ANS Standard for Due Diligence in Procuring/Sourcing Legal Timber

ANS LTDD 1.0 - 2013 

ANS Standard for Due Diligence in 

Procuring/Sourcing Legal Timber 

American National Standards Institute, Inc. 

Abstract 

This Standard establishes nationally recognized requirements for compliance with the legal 

requirements in the United States, European Union, Japan, Australia, and other jurisdictions to 

harvest, use, and consume legally harvested timber and the products derived from them. 

This consensus Standard serves to document a common understanding of the best internal 

management system for reducing the risk of illegal timber in the timber supply chain. Entities 

may choose to self-certify or to engage a third party with ISO/IEC 65 credentials to perform an 

independent audit and prove compliance with this Standard. 

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TABLE OF CONTENTS 

SECTIONS 

PAGE 

1. PURPOSE 1 

2. SCOPE 1 

3. DEFINITIONS 1 

4. REQUIREMENTS 3 

4.1 Procurement Policy Statement 3 

4.2 Infrastructure and Control Systems 3 

4.3 Preliminary Determinations 4 

4.4 Due Diligence Evaluation of Legality 5 

4.5 Establishment of Control Procedures 9 

5. INSPECTION and VERIFICATION PROCEDURES 10 

A. APPENDICES (Non-binding information) 11 

A.1 Policy Statement 11 

A.2 Relevant Industry Standards to Maintain 

Coordinator Competency 13 

A.3 Resources for Country Risk Assessments 14 

A.4 Sustainable Forest Certification and 3 rd Party 

Legality Verification 16 

A.5 Examples of Declaration of Legality and Origin 17 

A.6 Examples of Supplier Questionnaire and Purchasing Policies 18 

A.7 Examples of Timber Species References 18 

A.8 Examples of High Risk Suppliers 19 

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FOREWARD 

(This Foreword is not a part of the American National Standard for Due Diligence in Procuring/Sourcing 

Legal Timber. ANS LTDD 1.0 – 2013.) 

This American National Standard for Due Diligence in Procuring/Sourcing Legal Timber, ANS LTDD 1.0 – 

2013, is sponsored by the Hardwood Plywood & Veneer Association (formerly the Hardwood Plywood 

Manufacturers Association) and developed under the Procedures for Development of American National 

Standards. This is the first national consensus Standard for providing a quality assurance program to 

assist in the determination of the legality of timber in global commerce. 

Consensus for this Standard was achieved by use of the “ANSI Essential Requirements: Due Process 

Requirements for American National Standards” and the ANSI accredited HPVA Procedures for the 

Development of American National Standards. The following organizations, recognized as having an 

interest in legal timber and wood products that they purchase or sell and other interested parties, were 

contacted prior to the approval of this Standard. Inclusion in this list does not necessarily imply that the 

organization concurred with the proposed Standard as submitted to ANSI. 

Published by 

Hardwood Plywood & Veneer Association 

1825 Michael Faraday Drive 

Reston, VA 20190 

Telephone: (703) 435-2900 Fax: (703) 435-2537 

Web site: www.hpva.org 

Publication History 

Printing History 

2013 – 5,000 copies 

Copyright © 2012 by the Hardwood Plywood & Veneer Association 

No part of this publication may be reproduced in any form, in an electronic retrieval system or otherwise, 

without prior permission of the publisher. 

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1.0 Purpose 

The purpose of this Standard is to facilitate compliance with legal requirements in the United 

States (U.S.), European Union (E.U.), Japan, Australia, and other jurisdictions to harvest, use, 

and consume legally harvested timber and the products derived from them. 

This consensus Standard serves to document a common understanding of the best criteria for 

establishing a management system to reduce the risk of illegal timber in the timber supply chain. 

Entities may choose to self-certify to this Standard or to engage a third party with ISO 65 

credentials to perform an independent audit and to validate compliance with this Standard. 

2.0 Scope 

This Standard is intended to assist companies in establishing a quality-controlled system to 

significantly reduce or eliminate the risk of illegal timber and wood products entering their supply 

chain and to demonstrate the level of due diligence in controlling that risk. 

The scope of this Standard covers importing, exporting, and inter-state commerce of timber and 

wood products. 

This Standard is neither a chain-of-custody scheme, a legal verification system nor a 

sustainability certification. 

3.0 Definitions 

Applicable Legislation - the legislation in force in the country of harvest at the time of harvest 

that cover: rights to harvest timber within legal boundaries; payments for harvest rights and 

timber including duties related to timber harvesting; stumpage fees; timber harvesting, including 

environmental and forest legislation including forest management and biodiversity conservation, 

where directly related to timber harvesting; third parties‟ legal rights concerning use and tenure 

that are affected by timber harvesting; and trade and customs, in so far as the forest sector is 

concerned. (European Union (EU) Timber Regulation) Processing laws and related regulations 

are outside the intended scope of this standard. 

