Public Notification Letter FSC® Chain of Custody Controlled Wood Stakeholder Consultation · 2017-09-08 · Procedure for filing complaints Note: for further details on complaints

Version 1-0 (February 2017) | © SCS Global Services Page 1 of 2

Public Notification Letter

FSC® Chain of Custody Controlled Wood Stakeholder Consultation To: Interested Parties

From: SCS Global Services

Consultation period: 9/6/17 – 10/18/17

Re: Notification of intent to audit West Coast Paper Mills Ltd. against FSC Chain of Custody Controlled Wood standard FSC-STD-40-005 V3-1

The Forest Stewardship Council® (FSC) requires that a certification body conducting an audit of a certified organization or applicant must consult stakeholders whenever the audit includes intent to source and use uncertified material in an FSC Chain of Custody (CoC) program according to the requirements in FSC-STD-40-005 V3-1 “Requirements for Sourcing FSC Controlled Wood”. Therefore, SCS Global Services (SCS) is seeking input from interested and directly affected stakeholders regarding the relevance, effectiveness, and/or adequacy of West Coast Paper Mills Ltd.’s Due Diligence System (DDS).

An explanation of ‘FSC Controlled Wood’, as well as a copy of FSC-STD-40-005 V3-1, is available here: https://ic.fsc.org/en/certification/types-of-certification/controlled-wood-02 ; a copy of this standard is also available from SCS upon request. Due Diligence Systems are required for certified organizations in order to avoid the sourcing and use of material originating from unacceptable sources in their FSC CoC program.

Directly affected stakeholders include any person, group of persons, or entity that is, with high probability, subject to the effects of the activities related to an organization’s controlled wood sourcing program, including the activities of their suppliers and sub-suppliers, as well as those who influence risk identified through the organization’s Due Diligence System.

This letter serves as SCS’ invitation to directly affected stakeholders to participate in our consultation process. This letter also serves as SCS’ public notification for any interested stakeholders, who are also invited to participate in the consultation process. Participation in this stakeholder consultation process is voluntary; stakeholders are not required to submit comments. Scope of audit and audit details: The audit will assess the conformity of the organization’s controlled wood program – including Risk Assessment(s) and DDS – according to the certification requirements as per FSC-STD-40-005 V3-1. The company’s DDS Public Summary and Risk Assessment (excluding confidential information), as well as any other information or documents deemed relevant for the purpose of this stakeholder consultation, are included as appendices to this letter—see below. For a list of the information that is required to be publically available for stakeholder consultation by SCS, see FSC-STD-40-005 V3-1, Section 6.

2000 Powell Street, Ste. 600 Emeryville, CA 94608 USA +1.510.452.8000 main +1.510.452.8001 fax

https://ic.fsc.org/en/certification/types-of-certification/controlled-wood-02

Version 1-0 (February 2017) | © SCS Global Services Page 2 of 2

Additional certificate holder information: https://info.fsc.org/details.php?id=a0240000005umZVAAY&type=certificate Options for participation and provision of comments: Please submit written comments and evidence (where appropriate) by mail, FAX or email to SCS:

GICIA India Pvt. Ltd. Att’n: Teena Antil, Sr. Manager Natural Resources Division 505, 5th Floor, Matrix Tower, B - 4, Sector - 132, Noida - 201304 (U.P.), India

Email: [email protected] Phone: 0120- 6758612/13

A summary of the stakeholder consultation and comments received will be made publically available on the FSC certificate database, as per FSC-STD-20-011 V4-0. Verbatim comments will only by published with prior consent from the stakeholder and will not be associated with stakeholder names. Note that, while SCS is required to evaluate all information and comments objectively, SCS certification decisions are affected by stakeholder comments only insofar as the comments provide evidence of conformity or nonconformity to the applicable requirements. Within 30 days of making our certification decision, SCS will respond to all stakeholders who provided comments to explain how their comments were taken into account. More information about FSC and SCS can be found on our respective websites: www.fsc.org and www.scsglobalservices.com.

https://info.fsc.org/details.php?id=a0240000005umZVAAY&type=certificate

mailto:[email protected]

http://www.fsc.org/

http://www.scsglobalservices.com/


2000 Powell Street, Ste. 600 Emeryville, CA 94608 USA +1.510.452.8000 main +1.510.452.6882 www.SCSglobalservices.com

Version 1-1 (November 2016) | © SCS Global Services Page 1 of 7

Publically Available Information for FSC Controlled Wood Certificate Holders

INSTRUCTIONS

FSC® requires that organizations track their controlled material and publish specific findings. This form helps you meet the requirements in Section 6 of FSC-STD-40-005 V3-0 “Publically Available Information”.1

Organization Name West Coast Paper Mills Ltd

FSC COC Certificate Number SCS-COC-003383

Name of Authorized Representative (Contact information for person or position responsible for addressing

complaints)

Dr. S.K Sharma [email protected]

Procedure for filing complaints Note: for further details on complaints

procedure, see section 7 in FSC-STD-40-005 V3-0

If any complaint/information received regarding the breach of any standards of company’s control wood policy with supported evidence, those will be assessed by GM-RMP / DGM Raw Material within two weeks of receipt if such complaint / information. In the event that evidence is considered relevant, field investigation / verification would be conducted within two months of receipt of the complaint. Field verifications would be conducted by the personnel having good expertise and knowledge for the purpose.

On receipt of complaint / information in regard to violation of any norms mentioned in controlled wood policy of the company, the GM Raw Material Procurement would form a three member committee

1 This document is meant as guidance only, utilization of templates and guidance documents is no guarantee of conformity with FSC requirements. It is your organization’s responsibility to conform to relevant FSC requirements.




involving the followings:

1. A person from the local Panchayat of the area to which the complaint belong, who has a knowledge about the farm forestry

2. NGO, with the social angle 3. A person among the staff, who has

agro/forestry knowledge base, nominated by the GM-Raw Material Procurement.

Committee will examine the source and confirm the documents issued from the source and its validity. It will also examine the harvesting field on spot and in case of any doubt shall report immediately to hold the supplies and report for the supply in pipeline to the company. On detail examination, if the field verification concludes that wood does not meet the requirements of the Company Policy and requirements of FSC Controlled Wood standard, or if field verification is not conducted within 2 months of receipt of complaint, then supply would be excluded from Company’s FSC Product Groups and no claims about this material would be made until the supply has been proven the policy and FSC Controlled Wood requirements. The company shall exclude supply and supplier from the company’s FSC Controlled Wood category if any non compliance of Controlled Wood requirements is found and supplier will be able to supply controlled wood only after it has been proved that if compliance the Controlled Wood requirements.

Further, the Company would notify the SCS in case of non-compliance with Controlled Wood requirements, once non-compliance is confirmed from low risk area. In case of frequent non-compliance in low risk area, the company will review its risk assessment and necessary action will be taken.




Records of all complaints received and actions taken will be kept for a minimum of 5 years and would be made available to SCS upon request.




Risk Assessment Summary In the case that there are multiple risk assessments, copy and paste this table below for each

assessment.

Description of Supply Area

Andhra Pradesh, Karnataka, Kerala, Maharashtra states of India

Reference to the applicable Risk Assessment Company’s own Risk Assessment

Submit applicable risk assessment (excluding confidential information) in a separate document

Risk Designations Summary For any category not rated as “Low” please fill in control

measures by risk assessment indicator

Sub-category

In order to select a checkbox, “double-click” on the box, and select default value as “checked”.

Overall Risk Designation for the Supply Area Unspecified (see below for

unspecified risk designations) Low

1. Illegally harvested wood Overall Risk Designation: Unspecified Low Control Measures per indicator (if applicable)

1.1 Unspecified Low 1.2 Unspecified Low 1.3 Unspecified Low 1.4 Unspecified Low

2. Wood harvested in violation of traditional and human rights Overall Risk Designation: Unspecified Low Control Measures per indicator (if applicable)

2.1 Unspecified Low

2.2 Unspecified Low

2.3 Unspecified Low

2.4 Unspecified Low

2.5 Unspecified Low

3. Wood harvested from forests in which high conservation values are threatened by management activities Overall Risk Designation: Unspecified Low Control Measures per indicator (if applicable)

3.1 Unspecified Low

3.2 Unspecified Low

4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses Control Measures (if applicable)

4.1 Unspecified Low

5. Wood harvested from forests in which genetically modified trees are planted Control Measures (if applicable)

5 Unspecified Low




Stakeholder Consultation Summary N/A No stakeholder consultations conducted

Summary of the consultation process(es) performed according to

Annex B of FSC-STD-40-005 V3




Expert Engagement Summary N/A No expert engagement conducted

Information on the engagement of one or more experts in the

development of control measures in accordance with Annex C

of FSC-STD-40-005 V3

Note: For individual experts this includes the names of the experts,

their qualifications, their license/registration number (if

applicable), and the scope of their services. For publically available expertise, the specific sources of

information shall be cited.




