Oji Holdings Corp

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 a sustainable procurement policy.

3. High-level position of responsibility for sustainability?

The Secretariat within the company's Corporate Sustainability Department is responsible for sustainability.

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

The company reports it has a sustainability committee chaired by the representative director of the board and the President (Group CEO).

5. Reports gender balance of senior management team?

The company reports the percentage of women in management positions as 13.4% as of December 2023. The data covers all company operations (domestic and overseas), however, it is unclear if it refers to senior management specifically.

6. Reports gender balance of board members?

2 - The company reports 12 members as a part of its board, of which two (2) members are female. Data as of December 2023.

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] Signatory of UNGC.

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

The company reports multiple collaborations with governments, institutions, and NGOs, some of which include joining the 30by30 Alliance for Biodiversity which aims to "protect at least 30% of land and sea by 2030 and a collaboration with 'Mount Apoi Restoration Committee' for conservation activities for endangered alpine plants.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2023, covering the years 2022 and 2023 (April 2022 to March 2023).

10. Reports through standardised reporting systems?

The company has submitted CDP questionnaires for Forests, Climate Change & Water Security in 2023.

11. Climate risks assessment available?

The company has conducted and published a climate risk assessment. However, the assessment is not externally verified.

12. Natural capital assessment available?

13. Lists countries and operations?

The company manages plantations in New Zealand, Brazil, Australia, Indonesia and Vietnam. Processing facilities are in China, Indonesia, Vietnam, Brazil, Australia, Japan and New Zealand.

14. Lists countries sourcing from?

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

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

602833 - The company manages a total of 602,833 ha of forest concessions. Data as of June 2023.

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

This indicator is disabled as the company reports that it only has plantation-based operations OR does not produce wood/wood fibre.

17. Total area of forest plantation (ha)?

455030 - The company has 455,030 ha of production forests as of June 2023. Figures exclude outgrower scheme areas.

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)?

147805 - The company has 147,805 ha of conservation forests as of June 2023.

21. Area of Intact Forest Landscape (ha)?

22. Number of Forest Management Units (FMUs)?

10 - The company reports information on 10 FMUs controlled by it overseas in six countries. However, information on the number of FMUs owned by the company in Japan is not reported.

23. Maps of forest management units (FMUs)?

Only static image files without coordinates are available some of the company's FMUs (domestic and overseas) in their respective FSC annual audit reports and on the company website.

24. Forest management plans available for all FMUs?

Forest management plans and summaries are only available for some of the company's FMUs.

25. Monitoring of forest management plan implementation available?

Monitoring of forest management plan implementation is only available for one of the company's FMUs.

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?

2 - The company has at least two sawmills, however, it is unclear if this number covers all operations.

31. Names and locations of company owned sawmills?

The company only discloses the name and location of one of its sawmills.

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

9 - The company lists five paper mills associated with Oji Paper, three pulp mills associated with Oji Fibre Solutions and one pulp mill with Pan Pac. However, it is unclear if this information covers all of the company's pulp and paper mills and the data reported is now over five years old.

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

Locations of five paper mills are provided, however the data is undated.

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?

The company reports information on sourcing done by its seven (7) manufacturing facilities in 2022. The traceability information is externally verified by SGS, however, it is unclear if this information covers all volume sourced by the company-owned pulp and paper mills.

36. Number of third party supplying mills?

The company reports it has 425 domestic wood chip suppliers and 244 imported wood suppliers, however, it is not clear if each supplier is a supplying mill and not a trader.

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 it has procedure to trace materials to the forest of origin.

40. Percentage of supply traceable to country of harvest?

100 - The company reports that it has achieved 100% traceability for all wood chip and market pulp supply.

41. Procedures to trace raw materials to FMU level?

The company has procurement guidelines that ensure traceability back to the forest.

42. Percentage of supply traceable to FMU level?

The company reports that it has achieved 100% traceability for all wood chip and market pulp supply.

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

The company commits to achieving 100% legality of FMUs by 2030 by becoming FSC and PEFC certified.

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

54% - The company has a total landbank of 602,833 ha, which comprises 455,030 ha of company-owned production forests in Japan and overseas and 147,805 ha of conservation forests. The percentage of certified forests has been calculated to include only FMUs where the certified area (ha) is available on FSC/PEFC databases or the FSC/PEFC certificates/audit reports are publicly available. Some certified FMUs have therefore been excluded from the calculation.

