Stakeholder Consultation

Transcription

1 KPMG Forest Certification Services Inc. Box 10426, 777 Dunsmuir Street Vancouver BC V7Y 1K3 Canada Telephone (604) Fax (604) To: Skookumchuk Pulp Inc. FSC CoC/CW Stakeholders May 29, 2017 Dear Stakeholder: Stakeholder Consultation KPMG Forest Certification Services Inc. (KPMG FCSI) to conduct an FSC Chain and Custody/Controlled Wood Re-certification Audit of Skookumchuk Pulp Inc. Purpose and scope of the audit KPMG Forest Certification Services Inc. (KPMG FCSI) will be conducting a re-certification audit of Skookumchuk Pulp Inc. against the requirements of the current Forest Stewardship Council (FSC) chain of custody (CoC) and controlled wood (CW) standards. A stakeholder consultation process is planned for the spring of 2017, with the main assessment scheduled to begin on July 5, 2017 and conclude on July 7, Skookumchuck Pulp holds a single-site FSC CoC/CW certificate for their Skookumchuck mill. The supply area for Skookumchuk Pulp covers those portions of the WWF ecoregions listed below that are located within Canada and the USA: North Central Rockies Forest Alberta-British Columbia Foothills Forest Alberta Mountain Forest A map of the WWF ecoregions can be found at: The audit will be based on the current FSC CoC (FSC-STD V3-0) and CW (FSC-STD V3-1) standards. This letter serves as an invitation to interested and affected stakeholders who wish to provide comments that are pertinent to Skookumchuck Pulp s FSC CoC/CW certification. The comments received will be considered by KPMG FCSI in reaching its conclusions regarding Skookumchuck Pulp s conformance with the applicable FSC CoC and CW standards.

2 Skookumchuk Pulp Inc. FSC CoC/CW Stakeholders May 29, 2017 Page 2 About FSC and the CoC and CW standards The FSC is an international non-profit organization founded in 1993 to support environmentally appropriate, socially beneficial, and economically viable management of the world's forests. It supports the development of national and regional standards to be used to evaluate whether a forest is being well-managed. It is an association of members consisting of a diverse group of representatives from environmental and social organizations, forest and product industries, Indigenous People's organizations, community forestry groups and certification bodies from around the world. Membership is open to all who are involved in forestry or forest products and share its aims and objectives. FSC, with its head office in the city of Bonn, Germany, is governed by an elected Board which consists of people from industry, environmental, social and labor groups, Indigenous People's representatives and others. FSC-STD V3-0 and FSC-STD V3-1 were recently released for use by FSC. Organizations holding certifications to the previous versions of these standards must be assessed against the current version by December 31, 2017 (in the case of FSC-STD V3-1) and March 31, 2018 (in the case of FSC-STD V3-1). Your role We would appreciate your comments on issues that are pertinent to Skookumchuck Pulp s FSC CoC/CW certification. Such comments may include, but are not necessarily limited to, concerns or observations regarding the Company s due diligence system (i.e., the system of measures and procedures developed by the organization to minimize the risk of sourcing material from unacceptable sources), one component of which is the company risk assessment. Comments received will be considered by KPMG FCSI in assessing Skookumchuck Pulp s performance against the requirements of the applicable FSC CoC and CW standards. A summary of stakeholder comments will also be included in the Skookumchuck Pulp FSC CoC/CW certification audit summary report. A questionnaire is provided with this letter for your comments on issues that are pertinent to Skookumchuck Pulp s FSC CoC/CW certification. However, additional materials and other methods of communication will also be accepted. Upon request, arrangements may also be made to allow stakeholders to meet with members of the audit team during the on-site portion of the audit.