Summary of Field Verification (undertaken as a control measure)

N/A No field verifications conducted as control measures

A summary of the organization’s findings from field verification

undertaken as a control measure, and steps taken by the organization

to address identified non conformities where they occurred,

unless confidential. The organization shall provide a justification for the

exclusion of confidential information.

Note: The confidential nature of the information may be determined by

the legislation that the organization must be in compliance with.

Commercially sensitive information, and the names of individual

landholders may be treated as confidential.


2000 Powell Street, Ste. 600 Emeryville, CA 94608 USA +1.510.452.8000 main +1.510.452.8001 fax www.SCSglobalServices.com

Version 5-1(November 2016) | © SCS Global Services | FSC-A000521 Page 1 of 12

Publicly Available FSC® Controlled Wood Simplified Risk Assessment

This template is provided as a guide1, based on FSC-STD-40-005 v3,Annex A, Section 3.

Risk assessments can be provided in any format as long as the contents meet FSC requirements.

A simplified risk assessment is only to be conducted when an FSC risk assessment for all five controlled wood categories is scheduledto be approved before 31 December 2017. A simplified risk assessment shall not be used after 31 December 2017.

To be completed by client To be completed by SCS Company Name:West Coast Paper Mill Ltd. Date Reviewed by SCS:

COC Code: SCS-COC-003383

Date of last revision to this Risk Assessment: .10.07.2017

Countryand supply area(s): Andhra Pradesh, India Sources of information:

1This document is meant as guidance only, utilization of templates and guidance documents is no guarantee of conformity with FSC requirements. It is your organization’s responsibility to conform to relevant FSC requirements.

Version 5-1 (November2016) | © SCS Global Services | FSC-A000521 Page 2 of 12

FSC Global Forest Registry risk designations for country/supply area

Please fill this section out for each Country/Supply Area,using the FSC Global Forest Registry (http://www.globalforestregistry.org/map).

Global Forest Registry Risk Designation for Each Category Sub-category

Illegally harvested wood Unspecified Low

1.1 Unspecified Low

1.2 Unspecified Low

1.3 Unspecified Low

1.4 Unspecified Low

Wood harvested in violation of traditional and human rights Unspecified Low

2.1 Unspecified Low

2.2 Unspecified Low

2.3 Unspecified Low

2.4 Unspecified Low

2.5 Unspecified Low

Wood harvested from forests in which high conservation values are threatened by management activities Unspecified Low

3.1 Unspecified Low

3.2 Unspecified Low Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses

Unspecified Low 4.1 Unspecified Low

Wood harvested from forests in which genetically modified trees are planted Unspecified Low

5 Unspecified Low

http://www.globalforestregistry.org/map


Company Risk Assessment

1. Illegally Harvested Wood2 The supply area may be considered low risk inrelation to illegal harvesting when all the followingindicators related to forest governance are met:

Findings Risk Level

Unspecified Low

1.1Evidence of enforcement of logging related laws in the district. a) Use the ‘Minimum list of applicable laws, regulations, and

nationally-ratified international treaties, conventions and agreements’ (Table A at end of document) for the identification of logging related laws in the supply area under evaluation.

b) The organization may use existing national lists from approved FSC National Forest Stewardship Standards and other reputable sources in order to compile the list.

Where the FSC Global Forest Registry contains an FSC approved list of applicable laws for a country, it is mandatory to use this list.

The raw material such as Eucalyptus, Casuarina and Acacia are procured from government agencies like KSFIC & KFDC or through private vendors through the tender and auction as per the rules and regulations imposed by them. The material supplied by the private vendors will also verified by the forest department officials and these materials are transported with the valid permit along with the necessary documents. The organization has maintained a minimum list of applicable laws & regulations for the districts under evaluation & is ensuring that all consignment are in compliance with such laws. Source of Information: http://www.globalforestregistry.org/ The Child Labour (Prohibition and Regulation) Act 1986 The Factories Act 1948 The Forest Conservation Act 1980 The Environment (Protection) Act 1986 http://www.globalforestregistry.org/map

Unspecified Low

1.2 There is evidence in the supply area demonstrating the legality of harvests and wood purchases,including, e.g. robust and effective systems for granting licenses and harvest permits.

Movement / sale of extracted tree species are done on the basis of document issued by the respective AMC. These species are also not grown in forests and these are treated as agriculture crops for their management and marketing regulations as per Government constituted Agricultural Marketing Committees (AMCs). As

Unspecified Low

2 Examples of sources of information: FSC network partners and regional offices (contacts: ic.fsc.org), The Royal Institute of International Affairs (www.illegal-logging.info), Environmental Investigation Agency (www.eia-international.org), Global Witness (www.globalwitness.org), Telapak (for Indonesia www.telapak.org), UK Government’s Department for International Development (DFID), EU FLEGT process (http://www.euflegt.efi.int/home), Transparency International Corruption Perception Index (www.transparency.org), WWF (wwf.panda.org), ELDIS regional and country profiles (www.eldis.org), CITES (www.cites.org), NGOs and involved stakeholders.

http://www.illegal-logging.info/


http://www.eia-international.org/

http://www.globalwitness.org/

http://www.telapak.org/

http://www.euflegt.efi.int/home

http://www.transparency.org/

http://www.eldis.org/

http://www.cites.org/


Casuarinas, Subabul and Eucalyptus are declared Agriculture produce in this FSC district area, no harvesting or transit permit is required.

1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.

Illegal harvesting and transport of pulpwood will attract prosecution and penalty as per provisions of the Indian Forest Act-1927 (annexure 45). There is no evidence available suggesting illegal harvesting in the district of origin. As the species sourced from the Private Vendor and AMC are raised by the farmers on their own land & harvesting is done by them, there is no question of illegal harvesting. In case of species sourced from the Government sources, harvesting is done by the government itself, there is no chance of illegal harvesting Further, There is no evidence available suggesting illegal harvesting in present FSC district.

Unspecified Low

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.

The annually published Transparency International Corruption Perception Index (CPI) shall be used. Countries with a score of less than 50 shall be considered as unspecified risk,unless there is specific independent and credible information at a lower scale (e.g. implemented independent timber tracking systems) that demonstrates the contrary.

The CPI Score of India is 40 as per detail on https://www.transparency.org/cpi2016/results Procurement of Casuarina, Subabul, and Eucalyptus is done from farmers through private vendors and these species are exempt from Forest Rule & regulation. Pulpwood movement of material is either inter- divisional and inter-state and cross-check and verification systems are already put in place, leading to no scope for corruption related to granting of permits for harvesting and trade. http://www.lawnotes.in/Andhra_Pradesh_Forest_Act,_1967 http://forest.ap.nic.in/ap_forest_laws.htm

Unspecified Low

2. Wood harvested in violation of traditional or civil rights The supply area may be considered low risk inrelation to the violation of traditional and humanrights when all the following indicators are met:

Findings Risk Level

Unspecified Low

2.1 There is no UN Security Council ban on timber exports from the country concerned.3

This has applied to Liberia, as of July 2003 (www.un.org/esa/africa/UNNews_Africa/timb er.htm) in reference to Global witness.org There is no ban on the timber exports imposed by the UN Security Council in the country concerned.

