Chain of Custody Checklist & Assessment Report

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1 Chain of Custody Checklist & Assessment Report Organization Contact Person Office Address Mill Address Telephone Fax Komill Corporation ( H) Manufacturer: Bidasari ( K) Alfred Yong (Bidasari COC MR) Hussain Manap (Komill COC MR) 40-3, Jalan 28/70A, Desa Sri Hartamas, Kuala Lumpur, Malaysia. Lot NT Kg. Lanas, Kimanis, P.O. Box 601, Papar, Sabah, Malaysia (Kota Kinabalu) (Kuala Lumpur) (Kota Kinabalu) (Kuala Lumpur) Reference # GFSS a Proposal # Assessment # GFSS P Assessment Date 04 Apr 2017 Date of Report Date of close out Lead Assessor 04 Apr Wong Bin Heang Assessor - Approved By Dr. Kevin Grace Statement of Participation GFS WTP # GFS 035a WTP Issuance Date 17 April 2017 Expiration Date 16 April 2022 Scope of Assessment Company Type Scope of Assessment Product Group Source of Material Species Limitations of Assessment Sawmill and moulding and Trading Komill Corporation and Bidasari Solid wood Products (sawn timber, mouldings for truck body flooring, indoors flooring, desking, chair, door, window components, internal architectural components (skirting & architraves), furniture components, etc. Verified Legal: Sabah, Malaysia. Acacia spp. (Acacia) and Mixed Hardwood species. 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: Komill Corporation (Komill) is registered in Kuala Lumpur, Malaysia with registration # H. Komill has intended to obtain GFS WTP to trade Verified Legal (VL) timber products. Associated Organizations & Subcontractors: Komill is associated to Bidasari (Bidasari), a manufacturing plant located at Kimanis, Sabah and is registered in Kuala Lumpur, Malaysia with registration # K. Bidasari has obtained FSC COC certification in March 2013 with the certificate #: BV-COC to sell FSC certified timbers and valid through 10 th March Bidasari has voluntarily suspended their GFS WTP (GFS 031a WTP) and has signed an agreement to sell VL timber products only to Komill that trades finished wood products. In September 2016, Bidasari sawmill and moulding license has been upgraded to Utilizing Plantation Logs Cum Moulding Mill to operate sawmill for plantation logs. Description of the Supply Chain: From April 2016 to March 2017, Bidasari (Komill) purchased / received raw materials from suppliers as below: Supplier License Raw Material Location Audit Statement # NWP Industries JP(PT) 001/05(M) Sawn timber Papar GFS 092 WTP Usaha Sensasi JP(K)RN002/12(B01)R Sawn timber Ranau GFS 068 WTP Tropical Wood Plantation JP(K)KK001/14(M01) Sawn timber Kota Kinabalu GFS 135 WTP Goodworld Industries Sdn. JP(N)SO 001/12(B01) Sawn timber Sook GFS 098 WTP Cymasun Trading Sdn. JP(K)KK 001/14(M01) Sawn timber Kota Kinabalu GFS 091 WTP Pengkalan Bakat Sdn. JP(N)SO 002/13 Sawn timber Sook GFS 097 WTP Sri Jomatsu JP(N)NN 014/07 (B01) Sawn timber Nabawan GFS 166 WTP (MK Dimaju ) Samisun Timber Sdn. JP(N) SO 001/14 Sawn timber Sook GFS 137 WTP (B01) Inspiration Furniture Sdn. JP(PT)004/15 Sawn timber Kota Kinabalu GFS 198 WTP Syarikat Pensiangan Jaya JP(N)SO001/14 (X62) Sawn timber Sook GFS 127 WTP Seratim DBKK Sawn timber Kota Kinabalu GFS 022 WTP Sentorama JP(N)SO 007/06 (B01) Sawn timber Sook GFS 107 WTP AG Mahmud PG Daud & 1 Peserta JPHTN/PP700-3/3/3/Klt.8(11) Acacia logs plantation Papar -