3 Skookumchuk Pulp Inc. FSC CoC/CW Stakeholders May 29, 2017 Page 3 Access to information FSC requires that stakeholders be provided access to certain information as part of the consultation process, including: A description of the supply area and respective risk designation. This information is included within the body of this letter and the summary of the Skookumchuck Pulp Due Diligence System (DDS). A written summary of the Skookumchuck Pulp DDS. A copy of this document is available on KPMG FCSI s website at Copies of the applicable FSC CoC and CW standards. These can be obtained from FSC International at A copy of the current (2016 version) Skookumchuck Pulp company risk assessment. This can also be obtained from FSC International at The procedure for filing complaints. A copy of KPMG FCSI s dispute resolution procedures are available on KPMG FCSI s website. Contact information of the person or position responsible for addressing complaints. This can be obtained by visiting the KPMG FCSI website noted above. KPMG FCSI Contact information All comments and requests for additional information should be directed to Branden Beatty at: KPMG Forest Certification Services Inc. PO Box 10426, Pacific Centre Vancouver, B.C. V7Y 1K3 Fax: (604) Our commitments 1 The source of specific comments received will remain confidential unless the commenting party specifically indicates to the contrary. 2 We will respond to all stakeholders who provide comments and provide information on how their comments were taken into account. 3 A summary of stakeholder comments and how they were considered by KPMG FCSI will be included in the Skookumchuk Pulp FSC CoC/CW certification audit summary report.

4 Skookumchuk Pulp Inc. FSC CoC/CW Stakeholders May 29, 2017 Page 4 Yours very truly, Branden, MSc, R.P.Bio Senior Associate, KPMG Performance Registrar (204) Enclosures

5 FIBRE PROCUREMENT ASSSESSMENT PROCEDURE Site: Skookumchuck Pulp Inc. Location: Skookumchuck, BC DCS version: 3.0 Date of last revision: May 5, 2017 PURPOSE: Establish corporate requirements for use in all operations from which regional and site level procedures may be developed if necessary to: 1. Meet the requirements of FSC chain of custody, FSC Controlled Wood and FSC trademark use standards. 2. Meet the requirement of PEFC Due Diligence System for avoidance of raw material from controversial sources, PEFC Chain of custody. 3. Determine and keep records of country and district of origin of fibre supply. 4. Carry out and maintain risk assessment and verification programs of wood fibre supplies. SCOPE: Applies to all fibre purchases of round wood, lumber, pulp, and other purchased fibre (chips, sawdust, bark, etc.) delivered to Skookumchuck facilities where FSC chain of custody, FSC Controlled Wood and PEFC chain of custody certifications are in place. This procedure should be used in conjunction with the FSC Controlled Wood Documented Control System to meet the requirements of the FSC Controlled Wood standard and DCS for management of PEFC single-site certification for the requirements of the PEFC chain of custody standard. DEFINITIONS: FSC Origin Forest area where the trees for the wood or fibre were harvested. FSC District Generic geographical definition within a country, which has similar features and similar risk for controlled wood categories and from which wood is sourced. It can be a county, locality or watershed, and is normally a sub-set of an ecoregion. FSC Controlled Wood wood which is identified by a company for avoidance of the following categories: a. Wood harvested from forest areas where traditional or civil rights are violated; b. Wood harvested from non-fsc certified forest areas having high conservation values which are threatened; c. Wood harvested from forests in which genetically modified trees are planted; d. Wood is illegally harvested; e. Natural forests that have been converted to non-forest use or plantations (as defined by FSC). PEFC origin -Information associated with the raw material used in the product referring to the characteristics of the place the raw material comes from. There are three categories of origin: certified, neutral and other material.

6 PEFC Controversial sources Forest management activities which are: a) not complying with local, national or international legislation, in particular related to the following areas: forestry operations and harvesting, including conversion of forest to other use, management of areas with designated high environmental and cultural values, protected and endangered species, including requirements of CITES(Convention on International Trade in Endangered Species), health and labour issues relating to forest workers, indigenous peoples property, tenure and use rights, payment of taxes and royalties b) utilizing genetically modified organisms, c) converting forest to other vegetation type, including conversion of primary forests to forest plantations. RESPONSIBILITIES The Fibre Procurement Superintendent shall be the point of contact for all internal and external parties including FSC and PEFC accredited certification bodies, FSC International and PEFC Council with respect to the implementation of this procedure. The certification coordinator shall provide guidance and training on the implementation of this procedure to the personnel whose responsibilities are identified below. Fibre Procurement personnel and/or chain of custody coordinator are responsible to ensure that all fibre suppliers are evaluated, district of origin of fibre is identified, supplier declarations are obtained from external fibre suppliers and pertinent documentation as proof of district of origin is verified. Fibre procurement personnel and/or chain of custody coordinator are also responsible to ensure that all information received is transmitted the forest certification coordinator for risk assessment and that the central supplier list is updated with supplier information and transmitted to the central office certification coordinator. METHODOLOGY I. SUPPLIERS DOCUMENTATION REQUIREMENTS A current supplier list is maintained by the Fibre Procurement Superintendent and stored on the Skookumchuck intranet. The list will be updated each time a new supplier of material is put under contract. A. FSC CONTROLLED WOOD REQUIREMENTS See FSC Controlled Wood documented control system for details on the supplier list Each supplier of wood/fibre of one or more of the categories listed below shall be listed in the supplier list. The list includes name and address, description of wood, species and category of material supplied as well as reference to the relevant purchasing documentation. The facility s fibre procurement and/or chain of custody coordinator at each facility shall categorize all wood/fibre supply as follows:

7 1. FSC certified wood from FSC certified supplier: o All wood/fibre supplied as FSC certified by a FSC certified supplier shall be clearly identifiable as such; o All wood/fibre supplied as FSC certified shall be accompanied by the relevant documentation; o The transport documentation and invoices issued shall reference the supplier s FSC certificate number. o The facility s fibre procurement and/or chain of custody coordinator shall verify that the supplier holds a valid FSC certificate on 2. FSC Controlled Wood inputs from suppliers certified to deliver FSC Controlled Wood; o All wood/fibre supplied as FSC Controlled Wood by a FSC Controlled Wood certified supplier shall be clearly identifiable as such; o All wood/fibre supplied as FSC Controlled Wood shall be accompanied by the relevant documentation; o The transport documentation and invoices issued shall reference the supplier s FSC Controlled Wood code; o The fibre procurement and/or chain of custody coordinator shall verify on that the supplier holds a FSC chain of custody certificate with Controlled Wood included in the scope, or a valid FSC Controlled Wood certificate. 3. FSC Controlled Wood inputs from non FSC certified suppliers: o Determine and keep records of country and district of origin of wood/fibre supplied; o Ensure that the documentation demonstrating the district of origin of the wood supplied/fibre is maintained. These records should include legally required transport documents and proof of purchase from the forest management unit of origin. NOTE: A declaration from the supplier alone is not considered sufficient evidence under the current standard requirements. If a declaration is provided, it needs to be backed up by documentation which formally demonstrates the district of origin to the forest level. o The Fibre procurement and/or chain of custody coordinator, shall implement verification of transport and purchase documents on the basis of sampling, to confirm the country and district of origin of the wood/fibre that is received. 4. Uncontrolled wood inputs o Skookumchuck Pulp Inc. will not purchase any material deemed uncontrolled as the segregation of the chips is not feasible. B. PEFC REQUIREMENTS 1. Identification of origin at delivery level o The Fibre Procurement personnel shall obtain from the suppliers for each delivery of certified materials/products information necessary to identify their certified status. o For each delivery of material entering the PEFC chain of custody, the following information from the supplier is necessary to identify and verify the category of origin of the procured wood fibre. The facility s identification as the customer of the delivery, Supplier s identification, Product (s) identification, Quantity of delivery for each product covered by the documentation, Date of delivery / delivery period / accounting period, Formal claim on the material origin (including percentage of certified material) specifically for each certified product covered by the documentation, The identifier of the supplier s chain of custody or forest management certificate or other document confirming the supplier s certified status. o For each delivery, the facility fibre procurement and/or chain of custody coordinator shall classify the procured material as certified, neutral or other material following the claim specification for which the chain of custody was implemented. Note: Certified material is raw material whose origin is covered by the chain of custody claims. Neutral material is raw material whose origin is considered neutral in the calculation of the certification percentage. Other material is raw material other than certified and neutral material.

