TNPL s Group Procedure Manual

Transcription

1 TNPL s Group Procedure Manual With reference to FSC standard for Group entities in Forest Management Groups FSC-STD (V1-0) EN PREPARED BY DEPARTMENT OF PLANTATION TAMILNADU NEWSPRINT AND PAPERS LIMITED KAGITHAPURAM, KARUR DT

2 PAGE INDEX S.No Contents Page No Part 1. Quality System Requirements 1 Genera l requirements 1 2 Responsibilities 2 3 Group entities procedures 4 4 Informed Consent of group members 15 5 Group records 17 Part 2. Group Features 6 Group size 17 7 Multinational groups 18 Part 3. Internal Monitoring 8 Monitoring requirements 18 Part 4.Chain of Custody 9 Sales of Forest products and use of the FSC trademark 21

3 PART 1 QUALITY SYSTEM REQUIREMENTS 1 General requirements 1.1. Tamil Nadu Newsprint and Papers Limited (TNPL) is an independent legal entity. The board of directors list can be seen through this link It was established in 1979 by the Government of Tamil Nadu to produce Newsprint and Printing & Writing paper using wood and baggase, a sugarcane residue, as the primary raw material at Kagithapuram near Karur District, Tamil Nadu, India. 1.2 The Group entity is complied with relevant legal obligations, as registration and payment of applicable fees and taxes. The group entity is a state administrative company and this details is available in this following link, The group entity also have relevant legal obligations, as registration and payment of applicable fees and taxes. The details are presented in The Group entity having a written public policy of commitment to the FSC Principles and Criteria. The same policy is made available in The Group entity having a defined training needs and it will implement the training activities and/or communication strategies which are relevant to implementation of applicable FSC standards. The success of any people centered plantation programme is vested with the awareness created and the level of participation by the people. Hence group entity has systematically incorporated awareness creation programme and decentralized capacity building activities to all levels of stakeholders involved in the plantation programme. The following activities will help to resolve the issues related to plantation promotional activities, conflict resolution and to create entrepreneurial skill among the participating stakeholders. Technology sensitization Nature of Training Semi-mechanized Operation Safety FSC and Inventory, Identification & Documentation of various HCVFs Personality development LOCATION Mill site Plantation areas Mill site Mill site / Plantation areas Mill site

4 2 Responsibilities 2.1 The Group entity having the clearly defined responsibilities for Group entity and Group members and documented the division of responsibilities between them in relation to forest management activities (Example: Management planning, Planting & Maintenance of plantations, Monitoring, Harvesting, Quality control, Marketing & Sale of FSC products, etc.,) The responsibilities for the group entity and the group members in relation to forest management activities are given below, S.No Responsibilities Group entity responsibility 1 Management planning Fixing up plantation target for each region A Farm Forestry Extension activities Production of required seedlings/clones Identification of land Legal clearance for the land which are to be taken To fix contractor through B tender and obtain the rate Captive for scope of works to be plantation carried out Execution of Memorandum of Understandings (MOU) with group member 2. Planting and Maintenance of plantations A B Farm Forestry Captive plantation 3 Monitoring Supply of superior seedlings/clones to group member s field at subsidized rate To provide technical support for establishment and development of pulpwood plantations The land development, establishment and maintenance of plantations till harvest The internal monitoring of plantations to be carried out periodically at various level Group member responsibility Planning for the area to be planted Species to be planted Decision making to hand over the land to group entity either on lease or revenue share basis Execution of Memorandum of Understandings (MOU) with group entity From land development till harvest the group member has the entire responsibility Execution of maintenance activates as per the guidelines given by group entity The group member does not have any responsibility on maintenance of captive plantations In case of Farm Forestry the group member need to monitor the plantations at his own In captive plantations the group member does not

5 4 Harvesting A B Farm Forestry Captive plantation Yield estimation Collection of harvesting application from group member Release of purchase order Yield estimation Collection of harvesting application from group member Release of purchase order Harvesting through contractor have any role in monitoring aspects Giving consent to harvest the plantations either by group entity or by group member himself Giving consent to harvest the plantations by group entity 5 Quality control Supply of superior quality seedlings/clones Maintaining good quality plantations till harvest in case of Captive plantations 6 Marketing& Timber sale The entire pulpwood will be harvested from both Farm Forestry and Captive plantations and consumed internally by the group entity 7 Processing Either storage of pulpwood in wood yard or direct feeding for chipping Maintaining good quality plantations till harvest in case of Farm Forestry The group member has to sell the pulpwood to group entity as per the terms and conditions of the bilateral agreement incase of Farm Forestry Under Captive Plantation the group member has to give the consent to harvest the plantations The group member doesn t have the responsibility in processing 2.2 The Group entity has appointed DGM (Plantation) as a management representative who is having overall responsibility and authority for the group entity s compliance with all applicable requirements of this standard. 2.3 The Group entity staff and Group members will have the knowledge of the Group s procedures and the applicable Forest Stewardship Standard. To facilitate them to acquire knowledge on this the hard copy of TNPL s Group Procedure Manual is made available at main site as well as in all regional office of TNPL s Plantation Department. The soft copy of this