Chain of custody (CoC) - the chronological documentation or records by a person or 

organization in the course of activities. 

Coordinator - that competent person assigned by the Operator‟s top management to maintain 

the quality control systems according to this Standard. 

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Country of Harvest - the country or territory from which the timber or the timber embedded in 

the timber products was taken or harvested. This definition is to be distinguished from country 

of origin as defined in 19 CFR 134.1 pertaining to customs regulations. 

Document Control System - the means for maintaining the documents and records, digital or 

physical, of an organization from the time they are created up to their eventual disposal. This 

may include classifying, storing, securing, and destruction of records. 

Entity – A business or commercial organization or establishment doing business as a 

corporation, partnership, sole proprietorship or other enterprise. 

EU Timber Regulation - the European Union legal requirements which entered into force on 

December 2, 2010, and will, as of March 3, 2013, make it illegal to place illegally harvested 

timber and timber products on the EU market. See Regulation (EU) No 995/2010. 

Forest Management Unit (FMU) - a clearly demarcated area of land covered predominantly by 

forests, managed to a set of explicit objectives and according to a long-term forest management 

plan. 

Forest Owner – having the legal right to possess woodlands and sell the timber thereon. 

Illegal Logging and its related trade and corruption - when timber is harvested or traded in 

violation of relevant national or sub-national laws or where access to forest resources or trade in 

forest products is authorized or conducted through corrupt practices. 

Lacey Act - United States legislation enacted in 1900 to stop the trafficking of protected wildlife. 

The act was amended in May 2008 to make it unlawful to take, possess, transport or sell lumber 

or wood products in violation of the laws of the United States, a State, Indian Tribe, or any 

foreign law that protects plants; falsify or submit falsified documents, accounts or records of any 

plant covered by the Lacey Act; and import plants and plant products (with some exceptions) 

without an import declaration. 16 USC 53. 

Operator - an entity engaged in importing or exporting wood and/or wood products into the 

international or interstate (United States) stream of commerce. 

Quality Control System - a system in place to verify and maintain a desired level of quality in a 

product or process by careful planning, use of proper equipment, continued inspection, and 

corrective action as required. 

Spatial Risk Assessment - the analysis of geo-referenced data pertaining to some adverse 

outcome such as illegal logs entering a procurement system. The spatial risk map identifies the 

geographic areas that drive the risk, thus aiding in decisions on a remedial course of action. 

Removal of higher risk areas may sufficiently reduce exposure for certain activities. 

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Sustainable Forestry Certification Scheme - a system for certifying that a forest is being 

managed according to the principles of sustainable forest management as defined by the Food 

and Agriculture Organization of the United Nations (FAO) to mean: 

Management of a forest with the aim to ensure that the goods and services derived from 

the forest meets present-day needs while at the same time securing their continued 

availability and contribution to long-term development. In its broadest sense, forest 

management encompasses the administrative, legal, technical, economic, social, and 

environmental aspects of the conservation and use of forests. It implies various degrees 

of deliberate human intervention, ranging from actions aimed at safeguarding and 

maintaining the forest ecosystem and its functions, to favoring specific socially or 

economically valuable species or groups of species for the improved production of 

goods and services. 

Timber - wood products including logs, lumber, veneer, chips, shavings, sawdust, bark, pulp, 

paper and products from these materials excluding recycled products. 

Trader – an entity engaged in the business of buying and/or selling timber and wood products. 

4.0 Requirements - The Operator shall implement a publicly available purchasing policy 

that minimally contains the elements of this section. The Operator may choose to institute an 

established and reputable responsible purchasing policy as long as it minimally includes the 

following elements. See examples in Appendix 6 

4.1 Procurement Policy Statement - The Operator shall prepare a procurement 

policy statement, approved and supported by top management that shall 

minimally include the following: 

4.1.1 Statement as to the scope of the commitment of the company to purchase 

and trade legal timber 

4.1.2 Statement as to the strategy of the company to achieve the goal of 

purchasing and trading 100% legal timber 

4.1.3 Statement as to the sources of timber that are systematically eliminated 

from the supply chain (i.e. unknown or unsustainable sources) 

4.1.4 Statement as to the specific actions taken to reduce the risk of illegal timber 

entering the supply chain (i.e. consequences to suppliers) 

See examples in Appendix A1. 

4.2 Infrastructure and Control Systems - The Operator shall establish a 

quality control system and a designated competent Coordinator to 

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manage the requirements of this Standard (Section 4.2.2). The Operator 

shall establish a document control system to fulfill the document control 

requirements of this Standard (Section 4.2.3). The quality and document 

control systems may be incorporated into a larger audited system used by 

the Entity, such as ISO 9001, ISO 14001. The Operator shall provide 

adequate and competent staff to implement and maintain the control 

systems. The Operator shall appoint an individual, the Coordinator or 

member of top management, to manage the relationships with internal 

and external stakeholders in the procurement policy. 

