RA-Cert Division Headquarters 65 Millet St. Suite 201

Richmond, VT 05477 USA Tel: 802-434-5491 Fax: 802-434-3116

www.rainforest-alliance.org

Audit Managed by:

Mesoamerica Regional Office

8a. Avenida 15-62 Zona 10, Guatemala City, Guatemala

Tel: (502) 2300-6800 Fax: (502) 2300-6890

Contact Person: Adolfo Lemus Email: alemus@ra.org

Verification of Legal Compliance

Assessment 2016 Report for:

Willems Timber and Trading

Company Limited In

Cuyuni-Mazaruni Region, Guyana

Report Version: Public Summary Report Finalized: 28 April 2016 Audit Date: February 02-05, 2016 Audit Team: Cristina Vidal, Edgar

Bámaca Verification code: RA-VLC-006618 Verification Date: 29 de abril de 2016 Report based on Standard: Rainforest Alliance Standard for verification of Legal Compliance for Guyana Version: June 06, 2013

TABLE OF CONTENTS INTRODUCTION ................................................................................................................................. 3

1.1 Background ........................................................................................................................... 3

1.2 Dispute resolution ................................................................................................................. 3

VERIFICATION CONCLUSIONS .......................... .............................................................................. 4

1.3 Auditor Recommendation ...................................................................................................... 4

1.4 New Nonconformity Reports (NCRs) as a Result of This Audit.............................................. 4

1.5 Observations ......................................................................................................................... 5

1.6 Actions Taken by Organization Prior to Report Finalization ................................................... 7

AUDIT PROCESS ............................................................................................................................... 7

1.7 Description of Audit Process ................................................................................................. 7

1.8 Audit Team............................................................................................................................ 7

1.9 Audit Schedule ...................................................................................................................... 8

1.10 Sampling* ............................................................................................................................. 8

1.11 Notes for Next Audit .............................................................................................................. 8

ORGANIZATION INFORMATION .......................... ............................................................................. 9

1.12 Primary Contact for Organization Seeking Verification .......................................................... 9

1.13 Billing Contact ....................................................................................................................... 9

1.14 Location Where Relevant Records will be kept ..................................................................... 9

1.15 On-Line Public Information .................................................................................................... 9

VERIFICATION SCOPE ..................................................................................................................... 9

1.16 Scope Description ................................................................................................................. 9

1.17 Site Details: Processing, Trade and Wholesalers .................................................................10

1.18 Site Details: Forest Management Enterprises (FMEs) ..........................................................10

1.19 Product Group Details ..........................................................................................................10

1.20 Information on Suppliers NOT Included in the Scope of Verification .....................................11

1.21 Flow Chart of Supply Chain Included in the Scope ...............................................................11

1.22 Organization Background (Optional) ....................................................................................11

APPENDIX A: VLO AND VLC STANDARD CHECKLIST FOR PROC ESSING INDUSTRY AND TRADE ORGANIZATIONS (Confidential) ................ .............................................................13

Evaluation of Site: Lakeram Singh Harridat Sawmill .......................................................................13

List of Nonconformity Reports (NCRs) and Observations ................................................................13

APPENDIX B: VLO AND VLC STANDARD CHECKLIST FOR PROC ESSING INDUSTRY AND TRADE ORGANIZATIONS (Confidential) ................ .............................................................20

Evaluation of Site: Willems Timber and Trading Company Limited (WTTCL) .................................20

List of Nonconformity Reports (NCRs) and Observations ................................................................20

APPENDIX C: VLC STANDARD CHECKLIST FOR FMEs (Confid ential) .......................................27

Evaluation of FME: Willem`s Timber and Trading Company Limited (WTTCL): TSA 01/91, 10/85 .27

List of Nonconformity Reports (NCRs) and Observations for FME ..................................................30

VLC Standard Checklist for Forest Management Enterprise ...........................................................31

APPENDIX D: FME Map (Required for Assessment of FME ) .........................................................49

APPENDIX E: VERIFIED PRODUCTION SUMMARIES (Confiden tial) ............................................5 1

APPENDIX F: VERIFICATION SCOPE RISK ASSESSMENT (Con fidential) ...................................52

APPENDIX G: FME VERIFIED POOL PARTICIPANT LIST (Con fidential) ......................................55

APPENDIX H: SUMMARY OF EXHIBITS (Confidential) .... ..............................................................55

INTRODUCTION The purpose of this report is to document conformance of Willems Timber and Trading Company Limited (WTTCL) hereafter referred to as “Organization”.,with the requirements of the Rainforest Alliance Verification of Legal Compliance (VLC) Standard for Guyana, Version dated June, of 2013, The report presents the findings of Rainforest Alliance auditors who have evaluated Organization systems and performance against the applicable standard(s). Section 2 below provides the audit conclusions and any necessary follow-up actions by the Organization through Corrective Action Requests (NCRs). Section 3 describes the audit process and Section 5 defines the scope of the assessment (including organization and non-organization suppliers of raw or processed material). Additional comments about the audit: None.

1.1 Background

The Rainforest Alliance’s SmartWood program was founded in 1989 to verify responsible forestry practices and now focuses on providing a variety of certification and verification auditing services. The Rainforest Alliance legality verification services are applicable to single Forest Management Enterprises (FMEs), wood processing and trading companies as well as complete or parts of supply chains involving both FMEs and processing industry. Verification of Legal Origin audits evaluate that the forest source of the wood has obtained the license to harvest, acquired planning approvals and permits, paid the required taxes, royalties and/or harvesting fees, complies with transport and trade regulations and maintained a chain of custody system. Verified Legal Compliance audits evaluates that the forest source is in conformance with the VLC standard and in compliance with applicable laws relating to environmental protection, wildlife, water and soil conservation, harvesting rules and practices, worker health and safety, and fairness to communities. VLC thus review compliance to a broad range of legal requirements pertaining to forestry in the region in question. For wood processing industry and trade organizations the verification include verification that applicable trade, transport and registration requirements are met, including taxation and royalty payments as well as verifying that a chain of custody system is maintained from a verified supply of wood (either VLO or VLC as defined above). For multi-site verification of whole or parts of supply chains all sites will be required to maintain a CoC system to track and document supply of wood from the forest source through all downstream entities in a defined supply chain.

1.2 Dispute resolution

If Rainforest Alliance clients encounter organizations or individuals having concerns or comments about Rainforest Alliance and our services, these parties are strongly encouraged to contact Rainforest Alliance Headquarters directly. Formal complaints or concerns should be sent in writing.

VERIFICATION CONCLUSIONS The following section contains the conclusions of the audit as well as a list of applicable Corrective Action Requests issued during the audit. The NCRs are issued to each individual site included in the scope of the verification. In the below the relevant NCRs are listed for each site included in the scope.

1.3 Auditor Recommendation

Based on Organization’s conformance with the Rainfo rest Alliance/ Rainforest Alliance legality verification requirements, the au ditor makes the following recommendation:

Verification approved: Upon acceptance of NCR(s) issued below

Verification not approved:

Timeline for the next audit: 1 year

Additional comments: None.

Note: NCRs describe required actions or improvements that address ORGANIZATION non-conformances identified during audits. NCRs include defined timelines for completion. Major NCRs issued during assessments/ reassessments shall be closed prior to issuance of verification statement. Major NCRs issued during audits shall be closed within timeline or result in suspension.

1.4 New Nonconformity Reports (NCRs) as a Result of This Audit

NCR#: 01/16 NC Classification: Major Minor X NCR issued for: Lakeram Singh Harridat Sawmill

Report Section: Appendix A , 2.8

Standard & Requirement: VER-23: Rainforest Alliance Generic Legality Standard for Processing and Trade May 2013 version. Criterion 2.8

Description of Nonconformance and Related Evidence: Organization shall develop and maintain records to document quantities of verified materials for the following: a.Purchased as inputs/raw material; b.Used in production, including conversion factors; c.Inputs and final products in stock; d.Final products sold with and without a claim. Conversion factor methodology and calculations were not included in SOP. Corrective Action Request:

Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above.

Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance:

By the next annual surveillance audit.

Evidence Provided by Organization:

PENDING

Findings for Evaluation of Evidence:

PENDING

NCR Status: OPEN Comments (optional): PENDING

NCR#: 02/16 NC Classification: Major Minor X NCR issued for: WTTCL, FME

Report Section: Appendix C, 10.1.2.

Standard & Requirement: Rainforest Alliance Standard for Verification of Legal Compliance (VLC) for Forest Management Enterprises (FME) in Guyana, VER-04-GUYANA, Version June 2013: 10.1.2.

Description of Nonconformance and Related Evidence: Individual responsible persons shall be designated for each critical control point in the CoC control system. FME did not mention individual responsibilities for each control point in its FME SOP Corrective Action Request:

Organization shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance.

Timeline for Conformance:

By the next annual surveillance audit.

Evidence Provided by Organization:

PENDING

Findings for Evaluation of Evidence:

PENDING

NCR Status: OPEN Comments (optional): PENDING

1.5 Observations

Note: Observations are issued for the early stages of a problem which does not of itself constitute a non-conformance, but which the auditor considers may lead to a future non-conformance if not addressed by the organization; observations may lead to direct non-conformances if not addressed.

OBS: 01/16 Reference Standard & Requirement: Rainforest Alliance Standard for Verification of Legal Compliance (VLC) for Forest Management Enterprises (FME) in Guyana, VER-04-GUYANA, Version June 2013: 3.1.1.

OBS issued for: WTTCL, FME Description of findings leading to observation: WTCCL has a pending balance (royalties and acreage fee) with GFC of GYD$ 1,500,000. GFC allows that harvest activities continues without any restriction.

Observation: WTTCL should paid the total outstanding (royalties and acreage fee) as soon as possible to avoid any issue with GFC.

OBS: 02/16 Reference Standard & Requirement: Rainforest Alliance Standard for Verification of Legal Compliance (VLC) for Forest Management Enterprises (FME) in Guyana, VER-04-GUYANA, Version June 2013: 9.1.1

OBS issued for: WTTCL, FME Description of findings leading to observation: FME has a map of mining legal rights in its EMP with the number of license for each claim, however no information on the owner of the claims are available.

Observation: WTTCL should has the information of the mining claim holders in case it needs to consult or follow up their activities.

OBS: 03/16 Reference Standard & Requirement: Rainforest Alliance Standard for Verification of Legal Compliance (VLC) for Forest Management Enterprises (FME) in Guyana, VER-04-GUYANA, Version June 2013: 11.4

OBS issued for: WTTCL, FME Description of findings leading to observation: WTTCL has demarcated the log pond with mobile sings that indicate the status of the log, whether if it is VLC or Non VLC. The log pond is also shared with other logs owner and its boundaries are not well defined. Observation : FME should define the boundaries of its log property to avoid any confusion.

OBS: 04/16 Reference Standard & Requirement: Rainforest Alliance Standard for

Verification of Legal Compliance (VLC) for Forest Management Enterprises (FME) in Guyana, VER-04-GUYANA, Version June 2013: 13.2.3.

OBS issued for: WTTCL, FME Description of findings leading to observation: FME states in its SOP, that it will use SW-VLC-XXXX. However SW is no longer verification body initials.

Observation : FME should use RA instead of SW in its verification code.

1.6 Actions Taken by Organization Prior to Report F inalization

None.

AUDIT PROCESS

1.7 Description of Audit Process

Audit process started with an opening meeting held with WTTCL relevant staff and Director. After it, the documents review started and stakeholders consultation were carried out. The second day, the audit team traveled to Iteballi to assess the log yard. Inspection of data base records and hard records were done as well as log pond inspection on site. Consultation with the chair of the local community and GFC local staff was carried out. The third day, was assigned for the field inspection. Concession 01/91 was assessed given that harvesting was done recently. Blocks numbers: 9E, 8C, 8D, 18M were assessed on the ground. Tracking system was checked from the standing tree to the log market. 25 stumps were viewed; buffer protection and RIL techniques application were also inspected at the site. In Block 18M two groups of workers were interviewed. Next day, the sawmill was checked against the requirements of the VLC standard for processing sites. Relevant staff were interviewed and physical inspection took place on site to observe the proposed implementation of company`s procedures given that no VLC materials were in site. The last day, the audit team prepared the preliminary findings and informed them to the relevant staff and director during the closing meeting.

1.8 Audit Team

Auditor(s) Qualifications, Affiliations

Cristina Vidal

Lead Auditor. Paraguayan based in Costa Rica; Forestry Engineer; in 2004 she received a M.Sc. in Tropical Forest Management and Biodiversity Conservation from CATIE (Costa Rica). She has developed experience working in protected areas, ecosystem restoration, commercial plantations, silviculture, forestry production, ecology monitoring. She has received training as a lead auditor under ISO 14001:2004, and FSC formal training. She had participated in FSC certification audits as lead auditor. Nowadays, she is involved in a formal carbon training (VCS and CFS) and Verification of Legal Compliance (VLC).

