8.4 Steps to Exercise Due Diligence
Key Points in Excercising Due Diligence
- The first step in reducing risk of illegally sourced timber entering your supply chain is to perform an assessment to rate the level of risk your suppliers represent. This is achieved by having suppliers fill out questionnaires, analyzing responses using scenario tables and assigning suppliers a numeric index of scores that rate them as high or low-risk.
- On the basis of a supplier's risk rating, different levels of verification actions can be selected. High-risk suppliers need independent assessments of legality.
- Traceability of all timber products is key to ensuring that legal and illegal timber and timber products do not get mixed together in the supply chain. There are both paper-based (most common) and technology-based traceability systems available.
Because simple, objective evidence demonstrating legality is rarely available from countries with the highest levels of illegal harvesting, your organisation will need to identify which suppliers are most likely to be able to comply with your company's aims and which are least likely—that is, which suppliers present the lowest risk of supplying illegal timber and which suppliers present the highest risk.
Your organization will need to develop systems for assessing and rating risk (risk rating). Risk rating allows you to do the following:
- Systematically identify the suppliers most likely to be trading illegal timber
- Develop future sourcing strategies based on the risk rating of suppliers
- Show suppliers what actions they could take that would help them reduce their risk rating
- Monitor the progress of suppliers over time as they work toward being able to supply legal timber, that is, continual improvement
Step 1 - Assessing the Level of Risk
Risk rating is used to assess the likelihood that a given non-certified product from a given supplier contains illegally sourced timber. Rating suppliers based on this risk considers a range of information from various sources, some of which is available in the public domain and some that is provided by the suppliers themselves.
Risk rating consists of the following activities:
- Requesting suppliers to complete and return questionnaires
- Analyzing the returned questionnaires using scenario tables
- Feedback to suppliers and monitoring for continuous improvement
- Data management
Requesting Suppliers to Complete and Return Questionnaires
The first step in the risk rating process is to send questionnaires to your suppliers. A model questionnaire and guidance that can be adapted for use in your organization is available here.
Analyzing the returned questionnaires using scenario tables
The returned questionnaires need to be systematically analyzed so that suppliers can be rated between high-risk and low-risk. The risk of illegal timber being traded along a supply chain can be broken down into three broad elements.
- Country of origin of the timber. There are risks associated with the geographical source of the supply. If a supplier is based in a country from which high volumes of illegal timber are exported and that supplier is unable to provide objective evidence demonstrating legality, then the risk that the timber is illegal is high. The scenario tables indicate the type of regulatory infrastructure that is most likely to encourage trading in both legal and illegal timber. Ratings for some countries are suggested, based on estimated rates of illegal logging or "suspicious" sources in those countries.
- Supplier company's attitude. The way a supplier operates with regard to a range of issues, such as its own general sourcing policies, how it relates to stakeholders and its attitude toward local communities, has been shown to be strongly linked to that company's attitude to buying and supplying illegal timber. The questionnaire asks a number of questions in this respect.
- Supply chain complexity. The way a supplier sources timber from its own suppliers is key to the risk of it trading in illegal timber or timber products. The questionnaire requests various types of objective evidence to assess whether sufficient supporting documentation has been gathered. You can analyze these three elements using the scenario tables. The analysis uses three different scenario tables, which relate to different sections of the questionnaire. Although indexes tend to be difficult to justify in purely scientific terms, they provide a systematic means for analyzing questionnaires. For example, the UK Timber Trade Federation, which used scenario tables for field trials (using a very similar approach), showed that the tables were effective and the results were independently repeatable.
In an ideal world it would be possible to calculate a risk rating for each product that you purchase—that is, each product in your inventory that carries a unique product code would have an individual risk rating. In reality this may not prove cost-efficient because of the difficulty of gathering any meaningful information on a product-by-product basis. Experience has shown that a more practical approach may be to group products into product categories, such as redwood mouldings from company X, rather than rate each individual molding (with all their different dimensions) supplied by company X.
Any supplier that has not returned a questionnaire within the specified deadline is automatically classified as a high-risk. The assumption is that the supplier was either unable or unwilling to supply the required information or too badly organized to do it. The importance of receiving the supplier's objective evidence to support the questionnaire answers cannot be overemphasized.
Examples of objective evidence can be found here. A completed questionnaire without objective evidence is just a self-declaration. Experience suggests that self-declarations without supporting evidence cannot be relied on.
Feedback to Suppliers and Monitoring for Continuous Improvement
The analysis of the questionnaire to reach a supplier rating has the added advantage of identifying weaknesses in the supplier's responses. It is then possible to give suppliers feedback, explaining how their score was derived and the types of actions needed to reduce the score. It is therefore possible to provide practical advice (without necessarily being specific or an expert) on how they can reduce their risk rating—an additional benefit to the supplier for completing the questionnaire. The types of actions that will move suppliers from the high-risk to the low-risk category are discussed later in this section.