4.2.1 Coordinator Responsibilities - The Operator shall provide the 

Coordinator with the necessary resources to fulfill the obligations of this Standard 

and maintain his or her competency to relevant industry standards (see 

Appendix A3 or other monitoring organizations). The Operator shall establish a 

responsibility chain so that the Coordinator‟s determinations are supported by top 

management and so that non-compliances can be mitigated efficiently. 

4.2.2 Quality Control System 

4.2.2.1 Database of Suppliers - The Coordinator shall maintain a 

database of suppliers that minimally includes the suppliers‟ identification 

and contact information, certification numbers, legality declarations, 

species handled/supplied, including all component species, and countries 

of timber origin of those species. The same database shall contain the 

result of the risk analysis of that supplier (see Section 4.4.3). 

4.2.2.2 Database of Country/Region Information - The Coordinator 

shall maintain a database of timber source countries with a risk analysis 

of each country using publicly available information such as found in 

Appendix A2. The Coordinator shall stay informed of developments in 

the region(s) and update the database accordingly. 

4.2.2.3 Current Reference Material - The Coordinator shall maintain 

current reference material according to the document control system 

(Section 4.2.3). 

4.2.3 Document Control System - The Operator shall establish and maintain 

a document control system to ensure the current status of all documents and 

references required by this Standard. The Coordinator shall establish expiration 

and review periods for each type of document or record and maintain a 

corresponding list. Reference materials shall be included in the document 

control system. 

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4.3 Preliminary Determinations - The Operator shall make preliminary 

determinations of all suppliers, all species, and all potential countries of origin, 

upon the implementation of this Standard. 

4.3.1 Sustainable Forest Management (SFM) Certified Timber - The Operator 

shall determine if the timber supplier is currently certified to Forest Stewardship 

Council (FSC), Programme for the Endorsement of Forest Certification (PEFC), 

Sustainable Forestry Initiative (SFI), American Tree Farm System (ATFS) or 

another SFM certification scheme approved by top management. This 

determination shall be verified by checking the certification number on the 

Internet. The number and verification shall be logged in the supplier database 

annually. If the SFM certification is current, the Coordinator may approve the 

purchase from the supplier. (see Appendix A4) 

In the case of a timber supplier that is not the primary source (not in control of the 

forest management unit from which the timber came), but is a trader, the trader 

must have a valid chain-of-custody to support the claim that the timber originated 

from a certified source. 

The Operator shall not pass on a certificate of sustainable forestry without first 

having the corresponding chain-of-custody certificate. Checking the validity of a 

sustainable forestry certificate serves to reduce the risk of false claims, however, 

without a chain-of-custody, risk remains that a supplier may make a false claim 

as to the origin of the supplied timber. 

Notwithstanding the verifications described above, a review of legal risk reports 

of the applicable SFM certification scheme shall also be undertaken. 

4.3.2 Third Party Legally Verified Timber - The Operator shall, in the absence 

of an SFM certificate, determine if the timber supplier has a 3 rd party legality 

verification from a system listed in Appendix A4 or another legality verification 

scheme approved by top management. This determination shall be verified by 

checking the certification number on the Internet. The number and verification 

shall be logged in the supplier database. If the 3 rd party legality verification is 

current, the Coordinator may approve the purchase from the supplier. 

4.3.3 Non-certified/3rd Party Verified Timber - Timber may have legality 

verification from an independent inspection organization that declares that no 

illegal timber is entering the supply chain. Upon approval of the competency of 

the inspection organization, the Coordinator may approve the purchase from the 

supplier. 

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4.3.4 Non-3rd Party Verified Timber -Timber with no 3 rd party certification or 

verification of legality shall undergo a due diligence evaluation of legality as 

described in Section 4.4. 

4.4 Due Diligence Evaluation of Legality - A due diligence evaluation of legality 

shall be completed in the absence of a current SFM or third-party legality 

verification. A due diligence evaluation of legality shall include a spatial risk 

assessment of the country of harvest, a legality requirements determination, a 

preliminary risk assessment of the supplier, and collection of documentation. 

4.4.1 Spatial Risk Assessment of Country and Region - Top management 

shall determine the risk rating (Very High, High, Medium, or Low) of each 

source country and region based on the accumulated information in the 

Country/Region database (Section 4.2.2.2). This determination and its 

basis shall be documented. 

Very High Risk countries or regions shall be eliminated from the supply chain. 

The operator may purchase supplies from Low Risk source countries or regions, 

provided documentation of contract or bill of sale from a forest owner, chain of 

custody, legal timber risk assessments, trip tickets, or other relevant evidence is 

obtained. 

