Klabin SA

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 socio-environmental responsibility policy covering multiple dimensions of both social and environmental issues that applies to all its suppliers.

3. High-level position of responsibility for sustainability?

The company reports three members on its sustainability committees, out of which two are full-time board members, and the other is former CEO and alternate board of directors. However, data is unclear for the position of high-level responsibility.

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

The company has a sustainability committee consisting of three board members.

5. Reports gender balance of senior management team?

198 - The company reports that it has 198 (23.44%) women on its senior management team.

6. Reports gender balance of board members?

3 - The company reports three (14.29%) women on its board of directors.

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

[Externally verified] FSC and UNGC.

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

The company collaborates with various stakeholders such as the Social Progress Index (SPI) was launched in municipalities, supporting & providing education in public schools creating awareness in society of the importance of volunteer work, and giving technical support to small and medium-sized farm owners to operate more efficiently, with profitability, and in an environmentally friendly manner to reduce negative environmental or social outcomes.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2022.

10. Reports through standardised reporting systems?

The company follows GRI standards and has published CDP (Forest, Water Security, and Climate Change Report 2023) on its website.

11. Climate risks assessment available?

The company published the latest CDP climate change report 2023 which has a detailed discussion on climate-related risk assessment.

12. Natural capital assessment available?

13. Lists countries and operations?

Mills (22 in Brazil and one in Argentina) and Planation (22 in Brazil and one in Argentina).

14. Lists countries sourcing from?

The company reports that its suppliers are distributed throughout Brazil.

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

751000 - The company reports the total land area managed/controlled for forestry as 751,000 ha.

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

17. Total area of forest plantation (ha)?

375000 - The company reports the total area of forest plantation as 375,000 ha.

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)?

301980 - The company reports 301,980 ha of conserved areas.

21. Area of Intact Forest Landscape (ha)?

22. Number of Forest Management Units (FMUs)?

3 - The company has three FMUs in Santa Catarina, Sao Paulo, and Parana region.

23. Maps of forest management units (FMUs)?

The company has presented a static map of its forest management units.

24. Forest management plans available for all FMUs?

The company has a forest management plan for all of its FMUs.

25. Monitoring of forest management plan implementation available?

[Externally verified] The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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?

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

31. Names and locations of company owned sawmills?

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

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

23 - The company reports a total of 23 mills of which 22 are in Brazil and one in Argentina.

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

The company reports only static images without coordinates showing the location of all mills.

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

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

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

The company reports that more than 70% of raw material comes from its own operation and approximately 30% comes from certified and controlled wood suppliers. However, this information is only approximate.

36. Number of third party supplying mills?

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

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

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

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

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

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

The company reports that 82% of the company's supply (both certified-own wood and certified wood purchased from third parties) has FSC certification. Also, the company processes non-certified raw materials and carries out audits for all the suppliers every quarter.

40. Percentage of supply traceable to country of harvest?

100 - The company reports that all wood suppliers are traceable and audited based on controlled wood and chain of custody criteria.

41. Procedures to trace raw materials to FMU level?

The company conducts quarterly field audits for all its suppliers and follows controlled wood criteria.

42. Percentage of supply traceable to FMU level?

The company reports that all wood suppliers are traceable and audited based on controlled wood and chain of custody criteria.

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

The company is 100% legality verified by FSC.

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

100% - The company is 100% legality verified by FSC.

45. 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 2030 using FSC verification.

46. Percentage of all wood/wood fibre supply traded/processed verified as being in legal compliance by a third party?

71% - The company's supply chain is 71% FSC certified.

47. Percentage area (ha) FSC FM certified?

100% - The company reports that its area is 100% FSC FM certified.

48. Time-bound plan for achieving 100% FSC FM certification of FMUs within 10 years?

The company is 100% FSC FM certified.

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

71% - The company's supply chain is 71% FSC certified. However, the information is not clear on which part is FM certified and which part is COC certified.

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

The company commits to only source wood/wood fibre that meets FSC Controlled Wood requirements.

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

This indicator is disabled as the company is 100% FSC FM certified.

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. The company also commits to this in its own reporting.

55. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation, however the commitment was made after January 2020.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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

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

The company states that it monitors risk areas by using remote sensing, generating a temporal analysis of forest conversion by using LandSat 1994 images, and the Map Biomass Tool to monitor deforestation, satellite monitoring, and invests in environmental and social programs to assist partner producers to adopt similar practices. However, the information does not specify the extent of the area monitored and the timeframe for monitoring and also it is not externally verified.

