The Westervelt Company 2017 SFI Fiber Sourcing Public Summary Audit Report

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Introduction The Westervelt Company 2017 SFI Fiber Sourcing Public Summary Audit Report Printed: November 29, 2017 The SFI Program of The Westervelt Company of Tuscaloosa, AL has demonstrated conformance with the SFI 2015-2019 Standard and Rules, Section 3 Fiber Sourcing Standard, according to the NSF certification process. Appendix 1 of Section 3 is not included in the scope. NSF initially certified Gulf States Paper Corporation (GSPC) in July 2004. GSPC has since changed its name to The Westervelt Company and was recertified in 2007, 2012, and 2015. This report describes the second surveillance audit for the third recertification designed to focus on changes in the standard, changes in operations, the management review system, and efforts at continuous improvement. This audit included a detailed review of a sample of the SFI requirements. The Westervelt Company manages over five hundred thousand acres of fee and long term lease land in Alabama, Georgia, Mississippi, South Carolina and Virginia. The Westervelt Company operates a large pine sawmill and a cantor wood mill in Moundville, Alabama and a pellet mill in Aliceville, Alabama and typically procures wood within a ninety mile radius of these facilities. Pine is the primary species utilized. The Westervelt Company s SFI FS Program is managed by Jonathan Lowery. The Company has a robust verifiable monitoring system to maintain rates of conformance to best management practices and to identify areas for improved performance. The system includes conducting BMP inspections on all direct purchase tracts and a sample of wood supplier tracts. The Company also reviews state BMP data. The audit was performed by NSF on April 24-28, 2017 by an audit team headed by Norman Boatwright, Lead Auditor. Audit team members fulfill the qualification criteria for conducting audits contained in SFI 2015-2019 Standards and Rules, Section 9 - Procedures and Auditor Qualifications and Accreditation. The scope of the SFIS Audit included the SFI program of The Westervelt Company its procurement operations supplying timber and wood fiber to its manufacturing facilities in Moundville and Aliceville, Alabama. Procurement operations occurring in the past 12 months were reviewed to ensure that SFI Procurement Standards were met, in addition to SFI obligations to promote sustainable forestry practices, to seek legal compliance, and to incorporate continual improvement systems were within the scope of the audit. Several of the SFI Section 3 requirements were outside of the scope of The Westervelt Company s SFI program and were excluded from the scope of the Audit as follows: Audit Process Indicator 5.1.2 - The Westervelt Company does not support or conduct research on genetically engineered trees. Indicator 6.2.3 - Alabama, Mississippi, and Georgia do not have logger certification programs. Objective 8 - The Westervelt Company does not have forest management responsibilities on public lands. Objectives 11-13 The Westervelt Company does not purchase fiber outside Canada and the US. During the audit NSF reviewed a sample of the written documentation assembled to provide objective evidence of conformance. NSF also selected field sites for inspection based upon the risk of environmental impact, likelihood of occurrence, special features, and other criteria outlined in the NSF protocols. NSF selected and interviewed stakeholders such as contract loggers, landowners and other interested parties, and interviewed employees within the organization to confirm that the SFI Standard was understood and actively implemented. The possible findings of the audit included Full Conformance, Major Non-conformance, Minor Non-conformance, Opportunities for Improvement, and Practices that exceeded the Basic Requirements of the standard. Overview of Audit Findings The Westervelt Company was found to be in conformance with the standard. NSF determined that there was a minor nonconformance: Indicator 6.1.5: Program Participants shall have written agreements for the use of qualified logging professionals and/or certified logging professionals (where available) and/or wood producers that have completed training programs and are recognized as qualified logging professionals. Finding: Review of the following Cut & Haul Contracts for Company contract loggers and purchase contract loggers indicate that a trained logger clause is not present: BHL, Inc. dated 8/11/14, Clearwater Foresters, Inc. dated 9/22/2016 and Robert Phillips Logging. Page 1 of 5

The Westervelt Company has developed plans to address this issue. No opportunities for improvement were identified. The resolution of the following minor non-conformance issued during the 2016 audit was confirmed: Indicator 2.1.2 Use of written agreements for the purchase of raw material sourced directly from the forest is required and must include provisions requiring the use of best management practices. Finding: Not all purchase contracts contain requirements for BMPs. Resolution: Annual Wood Purchase Agreements, Wood Orders and Timber Conveyances require BMP Compliance. The next Surveillance Audit is schedule for the week of April 23, 2018. Page 2 of 5

