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Forests Serial Offender Vietnam’s continued imports of illegal Cambodian timber ©EIAimage quibusandit, sitaqueenture dolendit, voluptam endusci psunto voluptas enisasdeevel ipsam anonymous. maximolorera doles magni tetea for safety reasons, mustremain tem aspedque nnes apeverrovid production and ofthisreport who, sin net fugitatur, qui int quenihic individuals who contributedto the dolorem volla vendam, consuo molor EIA expresses itsgratitudeto the nihic tem aspedquei oditaquates molorresponsibility ofEIA. sinnet fugitatur, qui int que doloremof this publication are the sole volla vendam, consequo vollaCooperation (NORAD).The contents vendam, conseqci oditaquates Agency forDevelopmentasped queiNorwegian oditaquates dolorem fugitatur,assistance ofUKaidand the qui int quenihic tem vendam,been produced with the consequo molor financial sin net cusAgency aci oditaquates dolorem UKLtd.Thisdocument has volla nobitby the ium alici bla Environmental cone consequam Investigation waswrittenand edited Ximporae.This report Utautfugitis resti utatia We wouldlike to thank 2 Forests efficiency inthe cooling sector. illicit tradeand improving energy greenhouse gases,exposing related to refrigerant eliminate powerful climate change by campaigning Finally, wereduce the impactof whales, dolphins and porpoises. and commercial exploitation of by plastic pollution, bycatch by addressing the threats posed safeguard global marine ecosystems cash crops like palmoil.We work to illegal logging and deforestation for tigers, and forest crimes suchas with afocusonelephants and expose transnationalwildlife crime, Our undercover investigations environmental crime and abuse. We investigate and campaign against ABOUT EIA eia-international.org E: [email protected] T: +44(0)2073547960 London N10NY UK and Wales Number: 440569842. Registered in England (UK) Ltd.Company Number: 7752350VAT Environmentalin England and Investigation Wales Agency VAT Number: 440569842. Registered (UK) Ltd.Company Number: 7752350 Environmental Investigation Agency eia-global.org E: [email protected] T: +12024836621 Washington DC20009USA PO Box 53343 EIA US 62-63 UpperStreet, EIA UK Environmental Investigation Agency

©EIAimage Serial offender official border crossing border official nearby the avoiding road, this along travel Sanctuary Wildlife Prich Phnom in felled carrying timber illegally Province, Cambodia. Trucks Snoul in border Vietnamese the near asawmill cover: Front ‘laundered’ be to boundaries 2Dam Sesan Lower the outside from felled illegally logs transports arev An Above:

Annex 2 Annex 1 Recommendations Consequences forthe VPA Counting crime 3.Phnom PrichWildlife Sanctuary 2.LowerSesan2Dam 1.Virachey NationalPark Stilloffending inCambodia-2018casestudies: Nolegalsource Introduction CONTENTS 20 22 25 14 10 16 21 12 4 8 6 3

through official border crossings at Hoa Lu in Bình Phước province and Le Introduction Thanh in Gia Lai province, and where it was smuggled out of Cambodia and into Vietnam across informal crossings near The Environmental Investigation Agency both Hoa Lu and Le Thanh. (EIA) has published numerous reports The formal quota system described in detailing Vietnam’s trade in timber illegally Repeat Offender appears to have ceased, harvested in, and illegally exported from, its resulting in a reduced imperative for 1234 Vietnamese traders to ‘legalise’ their neighbours . Laos long bore the brunt of this timber into Vietnam. Without the need trade but, as EIA detailed in its 2017 report to pay import taxes in Vietnam, EIA identified Vietnamese timber traders now Repeat Offender, the focus of this illicit trade offering timber ‘without papers’7. switched to Cambodia during the 2016-17 Within Cambodia, promises have been harvest season following stricter enforcement ©EIAimage made for decades to tackle illegal logging and the rampant deforestation affecting of logging and export bans in Laos. local communities and contributing to investigate whether the illegal trade in Above: illegally felled logs Cambodia’s poor governance record. are transported to the Sesan Cambodian timber – and Vietnam’s role in sawmill complex Cambodian Prime Minister Hun Sen has In Repeat Offender, EIA detailed how Forces license plates. it as a repeat offender – had ceased. Vietnam’s Gai Lai Provincial Government, repeatedly pledged he will end illegal mandated by Vietnam’s Ministry of logging. Nonetheless, illegal logging Hundreds of ‘arevs’ – basic trucks capable This report details how investigators Industry and Trade – a division of the 3 operations in Cambodia are coordinated of carrying up to 20m of logs along jungle found that while the nature of the illicit Central Government in Hanoi – had in Cambodia by powerful tycoons with tracks – ferried illegally harvested logs to trade had changed, there are still huge in 2016 issued quotas for the import close connections to senior members of timber depots inside Vietnamese Border volumes of illegally logged and traded of 300,000m3 of logs from Cambodia the Government and by members of the Army compounds located just inside Cambodian timber flowing across the in blatant disregard of Cambodia’s log armed forces and Government. Vietnam. These arevs avoided official border to Vietnam, despite Vietnam’s export ban. These quotas facilitated and border gates and Cambodian customs preparations for the VPA. Vietnamese incentivised large-scale illegal logging in Some enforcement appears to have officials, crossing instead into areas importers declared imports of 178,000m3 national parks and wildlife sanctuaries in occurred in Vietnam at the time of writing, controlled by the Vietnamese Border of logs and sawn timber worth nearly $76 Cambodia’s Ratanakiri Province at a time with the arrest of Phan Huu Phuong8, Army. million between October 2017 and March when the Cambodian Government was allegedly a central figure in a Vietnamese 2018, a vast majority (if not all) of which publicly demanding an end to all timber illegal logging network. Phoung is accused At these depots, logs were measured, is illegal6. As detailed below, the actual trade with Vietnam. of logging within a national park in taxed, and ‘legalised’ into the Vietnamese volume of this trade may be significantly Vietnam’s Daklak province, with some economy by members of the Vietnamese higher as there are reasons to believe reports stating that timber was also EIA also exposed how the quotas customs and forest departments before not all imports are being registered with being smuggled from Cambodia9. Media themselves may have been incentivised being loaded onto large trucks and sent to Vietnam Customs or being aggregated in 3 has reported possible “high probability with corrupt payments of $45 per m factories and wood processing hubs in Gai its statistics. to Vietnamese officials, including, as Lai, Ho Chi Minh, Quy Nhon and beyond. of collusion between law enforcement alleged by traders, the Chairman of Gia Lai agencies and the ring leader”10. EIA identified three main areas within Province’s People’s Committee, customs Just three days after the publication of Cambodia where substantial illegal and border army (military) personnel – While this arrest is not related to the large- Repeat Offender, Vietnam initialled a logging operations were under way, potentially amounting to $13.5 million in scale operations described in this report Forest Law Enforcement, Governance namely Virachey National Park in corrupt payments on the 300,000m3 of and appears to be an isolated instance of and Trade (FLEGT) Voluntary Partnership Rattanakiri province, the forests quotas. enforcement by Vietnamese officials, it Agreement (VPA) with the European surrounding the controversial Lower does show that enforcement is possible Union, a trade agreement that includes Sesan 2 dam in Stung Treng province in Vietnam. While such enforcement Quotas in hand, Vietnamese companies the provision for Vietnam to pass and and Phnom Prich Wildlife Sanctuary in should be welcomed, it appears that it is and their Cambodian counterparts implement legislation to address its Mondulkiri province. organised hundreds of loggers to enter significant imports of illegally harvested a breach of Vietnam’s logging ban that protected areas in Cambodia and the Below: logs from Phonm has motivated these actions and Vietnam or traded timber in return for timber Investigators tracked timber from these forests swiftly filled with the noise of exports to the EU being deemed to comply Prich Wildlife Sanctuary continues its role as a serial offender in are transported to Vietnam sites to where it entered Vietnam, both chainsaws. Having likely bought off with the requirements of the European the illegal timber trade, with much larger Cambodian provincial government Union Timber Regulation (EUTR)5. volumes of illegal timber continuing officials and members of the Cambodian to flow across the Cambodian border Armed Forces, loggers enjoyed their With the formal signing and ratification unhindered. protection as roads were closed to of this agreement expected in the outsiders and timber convoys escorted by second half of 2018, EIA returned to the 6 Both illegally harvested and exported – see ‘No Legal Source’, below vehicles bearing Cambodian Armed region during the 2017-18 dry season to 7. Timber without papers was advertised on the facebook group ‘Vietnam Wood Market’. Accessed January 2018 8. https://tuoitrenews.vn/news/society/20180428/vietnam-arrests- mastermind-behind-largescale-illegal-logging-ring/45345.html 1 EIA, Borderlines: Vietnam’s Booming Furniture Industry and Timber Smuggling in the Mekong Region, 2008 9. https://laodong.vn/phap-luat/vu-go-lau-sat-don-bien-phong- 2 EIA, Crossroads: The Illicit Timber Trade Between Laos and Vietnam, 2011 muon-danh-vot-go-thanh-ly-de-tuon-tu-campuchia-ve-604910.ldo 3 EIA, Checkpoints: How Powerful Interest Groups Continue to Undermine Forest Governance in Laos, 2012 10. http://english.thesaigontimes.vn/59598/Through-a- 4 EIA, Repeat Offender: Vietnam’s persistent trade in illegal timber. 2017 needle%E2%80%99s-eye.html 5 http://ec.europa.eu/environment/forests/pdf/11_05_2017_EU_Vietnam_VPA.pdf

4 Environmental Investigation Agency 5 ©EIAimage No legal source All of the timber trade from Cambodia to Vietnam is illegal. This illegality takes two forms – illegal harvest and illegal export to Vietnam.

