Meadow Lake Mechanical Pulp Inc. - Stakeholder Package · Stewardship Council® (FSC) chain of custody (CoC) and controlled wood (CW) standards. A stakeholder consultation process

KPMG Forest Certification Services Inc. Box 10426, 777 Dunsmuir Street Vancouver BC V7Y 1K3 Canada

Telephone (604) 691-3000 Fax (604) 691-3031

www.kpmg.ca

August 24, 2017

Dear

Stakeholder Consultation

KPMG Forest Certification Services Inc. (KPMG FCSI) to conduct an FSC® Chain

and Custody/Controlled Wood Re-certification Audit of Meadow Lake Mechanical

Pulp Inc.

Purpose and scope of the audit

KPMG Forest Certification Services Inc. (KPMG FCSI) will be conducting a re-certification audit

of Meadow Lake Mechanical Pulp Inc. (MLMP) against the requirements of the current Forest

Stewardship Council® (FSC) chain of custody (CoC) and controlled wood (CW) standards. A

stakeholder consultation process is planned for the summer of 2017, with the main assessment

scheduled to begin on October 2, 2017 and conclude on October 4, 2017.

MLMP holds a single-site FSC CoC/CW certificate that covers the production of bleached chemi-

thermo mechanical pulp (BCTMP) at the Company’s Meadow Lake, Saskatchewan pulp mill.

The supply area for the MLMP pulp mill covers those portions of the WWF ecoregions listed

below that are located within the province of Saskatchewan:

Canadian Aspen Forests and Parklands

Mid-Continental Canadian Forests

Mid-Western Canadian Shield Forests

A map of the applicable WWF ecoregions as well as information regarding their conservation

status can be found at: https://www.worldwildlife.org/science/wildfinder/.

«Title» «FirstName» «LastName»

«Company»

August 24, 2017

Page 2

The audit will be based on the current FSC CoC (FSC-STD-40-004 V3-0) and CW (FSC-STD-40-

005 V3-1) standards.

This letter serves as an invitation to interested and affected stakeholders who wish to provide

comments that are pertinent to MLMP’s FSC CoC/CW certification. The comments received will

be considered by KPMG FCSI in reaching its conclusions regarding MLMP’s conformance with

the applicable FSC CoC and CW standards.

About FSC and the CoC and CW standards

The FSC is an international non-profit organization founded in 1993 to support environmentally

appropriate, socially beneficial, and economically viable management of the world's forests. It

supports the development of national and regional standards to be used to evaluate whether a forest

is being well-managed.

It is an association of members consisting of a diverse group of representatives from environmental

and social organizations, forest and product industries, Indigenous People's organizations,

community forestry groups and certification bodies from around the world. Membership is open to

all who are involved in forestry or forest products and share its aims and objectives.

FSC, with its head office in the city of Bonn, Germany, is governed by an elected Board which

consists of people from industry, environmental, social and labor groups, Indigenous People's

representatives and others.

FSC-STD-40-004 V3-0 and FSC-STD-40-005 V3-1 were recently released for use by FSC.

Organizations holding certifications to the previous versions of these standards must be assessed

against the current version by December 31, 2017 (in the case of FSC-STD-40-005 V3-1) and

March 31, 2018 (in the case of FSC-STD-40-005 V3-1).

Your role

We would appreciate your comments on issues that are pertinent to MLMP’s FSC CoC/CW

certification. Such comments may include, but are not necessarily limited to, concerns or

observations regarding the Company’s due diligence system (i.e., the system of measures and

procedures developed by the organization to minimize the risk of sourcing material from

unacceptable sources), one component of which is the company risk assessment (which FSC has

decided may continue to be used until an approved national risk assessment for Canada is in place).

Comments received will be considered by KPMG FCSI in assessing MLMP’s performance against

the requirements of the applicable FSC CoC and CW standards. A summary of stakeholder

comments will also be included in the MLMP FSC CoC/CW certification audit summary report.


«Company»

August 24, 2017

Page 3

A questionnaire is provided with this letter for your comments on issues that are pertinent to

MLMP’s FSC CoC/CW certification. However, additional materials and other methods of

communication will also be accepted. Upon request, arrangements may also be made to allow

stakeholders to meet with members of the audit team during the on-site portion of the audit.

