VPAs once agreed then will have FLEGT (Forest Law Enforcement Governance and Trade) licence. Cameroon Congo Gabon Liberia Ghana Indonesia/Vietnam/Malaysia have pledged but not yet signed.
Access to Information Description of product bought Country of harvest Quantity of material procured Name and address of Supplier Documents proving compliance with local legislation Risk Assessment Compliance with applicable legislation which may include Chain of Custody certification or Verified Legal Schemes (VLS) that are 3 rd party verified. No illegal harvesting of specific tree species. No illegal harvesting or practices in country of harvest. Complexity of supply chain Risk Mitigation Measures and procedures to minimise effectively the risk of illegality including: 3 rd party verification, additional documentation or changing supplier.
DEFRA are drafting and adoption of additional legislation covering detail on monitoring organisations and due diligence systems – to be finalised by June 2012. In short no MO’s have been authorised!
A competent authority has now been appointed – it is National Measurement Office (formerly weights and measures) Defra’s Animal Health & Veterinary Laboratories Agency (AHVLA) will be the designated Competent Authority for implementing the FLEGT licensing system in the UK. The UK Border Agency will be the enforcement authority for the regulations at the border . Away from the border AHVLA Wildlife Inspectors will have a role in checking compliance with the domestic regulations, with the police being responsible for investigating breaches and taking forward charges and prosecutions.
If you are a 'Trader' only, the EUTR requires that due diligence is carried out. If a small sub-contractor supplies you with timber and it was proven that the timber was in fact illegally sourced, because of their failing to carry out their own due diligence, your company would be at risk and be caught up in any investigation. Although it would be highly unlikely that a fine would be imposed, your industry reputation will be at risk.
By using ALTW you can be assured that a robust Due Diligence process has taken place. We are signatories to the Timber Trade Federations Responsible Purchasing Policy that is aligned to meet the EUTR obligations for ‘Operators’ (First placers). We hold FSC and PEFC Chain of Custody across all our Timberworld’s. Not all suppliers will have a Due Diligence system in place. On all timber contracts or purchase orders stipulate that “ All timber supply must comply with EUTR regulations ”
Who bought product from? I.e. Purchase orders – description of product. Who sold it to? i.e. Sales invoices
In terms of the 'who goes to jail'...if a due diligence system was in place and it failed to identify illegal timber being brought into the EU.....then it is more likely that a fine would be imposed that is proportionate to the 'crime'.....hence the industry reputational risk is higher...also beware of the ‘interested party’ brigade that will no doubt follow an illegal shipment to its end user!
Sustainability in Timber
Arnold LaverSustainability Seminar
Overbury & Morgan Lovell Sustainability Programme Neil Pike Steve Smith
• What is Sustainability?• Our sustainability programme• EUTR Regulations
PEOPLE PLANET PROFI T SIX TOTAL COMMITMENTS1.Health & Safety 3.Energy & Carbon 5. Procurement2.Training & Education 4.Waste 6. Employment
What is it?• “Sustainability” means different things to different people• The majority of construction personel still associate sustainability with ‘environmental & energy’ initiatives• Many of our clients are extremely advanced in their sustainability programmes which embrace: Community Energy EnvironmentalProcurement Social Charity Health & Safety Staff Wellbeing
What is our sustainability vision?100% recommendedTherefore we need to develop a flexible sustainability framework which enables us to deliver for ourClients – Staff - Suppliers
What are our key sustainability drivers?1.Provide our clients with new sustainablealternatives2.Engage with our suppliers and tradecontractors to develop sustainableinnovations3.Challenge the status quo of how weprocure and deliver our projects
Overbury aspire to developing our Overbury are committed toenvironmental management to minimise progressively improving the waste, enhance energy efficiency and health and safety of our reduce our environmental impacts in employees and assisting those everything we do. who work on our sites or interface with us to do the same Overbury recognises that talented people are the key to success. We are committed to looking after our staff to create a effective work-life balance. Overbury’s office and site activities Overbury have developed a impact on local communities. We are sustainable supply chain over many committed to working with years. We are committed to communities to enhance employment offering ethically sourced products opportunities and developing a better and services for our clients. environmental.