Illegal harvest Logging in Virachey National Park more closely resembles the type of operation Within two areas identified by EIA, described in Repeat Offender. Here powerful Cambodian timber barons the illegal trade has been initiated by supply the Vietnamese market through Vietnamese companies which have companies which possess various logging paid substantial bribes to Cambodian permits. However, these permits are used authorities to be able to illegally fell timber to launder timber illegally felled in the in the national park and smuggle it to areas surrounding their concessions, Vietnam and to receive protection while including protected areas. The pretence in Cambodia. All logging in Virachey of legality given by these companies does National Park occurred with no pretence not hold up to scrutiny and they have been of legality – instead, Cambodian forest the focus of allegations of illegal logging rangers and armed forces, i.e those for a number of years. responsible for preventing illegal logging from occurring, blocked roads to prevent At the Lower Sesan 2 dam, Ang & outside eyes from accessing logging areas Associates Lawyer Co Ltd holds a logging and exposing illegal activities13. concession within the dam reservoir boundary. Having been repeatedly Illegal export accused of logging outside the concession boundaries since 2013, the company All of the trade to Vietnam appears to be has faced numerous demands from in breach of Cambodian laws. Cambodia the Cambodian Government to cease passed Sub-decree No.131 in November operations1112. Despite the dam reservoir of 200614, Article 3 of which prohibits the being filled during the 2017-18 season, export of: timber continues to flow out of the concession and onto the Vietnamese • round logs except from plantations market from logging sites up to 20km ©EIAimage outside of the concession. • rough sawn timber except from plantations ©EIAimage

Phnom Prich Wildlife Sanctuary, a • square and rectangular timber of protected area in Eastern Cambodia, saw 20 thickness and width more than 25cm Above: an aerial view of part It also appears that the luxury timber thnong per cent of its area converted to Economic of the Lower Sesan 2 dam (Pterocarpus pedatus/macrocarpus) was being Land Concessions (ELCs) during 2011-12, sawmill complex. The filled • luxury timber and timber products reservoir is visible at the top logged in Phnom Prich Wildlife Sanctuary where ‘degraded’ forest was allowed to of this image and illegally exported to Vietnam. Import be logged. Again, illegal logging outside • charcoal from natural forests. declarations submitted to Vietnamese Customs concession boundaries was widespread Right: trucks loaded with logs Further, the Cambodian Coalition make their way towards the from October 2017 to March 2018 – seen by EIA and Phnom Prich became a focal point Vietnamese border. Snoul 3 Committee for Forest Crime Prevention, – include 14,791 m of Thnong worth $17 million, of the Cambodian Government’s 2016 Province, Cambodia established at the behest of Cambodia’s none of which could be legally exported. crackdown on illegal logging. Today, these ELCs are largely logged out, with Prime Minister during a 2016 illegal Vietnam signed a MoU on illegal logging and investigators finding fields where logs logging crackdown, completely closed the cross-border transport with Cambodia in 201215 supposedly originated. Despite this, border with Vietnam to the timber trade yet has consistently failed to respect Cambodia’s extremely high volumes of timber were cut in 2016 in response to the high levels of timber export laws. and hauled to Vietnam from ELCs inside illegal timber flowing into the Vietnamese Phnom Prich Wildlife Sanctuary during the market. 2017-18 season; even concessions which EIA observed both round logs and rough have had their licenses cancelled by the sawn ‘square logs’ from each of the Cambodian Government continuing to three sites being sent to Vietnam in send timber to Vietnam. clear contravention of Cambodian law.

11. The Cambodia Daily, Government Suspends Logging in Stung Treng Dam Concession, 25/10/13 12. The Phnom Penh Post, Answers demanded on dam site, 2211/13 15. EU FLEGT Facility, EFI, ASEAN timber trade, customs and timber legality scoping 13. Investigators were prevented from accessing logging areas by rangers and military police in January 2018 study. April 2014 ©EIAimage 14. Article 3 of Sub-Decree No.131 dated 28 November 2006 on Forest and Non-Timber Forest Products Allow for Export and Import 6 Environmental Investigation Agency Serial offender 7 Still offending in Cambodia - 2018 case studies: EIA identified 3 areas in Cambodia where large volumes of timber are illegally felled and sent to neighbouring Vietnam:

• In Virachey National Park, a Vietnamese company struck a multimillion-dollar deal with a Cambodian Border Army Unit to construct a road into the National Park and steal timber.

• At the Lower Sesan 2 Dam site, a massive complex of up to 60 sawmills processes logs which have been illegally felled in forests up to 20km away, and then laundered through the dam site.

• Inside Phnom Prich Wildlife Sanctuary, cartels controlled by powerful logging barons strip timber from inside the protected area. Millions of dollars in bribes are paid to forest rangers, military, police, and media, as trucks travel Image Landsat / Copernicus, © 2018 down a ‘road of tolls’ to Vietnam Google, US Dept of State Geographer, Data SIO, NOAA, US Navy, NGA, GEBCO

8 Environmental Investigation Agency Serial offender 9 A deal was reportedly brokered by an officer of the Cambodian Border Police Still Offending in Cambodia: Unit 203, who reportedly accepted $60,000 from Yin Tin company to ensure local 2018 case studies communities would not stand in the way of logging plans. In June 2017, he 1. Virachey National Park reportedly promised payment from the Vietnamese company of $10,000 to the Logging within Virachey National Park, deal with members of Cambodia’s Border O’Kampha community and $6,000 to the largest in Cambodia, was exposed in Army Unit 23 to construct a road into the Phnom Panha Khlaing’s community in EIA’s 2017 report Repeat Offender, which area and extract timber. This information return for access to their forests. detailed how Vietnamese businesses, has since been confirmed by Cambodian with the support of the Vietnamese media reports1617. With the way clear to access the forests provincial government in Gai Lai province and smuggle timber across the border to Local sources alleged that Huang Korn, and Vietnamese military, illegally logged Vietnam, Vietnamese workers arrived of Yin Tin Company, paid Cambodian large volumes of timber from O’Tabok in the area en-masse in October 2017, authorities $10 million to facilitate the Community Forest, in the park’s north- bringing earth-moving equipment to smuggling of timber across O’Yerl and eastern corner. construct a road from the Vietnamese Donha San border posts. These are not border into the national park19. Chainsaws EIA returned to Virachey during the 2017- formal border crossings – the names refer and arevs soon followed. 18 logging season and again uncovered to Cambodian border police posts. large scale timber theft by Vietnamese To protect the operation from prying eyes, A wide range of different Cambodian companies, focused primarily within the forest rangers and members of Cambodia’s authorities were alleged to have accepted O’Kampha Community Protected Area and armed forces blocked roads and prevented bribes, with key players including Border Phnom Panha Khlaing Community Forest, access to the forest during logging and Police Unit 203 commander But Tily and directly to the west of O’Tabok. transport. Despite this, EIA investigators Military Police officer Nob Nak said to be were able to gain access and documented EIA investigators spoke with local facilitating the day-to-day operations. Nob 31 sites where illegal logging was Cambodian Border Police, Vietnamese Nak was reported by Cambodian media occurring and three Vietnamese logging loggers working inside Virachey National as having the ‘support’ of both Rattanakiri camps across the north-eastern corner of Park and local community members, who provincial military police commander the national park. detailed how the Vietnamese company Kim Rasmey and of Rattanakiri Province Yin Tin (believed to be a front company, Governor Thang Savon18. High value timber was roughly milled hiding the true company name) struck a into square logs within the forest, loaded ©EIAimage Below: an Arev loaded onto arevs and driven across the border. with illegally felled logs in 16. Reported by Cambodian news network PNN, 12/12/17 22 A lesser value species, pyinkado (‘sokram’ Cambodia to Vietnam . Above: kogs that have been Virachey National Park 17. http://swiftnewsdaily.com/archives/156285 18. http://swiftnewsdaily.com/archives/156285 in Cambodia, ‘cẩm xe’ in Vietnam, a rough sawn in Virachey hardwood used in construction) was In March 2018, EIA returned to the National Park, prior to being smuggled into brought to Vietnam as whole logs – a area around Le Thanh in Vietnam’s Vietnam further offence, as Cambodia has had a log Gia Lai province, where timber was export ban in place since at least 200620, entering Vietnam from Rattanakiri, and alongside banning timber trade with interviewed Vietnamese villagers who told Vietnam in 2016. investigators the Vietnamese Government had halted the trade at Chinese New Investigators uncovered how loaded arevs Year, although a Cambodian media report pass the local Cambodian Border Police from 30 March reported the trade had Unit 203’s headquarters21 and Cambodian resumed23. border post O’Takay before entering into Vietnam through the rear of the Đội Cao Cambodian media also reported24 on 28 Su Thanh Niên rubber plantation in Kon April that between 24 March and 2 April, Tum Province. and 23-28 April, 246 large trucks smuggled timber into Vietnam with the assistance Đội Cao Su Thanh Niên (Youth Team of the Cambodian police border gate at Rubber) is a subsidiary of Công ty cổ phần Oyadao. At least $19,000 in bribes was paid Cao su Sa Thầy (Sa Thay Rubber Joint per truck – amounting to at least $4.92 Stock Company, or SARUCO), a state- million in bribes across just 16 days. owned or state-controlled enterprise in Vietnam. SARUCO is itself a subsidiary of the Vietnam Rubber Group, which has been tied to numerous illegal logging and timber smuggling operations from

