forest management certification report - sgs · 2016. 2. 17. · date of issue 08 december 2009...
TRANSCRIPT
SGS QUALIFOR
(Associated Document)
Doc. Number: AD 36-A-05
Doc. Version date: 24 May 2007
Page: 1 of 76
SGS South Africa (Qualifor Programme) 58 Melville Road, Booysens - PO Box 82582, Southdale 2185 South AfricaSystems and Services Certification Division [email protected] South Africa (Qualifor Programme) 58 Melville Road, Booysens - PO Box 82582, Southdale 2185 - South AfricaSystems and Services Certification Division Contact Programme Director at t. +27 11 681-2500 www.sgs.com/forestry
FOREST MANAGEMENT CERTIFICATION REPORT
SSEECCTTIIOONN AA:: PPUUBBLLIICC SSUUMMMMAARRYY
Project Nr: 6274-ZA
Client: Mondi Ltd., South Africa
Web Page: www.mondigroup.com
Address: 171 Jabu Ndlovu Street, Pietermaritzburg , 3200
Country: South Africa
Certificate Nr. SGS-FM/CoC-000084
Certificate Type:
Forest Management
Date of Issue 08 December 2009 Date of expiry: 26 December 2012
Evaluation Standard SGS Forest Management Standard (AD33) adapted for South Africa version 04 of 29 March 2010
Forest Zone: Temperate
Total Certified Area 234 153 ha
Scope: Old Scope:
Forest management of plantations in the provinces of Mpumalanga, & KwaZulu-Natal in South Africa for the production of soft and hardwood timber and the purchase and sale of FSC certified Pine, Eucalyptus and Wattle pulpwood from Mondi plantations and outside sources, and the purchase of Controlled Wood from outside sources for sale as FSC Controlled wood on the transfer system.
New Scope:
Forest management of plantations in the provinces of Mpumalanga, & KwaZulu-Natal in South Africa for the production of soft and hardwood timber and the purchase and sale of FSC certified Pine, Eucalyptus and Wattle wood products, and the purchase of Controlled Wood from outside sources for sale as FSC Mixed wood on the Credit system to internal markets and the sale of FSC Certified hardwood and soft wood in the rough to external markets on the transfer system.
Location of the FMUs included in the scope
Iswepe, Piet Retief Areas are located in Southern Mpumalanga. eDumbe and Tygers Areas are in Northern KwaZulu Natal, Ntonjaneni and Umfolozi areas are in Zululand and the Greytown areas is in the KwaZulu Natal midlands.
Company Contact Person:
Tony Bold
Address:
Silvicultural Manager – Forests Operations
Mondi Ltd., South Africa
PO Box 39 Pietermaritzburg, 3200, South Africa
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Tel:
Tel : +27(0)33 8974077
Mobile : +27 (0)82 903 4843
Fax :+27(0)33 3456555
Email: [email protected]
Evaluation dates:
Main Evaluation 3 – 7 September 2007
Surveillance 1 15-23 September 2008
Surveillance 2 5-13 September 2009
Surveillance 3 2-8 November 2010
Surveillance 4
Copyright: © 2010 SGS South Africa (Pty) Ltd
All rights reserved
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TTAABBLLEE OOFF CCOONNTTEENNTTSS
1. SCOPE OF CERTIFICATE ..................................................................................................................... 5
2. COMPANY BACKGROUND .................................................................................................................. 8
2.1 Ownership .................................................................................................................................................... 8
2.2 Company Key Objectives .............................................................................................................................. 8
2.3 Company History .......................................................................................................................................... 9
2.4 Organisational Structure ............................................................................................................................... 9
2.5 Ownership and Use Rights ..........................................................................................................................11
2.6 Other Land Uses .........................................................................................................................................11
2.7 Non-certified Forests ...................................................................................................................................11
3. FOREST MANAGEMENT SYSTEM ..................................................................................................... 11
3.2 History of use ..............................................................................................................................................19
3.3 Planning process .........................................................................................................................................19
3.4 Harvest and regeneration ............................................................................................................................21
3.5 Monitoring processes...................................................................................................................................22
4. SOCIO-ECONOMIC AND ENVIRONMENTAL CONTEXT .................................................................... 23
4.1 Social aspects .............................................................................................................................................23
4.2 Environmental aspects ................................................................................................................................23
4.3 Administration, Legislation and Guidelines. ..................................................................................................24
5. CHANGES IN MANAGEMENT, HARVESTING, SILVICULTURE AND MONITORING......................... 26
6. PREPARATION FOR THE EVALUATION ........................................................................................... 28
6.1 Schedule .....................................................................................................................................................28
6.2 Team ..........................................................................................................................................................28
6.3 Checklist Preparation...................................................................................................................................28
6.4 Stakeholder notification ...............................................................................................................................29
7. THE EVALUATION .............................................................................................................................. 29
7.1 Opening meeting .........................................................................................................................................29
7.2 Document review.........................................................................................................................................29
7.3 Sampling and Evaluation Approach ..............................................................................................................29
7.4 Field assessments .......................................................................................................................................29
7.5 Stakeholder interviews .................................................................................................................................29
7.6 Summing up and closing meeting.................................................................................................................30
8. EVALUATION RESULTS ..................................................................................................................... 30
8.1 Findings related to the general QUALIFOR Programme ................................................................................30
PRINCIPLE 1: Compliance with law and FSC Principles.................................................................................30
PRINCIPLE 2: Tenure and use rights and responsibilities ...............................................................................32
PRINCIPLE 3: Indigenous peoples’ rights ......................................................................................................33
PRINCIPLE 4: Community relations and workers rights ..................................................................................33
PRINCIPLE 5: Benefits from the forest..........................................................................................................35
PRINCIPLE 6: Environmental impact ............................................................................................................36
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PRINCIPLE 7: Management plan ..................................................................................................................39
PRINCIPLE 8: Monitoring and evaluation .......................................................................................................40
PRINCIPLE 9: High Conservation Value Forests ............................................................................................41
PRINCIPLE 10: Plantations .............................................................................................................................42
9. CERTIFICATION DECISION ................................................................................................................ 43
10. MAINTENANCE OF CERTIFICATION ................................................................................................. 44
11. RECORD OF CORRECTIVE ACTION REQUESTS (CARs) ................................................................. 46
12. RECORD OF OBSERVATIONS ........................................................................................................... 59
13. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS ........................................................ 64
14. RECORD OF COMPLAINTS ................................................................................................................ 69
ASSOCIATED DOCUMENTS (not part of the Public Summary)
AD 20: Evaluation Itinerary
AD 21: Attendance Record
AD 26: Corrective Action Requests
AD 36-B: Evaluation – Observations and Information on Logistics
AD 40: Stakeholder Reports
Evaluation team CV’s
List of stakeholders contacted
Complaints and Disputes
Procedures for submitting complaints, appeals and disputes, and the SGS processing of such are published on www.sgs.com/forestry. This information is also available on request – refer contact details on the first page.
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INTRODUCTION
The purpose of the evaluation was to evaluate the operations of Mondi Ltd., Forests Division, against the requirements of the QUALIFOR Programme, the SGS Group’s forest certification programme accredited by Forest Stewardship Council.
1. SCOPE OF CERTIFICATE
The scope of the certificate falls within the Temperate Forest Zone and includes 29 Forest Management Units (FMUs) as described in Annexure A where the full list of properties included in the scope of this certificate is provided.
2010 Update: The Business Unit North has been sold, so the areas listed below are the ones within the scope of the certificate:
Description of Areas:
Description Ownership Area (ha) Longitude E/W Latitude N/S
Iswepe Own & Leased See Annex A See Annex A See Annex A
Piet Retief Own & Leased See Annex A See Annex A See Annex A
E’Dumbe Own & Leased See Annex A See Annex A See Annex A
Tygers Own & Leased See Annex A See Annex A See Annex A
Ntonjaneni Own See Annex A See Annex A See Annex A
Umfolozi Own & Leased See Annex A See Annex A See Annex A
Greytown Own & Leased See Annex A See Annex A See Annex A
Size of FMUs:
Nr of FMUs Area (ha)
Less than 100ha 0 0
100 to 1000 ha in area 0 0
1001 to 10000 ha in area 19 114 294.1
More than 10000 ha in area 13 185 817.3
Total 300 111.4
2010 Update: There are 7 areas (FMUs) comprising 234 153.0 ha
Total Area in the Scope of the Certificate that is:
Area (ha)
Privately managed (2010 update is 234 153ha) 300 111.4 ha
State Managed 0
Community Managed 0
Composition of the Certified Forest(s)
Area (ha)
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Composition of the Certified Forest(s)
Area (ha)
Area of forest protected from commercial harvesting of timber and managed primarily for conservation objectives
102 070.5 ha
Area of forest protected from commercial harvesting of timber and managed primarily for production of NTFPs or services
0 ha
Area of forest classified as “high conservation value forest” 954.1 ha
Total area of production forest (i.e. forest from which timber may be harvested) 197 086.8 ha
Area of production forest classified as “plantation” 197 086.8 ha
Area of production forest regenerated primarily by replanting 197 086.8 ha
Area of production forest regenerate primarily by natural regeneration 0
List of High Conservation Values
Description Notes
Protection of Indigenous Forests
Protection of Grasslands
Protection of Coastal forests
List of Timber Product Categories
Product Class Product Type Trade Name Category Species
Wood in the rough
Logs of coniferous wood
Pine Logs Conifer
Pinus spp
Wood in the rough
Logs of non-coniferous wood
Eucalyptus logs Deciduous (Hardwood)
Eucalyptus spp
Wood in the rough
Logs of non-coniferous wood
Acacia logs Deciduous (Hardwood)
Acacia spp
Annual Timber Production
Species (botanical name) Species (common name) Area (ha) Maximum Annual Sustainable Yield (m3)
Projected Actual
Eucalyptus sp Gums 13 283 3 181 636 2 208 569
Pinus sp Pines 1 405 382 650 337 985
Acacia sp Wattle 1 998 249,468 164 627
Totals 16 686 ha 4,733,044 3 331 749
List of Timber Product Categories
Product Notes
Hard and soft wood round timber for pulp
Mondi is a paper mill and all timber is utilised as pulp.
Totals
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Approximate Annual Commercial Production of Non-Timber-Forest-Products
Product Species Unit of measure Total units
Botanical Name Common Name)
Mushrooms Boletus edulis Button mushroom kg 12722
Lists of Pesticides: Forests
Product Name Quantity Used (litres) Area of application (ha)
MA SA1 SA2
SA3 SA4 MA SA1 SA2 SA3 SA4
Alpha cypermethrin 1106 3659
Clopyralid 152 85
Deltamethrin 1692 1460
Fluroxypyr 877 3563
Fluroxypyr/picloram 1275 2325
Glufosinate ammonium 85 100
glyphosate 170017 103244
Imazapyr 4579 15271
Metazachlor 402 656
Metsulfuron-methyl 47 427
Paraquat 1730 2151
Picloram 7098 2426
Triclopyr 8960 25850
Lists of Pesticides: Nurseries
Product Name Quantity Used (litres) Area of application (ha)
MA SA1 SA2 SA3 SA4 MA SA1 SA2 SA3 SA4
Bendioxide 167 242
Deltamethrin 5.2 12
glyphosate 136 72
Captab 156 N/a
Tebuconazole (Folicur) 9 37
Prochloraz manganese chloride (Octave)
36 12
Propamocarb hydrochloride (Previcur N)
54 N/a
N, N-didecyl-N, N-dimethylammonium chloride (Sporekill)
338 N/a
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2. COMPANY BACKGROUND
2.1 Ownership
Mondi is a leading international paper and packaging group, with 34,000 employees across 112 sites in 34 countries.
Today Mondi have two primary businesses, Packaging and Paper business units, each of which is a major player in its own market sector. Mondi Ltd., is the largest producer of office paper and second largest producer of uncoated wood free paper in Europe. This assessment is done on the operations of Mondi Ltd., Forest Division in South Africa and the certificate only covers the South African operations.
Mondi have corporate offices in both the UK and South Africa, and are listed in London and Johannesburg under a dual-listed company structure.
Total land holdings is 295 189 ha of which 239 428,6 is owned by Mondi and the rest is leased.
Peak plantations in Swaziland that previously formed part of the certificate was sold in 2007 and is not included in this certificate.
The Letaba estates were at the time of the audit also being considered for sale and also not included in the certificate.
2.2 Company Key Objectives
Objective Notes
Commercial
As a major wood and pulp user, it is important to Mondi that our forest management governance framework is robust and effective in ensuring we abide by best practice in all aspects of forest management, wood/pulp sourcing and procurement.
Social
Recognizing and respecting the rights of indigenous peoples and local communities to own, use and manage their land and resources.
Promoting strong relations with Government, Non-Governmental Organizations (NGOs), local communities and relevant stakeholders to support transparency and willingness to engage on sustainability issues.
Ensuring that land use rights for forestry operations are clearly defined and established.
Abiding by the relevant national/regional laws and international treaties.
Environmental
Ecologically, plantation forestry can have a negative effect on the environment if poorly managed, including the loss of indigenous wildlife and an increased risk of invasion by alien species.
Mondi was one of the leaders in the development of “new generation plantation forests” that demonstrate sustainable and responsible plantation management. These initiatives include:
• Leading the development of practical national definitions for wetland and riparian delineation.
• Sponsoring and supporting the Mondi Wetlands Project and implementing the Mondi wetland policy that demonstrates the identification and protection of wetlands and riparian systems.
• Actively participating with WWF and other NGOs to identify and protect High Conservation Value (HCV) areas associated with our plantations.
• Supporting pioneering work at the Stellenbosch University to identify and assess the value and effectiveness of Mondi’s biodiversity corridors.
• Sponsoring and supporting a WWF initiative to assess the biodiversity priorities of South Africa’s freshwater systems.
• Ensuring that at least 10% of our forests’ plantation area (including all areas classified as biologically sensitive) is managed for biodiversity and forest protection. These areas include important wetlands,
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Objective Notes
grassland and indigenous forest ecosystems
2.3 Company History
The roots of the global business that is now Mondi were first planted in 1967 in South Africa, when our former owners Anglo American plc built the Merebank Mill. Following more than two decades’ growth and consolidation in South Africa, Mondi expand to Europe in the early 1990s to start a long period of expansion through acquisition. Mondi have bought businesses in countries including Austria, the UK, France, Russia, Slovakia, Poland, Hungary, Slovakia, Denmark, the Netherlands, Bulgaria and Italy, as well as operations in Mexico, the US and China. During this time, many major companies – often market leaders in their home nations – became part of Mondi. These included Austria’s Neusiedler AG and Frantschach AG, Cofinec in Poland, and Russia’s Syktyvkar Mill, which is central to our future expansion plans alongside emerging opportunities in Asia and the Americas. In 2004, Mondi restructured the business into two main business units, Packaging and Business Paper, both of which now have dominating positions in their respective markets. Mondi also own UK and South African newsprint businesses and Europapier, a European paper merchant group. Mondi Group achieved sales of €5.36 billion in the year following the restructuring. As a result of the expansions and merges there are different FSC certificates within the Mondi group. This one is specific to the Mondi Business Paper operations in South Africa. Significant recent changes dating back to 2005 were the expansion of pulp mill in Richards Bay and the rebuild of PM31 paper machine in Merebank. Both these mills operate under their own CoC certificates. Mondi became an independent dual-listed business in mid-2007 when we successfully de-merged from Anglo American with listings on the London and Johannesburg Stock Exchanges.
2.4 Organisational Structure
The organizational structure of Mondi’s forestry operations of Mondi aims to focus maximum decision making authority to the three Business Unit (BU) levels. Operational control below this stratum is vested in Area Managers. All Technical Specialists are managed through a Competency Centre (CC) with the primary focus of maximum support to operational staff. Detailed organo-grams for all levels of staffing within forestry operations are indicated below.
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2.5 Ownership and Use Rights
The majority of the land holdings belong to the company 81%, but there are also some farms that are leased from private owners. Lease agreements are drawn up between Mondi and the owner and differ from farm to farm. Leased farms are also included in the scope of the certificate and Mondi takes full responsibility for the sustainable management of timber resources on these farms as well as the implantation and maintenance of the environmental safeguards.
2.6 Other Land Uses
It is taken into consideration that Mondi’s primary focus is the growing of trees for the production of paper. Land is therefore primarily acquired for that purpose and selected for its suitability to grow trees. It is reflected in the scope of the certificate in par 1. Despite this, about 27% of the land is not planted to trees and amounts to just below the 100 000ha. This is a substantial area and is managed by Mondi as open areas. A small portion, about 1700 Ha is under sugarcane. The remainder includes the land occupied by infrastructure and the majority by conservation zones. Conservation zones includes all the wetlands, riparian zones, rocky outcrops, forests, duineveld etc, each with its own specific management requirements that is included in the particular estate’s management plan for that open area. The Satico estate is leased from Safcol and historic mines occur. They are no longer active and the management of the land is under Mondi’s control.
2.7 Non-certified Forests
The Letaba estates were at the time of the audit also being considered for sale and also not included in the certificate.
During 2004, the non-core Mondi Forests Letaba plantations and the Mondi Mining Supplies Division were incorporated (and empowered) into an entity known as Mondi Imbani Mining Supplies (MIMS).
MIMS assumed responsibility for these assets and managed them independently of Mondi Forests until the business was sold to Reatile Mining Solutions (RMS) in October 2005. The RMS transaction excluded the Letaba plantations and these reverted to Mondi Forests (subsequently renamed the Forest Operations of Mondi Business Paper South Africa). As these plantations were still regarded as non-core, board approval was sought for their disposal.
Permission was granted in December 2006 and negotiations commenced with a number of interested parties including Shanyela Timber Resources and Silicon Smelters. Negotiations are currently at an advanced stage.
The current fibre shortage (exacerbated by the recent fires) has lead to the review of the decision to sell any landholdings. Accordingly, the sale of the Letaba plantations has been placed on hold pending the review. Should the decision to sell be reversed, it is likely that these plantations will be re-included into the certified FMU.
3. FOREST MANAGEMENT SYSTEM
3.1 Bio-physical setting
Geography:
Mondi’s plantations are situated on the eastern part of the Kwazulu Natal and Mpumalanga provinces of South Africa. The topography of Mondi’s landholdings varies immensely from the flat Zululand coastal plains to the steep sided Lebombo mountain range, and can be viewed for specific farms through the Mondi GIS system. Slopes classes and ground roughness data is also available.
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Ecology:
Mondi’s landholdings in South Africa occur along the Eastern seaboard of the country and are characterized by hot summers and mild to cold winters. Frost occurs in most areas at higher altitudes (>900 m), with snow falls recorded on higher lying farms generally above 1200 m in altitude. Mean annual temperatures (MAT) range from 14.0 – 22 °C. Rainfall varies between 800 mm - 1 200 mm per annum. The majority of Mondi Business Paper land holdings are situated within the Sub-Escarpment Savannah and Indian Ocean Coastal Belt Bioregions (Mucina and Rutherford, 2006).
In terms of the National Spatial Biodiversity Assessment (NSBA), significant areas of priority vegetation types within Mondi Business Paper landholdings are described by Mucina and Rutherford 2006.
• Midlands Mistbelt Grassland
Found in the KwaZulu-Natal and Eastern Cape Provinces. In the KwaZulu-Natal Midlands it is scattered in a broad belt in the form of several major patches, including Melmoth-Babanango area,
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Kranskop and Greytown, Howick Lions River, Karkloof, Balgowan, Cedara, Edendale, Hilton, Richmond, the Ixopo-Highflats area, Mount Malowe in the Umzimkhulu enclave of the Eastern Cape Province and the Harding-Weza area. Found within an altitudinal range of 760 - 1400 m.
Only a few patches of these original species-rich grasslands remain and is one of the most threatened vegetation types of KwaZulu-Natal. A small fraction (about 0.5%) is statutorily conserved in a number of reserves such as Ngeli, Impendle, Blinkwater, Qudeni, Doreen Clark, Karkloof and Queen Elizabeth Park, and is still heavily under-represented in conservation plans. More than half of this endangered vegetation type is already transformed by plantations, cultivated land and urban sprawl. Uncontrolled fires and poorly regulated grazing by livestock add to threats to this unique grassland. Some aliens (including Solanum mauritianum, species of Rubus, Acacia, Pinus and Eucalyptus) are of concern in places.
• Maputaland Wooded Grassland
Found in KwaZulu-Natal Province and southern Mozambique. In South Africa it is found from the Mozambique border near Kwa-Ngwanase southwards to Sileza, Sibaya, Mseleni, Mbazwana, Sodwana Bay, Ozabeni, eastern and western shores of Lake St Lucia, Kwambonambi and as far south as Richards Bay. Altitudinal range varies from 20 -120 m.
About 17% of this vegetation type is statutorily conserved, mainly in the Greater St Lucia Wetland Park. Another 46% is transformed mostly by plantations and cultivated land, especially in the southern half of the area where over 90% of this vegetation type has been transformed mostly to pulpwood timber plantations, cane fields and informal settlements. Aliens include scattered populations of Chromolaena odorata and Lantana camara.
• Swamp Forest
Found in KwaZulu-Natal and the Eastern Cape Provinces in pockets and narrow ribbons, extending in a narrow belt along the Indian Ocean coast from Maputaland to as far south as Port Grosvenor in Pondoland. Swamp Forests reach lower latitudes than Mangrove Forests, which suggests that they are climatically more limited than the mangroves. They occur at low altitude, mainly between 20 - 60 m. Swamp forests have a strong tropical link and reach their southern most distribution limit in South Africa.