Edgar Bámaca

Guatemalan, Agronomist in Natural Renewable Resources (Agronomy School of Universidad de San Carlos de Guatemala). He has a Magister Scientae in Tropical Forest Management (Centro Agronómico Tropical de Investigación y Enseñanza, CATIE, Costa Rica). He has 12 years of international experience in forest management and chain of custody assessment and audits and he has received an ISO 14,001 Lead Auditor training. Edgar is currently Associate Manager for the RA-Cert Mesoamerican Office.

1.9 Audit Schedule

Date(s) Site(s) Main Activities February 02nd,

2016 WTTCL Office Opening meeting.

February 02nd, 2016

WTTCL Office

Georgetown City

• Opening meeting. • Documentation review. Stakeholders consultation: Guyana Forestry Commision (GFC), Environmental Protection Agency (EPA), Guyana Geology and Mines Commision (GGMC), Department of Labour.

February 03rd, 2016

WTTCL Log Yard.

Travel to Iteballi. • Inspection of the log yard. • Documentation review. • Stakeholders consultation: Iteballi Chair and

GFC local staff. • Staff interview.

February 04th, 2016

TSA 01/91 Inspection of blocks 9E, 8C, 8D, 18M. Travel to Georgetown City.

February 05th, 2016

Lakeram S. Harridat Sawmill

WTTCL Office

• Inspection of the sawmill. • Documentation review. • Staff interview. • Review of pending information. • Closing meeting.

1.10 Sampling*

Sub-set number

Sub-set type (e.g. FME, processing) # of sites Risk Class*

Minimum sampling number

# audited

1 FME 01 Low 01 01

2 Procesing 01 Low 01 01

3 Trader 01 Low 01 01

*Refer to the Appendix for Risk Assessment Describe how the sample was chosen:

Only TSA 01/91 was visited because is active. TSA 10/85 does not have operations on the field.

1.11 Notes for Next Audit

None.

ORGANIZATION INFORMATION

1.12 Primary Contact for Organization Seeking Verif ication

Primary Contact, Position: Pamela Baig / Director

Address: Lot 102, La Flora Gardens Eccles Park, East Bank, Demerara, Guyana.

Tel/Fax/Email: (592) 233-3036 / pbaig@wttcguyana.com

1.13 Billing Contact

Same as shown for primary contact

1.14 Location Where Relevant Records will be kept

Same as shown for primary contact

1.15 On-Line Public Information

Note: upon Verification, the Rainforest Alliance websi1s and maintains details for organizations with the information in the table below at http://www.rainforest-alliance.org

Field Text Has this Information

Changed? Contact, Title: (Sales & Marketing)

Harry Rambarran / Chairman Yes No

Address: Lot 102, La Flora Gardens Eccles Park, East Bank, Demerara, Guayana. Yes No

Tel/Fax/Email/Website: (592) 233-3036 / willemstimber@aol.com Yes No

VERIFICATION SCOPE

1.16 Scope Description

Scope Item Check all that apply to the Verification Scope Change in Scope (N/A for

Assessments)

Verification Type: Single Multi-site

Primary Activity of the Verification Statement Holder (VSH):

Logging/FME

VSH Legal Unit: Limited

Jurisdiction: Guyana

Number of entities 02

• FME 01

• Manufacturing/trading entities

02

Comments:

1.17 Site Details: Processing, Trade and Wholesaler s

Site

Contact (Responsible person, Address,Tel, Fax, Email) Type of Operation

Lakeram S. Harridat Sawmill

Lakeram Harridat / Lot 5 Unity, East Bank Essequibo, Guyana / Tel: (592) 262-0095

Primary manufacturer

1.18 Site Details: Forest Management Enterprises (F MEs)

N/A: No FMEs are included in the scope

Name

Contact (Responsible person, Address, Tel, Fax, Email)

Total Area (Ha)

TSA 01/91 Harry Rambarran / Chairman / Lot 102, La Flora Gardens Eccles Park, East Bank, Demerara, Guayana / (592) 233-3036 /

willemstimber@aol.com

56,618.74

TSA 10/85 55,988.21

Total Area 112,606.95

1.19 Product Group Details

Site (name and location)

Inputs to Product Groups (species) Product Groups

Product Type (FSC-STD-40-004a)

WTTCL, FME

VLC Logs. Species : Greenheart (Chlorocardium rodie), Purpleheart (Peltogyne venosa), Mora (Mora gonggrijpii, Mora excels), Shibadan (Aspidosperma album), Wamaradan (Dicorynia guianensis), Kabukalli (Goupia glabra), Wallaba soft (Eperua falcata), Darina (Hymenolobim spp.)

VLC Logs W1.1

Lakeram Sawmill

VLC Logs. Species : Greenheart (Chlorocardium rodie), Purpleheart (Peltogyne venosa), Mora (Mora gonggrijpii, Mora excels), Shibadan (Aspidosperma album), Wamaradan

VLC Rough Sawn Lumber

VLC Finished Sawn Lumber

VLC Poles and square piles

W5.2

W6.1

W5.5

(Dicorynia guianensis), Kabukalli (Goupia glabra), Wallaba soft (Eperua falcata), Darina (Hymenolobim spp.)

WTTCL, Trader

VLC Rough Sawn Lumber, VLC Finished Sawn

Lumber or VLC Poles and square piles

Species : Greenheart (Chlorocardium rodie), Purpleheart (Peltogyne venosa), Mora (Mora gonggrijpii, Mora excels), Shibadan (Aspidosperma album), Wamaradan (Dicorynia guianensis), Kabukalli (Goupia glabra), Wallaba soft (Eperua falcata), Darina (Hymenolobim spp.)

VLC Rough Sawn Lumber

VLC Finished Sawn Lumber

VLC Poles and square piles

W5.2

W6.1

W5.5

1.20 Information on Suppliers NOT Included in the S cope of Verification

N/A: there are no verified suppliers.

1.21 Flow Chart of Supply Chain Included in the Sco pe

(Required for multi-site verification with more than 2 entities included in the scope)

1.22 Organization Background (Optional)

WTTCL is a privately owned company that was incorporated in 1933 and operated and managed by the Willems family along with a Board of Directors until 2001. The company went into receivership in the year 2002 and was acquired by Guyana Lumber & Timber Company Inc

(GLTCI) on 11th November 2002. GLTCI entered into an agreement of sale with Aurelius INC on the 13th January 2005; however, this agreement of sale was terminated. Willems Timber & Trading Company Limited is a registered Company incorporated in Guyana on the 30th March 1933 under the Company Act Chapter 89:01 with certificate No. 299. The logs harvested from the WTTCL’s concessions, are sold and transported by barge to Lakeram Harridat Sawmills, a third party relationship that is solely responsible for processing WTTCL’s VLC Logs into VLC RA Claimed End Products. Such end products, consisting of hewn squares, baulk and sawn timber and green heart piles are then prepared for the purpose of sale and export.

APPENDIX A: VLO AND VLC STANDARD CHECKLIST FOR PROC ESSING INDUSTRY AND TRADE ORGANIZATIONS (Confidential)

This checklist is based on VER-23: Rainforest Alliance Generic Legality Standard for Processing and Trade May 2013 version.

The checklist shall be used for processing, manufacturing, traders and other downstream sites that are not Forest Management Enterprises (FMEs). FMEs shall be assessed against the full VLO or VLC standard as in applicable checklists.

The checklist is used for evaluating conformance to requirements related to transport, trade and the CoC Principle. This checklist is used for both Verified Legal Origin (VLO) and Verified Legal Compliance (VLC) of processing industry and trade organizations.

For multi-site verifications individual audit conformance checklists are necessary for each site visited . In case operations and findings are similar, checklist can be combined for multiple entities with clear justification. The below evaluation detail and checklist shall be duplicated for each site included in the scope of verification.

Evaluation of Site: Lakeram Singh Harridat Sawmill

Evaluation Details

Locations Visited: Lakeram Singh Harridat Sawmill

People Interviewed, Titles: • Nutan Salick, administrative officer. • Natashia Vieira, administrative officer. • Julian Ramnauth, VLC officer. • Christopher Blukhave, Sawmill operator.

Auditor Recommendation

Based on sites’ conformance with the Rainforest Alliance requirements, the auditor makes the following recommendation:

Inclusion in Verification Scope Approved: Upon acceptance of NCR(s) issued below

Inclusion in Verification Scope Not Approved:

Additional comments: None

List of Nonconformity Reports (NCRs) and Observatio ns

Details are found in Section 1.4. NCR Number ( NCR XX/XX) Standard Reference

01/16 VER-23: 2,8

Observation Number (OBS XX/XX) Standard Reference

Standard Requirement Compliance

PART I: LEGAL REGISTRATION, TRANSPORT, AND TRADE

The organization shall be legally registered and approved for conducting the defined business as well as it shall adhere to applicable transport as well as trade, import or export regulations, procedures and restrictions.

Principle Level Findings: The organization fully complies with all legal requirements to conduct the applicable business. It also showed the corresponding transport official documents and other required trade records. Export or import process are not carried out by this site.

1 Registration, Transport and Trade Requirements

1.1 Organization shall be legally registered and licensed as a business and approved for conducting the defined business activities with the relevant authorities as required by law.

Yes No

N/A

Criterion Level Findings: The organization presented to audit team the following legal registration documents: • Certificate of registration: Issued by Registar of Joint Stock Companies, January 4, 2010. It is renewed every year,

last update was on 9 April, 2015. Certificate number 1014, registration number 379480. The company was established in July 2000, registered in 8 of August 2008.

• Certificate of registration for the Lumber yard: Issued by Registrar of Joint Sock Companies, with certificate number 2694 and registration number 379482, valid until 1 Jan 2017 (renewed annually).

• GFC local storage License: Nº GFCESS02122015, expired by Dec 2015 and in process. • License to operate issued by EPA, with reference number 20070502-LSHSO given to Mr. Lakeram Singh Harridat,

issued in July 2014 and valid until July 2017. • Sawmill License issued by GFC: reference number GFCESS07172015, issued on 23-March 2015, valid until 31 Dec.

2015. Renewal license is still in process, receipts of payments were shown for compliance on 16 Dec, 2015 to renew sawmill license (receipt nº 178950). Receipt for license to erect a new sawmill was paid on 16 Dec, 2015 (receipt nº 178952). Receipt for license for the lumber yard (receipt nº 178951) on 16 Dec, 2015.

1.2 Income from wood and wood products sales shall be declared according to the legislation, and income tax shall be paid in full within required timelines.

Yes No

N/A

Criterion Level Findings: The organization showed compliance against this criterion. The following taxes are demanded to pay in processing industries: • Value added Tax (VAT): It is paid for each invoice of purchase. The amount is 16% on the price of the logs. January

invoices have been checked. Organization also pays taxes on equipment and machineries purchased, copies of invoices were shown as proof of compliance.

• Income tax (owner): Tax Identification Number (TIN): 110229139, registration number: 109168554, earning period Dec. 2014, valid until April 31st 2016. For 2015, accounting is still preparing.

There is no tax on lumber products sold to customer.

1.3 Organization shall adhere to applicable wood and wood products transport regulations and/or restrictions.

Yes No

N/A

Criterion Level Findings: Organization showed official documents of transportation. The Transhipment Permit to remove forest produce is the required legal document to transport logs, the company compiles it in each purchase order. Transhipment permits numbers reviewed on site: 26149, 26151, 26144, 26145, 26146. For lumber products there are no official transport documents.

1.4 Permission to trade CITES-listed species shall be documented, and compliance with the applicable provisions and requirements of CITES shall be demonstrated.

Yes No

N/A

Criterion Level Findings: No CITES species are traded. The site is not in charge of exporting.

1.5 Organization shall document clear evidence of possession of authentic applicable official documents (customs documents etc.) of wood and wood products for import and export in accordance with relevant laws and regulations.

Yes No

N/A

Criterion Level Findings: Company does not import wood and not export wood directly.

1.6 Organization shall adhere to the terms of wood and wood products sales agreements and/or contracts.

Yes No

N/A

Criterion Level Findings: The organization only have written contract with WTTCL, no complaint have been received on wood products sales from this company.

Part II: CHAIN OF CUSTODY

Documented control of the chain of custody (CoC) of forest products is a fundamental requirement in the traceability of the verified forest products from the forest source through manufacturing and distribution to ensure the authenticity of a verified product claim.

This section applies from the forest gate through all points of handling including processing facilities, suppliers, manufacturers, and traders. The CoC checklist is currently only applicable to Rainforest Alliance standards for VLO and VLC; other legality verification schemes may be approved by Rainforest Alliance as equivalent to VLO or VLC; such approvals will be posted on the Rainforest Alliance website when applicable.

Note: in the CoC criteria, “verified” refers to materials qualifying as Rainforest Alliance VLO/VLC or equivalent/eligible material. PEFC materials from low-risk countries and FSC materials can be considered as eligible material.

