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    SGS QUALIFOR

    (Associated Documents)

    Doc. Number: AD 54-F-06

    Doc. Version date: 17 April 2009

    Page: 1 of 16

    CONTROLLED WOOD RISK ASSESSMENT REPORT

    INTRODUCTION

    This document must be used with the RD 15-01 - Guideline - Approach and criteria for assessing riskwhen uncertified controlled wood is used in FSC certified products and FSC-ADV-40-016 V2 -Implementation of FSC Controlled Wood requirements in FSC STD-40-005 V2-1 and FSC-STD-20-011V1-1.

    This template is a guideline to do the risk assessment and must not be seen to include all information.Any other sources of information may be added to ensure that all detail were analysed.

    This assessment must be done on origin of uncertified wood that will be used in FSC products ascontrolled wood.

    If it is determined that the material is classified as being from a source that is classified as unspecifiedrisk, the requirements of the RD16 - Guideline - Requirements for company verification program must befollowed. This will be audited annually.

    Note: This document details all the elements that are required to do the risk assessment. However, thedocument is divided into a Restricted Information section and a Public Information section. Only theinformation recorded in the Public section will be available on the FSC website. The information in theRestricted section will be covered by the SGS rules of confidentiality and will not be disclosed.

    The Risk Assessment requires a precautionary approach. Any area worldwide is therefore considered

    unspecified risk until low risk can be determined in line with the risk assessment set out hereunder(refer Section 1.1 of FSC-STD-40-005)

    The following is important:

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    RESTRICTED INFORMATION

    1. COMPANY DETAIL

    Company name York Timbers (Pty) Ltd

    Certificate number: SGS-COC-008395

    Controlled wood Certificate number SGS-CW-008395

    Country: South Africa

    Company address Physical Address:

    1 Milkwood streetSabie1260

    Mpumalanga

    South Africa

    Contact detail: Contact person: D. Malloch-Brown

    Telephone: 013 764 9237

    Fax: 013 764 3555

    e-mail Address [email protected]

    Assessment done by: D. Malloch-Brown

    Relation to the company: Resource Development Manager

    Date: 19 November 2011

    Signature

    mailto:[email protected]:[email protected]:[email protected]
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    Country: South Africa

    District: Mpumalanga

    Company Name: De Witt Trust

    Country: South Africa

    District: Mpumalanga

    Company Name: Erasmushoop

    Country: South Africa

    District: Mpumalanga

    Company Name: Gradely Farms

    Country: South Africa

    District: Mpumalanga

    Company Name: Steenkamp

    Country: South Africa

    District: Mpumalanga

    Company Name: Tony Mason (Milikin)

    Country: South Africa

    District: Mpumalanga

    Company Name: United Forest Products

    Country: South Africa

    District: Mpumalanga

    Company Name: Zonstraal Boerdery

    Country: South Africa

    District: Mpumalanga

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    3. LIST OF COUNTRIES AND DISTRICTS OF ORIGIN

    List the countries and districts of origin of timber supplied within the companys FSC ControlledWood Program.

    Product Species District Country

    Pine logsPinus taeda Loblolly PinePinus elliottii Slash Pine

    Pinus patula

    Mpumalanga

    Kwazulu Natal

    South Africa

    Eucalyptus logs Eucalyptus nitens

    Eucalyptus grandis

    Eucalyptus maccarthurii

    Mpumalanga

    Kwazulu Natal

    South Africa

    4. SUPPLY CHAIN

    Manufacturers or traders that wish to control their timber sources within their own verificationprogram shall demonstrate to the satisfaction of their certification body that its supply chain is

    identifiable and traceable down to the district (forest) level.