Of this critically endangered vegetation type some 66% is statutorily conserved in the Greater St Lucia Wetland Park, Maphelana, Dududuku, Raphia Palms and Umlalazi Nature Reserves. An unknown portion has been already transformed either to plantations or by illegal clearing for making fruit and vegetable gardens. Chromolaena odorata, Lantana camara and Pereskia species are common invaders in disturbed swamp forests. Change in local hydro-geological conditions poses another serious threat to this fragile forest ecosystem.
• KwaZulu-Natal Sandstone Sourveld
Found in the KwaZulu-Natal Province on elevated coastal inland sandstone plateaus from Mapumulo near Kranskop in the north to St Faiths near Port Shepstone in the south (including Noodsberg, Hillcrest, Kloof, Table Mountain, Inanda, Stony Hill, Umbumbulu, Mid-Illovo, Dumisa, Highflats). Altitudinal range is 500 -1100 m.
Of this endangered vegetation type only 0.2% is statutorily conserved in the Krantzkloof and Vernon Crookes Nature Reserves. Some 68% has been transformed by cultivation, plantations, urban development or road building. This highly transformed vegetation type is a prime agricultural area primarily planted to sugar cane and timber plantations. The urban sprawl of the Ethekwini (Durban) Metropolitan Area and densely populated subsistence farming areas account for most of the remainder. Apart from the critically little conserved areas (only several hundred hectares), most remaining areas are subjected to high levels of grazing and frequent fire not conducive to the recruitment of seedlings of many of the shrubs and herbs.
• Kaalrug Mountain Bushveld
It is found primarily in the Mpumalanga Province. It also occurs in a small area in Swaziland on mountain slopes and hills from Barberton in the west continuing eastwards south of the Kaaps River, and lower Crocodile River, including the lower slopes of Three Sisters and Kaalrug. Generally occurs at an altitude range of range of 350 - 950 m.
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Some 16% of this vegetation type is statutorily conserved, almost all in Mountainlands Nature Reserve. A further 9% is conserved in the private reserves of Cwantalala and Boondocks. About 12% had been transformed, mainly by cultivation and plantations.
• Northern Coastal Forest
Found in KwaZulu-Natal and to a very small extent in the Eastern Cape Province, especially along the seaboards of Indian Ocean of KwaZulu-Natal Province, and particularly well-developed in Maputaland. Beyond South Africa, these forests occur throughout the Mozambican seaboard as far as southern Tanzania. Found at low altitudes, from 10 - 150 m.
This vegetation type is under threat on coastal dunes of KwaZulu-Natal due to mining. About 68% is statutorily conserved in Manguzi, Greater St Lucia Wetland Park, Maphelana, Dukuduku, Sodwana Bay, Richards Bay, Umlalazi, Enseleni, Amathigulu, Harold Johnson, Hawaan, Umhlanga Lagoon, Kenneth Stainbank, Impisini, Skyline, Frederika, Mpenjati Nature Reserves, mostly under Ezemvelo KZN Wildlife management. The original extent of these forests has been diminished by agriculture (mainly sugar cane and fruit gardens), timber plantations, urban sprawl and tourism-oriented development on the KwaZulu-Natal coast. Besides the ongoing coastal development pressures, illegal clearing of the forest and turning it into lots for small-scale agriculture is a current threat. Coastal dunes are being prospected and exploited for heavy metals though some companies are, however, actively engaged in dune forest regeneration programmes. These subtropical forests are sensitive to alien plant invasion, and invaders such as Chromolaena odorata, species of Pereskia and Acacia are posing serious threats.
• Barberton Montane Grassland
Found in the Mpumalanga Province and north-western Swaziland from Barberton westwards towards Nelshoogte, northwards along the high-lying grassland areas towards Kaapmuiden and Malelane, and southeast towards Piggs Peak. It generally occurs at high altitudes, ranging from 760 m in the north to 1 640 m in the southwest.
This vegetation type is classified as vulnerable. The conservation target of 27% has almost been reached as 26% of this unit is protected within nature reserves (Songimvelo Game Reserve and Mountainlands Nature Reserve). Almost 40% has been transformed by plantations.
• Northern Zululand Mistbelt Grassland
Found in KwaZulu-Natal Province along the crests and slopes of the Ngome Mountain range and the Ngoje Mountain surrounding Louwsburg, as well as some smaller mountainous areas of Langkrans, KwaCeza, KwaNtimbankulu and Nhlazatshe. Altitude range varies from approximately 780 -1540 m.
This vegetation type is classified as vulnerable and only about 3% is statutorily conserved in the Ithala Nature Reserve and in the Ntendeka Wilderness Area of the Ngome State Forest. Some 22% has been transformed by plantations or cultivated land. Threats to the remaining grasslands are heavy selective grazing by livestock and extensive annual burning. Spread of alien Acacia mearnsii and Eucalyptus species is of serious concern.
• Paulpietersburg Moist Grassland
Found in the KwaZulu-Natal and Mpumalanga Provinces including the broad surrounds of Piet Retief, Paulpietersburg and Vryheid, extending westwards to east of Wakkerstroom. It occurs in the uppermost catchments of the Phongolo River. Altitude range varies from 920 - 1 500 m.
This vegetation type is classified as vulnerable. Only a very small portion is statutorily conserved in the Witbad, Vryheid Mountain, Paardeplaats and Phongola Bush Nature Reserves. Some private reserves protect small patches (Rooikraal, Mhlongamvula, and Kombewaria). About one third has already been transformed by plantations or cultivated land. Heavy livestock grazing and altered fire regimes have greatly reduced the area of grasslands of high conservation value. Aliens such as species of Acacia, Eucalyptus and Pinus are of major concern in places.
• Maputaland Coastal Belt
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Found in the KwaZulu-Natal Province (and continues in southern Mozambique) in a broad strip (up to 35 km wide) along the coast of the Indian Ocean, stretching from the Mozambique border in the north to Mtunzini in the south. Altitude varies from about 20 - 120 m.
Of this vulnerable vegetation type 15% is statutorily conserved in the Greater St Lucia Wetland Park as well as in Sileza, Enseleni and Amathikulu Nature Reserves. More than 30% has been transformed by plantations, cultivation and by urban sprawl. Aliens include scattered populations of Chromolaena odorata and Lantana camara. This vegetation type has a relatively high number of plant taxa at the southernmost and northernmost limits of their distribution range - the occurrence of outlier populations increase the conservation value of this vegetation type.
• Northern Escarpment Quartzite Sourveld
Found in the Limpopo and Mpumalanga Provinces occurring along the high-altitude crests of the Northern Escarpment, from Haenertsburg in the north, south-eastwards, then bending southwards past Blyde River Canyon, Graskop and as far south as the vicinity of Kaapsehoop. Altitude range is 1000 -1740 m.
Of this vulnerable vegetation type 15% is protected within the Lekgalameetse and Blyde River Canyon National Park. Up to 38% of this vegetation type has been transformed by plantations (37%) and some limited cultivated areas.
• KaNgwane Montane Grassland
Found in Mpumalanga and Swaziland, and marginally into northern KwaZulu-Natal. It occurs along the gentle slopes of the Escarpment, from the Phongolo Valley in the south, northwards to the Usutu Valley and to the uppermost Lomati Valley near Carolina, including the western grassland areas of Swaziland. Altitude range is 880 -1740 m.
This vegetation type which is classified as vulnerable has only 0.4% protected within any formally proclaimed nature reserves (Malalotja, Nooitgedacht Dam and Songimvelo). A number of private conservation areas protect small patches of this unit. It is well suited for afforestation and 30% has already been converted to plantations. A further 6% is under cultivation.
• Southern Mistbelt Forest
Found in KwaZulu-Natal and Eastern Cape Provinces. Occurs as forest patches varying in size; usually in fire-shadow habitats on south and southeast-facing slopes and located along the Great Escarpment, spanning a large area from Somerset East, the Amathole Mountains, scarps of Transkei to the KwaZulu-Natal Midlands as far east as Ulundi. In KwaZulu-Natal these forests are found in a wide band sandwiched between the Drakensberg Montane Forests and Northern KwaZulu-Natal Mistbelt Forests at higher altitudes, and Eastern Scarp Forests at lower altitudes. Belts of forest patches belonging to this vegetation unit occur in the Baviaanskloof Mountains, Zuurberg Mountains and in the region spanning Grahamstown and King William’s Town. Found at altitudes spanning 850 -1600 m (most patches are between 1000 -1400 m).
This vegetation type is classified as least threatened. Some 8% is statutorily conserved (including forests under DWAF jurisdiction) in the Eastern Cape. In KwaZulu-Natal these forests are statutorily protected at Impendle, Igxalingenwa, Karkloof and Qudeni Nature Reserves. Several private reserves protect smaller patches. About 5% has been transformed by plantations. Invasive aliens include Solanum mauritianum, Rubus species and several Acacia and Eucalyptus species. Uncontrolled harvesting of timber, poles and fire wood, over exploitation of non-timber forest products, and mismanagement of fire and burning regimes in surrounding grasslands are considered major threats.
• Southern KwaZulu-Natal Moist Grassland
Found in the KwaZulu-Natal and Eastern Cape Provinces, specifically in interior valley basins at Creighton, Malenge and Centocow in the south, and the upper Mkomazi River and Howick in the north. Altitude range is 880 - 1480 m.
About 4% of this vegetation types is statutorily conserved at the Impendle, Midmar, Igxalingenwa and Ingelabantwana Nature Reserves as well as in the Soada Forest Nature Reserve, and in the uKhahlamba Drakensberg Park. More than one third is already transformed by cultivation, plantations, urban sprawl and building of dams (such as Midmar). Several woody aliens (Solanum
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mauritianum, Arundo donax, Eucalyptus species, Melia azedarach, Sesbania punicea, Populus alba) occur in these grasslands, but their impact is only of local importance.
• Swaziland Sour Bushveld
Found in the Mpumalanga Province, Swaziland and marginally into KwaZulu-Natal from Badplaas, Tjakastad east to Piggs Peak area in the north, southwards through valleys around Manzini and slopes around the Grand Valley, and some isolated mountain outcrops in the lowveld plains. Altitude range is 400 - 1100 m.
Classified as vulnerable, about 6% is statutorily conserved in the Songimvelo, Ithala and Malalotja Nature Reserves, and a further 0.5% conserved in the Mlilwane Game Sanctuary in Swaziland. Some 21% has been transformed by cultivation and plantations.
• Northern Zululand Sourveld
Found in KwaZulu-Natal and the Lusthof area in Swaziland, south-wards with scattered patches in northern Zululand in the surrounds of Hlomohlomo, east of Louwsburg, Nongoma and the vicinity of Ulundi, including Nkandla. In the Hluhluwe-Umfolozi Park it occurs at the highest altitudes. Altitude range is between 450 - 900 m.
Only 4% of this vegetation type is statutorily conserved, mainly in the Hluhluwe-Umfolozi Park and Ithala Game Reserve. Some 22% is already transformed, mainly by cultivation and plantations.
• Ngongoni Veld
Found in KwaZulu-Natal and the Eastern Cape Provinces, from Melmoth in the north to Libode in the former Transkei (including Eshowe, New Hanover, Camperdown, Eston, Richmond, Dumisa, Harding, Lusikisiki and the Libode area). Altitude range is 400 - 900 m.
Less than 1% of this vegetation type is statutorily conserved in the Ophathe and Vernon Crookes Nature Reserves. Some 39% has been transformed by cultivation, plantations and urban development.
• Drakensberg Foothill Moist Grassland
Found in the KwaZulu-Natal and Eastern Cape Provinces in a broad arc of Drakensberg piedmonts covering the surrounds of Bergville in the north, Nottingham Road, Impendle, Bulwer in the east, and Kokstad, Mount Currie, Underberg (KZN) and the surrounds of Mt Fletcher, Ugie, Maclear and Elliot (Eastern Cape) in the south-west. Altitude range is 880 - 1860 m.
Though currently classified as least threatened, only 2 to 3% is statutorily conserved in the uKhahlamba Drakensberg Park, Ntsikeni Wildlife Reserve as well as in the Karkloof, Mount Currie, Coleford, Fort Nottingham, Impendle, Ngeli, and Umgeni Vlei Nature Reserves. Almost 20% is already transformed by cultivation, plantations and urban sprawl. Alien woody species including Rubus, Acacia dealbata and Solanum mauritianum may become invasive in places.
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Summary description of vegetation types found on Mondi land
Vegetation type Area (ha)
Barberton Montane Grassland 5,077
Drakensberg Foothill Moist Grassland 166
Eastern Highveld Grassland 5,081
Eastern Temperate Freshwater wetlands 11
Eastern Valley Bushveld 115
Income Sandy Grassland 3,575
Ithala Quartzite Sourveld 511
Kaalrug Mountain Bushveld 3,270
KaNgwane Montane Grassland 16,708
KwaZulu-Natal Coastal Belt 378
KwaZulu-Natal Highland Thorn veld 263
KwaZulu-Natal Hinterland 885
KwaZulu-Natal Sandstone 707
Legogote Sour Bushveld 6,291
Lydenburg Montane Grassland 1,251
Makhado Sweet Bushveld 310
Maputaland Coastal Belt 4,220
Maputaland Wooded Grassland 557
Midlands Mistbelt Grassland 9,484
Mooi River Highland Grassland 13
Ngongoni Veld 6,079
Northern Afrotemperate Forest 8
Northern Coastal Forest 164
Freshwater Lakes 3
Northern Escarpment Dolomite 1,001
Northern Escarpment Quartzite Sourveld 2,406
Zululand Lowveld 8
Northern Mistbelt Forest 84
Northern Zululand Mistbelt Grassland 6,442
Northern Zululand Sourveld 15,594
Paulpietersburg Moist Grassland 8,439
Pretoriuskop Sour Bushveld 221
Scarp Forest 165
Southern KwaZulu-Natal Moist Grassland 112
Southern Mistbelt Forest 524
Soutpansberg Mountain Bushveld 157
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Subtropical Freshwater Wetlands 71
Swaziland Sour Bushveld 79
Thukela Thornveld 1
Wakkerstroom Montane Grassland 1,524
Zululand Coastal Thornveld 116
Grand Total 102,070
Although vegetation is used to describe the general veldtypes it also includes the normal ecological functions associated with that veldtype. Mondi’s land hosts 51 red data plant species, 42 mammal species, 15 Reptiles, 10 amphibians and 28 bird species. These species are protected on Mondi’s land and special care is taken in the management plans for them.
Soils:
Mondi’s forestry soils are a complex assortment of types which maybe ascribed to a wide variety of parent materials, differences in climate, vegetation and topography, and differences in the length of time that the soil forming processes have been operating. Plantations cover five major soil associations and can be briefly described as follows:
A. Low base status, apedal, red and yellow, well drained clayey soils
These are highly leached (dystrophic), very acid, apedal (i.e. weakly structured), clayey soils occurring in the high rainfall areas a long the eastern seaboard of KwaZulu-Natal, Mpumalanga, Northern Province and Swaziland. These are excellent forestry soils.
B. Red, yellow and grey soils in catenary association (red-yellow-grey latosol plinthic catena)
A catena implies a sequence of soils of about the same age, derived from similar parent material, and occurring under similar climatic but with different characteristics sue to variation in relief and drainage. The red soils usually occur on the higher lying, well drained sites, the yellow soils with plinthic (mottles or iron concretions)subsoils on moderately well drained sites; the grey soils with plinthic subsoils on somewhat poorly drained, low lying sites; the dark coloured gleyed soils in poorly drained bottomland areas. These soils are considered to be of a slightly lower suitability than that of association A above.
C. Duplex and paraduplex soils
This association is characterised by a duplex morphology which means that the topsoils differ markedly from the subsoils in texture, structure and consistency, e.g. a relatively coarse-textured, soft, structure-less topsoil overlying relatively clayey, slowly permeable, strong structured subsoil. In duplex soils the topsoil always overlies the subsoil abruptly, whereas in paraduplex soils an abrupt transition between top soil and sub-soil is not present. The soil process taking place implies a downward movement of clay into the subsoils, causing colour variations and a higher clay content, manifested as prominent clay cutans .
D. Weakly developed soils on rock (lithosols)
The dominant soils of this association exhibit a profile consisting of only topsoil overlying rock or weathered rock. They are therefore shallow and in texture resemble the rock from which they have originated (e.g. shale yields loamy to clayey soils, and granite, sandstone and quartzite sandy soils). Dominant soil forms are Mispah, Glenrosa, Mayo and Swartland (where shale or granite are the parent material), or Cartref, Houwhoek, Groenkop and Jonkersberg (where sandstone or quartzite are the parent material) These lithosols are generally not suited to commercial forestry because of their shallow state and the rugged terrain that they tend to occur on. However, where they do occur it is sometimes planted to Acacia mearnsii or Pinus elliottii.
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E. Sandy soils
These soils (usually very deep) have less than 10% clay. Of importance to forestry is the deep grey sands derived mainly from beach deposits which occur extensively along the coast. Dominant soils forms are Fernwood, Vilafontes and deep Kroonstad (Zululand) These soils are generally quite infertile, with low water holding capacities and subject to wind erosion. Where rainfall is adequate (such as along the east coast, north of Durban), these soils have a moderate to moderate-high suitability for commercial forestry. These soils dominate the Zululand coastal plain from Mtunzini to Dukuduku and allow excellent tree growth during period of good rainfall but are very susceptible to drought stress due to their poor water holding capacities.
Detailed soil surveys are part of routine forest operations in Mondi and are managed as an extensive layer in the Geographical Information System to assist in strategic, tactical and operational decision making. To ensure human actions do not leave an environmental footprint on soils, potential impacts on the soils are considdered when harvesting operations or slash management are planned by mitigating the impacts with sound practices such as delineation of hydromorphic soils, planned extraction routes, exercise no-burn options and practicing sound forest nutrition principles.
The Mondi target was to soil survey and map 80% of all its land holdings by December 2007. That figure was exceeded and 95% achieved.
3.2 History of use
The properties currently managed by Mondi is inter dispersed by agricultural holdings. Agriculture commodities include sugarcane, cattle ranching and private timber growers. Properties are mainly owned by the individual farmers or the large corporate like Mondi. Initially agriculture were viewed the most preferential land use until such time as timber became a prosperous industry. Today certain areas are well known forestry regions and many of the smaller towns depends on the forestry sector for
their existence and prosperity.
3.3 Planning process
A series of very comprehensive databases are incorporated within the Geographic Information System (GIS) system and includes soil data and climatic data, cadastral data, open area management data, areas of special interest, and many other data sets which are maintained for responsible plantation management.
Every farm and compartment is mapped and the digital data is managed by the GIS section within Mondi Business Paper. Compartment details such as species, growth cycle, compartment area, enumerated volume, plant date, fell date, previous species and next species to plant, site index, and silvicultural operations performed in the compartments are maintained and updated on ‘Micro-Forest’ (MF) software system.
All systems are linked for the production of maps and synchronisation of data sets. Database Administrators assist in keeping the database up to date by monthly reporting of operations, editing the data after re-mapping, delineation surveys, database corrections, and replanting has taken place. The GIS software system calculates the areas of compartments and updates MF with the new areas when corrections have taken place.
Age class reports are published annually in the long term (30 year) plan. The species mix and age class are managed by the annual update of the thirty year plan which indicates the next species to plant at a compartment level.
All details pertaining to the annual planting plan are available on the Mondi GIS system and include site quality, soil type, and the next species choice. It also indicates second and third choice specie that can be planted, with permission, should there be seedling shortages or crop failures. The felling plan is the first year of the long term plan which is also updated annually. This gives the compartments and their volume to be felled for the next 30 years, but more specifically the current year and the next year from the working plans.
Micro-Forest data is exported to ‘Harvest Simulator System’ (HSS) annually to create a long term plan. This plan is calculated for a period of 30 years which equates to two rotations of 15 years for pine plantations. HSS calculates volume with the use of growth models at compartment level (Figure 1) and works on the basis of felling the oldest compartments first until a desired volume for that year has been reached. Felled compartments are then scheduled for replanting. HSS then proceeds to fill the
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second year and third years until it has completed the 30 year period. HSS also calculates the age at which the compartments will be felled. Several simulations are run to achieve an optimum and sustainable plan in terms of annual delivered volume. Minimum and maximum age, volume per year and hectare parameters can be set to achieve a constant felling volume over time.
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Figure 1: Utilisable MAI and CAI curves for E.gxc hybrid clones grown along the Zululand Coast
The first few years of the felling plan generated above can be kept intact to form working plans (short term plans). This working plan is compiled by taking account of market demands, proximity of compartments to each other (block felling), road network and depot positioning, and rail availability. These working plans endeavour to consolidate the felling of farms and locations within farms, with the aim of reducing harvesting and transport costs.
Planning also includes data audits, enumerations (stock inventory of compartments 18 months prior to felling), working plan compilation and planting plans (including the site species matching aspect). These plans are in preparation for the current year’s production and the following year’s APO regarding volume and hectares to be felled. These plans determine the species to be grown in the future and will determine the markets that can be supplied. The company is controlled by the age class, volume and species mix that can be felled.
� Projected age class distribution details.
� Thirty year planting plan.
� Thirty year harvesting plan.
� Compartment details of total Forest Management Unit (FMU).
� Summary of species planted to FMU.
� APO for all Areas.
� APO for all Business Units.
� Current and future products and utilization are set out in the thirty year plan and APO
3.4 Harvest and regeneration
Silviculture of commercial plantations deals with the establishment, tending, development, protection and re-establishment of plantations. Good silviculture is part science, part business, and part art. The “art” of silviculture is the imaginative skill a Forester must use to interpret scientific knowledge in a particular situation and necessitates finding a suitable set of prescriptions to apply in each situation (Theron, 2000).
