Kimberly Clark Australia Ltd risk assessment of wood supply.

Transcription

1 Kimberly Clark Australia Ltd risk assessment of wood supply. Introduction Kimberly Clark Australia is Australasia s largest producer of specialty tissue products. Supply for their products comes from a variety of sources. Some are FSC certified and some are controlled wood source. Controlled wood comes from both imported and local fibre sources. Local supply is organized by ForestrySA from 3 sources: Forest management units under the direct management of ForestrySA. Including smaller volumes under contract to ForestrySA from a variety of smaller producers who come under the ForestrySA management planning process. Forestry management units under the control of Green Triangle Forest product (GTFP). Smaller volumes supplied by larger forest managers who have FSC, FSC CW or AFS certification. Kimberly Clark has conducted a risk assessment on supply from ForestrySA as part of their verification program for controlled wood sources under FSC-STD (V2-1) EN. Given that FSC Australia have published an FSC accredited national (Annex 2) risk assessment there is already a determination of risk for South Australia and Victoria at the annex 2 level for 4 controlled wood criteria. Therefore the risk assessment is confined to an Annex 3 assessment focused on High Conservations values (HCV) only. A separate risk assessment has been completed for Green Triangle Forest products, whom operate the largest forest management system contracted by ForestrySA for supply to Kimberly Clark Australia. Contents 1. Details of the annex 3 risk assessment audit for ForestrySA. 2. Details of the annex 3 risk assessment audit for Green Triangle Forest Products (GTFP). 3. Details of the annex 3 risk assessment audit for Gunn s. 4. Associated Kiln Drier (AKD) covered by FSC controlled wood certificate SW-CW Procedures for verifying the supplier s procedures at the annex 3 level. 6. Summary Districts and sample plans.

2 Controlled Wood code: Pending Date of SmartWood approval: Pending Date of Risk Assessment: 5 th March & 14 th May 2010 Address of SmartWood: 65 Millet Street, Suite 201, Richmond Vermont USA P.O. Box 156, Millicent, SA, 5280, Australia Certificate holder address: Districts, including FMUs covered with this risk assessment: Supplier Address Description IBRA Eco-region District 1 IBRA Eco-region District 2 Volume (m 3 ) FMU's FMU's ForestrySA Jubilee Highway East, Mt. Gambier, SA Radiata Pinus Naracoorte Coastal Plain Mt. Gambier Flinders Lofty Block Adelaide Hills {Jan Newport: mbl } Mt. Burr Mt. Crawford Hills Mt. Crawford Depot, Warren Rd, Williamstown Mt. Gambier Kuitpo Category FSC Indictor Information Source Used Brief Justification Risk Designation 1. Illegally Harvested Wood. The district of origin may be considered low risk in relation to illegal harvesting when all the flowing indicators related to forest governance are present: 1.1 Evidence of enforcement of logging related laws in the district. Royal Institute of International Affairs ( Environmental Investigations Agency ( Global Witness ( Transparency International ( CITES ( World Bank Governance and Anti Corruption Data ( Code of practice for timber plantations in Western Australia. All Australian jurisdictions have in place strong legislative, regulatory and practice (generally in the form of Forest Practices Codes) instruments which are used both to guide and enforce the application of legal requirements for forest operations and timber harvesting (for public and private forests and plantations). Code violations are relatively rare and not normally on a scale envisaged to encompass illegal logging. However, serious, knowing or continuing breaches of the code can constitute contravention of the law.

3 1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits. 1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin. 1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade. All forest codes of practice are audited by the relevant state or territory All forest codes of practice are audited by the relevant state or territory According to Transparency International CPI for this country is 8,6 (CPI is higher or equal to 5) There is no UN Security Council export ban in the country. According to Global Witness there is currently export ban on Liberia. The country is not associated with or designated as source of conflict timber according to latest available research. No evidence of child labor or violation of ILO fundamental principles on a remarkable scale is known to occur. 2. Wood harvested in violation of traditional or civil rights. The district of original may be considered low risk in relation to the violation of traditional, civil and collective rights when 2.1 There is no UN Security Council ban on timber exports from the country concerned; Global Witness ( USAID: Conflict Timber: Dimensions of the problem in Asia and Africa Vol 1 available at: pubs/vol1synth.pdf No evidence that current legislation and related practices are not recognised or equitable