8 2. Identification at the supplier level o A copy of or an access to a copy of the forest management or chain of custody certificate or other document confirming the supplier s certified status, which proves that the criteria set for the supplier of the certified material have been met shall be required from all suppliers of certified material. o Scope and validity of supplier s certificate shall be evaluated. In addition to the receipt of a document identified from the suppliers, the fibre procurement and/or chain of custody coordinator should make use of publicly available registers of suppliers of certified material kept by the PEFC Council ( or other recognized organizations ( Note: PEFC recognized certificate is: i. a valid accredited forest management certificate issued by a PEFC notified certification body against the forest management scheme/standard which is endorsed by PEFC council; ii. a valid accredited chain of custody certificate issued by a PEFC notified certification body against the PEFC chain of custody standard together with PEFC recognised specification of the origin, or iii. a valid accredited chain of custody certificate issued by a PEFC notified certification body against a scheme specific chain of custody standard which is endorsed by the PEFC council. 3. Self-declaration of suppliers o A signed self-declaration that the supplied material does not originate from a controversial source is required from all suppliers of non certified material. The supplier s self-declaration shall include: i. a written statement that to the best of the supplier s knowledge the supplied material does not originate from a controversial source, ii. a written commitment to provide information on the geographical origin (country / region) of the supplied raw material which is necessary information for the risk assessment, iii. a written commitment that, in the case where the supplier s supplies are considered as high or significant risk, the supplier will provide us with necessary information to identify the forest management unit(s) of the raw material and the whole supply chain relating to the high/significant risk supply, iv. a written commitment, where the supplier s wood supply is considered as high or significant risk, the supplier will enable us to carry out a second party or a third party inspection of the supplier s operation as well as operations of the previous suppliers in their supply chain. o These requirements shall be covered in the contract documentation where there is a contract signed with the supplier. See Appendix 2 for a copy of the supplier declaration. II. RISK ASSESSMENT AND VERIFICATION PROGRAM A. FSC Controlled Wood requirements for non-fsc suppliers 1. Risk Assessments o Under the direction of the Regional Manager, BC Fiber, the forest certification coordinator shall undertake a Risk Assessment using the checklist criteria provided in this procedure (see Appendix 1). o Private lands within a district or municipality shall be treated as a management unit for assessment purposes. o For each FSC Controlled Wood category, a risk assessment should start at the broadest relevant scale. This will generally mean at the national or state level. If a credible low or negligible risk determination can be made at the national or state level there is no need to do another assessment at a lower (i.e. district) level. A lower level (e.g. district level) is only needed if no credible low or negligible risk designation at larger scale can be conducted. Comments shall be provided in the risk assessment to describe the designation of risk. o Where national or regional interpretation or guidance have been provided by FSC National Initiative, this interpretation shall prevail. o When there is a low or negligible risk designation (at whatever scale, whether district or national), there is no need to implement a verification program at the FMU level, unless there is sufficient evidence that a particular source fails to meet the requirements for FSC Controlled Wood.

9 2. Verification program o For areas where a designation of low or negligible risk cannot be confirmed, the certification coordinator in collaboration with the fibre procurement personnel shall either: i. Require the supplier to provide independent verification by an accredited certification body that the source meets requirements of FSC. ii. Implement a verification program that will provide evidence that wood/fibre coming from a particular supplier has been controlled for the categories outlined in FSC Controlled Wood standard. For each of the five categories that cannot be considered low or negligible risk, the responsible personnel will identify and provide the rationale for documents and other evidence needed to demonstrate that the wood complies with the requirements for FSC Controlled Wood for that specific category. These documents will be available for verification by the FSC accredited certification body. A regular (at least annual) verification audit process to confirm the authenticity of the specified documentation and other evidence will be implemented. The audit process shall include consultation with relevant stakeholders, staff interview and field visits at harvesting sites. The number of verification audits that are conducted shall be determined by sampling method. For each set of similar forest management units (i.e. same forest type (natural forest vs. plantation), geographical location (district), size of operation) a sample representing at least 0.8 times the square root of the number of units shall be selected for evaluation per annum. Sample for field verification shall be defined randomly. Documentation will be maintained on file at the site for a minimum of 5 years for inspection by FSC and audit personnel. 3. Availability of Information o The results of the risk assessment shall be publicly available upon request. A summary of the risk assessment is available on under Skookumchuck chain of custody certificate details/documents. 4. Complaints Mechanism o If a risk assessment is challenged, the Forest Certification Coordinator will review the nature of the complaint with the Regional Manager, BC Fiber within 10 business days of its receipt. Field verification (if necessary) shall occur within two months of receipt of the complaint. o The certifier and FSC national office shall be advised within 10 business days of the receipt of a complaint. o In the event of non-compliance with the FSC Controlled Wood standard, the site shall exclude the applicable supply as outlined in its Non-controlled Wood procedure and shall only include the applicable supply when compliance with the Controlled Wood standard can be demonstrated. A response to a complainant shall occur within 30 business days or as soon as possible following a field inspection.