Unspecified Low

3 Examples of sources of information: Global Witness (www.globalwitness.org)



2.2 The country or supply area is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber).4

The country or district is not designated as a source of conflict timber (E.g. USAID Type 1 conflict timber). Procurement districts/zone does not fall under designated source of conflict timber (E.g. USAID Type 1 conflict timber; Annexure 46)

Unspecified Low

2.3 There is no evidence of child labor or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the supply area concerned.5

Constitution of India guarantees fundamental rights to all citizens including children, who are protected against exploitation. Article 24 provides for prohibition of employment of children in factories, mines and hazardous industries which resulted in enactment of Factories Act, 1948 and Mines Act, 1952. Employment of Children Act, 1938 was replaced by Child Labour (P&R) Act,1986 which is a comprehensive legislation that prohibits employment of children up to the age of 14 years in hazardous employments. Article 45, which was a directive principle of state policy was elevated to a constitutional right to education to all children of 6-14 years age under Article 21 (A) that resulted in enactment of Right of the Children to Free and Compulsory Education Act, 2009. Other Acts like Bonded Labour System (Abolition) Act, 1976, and Juvenile Justice (Care and Protection of Children) Act, 2000 also contribute to elimination of child labour.Child labour is prohibited in whole India including the designated FSC district by The Child Labour (Prohibition and Regulation) Act 1986 (As per Annex.4) and The Factories Act 1948 (As per Annex.5) and The Minimum Wages Act, 1948 and is punishable by law. Besides wood harvesting and transportation work is able bodied job and the child is not engaged in any of the activities starting from wood harvesting to goods sale.STATE ACTION PLAN FOR ELIMINATION OF CHILD LABOUR IN ANDHRA PRADESH 2013 also ensures the resolved to address the issues of child labour in all aspects with a convergence and institutional approach towards prevention and total elimination of child labour which yielded significant results .Child labour is prohibited and is a

Unspecified Low

4 The final report of the expert panel on illegal exploitation of natural resources and other forms of wealth in Democratic Republic of Congo, 2002, Annexes I and III (S/2002/1146). Conflict Timber: Dimensions of the Problem in Asia and Africa. Volume I. Synthesis report. June 2003 5 FSC network partners and regional offices (contacts: ic.fsc.org), ILO country offices


punishable offence in whole of India, which include wood procurement districts. Refer the Child Labour (Regulation and Prohibition) Act 1986 (As per Annexure-47) and Factories Act 1948 (annexure 48). By the vary nature of the job of manual tree felling, extraction, debarking and processing being carried out in wood procurement districts, where child labour cannot be employed. As such engagement of Child Labour is NOT entertained. Similarly our suppliers are also required to enforce the same.

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 supply area concerned.6

In case of raw material sourcing from private owners, species like Eucalyptus, Subabul, Casuarina and Acacia are grown on private farmers land having clear ownership rights; therefore there is no question of conflicts pertaining to traditional rights. The raw material Sourcing from Government Forest or agencies from the designated district and these forest areas are reserve forests declared under Indian forest Act 1927 (As per Annexure. 45). In this case, before declaration of the area as reserve forests, all traditional rights over the land / forests is settled as per provision of Indian Forest Act 1927.

Unspecified Low

2.5 There is evidence of no violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the supply area concerned.

The standard does not refer to the ratification of ILO 169 and a risk assessment shall involve an assessment of evidence of violation of ILO requirements, irrespective of whether they have been ratified by the country in which the risk assessment is made.7

There is evidence of no violation of the ILO Convention 169 (Annexure 49) on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned. Indian Forest Act and PESA Act adequately cover tribal right in the area of their dwelling for the related districts. There is no violation of ILO convention 169 on Indigenous and Tribal People taking place in related forest area.

Unspecified Low

6 FSC network partners and regional offices (contacts: ic.fsc.org), Indigenous Peoples’ organization, Local community associations, National Sources (e.g. records of land claims negotiation concluded or in progress, summaries of court decisions) 7 FSC network partners and regional offices (contacts: ic.fsc.org), ILO country offices.


3. Wood harvested from forest in which high conservation values are threatened by management activities The supply area may be considered low risk in relation to threat to HCVs if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the supply area by non-compliance with 3.1.

Findings Risk Level

Unspecified Low

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant HCVs.

The organization shall first assess whether any HCVs are threatened at the ecoregional level. If there are any HCVs threatened at the ecoregional level, the organization shall assess how forest management activities relate to these HCVs at the supply area level.

For the risk assessment of this category the identification of ecoregionally significant HCVs is required, which in practical terms implies that locally relevant values are not in the focus of this step of the risk assessment.

Threatened ecoregions can be identified through the supporting information that references, but is not limited to e.g. Biodiversity Hotspots, Global 200 Ecoregion, Frontier Forest, Intact forest landscapes.

Regarding Intact Forest Landscape, firefighting or fire prevention for the protection of public safety is not considered an economic activity of minimal disturbance. Fire control in the context of forest management activities is not considered to be an economic activity of minimal disturbance.

Low risk for this indicator may be demonstrated as follows: a) Material does not originate from any of the mapped areas of

HCVs (as listed in 3.1), or b) There are no eco-regionally significant HCVs in the supply area

according to independent verifiable information at the supply area/supply unit level (NGO reports, environmental impact

List ecoregions The raw material sourcing from farmer’s private land and there is no question of threatening the ecologically sensitive and high conservation values arises and these farmer’s land does not fall under any of the Eco-region, biodiversity hot spots or threatened forests. In case of sourcing from government forest, again these areas does not fall under Eco region, biodiversity hot spot or threatened forest areas as per latest synthesis report issued by the USAID and latest biodiversity hot spot map of Conservation International. These reserve forest areas are protected under Indian Forest Act-1927, and Forest Conservation Act-1980 (annexure 80). Management / harvesting activities are in compliant with these Acts. Hence, there is no question of threatening of ecologically significant and high conservation value forests. Pulpwood (tree species) is sourced from non-forest areas and pulp wood species are not grown in these hot spot areas. The nearest Biodiversity Hot Spot from the FSC district area is more than 500 km away; therefore there is no question of threatening of ecologically significant and high conservation value forests.

Unspecified Low


assessments, etc.)8 3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

Low risk for this indicator shall be demonstrated as follows: a) A strong system of protection of HCVs is in place. The definition

of strong shall be based on the effectiveness of law enforcement in the country. This can be demonstrated through a high rating (≥ 75%) in the World Bank ‘rule of law’ index (www.goindicators.org), and

b) Significant support by relevant national/regional stakeholders from the assessed supply area, or

c) The forest manager has agreed to an approach of HCV protection at the supply unit level with national/regional environmental stakeholders relevant for the assessed supply area.

d) Indicator 3.2 cannot be met if there is substantial objection from relevant national or regional stakeholders against a low risk designation for the HCV category.9

In case of sourcing from government forest, these areas are protected under Indian Forest Act 1927, and Forest Conservation Act 1980. Management / harvesting activities are in compliant with these existing Acts and as per the working plan stipulated by the forest department.

Unspecified Low

8 FSC documentation on HCVs (ic.fsc.org); Ecoregion definition and information (www.worldwildlife.org/biomes); regions identified by Conservation International as a Biodiversity Hotspot; or ecosystems and communities that are explicitly identified by Conservation International as a key component of a Biodiversity Hotspot; forest, woodland, or mangrove ecoregions identified by WWF as a Global 200 Ecoregion and assessed by WWF as having a conservation status of endangered or critical. If the Global 200Ecoregion comprises more than a single terrestrial ecoregion, an ecoregion within the Global 200 Ecoregion can be considered low risk if the sub-ecoregion has a Conservation Status other than critical or endangered (www.worldwildlife.org/science/wildfinger); regions identified by the World conservation Union (IUCN) as a Centre of Plant Diversity; regions identified by CI as a High Biodiversity Wilderness Area that contain contiguous forest ecosystems greater than 500 km2 ; regions identified by the World Resources Institute as a Frontier Forest; Intact Forests Landscapes, as identified by Greenpeace (www.intactforests.org) 9 FSC network partners and regional offices (contacts: ic.fsc.org); signatory to the convention on Biological Diversity and demonstrable progress towards completing a network of protect area, such as an overall positive analysis of the latest country thematic report on Forest Ecosystems (www.cbd.int)

http://www.goindicators.org/

http://www.worldwildlife.org/biomes

http://www.worldwildlife.org/science/wildfinger

http://www.intactforests.org/

http://www.cbd.int/


4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses The supply area may be considered low risk in relation to forest conversion of forest to plantations or non-forest uses when the following indicator is present: (Note: The change from plantations to other land uses is not considered as conversion.)