6 procedure is available in the folder of FSC at network location of TNPL Plantation (\\nassvr) (K :) and Share (\\nassvr) (S :). This procedure is also made public in following link 3. Group entity s procedures 3.1 The Group entity will establish, implement and maintain written procedures for Group membership covering all applicable requirements of this standard, according to scale and complexity of the group including: I. Organizational structure; The Organizational structure is represented in Annexure-1. II. Responsibilities of the Group entity and the Group members including main activities to fulfill such responsibilities (i.e. Management planning, Planting and Maintenance of plantations, Monitoring, Harvesting, etc) are given below; S.No Responsibilities 1 Management planning A B Farm Forestry Captive plantation Group entity responsibility The region wise target will be fixed and the field officers will plan accordingly to achieve the target The extension activities such as farmers meeting, participating in farmers mela, etc., will be carried out to motivate small and marginal farmers to establish pulpwood plantations The contractor will be fixed through tendering process and the required quality seedlings/clones will be produced at group entity nursery and transport to group member s field Group entity will offer technical assistance for planting and advisory services for maintenance till harvest at free of cost. The land will be identified and selected based on the site conditions The Legal clearance for the identified land will be obtained Group member responsibility The group member will decide the area to be planted and the species. The land development activities such as clearing, ploughing, etc., will be planned to carry out before the monsoon season The group member will execute agreement with group entity by paying required amount for the plants The group member will execute the MoU with group entity either on lease or revenue share basis

7 and the MoU will be executed with group member The rate for the scope of the works will be fixed through tender 2. Planting and Maintenance of the plantations The superior seedlings/clones will be transported through contractor to group member s field. The plants will be supplied at subsidized rate. The technical support for A Farm Forestry establishment and development of pulpwood plantations will be given to group member s by group entity field officials B Captive plantation 3 Monitoring 4 Harvesting A Farm Forestry The contractor will be fixed and the purchase orders will be issued to them to carry out plantation activities such as land development, planting, and maintenance activities The internal monitoring of plantation activities will be carried out periodically on a random 0.6* square root of number of FMU incase of New FMU s and 0.3* square root of number of FMU incase of old FMU s by the field executives of group entity. The yield will be estimated by field officials based on sampling method. The harvesting application along with yield estimation sheet will be sent to mill site and the purchase orders will be issued based on this documents. In case of harvesting by group entity, the contractor will be fixed by group entity to harvest the The group member will carry out the plantation activities such as land development, planting, ploughing, etc., The group member will execute the maintenance activates as per the guidelines given by group entity field officials The group member doesn t have any responsibility on maintenance of captive plantations The group member has to monitor the plantations activities at his own under Farm Forestry In captive plantations the group member does not have any role in monitoring aspects. The group member will give his consent to harvest the plantations either by group entity or by group member himself In case of harvest by himself, he will get the purchase order from group

8 B Captive plantation plantations. Through this contractors the plantations will be harvested and transported to mill site. The harvested pulpwood will be weighed at local weighbridge and transported to mill site along with delivery challan, Form JJ and FSC claim. The delivery challan, Form JJ and FSC claim will be signed by group entity field officials. The yield will be estimated by field officials based on sampling method. The harvesting application along with yield estimation sheet will be sent to mill site and the purchase orders will be issued based on this documents. The contractor will be fixed by group entity to harvest the plantations and the contractor will harvest and transport the pulpwood to mill site. The harvested pulpwood will be weighed at local weighbridge and transported to mill site along with delivery challan, Form JJ and FSC claim. The delivery challan, Form JJ and FSC claim will be signed by group entity field officials. 5 Quality control The seedlings/clones will be graded at open nursery in mill site before despatch. Hence only the superior quality seedlings/clones will be supplied to group member s field. The captive plantations will be maintained by group entity through carry out maintenance activities every year. By this the good quality plantations will be raised and maintained by group entity under Captive plantations. entity to harvest the plantations on his own to mill. Then he will harvest and transport the pulpwood to mill site along with delivery challan, Form JJ and FSC claim. The delivery challan, Form JJ and FSC claim will be signed by group entity field officials. The group member will give his consent to harvest the plantations by group entity. The group member will establish and maintain good quality plantations through carrying out silvicultural operations in time based on the technical guidance given by group entity under Farm forestry

