Greif Packaging LLC. 861 Fibre Plant Road Gladstone, Virginia SFI Standards and Rules, Section 3 Fiber Sourcing. Surveillance Audit

Transcription

1 Greif Packaging LLC 861 Fibre Plant Road Gladstone, Virginia SFI Standards and Rules, Section 3 Fiber Sourcing Surveillance Audit

2 NSF International Forestry Program Audit Report A. Program Participant Name Greif Packaging LLC NSF Customer Number (FRS) C Contact Information (Name, Title, Phone & ) Jay Phaup, Wood Procurement Supervisor Greif Packaging LLC PO 339 Amherst, VA B. Scope of Certification The procurement organization supplying wood fiber to its manufacturing facility located in Riverville, Virginia. The scope of the SFI Program includes Section 3, Objectives The SFI Certificate Number is NSF-SFIS- C Locations Included in the Certification Riverville, VA C. NSF Audit Team Tucker Watts D. Audit Dates May 9-10, 2017 E. Reference Documentation (Standards, Guidance, etc.) SFI Standards and Rules, Section 3 Fiber Sourcing Company Documentation (Program Manual, Procedures, etc.) SFI Fiber Sourcing Program (GPL-SFI-03) SFI Evidence File (GPL-SFI-02) SFI Evidence Manual (GPL-SFI-01) F. Audit Results: Based on the results of this assessment, the auditor concluded: Acceptable with no nonconformities The following nonconformities were identified and will require corrective action: Major: Minor: Summary of nonconformities In addition, opportunities for improvement (OFIs) were identified. AESOP 4742; ISSUE 21; STATUS-PUBLISHED; EFFECTIVE 30 MAR 2017; AUTHORITY STACEY MACK This document is the property of NSF International. Page 2 of 30

3 G. Changes to Operations or to the Standard Note: Were there any significant changes in operations, procedures, specifications, facility records, etc., from the previous visit? Yes (Please explain: [explanation]) No H. Other Issues Reviewed Yes No N/A Public report from previous audit(s) is posted on the [SFI/SBP/etc.] website Yes No N/A Relevant industry specific logos or labels (SFI, PEFC, etc.) are utilized correctly. Yes No N/A Relevant accreditation logos (ANSI or ANAB) are utilized correctly and meet rules specified in NSF SOP and SOP Yes No N/A Nonconformities from previous audit were reviewed. [If yes, explain] I. Future Audit Schedule Following the initial registration audit, continued certification requires annual assessments commonly referred to as Surveillance Audits. Additionally, at the end of the certification period, maintaining certification requires the completion of a recertification or Reassessment Audit. The following table lists the dates of the audits in the current certification period and (for multi-site certificates) the sites chosen at each visit. Registration / Reassessment Surveillance 1 Surveillance 2 Surveillance 3 Surveillance 4 Date(s) Date(s) Date(s) Date(s) Date(s) April 6-8, 2015 April 25-26, 2016 May 9-10, 2017 Sites visited Sites visited Sites visited Sites visited Sites visited J. Appendices Appendix 1: Appendix 2: Appendix 3: Appendix 4: Audit Notification Letter and Audit Schedule SFI Fiber Sourcing Public Summary Report Audit Standard Checklist(s): SFI Fiber Sourcing Standard Meeting Attendance AESOP 4742; ISSUE 21; STATUS-PUBLISHED; EFFECTIVE 30 MAR 2017; AUTHORITY STACEY MACK This document is the property of NSF International. Page 3 of 30

4 Appendix 1 Audit Notification Letter May 2, 2017 David Scott Jay Phaup Greif Packaging, LLC 861 Fibre Plant Road Gladstone, Virginia Re: Confirmation of 2017 SFI Standard Surveillance Audit and FSC/SFI/PEFC Chain of Custody Surveillance Audit Dear David and Jay; As we discussed, I will be conducting the Surveillance Audit of your procurement operation for the Gladstone facility on May 9-10, 2017 and your chain of custody programs May 11, as described in the attached itinerary. Please confirm that these dates are still appropriate for the audit of your program s continued conformance to the SFI Fiber Sourcing Standard, SFI Chain of Custody Standard, PEFC 2002:2013 Standard, FSC-STD-0-004, and FSC-STD Preparing for the Audit A key part of the audit is a review of selected evidence related to your program, which may include: SFI Procedures SFI Evidence Manual Internal Audit records Management Review records Training records Monitoring of BMPs Policies regarding certification Chain of Custody Procedures Reclaimed Material Procedures Receiving documents for raw material Supplier documentation of certification Examples of sales documents such as invoices, shipping documents Calculations for average % (or credit systems as applicable) Approval for logo usage (if used) Verification of Controversial Sources Internal Audit records Management Review records Training records Documentation for operation of complaint procedure Documentation for subcontracting/outsourcing Documentation for multisite organization (if applicable) Policies regarding certification, health, and safety Please have this information available for me during the audit.