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

The company's deforestation control system is done by satellite monitoring and field evaluations and its GIS team is responsible for updating own, leased, and third-party area images through satellite monitoring. However, the time frame and area being monitored are unclear and it is not externally verified.

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

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

0 (0%) - The company reported zero ha of deforestation had occurred in supplier operations since 2008.

62. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

The company has an unclear commitment regarding the restoration of the ecosystem.

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. Additionally, the company also reports some jurisdictional approaches like the creation of the Local Development Forum and the Sustainable Development Forum at the Goiana Unit (facility) to promote local people.

65. Biodiversity policy?

The company states a general statement for the conservation of biodiversity through a monitoring program. However, no commitment or time-bound targets could be found.

66. Biodiversity policy applies to all suppliers?

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

[Externally verified] The company reports that it has identified various species such as 855 fauna, 29 endangered, and 1,968 plant species listed in the UCN Red List. Conecta Consultores has externally verified this information.

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 (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria. Additionally, the company reports mosaic forestry management that combines conserved native forests with planted pine and eucalyptus forests. This form of management helps to protect the conservation of biodiversity through ecological corridors that enable the circulation of hundreds of species of wildlife.

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

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

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

71. Commitment to protect forest areas from illegal activities?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications 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?

The company reports that 71% of wood-based raw materials are certified to a responsible purchasing standard?? in 2021.

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.

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

78. High Conservation Value (HCV) assessments available?

The company reports High Conservation Value (HCV) assessments for all three FMUs in its public summary reports. However, it is not externally verified.

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

The company reports High Conservation Value (HCV) management and monitoring plans for all three FMUs in its public summary reports. However, it is 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 makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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?

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 makes this commitment for soil only through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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 makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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

This indicator is disabled as the company reports that it does not source wood/wood fibre from third-party suppliers OR only sources from plantations.

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.

98. Commitment 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 been awarded according to the percent of company landbank certified by PEFC. Additionally, the company reported its fire prevention measures like telephone numbers which operate 24 hours a day, and structure to combat forest fires, whose main objective was to train field teams in combat.

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

The company reports the number of hotspots for all of its FMUs. However, an overall consolidated figure has not been reported. Hence, the figure column is left blank.

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

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

The company commits to reducing scope 1 and 2 GHG emissions per ton of pulp, paper, and packaging by 25% by 2025 and by 49% by 2035, from a 2019 baseline. This target is verified by the Science Based Targets Initiative (SBTi).

104. GHG emissions intensity?

The company reports that its GHG emissions intensity for 2022 is 262.66 kg CO2e/ton prod.

105. GHG emissions from land use change in company's own operations (scope 1)?

106. GHG emissions from land use change in supplier operations (scope 3)?

107. Progress towards commitment to reduce GHG emissions intensity?

The company reports its GHG emission intensity for 2022 (262.66 kg CO2e/ton prod) in comparison to 2021 (249.79 kg CO2e/ton prod), and 2020 (278.02 kg CO2e/ton prod). However, the intensity figure has not improved from the previous year.

108. Methodology used to calculate GHG emissions?

The company follows the Brazilian GHG Protocol to calculate GHG emissions.

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

The company commits to reduce water intensity by 20% by the year 2030.

110. Water use intensity?

3.6328 - The company reports total water consumption as 3.6328 m³/ton.

111. Progress towards commitment on water use intensity?

The company reports its total water consumption (m³/ton) for 2022 (3.6328) in comparison to 2021 (3.7328).

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

The company reports that BOD and COD are being monitored and compared to global benchmarks, such as the IFC guidelines. However, no time-bound commitment could be found and it is unclear whether this information covers all forestry operations.

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

The company reports that BOD and COD are being monitored and compared to global benchmarks, such as the IFC guidelines, however, the information is insufficient for the progress towards water quality commitment.

114. Treatment of pulp and paper mill effluent?

[Externally verified] The company explicitly mentions the treatment of wastewater from pulp and paper mills. This information has been externally verified by Conecta Consultores.

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

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

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

117. Commitment to protect natural waterways through buffer zones?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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

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 makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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?

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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?

The company reports herbicide and formicide consumption for all three FMUs.

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] The company has a waste management system in place that covers various aspects of timber or pulp production and processing to ensure waste storage, treatment, and disposal practices. In addition, its all units undergo internal auditing by its team. This information has been externally verified by Conecta Consultores.

130. Commitment to human rights?

The company has received full points for its FSC certification, which aligns with its commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). The company also commits to the Universal Declaration of Human Rights in its policy.