Findings Risk Level

Unspecified Low

4.1 There is no net loss OR 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.10

Conversion of forestland to plantation is considered as non-forestry activity as per Forest Conservation Act 1980 (annexure 50) is not allowed, except in case of some developmental activity, which is controlled by the strict evaluation and permission of Central Empowered committee appointed by the Supreme Court of India. There is no record that forestland have been converted to plantations/non-forestry activity in related districts. The forest cover in India has increased by 21.34 % in last years.( http://fsi.nic.in/isfr-2015/isfr-2015-forest-cover.pdf) There is also significant gain of forest cover in related districts/states as per Forest Survey of India (FSI) latest report (2015) the % loss/gain of forest cover in these States between 2013-2015, as per FSI report (annexure-51) is 0.27%

Unspecified Low

10 FAO GOFC-GOLD Global Observation of Forest and Land Cover Dynamics; FAO Global Forest Resources Assessment; CI Regional Analysis Program; University of Maryland Department of Geography; UNEP/GRID – Division of Early Warning and Assessment; SERVIR – Regional monitoring and visualization system for Mesoamerica; Congo Basin Forest Partnership and CARPE; CEC Joint Research Centre; INPE-PRODES – Brazil’s National Institute for Space Research; Hansen, M., DeFries, R., Townshend, J.R., Carroll, M., Dimiceli, C., Sohlberg, R. 2003. 500 m MODIS Vegetation Continuous Fields. College Park, Maryland; The Global Land Cover Facility; National data sources; FSC network partners and regional offices (contacts: ic.fsc.org).


5. Wood from forests in which genetically modified trees are planted The supply area may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is met11:

Findings Risk Level

Unspecified Low

a) There is no commercial use of genetically modified trees of the species being sourced; OR

As per Environment (Protection) Act 1986 (As per annexure 52), License is required for commercial cultivation of genetically modifies tree species and there is no license given for any of the tree species anywhere in India for commercial cultivation. WCPM is procuring the pulpwood grown through seed origin or being replicated through cuttings in nursery.

Unspecified Low

b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use of the species being sourced; OR

As per Environment (Protection) Act 1986, License is required for commercial cultivation of genetically modifies tree species and there is no license given for any of the tree species anywhere in India for commercial cultivation

Unspecified Low

c) It is forbidden to use genetically modified trees commercially in the country concerned.

The Ministry of Environment & Forests, Government of India notified the rules under the Environmental Protection Act 1986 (EPA). No person shall import, export, transport, manufacture, process, use or sell any GMOs, substances or cells except with the approval of the GEAC.

Unspecified Low

TableA- Minimumlistofapplicablelaws,regulations,nationally-ratifiedinternational treaties,conventions,andagreements

1.Legalrightstoharvest

1.1Landtenure andmanagementrights

Legislationcoveringlandtenurerights,includingcustomaryrightsaswellasmanagementrights,thatincludestheuseoflegalmethodstoobtaintenurerightsandmanagementrights.Italsocoverslegalbusinessregistrationandtaxregistration,includingrelevantlegallyrequiredlicenses.

1.2Concession licenses

Legislationregulatingproceduresforissuingforestconcessionlicenses, includingtheuseoflegalmethodstoobtainconcessionlicenses.Bribery,corruptionandnepotismareparticularlywell-knownissuesthatareconnectedwithconcessionlicenses.

1.3Managementandha Anynationalorsub-nationallegalrequirementsformanagementplanning, including conducting forest inventories, having a forest

11 FAO, 2004. Preliminary review of biotechnology in forestry, including genetic modification. Forest Genetic Resources Working Paper FGR/59E. Forest Resources Development Services, Forest Resources Division, Rome. Italy (http://www.fao.org/docrep/008/ae574e/AE574E00.HTM). National and regional data sources

http://www.fao.org/docrep/008/ae574e/AE574E00.HTM


rvestingplanning managementplanandrelatedplanningandmonitoring,impactassessments,consultationwithotherentities,aswellasapprovalofthesebylegallycompetentauthorities.

1.4Harvestingpermits

Nationalorsub-nationallawsandregulationsregulatingproceduresforissuingofharvestingpermits,licensesorotherlegaldocumentrequiredforspecificharvestingoperations.Thisincludestheuseoflegalmethodstoobtainthepermits.Corruptionisawell-knownissuethatisconnectedwiththeissuingofharvestingpermits.

2.Taxesandfees

2.1Paymentof royaltiesandharvestingfees

Legislationcoveringpaymentofalllegallyrequiredforestharvesting-specificfees such asroyalties, stumpagefeesandother volume-basedfees.Thisincludespaymentsofthefeesbasedonthecorrectclassificationofquantities,qualitiesandspecies. Incorrectclassificationofforestproductsisawell-knownissuethatisoftencombinedwithbriberyofofficialsinchargeofcontrollingtheclassification.

2.2Valueadded taxesandothersalestaxes

Legislationcoveringdifferenttypesofsalestaxeswhichapplytothematerialbeingsold,includingthesaleofmaterialasgrowingforest(standingstocksales).

2.3Incomeandprofittaxes

Legislationcoveringincomeandprofittaxesrelatedtoprofitderivedfromthesaleofforestproductsandharvestingactivities.Thiscategoryisalso relatedtoincomefromthesaleoftimberanddoesnotincludeothertaxesgenerallyapplicableforcompaniesandisnotrelatedtosalarypayments.

3.Timberharvestingactivities

3.1Timber harvestingregulations

Any legal requirements for harvesting techniques and technology,including selective cutting, shelter wood regenerations, clear felling, transport of timber from the felling site, seasonal limitations, etc. Typically this includes regulations on the size of felling areas, minimum age and/or diameter for felling activities, and elements that shall be preserved during felling, etc. Establishment of skidding or hauling trails, road construction, drainage systems and bridges, etc., shall also be considered as well as the planning and monitoring of harvesting activities. Any legally binding codes for harvesting practices shall be considered.

3.2Protected sitesandspecies

International,national,andsub-nationaltreaties,laws,andregulationsrelated to protected areas, allowable forest uses and activities, and/or rare, threatened, or endangered species, including their habitats and potential habitats.

3.3Environmentalrequirements

National and sub-national laws and regulations related to theidentification and/or protection of environmental values including but not limited to those relating to or affected by harvesting, acceptable levels for soil damage, establishment of buffer zones (e.g. along water courses, open areas and breeding sites), maintenance of retention trees on the felling site, seasonal limitations of harvesting time, environmental requirements for forest machineries, use of pesticides and other chemicals, biodiversity conservation, air quality, protection and restoration of water quality, operation of recreational equipment, development of non-forestry infrastructure, mineral exploration and extraction, etc.

3.4Healthand safety

Legallyrequiredpersonalprotectionequipmentforpersonsinvolvedinharvesting activities, implementation of safe felling and transport practices, establishment of protection zones around harvesting sites, safety requirements for machinery used, and legally required safety requirements in relation to chemical usage. The health and safety requirements that shall be considered relevant to operations in the forest (not office work, or other activities not related to actual forest operations).

3.5Legal employment

Legalrequirements foremploymentofpersonnel involved inharvestingactivities including requirements for contracts and working permits, requirements for obligatory insurance, requirements for competence certificates and other training requirements, and payment of social and income taxes withheld by the employer. Also covered are the observance of minimum working age and


minimum age for personnel involved in hazardous work, legislation against forced and compulsory labour, and discrimination and freedom of association.

4.Thirdparties’rights 4.1Customary rights

Legislation coveringcustomary rights relevant to forest harvestingactivities, including requirements covering the sharing of benefits and indigenous rights.

4.2Free,prior andinformedconsent

Legislationcovering‘free,priorandinformedconsent’inconnectionwiththe transfer of forest management rights, and customary rights to the organization in charge of the harvesting operation.

4.3Indigenous Peoples’rights

LegislationthatregulatestherightsofIndigenous Peoplesasfarasitisrelated to forestry activities. Possible aspects to consider are land tenure, and rights to use certain forest related resources and practice traditional activities, which may involve forest lands.

5.Tradeandtransport (NOTE: This section covers requirements for forest management operations as well as processing and trade.)

5.1Classificationofspecies,quantities,qualities

Legislationregulatinghowharvestedmaterialisclassifiedintermsofspecies, volumes and qualities in connection with trade and transport. Incorrect classification of harvested material is a well-known method to reduce or avoid payment of legally prescribed taxes and fees.

5.2Tradeand transport

Allrequiredtradingandtransportpermitsshallexistaswellaslegallyrequired transport documents which accompany the transport of wood from forest operations.

5.2Offshore tradingandtransferpricing

Legislationregulatingoffshoretrading.Offshoretradingwithrelatedcompanies placed in tax havens, combined with artificial transfer prices is a well-known way to avoid payment of legally prescribed taxes and fees to the country of harvest and is considered to be an important source of funds that can be used for payment of bribery to the forest operations and personnel involved in the harvesting operation.

