Developing a methodology to assess paper mills’ forest-sourcing practices

Six steps to guide mill visits

The Mill Assessment Framework includes six steps (topic areas) against which mills are assessed:

1. Right people, right conversation: Is the BCP team able to speak directly with those who manage responsible sourcing for the mill, and are the latter willing to share examples of resources, systems, and databases?
2. Capability and resourcing: To what extent does the mill know the country origin and associated risks of its sources, choose suppliers based on sustainability considerations, and engage in long-term supplier relationships? How well are the relevant staff members trained and equipped?
3. Supply chain assessment and management: How does the mill manage for responsible fibre sourcing, including through information collection, risk assessment, certification, and other control mechanisms?
4. Supplier engagement: How are sourcing requirements communicated to suppliers and how are suppliers supported to meet those criteria? 
5. Ambition and commitment: How well-defined and rigorous are the mill’s responsible sourcing objectives, targets, and tracking and reporting processes?
6. Mill wastewater treatment: Is the mill conserving water and protecting sensitive water supply areas? Is it adequately managing wastewater and sludge to minimise pollution?

Each step includes one or more indicators against which mills are given one of the following grades based on a clear set of criteria: Beginning (20%), Learning (40%), Consolidating (60%), Developing (80%), and Leading (100%).

Before a BCP visit, the mill receives a guidance document that summarises the steps and types of questions that will be asked so that the operator understands the scope of the discussion. Once on site, BCP team members interview employees who are responsible for procurement, certification management, supplier engagement, and other pertinent areas, as well as reviewing key documents, systems, and tools (e.g., training materials, supplier code of conduct, sourcing policy, etc.). The mill is then graded on each of the Mill Assessment Framework’s six steps, using standardised criteria.

Grading is done on a five-point scale that ranges from “Beginning,” for mills that have not yet started to consider responsible forest sourcing issues, to “Leading,” for those that are at the forefront of responsible sourcing practices. The score is determined by indicators and criteria included in the MAF, resulting in an objective assessment across the six steps.

After a visit, the BCP draws up a draft report and shares it with the mill operator, which is allowed to provide comments and additional information before it is finalised. The BCP also sends the mill a variety of tools and documents to help it move up the five-point scale on each MAF topic by identifying gaps and making improvements. These resources include key elements of the AFi’s Operational Guidance—particularly on supply chain management; Free, Prior, and Informed Consent (FPIC) to ensure respect for the rights of Indigenous Peoples and local communities; and monitoring and verification. Mills are encouraged to use the report and supporting materials to identify strengths and weaknesses in their current approach, and to improve their policies and processes. Each mill’s score is then shared with publishers, which can use it to make purchasing decisions. 

The MAF examines a range of issues, including supply chain mapping and traceability, staff capabilities and training, awareness and management of risk for each sourcing origin, and supplier engagement. For example, in the area of supplier engagement — step 4 — the BCP team reviews how well a mill is communicating its responsible sourcing requirements to its fibre suppliers. This includes questions such as: Are there strong policies and standards in place? Do these cover all key social and environmental issues relating to responsible fibre? Do mechanisms exist to ensure that suppliers understand what compliance entails? The answers to these and other questions determine the mill’s scores for that step.

Carnstone’s Neil Everett gives a specific example of how the BCP applied the Accountability Framework when creating the MAF: “The Framework’s Core Principle 6.4 helped us to determine the way we shape questions to mills based on the complexity of their supply chains and level of control over forest management.” This Core Principle describes good practice for managing indirect suppliers, which the MAF reflects by defining different criteria for integrated mills (where raw timber is processed into paper) than for non-integrated mills (where market pulp is purchased from other suppliers).

Because integrated mills source timber directly from a forest owner, the assessment focuses on forest management and on-the-ground mechanisms. Since non-integrated mills source fibre through an intermediary (a pulp mill), they must ascertain the forest sources of indirect suppliers as a way of mitigating their own risk, as well as communicating and enforcing their requirements with the pulp mill from which they are buying. For the BCP, each mill visit is the first stage of a relationship that is expected to deepen over time. Toward this goal, the BCP has also started running workshops in key sourcing countries, bringing forestry experts and others together with its mill groups to help build awareness of sourcing issues and the capacity to address them.