4 all the following indicators are present: 2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber) 2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned. Same as above International convention on the rights of the Child (www2.ohchr.org/english/law/crc.htm) There is no evidence of violation of the ILO convention taking place in forest areas of district concerned The Supplying company system demonstrates control of HCV. The Supplying company system demonstrates control of HCV. 2.4 There are recognized and equitable processes in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned. ( covers issues relating to the local indigenous peoples in the project area. Native title tribunal ( According to last FAO report (State of World's Forests 2007) forest area annual net loss is -0,1% (=< 0,5% per year). Evidence exists that conversion of native forest is still taking place in NT (eg Tiwi Islands) and areas of Tasmania (with existing licenses still valid after new legislation stopping conversion on public land only was introduced in 2006). According to the latest available FAO study ("Preliminary review of biotechnology in forestry, including genetic modification", (available at )) there is no commercial usage of any GM trees in the country. In Australia, GMO's are regulated by the Gene Technology Act which is administered by the Office of the Gene Technology Regulator (OGTR). Current search (March 09) for licenses shows no licenses given for tree species.

5 Licenses are required under the Gene Technology Act, which is regulated by the Office of the Gene Technology Regulator (OGTR). Current search (March 09) for licenses shows no licenses given for tree species Wood harvested from forest in which high conservation values are threatened by management activities. The district of origin may be considered low risk in relation to threat to high conservation values if: 1) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by noncompliance with There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned. 3.1 Forest management activities in the relevant level (ecoregion, sub-ecoregion, local) do not threaten ecoregionally significant high conservation values. 3.2 Strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCV's in the eco-region. As above Conservation International Biodiversity Hotspots ( efault/aspx). IBRA bioregions ( ience/bioregionframework/ibra/index.html). Framework for Assessing High Conservation Values in Controlled Wood Risk Assessments in Australia ( HCV%20doc.pdf). World Bank "rule of law" index ( Currently illegal to use genetically modified tress for commercial purposes There are HCV at every Bioregion in Australia so this indicator cannot be satisfied. All Australian jurisdictions have in place strong legislative, regulatory and practice (generally in the form of Forest Practices Codes) instruments which are used both to guide and enforce the application of legal requirements for forest operations and timber harvesting (for public and private forests and plantations). Code violations are relatively rare and not normally on a scale envisaged to encompass illegal logging. However, serious, knowing or Unspecified

6 continuing breaches of the code can constitute contravention of the law. Examination of the HCV control system at ForestrySA shows: HCV 1. Existing management plans for all values are in place for all areas containing native forests. Most of these areas are also gazetted by the state Government giving them protected status. Assessment of habitats for or occurrence of rare or endangered species or ecosystem is done by specialists using survey work and existing sources e.g. regional plans or publically available overlays. Prescriptions for management of rare an endangered species or ecosystems are set by specialist planners using available information and research. All information is recorded on GIS maps and layers used in all forestry operations. All Plans are publicly consulted and are available on the ForestrySA Web site. Verified by sighting plans and maps and confirming practices during field audit. HCV 2. No large natural landscape level forests exist in the forestry estates managed under this supply arrangement.

7 Confirmed by reference to estate level maps. HCV 3. The is no state level Code of Practice covering aspects of HCV 3 such as erosion, backside protection and water quality. However the industry Guidelines for Plantations Forestry in South Australia (PIRSA Forestry 2009) government guidelines are consulted and all of these aspects are covered in operational plans. (These guidelines are not legally binding.) Verified by sighting guidelines, operational plans and confirming practices during field audit. For catchment management in the Mount Lofty Ranges, ForestrySA s Environmental Performance Agreement with the South Australian Environment Protection Authority (EPA), refers ForestrySA estate located in the Mount Lofty Ranges Water Protection Area (MLRWPA), regulating and monitoring herbicide use for the establishment of plantations and the following 2 years. An MOU with SA Water establishes a framework that enables ForestrySA to have ongoing access to nominated areas within the SA water estate for the commercial plantations. This covers aspects of forest management that could impact on the water catchment. Verified by sighting agreements and management plans reflecting the agreement and by confirming

