LegalSource TM Audit Report

Transcription

1 LegalSource TM Audit Report for SMARTT Timber Sales BV Annual audit Public summary Report date: 8 th January 2018 Certificate code: NC-LS/MO Issued date: 17 th December 2014 Organisation Contact Robert Jan de Waard Albert Joachimikade BG Goes Audit managed by NEPCon Sp. z o.o. ul. Emaus 7/11, Kraków, Poland Contact person: Debora van Boven-Flier Tel: dbf@nepcon.org NEPCon OU, Filosoofi 31, Tartu, Estonia,

2 LegalSource Audit Report Template: Document Code: Type of document: Scope: Status of document: LS-03 LegalSource Audit Report Template International Approved Version: V 2.0 Date: 25 th January 2017 Consultation period: Approval body: Contact person: Contact N/A NEPCon Christian Sloth, Forest Legality Programme Manager cs@nepcon.org 2

3 Contents A. INTRODUCTION... 4 B. SCOPE... 4 C. AUDIT FINDINGS

4 A. Introduction The purpose of this report is to document conformance with the requirements of the LegalSource standard by SMARTT Timber Sales BV hereafter referred to as Organisation. The report presents findings of LegalSource auditors, who have evaluated the Organisation s systems and performance against the applicable requirements. The sections below provide the audit conclusions and follow-up actions required by the Organisation. Dispute resolution: If stakeholders have concerns or comments about the LegalSource standard or the auditing body, they are encouraged to contact their closest NEPCon regional office. Formal concerns and complaints should be sent in writing. B. Scope The LegalSource audit, report and certificate covers the following scope: Report Type Report type: Public Summary Organisation Details Primary contact: Robert Jan de Waard Address: Albert Joachimikade BG Goes The Netherlands Tel/Web/ T +31 (0) F +31 (0) rjdw@smartt.nl Jurisdiction of primary legal entity: Primary Activity Description of Organisation: The Netherlands Broker/trader without physical handling Import and distribution of softwood, especially for Dutch and Belgian markets. Products are rough and planed softwoods, spruce and pine both for timber shops, the packaging -and timber industry. Imports are from Russia on a monthly basis and also from Norway. Organisation is both FSC and PEFC certified. Certificate Scope Certificate Type Single site certificate Group/ Multi-site certificate Standards Evaluated: LegalSource Standard (LS-02) v2 4

5 NEPCon Generic Chain of Custody Standard (NC-STD-01) NEPCon Generic Group & Multi-Site Standard (NC-STD-02) Product scope: Changes to certificate scope since last audit: Sawn wood Picea abies Pinus sylvestris Larix siberiensis Origin: Russia, Norway Change from version 1.0 to 2.0 Certificate Sites or Group members In place of below table, details are found in Exhibit [ENTER NUMBER OF EXHIBIT] Not applicable Evaluation Process Audit team: Debora van Boven-Flier Debora holds an MSc in Tropical Forestry from Wageningen University and Research Centre, the Netherlands. She has participated in various lead auditor courses for FSC, PEFC, LegalSource and SAN and she has been conducting audits since Tim Roelandts Tim Roelandts is auditor for NEPCon in the Netherlands and Belgium. Tim has a Master in international relations and is carrying out CoC audits since He passed FSC and LegalSource lead auditor courses since Description of Audit Process: Prior to the audit SMARTT Timber Sales B.V. (SMARTT) had submitted their Due Diligence system for sourcing of timber products, relevant legality documents and the audit reports of their suppliers. On-site audit was carried out on 10 th October 2017 ( ) and covered the following: 1. Opening meeting, audit program and scope 2. Introduction by SMARTT to the organization and their Due Diligence system 3. Evaluation of the documented procedures, including responsibilities, commitments made by the organization, procedures for internal monitoring and definition of product scope 4. Evaluation of the general procedures for access to information, risk assessments and risk mitigation procedures adopted by SMARTT 5. Evaluation of operational implementation of the DD system, including: a. Interview with staff involved in the operational implementation of the DD system 2011