    Company Process Input and origin Controlled system verified

    AG Muller Timber grower. Sale ofround logs

    Timber Grower in SouthAfrica Selling to York

    Supply agreement with the timbergrower to supply timber directlyfrom the FMU to the York mill. Noother handling of the timber

    Avalon Farm Timber grower. Sale of

    round logs

    Timber Grower in South

    Africa Selling to York

    Supply agreement with the timber

    grower to supply timber directlyfrom the FMU to the York mill. Noother handling of the timber

    Breytenbachskraal Timber grower. Sale ofd l

    Timber Grower in SouthAf i S lli t Y k

    Supply agreement with the timbert l ti b di tl

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    Company Process Input and origin Controlled system verified

    Gradely Farms Timber grower. Sale ofround logs

    Timber Grower in SouthAfrica Selling to York

    Supply agreement with the timbergrower to supply timber directlyfrom the FMU to the York mill. Noother handling of the timber

    Steenkamp Timber grower. Sale ofround logs

    Timber Grower in SouthAfrica Selling to York

    Supply agreement with the timbergrower to supply timber directlyfrom the FMU to the York mill. Noother handling of the timber

    Tony Mason (Millikin) Timber grower. Sale of

    round logs

    Timber Grower in South

    Africa Selling to York

    Supply agreement with the timber

    grower to supply timber directlyfrom the FMU to the York mill. Noother handling of the timber

    United Forest Products Timber grower. Sale ofround logs

    Timber Grower in SouthAfrica Selling to York

    Supply agreement with the timbergrower to supply timber directlyfrom the FMU to the York mill. Noother handling of the timber

    Zonstraal Boerdery Timber grower. Sale ofround logs

    Timber Grower in SouthAfrica Selling to York

    Supply agreement with the timbergrower to supply timber directly

    from the FMU to the York mill. Noother handling of the timber

    The following harvestingcontractors are used (allin South Africa):

    GDH harvesting

    Mountain View

    Dave Logging

    Silver Cherry

    Log-X

    Bosbok Ontginning

    Harvesting contractorsfelling and log making

    Harvesting under contractonly

    No movement of timber.Transporters are contracted tomove the timber from the FMU tothe York Mill.

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    SGS Qualifor auditor: N. Knibbs

    Comments: Approved

    Date: 23/11/2011

    Signature

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    PUBLIC INFORMATION

    A APPROVAL

    Approving Certification Body: SGS South Africa (Pty) Ltd - Qualifor Programme

    PO Box 82582SouthdaleSouth Africa2135

    E-mail Address: [email protected]

    Date of Risk Assessment 19 November 2011

    Comments: Approved

    Date Approved: 23 November 2011

    B ORIGIN OF TIMBER

    Country: South Africa

    District Mpumalanga, Natal,

    Risk Assessment Level

    (indicate the risk for the differentlevels)

    Country District FMU

    Unspecified Risk Low Risk Low Risk

    C. RESULT OF RISK ASSESSMENT

    Type of source e.g. natural forestor plantations and generaldescription of the supplier

    The timber suppliers all have commercial exotic plantation forestry,and are all licensed by the government (legal requirement).

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    SPECIFIC REQUIREMENTS FOR EACH FSC CONTROLLED WOOD CATEGORY

    1. ILLEGALLY HARVESTED WOOD

    1.1 The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forestgovernance are present:

    NOTE: FSC-STD-40-005 V2-1 requires a precautionary approach by companies when assessing risk. This means that if there is lack ofinformation on corruption for the forestry sector, a country/district shall be defined as unspecified risk for the referenced indicator and therefore forthe whole Controlled Wood category

    Requirements Examples of sources of information

    Finding & Evidence

    (FSC-ADV-40-016 v2 - Sources ofinformation used to assess theindicators must be listed)

    Result

    Unspecifiedrisk

    Low

    1.1.1 Evidence of enforcement oflogging related laws in thedistrict

    FSC National Initiatives (contacts fromwww.fsc.org);

    http://www.Transparency.org

    The Royal Institute of International Affairs(www.illegal-logging.org);

    Environmental Investigation Agency (www.eia-international.org);

    Global Witness: (www.globalwitness.org);

    Telapak (for Indonesia -www.telapak.org);

    UK Governments Department for InternationalDevelopment (DFID)

    EU FLEGT process:

    http://ec.europa.eu/comm/development/body/theme/forest/initiative/index_en.htm

    Transparency international index(www.transparency.org) Corruption perceptions

    WWF (www.panda.org);

    ELDIS (www.eldis.org) regional and countryprofiles

    www.cites.org

    No illegal logging takes place within Yorkssupply. York buys the timber directly fromthe legal owner of the property. Since Yorkcontrols the harvesting and transport, thereis no danger of this timber getting mixedwith illegally harvested logs.