Defining standard practices for the broad range of sites across our landholdings may appear to be naïve. Regrettably, audits have shown that current best practices are not consistently applied and that in many instances we are in fact doing the wrong things. This manual therefore serves as a single source reference guide to Foresters and Contractors to ensure that recommended standard silvicultural practices are applied.
The Silviculture Procedure Manual covers the following topics:
� Establishment
� Species Selection
� Planting Stock Quality
� Rotations
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� Spacing
� Regimes
� Stump Treatment
� Slash Management
� Land Preparation Policy
� Planting, Blanking and Watering
� Fertilizing
� Coppice Reduction
� Weed Control
� Pruning
� Wattle Spacing
� Fire Protection - Tracer Belts
� Annexure 1 - Silviculture Glossary
� Annexure 2 - Assessment Procedure
� Annexure 3 - Insects and Diseases
� Annexure 4 - Chemical Code of Practice
All policies and procedures pertaining to harvesting in Mondi are contained in the Harvesting Procedures Manual (HPM).The Harvesting Procedures Manual (HPM) is part of MBPSA, MSN and SQF self assessment programme. Legal and company standards and procedures must be available to, and understood by, the relevant company employees and contractors. These include any MBPSA, MSN or SQF Policies and Procedures, Legal Acts and Regulations, South African Guidelines for Forest Engineering Practices and other FESA or ICFR Forest Engineering Programme (ICFR-FEP), and industry safety and best operating practice manuals.
The HPM is to be implemented to ensure that all levels of planning and support are in place and correct harvesting procedures and standards are followed. Where required, corrective actions are to be recorded, addressed and closed out according to the MBPSA, MSN or SQF corrective action request process.
The guidelines and regulations in the HPM are based on minimum requirements and recommendations. It remains the responsibility of the Harvesting Manager and Contractor to ensure that all harvesting operations are conducted in a legal and environmentally acceptable manner. It is the responsibility of the Harvesting Manager to ensure that all data and information is correct and that the data base is kept up to date.
Recently Mondi has started with mechanising harvesting operations. This has been done after consultation with stakeholders, and full socio economic studies, as well as environmental impact studies. Mechanising can varies from partly mechanising certain activities to full mechanised operations.
3.5 Monitoring processes
Mondi Business Paper operates within a clear corporate governance framework which encompasses corporate objectives and strategies, corporate values, business planning, audit committees and control structures which include risk management and a performance management system. Various management systems, the most important of which are detailed below, have been developed to facilitate continuous improvement in the areas of safety, health, environment, social responsibility and economic performance.
Monitoring by a system of audits is carried out to facilitate management across all activities. These audits examine whether activities are being carried out according to laid down practices and procedures.
Commercial data is captured on a continuous basis and information fed into management planning. Monitoring of ecological and environmental issues consists of various different actions from own monitoring observations to monitoring done by external specialists or specially interested groups.
Water monitoring is done on all the catchments on Mondi’s property and monitoring sites are established.
� Crocodile catchment - 9 monitoring sites
� Komati catchment - 15 monitoring sites
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� Umgeni catchment - 10 monitoring sites
� Umkomaas catchment -14 monitoring sites
� St Lucia Drainage Region -26 monitoring sites
� Great Usutu catchment - 29 monitoring sites
� Phongolo catchment - 19 monitoring sites
Documentation pertaining to specific studies is available at the relevant Area office.
4. SOCIO-ECONOMIC AND ENVIRONMENTAL CONTEXT
4.1 Social aspects
Number of own workers 258
Number of contract workers 10 741
Minimum daily wage for agricultural/forestry workers R 41.32
Infant mortality rates (under 5 years) 4.3 %
Proportion of workers employed from the local population (%) 90 %
The socio-economic impact of a business, which has a natural resource base in mainly rural areas, with long investment horizons is recognised as a critical element in sustainable development. Social development is integrated into all business strategies to ensure that effective relationships are developed with all community stakeholders. Mondi endeavour to engage constructively with the community stakeholders adjoining plantations to improve development opportunities that flow from operations in the communities. The SEAT (Social Economic Assessment Toolbox) process equips managers to understand the dynamics of social impacts, and having measured them, to manage them creatively. A Community Engagement Facilitator (CEF) is employed in each Business Unit to develop effective communications with community stakeholders.
Cultures / Social Groups
KwaZulu Natal (Ngome) -Zulu
Mpumalanga (Highveld - East) -Swazi , Ndebele, Ndebele
Social Problems
Poverty -Job creation
HIV/Aids -Awareness, wellness
Women and Child Abuse -Awareness
Literacy -Abet
Education -Facilities
Good progress has already been made in terms of:
� Maximising local job opportunities through forestry contractors.
� Catalysing community partnerships e.g. no fire bonus, grazing, mushrooms, vegetable gardens, and honey production.
� Small business development e.g. forest contractors.
� More traditional social investment activities e.g. study grants, support for schools etc.
Training and staff development programmes are managed by the Human Resources Department and all specialized and tertiary training is overseen by suitably qualified Management Specialists. All information pertaining to training in forestry can be obtained from the Mondi Training Manager.
4.2 Environmental aspects
The principle environmental impact in the SA forestry sector is alien invasive plant species in the non commercial and commercial compartments. Historical budget cuts in conservation programmes, turnover of staff, changing weed control plans, lack of dedicated teams for alien plant control and lack
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of follow-up (or too long intervals between follow-up) of initial control activities are some of the biggest problems in the South African forestry industry in terms of weed control, and Mondi is no exception. Mondi has developed a good management plan to manage this problem and bring it under control within the next few years. It has become a controversial issue to be certified with such prevailing problems. Mondi has therefore commit themselves and also provide the financial provision to overcome the problem.
Numerous sites of Rare, Threatened or Endangered species (RTE), and especially plant species have been identified by different consultants – there are detailed reports available and such sites are monitored according to schedules to ensure optimum conservation and protection of the sites and relevant species.
All site disturbing activities are assessed prior to any disturbance taking place by the completion of an internal EIA document identifying potential impacts and highlighting possible mitigation measures. Environmental monitoring of grasslands, water quality and riparian zones, wetland delineation and High Conservation Value Forests takes place annually.
4.3 Administration, Legislation and Guidelines.
Forestry in South Africa is practiced in the free market. It is regulated by government with regard to the areas available for planting. Permits are issued by the Department of Water Affairs and Forestry for all afforestation projects.
The following table lists the key national legislation, regulations, guidelines and codes of best practice that are relevant to forestry in the commercial, environmental and social sectors. This list does not purport to be comprehensive, but indicates information that is key to the forestry sector.
Legislation and regulation Notes
Constitution of South Africa (1996)
Advertising On Roads And Ribbon Development Act (No. 21 of 1940)
Agricultural Pests Act (No. 39 of 1983)
. Animal Disease Act (No. 35 of 1984)
Conservation of Agricultural Resources Act (No. 43 of 1983), as amended 2001.
Environment Conservation Act (No. 73 of 1989)
Fencing Act (No. 31 of 1963)
Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act (No. 36 of 1947).
Hazardous Substances Act (No. 15 of 1973)
Minerals and Petroleum Resources Development Act (No. 28 of 2002)
National Building Regulations and Building Standards (No. 103 of 1977)
National Environmental Management Act (No. 107 of 1998)
National Environmental Management: Air Quality Act (2004)
National Environmental Management: Biodiversity Act (No. 10 of 2004)
National Environmental Management: Protected Areas Act (No. 57 of 2003)
National Forests Act (No. 84 of 1998)
National Road Traffic Amendment Act [No. 21 of 1999]
National Veld and Forest Fire Act (No. 101 of 1998)
National Water Act (No. 36 of 1998)
Plant Breeders Rights Act (No. 15 of 1976)
Plant Improvement Act (No. 53 of 1976)
National Railway Safety Regulations Act no 16 of 2002
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Cultural and social:
Animal Protection Act (No. 71 of 1962)
Basic Conditions of Employment Act (No. 75 of 1997)
Communal Land Rights Act (No. 11 of 2004)
Compensation for Occupational Injuries and Diseases Act (No. 130 of 1993)
Employment Equity Act (No. 55 of 1998)
Extension of Security of Tenure Act (No. 67 of 1997)
Labour Relations Act (No. 66 of 1995) and Labour Relations Amendment Act
of 1997.
Land Reform Act (No. 3 of 1996)
National Heritage Resources Act (No. 25 of 1999)
Occupational Health and Safety Act (No. 85 of 1993)
Prevention of Illegal Eviction from and Unlawful occupation of Land Act (No. 19 of 1998)
Protection of Informal land Rights Act (No. 31 of 1996)
Restitution of Land Rights Act (No. 22 of 1994)
Skills Development Act (No. 97 of 1998)
Unemployment Insurance Act (No. 30 of 1966)
Skills Development Levies Act (No. 9 of 1999)
Security Officer’s Amendment Act (1997
B. REGULATIONS PERTINENT TO FORESTRY RELATED TO AND EMERGING FROM NATIONAL LEGISLATION AND OTHER
NATIONAL ATLASES:
Barnes, K. N. (ed.) 2000. The Eskom Red Data Book of Birds of South
Africa, Lesotho and Swaziland. BirdLife South Africa, Johannesburg - ISBN
number 0-620-25499-8
Bromilow, C. 2001. Problem Plants of South Africa. A guide to the
identification and control of more than 300 invasive plants and other weeds.
Briza Publications.
Draft Lists of Threatened and Protected Species issued in terms of Section
56 (1) of the National Environmental Management: Biodiversity Act, 2004.
Friedmann Y. and Daly B, (editors) 2004. Red Data Book of the Mammals of
South Africa: A Conservation Assessment: CBSG Southern Africa,
Conservation Breeding Specialist Group (SSC/IUCN), Endangered Wildlife
Trust. South Africa - ISBN number 0-620-32017-6
Golding, J. (ed) 2002. Southern African Plant Red Data Lists. South African
Botanical Diversity Network report No 14.
Henderson, L. 2001. Alien Weeds and Invasive Plants: A complete guide to
declared weeds and invaders in South Africa. Plant Protection Research
Institute handbook No12, Agricultural Research Council.
Hilton-Taylor, C. 1996. Red Data list of Southern African Plants. NBI.
C. INTERNATIONAL AGREEMENTS PERTINENT TO FORESTRY
South Africa is a signatory to the following, however, current South African
legislation encapsulates the obligations of these international agreements:
Convention on Biological Diversity
Convention on the International Trade in Endangered Species (CITES)
International Labour Organisation (ILO)
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Guidelines and Codes of Best Practice Notes
Mondi’s own set of Best operating Practices.
Local standards have also been introduced by the forestry industry.
Nationally or Industry endorsed local standards (Best Operating Practices)
are listed below:
� A practical field procedure for identification and delineation of wetlands and
� riparian areas. Final draft: February 2003. Department of Water Affairs and
� Forestry.
� Best Management Practices for Preventing and Controlling Invasive Alien
� Species. Symposium Proceedings, The Working for Water Programme, 2224 February 2000.
� Engelbrecht, G. v. R. and Warkotsch, P.W. 1994. Chute Operating Manual
� – FESA Chute Project Group
� Environmental Guidelines for Commercial Forestry Plantations in South
� Africa (Forestry South Africa, Second Edition, August 2002).
� Guidelines for Forest Engineering Practices in South Africa. Forest
� Engineering Working Group of South Africa (FESA), May 1999.
� Protective Device for users of sharp bladed tools: Requirements for leg
� protectors. FESA standard FESA 001:1998.
� Relevant ICFR Bulletins and handbook series.
� Responsible Use Guide. AVCASA Crop protection and Animal Health
� Association, October 2001.
� South African Forestry Handbook, Volumes 1 & 2. The South African Institute
� of Forestry, 2000.
� The Private Security Industry Regulatory Authority (SIRA) Regulations.
� The South African Cable-yarding Safety and Operating handbook (FESA).
� The South African Chainsaw Safety and Operating handbook January 2000.
� (FESA).
� The South African Forestry Road Handbook. FESA Working Group, August
5. CHANGES IN MANAGEMENT, HARVESTING, SILVICULTURE AND MONITORING
The following table shows significant changes that took place in the management, monitoring, harvesting and regeneration practices of the certificate holder over the certificate period.
Description of Change Notes
SURVEILLANCE 1
Responsibility for FSC was brought into each managers performance and not separate in an environmental division anymore.
The company’s name changed and is reflected above.
The CEO is replaced and several portfolio changes were made to top management.
SURVEILLANCE 2
Tony Bold has taken over the role of the FSC Representative.
Proposed sale of the North Business Unit:
While the Mondi Forest Management Unit remains as it is for this surveillance, Mondi advised SGS that the asset(s) in the Business Unit North (Nelspruit) are in the process of
The rationale for the disposal is as follows:
The land claims as they were, posed a risk to the fibre sustainability model for Mondi mills,
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Description of Change Notes
being disposed by the end of the 2009, and that will lead to a reduction in the FMU and the new FMU will stand at 241,713.7 hectares.
Based on these developments explained on the right, the Mondi Board authorized the sale of the BU North as a “going concern” to an industry player or players.
however, the Mondi Land division made a breakthrough in terms of a model for continuing relationships and supply arrangements with claimant communities ensuring reasonable security of fibre supply from claimed properties into the future. This model was later adopted by the industry and the Land claims commissioner for use in other similar claims. This meant that the BU North properties no longer needed to be kept as the back up fibre supply.
BU North plantations in the vicinity of Nelspruit have been an outer perimeter supplier (Zone 4 and 5) of pulp timber to the Mondi Mill at Richards Bay with a long and expensive rail connection. Mondi’s preferred Zones are Zone 1, 2 and 3 as determined in their land ownership strategy. During the rate negotiations with Spoornet for the 2009 rail tariff increases, the Piet Retief line, which carries the bulk of the Mondi rail supply of timber, was afforded a reasonable increase while the balance from BU North was allocated a rail tariff increase in excess of 30% per tonne. This resulted in BU North rethinking their business strategy to focus on sales to local markets for all products to try to make a profit which could then be used to procure substitute volumes of timber for the Richards Bay mill within the local supply perimeter.
Mechanisation of harvesting and pitting:
Mondi has embarked on a mechanisation strategy to meet the goals stated on the right. In carrying out the strategy, Mondi have stated that the following factors will be taken into consideration:
1. Appropriate systems will be sought to meet local specific conditions and requirements.
2. Impacts will be anticipated and researched to find locally equitable solutions. Appropriate mitigating measures will be implemented as the strategy is enacted.
3. Labour will be offered the options of transfer to other jobs particularly in Silviculture or compensated accordingly.
4. Existing contracted businesses in the affected focus areas will be evaluated as potential mechanisation partners in terms of their business ability and their BBEEE status or potential.
5. Where possible, in both the business and labour considerations, natural attrition may be a prioritised method of effecting the desired change in numbers.
The following statement was made by Mondi Limited:
Eucalyptus plantation harvesting in South Africa is currently predominantly done using the Motor-manual system. This involves the use of manual labour to fell trees, remove the bark, stack the logs and in some cases load the logs onto transport units. The manual operations have been deemed as putting excessive strain on the human form and as such they should be reduced and where possible replaced by labour saving mechanical systems.
Ultimately, mechanisation of strenuous human jobs must lead to respect for human dignity and improved sustainability in the face of global competition.
SURVEILLANCE 3
The sale of the Business Unit North to bedrock was finalised in August 2010 and the current land area is now 234153 ha.
Aspects of this report have been updated with the sale of the North BU, but the more detailed changes such as the summary of vegetation types, soil types etc will need to be changed at the re-assessment of 2012 to exclude the Mpumalanga Lowveld areas, although the
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Description of Change Notes
Highveld areas are still in.
SURVEILLANCE 4
6. PREPARATION FOR THE EVALUATION
6.1 Schedule
The Evaluation was preceded by a previous cycle of certification by SGS QUALIFOR during 2002 – 2007. Stakeholders were identified and informed of the audit more than six weeks prior to the audit. . Advertisements were also placed in local newspapers. Responses were faxed, mailed, emailed and by phone. All these are summarised in par 13 of this report. The audit was scheduled for the week 3 – 7 September 2007 and commenced on time. An official complaint was then received and an additional auditor tasked to do assist in the CoC part of the audit.
6.2 Team
The table below shows the team that conducted the main evaluation and the independent specialist(s) that were selected to review the main evaluation report before certification is considered.
Evaluation Team Notes
Team Leader Has a Diploma in forestry, Higher diploma in Conservation and a Masters degree in Environmental Management. He has 20 years experience in forestry and conservation and 6 years experience in Environmental Management internationally. 67 days FSC auditing, speaks local language Afrikaans and English.
Local Specialist Local Specialist Has a BLC. LLB. LLM (Human Rights and Democratisation in Africa) degrees and holds a Diploma in Alternative Dispute Resolution. He is currently completing a LLD in Environmental Law and has undertaken numerous short courses including environmental, social and FSC auditing. He has approximately 8 years relevant experience to environmental law and human rights issues internationally, regionally (Africa) and nationally.
6.3 Checklist Preparation
A checklist was prepared that consisted of the documents listed below. This checklist was prepared by adapting the QUALIFOR generic forest management checklist.
This adaptation included canvassing comments from stakeholders 4 weeks before the field evaluation. Comments were received from 16 number of stakeholders that included 8 ENGOs, 2 Government Departments and 0 Academics. A copy of this checklist is available on the SGS Qualifor website, www.sgs.com/forestry.
Standard Used in Evaluation Effective Date Version Nr Changes to Standard
SGS Qualifor: Generic Forest Management Standard (AD33-ZA-02) adapted for South Africa
Sept. 2005 02 None
2010 3rd Surveillance Visit:
SGS Qualifor New Generic Forest Management Standard AD33-ZA-04 adapted for South Africa.
29 March 2010
04 New generic indicator 5.5.3 has been included as well as reference to WI 16 in terms of Pesticide use. The adaptations for South Africa have also been revised and are included in the 2010 version. This has been incorporated into the AD36B section of the report.
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6.4 Stakeholder notification
A wide range of stakeholders were contacted 6 weeks before the planned evaluation to inform them of the evaluation and ask for their views on relevant forest management issues, These included environmental interest groups, local government agencies and forestry authorities, forest user groups, and workers’ unions. The full list of stakeholders that were contacted is available from SGS. Responses received and comments from interviews are recorded under paragraph 13 of this Public Summary.
7. THE EVALUATION
The Main Evaluation was conducted in the steps outlined below.
7.1 Opening meeting
An opening meeting was held at Mondi Head Office Pietermaritzburg. The scope of the evaluation was explained and schedules were determined. Record was kept of all persons that attended this meeting.
7.2 Document review
A review of the main forest management documentation was conducted to evaluate the adequacy of coverage of the QUALIFOR Programme requirements. This involved examination of policies, management plans, systems, procedures, instructions and controls.
7.3 Sampling and Evaluation Approach
A detailed record of the following is available in section B of the evaluation report. This section does not form part of the public summary, but includes information on:
� Sampling methodology and rationale;
� FMUs included in the sample;
� Sites visited during the field evaluation; and
� Man-day allocation.
Mondi Forests is divided into three regions. North, Central and South. Stakeholder consultation started approximately six weeks prior to the assessment and inputs were received throughout until the assessment dates. The Sampling included the head office in Pietermaritzburg because many of the strategic planning and specialists are situated in head office. Site visit records of the past was used to select sites that was not visited during third party audits in recent years. Sites was also selected to get a geographical representation over the three regions. A particular stakeholder complaint was received in the Melmoth area that required investigation. The social specialist who is also a legal specialist spend a day infield with the complainant. He was accompanied by a hydrologist that was assigned to the project for the investigation. A Chain of Custody auditor was assigned to do a dedicated CoC audit on the depots in the Vryheid and Piet Retief area. Two days were spend doing the CoC. Due to the vast spread out area of the company it required substantial travelling. Travelling usually took place after hours. Principles and criteria were checked randomly at all the sites, covering the whole standard over the entire area covered and not covering each criterion at each site. Unless it was an outstanding issue, problem situations were assessed at more than one area to establish the consistency of the observation. Prior knowledge of the area helped in selecting criteria more crucial to specific areas. E.g. Lowveld and midland areas are more prone to weed infestation than the highveld areas, and areas around Piet Retief are known for social conflict.
7.4 Field assessments
Field assessments aimed to determine how closely activities in the field complied with documented management systems and QUALIFOR Programme requirements. Interviews with staff, operators and contractors were conducted to determine their familiarity with and their application of policies, procedures and practices that are relevant to their activities. A carefully selected sample of sites was visited to evaluate whether practices met the required performance levels.
7.5 Stakeholder interviews
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Meetings or telephone interviews were held with stakeholders as determined by the responses to notification letters and SGS discretion as to key stakeholders that should be interviewed. These aimed to:
� clarify any issues raised and the company’s responses to them;
� obtain additional information where necessary; and
� obtain the views of key stakeholders that did not respond to the written invitation sent out before the evaluation.
Nr of Stakeholders contacted
Nr of Interviews with
NGOs Government Other
MAIN EVALUATION
203
It was also advertised in the media.
2 2 5
SURVEILLANCE 1
15 1 4
SURVEILLANCE 2
1 5
SURVEILLANCE 3
12 12
SURVEILLANCE 4
Responses received and comments from interviews are recorded under paragraph 13 of this Public Summary.