5 Scope of Certification: The procurement organization supplying wood fiber to its manufacturing facility located in Riverville, Virginia. The scope of the SFI Program includes Section 3, Objectives The SFI Certificate Number is NSF-SFIS- C Role of SFI Inc. Office of Label Use and Licensing As a reminder, your organization is responsible for contacting SFI, Inc. and complying with all requirements before using or changing any SFI label or logo. Your contact is: Rachel Dierolf Manager of Statistics and Labeling Sustainable Forestry Initiative, Inc th Street NW, Suite 700 Washington, DC rachel.dierolf@sfiprogram.org Agenda for Review Attached for your review is the tentative agenda that will guide the conduct of the audit. Please contact me via or phone if you would like to recommend changes or have any questions regarding what is needed for the audit. Thank you for selecting NSF International to provide your audit services. Sincerely, Tucker Watts Lead Auditor, NSF Jtwatts1@gmail.com

6 Audit Agenda Type of Audit Readiness Review (Stage 1) Registration (Stage 2) Surveillance Reassessment Transfer Verification Other Audit Objectives: Determine if certification should be maintained. Schedule Day/Date Time Activity/Process and Location to be Audited Auditor May 8, :00 4:00 PM Review of Chain of Custody Procedures and Due Diligence System Tucker Watts Opening Meeting/Agenda Review Riverville, VA Tucker Watts Review changes to the Facility Record Sheet Discuss changes/improvements to the SFI Program, changes in operations, or changes in scope since the previous audit Review NSF SFI Procedures May 9, :00 AM Discuss field site visit provisions and other logistical issues Verify effective implementation of any corrective action plans from the previous NSF audit Review SFI Survey forms and confirm public report is available to the public Review minutes of Management meetings Review Logo or Label use issues Select field sites SFI Program Review (SFI Fiber Sourcing Standard Tucker Watts Objectives 1 to 10 Requirements for Fiber Sourcing Standard Objectives to be reviewed 9:00 AM 1. Biodiversity in Fiber Sourcing 2. Adherence to Best Management Practices 4. Legal & Regulatory Compliance 5. Forest Research, Science & Technology 9. Communication & Public Reporting 10. Management Review & Continual Improvement 1:00 PM Visit field sites Tucker Watts 4:00 PM Summary of day Discuss agenda for next day Tucker Watts

7 May 10, :00 AM Continue visit of field sites Tucker Watts 3:30 PM Review findings and issues, prepare for Audit Report and any CARs Tucker Watts 4:00 PM Closing Meeting Tucker Watts Opening Meeting for Chain of Custody Audits Tucker Watts May 11, :00 AM Review changes to the Facility Record Sheet Discuss FSC Chain of Custody Program, scope of audit Review NSF Audit Procedures Discuss mill tour and safety issues Chain of Custody Audit Tucker Watts 8:30 AM Procurement/Scale Activities Shipping Activities Claims/Trademark Activities 1:00 PM Recycled Material Audit Tucker Watts 2:00 PM Mill Tour Tucker Watts 3:30 PM Review findings and issues, prepare for Audit Report and any CARs Tucker Watts 4:00 PM Closing Meeting Tucker Watts

8 Appendix 2 Public Summary Audit Report Introduction for SFI Fiber Sourcing The SFI Program of Greif Packaging LLC of Riverville, VA has demonstrated conformance with the SFI Standards and Rules, Section 3 Fiber Sourcing, according to the NSF Certification Process. Greif Packaging LLC is a publicly owned forest products company with corporate headquarters located in Delaware, Ohio, that operates a pulp mill in Riverville, Virginia. Greif Packaging LLC procures wood primarily from south central and western Virginia. The facility utilizes hardwood and reclaimed material. The audit was performed by NSF on May 9-10, 2017 by Tucker Watts, Lead Auditor. Audit team members fulfill the qualification criteria for conducting audits contained in SFI Standards and Rules, Section 9 Audit Procedures and Auditor Qualifications and Accreditation. The scope of the audit included procurement operations. Procurement operations occurring in the past 12 months were reviewed to ensure that SFI Procurement Standards were met. In addition, SFI obligations to promote sustainable forestry practices, to seek legal compliance, and to incorporate continual improvement systems were within the scope of the audit. Several of the SFI Section 3 requirements were outside of the scope Greif Packaging LLC s SFI program and were excluded from the scope of the Audit as follows: Indicator Greif Packaging LLC does not support or conduct research on genetically engineered trees. Indicator Virginia does not have a logger certification program. Objective 8 - Greif Packaging LLC does not have forest management responsibilities on public lands. Objectives Greif Packaging LLC does not purchase fiber outside Canada and the US Audit Process The audit was governed by a detailed audit plan designed to enable the audit team to efficiently determine conformance with the applicable requirements. The plan provided for the assembly and review of audit evidence consisting of documents, interviews, and on-site inspections of ongoing or completed forest practices. During the audit NSF reviewed a sample of the written documentation assembled to provide objective evidence of conformance. NSF also selected field sites for inspection based upon the risk of environmental impact, likelihood of occurrence, special features, and other criteria outlined in the NSF protocols. NSF selected and interviewed stakeholders such as contract loggers, landowners and other interested parties, and interviewed employees within the organization to confirm that the SFI Standard was understood and actively implemented. The possible findings of the audit included conformance, major non-conformance, and minor non-conformance, opportunities for improvement, and practices that exceeded the requirements of the standard. Overview of Audit Findings Greif Packaging LLC was found to be in conformance with the standard. NSF determined that there were no minor nonconformances. No opportunities for improvement were also identified. The next Surveillance Audit is scheduled for June 5-6, 2017.