2 Quality System Criteria:

2.1 Organization shall define CoC system responsibilities and appoint staff positions, including the following:

a. One overall responsible person shall be designated for the CoC control system; and,

b. Individual responsible persons shall be designated for each part of the CoC control system.

Yes No

N/A

Findings: The organization appointed to Julian Ramnauth, VLC officer, to manage VLC control system, he will oversee and has overall responsibility on the site. • Nutan Salick, responsible for data base record keeping • Natashia Vieira, in charge of sales and invoices. Detailed information on work instructions and positions are mentioned in section 10 of Sawmill SOP.

2.2 Organization shall develop and maintain an up-to-date documented control system, procedures and/or work instructions to ensure implementation of all applicable CoC standard requirements.

Yes No

N/A

Findings: The organization has a Standard Operating Procedures (SOP) which complies with the applicable standard and respond to the company demand.

2.3 Organization shall develop and implement procedures for addressing nonconformances (nonconformity reports, corrective action requests, observations) identified by auditors.

Yes No

N/A

Findings: Organization set procedures to address and follow up nonconformances identified by auditors (internals and externals) in section 6.4 of its SOP. VLC coordinator is the personnel in charge of monitoring corrective actions implementation and update the status of each nonconformance.

2.4 Organization shall develop and implement procedures for internal auditing of its systems as related to the requirements in this standard.

Yes No

N/A

Findings: Internal audits are prescribed in section 6.3 of SOP. VLC coordinator will carry out this process and ensure that the company is complying with the requirements of the standard. Internal audits has been conducted on October and November 2015, and January 2016.

2.5 Organization shall develop training requirements and implement training as follows: Yes No

a. All applicable staff and workers shall be trained according to the CoC procedures to a degree relevant to the scale and complexity of the system and position; and,

b. Records shall be kept to demonstrate training has taken place.

N/A

Findings: According to the interview held with the relevant staff, they were aware of their functions and duties to comply with VLC requirements. The following training records sheets signed up by trainees were submitted: • VLC standards and requirements given on February 8, 2016 to 4 staff personnel. • A general review on VLC standards and requirements held on February 12, 2016 to 4 persons. COC Training Program is described in section 7.0 of SOP.

2.6 Organization shall define and document verified Claim Categories and shall define each product group that will be tracked under the applicable Claim Category.

Yes No

N/A

Findings: Three product group has been defined, and 08 species has been included as VLC products. WTTCL has defined and document VLC as Claim category for all products in its product group schedule and SOP.

2.7 Organization shall document the availability of supply of verified material. Yes No

N/A

Findings: At present, there is no VLC inputs and or output at this site. The organization has procedures (Section 4.0 Database Control Procedures of SOP) in place to account all VLC supplied materials once arrived to the sawmill log yard. VLC Coordinator is the responsible to maintain all databases controls.

2.8 Organization shall develop and maintain records to document quantities of verified materials for the following:

a. Purchased as inputs/raw material;

b. Used in production, including conversion factors;

c. Inputs and final products in stock;

d. Final products sold with and without a claim.

Yes No

N/A

Findings: Organization developed procedures to comply with this requirement in section 4 of SOP. In this section, it describes all the procedures to handle and record all VLC materials and products. However conversion factor methodology and calculations were not included (NCR 01/16).

3 Segregation of Material

3.1 Organization shall keep verified material physically separate as secure units during all stages of handling, i.e., receiving, processing, storing, and shipping.

Yes No

N/A

Findings: Organization will keep the integrity of VLC materials throughout all the receiving, processing and storage of the products by using signage. • Reception: all logs received will carry physically painted information on both ends which includes WTTCL identifier,

GFC Tag Number, Tree number, Block number and species. Lakeram Sawmill has been establish a specific area for the storage of WTTCL´s VLC Logs.

• Processing: all logs will be processed by a specific work order, work in progress signs will be used to identify each batch until final bundling.

• Storage: All bundles will carry a specific bundle number with the identification of species and dimensions of the product.

• Transport: All VLC products will be transported with a packing list that will have the detailed information of each piece of product loaded. Signage will be used across the whole process to keep the integrity of the VLC materials.

These procedures are described in Section 2.0 Sawmill Operations of SOP.

3.2 All material that cannot be identified as verified shall be kept physically separate from verified material.

Note: material that is pending evidence of its legal status shall be kept separate until such time that adequate documentation is obtained.

Yes No

N/A

Findings: In the event that any material loose its identification or tracking is not possible, the organization will identified it as Non VLC material. This issue is documented in section 3.2. Segregation of SOP and relevant staff is aware of this procedure.

3.3 Organization shall use a distinguishing mark (e.g., the verification code) to identify products as verified during processing and transport.

Yes No

N/A

Findings: Organization will use signage to track VLC materials (inputs and outputs) throughout the processing, storage and transport of products. For details, see Criterion 3.1.

3.4 Organization shall develop and implement procedures to ensure that other verification bodies’ claims, marks or codes are distinguishable from that used to identify Rainforest Alliance verified material.

Yes No

N/A

Findings: There are no other certification/verification bodies used in inputs and or outputs. Only RA claims will be used.

3.5 Organization shall not mix verified and non-verified material though processing; only products containing 100% verified material (or material verified or certified against an equivalent or higher level standard approved by Rainforest Alliance) are eligible for Rainforest Alliance Verified™ claims.

Yes No

N/A

Findings: No mixing is foreseen during processing. The integrity of VLC material will be kept along the manufacturing, storage and transport. Relevant staff has been training to maintain integrity of the verified materials.

3.6 If VLO or VLC verified material is mixed with material verified or certified against an equivalent or higher standard approved by Rainforest Alliance, the organization shall only apply the lowest level verification claim to the total amount of the mixed product.

Yes No

N/A

Findings: There are not other certification/verification bodies used in inputs and or outputs. Only RA claims will be used.

4 Purchasing and Receiving Criteria

4.1 Organization shall verify the validity of the supplier’s certificate or Verification Statement. Yes No

N/A

Findings: The only supplier will be WTTCL, the Verification Statement Holder (VSH). It is in charge of the management of the verification status.

4.2 If organization is sourcing logs directly from undefined pool of individual smallholders, procedures for verifying legality of wood shall be in place and adhered to in the field including the following:

a. Land title;

b. Harvesting rights;

c. Health and safety issues during harvesting;

d. Transport

Yes No

N/A

Findings: This scenario is not foreseen. Only WTTCL logs will be sourced as VLC inputs.

4.3 Organization shall ensure that supplier invoices and delivery documents include the following:

a. The quantity(volume, weight or number of units) and species (common and scientific names) for each product;

b. The Rainforest Alliance verification code (RA-VLO-XXXXXX or RA-VLC-XXXXXX).

Yes No

N/A

c. The applicable certification code and claim for materials certified through other approved certification schemes.

Findings: Organization is aware of this requirement. Personnel in charge (VLC officer and administrative officers) explain, they will review in the delivery documents:

• The dimensions and species of products • The RA verification code to trace its VLC logs • No other certification schemes are used.

5 Processing Criteria

5.1 Organization shall use a tracking system and production records to document production of verified material.

Yes No

N/A

Findings: Organization will use a batch system to trace all the production until final status. Each batch has a number and respond to a specific work in order. Signage will be used along the processing to help with the identification of the sequence of the batch/work order.

5.2 Organization shall have a signed outsourcing agreement to ensure that any off-site processing that takes place at a subcontracted facility follows defined CoC procedures.

Yes No

N/A

Findings: No outsourcing will take place at this site.

6 Shipping and Sales Criteria

6.1 Organization shall include claim information on sales invoices and shipping documents, including the following:

a. The quantity/volume and species for each product;

b. The Rainforest Alliance verification code (RA-VLO-XXXXXX or RA-VLC-XXXXXX).

c. A clear indication of which products are verified when multiple items are stated on a document (e.g., indication of “RA VLO” or “RA VLC” per line item)

Yes No

N/A

Findings: Organization is aware of this requirement. It is documented in section 5.2 of SOP. Once the company has materials in place it will implement it accordingly.

7 Claims and Public Information Criteria

7.1 If Organization is not a Verification Statement Holder, Organization shall not use VLC claim without prior approval of the verification statement holder.

Yes No

N/A

Findings: Organization is not VSH. It has procedures in section 5.3 of SOP to respond to this criterion. Personnel and relevant staff were also aware of this.

7.2 Organization shall ensure that all VLO or VLC verification claims and marks follow the applicable Rainforest Alliance policies:

a. On-product labeling shall not be permitted;

b. Rainforest Alliance Trademarks for off-product promotion shall not be used; public promotion of the VLC claim shall not be permitted.

c. Use of the verification code (RA-VLO-XXXXXX or RA-VLC-XXXXXX) on products shall only be used for internal traceability of products; and

d. Business to business communication and promotion of VLC shall be approved by RA-Cert prior to being released by the organization for use.

Yes No

N/A

Findings: Organization is not in charge of making claims. This responsibility is on WTTCL company, the VSH. However procedures to comply with this criterion was established in section 5.3.

7.3 Organization shall have procedures in place to ensure and demonstrate submission of all Rainforest Alliance claims to Rainforest Alliance for review and approval prior to use.

Yes No

N/A

Findings: Not applicable on this site. See section 7.2

7.4 Organization shall have procedures in place and demonstrate that all review and approval correspondence with Rainforest Alliance for verification claims is kept on file for a minimum of five (5) years.

Yes No

N/A

Findings: Not applicable on this site. See section 7.2

Part III: MULTI-SITE MANAGEMENT REQUIREMENTS

The multi-site management criteria have been developed to facilitate evaluation of organizations that have two or more sites included in the scope of their supply chain and wish to manage those under one Verification Statement. The multi-site management requirements, plus communication with Rainforest Alliance, are coordinated by the Verification Statement Holder. Multi-site management criteria allow Rainforest Alliance to evaluate the participating sites based on audit sampling in recognition of control and reporting systems monitored by the Verification Statement Holder. In addition to these criteria, Rainforest Alliance shall ensure that all sites of a multi-site supply chain comply with all relevant legality and CoC requirements in the VLO or VLC verification standards as applicable.

N/A Check this box if the organization is not a multi-site

APPENDIX B: VLO AND VLC STANDARD CHECKLIST FOR PROC ESSING INDUSTRY AND TRADE ORGANIZATIONS (Confidential)

This checklist is based on VER-23: Rainforest Alliance Generic Legality Standard for Processing and Trade May 2013 version.

The checklist shall be used for processing, manufacturing, traders and other downstream sites that are not Forest Management Enterprises (FMEs). FMEs shall be assessed against the full VLO or VLC standard as in applicable checklists.

The checklist is used for evaluating conformance to requirements related to transport, trade and the CoC Principle. This checklist is used for both Verified Legal Origin (VLO) and Verified Legal Compliance (VLC) of processing industry and trade organizations.

For multi-site verifications individual audit conformance checklists are necessary for each site visited . In case operations and findings are similar, checklist can be combined for multiple entities with clear justification. The below evaluation detail and checklist shall be duplicated for each site included in the scope of verification.

Evaluation of Site: Willems Timber and Trading Com pany Limited (WTTCL)

Evaluation Details

Locations Visited: WTTCL central office, Georgetown, Guyana

People Interviewed, Titles: • Mr. Harry Rambarran, Chairman. • Ms. Pamela H. Baig, Director. • Mr. Cecil Persaud, Company secretary. • Ms. Nalini Pasram, Office administrator.

Auditor Recommendation

Based on sites’ conformance with the Rainforest Alliance requirements, the auditor makes the following recommendation:

Inclusion in Verification Scope Approved: No NCRs issued

Inclusion in Verification Scope Not Approved:

Additional comments: None

List of Nonconformity Reports (NCRs) and Observatio ns

Details are found in Section 1.4. NCR Number (NCR XX/XX) Standard Reference

N/A

Observation Number (OBS XX/XX) Standard Reference

N/A

Standard Requirement Compliance

PART I: LEGAL REGISTRATION, TRANSPORT, AND TRADE

The organization shall be legally registered and approved for conducting the defined business as well as it shall adhere to applicable transport as well as trade, import or export regulations, procedures and restrictions.

Principle Level Findings: Organization showed conformance against this principle. Legal registration and transport regulations are documented to follow up.

1 Registration, Transport and Trade Requirements

1.1 Organization shall be legally registered and licensed as a business and approved for conducting the defined business activities with the relevant authorities as required by law.

Yes No

N/A

Criterion Level Findings: WTTCL holds the following official registration documents: • Tax Identification Number certificate, with registration number 010086175 issued on January 04, 2012. • Timber Dealer Export renewal license GFCDEM00292016 issued by GFC through to December 31, 2016. • It was incorporated as a business on March 30, 1933 under the Laws of British Guiana, Chapter 178.

1.2 Income from wood and wood products sales shall be declared according to the legislation, and income tax shall be paid in full within required timelines.