7.6 Summing up and closing meeting
At the conclusion of the field evaluation, findings were presented to company management at a closing meeting. Any areas of non-conformance with the QUALIFOR Programme were raised as one of two types of Corrective Action Request (CAR):
� Major CARs - which must be addressed and re-assessed before certification can proceed
� Minor CARs - which do not preclude certification, but must be addressed within an agreed time frame, and will be checked at the first surveillance visit
A record was kept of persons that attended this meeting.
8. EVALUATION RESULTS
Detailed evaluation findings are included in Section B of the evaluation report. This does not form part of the public summary. For each QUALIFOR requirement, these show the related findings, and any observations or corrective actions raised. The main issues are discussed below.
8.1 Findings related to the general QUALIFOR Programme
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Criterion 1.1 Respect for national and local laws and administrative requirements
Strengths
Weaknesses Evidence of compliance with laws and regulations regarding planting permits could not be provided. Related Major CAR 06 was raised.
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In addition, contractors do not comply with the full sectoral determination for the forestry sector. Infringements include the payslips that do not meet minimum requirements. CAR 7 was raised in this regard.
Compliance At management level, a general awareness exists. Appropriate personnel have access to relevant legislation, code of practices and BOPs All managers interviewed at Richmond, Melmoth .and Iswepe had a good understanding of applicable legislation and BOPs
During the closing of findings audit in October, progress was made with comparing the Mondi database with those of DWAF. The mentioned farms forms part of the database and is incorporated in the process. DWAF has given official confirmation that an investigation in illegal plantings is underway and that Mondi should not take any action unless directed by the department. Official letter and various email correspondence was available. Due to the nature of this CAR, the issue cannot be not closed completely in such short time, but the progress made is sufficient to reduce it to minor status.
Major CAR 06 was closed and replaced with CAR 18.
Criterion 1.2 Payment of legally prescribed fees, royalties, taxes and other charges
Strengths
Weaknesses
Compliance Relevant levies and taxes are paid at company level. Relevant taxes, levies and payments of contractors was in order.
Adequate provision is made in the Mondi budget to cover such expenses in future. It forms a permanent cost item on the budget.
Criterion 1.3 Respect for provisions of international agreements
Strengths
Weaknesses
Compliance Provisions have been incorporated into South Africa’s national legislation, in particular the provisions of the Biodiversity Act. There exists an awareness of the relevant provisions at appropriate levels (i.e. environmental officers). Staff has access to relevant provisions through the services of a consultant.
ILO requirements have been incorporated into national legislation. Key staff has good understanding of ILO requirements. These have also been incorporated in to company reporting procedures (i.e. Occupational Health). In addition, at labour level both company and contractors sampled displayed a sound adherence to the relevant labour legislation.
Forest operations comply with national environmental legislation that encapsulates international conventions
Criterion 1.4 Conflicts between laws and regulations, and the FSC P&C
Strengths
Weaknesses
Compliance No conflicting legislation were identified. Some issues, like the land claim issues is time consuming and may affect the continuous compliance over the long term
Criterion 1.5 Protection of forests from illegal activities
Strengths
Weaknesses
Compliance Measures to identify, monitor and control illegal activities and harvesting are in place. Two control mechanisms are in place. First a permit system for i.e. the collection of firewood, cattle grazing, and honey collection. Another mechanism is a guard service (contractor) who patrols plantations. Reports are submitted on a monthly basis.
Criterion 1.6 Demonstration of a long-term commitment to the FSC P&C
Strengths
Weaknesses Major CAR 11 was raised at Criterion level for the lack of long term commitment referring to the
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high number of CARS that was raised.
Compliance A public policy is in place and available. This can, as example, be found on the Mondi website & management plan.
Progress October 2007:
Continuous compliance to FSC was demonstrated during the closeout of findings audit that was done 30 – 31 October in various ways:
� High profile management involvement and buy-in in the process of complying and addressing the CARs. Senior management took the lead in guiding and controlling the process.
� Official statements from the CEO and top management confirming continued commitment and the importance of compliance.
� The restructuring process that had a crippling effect on the company is almost complete and there is evidence of renewed motivation in operations. It resulted that FSC related issues are integrated into operational best operating practices and controlled through the optimization department with authority to act.
� Dedicated teams were formed to investigate each of the CARs and establish the root cause that led to the CAR. The extent to which Mondi succeeded in these investigations were commendable.
� Action plans were developed for all the CARs. It was developed to address the cause of the CAR with widespread repercussions. Action plans were immediately implemented and progress were made on all the CARs by the time of the closeout audit. Action plans for CARs were implemented across Mondi, irrespective of where it was raised. Report back was controlled and progress monitored.
� Resources were provided additional to the budget and commitment from top management was given for future budgets and resource allocation.
CAR 11 was closed.
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Criterion 2.1 Demonstration of land tenure and forest use rights
Strengths
Weaknesses
Compliance Mondi has ownership and title deed for its farms. Other farms are leased and lease agreements are signed. Commitment exists for more than 1 rotation cycle and polices and procedures indicate a long term commitment to forest management.
Criterion 2.2 Local communities’ legal or customary tenure or use rights
Strengths
Weaknesses
Compliance There are no legal or customary tenure rights on the planted areas. There are villages on some of the FMUs where the people have the right to stay in those villages. Land claims are pending against FMU’s on most Business Units. These claims are properly documented and the progress monitored.
The forestry operations are not affected by the tenure rights. Land claims that are in the process first have to go through the legal processes before any new agreements can be negotiated.
Criterion 2.3 Disputes over tenure claims and use rights
Strengths
Weaknesses
Compliance Various land claims are pending against Mondi. Comprehensive records are kept on the claims including status, progress and action to be taken. There are farms in different stages of the process. Five farms in Northern Natal is in a validation stage, five other in a negotiation stage and twelve more to be gazetted. Mondi’s policy is to keep good relations and to secure fibre for the mills.
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All land claims handled by Strategic Projects and Investment division in Pietermaritzburg.
There were no disputes that prevent the company from being certified.
It is Mondi’s policy to maintain good relations with the relevant stakeholders throughout the process and to follow the legal framework established for the purpose.
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Criterion 3.1 Indigenous peoples’ control of forest management
Strengths
Weaknesses
Compliance N/A
Criterion 3.2 Maintenance of indigenous peoples’ resources or tenure rights
Strengths
Weaknesses
Compliance N/A
Criterion 3.3 Protection of sites of special cultural, ecological, economic or religious significance to indigenous peoples
Strengths
Weaknesses
Compliance Mondi has identified a number of sites with cultural, historical, ecological, economic or religious value. Sites are identified and described in co-operation with relevant stakeholders. Depending on the nature of the ASI’s there are management plans to manage them. ASI’s forms part of the working plans of the specific compartment. It is mapped and indicated to contractors when ever operations are taking place in that compartment.
Criterion 3.4 Compensation of indigenous peoples for the application of their traditional knowledge
Strengths
Weaknesses
Compliance N/A
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Criterion 4.1 Employment, training, and other services for local communities
Strengths
Weaknesses
Compliance Contractors as well as the company give preference to people from local communities for employment. Tenders for contracts are advertised in local newspapers. Local communities and contractors are being used in operations.
The company provides internal and external training through i.e. guidance/career centre situated at the Central Business Unit. Bursary schemes are available to potential foresters. Internal training starts at basic level through i.e. ABET program to tertiary level through bursaries at i.e. Saasveld. Support is provided for local infrastructure through a range of social projects. This was specifically considered within the Piet Retief Region.
Foresters are all either Saasveld (technicon) or Stellenbosch (university) graduates.
It was observed that the average age of all the workers employed by the contractors is relatively high. It was argued that young people are just not interested in this kind of forestry labour anymore.
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Criterion 4.2 Compliance with health and safety regulations
Strengths
Weaknesses A CAR 13 was raised on the compliance with safety regulations. Gas cylinders were not stored correctly at Iswepe, Smooth tyre on truck that transport people at Satico, MSDS sheets for chemicals not available. At Satico, village visited was in below minimum condition. Inadequate sanitation, housing and waste management practises observed. It is noted that a program has/will be established to reform the accommodation. It is, however, in planning phase and not at implementation stage. Related CAR 09 was raised.
Although Mondi has an appropriate HIV/Aids Strategy in place it only applies to workers and its true impacts are not felt by the majority of the workforce that impact on the company’s operations. This is especially the case at the Highveld were the infection rate is high. Related observation 3 is raised
Compliance Forest managers are aware of the laws and regulations covering Safety. A dedicated staff component deals with Health & Safety. Appropriate risk assessments are done and reporting functions are implemented in order to ensure compliance. Safety and Health policy documentation exist at company level.
Progress October 2007: Safety plans were reinforced throughout all business units for all basic procedures. The mentioned issues were addressed.
BOP for the storage and handling of gas cylinders developed and circulated to all regions.
MSDS sheets were available for all chemicals in the store at Satico.
All vehicles found on the terrain and on site on Satico were compliant.
CAR 13 closed, but CAR 9 remains open for continuous monitoring.
Criterion 4.3 Workers’ rights to organise and negotiate with employers
Strengths
Weaknesses
Compliance Most of the workforce forms part of contractor employments. Although unions are not common, workers have the full right to join unions.
It was found that in Northern Natal labour were reluctant to join unions despite the freedom to do so. Negotiations are still taking place with leading unions regardless of if the workers belong to them or not.
Criterion 4.4 Social impact evaluations and consultation
Strengths
Weaknesses CAR 8 was raised for a prolonged stakeholder issue that was not resolved.
Compliance The implementation of harvesting mechanisation into the operations was preceded by formal impact assessment including social impact studies. The process followed was quite simple, although the final result becomes substantial and complex. The process included the gathering and sharing of information, stakeholder input, and evaluation of alternatives and mitigation of impacts.
Stakeholder lists are available and maintained with regular engagement with stakeholders. Mondi maintains a record of stakeholders through its Socio Economic Assessment Toolbox system. This provides a system for data collection on stakeholders and enable Community Facilitation Officers to build community profiles.
Records of community meetings and SHEAR requests are maintained at the FMUs.
Progress October 2007: SHEAR process revised to identify the level of management to become involved at what stage. There is not sufficient data for this process to evaluate corrective action in terms of the CAR and CAR 08 will remain open.
Criterion 4.5 Resolution of grievances and settlement of compensation claims
Strengths
Weaknesses
Compliance Mondi has ongoing consultation at community level in a proactive attempt to deal with i.e. complaints. Formal complaints are registered and dealt with at company level. Attempts are
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made to resolve issues through agreement and consent. Conflict situations such as the illegal grazing of cattle on the estates are treated with the utmost care. Stakeholders are consulted through village committee meetings and records are maintained of all such meetings.
Mondi has HR procedures defining mechanisms for resolving internal disputes. At contractor level the records of Merlin (Nelspruit) was verified.
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Criterion 5.1 Economic viability taking full environmental, social, and operational costs into account
Strengths
Weaknesses CAR 5 was raised because available forest land and the potential annual yield that was not optimally used. Burnt compartments at Hazyview still have patches of dead timber from the 2005 fire standing. These compartments are not yet replanted and therefore not productive.
Compliance Mondi is a paper manufacturer and their plantations are run on a short rotation. Optimization is achieved through continuous silviculture development to achieve best results. This is achieved from tree breeding in the nurseries to management of sites.
Budgets are linked to the APO to ensure money is spent against that specific cost item it is budgeted to. Each area manager is responsible for his own budget and formally applies for a budget for the area under his control. Social and Environmental issues are budgeted under that specific cost item for that area.
The company views its investment in more than just what is directly reflected in budgets against certain projects. It allows for multi resource use and includes the whole range of forest cervices. The Delineation and rehabilitation programs is also seen as investments in the ecological productivity of the forests. Research is done on RTE species and known locations are mapped. Mondi has also invest in the sponsoring of the Mondi Wetland program
A specific action plan for the recovery of the burnt area was prepared. All areas and methods for recovery were included. It was based on the shortest recovery time to get the land back in production with a weekly report back built into it. This weekly controls are also applicable to contractors. An area of 1312 ha was involved in the fire and it will be 90 % back in production by March 2008. Action plan was already implemented and substantial progress was made by October 2007. CAR 5 is closed.
Criterion 5.2 Optimal use and local processing of forest products
Strengths
Weaknesses
Compliance The company’s main objectives are to produce timber and any other benefit that comes from the forest is regarded as optional. Within the short rotation that Mondi is using, they are constantly looking for the best production on each site . All their timber is from managed plantations and therefore yield is regulated. Management is promoting and will actively help other enterprises interested in non timber products when not affecting the core business.
Timber is produced for the manufacturing of paper. There is very little product available that is not optimally used by the company.
Mushrooms, grazing, honey thatch and such non-timber resources are used by local markets and are allowed on a controlled basis.
Criterion 5.3 Waste minimisation and avoidance of damage to forest resources
Strengths
Weaknesses Various depots as well as road sides had old and decaying timber lying around. CAR 10 was raised in this regard.
Compliance Due to the short rotation, trees are cut when still fairly small. There is little risk of log damage as a result of harvesting techniques. Extraction is done on the litter mat that reduces the effect of site hardening due to harvesting machines. Timber produced for the paper industry and optimally used to smaller diameters than normal sawmills. This results that less timber goes to waste.
Harvesting sites and post harvest compartments were clean with no processed timber left
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behind in field. Transport is usually outsourced and problems occur when harvested timber is not always removed from road side and landings. During October audit all this timber was removed by various smaller markets.
Criterion 5.4 Forest management and the local economy
Strengths
Weaknesses
Compliance Mondi’s plantations are optimally grown for the production of timber for the paper mill. All plantable areas are therefore planted with timber for a specific purpose. Any additional non-timber products are optional and are usually taken under contract by other companies or individuals. Mondi themselves are not in the market for utilizing any of its non product markets. Mondi’s plantations are extensively used by local communities for grazing of cattle and in some areas for the collection of mushrooms. In the Piet Retief area Mondi has embarked on an extensive program to get all the cattle branded that utilises the plantation areas. In the Hazyview area a multi million business are made from locals growing nuts in the areas where the trees are still small.
Criterion 5.5 Maintenance of the value of forest services and resources
Strengths
Weaknesses
Compliance Managers described their forest resources as being multiple resource use. Apart from water that flow from the catchment it also provides grazing and thatch. Honey is collected and in certain areas even farmed. Mushrooms and nuts are harvested on large parts that are accessible to locals.
Criterion 5.6 Harvest levels
Strengths
Weaknesses
Compliance All data on forest growth is sent to the planning section. Pietermaritzburg. Data is kept on the Microforest program and information on all compartments is readily available. Control checks are done internally to verify that the data are correctly collected. The annual allowable cut is calculated for each plantation to prevent over cutting. Age class distributions are available and each area manager has this information readily available. Sustainability is achieved through ensuring that there is always a sustainable number of compartments to harvest.
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Criterion 6.1 Environmental impacts evaluation
Strengths
Weaknesses
Compliance The company has a system in place to evaluate the environmental impacts of all new developments. They have recently upgraded the system to incorporate changes in legislation with the new EIA regulations in their internal system. New forms are developed and in use.
Impact assessments were done according to the prescribed format throughout the districts
Operations are carried out according to the assessments that were done. When operations are outsourced potential impacts are included in the contract with the contractor and the forester remains ultimately responsible to ensure contract issues are adhered to.
Criterion 6.2 Protection of rare, threatened and endangered species
Strengths
Weaknesses After two cycles of certification, Mondi still struggles to get the weeds in the conservation zones under control. CAR 2 was raised for alien weeds that are not adequately controlled.
Compliance Mondi has engaged with several organisations in order to map sensitive areas and to predict conservation values of their FMUs. They uses the SANBI vegetation maps with overlays of
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Catchment Sensitivity maps from DWAF, The Important Landscape map of KZN and Important ecosystems & Vegetation community maps of the province to determine these sensitive areas. The C-plan maps of both Mpumalanga and KZN are also incorporated. Mondi has made a special effort to get all contractors involved in rare species by an awareness program. There is also close cooperation between Mondi and certain working groups that specialize in particular species for their protection.
Maps are prepared by the planning section in Pietermaritzburg and are regularly updated for all FMUs. Sophisticated GPS systems and drawing equipment is available and maps are clear and accurate. Field staff has access to this service. Conservation zones are clearly indicated. Operational plans are included in the APO and budgeted accordingly.
Criterion 6.3 Maintenance of ecological functions and values
Strengths
Weaknesses Mondi is one of the large companies practising slash burning and the sylvilcultural system lacks a monitoring guideline with regards to post-burn monitoring on the effect of fire. Major CAR 1 was raised.
CAR 15 was raised for the lack of action plan on the restoration of old mining sites in Mpumalanga.
Compliance The company has identified the broad natural vegetation types in which it operates and it is described in the management plan. Each vegetation type has its specific characteristics and ecological functions regarding diversity and conservation requirements described. Conservation status of rare species is known, conservation zones are identified and mapped. A company wide survey to establish the current state of weed infestation was done to enable them to set a strategy and objectives with definite targets.
Because of the short rotation, sylvilcultural actions around site – specie matching is important to gain maximum yield. In this field Mondi has featured well and their sylvilcultural management systems are appropriate to the scale of their operations. During October 2007 The Mondi “Sylvilcultural Precision Tool” is updated and includes soil mapping and a fire sensitive algorithms that can predetermine sites sensitive to fire and exclude them from slash burning and include criteria to monitor controlled fires. Major CAR 1 was closed, but CAR 15 remains open.
Criterion 6.4 Protection of representative samples of existing ecosystems
Strengths
Weaknesses
Compliance All areas that are not planted falls within the conservation zones and are managed under the open area management plan. These areas are indicated on maps and managed according to the prescriptions for that representative area. This could include forests, grasslands, wetlands or what ever the site represent
Criterion 6.5 Protection against damage to soils, residual forest and water resources during operations
Strengths
Weaknesses
Compliance FESA and environmental guidelines are used and implemented. Mondi also has its own operational guidelines for harvesting and silviculture. Road management is clearly described in the management plan and clear guidelines are provided to protect soil and water resources
Mechanical harvesting is being implemented and full social and environmental impacts were done. Guidelines are developed for these machines and being implemented by the contractor.
Buffer zones are demarcated on maps and the company has also embarked on surveys to determine what the ecological size of these buffer zones should be. In areas where it is only needed for throughway it can be smaller and is normal delineation for water enough. Other areas might need larger areas for resting and nesting in the corridor sections. This is also done to enhance the ecological sustainability of other forest services.
Criterion 6.6 Chemical pest management
Strengths
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Weaknesses Banned chemicals without any derogation were found in a chemical store. The chemical Karbadust containing Carbaryl as active ingredient was found on Satico and the explanation given was that it was used for the control of bees. MCAR 16 was raised and the company was immediately suspended. Suspension was lifted after a site audit of different chemical stores in the Lowveld region. Spill control specialists were used to remove the chemical from site and dispose of in a hazardous waste site.
The use of chemical pesticides as preferred method for controlling bees has not been determined and described by experts nor was the action justified. The chemical control of bees in the plantation at Satico has not been justified. CAR 14 was raised. This was linked to the karbadust that was found on site.
Compliance Updated chemical use lists were received from all the regions.
Although the long term goal is to reduce the use of chemicals, the immediate reality still requires the use of herbicides to reach other goals such as getting weeds into a maintenance phase. This is linked to the weed control strategy and might require an increase in the short term. Preliminary indication is that chemical use must almost double during the next three years before a remarkable reduction will be experienced. Only once all estates are in a maintenance phase, chemical use can be reduced.
On closing major CAR 16 that led to the suspension, CAR 14 was also investigated. The argument was defended that it is definitely not the practise on the estate and there were reports of bees in the compartment, but there were also documented response to the contractor that the bees are to be left alone.
All chemical stores visited complied with requirements for safe storage. Safety equipment for the treatment of accidental contact was available, and all sites provided for the accidental spills.
Criterion 6.7 Use and disposal of chemicals, containers, liquid and solid non-organic wastes
Strengths
Weaknesses On the re-visit to closeout major CAR 16 it was discovered that waste is dumped into a deep mineshaft. In terms of the lack of a management plan for the old mines it was argued that Mondi has no right, jurisdiction or control over these sites because they belong to the Department of Minerals and Energy. Using them as rubbish pits then intensifies this CAR for waste not disposed of in environmentally appropriate ways. According to previous argument it is actually dumped illegally in a departmental mine property. Because this issue was raised as a CAR in the previous cycle it was now raised as a major CAR 12.
Compliance Progress October 2007: Regarding waste disposal, dedicated people is appointed in each area. All relevant people were re-trained on own procedures. The specific site was discontinued and closed immediately. A new site was established with the necessary impact assessments done. The action plan as described in CAR 37 of the previous cycle was followed in all regions. CAR12 was closed.
Waste collection is situated around infrastructure. In field waste collection is done on the basis of what you take in you take out and sites visited were all clean. All villages visited had sufficient dustbins and it was evident that a regular waste removing system is in place. Only domestic waste is dumped in these areas. Waste like Chemical containers and batteries are returned to the suppliers.
Criterion 6.8 Use of biological control agents and genetically modified organisms
Strengths
Weaknesses
Compliance No biological control is used. No GMO’s are used. The possible involvement of Mondi in GMO developments in Tanzania were questioned and it was confirmed that Mondi is not involved in any such activities.
Criterion 6.9 The use of exotic species
Strengths
Weaknesses
Compliance By nature Mondi’s business is based on exotic species. They are constantly researching new clones and has a tree breeding program going. All new varieties are tested under controlled
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conditions before they are commercially used in plantations. Mondi is actively growing eucalyptus trees that can be considered a weed. Unwanted regeneration of these trees outside the production areas are then treated as weeds and eradicated during the weed control programs.