19. Locations reported by PNN 12/12/17 include 14.34513197814579,107.1400037404993 and 14.332520773634101,107.11342419345392 20. Article 3 of Sub-Decree No.131 dated 28 November 2006 on Forest and Non-Timber Forest Products Allow for Export and Import 21. at 14.2781, 107.368 22. Global Witness, Rubber Barons, 2013 23. http://www.moneaksekar.com/75874.html/ 24. Fresh News Asia, ខ្សឹបដាក់ត្រចៀក៖ ឈើសំរុកចេញទៅវៀតណាមតាមច្រកអូយ៉ាដាវ ខេត្តរតនគិរី តាមរថយន្តយីឌុប ក្រោយសមត្ថកិច្ចពង្រឹងនៅខេត្តក្រចេះ មណ្ឌលគិរី, 28/04/18

10 Environmental Investigation Agency Serial offender 11

©EIAimage site. A national police report This timing was met with a cynical from May 2017 stated that response from the Cambodian public, 2. Lower Sesan 2 dam “Forest destruction activities which interpreted the move as political Located on the Sesan River, just below informal crossings near both Trapaing Sre in Sesan district and timber and intended only to garner Government the confluence with the Srepok River in / Hoa Lu and Oyadao / Le Thanh border smuggling for sale in Vietnam support during the election rather than to Cambodia’s Stung Treng Province, the gates. is ongoing in the name of the prevent illegal logging. 400MW Lower Sesan 2 dam is the largest company clearing the Lower In Le Thanh, a focal point of the illegal Sesan 2 reservoir, owned by When EIA visited the surrounding forests ever built in Cambodia, with a 75m high in early 2018, the air remained full of the and five-mile-long dam wall25. The dam’s trade described in Repeat Offender, trucks business tycoon Kith Meng, but were illegally crossing the border after the relevant authorities have sound of chainsaws. Investigators found it 36,000-hectare reservoir began to be remarkably easy to find arevs transporting filled when the floodgates were closed in dark, as close as 1.5km from the official ignored it and failed to prevent crossing. EIA observed trucks re-joining it”34. timber. Depending on the cutting site, September 2017 and the first turbine began arevs were either delivering the logs generating power in November. the main road both in the centre of Le Thanh town and just beyond the towns’ Despite being aware of the vast directly to the sawmill or bringing them to The dam is a joint venture between edge, where they were met by Vietnamese amounts of illegally logged the banks of the Sesan river. At the river, Hydrolancang International Energy authorities. timber flowing through the logs were rafted together under boats (China, 51 per cent share), Royal Group dam site, transportation and and then transported out of sight to the (Cambodia, 31 per cent) and EVN Vietnam Four timber depots and sawmills were export licenses were still being sawmill. identified by EIA investigators visiting granted to Ang & Associates International Joint Stock (Vietnam, 10 per Despite members of the armed forces 26 the area in late 2017 and early 2018, three and Lawyers Co Ltd by the cent) . A subsidiary of the Royal Group, acting as security at the sawmill, EIA Ang & Associates Lawyer Co Ltd, chaired of which were in Le Thanh itself and the Cambodian Government as late fourth located on the main road to Pleiku as January 201735. investigators were able to interview by tycoon Kith Meng, has faced repeated various company managers. EIA was allegations that it has cleared outside city. Two of these sites had been recently constructed and were not in use when EIA The Cambodian Government informed that more than 60 companies of its concession in the dam’s reservoir finally responded to the illegal were operating within the complex, with 2728 visited the area in March 2017. EIA also since logging began in April 2013 . Ang & logging in Sesan at the end of a variety of Cambodian and Vietnamese Associates Lawyer Co Ltd has repeatedly observed vans with the seats removed and filled to the brim with timber crossing into February 2018, issuing a letter companies present. denied these allegations. demanding that all transport of Vietnam and making their way to one of ©EIAimage Managers estimated that approximately Satellite imagery from February 201829 these new yards31. all timber supposedly from the 36 60 per cent of the workforce was shows the reservoir almost entirely filled, reservoir cease . Government With Vietnamese authorities checking spokesperson Phay Siphan Vietnamese and that there were over meaning that the company’s assertions Above: An arev 200 arevs and 150 large haulage trucks it is only logging inside the reservoir trucks after they have illegally crossed the transporting illegally acknowledged illegally logged timber felled logs to the Sesan was being laundered through the dam involved throughout the entire operation. boundaries hold even less water. border and newly constructed log yards sawmill complex and sawmills in Le Thanh, it is clear that site, describing the situation as “out of The large trucks used to transport timber EIA investigators visited the region the Vietnamese Government has failed control”37. However, the letter stipulated to Vietnam are capable of holding at least 3 between September 2017 and March 2018, to address the issues raised in Repeat that timber transport, and logging in the 50m of timber. At least 50 of these trucks, identifying numerous logging areas well Offender, with the trade remaining very associated Economic Land Concession loaded with illegal timber, were said to outside of the reservoir boundary and open and visible. When EIA asked a local only come to a halt until after the national travel to Vietnam every day. tracking arevs loaded with illegally logged resident what was down a dusty road election. timber to a sprawling sawmilling complex that led to the illegal crossing point, she Below: The Sesan on the reservoir’s banks, 3km north of the replied: “That’s where the timber trucks sawmill complex, 30 where ore than 60 barrier itself . Investigators estimated the cross the border”. companies mill timber size of this site at about 100 hectares. illegally logged from 34. Radio Free Asia, Cambodia’s Lower Sesan 2 Dam Reservoir Used to Launder Illegal Timber: Police, 17/05/17 That the Lower Sesan 2 dam project has the surrounding 35. License of Exportation No: 084 Por Nor No Chor, December 22, 2017, issued by Ministry of Commerce and Customs; Timber export license areas. A Government No: L/P 002 Por No Nor Chor issued January 03, 2018, Permit Carry letter No: 004, issued January 05, 2018 for transportation of timber from EIA followed trucks transporting timber become a hub for illegal timber is also well Ang and Association Lawyer Co., Ltd sawmill Trapaing Sre border gate, Snuol, Kratie province, Customs Permit No: 00001 dated on January spokesperson has 04, 2018 of General Department of Customs from the Lower Sesan 2 sawmill complex known by the Cambodian Government. described illegal logging 36. Letter No. 252 Sor Chor Nor Kor Sor, February 27, 2018 on two distinct routes to Vietnam. One Less than a year after logging began, the related to the site as “out 37. https://www.phnompenhpost.com/national/government-defers-logging-permits of control” route saw trucks heading east to cross Ministry of Agriculture demanded that into Vietnam near the Oyadao / Le Thanh “anarchic deforestation” in the reservoir border gate (in Cambodia’s Ratanakiri cease. Despite public claims from the Below: An illegal logging site, 32 outside of the Lower Sesan 2 province and Vietnam’s Gia Lai province), company that logging had ceased , a dam concession boundaries while a second route headed far south month later the Government threatened towards Trapaing Sre / Hoa Lu border it with legal action for not complying crossing in Cambodia’s Kratie province with the order33. and Vietnam’s Bình Phước province. At both crossings, trucks avoided official However, illegal logging has continued, border gates, instead making use of with trees felled in the surrounding forests and laundered through the dam

