Due Diligence System (DDS) of compliance with requirements of European Union Timber Regulation N 995/2010 and Lacey Act, USA at the company SVEZA-Les LLC Greenwood Office Center, 17, Putilkovo, Krasnogorsk District, 72nd km of MKAD, Moscow Region, Russia, 143441 TABLE OF CONTENTS 1 Purpose of Due Diligence System .............................................................................................................. 3 2 Definitions & Abbreviations ......................................................................................................................... 3 3 Scope of DDS SVEZA-Les LLC ................................................................................................................. 4 4 List of documents submitted by SVEZA-Les LLC to Operators ................................................................. 9 5 Declaration SVEZA-Les LLC of compliance with EUTR and Lacey Act .................................................. 10 6 Declaration SVEZA-Les LLC about the origin of veneer logs .................................................................. 10 7 Features of the forest legislation in the Russian Federation .................................................................... 10 8 The system for collecting and monitoring information about wood origin and supply of veneer logs at Plywood mills .................................................................................................................................................... 11 9 Declaration of FSC certified supplier of veneer logs with FSC 100% category ....................................... 12 10 Declaration of FSC certified supplier of veneer logs with FSC Mix Credit and/or FSC Controlled Wood categories ………………………………………………………………………………………………………………13 11 Declaration non-certified supplier of veneer logs ..................................................................................... 13 12 Registry of contracts for supply and harvesting of veneer logs ................................................................ 13 13 Risk assessment of placing a birch plywood, produced from an inappropriate wood, on the EU and US markets ………………………………………………………………………………………………………………15 14 Mitigation of risk of placing the birch plywood produced from inappropriate wood, on the EU and US markets ………………………………………………………………………………………………………………15 15 Complaints review procedure ................................................................................................................... 16 Annex 1 Declaration of commitment to FSC values ..................................................................................... 18 Annex 2 Form of Declaration SVEZA-Les LLC of compliance with requirements of European Union Timber Regulation N 995/2010 and Lacey Act, USA ................................................................................................... 19 Annex 3 Form of Declaration SVEZA-Les LLC of veneer logs origin, used for manufacture of birch plywood ………………………………………………………………………………………………………………20 Annex 4 Forms of Declaration of veneer logs suppliers ............................................................................... 21 Annex 4a Form of Declaration of FSC certified supplier of veneer logs with FSC 100% category ................ 21 Annex 4b Form of Declaration of FSC certified supplier of veneer logs with FSC categories FSC Mix Credit and/or FSC Controlled Wood ........................................................................................................................... 22 Annex 4c Form of Declaration of non-certified supplier about veneer logs origin and compliance with requirements for Controlled Wood according to FSC standard FSC-STD-40-005 .......................................... 23 Annex 5 Forms of Registry of contracts for supply and harvesting of veneer logs. Instructions for filling ... 25 Annex 5a Registry of contracts for veneer logs supply by FSC certified suppliers- Form F1 ........................ 26 Annex 5b Registry of contracts for supply and harvesting of veneer logs with category FSC 100% - Form F2 ……………………………………………………………………………………………………………………...27 Annex 5c Registry of contracts for supply and harvesting of veneer logs by non-certified suppliers - Form F3 ……………………………………………………………………………………………………………………...28 Annex 6 Form of Act of inspection for Controlled Wood supplies ................................................................ 