Criterion 6.10 Forest conversion to plantations or non-forest land uses
Strengths
Weaknesses Major CAR 6 was raised for areas planted where the permits could not be provided.
Compliance Forest conversion in South Africa is regulated by means of a planting permit scheme. Forestry is an extensive land-use within South Africa and Mondi has a substantial share of this. No conversions are made in conservation land. Areas with specific conditions that should not be planted are specified in planting permit.
Wetland areas are identified as sensitive areas. There is a continuous delineation program implemented to establish the boundaries of wetland areas and trees are then removed from such areas. The conservation benefits from this conversion to non-forest land use is the improvement and extension of wetland areas. Where such conversions are done the areas are rehabilitated to improve the wetland.
During the revisit in October Major CAR 6 was reduced to a minor. Sufficient documentation and instruction from DWAF not to act before the investigation is completed.
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Criterion 7.1 Management plan requirements
Strengths
Weaknesses
Compliance There is a management plan that links all the operations. The management plan is a live and active document. It is used by all managers in daily activities. It is mostly in electronic form and different sections uses different parts of the management plan for planning, implementation and monitoring. Some aspects of the management plan is sometimes printed and made available as glossy pamphlets or booklets. Mondi has its objectives clearly stated in the management plan. It is divided into long-term, medium term and short term objectives.
The objective is mainly the production of timber for paper mills and Mondi has an obvious interest in ensuring the rate of harvest will provide a sustainable supply. Yields and annual cuts are carefully monitored and planned. Species selection is done on scientific basis and management prescriptions with various species suited for each site is available.
RT&E species likely to occur on Momdi land, are listed and described in the conservation plans for each specific veld-type.
Maps are GIS based and available to managers. The map office in Pietermaritzburg has all the data of tall the compartments available and do regular updates.
Equipment is described and justified according to slopes and terrain. Mondi as organisation has long term strategic plans that are regularly updated for the sustainable growth of the fibre resource. All FMU’s have annual plans that are based on these long term strategic plans. Strategic, and operational plans are documented. The annual plan of operations is also linked to the budget.
Criterion 7.2 Management plan revision
Strengths
Weaknesses
Compliance The area is divided in different regions and each regional manager is ultimately responsible to ensure the management plan for his region is up to date.
New technology and developments in forestry are being screened by the technical experts in the various fields. It is available to foresters in field, but changes are only made when reviewed as a section. New technology includes the mechanised harvesting, new clonal tree breeding in silviculture and the incorporating of various mapping databases into the biodiversity management
Both the Silviculture and the harvesting plans has been reviewed recently and the new
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information on soils has been incorporated in the new silvicultural manual.
Management plan is publicly available on their website. www.mondibp.com
Criterion 7.3 Training and supervision of forest workers
Strengths
Weaknesses Mondi’s Sylvilcultural guidelines are not followed and adequately implemented in the issuing of slash burning permits. Refer to previous CAR 36 from previous cycle. A Major CAR 1 was raised on this issue because not all activities are sufficiently supervised and monitored to ensure that plans and procedures are adequately implemented.
Compliance All workers and staff are adequately trained for the tasks they perform. Mondi has also established a support system for new contractors to support them in aspects such as business management and staff management.
During the close-out of findings audit this CAR was closed.
All foresters responsible for slash burning were retrained. Training records were verified. All the required info on the permit was reiterated and the importance emphasized. The sources and methods where to and how to retrieve the data was explained All foresters have access to the data and maps on computer, Permits for the planned burns was verified and the available planning data was filled in.
Criterion 7.4 Public availability of the management plan elements
Strengths
Weaknesses
Compliance Some of the management issues were published in glossy format booklets that are available to the public. Different groups focus on different types of statements and therefore the format changes according to target groups. The company has a website for interested parties - which complies with the requirements of standard.
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Criterion 8.1 Frequency, intensity and consistency of monitoring
Strengths
Weaknesses Slash burning is done without any criteria set or clear guidance as to what should be monitored to establish the effects of fire. Major CAR 1 also reflects on this aspect.
Compliance Mondi’s management plan explains the different management activities that need monitoring and it is further controlled by a system of internal audits. Yield related monitoring is done in-house while with many of the conservation related issues they rely on specialist interest groups.
Monitoring protocol was updated and the BOPs adjusted to include the criteria for evaluation. All foresters responsible were trained in this criteria. A slash burn register was introduced that contain the effects of the fires and the mitigating required. All fires of the past year were evaluated and the results entered on the register. This CAR is closed.
Criterion 8.2 Research and data collection for monitoring
Strengths
Weaknesses
Compliance All Timber yields are considered in the monitoring of the plantations yields. The recent fires was a good indication how efficient the system works and all the fire damaged areas were reincorporated into a strategic plan to get it back into production within the minimum time.
Non timber products such as mushrooms recorded by the relevant collecting companies and the results are regularly sent through to Mondi. Grazing is a common non timber resource use and although it is not one of Mondi’s core business commodities they are taking great care in controlling it by controlling the number of cattle allowed. Scientific studies were done by agriculture to establish the grazing capacity.
Data on RT&E species is collected in conjunction with the relevant working groups or specialist
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groups in that field.
Post harvest inspections are done prior to the site being given back to the silvicultural team. This ensures that all harvesting related impacts are managed by harvesting.
Criterion 8.3 Chain of custody
Strengths
Weaknesses CAR 17 was raised for not having certificates for all the suppliers.
Compliance A separate CoC audit was done on the timber traceability. Traceability of timber was good throughout. During the closeout of findings audit the CAR was closed.
Criterion 8.4 Incorporation of monitoring results into the management plan
Strengths
Weaknesses
Compliance The whole tree breeding and clone program is based on the trials and monitoring of the best productive material. Sylvilcultural manuals have recently being reviewed and practices are adapted by incorporating these monitoring results. Growth and yield monitoring is captured and combined with growth site information to get the best optimal site species matching. This monitoring information is used to update management plans.
Criterion 8.5 Publicly available summary of monitoring
Strengths
Weaknesses
Compliance Results are available as part of the management plan and annual report. Specific information is available on request from the head-office.
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Criterion 9.1 Evaluation to determine high conservation value attributes
Strengths
Weaknesses
Compliance Mondi has used several consultants that are specialists in their fields in establishing the conservation value of the different natural forest patches on the land they manage. All the forest patches have been evaluated and the conservation status determined.
All the studies conducted and the information received are documented and available.
Criterion 9.2 Consultation process
Strengths
Weaknesses
Compliance The company rely on the advice of consultants who are experts in their field in determining the issues of importance. It is then incorporated into the management plan and annual plan of operations.
None of the forests derives its HCVF status because of any cultural attributes.
Criterion 9.3 Measures to maintain and enhance high conservation value attributes
Strengths
Weaknesses
Compliance Mondi relies on the input from the specialist to provide the biological background and management prescriptions in managing HCVF. Biological attributes are described for the specific forests. The management plan describes the different types of forests with the areas remaining and areas under Mondi’s control. It also describes the conservation status of the different veld-types.
No harvesting is done in any natural forest. All the natural forests are protected by the open
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area management plans and includes the patrolling of the forests for illegal activities.
Criterion 9.4 Monitoring to assess effectiveness
Strengths
Weaknesses
Compliance Monitoring is conducted by experts and information made available for informed decision making for future management. Research reports are available to managers on the FMU. They have direct contact with specialists doing the studies and can include required actions into the APO and budgets.
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Criterion 10.1 Statement of objectives in the management plan
Strengths
Weaknesses
Compliance The management plan states all the objectives for the plantations to ensure a sustainable resource base and the protection of natural habitat. Achievements of management objectives are planned and controlled by the implementation of short and long term management plans and the regular reporting on achievements or reasons for deviations.
Criterion 10.2 Plantation design and layout
Strengths
Weaknesses
Compliance Good quality maps are provided by the planning section and maps can be ordered to show any management specific information. All areas both production and non productive land is indicated on these maps. This ensure optimal design and and layout of the plantations and infrastructure. Wetland delineation is done on an ongoing basis. As the land is excised it is rehabilitated into natural vegetation. All riparian zones are demarcated on maps. Plantations are restricted from these areas. Mondi uses a short term rotation and therefore all the forest stands are at least in a second rotation.
Criterion 10.3 Diversity in composition
Strengths
Weaknesses
Compliance Due to the nature of the business, uniform stands of trees are unavoidable. The short rotation also prevent large differentiation in age classes. Clones are used where they out perform other commercial species otherwise plantations are re-established using the best optimal site species selection. Clear cut sizes are established on the basis of the total area and the sustainable supply to Mondi’s own paper mills.
Criterion 10.4 Species selection
Strengths
Weaknesses
Compliance Exotic species are used to protect natural forests and because they outperform native species. Mondi only uses exotic species in their paper mills. Well documented trials are being used in the development of clones. This data is carefully managed by the tree breeding section within Mondi. The nursery is used to propagate these clones for production.
Criterion 10.5 Restoration of natural forest
Strengths
Weaknesses
Compliance Natural forests are all protected on Mondi’s property. Disturbed areas are being rehabilitated.
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Criterion 10.6 Impacts on soil and water
Strengths
Weaknesses
Compliance All soil type information is available for all compartments and operations consult with in-house sylvilcultural specialists. All wetland areas are mapped out. Water monitoring points are established across the properties in all major catchments.
Criterion 10.7 Pests and diseases
Strengths
Weaknesses
Compliance Very little is known at this stage about the sap sucking bug, Thamasticorus australicus. It attacks trees under stress and causes them to suffer even more. At this stage it appear that the invested trees might still recover. Research is still continuing.
All regions are well equipped and have trained proto teams available for fire fighting.
Criterion 10.8 Monitoring of impacts, species testing and tenure rights
Strengths
Weaknesses
Compliance Monitoring of impacts takes place on the different estates where it occurs. Clone development and testing of new species is specialised sylvilcultural trials that are closely monitored under controlled conditions in tree-breeding units.
Criterion 10.9 Plantations established in areas converted from natural forests after November 1994
Strengths
Weaknesses
Compliance No plantations occupy land converted since 1994. However Mondi is in negotiation with Water Affairs to gain more land for afforestation in cases where it can be swapped for land converted back to conservation.
9. CERTIFICATION DECISION
SGS considers that Mondi Business Paper’s forest management of their South African forests, in Mpumalanga and Kwazulu Natal provinces can be certified as:
i. There are no outstanding Major Corrective Action Requests
ii. The outstanding Minor Corrective Action Requests do not preclude certification, but Mondi BP is required to take the agreed actions before 1 September 2008. These will be verified by SGS QUALIFOR at the next surveillance to be carried out about 12 months from the date of the issuance of the certificate. If satisfactory actions have been taken, the CARs will be ‘closed out’; otherwise, Minor CARs will be raised to Major CARs.
iii. The management system, if implemented as described, is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation;
iv. The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate.
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10. MAINTENANCE OF CERTIFICATION
During the surveillance evaluation, it is assessed if there is continuing compliance with the requirements of the Qualifor Programme. Any areas of non-conformance with the QUALIFOR Programme are raised as one of two types of Corrective Action Request (CAR):
.01 Major CARs - which must be addressed and closed out urgently with an agreed short time frame since the organisation is already a QUALIFOR certified organisation. Failure to close out within the agreed time frame can lead to suspension of the certificate.
.02 Minor CARs - which must be addressed within an agreed time frame, and will normally be checked at the next surveillance visit
The full record of CARs raised over the certification period is listed under section 11 below.
The table below provides a progressive summary of findings for each surveillance. A complete record of observations demonstrating compliance or non-compliance with each criterion of the Forest Stewardship Standard is contained in a separate document that does not form part of the public summary.
SURVEILLANCE 1
Issues that were hard to assess
Number of CARs closed 5 Outstanding CARs were closed.
Nr of CARs remaining open None
New CARs raised 4 Minor CARs were raised.
Recommendation The management of the forests of Mondi Limited to remain certified as:
� The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; and
� The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate.
SURVEILLANCE 2
Issues that were hard to assess
None
Number of CARs closed Three Minor CARs were closed
Nr of CARs remaining open One Minor CAR remained open
Nr of New CARs raised Three new Minor CARs were raised
Recommendation The management of the forests of Mondi Limited to remain certified as:
� The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; and
� The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate.
SURVEILLANCE 3
Issues that were hard to assess
None
Number of CARs closed Two minor CARs were closed
Nr of CARs remaining open Two minor CARs remain open
Nr of New CARs raised Three new Minor CARs were raised
Recommendation The management of the forests of Mondi Limited to remain certified as:
� The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by
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the scope of the evaluation; and
� The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate.
SURVEILLANCE 4
Issues that were hard to assess
Number of CARs closed
Nr of CARs remaining open
Nr of New CARs raised
Recommendation
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11. RECORD OF CORRECTIVE ACTION REQUESTS (CARS)
CARs from the previous certification period
CAR # Indicator CAR Detail
38 Date Recorded>
8/9/2006 Due Date> 7/9/2007 Date Closed> 7/9/2007
Non-Conformance:
Alien weeds are not adequately controlled. Operations not supervised and progress and deviation monitored.
Objective Evidence:
Refer to Major Car 31 of 2005. It is closed as a Major but raised as a minor 38 for the following reasons. Refer to previous CAR 25 of 2004. The practice of slashing bugweed without treating it is still present and the evidence was found in Mkondo region. The repetitive nature of this problem prevents the CAR from being closed. Weeds were also addressed in CARs 08 of 2002 as well as 68 from the previous cycle.
Close-out evidence:
Progress 2007 As mitigating for not remaining as a major the following was taken in consideration. Mondi has developed a comprehensive weed control strategy with dedicated timeframes to address the weed infestation on all their land. The goals and targets are realistic and there was commitment throughout the FMUs visited to adhere to the targets set. It also provides for an auditable framework against which performance of the company can be measured. CAR closed and replaced by CAR 2 of re-assessment.
39 8.1.3 Date Recorded>
8/9/2006 Due Date> September
2007 Date Closed> 7/9/2007
Non-Conformance:
Consistent monitoring procedures not documented for activities with potential negative impacts.
Objective Evidence:
Monitoring the effects of fire impact after slash burning not adequately addressed by the current permit system.
Close-out evidence:
CAR closed and raised to Major 3 during re-assessment.
CARs from the current certification period
M01 7.3.3 Date Recorded>
7/9/2007 Due Date> 7/11/2007 Date Closed> 30/10/2007
Non-Conformance:
Not all activities are adequately supervised to ensure that plans, policies and procedures are adequately implemented.
Objective Evidence:
Refer to CAR 36 from the previous cycle.
Mondi’s Silvicultural guidelines are not followed and adequately implemented in the issuing of slash burning permits. Not all required weather and related detail on the permit form is completed when issuing the permit. Permits at Iswepe are incomplete.
Wash bay area and cleaning operations by contractors at Satico are not supervised. They are not using the dedicated wash bay area and this is causing pollution.
Medical waste was found in open cardboard boxes.
Close-out evidence:
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All foresters responsible for slash burning were retrained. Training records were verified. All the required info on the permit was reiterated and the importance emphasized. The sources and methods where to and how to retrieve the data was explained All foresters have access to the data and maps on computer, Permits for the planned burns in Greytown area was verified and the available planning data was filled in.
The internal SHEAR (Safety Health & Environment Action Request) system was re-emphasized. Stricter control and contractor audits were done and report back system implemented. The mentioned objective evidence on Satico was evaluated and the whole site was assessed for individual impacts. Mitigating actions were introduced and are in process of implementation. It includes the resurfacing of the washbay, re-building of the oil trap, discontinuing of the one oil store, soil rehabilitation area. Oil spills were treated.
Medical waste: All relevant staff across Mondi were re-trained by external company in the handling of the waste. Training certificates were available. BOP was done for the handling of bio-hazardous waste. Removal of bio hazardous waste is outsourced to registered company. Correct storage facilities is provided. All accrued costs is calculated and additionally budgeted.
This CAR is closed.
02 6.2.4 Date Recorded>
7/9/2007 Due Date> Next
surveilance Date Closed> 20/9/2008
Non-Conformance:
Conservation zones and protected areas, representative of existing ecosystems are not being protected. Alien weeds are not adequately controlled.
Objective Evidence:
Mondi has a good strategy with timeframes attached to bring weeds under control, but operational progress and deviation from that strategy is not monitored:
� Droegemoller leased farm has open areas that are invested with mature wattle stands.
� Greytown area has inadequate budget to bring weeds under control within reasonable time. Waterfall ASI is invested with bug weed and standing trees on cliffs.
� Melmoth area has various drainage lines weed invested.
Close-out evidence:
Progress October 2007: This issue was raised as an issue that negatively affects the company image and reprioritised. All action plans were reviewed and new budgets provided. A substantial amount was added to the budget and secured for the next five year to be able to achieve the targets that were set. Additional work has commenced and farms mentioned as objective evidence has been cleared. A weekly feedback system was introduced to report on progress. An Auditable progress presentation will be prepared for tracking the effectiveness. Due to the nature of this CAR and the fact that the issue is much more widespread than the farms mentioned, the progress is acknowledged but the CAR remain open for further monitoring.
2008: A large capital budget was allocated and secured for the next 5 years to this issue to get it under control under the set time frame. Sites visited throughout the company indicated a dedicated implementation of this program and noticeable progress was made. Concerned stakeholders were also consulted and they confirmed that there has been a remarkable improvement.
M03 8.1.3 Date Recorded>
7/9/2007 Due Date> 7/11/2007 Date Closed> 31/10/2007
Non-Conformance:
Refer CAR 39 from previous certification period:
Consistent monitoring procedures are not documented for activities with potential negative impacts.
Objective Evidence:
Slash burning is done without any criteria set or clear guidance as to what should be monitored, to establish the effects of fire. At Richmond compartment D19 had clear signs of the fire been to hot. The post-burn report had just a note scribbled on the back of the permit stating that there was “no problem”.
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Close-out evidence:
Monitoring of the effects of fires were included in the training referred to in CAR1. Monitoring protocol was updated and the BOPs adjusted to include the criteria for evaluation. A slash burn register was introduced that contain the effects of the fires and the mitigating required. All fires of the past year were evaluated and the results entered on the register.
This CAR is closed.
04 Date Recorded>
7/9/2007 Due Date> Date Closed> 31/10/2007
Non-Conformance:
Objective Evidence:
Close-out evidence:
CAR 04 was combined with CAR 01
5 5.1.1 Date Recorded>
7/9/2007 Due Date> Next
surveilance Date Closed> 31/10/2007
Non-Conformance:
Available forest land and the potential annual yield are not optimally used.
Objective Evidence:
Burnt compartments in the Q block of Hazyview still have patches of dead timber from the 2005 fire standing. These compartments have not been planted again and are not productive.
Close-out evidence:
A specific action plan for the recovery of the burnt area was prepared. All areas and methods for recovery were included. It was based on the shortest recovery time to get the land back in production with a weekly report back built into it. This weekly controls are also applicable to contractors. An area of 1312 ha was involved in the fire and it will be 90 % back in production by March 2008. Action plan was already implemented and substantial progress was made by October 2007.
This CAR is closed.
M6 1.1.1 Date Recorded>
7/9/2007 Due Date> 7/11/2007 Date Closed> 31/10/2007
Non-Conformance:
There is evidence of significant non-compliance with national laws and administrative requirements.
Objective Evidence:
Refer formal complaint from stakeholder:
Planting permits for the areas planted on the farms Barshen Fell & Prospect in the Melmoth district could not be provided. The confirmation given by a representative from the Department of Water Affairs and Forestry confirmed that there is a problem that is being investigated.
Close-out evidence:
Planting permits are captured on a central database within Mondi. Progress was made with comparing this database with those of DWAF. The mentioned farms forms part of the database and is incorporated in the process. DWAF has given official confirmation that an investigation is illegal plantings is underway and that Mondi should not take any action unless directed by the department. Official letter and various email correspondence was available. Due to the nature of this CAR, the issue cannot be not be closed completely in such short time, but the progress made is sufficient to reduce it to minor status.
CAR closed. Replaced with CAR 18.
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7 1.1.1 Date Recorded>
7/9/2007 Due Date> Next
surveilance Date Closed> 31/10/2007
Non-Conformance:
There is evidence of non compliance with national laws and administrative requirements regarding the contractor’s compliance with the full sectoral determination for the forestry sector.
Objective Evidence:
During the audit the requirements of the Sectoral Determination 12: Forestry promulgated in terms of the Basic Conditions of Employment Act was tested in respect of contractors. Although the determination contains an extensive and diverse range of requirements, the minimum requirements of what should be included on a payslip was sampled. Both contractors (Satico and Richmond did not comply).
Close-out evidence:
The whole sectoral determination was studied and a checklist compiled to cover all aspects. All contractors were audited against this checklist and the shortfalls identified. Audit forms available for all contractors in all regions.
This CAR is closed.
8 4.4.5 Date Recorded>
7/9/2007 Due Date> Next
surveilance Date Closed> 20/9/2008
Non-Conformance:
Issues raised by stakeholders are not always resolved constructively and objectively.
Objective Evidence:
The Concerns raised by a stakeholder regarding aforestation at the farms Barshen Fell & Prospect in the Melmoth district, has been ongoing since 1998 and this eventually led to a formal complaint against the certificate.
Oct 2007: Progress was made. SHEAR process revised to identify the level of management to become involved at what stage. Data not sufficient in such short time to close the CAR.