9 General Description of Evidence of Conformity NSF s audit team used a variety of evidence to determine conformance. A general description of this evidence is provided below, organized by SFI Objective. Objective 1 Biodiversity in Fiber Sourcing To address the practice of sustainable forestry by conserving biological diversity. Summary of Evidence: The Company actively supports and participates in the state SICs which have developed a landowner brochure that addresses the importance of maintaining biodiversity. Software that contains known occurrences of G1 and G2 species by county is used to view habitat and species descriptions on purchase stumpage. Objective 2 Adherence to Best Management Practices To broaden the practice of sustainable forestry through the use of best management practices to protect water quality. Summary of Evidence: Adherence to BMPs is addressed through written agreements with BMP clauses for wood producers, planning for adverse weather conditions, and monitoring state BMP implementation data. Results of BMP implementation is communicated to wood producers during one-on-one conversations during site visits. BMP training is a required component of state logger training every 3 years. Objective 3 Use of Qualified Resource and Qualified Logging Professionals To encourage forest landowners to utilize the services of qualified logging professionals, certified logging professionals (where available) and qualified resource professionals. Summary of Evidence: Objective 4 Legal and Regulatory Compliance Compliance with applicable federal, provincial, state and local laws and regulations. Summary of Evidence: The Company s SFI Policy specifies a commitment to achieving compliance with applicable environmental, forestry, and social laws and regulations. The company has a system to encourage its wood suppliers to comply with such laws and regulations. Controversial Sources Due Diligence System & Risk Assessment has been conducted for the procurement area. Objective 5 Forestry Research, Science, and Technology To support forestry research, science, and technology, upon which sustainable forest management decisions are based. Summary of Evidence: The Company financially supports forest operations and business research cooperative through membership in a cooperative. Objective 6 Training and Education To improve the implementation of sustainable forestry practices through appropriate training and education programs. Summary of Evidence: Objective 7 Community Involvement and Landowner Outreach To broaden the practice of sustainable forestry through public outreach, education, and involvement and to support the efforts of SFI Implementation Committees. Summary of Evidence: Objective 9 Communications and Public Reporting To broaden the practice of sustainable forestry by documenting progress and opportunities for improvement. Summary of Evidence: Summary Audit Report witnessed on SFI, Inc. website. Review of Annual Progress Report confirms record keeping is adequate and that reports are submitted on time.

10 Objective 10 Management Review and Continual Improvement To promote continual improvement in the practice of sustainable forestry, and to monitor, measure, and report performance in achieving the commitment to sustainable forestry. Summary of Evidence: Records of program reviews, agendas, and notes from management review meetings and interviews with personnel from all involved levels in the organization were assessed. Relevance of Forestry Certification Third-party certification provides assurance that forests are being managed under the principles of sustainable forestry, which are described in the Sustainable Forestry Initiative Standard as: 1. Sustainable Forestry To practice sustainable forestry to meet the needs of the present without compromising the ability of future generations to meet their own needs by practicing a land stewardship ethic that integrates reforestation and the managing, growing, nurturing and harvesting of trees for useful products and ecosystem services such as the conservation of soil, air and water quality, carbon, biological diversity, wildlife and aquatic habitats, recreation and aesthetics. 2. Forest Productivity and Health To provide for regeneration after harvest and maintain the productive capacity of the forest land base, and to protect and maintain long-term forest and soil productivity. In addition, to protect forests from economically or environmentally undesirable levels of wildfire, pests, diseases, invasive exotic plants and animals and other damaging agents and thus maintain and improve long-term forest health and productivity. 3. Protection of Water Resources To protect water bodies and riparian areas and to conform with forestry best management practices to protect water quality. 4. Protection of Biological Diversity To manage forests in ways that protect and promote biological diversity, including animal and plant species, wildlife habitats, and ecological or natural community types. 5. Aesthetics and Recreation To manage the visual impacts of forest operations, and to provide recreational opportunities for the public. 6. Protection of Special Sites To manage lands that are ecologically, geologically or culturally important in a manner that takes into account their unique qualities. 7. Responsible Fiber Sourcing Practices in North America To use and promote among other forest landowners sustainable forestry practices that are both scientifically credible and economically, environmentally and socially responsible. 8. Legal Compliance To comply with applicable federal, provincial, state, and local forestry and related environmental laws, statutes, and regulations. 9. Research To support advances in sustainable forest management through forestry research, science and technology. 10. Training and Education To improve the practice of sustainable forestry through training and education programs. 11. Community Involvement and Social Responsibility To broaden the practice of sustainable forestry on all lands through community involvement, socially responsible practices, and through recognition and respect of Indigenous Peoples rights and traditional forest-related knowledge.

11 12. Transparency To broaden the understanding of forest certification to the Fiber Sourcing Standard by documenting certification audits and making the findings publicly available. 13. Continual Improvement To continually improve the practice of forest management, and to monitor, measure and report performance in achieving the commitment to sustainable forestry. 14. Avoidance of Controversial Sources including Illegal Logging in Offshore Fiber Sourcing To avoid wood fiber from illegally logged forests when procuring fiber outside of North America, and to avoid sourcing fiber from countries without effective social laws. Source: Sustainable Forestry Initiative (SFI) Standard, Edition For Additional Information Contact: Norman Boatwright Daniel Freeman Mr. Jay Phaup NSF Forestry Program Manager NSF Project Manager Wood Procurement Manager PO Box 4021 Florence, SC N. Dixboro Road Ann Arbor, MI Fibre Plant Road Gladstone, Virginia