Some suppliers may rate as high-risk in terms of supplying illegal timber in the initial assessment but they may strive to improve by changing their practices so that on subsequent assessments their risk-rating score improves. Others' ratings may change very little over time. It is important to maintain records that demonstrate how suppliers have improved their performance and processes over time. Experience suggests that suppliers who are unwilling to make adjustments to comply with a buyer's sourcing policy requirements are potentially also those more likely to trade in illegal timber. Over time you may wish to stop trading with these suppliers and replace them with companies that seek to support your commitments.
Managing the whole process of supplier assessment involves sending out the questionnaires, following up with suppliers to get them to respond, capturing their responses and the associated objective evidence, analyzing the returns, and then reporting the results to all relevant parties. This process can be demanding in terms of management time. You will need an electronic database system and/or well-organized manual filing system to maintain the process.
Step 2 - Make Further Enquiries Where Needed
Once you have assessed the risk associated with a given product range from a given supplier and decided what kind of verification process is required, the next step involves implementing that process and, over time, progressively eliminating sources that are unable to provide the verification required.
One key strategy will be to make follow-up enquiries with suppliers that have provided weak responses to the questionnaire. Suppliers rated through the questionnaire assessment as being high-risk are likely to have not provided any or enough supporting evidence; thus the questionnaire, if returned, will be largely a self-declaration. You will need to either ask the supplier to provide more evidence or investigate the timber
Gathering information from the upstream parts of the supply chain is frequently difficult. Traders are concerned about issues such as confidentiality, particularly if they occupy a "middleman" position in the supply chain. They are concerned that the objective evidence will reveal the identity of their supplier and that you may begin trading directly with the upstream end of the supply chain. Also, suppliers occupying an intermediary role may have great difficulty getting the information from those upstream from them, particularly if they only buy a relatively small percentage of their supplier's total production; that is, they have limited leverage. Sometimes the objective evidence you require just does not exist.
Step 3 - Improve Traceability and Verify Legality
Certified timber is tracked using inspected and verified chain-of custody systems that enable you to easily answer the question, "How did it get here?". Timber and timber products that supposedly originate from a certified forest but are not accompanied by a current and credible chain-of-custody certificate cannot be regarded as certified because the chain-of-custody has been broken and illegal product may have become mixed with the certified product. Chain-of-custody certificates apply only to timber and timber products from a certified forest. If a product comes from a verified legal forest, traceability is just as critical.
A key component of ensuring that timber is kept legal once it leaves the forest and enters the supply chain is to prevent illegal timber mixing with it. If legal timber and illegal timber are mixed, the whole product line can be "tainted". Once timber has left the forest, its legal quality can only be recognized if it can be shown to have come from that forest—in other words, traceability.
Without traceability, verification of the legality of forest management is largely a waste of time. The supply chain, or as some prefer to call it the demand chain, must have a dependable level of integrity. An efficient way of achieving this is to encourage suppliers to develop a system for tracing all timber and timber products from their own suppliers.
If you take the demand chain view, traceability should start at the downstream end of the chain and steadily be applied back upstream toward the forest. Traceability implemented in this manner will have a strong commercial orientation with a greater likelihood for successful implementation, with each business that forms a step along the demand chain benefiting.
Logs, timber and processed timber goods start their journey in the source forest and are then processed by primary and possibly secondary processing industries, exported, possibly transshipped and imported. All this may happen before the goods finally fall under your organization's control. Although it is critical to identify the source forest, it is also critical to make sure that the timber from that source forest is what you receive, rather than illegal timber that has infiltrated into the supply chain en route.
The traceability of the supply chain is vital for ensuring that you receive goods containing legal timber and that there is no "laundering" of illegal timber. In practical terms, it can be expensive and, in some cases, physically impossible to track timber down highly complex or fragmented supply chains. Complex supply chains will always be more likely to support the laundering of illegal timber.
The risk-rating system takes into consideration the potential for dilution of the supply chain by illegal timber. In high-risk situations that have a history of laundering timber, mixing legal and illegal timber to yield "legal" timber, the best option to ensure a clean supply chain is by tracking the timber from the source forest to the physical location where it comes under your organization's control. Without such tracking or traceability in their supply chains, your suppliers will be unable to meet your verification requirements for a verified legal or known licensed source or any other verification approach, such as those described below.