25. https://www.independent.co.uk/news/world/asia/dam-flood-cambodia-china-village-srekor-underwater-submerged-silent- waterworld-a8193461.html 26. Khmer Times, របាយការណ៍៖ គម្រោងវារីអគ្គិសនី សេសាទក្រោម២ កំពុងបំផ្លាញព្រៃ ឈើ កម្ពុជាយ៉ាងធ្ងន់ធ្ងរ 11/11/16 - https://www. khmertimeskh.com/news/31969/------/ 27. Radio Free Asia, Cambodia’s Lower Sesan 2 Dam Reservoir Used to Launder Illegal Timber: Police, 17/05/17 https://www.rfa.org/english/ news/cambodia/timber-05172017174724.html 28. The Cambodia Daily, Government Suspends Logging in Stung Treng Dam Concession, 25/10/13 https://www.cambodiadaily.com/news/ government-suspends-logging-in-stung-treng-dam-concession-45878/ 29. The sawmill complex is located at: 13.590340°, 106.261100° 30. https://earthobservatory.nasa.gov/IOTD/view.php?id=91761 31. 13.768206°, 107.517319° 32. The Cambodia Daily, Official Disputes When Dam Clearing Ceased, 28/10/13 ©EIAimage 33. The Phnom Pehn Post, Answers demanded on dam site, 22/11/13 12 Environmental Investigation Agency ©EIAimage 3. Phnom Prich Wildlife Sanctuary Covering 222,500 ha in Mondolkiri operations. The area became a focal Province, Phnom Prich Wildlife Sanctuary point during a 2016 national crackdown, is in Cambodia’s Eastern Plains Landscape, with arrest warrants issued for some of described by WWF as one of the world’s the high-profile tycoons controlling the 200 most biologically important areas38. trade; Prime Minister Hun Sen even made two helicopter gunships available to fire EIA investigations between September upon illegal logging operations “without 2017 and March 2018 uncovered illegal mercy”. While the illegal trade continued logging operations on an unprecedented elsewhere in Cambodia, it appeared to halt scale within the wildlife sanctuary, along within Phnom Prich Wildlife Sanctuary, with large-scale corruption implicating albeit only temporarily. various elements of the Cambodian Government. The timber was destined This illegal trade is run by two cartels for the Vietnamese market, with the controlled by six tycoons – including majority smuggled out of Cambodia across those named in the 2016 arrest warrants informal border crossings close to the plus members of the military police and officialTrapaing Sre / Hoa Lu border gate armed forces – cooperating in a massive and connected to company warehousing illegal logging operation which makes compounds, in order to avoid paying taxes use of the Economic Land Concessions to in Cambodia. launder this timber. WWF has found that there were 63 sawmills operating within This timber is then transported to the the Eastern Plains Landscape – of which Vietnamese town of Hoa Lu, in Bình only five were licensed – in November Phước province, where it is either stored 201741. at log yards and assessed by Vietnamese customs agents or trucked directly Between September 2017 and March 2018, past the customs office and onward to hundreds of Cambodian and Vietnamese Vietnam’s domestic market and, in some workers were sent to Phnom Prich Wildlife instances, on to China. Sanctuary to illegally cut huge volumes of ©EIAimage high-value timber. This timber was then Logging is not legally allowed within the transported to Vietnam, both through bodyguard unit which reports directly of taxes and customs procedures in protected areas of Phnom Prich Wildlife the official Trapaing Sre / Hoa Lu border Above: Arevs are slow moving, basic trucks, to Prime Minister Hun Sen. Use of these Cambodia. Sanctuary; however, in 2011 and 2012 the crossings and through smuggling routes capable of carrying Cambodian Government granted logging up to 20m3 of logs same trucks, organised by Hak Mao, was connected to cartel warehouses at the 42, EIA viewed a receipt issued by Vietnamese rights to companies across 60,287 ha of along basic jungle documented by Global Witness in 2007 at border. EIA investigators documented tracks. Equipped with border police at Hoa Lu on 19 January Economic Land Concessions (ELCs) inside which time he was reported to be making a ‘road of tolls’ through Phnom Prich cranes, arevs can 2018 to a driver transporting nearly 100 the protected area. While logging was collect logs directly an estimated $1.2 million annually from Wildlife Sanctuary. Trucks travelling this from felling sites tonnes of round logs from Phnom Prich legally allowed in these ELCs, with more transporting illegally logged timber. road pass four permanent ranger stations Wildlife Sanctuary. Alongside the illegal than 60 sawmills operating from 2012-15, and more than 20 checkpoints manned by EIA documented approximately 80 harvesting of this timber, Cambodia has a today these areas are largely cleared and soldiers and military police, all nominally 70-tonne trucks, each able to carry the well-publicised log export ban and a ban logged out. responsible for policing illegal logging. equivalent of two shipping containers’ on all timber exports to Vietnam – yet worth of timber, transporting timber to Vietnamese customs officials were happy Almost from their outset, these ELCs were Log trucks travel down this road in Vietnam, while interviews with local to allow the logs into Vietnam. used as a front to launder timber illegally convoy, with a lead vehicle stopping at harvested from outside their boundaries. residents placed the total at more than a series of informal checkpoints where, EIA investigators also identified three In an unpublished report seen by EIA39, Below: Timber leaves Phonm 100 trucks. Drivers confirmed each truck instead of policing, bribes are received by large timber depots in Hoa Lu. While one of WWF found there had been a “massive Prich Wildlife Sanctuary both paid up to $10,000 in bribes and fees per a range of different actors, including forest as round logs and as roughly these was filled with what appeared to be surge of illegal logging” in Phnom Prich sawn timber trip. With the trade running for at least 150 rangers, police, members of the armed timber from previous years’ harvests, two Wildlife Sanctuary since the ELCs were days, this amounts to millions of dollars in forces and even local media (see map page new depots have been constructed which established, with a doubling of cases bribes. 8-9) to allow the trucks to pass. Some of were filled with thousands of cubic metres between 2012-16. WWF’s report found that the convoys documented by EIA had a EIA investigators followed numerous of freshly cut timber from Cambodia. even cancelled ELCs within the wildlife lead vehicle with Royal Cambodia Armed trucks from Phnom Prich to where These depots function in the same manner sanctuary are “continuing to play a critical Forces license plates. they crossed the border into Vietnam, as bonded warehouses – while the timber part in the organisation of illegal logging”, estimating that only 10 per cent crossed is physically present in Vietnam, it has with at least 400 people engaged in illegal EIA investigators also interviewed via official crossing points. A majority of not yet entered the Vietnamese economy logging in the area. a truck driver whose vehicle had a trucks travelled to the Trapaing Sre / Hoa and likely does not yet appear within distinctive ‘m’ logo – one of many such 40 Lu border crossing, where each cartel Vietnamese customs data. Illegal timber cases quadrupled in 2015 trucks transporting timber to Vietnam. has a warehouse near the border. Aerial and the Cambodian Government began The driver reported that the truck was footage revealed dirt roads running from conducting raids on illegal logging owned by General Hak Mao, from the elite these warehouse compounds into a rubber plantation in Vietnam, avoiding payment 38. Phnom Prich Wildlife Sanctuary Profile 2016 - WWF 39. WWF, Evidence of Industrial-scale Illegal Logging in Phnom Prich Wildlife Sanctuary Under The Cover of Economic Land Concessions, 2016 ©EIAimage 40. WWF 41. https://www.phnompenhpost.com/national/impunity-threatens-mondulkiri-preserves 42. Cambodia’s Famil Tree, Global Witness, 2007

14 Environmental Investigation Agency Serial offender 15 Counting crime

The scandal of ongoing Vietnamese pressure on these two species. timber sector offences in Cambodia is partially quantifiable through analysis A further 14,791m3 - eight per cent of of the volume and value of trade. It is the trade over the same period, was clear that, despite having advanced thnong (Burmese padauk / pterocarpus significantly down the path towards a macrocarpus/pedatus) – a species FLEGT VPA, Vietnam is still recording prohibited from harvest and export very substantial volumes of illegal timber in Cambodia in any form and a clear imports from Cambodia. candidate for a CITES Appendix II listing. The high price of this timber saw the In 2016, Vietnam Customs reported reported total value of this trade as imports of 310,232m3 of Cambodian logs $17,127,819. and sawn timber, worth a combined US$181 million43. Little, if any, was legal. However, there are several reasons that the volumes of timber crossing the In 2017, Vietnam Customs reported an border may be greater than that shown incredible 435,764m3 of logs and sawn in Vietnamese companies’ import timber imports from Cambodia, worth a declarations, or in the official Vietnam combined $213 million - 40 per cent higher Customs trade statistics derived from in volume and a 13 per cent higher in them. value than in 201644. Avoiding inspection However, annual trade data does not reflect the boom-bust cycle of logging In 2017-18, large proportions of the and trade on the ground, which is defined illegally harvested timber crossed into by the busy dry season, running from Vietnam without passing through official approximately October to April. It is Cambodian ports of exit. This was done to this period that defines the timber trade avoid Cambodian export laws and taxes, ‘season’. or the substantial bribes required to have these ignored by Cambodian enforcement Vietnam Customs or other sources have agencies. Such smuggling meant timber yet to publish volume data for imports often did not enter Vietnam through since December 2017. Nonetheless, high official border gates, instead entering quality commercially available data via tracks through rubber plantations acquired by EIA allows for an analysis adjacent to them. of the scale of the 2017-18 dry season operations45. Vietnam has no problem registering into the Vietnamese economy timber This data records 178,119m3 of logs and illegally smuggled out of Cambodia. When sawn timber worth $75,800,641 entering registering imports with Vietnamese Vietnam from Cambodia during the 2017- Customs, trade data reveals that 18 logging season. Vietnamese importers are regularly declaring the Cambodian port of export The import declarations accessed by EIA as “Other”, or “Cambodia”, indicating no reveal trade is also disproportionately official crossing was used in Cambodia. targeting luxury and high value species in ways set to undermine the balance of From October 2017 to March 2018, species present in Cambodia’s globally Vietnamese companies declared they 3 significant biodiversity landscapes. had imported a total of 55,106m of logs and sawn timber through these “Other” Sokram (Xylia dolabriformis Benth / or “Cambodia” border crossings. This Pyinkado / câm xe) and Sramo/Sa mao suggests 30 per cent of the trade during tchet (Terminalia chebula) were particularly the most recent season was through targeted, representing over 60 per cent of informal crossings avoiding inspection by the wood exported to Vietnam during the Cambodian officials. recent logging season, placing intense

43. Includes 138,926 m3 of Cambodia logs worth nearly US$33 million and 171,306 cubic metres of sawn wood worth $148 million, figures compiled by Forest Trends from Vietnam Customs data. 44. Includes 163,071 m3 of logs worth $40 million, and 272,693 m3 of sawn timber worth over US$173 million, figures collated by Forest Trends from Vietnam Customs data. 45. EIA analysis of data extracted from import declarations submitted by Vietnamese importers to Vietnam Customs, detailing every individual import of HS4403 and HS4407 into Vietnam from January 2016 to March 2018, as made available by Export Genius - https://www. exportgenius.in/