12 Appendix 3 SFI , Section 3: Fiber Sourcing Standard Audit Checklist C Greif Packaging LLC Date of audit(s): May 9-10, 2017 Multi-site Assessment Yes. Section 9, Appendix 1 Checklists (main and 1 sub-checklist) must be completed. No. Section 9, Appendix 1 Checklists are not included. 1.2 Additional Requirements SFI Program Participants that own or have management authority for forestlands must also conform to the SFI Forest Management Standard. Use of the SFI on-product labels and claims shall follow Section 5 - Rules for Use of SFI On-Product Labels and Off-Product Marks as well as ISO 14020:2000. Section 3, Appendix 1: Rules for Use of SFI Certified Sourcing Label Applicability The organization applies or intends to apply the Certified Sourcing label. Yes: Section 3, Appendix 1 checklist must be completed. No: Section 3, Appendix 1 checklist may be deleted. Fiber sourcing within the United States and Canada (Objectives 1-10 apply)

13 Objective 1 Biodiversity in Fiber Sourcing. To address the practice of sustainable forestry by conserving biological diversity. Performance Measure 1.1 Promotion and conservation of biological diversity Program participant shall address conservation of biodiversity, individually or collaboratively, through a Program which includes one or more of the following: a. promotion of biological diversity utilizing information from organizations such as World Resources Institute, The Nature Conservancy, NatureServe, Conservation International, State Wildlife Action Plans, State Forest Action Plans and assessments; b. conducting local and regional level landscape assessments; c. involvement with local or regional conservation efforts; d. use of relevant information on biological diversity from credible sources (such as those noted above) in approved training and education programs; and e. other credible approaches. VA SIC has developed brochures for landowners on biodiversity. Information is provided to landowners during procurement activities. Witnessed letter to forest landowners. Brochures are also provided to contract loggers and wood producers. Wood producers are encouraged to pass the information to landowners as they purchase wood. Brochures include the following: Sustainable Forestry: A Guide for Virginia Forest Landowners Guide to Threatened and Endangered Species on Private Lands in Virginia Resources for Sustainable Forestry: A guide for Virginia Forest Landowners Letter to forest landowners and wood producers also encourages biodiversity, along with a link to the Virginia Wildlife Action Plan Program to address Forests with Exceptional Conservation Value in harvests of purchased stumpage. Greif Packaging LLC has purchased software from Wiregrass Ecological Associates (utilizing NatureServe) that contains known occurrences of G1 and G2 species by county. The program has hyperlinks that allow Greif to view habitat and species descriptions. The database is updated every 2 years. The process is a 2 stage process: Stage 1. Identifying Critically Imperiled or Imperiled Species and Ecological Communities Stage 2. Develop Conservation Strategies If the landowner chooses to implement particular management measures, the Area Foresters will work with the landowner to implement those measures during the course of road construction, timber harvesting and other associated management activities. While the company can promote the conservation of Forests of Exceptional Conservation Value, the ultimate decision and authority for implementation protection measures rests with the private landowner.

14 Objective 2 Adherence to Best Management Practices. To broaden the practice of sustainable forestry through the use of best management practices to protect water quality. Performance Measure 2.1 Program Participants shall clearly define and implement policies to ensure that facility inventories and fiber sourcing activities do not compromise adherence to the principles of sustainable forestry. The Company s Sustainable Forestry Initiative Fiber Sourcing Policy (revised 3/1/16), procedures for inspecting BMP implementation on purchase stumpage tracts and its wet weather procedures satisfy this requirement Program to require that harvests of purchased stumpage comply with best management practices. SFI Fiber Sourcing Program (GPL-SFI-03) includes contracts, education, and monitoring for BMP compliance. Harvesting and Delivery Agreement 5. Contractor Obligations and Rights E. BMPs; No logger training Contract/Agreement/Self-Declaration 1) logger training; 2) BMP BMP Monitoring Report & Final Inspections Verbal and/or written is received is issues Silvicultural Best Management Practices Implementation Monitoring for Virginia Use of written agreements for the purchase of raw material sourced directly from the forest is required and must include provisions requiring the use of best management practices. Written agreements witnessed for sites visited. Written agreements include the following: Timber Deed Harvesting and Delivery Agreement Contract/Agreement/Self-Declaration Program to address adverse weather conditions. Where Greif Packaging LLC directly purchases stumpage from forest landowners and has control of the harvesting operations, the Wood Procurement Supervisor and the Area Foresters use the following guidelines to plan for and manage adverse weather conditions, including but not limited to: 1. Follow all applicable state BMPs and local regulations in the harvesting of timber and construction of roads, landings and skid trails; 2. Identify when soil and road conditions are not conducive to logging activities and plan such activities when conditions are more favorable; 3. Harvest upland portions of tracts that are appropriate for wet weather conditions; 4. Use gravel, mats and other practices as appropriate to stabilize roads, minimize erosion, and improve accessibility during adverse weather; 5. Maintain a number of optional sites that can be harvested without causing excessive rutting or other environmental damage; 6. Schedule harvests on stumpage contracts to coincide with proper weather conditions and landowner requirements; 7. Access drier and more accessible tracts that can be harvested during periods of inclement weather; and 8. Evaluate operations that may require the use of alternative logging systems or should be suspended until weather and soil moisture conditions improve.