    Low risk

    1.1.2 There is evidence in thedistrict demonstrating thelegality of harvests and woodpurchases that includes robustand effective systems forgranting licenses and harvest

    permits.

    York has a robust framework is in place tocontrol any outside purchases. Purchaseagreements are in place prior to any logsupply and all suppliers either haveplanting permits or plantations that were

    planted before 1972. York mills follow aCOC system that identifies sources oftimber.

    No licencing or Harvest permits systemexists due to all timber being commerciallygrown by private growers.

    Furthermore dedicated York staff isappointed in the Logistics dept. who dealwith the controlled wood sources and thelogistical flow of timber from our sources.

    Low Risk

    http://www.fsc.org/http://www.fsc.org/http://www.transparency.org/http://www.transparency.org/http://www.illegal-logging.org/http://www.illegal-logging.org/http://www.illegal-logging.org/http://www.eia-international.org/http://www.eia-international.org/http://www.eia-international.org/http://www.eia-international.org/http://www.globalwitness.org/http://www.globalwitness.org/http://www.globalwitness.org/http://www.telapak.org/http://www.telapak.org/http://www.telapak.org/http://ec.europa.eu/comm/development/body/theme/forest/initiative/index_en.htmhttp://ec.europa.eu/comm/development/body/theme/forest/initiative/index_en.htmhttp://ec.europa.eu/comm/development/body/theme/forest/initiative/index_en.htmhttp://www.transparency.org/http://www.transparency.org/http://www.transparency.org/http://www.panda.org/http://www.panda.org/http://www.panda.org/http://www.eldis.org/http://www.eldis.org/http://www.eldis.org/http://www.cites.org/http://www.cites.org/http://www.cites.org/http://www.eldis.org/http://www.panda.org/http://www.transparency.org/http://ec.europa.eu/comm/development/body/theme/forest/initiative/index_en.htmhttp://ec.europa.eu/comm/development/body/theme/forest/initiative/index_en.htmhttp://www.telapak.org/http://www.globalwitness.org/http://www.eia-international.org/http://www.eia-international.org/http://www.illegal-logging.org/http://www.transparency.org/http://www.fsc.org/
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    1.1.3 There is little or no evidence orreporting of illegal harvestingin the district of origin.

    NGOs and involved stakeholders York Forestry only purchases timber fromlegal landowners/growers and not from 3

    rd

    party timber traders.Low Risk

    1.1.4 There is a low perception of

    corruption related to thegranting or issuing ofharvesting permits and otherareas of law enforcementrelated to harvesting and woodtrade

    Although the Transparency International

    CPI for South Africa is below 5, there is noevidence of corruption in our timbersupplies. All trade in timber products intoour plants and operations are conducted bycompany employees and not through thirdparty timber traders. All purchases aremade from private growers/landownerswho trade from registered companies andhave all the necessary licenses andpermits. Due to the systems in place, see1.1.2 above, we determine the risk to below.

    Low Risk

    2 WOOD HARVESTED IN VIOLATION OF TRADITIONAL OR CIVIL RIGHTS

    2.1 The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the followingindicators are present:

    Requirements Examples of sources of information

    Finding & Evidence

    (FSC-ADV-40-016 v2 - Sources ofinformation used to assess the indicatorsmust be listed)

    Result

    Unspecifiedrisk

    Low

    2.1.1 There is no UN Security

    Council ban on timber exportsfrom the country concerned;

    E.g. This has applied to Liberia, as of July 2003(www.un.org/esa/africa/UNNews_Africa/timber.htm)

    Global Witnesswww.globalwitness.org

    No known export bans for South Africa

    Sources used:

    www.un.org

    www.globalwitness.org

    www.illegal-logging.info

    www.eldis.org

    Low Risk

    http://www.un.org/esa/africa/UNNews_Africa/timber.htmhttp://www.un.org/esa/africa/UNNews_Africa/timber.htmhttp://www.un.org/esa/africa/UNNews_Africa/timber.htmhttp://www.un.org/esa/africa/UNNews_Africa/timber.htmhttp://www.globalwitness.org/http://www.globalwitness.org/http://www.globalwitness.org/http://www.globalwitness.org/http://www.un.org/esa/africa/UNNews_Africa/timber.htmhttp://www.un.org/esa/africa/UNNews_Africa/timber.htm
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    2.1.2 The country or district is notdesignated a source of conflicttimber (E.g. USAID Type 1conflict timber);

