Doc. Number: AD 36-A-01

Doc. Version date: 1 February 2005

SGS QUALIFOR (Associated Document)

Page: 1 of 53

SGS QUALIFOR, Unit 5 Mifa Park, 399 George Rd, Randjespark, Midrand, South Africa CONTACT PERSON: Programme Director, Tel: +27 (0)11 652 1441, Fax: +27 (0)11 652 1403

WWW.SGS.COM/forestry

FOREST MANAGEMENT CERTIFICATION REPORT

SSEECCTTIIOONN AA:: PPUUBBLLIICC SSUUMMMMAARRYY

Project Nr.: 6528-ZW

Client: The Wattle Company Limited

Web Page: www.wattle.co.zw

Address: P.O. Box 250, Mutare,

Country: Zimbabwe

Certificate Nr. SGS-FM/COC-000655 Certificate Type: Forest Management

Date of Issue 05 June 2006 Date of expiry: 21 March 2011

Scope: The management of exotic Pine, Eucalyptus and Wattle plantations on Nyanga and Dunsinane Estates in Manicaland Province of Zimbabwe, and the manufacture and sale of FSC Pure sawn timber, mouldings and structural finger jointed products from the Nyanga Sawmill and operating sub-sites. (Using the transfer system.)

Company Contact Person:

Alois Mabutho

Address: P.O. Box 250, Mutare, Zimbabwe

Tel: 263 20 63821

Fax 263 20 64564

Email: Mabuthoa@wattle.co.zw

Evaluation dates:

Main Evaluation 31 January to 4 February 2006

Surveillance 1 5-7 March 2007

Surveillance 2 24 -25 March 2009

Surveillance 3

Surveillance 4

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TTAABBLLEE OOFF CCOONNTTEENNTTSS

1. SCOPE OF CERTIFICATE ...........................................................................................................5 2. COMPANY BACKGROUND.........................................................................................................7

2.1 Ownership ...................................................................................................................................... 7 2.2 Company Key Objectives................................................................................................................ 7 2.3 Company History ............................................................................................................................ 8 2.4 Organisational Structure ................................................................................................................. 8 2.5 Ownership and Use Rights ............................................................................................................. 9 2.6 Other Land Uses ............................................................................................................................ 9

3. FOREST MANAGEMENT SYSTEM...........................................................................................10 3.1 Bio-physical setting....................................................................................................................... 10

3.1.1 Geology ......................................................................................................... 10 3.1.2 Topography.................................................................................................... 10 3.1.3 Soils............................................................................................................... 11 3.1.4 Hydrology....................................................................................................... 11 3.1.5 Climate .......................................................................................................... 12 3.1.6 Rainfall........................................................................................................... 12 3.1.7 Temperature .................................................................................................. 13 3.1.8 Wind .............................................................................................................. 13

3.2 History of use................................................................................................................................ 13 3.3 Planning process .......................................................................................................................... 13 3.4 Harvest and regeneration ............................................................................................................. 14 3.5 Monitoring processes.................................................................................................................... 16

4. SOCIO-ECONOMIC AND ENVIRONMENTAL CONTEXT ........................................................16 4.1 Social aspects .............................................................................................................................. 16 4.2 Environmental aspects ................................................................................................................. 17

4.2.1 Flora .............................................................................................................. 17 4.2.2 Weeds and Invader Species .......................................................................... 17 4.2.3 Conservation Areas ....................................................................................... 17

4.3 Administration, Legislation and Guidelines ................................................................................... 18 5. CHANGES IN MANAGEMENT, HARVESTING, SILVICULTURE AND MONITORING...........19 6. PREPARATION FOR THE EVALUATION.................................................................................19

6.1 Schedule....................................................................................................................................... 19 6.2 Team ............................................................................................................................................ 20 6.3 Checklist Preparation.................................................................................................................... 20 6.4 Stakeholder notification ................................................................................................................ 20

7. THE EVALUATION .....................................................................................................................20 7.1 Opening meeting .......................................................................................................................... 20 7.2 Document review.......................................................................................................................... 20