Close-out evidence:
During the audit a meeting was held with the Melmoth farmers association. The farmer that laid the original complaint was also present as one of the delegates. Discussions focused around the interaction between Mondi and its stakeholders. The meeting agreed that there was a good effort from Mondi side and that this CAR can be closed.
9 4.2.9 Date Recorded>
7/9/2007 Due Date> Next
surveilance Date Closed> 20/9/2008
Non-Conformance:
Worker accommodation on the FMU does not comply with minimum requirements.
Objective Evidence:
At Greenville village (Richmond) electrical wires were exposed and there are various concerns relating to safety & health risks at Satico
Oct 2007: Progress was made and action plans drawn up. Additional budget allocations were made. Although some villages were completed this CAR remain open for future monitoring.
Close-out evidence:
A top management decision was made to invest in all the villages where needed. Additional funds were made available and an amount of R 5 mil / yr for the next 3 years was allocated to this project. All the villages visited had either been upgraded or the upgrading were in progress. There was a noticeable improvement in all villages and a strong commitment from management to complete the village upgrade program.
10 5.3.4 Date Recorded>
7/9/2007 Due Date> Next
Surveilance Date Closed> 31/10/2007
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Non-Conformance:
Harvest and processed products are not transported from site before decay takes place.
Objective Evidence:
Various depots in the Richmond area as well as road sides at Satico had old and decaying timber going to waste.
Close-out evidence:
It is included as a measurement on the “Pushing the Limit” report under fibre wastage. Inventories were done for all estates. Action plans were implemented immediately and all depots cleaned up.
CAR closed.
M11 1.6 Date Recorded>
7/9/2007 Due Date> November
2007 Date Closed> 31/10/2007
Non-Conformance:
Failure to ensure adequate continuous compliance with the FSC standard.
Objective Evidence:
The high number of CARs raised during the 3rd
assessment period.
High number of CARs raised per principle for principles 4 & 6.
Close-out evidence:
Continuous compliance to FSC was demonstrated during the closeout of findings audit that was done 30 – 31 October in various ways:
� High profile management involvement and buy-in in the process of complying and addressing the CARs. Senior management took the lead in guiding and controlling the process.
� Official statements from the CEO and top management confirming continued commitment and the importance of compliance.
� The restructuring process that had a crippling effect on the company is almost complete and there is evidence of renewed motivation in operations. It resulted that FSC related issues are integrated into operational best operating practices and controlled through the optimization department with authority to act.
� Dedicated teams were formed to investigate each of the CARs and establish the root cause that led to the CAR. The extent to which Mondi succeeded in these investigations were commendable.
� Action plans were developed for all the CARs. It was developed to address the cause of the CAR with widespread repercussions. Action plans were immediately implemented and progress were made on all the CARs by the time of the closeout audit. Action plans for CARs were implemented across Mondi, irrespective of where it was raised. Report back was controlled and progress monitored.
� Resources were provided additional to the budget and commitment from top management was given for future budgets and resource allocation.
CAR closed.
M12 6.7.2 Date Recorded>
7/9/2007 Due Date> November 2007
Date Closed> 31/10/2007
Non-Conformance:
Waste generated on the FMU is not always disposed of in environmentally appropriate ways.
Objective Evidence:
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Medical waste at Satico was found in open cardboard boxes.
On the re-visit to closeout CAR 16 it was discovered that Satico’s waste is dumped into a deep mineshaft. During the debate on the lack of a management plan for the old mines on Satico it was argued that Mondi has no right, jurisdiction or anything over these sites because they belong to department of Minerals and Energy. Using them as rubbish pits then intensifies this CAR for waste not disposed of in environmentally appropriate ways. According to previous argument it is actually dumped illegally in a departmental mine property.
This CAR was raised as a major CAR 37 during the previous certification cycle.
Close-out evidence:
The medical waste portion of the CAR was addressed under CAR 1 and a complete protocol for the handling of bio-hazardous waste was developed.
Regarding waste disposal, dedicated people is appointed in each area. All relevant people were re-trained on own procedures. The specific site was discontinued and closed immediately. A new site was established with the necessary impact assessments done. The action plan as described in CAR 37 of the previous cycle were followed in all regions.
CAR closed.
13 4.2.1 Date Recorded>
7/9/2007 Due Date> Next
surveilence Date Closed> 31/10/2007
Non-Conformance:
Forest managers are not always aware of health and safety laws and regulations and comply with such. General safety issues not adequately addressed and monitored.
Objective Evidence:
Gas cylinders were not stored correctly at Iswepe.
Smooth tyre on truck that transports people.
MSDS sheets for chemicals not available.
Close-out evidence:
Safety plans were reinforced throughout all business units for all basic procedures. The mentioned issues were addressed.
BOP for the storage and handling of gas cylinders developed and circulated to all regions.
MSDS sheets were available for all chemicals in the store at Satico.
All vehicles found on the terrain and on site on Satico were compliant.
CAR closed.
14 6.6.4 Date Recorded>
7/9/2007 Due Date> Next
Surveillance Date Closed> 13/9/2007
Non-Conformance:
The use of chemical pesticides as preferred method for controlling bees has not been determined and described by experts nor was the action justified.
Objective Evidence:
The chemical control of bees in the plantation at Satico has not been justified.
Close-out evidence:
Evidence was shown of an earlier complaint about bees by some of the contractors, and the written response from the manager that they should be left alone and by no means destroyed. Also indicating that it is not Mondi’s policy to destroy bees in the wild. CAR closed.
15 6.3.3 Date Recorded>
7/9/2007 Due Date> Next
surveillance Date Closed> 20/9/2008
Non-Conformance:
Ecological functions are not maintained and there is no program for the restoration of degraded sites.
Objective Evidence:
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Old mining sites at Satico have no action plan in place for their restoration and management.
Close-out evidence:
Oct 2007: There were progress made with negotiations with both SAFCOL and DME. Correspondence is on file. Issue not at stage where the CAR can be closed.
2008: Mining Sites – Department of Geosciences now handling this issue. A consultant was appointed for preparing a rehabilitation program for the sites with them.
M16 6.6.2 Date Recorded>
7/9/2007 Due Date> Immediate Date Closed> 13/9/2007
Non-Conformance:
Banned chemicals without any derogation were found in chemical store.
Objective Evidence:
The chemical Karbadust, containing Carbaryl as active ingredient, was found at Satico and the explanation given was that it was used for the control of bees.
Close-out evidence:
The following steps were taken to close out this CAR:
Mondi immediately arranged for the chemical to be removed by a registered spill control company and it was removed to a hazardous waste site by Savuti spill control on the 10
th
September. Removal statement available.
A second party audit was carried out at all chemical stores on all the estates and the results were sent through. No further banned substances were found.
The latest TIPWG list was circulated to all officers in charge of chemical stores.
MSDS sheets are distributed to all chemical stores for the chemicals kept in storage.
Annual medical inspections include all contractors’ people working with chemicals.
A chemical registering report was set up whereby all chemicals in any particular store is “registered” with the forester in charge who can verify it complies with TIPWG list.
Site visit confirms material was removed. Three sites were visited. Satico, where the chemical were found, DeKaap estate and Springfarm. None of the inspected sites had any banned material or any register of that.
Site inspections included the dumpsites to ensure it was not simply dumped.
Delivery notes on site were all clearly marked Non FSC. Deliveries were made to Reatile, an uncertified client. CoC can only be checked at a later stage as the timber has not passed any controls yet.
There is sufficient evidence the company has taken the right action to remove the banned substance from site and to prevent any similar incident from happening. The CAR is closed and it is recommended the suspension is lifted.
AD 36-A-05 Page 53 of 76
17 CoC
2.3.2
Date Recorded>
7/9/2007 Due Date> Next
surveilance Date Closed> 31/10/2007
Non-Conformance:
Copies of supplier’s certificates are not available.
Objective Evidence:
There are two computer programs operating simultaneous. Fortes and AS400. The Fortes system contain corrupted / incorrect information, especially with regard to FSC CoC certificate numbers of clients listed as certified clients who are not.
Close-out evidence:
Database combined and only Fortes is in use, certificates are reviewed and validity of certificates are verified. It also forms an database entry to make it easy to track clients and certificate validity.
CAR closed.
18 1.1.1 Date Recorded>
31/10/2007 Due Date> Next
surveilance Date Closed> 20/9/2008
Non-Conformance:
There is evidence of significant non-compliance with national laws and administrative requirements.
Objective Evidence:
Refer formal complaint from stakeholder:
Planting permits for the areas planted on the farms Barshen Fell & Prospect in the Melmoth district could not be provided. The confirmation given by a representative from the Department of Water Affairs and Forestry confirmed that there is a problem that is being investigated. Refer formal complaint from stakeholder:
Close-out evidence:
The issue is not as simple as getting a permit for all plantings and not entirely in the company’s hands. The Department of Water Affairs is in itself in disarray and not able to provide a database regarding permits for all the plantings. The company is now working in cooperation with the department to establish such a database from both historical plantings pre ’72 to the more recent plantings. Each farm and compartment is individually dealt with and linked to the GIS system. The process timeframe is for completion in May 2009. There is sufficient evidence of the progress made to close the CAR, but an observation is raised to ensure monitoring during the next surveillance.
19 8.3.5 Date Recorded>
20/9/2008 Due Date> Next
surveilance Date Closed> 13 Oct 2009
Non-Conformance:
Use of the FSC trademark is not in accordance with policy and has not been approved by SGS Qualifor
Objective Evidence:
The whole of Tygerskloof WPU management were wearing jackets with FSC 2008 on it. Although it created a good team spirit, there was no authorization for it.
Close-out evidence:
Mondi Limited has taken a decision not to use the trademark in the forests. All existing trademark use has been removed and all future trademark use will be done by the Marketing Division, who will correspond with SGS. The above mentioned jackets have been withdrawn.
20 4.2.2 Date Recorded>
20/9/2008 Due Date> Next
surveillance Date Closed> 13 Oct 2009
Non-Conformance:
AD 36-A-05 Page 54 of 76
Not all risks associated with the company’s key responsibilities have been adequately assessed.
Objective Evidence:
Several estates have dams on the estate that are managed by the company. The risks of dam safety for those dams with walls higher than 5 m was not adequately assessed as required by chapter 12 of the Water Act.
The lookout at Louwsburg did not have a harness to climb up the stairs.
Harvesting trailer at Kwambonabi did not have safety strips along the side.
Close-out evidence:
650 impoundments have been identified by GIS on Mondi Limited land (including Letaba and SQF). A dam site inspection report was drawn up with the plan to inspect every single impoundment and create a report per area. This has been completed for the Ntonjaneni Area, where 57 dams were visited and classified according to the DWAF requirements. Of these dams, 13 are required to be registered, and the documentation submitted to DWAF. Safety inspections will by carried out by DWAF (now DWEA). This is being rolled out to all of the areas, including Letaba (not certified) and Siyaqhubeka. The detailed inspection data is excellent and Mondi’s approach was commended.
A harness has been provided for the Lookout at Louwsberg, and the Mistly Fire Tower inspected on Seven Oaks did have a safety harness, and the operator also wore a helmet ascending and descending the ladder.
Safety strips have been provided for the harvesting trailer at Kwambonambi, and all other trailers have been inspected. This was checked at the Second Party Audit level.
This CAR is closed, but the progress with the impoundment inventory will continue to be monitored (noted as Observation 12).
21 2.2.5 Date Recorded>
20/9/2008 Due Date> Next
surveillance Date Closed> 8 Nov 2010
Non-Conformance:
The extent to which the forest is accessible to local rights holders is detrimental to the forest’s ecological function.
Objective Evidence:
Grazing is allowed on the grasslands surrounding the dam on The Bends to such an extent that overgrazing occurred and erosion has resulted.
2009 Update: Control of cattle and their grazing areas need to be monitored in more of the areas than the audit sample allowed. These areas need to be physically visited to check veld condition. Mondi have started a programme of livestock surveys, meeting and training of livestock owners, establishment of Livestock Forums (Piet Retief and Iswepe) and assisting with cattle branding and cattle auctions (Iswepe). Carrying capacities of the various veld types has been calculated, but determining the number of cattle is difficult, since the cattle move, and owners sometimes lie about the number of cattle that they own for various reasons. Capacity building of livestock owners and herdsmen, training and active commercialisation is still necessary in all of the areas. The problem of cattle and annual burning go hand in hand and the problem is not yet resolved. With the active commercialisation (e.g. cattle auctions), Mondi are hoping to reduce the number of cattle, but improve the quality of cattle. This is an innovative approach to a difficult social problem. Continued monitoring is necessary.
Close-out evidence:
AD 36-A-05 Page 55 of 76
Each area has employed a CEF (Community Engagement Facilitator), who works exclusively with communities, and the issue of the control of cattle has been at the top of the agenda. Different areas have different approaches to the cattle problem, but essentially the move to making more use of government departments (e.g. KZN Agriculture) to assist with the capacity building of livestock owners has progressed well. Mondi is providing assistance with cattle dipping/treatment and the active commercialisation of the cattle. The control of cattle has improved through better communication, herding of cattle and monitoring of their movement in the different areas. Ntonjaneni Area has drawn up a guideline on management of livestock, and divided the stakeholders involved into different categories. For each category, a census has been carried out of the number of cattle and their location. For each of these areas the grazing has been assessed, areas of overgrazing identified, problems identified and management statements made
Grassland monitoring has resulted in certain recommendations with regard to carrying capacity and overgrazed areas which should not be further grazed (e.g. some areas in Ntonjaneni). Cattle grazing is always going to be an issue that needs careful monitoring and good communication with communities.
This CAR is closed.
22 6.6.5 Date Recorded>
20/9/2008 Due Date> Next
surveillance Date Closed> 13 Oct 2009
Non-Conformance:
Storage of hazardous substances not always according to standard.
Objective Evidence:
There was no integrity testing done on any of the underground fuel tanks as was seen at Mtunzini.
Close-out evidence:
A process of integrity testing on underground storage tanks has been initiated, and the removal of unused tanks is also being negotiated with the suppliers. In total there are 22 tanks in use on the Mondi holdings, of which 16 have been tested. One tank still needs to be tested in the South BU and 5 tanks need to be tested in the North BU. These are all pending supplier action. This CAR is closed on the basis of the progress to date.
23 4.1.7 Date Recorded>
13 Oct 2009 Due Date> Next
surveillance Date Closed> 8 Nov 2010
Non-Conformance:
Full compliance with the Sectoral Determination for Forestry Workers has not yet been achieved amongst all contractors
Objective Evidence:
Debarking team working for MID contractors at Bobsloop F17 are being paid according to task system, and are not paid for all the days worked. This was found out from interviewing the workers, viewing payslips, interviewing the tally clerk and examining the work record register.
Close-out evidence:
No instances of workers being paid below the minimum daily wage for not completing their tasks were found during the audit. Contractors where this was checked included: Mooiplaas Contractors at Ntonjaneni; ZAF, Siyathukuka and Kubuzi Contractors at Umfolozi. This CAR is closed. CAR 28 was raised to ensure that this practice is completely abolished in the company.
24 8.5.1 Date Recorded>
13 Oct 2009 Due Date> Next
surveillance Date Closed>
Non-Conformance:
Regular summaries of monitoring results and analysis by FMU are not readily available
Objective Evidence:
AD 36-A-05 Page 56 of 76
Monitoring results are available to the public on request, but have not been summarized and analysed to indicate trends over time. E.g. Water quality monitoring, grassland monitoring, weed control status (e.g. Iswepe), indigenous forest monitoring, monitoring of RT&E species etc. Individual reports need to be pulled to gather this data, and the data would have to be explained to the member of the public. This was the situation at all areas visited. By means of example, there were stakeholder concerns about lack of weed control in the open areas and it was not possible to supply the stakeholders with these trends immediately, since they would need to be collated and put into an explanation document.
2010 Progress:
All areas now have an Area Management Plan Summary. This summary includes of monitoring results and analysis e.g. trends in Invasive Alien Plant control over the past 4 years, trends in pesticide use, health and safety statistics etc. In addition, there is also a summary of monitoring activities listed under the sub-headings Environmental (e.g. River health, grasslands, wetlands, HCVAs, RT&E species, and sites of conservational significance etc), General (e.g. villages, potable water), Planning (e.g. TUP, PSPs); Silviculture, Social, Safety, Health, Harvesting and Transport. The selection of results/trends to make publicly available has caused some confusion. The FSC criterion specifies that the FMU shall make available a summary of the results of monitoring indicators , including the following:
yield of all forest products harvested;
growth rates, regeneration and condition of the forest;
composition and observed changes in the flora and fauna;
environmental and social impacts of harvesting and other operations;
costs, productivity, and efficiency of forest management.
The above can be presented in the form of trends, so as not to reveal any confidential information. Of the above list, the yield trends have not been presented, fauna and flora monitoring has only been presented in terms of the AIP eradication trends. Monitoring of environmental impacts (e.g. River health, wetlands) has not been presented (although results are available) and trends in costs, productivity and efficiency of forest management are not presented.
It is therefore recommended that this CAR be kept open.
Close-out evidence:
25 7.4.1 Date Recorded>
13 Oct 2009 Due Date> Next
surveillance Date Closed>
Non-Conformance:
The Publicly available summary of the management plan is lacking in certain aspects
Objective Evidence:
AD 36-A-05 Page 57 of 76
The publicly available summary of the management plan
1. is not updated and fails to include a statement about the proposed sale of the North Business Unit.
2. does not adequately describe and justify the mechanized harvesting and mechanized pitting.
3. inadequately reports on measures to conserve and enhance HCVF’s as per Criterion 9.3
4. lacks updated plans for the identification and protection of RT&E species and habitat and does not make reference to Legogote Sour Bushveld in the description of vegetation types.
5. does not include maps indicating protected areas or make reference to such maps 2010 Progress: All areas now have an Area Management Plan Summary. The summary described above (2009) is no longer used, and each Area Manager is responsible for drawing up his own plan, which is customised to his particular area. These summaries were seen as power point presentations for the Tygerskloof, Ntonjaneni, Umfolozi and Richmond Areas (surprise visit). This is an excellent initiative, and the Area Manager now has the power to distribute this to stakeholders in his area. In addition, Mondi also has the Mondi Group Sustainability Summary 2009, which is available hard copy, electronically and has numerous links that can be followed for more information. The combination of these two documents, however, still does not cover the FSC requirements of the contents of a publicly available summary of the management plan. The following aspects are still lacking (see Criterion 7.1):
c) rationale for rate of annual harvest and species selection;
e) environmental safeguards based on environmental assessments (here the industry environmental guidelines can be referred to);
f) plans for the identification and protection of rare, threatened and endangered species (and measures to enhance HCVAs);
h) description and justification of harvesting techniques and equipment to be used (this was mostly covered by the opening presentation by RM, but has not been built into the AMP summaries and does not cover e.g. cable yarding which is used in the steep areas).
It is therefore recommended that this CAR be kept open.
Close-out evidence:
26 6.7.1 Date Recorded>
8 Nov 2010 Due Date> Next
surveillance Date Closed>
Non-Conformance:
Lack of effort to recycle non-organic waste (see Obs 10)
Objective Evidence:
1. In 2009 there was no evidence of any recycling at the Ntonjaneni Area (Babanango WPU), and in 2010 there was still no evidence of recycling initiatives at the Ntonjaneni Area (Babanango and Kataza WPU).
2. At the Umfolozi Area, Mtunzini WPU there was no recycling/separation of waste and fluorescent tubes were in the same trash as the domestic waste, contrary to Mondi’s waste management procedure. Waste such as tyres, metal and plastic was also seen in the Sinkhole, which is an ASI at Z008. Similarly there was no recycling effort at Mtubatuba WPU, Teza Village. All waste is taken to the Mtubatuba Municipal Dump (which was visited, and found to be in a shocking condition).
3. Richmond Area: No separation of waste and all waste is collected and taken to a central point where it is taken to the Richmond Municipal dump.
The good effort made at Tygerskloof is acknowledged, where receipts of payment for recycled cans, plastic, bottles and cardboard were available!
Close-out evidence:
27 7.1.12 Date Recorded>
8 Nov 2010 Due Date> Next
surveillance Date Closed>
AD 36-A-05 Page 58 of 76
Non-Conformance:
Absence of long term burning plans for the conservation areas.
Objective Evidence:
At Ntonjaneni area there was no evidence of any biennial burns, with every grassland burnt annually, including the Langefontein HCVA, and there were no historical records for burns (e.g. Z18-20 no records for 2009. In addition the fire protection and conservation burning is not linked.
At Umfolozi area, Mtunzini WPU there was also no long term burning programme, but there were recommendations made by Rick van Wyk (e.g. triennial burns for some areas). It was also not known which vegetation type they were managing for e.g. grassland or forest. This will influence the burning regimes selected. Similarly at the Mtubatuba WPU, the burning programme was not based on Rick van Wyk’s recommendations, the burning regime was not documented and the selection of Z-compartments to burn was not justified based on a long term plan.
Close-out evidence:
28 8.1.1 Date Recorded>
8 Nov 2010 Due Date> Next
surveillance Date Closed>
Non-Conformance:
Certain activities that require monitoring have not been identified.
Objective Evidence:
Wage audits do not have a system for checking that workers are not paid below the minimum daily wage for failing to complete their tasks.
Close-out evidence:
AD 36-A-05 Page 59 of 76
12. RECORD OF OBSERVATIONS
OBS # Indicator Observation Detail
1 7.3.3 Date Recorded> 8/9/2006 Date Closed> 7/9/2007
Observation:
It was observed that there is no direct auditing or control over the sites leased by other companies such as Black Gold.