15 Greif Packaging LLC s Area Foresters and/or Wood Procurement Supervisor are authorized to suspend operations on purchased stumpage tracts if, in their opinion, continuation of operations would result in excessive rutting or soil disturbance which compromises adherence to state BMP guidelines. The company builds wood inventory levels during periods of dry weather to support the mill s wood requirements through the wetter months of the year. The SFI Team periodically monitors and manages wood inventories to avoid logging during adverse weather conditions. A monthly budget to plan wood inventories is available to demonstrate the adverse weather program. Witnessed Inventory plan and trends graph. Greif Packaging LLC also works to develop and maintain a diverse wood supplier network throughout its wood supply area to offset localized supply interruptions due to adverse weather. The company cuts back wood procurement in certain areas during times of saturated soil conditions and during periods of adverse weather conditions and takes steps to expand procurement from unaffected areas when necessary Program Participants shall clearly define their fiber sourcing policies in writing and make them available to wood producers. Sustainable Forestry Policy signed by David Scott, Vice President Mill Operations Letter to forest landowners, contractors, wood producers dated April 25, Performance Measure 2.2 Program Participants shall monitor the use of best management practices. Indicators: A verifiable monitoring system to: a. monitor the use of best management practices by wood producers supplying the Program Participant; and b. evaluate use of best management practices across the wood and fiber supply area. The Company has a program that includes documenting BMP implementation of purchase stumpage tracts. The results of this activity was rolled up into the Greif BMP Audit Results document indicating 73 inspections were performed (98% compliance). The Company has also reviewed the Silvicultural Best Management Practices Implementation Monitoring for Virginia 2016 which identified roads, skidding, and fires as least compliant. Information from the SIC Inconsistent Practices Subcommittee is also used in their monitoring program Use of information from the verifiable monitoring system to maintain rates of conformance to best management practices and to identify areas for improved performance. BMP monitoring information from inspections of purchase stumpage and the results of the VADOF BMP Compliance Monitoring Report were discussed in the annual management review on March 16, Issues are discussed with loggers during one-on-one communication. CEUs include a required BMP component (3 CEU every 3 years). Greif sponsored on training on 4/6/17.

16 Objective 3 Use of Qualified Resource and Qualified Logging Professionals. To encourage forest landowners to utilize the services of qualified logging professionals, certified logging professionals (where available) and qualified resource professionals. Performance Measure 3.1 Program Participants shall encourage landowners to utilize the services of qualified logging professionals, certified logging professionals (where available), qualified resource professionals and in applying principles of sustainable forest management on their lands Program to promote the use of qualified logging professionals, certified logging professionals (where available), and qualified resource professionals List of qualified logging professionals, certified logging professionals and maintained by a Program Participant, state or provincial agency, loggers association or other organization.

17 Objective 4 Legal and Regulatory Compliance To comply with applicable federal, provincial, state and local laws and regulations. Performance Measure 4.1 Program Participants shall comply with applicable federal, provincial, state and local forestry and related social and environmental laws and regulations and take steps to avoid illegal logging. See Indicators below Access to relevant laws and regulations in appropriate locations. SFI Fiber Sourcing Program (GPL-SFI-03) has link to websites of applicable laws and regulations. Foresters have BMP manual and field guides System to achieve compliance with applicable federal, provincial, state or local laws and regulations. Greif Packaging LLC s system to achieve regulatory compliance is based upon environmental management system elements, similar to those contained in ISO The management system elements include the following: 1. A policy commitment to achieve continuing regulatory compliance; 2. Contract provisions with loggers requiring regulatory compliance; 3. Ready access to applicable laws and regulations through the internet; 4. SHARP Logger training of appropriate staff and logging contractors in applicable regulations: 5. Monitoring of BMP compliance on all purchased stumpage; 6. Corrective and preventive action where compliance is unsatisfactory; and 7. Annual management review and continual improvement by the SFI team Demonstration of commitment to legal compliance through available regulatory action information. Interview of VA Dept of Forestry Water Quality specialist confirmed demonstration of commitment Program to assess the risk that the Program Participant s fiber sourcing program could acquire material from illegal logging by considering some of the following: a. communications with suppliers; b. independent research; c. contract documentation; and d. maintain records. Controversial Sources Due Diligence System & Risk Assessment (GPL-SFI08) has been conducted for procurement area. State notification system notifies landowner of harvest on their property. Payment is not made for wood unless a Harvest Notification Number is received Program to address any significant risk identified under Findings conclude Negligible Risk, therefore low risk of non-controversial sources. Current program addresses significant risk.

18 Performance Measure 4.2 Program Participants shall take appropriate steps to comply with all applicable social laws at the federal, provincial, state and local levels in the country in which the Program Participant operates Written policy demonstrating commitment to comply with social laws, such as those covering civil rights, equal employment opportunities, anti-discrimination and anti-harassment measures, workers compensation, Indigenous Peoples rights, workers and communities right to know, prevailing wages, workers right to organize, and occupational health and safety. Sustainable Forestry Policy demonstrates commitment to compliance with social laws. Greif Packaging, LLC s Human Resource Policies addresses social laws. Witnessed on intranet website. Witnessed posting of social laws on HR bulletin board.