Manycountrieshaveestablishedlegislationcoveringtransferpricingandoffshoretrading.Itshouldbenotedthatonlytransferpricingandoffshoretrading,asfarasitislegallyprohibitedinthecountry,canbeincludedhere.

5.4Custom regulations Customlegislationcoveringareassuchasexport/importlicensesandproduct classification (codes, quantities, qualities and species).

5.5CITES CITESpermits(theConventiononInternationalTradeinEndangered Species ofWild Fauna andFlora, alsoknownas theWashingtonConvention).

6.Duediligence/duecare 6.1Duediligence/duecareprocedures

Legislationrequiringduediligence/duecareprocedures,includinge.g.due diligence/duecaresystems, declarationobligations, and/orthekeepingoftraderelateddocumentsetc.







To be completed by client To be completed by SCS Company Name: West Coast Paper Mills Ltd. Date Reviewed by SCS:


Date of last revision to this Risk Assessment: 10.07.2017

Countryand supply area(s): Karnataka, INDIA Sources of information: In annexure







1.1 Unspecified Low

1.2 Unspecified Low

1.3 Unspecified Low

1.4 Unspecified Low


2.1 Unspecified Low

2.2 Unspecified Low

2.3 Unspecified Low

2.4 Unspecified Low

2.5 Unspecified Low


3.1 Unspecified Low




5 Unspecified Low





Findings Risk Level

Unspecified Low





The raw material such as Eucalyptus, Casuarina and Acacia are procured from government agencies like KSFIC & KFDC or through private vendors through the tender and auction as per the rules and regulations imposed by them. The material supplied by the private vendors will also verified by the forest department officials and these materials are transported with the valid permit along with the necessary documents. We refer the following laws from Global Forest Registry The Child Labour (Prohibition and Regulation) Act 1986 The Factories Act 1948 The Forest Conservation Act 1980 The Environment (Protection) Act 1986 http://www.globalforestregistry.org/map

Unspecified Low


Pulpwood from government sources / private farmers is having necessary permission to harvest and transported with transit permit. Where as pulpwood transported from private vendor will also enclosed with necessary transit pass or permit. Meanwhile, Eucalyptus and Casuarina wood are free to grow and transport without any licence in Karnataka (annexure 37).

Unspecified Low













Illegal harvesting and transport will attract prosecution and penalty as per provisions of the Indian Forest Act, 1927 and The Forest (Conservation) Act,1980 (copies enclosed). There is no evidence available suggesting illegal harvesting in the district of origin. Forests are managed by the government and are strictly protected. Timber species sourced from the Govt. owned forest area, harvesting is done by the govt. itself as per forest working plan provisions there is no chance of illegal harvesting.

Unspecified Low



The CPI Score of India is 40 as per detail on https://www.transparency.org/cpi2016/results There is a robust system in vogue set by the Govt., as the movement of pulpwood is either inter- divisional Or inter-state & verification systems are already in place, leading to no scope for corruption relating to granting of permission for harvesting and transport. More over Acacia species, a restricted wood; is not grown in natural forests but only in fringes of forests. In Karnataka state of India, the rosewood timber species are the property of the government. These Rosewood timber species are sold in the public market through government approved public auction houses only as it is the property of the Indian government and it is categorized as the restricted species. These auctions are monitored by the Central vigilance department. If anyone wants to harvest this timber even in their own land needs to take permission from the forest department (higher than DCF- Divisional Conservator of forests) and sold only through government owned forest auction houses maintained by the forest department, if not means it will attract punishment according the Indian penal court. State acts like The Karnataka Preservation Of Trees Act (1976) are in force and cutting permit is required to get from Divisional Forest Officer (DFO).

Unspecified Low



Findings Risk Level

Unspecified Low



Unspecified Low


The country or district is not designated as a source of conflict timber (E.g. USAID Type 1 conflict timber). Procurement districts/zone does not fall under designated source of conflict timber (E.g. USAID Type 1 conflict timber; Annexure 46).

Unspecified Low


Child labour is prohibited and is a punishable offence in whole of India, which include wood procurement districts. Refer the Child Labour (Regulation and Prohibition) Act 1986 (As per Annexure-47) and Factories Act 1948 (annexure 48). By the vary nature of the job of manual tree felling, extraction, debarking and processing being carried out in wood procurement districts, where child labour cannot be employed. As such engagement of Child Labour is NOT entertained. Similarly our suppliers are also required to enforce the same.

Unspecified Low


In case of raw material sourcing from private owners, species like Eucalyptus, Subabul, Casuarina and Acacia are grown on private farmers land having clear ownership rights; therefore there is no question of conflicts pertaining to traditional rights. The raw material Sourcing from Government Forest or agencies from the designated district and these forest areas are reserve forests

Unspecified Low

3 Examples of sources of information: Global Witness (www.globalwitness.org) 4 The final report of the expert panel on illegal exploitation of natural resources and other forms of wealth in Democratic Republic of Congo, 2002, Annexes I and III (S/2002/1146). Conflict Timber: Dimensions of the Problem in Asia and Africa. Volume I. Synthesis report. June 2003 5 FSC network partners and regional offices (contacts: ic.fsc.org), ILO country offices 6 FSC network partners and regional offices (contacts: ic.fsc.org), Indigenous Peoples’ organization, Local community associations, National Sources (e.g. records of land claims negotiation concluded or in progress, summaries of court decisions)



declared under Indian forest Act 1927 (As per Annexure. 45). In this case, before declaration of the area as reserve forests, all traditional rights over the land / forests is settled as per provision of Indian Forest Act 1927. Other rights regarding cultural and traditional aspects are protected/resolved by Local Panchayats as per Panchayat (Extension to Scheduled Areas) , PESA ACT, 1996 .




Unspecified Low


Findings Risk Level

Unspecified Low



For the risk assessment of this category the identification of ecoregionally significant HCVs is required, which in practical terms implies that locally relevant values are not in the focus of this step

List ecoregions The raw material is sourcing from farmer’s private land and there is no question of threatening the ecologically sensitive and high conservation values arises and these farmers land does not fall under any of the Eco-region, biodiversity hot spots or threatened forests. In case of raw material sourcing from government forest, again these area does not fall under Eco region, biodiversity hot spot or threatened forest areas as per latest synthesis report issued by the USAID and latest biodiversity hot spot map of Conservation International. These reserve forest areas are protected under Indian Forest Act-1927 and Forest Conservation Act-1980 (annexure 50). Management / harvesting activities are in compliant with these

Unspecified Low

7 FSC network partners and regional offices (contacts: ic.fsc.org), ILO country offices.


of the risk assessment.





according to independent verifiable information at the supply area/supply unit level (NGO reports, environmental impact assessments, etc.)8

Acts. Hence, there is no question of threatening of ecologically significant and high conservation value forests. Pulpwood (tree species) is sourced from non-forest areas. Pulp wood species are not grown in these hot spot area and there is no question of procuring the material from that area.here is evidence of no violation of the ILO Convention 169 (Annexure 49) on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned. Indian Forest Act and PESA Act adequately cover tribal right in the area of their dwelling for the related districts. WCPM is procuring wood from the suppliers for whom source is government forest, and this area does not fall under Eco region, biodiversity hot spot or threatened forest areas as per latest synthesis report issued by the USAID. .http://www.worldwildlife.org/science/ecoregions.cfm. The forest area in India is government property and is maintained by forest departments. In 2014, Wildlife Institute of India has got independently evaluated 125 national parks and wildlife sanctuaries in the country from 2006 to 2014. Despite all odds, the overall outcomes of these assessments are encouraging and the mean MEE score of the Indian Protected areas is 60.80%, which is higher than the global mean of 56 percent.