Follow-up evidence:
The observation was closed and included as objective evidence in Major CAR 1
2 1.6.1 Date Recorded> 7/9/2007 Date Closed> 20/9/2008
Observation:
There is a certain lack of commitment at some estates. Although all the estates prepared good formal presentations with relevant information, supporting documentation is not always readily available. It is viewed in the sense that the company has been certified for 10 years and have the FSC principles and criteria available with the checklist. Therefore demonstrating the company’s compliance to each aspect should be easy and obvious with documentation readily available as objective evidence during the audit. Requesting normal, straight forward documentation sometimes took long to find and slowed down the audit process. (This is not referring to some of the more advanced searches that were requested by this particular audit).
Follow-up evidence:
Required information was readily available.
3 4.2.10 Date Recorded> 7/9/2007 Date Closed> 20/9/2008
Observation:
The program that raises awareness of illnesses and diseases in Mondi that effect their operations is inadequate as it is limited to own workers and not extended to contractors where appropriate.
Follow-up evidence:
Mobile clinic is available to the contractors. A Voluntary counselling and testing service is available. Some regions had a 100% screening for TB. The feeding scheme will be rolled out throughout the whole company and is specifically for the contractor workers.
4 10.1.2 Date Recorded> 7/9/2007 Date Closed> 20/9/2008
Observation:
Inadequate resources provided to effectively implement management plans.
People are all new on sites and continuity is lost in implementing operational plans.
Areas such as Satico have many steep and inaccessible areas and no skyline system is provided.
Follow-up evidence:
It appears that there is more stability in the company and people are settled in their posts. Recourses are made available to implement plans. No further evidence required.
5 Date Recorded> 20/9/2008 Date Closed> 13 Oct 2009
Observation:
AD 36-A-05 Page 60 of 76
OBS # Indicator Observation Detail
Several good initiatives were implemented during the past year and large investments were made that enable the company to close out some of the difficult CARs. Some of the initiatives will be closely monitored by FSC.
- Weed control and open area management for achieving target dates.
- Stakeholder engagement. (Melmoth community requested follow-up meeting for next year).
- Permits for planting and the database that is due to be completed in May 2009.
- Community engagement and translocation program.
- Villages upgrade.
Follow-up evidence:
Weed control is progressing well. Data for all areas that are currently in maintenance phase, 5% weed has been appended to the checklist report section.
Planting Permits: Mondi is interacting with authorities on all areas with unlawful plantings. All pre-1972 plantings are being re-evaluated in an effort to reduce unlawful plantings. Currently 21807 ha still need to be verified by aerial photography (pre-1972 or not).
Stakeholder engagement: Good progress has been made in improving the relationship with commercial farmers in the Ntonjaneni District, through meetings and report-backs given to the Melmoth Farmers Association. A member of the Melmoth Farmers Association expressed satisfaction about progress in addressing most of the concerns raised during the past few years, in particular weed control and firebreaks.
Community engagement and translocation: The programme to provide a range of alternative housing options to residents has progressed, albeit at a slow place due to the complexity of the partnerships involved and the slow pace of government delivery. The urban housing project in Piet Retief is now moving ahead after long delays arising from problems with key Government partners. The Provincial Department of Agriculture and the Premiers office have picked up the agri-village proposal, and the first village at Jabulane is to be officially launched before year end. The establishment of a dedicated Land Division to attend to all matters related to land claimants, residents and neighbouring communities has considerably improved communication with these crucial stakeholders.
Village upgrade: This is the second year of a three year programme to upgrade all worker accommodation, with an expenditure of about R10 million per year. Progress has been good, and expenditure is on track.
6 4.3.3. Date Recorded> 20/9/2008 Date Closed> 8/11/2010
Observation:
Review of information made available on the proposed worker feeding scheme that has been launched in 3 pilot areas suggests that there has been little to no consultation with workers about the program. Management has indicated that they will involve workers in an evaluation of the pilot schemes, and roll-out to the rest of the operations thereafter. A question remains regarding adequacy of consultation, and indeed structures or mechanisms for enabling participation, in the absence of unions.
Follow-up evidence:
AD 36-A-05 Page 61 of 76
OBS # Indicator Observation Detail
Regular spot checks are carried out of meals provided in field by the team in charge of the Food for Forests program. The main focus is to ensure compliance with hygiene and nutrition standards, but in addition, a few workers are asked to give their opinions of the meal provided, with the aim of improving the service. During this surveillance the small sample of contractors interviewed were all extremely positive about the initiative, some claiming it had improved worker morale and the completion of tasks, and reduced absenteeism. Management has advanced convincing reasons for providing infield meals, and for not carrying out more thorough consultations with workers regarding options (for example adding the amount it costs the company to the wage, which workers are likely to opt for, but which would only indirectly address the core problem of inadequate nutrition of forest workers). There is however a possibility that concerns about the feeding programme may come up in future, so Mondi’s efforts to monitor acceptance and impact should continue to be monitored. The observation remains open.
2010: Mondi carried out a questionnaire survey amongst forest workers to evaluate the impact of the feeding scheme and gauge opinions about the provision of meals. Over 90% of respondents said they felt happier since receiving meals at work, and over 80% said they felt stronger. All contractors and workers interviewed during the survey were overwhelmingly positive about the introduction of a hot meal for all forest workers every day.
7 4.2.5 Date Recorded> 13 Oct 2009 Date Closed> 8 Nov 2010
Observation:
No UV protection provided (A007 planting and D004 spraying, Seven Oaks, (Greytown Area). Lack of risk assessment in terms of UV protection for Mondi as a whole.
Follow-up evidence:
Each Contractor’s pre-entry risk assessment includes the daily evaluation of the UV risk faced by each work team. All workers are provided with hard hats and the choice to wear a soft hat is based on the risk evaluated by the supervisor. E.g. workers planting trees may replace their hard hats with soft hats.
Mondi has also carried out a risk assessment of UV on different skin types with risk reduction measures (including e.g. long sleeves etc) and monitoring such as annual medical surveillance. The toolbox talks also discuss heat stress and the need to maintain the body well hydrated. At all sites visited, there was ample drinking water available. Observation closed.
8 4.4.1 Date Recorded> 13 Oct 2009 Date Closed>
Observation:
Mechanisation of harvesting will result in the loss of an estimated 2410 jobs, and a loss of income of R37.6 million. Although mitigation measures and wage increases associated with skilled jobs will offset these losses, the actual impact will depend on the choices made during implementation. The Mechanisation Strategy makes provision for a range of mitigation and offset measures to be applied selectively on an area basis. The development of Area based plans needs to be monitored in future surveillances, to make sure that economic considerations do not override the need to protect jobs and provide for alternative sources of income.
Mechanisation has been implemented and partially implemented at Tygerskloof and Ntonjaneni. Job losses were minimal in these Areas as a result of redeployment and Contractors having manual harvesting contracts with other companies. This observation remains open as mechanisation is ongoing.
Follow-up evidence:
9 4.2.3 Date Recorded> 13 Oct 2009 Date Closed> 8 Nov 2010
Observation:
AD 36-A-05 Page 62 of 76
OBS # Indicator Observation Detail
One of the many negative impacts of outsourcing has been that many contractors do not keep up with the required training of their workers, owing to cash flow and other management related problems. Mondi is the process of putting in place a system that will give them greater control over the provision of training. Training matrices will be provided by contractors, and Mondi will arrange and pay for the training on their behalf, with accredited service providers. Whilst this may be the right approach for contractors who are failing to provide all the necessary training, it should not be imposed on contractors who have shown they are able to manage their own training programmes. Contractors interviewed (all able to provide training to their employees) expressed their opposition to the proposal.
Follow-up evidence:
The new labour training system has been implemented. Mondi now pays directly for training, and assists contractors to link up with training providers if required. None of the contractors interviewed were opposed to having their training paid for directly by Mondi. A contractor interviewed said he was not given the option to continue to pay for labour training, but that he had accepted the system and not approached Mondi for an exemption.
10 6.7.1 Date Recorded> 13 Oct 2009 Date Closed> 8 Nov 2010
Observation:
General lack of effort to implement any re-cycling initiatives in all of the Mondi WPU and areas visited (with exception of Mountain Home Nursery).
Follow-up evidence:
Minor CAR 26 was raised since there is still a general lack of effort to recycle.
11 8.1.3 Date Recorded> 13 Oct 2009 Date Closed> 8 Nov 2010
Observation:
There is no system for monitoring of timber theft to quantify losses at the Dumbe Area. Timber theft is rife and is increasing according to the Security records and interviews with security staff, yet the volume and value of the timber theft has not been quantified for each case to determine the extent of the problem. Toverton Compartment 24 was visited where extensive theft was evident. All of the other areas checked (Piet Retief, Numbi) did have systems in place for such monitoring.
Follow-up evidence:
At Ntonjaneni, there was evidence of some timber theft in the wattle near Langfontein, but this was quite old. Records confirmed that there was theft reported in that same area. There is a process in place to report plantation losses, and follow up on these incidents (Incident Control Register) and weekly meetings. Observation closed.
12 6.3.3, 1.1.1
Date Recorded> 13 Oct 2009 Date Closed>
Observation:
Follow up on the progress with weed control of open areas, planting permits and the assessment and registration of dams (see CAR 18 regarding legal compliance).
2010 Update: Ongoing monitoring is necessary. Weed control of the open areas has shown remarkable progress, with Umfolozi area 93% in maintenance phase. Planting permits and registration of dams was not checked.
Follow-up evidence:
13 4.1.1 Date Recorded> 18 Feb 2011 Date Closed>
Observation:
AD 36-A-05 Page 63 of 76
OBS # Indicator Observation Detail
A number of contractors raised concerns that they are unable to grow their businesses or generate profit due to the extremely tightly managed costing structure Mondi uses to calculate rates, coupled with the imposition of costly operating and labour standards. It becomes questionable whether these are contracting opportunities or setting business people up to fail. Mondi is in the process of reviewing all contracts and re-tendering many of those that have been rolling over for some time. The impact of these changes to contract opportunities should be monitored in future surveillances
Follow-up evidence:
AD 36-A-05 Page 64 of 76
13. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS
Nr Comment Response
Main Evaluation
1 Improvement on long term budgets required. The lack of allocation of funds to achieve management objectives was identified during the audit and some CARs are as a result of lack of funding. The situation was immediately addressed. A closeout of findings audit was done during October and substantial budget increases were found. It is especially the case where critical management objectives were not met. E.g. open area management and labour accommodation. Further confirmation was given by head office to ensure these funds for the next five year.
2 Opposing mechanical harvesting due to increased compaction and slash.
Extensive impact assessments were done prior to the implementation of the mechanisation. Mitigating actions are available to reduce compaction. Soil monitoring indicates no substantial loss in grow medium due to compaction.
3 Burning policy:
Not burning valleys and slash hiding behind FSC.
Opposing burning of slash due to nitrogen depletion and increased soil erosion.
Fire equipment inadequate, rely on aeroplanes that don’t fly at night and in strong wind.
Inadequate fire breaks.
FSC does not prescribe burning policies to companies, but do require them to make informed decisions when deciding to burn or not to burn. All actions regarding burning must be responsible regardless if it is valleys or slash. A substantial amount is invested in alternative methods of slash management such as mulching.
Fire equipment is budgeted and maintain at each estate. Actual fires in the Melmoth area during the audits were well covered by ground crews.
Fire breaks inspected in the Iswepe area were all adequate for normal fires. This year’s devastating fires were industry wide disastrous and Mondi was no exception.
4 No sentiments and personal attack on Austrian immigrants.
SGS acknowledges the comment, but personal sentiments are outside the scope of the audit.
5 Clarifications required on Mondi’s plantations in Swaziland.
The plantations in Swaziland were all sold and are not included in the scope of this certificate.
6 Objection to calling Mondi’s forests “forests” and certify them as “forests” as they are plantations.
FSC and SGS as certifying body acknowledge the difference in opinion about the definition of “forests”.
The National Forest Act 84 of 1998 section 2 interpretation of forests includes: natural forest, woodland and plantations. The current FSC standard makes provision for the certification of plantations under the forest certification scheme and therefore the certification of Mondi’s plantations is justified.
7 Objectivity of the auditor questioned based on previous relationship with Mondi.
The auditors has never worked for Mondi, were never paid by Mondi, has not in the past consulted for Mondi, do not serve on any boards of Mondi, do not hold any shares in Mondi or have any relationship with Mondi. The auditor assisting in the CoC part of the audit had a previous relationship with Mondi that dates back more that ten years ago.
AD 36-A-05 Page 65 of 76
Nr Comment Response
8 Several RTE species mentioned that occur on estates. Oribi, Ground Hornbill, Blue Swallow. Estates mentioned were mainly Mondi Shanduka, but comment apply to Mondi BP as well.
How does Mondi establish existence of RTE species, sensitized their workers and contractors to secure the safety of RTE habitats.
Mondi had intensive studies done on the possibility of occurrence of all RTE species on their land. Through the environmental officers in each region this likelihood of occurrences are brought to the attention of management and contractors. Known occurrences of certain species are documented and the necessary management precautions are taken according to the relevant species. Mondi also interacts with the various working groups on different species.
9 Roads not clear
Roads to far apart. Fire hoses don’t reach.
Roads causes soil disturbance, reduce plantable area and increase costs due to more maintenance. Therefore roads are strategically planned for the optimum service to management. Engineers are employed to ensure and improve on the quality of the roads.
10 Weeds: How is the weed control program planned, thresholds defined, Timeframes set, implemented, budgeted, effectiveness measured and monitored.
Mondi has a very good plan with thresholds defined and timeframes set. However the company has become placid about weed control and their own control plan and this plan is not sufficiently implemented, or the effectiveness monitored. A corrective action was requested in this regard. During the closeout of findings audit a renewed effort was made on this issue and an additional budget allocate to get the program on track and within the planned timeframes. The CAR was not closed because it will require long term monitoring to verify if the company is genuine about the weed control program.
11 Allowing kraals on their property. Like many other companies and private individuals, Mondi is challenged with the current situation in South Africa where people staying on land have various different legislations protecting their rights and corporate companies have to abide by the rules. The FSC audit also covers the rights of people in the principles of the standard. In this regard Mondi has done good in managing the different processes as they are relevant.
12 How is highly sensitive grasslands on their property protected and set aside for conservation. How are they managed?
Mondi has identified all the different veld types on their property and has established the conservation status and also the percentage of the area under conservation of each veltype on their property. This information is available in the management plans. Mondi has also set aside a farm for the protection of the last remaining mistbetl grasslands in the Babanago area that is also suitable for Oribi. It is to be manages jointly by Mondi and KZN wildlife.
13 Safety &Security in villages. Lack of provision of electricity, water, firewood. People exposed to crime.
There are also positive comments made on how well these resources are provided.
This issue was found to differ from region to region and while good relationships and good social programs were done at some sites, others had CARs raised for non-compliances. During the closeout of findings audit it was found one of the areas where a substantial increase in budget allocations was made.
14 Positive commenting policy to employ locally. It is still Mondi’s policy to employ locally as far as possible.
15 Positive commenting on communication and relationships in local community.
Like the security comments, this was not uniform across the company and although a CAR was raised on stakeholder issues the community relation ships on local level was found to be good.
AD 36-A-05 Page 66 of 76
Nr Comment Response
16 Bigger investment in local development anticipated. Especially referring to maintenance of roads.
Roads was also one of the cost items that received an increase in budget allocations. New Civil engineers are employed by Mondi of whom the main focus area would be roads.
17 Outspoken support for some individuals in Mondi. And criticism of the arrogance of others.
This comment is reflected purely because it was mentioned. The audit standard itself is not able to make any staff assessments and therefore there is no comment from the audit team.
18 Promises regarding the improvement of the management of estates are not kept. These include issues such as staffing, roads, weeds, firebreaks, fire fighting capacity, slash burning,
Mondi has gone through severe restructuring during the last year prior to the audit. As normal such restructuring does have a negative impact on management, maintenance and keeping up with policies. It is mentioned as an observation, but the results were reflected in the high number of CARs the company received during the audit and the fact that it initially disqualified them from being re-certified. A follow up audit was done to re-assess the progress made with addressing problem areas. Sufficient progress was made to close many of the CARs and then recommend re-certification.
19 Reluctance from the public side to accept FSC as a Legitimate instrument, if Mondi’s claim to it is an indication of what is certifiable.
This comment is aimed at FSC and certification and not specifically to Mondi. The process covers a wide range of issues on witch companies are audited on, and sufficient objective evidence were found across the spectrum to certify good management, despite the corrective actions that is still required here and there.
20 Lack of clear policy about cattle and bees and the implementation of such a policy.
Mondi do have policies on bees and cattle and are also involved in extensive management programs on assisting communities in Cattle branding. Cattle are allowed on a controlled system with permits, law enforcements, patrols and intensive community interaction programs in place. Comments are made very non specific and therefore do not become specific stakeholder issues that can be investigated and the outcomes tested. Except for the incident that led to the temporary suspension, bees and cattle are being managed very well.
21 Planting permits are questioned. Evidence were found of problems with the planting permits and a major CAR was raised. This was reduced to minor CAR after consultation with Department of Water Affairs. The CAR remains open because it is not investigations that can be done over night. Investigations being done by Water Affairs.
22 Rehab of land that has come out of production
Farms Duikerhoek, Golden Reef, Saxony.
The farms Golden Reef and Saxony did not come out of production; a planting permit has been issued. On the farm Duikerhoek the pines are removed and the understanding is that the Melmoth soil conservation group will do 6 monthly monitoring and report back.
Surveillance 1
1 As a result of the open CAR on stakeholder interaction, a stakeholder meeting was held during the audit. The focus of the meeting was on Mondi’s constructive dealing with stakeholder issues. There was unanimous agreement that the situation had improved and that the CAR can be closed.
The CAR regarding the stakeholder interaction was closed will full consent of all parties present at the meeting.
During the meeting several additional proposals were made of which Mondi took note and will follow-up.
It was management related issues and not directed to FSC and therefore also not mentioned here.
Surveillance 2
AD 36-A-05 Page 67 of 76
Nr Comment Response
1 The property of the owner of one of the Mondi Leased farms which is due to be handed back in 2010, was inspected and the owner interviewed. He stated that he was satisfied with the work that Mondi had done on his farm.
The owner confirmed that there had been good communication with Mondi foresters and that he was happy with the state of the farm. Mondi has met the owner’s requests and the farm will be handed back to the owner in a satisfactory state in terms of weed control and re-planting of compartments.
2 The proposers of the Nosilla Ethno Botanic Garden project are still anxious to purchase the farm Nosilla in the White River Area, and needed an explanation why Mondi could not sell directly to them. The high infestation of weeds on Nosilla was also an issue.
A meeting was organised between the potential buyers, Mondi and the FSC Auditors. The sale of the Mondi Business Unit as a “Going Concern” was explained, as was the fact that one farm could not be separated out of the sale units. The fact that discussions around Nosilla had commenced prior to the decision to sell, meant that these discussions would continue with the new owners, and the same Mondi staff would still be there The sale of Nosilla to become part of the proposed botanic garden is therefore still a strong probability, but would need to be negotiated with the new owners.
Mondi is aware of the weed situation in Nosilla and the whole of the Numbi area is under a stringent weed control programme which is being closely monitored. Mondi have, however, agreed to prioritise Nosilla in terms of the weed control programme.
3 A complaint was made by a resident about unhygienic and unsafe conditions associated with an ablution block in the village. There is a sewage overflow and the manhole covers on a disused septic tank are missing and present a danger to children.
The Manager of Land, Central was present during the visit and expressed his great concern about the problem and made immediate arrangements to have it attended to.
4 The Headmaster of the KwaShuku school at Witklip commended Mondi for refurbishing an old worker village and allowing the nearby secondary school to use it for a boarding hostel. He was of the view that this has contributed to an improved Senior Certificate pass rate, as students are able to attend extra classes.
No further comment necessary.
5 A number of contractors interviewed raised concerns about the proposal by Mondi to take over the management of their training programmes. They feel this would limit the control they have over their businesses and create unnecessary delays and administrative complexity to the delivery of training.
Mondi has not yet begun to implement their proposal to take over the management of contractor training. There was openness to the suggestion that contractors who are able to manage their own training be allowed to continue to do so. An observation was raised to check this in the next surveillance
6 A harvesting contractor in White River raised concerns about the system for adjusting rates for harvesting compartments with low strippability. He was also concerned about the high handedness and lack of cooperation from the local management.
A fair system for adjusting rates in compartments with low strippability is in place and the contractor was paid an adjusted rate for compartments where this problem came up.
The local manager has made efforts to resolve the conflict with this contractor, and has brought in third parties to assist. The third parties (the Mondi compliance facilitator and an independent consultant who is providing business advice and support to the contractor) confirmed that every effort had been made by the local management to address the concerns raised by the contractor. Three other contractors were interviewed and all said they considered the local management to be cooperative, especially when it comes to negotiation and adjusting of rates.
Surveillance 3
AD 36-A-05 Page 68 of 76
Nr Comment Response
1 ZAF Contractors
All labour transport vehicles were refitted at great expense to meet the new Mondi requirements. Now the specs have been changed, and it will be necessary to get new vehicles. This is going to be prohibitively expensive. Concerned that the new directives will be imposed without taking contractors concerns into account.
Area Manager
Appreciates the concern raised, and gives assurance that Mondi will be willing to negotiate the phasing new vehicles in and an increase in rates to accommodate the additional expense.
