• APRIL has completed the relevant preconditions to commence the process for ending its disassociation with FSC.
• In November 2023, APRIL signed a Memorandum of Understanding (MoU) with FSC to start the remedy process. The MoU constitutes a commitment by APRIL and its Corporate Group to work constructively towards ending association in a timely manner, while complying with the applicable terms and conditions set forth in the FSC Remedy Framework.
• All updates related to the remedy process will be made available on FSC Connect.
• FSC has appointed and contracted independent assessors to conduct social and environmental baseline assessments as outlined in the FSC Remedy Framework.

• Upon completion of the independent baseline assessments, a Remedy Plan will be developed, in dialogue with impacted rightsholders and affected stakeholders to determine agreed actions that APRIL will undertake to remedy past harms. This Remedy Plan will be reviewed and approved by a Third Party Verifier appointed by FSC.
• Once approved, APRIL will then proceed to implement the Plan.
• Upon fulfillment of agreed association thresholds, subject to monitoring and third-party verification, the FSC Board of Directors will consider a decision to end APRIL’s disassociation.

• The previous baseline assessment that was conducted by Forest Finest Consulting in January 2020 was part of FSC’s pilot program to test the generic roadmap for developing company-specific roadmaps for ending disassociation.
• In July 2023, FSC adopted the FSC Remedy Framework (FSC-PRO-01-007 V1-0) which requires the conduct of new baseline assessments to comply with new provisions.

• Under the updated FSC Policy for Association V3, a “Corporate Group” encompasses all entities to which an associated organization exercises “control.” This definition broadens beyond ownership and emphasizes the ability to direct, restrict, regulate, govern, or administer another company’s performance through various means, including authority, rights, contractual arrangements, or other mechanisms.
• Following this definition, the Corporate Group[1] for our case includes the following Business Groups and related entities: Royal Golden Eagle (RGE), Asia Pacific Resources International Limited (APRIL) Group, Bracell, Sateri, Asia Pacific Rayon, Asia Symbol, Asian Agri, Apical Group, Pacific Energy, International Woodchip Corporation (IWC), Asia Honour Paper, and PT. Toba Pulp Lestari (TPL).
• Any new acquisitions by APRIL or related entities that fulfill the FSC PfA V3 definition of control will be part of the Corporate Group.
• For APRIL and Apical, the framework also encompasses third-party suppliers. Please refer to Corporate Group list for the scope of the FSC Remedy Framework as assessed and published by FSC.
• All entities within the Corporate Group must fulfill what are referred to in the Remedy Framework as ‘foundational and trust-building’ requirements by establishing policies and systems to prevent unacceptable activities.

• Under the updated FSC Policy for Association V3, a “Corporate Group” encompasses all entities to which an associated organization exercises “control.” This definition broadens beyond ownership and emphasizes the ability to direct, restrict, regulate, govern, or administer another company’s performance through various means, including authority, rights, contractual arrangements, or other mechanisms.
• In the case of TPL, two factors necessitate its inclusion in the Corporate Group for the APRIL Remedy process: shared ownership and commercial relationship.
• The FSC case page identifies TPL as part of APRIL’s FSC Corporate Group.

• The requirement for addressing past environmental and social harms applies to APRIL, its third-party suppliers, and TPL. The comprehensive list of companies can be found on the FSC Case Page.
• Based on this, our remedy plan will cover these impact areas:
  • Riau: APRIL (RAPP, Supply Partners and listed third-party suppliers concessions)
  • North Sumatra: TPL concessions
  • Kalimantan: IHM and listed third-party supplier concessions

• Until APRIL has achieved the Association Threshold as outlined in the Remedy Plan, RGE BGs (and any other new entity that becomes part of the Corporate Group) will be unable to pursue FSC associations such as applying for certification, membership, trade mark license agreements or promotional license agreements.

• Business Groups and related entities listed under the Corporate Group will be eligible to commence their certification process once third-party verification confirms that APRIL has achieved the Association Threshold as outlined in the Remedy Plan. This threshold defines the level of progress required for the Corporate Group to be considered for re-association with the FSC.

• As the first case under this new framework, a clear understanding of some of the requirements is still evolving from discussions with FSC and interested stakeholders. This contributes to the challenge of establishing definitive timelines.
• Despite the uncertain timeline, APRIL remains committed to ending its disassociation with FSC, noting we started this engagement with FSC in 2016 and have been actively working towards re-association.

• The remedy process consists of these phases:
  1) Identifying past environmental and social harms
  2) Developing a remedy plan
  3) Implementing and meeting association threshold
  4) Completion of implementation with monitoring, verification and participatory appraisal.

• APRIL is currently in the first phase of the remedy process.

• An independent third-party verifier appointed by FSC will review and verify the APRIL Remedy Plan to ensure it adheres to all stipulated requirements in the Remedy Framework.

• Implementation will commence upon formal approval of the Remedy Plan and duration will depend on the agreed remedy actions.

• Challenges mostly center on this being the first ever case of a remedy process under a very recently approved Remedy Framework and, therefore, many of the implementing procedures and mechanisms are still being developed as we go.

• Companies in the Corporate Group that are operating in the three impact areas – Riau, North Sumatra and Kalimantan – have each established a Human Rights Due Diligence system. This means that assessment of impacts, action planning and implementation to address salient issues, tracking, and communication of progress in addressing human rights impact are being conducted in each impact area.
• Important new policies on human rights, responsible sourcing, integrity, and ethics have already been developed and adopted across the whole Corporate Group.
• More information about APRIL human rights due diligence is available in our 2023 Sustainability Report.

• FSC Remedy Framework provides a definition of Indigenous Peoples which is adapted from the United Nations Permanent Forum on Indigenous Issues, Factsheet ‘Who are Indigenous Peoples’ October 2007; United Nations Development Group, ‘Guidelines on Indigenous Peoples’ Issues’ United Nations 2009, United Nations Declaration on the Rights of Indigenous Peoples, 13 September 2007. (Source: FSC-STD-01-001 V5-2) This is incorporated into the methodologies for the Social Baseline which will be applied by the Independent Assessors.

• The FSC Remedy Framework requires that FPIC processes are carried out when affected rights holders are present within the impact area.
• According to the FSC-STD-60-004 V2-0 International Generic Indicators, affected rights holders are persons and groups, including Indigenous Peoples, traditional peoples and local communities with legal or customary rights whose free, prior and informed consent is required to determine management decisions.
• Prior to applying FPIC as required by the remedy framework, it is important to first identify the affected rights holders that are present within the impact areas and their legal or customary rights which may have been impacted by the implementation of unacceptable activities.
• FPIC also establishes a framework for the participation of rights holders in the determination of remedy activities.
• An FPIC process is not needed if there are no rights holders affected by the unacceptable activities and/or no management decisions are to be determined.
• For more updates on FPIC application in APRIL’s Remedy Process, please go to the Remedy Process tab of the Remedy Microsite.

The methodologies for the baseline assessments are developed by APRIL to guide the Independent Assessor in conducting the assessments.  The implementation of the methodology by the Independent Assessor is based on their expertise and expert judgment. You can learn more about the methodology here.