8 practices in field audits. The balance of supply is from areas of ground water catchments managed according to state level Natural Resources Management plans. Verified by sighting plans and maps and confirming practices during field audit. Verified by sighting the agreements. HCV 4. There are no known issues. There is an operating stakeholder database used for stakeholder engagement. HCV 5. There are no known aboriginal issues or cultural heritage sites known in the estate. There are some post colonial sites recognized under the Heritage places Act There are state guidelines for both Aboriginal and post colonial cultural heritage. These are reflected in the Forest management plant. Confirmed by sighting the forest management plans. Small suppliers under the ForestrySA contract come under the management planning of ForestrySA. Those that do not have their own separate risk assessment. Verification of such suppliers is confirmed by audits

9 of suppliers according to the FSC sampling plan. 4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses. The district of origin may be considered low risk in relation to conversion of forest to plantations or nonforest uses when the flowing indicator is present: 5. Wood from forests in which genetically modified trees are planted. The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with: 4.1 There is no net loss AND no significant rate of loss (>0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question. a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned. b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use. c) It is forbidden to use genetically modified trees commercially in the country concerned. Department of Agriculture Commonwealth of Australia Gene Regulator. Forest and Agriculture Organization. Department of Agriculture ( According to last FAO report (State of World's Forests 2007) forest area annual net loss is -0,1% (=< 0,5% per year). Evidence exists that conversion of native forest is still taking place in NT (eg Tiwi Islands) and areas of Tasmania (with existing licenses still valid after new legislation stopping conversion on public land only was introduced in 2006). In June 2001 the Gene Technology Act 2000 was introduced as a national scheme to regulate genetically modified organisms in Australia to protect the Australian environment. In Australia Genetically modified Eucalypts cannot be grown. Standard breeding techniques and natural hybridization are used to gain improvement in tree genetics. Controlled Wood code: Pending Date of SmartWood approval: Pending Date of Risk Assessment: 5 th March & 16 th April 2010 Address of SmartWood: 65 Millet Street, Suite 201, Richmond Vermont USA Certificate holder address: P.O. Box 156, Millicent, SA, 5280, Australia Districts, including FMUs covered with this risk assessment:

10 Supplier Address Description IBRA Eco-region District 1 IBRA Eco-region District 2 FMU's FMU's GTFP Lot 11, Monterey Drive, Mt. Gambier, SA Radiata Pinus Naracoorte Coastal Plain SA Naracoorte Coastal Plain Victoria {Mark Ellis: mbl } Caroline Dartmoor Tarpeena Kentbruck Cafprico Kongorong Category FSC Indictor Information Source Used Brief Justification Risk Designation 1. Illegally Harvested Wood. The district of origin may be considered low risk in relation to illegal harvesting when all the flowing indicators related to forest governance are present: 1.1 Evidence of enforcement of logging related laws in the district. Royal Institute of International Affairs ( Environmental Investigations Agency ( Global Witness ( Transparency International ( CITES ( World Bank Governance and Anti Corruption Data ( Code of practice for timber plantations in Western Australia. All Australian jurisdictions have in place strong legislative, regulatory and practice (generally in the form of Forest Practices Codes) instruments which are used both to guide and enforce the application of legal requirements for forest operations and timber harvesting (for public and private forests and plantations). Code violations are relatively rare and not normally on a scale envisaged to encompass illegal logging. However, serious, knowing or continuing breaches of the code can constitute contravention of the law. 1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits. 1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin. All forest codes of practice are audited by the relevant state or territory All forest codes of practice are audited by the relevant state or territory

11 1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade. According to Transparency International CPI for this country is 8,6 (CPI is higher or equal to 5) There is no UN Security Council export ban in the country. According to Global Witness there is currently export ban on Liberia. The country is not associated with or designated as source of conflict timber according to latest available research. No evidence of child labor or violation of ILO fundamental principles on a remarkable scale is known to occur. 2. Wood harvested in violation of traditional or civil rights. The district of original may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present: 2.1 There is no UN Security Council ban on timber exports from the country concerned; 2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber) 2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned. Global Witness ( USAID: Conflict Timber: Dimensions of the problem in Asia and Africa Vol 1 available at: ubs/vol1synth.pdf Same as above International convention on the rights of the Child (www2.ohchr.org/english/law/crc.htm) No evidence that current legislation and related practices are not recognised or equitable There is no evidence of violation of the ILO convention taking place in forest areas of district concerned The Supplying company system demonstrates control of HCV. The Supplying company system demonstrates control of HCV.