16 Left: Arev tracks crisscross the 17 landscape near the Lower Sesan 2 Dam While all such timber is understood The View from Phnom Penh from locals, logging camp managers and to have been officially formalised into military personnel about the volume of Vietnam through Government quotas Whatever the actual reliability of timber being transported to Vietnam from during the 2016-2017 season, trade in 2017- Vietnam’s trade data, incredibly, each of the three illegal logging hotspots 18 has been less formal. With these quotas Cambodia’s Government appears not to documented. no longer in place, it is likely that not want to accept it at all. all Cambodian timber entering Vietnam While EIA’s field estimates cannot be through unofficial crossings is registered Cambodian trade data does not report considered accurate, they do reflect by Vietnam Customs, due in large part to the high levels of trade observable in the strong sense investigators had that the illicit nature of the trade and a desire Vietnamese data or on the ground. The logging and trade in late 2017 was higher to avoid required taxes and bribes. Bank of Cambodia publishes Economic & than the preceding year. Monetary Statistics monthly, including the Evidence that timber is not being value of sawn timber exports. It records In Virachey National Park, investigators registered in Vietnam exists in plain 2016 exports of $5.7 million and 2017 estimated that around 180,000m3 of timber sight. Many Vietnamese traders are exports of just 5.03 million – 42 times less could have been smuggled into Vietnam offering Cambodian wood in Vietnam than Vietnam reports receiving48. during the 2017-18 dry season53. on social media platforms and other 46 marketing mediums . When contacted by During 2017, multiple actors, including Investigators also estimated that during EIA investigators posing as prospective EIA, presented Vietnamese customs data the season a further 375,000m3 of timber buyers, many companies offered two to Cambodian authorities in an effort could have been sent to Vietnam from the different prices for the same timber; one ©EIAimage to engender Cambodia’s recognition of sawmill complex at Lower Sesan 2 dam for the timber with Vietnamese customs, the natural resources theft its citizens in Stung Treng54 and that the operation tax and transport papers and one without are suffering. EIA submitted not just the in Phnom Prich Wildlife Sanctuary in 47 these documents . Cambodian wood has argued is inevitable because wood Above: despite a clear paper annual statistics but also a dossier of trail of licenses, transport Kratie province could have contributed 3 without paperwork is clearly freely “in transit” never technically enters the permits and receipts, the actual sales invoices, log lists connected a staggering 600,000m of timber to available in Vietnam’s domestic market. jurisdiction of Vietnam. Cambodian government to them and Vietnamese Customs tax levy Vietnam55. refuses to acknowledge the 49 trade records for the same specific shipments . Held in bond Understated Combined, EIA’s field estimates suggest Yet Cambodia’s Environment Minister that over the recent 2017-18 dry season, EIA witnessed thousands of cubic Finally, it is likely that Vietnam Customs’ HE Say Samal has repeatedly rejected the if running at full capacity throughout meters of fresh-cut Cambodian timber records of imports from Cambodia evidence out of hand, either by doubting the full season these three illegal stored in bonded warehouses just inside understate actual volumes by 10per the accuracy of Vietnamese trade data50 logging operations in Cambodia had the Vietnamese territory, particularly in cent as a matter of course. Vietnamese or complaining that the data had been capacity to have sent 1.15 million m3 of Hoa Lu, Bình Phước province, indicating Customs allow a 10 per cent margin presented by NGOs without “an official timber to Vietnam. This is 6.5 times the significant volumes of Cambodian timber of error in declared volumes. In 2017, letter or data” from the Vietnamese volume detailed in Vietnamese import imported in recent months may not yet EIA investigators were informed by Government51. Minister Samal apparently declarations for the same period and 2.6 have formally passed customs in Vietnam, Vietnamese importers in Gia Lai that has little confidence in the evidence or times official Vietnam Customs volume or been included in trade statistics. all importers very accurately measure motivations of EIA, saying in November reports the whole of 2017. their logs as a standard procedure before 2017: “We don’t know where they got Much of the timber offered for sale without submitting import declarations that their data from so we think the report is There are various manners in which Vietnamese paperwork is stored in bonded reduce the real volume by 10 per cent. politically motivated”52. Such data is also timber is either not captured within warehouses, allowing companies to avoid Exploiting such loopholes could add a publicly available from the Vietnamese the trade data or is under-reported as it paying import taxes and administration further 18,000m3 of timber to the officially Customs website, but it appears that enters Vietnam. Combined with the large fees prior to sale. Where buyers are willing declared 2017-18 dry season trade. the Cambodian Government is refusing disparity between what is reported and to take timber without papers, that timber to acknowledge the existence of well- what was estimated by EIA on the ground, may never pass through Vietnamese Combined, these factors suggest that documented, industrial-scale illegal it is reasonable to assume that the actual Customs and never enter Vietnamese official Vietnamese trade data – while logging and smuggling operations in volume of timber entering Vietnam was trade statistics. This enables sellers to use already showing huge levels of illegal Cambodia. substantially higher than that reported any papers they may have to legitimise trade are persisting – has not likely by Vietnam Customs. However, due to other batches of unregistered timber or captured all real-world trade from Evidence from the ground: its shadowy nature, the true scale of the sell the papers to other companies that Cambodia in the recent logging season. trade may never be known. Even if figures need to launder their wood into Vietnam. While investigating illegal logging and reported by Vietnamese Customs are That Vietnam Customs may be failing trade in Cambodia and on the Cambodia taken at face value, it is clear that Vietnam In transit to capture all trade for Cambodia raises / Vietnam border from October 2017 continues to accept huge volumes of significant concerns about the ability to March 2018, EIA made numerous Additionally, timber classified as “in illegally harvested and traded timber. of Vietnamese agencies to effectively observations and collected testimonies transit” may not be included in official implement and enforce timber import Vietnamese import data as it is not laws Vietnam is currently revising for the 48. https://www.nbc.org.kh/english/publications/economic_and_monetary_statistics.php?page=2 technically imported into Vietnam. Such EU FLEGT VPA. 49. https://eia-international.org/repeat-offender-online-library-evidence timber is beyond the scope of Vietnam’s 50. Phnom Penh Post, Vietnamese data show timber exports are continuing, 27 June 2017, https://www.phnompenhpost.com/national/ vietnamese-data-show-timber-exports-are-continuing proposed Timber Legality Assurance 51. Phnom Penh Post, Timber Trade to VN up – again, 8 February 2018, https://www.phnompenhpost.com/national/timber-trade-vietnam- System (TLAS) – an outcome Vietnam again 52. Khuon Narim, Khmer Times, Cambodia continues to fuel Vietnam timber trade, 3 November 2017, http://www.khmertimeskh. com/5088921/cambodia-continues-fuel-vietnam-timber-trade/ 53. Estimate based on: 100 arevs ferrying an average of 20m3 of logs each a day for 90 days between October 2017 and mid-February 2018 (up 46. Timber without papers was advertised on the facebook group ‘Vietnam Wood Market’ - https://www.facebook.com/ until Chinese New Year, when imports into Vietnam at Le Thanh were reportedly suspended). groups/1765712736996311/. Accessed January & April 2018 47. During March and April 2018, EIA contacted various traders advertising freshly imported Cambodian timber in Vietnam on a 54 Estimate based on: 50 flat-bed haulage trucks capable of carrying at least 50m3 of timber each (and often as much as 70) had been prominent Facebook Group (https://www.facebook.com/groups/1765712736996311/), and were repeatedly offered two prices depending on ferrying timber to Vietnam daily over 150 days between September 2017 and March 2018 55. Estimate based on: 80 flat-bed trucks carrying 50m3 to Vietnam each day, which, over 150 days between September 2017 and March 2018 whether buyers wanted official papers issued by Vietnam Customs an the Forest Protection Department.