3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.


of strong shall be based on the effectiveness of law enforcement in the country. This can be demonstrated through

NA …Not applicable as the source is legally and privately owned farm lands. The forest conservation act 1980 and the Indian Forest Act 1927 are in place that ensures that HCV’s are not affected. The protected area are protected by the forest department and the entry to the area are on permission by forest department. These area has been conserved and have a well defined

Unspecified Low

8 FSC documentation on HCVs (ic.fsc.org); Ecoregion definition and information (www.worldwildlife.org/biomes); regions identified by Conservation International as a Biodiversity Hotspot; or ecosystems and communities that are explicitly identified by Conservation International as a key component of a Biodiversity Hotspot; forest, woodland, or mangrove ecoregions identified by WWF as a Global 200 Ecoregion and assessed by WWF as having a conservation status of endangered or critical. If the Global 200Ecoregion comprises more than a single terrestrial ecoregion, an ecoregion within the Global 200 Ecoregion can be considered low risk if the sub-ecoregion has a Conservation Status other than critical or endangered (www.worldwildlife.org/science/wildfinger); regions identified by the World conservation Union (IUCN) as a Centre of Plant Diversity; regions identified by CI as a High Biodiversity Wilderness Area that contain contiguous forest ecosystems greater than 500 km2 ; regions identified by the World Resources Institute as a Frontier Forest; Intact Forests Landscapes, as identified by Greenpeace (www.intactforests.org)





a high rating (≥ 75%) in the World Bank ‘rule of law’ index (www.goindicators.org), and




boundary. The plantation are far away from these protected areas and on private lands and there has been no disturbance due to plantation activities in the protected areas. In case of sourcing from government forest, these areas are protected under Indian Forest Act 1927, and Forest Conservation Act 1980. Management / harvesting activities are in compliant with these existing Acts and as per the working plan stipulated by the forest department.


Findings Risk Level

Unspecified Low


Conversion of forestland to plantation is considered as non-forestry activity as per Forest Conservation Act 1980 (annexure 50) except in case of some developmental activity, which is controlled by the strict evaluation and permission of Central Empowered committee appointed by the Supreme court of India. There is no record that forestland have been converted to plantations/non-forestry activity in related districts.

Unspecified Low

9 FSC network partners and regional offices (contacts: ic.fsc.org); signatory to the convention on Biological Diversity and demonstrable progress towards completing a network of protect area, such as an overall positive analysis of the latest country thematic report on Forest Ecosystems (www.cbd.int) 10 FAO GOFC-GOLD Global Observation of Forest and Land Cover Dynamics; FAO Global Forest Resources Assessment; CI Regional Analysis Program; University of Maryland Department of Geography; UNEP/GRID – Division of Early Warning and Assessment; SERVIR – Regional monitoring and visualization system for Mesoamerica; Congo Basin Forest Partnership and CARPE; CEC Joint Research Centre; INPE-PRODES – Brazil’s National Institute for Space Research; Hansen, M., DeFries, R., Townshend, J.R., Carroll, M., Dimiceli, C., Sohlberg, R. 2003. 500 m MODIS Vegetation Continuous Fields. College Park, Maryland; The Global Land Cover Facility; National data sources; FSC network partners and regional offices (contacts: ic.fsc.org).


http://www.cbd.int/


The forest cover in India has increased by 21.34 % in last years.( http://fsi.nic.in/isfr-2015/isfr-2015-forest-cover.pdf) There is also significant gain of forest cover in related districts/states as per Forest Survey of India (FSI) latest report (2015) the % gain of forest cover in this State between 2013-2015, as per FSI report (annexure-51) is 0.79 %


Findings Risk Level

Unspecified Low


As per Environment (Protection) Act 1986 (As per annexure 52), License is required for commercial cultivation of genetically modifies tree species and there is no license given for any of the tree species anywhere in India for commercial cultivation. WCPM is procuring the pulpwood grown through seed origin or being replicated through cuttings in nursery

Unspecified Low



Unspecified Low


The Ministry of Environment & Forests, Government of India notified the rules under the Environmental Protection Act 1986 (EPA). No person shall import, export, transport, manufacture, process, use or sell any GMOs, substances or cells except with the approval of the GEAC

Unspecified Low










1.3Managementandharvestingplanning

Anynationalorsub-nationallegalrequirementsformanagementplanning, including conducting forest inventories, having a forest managementplanandrelatedplanningandmonitoring,impactassessments,consultationwithotherentities,aswellasapprovalofthesebylegallycompetentauthorities.



2.Taxesandfees













National and sub-national laws and regulations related to theidentification and/or protection of environmental values including but not limited to those relating to or affected by harvesting, acceptable levels for soil damage, establishment of buffer zones (e.g.


along water courses, open areas and breeding sites), maintenance of retention trees on the felling site, seasonal limitations of harvesting time, environmental requirements for forest machineries, use of pesticides and other chemicals, biodiversity conservation, air quality, protection and restoration of water quality, operation of recreational equipment, development of non-forestry infrastructure, mineral exploration and extraction, etc.

3.4Healthand safety


3.5Legal employment

Legalrequirements foremploymentofpersonnel involved inharvestingactivities including requirements for contracts and working permits, requirements for obligatory insurance, requirements for competence certificates and other training requirements, and payment of social and income taxes withheld by the employer. Also covered are the observance of minimum working age and minimum age for personnel involved in hazardous work, legislation against forced and compulsory labour, and discrimination and freedom of association.

















6.Duediligence/duecare


6.1Duediligence/duecareprocedures








To be completed by client To be completed by SCS Company Name:West Coast Paper Mills Ltd Date Reviewed by SCS:



Countryand supply area(s): Kerala, INDIA Sources of information: In annexure







1.1 Unspecified Low

1.2 Unspecified Low

1.3 Unspecified Low

1.4 Unspecified Low


2.1 Unspecified Low

2.2 Unspecified Low

2.3 Unspecified Low

2.4 Unspecified Low

2.5 Unspecified Low


3.1 Unspecified Low




5 Unspecified Low





Findings Risk Level

Unspecified Low





Over the last 20 years, large-scale planting of Eucalyptus, as a fast growing species, has occurred in India, outside forest areas, making it a part of the drive to reforest and create an adequate supply of timber under social and agro forestry. With an objective to reduce pressure on forests, Government is promoting these tree species under social and agro forestry, and has issued guidelines to exempt these species from felling and transit restrictions. We refer the following laws from Global Forest Registry The Child Labour (Prohibition and Regulation) Act 1986 The Factories Act 1948 The Forest Conservation Act 1980 The Environment (Protection) Act 1986 http://www.globalforestregistry.org/map As per Kerala Forest Act 1961, (Act 4 of 1962),Eucalyptus has been exempted from transit regulation hence these are restricted free species and no pass or permission shall be necessary for the removal of these. Copy of Kerala Forest Act 1961 is attached under Annexure

Unspecified Low













For wood, Eucalyptus tree species have been exempted from felling and transit restrictions and being promoted under social and agro forestry with an objective to reduce pressure on forests for wood. These species are grown outside forest areas and are treated as agriculture produce for management and marketing regulations. Private parties are not allowed to cut trees for harvesting. Only government has the right to cut down trees. Wood from the forests is harvested as per the Government Working Plans .In case somebody from private agency wants to cut trees from his courtyard, they need to take special permission from government and tree can be cut down only in front of the government agent’s presence.

Unspecified Low


Extraction and marketing of Eucalyptus tree species from non forest land is covered under social and Agro forestry. There is no evidence available suggesting illegal harvesting in the district of origin. Illegal harvesting and transport of pulpwood will attract prosecution and penalty as per provisions of the Indian Forest Act-1927 (annexure 45).

Unspecified Low



The CPI Score of India is 40 as per detail on https://www.transparency.org/news/feature/corruption_perceptions_index_2016 Eucalyptus are neither restricted species nor from sensitive areas and are of ‘Category C Tree Species’ for which felling permission, transit permission, transit pass not required from the Prescribed Authority. Also movement of material is either inter- divisional and inter-state and cross-check and verification systems are already put in place, leading to no scope for corruption related to granting of permits for harvesting and trade.

Unspecified Low



Findings Risk Level

Unspecified Low


This has applied to Liberia, as of July 2003 (www.un.org/esa/africa/UNNews_Africa/timb er.htm) in reference to Global witness.org India is exempted from UN security council ban http://www.globalwitness.org/pages/en/forests.html.

