ANS Standard for Due Diligence in Procuring/Sourcing Legal Timber

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ANS LTDD 1.0 - 2013 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 10
ANS LTDD 1.0 - 2013 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. 11
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ANS Standard for Due Diligence in Procuring/Sourcing Legal Timber

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