General Description of Evidence of Conformity NSF s audit team used a variety of evidence to determine conformance. A general description of this evidence is provided below, organized by SFI Objective. Objective 1 Biodiversity in Fiber Sourcing To address the practice of sustainable forestry by conserving biological diversity. Objective 2 Adherence to Best Management Practices To broaden the practice of sustainable forestry through the use of best management practices to protect water quality. Summary of Evidence: The Company requires all direct logging contractors working on purchased stumpage tracts to complete an SFI recognized training program. Direct logging contractors are also contractually obligated to follow the State BMPs. The Company has a robust verifiable monitoring system in place to review BMP implementation on purchase and wood supplier tracts. Field observations did not identify any BMP issues. Objective 3 Use of Qualified Resource and Qualified Logging Professionals To encourage forest landowners to utilize the services of qualified logging professionals, certified logging professionals (where available) and qualified resource professionals. Objective 4 Legal and Regulatory Compliance Compliance with applicable federal, provincial, state and local laws and regulations. Objective 5 Forestry Research, Science, and Technology To support forestry research, science, and technology, upon which sustainable forest management decisions are based. Summary of Evidence: Confirmed via review of records on file and interviews that the SFI team is aware of the effects of climate change of forest and wildlife and that the Company has funded forestry research. Objective 6 Training and Education To improve the implementation of sustainable forestry practices through appropriate training and education programs. Summary of Evidence: Confirmed by the Company s financial and physical support of the State SIC and its development of education and logger training programs. Objective 7 Community Involvement and Landowner Outreach To broaden the practice of sustainable forestry through public outreach, education, and involvement and to support the efforts of SFI Implementation Committees. Objective 9 Communications and Public Reporting To broaden the practice of sustainable forestry by documenting progress and opportunities for improvement. Summary of Evidence: Confirmed audit report was filed on time with SFI Inc. and that the Company maintains copies of previous reports. Objective 10 Management Review and Continual Improvement To promote continual improvement in the practice of sustainable forestry, and to monitor, measure, and report performance in achieving the commitment to sustainable forestry. Summary of Evidence: The Company s SFI Team annually meets to review the Sustainable Forestry Policy and Procurement Program to evaluate their effectiveness and has a system for annually collecting, reviewing and reporting information addressing progress in achieving the SFI Standard. Page 3 of 5

Relevance of Forestry Certification Third-party certification provides assurance that forests are being managed under the principles of sustainable forestry, which are described in the Sustainable Forestry Initiative Standard as: 1. Sustainable Forestry To practice sustainable forestry to meet the needs of the present without compromising the ability of future generations to meet their own needs by practicing a land stewardship ethic that integrates reforestation and the managing, growing, nurturing and harvesting of trees for useful products and ecosystem services such as the conservation of soil, air and water quality, carbon, biological diversity, wildlife and aquatic habitats, recreation and aesthetics. 2. Forest Productivity and Health To provide for regeneration after harvest and maintain the productive capacity of the forest land base, and to protect and maintain long-term forest and soil productivity. In addition, to protect forests from economically or environmentally undesirable levels of wildfire, pests, diseases, invasive exotic plants and animals and other damaging agents and thus maintain and improve long-term forest health and productivity. 3. Protection of Water Resources To protect water bodies and riparian areas and to conform with forestry best management practices to protect water quality. 4. Protection of Biological Diversity To manage forests in ways that protect and promote biological diversity, including animal and plant species, wildlife habitats, and ecological or natural community types. 5. Aesthetics and Recreation To manage the visual impacts of forest operations, and to provide recreational opportunities for the public. 6. Protection of Special Sites To manage lands that are ecologically, geologically or culturally important in a manner that takes into account their unique qualities. 7. Responsible Fiber Sourcing Practices in North America To use and promote among other forest landowners sustainable forestry practices that are both scientifically credible and economically, environmentally and socially responsible. 8. Legal Compliance To comply with applicable federal, provincial, state, and local forestry and related environmental laws, statutes, and regulations. 9. Research To support advances in sustainable forest management through forestry research, science and technology. 10. Training and Education To improve the practice of sustainable forestry through training and education programs. 11. Community Involvement and Social Responsibility To broaden the practice of sustainable forestry on all lands through community involvement, socially responsible practices, and through recognition and respect of Indigenous Peoples rights and traditional forest-related knowledge. 12. Transparency To broaden the understanding of forest certification to the Fiber Sourcing Standard by documenting certification audits and making the findings publicly available. 13. Continual Improvement To continually improve the practice of forest management, and to monitor, measure and report performance in achieving the commitment to sustainable forestry. 14. Avoidance of Controversial Sources including Illegal Logging in Offshore Fiber Sourcing To avoid wood fiber from illegally logged forests when procuring fiber outside of North America, and to avoid sourcing fiber from countries without effective social laws. Page 4 of 5

Source: Sustainable Forestry Initiative (SFI) Standard, 2015-2019 Edition For Additional Information Contact: Norman Boatwright Daniel Freeman Jonathan Lowery NSF Forestry Program Manager NSF Project Manager Forest Sustainability & Policy Manager PO Box 4021 Florence, SC 29502 789 N. Dixboro Road Ann Arbor, MI 48105 P. O. Box 48999 Tuscaloosa, AL 35404-8999 843-229-1851 734-214-6228 205-562-5454 nboatwright12@gmail.com dfreeman@nsf.org jlowery@westervelt.com Page 5 of 5