9 6 Sales & Marketing of FSC products The entire pulpwood is taken from both the Farm Forestry and Captive plantation and consumed internally by the group entity. The FSC papers are produced by group entity and will be marketed by them. 7 Processing The harvested pulpwood will be received at mill site and weighed at mill weighbridge. After weighment the pulpwood will be either stored in wood yard or sent to direct feeding for chipping. In wood yard the pulpwood are stored in separately. Thus the group entity is ensured that the FSC pulpwood are not mixed with uncontrolled pulpwood. During chipping also the identity of FSC material will be maintained by group entity.. III. Rules regarding eligibility for membership to the Group; The group member will sell the pulpwood to the group entity as per the terms and conditions of the bilateral agreement incase of Farm forestry Under captive plantation scheme the group member will give the consent to harvest the plantation. The group member doesn t have the responsibility in processing TNPL is actively implementing a plantation programme under two major areas. 1. Captive plantation scheme 2. Farm Forestry scheme Captive plantation scheme:- The entire captive plantation establishment and maintenance activities will be carried out by the group entity with its own expenditure and maintained up to harvesting. Under this scheme, Government waste lands, Temple lands, Industrial / Institutional lands are taken on lease / revenue sharing basis and pulp wood plantations are developed by the group entity using high yielding pulp wood species.

10 The eligibility to join as a group member in the captive plantation scheme is as follows:- a. The size of the unit of the land must be 10 Ha in a single location, single ownership or owned by a family members. b. The land should be patta land with proper legal rights to the group member. c. The group member land should be cleared legally by the advocate nominated by group entity. The group member should accept the FSC policies and adhere to all the FSC principles / criteria and will be allowed to sign MOU with group entity. FARM FORESTRY SCHEME The entire Farm Forestry work is carried out by the group member with their own expenditure and maintenance up to harvesting. TNPL is assisting the farmers to use un-utilized degraded lands for raising pulp wood plantation. The eligibility to join as a group member in the Farm Forestry scheme is as follows:- a) The group member must give patta land for planting the tree with no restriction in size of the land to become eligible as group member, which may be dry land or irrigated land. b) The group member must submit one of their land documents viz., patta or chitta or adangal or parent documents of their land or Land tax receipt along with their application form to prove his land ownership. c) The superior planting materials are delivered at farm gate at subsidized cost by the group entity. The group member has to agree to buy the required plants for the area registered with the group entity. d) The group member has to agree to give the pulpwood to the group entity as per the bilateral agreement at the end of the rotation period or at the time of harvesting. IV. Rules regarding withdrawal/ suspension of members from the Group; Farm Forestry: In Farm Forestry Scheme, the fields are managed by FMU (farmers). FMU will be suspended temporarily from the group in case of non-closure of non-conformances raised during internal audit within three months of time period. The non-conformances will be issued for the following reasons. 1) Employment of Child Labour

11 2) Non availability of first aid kits and non usage of safety equipments during harvesting of pulpwood 3) Non payment of wages to labours as per prevailing local standards / laws 4) Usage of chemicals prohibited by FSC (FSC-STD a) or those banned by Indian government, World health organisation Type 1A or 1B and chlorinated hydro carbon pesticides. 5) Availability of grown pulpwood trees under electric line. 6) Non intimation of fire accident / other accidents within a week 7) Selling pulpwood to other company An intimation or notification letter will be send to the group member regarding the suspension from the group. The letter will have the details of reason and effective date of suspension. TNPL will withdraw FMU (permanently) from the group for the following reasons 1) Suspension is not revoked with three months of time period. 2) FMU is not interested or willing to continue. An intimation or notification letter will be sent to the group member regarding the withdrawal of group membership. The letter will have the details of reason and effective date of withdrawal. Captive Plantation: In captive plantation scheme, the plantation fields are managed by Group entity. As per the legal agreement, the land owner will be receiving either annual lease amount or one time share at the time of pulp wood harvesting. Hence, the land owner is not involved in the planting, monitoring, management or harvesting operations. All the activities are carried out by the contractor through work order. The group member may be withdrawn (permanently) from the group under the following circumstances. The land owner agrees that he/she shall not cut the pulpwood trees or create any charge, lien, mortgage or transfer the right, title, interest of any nature whatsoever the said prosperity or on trees without prior written permission of the company. If the land owner violates the above condition then his membership will be withdrawn. An intimation or notification letter will be send to the group member regarding the suspension from the group. The letter will have the details of reason and effective date of suspension. TNPL will withdraw FMU (permanently) from the group for the following reasons 1) Suspension is not revoked with three months of time period. 2) FMU is not interested or willing to continue.