12 2.4 There are recognized and equitable processes in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned. ( covers issues relating to the local indigenous peoples in the project area. Native title tribunal ( According to last FAO report (State of World's Forests 2007) forest area annual net loss is -0,1% (=< 0,5% per year). Evidence exists that conversion of native forest is still taking place in NT (eg Tiwi Islands) and areas of Tasmania (with existing licenses still valid after new legislation stopping conversion on public land only was introduced in 2006). According to the latest available FAO study ("Preliminary review of biotechnology in forestry, including genetic modification", (available at )) there is no commercial usage of any GM trees in the country. In Australia, GMO's are regulated by the Gene Technology Act which is administered by the Office of the Gene Technology Regulator (OGTR). Current search (March 09) for licenses shows no licenses given for tree species. Licenses are required under the Gene Technology Act, which is regulated by the Office of the Gene Technology Regulator (OGTR). Current search (March 09) for licenses shows no licenses given for tree species There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned. As above Currently illegal to use genetically modified tress for commercial purposes

13 3. Wood harvested from forest in which high conservation values are threatened by management activities. The district of origin may be considered low risk in relation to threat to high conservation values if: 1) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by noncompliance with Forest management activities in the relevant level (eco-region, subeco-region, local) do not threaten eco-regionally significant high conservation values. 3.2 Strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCV's in the ecoregion. Conservation International Biodiversity Hotspots ( ault/aspx). IBRA bioregions ( nce/bioregionframework/ibra/index.html). Framework for Assessing High Conservation Values in Controlled Wood Risk Assessments in Australia ( CV%20doc.pdf). World Bank "rule of law" index ( There are HCV at every Bioregion in Australia so this indicator cannot be satisfied. All Australian jurisdictions have in place strong legislative, regulatory and practice (generally in the form of Forest Practices Codes) instruments which are used both to guide and enforce the application of legal requirements for forest operations and timber harvesting (for public and private forests and plantations). Code violations are relatively rare and not normally on a scale envisaged to encompass illegal logging. However, serious, knowing or continuing breaches of the code can constitute contravention of the law. Unspecified Examination of the HCV control system at GTFP shows: HCV 1. Existing management plans Before each harvest of GTFP forest compartments, an assessment is conducted using the GTPF SBDV Feature Management Guide and the Quick SBDV Reference Page. The results are recorded on the Assessment Recording sheet. This sheet is checked

14 by the harvesting contractor prior to harvesting, triggered by the Work plan. {SBDV = Significant Biological Diversity Values.) {Potential endangered species are identified through the DEH overlays (SA and the DSE maps (Victoria).} Verified by sighting plans and maps and confirming practices during field audit. HCV 2. No large natural landscape level forests exist in the forestry estates managed under this supply arrangement. Confirmed by reference to estate level maps. HCV 3. There are no state level Code of Practice covering aspects of HCV 3 such as erosion, backside protection and water quality. However the Code of Practice for Timber Production 2007, Department of Sustainability and Environment, Victoria, is a key document which GTFP use to manage the areas mentioned in the report. The Guidelines for Plantation Forestry in SA 2009 is also used. There are many legislative requirements that are relevant to HCV3 which GTFP must comply with for example; EPA acts SA & Vic, NRM Act SA and Catchment and Land Protection Act Vic. The operational plans consist of a Work Plan Checklist and a Harvesting Work Plan.

15 Implementation of each risk control is signed off in the field. Surface water is identified by GIS maps and aerial photos. Water quality is governed by the Planning Authority (Glenelg Shire), the Victorian Code of Practice and Guidelines to Plantation Forestry in SA. Also there is a procedure for winter and summer logging to avoid erosion of wet soil and vehicles getting bogged. Verified by sighting plans and maps and confirming practices during field audit. HCV 4. There are no known issues. There is an operating Stakeholder Register spreadsheet with discussions recorded. There is also a Neighbour s Register with communications of harvesting activities. HCV 5. Aboriginal heritage sites are listed with locations on 2 spreadsheets (SA & Victoria). These sites are drawn on the compartment maps attached to the Harvesting Work Plan. Confirmed by sighting the forest harvesting plans and the management spreadsheets.