Yes No

N/A

Criterion Level Findings: WTTCL presented to the audit team its Corporation Tax original assessment with number 185253, year of assessment 2015, stating the year of income 2014. Next assessment (for 2015) need to be presented in April 2016. It confirms that WTTCL is up to date with this requirement. Also, WTTCL presented its Value Added Tax Return annual declaration from period 01/Jan/2015 to 31/Dec/2015. This declaration it is a conciliation between Input VAT (VAT claimed on goods and services acquired solely for making taxable supplies) and Output VAT (VAT claimed on sales). WTCCL paid GYD$ 1,792,285 (US$ 8,623) on this period.

1.3 Organization shall adhere to applicable wood and wood products transport regulations and/or restrictions.

Yes No

N/A

Criterion Level Findings: Organization uses transhipment permits to transport logs to the export port. Lumber products are transported with a packing list. Documents was reviewed on the central office.

1.4 Permission to trade CITES-listed species shall be documented, and compliance with the applicable provisions and requirements of CITES shall be demonstrated.

Yes No

N/A

Criterion Level Findings: No CITES species are traded.

1.5 Organization shall document clear evidence of possession of authentic applicable official documents (customs documents etc.) of wood and wood products for import and export in accordance with relevant laws and regulations.

Yes No

N/A

Criterion Level Findings: All wood that WTCCL export coming from TSA 01/91 or TSA 10/85, so no wood is imported. About exportations, WTTCL buy again the wood that it is processed by Lakeram Harridat Sawmill, and then it is exported following requirements given by the Guyana Forestry Commission, the Customs and Trade Administration, Customs Anti-Narcotis Unit and the Phyto-Sanitaty Unit of the Ministry of Agriculture. Documents required to permit any export are: Timber Marketing Certificate, Commercial Invoice, Certification of Origen, Customs C72 Declaration Form, Timber Export Certificate, Packing List, Phyto-sanitary Certificate and Statement of Origen. WTTCL showed documentation of Invoices ASPL 13/2015 and LF 35/2015 (mainly market of the company is local).

1.6 Organization shall adhere to the terms of wood and wood products sales agreements and/or contracts.

Yes No

N/A

Criterion Level Findings: There are no complaints or query raised by WTTCL customers, therefore, audit team considers that the organization complies with this requirement.

Part II: CHAIN OF CUSTODY

Documented control of the chain of custody (CoC) of forest products is a fundamental requirement in the traceability of the verified forest products from the forest source through manufacturing and distribution to ensure the authenticity of a verified product claim.

This section applies from the forest gate through all points of handling including processing facilities, suppliers, manufacturers, and traders. The CoC checklist is currently only applicable to Rainforest Alliance standards for VLO and VLC; other legality verification schemes may be approved by Rainforest Alliance as equivalent to VLO or VLC; such approvals will be posted on the Rainforest Alliance website when applicable.

Note: in the CoC criteria, “verified” refers to materials qualifying as Rainforest Alliance VLO/VLC or equivalent/eligible material. PEFC materials from low-risk countries and FSC materials can be considered as eligible material.

2 Quality System Criteria:

2.1 Organization shall define CoC system responsibilities and appoint staff positions, including the following:

c. One overall responsible person shall be designated for the CoC control system; and,

d. Individual responsible persons shall be designated for each part of the CoC control system.

Yes No

N/A

Findings: The personnel in charge of this site is:

• Overall Management Responsibility: Harry Rambarran (Chairman & Chief Executive Officer) and Pamela Baig (Director).

• Forest Operations Responsibility: Rickford Innis (Operation Manager). • Invoicing Process: Nalini Parsram (Office administrator).

On the SOP for Sawmill operations only are included the name of the Overall Management Responsibility person and the Forest Operations Responsibility person, the remaining personnel were not mentioned.

2.2 Organization shall develop and maintain an up-to-date documented control system, procedures and/or work instructions to ensure implementation of all applicable CoC standard requirements.

Yes No

N/A

Findings: The organization has a Standard Operating Procedures (SOP) which complies with the applicable standard and respond to the company demand. The version of this SOP is January 2016.

2.3 Organization shall develop and implement procedures for addressing nonconformances (nonconformity reports, corrective action requests, observations) identified by auditors.

Yes No

N/A

Findings: Organization set procedures to address and follow up nonconformances identified by auditors (internals and externals) in section 6.4 of its SOP. VLC coordinator is the personnel in charge of monitoring corrective actions implementation and update the status of each nonconformance.

2.4 Organization shall develop and implement procedures for internal auditing of its systems as related to the requirements in this standard.

Yes No

N/A

Findings: Internal audits are prescribed in section 6.3 of SOP. VLC coordinator will carry out this process and ensure that the company is complying with the requirements of the standard. Internal audits has been conducted on October and November 2015, and January 2016

2.5 Organization shall develop training requirements and implement training as follows:

c. All applicable staff and workers shall be trained according to the CoC procedures to a degree relevant to the scale and complexity of the system and position; and,

d. Records shall be kept to demonstrate training has taken place.

Yes No

N/A

Findings: Organization carried out training to established VLC procedures for trade and invoicing in June 2015, one person participated. For this site the only relevant staff is the Office Administrator.

2.6 Organization shall define and document verified Claim Categories and shall define each product group that will be tracked under the applicable Claim Category.

Yes No

N/A

Findings: Three product group has been defined, and 08 species has been included as VLC products.

2.7 Organization shall document the availability of supply of verified material. Yes No

N/A

Findings: This site will be in charge of export sales. At the moment there are no supply of verified material. The Organization has procedures (Section 4.0 Database Control Procedures of SOP) to maintain all database controls. VLC Coordinator is the responsible to maintain these databases.

2.8 Organization shall develop and maintain records to document quantities of verified materials for the following:

e. Purchased as inputs/raw material;

f. Used in production, including conversion factors;

g. Inputs and final products in stock;

h. Final products sold with and without a claim.

Yes No

N/A

Findings: Organization developed procedures to comply with this requirement in section 4 of SOP. Data base record keeping procedures are also considered to compile the sales and final products inventory.

3 Segregation of Material

3.1 Organization shall keep verified material physically separate as secure units during all stages of handling, i.e., receiving, processing, storing, and shipping.

Yes No

N/A

Findings: All VLC products will be identified by a bundle number. At this site only finished products will be handled. During transport, a packing list will back the VLC products to the port.

3.2 All material that cannot be identified as verified shall be kept physically separate from verified material.

Note: material that is pending evidence of its legal status shall be kept separate until such time that adequate documentation is obtained.

Yes No

N/A

Findings: In the event that any material loose its identification or tracking is not possible, the organization will identified it as Non VLC material. This issue is documented in section 3.2. Segregation of SOP.

3.3 Organization shall use a distinguishing mark (e.g., the verification code) to identify products as verified during processing and transport.

Yes No

N/A

Findings: This site is the responsible to local sales and export sales, so, the use of distinguishing mark is not required.

3.4 Organization shall develop and implement procedures to ensure that other verification bodies’ claims, marks or codes are distinguishable from that used to identify Rainforest Alliance verified material.

Yes No

N/A

Findings: There are no other certification/verification bodies used in inputs and or outputs. Only RA claims will be used.

3.5 Organization shall not mix verified and non-verified material though processing; only products containing 100% verified material (or material verified or certified against an

Yes No

N/A

equivalent or higher level standard approved by Rainforest Alliance) are eligible for Rainforest Alliance Verified™ claims.

Findings: No mixing is foreseen during processing. The integrity of VLC material will be kept along the manufacturing, storage and transport.

3.6 If VLO or VLC verified material is mixed with material verified or certified against an equivalent or higher standard approved by Rainforest Alliance, the organization shall only apply the lowest level verification claim to the total amount of the mixed product.

Yes No

N/A

Findings: There are no other certification/verification bodies used in inputs and or outputs. Only RA claims will be used.

4 Purchasing and Receiving Criteria

4.1 Organization shall verify the validity of the supplier’s certificate or Verification Statement. Yes No

N/A

Findings: WTTCL is the Verification Statement Holder (VSH), it will be supplied by L.S. Harridat sawmill, which is included in this scope. WTTCL, itself, in charge of the management of the verification status of all the sites included in the scope.

4.2 If organization is sourcing logs directly from undefined pool of individual smallholders, procedures for verifying legality of wood shall be in place and adhered to in the field including the following:

e. Land title;

f. Harvesting rights;

g. Health and safety issues during harvesting;

h. Transport

Yes No

N/A

Findings: This scenario is not foreseen. Only one supplier will be used.

4.3 Organization shall ensure that supplier invoices and delivery documents include the following:

d. The quantity(volume, weight or number of units) and species (common and scientific names) for each product;

e. The Rainforest Alliance verification code (RA-VLO-XXXXXX or RA-VLC-XXXXXX).

f. The applicable certification code and claim for materials certified through other approved certification schemes.

Yes No

N/A

Findings: Organization will review in the delivery documents (invoices and packing list): • The dimensions and species of products • The RA verification code to trace its VLC logs • No other certification schemes are used.

5 Processing Criteria

5.1 Organization shall use a tracking system and production records to document production of verified material.

Yes No

N/A

Findings: This site will be in charge of export sales, so production is not part of the site.

5.2 Organization shall have a signed outsourcing agreement to ensure that any off-site processing that takes place at a subcontracted facility follows defined CoC procedures.

Yes No

N/A

Findings: No outsourcing will take place at this site.

6 Shipping and Sales Criteria

6.1 Organization shall include claim information on sales invoices and shipping documents, including the following:

d. The quantity/volume and species for each product;

e. The Rainforest Alliance verification code (RA-VLO-XXXXXX or RA-VLC-XXXXXX).

f. A clear indication of which products are verified when multiple items are stated on a document (e.g., indication of “RA VLO” or “RA VLC” per line item)

Yes No

N/A

Findings: Organization is aware of this requirement. It is documented in section 5.2 of SOP. Once the company has materials in place it will implement it accordingly. WTTCL has the experience to use a Rubber Stamp with the VLC code because it was verified by Rainforest Alliance in the past. The Rubber Stamp was showed by the company.

7 Claims and Public Information Criteria

7.1 If Organization is not a Verification Statement Holder, Organization shall not use VLC claim without prior approval of the verification statement holder.

Yes No

N/A

Findings: Organization has procedures in section 5.3 of SOP to comply with this criterion. Personnel and relevant staff were also aware of this.

7.2 Organization shall ensure that all VLO or VLC verification claims and marks follow the applicable Rainforest Alliance policies:

e. On-product labeling shall not be permitted;

f. Rainforest Alliance Trademarks for off-product promotion shall not be used; public promotion of the VLC claim shall not be permitted.

g. Use of the verification code (RA-VLO-XXXXXX or RA-VLC-XXXXXX) on products shall only be used for internal traceability of products; and

h. Business to business communication and promotion of VLC shall be approved by RA-Cert prior to being released by the organization for use.

Yes No

N/A

Findings: This site is in charge of making VLC claim. It holds specific procedures in section 5.3. Relevant staff is aware of them.

7.3 Organization shall have procedures in place to ensure and demonstrate submission of all Rainforest Alliance claims to Rainforest Alliance for review and approval prior to use.

Yes No

N/A

Findings: Organization has procedures in place in section 5.3 of SOP. Relevant staff is aware of them.

7.4 Organization shall have procedures in place and demonstrate that all review and approval correspondence with Rainforest Alliance for verification claims is kept on file for a minimum of five (5) years.

Yes No

N/A

Findings: Organization established a procedure to follow up with this criterion in section 5.3 of SOP. Relevant staff is aware of them.

Part III: MULTI-SITE MANAGEMENT REQUIREMENTS

The multi-site management criteria have been developed to facilitate evaluation of organizations that have two or more sites included in the scope of their supply chain and wish to manage those under one Verification Statement. The multi-site management requirements, plus communication with Rainforest Alliance, are coordinated by the Verification Statement Holder.

Multi-site management criteria allow Rainforest Alliance to evaluate the participating sites based on audit sampling in recognition of control and reporting systems monitored by the Verification Statement Holder. In addition to these criteria, Rainforest Alliance shall ensure that all sites of a multi-site supply chain comply with all relevant legality and CoC requirements in the VLO or VLC verification standards as applicable.

N/A Check this box if the organization is not a multi-site

APPENDIX C: VLC STANDARD CHECKLIST FOR FMEs (Confid ential) This checklist is based on VER-04 Rainforest Alliance Standard for Verification of Legal Compliance (VLC) for Forest Management Enterprises (FME) in Guyana Version 06 June 2013. This following section summarizes the FME’s compliance with the requirements of the Rainforest Alliance Standard for Verification of Legal Compliance (VLC). Individual audit conformance checklists are necessary for each individual FME , but multiple FMUs can be included under one checklist for each FME. The below evaluation checklist shall be duplicated for each FME included in the scope of verification.