12 An intimation or notification letter will be sent to the group member regarding the withdrawal of group membership. The letter will have the details of reason and effective date of withdrawal. V. CORRECTIVE ACTION REQUESTS The process to fulfill any corrective action requests issued internally and by the certification body including timelines and implications if any of the corrective actions are not complied with is as follows, The monitoring of plantation activities will be carried out once in year on a random basis at the rate of 0.6* square root of number of FMU in case of New FMU s and 0.3* square root of number of FMU in case of old FMU s by the field executives of group entity. Any corrective action issued by field executives of group entity will be assessed by higher executive cadre of group entity (Assistant Manager and above). The higher executive cadre of group entity will verify the action taken by FMU including the timelines as specified in the corrective report. The format of corrective action report is presented in Annexure-2. Any corrective action requests issued by the certification body will be resolved by group entity within the timelines as specified by the certification body. VI.Documented procedures for the inclusion of new group members; The following procedures are followed for inclusion of the new group as in the group entity procedure document. 1. Farm forestry scheme: a. Printed application form and bilateral agreement is issued to the identified tree grower by the group entity with free of cost through their field officers/field supervisors/plantation executors. b. The application from has to be filled by the tree grower and submit to the group entity through their field officers/field supervisors/plantation executors along with any one of the relevant land documents like chitta, patta, adangal or land tax receipt for proof of ownership. c. The field verification is carried out by the Field officer by verifying the details furnished in the documents. d. The bilateral agreement signed by the group member along with his application for registration is recommended by the field officer and sent to the plantation office to register as a new member

13 e. After completion of the above process the group member may get the plants at door step with free transportation from the group entity as and when required. The included member will be intimated to certification body once in a year. 2. Captive plantation scheme : a. The minimum land requirement under this scheme is 10 Ha in a single block. The land may be owned by single ownership or family or institution. The group member has to produce the required land documents like chitta, adangal, patta, parent documents, topo sketch, field map, Encumbrance Certificate for 22 years, land tax receipt etc., at his own risk to prove the legal rights over the said land for raising plantation. b. These documents are sent to the TNPL s legal department for their clearance. c. The group members satisfy the legal as well as technical requirements, will be allowed for signing the bilateral agreement and included as member. The included member will be intimated to certification body once in 12 months. VII. COMPLAINTS PROCEDURE FOR GROUP MEMBERS. The Group members may complaint about their field problems and get the solutions by one of the followings means: 1. By phone call to concern Field officer or to the plantation office. 2. By registering in the complaints register available in the plantation office of TNPL 3. By sending mail to the group entity through the website. 4. By sending the written complaints through pots/courier 3.2. The group entity's procedures are sufficient to establish an efficient internal control system ensuring that all members are fulfilling applicable requirements The group entity has established systematic monitoring mechanism to evaluate the performance of growth and dynamics of pulp wood plantations. The group entity has internal monitoring mechanism on monthly basis and the status of plantation programme and procurement plan are elaborately reviewed and the issues related to constraints are resolved on need basis. The annual growth rate in terms of height, diameter and volume increments is assessed and the growth pattern reports have been maintained by the plantation department.

14 Monitoring Mechanism 100% of plantations are being monitored at the time of inspecting the work in all the plantation areas during the course of implementing different operations in different locations by the field staff up to the level of Officer in Charge of the Region. The Field Supervisors are to visit their all plantation areas on monthly basis and report to the Regional officers The Regional Officers are to visit the plantation areas in their control once in six months and report to the Head of Plantation department The internal Audit/Monitoring team members Manager (Plantation)/Manager (Forestry)/Deputy manager (Plantation)/Field Officer will visit all the Captive Plantation and Farm Forestry areas on random basis once in a year and report to the Head of Plantation Department The Head of Plantation Department will visit all the Captive Plantation once in a year and need based visit to Farm forestry areas. The monitoring indicators developed in order to assess the Management & Evaluation team to assess the output and outcome of the plantation programme are presented in the below table. Sl.N Activity o 1. Clonal / Seedling production 2. Capacity building 3. Annual expansion of industrial plantation 4. Wood technological characterizati on and development of alternate pulpwood species Monitorable indicator Number of ramets /clones produced and supplied within stipulated time Number of trainings conducted Area of coverage of plantation Number of beneficiary farmers Number of species /clones characterized for cellulose (>45%) Number of alternate species/clones developed Output Production of 1.5 crores ramets/seedlin gs Two trainings /year/region Minimum of acre per annum Maximum number of small & marginal farmers Availability of at least one potential species suitable for varied agro climatic condition Outcome Availability of quality planting stock in time Awareness on commercial tree farming Generation of skilled man power Increased area under pulpwood plantations Improved standard of living of tree growers Augmented Clean Development Mechanism Alternate genetic resources with high cellulose available to growers and industries