16 4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses. The district of origin may be considered low risk in relation to conversion of forest to plantations or nonforest uses when the flowing indicator is present: 5. Wood from forests in which genetically modified trees are planted. The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with: 4.1 There is no net loss AND no significant rate of loss (>0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question. a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned. b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use. c) It is forbidden to use genetically modified trees commercially in the country concerned. Department of Agriculture Commonwealth of Australia Gene Regulator. Forest and Agriculture Organization. Department of Agriculture ( According to last FAO report (State of World's Forests 2007) forest area annual net loss is -0,1% (=< 0,5% per year). Evidence exists that conversion of native forest is still taking place in NT (eg Tiwi Islands) and areas of Tasmania (with existing licenses still valid after new legislation stopping conversion on public land only was introduced in 2006). In June 2001 the Gene Technology Act 2000 was introduced as a national scheme to regulate genetically modified organisms in Australia to protect the Australian environment. In Australia Genetically modified Eucalypts cannot be grown. Standard breeding techniques and natural hybridization are used to gain improvement in tree genetics.

17 Controlled Wood code: Pending Date of SmartWood approval: Pending Date of Risk Assessment: 23 rd April 2010 Address of SmartWood: 65 Millet Street, Suite 201, Richmond Vermont USA P.O. Box 156, Millicent, SA, 5280, Australia Certificate holder address: Districts, including FMUs covered with this risk assessment: Supplier Address Description IBRA Eco-region Gunn's Bay Road, Mount Gambier, SA 5290 Radiata Pinus Naracoorte Coastal Plain Category FSC Indictor Information Source Used Brief Justification Risk Designation 1. Illegally Harvested Wood. The district of origin may be considered low risk in relation to illegal harvesting when all the flowing indicators related to forest governance are present: 1.1 Evidence of enforcement of logging related laws in the district. 1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and Royal Institute of International Affairs ( Environmental Investigations Agency ( Global Witness ( Transparency International ( CITES ( World Bank Governance and Anti Corruption Data ( Code of practice for timber plantations in Western Australia. All Australian jurisdictions have in place strong legislative, regulatory and practice (generally in the form of Forest Practices Codes) instruments which are used both to guide and enforce the application of legal requirements for forest operations and timber harvesting (for public and private forests and plantations). Code violations are relatively rare and not normally on a scale envisaged to encompass illegal logging. However, serious, knowing or continuing breaches of the code can constitute contravention of the law. All forest codes of practice are audited by the relevant state or territory

18 harvest permits. 1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin. 1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade. All forest codes of practice are audited by the relevant state or territory According to Transparency International CPI for this country is 8,6 (CPI is higher or equal to 5) There is no UN Security Council export ban in the country. According to Global Witness there is currently export ban on Liberia. The country is not associated with or designated as source of conflict timber according to latest available research. No evidence of child labor or violation of ILO fundamental principles on a remarkable scale is known to occur. 2. Wood harvested in violation of traditional or civil rights. The district of original may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following indicators are present: 2.1 There is no UN Security Council ban on timber exports from the country concerned; 2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber) Global Witness ( USAID: Conflict Timber: Dimensions of the problem in Asia and Africa Vol 1 available at: s/vol1synth.pdf Same as above No evidence that current legislation and related practices are not recognised or equitable There is no evidence of violation of the ILO convention taking place in forest areas of district concerned

19 2.3 There is no evidence of child labour or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned. International convention on the rights of the Child (www2.ohchr.org/english/law/crc.htm) The Supplying company system demonstrates control of HCV. The Supplying company system demonstrates control of HCV. 2.4 There are recognized and equitable processes in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned. ( covers issues relating to the local indigenous peoples in the project area. Native title tribunal ( According to last FAO report (State of World's Forests 2007) forest area annual net loss is - 0,1% (=< 0,5% per year). Evidence exists that conversion of native forest is still taking place in NT (eg Tiwi Islands) and areas of Tasmania (with existing licenses still valid after new legislation stopping conversion on public land only was introduced in 2006). According to the latest available FAO study ("Preliminary review of biotechnology in forestry, including genetic modification", (available at htm)) there is no commercial usage of any GM trees in the country. In Australia, GMO's are regulated by the Gene Technology Act which is administered by the Office of the Gene Technology Regulator (OGTR). Current search (March 09) for licenses shows no licenses given for tree species. Licenses are required under the Gene Technology Act, which is regulated by the Office of the Gene Technology Regulator (OGTR). Current search (March 09) for licenses shows no licenses given for tree species.

