

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

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. Additional points have not been awarded as the company reports approximate figures on its total landbank due to which the percentage of company landbank certified by PEFC cannot be calculated. The company's own reporting provides limited information for some operations which includes maintaining water at optimum levels, draining excess water to prevent peat degradation, and providing technical and advisory support for ongoing management and care for the peatland.

95. Commitment to reduced impact logging?

The company reports conducting training programs on Reduced Impact Logging Plan (RILP) in 2022, however, does not report a clear commitment to reduced impact logging.

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

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.

98. Commitment to zero burning?

The company commits to zero burning.

99. Commitment to zero burning applies to all suppliers?

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 not been awarded as the company reports approximate figures on its total landbank due to which the percentage of company landbank certified by PEFC cannot be calculated.

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

0 (0%) - The company reports that no open burning occurred in 2022 in the areas owned and operated by the company.

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

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

104. GHG emissions intensity?

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?

108. Methodology used to calculate GHG emissions?

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

110. Water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

111. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

114. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

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

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

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?

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

122. Commitment to no use of 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?

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

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

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

127. Implementation of commitment to minimise inorganic fertiliser usage?

The company only mentions that in its effort to uphold a sustainable planting culture, it has scaled down its reliance on fertilisers, pesticides, and herbicides. However, figures for reduction are not reported by the company and the information is over two years old now.

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 not been awarded as the company reports approximate figures on its total landbank due to which the percentage of company landbank certified by PEFC cannot be calculated.

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 reports having a waste management system in place for all its timber operations. However, the information reported is not externally verified.

130. Commitment to human rights?

The company reports a commitment to support and respect human rights, however, does not reference the Universal Declaration of Human Rights or its equivalent.

131. Commitment to human rights applies to all suppliers?

132. Progress on human rights commitment ?

133. Commitment to respect Indigenous Peoples' and local communities' rights?

The company reports a commitment to respect the customary or native rights of Indigenous and local communities. However, the commitment does not reference the UN Declaration/ILO Convention.

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

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

The company only reports commitment to respect the customary or native rights of Indigenous and local communities. A commitment to respect legal land tenure rights is not reported.

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

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

The company only reports that it ensures that prior informed consent of local communities is obtained through discussions and negotiations before commencing any new operations. However, a clear commitment to respect free, prior and informed consent (FPIC) is not reported by the company.

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

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

140. Examples of local stakeholder engagement to prevent conflicts?

141. Details of process for addressing land conflicts available?

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

The company reports it provides its employees with equal job opportunities and had approximately 4:1 men to women ratio in the workforce in 2022, with women employees assigned to lighter work such as admin clerk, manuring, weeding, cleaning, gardening and loose fruit collection. However, the information on barriers faced is not reported.

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 does not operate in a country currently covered by Open Timber Portal.

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

145. Commitment to provide essential community services and facilities ?

The company reports a commitment to providing essential community services and facilities.

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

The company only reports supporting the local community through donations, helping local institutions, and improving the infrastructure, such as upgrading main roads. However, no specific examples of progress or services are provided by the company.

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

The company reports supporting local communities by creating more employment opportunities.

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 does not operate in a country currently covered by Open Timber Portal.

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

150. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies 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 not been awarded as the company reports approximate figures on its total landbank due to which the percentage of company landbank certified by PEFC cannot be calculated.

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

The company reports a commitment to eliminating gender-related discrimination with regard to employment.

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

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

The company only reports that no incidents of discrimination were reported in the year 2022.

155. Percentage or number of temporary employees?

156. Reports gender balance of employees?

The company only mentions that it had an approximately 4:1 men-to-women ratio in the workforce as of 2022. A clear number or percentage of the number of women employees is not reported by the company.

157. Commitment to pay a living wage?

The company only reports that it has implemented the minimum wage stipulated by the Malaysian Government and its employees are mainly from Malaysia, Indonesia, and Myanmar, and abide by the minimum wage standard. A clear commitment to pay a living wage is not reported by the company.

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

159. Progress on commitment to pay a living wage?

160. Reporting of salary by gender?

161. Commitment to address occupational health and safety?

The company reports commitment to address occupational health and safety, however, the commitment reported does not reference the ILO Code of Practice on Safety and Health in Forestry Work.

162. Commitment to address occupational health and safety 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 not been awarded as the company reports approximate figures on its total landbank due to which the percentage of company landbank certified by PEFC cannot be calculated.

164. Time lost due to work-based injuries?

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

0 - The company reports no fatalities in 2022 across its operations.

166. Commitment to support smallholders?

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

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

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

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

171. Suspension or exclusion criteria for suppliers?

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

173. Proportion of supply from suppliers that is verified as deforestation and/or conversion-free (DCF)?

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and 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 prohibition of corruption.

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

The company reports it has an Anti-Bribery Management System (ABMS) and quarterly risk assessments are in place to evaluate all operations related to corruption, and emerging risks and to develop action plans to mitigate the risk with the guidance from the Board Risk Management Committee. In 2022, there were no reported cases of corruption within the company. However, the information reported is not externally verified.

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 does not operate in a country 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 does not operate in a country currently covered by Open Timber Portal.

180. Whistleblowing procedure?

The company has published its whistleblowing policy which includes a clear description of steps taken, how the whistleblowers can report anonymously, and how they are protected.

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

The company reports having a grievance procedure but limited details are provided and the procedure is reported as a part of the company's whistleblowing mechanism and is only open to company employees.

182. Details of complaints and grievances disclosed?