131. Commitment to human rights applies to all suppliers?

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

132. Progress on human rights commitment ?

[Externally verified] The company has conducted the EcoVadis assessment to assess suppliers on the topics of Environment, Labor, and Human Rights and analysed the risks and impact of human rights. This information has been externally verified by Conecta Consultores. However, the company does not specify whether it applies to its whole operations or the supply chain.

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

The company's FSC certification ensures compliance with the FSC Policy for Association (FSC-POL-01-004 V3-0), hence, full points are awarded. The company also commits to this in its own reporting.

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

The company has general guidelines to comply with International Labor Organization (ILO) on the Fundamental Rights and Principles at work which applies to all suppliers. However, no commitment could be found.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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

The company commits to this through the FSC and PEFC certification of its supply chain. However, all supply is not 100% certified.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.). The company also commits to free, prior and informed consent (FPIC) in its own reporting.

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 has also reported several examples of local stakeholder engagement activities to prevent conflicts.

141. Details of process for addressing land conflicts available?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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

[Externally verified] The company reports its initiative to support the inclusion of women and minority groups. However, the initiative was not specific to forestry operations. The information has been externally verified by Conecta Consultores.

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?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

145. Commitment to provide essential community services and facilities ?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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?

The company commits to the FSC Policy for Association (FSC-POL-01-004 V3-0) and reports on its certification. The company also commits to this in its own reporting.

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

The company commits to ILO's Declaration on Fundamental Principles and Rights at Work which 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. The company also provides evidence of actions taken to implement its workers' rights in its own reporting.

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

The company commits to no gender-related discrimination with regard to employment.

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

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

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

[Externally verified] The company provides evidence of actions taken to implement its gender policies such as expanding minority groups, raising awareness, and providing training on harassment and discrimination. The information has been externally verified by Conecta Consultores.

155. Percentage or number of temporary employees?

0 (0%) - The company reports zero temporary employees in 2022.

156. Reports gender balance of employees?

3758 (20.39%) - The company reports that it has 3,758 (20.39%) women employees in 2022.

157. Commitment to pay a living wage?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years). The company also reports that it pays wages above the national minimum wage standard.

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

159. Progress on commitment to pay a living wage?

[Externally verified] Limited, externally verified points have been awarded on the basis the company's landbank is either 100% or ?75% (and a further commitment to be 100% certified within 5 years) FSC FM certified (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria, and company only provides evidence that workers are paid minimum wages. The company has also provided evidence that workers are paid minimum wages in its own reporting.

160. Reporting of salary by gender?

The company reports the ratio of the organisation's lowest salary to the local minimum wage by gender? for 2022.

161. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years.). The company also commits to addressing occupational health and safety in its own reporting.

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

The company's commitment to occupational health and safety applies to all suppliers. However, it does not refer to the ILO Code of Practice on Safety and Health in Forestry Work.

163. Provision of personal protective equipment and related training?

Limited, externally verified points have been awarded based on 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 also reports that it provides PPE to 100% of its employees and temporary workers. However, this information is two to five years old.

164. Time lost due to work-based injuries?

1.34 - The company reports the rate of recordable work-related injuries as 1.34 for 2022.

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

0 - The company reports zero fatalities as a result of work-related accidents in 2022.

166. Commitment to support smallholders?

The company commits to supporting smallholders.

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

[Externally verified] The company reports that it supports smallholders by assisting them in achieving FSC certification through its Forest Certification Program. The information has been externally verified by Conecta Consultores.

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

258 - The company reports that 258 farmers were certified by the Small Rural Producers Forest Certification Program in 2022. However, the information is not externally verified.

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

The company reports that it assesses suppliers using the EcoVadis methodology on the topics of Environment, Labor and Human Rights, Ethics, and Sustainable Purchasing.

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

[Externally verified] 73 - The company reports that 73 suppliers were selected from the 4th wave of evaluation of the Corporate Social Responsibility (CSR) Program in the supply chain, using the EcoVadis methodology. This is externally verified data.

171. Suspension or exclusion criteria for suppliers?

The company states that any supplier who does not follow its social and environmental obligations shall be grounded for termination of the agreement.

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 the prohibition of corruption.

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

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

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

[Externally verified] The company provides an Integrity Program that includes prevention and detection actions related to anti-corruption and also conducts training for its employees to mitigate bribery and corruption. The information has been externally verified by Conecta Consultores.

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?

The company describes how it pays taxes to the government and states a governance body which is responsible for the tax strategy in its tax guidance policy.

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 its own whistleblowing channel.

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

The company has an independent ombudsman channel for all internal and external stakeholders to report complaints or grievances.

182. Details of complaints and grievances disclosed?

The company only reports the number of cases checked and confirmed.