Chain of Custody Checklist & Assessment Report

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1 Chain of Custody Checklist & Assessment Report Organization Gold Rank Sdn. Bhd. ( K) Reference # G Contact Address (O) Address (M) Mr. Francis Loo (COC MR) Jason Gan Sally (COC ler) TB 10771, Ground Floor, Jalan Megah 5, 91000, Tawau, Sabah, Malaysia P. O. Box, 1601, 91041, Off KM 19, Kg. Pitas Bombalai, Merotai Highway, Tawau, Sabah, Malaysia Assessment Date 10 Sept 2012 Report - Date 17 Sept 2012 Lead Assessor Jessie Ooi Telephone Assessor Not Applicable Fax Close out Date Not Applicable unlumber@yahoo.com, goldrank_tawau@yahoo.com Approved Dr. Kevin Grace Scope of Assessment Company Type Scope of Assessment Product Group Source of Material Species Sawmill (GFS 010 WTP) Gold Rank Sawmill at Kg. Pitas, Bombalai, Merotai Highway, Tawau Rimba Kekal Kiln Dry Mill, Merotai Highway, Tawau Sawn Timbers VLO Sabah, Malaysia. ITP (Intensive Tree Plantation) and NFM (Natural Forest Management) Coupe Area SFMLA 09/97 (Tawau Yayasan Sabah) and ITP Coupe License Area SFMLA 03/97 (Keningau Bornion Timber) White Seraya (Shorea anthoshorea), Yellow Seraya (Shorea roxburg), Red Seraya (Shorea rubirosa), Selangan Batu (Hopea spp), Kapur (Dryobalanops spp), Keruing (Diptero-carpus spp), Nyatoh (Palquium spp), Obah Suluk / Dark Red Seraya / Heavy Majau (Shorea johorensis), Mengkulang (Hertiera spp), Penggiran (Anisoptera spp.), Keranji (Dialium spp), Kembang Semangkuk (Scaphium spp.), Agathis (Agathis spp) Limitations of Assessment The information presented in this report is based on documentation and other information presented by the client and observations made during the field verification under the assessment. GFS reporting of information presented by the client are taken as accurate, unless evaluated differently through the observations made during the assessment. All information presented in the report is accurate and complete to the best of knowledge of GFS.

2 Background Information : Gold Rank is registered sawmill and moulding mill (JP (T)TW 001/10(X04)) in Sabah, Malaysia. Associated organizations : Gold Rank has changed ownership since July 2008 and managed under the sister company : Uni-lumber Sdn. Bhd. From January to date, Gold Rank sends the VLO sawn timbers for kiln dry services at Rimba Kekal Sdn. Bhd. located at Mastergroup, Merotai Road, Tawau, Sabah. Description of the Supply Chain : Gold Rank logs supplies are from the Sabah forest license area : Forest License Area Coupe Area SFMLA 09/97 TWU 32/04 YT 1/04 (1) (2), TWU 08/09 YT 2/08 (201) (208)(211)(209), TWU 12/08- YT1/08, TWU 29/06 YT 2/06 SFMLA 03/97 KGU 06/11, (JTP18)(ITP22) (ITP16) (ITP19) (ITP20), KGU 03/11 & KGU 09/11 (ITP16) (ITP19) (ITP20) Since 2009, GFS has conducted Timber Legality Assurance System (TLAS) Sabah audit for 24 Forest Management Units in Sabah and in 2012, has extended to include forest license area under Form 1 and Form 2B in Sabah. Besides that, GFS RIL has conducted RIL auditing for all harvesting operations in Yayasan Sabah concession and production forest in Sabah, Malaysia. Common species used are Red Meranti, Yellow Meranti, MLH, Selangan Batu, Kapur, Kempas, Keranji, Keruing Resak etc. Sales markets include Hong Kong, Middle East, Korea, Thailand, China, South Africa, Taiwan, India and others. Highlights of Assessment Documented Policy & Procedures Gold Rank has formal policy and procedures but the company did not have a formal agreement for kiln drying with subcontractor that resulted in a minor gap. Organization & Training Gold Rank maintains training records and has conducted training for subcontracted kiln drying activities that addressed a previous gap. Purchasing & Receiving The company has a supplier risk assessment for VLO log purchasing from Rakyat Berjaya and Bornion Timber concessions in Sabah Malaysia. The concessions have been assessed under the Sabah TLAS program and Reduced Impact Logging project by GFS in 2011 and All logs purchased from January to August 2012 are traceable to the forest license area through the records of Removal Pass and Timber