4.4.2 Preliminary Risk Assessment of Suppliers - The Coordinator shall 

complete a preliminary risk assessment of all suppliers with uncertified, 

non-verified timber originating from Medium or High Risk countries or 

regions. The Coordinator shall request that the supplier notify the Entity of 

any changes in the sourcing information provided. 

4.4.2.1 If the procurement by the supplier is within the country of harvest, 

and none of the exclusionary factors listed in 4.4.2.2 are present, then the 

Coordinator shall collect the following documents from the supplier: 

Logging permit 

List/map with the valid concession or harvest title 

Forest Management Plan approval 

Proof of tax payment 

as well as any additional documents according to applicable legal 

requirements (Section 4.4.4) 

4.4.2.2 If the procurement by the supplier is not within the country of 

harvest, and none of the following factors are evident: 

Timber originating from areas associated with human rights 

violations, armed conflict or violation of UN sanctions 

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Timber from areas where open conflict exists between 

communities, worker groups, concession managers and/or 

government forces 

Any suspicion that timber originates from Protected Areas, 

National Parks or other illegal sources 

Suppliers that are suspected to be involved in armed conflict or 

illegal logging 

Species on CITES list Appendix I 

Species on CITES list Appendices II or III or partially protected by 

national law without compliant permits, 

then the Coordinator shall collect a questionnaire and legality declaration 

from the supplier that shall serve as a part of the commercial warranty 

between the supplier and the Operator. (see Appendices A4 and herein) 

If any of the preceding exclusionary factors are present, the timber shall 

be excluded from the supply chain. 

4.4.2.3 When the supplier is merely an intermediary between the 

forest/mill and the Entity, every effort should be made to ensure that the 

forest/mill is answering the questionnaire directly. 

The Coordinator shall ensure that the Preliminary Risk Assessment steps 

are carried out for all forest sources included in the timber products. 

4.4.3 Secondary Risk Assessment of Suppliers - The Coordinator shall use 

the information supplied in the preliminary risk assessment to make a 

recommendation to top management as to the risk level of the supplier 

(High, Medium or Low Risk) according to their likelihood of supplying 

illegal timber. Factors such as deep discounts, cash transactions, past 

illegality, reputation, targets of Non-Government Organizations (NGO) 

reports or new entrants shall be taken into consideration when evaluating 

the supplier. 

Top management shall determine the risk rating of each supplier based 

on the accumulated information and recommendation of the Coordinator. 

High Risk suppliers shall be eliminated from the supply chain. Medium 

and Low Risk suppliers shall be engaged by the Coordinator in a control 

procedure to include paper and/or physical audits as appropriate to the 

risk level. (see Section 4.5.2.3) 

The Operator shall develop an improvement program with the 

supplier including firm targets. Medium to Low Risk suppliers that do not 

cooperate with the audit/improvement program shall be eliminated from 

the supply chain. Procurement may continue with cooperating suppliers. 

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The following requirements are intended for suppliers in the Medium and 

Low Risk categories sourcing timber from Medium and High Risk 

countries. 

4.4.4 Legality Requirements Determination of Country/Region/FMU - 

A list of legal requirements of the timber source countries or regions is 

important for: 

The documentation request of the Preliminary Risk Assessment of 

Suppliers (Section 4.4.2.1) 

The improvement programs for Medium and Low Risk suppliers 

procuring outside the country of harvest (4.5.3) 

The Coordinator shall maintain a database of legal requirements of the 

timber source countries or regions. Legal requirements may be limited to 

those pertaining to forest management and/or those relevant to 

stakeholder concerns. A list of species handled, including component 

species, and their likely countries of origin shall be maintained to limit or 

expand the analysis of legal requirements according to the Operator‟s 

handled species. (see Appendix A4 for resources.) 

A legal review based on the laws of the country may be performed by 

local legal counsel with expertise both in forestry and export laws. This 

legal review combined with a thorough review of all the appropriate 

documentation can be used to establish the legality of the initial 

ownership with the right to sell, harvest, transport, and export. 

Legal requirements may be unclear because of conflicting 

local/national/international laws. In these instances the Coordinator shall 

note the conflict and document the basis for the legal determination in the 

database. 

4.4.5 Collection of Documentation - For procurement outside the country of 

harvest, the Coordinator shall collect a questionnaire and legality 

declaration to determine the risk rating of the supplier on an annual basis. 

The following document verification procedure shall be considered in 

determining the risk of the supplier. 