15 5. Precision silviculture techniques 6. Harvest and post-harvest Quantifiable growth response of industrial wood species to fertigation Improvement in harvest efficiency through skilled personnel Number of trees harvested per unit time Post-harvest management Optimal irrigation and fertigation technique for different agroclimatic zones demonstration /cluster Harvest efficiency of 10/ 2 man day augmented shelf-life of harvested wood Site specific Precision silviculture techniques and productivity improvement Harvest efficiency improvement and reduced impact logging Reduction in human drudgery Increased storage of logs To establish an efficient internal control system ensuring that all members are fulfilling applicable requirements TNPL s Plantation Department is developing a system called mobile monitoring of plantation activities. It covers all the plantations activities such as Pre Inspection of land, FMU Registration (including assessment of FSC standard requirements and details of HCVF), Pre Planting Inspection, Distribution Acknowledgement, Post Planting Inspection, Periodic Inspection (Regular), Periodic Inspection (Need Based), Pre Harvest Inspection, Pulp Wood Supply, Post harvest Inspection etc. This system is also includes Farmers List, Transaction Summary, Weather Information. 3.3 The group entity having the defined personnel responsible for each procedure together with the qualifications or training measures required for its implementation. The details are as follows, Executives Qualification Responsibility Training requirement Deputy General Manager (Plantation) Manager (Forestry) Doctorate in Environment Management, Post graduate in Environmental science & Post Graduate Diploma In Forest Management and Graduate in Agriculture Post graduate in Agronomy Overall responsibility for implementation of FSC standards. In charge of Forest procurement and monitoring of Farm Forestry and Captive plantation felling operations. Technology sensitization, Mechanized operation & HCVF FSC Principles, Safety, Mechanized operation & HCVF

16 Manager (Plantation) Dy. Manager (Plantation) Field Officer- CPRC Asst Field Officer- Karur and Namakkal Region Field Officer - Pudukottai Field Officer- Gandarvakottai Field Officer-Alangudi Field Officer - Karaikudi Region Asst. Manager -Trichy Region Field Officer- Jayamkondam Field Officer- Kanchipuram Field Officer- Plantation office Post graduate in Agriculture Extension Doctorate in Forest Genetics and Tree improvement Doctorate in Soil Science Post graduate in Plant Breeding Agricultural Science Graduate in Agriculture Post graduate in Forestry sp in Forest Pathology Post graduate in Agriculture Extension Post graduate in Horticulture Post graduate in Botony Graduate in Forestry Post graduate in Forestry sp in Silviculture Post graduate in Forestry Tree improvement. In charge of Farm Forestry and Captive plantation planting and monitoring. In charge of Forestry Research and Development work and monitoring of clonal/seedling plant production operations. In charge of Clonal Propagation Research Center Plant Production and Dispatch Monitoring Farm Forestry and Captive plantation work in Karur and Namakkal region. Monitoring Farm Forestry & Captive Plantation work in Pudukottai region. Monitoring Farm Forestry & Captive plantation work in Gandarvakottai region. Monitoring Farm Forestry & Captive plantation work in the Alangudi region. Monitoring Farm Forestry and Captive plantation work in Karaikudi region. Monitoring Farm Forestry & Captive plantation work in Trichy region. Monitoring Farm Forestry & Captive plantation work in Jayamkondam region. Monitoring Farm Forestry plantation work in Kanchipuram region. Office coordination FSC Principles, Safety & HCVF Technology sensitization, FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF FSC Principles, Safety & HCVF

17 3.4 The Group entity or the certification body will evaluate every applicant for membership of the Group and ensure that there are no major nonconformities with applicable requirements of the Forest Stewardship Standard, and with any additional requirements for membership of the Group, prior to being granted membership of the Group. The evaluating criteria s are as follows, Agree to join membership of the plantation scheme Submitted the required land documents/ Legal ownership and agree to sign the bilateral agreement with FSC standards Knowledge of FSC standards/access to a copy of the FSC standards. Knowledge of FSC certification process. Agreed to access His/Her forest area by the group entity or FSC officials or certification body officials for the purposes of evaluation and monitoring. Agreed to access His/Her forest area by the group entity or FSC officials or certification body officials for the purposes of evaluation and monitoring. Knowledge of Certification body s and FSC requirements with respect to publication of information. Interest on participation of FSC training organized by the group entity. Agreed to follow the FSC principles 1-10, criteria and indicators. Potential to confirm with condition or corrective action requests issued by the certification body. Having Knowledge on pesticides banned by international agreement / FSC /Govt. of India and agree to use non chemical methods or strive to avoid the chemical pesticides Agree to protect rare, threatened and endangered species and their habitats if any. Co-operation to the group entity to identify and protect the sites of special cultural, ecological, economic or religious significance to indigenous peoples. Based on the above criteria the field executives of TNPL will recommend for grand of membership. The evaluation format is enclosed as Annexure-3 4 Informed consent of Group members 4.1 The Group entity will provide each Group member with documentation, or access to documentation, specifying the relevant terms and conditions of Group membership. The documentation includes: i) The applicable Forest Stewardship Standard is available in bilateral agreement between group entity and group member. Also the group member can access the applicable Forest Stewardship Standard

