ANS Standard for Due Diligence in Procuring/Sourcing Legal Timber

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ANS LTDD 1.0 - 2013 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. 14
ANS LTDD 1.0 - 2013 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. 15
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ANS Standard for Due Diligence in Procuring/Sourcing Legal Timber

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