3 DG Rosnani AG Othman JPHTN/PP700- Acacia logs Papar - 3/3/3/Jld.14/9 plantation Salbia B. Sulaiman & 1 JPHTN/PP700- Acacia logs Papar - Peserta 3/3/3/Jld.14/96 plantation Vamco Timber Company X Sawn timber Merapok - The Wise Three DBKK Sawn timber Kota Kinabalu - Common species used include Acacia spp. (Acacia) and Mixed Hardwood species. The finished goods are currently sold for Europe (United Kingdom, Germany, Holland & Belgium), Japan and Australia. Highlights of Assessment 1.0 Legal Requirements Komill and Bidasari maintain permits for all their trading and export activities. There was no evidence of non-compliance to legal requirements. At Bidasari mill, mitigation measures have been taken to rectify issues raised by DOSH during periodically inspection. Bidasari has an active license to hire 10 foreign workers (10 Indonesians), license #: JTK.H.BFT.600-4/1/20100/1484 with the expiry date on 18 th July Local workers are insured under SOCSO, whereas foreign workers are insured under Foreign Workers Compensation Scheme by Lonpac Insurance. SOCSO contributions for Komill and Bidsari are submitted on time. 2.0 Documented Policy & Procedures Komill has a signed environmental policy dated 21 st November 2012, that referenced to compliance of legal requirement, support the traceability of forest products through the verification of supply, non use of GMO (Genetic Modified Organism) timbers, elimination of forest products considered to be controversial or from converted forest that may have HCV (High Conservation Value) area and non use of CITES (Centre of International Trade of Endanger Species). Komill has a documented chain of custody procedure that clearly defines the process of purchasing and selling VL timber products. The procedure also includes administration process reference to refreshment training, and maintaining key records for at least 5 years. A Corrective Action Request (CAR) form (BSB- ADM-007) is developed for addressing gaps issued by external auditors. Bidasari has a formal signed policy dated 10 th October 2012, which spells the company, shall comply with legal requirements and support environmental protection (CITIES), purchase responsibly of legal source raw material & products and also support Sustainable Forest Management. Bidasari has formal procedures for Purchasing, Receiving & Storage of rough sawn timber, Production Control, and Sales & Administration. An agreement was signed between NWP Industries and Bidasari detailing that NWP Industries as the new subcontractor of Bidasari that agrees to sell, handle and deliver VL logs of Bidasari in line with the GFS WTP Chain of Custody Standard (WTP 005) as an outlined in the Chain of Custody Procedures furnished by Bidasari. In September 2016, sawmill and moulding license has been upgraded to Utilizing Plantation Logs Cum Moulding Mill to operate sawmill for plantation logs.

4 3.0 Organisation & Training Mr. Hussain Manap was appointed as the COC MR for Komill and Mr. Alfred Yong remains as the COC MR for Bidasari. Both companies have the organization chart that reference of the key person name for each role and department. Key staffs understood their responsibilities in maintaining the chain of custody. Bidasari conducted internal training, briefing and discussions on VL system with management key personnel and ground staff. Record of attendance is documented and maintained. The records on Safety and Health trainings were documented and maintained. 4.0 Purchasing, Importing & Receiving Sawn timber purchased from Sabah TLAS approved suppliers are associated with Removal Passes, Timber Disposal Permits and forestry documents that were audited by GFS and issued an Audit Statement in accordance to the Sabah TLAS standard, thus could be considered low risk. Risk assessment (GFS WTP 015) was conducted for Binar Bestari (AG Mahmud PG Daud & 1 Peserta, DG Rosnani AG Othman, and Salbia B. Sulaiman & 1 Peserta). Product sold under the GFS WTP to buyers are processed only from raw material sawn timber from NWP Industries Sdn. Bhd (GFS 092 WTP) and acacia plantation logs from Sinar Bistari (AG Mahmud PG Daud & 1 Peserta, DG Rosnani AG Othman, and Salbia B. Sulaiman & 1 Peserta) that were evaluated as low risk. 5.0 Process Controls Not applicable for Komill as it is a trading company. Bidasari uses Internal contract # and Stacking List Running # (SLRN) as a control for production. An Internal contract will be issued to produce a defined unit of finished goods, based on buyer s specification. Raw material is issued into IC according to a series of Stacking List Running # (SLRN), with specific sizes and volume. WIP raw materials sampled during field assessment are able to trace back to its production and its origin based on batch # (SLRN). Observation 001: Bidasari still using the term Verified Legal origin (VLO) that need to be updated to Verified Legal (VL). 6.0 Sales, Exports & Customs Komill COC procedure defines the use of sales documents for VL timber products. The sales invoice, packing list and product declaration form shall reference to environmental status and species for sales of VL timber products. Bidasari has a formal procedure for sales of VL timber products. The exports of finished goods are in compliance with export regulations and traceable to defined production units. 7.0 Records & Data Komill and Bidasari COC procedure specifies key documents for chain of custody system (purchasing, production, admin and sales) shall be kept for at least 5 years.

5 Summary results: (Major Gap* = 0; Minor Gap = 0) GAPs: Issued during current assessment GAP # Type Checklist # Description of GAP Status of Outstanding GAPs: GAP # Type Checklist Status Description of close out Major Gaps are considered as non-conformance Observations Obs # Checklist Description Bidasari is still using the term Verified Legal Origin (VLO) that needs to be updated to VL. Highlights of Close out visit (if applicable) Date: - Not applicable Recommendations Komill Corporation / Bidasari have demonstrated compliance to the Wood Tracking Program requirements (WTP-005 v09 Jan 2015) and is recommended to maintain the Statement of Participation. Observations identified in this assessment should be addressed by the next surveillance visit. Checklist The term Verified Legal Origin (VLO) needs to be updated in their system to Verified Legal (VL). The next surveillance visit is scheduled in April End of Summary Report