18 ii) The certification process is explained to the tree growers during signing of the bilateral agreement between the group member and group entity. It can also be viewed in iii) Rights to access the group members' forests and documentation for the purposes of evaluation and monitoring by the certification body s and FSC's is incorporated in the bilateral agreement between group member and the group entity. iv) The group members will give consent with respect to publication of information by the certification body's, and FSC's as per the bilateral agreement between group member and the group entity. v) The following are the explanation of any obligations with respect to group membership: Maintenance of information for monitoring purposes of group membership can be assessed in the bilateral agreement between group member and the group entity. Systems for tracking and tracing of forest products can be assessed in the bilateral agreement between group member and group entity The conditions or corrective action requests issued by the certification body and the group entity are available in the bilateral agreement between group member and the group entity. Any special requirements for group members related to marketing or sales of products within and outside of the certificate are as per bilateral agreement between group member and the group entity. Other obligations of Group membership if any will be discussed case by case and will be meet out by FME The group member is agreed to receive the plants from the group entity with subsidized cost as per the bilateral between group member and the group entity. 4.2 A consent declaration or equivalent will be available between the Group Entity and each Group member or the member s representative who voluntarily wishes to participate in the Group. The consent declarations will: Include a commitment to comply with all applicable certification requirements; Acknowledge and agree to the obligations and responsibilities of the Group entity; Acknowledge and agree to the obligations and responsibilities of Group membership; Agree to membership of the scheme, and Authorise the group entity to be the primary contact for certification and to apply for certification on the member's behalf. This consent declaration is made available between the group entity and each group member through the bilateral agreement made between group member and group entity.

19 5 Group Records 5.1 The group entity will maintain complete and up-to-date records covering all applicable requirements of this standard. These includes: i List of names and contact details of Group members, together with dates of entering and leaving the Group scheme, reason for leaving, and the type of forest ownership per member; ii. Any records of training provided to staff or Group members, relevant to the implementation of this standard or the applicable Forest Stewardship Standard; iii A map or supporting documentation describing or showing the location of the member s forest properties; iv. Evidence of consent of all Group members; v. Documentation and records regarding recommended practices for forest management (i.e. silvicultural systems); vi. Records demonstrating the implementation of any internal control or monitoring systems. Such records shall include records of internal inspections, non-compliances identified in such inspections, actions taken to correct any such non-compliance; viii. Records of the estimated annual overall FSC production and annual FSC sales of the Group Records to conform to the above requirements are made available in the Department of Plantation office at mill site. 5.2 Group records will be retained for at least five (5) years Group entities will not issue any kind of certificates or declarations to their group members that could be confused with FSC certificates. Group member certificates may however be requested from the certification body. PART 2 GROUP FEATURES 6 Group Size 6.1 There is no restriction on the maximum size that a group certificate can cover in terms of number of group members, their individual forest property size or total forest area. The Group entity having sufficient human and technical resources to manage and control the Group in line

20 with the requirements of this standard. The group entity organization structure presented in Annexure-1 and the qualification of group entity executives are presented in 3.3 of Group entity procedures. 6.2 The Group entity could be able to support 10,000 group members by its management system and it has sufficient human and technical resources as per organization set up given in the Annexure-1 to manage and control the group. 7 Multinational groups 7.1 Group schemes will only be applied to national groups which are covered by the same Forest Stewardship Standard. The TamilNadu Newsprint and papers Ltd (TNPL) is an independent legal entity, which are having the plantation operation in the state of Tamil Nadu, India. Hence the group scheme is applied to national group. 7.2 In cases where homogeneous conditions between countries/ regions may allow an effective and credible cross- border or multi-regional monitoring system, the Group entity can request formal approval by FSC IC through their accredited Certification Body to allow certification of such a group scheme. But group entity (TNPL) not having any such circumstances hence this point will not be applicable to the group entity. PART 3 INTERNAL MONITORING 8 Monitoring requirements 8.1 The Group entity will implement a documented monitoring and control system that includes at least the following: i. Written description of the monitoring and control system; ii. Regular (at least annual) monitoring visits to a sample of Group members to confirm continued compliance with all the requirements of the applicable Forest Stewardship Standard, and with any additional requirements for membership of the Group. 8.2 The Group entity will define criteria to be monitored at each internal audit and according to the group characteristics, risk factors and local circumstances The minimum sample to be visited annually for internal monitoring is determined as follows: b) Type II Resource Manager Groups:

