Golden Pharos

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

The company's sustainability commitments are reported as part of different policies available on its website, covering multiple dimensions of sustainability across the company's operations.

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

3. High-level position of responsibility for sustainability?

The company reports it has a sustainability committee headed by the Chief Sustainability Officer (CSO)- Zulkifli bin Omar.

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

The company's board of directors sit at the top of the company's sustainability governance structure.

5. Reports gender balance of senior management team?

2 - The company reports 12 members as a part of its senior management team, of which two are women. Data as of 2023.

6. Reports gender balance of board members?

1 - The company reports that one female director out of a total of eight directors represented 13% of the board composition during FY2023.

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 collaborating with organisations like WWF and the Department of Wildlife and National Parks (PERHILITAN) to identify threatened and endangered species. In FY2023, the company planted tree saplings at Ladang Hutan GPFP, Jerangau in support of the Greening Malaysia programme, 100 million Tree-Planting Campaign 2021-2025 under the auspices of the Energy and Natural Resources Ministry with cooperation from the Forestry Department of Peninsular Malaysia, State Forest Departments, Forest Research Institute of Malaysia and State Governments.

9. Sustainability report published within last two years?

The sustainability report is published in 2024 as a part of the company's annual report covering the year 2023.

10. Reports through standardised reporting systems?

11. Climate risks assessment available?

12. Natural capital assessment available?

13. Lists countries and operations?

Malaysia (forest concessions, sawmills, plywood mill).

14. Lists countries sourcing from?

The company sources wood from Malaysia.

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

129143 - The company controls 126,274 ha of forest concessions and 2,869 ha of forest plantations in Malaysia. Data as of 2023.

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

0

17. Total area of forest plantation (ha)?

287 - The company reports that as of 31 December 2023, it has 287 ha of planted forests.

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

0

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

0

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

12799 - The company reports that a total of 12,267 ha has been reserved as protected areas and states having HCVA of 525 ha at DTC and 7 ha at its Cherul Forest Concession (CFC). A clear figure on total conservation set-aside areas, including HCV areas, is not known.

21. Area of Intact Forest Landscape (ha)?

0

22. Number of Forest Management Units (FMUs)?

2 - The company reports that it operates two FMUs under its subsidiary KPKKT- Cherul Forest Concession (CFC) and Dungun Timber Complex (DTC).

23. Maps of forest management units (FMUs)?

24. Forest management plans available for all FMUs?

A summary of the forest management plan is available for all FMUs of the company.

25. Monitoring of forest management plan implementation available?

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 have forest management operations 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 have forest management operations 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 have forest management operations in a country currently covered by Open Timber Portal.

29. Maps of all third-party supplying FMUs?

30. Number of company owned sawmills?

2 - The company owns two sawmills.

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 makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

40. Percentage of supply traceable to country of harvest?

41. Procedures to trace raw materials to FMU level?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

42. Percentage of supply traceable to FMU level?

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

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

97.77% - 126,274 ha of the company's total landbank of 129,143ha is certified under FSC FM standards.

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?

97.77% - 126,274 ha of the company's total landbank of 129,143ha is certified under FSC FM standards.

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)?

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?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

55. Commitment to zero deforestation applies to all suppliers?

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's partial FSC FM or CoC certification.

57. Criteria and cut-off date for defining deforestation and/or ecosystem conversion 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 FSC FM certification (FSC-STD-01-001 V5-2 EN). As the Standard does not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded.

65. Biodiversity policy?

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 FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. The company has also identified species of conservation concern, referencing the CITES and IUCN Red List. However, own reporting is not externally verified.

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. The company reports that it partners with NGOs, including the WWF, to identify threatened and endangered mammal species. However, limited details are provided.

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

The company only commits to no hunting and poaching of wildlife and birds. It is unclear if this commitment covers no hunting of all species in all concessions of 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?

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

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

73. Evidence of protecting forest areas from illegal activities?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria.

74. Commitment to no use of genetically modified organisms?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its commitment to conducting High Conservation Value (HCV) assessments.

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

78. High Conservation Value (HCV) assessments available?

The High Conservation Value (HCV) assessments for all FMUs of the company are available. However, these assessments are not externally verified.

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

The High Conservation Value (HCV) management and monitoring plans are available for all FMUs of the company. However, these plans are not externally verified.

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 only commits to conducting social 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 social and environmental impact assessments (SEIAs) are available, however, the management and monitoring plans are only available for some FMUs of the company and provide limited details.

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 have forest management operations 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 soils and peat.

