CLIMATE MITIGATION – REHABILITATION AND REFORESTATION

4. Audit Within two years after the beginning of the activity and every 10 years thereafter, the compliance of the activity with the substantial contribution to climate change mitigation criteria and the DNSH criteria are verified by either of the following: (a) the relevant national competent authorities; (b) an independent third-party certifier, at the request of national authorities or the operator of the activity. In order to reduce costs, audits may be performed together with any forest certification, climate certification or other audit. The independent third-party certifier may not have any conflict of interest with the owner or the funder, and may not be involved in the development or operation of the activity.

SFI certification requires an annual third-party audit to maintain SFI certification. SFI Section 10 SFI 2022 Audit Procedures and Auditor Qualifications and Accreditation, Part 6. addresses certification body independence and conflict of interest.

5. Group Assessment The compliance with the criteria for substantial contribution to climate change mitigation and with DNSH criteria may be checked: (a) at the level of the forest sourcing area (37) as defined in Article 2, point (30), of Directive (EU) 2018/2001;

SFI has three standards that address forest sustainability and therefore address climate change mitigation.

-SFI 2022 Forest Management Standard -SFI Small Lands Group Certification Module -SFI Small Scale Forest Management Module for Indigenous Peoples and Families

5. Group Assessment (b) at the level of a group of holdings sufficiently homogeneous to evaluate the risk of the sustainability of the forest activity, provided that all those holdings have a durable relationship between them and participate in the activity and the group of those holdings remains the same for all subsequent audits.

Addressed by SFI Section 10, Appendix 2 - Group Certification Organizations

DNSH 2 - Climate Change Adaptation The activity complies with the criteria set out in Appendix A to this Annex.

Performance Measure 9.2 Certified Organizations shall individually and/or through cooperative efforts involving SFI Implementation Committees or other partners identify and address opportunities to mitigate the effects associated with its forest operations on climate change.

DNSH 5 - Pollution prevention and control The use of pesticides is reduced and alternative approaches or techniques, which may include non-chemical alternatives to pesticides, are favored, in accordance with Directive 2009/128/EC, with exception of occasions where the use of pesticides is needed to control outbreaks of pests and of diseases.

Performance Measure 2.2. Certified Organizations shall have a program to minimize chemical use required to achieve management objectives while protecting employees, neighbors, the public and the environment, including wildlife and aquatic habitats.

DNSH 5 - Pollution prevention and control. The activity minimizes the use of fertilizers and does not use manure. The activity complies with Regulation (EU) 2019/1009 or national rules on fertilizers or soil improvers for agricultural use.

Performance Measure 2.2. Certified Organizations shall have a program to minimize chemical use required to achieve management objectives while protecting employees, neighbors, the public and the environment, including wildlife and aquatic habitats.

DNSH 5 - Pollution prevention and control Well documented and verifiable measures are taken to avoid the use of active ingredients that are listed in the Annex I, part A, of Regulation (EU) 2019/1021 (38), the Rotterdam Convention on the prior informed consent procedure for certain hazardous chemicals and pesticides in international trade, the Minamata Convention on Mercury, the Montreal Protocol on Substances that Deplete the Ozone Layer, and of active ingredients that are listed as classification Ia (‘extremely hazardous’) or Ib (‘highly hazardous’) in the WHO Recommended Classification of Pesticides by Hazard. The activity complies with the relevant national law on active ingredients.

Performance Measure 2.2. Certified Organizations shall have a program to minimize chemical use required to achieve management objectives while protecting employees, neighbors, the public and the environment, including wildlife and aquatic habitats.

Indicator 5. The World Health Organization (WHO) type 1A and 1B pesticides shall be prohibited, except where no other viable alternative is available.

DNSH 5 - Pollution prevention and control. Pollution of water and soil is prevented and cleaning up measures are undertaken when pollution occurs.

Performance Measure 2.2. Certified Organizations shall have a program to minimize chemical use required to achieve management objectives while protecting employees, neighbors, the public and the environment, including wildlife and aquatic habitats.

Indicator 8: Use of management practices appropriate to the situation, such as: i. use of spill response plans and chemical spill kits

Performance Measure 3.1. Certified Organizations shall meet or exceed all applicable federal, provincial, state and local water quality laws and meet or exceed best management practices.

Performance Measure 3.2. Certified Organizations shall implement water, wetland, and riparian protection programs based on climate, soil type, terrain, vegetation, ecological function, harvesting system, state best management practices (BMPs), provincial guidelines and other applicable factors.

Performance Measure 11.1 Certified Organizations shall comply with applicable federal, provincial, state, and local forestry and environmental laws and regulations.