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7.3 Sampling and Evaluation Approach.............................................................................................. 21 7.4 Stakeholder interviews.................................................................................................................. 21 7.5 Summing up and closing meeting................................................................................................. 22

8. EVALUATION RESULTS ...........................................................................................................22 PRINCIPLE 1: Compliance with law and FSC Principles....................................................... 22 PRINCIPLE 2: Tenure and use rights and responsibilities..................................................... 23 PRINCIPLE 3: Indigenous peoples’ rights ............................................................................. 23 PRINCIPLE 4: Community relations and workers rights ........................................................ 24 PRINCIPLE 5: Benefits from the forest................................................................................. 25 PRINCIPLE 6: Environmental impact ................................................................................... 26 PRINCIPLE 7: Management plan .......................................................................................... 28 PRINCIPLE 8: Monitoring and evaluation.............................................................................. 31 PRINCIPLE 9: High Conservation Value Forests .................................................................. 32 PRINCIPLE 10: Plantations..................................................................................................... 33

9. CERTIFICATION DECISION ......................................................................................................34 10. MAINTENANCE OF CERTIFICATION.......................................................................................35 11. RECORD OF CORRECTIVE ACTION REQUESTS (CARs) .....................................................37

11.1 CAR’s open from the previous certificate...................................................................................... 37 11.2 New CAR’s raised during the reassessment:................................................................................ 37

12. RECORD OF OBSERVATIONS .................................................................................................46 13. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS............................................51 14. RECORD OF COMPLAINTS ......................................................................................................53

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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 Wattle Company 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 Subtropical Forest Zone and includes 2 of Forest Management Units as described below.

Description of FMUs:

Description Ownership Area (ha) Longitude E/W Latitude N/S

Nyanga Estate Wattle Company 14 679 32° 48 min E 18° 25 min S

Dunsinane Estate Wattle Company 4 293 32° 45 min east 18° 38 min

Size of FMUs:

Nr of FMUs Area (ha)

Less than 100ha 0 -

100 to 1000 ha in area 0 -

1001 to 10000 ha in area 1 3934

More than 10000 ha in area 1 13990

Total 2 17924

Total Area in the Scope of the Certificate that is:

Area (ha)

Privately managed 17924

State Managed -

Community Managed 1048

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

5405

Area of forest protected from commercial harvesting of timber and managed primarily for

production of NTFPs or services

-

Area of forest classified as “high conservation value forest” Ringing Rock 45

Total area of production forest (i.e. forest from which timber may be harvested) -

Area of production forest classified as “plantation” 12474

Area of production forest regenerated primarily by replanting 12474

Area of production forest regenerate primarily by natural regeneration

List of High Conservation Values

Description Notes

Ringing Rock

One conservation area named the ‘Ringing Rock’ has been selected and classified as a high value conservation area and has been set aside as a botanical reserve under the now defunct Intensive Conservation Act. The area contains ancient terracing and pit structures, the well-known ‘Ringing rock’ for which, the area is named, two colonies of the very rare Protea asymmetrica, and widdringtonia nodiflora. The area is also rich in Gladilous spp, Lapirousia moraea, Diaerama spp, Tulbahia spp which grow with the sedges and mosses of the steep area.

The area is protected from wild fires, and invasive woody weeds are regularly removed as part of the management prescriptions

Annual Timber Production

Maximum Annual Sustainable Yield (m3) Species (botanical name) Species (common name) Area (ha)

Projected Actual

Pinus patula, P. taeda, P. elliottii, P. kesiya, P. tecunamannii,

12474 150 000 154 000 (2004/5)

Totals 12474 150 000

List of Timber Product Categories

Product Notes

Round wood All certified round wood is sold to Nyanga sawmill

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List of Timber Product Categories

Product Notes

Sawn timber All certified sawn timber is sold to South African clients

Totals

Approximate Annual Commercial Production of Non-Timber-Forest-Products

Species Product

Botanical Name Common Name)

Unit of measure Total units

N/A

2. COMPANY BACKGROUND

2.1 Ownership

Wattle Company is Mulana Corporation N.V.