19 Objective 5 Forestry Research, Science and Technology To invest in forestry research, science and technology, upon which sustainable forest management decisions are based and broaden the awareness of climate change impacts on forests, wildlife and biological diversity. Performance Measure 5.1 Program Participants shall individually and/or through cooperative efforts involving SFI Implementation Committees, associations or other partners provide in-kind support or funding for forest research to improve forest health, productivity, and sustainable management of forest resources, and the environmental benefits and performance of forest products Financial or in-kind support of research to address questions of relevance in the region of operations. Examples could include, but are not limited to areas of forest productivity, water quality, biodiversity, community issues, or similar areas which build broader understanding of the benefits and impacts of forest management. Dues of $3,500 paid to VA Tech Foundation for funding forest operations and business research cooperative. Witnessed letter of appreciation from Chad Bolding, Director, Forest Operations and Business Research Cooperative Research on genetically engineered trees via forest tree biotechnology shall adhere to all applicable federal, state, and provincial regulations and international protocols ratified by the U.S. or Canada depending on jurisdiction of management. Performance Measure 5.2 Program Participants shall individually and/or through cooperative efforts involving SFI Implementation Committees, associations or other partners develop or use state, provincial or regional analyses in support of their sustainable forestry programs Participation, individually and/or through cooperative efforts involving SFI Implementation Committees and/or associations at the national, state, provincial or regional level, in the development or use of some of the following: a. regeneration assessments; b. growth and drain assessments; c. best management practices implementation and conformance; d. biodiversity conservation information for family forest owners; and e. social, cultural or economic benefit assessments. Performance Measure State of the Forest, and 2015 Forest Inventory and Analysis contains regeneration, and growth and drain assessments are used in fiber planning. BMP Assessment is used for the monitoring of BMPs in Performance Measure 2.2. SIC landowner Brochure contains information on biodiversity conservation for family forest owners. Brochure is distributed to wood suppliers and landowners. Program Participants shall individually and/or through cooperative efforts involving SFI Implementation Committees, associations or other partners broaden the awareness of climate change impacts on forests, wildlife and biological diversity Where available, monitor information generated from regional climate models on long-term forest health, productivity and economic viability. EPA website is monitored periodically for information on climate change. Documentation from website witnessed. SFI Fiber Sourcing Program (GPL-SFI-03) contains a summary of findings on climate change.

20 5.3.2 Program Participants are knowledgeable about climate change impacts on wildlife, wildlife habitats and conservation of biological diversity through international, national, regional or local programs. Interviews confirm knowledge of climate change impacts.

21 Objective 6 Training and Education To improve the implementation of sustainable forestry practices through appropriate training and education programs. Performance Measure 6.1 Program Participants shall require appropriate training of personnel and contractors so that they are competent to fulfill their responsibilities under the SFI Fiber Sourcing Standard Written statement of commitment to the SFI Fiber Sourcing Standard communicated throughout the organization, particularly to facility and woodland managers, fiber sourcing staff and field foresters Assignment and understanding of roles and responsibilities for achieving SFI Fiber Sourcing Standard objectives Staff education and training sufficient to their roles and responsibilities Contractor education and training sufficient to their roles and responsibilities Program Participants shall have written agreements for the use of qualified logging professionals and/or certified logging professionals (where available) and/or wood producers that have completed training programs and are recognized as qualified logging professionals. Performance Measure 6.2 Program Participants shall work individually and/or with SFI Implementation Committees, logging or forestry associations, or appropriate agencies or others in the forestry community to foster improvement in the professionalism of wood producers Participation in or support of SFI Implementation Committees to establish criteria and identify delivery mechanisms for wood producer training courses and periodic continuing education that address: a. awareness of sustainable forestry principles and the SFI program; b. best management practices, including streamside management and road construction, maintenance and retirement; c. reforestation, invasive exotic plants and animals, forest resource conservation, aesthetics and special sites; d. awareness of responsibilities under the U.S. Endangered Species Act, the Canadian Species at Risk Act, and other measures to protect wildlife habitat (e.g., Forests with Exceptional Conservation Value); e. awareness of rare forested natural communities as identified by provincial or state agencies, or by credible organizations such as NatureServe, The Nature Conservancy, etc. f. logging safety; g. U.S. Occupational Safety and Health Administration (OSHA) and Canadian Centre for Occupational Health and Safety (CCOHS) regulations, wage and hour rules, and other provincial, state and local employment laws; h. transportation issues; i. business management; j. public policy and outreach; and k. awareness of emerging technologies.

22 6.2.2 The SIC-approved wood producer training programs shall have a continuing education component with coursework that supports the current training programs, safety and the principles of sustainable forestry Participation in or support of SFI Implementation Committees to establish criteria for recognition of logger certification programs, where they exist, that include: a. completion of SFI Implementation Committee recognized logger training programs and meeting continuing education requirements of the training program; b. independent in-the-forest verification of conformance with the logger certification program standards; c. compliance with all applicable laws and regulations including responsibilities under the U.S. Endangered Species Act, the Canadian Species at Risk Act and other measures to protect wildlife habitat; d. use of best management practices to protect water quality; e. logging safety; f. compliance with acceptable silviculture and utilization standards; g. aesthetic management techniques employed where applicable; and h. adherence to a management or harvest plan that is site specific and agreed to by the forest landowner.