For procurement inside the country of harvest, the Coordinator shall 

determine the fulfillment of legality requirements by collecting objective 

evidence and completing the following document verification procedure: 

4.4.5.1 Legal Right to Harvest 

The Coordinator shall collect/conduct the following: 

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The position of the known source forest on a map 

The harvesting/logging permit and authorization of forest 

owner or concession licensee 

4.4.5.2 Legal Compliance of Harvest - The Coordinator shall collect/ 

conduct the following: 

Approved management plan or equivalent consulting 

forester best management plan 

Specification of applicable harvesting restrictions 

Evidence (map/records) showing harvesting from the 

designated harvest area (audit by paper or on-the-ground 

as necessary based on risk per Section 4.5.2) 

Records showing yield figures, volumes and species for 

evidence of harvesting rate compliance such as Bills-of- 

Lading (audit by paper or on-the-ground as necessary 

based on risk per Section 4.5.2) 

Professional harvest certificate 

Sales and purchase contracts 

Evidence of fee payment for harvesting 

Evidence of compliance with harvesting permit/contract 

Current list of species harvested (to compare with CITES 

list) 

Bill of Lading or trip tickets to show compliance with timber 

transport regulations 

Records and photos to show compliance in harvesting 

with, for example: 

o water protection zones 

o skid trails 

o stream crossings 

• Conduct audits (see Section 4.5.2) 

Any evidence of a dispute over the right to harvest shall be 

investigated and purchases put on hold until the dispute is 

satisfactorily resolved. Determinations shall be documented in 

every case. 

The Coordinator shall be competent to identify evidence of fraud 

and other falsehoods in the documents (see examples in 

Appendix A8) 

4.5 Establishment of Control Procedures - Establishment of control procedures 

including document retention and renewal, audits, and improvement programs 

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shall be completed in the absence of a current SFM or third-party legality 

verification. 

4.5.1 Document Retention and Renewal - A document control program shall 

be written that instructs the Coordinator in retaining and renewing 

documents according to their type. 

A new questionnaire shall be required of suppliers providing new 

product(s). 

Questionnaires and timetables of Medium- to Low-Risk suppliers shall be 

updated according to the established timetable. 

Confidentiality agreements may be a necessary part of each 

questionnaire. 

4.5.2 Control Procedures - Control procedures including audits shall be 

relevant to the risk. The level of verification procedure (document audits 

or on-the-ground audits) shall correspond to the level of risk that the 

supplier is trading in illegal timber, in order to keep the Operator‟s supply 

chain legal. For example, a Low-Risk supplier in a Medium-Risk country 

might have his audits tailored to the specific timber management - related 

risks of that country or region. 

4.5.3 Improvement Programs 

The preliminary assessment of the supplier will reveal gaps in supply 

chain management. These areas shall be the focus of an improvement 

program. Targets and objectives shall be established for suppliers who 

provided weak responses to the questionnaires but who are not 

considered to be very High Risk. The targets and objectives of the 

improvement program shall be specific, measurable, achievable, realistic, 

and time-bound. Mitigation must be adequate and proportionate to 

minimize the identified risk. Progressive follow-up inspections are 

required and consequences, including removal from the list of approved 

suppliers, shall be included in the program. 

The Coordinator shall document all stages of each supplier‟s individual 

improvement program. 

5.0 Inspection and Verification Procedures - The Operator shall develop and maintain a 

quality control procedure for this program including an annual report of supplier progress 

toward objectives and targets as well as an annual report of the Operator‟s progress 

toward its internal objectives and targets. 

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APPENDICES 

The following Appendices are not a part of the ANSI Standard for Due Diligence in 

Procuring/Sourcing Legal Timber but are included for information purposes only. 

A1. Policy Statement 

The United States Congress passed an amendment to the Lacey Act in 2008, which impacts the 

importation and interstate sale of wood and other plant products in an effort to combat illegal 

logging. These amendments subject violators to severe criminal and civil penalties which may 

include imprisonment. The legislation provides that individuals and companies shall not “import, 

export, transport, sell, receive, acquire or purchase” any plant (including wood and wood 

products) that has been illegally removed from its place of origin. It applies to all species of 

wood. 

The European Union‟s Timber Regulation went into force on December 2, 2010 and will also 

make it illegal to place illegally harvested timber and timber products on the EU market effective 

March 3, 2013. 

The Japanese government has implemented a policy to prevent the government purchase and 

use of wood materials harvested illegally. The system requires confirmation that the timber is 

from legally harvested forests. Effective July 1 2006, any wood products purchased in Japan will 

have to hold certification issued by groups such as environmental non-government 

organizations (ENGOs) or Japanese timber organizations, proving that the wood was harvested 

legally. 

Australia has similar legislation pending in 2012 requiring trade in legally harvested timber and 

timber products in Australia. 

These laws have common characteristics. In general, they: 

Prohibit all trade in timber and wood products that are illegally sourced from any U.S. state, 

province or foreign country 

Require importers to declare the origin and species name of all wood contained in their 

products 

Establish penalties for violation of the law, including forfeiture of goods, fines or jail time or 

seizure of transportation vehicles and equipment in the most serious cases 

These laws apply to every person and company involved in the interstate and international 

commerce of wood products. Manufacturers, importers, distributors, retailers, contractors, and 

even individuals must comply with these new rules of business. It is important to note that the 

Lacey Act and the E.U. Timber Regulation provide some enforcement relief for persons and 

companies who exercise “due care” in verifying that wood is legally harvested. 