Wattle Company currently does not intend to purchase any new forestry area. However, due to the land claims in Zimbabwe, Wattle Company has ceded the following areas. These areas are currently still legally owned by Wattle Company, but the areas do not form part of the certified FMU. Further more, Wattle Company intends to remove the land from their title deeds in the future. The names of the 3 areas that have been ceded are:

Nyanga:

G-Block: 248 ha

Btittania: 430 ha

Dunsinane:

Charity: 363 ha

2.2 Company Key Objectives

Objective Notes

Commercial

To optimize the utilization of land and resources on the Estate while minimizing negative impacts and ensuring the conservation of important ecological, cultural and socio-economic features.

Forest management objective

To transfer timber from the plantation to the sawmill with maximum efficiency, at the least cost and with the minimum adverse environmental impact.

Transport objective

To optimise the plantation forestry yield potential of the Estate with a minimum adverse impact on the environment.

Forest management objective

To provide an efficient and safe access to all parts of the Estate while minimizing the area of forest roads, and reducing negative impacts on indigenous fauna and flora, and on catchment water

Road management objective

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Objective Notes

quality.

To manage our timber assets through pre-emptive action against loss from fire, pest and diseases

Forest protection objective

To improve profitability Achieved through product optimisation, grading and value addition.

Expand customer base Providing a wider range, high value product mix

Social

To provide recreational facilities for staff and general public on the Estate.

Community objective

Highest safety and health standard H&S objective

To furnish comfortable, safe and hygienic accommodation for personnel and to provide facilities that is efficient with a minimum of adverse environmental effects.

Worker well being objective

Environmental

Sustainable plantation forestry practices Environmental management objective

Minimise waste pollution Water management objective

To conserve the natural assets which occur on the Estate. ASI, RTE, HCVF objective

2.3 Company History

The Wattle Company Limited was formed on 6 February 1945 with the purpose of developing a wattle extract industry in Zimbabwe. The company is wholly Mulana Corporation N.V., with head office in Mutare, Zimbabwe. Subsequent changes in the demand for wattle and the increasing demand for high quality pine sawn timber, gum poles and charcoal, led to the diversification into such products. Today, the "Nyanga Pine" Division of the Wattle company produces and sells 75 000m3 of pine sawn board per annum from its own sawmill, representing about one fifth of Zimbabwe's total sawn timber output. Of this, 30% is supplied to the local Zimbabwe market, and 70% exported, mainly to South Africa.

The Wattle Company is the only producer of wattle extract in Zimbabwe, and one of the eight producers in the world. Charcoal is also produced as a by-product of the wattle extract process. The company is also the largest producer of gum poles in Zimbabwe and owns Eucalyptus plantations in the Vumba region.

The Wattle Company's Pine Division employs approximately 1100 workers, including permanent workers, labourers on daily contracts, and contracting companies.

2.4 Organisational Structure

The labour requirement on the estates fluctuates, but is generally held at this level of employment.

Harvesting 115

Silviculture 608

Support Services 178

TOTAL 901

Male 55%

Female 45%

The staff levels for the estate are generally fixed and presently comprise the following:

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General Manager (Pine)

Estate Manager (Dunsinane) and two Foresters, Silviculture and Harvesting Forester

Estates Manager Nyanga, five Foresters, two Senior Foresters and a Planning Forester.

Two Harvesting Foresters

Administration and Finance Manager, Personnel Officer and associated staff.

Civil Engineer

Workshop Manager, Maintenance Foreman and associated staff.

Sawmill Manager

Production Manager

Sawmill Engineer

2.5 Ownership and Use Rights

The company also has a good track record with neighbours and neighbouring communities.

Communities are allowed to access specific sites for the performance of their rites and rituals (e.g. rain making ceremonies and thatch grass collection).

2.6 Other Land Uses

There are currently no non-forestry activities occurring on the FMU

Non-certified Forests

Names, areas, locations, forest type of all forest holdings owned by Wattle Company are given in the table below:

Name Area (ha)

Location Forest type Reason for not being certified.