    The final report of the expert panel on illegalexploitation of natural resources and other formsof wealth in Democratic Republic of Congo,2002, Annexes I and III (S/2002/1146)www.naturalresources.org/minerals/CD/docs/oth

    er/N0262179.pdfConflict Timber: Dimensions of the Problem inAsia and Africa. Volume I. Synthesis report.June 2003, available at:www.usaid.gov/hum_response/oti/pubs/vol1synth.pdf

    South Africa is not a source of conflicttimber. Low Risk

    2.1.3 There is no evidence of childlabour or violation of ILOFundamental Principles andRights at work taking place in

    forest areas in the districtconcerned

    FSC National Initiatives and Regional Officescontactswww.fsc.org

    ILO country offices

    No violations are known or have beenreported against any of the suppliers listed in2. Supplier Details in the restrictedinformation section above. Labour Law inSouth Africa is enforced by the Dept. ofLabour. York only deals with registeredlegal companies throughout its business.Adherence to all applicable SA legislationforms part of the York contract agreementwith contractors.

    Low Risk

    2.1.4 There are recognized andequitable processes in place toresolve conflicts of substantialmagnitude pertaining totraditional rights including userights, cultural interests ortraditional cultural identity in

    the district concerned;

    FSC National Initiatives and Regional Officescontactswww.fsc.org

    Indigenous Peoples Organizations

    Local community associations in the district

    Risk register

    National Sources (e.g. records of land claimsnegotiation concluded or in progress,summaries of court decisions)

    There is a legal framework for land claims,and other conflicts of traditional rights thatcan be considered to deal with these issues.

    Low Risk

    2.1.5 There is no evidence ofviolation of the ILO Convention169 on Indigenous and TribalPeoples taking place in theforest areas in the districtconcerned.

    FSC National Initiatives and Regional Officescontactswww.fsc.org

    ILO country offices No evidence of this is available. Low Risk

    http://www.usaid.gov/http://www.usaid.gov/http://www.usaid.gov/hum_response/oti/pubs/vol1synth.pdfhttp://www.usaid.gov/hum_response/oti/pubs/vol1synth.pdfhttp://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.usaid.gov/hum_response/oti/pubs/vol1synth.pdfhttp://www.usaid.gov/http://www.usaid.gov/
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    3 WOOD HARVESTED FROM FOREST IN WHICH HIGH CONSERVATION VALUES ARE THREATENED BY MANAGEMENTACTIVITIES

    3.1 The district of origin may be considered low risk in relation to any threat to high conservation values if:

    a) indicator 3.1 is met; or

    b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by non-compliance with 3.1

    Requirements Examples of sources of information

    Finding & Evidence

    (FSC-ADV-40-016 v2 - Sources ofinformation used to assess the indicatorsmust be listed)

    Result

    Unspecifiedrisk

    Low

    3.1.1 Forest management activitiesin the relevant level (eco-region, sub-eco-region, local)do not threaten eco-regionallysignificant high conservation

    values;

    FSC documentation on HCVFs:www.fsc.org

    Eco-region definition and information:

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

    cfmThose regions identified by ConservationInternational as a Biodiversity Hotspot

    (or) Those ecosystems and communities thatare explicitly identified by ConservationInternational as a key component of aBiodiversity Hotspot

    Those forest, woodland, or mangrove eco-regions identified by World Wildlife Fund as aGlobal 200 Eco-region and assessed by WWFas having a conservation status ofendangeredorcritical. If the Global 200 Eco-region

    comprises more than a single terrestrial eco-region, an eco-region within the Global 200 Eco-region can be considered low risk if the sub-eco-region is assessed with a Conservation Statusother than critical/endangered.

    Those regions identified by the WorldConservation Union (IUCN) as a Centre of PlantDiversity

    Those regions identified by ConservationInternational as a High Biodiversity WildernessArea that are forests and contain contiguous

    Commercial forest harvesting in SA is fromtimber plantations. There is no establishedtrade in natural forest timber products fromthe areas York source their controlled woodfrom. The planting permits prohibit plantingof plantations in sensitive areas. Satellitemonitoring is done by government to monitorthis through independent consultants.Currently, York only sources Pine and

    Eucalyptus timber from established timberplantations.