Does the FME consist of a group of multiple landholdings/FMUs? Yes No

If the FME consists of a group of individual FMUs or individual landowners the FME shall be evaluated against the multisite CoC criteria and the Appendix named “Verified Pool Participant List” shall be filled in with the names of each individual member.

Evaluation of FME: Willem`s Timber and Trading Com pany Limited (WTTCL): TSA 01/91, 10/85

Evaluation Details

Locations Visited: • WTTCL Central office. • Iteballi log pond. • TSA 01/91.

People Interviewed, Titles: • Harry Rambarran, Chairman. • Pamela H. Baig, Director. • Cecil Persaud, Company secretary. • Nalini Pasram, Office administrator. • MRickford Innis, Forest operations manager. • John Campbell, Forest consultant. • Imitienz Khan, Office Clerk at Puriari camp. • Ganeshwar, Production supervisor, Puriari Camp. • Yuland Henry, Cook, Puriari camp. • Saquid M. Rizcoal, Scaler at log pond. • Collis Innis, Data record at log pond. • Laikhram Das Indarjet, Forest Coordinator. • Rakeh Warren, Feller. • Kislore Campbell, Feller helper. • Eric Thornhill, Block inspector. • Laurence Bascom, Inventory leader. • Clint Shuman, Line cutter. • Cleveland Jacobs, Line cutter. • Dwright Heny, Line cutter. Stakeholders consulted: • Mr. James Sighn, Commisioner of Forests (GFC). • Mr. Rawle Lewis, Deputy Commissioner for Forest Resources

Management Division at Guyana Forest Commission (GFC). • Ms. Teij Persaud, CEO at Environmental Protection Agency (EPA). • Mr. Newell Dennison, Deputy Commissioner (Guyana Geology and

Mines Comission). • Ms. Michelle Baburam, Snr. Labour Occupational Safety and Health

Officer (Ministry of Labour, Human Services and Social Security). • Ms.Colleen Singh, Chair of Iteballi community. • Mr. Roydon John, Forest ranger of GFC at Iteballi.

FME Information

FME jurisdiction: Guyana Location of forest areas covered by verification

Latitude: Longitude: Latitude: Longitude:

TSA 01/91 N 06 degrees 21.60 minutes W 59 degrees 9.763 minutes TSA 10/85 N 06 degrees 15.818 minutes W 58 degrees 43.324 minutes

Forest zone classification Tropical Area under forest type

- Natural TSA 01/91: 56,618.74 hectares TSA 10/85: 55,988.21 hectares

TOTAL: 112,606.95 hectares - Plantation hectares - Semi-natural, mixed plantation and

mixed forest hectares

Total area of production forest (area where timber may be harvested, all forest types)

TSA 01/91: 31,197.78 hectares TSA 10/85: 40,111.02 hectares

TOTAL: 71,308.80 hectares Total area of FME TSA 01/91: 56,618.74 hectares

TSA 10/85: 55,988.21 hectares TOTAL: 112,606.95 hectares

Scope of the Verification

Type of verification: multiple FMU FMU name Location Owner Area (Has)

TSA 01/91 Cuyuni-Mazuruni Region, Guyana

Government of Guyana

56,6818.74

TSA 10/85 Cuyuni-Mazuruni Region, Guyana

Government of Guyana

55,988.21

Total area: 112,606.95 Exclusion of FMU-s from the evaluation scope

All forest land owned or managed by the FME is included in the scope of this verification.

Some FMUs under the management of the FME are being excluded from the verification.

Explanation for exclusion:

FMU name Location Owner Area (ha)

Species Included in the Scope

Botanical name Common trade name Chlorocardium rodiei Greenheart

Peltogyne venosa Purpleheart Mora excels / Mora gonggrijpii Mora

Goupia glabra Kabukalli Aspidosperma cruentum Shibadan

Hymenolobium spp. Darina Dicorynia guianensis Wamaradan

Eperua falcata Wallaba soft List of approved contractors (logging, planting, ha uling, transport etc.)

Organization Legal Name Elton France, individual operator contractor.

Auditor Recommendation

Based on FMEs conformance with the Rainforest Alliance requirements, the auditor makes the following recommendation:

Inclusion in Verification Scope Approved: Upon acceptance of NCR(s) issued below

Inclusion in Verification Scope Not Approved:

Additional comments: None

List of Nonconformity Reports (NCRs) and Observatio ns for FME

Details are found in Section 1.4. NCR Number ( NCR XX/XX) Standa rd Reference

02/16 10.1.2.

Observation Number (OBS XX/XX) Standard Reference 01/16 3.1.1. 02/16 9.1.1. 03/16 11.4. 04/16 13.2.3.

VLC Standard Checklist for Forest Management Enterp rise

Part I: Principles and Criteria for Verification of Legal Conformance

Standard Requirement Compliance

PRINCIPLE 1: LEGAL RIGHT TO HARVEST

The legal status of the FME shall be clearly defined and its boundaries delineated. The FME shall prove that it has validly obtained the legal right to operate and to harvest timber from within the defined FMU.

Principle Level Findings: WTTCL showed a satisfactory compliance against this principle.

1.1 Clear and documented legal registration of FME with authorization to carry out forest managem ent activities shall exist.

Criterion Level Findings: WTTCL is a privately owned company founded in 1933 and duly incorporated in the Company Act of Guyana, with Tax Identification Number certificate updated. GFC commented that registration as a FME has been done according to the legal prescribed process. The company is in Court to resolve the ownership of shares. However the management representative is clear to the Court and to GFC, therefore it is allowed to operate.

1.1.1: FME shall have valid Tax Identification Number and business/company registration to operate within the jurisdiction.

Yes No

N/A

Findings: WTTCL showed to the audit team its TIN certificate (Tax Identification Number), with registration number 010086175 issued on January 04, 2012. The company was incorporated as a business on March 30, 1933 under the Laws of British Guiana, Chapter 178. Later on, the laws has been changed and an article of continuance was issued to the company on March 30, 1983, under the Companies Act 89:01 of 1991 (Section 338), with the company nº 299. It was acquired by Guyana Lumber & Timber Company Inc. (GLTCI) in 2002 with registration certificate number 4966 and it updated its registration with the certificate of restauration under the Company Act 29 of 1991 on the 29th day of August 2014. The company is owned by Mr. Harry Rambarran, he is the chairman of the board of directors.

1.1.2: The registration of the FME shall have been granted according to the legally prescribed process.

Yes No

N/A

Findings: According to GFC, WTTCL followed the legally prescribed process to be incorporated as a FME. At those times (1933), the only requirement was an application to manage the concessions. Current procedures are not applicable to WTTCL anymore.

1.1.3: The FME shall not be subject to a court or other legally established order to cease operations.

Yes No

N/A

Findings: On September 11 2014, GFC suspend the Timber Sales Agreements 01/91 and 10/85 because it was not clear who is the owner of WTTLC. This suspension was appelled by WTTLC on September 23, 2014 in a court of Constitutional and Administrative Jurisdiction (Record # 2014-HC-DEM-CIV-CM-100). On April 29, 2015, the court declare that the suspension of both TSA is unlawful, unreasonable, arbitrary, capricious, irrational, procedurally, improper, unconstitutional, ultra vires, null, void, and of no legal effect. On September 2015, a new resolution of case 2015-HC-DEM-CIV-CM-48 ordered to GFC to permit to WTTC to continue their operations in TSA 01/91 and TSA 10/85 and supply tree tags to harvest timber from approval blocks. Under this resolution, WTTCL restarted with harvest. WTTLC has a file in its office with information of all this process.

1.1.4: If the legal status and rights are being challenged, the FME shall be engaged in a legal process to resolve the challenges.

Yes No

N/A

Findings: On September 11 2014, GFC suspend the Timber Sales Agreements 01/91 and 10/85 because it was not clear who is the owner of WTTLC. WTTLC has a file in its office with information of this situation:

• On January 13 2005, owner of WTTCL, Guyana Lumber and Timber Company Inc, and Kakabara Company Limited signs and a contract of sales of these companies with Aurelius Inc.

• On December 13, 2009, owner of WTTCL, Guyana Lumber and Timber Company Inc, and Kakabara Company Limited decided to terminate the contract because Aurelis Inc. did not paid a sum of US$ 1,583,997. This termination was notified by a letter that said "Take notice that pursuant to clause 13 (b) of the above contract (the original contract) the vendors terminate the said contract with immediate effects for failure by the purchaser to pay the balance of the purchase price in a timely manner".

• On August 2014, Mr. Harry Rambarran (Chairman of WTTCL) was notified of a restriction over all properties of WTTC and restriction to conduct business transactions in the name of WTTC. This was the beginning of a process in a Court between Aurelius Inc. and Harry Rambarran, with several visits to court.

GFC commented that the Court process is still going on but is not an impediment to legally operate, due that the Court resolved that Mr. Rambarran as the legitimate operation manager of TSA concessions granted to WTTCL (See details in Criteria 1.1.4.). Therefore GFC does not oversee any inconvenient with the process.

1.2 FME shall have authorization to harvest in the forest management unit.

Criterion Level Findings: WTTCL show evidences of authorization to harvest in TSA 01/91 and 10/85.

1.2.1: FME shall have documented permission from the Guyana Forestry Commission, Amerindian Village Council, Private Landowner.

Yes No

N/A

Findings: WTTCL has two Timber Sales Agreement (10/85 and 01/91) signed by the Guyana Forestry Commision on January 20th 2000. Both TSA has a validation period of 30 years. No other permissions are required.

1.2.2: The FME shall hold a valid license (TSA, WCL or SFP), or similar instrument governing the harvesting of forest resources.

Yes No

N/A

Findings: The Guyana Forestry Commision signed Timber Sales Agreement (TAS) No. 10/85 and 01/91 on January 20th, 2000 for a period of 30 years. Both TSA were a renewable where the beneficiary is Willems timber & Trading Company Ltd. These TSA governing the harvesting of forest resource. Concession 10/85 has an extension 168,038 acres and concession 01/91 has an extension of 139,907.40 acre.

1.2.3: Legal license or similar instrument shall have been issued according to the relevant laws and regulations by the Guyana Forestry Commission under authority of the responsible Ministry.

Yes No

N/A

Findings: The legal license are the Timber Sales Agreements signed by the Guyana Forestry Commission (GFC). Other documents required to operate concessions are:

• Operation Permits: Issued by the Environmental Protection Agency (under the Environmental Protection Act No. 11 of 1996, the environmental production (amendment) Act 2005 and the environmental protection regulation 2000). The permits are No. 20130214-WTTLO by TSA 10/85 and No. 2013027-WTCPOL by TSA 01/91 for period June 2013 to May 2016. Both permits were signed by Indarjil Ramdass, Executive Director on Jun 19, 2013.

• Forest Management Plan: Both plans (TSA 01/91 and 10/85) were approved on September 2014 by Mr. Rawle Lewis, Deputy Commissioner of Forest, GFC.

• Annual operation Plan: Both plans were approved by Mr. Rawle Lewis of the GFC. AOP of TSA 10/85 was approved on January 13, 2016 and AOP of TSA 01/91 on January 18, 2016.

• Block Approval: June 30, 2015 were approved blocks 9E, 9F, 10F, 11D, 12E, 10D by Tawle Lewis, Deputy Commissioner of Forest (GFC) and January 20, 2016 were approved blocks 8E, 18M, 18N. All blocks are of the TSA 01/91.

Legal licenses to operate were showed to the audit team as proof of compliance. Issuance was done according to the legal procedures.

1.3 Evidence shall exist that the forest manag ement area has been legally classified for the type of land-use or commercial activities conducted.

Criterion Level Findings: GFC is the authority that has the right to classify the forest land use. Willems Timber & Trading Company Limited was granted a Timber Sale Agreement (TSA) reference TSA 01/91 and 10/85 in Region 7 by the Government of Guyana. Maps were produced to demonstrate clear identification of boundaries. FME respect the prescription of the license in terms of restricted areas.

1.3.1: The forest harvesting activities shall correspond to the legal land use classification for the FMU.

Yes No

N/A

Findings: The Forest Resource Information Unit (FRIU) of the Guyana Forestry Commision (GFC) has prepared the Forest Resource Allocation Map of Guyana. On this map is clearly identified WTTC as beneficiary of the TSA 01/91 and 10/85.

1.3.2: Forest harvesting area shall be indicated on a map at a scale to permit identification of boundaries.

Yes No

N/A

Findings: WTTCL has the Forest Resources Allocation Map of Guyana at Scale 1:1,000,000. This scale permit identification of boundaries in a general terms. Organization has another maps Scale 1:50,000 prepared by GFC were boundaries are clearly.

1.3.3: The harvesting areas shall not conflict with land-use classifications for areas where timber harvesting is prohibited.

Yes No

N/A

Findings: Timber Sales Agreements 01/91 and 10/85 were defined by GFC. The only restrictions are: not harvesting in the buffer zones, not harvesting in areas with slopes > 40% and not harvest in 4.5% of the productive forests (Biodiversity reserve)

1.3.4: The designation of the FMU for timber harvesting of the type being carried out shall have followed the legally prescribed procedures.