3 Disposal Permits kept in Gold Rank office. However, Gold Rank does not keep all copies of the Purchase Contract with the log suppliers resulted another minor gap. Planning & Process Controls There are adequate documents & records in the Gold Rank office to support the traceability of sawn timbers from the invoice (with batch #) back to the Removal Pass # or Timber Disposal Permit # (supplier) through the Log Batch #. All stocks in the finish good storage area have a bundle card tagged to each bundle of sawn timbers that reference to the species, batch #, length, pieces and environmental status. Sales The Sales Invoices and Packing Lists for sales of VLO sawn timber under GFS WTP clearly reference the batch #, environmental status and GFS WTP #. Gold Rank shall use the new format of Product Declaration Form instead of the old format; Product Identification Statement, that was used for every sales of VLO sawn timbers from January to August 2012 (Observation # 004). Records & Data Gold Rank maintains monthly summary records for receiving, production, kiln dry and sales of VLO logs/ sawn timbers. The monthly summary records for each department includes defining the environmental status, species and batch number (production unit). Legal Requirements Gold Rank maintains permits for all their wood processing and export activities but the list of regulations needs to be updated which resulted in an observation. There was no evidence of non compliance to legal requirements. All Minor GAPs are to be corrected by the first surveillance in 10 March Non-Conformance : (GAPs) GAP # Type Checklist # Description 01/2012 Minor /2012 Minor 3.3 There was no subcontractor agreement developed between Gold Rank and MGR for kiln drying VLO sawn timbers. Gold Rank does not keep all copies of the Purchase Contract with the log suppliers. The Purchase Contracts between Gold Rank and the log suppliers does not reference to the environmental status Observations Obs # Checklist # Description Gold Rank current environmental policy does not include elements of non use of GMO, elimination of forest products that area considered controversial where

4 timbers are coming from converted forest (may have High Conservation Values), non use of CITES (Convention of International Trade in Endangered Species) unless there is a valid approved CITES certificate and support of Sustainable Forest Management (SFM). Organization chart needs to be updated to include key personnel of moulding operation. Gold Rank shall define the process to go through GFS WTP website to check the supplier validity in terms of supplying VLO sawn timbers in the purchasing procedure. Gold Rank shall use the recent Supplier Evaluation Risk Assessment (WTP 15a VLO Risk Assessment v04 July 2012) developed by GFS for evaluating potential or existing logs/ sawn timber supplier s environmental status Gold Rank shall use the new format of Product Declaration Form instead of the old format; Product Identification Statement, that was used for every sales of VLO sawn timbers from January to August The existing list of legal regulation does not reference to the above licenses. Non-Conformance : (GAPs) Previously Issued GAP # Type Status Description 02/2011 Minor Closed Gold Rank kept a separate record and summary for VLO sawn timbers sent for KD services from January to August /01 Minor (Outsta nding) Closed Training was conducted at the outsourced kiln dry operator in regards of WTP Chain of Custody dated 10 September 2012 Highlights of Close out visit (if applicable) Not applicable Date Recommendations Gold Rank Sdn. Bhd. is recommended for the awarding of the Statement of Participation based on GFS Wood Tracking Program requirements. Monitoring is needed especially with action points in order to ensure COC system implement within the organization to adhere responsible purchasing under WTP requirements. All the gaps should closed in next surveillance visit. Some actions upon the observations issued are required in order to prevent gap in the next surveillance are as below : Observation # 001 : Gold Rank current environmental policy does not include elements of non use of GMO, elimination of forest products that area considered controversial where timbers are coming from converted forest (may have High Conservation Values), non use of CITES (Convention of International Trade in Endangered Species) unless there is a valid approved CITES certificate and support of Sustainable Forest Management (SFM). Observation # 003 : Gold Rank shall define the process to go through GFS WTP website to

5 check the supplier validity in terms of supplying VLO sawn timbers in the purchasing procedure. Gold Rank shall use the recent Supplier Evaluation Risk Assessment (WTP 15a VLO Risk Assessment v04 July 2012) developed by GFS for evaluating potential or existing logs/ sawn timber supplier s environmental status. Observation # 004 : Gold Rank shall use the new format of Product Declaration Form instead of the old format; Product Identification Statement, that was used for every sales of VLO sawn timbers from January to August Note : End of Summary Report

6 Doc #: WTP 006 Title: Checklist & Assessment Report Issue: 04 Date: 20 August 2012