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(NAME OF COMPANY) is firmly committed to the legal trade of wood products. As such, we 

expect the same commitment from our suppliers. We will not knowingly purchase or use wood, 

wood fiber or products for distribution that originate from illegal logging. 

To implement these legal requirements, we have contacted all of our associated suppliers and 

verified the materials sourced are in compliance with applicable legal wood standards. (NAME 

OF COMPANY) is committed to making best efforts to identify the sources of wood used in the 

manufacture and sale of our products but recognizes the difficulty in achieving 100% certainty. 

We expect the complete cooperation and responsiveness from each of our suppliers. 

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A2. Relevant Industry Standards to Maintain Coordinator Competency – There should be a 

written procedure that describes how training and qualification of personnel are determined, 

delivered, and documented. It should define the requirements for the identification and delivery 

of necessary training to meet the requirements of Sections 4.0 and 5.0 of the ANSI Standard for 

Due Diligence in Procuring/Sourcing Legal Timber. 

The Operator‟s top management supervising the Coordinator should be responsible for: 

Maintaining a list of individuals authorized to perform specific inspections, requests and 

analyses 

Identifying skills or tasks that require training 

Maintaining a list of operations and activities that require training 

Establishing training requirements for each procedure and work instruction requiring 

training 

Determining the content of training sessions 

Establishing and maintaining training schedules to ensure that employee training is 

current 

The Operator‟s top management supervising the Coordinator is responsible for establishing and 

maintaining a training schedule and training records with respect to the Quality Manual and 

Quality Procedures. 

Training should include sessions addressing all aspects of the Due Diligence Management 

System including the quality policy, quality manual, quality procedures, inspection and 

conducting risk assessments, information solicitation methods, work instructions, and records. 

Training and orientation of newly hired employees should include the subjects in Sections 4.0 

and 5.0 within thirty days of the hire date. Employees should receive training within thirty days 

of the initial issue or revision issue of quality documents, including those types listed in 4.0 and 

5.0. 

Technical proficiencies for inspections, risk assessments and information solicitation performed 

as part of the quality system should be determined and documented by the Operator‟s top 

management supervising the Coordinator. Satisfactory completion of training may be 

evidenced by use of written “open book” tests, verbal tests or demonstrations of competence 

witnessed and attested by the Operator‟s top management supervising the Coordinator. 

Each employee performing inspections and test methods should demonstrate proficiency in the 

requirements annually. Records of individual proficiency should be maintained. A records 

retention policy should also be established. Quality system training content and frequency is 

based upon Operator‟s top management supervising the Coordinator„s recommendations to 

meet the objectives of the due diligence quality system. 

REFERENCES 

ISO Guide 65, par 4.5, 4.8 4.9, and 5.0 

ISO 17020 par 6, 8, and 10 

ISO 17025 par 4.1.5 and 5.2 

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A3. Resources for Country Risk Assessments 

Central Point of Expertise for Timber Procurement maintains lists of UN Sanctions against 

timber producing countries. It also indicates the status of countries with the EU FLEGT 

Voluntary Partnership Agreements (full implementation, development, negotiation, information). 

www.cpet.org.uk/eutr 

Chatham House features Consumer Country Policy initiatives including the status of EU 

FLEGTVPAs. See also “Illegal Logging and Related Trade: Indicators of the Global Response,” 

July 2010, Sam Lawson, Larry MacFaul, Chatham House (data from 2006 -2009). 

www.chatthamhouse.org 

CITES list annex I, II, and III 

Appendices I, II, and III to the Convention are lists of species afforded different levels or types of 

protection from over-exploitation. The CITES Trade Database, managed by UNEP-WCMC on 

behalf of the CITES Secretariat, is a unique resource and currently holds more than 10 million 

records of trade in wildlife and 50,000 scientific names of taxa listed by CITES. Currently, more 

than 750,000 records of trade in CITES-listed species of wildlife are reported annually. 

http://www.cites.org/eng/app/index.php; http://www.cites.org/eng/resources/species.html 

Forest Legality Alliance provides a simple, interactive online risk assessment tool developed 

by the Tropical Timber Action Plan that outlines four steps to help companies assess their risk 

of inadvertently buying illegally produced timber products. 

http://www.forestlegality.org/tools-guides/ttap-risk-assessment-tool 

illegal-logging.info is a website which provides information on the key issues in the debate 

around illegal logging and the trade in illegal timber, via news stories and key documents, as 

well as details of relevant events and links to other relevant websites. Funded by UKaid from the 

Department for International Development with additional support from the European Forest 

Institute's EU FLEGT Facility. The EU FLEGT Facility is funded by the European Union, the 

Governments of Finland, France, Germany, the Netherlands, United Kingdom, and the 