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 FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

95. Commitment to reduced impact logging?

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

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

97. Evidence of implementing reduced impact logging practices?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC. The company also reports multiple examples of minimising impacts of logging roads and other reduced-impact logging practices in its FM plan.

98. Commitment to zero burning?

99. Commitment to zero burning applies to all suppliers?

100. Evidence of fire monitoring and management?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

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

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

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

104. GHG emissions intensity?

The company reports GHG emission figures (scope 1 and scope 2) in 2023 separately for all its operations; however, the figures are not reported as 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?

The company reports GHG emission figures (Scope 1, 2, 3) for the whole group as 3,962.4 CO2 e (MT) in 2023 and 3,465.4 CO2 e (MT) in 2022. The figures are not reported as intensity and also reflect an increase in 2023 as compared to 2022.

108. Methodology used to calculate GHG emissions?

The company reports using Intergovernmental Panel on Climate Change (IPCC) GHG Protocol for quantifying 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.

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?

[Externally verified] Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

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

The company commits to minimise the use of chemicals but does not mention chemical fertilisers or 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?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

128. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

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 FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. The company reports adopting a circular economy approach to minimise waste generation, which involves innovative initiatives to utilise production byproducts, including sawdust and woodchips. However, the information is limited and not externally verified.

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to the Universal Declaration of Human Rights.

131. Commitment to human rights applies to all suppliers?

132. Progress on human rights commitment ?

The company only states that there were no complaints of human rights violations during 2025.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company commits to respecting the rights of local communities and indigenous peoples, 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 makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's partial FSC FM or CoC certification. The company also reports its own commitment to respect legal and customary land tenure rights, however, the commitment is reported in relation to FPIC.

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

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

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

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?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. The company provides limited details on local stakeholder engagement to prevent conflicts, including maintaining a dialogue with the Orang Asal community. In addition, its subsidiary companies KPKKT and PESAMA are active members of the Joint Consultative Committee, which is tasked with addressing any forest land ownership conflicts that may arise.

141. Details of process for addressing land conflicts available?

The company has procedures in place for addressing land conflicts.

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

The company reports limited information to support the inclusion of women across forestry operations, which includes offering opportunities to women to occupy roles in tree nurseries or planting, apart from management and administration.

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 have forest management operations 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 provide essential community services and facilities.

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

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

The company commits to provide work opportunities for local communities.

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

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

149. 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 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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 FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

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

The company reports a commitment to maintain a non-discriminatory workplace with regard to gender and also has a gender equality policy in place.

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

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

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

The company has a procedure in place to deal with cases of sexual harassment in the workplace and mentions that no incidents of discrimination were reported during FY2023. However, the details on how the procedure is implemented is not reported.

155. Percentage or number of temporary employees?

153 (34%) - The company reports 153 contract workers and a total workforce of 448 in 2023.

156. Reports gender balance of employees?

134 (30%) - The company reports that 30% of its total workforce is women. Data as of December 2023.

157. Commitment to pay a living wage?

The company only commits to paying the minimum wage.

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

159. Progress on commitment to pay a living wage?

1800 - The company only reports the ratio of the minimum wage to the local minimum wage by country of operation.

160. Reporting of salary by gender?

The company reports the ratio of entry-level wages versus minimum wages for men and women. However, the information is from 2020 and is over two years old and is not split as per the employee category or significant locations of operation in line with GRI reporting.

161. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification. The company's own reported commitment to addressing health and safety 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?

The company commits suppliers to addressing health and safety, however, the commitment does not reference the ILO Code of Practice on Safety and Health in Forestry Work.

163. Provision of personal protective equipment and related training?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2 and FSC-STD-60-004) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

164. Time lost due to work-based injuries?

6.3 - Loss Time Injury Frequency Rate (LTIFR) is reported as 6.3% in FY2023.

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

0 - The company reports zero deaths in 2023.

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?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria.

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 that it provides regular training on existing policies to ensure its employees conduct themselves with the utmost integrity and assurance. Additionally, the company has also established an Integrity Governance Unit (IGU) to oversee all activities and complaint management, which reports directly to both the MACC and the board semi-annually. In 2023, there were no incidents of corruption. 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 have forest management operations 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 have forest management operations in a country currently covered by Open Timber Portal.

180. Whistleblowing procedure?

The company reports its whistleblowing policy and procedure.

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

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification. The company's own reporting also mentions having a grievance mechanism open to all stakeholders, however, the flow chart of grievances is only reported for local communities.

182. Details of complaints and grievances disclosed?