Yes No

N/A

Findings: Concessions areas were defined by GFC and clearly identified in the Forest Resource Allocation Map of Guyana as "Forest Reserve".

Standard Requirement Compliance

PRINCIPLE 2: APPROVED PLANNING AUTHORIZATIONS AND O PERATIONS

The FME shall have received the necessary approval for the basic and fundamental planning requirements legislated as necessary to enable forest management and shall adhere to the planning and operational requirements.

Principle Level Findings: AOP and FMP were approved by GFC. According with GFC and with evidences reviewed all the legally required procedures are adhere to in all documents.

2.1 If legally required, a current Forest Mana gement Plan approved by the relevant authorities sh all be in place prior to commencement of corresponding forest management activities.

Criterion Level Findings: WTTCL has two FMP, one for each TSA for period 2014-2018. Both FMP were approved by GFC on September 2014

2.1.1: A forest management plan shall be in place prior to commencement of utilization of the forest and approved by the Guyana Forestry Commission.

Yes No

N/A

Findings: Both plans (TSA 01/91 and 10/85) were approved on September 2014 by Mr. Rawle Lewis, representative of the GFC. These plans are an update for these period. Plans were approved by a letter stating "Please note that the plan is in keeping with the GFC minimum requirements for sustainable forest management plan". Issuance was done according to the legal procedures (Verified with GFC).

2.1.2: The forest management plan shall have been approved according to the legally prescribed process.

Yes No

N/A

Findings: GFC confirmed that WTTCL submitted its management plans in the time and appropriate fashion. A letter of approval was issued by GFC as proof of compliance.

2.1.3: Clear evidence (e.g. maps) shall confirm that the management plan area is located within the licensed FMU.

Yes No

N/A

Findings: Each FMP includes maps that confirm that the management plan area is located inside of each TSA agreement. These areas were verified on the field.

2.2 If legally required, annual operating or harvesting plans shall be in place and approved by legally qualified authorities.

Criterion Level Findings: WTTCL has two AOP, one for each TSA for 2016 year. Both AOP were approved by GFC on January 2016.

2.2.1: If legally required, a current, approved operating or harvesting plan shall exist. Yes No

N/A

Findings: Both AOP were approved by Mr. Rawle Lewis of the GFC. AOP of TSA 10/85 was approved on January 13, 2016 and AOP of TSA 01/91 on January 18, 2016. Plans were approved by a letter stating "Please note that the plan is in keeping with the GFC minimum requirements for sustainable forest management". Issuance was done according to the legal procedures (Verified with GFC).

2.2.2: The contents of the operating and harvesting plans shall be consistent with approved forest management plans and adhered to in the field.

Yes No

N/A

Findings: Annual Operating Plans are aligned with Forest Management Plan. No inconsistencies were found in these documents.

2.3 Legally prescribed dimension restrictions and annua l allowable cut or production quotas shall clearly be included in appl icable planning and operational documents and adhered to in practice.

Yes No

N/A

Criterion Level Findings: During the field inspection, the following observations were made: • Respect of buffer zones: one creek was checked, marks were established to identify the restricted area • Application of directional felling: 25 stumps were checked. • Respect of Maximum Cutting Diameter, which was equal or above 35 cm in all cases. • Proximity restrictions: 8 meter between 35-40 cms and any restriction 40 cm and over. • Compliance against the cutting intensity established by GFC (8.33 m3/ha): 10 blocks were harvested in 2015 and

only 2008 m3 out of 7589 m3 allowed were harvested in the reported season. All this requirement are included in the "Code of Practice for Forest Operations" for Timber Sales Agreement and Wood Cutting License Holders, 3rd edition, May 2013.

2.4 Harvesting and felling shall be strictly confined to areas and species approved for harvesting by national, regional or local regulations; these shal l be adhered to in practice and, if legally require d, identified in the operating or harvesting plans.

Criterion Level Findings: The audit team did not find any inconsistency with the compliance of species and harvesting areas restriction. The planning documents and maps provide these information accordingly.

2.4.1: Harvesting shall only be conducted within the authorized boundaries of FMU and shall not take place in areas where harvesting is legally prohibited or subject to restrictions.

Yes No

N/A

Findings: During the field visit (Blocks 9E, 8C, 8D, 18M of TSA 01/91 area), it was confirmed that harvesting is carried out in the authorized boundaries, according to the AOP and FMP.

2.4.2: Only species and/or trees allowed for harvest by the Forests Act and associated regulations shall be harvested.

Yes No

N/A

Findings: According to site inspection and document review, the company only harvest the allowed species. It was confirmed by GFC consultation. Mainly harvested species are: Greenhearth, Purplehearth, Shibadan, Locust, Washiba, Darina, Mora, Tatabu and Kabukalli.

2.4.3: For Timber Sales Agreements (TSAs), areas where harvesting is prohibited or subject to legal restrictions (e.g. riparian buffers, slopes exceeding a set gradient, etc.) shall be identified in maps and in the operating and management plans.

Yes No

N/A

Findings: WTTCL holds maps where buffer zones are indicated clearly following requirement of Code of Practices (Section 4.4.3. Width of buffer zones). Areas with slope greater than 40% are segregated from harvesting as CoP prescription.

2.4.4: Wood confiscated or seized from illegal operations shall not be allowed as legally verified, unless being subject to recourse (e.g. fines, court decision, compensation) wood subsequently becomes legal following the relevant requirements of the law.

Yes No

N/A

Findings: No wood have been confiscated within the boundaries of FMU. But, according with Code of Practices, WTTCL should inform to GFC of illegal forestry activities. GFC shall to do an inspection and measure the wood. This wood is property of GFC and GFC has the option to sell it. According with WTTCL, the company is not interested in buy this kind of wood.

2.5 If legally required, approved Environmenta l and Social Impact Assessments shall be in place.

Criterion Level Findings: No Social Impact Assessment is needed. Instead, EPA requires an Environmental Management Plan for each concession license. WTTCL submitted to EPA the correspondent documents.

2.5.1: If required by the Guyana Forestry Commission or the Guyana Environmental Protection Agency, Environmental and Social Impact Assessments shall have been approved by the legally qualified authority, the Guyana Environmental Protection Agency.

Yes No

N/A

Findings: EPA commented that Environmental Management Plan is the requirement to comply with environmental aspects. WTTCL submitted to EPA the corresponding EMP for each granted concession. The permits are No. 20130214-WTTLO by TSA 10/85 and No. 2013027-WTCPOL by TSA 01/91 for period June 2013 to May 2016. Both permits were signed by Indarjil Ramdass, Executive Director on Jun 19, 2013.

2.6 FME shall keep approvals and related docum ents for a minimum of five (5) years and until any renewal.

Yes No

N/A

Criterion Level Findings: WTTCL is aware of this procedure. The audit team viewed approval documents from 2013.

Standard Requirement Compliance

PRINCIPLE 3: PAYMENT OF RELEVANT FEES AND TAXES

The forest management enterprise shall fulfill all obligatory taxes, fees and/or royalty payments associated with maintaining the legal right to harvest and permitted harvesting volumes.

Principle Level Findings: The FME complies with this principle.

3.1 All applicable and legally prescribed fees, royalti es, taxes and other charges shall be paid in keeping with the requirements of the GFC or relevan t agency.

Criterion Level Findings: WTTCL showed evidences of royalties, taxes and acreage fees payments.

3.1.1: FME shall be current with required payments – or have and abide by an agreed payment plan with the Guyana Forestry Commission – and shall maintain documentation for payment of royalties and acreage fees.

Yes No

N/A

Findings: WTTCL paid an Acreage Fees annually for each TSA area and paid Royalties according with information of the Removal Permits prepared monthly. On January 15 2016, GFC send a letter signed by Edward Goderhan, Head of Finance, to M. Harry Rambarran with a statement of account at 31/December/2015 for both TSA area, including Royalty and Acreage Fee. These statements including next information: a. TSA 01/91: WTTCL had a total outstanding of GYD$ 84,721. At September 2015, WTTCL had a royalty

outstanding of GYD$ 1,440,487 and an Acreage Fees outstanding of GYD$ 2,308,476. WTTCL paid GYD$ 1,500,000 on October 09, 2015 (Receipt A187338) and other GYD$ 1,500,000 on November 26, 2015 (Receipt A18864).

b. TSA 10/85: Total outstanding is GYD$ 3,046,827, GYD$ 95,239 of Royalties and GYD$ 3,046,827 of Acreage Fee. WTCCL mention that any payment was made because not harvesting activities were conducted.

On February 01, 2016, WTCCL paid GYD$ 84,721 of TSA 01/91 and GYD$ 1,500,000 of TSA 10/84 (Receipt A193121). Pending balance at this month is GYD$ 1,500,000 of TSA 10/85. All receipts were presented by the company. Although WTTC has a debt to the Government, GFC allows that harvest activities continue without any restriction. It is a recommendation that WTTCL paid the total outstanding as soon as possible to avoid any issue with GFC (OBS 01/16).

3.1.2: Royalties shall be paid according to the actual harvested volume, species and qualities following legal requirements.

Yes No

N/A

Findings: Royalty is paid based on the Removal Permit where species, volume and qualities are specified. This document is produced monthly and they were checked during document review. GFC also indicated that payments are aligned with this official document.

3.1.3: Income tax shall be declared according to the legislation and applicable tax shall be paid within required timelines.

Yes No

N/A

Findings: WTTCL presented to the audit team its Corporation Tax original assessment with number 185253, year of assessment 2015, stating the year of income 2014. Next assessment (for 2015) need to be presented in April 2016. It confirms that WTTCL is up to date with this requirement. Another tax is the Value Added Tax. This is paid montly to the Guyana Revenue Authority. This tax is 16% of total of sales logs. Company presented declarations of November (paid December 21, 2015) and December (paid January 22, 2015).

Standard Requirement Compliance

PRINCIPLE 4: TRANSPORT AND TRADE

The FME shall adhere to applicable transport, trade, import or export regulations, procedures and restrictions.

Principle Level Findings: WTTCL showed compliance with the requirements of this principle.

4.1: FME shall be legally registered and licensed as a b usiness and approved for conducting the defined business activities with the relevant authorities (e.g. GFC), as required by law.

Yes No

N/A

Criterion Level Findings: WTTCL is allowed to transport logs throughout the transhipment permit. Legal registration as a business was demonstrated in indicator 1.1.1.

4.2: Income from wood and wood product sales shall be declared according to the legislation, and income tax shall be paid in full w ithin the required timelines.

Yes No

N/A

Criterion Level Findings: WTTCL pays VAT on log sales. Invoices were seen as proof of compliance. Company Income tax is up to date (see indicator 3.1.3).

4.3: FME shall adhere to applicable wood and wood produc ts trade and transport regulations and/or restrictions.

Yes No

N/A

Criterion Level Findings: WTTCL uses transhipment permits to transport the logs from one point to another, this is the only transport regulation prescribed by GFC.

4.3.1: The export price of forest products shall be approved by GFC as reflecting true market value (i.e., in line with the GFC benchmark prices for different species) prior to export.

Yes No

N/A

Findings: WTTCL present the GFC benchmark prices for differences species. Prices declared in export invoices reviewed (Invoices ASPL 13/2015 and LF 35/2015) are in line with GFC prices.

4.4: Permission to trade CITES -listed species shall be documented, and compliance with the applicable provisions and requirements of CITES sha ll be demonstrated.

Criterion Level Findings: No CITES species are traded.

4.5: FME shall document clear evidence of possession of applicable authentic official documents (e.g., custom documents ) of wood and wood products for import and export, in accordance with relevant laws and regulations.

Criterion Level Findings: WTTCL export logs and sawn wood. On this section only apply exportation of logs. WTCCL has License No. GFCESS00292016 of Timber Dealer Export. The license was request by WTTCL on January 04, 2016 as renewal and was approved by GFC on January 06, 2016. The license authorize at WTTCL export timber since Itaballi landing until December 2016.

4.5.1: All export of wood products must be accompanied by the appropriate documentation as required by the GFC, Customs and Trade Authority and Plant Health Services Unit.

NOTE: All material shall be classified correctly according to species, quality and quantity.

Yes No

N/A

Findings: Logs are exported following requirements given by the Guyana Forestry Commission, the Customs and Trade Administration, Customs Anti-Narcotis Unit and the Phyto-Sanitaty Unit of the Ministry of Agriculture. Documents required to permit any export are: Timber Marketing Certificate, Commercial Invoice, Certification of Origen, Customs C72 Declaration Form, Timber Export Certificate, Packing List, Phyto-sanitary Certificate and Statement of Origen. WTTCL showed documentation of Invoices ASPL 13/2015 and LF 35/2015.