21 The group entities who also operate as resource managers will define the required internal sampling intensity at their own discretion for the forest properties they are managing, independent of their size and ownership (the minimum numbers as defined above do not apply here). 8.4 For monitoring purposes the Group entity will use the same stratification into sets of like FMUs as defined by the certification body in their evaluation. 8.5 The Group entity will visit different members in their annual monitoring than the ones selected for evaluation by the certification body, unless pending corrective actions, complaints or risk factors are requiring a revisit of the same units. 8.6 In the selection process of members to be visited, the Group entity will include random selection techniques. 8.7 The Group entity will issue corrective action requests to address non-compliances identified during their visits and monitor their implementation. 8.8 Additional monitoring visits will be scheduled when potential problems arise or the Group entity receives information from stakeholders about alleged violations of the FSC requirements by Group members. The monitoring mechanisms of group entity are presented in 3.2 of group entity procedures. The monitoring and control system executives will visits the group member field once in a year to confirm continued compliance with all the requirements of the applicable Forest Stewardship Standard, and with any additional requirements for membership of the Group. The following criteria are monitored at each internal audit. Awareness on FSC Principles Employment of local people by FMU for forest management activities Wages paid to labours as per prevailing local standards Attending training program of worker safety, Health and FSC (Principle Criteria, Indicators and group procedures) Intimation to FME on work- related accidents, and preferably all safety performance Non employment of Child labour Intimation to FME grievances related to legal rights, damage compensation and negative impacts Processing the harvesting operation locally. Minimization of waste Intimation to FME on rare, threatened and endangered species and their habitat, the FME shall use this information to protect these resources. Following silvicultural systems, pest management system Is chemicals used (Yes / No) If Yes,

22 Name Quantity Date of application Method of application Method of Storage Remarks (if any) Is Manure / Bio-pesticide / Bio-fungicide used (Yes / No) If Yes, Name Quantity Date of application Method of application Method of Storage Remarks (if any) Avoidance of Chemicals prohibited by the FSC (FSC-POL ) or those banned in Europe, U.S., and India, or World Health Organization Type 1A or 1B and chlorinated hydrocarbon pesticides Safe disposal of Chemical container and other wastes. Identification of forest fire Record of any accident Occurrence of Electric wire over the plantation The plantation activities are carried out within the state of TamilNadu, India. Hence, the group characteristic, risk factors and local circumstances will be similar for all FMUs. The number of sample visited by the monitoring and control system executives will be 0.6* square root of number of FMU in case of New FMU s and 0.3* square root of number of FMU in case of Old FMU s by the field executives of group entity. The Group entities use the same stratification into sets of FMUs as defined by the certification body in their evaluation for monitoring purposes. The group entity will visit different members in their annual monitoring than the ones selected for evaluation by the certification body. The group entity will revisit the same units on complaints, risk factors or due to pending corrective actions. Random selection technique will be adopted by group entity in the selection process of members to be visited. The group entity will issue the corrective actions requests to address non-compliances identified during their visits and monitor their implementation.

23 When potential problems arise or the group entity receives information from stakeholders about alleged violations of the FSC requirements by Group members then the additional monitoring visits are scheduled The Group entity is developing a system called mobile based monitoring of plantation activities which is an efficient monitoring and control system. The software of these monitoring activities is developed by Source trace Systems, Coimbatore. It covers all the plantations activities such as Pre Inspection of land, FMU Registration (including assessment of FSC standard requirements and details of HCVF), Pre Planting Inspection,Distribution Acknowledgement, Post Planting Inspection, Periodic Inspection (Regular), Periodic Inspection (Need Based), Pre Harvest Inspection, Pulp Wood Supply, Post harvest Inspection etc. This system is also includes Farmers List, Transaction Summary, Weather Information. This system is implemented and the plantation registration is being documented. PART 4 CHAIN OF CUSTODY 9. Sales of forest products and use of the FSC trademark 9.1 The Group entity will document and implement a system for tracking and tracing of forest products produced by the Group members which are supposed to be sold as FSC certified. 9.2 For the purpose of ensuring that non certified material is not being mixed with FSC certified material, FSC products will only be sold according to a sales protocol agreed by the group members and the Group entity. 9.3 The Group entity will ensure that all invoices for sales of FSC certified material are issued with the required information (see FSC-STD V2-0 Clause 6.1.1) and are filed by the group members. 9.4 The Group entity will ensure that all uses of the FSC Trademark are approved by the responsible certification body in advance. The FSC products are consumed internally by the group entity for the paper production and hence there is no sales of FSC products. The system to track and tracing of forest products produced by the group members and the non certified material is not being with FSC certified material are presented in section 1.3 of TNPL/FSC/FM/COC. FME ensures compliance with all applicable FSC/Rainforest Alliance/SmartWood trademark use requirements. FME would get appropriate approval from FSC/Rainforest Alliance/SmartWood for use of trademarks. The general labeling requirements and eligibility for labeling are carried out as per TNPL/FSC/COC/LA.