Access to information

FSC requires that stakeholders be provided access to certain information as part of the consultation

process, including:

A description of the supply area and respective risk designation. This information is included

within the body of this letter and the summary of the MLMP Due Diligence System (DDS).

A written summary of the MLMP DDS. A copy of this document is available on KPMG

FCSI’s website at https://home.kpmg.com/ca/en/home/services/audit/sustainability-

services/kpmg-forest-certification-services-inc.html.

Copies of the applicable FSC CoC and CW standards. These can be obtained from FSC

International at https://ic.fsc.org/en.

A copy of the current (2016 version) MLMP company risk assessment. This can also be

obtained from FSC International at http://info.fsc.org. Note: The 2017 version of the MLMP

company risk assessment was still under development at time of writing. Once finalized by

MLMP and approved by KPMG FCSI it will be posted to the above FSC website.

The procedure for filing complaints. A copy of KPMG FCSI’s dispute resolution procedures

are available on KPMG FCSI’s website.

Contact information of the person or position responsible for addressing complaints. This can

be obtained by visiting the KPMG FCSI website noted above.

KPMG FCSI Contact information

All comments and requests for additional information should be directed to Dave Bebb at:

KPMG Forest Certification Services Inc.

PO Box 10426, Pacific Centre

Vancouver, B.C.

V7Y 1K3

Fax: (604) 691-3031

https://ic.fsc.org/en

http://info.fsc.org/


«Company»

August 24, 2017

Page 4

Our commitments

1 The source of specific comments received will remain confidential unless the commenting

party specifically indicates to the contrary.

2 We will respond to all stakeholders who provide comments and provide information on how

their comments were taken into account.

3 A summary of stakeholder comments and how they were considered by KPMG FCSI will be

included in the MLMP FSC CoC/CW certification audit summary report.

Yours very truly,

Dave Bebb, RPF(BC), EP(EMSLA)

Vice President, Certification Operations

(604) 691-3451

Enclosures

Stakeholder Questionnaire – 2017 Meadow Lake Mechanical Pulp Inc.

FSC® Chain of Custody/Controlled Wood Re-certification Audit

To: Dave Bebb, KPMG FCSI Fax #: 604-691-3031

From: Phone #: ____________

Organization (if applicable):

KPMG Forest Certification Services Inc. (KPMG FCSI) will be conducting a re-certification audit

of Meadow Lake Mechanical Pulp Inc. (MLMP) against the requirements of the current Forest

Stewardship Council® (FSC) chain of custody (CoC) and controlled wood (CW) standards. A

stakeholder consultation process is planned for the summer of 2017, with the main assessment

scheduled to begin on October 2, 2017 and conclude on October 4, 2017. This questionnaire is

intended to obtain information from interested and affected stakeholders regarding issues that are

pertinent to MLMP’s FSC CoC/CW certification. Such comments may include, but are not

necessarily limited to, concerns or observation’s regarding the Company’s due diligence system

(i.e., the system of measures and procedures developed by the organization to minimize the risk of

sourcing material from unacceptable sources), one component of which is the company risk

assessment (which FSC has decided may continue to be used until an approved national risk

assessment for Canada is in place). Comments received will be considered by KPMG FCSI in

assessing MLMP’s performance against the requirements of the applicable FSC CoC and CW

standards. A summary of stakeholder comments will also be included in the MLMP FSC

certification report. However, the identity of individuals/organizations providing comments will be

kept confidential by KPMG FCSI unless the party providing comments specifically indicates in

writing to the contrary.

NB: In order to be considered during the 2017 audit, comments must be received no later than

October 4, 2017.

1. Do you have any specific concerns regarding the MLMP due diligence system

(DDS), company risk assessment or other issues that are pertinent to the

Company’s FSC CoC/CW certification?

Comments:

YES/NO/

NA

Stakeholder Questionnaire – 2017 MLMP FSC CoC/CW Audit


From: Phone #: ____________


2. If you answered yes to question 1 above, have you communicated your

concerns to MLMP?

Comments:

YES/NO/

NA

3. If you answered yes to question 2 above, in your opinion, has MLMP made a

reasonable attempt to address your specific concerns?