Standard Requirement Compliance

PRINCIPLE 5: FULFILMENT OF HARVESTING REGULATIONS The FME shall be operating in conformance with legal requirements relating to the harvesting of forest products. Management plans and annual operating plans as required by law shall exist, shall contain accurate information, and be adequately implemented.

Principle Level Findings: WTTCL complies with the management plans and annual operating plans according to

GFC requirements. Adequate implementation on the ground was also observed.

5.1: Compliance with relevant local and national laws, a nd legally binding codes of practice relating to fo rest management and harvesting operations shall be docum ented.

Criterion Level Findings: WTTCL is mandated by GFC to prescribe the code of practice of timber forest harvesting. In this regards, the company has documented procedures in its FMP to undertake harvesting activities under this management practice.

5.1.1FME shall document and adhere to all legally prescribed specifications for harvesting, covering aspects such as timing, harvesting procedures, equipment, and/or layout of harvest.

Yes No

N/A

Findings: FME holds two a FMP for each concession, where the all the forest activities are documented following the Guyana Code of Practice (CoP). It also includes production schedule, equipment to be used and lay out of harvest.

5.2: FME shall be in conformance with forest mana gement plan requirements.

Criterion Level Findings: Management plans contains the relevant and required information according to GFC guidelines. Implementation is taken place in consistency with the planning documents.

5.2.1: Forest management plans shall contain all the legally required information and procedures in accordance with the GFC Forest Management Plan Guidelines.

Yes No

N/A

Findings: Management Plans are in alignment with the overall requirements demanded by GFC. Both FMP were approved by GFC on September 14, 2014.

5.2.2: FME shall implement the management plan according to all applicable legal requirements.

Yes No

N/A

Findings: During the field visit it was witnessed the proper implementation of the management plan, complying with legal requirements.

5.3: FME shall be in compliance with requirements in ann ual operating or harvesting plans.

Criterion Level Findings: By document review and field visits the audit team concluded that AOP is taking place according to all legal requirements.

5.3.1: Annual operating or harvesting plans shall contain accurate information and procedures, according to all legal requirements as set out in the GFC Annual Plan of Operations Guidelines.

Yes No

N/A

Findings: Annual Operations Plans follows the guidelines provided by GFC including all the required information to undertake the harvesting accordingly. Both AOP were approved by GFC on January 2016.

5.3.2: FME shall implement the annual operating or harvesting plans according to all legal requirements.

Yes No

N/A

Findings: By site inspection it was possible to verify that FME implements AOP respecting all legal requirements.

5.4: Reports on harvesting shall be compiled according t o legal requirements. Yes No

N/A

Criterion Level Findings: Removal permit are legally required by GFC as monitoring documents. They are submitted annually according with GFC requirements.

5.5: FME shall document legality of all contractors, inc luding the registration and compliance to legal requirements, to undertake harv esting activities.

Yes No

N/A

Criterion Level Findings: The human resource officer provided the list of contractors with its appropriate registration. NIS and income tax payments were also showed as legal compliance to undertake the work as a contractor.

PRINCIPLE 6: FULFILLMENT OF ENVIRONMENTAL REGULATIO NS

The FME shall demonstrate conformance with local and national laws relating to the environmental obligations of a forest management operation, including but not limited to conservation of protected areas, wildlife, rare, threatened and endangered species, water and soil.

Principle Level Findings: FME complies with the environmental guidelines established by GFC.

6.1: FME shall implement legally required environmental precautions and impact mitigation measures required, such as those related to soil damage, buffer zones, retention of trees, seasonal restrictions, e tc.

Yes No

N/A

Criterion Level Findings: EPA commented that Environmental Management Plan is the requirement to comply with environmental aspects. However, all required environmental precautions and impact mitigation measures are including in the "Code of Practice for Forest Operations" for Timber Sales Agreement and Wood Cutting License Holders, 3rd edition, May 2013. This is the official guide of forest activities on TSA areas. Restrictions and impact mitigation measures are included in section 4. Pre-Harvest planning, 5. Construction of road network, drainage structures and watercourse crossings, and section 6. Logging operations. During the field visit, auditors verified that FME implement environmental precautions and impact mitigation measure included in the Code of Practice.

6.2: FME shall implement nature protection regulations a s applicable, for protected areas, set-asides, protected species, etc .

Yes No

N/A

Criterion Level Findings: Timber Sales Agreements 01/91 and 10/85 were defined by GFC. The only restrictions are: not harvesting in the buffer zones, not harvesting in areas with slopes > 40% and not harvest in 4.5% of the productive forests (Biodiversity reserve). WTTCL harvest wood in permitted areas. No evidence of harvesting protected species was found.

6.3: All legally required procedures for surveying, mana ging and protecting endangered or threatened species within the managem ent unit shall be followed.

Yes No

N/A

Criterion Level Findings: The only legally procedures for endangered or threatened species is protection. No evidences of damage of endangered or threatened species were found.

6.4: Employees of the FME shall be prohibited from hunti ng and trade in wildlife, unless it is legally permitted, and documented perm ission from the resource owner exists.

Yes No

N/A

Criterion Level Findings: Company had prohibited hunting in both TSA. Field worker confirmed this prohibition. Not evidence of hunting was observed during the visit of camps.

6.5: FME shall be in conformance with legal requirements of environmental monitoring, if applicable.

Yes No

N/A

Criterion Level Findings: Operation permits issued by EPA include the clause 6.11 that said "Submit annual reports to the EPA on the progress of the operation and compliance with the conditions under which this Environmental Permit was granted on or before 31 March each year (please see attached form)". Both permits were issued on January 2013. On February 12 2016, WTTCL presented the first annual report to the Environmental Protection Agency for both TSA areas. The environmental aspects of the project described on these reports are: waste management, water supply,

fuel storage, forest monitoring, fire, pest and disease management, use of chemicals, biodiversity reserves, drainage system, noise management, flora and fauna. No other environmental monitoring activities are required.

Standard Requirement Compliance

PRINCIPLE 7: WORKER’S RIGHTS

The FME shall demonstrate compliance with local and national laws relating to social issues such as health and safety, labor laws, and third parties’ use rights.

Principle Level Findings: FME showed outstanding compliance against the requirements of this principle.

7.1: FME and contractors shall meet all applicable laws and/or regulations coverin g health and safety of employees and their families.

Criterion Level Findings: FME and contractors hold basic procedures on health and safety aspects in section 7.2 of its AOP 2016, FMP also contains some guidelines to address it. Detailed procedures are documented in its SOP/Doc 10, which follows national guidelines related to Occupational Health and Safety (OHS) procedures. Implementation was seen during field visit.

7.1.1: Legal requirements for Occupational Health and Safety shall be adhered to. Yes No

N/A

Findings: The company holds procedures on Occupational Health and Safety (OHS) that cover the legal requirements demanded by the Government. At the facilities they were observed first aid kits for employees in the forest base camp and log pond, proper demarcation of workshop, oil storage and extinguisher allocated in strategic sites, proper waste disposal, and use of the basic Personnel Protection Equipment (PPE).

7.1.2: National or regional minimum age established for persons involved in hazardous work shall be adhered to.

Yes No

N/A

Findings: There were no employee under 16 years, which is the minimum age for hazardous work in Guyana.

7.2 All employees of FME and contractors shall b e employed under formal contract if legally required.

Yes No

N/A

Criterion Level Findings: This criterion is not legally required. Only contractors have written contracts, staff personnel is on verbal agreement.

7.3 All employees shall be covered by applicable legally required insurance. Yes No

N/A

Criterion Level Findings: WTTCL showed the receipt of National Insurance Scheme (NIS) payment for December 2015, done on 16 January 2016 for 30 personnel workers. An employee interviewed showed his NIS card as proof of compliance. Contractors are individuals workers and payed their own NIS. Copies of receipts were seen at the human resource office.

7.3.1: National Insurance Scheme payments should be made by the FME and contractors as required for its direct employees.

Yes No

N/A

Findings: FME pays to their employees 5.6% of the NIS and 8.4% is paid by the worker. Payrolls of December 2015 were checked to confirm compliance. WTTCL showed the records of NIS payments for his contractor dated of December 2015.

7.4: All employees shall hold applicable legally required certificates of competence for the function they carry out.

Yes No

N/A

Criterion Level Findings: This requirement is not applicable to Guyana.

7.5: All employees of FME shall be paid and treat ed in compliance with national laws and regulations as well as applicable international con ventions.

Yes No

N/A

Criterion Level Findings: Throughout several interviews held with workers and stakeholders, audit team verified that national laws and ILO principles are respected.

7.5.1: FME shall adhere to the International Labor Organization's Fundamental Principles:

• Freedom of association and the effective recognition of the right to collective bargaining;

• Elimination of all forms of forced or compulsory labor;

• Effective abolition of child labor;

• Elimination of discrimination in respect of employment and occupation.

Yes No

N/A

Findings: Interviews to workers revealed the following:

• Workers do not have association due that they are able to negotiate their benefits and rights directly with FME managers.

• All workers earns minimum or above the minimum salary. • No children were seen working in the FME. • Workers commented that they do not feel discrimination of any kind.

7.5.2: Minimum wage laws shall be followed if applicable. Yes No

N/A

Findings: The minimum payment in the payroll is 70,000 Gy$ /monthly, which is the minimum wage in Guyana. Payrolls of January 2016 were reviewed to confirm this finding.

Standard Requirement Compliance

PRINCIPLE 8: THIRD PARTIES RIGHT

Principle Level Findings: There are no communities with customary rights within and or around the granted concessions. Consulted stakeholders confirmed this finding.

8.1: Legally recognized customary rights shall be t aken into account in management of forest resources .

Criterion Level Findings: No customary rights were found.

8.1.1: Documented agreements with those who hold customary user rights shall be in place prior to harvesting.

Yes No

N/A

Findings: No customary rights were found.

8.1.2: Appropriate mechanisms and procedures shall be implemented to mitigate and resolve conflicts and grievances related to land rights and user's rights.

Yes No

N/A

Findings: No customary rights were found.

Standard Requirement Compliance

PRINCIPLE 9: CONTROL OF UNAUTHORIZED ACTIVITIES

The FME shall work to control unauthorized or illegal activities. The FME shall identify, monitor, and implement activities to control illegal or unauthorized activities that may occur within the FMU.

Principle Level Findings: FME has procedures in place to detect and prevent illegal activities within the holding concessions. Mining is the only non-forestry activity that is taking place on site. FME established a multiagency collaboration to combat illegal mining.

9.1: Illegal or unauthorized activities, e.g., il legal logging, poaching or illegal settlement, that occur within or through the forest shall be id entified and documented.

Yes No

N/A

Criterion Level Findings: No illegal activities were found within the concessions. . FME holds procedures and protocols to detect and prevent record them if it is the case, in its SOP/Doc 11 (Illegal logging, illegal mining and encroachment).

9.1.1: The FME should demonstrate awareness of non-forestry legal rights occurring on its concession (e.g. map of mining claims).

Yes No

N/A

Findings: FME has a map of mining legal rights in its EMP with the number of license for each claim, however no information on the owner of the claims are available. FME should has the information of the mining claim holders in case it needs to consult or follow up their activities (OBS 02/16).

9.1.2: As far as practicable the FME should identify and document non-forestry activities occurring in active areas of its concession.

Yes No

N/A

Findings: FME has a list of concession licenses number and a map of them. Besides mining, there are not other non-forestry activities within the concessions.

9.2: Illegal or unauthorized activities shall be controlled in collaboration with the resource owner, regulatory agencies, and other relevant part ies as appropriate.

Yes No

N/A

Criterion Level Findings: FME plans to lease with GFC and GGMC to control illegal logging or mining. Up to date no records were found.

9.2.1: Where illegal or unauthorized activities are identified within the concession, the FME shall inform the appropriate authorities and collaborate as feasible with control efforts.

Yes No

N/A

Findings: Lastly there were no claim on illegal mining activities. According to FME, in the event that it is found, the procedure is to report to the nearest GGMC office who is in charge to follow up the case. According to GGMC consultation, there was no reporting on illegal mining so far within both concessions. However, if there is a case, it will proceed to investigate accordingly.

Part II: Principles and Criteria for Chain of Custo dy (CoC)

Documented control of the Chain of Custody (CoC) of forest products is fundamental to the traceability of verified forest products from the forest source through manufacturing and distribution to ensure the authenticity of a verified product claim. This principle applies from the point of harvest up to the forest gate for FMEs.

Note: in the CoC criteria, “verified” refers to materials qualifying as Rainforest Alliance VLO/VLC or equivalent.

Standard Requirement Compliance

10 Quality System Criteria

10.1: FME shall define CoC system responsibilities and ap point staff positions Yes No

N/A

Criterion Level Findings: FME did not mention individual responsibilities for each control point in its FME SOP (NCR 02 /16).

10.1.1: One overall responsible person shall be designated for the CoC control system. Yes No

N/A

Findings: The overall responsible person is Mr. Harry Rambarran, WTTCL Chairman. On the field the person in charge for the CoC control system is Mr. Rickfor Innis, Operation Manager. These designation are described in introduction section of the SOP.