6 b. Evaluation of a sample of supply chains and the implementation of the Due Diligence on the selected samples (access to information, risk assessment and risk mitigation) 6. Closing meeting: presentation of LegalSource audit conclusions and discussions and follow-up. A wide range of documentation and records were reviewed during the audit, including the following (NEPCon DDS documents are used): - Handboek Stelsel van Zorgvuldigheidseisen - Staff Instruction Sheet - Legality Declaration for Suppliers - Supplier Consent and Information Form - Responsible Purchasing Policy - Letter for request of information During the audit a sample of consignments (both boat and truck loads) were selected for which SMARTT presented how their Due Diligence system had been implemented. Actions taken by Organisation prior to report finalisation: Update of the manual to meet the new standard requirements. Notes for the next audit: 6

7 C. Audit Findings Audit Conclusion: Organisation approved: MAJOR non-conformance(s) issued Organisation not approved: Additional comments: Non-Conformances Non-conformance reports (NCRs) describe the non-conformances identified during audits. NCRs include defined timelines for the Organisation to demonstrate conformance. MAJOR nonconformances issued during assessments/reassessments shall be closed prior to issuance of the certificate. MAJOR non-conformances issued during annual audits shall be closed within the timeline specified in the NCR, or result in certificate suspension. Where applicable, all non-conformances against standard requirements are shown below: NCR number: 01/ NC grading: Major Minor Standard & Requirement: LegalSource standard (V2) Description of Non-conformance: Currently, there are no procedures present in the manual to discontinue relationships with suppliers in cases of major or continuous violations of the standard. Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. NCR conformance deadline: Client evidence: Evaluation of Evidence: NCR Status: By next audit, but not later than 12 months after report finalisation date Open Comments (optional): 2011

8 NCR number: 02/ NC grading: Major Minor Standard & Requirement: LegalSource standard (V2) Description of Non-conformance: Currently, there are no written procedures for non-conforming products in place yet, NCR 02/17 was issued. Each shipment is already thoroughly checked and sold prior to shipment, so in practice this it is easy to identify the relevant buyers and to inform them in case this event does take place. Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. NCR conformance deadline: Client evidence: Evaluation of Evidence: NCR Status: By next audit, but not later than 12 months after report finalisation date Open Comments (optional): 8

9 NCR number: 03/ NC grading: Major Minor Standard & Requirement: LegalSource standard (V2) Description of Non-conformance: Currently, The Organisation making a record of the evaluation of the certification system is not yet part of Organisation s procedures. Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. NCR conformance deadline: Client evidence: Evaluation of Evidence: NCR Status: By next audit, but not later than 12 months after report finalisation date Open Comments (optional): 2011

10 NCR number: 04/ NC grading: Major Minor Standard & Requirement: LegalSource standard (V2) Description of Non-conformance: Not placing products on the market in case of unknown origin or specified risk is not yet part of Organisation s procedures since this is a new requirement under LegalSource, but in practice this is has not happened so far. Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. NCR conformance deadline: Client evidence: Evaluation of Evidence: NCR Status: By next audit, but not later than 12 months after report finalisation date Open Comments (optional): 10

11 Observations Observations (Obs) are issued for the early stages of a problem which does not in and of itself constitute a non-conformance, but which the auditor considers may lead to a future nonconformance if not addressed by the Organisation or where general improvements may be made. Where applicable, all observations are shown below: None were issued. Closed Non-Conformances This section indicates where the Organisation has adequately addressed non-conformances issued during or since the last audit. Any non-conformances which cannot be closed remain open and appear in Section C (above). Failure to comply with a minor non-conformance results in the NCR being upgraded to major; the specified follow-up action is required by the Organisation or involuntary suspension will take place. NCR number: 01/ NC grading: Major Minor Standard & Requirement: LegalSource standard (V1) Description of Non-conformance: Section 4.3 it is stated that every year the DDS shall be revised. Existing suppliers have not changed in the audit period, new suppliers underwent the risk assessment. The existing risk assessment have not been monitored or revised, other than that certificate and scope are regularly checked on the website of FSC. Since there's one supplier who possibly might be delivering FSC CW, this requirement is relevant, even though all other deliveries are FSC Certified. Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. NCR conformance deadline: 12 months Client evidence: Evaluation of Evidence: Risk assessment has been revised and submitted to the auditor. Each supplier was sent a new declaration to sign and no big changes have taken place in the supply 2011

12 NCR Status: Comments (optional): chain. Risk assessments are still concluded as low, all material being FSC certified. Closed 12