Unspecified Low


The country or district is not designated a source of conflict timber (Eg USAID Type 1 conflict timber). Procurement districts do not fall under designated source of conflict timer (Eg USAID Type 1 conflict timber; Annexure 46)

Unspecified Low


Child labour is prohibited in the entire country and is a punishable offence in whole of India, which include wood procurement districts also as per Child Labour (Regulation and Prohibition) Act 1986 (As per Annexure-47) and Factories Act 1948 (annexure 48). By the vary nature of the job of manual tree felling, extraction, debarking and processing being carried out, in wood procurement districts, where child labour cannot be employed. In line with judiciary, Government has taken drastic steps to prevent child labor and encouraged literacy to develop. According to Indian constitutional article 45 — universal free compulsory education should be achieved. Prescribed authorities under various acts protect controversial activities and prevent violation of human rights. In India, child of age 6 to 14 has right to free and compulsory education as per “The Right of Children to Free and compulsory Education Act 2009. Child Labor (Regulation and Prohibition) Act 1986 ”

Unspecified Low

3 Examples of sources of information: Global Witness (www.globalwitness.org) 4 The final report of the expert panel on illegal exploitation of natural resources and other forms of wealth in Democratic Republic of Congo, 2002, Annexes I and III (S/2002/1146). Conflict Timber: Dimensions of the Problem in Asia and Africa. Volume I. Synthesis report. June 2003 5 FSC network partners and regional offices (contacts: ic.fsc.org), ILO country offices



In the six years between 2010 and 2016, official figures say, only 11 prosecution cases have been filed in the state. The surprising claim is that there is no child labour in any establishments. As per Child Labour (Control and Prevention) Act, 1986, assistant labour officer and district labour officer (enforcement) have been appointed as protection inspectors in each district. Besides, child labour rehabilitation-cum-welfare societies and task forces function in all the 14 districts.


As the raw material is sourcing from private vendor and these species are grown on private farmer land having clear ownership rights, and there is no conflict pertaining to traditional. .

Unspecified Low



The Indian Forest Act (Annexure-1) and PESA Act (Annexure-7. Indian Forests Right Act ), The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 adequately cover tribal right in the area of their dwelling for the related districts. There is no violation of ILO convention 169 (Annexure- 5) on Indigenous and Tribal People taking place in related forest area.

Unspecified Low


Findings Risk Level

Unspecified Low


The organization shall first assess whether any HCVs are threatened

List ecoregions The raw material is sourcing from farmer’s private land, which do not fall under any of the Eco-region, biodiversity hot spots or threatened forests. In case of sourcing from government forest, again these area does not fall under Eco region, biodiversity hot

Unspecified Low



at the ecoregional level. If there are any HCVs threatened at the ecoregional level, the organization shall assess how forest management activities relate to these HCVs at the supply area level.







spot or threatened forest areas as per latest synthesis report issued by the USAID and latest biodiversity hot spot map of Conservation International. These reserve forest areas are protected under Indian Forest Act-1927, and Forest Conservation Act-1980 (annexure 50). Management / harvesting activities are in compliant with these Acts. Hence, there is no question of threatening of ecologically significant and high conservation value forests. Pulpwood are sourced from non forest areas i.e., from private / farmer’s land and question of these threatening ecologically sensitive and high conservation values do not arise. The forest area in India is government property and is maintained by forest departments.In 2014, Wildlife Institute of India has got independently evaluated 125 national parks and wildlife sanctuaries in the country from 2006 to 2014. Despite all odds, the overall outcomes of these assessments are encouraging and the mean MEE score of the Indian Protected areas is 60.80%, which is higher than the global mean of 56 percent. HCV forest areas fall under the reserve category and they are highly protected. Ministry of environment and forests and other state departments will only maintain the forests and nature felled trees are cleared for general management activities and minimum DFO and CFO level are responsible for managing. These reserve forest areas are also protected under Indian Forest Act-1927, and Forest Conservation Act-1980. Timber procurement districts do not fall under any of the eco-region, biodiversity sensitive areas or threatened forests as per latest “State of Forest Report-2015” issued by Forest Survey of India - (Ministry of Environment & Forests), Dehradun http://www.worldwildlife.org/ecoregions






http://www.fsi.org.in/final_2011.pdf).



of strong shall be based on the effectiveness of law enforcement in the country. This can be demonstrated through a high rating (≥ 75%) in the World Bank ‘rule of law’ index (www.goindicators.org), and




In case of sourcing from government forest, these areas are protected under Indian Forest Act-1927, and Forest Conservation Act-1980. Management/harvesting activities are in compliant with these Acts and as per working plan

Unspecified Low


Findings Risk Level

Unspecified Low


Conversion of forestland to plantation is considered as non-forestry activity as per Forest Conservation Act 1980 (annexure 50) except in case of some developmental activity, which is controlled by the

Unspecified Low

9 FSC network partners and regional offices (contacts: ic.fsc.org); signatory to the convention on Biological Diversity and demonstrable progress towards completing a network of protect area, such as an overall positive analysis of the latest country thematic report on Forest Ecosystems (www.cbd.int)


http://www.cbd.int/


strict evaluation and permission of Central Empowered committee appointed by the Supreme court of India. There is no record that forestland have been converted to plantations/non-forestry activity in related districts. The forest cover in India has increased by 21.34 % in last years.( http://fsi.nic.in/isfr-2015/isfr-2015-forest-cover.pdf) There is also significant gain of forest cover in related districts/states as per Forest Survey of India (FSI) latest report (2015) the % gain of forest cover in this State between 2013-2015, as per FSI report (annexure-51) is 6.85%


Findings Risk Level

Unspecified Low



Unspecified Low



Unspecified Low

10 FAO GOFC-GOLD Global Observation of Forest and Land Cover Dynamics; FAO Global Forest Resources Assessment; CI Regional Analysis Program; University of Maryland Department of Geography; UNEP/GRID – Division of Early Warning and Assessment; SERVIR – Regional monitoring and visualization system for Mesoamerica; Congo Basin Forest Partnership and CARPE; CEC Joint Research Centre; INPE-PRODES – Brazil’s National Institute for Space Research; Hansen, M., DeFries, R., Townshend, J.R., Carroll, M., Dimiceli, C., Sohlberg, R. 2003. 500 m MODIS Vegetation Continuous Fields. College Park, Maryland; The Global Land Cover Facility; National data sources; FSC network partners and regional offices (contacts: ic.fsc.org). 11 FAO, 2004. Preliminary review of biotechnology in forestry, including genetic modification. Forest Genetic Resources Working Paper FGR/59E. Forest Resources Development Services, Forest Resources Division, Rome. Italy (http://www.fao.org/docrep/008/ae574e/AE574E00.HTM). National and regional data sources




The Ministry of Environment & Forests, Government of India notified the rules under the Environmental Protection Act 1986 (EPA). No person shall import, export, transport, manufacture, process, use or sell any GMOs, substances or cells except with the app

Unspecified Low











2.Taxesandfees







3.Timberharvestingactivities 3.1Timber harvestingregulations

Any legal requirements for harvesting techniques and technology,including selective cutting, shelter wood regenerations, clear felling, transport of timber from the felling site, seasonal limitations, etc. Typically this includes regulations on the size of felling


areas, minimum age and/or diameter for felling activities, and elements that shall be preserved during felling, etc. Establishment of skidding or hauling trails, road construction, drainage systems and bridges, etc., shall also be considered as well as the planning and monitoring of harvesting activities. Any legally binding codes for harvesting practices shall be considered.




National and sub-national laws and regulations related to theidentification and/or protection of environmental values including but not limited to those relating to or affected by harvesting, acceptable levels for soil damage, establishment of buffer zones (e.g. along water courses, open areas and breeding sites), maintenance of retention trees on the felling site, seasonal limitations of harvesting time, environmental requirements for forest machineries, use of pesticides and other chemicals, biodiversity conservation, air quality, protection and restoration of water quality, operation of recreational equipment, development of non-forestry infrastructure, mineral exploration and extraction, etc.

3.4Healthand safety


3.5Legal employment



















6.Duediligence/duecare 6.1Duediligence/duecareprocedures








To be completed by client To be completed by SCS Company Name:West Coast Paper Mill Ltd Date Reviewed by SCS:



Countryand supply area(s): Maharashtra, India Sources of information:







1.1 Unspecified Low

1.2 Unspecified Low

1.3 Unspecified Low

1.4 Unspecified Low


2.1 Unspecified Low

2.2 Unspecified Low

2.3 Unspecified Low

2.4 Unspecified Low

2.5 Unspecified Low


3.1 Unspecified Low




5 Unspecified Low





Findings Risk Level

Unspecified Low





The raw material such as Eucalyptus, Casuarina and Acacia are procured from government agencies like KSFIC & KFDC or through private vendors through the tender and auction as per the rules and regulations imposed by them. The material supplied by the private vendors will also verified by the forest department officials and these materials are transported with the valid permit along with the necessary documents. We refer the following laws from Global Forest Registry The Child Labour (Prohibition and Regulation) Act 1986 The Factories Act 1948 The Forest Conservation Act 1980 The Environment (Protection) Act 1986 http://www.globalforestregistry.org/map

Unspecified Low


Pulpwood from private farmers is having necessary permission to harvest and transported with transit permit. Where as pulpwood transported from private vendor are also produce necessary document for transport. Mean while Eucalyptus and Casuarina

Unspecified Low












wood are free to grow and transport without any licence in Maharashtra.