2 Contractors raised concerns about the amount of work being cut back, and the impact this has on cash flow and profitability. This concern was raised by Nursery Contractor, Weed Clearance Contractor, and Catering Contractor
Contracts specify amount of work, and the terms under which this can be adjusted up or down. Contracts usually make provision for fixed and variable portions of the rate.
This is a wider problem that relates to Mondi’s need to control costs and ensure that labour and performance standards are met which results in a squeeze on contractor profit margins.
3 ZAF Contracting
Contractors welcome the use of costing spreadsheets to set and negotiate fair rates for contract work, and confirmed that Area mangers are willing to discuss and address concerns that arise.
No comment required
4 Ebomvini community
A number of tenant households have to walk very long distances to get water.
The homesteads of this community are scattered over a large area and located down steep slopes a considerable distance from roads. The people have indicated they do not want to move to a central place near to the school. A water supply scheme had been planned by the Municipality. Mondi is working with the Municipality to supply water to this and other tenant villages.
Surveillance 4
AD 36-A-05 Page 69 of 76
14. RECORD OF COMPLAINTS
Nr Detail
Complaint: Date Recorded > 27 August 2007
1 Mondi has over planted Eucalyptus within the catchment of the Mapopoma river to such an extend that there is no winter flow whatsoever for down stream users. The stream used to yield one cusec in winter and was a strong permanent river. This is in contravention of the 1998 Water Act which calls for a fair allocation of water resources.
Objective evidence obtained:
Prior to aforestation of new areas, all aspects of and impacts on catchment hydrology are considered by the License Assessment Advisory Committee, which is chaired by the Department of Water Affairs and Forestry (DWAF). The conditions attached to the license/permit are included in the planting plan and special care is taken to minimise the impact on wetlands and riparian areas. Monitoring is carried out by DWAF and the License Assessment Advisory Committee during external audits.
A special field visit was arranged during the audit to investigate the complaint. The auditors were accompanied by a Hydrologist to interpret the evaluations of the findings in field. Various documents including hydrologist studies of the past, communication between the complainant and Mondi, Communication with Water Affairs, minutes of meetings etc were verified. Mondi also provided maps of all their timber in the area. It was found that various companies including Mondi as well as the complainant himself has plantations in the catchment area. The hydrologist report confirms that it is a known fact that plantations have a negative effect on stream flow. The owner also extracts water form the river. The scale of plantation forestry in the headwater area of the Mapophoma catchment, as a proportion of total available land, has significantly reduced streamflow. Confidence in this finding is high.
Total flows will not be enhanced by gabions in the erosion channel above Diepkloof farm, but dry season, or low flows, may benefit from such an approach. Gabions would however be a useful method for withholding sediment in the upper reaches of the Mapaphoma catchment.
Close-out information: Date Closed > 20/9/2008
Mondi has negotiated with the complainant and came to a negotiated agreement. They also undertook an independent geohydrological study through the university of Natal and will based on the outcome of the study remove trees as is necessary.
2 Complaint: Date Recorded > 27 August 2007
Mondi has unlicensed timber on the farms Prospect and Remainder 1 of Keurplaats, also known as Barsham Fell.
Objective evidence obtained:
Problems regarding the planting permits for the above mentioned farms were found. Initially a major CAR was raised. After consultation and written confirmation with Department of Water Affairs and Forestry this was reduced to a minor, but remains open as CAR 18.
Close-out information: Date Closed > 20/9/2008
Mondi engaged in negotiations with the department to solve the problem. Currently the department does not have the capacity to deal with the situation and Mondi undertook to put all the data on a database that can be used by both the company and the department. It was discussed with the claimant and they accept.
3 Complaint Date Recorded > 27 August 2007
On the farm Rusverwacht Mondi has sheet burned pine brush wood. The replanted rows of timber run up and down the slope, resulting in major, resulting in major erosion in the inter-row. This practice seems to be the norm for mondi, as there are sheet burns every year. When challenged they say the wind “turned”
Objective evidence obtained:
Slash burning is not unique to the mentioned farm and Mondi do burn slash on their estates. The specific farm was not visited but the issue addressed at various other sites. Two respective Major CARs were raised on this issue. One deals with the burning permits that inadequately control the conditions under which slash are permitted to be burned. The other addresses the inadequate post burn monitoring and corrective actions that is not done.
AD 36-A-05 Page 70 of 76
Nr Detail
Close-out information: Date Closed > 30/10/2007
All foresters responsible for slash burning were retrained. Training records were verified. All the required info on the permit was reiterated and the importance emphasized. The sources and methods where to and how to retrieve the data was explained All foresters have access to the data and maps on computer, Permits for the planned burns in Greytown area was verified and the available planning data was filled in. Monitoring of the effects of fires were included in the training referred to in CAR1. Monitoring protocol was updated and the Best Operating Practices (BOPs) adjusted to include the criteria for evaluation. A slash burn register was introduced that contain the effects of the fires and the mitigating required. All fires of the past year were evaluated and the results entered on the register.
4 Complaint: Date Recorded > 27 August 2007
Mondi has no control over cattle, which they allow to graze in their plantations. The cattle should be branded (it is law), and herded. Often un-herded cattle at night wander onto busy main road and are hit by passing cars, not to mention trespassing on privately owned land.
Objective evidence obtained:
A meeting was held with the complainant during the audit. Mondi”s extensive cattle branding program and the control mechanisms were discussed. The areas are not fenced. Stray cattle that occur on the road and private farms could be stray cattle from anywhere and is not necessarily “permitted” by Mondi.
Close-out information: Date Closed > 5/9/2007
The meeting was held with the complainant and the issue resolved.
5 Complaint Date Recorded > 27 August 2007
Mondi has been certified for FSC for ten years, yet they are still ten years away from having their valleys cleared of alien vegetation.
Objective evidence obtained:
Open area management and specifically alien weed control is still a concern, not only to the complainant, but also to the certifying body. Despite a very good and comprehensive action plan to bring it under control within a reasonable and measurable timeframe the success of implementation is lacking. A CAR was raised for the lack of resources allocated to implement the plan and for inadequately controlling progress on the issue. During the closeout of findings audit that was held in October the specific valleys that was referred to was cleared and a substantial additional budget allocation was made. Head office confirmation of the availability of the funds for the next five years was also available. The CAR remains open as it is not an issue that can be closed out in such short time.
Close-out information: Date Closed > 20/9/2008
During the past year Mondi has invested a large amount of money into clearing open areas and also commit the money for the initial clearing of all open areas. A stakeholder meeting was held during the audit and stakeholders and the complainant agreed that there has been a remarkable input from Mondi’s side.
AD 36-A-05 Page 71 of 76
ANNEXURE A
Description of FMUs:
Description Ownership Area (ha) Longitude E/W Latitude N/S
Northern Region
De Kaap
Owned 7214.6 30d52'30.75"E
30d51'09.49"E
30d49'12.39"E
25d40'23.92"S
25d45'45.73"S
25d37'40.92"S
Satico
Leased 15627.7 31d27'32.61"E
31d22'23.09"E
31d24'56.99"E
31d27'32.14"E
25d37'22.75"S
25d41'30"S
25d37'40.94"S
25d35'59.54"S
Hazyview
Leased 732.3 31d02'43.33"E
31d00'13.64"E
24d57'53.34"S
24d55'36.82"S
Owned 4243.3 30d59'38.3"E
31d01'34.09"E
30d59'27.35"E
31d01'13.06"E
30d56'00.67"E
31d02'20.15"E
24d55'25.61"S
24d57'10.96"S
24d54'47.88"S
24d56'33.1"S
24d58'01.84"S
25d00'06.22"S
White River
Leased 3044.5 30d49'20.76"E
30d53'02.08"E
30d51'33.7"E
30d57'04.79"E
25d15'03.19"S
25d11'56.04"S
25d10'41.51"S
25d06'40.01"S
Owned 8217.1 30d43'53.51"E
30d44'17.3"E
30d54'16.78"E
31d05'30.63"E
31d01'16"E
31d01'38.7"E
31d04'34.59"E
30d59'49.31"E
31d02'52.59"E
31d02'54.51"E
31d00'38.06"E
31d03'33.75"E
30d59'55.48"E
30d59'27.61"E
31d04'57.86"E
30d59'51.53"E
31d01'38.32"E
31d01'57.76"E
30d54'43.69"E
30d41'48.67"E
30d55'41.76"E
31d01'23.66"E
31d02'33.49"E
25d20'57.28"S
25d19'50.37"S
25d20'52.92"S
25d19'04.64"S
25d16'52.45"S
25d15'53.67"S
25d18'36.95"S
25d18'21.9"S
25d17'48.14"S
25d17'23.73"S
25d18'05.19"S
25d13'41.85"S
25d17'19.1"S
25d15'24.96"S
25d18'42.63"S
25d14'58.28"S
25d12'58.4"S
25d13'29.31"S
25d11'24.82"S
25d20'32.93"S
25d05'29.61"S
25d10'11.28"S
25d10'42.97"S
Sjonajona
Owned 15540.6 30d38'40.9"E
30d00'11.12"E
25d45'12.7"S
25d33'04.99"S
Soekmekaar Leased 1845.3 Uncertified
AD 36-A-05 Page 72 of 76
Description of FMUs:
Description Ownership Area (ha) Longitude E/W Latitude N/S
Owned 150.4 Uncertified
Louis Trichardt Leased 1371.9 Uncertified
Tzaneen Leased 942.2 Uncertified
Owned 3616.2 Uncertified
Central Region
Engode
Leased 3227.2 30d49'49.95"E
30d32'53.78"E
30d48'49.4"E
30d48'57.97"E
27d19'23.75"S
27d13'53.61"S
27d26'22.53"S
27d21'45.36"S
Owned 7172.8 30d50'18.21"E
30d44'40.78"E
30d54'57.73"E
30d46'07.87"E
30d51'07.34"E
30d42'49.13"E
30d43'08.45"E
30d43'27"E
30d48'03.91"E
30d44'30.72"E
30d54'41.63"E
30d52'33.45"E
30d49'47.01"E
30d48'04.72"E
27d22'04.16"S
27d19'25.69"S
27d23'13.41"S
27d20'25.01"S
27d22'04.63"S
27d18'03.18"S
27d19'11.31"S
27d20'27.12"S
27d22'14.42"S
27d21'17.78"S
27d25'15.8"S
27d24'15.38"S
27d23'19.23"S
27d21'04.37"S
Moolman
Leased 690.2
Owned 5039.1 30d50'42.92"E
30d53'51.7"E
30d57'32.47"E
30d58'34.07"E
30d57'27.7"E
30d56'07.32"E
27d12'36.82"S
27d07'42.25"S
27d08'56.93"S
27d12'17.86"S
27d16'00.57"S
27d15'10.73"S
Pivaan
Leased 4229.5 30d49'30.72"E
30d48'47.95"E
27d32'41.04"S
27d34'58.6"S
Owned 10292.9 30d44'59.28"E
30d41'00.15"E
30d31'04.27"E
30d29'13.51"E
30d37'38.41"E
30d47'45.52"E
27d28'06.44"S
27d28'57.6"S
27d33'39.35"S
27d27'06.08"S
27d28'38.01"S
27d33'11.06"S
Amsterdam
Leased 2214.0 30d45'17.06"E
30d42'56.35"E
26d36'35.74"S
26d33'24.64"S
Owned 6504.2 30d34'12.38"E
30d46'51.4"E
30d46'51.51"E
30d45'31.42"E
30d43'55.26"E
30d30'54.01"E
30d31'16.47"E
26d22'55.45"S
26d34'27.95"S
26d35'39.27"S
26d35'14.99"S
26d36'21.75"S
26d37'48.86"S
26d36'05.56"S
The Bends
Owned 13907.9 30d32'27.32"E
30d42'44.69"E
30d35'57.29"E
26d45'56.54"S
26d51'14.96"S
26d44'32.3"S
AD 36-A-05 Page 73 of 76
Description of FMUs:
Description Ownership Area (ha) Longitude E/W Latitude N/S
30d37'09.89"E
30d39'23.52"E
30d40'48.82"E
26d48'10.24"S
26d50'01.36"S
26d48'56.44"S
Zoar
Leased 1814.6 30d33'46.91"E
30d34'36.58"E
26d48'22.72"S
26d50'35.17"S
Owned 12605.2 30d23'16.09"E
30d28'06.54"E
30d31'05.2"E
30d34'03.9"E
30d22'06.31"E
30d30'00.64"E
30d28'17.81"E
26d43'41.07"S
26d51'17.54"S
26d49'33.3"S
26d49'27.94"S
26d51'52.29"S
26d47'45.26"S
26d49'10.41"S
Derby Leased 356.0 30d54'13.75"E 26d53'01.8"S
Owned 7428.9 30d46'40.34"E
30d48'15.03"E
30d46'56.88"E
30d52'27.95"E
30d51'32.14"E
30d50'29.67"E
30d42'58.71"E
30d43'42.04"E
30d46'00.45"E
30d47'48.79"E
30d52'39.17"E
30d48'01.61"E
26d53'30.7"S
26d51'40.72"S
26d51'07.59"S
26d53'05.43"S
26d49'47.84"S
26d51'34.91"S
26d52'55.44"S
26d53'37.39"S
26d54'21.35"S
26d49'17.24"S
26d50'07"S
26d53'00.4"S
Mooihoek Owned 10357.3 30d43'29.93"E
30d47'19.19"E
30d45'28.35"E
30d46'43.06"E
30d48'34.78"E
30d46'06.6"E
30d44'55.41"E
30d50'46.06"E
30d51'08.97"E
30d49'37.08"E
30d50'04.9"E
30d48'21.25"E
30d50'25.23"E
30d49'20.49"E
30d46'42.7"E
27d01'00.11"S
26d55'54.07"S
26d58'04.12"S
26d56'47.48"S
26d54'14.87"S
26d59'17.6"S
27d00'08.04"S
26d53'45.55"S
26d54'59.49"S
26d55'01.77"S
26d56'44.26"S
26d56'34.49"S
26d55'16.86"S
26d57'37.44"S
27d00'36.61"S
Tower Forest
Owned 6832.5 30d37'40.86"E
30d35'47.47"E
30d36'22.62"E
27d01'55.07"S
26d56'25.64"S
27d02'58.39"S
Vrede
Leased 1556.4 30d45'24.37"E
30d49'02.2"E
30d51'51.18"E
27d05'28.76"S
27d04'52.89"S
26d55'17.18"S
Owned 7061.8 30d55'33.84"E
30d54'14.32"E
30d52'59.09"E
30d52'27.61"E
30d54'22.17"E
30d49'14.88"E
26d59'25.08"S
26d56'08.74"S
27d00'29.43"S
26d56'07"S
27d01'24.16"S
27d05'44.92"S
AD 36-A-05 Page 74 of 76
Description of FMUs:
Description Ownership Area (ha) Longitude E/W Latitude N/S
30d55'03.14"E
30d53'12.96"E
30d51'13.63"E
26d57'51.79"S
26d57'09.01"S
27d03'12.7"S
Hilton Heritage
Owned 6406.5 31d16'24.34"E
31d16'09.42"E
31d18'29.66"E
31d14'57.03"E
31d12'48.43"E
27d47'16.93"S
27d48'14.67"S
27d50'51.38"S
27d49'26.67"S
27d47'59.91"S
Louwsburg
Owned 6523.5 31d23'17.33"E
31d15'33.22"E
27d35'33.52"S
27d38'16.7"S
Welmountain
Leased 2114.3 31d18'14.72"E
31d03'08.35"E
31d02'59.56"E
31d16'37.57"E
27d55'26.89"S
27d46'13.03"S
27d48'34.76"S
27d50'19.58"S
Owned 7318.0 31d06'26.76"E
31d05'60"E
31d20'29.91"E
31d03'16.94"E
31d02'41.2"E
31d06'04.54"E
31d00'06.01"E
31d04'33.93"E
31d07'31.12"E
31d02'49.3"E
31d18'23.08"E
31d16'56.55"E
31d18'32.23"E
31d20'41.04"E
31d11'59.19"E
27d57'27.94"S
27d55'18.97"S
27d54'51.79"S
27d51'46.18"S
27d50'59.53"S
27d56'20.31"S
27d51'51.77"S
27d55'38.48"S
27d57'23.94"S
27d53'02.83"S
27d52'46.66"S
27d51'30.86"S
27d54'13.6"S
27d57'21.08"S
27d49'32.32"S
Southern Region
Ahrens
Owned 16402.8 30d43'17.99"E
30d48'52.52"E
30d51'10.51"E
30d48'58.41"E
30d50'37.76"E
30d55'58.69"E
30d57'44.96"E
30d52'33.2"E
30d53'50.63"E
30d42'56.99"E
30d47'24.74"E
29d09'13.94"S
29d06'10.73"S
29d03'39.47"S
29d01'55.79"S
28d58'12.93"S
29d01'08.13"S
29d02'43.1"S
29d03'14.51"S
29d03'10.48"S
29d00'52.7"S
28d56'34.95"S
Seven Oaks
Leased 5027.1 30d28'34.7"E
30d34'45.45"E
30d15'45.5"E
29d10'54.48"S
29d02'00.44"S
29d13'46.34"S
Owned 9284.4 31d05'37.84"E
30d23'16.19"E
30d31'18.35"E
30d30'33.57"E
30d39'47.87"E
30d41'02.6"E
30d27'17.42"E
29d20'57.76"S
29d09'30.25"S
29d03'17.32"S
29d01'14.87"S
29d13'01.14"S
29d11'24.5"S
29d13'11.96"S
AD 36-A-05 Page 75 of 76
Description of FMUs:
Description Ownership Area (ha) Longitude E/W Latitude N/S
30d30'50.05"E
30d30'40.84"E
30d28'49.49"E
29d08'54.05"S
29d05'42.86"S
29d08'07.83"S
Babanango Owned 23302.5 31d15'16.42"E
31d11'29.6"E
31d12'39.38"E
31d06'54.04"E
31d07'58.09"E
31d05'10.47"E
31d02'44.17"E
31d03'57.02"E
28d31'15.11"S
28d36'06.72"S
28d31'09.02"S
28d24'35.32"S
28d30'46"S
28d27'38.53"S
28d23'36.16"S
28d22'47.39"S
Melmoth Owned 13072.6 31d28'16.56"E
31d24'27.18"E
31d21'26.68"E
31d17'58.7"E
31d15'35.02"E
31d18'11.8"E
28d39'26.65"S
28d36'07.15"S
28d35'12.3"S
28d37'04.19"S
28d36'19.59"S
28d32'38.29"S
Greenhill Leased 4315.6 30d03'08.37"E
30d09'15.46"E
30d09'31.47"E
30d14'46.72"E
29d56'07.93"S
29d47'54.31"S
29d54'34.21"S
29d47'01.83"S
Owned 8376.0 29d57'51.68"E
30d16'29.9"E
29d58'51.76"E
30d17'41.84"E
30d22'01.69"E
30d13'44.92"E
30d07'29.75"E
30d10'56.11"E
30d09'20.1"E
29d33'48.13"S
29d33'48.52"S
30d37'24.72"S
29d51'22.93"S
29d51'51.85"S
29d50'16.54"S
29d47'15.6"S
29d51'13.01"S
29d51'20.82"S
New Hanover Leased 5522.0 30d27'54.03"E
30d34'35.86"E
30d27'42.11"E
30d30'47.15"E
30d30'24.14"E
29d21'48.01"S
29d16'13.51"S
29d20'43.37"S
29d19'02.94"S
29d16'42.78"S
Owned 3927.6 30d35'47.71"E
30d27'23.35"E
29d18'56.55"S
29d18'57.68"S
Kwambonambi Owned 7629.9 32d04'19.84"E
32d07'00.56"E
32d10'59.26"E
32d07'05.69"E
32d05'29.37"E
32d03'11.75"E
28d34'27.4"S
28d34'45.3"S
28d35'51.26"S
28d36'45.25"S
28d38'01.59"S
28d36'47.33"S
Mtubatuba Owned 3998.2 32d11'23.53"E
32d13'45.36"E
32d15'59.44"E
32d10'18"E
32d09'28.43"E
32d10'08"E
32d13'26.29"E
32d14'53.2"E
28d23'31.95"S
28d25'01.43"S
28d23'54.4"S
28d25'15.64"S
28d27'57.32"S
28d31'17.48"S
28d31'08.93"S
28d31'55.05"S
AD 36-A-05 Page 76 of 76
Description of FMUs:
Description Ownership Area (ha) Longitude E/W Latitude N/S
Mtunzini Owned 3919.6 31d46'47.28"E
31d42'51.65"E
31d43'01.59"E
31d39'42.56"E
31d40'09.17"E
28d54'46.02"S
28d59'45.36"S
28d58'39.37"S
29d01'02.88"S
29d02'05.03"S
Nseleni Owned 5068.7 32d02'56.12"E
32d01'49.76"E
32d03'21.89"E
32d01'55.85"E
32d00'23.67"E
32d01'42.34"E
32d04'12.34"E
31d58'35.16"E
31d58'36.96"E
31d57'50.33"E
31d56'51.88"E
31d59'56.7"E
28d39'26.18"S
28d40'39.83"S
28d41'00.72"S
28d41'58.51"S
28d42'35.39"S
28d43'27.5"S
28d43'01.13"S
28d41'44.02"S
28d43'30.53"S
28d43'48.25"S
28d45'00.33"S
28d45'25.85"S
Nyalazi Leased 407.7 32d20'11.92"E 28d11'56.3"S
Owned 3658.7 32d19'51.91"E
32d18'03.32"E
32d17'27.26"E
32d14'55.56"E
28d12'50.95"S
28d14'57.5"S
28d17'47.87"S
28d18'38.59"S
End of Public Summary