    Low Risk

    http://www.fsc.org/http://www.fsc.org/http://www.fsc.org/http://www.worldwildlife.org/science/ecoregions.cfmhttp://www.worldwildlife.org/science/ecoregions.cfmhttp://www.worldwildlife.org/science/ecoregions.cfmhttp://www.worldwildlife.org/science/ecoregions.cfmhttp://www.worldwildlife.org/science/ecoregions.cfmhttp://www.fsc.org/
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    forest ecosystems greater than 500 km .

    Those regions identified by the WorldResources Institute as a Frontier Forest

    Intact Forests Landscapes, as identified byGreenpeace (www.intactforests.org)

    3.1.2 A strong system of protection(effective protected areas andlegislation) is in place thatensures survival of the HCVsin the eco-region;

    FSC National Initiatives

    Signatory to the Convention on BiologicalDiversityhttps://www.biodiv.org/world/parties.asp anddemonstrable progress towards completing anetwork of protected areas, such as an overallpositive analysis of the latest country thematicreport on Forest Ecosystemshttps://www.biodiv.org/reports/list.aspx?type=for

    Yes, legislation is in place to protect thesespecies refer to planting permits. As statedabove, commercial forests are not planted inHCV areas.

    Low Risk

    4 WOOD HARVESTED FROM AREAS BEING CONVERTED FROM FORESTS AND OTHER WOODED ECOSYSTEMS TOPLANTATIONS OR NON-FOREST USES

    4.1. The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the followingindicator is present:

    [Note: the change from plantations to other land uses is not considered as conversion].

    Requirements Examples of sources of information

    Finding & Evidence

    (FSC-ADV-40-016 v2 - Sources ofinformation used to assess the indicatorsmust be listed)

    Result

    Unspecifiedrisk

    Low

    4.1.1 There is no net loss AND nosignificant rate of loss (> 0.5%per year) of natural forests andother naturally woodedecosystems such assavannahs taking place in theeco-region in question

    FAO GOFC-GOLD Global Observation of Forestand Land Cover Dynamics

    FAO Global Forest Resources Assessment

    Conservation International Regional AnalysisProgram

    University of Maryland Department ofGeography

    UNEP/GRID Division of Early Warning andAssessment

    Planting permits govern this private landowners are not allowed to unilaterallyconvert unplanted areas to plantations.There are numerous examples in the pastwhere planting regulations have been strictlyenforced. Any loss of open areas isgenerally due to expansion of urban areasand not due to expanding plantations. Losscan also be attributed to fires but, in theopen areas, this is allowed to re-grow and inthe case of plantations, the area is

    Low Risk

    http://www.intactforests.org/http://www.intactforests.org/http://www.intactforests.org/https://www.biodiv.org/world/parties.asphttps://www.biodiv.org/world/parties.asphttps://www.biodiv.org/reports/list.aspx?type=forhttps://www.biodiv.org/reports/list.aspx?type=forhttps://www.biodiv.org/reports/list.aspx?type=forhttps://www.biodiv.org/world/parties.asphttp://www.intactforests.org/
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    SERVIR Regional Monitoring andVisualization System for Mesoamerica

    Congo Basin Forest Partnership and CARPE

    CEC Joint Research Centre

    INPE-PRODES Brazils National Institute forSpace Research

    Hansen, M., DeFries, R., Townshend, J.R.,Carroll, M., Dimiceli,C., Sohlberg, R. 2003. 500m MODIS Vegetation Continuous Fields.College Park, Maryland: The Global Land CoverFacility.

    National data sources

    FSC National Initiatives and Regional Officescontacts www.fsc.org

    replanted.