18 Environmental Investigation Agency SERIAL OFFENDER 19 Consequences for the VPA Recommendations

The European Union’s FLEGT Action National Park revealed in this report. State To the Vietnamese Government To the Cambodian Government Plan embodies Voluntary Partnership companies are among those implicated. • Publicly state what the Government will do • Communicate to Vietnam that the border has been Agreements (VPAs) as a core tool in Where Vietnamese companies have not immediately to prevent further illegal timber imports closed to the timber trade and request that Vietnam addressing illegal logging and the trade been directly responsible for initiating from Cambodia stop accepting Cambodian timber and share records in illegal timber. VPAs are bilateral logging, it has been their demand for of imports and the names of exporters from 2016-18 agreements between the EU and timber- timber that has been the driving force • Formally and transparently share with Cambodia’s producing countries which are legally behind illegal logging. Government official Vietnamese customs records of • Instruct all Cambodian border posts to enforce binding once ratified. Central to the legal Vietnamese officials have allowed imports of wood and wood products from Cambodia timber export bans and governance reforms sought by VPAs Vietnamese traders to circumvent to enable effective enforcement in Cambodia are Timber Legality Assurance Systems • Revoke all Economic Land Concessions within Cambodian law by allowing timber ©EIAimage (TLAS) which are designed to verify the • Publicly report on progress with the development of protected areas, including Phnom Prich Wildlife to enter Vietnam though unofficial legality of timber. Within the Vietnamese new legislation to address imports of illegal timber, Sanctuary crossings, avoiding inspection and VPA, a key reform for Vietnam is the as pledged in the VPA texts and annexes initialled in taxation in Cambodia. Customs officials introduction of legislation requiring May 2017 • Permanently revoke all logging concessions within in Vietnam have legalised this timber into Vietnamese importers to conduct due the Lower Sesan 2 dam the Vietnamese economy, despite clear diligence to avoid the import of illegally • Ensure that legislation to address illegal timber evidence of illegal harvest and export. • Investigate corruption associated with Border Police harvested or traded timber – something imports, pledged in VPA texts, includes a clear Where this timber has not been legalised, post 203, Rattanakiri provincial military police Vietnam resisted agreeing for years but prohibition on importing illegal timber and that its these same officials have, at best, turned commander Kim Rasmey and Rattanakiri Province conceded to in May 2017, just prior to due diligence provisions are robust a blind eye to the huge volumes of timber Governor Thang Savon. initialling the VPA. Once fully operational, being smuggled into Vietnam – if not • Register companies detailed in Annexes 1 and 2, next Vietnam’s TLAS will issue FLEGT licences outright profiting from this trade. page, as Category 2 (high risk) in the Organisations to accompany timber exported to the EU Classification System (OCS) as described in table 2 and only licensed timber products will be The current situation in Vietnam clearly of Annex V of the VPA (the Vietnam Timber Legality exported to the EU by Vietnam. cannot co-exist with a functioning VPA. Assurance System, or VNTLAS) A systematic failure of respect to the Timber issued with a FLEGT licence is laws of neighbouring countries, and • Investigate and prosecute the collusion and considered to meet the requirements of apparent widespread corruption by the corruption between Vietnamese state officials and the EUTR, Europe’s flagship anti-illegal same officials who will be at the front line timber traders, which drives and facilitates illegal logging legislation which exists to ensure of enforcement of Vietnam’s new timber logging in Cambodia and legitimises shipments no timber with any risks of illegality import laws, which are central to the of illegal timber into Vietnam and make those enters the European market. EU operators VPA, throws into serious doubt Vietnam’s outcomes public placing FLEGT-licenced timber onto the ©EIAimage capacity to ensure compliance with these market are not required to conduct any • Ensure Forest Department and customs officials laws. due diligence to ensure their timber is involved in the current illegal timber trade from Top: Loaded trucks, destined from a legal source. Cambodia to Vietnam cannot perform duties in for Vietnam, travel in convoys Vietnam’s delivery of a functioning TLAS depends upon its ability to demonstrate implementing functions central to section 6.3.7 down a ‘road of tolls’ in Phnom Vietnam’s timber import legislation Prich Wildlife Sanctuary, that illegal timber is no longer entering its “Imported timber (Critical control point 1g)” of where bribes are paid to will assign risk categories to different economy. By initialling the VPA, Vietnam Vietnam’s VNTLAS, as detailed in Annex V of the various authorities species, countries of origin and individual is now committed to actively crack down VPA. companies. As a bare minimum, EIA Above: timber is loaded onto on its illegally sourced imports and recommends that Vietnam categorises To the European Commission a truck near the Lower Sesan ensure, through negotiations with the EU, 2 dam all timber imports from Cambodia, that a robust and strong system is put and all supply chains which include • Continue to work with Vietnam through the VPA in place. The EU cannot accept FLEGT companies (including those owned by process to ensure it delivers a TLAS which is robust licenses from Vietnam until that country the Vietnamese state), involved with this and fit for purpose, in line with recommendations has been able to demonstrate not only trade56 as being of high risk. made to Vietnam above the passing of new laws, but also that Vietnam has been complicit in the trade these laws are being effectively enforced. • Refuse to agree to the initiation of FLEGT licensing of illegal timber from its neighbours Anything less will effectively undermine for Vietnamese exports to the EU until Vietnam has Laos and Cambodia for many years. the entire FLEGT VPA process and bring clearly demonstrated that illegally harvested and/ Vietnamese companies, with the support into question its capacity to address or traded timber is no longer entering the country, of the Vietnamese Government, army and forest governance issues, while eroding regardless of whether it is destined for the EU market customs department, have often initiated EU consumer trust in licensed products • Ensure existing EUTR cases focused on Vietnamese the logging in these countries, as is the from other countries. supply chains are prosecuted, including those cases case with the logging in Virachey submitted by EIA in Italy.

56. Lists of Cambodian and Vietnamese companies identified by EIA to be involved are attached as an annexes 1 & 2 to this report

20 Environmental Investigation Agency Serial offendernder 21 GREAT FIELD (CAMBODIA) INTERNATIONAL LIMITED Annex 1 GREEN WOOD CO., LTD HA GIA APHIVATH CAOUTCHOUC CO.,LTD Cambodian companies at risk of involvement in the illegal Cambodian timber trade to Vietnam HANH HUU CO..LTD HANH ORGANIC., LTD (from EIA field investigations and data from import declarations submitted to Vietnam Customs by Vietnamese importers to Vietnam Customs, detailing every individual import of HS4403 and HS4407 into Vietnam from January HE SOMSY 2016 to March 2018, as made available by Export Genius - https://www.exportgenius.in - September 2016 to October HENG DEVELOPMENT CO., LTD 2017). HENG SOKNGUN IMPORT-EXPORT CO.,LTD EIA recommends that, immediately on the entry into force of the imported timber legislation Vietnam is currently INTERNATIONAL INVESTMENT CO KRYSTAL MAXX., LTD developing, the Vietnamese Government categorises the below companies in Category 2 (“high risk”) in the proposed INVESTMENT DEVELOPMENT CO SAMAKI CORPRATION., LTD 57 Organisations Classification System (OCS) as described in table 2 of the VNTLAS detailed in Annex V of the VPA . INVESTMENT DEVELOPMENT CO ZHAI JIAN PU., LTD INVESTMENT GROUP CO.LTD constellation ROEUN Company Name JIAN PU ZHAI INVESTMENT DEVELOPMENT CO., LTD A.L.A.M.D INTERNATIONAL CORP K. CHANTHAN TRADING CO., LTD ANG AND ASSOCIATES LAWYERS CO., LTD. KHOEUY SIN CO., LTD (អាំងអេន អាសូស៊ីអេត ឡយឺរ ខូ អិលធីឌី) oc ANGKOR PLYWOOD CO., LTD. (អង្គរ ផ្លាយវូត KIM BUN HENG LIMITED COMPANY ខូ អិលធីឌី) oc KONG HENG TANAS CO., LTD. IMPORT EXPORT (គង់ ហេង តាណះ អាហរ័ណ នីហរ័ណ) oc ASIA LTPS CO., LTD BAYON APHIVATH KAKSEKAM CO., LTD. KONG LAYHENG INVESTMENT IMPORT EXPORT CO., LTD (បាយ័ន អភិវឌ្ឍន៍ កសិកម្ម) oc LAYHENG KONG INVESTMENT IMPORT - EXPORT CO., LTD. BICH QUYNH CO - Kratie CO., LTD LENG CHENG XPORT( CAMBODIA) CO.,LTD BRIGHTWAY FUNITURE CO., LTD LTPS ASIA CO., LTD CHENG BO YING CO.,LTD MAXXINOI CAM INTERNATIONAL C0.,LTD CHHUN RAT CO.,LTD. MAXX KRYSTAL INTERNATIONAL INVESTMENT CO., LTD CHOM ROEUN INVESTMENT GROUP CO.LTD MEGASTAR INVESTMENT & FORESTRY DEVELOPMENT CO.,LTD CONG TY MEAS RITTHIKRUP MORK SOKHOEUN IMPORT-EXPORT CO.,LTD CONG TY MONG HEN NEAM THEARITH TRANSPORT CO.,LTD CONG TY TNHH DAU TU MAKINAVY NEFS FURNITURE (CAMBODIA) CO., LTD COOPERATION DEVELOP ORGANIZATION (CDO) NEANG POV IMPORT - EXPORT CO., LTD CPDCI INTERNATIONAL CO., LTD NEWLINE CAM PTY LTD CV SUNLIGHT JS CO., LTD. (ស៊ីវី សាន់ឡៃថ៍ ជេអេស ឯ.ក) oc NEW YORK IMPORT EXPORT CO., LTD. cc CYPRESS.SUNADAYA CO., LTD. NY DARIN CONSTRUCTION.CO.,LTD D.T.C GROUP CO.,LTD PHAT SOK CHEA TRADING DEVELOPMENT CO.,LTD DAI CHE IMPORT EXPORT CO.,LTD PICH RITHSEY CO., LTD. (ពេជ្រ ឫទ្ធសី) oc DANG NARITH DEVELOPMENT CAMBODIA INTERNATIONAL INVESTMENT PSKV CONSTRUCTION CO.,LTD DARIN CONSTRUCTION.CO NY., LTD PU JIAN INVESTMENT DEVELOPMENT CO Zhai., LTD DR DEVELOPMENT CO., LTD PUBLIC GLOBAL VISION TRADING CO., LTD EAST ASIA COMMODITIES PVT LTD QIANG SHENG HUA DA ( CAMBODIA ) INVESTMENT C0.,LTD ELEVATOR COMPANY SROs KHANTEY CO., LTD ROUGIER AFRIQUE INTERNATIONAL ENG HENG INVESTMENT CO .,LTD SAMAKI INVESTMENT DEVELOPMENT CORPRATION CO., LTD EXPOPT rookie LONG IMPORT COMPANY LIMITED SARKOR RUBBER CO.,LTD EXPORT - IMPORT CO HENG SOKNGUN.,LTD SENG MONY MONEY CO., LTD. (សេង មុន្នី ម៉ាន់នី ឯ.ក) oc EXPORT IMPORT NEANG CO..LTD POV SHAOXING XIANGLU KNITING WEAVING GARMENT CO.,LTD EXPORT IMPORT POV Neang Co..Ltd SIN KHOEUY CO., LTD EXPORT IMPORT TRADE CO THARY., LTD. SOK HENG STORES CO., LTD FIRST PRO SOLUTION CO.LMT (CAMPUCHIA) SOK PHAT TRADING DEVELOPMENT CO CHEA., LTD FVC ROYAL GROUP CO LTD SOKCHAMROEUN COMPANY CO.LTD GLOBAL PUBLIC VISION TRADING CO.,LTD SOKHA HAI IMPORT EXPORT CO., LTD. GOLD JMGC CORPORATION STARWEB RESOURCES LIMITED

57. Annex V to the Voluntary Partnership Agreement between the European Union and the Socialist Republic of Vietnam on Forest Law Enforcement, Governance and Trade, as initialled by Vietnam and the EU on 11 May 2017, and assessed at: http://ec.europa.eu/environment/forests/pdf/11_05_2017_EU_Vietnam_VPA.pdf