Illegal harvesting and transport of pulpwood will attract prosecution and penalty as per provisions of the Indian Forest Act-1927 (annexure 45). We are procuring the raw materials from government sources and private vendors. In case of Govt, the plantations has been done and harvested as per the forest working plans, where as in case of private vendors, the plantation has been done by the farmers on their own land. There is no scope or evidence available suggesting illegal harvesting of raw material in the district of origin.

Unspecified Low



The CPI Score of India is 40 as per detail on https://www.transparency.org/cpi2016/results There is a robust system in vogue set by the Govt., as the movement of pulpwood is either inter- divisional Or inter-state & verification systems are already in place, leading to no scope for corruption relating to granting of permission for harvesting and transport. More over Acacia species, a restricted wood; is not grown in natural forests but only in fringes of forests.

Unspecified Low


Findings Risk Level

Unspecified Low



Unspecified Low


The country or district is not designated as a source of conflict timber (E.g. USAID Type 1 conflict timber). Procurement

Unspecified Low

3 Examples of sources of information: Global Witness (www.globalwitness.org) 4 The final report of the expert panel on illegal exploitation of natural resources and other forms of wealth in Democratic Republic of Congo, 2002, Annexes I and III (S/2002/1146). Conflict Timber: Dimensions of the Problem in Asia and Africa. Volume I. Synthesis report. June 2003



districts/zone does not fall under designated source of conflict timber (E.g. USAID Type 1 conflict timber; Annexure 46)


Constitution of India guarantees fundamental rights to all citizens including children, who are protected against exploitation. Article 24 provides for prohibition of employment of children in factories, mines and hazardous industries which resulted in enactment of Factories Act, 1948 and Mines Act, 1952. Employment of Children Act, 1938 was replaced by Child Labour (P&R) Act,1986 which is a comprehensive legislation that prohibits employment of children up to the age of 14 years in hazardous employments. Article 45, which was a directive principle of state policy was elevated to a constitutional right to education to all children of 6-14 years age under Article 21 (A) that resulted in enactment of Right of the Children to Free and Compulsory Education Act, 2009. Other Acts like Bonded Labour System (Abolition) Act, 1976, and Juvenile Justice (Care and Protection of Children) Act, 2000 also contribute to elimination of child labour.Child labour is prohibited in whole India including the designated FSC district by The Child Labour (Prohibition and Regulation) Act 1986 (As per Annex.4) and The Factories Act 1948 (As per Annex.5) and The Minimum Wages Act, 1948 and is punishable by law. Besides wood harvesting and transportation work is able bodied job and the child is not engaged in any of the activities starting from wood harvesting to goods sale. Child labour is prohibited and is a punishable offence in whole of India, which include wood procurement districts. Refer the Child Labour (Regulation and Prohibition) Act 1986 (As per Annexure-47) and Factories Act 1948 (annexure 48). By the vary nature of the job of manual tree felling, extraction, debarking and processing being carried out in wood procurement districts, where child labour cannot be employed. As such engagement of Child Labour is NOT entertained. Similarly our suppliers are also required to enforce the same

Unspecified Low

5 FSC network partners and regional offices (contacts: ic.fsc.org), ILO country offices



In case of sourcing from private owners, species like Casuarina, Subabul, Eucalyptus, are being grown on private farmers land having clear ownership rights, therefore there is no question of conflicts pertaining to traditional rights. In case of Sourcing from Government Forest for Bamboo or other species in the designated district, these forest areas are reserve forests declared under Indian forest Act 1927 (As per Annex. 6). In this case before declaration of the area as reserve forests, all traditional rights over the land / forests is settled as per provision of Indian Forest Act 1927.

Unspecified Low




Unspecified Low


Findings Risk Level

Unspecified Low



List ecoregions The raw material is sourcing from farmer’s private land and there is no question of threatening the ecologically sensitive and high conservation values arises and these farmers land does not fall under any of the Eco-region, biodiversity hot spots or threatened forests. In case of raw material sourcing from government forest, again these area does not fall under Eco region, biodiversity hot spot or threatened forest areas as per latest synthesis report issued

Unspecified Low









by the USAID and latest biodiversity hot spot map of Conservation International. These reserve forest areas are protected under Indian Forest Act-1927 and Forest Conservation Act-1980 (annexure 50). Management / harvesting activities are in compliant with these Acts. Hence, there is no question of threatening of ecologically significant and high conservation value forests. Pulpwood (tree species) is sourced from non-forest areas. Pulp wood species are not grown in these hot spot area and there is no question of procuring the material from that area.



of strong shall be based on the effectiveness of law

In case of sourcing from government forest, these areas are protected under Indian Forest Act 1927, and Forest Conservation Act 1980. Management / harvesting activities are in compliant with these existing Acts and as per the working plan stipulated by the forest department.

Unspecified Low






enforcement in the country. This can be demonstrated through a high rating (≥ 75%) in the World Bank ‘rule of law’ index (www.goindicators.org), and





Findings Risk Level

Unspecified Low


Conversion of forestland to plantation is considered as non-forestry activity as per Forest Conservation Act 1980 (annexure 50) is not allowed, except in case of some developmental activity, which is controlled by the strict evaluation and permission of Central Empowered committee appointed by the Supreme Court of India. There is no record that forestland have been converted to plantations/non-forestry activity in related districts.

Unspecified Low

9 FSC network partners and regional offices (contacts: ic.fsc.org); signatory to the convention on Biological Diversity and demonstrable progress towards completing a network of protect area, such as an overall positive analysis of the latest country thematic report on Forest Ecosystems (www.cbd.int) 10 FAO GOFC-GOLD Global Observation of Forest and Land Cover Dynamics; FAO Global Forest Resources Assessment; CI Regional Analysis Program; University of Maryland Department of Geography; UNEP/GRID – Division of Early Warning and Assessment; SERVIR – Regional monitoring and visualization system for Mesoamerica; Congo Basin Forest Partnership and CARPE; CEC Joint Research Centre; INPE-PRODES – Brazil’s National Institute for Space Research; Hansen, M., DeFries, R., Townshend, J.R., Carroll, M., Dimiceli, C., Sohlberg, R. 2003. 500 m MODIS Vegetation Continuous Fields. College Park, Maryland; The Global Land Cover Facility; National data sources; FSC network partners and regional offices (contacts: ic.fsc.org).


http://www.cbd.int/


The forest cover in India has increased by 21.34 % in last years.( http://fsi.nic.in/isfr-2015/isfr-2015-forest-cover.pdf) There is also significant gain of forest cover in related districts/states as per Forest Survey of India (FSI) latest report (2015) the % Loss of forest cover in these States between 2013-2015, as per FSI report (annexure-51) is - 0.01 %


Findings Risk Level

Unspecified Low



Unspecified Low



Unspecified Low


The Ministry of Environment & Forests, Government of India notified the rules under the Environmental Protection Act 1986 (EPA). No person shall import, export, transport, manufacture, process, use or sell any GMOs, substances or cells except with the approval of the GEAC.

Unspecified Low














2.Taxesandfees













National and sub-national laws and regulations related to theidentification and/or protection of environmental values including but not limited to those relating to or affected by harvesting, acceptable levels for soil damage, establishment of buffer zones (e.g.


along water courses, open areas and breeding sites), maintenance of retention trees on the felling site, seasonal limitations of harvesting time, environmental requirements for forest machineries, use of pesticides and other chemicals, biodiversity conservation, air quality, protection and restoration of water quality, operation of recreational equipment, development of non-forestry infrastructure, mineral exploration and extraction, etc.

3.4Healthand safety


3.5Legal employment


















6.Duediligence/duecare


6.1Duediligence/duecareprocedures


Documents

Public Notification Letter FSC® Chain of Custody Controlled Wood Stakeholder Consultation · 2017-09-08 · Procedure for filing complaints Note: for further details on complaints