Sustainable Integrated education working Moving boundariesEngaging local suppliers Enhanced communication Radical problem solving Changing Sharing attitudes Technology
Points to be coveredWhy is it important to you?What is the timescale?What are your obligations?What is the role of Monitoring Organisations?Who will enforce the EUTR?What are the penalties for not complying?What should you, the buyers be doing?What information is needed from enquiry to order?What assurances can Lavers offer?Q & A’s
What is the EUTR?• This is the European Union Timber Regulation• It covers the importation of any timber based product into the EU• It is primarily focused on Tropical Hardwoods and Far Eastern/Chinese Plywoods• Voluntary Partnership Agreements (VPAs) have been signed between EU and five other countries• China made no comment on pledge
Why is it important to you?• Prohibition on the first placing of illegal timber that has been illegally harvested on the EU market
What is the timescale?• The regulation comes into effect on 3 rd March 2013
What are your obligations?• Your obligations are determined by whether you are a ‘Trader’ or an ‘Operator’• The likelihood is that you are a Trader
Operators• This is defined as those who first place timber and/or timber-based products onto the EU market.• Must have a Due Diligence system in place comprising of: • Access to Information • Risk Assessment • Risk Mitigation
What is the role of Monitoring Organisations?• Maintain and regularly evaluate a due diligence system and grant operators the right to use it• Checks that operators are using it’s due diligence system properly• Takes appropriate action if an operator is not using it’s due diligence system properly• Provide 3rd party credibility to the due diligence system process
Who will enforce the EUTR?• National Measurement Office Risk and intelligence-based approach to enforcement Carry out checks on operators and monitoring organisations to verify compliance Advise and provide guidance on complying with the regulation
What are the penalties for not complying?• Fines proportionate to: – the environmental damage – the value of the products – the tax losses – economic detriment caused• Seizure of the goods• immediate suspension of authorisation to trade• Imprisonment (for serious violation)
Traders• This is defined as those who sell or buy on the EU markets any timber and/or timber-based products that have already been placed onto the EU market by an operator.• All ‘Traders’ throughout the supply chain must keep records of who they have purchased from and (if applicable) who they have supplied too.• Records must be kept for a minimum of FIVE years
What should you be doing?• Gain a basic understanding of EUTR and what your obligations are to comply.• Establish if you are a ‘Trader’, ‘Operator’ or both• Carry out a level of Due Diligence even if you are a ‘Trader’. Company image is everything!• Check delivery notes and invoices for correct specification• Add note to purchase documentation along lines of “All timber supply must comply with EUTR Regulations”
What information is needed from enquiry to order?• Ensure that your chosen supplier has FSC and PEFC accreditation• Ensure that your chosen supplier adopts a Due Diligence system such as the TTF Responsible Purchasing Policy to mitigate risk• Specify FSC or PEFC certified products at time of enquiry / order
What assurances can Lavers offer?• We are both ‘Traders’ and ‘Operators’ and understand the EUTR requirements for both.• We have representation on various trade federation committees including Board level and the EUTR is on the agenda• We hold FSC and PEFC Chain of Custody• We operate a robust Due Diligence system that is 3rd party verified on an annual basis• We have introduced a Supplier Charter
Our mission ‘To be the first choice supplier of certified timber and timber based products in the UK, by making it easy for our customers to trade with us’
Who are we?• A timber importer and merchant• Established 1920• Turnover approx. £100m• A family business• 13 branches / multi-regional• 550 personnel• Unique position within the marketplace• Expansive product range - held in stock• Highly trained and experienced personnel
Why are we different?Service• Staff : trained experts - “the best in the business”Supply Chain Management• Robust supply chain• Partnership approach• Product innovation• Market evolution
Partnerships - we develop genuine long termpartnerships with our suppliers .. Just some of our leading supply partners
Why are we different?Logistics• Strategically located very large depots• Significant quantities of stock• Local services - machining / treatment / bespoke• National production centre• Rapid response delivery - 24/48hrs• Vehicle tracking
Why are we different? Corporate systems• Progressive approach to IT solutions• Mobile data• Electronic trading – EDI / COINS / TRADEX• Extranet• E-trading
Environmental PolicyOur commitment; ‘to help preserve the world’s forests and promote effective forestry management’.• Over 96% of the material we supply is certified• Full Chain of Custody• CPET (Central Point of Expertise for Timber)• FSC, PEFC, CSA, MTCC, MTCS & SFI• RPP
Chain of Custody• Chain of Custody certification provides evidence of an unbroken chain from the forest to product.• Chain of Custody certification is required within every link in the Supply Chain.• The Chain of Custody is broken when legal ownership of the product is taken by any party which is not accredited.• Chain of Custody certification requires 3rd Party accreditation by a recognised certification organisation (BM Trada Certification Ltd).
TTF Responsible Purchasing PolicyThe Responsible Purchasing Policy requires a Company Policy with environmental commitments towards procurement activities. This involves:• a Risk Assessment procedure to evaluate a suppliers ability to support Company Policy.• a Management Report to summarise the achievements made.• an annual 3rd Party audit to ensure compliant to the policy and continuous improvement is being achieved.
Our service promiseBy working in conjunction with our customers weendeavour to ensure that;• We provide a professional, helpful and friendly service• All materials are delivered correct, in full and on time•Materials supplied are fit for purpose – we will ensurethat the right material is provided for each application•We look to provide product and service innovation wherepossible• Any problems are dealt with quickly and effectively• We listen to our customers
London 2012Gold medal for timber supply• Over 50% of all timber used• Four times more than next supplier• Collaborative approach• Making it ‘easy’ for the customer• Legacy for our company