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?

54% - The company's FSC FM-certified area is 325,581.07 ha.

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)?

The company has PEFC certified FMU's but the total area covered by these certificates is not publicly available.

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's own reporting only mentions to ensure that it does not participate in deforestation or illegal logging.

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 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?

The company only provides a general commitment to the restoration of ecosystems but does not include a cut-off date and the commitment itself is unclear.

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 making this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2 EN) and the PEFC International Standard (PEFC ST 1003:2018). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC/PEFC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

65. Biodiversity policy?

The company reports information on its multiple initiatives for biodiversity conservation. However, a measurable time-bound target is not 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 FSC FM (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements do not fully meet the SPOTT indicator criteria. The company has also identified species of conservation concern, referencing the IUCN system of species classification, however, the information reported 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 (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percentage of company landbank certified by FSC. The company's own reporting also mentions multiple examples of species and habitat conservation, some of which include conservation activities for Kiwi, Itou conservation activities in Sarufutsu, etc.

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

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's 'Procurement Policy' specifies a commitment to no illegal logging, but no other illegal activities are mentioned.

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

All suppliers are subject to the company's 'Procurement Policy' which specifies a commitment to no illegal logging, but no other illegal activities are mentioned.

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. Additional points have been awarded according to the percentage of company landbank certified by FSC.

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. The company also reports its own commitment to the avoidance of genetically modified wood.

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

The company commits all suppliers to not use genetically modified organisms or transgenic species.

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?

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

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)?

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?

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. Additional points have been awarded according to the percentage of company landbank certified by FSC. The company's reporting only covers information on developing subsoiling activities before planting seedlings, enhancing regular rainwater infiltration into soil that has been compacted by the activity of heavy machinery in its forests to contribute to the recovery of underground water retention in compacted pasture lands, as well as the prevention of erosion.

95. Commitment to reduced impact logging?

This indicator is disabled as the company reports that it only has plantation-based operations OR does not produce wood/wood fibre.

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

97. Evidence of implementing reduced impact logging practices?

This indicator is disabled as the company reports that it only has plantation-based operations OR does not produce wood/wood fibre.

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 not been awarded as the percentage of company landbank certified by PEFC is unclear. The company's reporting only covers information on fire monitoring systems implemented by its unit CENIBRA which includes using artificial intelligence (AI) for fire fighting and monitoring.

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?

The company commits to reducing GHG emissions intensity (scope 1 and scope 2) by 70% by FY2030 from a 2018 baseline.

104. GHG emissions intensity?

The company reports scope 1 and 2 GHG emissions intensity as 0.498 (tCO2e/ t-production) in FY 2022.

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

The company reports scope 1 emission figures, however, a separate figure including only land use change emissions is not reported by the company.

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

107. Progress towards commitment to reduce GHG emissions intensity?

The company achieved a 16.7% reduction in GHG emissions intensity in FY2022 (4.377(t-CO2e/ Sales million yen)) compared with FY2018 (5.052 (t-CO2e/ Sales million yen). However, the figures are reported as intensity for sales and are not externally verified.

108. Methodology used to calculate GHG emissions?

The company reports that the calculations for its Japanese operations are based on the 'Act on rationalizing Energy Use and Shifting to Non-fossil Energy' and the 'Act on Promotion of Global Warming Counter measures', while overseas operations calculations are based on the Greenhouse Gas Protocol Initiative.

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

The company commits to reducing water intake intensity by 6% or more from FY2018 in FY2030.

110. Water use intensity?

47.3 - The company reports water use intensity as 47.3(m3/ t-production) in FY2022.

111. Progress towards commitment on water use intensity?

The company reports water intake intensity figures in FY 2021 (47.5 (m3/ t-production)) and FY 2022 (47.3(m3/ t-production)) showing an improvement in FY 2022. However, the information reported is not externally verified.

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

As of 2023, the company's BOD and COD levels are within legal limits.

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

The company reports BOD and COD figures from 2018 to 2022, showing that figures are under the regulatory limits set by the government. However, the information reported is not externally verified.

114. Treatment of pulp and paper mill effluent?

The company states it treats wastewater from its pulp and paper facilities. However, the information reported is not externally verified.