Vumba Estate 4930 Vumba Eucalyptus plantation

No market advantage with FSC certification, as poles are sold locally

Chimanimani Estate

16784 Chimanimani Wattle plantation

No FSC requirements for wattle logs and wattle bark

THE WATTLE COMPANY

Nyanga Pine Organogram

Chief Engineer Forestry Technical Manager

Sales and Marketing Mgr

Sawmill Secretary

Production Manager Sawmill Engineer

Sawmill Manager

Maint. Foreman

Civil Engineer

Personnel Officer

Clinic Nurse x 3

Accounting Officer

Health and Safety Mgr

Stores Control Manager

VacantFinance & Admin Mgr

Service Advisor Maintenance Planner

Workshop Foreman

Workshop Manager

Senior Forestor North

Senior Forester South

Forester

Forester

Forester

Planning Forester

Nyanaga Estate Mgr

Harvesting Forester

Tpt & Logistics Officer

Harvesting & TPT Mgr

Harvesting Forester

Silvics Forester

Dunsinane Estate Mgr

General Manager (Pine) Euc Division Wattle Division

Managing Director

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Chipinge Estate

4588 Chipinge Wattle plantation

No FSC requirements for wattle logs and wattle bark

There is currently no risk of confusing the certified products from the non-certified products within the certified FMU, as the Wattle Company is only selling certified pine products. Wattle Company is considering going into a long-term lease contract with the National Parks and wildlife management authority to manage areas of wattle jungle for the production of wattle bark and wattle timber. This agreement is in the process of negotiation and has not been finalised but is envisaged to be in place within the next few months.

3. FOREST MANAGEMENT SYSTEM

3.1 Bio-physical setting

In Zimbabwe, plantation forestry is primarily limited to the Eastern Highlands of the country, in Manicaland Province, and covers about 120 000ha in total, or 0.3% of the land area of the country. The Highlands are well suited for commercial timber production, with an altitudinal variation of 1000 - 1800m above sea level and an average rainfall of about 1500mm per year.

Climate and the effect of fires have confined indigenous forest to a very small proportion of the land area. Such forests tend to be confined to riverine areas and steep sided valleys, and are locally known as "gwasha" vegetation. The dominant natural vegetation types are grassland and savannah, also known as open 'Msasa" (Brachystegia spp) woodland, and a range of shrub-land, bushland and thicket types. Wetlands occur in the valley bottoms.

The Pine Division is comprised of two forest plantations i.e Nyanga Estate and Dunsinane estate. The Nyanga estate lies in the extreme south of the Nyanga District in the Commercial Farming Land of Administrative Ward No. 26 (Sanyanga) between latitudes 180 251 south and longitude 320 38I and 320 48I east. The Dunsinane Estate lies within the Mutasa North district in the Commercial Farming Land of Administrative Ward No. 18 latitude 18°39′and 18°45′ and longitude 32° 42′ and 32° 48′ east.

The Nyanga estate lies due north of Mutare, straddling the Mutare, Juliasdale, and Nyanga road. The administrative and sawmill centre is 60 kilometers from Mutare and 50 kilometers south of Nyanga. The Dunsinane estate is situated 55km north of Mutare on the Penhalonga road.

Immediately adjacent to the southern boundary of the Nyanga estate lies the administrative post of Mutasa where the District Administrator and a Police post are established.

The relevant 1: 50 000 Government survey map grid references are:

JULIASDALE 1832 B3

INYANGANI 1832 B4 and 1833 A3

WATSOMBA 1832 D1

STAPLEFORD FOREST 1832 D2

The Nyanga Estate is bordered on the south and west by Communal Land, to the east by Communal Farming Land and to the north and east by Forest Land and National Parks Land. Enclaves of Commercial Farming exist in the north. Forest plantations on the Northern and Eastern boundaries neighbour the Dunsinane estate, the Smallbridge dam on the Southern boundary and by small plot holders and the Honde Valley communal lands on the western and Northern boundary.

3.1.1 Geology

The Estates are underlain by the ancient craton of granite and gneiss known as the Basement Complex, which underlies much of Zimbabwe. Dolerite dykes and sills have intruded this.