10 B. PEFC Due Diligence System (DDS) for avoidance of raw material from controversial sources 1. Scope o A PEFC Due Diligence System is required to be implemented for all input forest based material of the wood/fibre covered under the company s chain of custody and for which a percentage based method is applied, with the exception of: Certified material/product delivered with PEFC recognized certificate; Recycled material; Material/product other than certified which are covered by the supplier s PEFC recognized chain of custody certificate; Material covered by the supplier s PEFC DDS certificate which was issued by PEFC accredited certification body. o The PEFC DDS will be implemented in three steps: Supplier s self-declarations (see above section for details); Risk assessment; Managing of high or significant risk supplies. 2. Risk assessment o Under the direction of the Regional Manager, BC Fiber, the forest certification coordinator shall undertake a Risk Assessment using the checklist criteria provided in this procedure (see appendix 1); o The risk assessment shall results in the classification of supplies into the low/negligible or high/significant risk category; o The risk assessment will be carried out bases on an evaluation of: The likelihood that activities defined under the term controversial sources occur in the country/region of supply (hereinafter referred to as the likelihood at country/region level) and; The likelihood that the supply chain has not been able to identify a potential controversial source of supply (hereinafter referred to as the likelihood at the supply chain level). o The risk shall be determined based on the combination of the likelihood at country/region level and the likelihood at the supply chain level in order to classify all supply as high/significant risk where both likelihoods are assessed as high/significant, o The likelihood at country / region level shall be classified as high/significant for all supplies where any of the following indicators apply: Actual corruption perception index (CPI) of the country presented by Transparency International (TI) is lower that 5.0; The country/region level is known as a country with low level of forest governance and law enforcement; Comments supported by reliable evidence from customers or other external parties are received relating to supplies with respect to controversial sources, which have not been disproved by the company s own investigation. o The likelihood at the supply chain level shall be classified as high/significant for all supplies where none of the indicators apply: Supplies declared as certified against a forest certification scheme (other than PEFC endorsed) supported by a forest management or chain of custody certificate issued by a third party certification body; Supplies verified by governmental or non-governmental verification or licensing mechanisms other than forest certification schemes focused on activities covered by the term controversial sources (e.g. EU FLEGT, Tropical Forest Trust, etc.); Supplies supported by verifiable documentation which clearly identifies all suppliers within the supply chain, forest management unit of the supply origin and provides sufficient evidence on compliance with legal requirements. Evidence on compliance with legal requirements can be statement from law enforcement authority on legal compliance or absence of non-compliance, harvest permit issued or forest management plan approved by the relevant law enforcement authority. 3. Management of high or significant risk supplies o A second or third party verification program for supplies classified as high/significant risk. The verification program will cover: i. Identification of the whole supply chain and forest management unit(s) of the supply s origin: information on the whole supply chain and forest management unit(s) of the supply s origin shall be required from all suppliers of high/significant risk supplies;