    5 WOOD FROM FORESTS IN WHICH GENETICALLY MODIFIED TREES ARE PLANTED

    5.1 Requirements related to wood from forests in which genetically modified trees are planted

    Requirements Examples of sources of information

    Finding & Evidence

    (FSC-ADV-40-016 v2 - Sources ofinformation used to assess the indicatorsmust be listed)

    Result

    Unspecified risk

    Low

    5.1.1 The district of origin may be

    considered low risk in relationto wood from geneticallymodified trees when one of thefollowing indicators is compliedwith:

    a) There is no commercial use ofgenetically modified trees ofthe species concerned takingplace in the country or districtconcerned. OR

    b) Licenses are required for

    FAO, 2004. Preliminary review of biotechnologyin forestry, including genetic modification. ForestGenetic Resources Working Paper FGR/59E.Forest Resources Development Service, ForestResources Division, Rome, Italy. Availableonline:

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

    National and regional data sources

    No GMO commercial plantations in thecountry also none in use by the currentcontrolled wood sources. There is noevidence at all that any such trees are beingcommercially grown in the country that mightfind their way into our supply chain. TheGenetically Modified Organism Act (No.15 of1997) of South Africa applies strict rules forany GMO testing.

    Low Risk

    http://www.fsc.org/http://www.fao.org/docrep/008/ae574e/AE574E00.HTMhttp://www.fao.org/docrep/008/ae574e/AE574E00.HTMhttp://www.fao.org/docrep/008/ae574e/AE574E00.HTMhttp://www.fao.org/docrep/008/ae574e/AE574E00.HTMhttp://www.fao.org/docrep/008/ae574e/AE574E00.HTMhttp://www.fsc.org/
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    commercial use of geneticallymodified trees and there areno licenses for commercial useOR

    c) It is forbidden to use

    genetically modified treescommercially in the countryconcerned.

    6 GENERAL

    Requirements Examples of sources of information

    Finding & Evidence

    (FSC-ADV-40-016 v2 - Sources ofinformation used to assess the indicatorsmust be listed)

    Result

    Unspecifiedrisk

    Low

    General search on the company

    e.g. Google

    On an internet search using Google andYahoo, no controversial evidence was foundon any of the suppliers listed in 2. SupplierDetails above.

    There was however, an aged petition foundagainst York Timbers and other forestrycompanies titled mass killing of baboons bytimber companies in south Africa. Thispetition is old (approx 2007) and has beenclosed. The content in the petition is notbased on factual evidence but is based onhearsay and unsubstantiated allegations. Afew local press articles reporting on the

    Baboon problem also appear on the internet.2011 Update

    A local NGO, GeaSphere, lodged a formalcomplaint against 3 forestry companiesincluding York Timbers with FSC in January2011 alleging that baboon control infringedcertain Principles & Criteria, and thataccordingly all FSC-certified forestrycompanies should be de-certified. AnIndependent Investigation Panel was set upby the FSC and this convened in May 2011.

    Low Risk

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    A final report was issued on 29 May 2011detailing its findings and recommendations:

    Panel Findings:

    1. No National legislation orInternational Rules or Convention

    has been broken;

    2. There is no infraction of Criterion6.6 which deals with Pestmanagement;

    3. While ethics were not a specificcomplaint, there was an ethicalundertone in supportingdocuments. The finding on this wasthat ethics of species notendangered or specificallyprotected is not adequatelyaddressed in the P&Cs. The panel

    found that the companies shouldcontinue to seek the mostappropriate means of control, andnon-lethal approaches wherepossible; and the FSC mustdevelop policies and guidelines forethical issues relating to control ofspecies causing damage to forests.

    Panel Recommendations:

    1. The FSC work urgently to provideethical guideline for the control ofspecies causing damage to forests;

    2. The panel is not prepared torecommend a moratorium on thekilling of baboons,

    3. A number of managementsuggestions were made forconsideration by variousstakeholders.

    York Timbers is a member of the industryBaboon Damage Working Group which hasbeen formed to find ethical and sustainable

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    solutions to reduce damage by baboons.The group consists of the 3 local timbercompanies, 2 government departments, and5 other members representing NGOs andpublic stakeholders. Whilst efforts areunderway to find non-lethal control methods,

    the damage is of such an extent thatcompanies have had to resort to short-termreduction of baboon populations to protectthe sustainability of the timber crop. All suchoperations are carried under permits issuedby the Mpumalanga Tourism & ParksAgency (MTPA), and also comply with theethics and best operating practice defined inthe Protocol for managing Baboon damagein Southern African Commercial TimberPlantations. The MTPA also inspect suchoperations from time to time as anindependent control. In light of this, York

    Timbers views the risk to be low.

    End of report