29 2 1 Purpose of Due Diligence System 1.1 This Due Diligence System (hereinafter – DDS) - developed for Buyers of birch plywood, in the European Union (hereinafter - EU) and in the United States of America (hereinafter - USA), by orders of which, seven large plywood mills - affiliate legal entities of SVEZA-Les LLC, located in the Russian Federation (hereinafter - RF), produce the birch plywood, and - confirms that, during timber harvesting, manufacture and supply of these products to the buyers, ensured compliance with the requirements of: 1 - European Union Timber Regulation N 995/2010 (hereinafter - EUTR), and 2 - Lacey Act, USA. 1.2 This Due Diligence System is voluntary and developed by SVEZA-Les LLC in order to allow the Buyers (Operators): - were able to consider special features of: legislation in Russian Federation, purchases of wood raw materials (veneer logs), structure of supplies, and manufacture of plywood on the plywood mills affiliate with SVEZA-Les LLC, and, - comply with requirements of EUTR and Lacey Act, by integrating of this DDS into own Due Diligence Systems. 1.3 The compliance with EUTR and Lacey Act requirements based on the fulfilment of requirements of forest certification, according to the Forest Stewardship Council (FSC) certification scheme. SVEZA-Les LLC and all affiliate plywood mills have valid FSC certificates. Directors of all plywood mills jointly adopted and enforce compliance with Declaration of commitment to FSC values (see Annex 1). This Declaration is a public obligation not participates in such activities as: Illegal logging or trade of illegal wood or forest products; violation of traditional and human rights in forestry operations; destruction of high conservation values in forestry operations. Specified in this DDS procedures and forms of documents for confirmation legality for veneer logs and plywood, are the procedures and documents, which are applied in the framework of FSC certification. Thus, annual audits of compliance with FSC standards for supplies of veneer logs and plywood by accredited certification bodies are in the same time independent confirmation of compliance with the requirements of this Due Diligence System by third party. 1.4 The requirements of this DDS are observed for all plywood, manufactured on plywood mills affiliate with SVEZA-Les LLC, and sold by SVEZA-Les LLC, independently of requirements in the contract with a Buyer for sale of plywood with specific FSC category or without any FSC claims. DDS is not applied to forest resources that are owned or managed by LLC “SVEZA-Les” and its subsidiaries. 2 Definitions & Abbreviations In this Due Diligence System used following general terms and definitions, unified with European Union Timber Regulation N 995/2010 and Lacey Act, USA: 2.1 DDS - Due Diligence System of compliance with requirements of EUTR and Lacey Act. 2.2 Exporter - in the framework of this DDS - SVEZA-Les LLC - Seller of plywood under the contract with Operator. 2.3 Operator - one of the plywood buyers under the contract with SVEZA-Les LLC placed it on the EU or US market. 2.4 Plywood mill (Mill) - one of seven plywood mills/plants affiliate with SVEZA-Les LLC, which is manufacture and ship plywood to operator's consignee, by the orders, received from SVEZA-Les LLC. 2.5 Consignee - recipient of plywood party in the EU countries or in the USA, under the contract with the Operator. 3 2.6 Supplier - supplier of veneer logs under the contract with Plywood mill. 2.7 Logging operator - legal entity or person performing: 1) Timber harvesting, in accordance with the contract signed with the Russian forest authorities, 2) Manufacturing of birch veneer logs, and 3) Supply of veneer logs to Plywood mill or Trading company. 2.8 Trading company - legal entity or person which is provides services for supply of veneer logs from Logging operator to Plywood mill. 2.9 Forest management authority- authorities of Russian Federation or local government which are (in accordance with Forest Code of Russian Federation dated 04.12.2006 No 200-FZ on behalf of the State as owner of the forests in the Russian Federation) have rights to conclude the contracts with Logging operators provides timber harvesting. 3 Scope of DDS SVEZA-Les LLC 3.1 The scope of DDS SVEZA-Les LLC includes SVEZA-Les LLC and seven affiliate with SVEZA-Les LLC plywood mills (production sites) that have valid FSC certificates. Their names, addresses and FSC certificates codes are listed in the Table 1., as well as all suppliers and subsuppliers of veneer logs, according to registries of contracts. (annex 5а-в). Table 1 Names, addresses and FSC certificates codes of SVEZA-Les LLC and affiliate with SVEZA-Les LLC plywood mills FSC Name and addresses certificate code Limited Liability Company «SVEZA-Les» (SVEZA-Les LLC) GFA-COC-002290 Greenwood Office Center, 17, Putilkovo, Krasnogorsk District, 72nd km of MKAD, Moscow Region, Russia, 143441 GFA-CW-002290 Joint Stock Company «SVEZA Ust-Izhora» (JSC SVEZA Ust-Izhora) GFA-COC-001378 Fanernaya street. 5, p. Pontonniy, St.Petersburg, 196643, Russia GFA-CW-001378 Joint Stock Company «SVEZA