20 3. Wood harvested from forest in which high conservation values are threatened by management activities. The district of origin may be considered low risk in relation to threat to high conservation values if: 1) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by noncompliance with There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned. 3.1 Forest management activities in the relevant level (eco-region, sub-ecoregion, local) do not threaten eco-regionally significant high conservation values. 3.2 Strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCV's in the eco-region. As above Conservation International Biodiversity Hotspots ( ult/aspx). IBRA bioregions ( ce/bioregion-framework/ibra/index.html). Framework for Assessing High Conservation Values in Controlled Wood Risk Assessments in Australia ( V%20doc.pdf). World Bank "rule of law" index ( Currently illegal to use genetically modified tress for commercial purposes There are HCV at every Bioregion in Australia so this indicator cannot be satisfied. All Australian jurisdictions have in place strong legislative, regulatory and practice (generally in the form of Forest Practices Codes) instruments which are used both to guide and enforce the application of legal requirements for forest operations and timber harvesting (for public and private forests and plantations). Code violations are relatively rare and not normally on a scale envisaged to encompass illegal logging. However, serious, knowing or continuing breaches of the code can constitute contravention of the law. Unspecified Examination of the HCV control system at Gunn s shows:

21 HCV 1. Existing management plans Prior to any harvest in Gunn s plantations, a Forest Operations Plan (FOP) is completed. This FOP includes a section relating to company requirements in high conservation areas. These conservation areas are assessed for habitat and/or sensitivity based on a visual inspection by a forester or experienced harvesting supervisor and are annotated on the FOP map. All assessments are classified using the Code of Practice for Timber Production 2007 or the Guidelines for Plantation Forestry in South Australia As part of the FOP a checklist is also completed with a section dedicated to environmental care. The harvesting contractor and supervisor both sign off on the FOP before the operation can begin. Verified by sighting plans and maps and confirming practices during field audit. HCV 2. No large natural landscape level forests exist in the forestry estates managed under this supply arrangement. Confirmed by reference to estate level maps.

22 HCV 3. Aspects of HCV 3 such as erosion, backslide protection and water quality are all covered in the Code of Practice for Timber Production 2007 and the Guidelines for Plantation Forestry in South Australia These documents are strictly adhered to and are a major part of the FOP. The protection of such aspects is defined by buffer zones and operational restrictions which are dependant on the classification of each watercourse/wetland/land capability class, all which are evident on the FOP map. The classification is done by visual inspection. Verified by sighting plans and maps and confirming practices during field audit. HCV 4. There are no known issues. There is an operating Stakeholder Register spreadsheet with several discussions recorded. HCV 5. There are no registered aboriginal or post colonial in the Green Triangle area. (A post colonial cottage was identified, but has not as yet been put on the state register. Confirmed by sighting the forest harvesting plans and the management spreadsheets.

23 4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses. The district of origin may be considered low risk in relation to conversion of forest to plantations or nonforest uses when the flowing indicator is present: 5. Wood from forests in which genetically modified trees are planted. The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with: 4.1 There is no net loss AND no significant rate of loss (>0.5% per year) of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question. a) There is no commercial use of genetically modified trees of the species concerned taking place in the country or district concerned. b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use. c) It is forbidden to use genetically modified trees commercially in the country concerned. Department of Agriculture Commonwealth of Australia Gene Regulator. Forest and Agriculture Organization. Department of Agriculture ( According to last FAO report (State of World's Forests 2007) forest area annual net loss is - 0,1% (=< 0,5% per year). Evidence exists that conversion of native forest is still taking place in NT (eg Tiwi Islands) and areas of Tasmania (with existing licenses still valid after new legislation stopping conversion on public land only was introduced in 2006). In June 2001 the Gene Technology Act 2000 was introduced as a national scheme to regulate genetically modified organisms in Australia to protect the Australian environment. In Australia Genetically modified Eucalypts can not be grown. Standard breeding techniques and natural hybridization are used to gain improvement in tree genetics.