11 ii. iii. On-site inspections: Verification program will include on-site inspections of suppliers delivering high/significant risk supplies. The on-site inspection can be carried out as second or third party inspection; On-sit inspection may be substituted with documentation review where the documentation provides sufficient confidence in the material origin in non-controversial sources; A sample of high or significant risk supplies to be verified shall be determined. The size of the sample shall be at least the square root of the number of high or significant risk supplies, and the sample shall include all suppliers of the high or significant risk supply. The onsite inspection will cover: 1. the direct supplier and all previous suppliers in the supply chain in order to assess compliance with supplier claims on the origin of the raw material and; 2. the forest owner/manager of the FMU of the supply origin or any other party responsible for management activities on that forest management unit in order to assess their compliance with legal requirements. Corrective and preventive measures: Corrective measures will be implemented for non-compliance for suppliers identified in the verification program. Corrective measures will be based on the scale and seriousness of the non-compliance and should include: 1. communication of the non-compliance with a request for improvement; 2. requiring suppliers to define corrective measures relating to forest management unit s compliance with legal requirements or efficiency of the information flow in the supply chain; 3. Cancellation of use of the supplier s supplies. o The supply from the suppliers which have not provided a self-declaration or have not provided information on the supply chain will be cancelled. 4. No placement on the market o Timber or timber product(s) from unknown sources or from controversial sources shall not be included in product groups covered by the organisation s PEFC chain of custody. o Timber known or reasonably suspected as coming from illegal sources (controversial sources 3.9(a) or (b)) shall not be processed and, shall not be traded and/or shall not be placed on the market unless appropriate documented evidence has been provided and verified which allows the timber supplied to be classified as presenting "negligible risk. ASSOCIATED DOCUMENTATION: Skookumchuck Fibre Procurement Policy Skookumchuck FSC Controlled Wood documented control system REFERENCE: FSC-STD Standard for multi-site certification of chain of custody operations FSC-STD FSC chain of custody standard for companies supplying and manufacturing FSC-certified products. FSC-STD Standard for company evaluation of FSC Controlled Wood FSC-STD FSC Requirements for use of the FSC trademarks by certificate holders PEFC ST 2002:2010 Chain of custody of Forest Based Products Requirements.

12 Stakeholder Questionnaire 2017 Skookumchuk Pulp Inc. FSC Chain of Custody/Controlled Wood Re-certification Audit. To: Branden Beatty, KPMG FCSI Fax #: From: Organization (if applicable): Phone #: KPMG Forest Certification Services Inc. (KPMG FCSI) will be conducting a re-certification audit of Skookumchuk Pulp Inc. against the requirements of the current Forest Stewardship Council (FSC) chain of custody (CoC) and controlled wood (CW) standards. A stakeholder consultation process is planned for the spring of 2017, with the main assessment scheduled to begin on July 5, 2017 and conclude on July 7, This questionnaire is intended to obtain information from interested and affected stakeholders regarding issues that are pertinent to Skookumchuk Pulp s FSC CoC/CW certification. Such comments may include, but are not necessarily limited to, concerns or observation s regarding the Company s due diligence system (i.e., the system of measures and procedures developed by the organization to minimize the risk of sourcing material from unacceptable sources), one component of which is the company risk assessment (which FSC has decided may continue to be used until an approved national risk assessment for Canada is in place). Comments received will be considered by KPMG FCSI in assessing Skookumchuk Pulp s performance against the requirements of the applicable FSC CoC and CW standards. A summary of stakeholder comments will also be included in the Skookumchuk Pulp s FSC certification report. However, the identity of individuals/organizations providing comments will be kept confidential by KPMG FCSI unless the party providing comments specifically indicates in writing to the contrary. NB: In order to be considered during the 2017 audit, comments must be received no later than July 6, Do you have any specific concerns regarding Skookumchuk Pulp s due diligence system (DDS), company risk assessment or other issues that are pertinent to the Company s FSC CoC/CW certification? Comments: YES/NO/ NA

13 Stakeholder Questionnaire 2017 Skookumchuk Pulp Inc. FSC CoC/CW Audit To: Branden Beatty, KPMG FCSI Fax #: From: Organization (if applicable): Phone #: 2. If you answered yes to question 1 above, have you communicated your concerns to 2017 Skookumchuk Pulp Inc? Comments: YES/NO/ NA 3. If you answered yes to question 2 above, in your opinion, has Skookumchuk Pulp made a reasonable attempt to address your specific concerns? Comments: YES/NO/ NA

14 Stakeholder Questionnaire 2017 Skookumchuk Pulp Inc. FSC CoC/CW Audit To: Branden Beatty, KPMG FCSI Fax #: From: Organization (if applicable): Phone #: 4. Do you have any other concerns regarding Skookumchuk Pulp FSC CoC/CW certification that have not been addressed in the above questions? Comments: YES/NO/ NA 5. Are there any specific issues or requirements of the FSC CoC or CW standard (FSC-STD V3-0 and FSC-STD V3-1) that you believe merit special attention during the 2017 Skookumchuk Pulp s FSC CoC/CW audit? Comments: YES/NO/ NA