European Forest 

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

International Labor Organization’s main aim is to promote rights at work, encourage decent 

employment opportunities, enhance social protection, and strengthen dialogue on work-related 

issues. 

www.ilo.org 

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Risk Awareness Tool for Multinational Enterprises in Weak Governance Zones aims to 

help companies that invest in countries where governments are unwilling or unable to assume 

their responsibilities and developed by OECD. 

http://www.oecd.org/investment/investmentpolicy/36885821.pdfhttp://www.oecd.org/investment/i 

nvestmentpolicy/36885821.pdf 

The Global Forest Registry maintained by the Forest Stewardship Council is a free source of 

information on the risk of sourcing controversial timber throughout the world. 

http://www.globalforestregistry.org/map 

Transparency International provides a website for the Corruption Perception Index with scores 

conducted on an annual basis by Transparency International. 

http://cpi.transparency.org/cpi2011/results/ 

http://gcb.transparency.org/gcb201011/infographic/cpi.transparency.org (/cpi2011) 

World Wildlife Fund Global Forest Trade Network provides a website with information about 

participants in WWF‟s Global Forest Trade Network. Useful papers that are available include: 

Framework for Assessing Legality of Forestry Operations, Timber Processing and Trade, 

October 2009, WWF 

Exporting in a Shifting Landscape, 18 June 2010, G. White, WWF 

GFTN‟s Guide to Legal and Responsible Sourcing, 17 June 2010, 

http://sourcing.gftn.panda.org/index 

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A4. Sustainable Forest Certification and Third Party Legality Verification 

American Tree Farm System 

http://www.treefarmsystem.org/ 

Forest Stewardship Council 

http://www.fsc.org/ 

Malaysian Timber Certification Council 

http://www.mtcc.com.my/ 

National Wood Flooring Association: Responsible Procurement Program 

http://www.nwfa.org/member/rpp.aspx 

OLB (Origine et Légalité du Bois) 

http://www.groupesefac.com/fra/p=757 

Programme for the Endorsement of Forest Certification 

http://www.pefc.org/ 

Rainforest Alliance Timber Legality Verification 

http://www.rainforest-alliance.org/forestry/verification/legal 

SmartwoodVLO (Verified Legal Origin) 

http://www.rainforest-alliance.org/forestry/certification/ 

Sustainable Forestry Initiative 

http://www.sfiprogram.org/ 

Timber Legality and Traceability Verification 

http://www.proforest.net/objects/publications/review-of-timber-legality-verification-schemes 

Timber Trade Federation , 

http://www.ttf.co.uk/Environment/Third_Party_Schemes.aspx 

World Wildlife Fund Global Forest Trade Network 

http://sourcing.gftn.panda.org/index 

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A5. Example of Declaration of Legality and Origin 

SELLER HEREBY REPRESENTS, WARRANTS, AND CERTIFIES THAT ALL WOOD AND PLANTS, INCLUDING 

THOSE FROM WHICH THE PRODUCTS MAY BE DERIVED, PURCHASED, AND SOLD PURSUANT TO THIS 

AGREEMENT: 

HAVE BEEN HARVESTED, TAKEN, POSSESSED, TRANSPORTED, AND 

SOLD IN COMPLIANCE WITH ALL LAWS, TREATIES AND 

REGULATIONS OF THE UNITED STATES AND ANY INDIAN TRIBAL 

LAW 

HAVE BEEN HARVESTED, TAKEN, ACQUIRED, POSSESSED, 

TRANSPORTED, SOLD, AND PURCHASED IN COMPLIANCE WITH ALL 

FOREIGN AND STATE LAWS, TREATIES, AND REGULATIONS THAT 

PROTECT OR REGULATE 

o PLANTS AND TREES OR WOOD, 

o THE THEFT OF PLANTS, TREES OR WOOD, 

o THE TAKING OF PLANTS, TREES OR WOOD FROM PARKS, 

FOREST RESERVES, OFFICIALLY PROTECTED OR 

OFFICIALLY DESIGNATED AREAS, OR 

o THE TAKING OF PLANTS, TREES OR WOOD WITHOUT, OR 

CONTRARY TO, REQUIRED AUTHORIZATION; AND 

o HAVE BEEN TAKEN, POSSESSED, TRANSPORTED AND SOLD 

IN COMPLIANCE WITH ANY LIMITATION UNDER ANY LAW OR 

REGULATION OF ANY STATE OR UNDER ANY FOREIGN LAW, 

GOVERNING THE EXPORT OR TRANSSHIPMENT OF PLANTS 

AND WOOD. 