23 Objective 7 Community Involvement and Landowner Outreach To broaden the practice of sustainable forestry through public outreach, education, and involvement and to support the efforts of SFI Implementation Committees. Performance Measure 7.1 Program Participants shall support and promote efforts by consulting foresters, state, provincial and federal agencies, state or local groups, professional societies, conservation organizations, Indigenous Peoples and governments, community groups, sporting organizations, labor, universities, extension agencies, the American Tree Farm System and/or other landowner cooperative programs to apply principles of sustainable forest management Support, including financial, for efforts of SFI Implementation Committees Support individually or collaboratively education and outreach to forest landowners describing the importance of and providing implementation guidance on: a. best management practices; b. reforestation and afforestation; c. visual quality management; d. conservation objectives, such as of critical wildlife habitat elements, biodiversity, threatened and endangered species, and Forests with Exceptional Conservation Value; e. management of harvest residue (e.g., slash, limbs, tops) considers economic, social, environmental factors (e.g., organic and nutrient value to future forests) and other utilization needs; f. control of invasive exotic plants and animals; g. characteristics of special sites; and h. reduction of wildfire risk Participation in efforts to support or promote conservation of managed forests through voluntary market-based incentive programs such as current-use taxation programs, Forest Legacy Program or conservation easements Program Participants are knowledgeable about credible regional conservation planning and priority-setting efforts that include a broad range of stakeholders and have a program to take into account the results of these efforts in planning Program Participants with fiber sourcing programs, either individually or collaboratively with SFI Implementation Committees, encourage forest landowners to participate in forest management certification programs. Performance Measure 7.2 Program Participants shall support and promote, at the state, provincial or other appropriate levels, mechanisms for public outreach, education and involvement related to sustainable forest management Periodic educational opportunities promoting sustainable forestry, such as a. field tours, seminars, websites, webinars or workshops; b. educational trips;

24 c. self-guided forest management trails; d. publication of articles, educational pamphlets or newsletters; or e. support for state, provincial, and local forestry organizations and soil and water conservation districts. Performance Measure 7.3 Program Participants shall establish, at the state, provincial, or other appropriate levels, procedures to address concerns raised by loggers, consulting foresters, employees, unions, the public or other Program Participants regarding practices that appear inconsistent with the SFI Standard principles and objectives Support for SFI Implementation Committees (e.g., toll-free numbers and other efforts) to address concerns about apparent nonconforming practices Process to receive and respond to public inquiries. SFI Implementation Committees shall submit data annually to SFI Inc. regarding concerns received and responses.

25 Objective 8 Public Land Management Responsibilities To participate and implement sustainable forest management on public lands. Performance Measure 8.1 Program Participants with forest management responsibilities on public lands shall participate in the development of public land planning and management processes Involvement in public land planning and management activities with appropriate governmental entities and the public Appropriate contact with local stakeholders over forest management issues through state, provincial, federal or independent collaboration.

26 Objective 9 Communications and Public Reporting To increase transparency and to annually report progress on conformance with the SFI Fiber Sourcing Standard. Performance Measure 9.1 A Program Participant shall provide a summary audit report, prepared by the certification body, to SFI Inc. after the successful completion of a certification, recertification or surveillance audit to the SFI Fiber Sourcing Standard The summary audit report submitted by the Program Participant (one copy must be in English), shall include, at a minimum, a. a description of the audit process, objectives and scope; b. a description of substitute indicators, if any, used in the audit and a rationale for each; c. the name of Program Participant that was audited, including its SFI representative; d. a general description of the Program Participant s forestland, fiber procurement and/or manufacturing operations included in the audit; e. the name of the certification body and lead auditor (names of the audit team members, including technical experts may be included at the discretion of the audit team and Program Participant); f. the dates the audit was conducted and completed; g. a summary of the findings, including general descriptions of evidence of conformity and any nonconformities and corrective action plans to address them, opportunities for improvement, and exceptional practices; and h. the certification decision. The summary audit report will be posted on the SFI Inc. website ( for public review. Performance Measure 9.2 Summary Audit Report for 2015 and 2016 witnessed on SFI, Inc. website. Program Participants shall report annually to SFI Inc. on their conformance with the SFI Fiber Sourcing Standard Prompt response to the SFI annual progress report survey. SFI Annual Progress Report submitted March 30, Response is prompt Record keeping for all the categories of information needed for SFI annual progress report surveys. Confirmed by review of 2016 Progress Report that recordkeeping is adequate Maintenance of copies of past survey reports to document progress and improvements to demonstrate conformance to the SFI Fiber Sourcing Standard. Witnessed reports from 2009 to present.

27 Objective 10 Management Review and Continual Improvement To promote continual improvement in the practice of sustainable forestry by conducting a management review and monitoring performance. Performance Measure 10.1 Program Participants shall establish a management review system to examine findings and progress in implementing the SFI Fiber Sourcing Standard, to make appropriate improvements in programs, and to inform their employees of changes System to review commitments, programs and procedures to evaluate effectiveness. Greif Packaging, LLC has a formal system for annually collecting information about its SFI implementation, evaluating the effectiveness of the SFI program, determining whether any changes or improvements are necessary to continually improve SFI Fiber Sourcing conformance, reporting information to management and communicating those changes to responsible personnel. Reviewed system and witnessed in Document Directory SFI Fiber Sourcing Documents (GPL-DOC-01) System for collecting, reviewing and reporting information to management regarding progress in achieving SFI Fiber Sourcing Standard objectives and performance measures. As outlined in the Program (GPL-SFI-03) for evaluating the effectiveness of promoting use of BMPs, the Area Foresters and/or Wood Procurement Supervisor conduct monitoring using the BMP Monitoring Reports on purchased stumpage tracts. The Area Foresters consolidate that information, as well as information from the Virginia BMP Compliance Monitoring Reports and summarizes patterns and trends as part of preparations for the annual management review. The management review will usually be coordinated with the completion of the SFI Annual Progress Reports during the second quarter of each calendar year. The designated Area Forester collects all of the appropriate information and works with the VP of Mill Operations and Wood Procurement Supervisor to set a formal agenda for the management review. The SFI Team holds the annual management review meeting to discuss the effectiveness of the SFI Promotion and Monitoring Programs and all other aspects of the SFI Program. The SFI Team is made up of the Wood Procurement Supervisor, three (3) Area Foresters, and one (1) VP of Mill Operations at Greif Packaging LLC. The SFI Team determines whether any substantive changes or improvements should be made to the SFI Program. All personnel are encouraged to actively participate in the annual review and to make suggestions for improvement as part of regularly scheduled meetings and as part of the annual management review. The Wood Procurement Supervisor then develops a summary of Action Items for improving the SFI Program and works to edit the SFI documents. The SFI Team then implements the changes and improvement to the SFI Program. Training or other orientation programs may be organized as appropriate Annual review of progress by management and determination of changes and improvements necessary to continually improve conformance to the SFI Fiber Sourcing Standard. Confirmed by review of agenda and meeting minutes that the management review occurred March 23, 2016 and included SFI. Very complete review including revisions to the SFI Program document, summary and review of trends from the BMP monitoring reports and state monitoring and outreach efforts. The minutes include an Action Item Section and clearly defined Opportunities for Improvement. Management Review Meeting was conducted on 3/16/17. Agenda and Minutes witnessed. Agenda included a review of findings and trends in the Silvicultural Best Management Practices Implementation Monitoring for VA and BMP Monitoring Reports by Greif Packaging, LLC. Minutes included Action Items and Opportunities for improvement.