22 Environmental Investigation Agency Serial offender 23 TAN BINH LONG IMPORT EXPORT CO., LTD. cc THANG SROS KHANTEY COMPANY CO., LTD Annex 2 THARY TRADE IMPORT EXPORT CO., LTD. (ថារី Vietnamese companies believed to be at risk of involvement in the import of Cambodian timber to Vietnam ពាណិជ្ជ នីហ័រណ អាហ័រណ) oc (Data from EIA field investigations and import declarations submitted to Vietnam Customs by Vietnamese importers THE SUM NOMER CORP LTD to Vietnam Customs, detailing every individual import of HS4403 and HS4407 into Vietnam from January 2016 to March 2018, as made available by Export Genius - https://www.exportgenius.in/ - September 2016 to October 2017). EIA THREE TRADE IMPORT - EXPORT CO, .LTD recommends that, immediately on the entry into force of the imported timber legislation Vietnam is currently developing, T.N.H.H BICH QUYNH-KRATIE CO., LTD. cc the Vietnamese Government categorises the below companies in Category 2 (“high risk”) in the proposed Organisations 58 V.D.CAM IMPORT EXPORT CO.,LTD Classification System (OCS) as described in table 2 of the VNTLAS detailed in Annex V of the VPA . V.ENERGY LOGISTICS CO., LTD. (វី.អេនើជី ឡូជីស្ទីក) oc Company Công Ty TNHH Một Thành Viên Phú Thiên code Company name (and other known names) 310546857 Quán WOOD INNOVATION & IMPORT EXPORT CO,LTD Công Ty TNHH Một Thành Viên Vũ Thái 0101632125 Công Ty Cổ Phần Quốc Huy XFREE CROPS CO.,LTD 310645287 Dương CôNG TY TNHH THươNG MạI VậN TảI SơN Công Ty TNHH Giao Nhận Vận Tải Thiên ZHEJIANG DONGYUAN IMPORT & EXPORT CORPORATION LIMITED 201852526 TùNG PHáT 311221587 Minh Phát 301922488 Cty Cổ Phần Go Sa Co Co. Freight Thien Minh Phat 302418379 Công Ty Cổ Phần Thái Bình Thien Minh Phat Transport Company Limited Thai Binh Joint Stock Company CôNG TY Cổ PHầN ĐầU Tư XâY DựNG Và Công Ty TNHH Đầu Tư Xây Dựng Dịch Vụ 311354629 PHáT TRIểN TâN PHúC THịNH Thương Mại Sản Xuất Xuất Nhập Khẩu Công Ty TNHH Thương Mại Dịch Vụ Xuất 302537979 Hồng Phước 311941225 Nhập Khẩu Phương Thúy Công Ty TNHH Sản Xuất Thương Mại Dịch Vụ 303390503 Công Ty TNHH Xuất Nhập Khẩu Sang Trọng 312108979 Xuất Nhập Khẩu Tân Thái Ngọc Deluxe Import Export Co., Ltd Công Ty TNHH Sản Xuất Thương Mại Xuất 312169918 Nhập Khẩu Vina Wood Export Company Limited Deluxe Công Ty TNHH Xuất Nhập Khẩu Quốc Tế IMPORT EXPORT COMPANY LIMITED 312170920 Thịnh Phát DELUXE Công Ty TNHH Thương Mại Dịch Vụ Hoàng 304045362 Công Ty TNHH Thiên Lộc 312237357 Dương Sài Gòn 304314287 Tinh Phuong Trading Co., Ltd Công Ty TNHH Một Thành Viên Xuất Nhập 312359274 Khẩu Phương Thùy Tinh Trading Co. Four Methods Company Limited Import Export Phuong Cty TNHH Thương Mại Công Nghệ Chiến Thuy 305169314 Thắng Công Ty TNHH Dịch Vụ Thương Mại Bích Phuong Thuy Import Export Co., Ltd 305228111 Quỳnh 312715042 Công Ty TNHH Thương Mại Đại Quốc Khánh Công Ty TNHH Sản Xuất Kinh Doanh Thương 305485239 Công Ty TNHH Xuất Nhập Khẩu Gỗ Việt Mỹ IMPORT EXPORT CO., VIETNAM AMERICAN 312964070 Mại Dịch Vụ Lê Vũ WOOD 313024873 Công Ty TNHH Lộc Thiện Ltd Vietnamese American Import Export Công Ty TNHH Thương Mại Sản Xuất Xuất Wood 313134160 Nhập Khẩu Nguyễn Lê Viet My Timber Import Export Company Công Ty TNHH Vật Liệu Xây Dựng Thiên Phú Limited 313141520 Lộc 309247436 Công Ty TNHH Hoàng Phú Long Co. Building Materials Thien Phu Loc 309259375 Công Ty TNHH Thương Mại Đỗ Khoa Thien Phu Loc Building Materials Co., Ltd Công Ty TNHH Sản Xuất- Xây Dựng- Công Ty Cổ Phần Thương Mại & Xuất Nhập 309560504 Thương Mại Dịch Vụ Đồng Tiến 313373842 Khẩu Thiên Hùng Phúc Công Ty TNHH Sản Xuất - Thương Mại Công Ty Cổ Phần Xuất Nhập Khẩu Casa - Dịch Vụ - Giao Nhận - Xuất Nhập Khẩu 309576399 Quang Minh Casa Import Export Joint Stock Company MANUFACTURING COMPANY LIMITED CORPORATION IMPORT EXPORT CASA - TRADING - SERVICE - FORWARDERS - EXPORT IMPORT QUANG MINH 313477665 Công Ty TNHH Vận Tải Quốc Tế Tuấn Phong Quang Minh Trade - Service - Import - Công Ty TNHH Thương Mại Dịch Vụ Và Xuất Export Co., Ltd 313568538 Nhập Khẩu Tùng Lâm Company Limited Trading Service Import 309586171 Công Ty TNHH Tiếp Vận Tân Quốc Export And Tung Lam 309758945 Anh Duc Trading Import Export Co., Ltd Tung Lam Trade And Service Import Export COMPANY LIMITED UK TRADE EXPORT Co., Ltd IMPORT GERMANY Tung Lam Trading And Import Export Co., Ltd Công Ty TNHH Thương Mại Xuất Nhập CôNG TY TNHH SảN XUấT THươNG MạI XUấT Khẩu Anh Đức 314087428 NHậP KHẩU THúY ANH Công Ty TNHH Sản Xuất Và Kinh Doanh Company Limited Production Trading Import 310502560 Tổng Hợp Quốc Tế Năm Sao Export Thuy Anh Five Star International Manufacturing And VIETNAM BRIEFS TRADING COMPANY Trading Co., Ltd LIMITED 58. Annex V to the Voluntary Partnership Agreement between the European Union and the Socialist Republic of Vietnam on Forest Law Enforcement, Governance and Trade, as initialled by Vietnam and the EU on 11 May 2017, and assessed at: http://ec.europa.eu/environment/forests/pdf/11_05_2017_EU_Vietnam_VPA.pdf