SELLER HEREBY FURTHER REPRESENTS, WARRANTS. AND CERTIFIES THAT ALL APPROPRIATE 

ROYALTIES, TAXES, AND STUMPAGE FEES REQUIRED BY ANY LAW OR REGULATION OF ANY STATE OR 

ANY FOREIGN LAW FOR THE PLANTS AND WOOD, INCLUDING THOSE FROM WHICH THE PRODUCTS MAY 

BE DERIVED, TAKEN, POSSESSED, TRANSPORTED, PURCHASED, AND SOLD PURSUANT TO THIS 

AGREEMENT HAVE BEEN PAID. 

Name: 

Signature 

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A6. Sources of Supplier Questionnaires and Purchasing Policies 

A.6.1 Example of a Supplier’s Questionnaire and Check List - The GFTN Guide to Legal 

and Responsible Sourcing, 

World Wildlife Fund 

http://sourcing.gftn.panda.org/index.phpid=20 

http://sourcing.gftn.panda.org/index.phpid=59#questionnaires 

http://sourcing.gftn.panda.org/files/PDF/Example_Questionnaire_1.pdf 

A.6.2 Sample Checklist of Questions 

1. Does supplier have long standing relationship with the supplier/s (exporter) of this product 

How long 

2. Does the supplier/s of this supplier buy this product from “spot markets” 

3. Does supplier regularly question their suppliers regarding the origin of this product 

4. Did supplier provide you with all required documentation 

a. For non high risk countries, a written and signed document from supplier identifying 

companies included in the full supply chain of the product back to the harvesting 

entity/ies, including name and location of the harvesting entity/ies and Forest 

Management Unit. 

b. A list of supplying companies harvesting wood from source forests and copies of the 

association harvesting permits for supplied product and/or other form of authorization 

from the forest owner, including, for example: 

c. Species, district of origin information and any other related harvesting or purchasing 

agreements. 

d. Evidence of compliance with timber transportation documents: Copies of transport or 

sales permits with specification of species and volumes as applicable. 

5. Have you reviewed the documents and verified that they meet the due diligence 

requirements 

6. Is there any reason for supplier to believe that paperwork from their suppliers may not be 

authentic for this product 

7. Is there a ban on exports from this region/country 

8. Have you checked on approved species/products with State/Province for that supplier, 

(etc.) 

9. Have you retained copies of required documentation 

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10. Is this supplier sourcing from a high risk country 

11. If yes, verify that additional required procedures were followed, e.g., 

a. product is certified against a Chain of Custody or Traceability Standard, 

b. the supplier certificate is valid and the scope includes the product supplied, 

c. the product has been traced along an unbroken and verified chain of custody from 

the purchaser back to the source entirely by obtaining supplier certification codes on 

documentation for that product down to forest level, and 

d. the harvest and export of the species is not restricted or prohibited in the source 

country. 

Source: U.S. Department of Justice, United States Attorney Middle District of Tennessee, In Re: 

Gibson Guitar Corporation, July 27, 2012, Appendix B, Attachment A. 

6.3 Examples of reputable, responsible purchasing policies: 

The Global Forest and Trade Network 

http://www.wwf.org.uk/what_we_do/safeguarding_the_natural_world/forests/responsible_forestr 

y_and_trade/forest_trade_network/ 

UK Timber Trade Federation 

http://www.ttf.co.uk/ 

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A7. Examples of Timber Species References 

World Customs Organization, Harmonized Commodity Description and Coding System, Chapter 

44, Annex 44 – Appellation of Certain Tropical Wood Species: Africa and other tropical woods 

http://www.wcoomd.org 

Wood Handbook: Wood as an Engineering Material, U.S. Forest Service 

www.fpl.fs.fed.us/products/publications/several_pubs 

Tropical Woods of the World, U.S. Forest Service 

www.fpl.fs.fed.us/research/centers/woodanatomy/techsheets 

Manual of the Trees of North America, Charles Sprague Sargent 

key in Charles Sprague Sargent 

American Woods, Shelley E. Schoonover 

key in Shelley E. Schoonover 

Veneer Species of the World, U.S. Forest Service 

www.fpl.fs.fed.us/research/centers/woodanatomy/techsheets 

Commercial Foreign Woods on the American Market, David A. Krips 

www.amazon.com/Commercial-foreign-woods-American-market 

Identifying Wood, R. Bruce Hoadley 

www.woodmagazine.com/community/persona/woodworker-biography-r-bruce-hoadley 

Timber Monographs, Edmondo Palutan 

www.books.google.com/books/about/Timber_Monographs 

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A8. Examples of High Risk Supplies 

• Goods significantly sold below going market rate 

• Cash only/lower price for goods without paperwork 

• Paperwork facially invalid or otherwise suspect 

• Unusual sales methods or practices 

• Transactions fit the description of illegal transactions discussed in trade/industry 

publications 

• Inability of suppliers to provide rational answers to routine questions 

• Bills of lading that exceed the timber allowances in the relevant permit 

• Documents that do not have matching PO numbers or some other identifier that is 

consistent 

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ANS Standard for Due Diligence in Procuring/Sourcing Legal Timber

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