28 There is no fiber sourcing outside the United States and Canada; Objectives do not apply and have been deleted. (End SFI Fiber Sourcing Checklist)

29 Field Notes Anderson Tract 18 Acre Clearcut. SMZ flagged by consultant in Blue. Greif Packaging LLC foresters have extended the SMZ to ensure no impact on water quality. They have flagged the extension in Pink. No entrance of SMZ. Verification of T&E species in Halifax, Co. included in sale folder. Good utilization. Smith Tract 42 Acre Clearcut. Cutting and hauling has been completed. Close-out remains to be completed. Verification of T&E species included in sale folder. Drain to pond and pond buffered. Crossing has been removed and stabilized. No issues. Minor rutting on slope. Debris added to stabilize. Cemetery discovered at the edge of SMZ by Lee. SMZ and cemetery buffered. Additional debris will be added to stabilize crossings. There are a few bundles of small hardwood that were left due to hardwood quota. Francisco #1 17 Acre Clearcut. Verification of T&E species in Halifax, Co. included in sale folder. Steel bridge used for crossing. Debris used for stabilization. Gravel on both sides of logging deck for stabilization. There are some small limbs along stream. There would be damage to the bank to remove. No impact on water quality or flow. Debris in main skid trail for stabilization. Water bars used as necessary. Francisco #2 3 Acre Clearcut. SMZ buffered and used for sale boundary. No entrance. There are 4 bundles of small hardwood that were left due to hardwood quota. No issues. Lloyd Tract 20 Acre Clearcut. Verification of T&E species included in sale folder. Greif Packaging LLC foresters have extended the SMZ to ensure no impact on water quality. Water bars, debris, and seeding have been installed for stabilization of skid trail. Debris use to stabilize crossings. Minor ruts in corner. No issues. Dickenson Tract 86 Acre Clearcut. Verification of T&E species included in sale folder. Greif Packaging LLC foresters have extended the SMZ to ensure no impact on water quality on 2 SMZs. No crossings. Gravel on logging deck for stabilization. Water bars and debris used to stabilize skid trails. Minor rutting around deck. No issue. Tract has been planted. Kennon Road Tract 60 Acre Clearcut. Verification of T&E species included in sale folder. SMZ is one of sale boundaries. Trees have been removed to a BA 50. No rutting. No issues. Tract has been planted. Ellis Tract 181 Acre Clearcut. Verification of T&E species included in sale folder. Wide SMZ. Gravel for low water crossing. Steel bridge used for another crossing. Area seeded and gravel on approach for stabilization. No issues. Clean water. Water bars on roads. Several crossings. Debris used to stabilize. Cemetery identified by landowner has been buffered. Pipeline crossing was matted. Harwood Tract 22 Acre Clearcut. Verification of T&E species included in sale folder. Greif Packaging LLC foresters have extended the SMZ to ensure no impact on water quality. Selection inside SMZ. No issues. Good utilization. Buffer established on neighbor s fence. Logger communicated with adjacent landowner about horses. Pearson Cutlett Tract 340 Acre Clearcut. Verification of T&E species included in sale folder. Steel bridge used for crossing. Debris used to stabilize crossing. High water has moved debris to edge of stream. Flow has not been blocked. No issue.

30 Appendix 4 NSF Audit Attendance Sheet Company Name Location Type of Audit Greif Packaging LLC Riverville, VA Surveillance Audit Opening Meeting Date May 9, 2017 Closing Meeting Date May 10, 2017 NAME (Printed) TITLE/POSITION OPENING MEETING (Initials) Jay Phaup Wood Procurement Supervisor JP JP Tim Kane Wood Procurement Forester TK TK Lee Johnson Wood Procurement Forester LJ LJ Rich Palermo Wood Procurement Forester RP RP Tucker Watts NSF Lead Auditor TW TW David Scott Joe Irving Kevin Dawson Vice President Operations Joseph L Irving Logging Inc. Virginia BMP Forester CLOSING MEETING (Initials)