10.1.2: Individual responsible persons shall be designated for each critical control point in the CoC control system.

Yes No

N/A

Findings: FME did not mention individual responsibilities for each control point in its FME SOP (NCR 02 /16).

10.2 FME shall develop and maintain an up-to-date documented control system, procedures and/or work instructions to ensure implementation of all applicable CoC standard requirements.

Yes No

N/A

Findings: WTTCL has prepared Standard Operation Procedures (SOP) for Sawmill Operations, Version January 2016. This SOP cover the movement of logs from WTTCL areas through to sawn lumber or log export. SOP include procedures to ensure implementation of all applicable CoC standard requirements.

10.3 FME shall develop and implement procedures for internal auditing of its systems as related to the requirements in this standard.

Yes No

N/A

Findings: Internal audits are prescribed in section 6.3 of SOP. VLC coordinator will carry out this process and ensure that the company is complying with the requirements of the standard. Internal audits has been conducted on October and November 2015, and January 2016.

10.4 FME shall develop and implement procedures for addressing nonconformances (nonconformity reports, corrective action requests, observations) identified by auditors.

Yes No

N/A

Findings: Organization set procedures to address and follow up nonconformances identified by auditors (internals and externals) in section 6.4 of its SOP. VLC coordinator is the personnel in charge of monitoring corrective actions implementation and update the status of each nonconformance. During the second and third internal audits, 27 action were follow-up.

10.5 FME shall develop training requirements and implement training as follows:

a. All applicable staff and workers shall be trained on the CoC procedures to a degree relevant to the scale and complexity of the system and position; and,

b. Records shall be kept to demonstrate training has taken place.

Yes No

N/A

Findings: According to interviews, workers were able to perform their job in line with CoC requirements. Records of CoC training were seen at central office. Mr. Rickford trained to its forest crew according to the position and duties to be developed from June to December 2015.

10.6 FME shall define and document verified Claim Categories. Yes No

N/A

Findings: One product group has been defined, and 08 species has been included as VLC products. WTTCL has defined and document VLC as Claim category for this product in its product group schedule and SOP.

10.7 FME shall define the sales system(s) or “Forest Gate” for each verified product covered by the CoC system (e.g., standing stock, sale from log yard in the forest, sale at the buyer’s gate, sale from a log concentration yard).

Yes No

N/A

Findings: The Forest Gate is the Iteballi Landing. All logs are stockpiled on this sites and logs are selected by the buyer on this site.

10.8 FME shall develop and maintain records to document quantities of verified materials for the following:

a. Production of materials; and,

b. Outputs sold with and without a claim.

Yes No

N/A

Findings: Organization developed procedures to comply with this requirement in section 4 Database Control Procedures of SOP. In Itaballi Landing, WTTCL has a office where information of logs received is recorded. Also, WTTCL has a local sale/export log Control. It is the responsibility of the VLC Coordinator to maintain all database controls. These databases were observed during the assessment visit. Each logs harvested in TSA managed by WTTCL has a unique GFC number tag. These number are registered in the Production Record Forms, in the Log Trucking Form and in the Permit To Remove Forest Produce Form. Auditors review Log Trucking Forms # 375, 359, 356 and 357. All logs will be verified materials becouse both TSA will be part of the validation scope.

11 Material Handling and Segregation

11.1 FME shall develop and implement an effective timber tracking system to demonstrate traceability from standing timber until ownership is transferred at the forest gate.

Yes No

N/A

Findings: FME uses GFC numbers to trace its logs in all stages of the supply chain, since the forest to the log market, trucking to the log yard and barging. Throughout records of production it also trace: block number, tree number, specie and dimensions of each log harvested. During log yard inspection it was possible to trace logs against its GFC tags in data base.

11.2 FME procedures and practices shall control the risk of mixing verified forest products with non-verified products which originate outside the scope of the verification.

Yes No

N/A

Findings: There is no risk of mixing material, given that all the logs received come from the company`s concessions (TSA 01/91 and 10/85).

11.3 A system shall exist to identify FME products as verified (e.g., through documentation or marking system) at the forest gate.

Yes No

N/A

Findings: WTTCL uses GFC number to identify its material until the forest gate. All the logs are documented in a format record, then downloaded into a data base. It is not necessary a marking system because all logs coming from the company TSA areas.

11.4 FME shall keep verified material physically separate as secure units at all stages of harvesting, storing, and transporting.

Yes No

N/A

Findings: WTTCL has demarcated the log pond with mobile sings that indicate the status of the log, whether if it is VLC or Non VLC. During transport, the logs will be backed by the transhipment permit and packing list that will contain the VLC claim. The log pond is also shared with other logs owner and its boundaries are not well defined. FME should define the boundaries of its log property to avoid any confusion (OBS 03/16).

11.5 All material that cannot be identified as verified shall be kept physically separate from verified material.

Note: material that is pending evidence of its legal status shall be kept separate until such time that adequate documentation is obtained.

Yes No

N/A

Findings: All the logs are easy to identify due that the GFC numbers are painted in both faces of the log, in the event that the tag is drop, the log will be kept separately from VLC sources and it will be identified as Non VLC log. These procedures were explained by the personnel in charge of Itaballi Landing and it is described in Section 3.2 Segregation of the SOP.

11.6 FME shall use a distinguishing mark (e.g., the verification code) to identify products as verified at all stages of handling.

Yes No

N/A

Findings: No marks are used to identify products. VLC claim will be used in WTTCL internal records.

11.7 FME shall develop and implement procedures to ensure that markings to identify Rainforest Alliance verified materials are distinguishable from other verification/certification markings and claims.

Yes No

N/A

Findings: WTTCL does not have another verification/certification codes.

12 Shipping and Sales Criteria

12.1: FME shall include claim information on sales invoic es and shipping documents, including the following:

Yes No

N/A

Criterion Level Findings: Organization is aware of this requirement. It is documented in section 5.2. of SOP.

12.1.1: A description of the product as verified by Rainforest Alliance (i.e., “RA VLC”) Yes No

N/A

Findings: Organization is aware of this requirement. It is documented in section 5.2. of SOP. Once the company has materials in place it will be implement it accordingly.

10.1.2: The quantity/volume and species for each product.

Yes No

N/A

Findings: Transhipment Permit to remove forest produce is the required legal document to transport logs, the company compiles it in each purchase order. Transhipment permits numbers reviewed on site: 26149, 26151, 26144, 26145, 26146. These documents include volume and species of each logs that it is sold.

10.1.3: The Rainforest Alliance verification code (i.e., RA-VLC-XXXXXX). Yes No

N/A

Findings: Organization is aware of this requirement. It is documented in section 5.2. of SOP. Once the company has materials in place it will be implement it accordingly. WTTCL has the experience to use a Rubber Stamp with the VLC code because it was verified by Rainforest Alliance in the past. The Rubber Stamp was showed by the company

13 Claims and Public Information

13.1 FME shall not use the VLC claim until it is in possession of a valid Rainforest Alliance Verification Statement.

Yes No N/A

Findings: WTTCL is not using VLC claim. The company is aware of this requirement and has procedures to follow up. Procedures are included in section 5.3. of SOP.

13.2 FME shall ensure that all VLC verification claims and marks follow the applicable Rainforest Alliance policies:

Yes No N/A

Findings: FME holds a Standard Operating Procedures (SOP) which in section 5 indicates procedures to make VLC claims according to RA policies. VLC coordinator is the personnel in charge of its compliance. He is aware of them.

13.2.1: On-product labeling shall not be permitted. Yes No

N/A

Findings: See findings of criterion 13.2.

13.2.2: Use of the Rainforest Alliance VerifiedTM Mark off-product shall only be allowed in combination with a qualifying and approved verification claim.

Yes No

N/A

Findings: See findings of criterion 13.2

13.2.3: Use of the verification code (RA-VLC-XXXXXX) on products shall only be used for traceability of products.

Yes No

N/A

Findings: FME states in its SOP, that it will use SW-VLC-XXXX. However SW is no longer verification body initials. FME should use RA instead of SW in its verification code (OBS 04/16)

13.2.4: Use of the Rainforest Alliance VerifiedTM Mark in promotion of the FME’s verification shall not imply that any aspects are included which are outside the scope of the verification.

Yes No

N/A

Findings: See findings of criterion 13.2

13.4 FME shall have procedures in place and demonstrate that all review and approval correspondence with Rainforest Alliance for verification claims is kept on file for a minimum of five (5) years.

Yes No

N/A

Findings: FME has procedures in place to follow up with this criterion. Awareness was proof during interview to relevant staff.

Part III: Multi-site Management Requirements The multi-site management criteria have been developed to facilitate evaluation of organizations that have two or more sites included in the scope of their supply chain and wish to manage those under one Verification Statement. The multi-site management requirements, plus communication with Rainforest Alliance, are coordinated by the Verification Statement Holder. Multi-site criteria allow Rainforest Alliance to evaluate the participating sites based on audit sampling in recognition of control and reporting systems monitored by the Verification Statement Holder. In addition to these criteria, Rainforest Alliance shall ensure that all sites included in the verification scope of a multi-site supply chain comply with all relevant legality and CoC requirements in the VLO or VLC verification standards as applicable. N/A Check this box if the organization is not a multi-site

14 Documented Procedures and Responsibility

14.1 The Verification Statement Holder shall appoint one person (or position) with overall responsibility for the multi-site management and conformance with Rainforest Alliance’s multi-site management requirements.

Yes No N/A

Findings: The Verification Statement Holder (VSH) appointed to Mr. Rickford Innis as the personnel with overall responsibility to oversee the multisite management requirements.

14.2 The Verification Statement Holder shall have documented procedures in place, covering all multi-site requirements of this standard.

Yes No N/A

Findings: VSH has a Standard Operating Procedure for its multisite scope that covers all the requirements of this standard.

15 Records

15.1 The Verification Statement Holder shall have access to, and collate data from all sites for Rainforest Alliance’s annual audits as well as upon request.

Yes No N/A

Findings: VSH will have access to data of all sites and information will be available for RA annual audits or upon request. Given that VSH is the company that holds the forest produce scope, no contracts are needed for this site. For the processing site, VSH signed a contract agreement (on January 04, 2016), where this procedure was considered.

15.2 The Verification Statement Holder shall maintain up-to-date, centralized records for all sites for a minimum of five (5) years, including:

1. List of sites in the verification scope, including name, address, site manager, date of entry, and date of removal when applicable.

2. Signed consent forms for all sites. 3. Records showing the scope of verification for each site. 4. Volume summary data for each product group, including purchases,

production and conversion, inventory, and sales for each site.

Yes No N/A

Findings: VSH will centralized the information requested. During the audit visit, the following exhibits were collected: • List of sites included in the verification scope with the date of entry, manager, address and phone • Signed consent form from the processing site only, given that the FME site is the VSH • Records of the scope of each verification. • Volume summary data was provided for the FME site, given that the processing site did not have any inputs and

outputs in place.

16 Site Management and Auditing

16.1 All sites in the scope of the verification shall have signed a consent form that includes the following:

a. Agreement to conform to the obligations and responsibilities of participation in the multi-site verification for the period as described in the Verification Statement Holder procedures and the Rainforest Alliance VLC Verification Agreement; and,

b. Agreement to conform to the relevant Rainforest Alliance Standard(s) and correct any nonconformances identified by Rainforest Alliance and/or the Verification Statement Holder.

Yes No N/A

Findings: VSH submitted to audit team the contract agreement held with L.S. Harridat sawmill signed on January 4, 2016 which includes the requirements demanded by this criterion.

16.2 Prior to admitting a new site into the scope of the verification, the Verification Statement Holder designated auditor shall carry out an initial audit of each site to ensure that it complies with all the requirements of the applicable Rainforest Alliance verification standard.

Yes No N/A

Findings: VSH has a checklist to assess the sites against the RA verification standard prior its inclusion in the verification scope. After the closing meeting, VSH conducted an assessment to verify the compliance of the sawmill using the provided checklist.

16.3 The Verification Statement Holder designated auditor shall carry out an audit of each site at least once a year to confirm continual conformance with all the requirements of the applicable Rainforest Alliance verification standard.

Yes No N/A

Findings: VSH holds procedures to undertake annual audits to all the sites included in its supply chain. It is documented in section 3.3 of the multisite management. Relevant staff is aware of the procedures to follow.

16.4 When nonconformances are found during internal audits, the Verification Statement Holder shall issue corrective actions for the nonconformances to applicable sites and verify implementation.

Yes No N/A

Findings: VSH has procedures in place to comply with this requirement (section 6.4. of the SOP). The VLC coordinator is in charge of implementation and is aware of it.

16.5 The Verification Statement Holder shall provide reports with the results of all internal audits. Yes No N/A

Findings: VSH delivered to RA the results of three Internal Assessments conducted to the different sites of the supply chain in order to follow this criterion.