24 ANNEXTURE -1 Organization Structure of Department of Plantation, TNPL Tamil Nadu Newsprint and Papers Limited (TNPL), Kagithapuram, Karur District, TamilNadu, India is the largest wood and baggase based integrated pulp and paper manufacturing Mill. PLANTATION & FORESTRY DEPUTY GENERAL MANAGER PLANTATION FORESTRY MANAGER MANAGER R&D / PROPAGATION PLANTATION HORTICULTURE TAFCORN NO RTH ZO NE TAFCORN SO UTH ZO NE OTHER AREA DY. MANAGER ASST. MANAGER ASST. MANAGER ASST. MANAGER ASST. MANAGER OFFICER (R&D) OFFICER (NURSERY) REGIONAL FIELD OFFICERS OFFICER (HORTICULTURE) FOREST OFFICER FOREST OFFICER FOREST OFFICER

25 Name of Forest management Scheme: Region: Taluk: FMU Code: Farmer Name: Area: Year of Planting: Details of species: ANNEXURE 2 CORRECTIVE ACTION REPORT Sl.No Category Remarks 1 Identification of Non Conformance 2 Identify by 3 Time line for completion 4 Action taken and Response by FMU 5 Non Conformance Open/Close 6 Reason for open Signature of Executives Date:

26 ANNEXURE 3 Check List for granting FSC group membership:- S.No Category Decision 1. Agree to join membership of the plantation scheme Yes No 2. Submitted the required land documents/ Legal ownership and agree to sign the bilateral agreement with FSC standards 3. Knowledge of FSC standards/access to a copy of the FSC standards. 4. Knowledge of FSC certification process. 5. Agreed to access hi /her forest area by the group entity or FSC officials or Certification body officials for the purposes of evaluation and monitoring. 6. Knowledge of Certification body s, and FSC requirements with respect to publication of information. 7. Interest on participation of FSC Training organized by the group entity. 8. Agreed to follow the FSC principles 1-10, criteria and indicators. 9. Potential to confirm with condition or corrective action requests issued by the Certification body. 10. Having Knowledge on pesticides banned by international agreement / FSC /Govt. of India and agree to use non chemical methods or strive to avoid the chemical pesticides. 11. Agree to protect rare, threatened and endangered species and their habitats. 12. Co-operation to the Forest Managers to identify and protect the sites of special cultural, ecological, economic or religious significance to indigenous peoples. Certified for grand membership: Yes / No Remarks (if any) :

27 Name of Forest management Scheme: Region: Taluk: FMU Code: Farmer Name: Area: Year of Planting: Details of species: ANNEXURE 4 INTERNAL AUDIT / MONITORING REPORT Sl.No Criteria Findings 1 Awareness on FSC Principles 2 Employment of local people by FMU for forest management activities 3 Wages paid to labours as per prevailing local standards. 4 Attending training program of worker safety, Health and FSC (Principle Criteria, Indicators and group procedures) 5 Intimation to FME on work- related accidents, and preferably all safety performance. 6 Non employment of Child labour 7 Intimation to FME grievances related to legal rights, damage compensation and negative impacts 8 Processing the harvesting operation locally. 9 Minimization of waste 10 Intimation to FME on rare, threatened and endangered species and their habitat, the FME shall use this information to protect these resources. 11 Following silvicultural systems, pest management system 12 Is chemicals used (Yes / No) If Yes, Name Quantity Date of application Method of application Method of Storage 13 Is Manure / Bio-pesticide / Bio-fungicide used (Yes / No) Remarks (if any) If Yes, Name

28 14 15 Avoidance of Chemicals prohibited by the FSC (FSC-POL ) or those banned in Europe, U.S., and India, or World Health Organization Type 1A or 1B and chlorinated hydrocarbon pesticides Safe disposal of Chemical container and other wastes. Quantity Date of application Method of application Method of Storage Remarks (if any) 16 Identification of forest fire Occurrence of Electric wire over the plantation If there is any soil erosion from barren land after felling? Whether the plantation activities improves the socio-economic status of FMU? Is there any exotic species invasion in the field? If HCVF present in the field what kind of protection and maintenance taken by FMU & FME? 22 Other Remarks Signature of Officer Date: Remarks made by verifying officer: