Chain of Custody Certification at a Glance

Chain of Custody Certification at a Glance So you re interested in Chain of Custody Certification? Congratulations on taking this first step. If you choose to become CoC certified, you will be helping your customers satisfy their goals for environmentally responsible purchasing by demonstrating your ability to protect the supply chain. You will be helping yourself by protecting existing business and pursuing new business that is environmentally sensitive. This document will answer many of the questions CoC applicants have at the onset of certification. It provides: A timeline for certification The Sustainable Forestry Initiative standard (abridged) The Forest Stewardship Council standard (abridged) Associated Costs

Timeline for Certification PRE-AUDIT 1) Review this document and acquaint yourself with the certification standards. Many printers find that they have established procedures in place that satisfy many of the requirements of both standards. Portions of the standards that pertain to printer certification are contained in this document. To download the standards in their entirety, go to: http://www.aboutsfi.org/coc.cfm http://www.fsc.org/en/about/documents/docs_cent/2,37 2) Complete and Return The Business Reply Card To expedite the certification process, please complete the Business Reply Card contained in the Chain of Custody information folder on the document titled Are You a Link in The Chain of Custody? In the alternative, print page 3 of this document and fax to: Michael Lyon, Bureau Veritas Certification, 716-664-7588. Upon receipt, a representative from Bureau Veritas Certification will contact you. 3) Telephone conference with Bureau Veritas Certification (BVC). When you are ready to proceed with the certification process, you will need to provide BVC with the information they need to schedule your audit and prepare a cost estimate. During the telephone conference, they will review information they need and provide you with a Request for Quote (RFQ). Once this is completed and returned to BVC, your audit can be scheduled. From the time the RFQ is submitted to the date of the audits varies greatly. Some companies are ready to proceed immediately. Others need time to establish procedures and train employees. BVC can typically schedule audits within four weeks of the initial request. In addition, pre-audits, via phone or in person, are available and serve as a dry run before the audit is scheduled. AUDIT 4) Audits. Typically, on-site audits of printing companies take 1/2-1 full day per location, depending upon the size of the facility, volume of business, and number of employees. POST-AUDIT 5) Report Generation. Following the on-site audits, BVC will generate their report, notifying the applicant of any incidents of non-compliance. Once the applicant has satisfied BVC they have corrected the issues and are in compliance, BVC will submit their report and recommendation for certification to SFI and FSC. 6) Review and Issuance of Certificates. Upon receipt of BVC s report, SFI will complete their review and issue Chain of Custody certificates within 2-4 weeks. FSC will complete their review and issue Chain of Custody certificates within 4-6 weeks. 7) Label Use Agreements. Once certified, CoC-certified printers will recieve logo and brand packages directly from SFI and FSC. Additionally, SFI will request printers to sign a Label Use Agreement. For more information about this agreement, contact SFI at 703-875-9500. 8) Notification and Publication. Upon issuance of certificates, BVC will notify SFI and FSC to update their published lists of certified printers. These lists are posted at their websites, www.aboutsfi.org and www.fscus.org.

Are you a link in the Chain of Custody? Chain of Custody ensures that our actions are as good as our intentions. It is the natural response to an evolving corporate culture, one that is as concerned with the social and environmental consequences of its decisions as it is with the economic outcomes. CORPORATE SOCIAL RESPONSIBILITY Frequently, these good intentions are captured in Corporate Social Responsibility (CSR) statements which demonstrate that a company considers society s best interest to be integral to policymaking. Companies with CSR statements perceive a competitive advantage in them, and seek out suppliers who embrace their vision and can help them achieve their stated goals. It is not uncommon for CSR statements to specify use of environmentally certifi ed papers. As such, paper merchants, brokers, printers and publishers whose customers specify certifi ed paper, or whose customers wish to place a certifi cation program s label on the end product, should consider third-party certifi cation for chain of custody Because chain of custody traces wood fi ber from the forests of origin to the end user, if an entity along that path is not third-party certifi ed, the specifi er cannot make the claim and use the identifying logo. PRINTER CERTIFICATION Together with its third party auditor, Bureau Veritas Certifi cation, we have created a streamlined process for printers seeking dual chain-ofcustody status from the Sustainable Forestry Initiative (SFI) and Forest Stewardship Council (FSC). * Bureau Veritas Certifi cation was established in 1987 and is considered a global leader in the independent third-party certifi cation industry. We selected Bureau Veritas Certifi cation because it is the only registrar that can simultaneously certify to both standards, reducing costs by increasing effi ciencies in the audit process. We were the first paper merchant to be nationally certified to both standards. PRINTER REQUIREMENTS To become chain-of-custody certifi ed, a printer must meet the requirements of the standards which include: 1) accurate identification of certified products on inbound and outbound shipments 2) the ability to segregate certified from non-certified inventory 3) efficient communication of its certification number to specifiers 4) documentation of procedures and training of employees. Printers must submit an application, complete an initial on-site audit, and complete an annual audit to maintain certifi cation. YOUR PREFERRED CoC MERCHANT As a chain-of-custody certifi ed merchant, we simplify the transaction. Shipping and receiving documents clearly identify certifi ed grades, and value-added services, like just-in-time delivery, minimize certifi ed inventory on the fl oor. In an ever-evolving industry, where jobs are awarded based on the environmental certifi cations held, ensure your ability to compete. Certify with a third-party registrar. Then specify with us. *We merely facilitate certification as a service to customers, and receive no remuneration. YES! I want to learn more about the Printer Certification program. Please have a representative from Bureau Veritas Certifi cation contact me to explain the requirements of the program. Please inform me of newly certifi ed products and other environmental initiatives. Name: Company: Address: City: Zip: Phone: Email: State: Complete this card and return via fax to Michael Lyon, Bureau Veritas Certification, 716-664-7588.

Certification Standards Abridged versions of the SFI and FSC standards are contained on the following pages. Only sections relevant to printer Chain of Custody certification have been included and are highlighted for ease of reference. For complete copies of the standards, go to: http://www.aboutsfi.org/coc.cfm http://www.fsc.org/en/about/documents/docs_cent/2,37 (Select FSC-STD-40-004 V1-0 EN FSC Chain of custody standard for companies supplying and manufacturing FSC-certified products)

Associated Costs - Estimated AUDIT EXPENSES BVC will provide a comprehensive estimate prior to scheduling the on-site audit. However, expenses are broken down as follows: SFI/FSC dual on-site audit: BVC estimates 1-1-1/2 days on-site per location at a rate of $1,250 per day. SFI/FSC dual off-site audit report: BVC estimates 1 day for audit preparation and report writing at $1,250 per day. Travel and related expenses: The cost of transportation and lodging is impacted by the distance traveled as well as the lead time prior to the travel date.

ANNEX 2 SFI CHAIN OF CUSTODY STANDARD This document replicates many elements from the Program for the Endorsement of Forest Certification schemes (PEFC) Chain of Custody of Forest Based Products Requirements, Normative Document, Annex 4, dated June 17, 2005.

3.4.1 Average percentage method The organization applying average percentage method shall use the certification percentage for all the products covered by the production batch for which the calculation has been carried out. Note 1: No minimum threshold is set to use the average percentage method. Note 2: If the certification percentage for the production batch is e.g. 54 % then all products covered by this production batch can be sold as certified products including 54 % of certified raw material. 3.4.2 Volume credit method 3.4.2.1 The organization applying volume credit method shall transfer the certification percentage into the volume credit in the single measurement unit of the output products of the production batch. The volume credit shall be distributed to the output products in a way that the certified products will be considered as including 100 % of certified raw material for any purchaser recognizing volume credit calculation. Note: If the certification percentage for the production batch consisting of 100 tonnes of output products is e.g. 54 % then 54 tonnes of the output products can be sold as certified products including 100 % of certified raw material. 3.4.2.2 The organization, which is not able to define (i) a single measurement unit for all output products of the production batch or (ii) which included in the production batch products with different ratios between input raw material volume and output product volume, shall transfer the certification percentage into volume credit separately for the products with different measurement unit or the input/output ratio. 3.4.2.3 The organization can cumulate the volume credit by creating a credit account, which can be used for the next production batches. The credit account shall be established respecting chapter 3.4.2.2. 3.4.2.4 The total quantity of credits cumulated at the credit account cannot exceed the sum of credits entered into the credit account during the last twelve months. 3.5 Sale of products 3.5.1 When the organization sells or transfers the certified products, the organization shall provide customers requesting this information with a document verifying the compliance with the chain of custody requirements. 3.5.2 The organization shall ensure that documentation for each delivery of the certified products clearly states at least the following information: (a) organization s identification, (b) quantity of delivery, (c) date of delivery / delivery period / accounting period (d) category of the origin (including actual percentage, as calculated under 3.4.1 or 3.4.2 of certified raw material included in the certified product) 3.5.3 If the organization uses the logo, both on-product and off-product usage shall be carried out according to the terms and conditions of the contract for the logo usage entered into by the user and the SFI Office of Label Use and Licensing. 30

3.6 Controversial sources 3.6.1 The organization shall establish adequate measures to ensure that the certified products do not include raw material from controversial sources. 3.6.2 The organization shall require from all suppliers of the forest based raw material, which is not classified as certified raw material, at least a signed self-declaration that the supplied raw material does not originate from a controversial source. The organization, which has signed contracts with its suppliers, shall include such a declaration in the contracts. 3.6.3 The organization shall evaluate the potential risk of procuring raw material from controversial sources and establish a sampling based program of second or third party verification of the suppliers self-declarations if a high risk exists that raw material originates from controversial sources. Note: The potential risk evaluation carried out by the organization should be based on the regional / country level. 3.6.4 The organization procuring raw material originating from threatened and endangered species classified by CITES shall follow all the regulations defined by CITES and other international as well as national legislation. Section 4: Minimum management system requirements 4.1 General requirements The organization shall operate a management system in accordance with the following elements of this standard, which ensure correct implementation, and maintenance of the chain of custody process. The management system shall be appropriate to the type, range and volume of work performed. Note: An organization s quality (ISO 9001:2000) or environmental (ISO 14001:2004) management system can be used to meet the minimum requirements for the management system defined in this standard. 4.2 Responsibilities and authorities 4.2.1 Management responsibilities 4.2.1.1 The organization s top management shall define and document its commitment to implement and maintain the chain of custody requirements in accordance with this standard. The organization s commitment shall be made available to the organization s personnel, suppliers, customers, and other interested parties. 4.2.1.2 The organization s top management shall appoint a member of the management who, irrespective of other responsibilities, shall have overall responsibility and authority for the chain of custody. 4.2.1.3 The organization s top management of the organization shall carry out a regular periodic review of the organization s chain of custody and its compliance with the requirements of this standard. 4.2.2 Responsibilities and authorities for chain of custody The organization shall identify personnel performing work affecting the implementation and maintenance of chain of custody and establish and set responsibilities and authorities relating to chain of custody process: 31

(a) raw material procurement and identification of the origin, (b) product processing covering physical separation or percentage calculation and transfer into output products, (c) product sale and labeling, (d) record keeping, (e) internal audits and non-conformity control. Note: The responsibilities and authorities for the chain of custody given above can be cumulated. 4.3 Documented procedures The organization s procedures for the chain of custody shall be documented. The chain of custody documentation shall include at least the following elements: (a) description of the raw material flow within the production process, (b) organization structure, responsibilities and authorities relating to chain of custody, (c) procedures for chain of custody process covering all requirements of this standard. 4.4 Record keeping 4.4.1 The organization shall establish and maintain records to provide evidence of conformity with the requirements and its effectiveness and efficiency. The organization shall keep at least the following records: (a) records of all suppliers of forest based raw material including information which confirms that the requirements at the supplier level are met, (b) records of all purchased forest based raw material including information on its origin, (c) records of all forest based products sold and their claimed origin, (d) records of internal audits, non-conformities which occurred and corrective actions taken. 4.4.2 The organization shall maintain the records for a minimum period of five years unless stated otherwise by law or the organization s policies. 4.5 Resource management 4.5.1 Human resources / personnel The organization shall ensure that all personnel performing work affecting the implementation and maintenance of the chain of custody shall be competent on the basis of appropriate training, education, skills and experience. 4.5.2 Technical facilities The organization shall identify, provide and maintain the infrastructure and technical facilities needed for effective implementation and maintenance of the organization s chain of custody with the requirements of this standard. 4.6 Inspection and control 4.6.1 The organization shall conduct internal audits at intervals of at least one year covering all requirements of this standard and establish corrective and preventive measures if required. 4.6.2 The report from the internal audit shall be reviewed by the organization s top management at least annually. 32

FOREST STEWARDSHIP COUNCIL INTERNATIONAL CENTER FSC STANDARD FSC CHAIN OF CUSTODY STANDARD FOR COMPANIES SUPPLYING AND MANUFACTURING FSC-CERTIFIED PRODUCTS FSC-STD-40-004 (Version 1-0) EN 2004 Forest Stewardship Council A.C. All rights reserved Charles-de-Gaulle-Str. 5 53113 Bonn, Germany Tel : +49-228 - 367 66 28 Fax : +49-228 - 367 66 30 policy.standards@fsc.org www.fsc.org

2004 Forest Stewardship Council A.C. All rights reserved. Part 1: Quality system requirements 1. Responsibilities 1.1. The company shall appoint one person (or position) as having overall responsibility for the company s compliance with all aspects of this standard. 1.2. All key personnel (employees and contractors) shall know and understand their specific responsibilities in order to implement all the requirements of this standard. 2. Scope of chain of custody system 2.1. The company shall maintain an FSC product group schedule of all product groups included in the company s FSC chain of custody control system. Examples of FSC product groups: 1. a line of pine fencing 2. a line of glue laminated lumber 3. a line of western red cedar window frames 4. a line of multiple layer flooring 5. a line of orientated strand board (OSB) 6. a range of paper items made with mixed conifer pulp 7. a single paper item or quality 8. a line of spruce sawn timber 2.2. Products within the product group may be manufactured from a mixture of species, however a single product group may not contain distinct product lines which differ in terms of their species composition, quality and/or value. For example, a product group may consist of a line of garden chairs each of which is manufactured using wood from a mixture of species. However, a product group could not consist of a line of garden chairs manufactured from one species, and a second line of garden chairs manufactured from a different species - these would have to be classed as two separate FSC product groups. 2.3. The product group schedule shall be kept up-to-date and shall be available upon request. 2.4. For each product group the company shall specify whether the product group is: a) FSC-pure b) FSC-mixed FSC-STD-40-004 V1-0 EN FSC CHAIN OF CUSTODY STANDARD FOR COMPANIES SUPPLYING AND MANUFACTURING FSC- CERTIFIED PRODUCTS 7 of 28

2004 Forest Stewardship Council A.C. All rights reserved. c) FSC-recycled 2.5. The company s FSC chain of custody control system (policies, systems, procedures, work instructions, etc.) shall be sufficient to ensure that all products specified on the company s FSC product group schedule meet all of the requirements of this standard at all times. 3. Documented procedures 3.1. The company shall have written procedures and/or work instructions to ensure implementation of all the elements specified in this standard. 3.2. The procedures/work instructions shall include identification of the person (or position) responsible for implementing each procedure and/or work instruction. 4. Records and reports 4.1. The company shall maintain accurate, complete, up-to-date and accessible records and reports covering all aspects of this standard. 4.2. Retention times for all records and reports shall be specified by the company and shall be at least five (5) years. 5. Training 5.1. The company shall specify the training requirements for all staff as required to implement this standard. 5.2. Training shall be provided to all staff as specified. 5.3. The company shall keep records of the training provided to staff in relation to implementation of this standard. FSC-STD-40-004 V1-0 EN FSC CHAIN OF CUSTODY STANDARD FOR COMPANIES SUPPLYING AND MANUFACTURING FSC- CERTIFIED PRODUCTS 8 of 28

2004 Forest Stewardship Council A.C. All rights reserved. Part 5: Invoicing, sales and shipping documentation 16. Sales invoices 16.1. All invoices issued for sales of products on the FSC product group schedule shall include the following information: a) the name and address of the buyer; b) the date on which the invoice was issued; c) description of the product which is the same as the description of the same product on the FSC product group schedule; d) the quantity of the products sold. e) the correct chain of custody certificate registration number issued by the certification body; f) reference to the product s batch and/or to related shipping documentation, sufficient to link the invoice to the goods received by the customer. 16.2 In line with the requirements outlined in FSC requirements for off-product use of the FSC trademarks by certificate holders, the company shall ensure: a) the registration code number on invoices is clearly linked to the certified products; b) when several codes cover different certified products on an invoice, there shall be a clear link between the products and their respective code; c) it is clear which products appearing on the invoice are FSC certified and which are not. 16.3. Invoices issued for sales of FSC-pure products shall include the statement FSCpure. This shall only be issued on invoices accompanying material sold as FSCpure. 16.4. Invoices issued for sales of FSC-mixed products containing FSC-certified and/or post consumer reclaimed material based on a threshold system shall include the minimum percentage of FSC material claimed for the product group over the labelling period. 16.5. Invoices issued for sales of FSC-mixed products containing FSC-certified and/or post-consumer reclaimed material based on an FSC-credit system shall include the statement FSC-credit material. This shall only be issued on invoices accompanying material sold as FSC-credit material. 16.6 Companies selling FSC-certified products shall comply with the requirements set out in Section3 and FSC requirements for off-product use of the FSC trademarks by certificate holders. FSC-STD-40-004 V1-0 EN FSC CHAIN OF CUSTODY STANDARD FOR COMPANIES SUPPLYING AND MANUFACTURING FSC- CERTIFIED PRODUCTS 18 of 28

2004 Forest Stewardship Council A.C. All rights reserved. 16.7 Quantitative claims may be made on invoices or chain of custody documentation for FSC-certified product groups which carry a percentage of FSC pure, mixed or post consumer reclaimed material and for which on product claims are not being made. 16.8 The company shall ensure that the FSC trademarks are not used for the promotion 9 of products which do not meet the thresholds for labelling outlined in Part 4 of this standard. 17. Shipping documentation 17.1. If the FSC-certified products are transported separately to the sales invoice, then the products shall be accompanied by shipping documentation which shall include the following information: a) the name and address of the buyer; b) the date on which the invoice was issued; c) a description of the product which is the same as the description of the same product on the FSC product group schedule; d) the quantity of the products included in the shipment; e) reference to the sales invoice for the products delivered, sufficient to link the goods shipped to the specific invoice for the goods. 17.2. Shipping documents issued for deliveries of products containing FSC-certified or post-consumer reclaimed material after the issue of the FSC chain of custody certificate shall include: a) the correct chain of custody certificate registration number issued by the certification body; b) the percentage of FSC-certified material claimed for the product group, as applicable. 18. Sales records 18.1. The company shall make and keep a record of all their buyers of FSC-certified material in the product group schedule and volumes of material sold as FSC-certified material (pure, mixed, recycled). This shall be available to FSC on request. 9 e.g. advertisements, publicity, promotion or any off-product claims FSC-STD-40-004 V1-0 EN FSC CHAIN OF CUSTODY STANDARD FOR COMPANIES SUPPLYING AND MANUFACTURING FSC- CERTIFIED PRODUCTS 19 of 28