24 Environmental Investigation Agency Serial offender 25 CôNG TY TNHH THươNG MạI DịCH Vụ Công Ty TNHH Một Thành Viên Chương 3901202014 Công Ty TNHH Mtv Hùng Thành Danh 5900479994 Doanh Nghiệp Tư Nhân Hiếu Phát 314119373 XUấT NHậP KHẩU PHúC HưNG VIệT SG 3602993142 Phát Company Limited Trading Service Import 3901204879 Công Ty TNHH Mtv Hùng Hùng Anh Hieu Phat Private Enterprise 3700303157 Công ty TNHH Hiệp Thành Công Ty TNHH Một Thành Viên Sang Thuận Export revival VIET SG Công Ty TNHH Dịch Vụ Thương Mại 5900481506 Công Ty TNHH Một Thành Viên Bảo Hoàng VIET PHAT PHAT TRADING SERVICE CO., 3901205287 Anh 3700380056 Tổng Hợp Hưng Hoàng Bao Hoang Company Limited LT D. 3901205632 Công Ty TNHH Mtv Xnk Gỗ Nguyễn Gia VIET PHONG HUNG VIETNAM TRADING 3700709037 Công Ty TNHH Chế Biến Gỗ Hải Thành Công Ty Trách Nhiệm Hữu Hạn Nguyễn 5900505450 Công Ty TNHH Một Thành Viên Vân Tiến SERVICE CO., LTD Hai Thanh Wood Processing Co., Ltd 3901209588 Minh Uyên ONE MEMBER LIMITED COMPANY VAN VIET PHAT HONG PHAT TRADING SERVICE Nguyen Minh Uyen Limited Liability TIEN 314119373 CO., LTD LTD HAI THANH WOOD PROCESSING Company Van Tien Company Limited CôNG TY TNHH DịCH Vụ SảN XUấT XUấT Wood Processing Co. Haicheng Công Ty TNHH Mtv Tm-Dv-Xnk Thiên Thiên 314289632 NHậP KHẩU TRườNG PHáT 3901210142 Lạc 5900514310 Công Ty TNHH Sơn Đông CôNG TY TNHH THươNG MạI DịCH Vụ 3701015049 Công ty TNHH Gỗ Tân Vĩnh Nghĩa Company Limited Import Export Service Tm Shandong Company Limited 314460946 THOA NGUYễN Tan Vinh Nghia Wood Co., Ltd Lac Thien Thien Công Ty TNHH Một Thành Viên Sản Xuất & Thien Thien Lac Tm-Dv-Xnk Company 5900521727 Công Ty TNHH Một Thành Viên Đại Thắng 401215651 Thương Mại Phúc Hưng Việt TIMBER CO. LTD. TAN VINH NGHIA Limited Công Ty TNHH Một Thành Viên Thương Công Ty TNHH Mtv Xnk Nông Lâm Sản 5900781965 Limited Liability Company 10b 1400519144 Công Ty TNHH Thành Phước 3800445701 Mại Xuất Nhập Khẩu Thúy Hằng 3901215905 Mekong Công Ty TNHH Một Thành Viên Nguyễn Công Ty TNHH Một Thành Viên Tiền Quốc Company Limited Trading Import Export 5900961397 Hiệu Gia Lai 3901217331 Công Ty TNHH Mtv Thanh Phú Lan 1401604988 Thái Thuy Hang COMPANY LIMITED NGUYEN GIA LAI PERFORMANCE 1402033617 Vũ Bằng Giang Thuy Hang Trading Import Export 3901221673 Doanh Nghiệp TN Khánh Ngọc Nguyễn Company Limited Khanh Ngoc Nguyen Enterprise Nguyen Trai Gia Lai One Member Co., Ltd 1402034628 Ngoc Thai Wood Products Enterprise Công Ty TNHH Một Thành Viên Nam 3800552358 Doanh Nghiệp Tư Nhân Đại Phúc Thành Business TN Wood Ngoc Thai KHANH NGOC NGUYEN BUSINESS TN 5901036931 Thanh Gia Lai Công Ty Trách Nhiệm Hữu Hạn Thương Mại CôNG TY TNHH XUấT NHậP KHẩU PHAN 3801021977 Công Ty TNHH Thịnh Phát Bp Nam Thanh Gia Lai One Member Limited 3901223092 Thái Phúc Hưng 1402052659 ANH ĐồNG THáP PUBLIC COMPANY LIMITED Aquarium Liability Company Công Ty TNHH Thương Mại - Dịch Vụ Và Import and Export Co., Ltd. Dong Thap 3801145669 NHI 3901224794 Công Ty TNHH Mtv Gỗ Phúc Anh 6000664636 Sản Xuất Cao Nguyên PHAN ANH COMPANY LIMITED TRADING - IMPORT 3900365312 EXPORT TAN HUNG Phuc Anh Wood Co., Ltd Cao Nguyen Trading - Service And PHAN ANH TRADING CO., LTD Công Ty Trách Nhiệm Hữu Hạn Thương Production Co., Ltd 3901226752 Công Ty TNHH Vy Bảo Anh TRADING COMPANY LIMITED - SERVICE 3900365312 Mại - Xuất Nhập Khẩu Tân Hưng 1402069444 CôNG TY TNHH CưA Xẻ Gỗ ANH VINH AND MANUFACTURING HIGHLANDS Company Limited Trade - Export Import 3901256891 CôNG TY TNHH HậU TâN HưNG Công Ty TNHH Tm-Dv Thanh Dũng Châu Công Ty TNHH Dịch Vụ Thương Mại Xuất Công Ty Cổ Phần Xuất Nhập Khẩu Và Đầu Tan Hung 1601961881 Đốc 4101460346 Nhập Khẩu An Vinh 6100190267 Tư Kon Tum Công Ty CP Thương Mại Dịch Vụ Xuất Tan Hung Export-Import Trade Co., Ltd An Vinh Trading Import Export Service Co., Corporation Import Export and Investment 1601971304 Nhập Khẩu Acacia Wood Công Ty Trách Nhiệm Hữu Hạn Một Ltd Kontum Doanh Nghiệp TN Trang Trí Nội Thất Kim Thành Viên Thương Mại-Dịch Vụ-Xuât Kon Tum Import Export And Investment 1602010550 Thảo 4201577972 Công Ty TNHH Dịch Vụ Hải Hoàng Phát Joint Stock Company 3900620058 Nhập Khẩu P&Đ Công Ty TNHH Kinh Doanh Xuất Nhập Khẩu 1602036083 VIETNAM SECURITY SERVICE CO., LTD Company Limited A Member Trading 4400966701 Phúc Thịnh 6100202610 Công Ty Trách Nhiệm Hữu Hạn An Phước CôNG TY TNHH MộT THàNH VIêN TM & SX Services-export and import P & A 5900188152 Công Ty Trách Nhiệm Hữu Hạn 30-4 Gia Lai 6400066574 Doanh Nghiệp Tư Nhân Thanh Loan 1602047448 QUANG THảO P & D Import-Export Trade Co., Ltd 30-4 Gia Lai Limited Liability Company 6400142391 Doanh Nghiệp Tư Nhân Thúy Vân 1701361528 Công Ty TNHH Trung Linh 3900770857 Doanh Nghiệp Tư Nhân Bảo Toàn Công ty cổ phần nông lâm nghiệp và xd. Private Enterprise Thuy Van TRUNG LINH COMPANY LIMITED Doanh Nghiệp Tư Nhân Quốc Toàn 5900189276 công trình Gia Lai Doanh Nghiệp Tư Nhân Chế Biến Xuất 3901120033 Thắng Agro-Forestry Joint Stock Company project Thuy Van Private Enterprise 1701973545 Nhập Khẩu Gỗ Đại Lâm Công Ty Trách Nhiệm Hữu Hạn Đặng Gia Lai Doanh Nghiệp TN Thương Mại Hải Triều Limited liability company Anshun Kien 3901161181 Kiều Vy Company shares of agriculture and forestry 6400306321 Đắk Nông and xd. works Gia Lai 1702019363 Giang Dak Nong Seafood Trade Enterprise COMPANY LIMITED KIEU VY DANG Công Ty Cổ Phần Kinh Doanh Và Phát Triển 1702027396 Doanh Nghiệp Tư Nhân Huỳnh Lộc Thọ Dang Kieu Vy Company Limited 5900233091 Miền Núi Gia Lai Dak Nong Trading Enterprise Corporation Business And Development Gia TN Commerce Business Dak Nong Hai 2300884579 Công Ty TNHH Biển Đông Dương 68 Công Ty TNHH Một Thành Viên Thương 3901163894 Mại Xuất Nhập Khẩu Gỗ Lê Hiền Lai Mountain Trieu 2700267228 Công Ty TNHH Xuất Nhập Khẩu Tài Anh Công Ty Trách Nhiệm Hữu Hạn Một CORPORATION BUSINESS AND THE Chi Nhánh Công Ty Cổ Phần Vinafor Đà 3901171535 Thành Viên Tâm Hồng Điệp MOUNTAIN DEVELOPMENT GIA LAI Nẵng - Xí Nghiệp Chế Biến Gỗ Vinafor Đà 3001791423 CôNG TY TNHH DịCH Vụ ĐứC HUY HOàNG Gia Lai Mountain Trading and Development COMPANY LIMITED A MEMBER TAM 400422373008 Nẵng Joint Stock Company Business TN Hoang Duc Huy HONG DIEP Branch of Asia-Pacific Construction and Công Ty Trách Nhiệm Hữu Hạn Thương 5900292957 Công Ty Cổ Phần Thương Mại Tây Gia Lai 3501857746001 Transportation Joint Stock Company DANG HUY HOANG SERVICE CO., LTD BRANCH CORPORATION BUILDING AND Mại Dịch Vụ Xuất Nhập Khẩu Dương DUY HUY HOANG SERVICE CO., LTD Tay Gia Lai Trading Joint Stock Company TRAFFIC ASIA-PACIFIC 3901180522 Phát Services Molding Company Limited Huy Chi Nhánh Công Ty TNHH Một Thành Viên Công Ty TNHH Một Thành Viên Xuất Trading Corporation West Gia Lai Hoang 5900521727001 Đại Thắng 3901184566 Nhập Khẩu Gỗ Hùng Lộc Phát Công Ty Cổ Phần Lâm Nghiệp và Xây Dựng Công Ty TNHH Một Thành Viên Hưng Branch of Dai Thang Limited Liability Hung Phat Timber Import Export 5900309368 An Khê 3100478116 Vượng Company Company Limited Công Ty TNHH Thương Mại-Dịch Vụ-Xuất 5900392711 Công ty TNHH MTV Công Thắng Gia Lai Công Ty Trách Nhiệm Hữu Hạn Quỳnh Branch of Victory Limited Company 3502268694 Nhập Khẩu Thiên Lâm Hải THE COMPANY OF THANG THANG 3901190792 Anh Khoa Cong Lai Limited Company Gia Lai COMPANY LIMITED TRADING SERVICE CORPORATION Công Ty TNHH Một Thành Viên Xuất IMPORT EXPORT THIEN-LINHAI 5900392870 Công Ty TNHH Nguyễn Trung Doanh Nghiệp Tư Nhân Phát Lợi - Chi Thien Lam Hai Trading - Service - Import - 3901192849 Nhập Khẩu Gỗ Khánh Vinh 6000467010001 Nhánh Gia Lai Công Ty TNHH Một Thành Viên Lộc Nguyen Trung Company Limited Export Co., Ltd Loi Private Enterprise Development - Gia 3901194902 Sông Bé 5900422395 Công Ty TNHH Phước Thắng Gia Lai Lai Branch 3602495041 CôNG TY TNHH HUệ NHàN Công Ty TNHH Một Thành Viên Nông Phuoc Thang Gia Lai Co., Ltd Phuc Loi Private Enterprise - Gia Lai PUBLIC COMPANY LIMITED Hued 3901199876 Sản Hồng Thiên Phát Branch Công Ty Cổ Phần Sản Xuất Thương Mại 5900422444 Công Ty TNHH Một Thành Viên Trang Đức Pho Loi Private Enterprise - Gia Lai Branch 3901200715 Dịch Vụ ấn Trà Trang Duc Company Limited CORPORATION SERVICE TRADING PRODUCTION PRINTING TEA Trang Duc One Member Co. Ltd 26 Environmental Investigation Agency Serial offender 27