Traceability can be achieved through various combinations of paper- and technology-based tracking systems. In many countries where the trade in illegal timber is a problem, elaborate official paper-based systems have been implemented to theoretically track the movement of timber from the forest to the point of export. This has included the use of unique government certificates or permits covering the transportation and movement of timber in general. These documents are often linked with national forest legislation, and in many cases, it is illegal to transport timber without the necessary specific official permission accompanying the timber or timber products.
However, such systems can easily break down in countries where the regulatory capacity is weak because of a lack of resources or because of corruption, where the forest areas to be regulated are huge, or where the government has no means to manage data centrally. To make matters worse, modern printing technologies have made it relatively simple to corrupt paper-based systems with virtually indistinguishable false or forged paperwork.
Nevertheless, paper-based documentation is still the mainstay of traceability systems and is likely to be so for some time. A good understanding of the system that produces documentation, and familiarity with the "look and feel" of relevant documentation, will provide a measure of confidence and some safeguard.
To assist with this, WWF has produced a series of Keep It Legal Country Guides (in PDF format) for Brasil, China, Indonesia and Russia, for use in conjunction with this guidance, that describe how these paper-based systems operate in reality and their strengths and weaknesses.
The feasibility of tracking timber has increased significantly as Internet-related technologies and services have become more effective, cheaper and more accessible. Unreliable paperwork combined with scribed or painted identifiers on the end of logs are starting to be replaced by bar-coded tags and radio frequency identification devices (RFIDs) with the data capture carried out with handheld personal computers (PC). This enables the tree-related information to be scanned electronically and uploaded from the handheld PC directly onto the Internet, and from there it is stored in dedicated database systems. These modern technologies provide the opportunity to link individual standing trees in the forest with the logs produced from them in a much more secure manner than was possible in the past. These approaches rely on the standing trees in the forest being tagged and then the data on its position and main parameters (height, species and diameter) all being captured on a database. The systems are made secure by using uniquely identifiable tags that are linked to the key tree measurements and resultant log metrics through a record on the database. More information on timber tracking systems can be found below.
Any supply (or demand) chain has a number of critical control points along its length. Critical control points are locations at which the timber undergoes basic changes, for example, where the trees are felled, where the logs are loaded onto a log lorry and where the logs enter the sawmill. The Internet enables information from these critical control points along the supply chain to be aggregated in a single online database, no matter how remote the geographic locations of the critical control points are or what companies are involved. To manage all or part of a supply chain efficiently, you need information on how the product is moving along the supply chain. An Internet-driven system of the type described helps those collecting the information to benefit directly from their efforts as they receive reports containing key management metrics that are compiled and made available the instant any new "flow" information arrives at the database.
In an ideal world, in countries where the risk of illegality is high, the timber or timber product would all be tracked from the standing tree in the forest to the point where it enters your warehouse or comes under your organization's control. The reality is that, currently, little tracking of the types described is taking place. It is a new approach and is being adopted only by the more innovative and forward-looking operators.
Tracking, if appropriately implemented, should help a business operate more efficiently. Information from tracking can be useful for forest managers, in terms of monitoring the volumes and species being harvested from each location, mill owners, in terms of knowing what logs, species or timber products are coming out of the forest and when they may arrive at the mill, the regulatory authorities, in terms of being able to verify the legal right of a specific forest operation to transport timber and for estimation of revenues to be collected, independent auditors wishing to audit legality.
Many of the business benefits have yet to be fully realized. Currently, log and timber tracking is principally seen as a system of control that is used by government and verification organizations rather than as a business tool. Once these systems are more widely implemented and understood, it is likely their full value will be better appreciated. (For a more detailed review of timber tracking and chain of custody systems, see Dykstra et al., 2003, Technologies for Wood Tracking Verifying and Monitoring the Chain of Custody and Legal Compliance in the Timber Industry.)
A promising recent technological advance is the use of DNA fingerprinting to prove the source and traceability of timber. Each individual tree has a unique genetic code (DNA) and code variations between individuals can be modeled to predict codes across a given geographical area. The primary use is to verify source by matching the DNA from samples taken from individual stumps in a source concession with the DNA from associated logs at a processing mill. The second, and possibly more powerful, method amalgamates the DNA data gathered from individual testing into a genetic database covering a geographical area.
The database allows samples taken from anywhere to be compared with known spatial DNA variations in order to pinpoint actual source to a geographical range. Certisource Timber has tested this technology in Southeast Asia and is currently able to undertake DNA matching for Merbau, Teak, Nyato, Mersawa and Matoa species.
Some companies that provide log and timber tracking services include:
Certisource Timber - www.certisource.net
TracElite - www.tracelite.com
Track Record - www.trackrecordglobal.com
Other organizations offer similar services.
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