Comments:

YES/NO/

NA

Stakeholder Questionnaire – 2017 MLMP FSC CoC/CW Audit


From: Phone #: ____________


4. Do you have any other concerns regarding MLMP’s FSC CoC/CW

certification that have not been addressed in the above questions?

Comments:

YES/NO/

NA

5. Are there any specific issues or requirements of the FSC CoC or CW standard

(FSC-STD-40-004 V3-0 and FSC-STD-40-005 V3-1) that you believe merit

special attention during the 2017 MLMP FSC CoC/CW audit?

Comments:

YES/NO/

NA

Meadow Lake Mechanical Pulp Inc., a Paper Excellence Company Box 9100, Meadow Lake, Saskatchewan S9X 1V7

T: 306.236.2444 | F: 306.236.4880 | [email protected] | www.paperexcellence.com

Meadow Lake Mechanical Pulp Mill Due Diligence System (DDS) Public Summary

1. Scope

Meadow Lake Mechanical Pulp (MLMP) is committed to environmentally sound business practices, which begin with our procurement methods and our dedication to uphold sustainable forest management standards. The Due Diligence System (DDS) applied by MLMP serves to achieve conformance with the Forest Stewardship Council® (FSC®) Standards for sourcing FSC Controlled Wood (CW) (FSC STD-40-005 V3.1). MLMP manufactures chlorine-free, high-yield, bleached hardwood pulp, mixed hardwood/softwood pulp, and softwood pulp though a zero-liquid effluent process. The DDS is part of the Chain of Custody (KF-COC-001010) and Controlled Wood (KF-CW-001010) program in order to avoid procuring material from controversial sources.

2. Description of the Supply Area The Fibre supply areas consist of FSC Certified Forest Management Areas (FMA) and non-FSC certified areas. Mistik Management Ltd, co-owned by MLMP and NorSask Forest Products of the Meadow Lake Tribal Council, manages an FSC Certified FMA where 100% FSC Certified wood may be sourced. Any roundrood procured outside of this area is covered under Mistik Management’s FSC CW risk assessment. Sakaw Askiy Management Inc. is a partnership of 6 forest companies and two First Nations groups who collectively manage the license for the Prince Albert Forest Management Area (PAFMA). The softwood chips that MLMP procures from this area are covered under MLMP’s FSC CW risk assessment. All of the materials procured by MLMP are not listed in Appendices 1, 2, or 3 of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Hardwood sources consist of various amounts of Trembling Aspen (Populus tremuloides) and Balsam Poplar (Populus balsamifera), while softwood sources consist of White Spruce (Picea glauca), Jack Pine (Pinus banksiana), and Black Spruce (Picea mariana). The majority of round wood originates from the FSC Certified FMA, while softwood chips originate from SFI and CSA Forest Management Certified Forests also certified to PEFC Chain of Custody. All forest management areas in the MLMP fibre supply are located in Saskatchewan within the following ecoregions, as defined by WWF Wildfinder. See appendix A for a map of these areas.

Version 1.0 August 2017


T: 306.236.2444 | F: 306.236.4880 | [email protected] | www .paperexcellence.com

Midwestern Canada Shield,

Mid-Continental Canadian Forest, and

Canadian Aspen Forest and Parklands. FSC Certified wood meets all the requirements of the FSC principles and criteria, while FSC Controlled Wood avoids sources from the following five categories:

Illegally harvested wood;

Wood harvested in violation of traditional human rights;

Wood from forests in which high conservation values (HCV) are threatened by management activities;

Wood from forests being converted into plantations or non-forest use; and

Wood from forest in which genetically modified trees are planted.

3. Due Diligence System (DDS) and Risk Assessment

The DDS defines the tasks and operational guidelines for training requirements, responsibilities of key personnel, product groups, production batches, and input specifications ensuring that the purchase of materials adheres to Chain of Custody (CoC) and Controlled Wood programs. Adequate infrastructure and training are also in place to effectively implement and maintain MLMP’s CoC system, which includes the tracking of inputs and outputs of material. Meadow Lake Mechanical Pulp will only handle FSC Mix material or PEFC volume credit material. All material is verified for certified content using the appropriate software and procedures by trained personnel. Should any uncontrolled fibre be delivered to MLMP, appropriate procedures to segregate and manage the materials are strictly applied. MLMP conducts an annual critical supplier audit which includes collecting signed contracts (declarations) from each supplier to ensure that material is not being procured from controversial or unspecified sources, and a commitment to inform MLMP of any potential changes or issues. Information on the geographical origin of all deliveries that may enter the supply chain and the identification of all tree species are documented. If a non-conformance results from the annual supplier audit process, MLMP shall issue corrective/preventative actions to resolve the non-conformance. The MLMP CW program is evaluated through a series of steps defined by the CW standard; the DDS is one of those measures. The three primary tools facilitated by the DDS include:

The collection of information on material;

Assessing the risk of a supply area and supply chain through the CW Risk Assessment; and




in cases where risk is identified, control measures are implemented. The effectiveness of those measures can be verified through the internal audit.

At this time, the MLMP CW Risk Assessment successfully demonstrates that the origin of material and the supply chain practices are a “low risk” of contravening the five categories. The 2016-2017 MLMP Risk Assessment can be located at www.fsc.org by searching for MLMP under the certificate search tab. The 2017-2018 MLMP Company Risk Assessment will be posted in the coming weeks. Mistik Management also completes an on-site verification to ensure that the sources are low-risk. A copy of Mistik Management Ltd. Risk Assessment Public Summary can be found on the FSC website.

4. Procedure for Stakeholder Input and Complaints

MLMP values the input of our stakeholders and has developed a procedure for stakeholder input and concerns. Stakeholders wishing to submit a complaint must do so in writing, supported by facts that are applicable to the scope of MLMP’s Chain of Custody Certificate. Any concerns related to the procurement of logs in the Misitk FMA can be directed to Mistik Management Ltd. If you have other comments or questions that may not be considered a complaint, feel free to contact MLMP. The MLMP procedures for filing complaints are as follows:

1. The complaint must be received in writing. The complaint must include the name and contact information of the complainant, a clear description of the issue, and evidence to support each element or aspect of the complaint.

2. The complaint is logged and reviewed to determine if it should be directed to Mistik Management Ltd. or dealt with by MLMP.

3. If the complaint pertains to the scope of MLMP, an initial response, as well as communicating the complaint procedure to the stakeholder will occur within two weeks.

4. Within two weeks, begin investigating to determine if the claim is substantial based on verifiable evidence.

5. Within two months, an investigation process will be implemented to verify the complaint is substantial. If a non-conformance to MLMP’s chain of custody is found, a corrective actions report will be created. If the complaint is substantial, corrective actions will be implemented to rectify the issue.

6. Substantial complaints will be communicated to the Certification Body and FSC Canada 7. If the Corrective Action cannot solve the issue the supplier will be excluded from the

supply chain.

http://www.fsc.org/




8. The effectiveness of Corrective Actions will be verified by MLMP during the annual internal audit.

9. The complainant, Certification Body, and FSC Canada will be informed of the actions taken and the results of those actions to ensure the issue has been resolved.

10. Copies of relevant correspondence, records, evidence, and actions taken will be documented.

Complaints are to be addressed to: Attention: Management Systems Coordinator Box 9100 Meadow Lake, Saskatchewan S9X 1V7 phone: (306) 236-9616 email: [email protected]




Appendix A: Fibre Supply Area Maps

Figure 1: MLMP

supply areas are

located across three

Saskatchewan

WWF ecoregions:

- Midwestern

Canadian Shield

- Mid-Continental

Canadian Forest

- Canadian Aspen

Forests and

Parklands

Figure 2: Here shows a

portion of the

Saskatchewan Fibre

basket. The blue and red

highlighted portions are

the MLMP fibre supply

areas.

Blue: Mistik Management

Ltd. FMA (co-managed

by MLMP and NorSask)

Red: The Prince Albert

FMA is managed by

Sakaw Askiy

Management

Ltd., a consortium of six

forestry companies and

two First Nations

partners.




Figure 3 (right): The PAFMA is

managed by Sakaw Askiy

Management Ltd.

Figure 4 (below): The Sakaw Askiy

planning area with partners

designated.

Documents

Meadow Lake Mechanical Pulp Inc. - Stakeholder Package · Stewardship Council® (FSC) chain of custody (CoC) and controlled wood (CW) standards. A stakeholder consultation process