24 Associated Kiln Drier (AKD) covered by FSC controlled wood certificate SW-CW Supplier Address Description IBRA Eco-region Ass. Kiln Driers 7-15 Forest street, Colac, Vic 250 Radiata Pinus Victorian Volcanic Plain The logs harvested by AKD, sourced by ForestrySA are covered by the FSC controlled wood certificate SW-CW A copy of the AKD risk assessment for their log supply to KCA is kept on file. Procedure for verifying the supplier s documentation at the Annex 3 level. Extract from company procedures RFMMQA Controlled Wood Verification Program audits the wood suppliers ForestrySA & GTFP (plus minor suppliers through ForestrySA) annually. a. The CoC Policy states for this Controlled Wood program; The company shall avoid sources dealing with: i. Illegally harvested wood; ii. Wood harvested in violation of traditional and civil rights; iii. Wood harvested in forests where high conservation values are threatened by management activities; iv. Wood harvested in forests being converted to plantations or non-forest use; v. Wood from forests in which genetically modified trees are planted. b. The FSC Australia {Annex 2} Risk Assessment was first referenced to verify that the regions audited are a low risk area (except for HCV s). AUS.pdf c. This Controlled Wood Risk Assessment provided guidance to both companies and certification bodies seeking to identify risks in accordance with the FSC Standard for Company Evaluation of FSC Controlled Wood (FSC-STD (Version 2-1). It identified low risk for all controlled wood categories except HCV which was undetermined at all IBRA bioregions in Australia. Therefore KCA completed an annex 3 risk assessment on HCV for all its suppliers using the draft guidelines from FSC Australia as the benchmark.

25 d. This resulted in the risk assessments, published on the FSC AUS web site: Field verifications inspects the HCV classes at each forest coup to confirm that supplier is following the HCV provisions in their harvest plans, which is used to verify this risk assessment. Evidence is gathered from these harvesting plans for: i. HCV 1: Provisions to not disturb endangered species habits or destroy endangered flora ii. HCV 2: Steep slopes are not applicable to Australia iii. HCV 3: Provisions to avoid water contamination and/ or soil erosion iv. HCV 4: Communicated to local communities (if applicable) v. HCV 5: Indigenous and post colonial sites are protected. e. Documented publically available operational plans were consulted; for ForestrySA (on their website ForestrySA), and the GTFP hardcopies (which are kept in the field audit records). Through inspecting these documents on site, these suppliers method of managing the HCVs are assessed. f. Upholding High Conservation Values (HCV) in harvesting practices. The annual audit sample in number of forest coups are: i. ForestrySA (2 Districts, 6 Forests) = 2 coups ii. GTFP (2 District, 6 Forests) = 2 coups iii. Minor Suppliers (3 Forests) = 2 coups. [Stated in table below] g. Sample frequency = 0.8 x #FMUs. Districts and Sampling Plans For ForestrySA there are two districts based on geographical locations under the same management system. These are the Mount Gambier area and the Adelaide Hills. The Adelaide Hills has 3 supplying forests and the Mount Gambier district has 3 supplying forests. This makes the sampling plan 2 forests in the Adelaide Hills and 2 in the Mount Gambier area. Each forest has a management plan. Green Triangle Forest Products has 6 forest units in 2 distinct districts, one in Victoria (4 forests) and one in South Australia (2 forests). The sampling rate is therefore 2 in Victoria and 2 in South Australia.

26 For both ForestrySA and Green Triangle Forest Products the required random sample selection can be achieved by selecting from the database of supplying source numbers for each forest unit collated by ForestrySA. About 5-10% of supply comes from other growers contracted by ForestrySA. Not all will supply wood in any one season and some of these are spot sales. These should be treated as one district with the sampling rate based on 0.8 times the square root of the number of units that have supplied Kimberly Clark in the preceding 12 months. Controlled Material Suppliers {Controlled wood verification program} Supplier Address Description IBRA Eco-region District 1 IBRA Eco-region District 2 Volume (m 3 ) FMU's FMU's ForestrySA Jubilee Highway East, Mt. Gambier, SA Radiata Pinus Naracoorte Coastal Plain Mt. Gambier Flinders Lofty Block Adelaide Hills {Jan Newport: mbl } 67,474 Mt. Burr Mt. Crawford Hills Mt. Crawford Depot, Warren Rd, Williamstown m 3 Mt. Gambier Kuitpo {Garry Pierson: mbl } Penola Second Valley GTFP Lot 11, Monterey Drive, Mt. Gambier, SA Radiata Pinus Naracoorte Coastal Plain SA Naracoorte Coastal Plain Victoria {Mark Ellis: mbl } 16,287 Caroline Dartmoor m 3 Tarpeena Kentbruck Cafprico Kongorong Minor Suppliers FSA contact: Nigel Tonk in: ph Radiata Pinus Contact Phone Gunn's Bay Road, Mount Gambier, SA Naracoorte Coastal Plain Neil Turner Ass. Kiln Driers 7-15 Forest Str, Colac, Vic 250 SW-CW ,815 Victorian Volcanic Plain Martin Hayden