Surveillance Audit: Audit Summary

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1 Bureau Veritas Certification North America, Inc. SFI Fiber Sourcing Audit Report 390 Benmar Drive, Suite 100 Houston, TX Phone (281) : Toll Free (800) Company Name Expera Specialty Solutions LLC Contact Person Bud Delano Address 600 Thilmany Road, Kaukauna, WI Phone / Fax / PQC Code E01E Contract Number Expera Specialty Solutions LLC Certification Audit: Re-Certification Audit: Surveillance Audit: 2 Scope extension audit: Audit Summary Introduction This report reflects the results of the initial audit for Expera Specialty Solutions, LLC, audited to evaluate the company certification to the SFI Fiber Sourcing standard. Julie Stangell, independent contract auditor acting on behalf of Bureau Veritas was the lead auditor and conducted all site visits. The opening meeting was held on August 22, 2016 and the closing meeting was conducted on August 24, Audit Scope, Objectives and Process The scope of the multi-site organization audit is Fiber Sourcing under an open market program for Expera s two primary producer mills located in Kaukauna and Mosinee, Wisconsin. The objective of the audit was to verify conformance to Section 3, SFI Fiber Sourcing Standard. Standard Bureau Veritas Certification protocols and forms were applied throughout the audit as provided by the most recent version of the Bureau Veritas Certification SFI Auditor Handbook. This audit was conducted in conjunction with annual audits for the SFI, FSC and PEFC chain of custody systems. At each site the auditor examined written procedures, interviewed key personnel, toured completed harvest operations and examined their filing and tracking control systems. Audit Plan An audit plan was developed for and forwarded to the client. A copy of the audit plan is on file with Bureau Veritas. Company Information Expera Specialty Solutions, LLC is a manufacturer of specialty paper products serving the packaging, pressure sensitive and industrial and technical markets. With over 125 years of paper making experience, Expera operates four facilities located in Wisconsin: Kaukauna, DePere, Mosinee and Rhinelander. Expera utilizes conifer and hardwood chips in manufacturing of various grades of paper products. Fiber is procured through gatewood and market pulp. The majority of the gatewood is purchased as roundwood and the remaining as residual chips. Fiber is sourced from within the US from the states of Wisconsin, Michigan and occasionally Minnesota and Illinois. -1- Bureau Veritas Certification SFI Fiber Sourcing Audit Report Jan 2015

2 Multi-Site Requirements Expera is a multi-site organization and has a central office or headquarters at which certain activities are planned, controlled or managed. The Kaukauna, WI central office provides the pulp mill facilities with information and guidance on fiber sourcing activities. The scope and scale of activities are similar at all four sites. Each facility operates under a common fiber sourcing system and policies & procedures that are managed and administered by the central office. The central office was audited remotely. Multi-Site X Group Certification Sites Kaukauna, WI (Central Office) Kaukauna, WI Mosinee, WI Rhinelander, WI De Pere, WI Sites Audited During this Event X X Secondary producer, not being certified to FS Standard Secondary producer, not being certified to FS Standard Audit Results The Expera chain of custody procedures were found to be effective and all employees had been trained. Expera has a written Sustainable Forestry Policy that guides its implementation and conformance to the SFI Fiber Sourcing Standard. An accounting system is in place to track all deliveries of raw material as it enters the mills. All raw materials are sourced from within the United States. Three field sites were visited during the audit, selected from 26 sites where fiber was sourced from non-certified locations. Visits to additional sites were attempted however permission from the landowner was withheld. The three sites were previously monitored by Expera procurement foresters utilizing their supplier audit form. Expera has an effective system with procedures covering all requirements of the SFI Fiber Sourcing Standard. Objective 1-Biodiversity in Fiber Sourcing: Expera has an active education and outreach program focused on providing information on biological diversity enhancement, conservation practices, certification opportunities and sustainable forest management techniques to their wood suppliers. Informational packets and s are sent to their round wood and chip suppliers. They also support multiple organizations including the Wisconsin SIC that support and promote research related to biodiversity of the forest. No FECVs have been identified in their sourcing area. Objective 2-Adherence to Best Management Practices: Expera has developed a supplier Contract Provisions and Declaration that all raw material suppliers must sign and follow. The contract includes the language that the supplier must ensure that, all product supplied to Expera is obtained from legal sources in accordance with relevant federal, state and local regulations and in compliance with applicable voluntary and mandatory best management practices. In addition, Expera procurement foresters monitor BMPs through site visits that are documented on BMP Monitoring Reports. The BMP Monitoring Reports are rolled up into a spreadsheet that summarizes results. Results of monitoring are periodically reviewed for trends and if there are repeated issues, wood may not be purchased from a supplier who has repeated infractions. Objective 3-Use of Qualified Resource and Qualified Logging Professionals: Use of qualified logging professionals is required in the Wood Purchase and Service Agreement that all suppliers must sign. Each seller must sign Exhibit A acknowledging they will use trained loggers. The majority of Expera s wood suppliers participate in FISTA, Forest Industry Safety & Training Alliance logger training or other SFI equivalent training. Additionally, Expera promotes the SFI SIC supported and -2- Bureau Veritas Certification SFI Fiber Sourcing Audit Report Jan 2015

3 American Logger Council approved Master Logger Certification (MLC) programs in Wisconsin and Michigan. Expera strives to encourage a preference to loggers that are certified under the Wisconsin or Michigan MLC programs ensuring sustainable forest management techniques are applied during the harvest of raw material. Objective 4-Legal and Regulatory Compliance: Expera s Sustainability Policy specifies a commitment to achieving compliance with all applicable laws and regulations as well as a commitment to scientifically, environmentally, socially and economically sustainable practices. The sustainability policy is available on their website and is included as an exhibit in the Wood Purchase Services Agreement that every supplier signs. In addition, a business card called SOAR with their web site address may be delivered in person, by mail and at community events. Their website has links to applicable laws, regulations and other links that promote sustainable forestry practices. Objective 5-Forestry Research, Science and Technology: Expera provides financial and in-kind support to research programs related to forest health, productivity and management of forest resources. They include support of Forest Resources Association, National Council for Air & Stream Improvement, Wisconsin SIC, Trees for Tomorrow including membership on their Board of Directors, Wood Supply Research Institute and the Wisconsin Paper Council. Objective 6-Training and Education: Expera s wood suppliers participate in FISTA, logger training or other SFI equivalent training. Additionally, Expera promotes the SFI SIC-supported American Logger Council approved Master Logger Certification programs in Wisconsin and Michigan. Expera Staff are trained on their roles in the SFI program and professional foresters take ongoing professional training courses to maintain their professional forester credentials. Objective 7-Community Involvement and Landowner Outreach: Expera supports the Wisconsin SIC committee and is active on the SIC Grants committee. They also have an active community education and outreach program that is focused on providing up-to-date information on sustainable forest management, biological diversity enhancement, conservation practices and certification opportunities. They have a Community Involvement and Landowner Outreach page on their website that includes links to informational brochures, handouts, websites, legal requirements and other resources. They have developed a business card called SOAR with their web site address that is delivered in person, by mail and at community events. Expera s leadership and management is very active in multiple industry and community organizations. Objective 8-Public Land Management Responsibilities: NA, Expera does not have public land management responsibilities. Objective 9-Communications and Public Reporting: The 2015 BV Audit Report was posted on the SFI website. All records necessary for reporting to SFI are maintained electronically and were reviewed as part of this audit. The annual SFI Progress Report was submitted for Objective 10-Management Review: Expera has a well established management review program in place where all managers review the COC and Fiber Sourcing programs and assign action items where adjustments to the system are required. The most current management review was conducted on August 17, Objective All fiber is sourced from the US from Wisconsin, Michigan and occasionally Minnesota and Illinois. Objectives are Not Applicable. -3- Bureau Veritas Certification SFI Fiber Sourcing Audit Report Jan 2015

4 Findings Previous non-conformances: There were no previous nonconformities as this was the initial audit. Non-conformances: No nonconformities were identified. Opportunities for Improvement: No opportunities for improvement were identified. Notable Practices: Per 4.1.1, access to relevant laws and regulations is made available by providing a business card called SOAR that has the link for the Expera website that includes links to all relevant laws and regulations and other websites with sustainable forest management information includint the Wisconsin SIC landowner brochure. These cards are made available in person, by mail and at public events. This was considered a best practice. Logo/label use: Expera uses the SFI logo for promotional use on its website and all use was approved and in conformance with use requirements as verified during the Chain of Custody audit. Expera does not use the Bureau Veritas Certification logo. SFI reporting: This is the initial audit therefore there is not an SFI Fiber Sourcing report posted. Conclusions In the opinion of the auditor and based on the evidence presented, the results of this initial audit conclude that Expera Specialty Solutions, LLC has procedures in place that meet all requirements of the SFI Fiber Sourcing standard. Immediate certification is recommended. SEE SF61 FOR AUDIT NOTES -4- Bureau Veritas Certification SFI Fiber Sourcing Audit Report Jan 2015

5 Summary of Audit Findings: Audit Date(s): From: August 22, 2016 To: August 24, 2016 Number of SF02 s Raised: Major: 0 Minor: 0 Is a follow up visit required: Yes No X Date(s) of follow up visit: Follow-up visit remarks: Team Leader Recommendation: Corrective Action Plan(s) Accepted Yes No N/A X Date: Proceed to/continue Certification Yes X No N/A Date: 8/24/16 All NCR s Closed Yes No N/A X Date: Standard audit conducted against: 1) SFI FS STD 3) 2) 4) Team Leader (1): Team Members (2,3,4 ) Julie Stangell 2) 3) 4) 5) Scope of Supply: (scope statement must be verified and appear in the space below) Fiber Sourcing under an open market program Accreditation's ANAB Number of Certificates 1 Proposed Date for Next Audit Event Date July/ August 2017 Audit Report Distribution Bud Delano : bud.delano@experaspecialty.com Dawn Komnick: dawn.komnick@us.bureauveritas.com -5- Bureau Veritas Certification SFI Fiber Sourcing Audit Report Jan 2015

6 Clause Opening Meeting Closing Meeting Participants: Discussions: Participants: Discussions: Audit Report Bud Delano, Mike Rawlsky, Jeff Berdorn, Don Peterson Introductions Scope of the audit Audit schedule/plan Nonconformance types Major / Minor Review of previous nonconformances - 0. Process approach to auditing and audit sampling Confidentiality agreement Termination of the audit Appeals process Closing meeting timing Bud Delano, Mike Rawlsky, Jim Brown, Bob Puent, Ann Funk, Mark Bosin, Rob Meyer, Addie Teeters, Prisca Johnsen, Tanya Clark, Jeff Verdorn, Don Peterson, Heather Waligursky Introductions and appreciation for selecting Bureau Veritas Certification. Review of audit process - process approach and sampling. Review of OFIs and System Strengths Nonconformances - 0 Date for next audit. Reporting protocol and timing -6- Bureau Veritas Certification SFI Fiber Sourcing Audit Report Jan 2015

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