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

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

117. Commitment to protect natural waterways through buffer zones?

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 percentage of company landbank certified by FSC.

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

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?

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 (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements do not fully meet the SPOTT indicator criteria. The company also has its own waste management system in place.

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 human rights principles as part of being a UN Global Compact member.

131. Commitment to human rights applies to all suppliers?

The company commits suppliers to respect human rights but does not reference the Universal Declaration of Human Rights or equivalent.

132. Progress on human rights commitment ?

The company reports it conducts human rights assessments that review human rights and labour practices. Additionally, the company provides human rights education as part of various training programs. The company also provides Diversity Management Web Training to managers and in FY2022, 2,566 managers attended the training.

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 also reports its own commitment to respect the United Nations Declaration on the Rights of Indigenous Peoples.

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.

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

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

The company commits 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.

141. Details of process for addressing land conflicts available?

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

The company only provides limited information on supporting the inclusion of women, which includes increasing of women in management positions to promote active participation of women and providing training such as career-building training for employees on the generalist track to pre-management male and female employees, aiming to eliminate gender gaps.

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?

This indicator is disabled as the company reports that it only has plantation-based operations OR does not produce wood/wood fibre.

145. Commitment to provide essential community services and facilities ?

The company reports a commitment to contribute to maintaining or enhancing local communities' social and economic well-being.

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 percentage of company landbank certified by FSC. The company's reporting also mentions providing support to communities in healthcare and education areas.

147. Commitment to provide business/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 operate 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. The company also reports its own commitment to respect the ILO Declaration on Fundamental Principles and Rights at Work.

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 (FSC-STD-01-001 V5-2) and PEFC FM (PEFC ST 1003:2018) certifications as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percentage of company landbank certified by FSC. The company's own reporting mentions the implementation of human rights due diligence by conducting human rights assessment that reviews human rights and labor practices. The company has also established forums for sharing management information and discussing various management issues, such as the Labour-Management Committee, a forum for communication between labor and management, as appropriate, to build sound labor-management relations.

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

The company only commits to the elimination of discrimination in respect of employment and occupation. A clear commitment to prevent employment and/or occupation-related discrimination based on gender is not reported.

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?

155. Percentage or number of temporary employees?

4942 (11.96%) - The company reports that 11.96% of its employees are on temporary contracts. Data as of March 2023.

156. Reports gender balance of employees?

17.03% - The company reports that 17.03% of its employees are women. Data as of March 2023.

157. Commitment to pay a living wage?

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

The company only commits suppliers to pay guaranteed wages in excess of the legal minimum wage.

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 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 also reports its own commitment to address occupational health and safety, however, the commitment 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 its suppliers to address occupational 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 PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have not been awarded as the percentage of company landbank certified by PEFC is unclear.

164. Time lost due to work-based injuries?

1.11 - The company reports its lost time injury frequency rate (LTIFR) in 2022.

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

3 - The company reported three fatalities in 2022.

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?

All suppliers are subject to the company's 'Sustainability Action Guidelines for Supply Chains' and 'Wood Raw Material Procurement Guidelines'.

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

[Externally verified] 705 - Traceability information for seven units of the company (covering 705 suppliers) is available for 2022, however, it is unclear if this covers all the company's operations. This report is externally verified by SGS. Additionally, the company also mentions conducting sustainability surveys, however, it only covers main suppliers (895 suppliers from FY2020 to FY2022).

171. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria. The company's own reporting mentions engaging in dialogue with suppliers and requesting improvements if the source or forest management status of the purchased wood is unknown or the wood does not conform to the procurement guidelines and states that it will not source from suppliers who do not make improvements as per their wood procurement guidelines. However, the timeframe for actions is not provided.

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 its 'Corporate Compliance Department' ensures informing o?cers and employees about the company's anti-corruption initiatives. The company also provides training in regions where there is a possibility that bribery may occur and states that in FY2022, there were no employee terminations resulting from violations of the anti-corruption policy and no penalty charges, surcharges, or settlement money related to 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 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 has published its tax policy and states that the finance officer is responsible for the group's tax governance.

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 a whistleblowing procedure, including a flowchart on steps taken by the company and details on how whistleblowers can report unethical conduct and how they are protected.

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.

182. Details of complaints and grievances disclosed?