3.1.2 Topography

Five distinct features can be identified within the Nyanga Estate namely the moderate eastern slopes of the Mutarazi Falls area; the rolling, easy sloping plateau country of the Iron Cliffs area (c.217m); the

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steep sloped Sanyanga’ Hill area; steep sided Britannia Mountain with rounded crest and the area stretching from Minnehaha to Rupangu which is generally sharply undulating with many spurs, saddlebacks and crests with easy rounded slopes, steep valley sides and comparatively flat river bed grades (c..1550m).

The eastern escarpment of the Nyanga mountains at its highest Mount Inyangani, to the northeast of Nyanga Estates, continues south as a series of towering cliffs, more or less along the boundary with Holden by Communal Land, extending across the Pungwe River and Pungwe Falls to the Mutarazi Falls and further south where it becomes less pronounced. Viewpoints on the Estate along this

Escarpment affords stunning views to the east over the Honde valley (c. 700m) and further. To the north lies the Juliasdale plateau and to the southwest spectacular granite country with numerous bare whaleback hills.

3.1.3 Soils

The soils on both estates are classified according to the Zimbabwean system as orthoferrallitic within the Kaolinitic order, derived from either granite rocks or dolerite.

The structural properties of orthoferrallitic soils including their good depth, permeability and structural stability, are highly favorable for cropping purposes, but these factors are partially counter-balanced by extremely poor chemical characteristics, particularly high levels of acidity and extreme chemical inertness and infertility. Although the slopes on which these soils occur are often very steep, due to their good permeability and depth, a large quantity of water can be stored without any run-off, with the result that these soils exhibit a high degree of resistance to erosion. Their tendency to support a close vegetative cover provides additional protection in this respect.

Descriptions of the soils of the Estate are as follows:

Mutarazi Falls: Variable ranging from sands to clays

Iron Cliffs: Mostly red clays and clay loams, Laterites are a feature of this area, often being compacted. Soil depths are therefore very variable, although textures are reasonably constant. Drainage is often impended.

Sanyanga’s Hill: Red clays and clay loams, between rock outcrops.

Britannia Mountain: Red Dolerite clays.

Minnehaha to Rupangu: Deep well drained pink to reddish sandy loams through sandy clay loams and clay loams to red clays.

3.1.4 Hydrology

Nyanga Estates is an important portion of the total catchment of the Odzi River. The Estate is mainly drained in a northeast – southwest plane either into the Odzi River through the Nyakupinga and Nyamaropa Rivers or into the Duru River, which flows into Honde Valley and the Mutarazi River which rises in the Iron cliffs area and flows over the Honde Valley escarpment forming the Mutarazi Falls.

The volumetric rate of flow for the above mentioned rivers are as follows: -

Odzi River (Gorge): 5.0 cusecs

Nyakupinga River: 7.0 cusecs

Nyamaropa River: 5.0 cusecs

Duru River: 3.0 cusecs

Mutarazi River: 0,5 cusecs

Total for Estate: 20.5 cusecs

There are two small dams on the Estate, namely the Chingamwe Dam on the Nyamaropa River and the Selborne Dam on the Chitowa Stream.

There are also three low yielding boreholes on the Estate drilled into granite rock.

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Dunsinane estate serves also as an important portion of the total catchment with two rivers merging into one and passing through the estate into the Lake Alexander from which some of the water is consumed by the City of Mutare Municipality for both domestic and industrial use.

The major uses of water on the Estates are primary supplies, industrial supply and recreation (fishing).

3.1.5 Climate

The two estates falls into Natural Region (NR) 1 in accordance with the agro ecological classification of Vincent and Thomas (1960) based on amount of rainfall received, the occurrence of rainy “pentads” and altitude, and into agro climatic zone 1 according to moisture availability, as defined by the ratio between mean annual rainfall and mean annual evapo-transpiration.

Differences in climate over the Estates are related to the variable relief. Two critical factors in this respect are altitude and aspect, both of which have a direct influence on rainfall and transpiration.

Climatic conditions across the Nyanga Estate are described as follows: Mutarazi Falls Altitude : 1550 – 1860m

Rainfall : 1524mm

Temperature : Max. 280C Min 00C

Cool and moist to wet with a touch of frost in winter

Iron Cliffs Altitude : 1860 – 2170m

Rainfall : 1270 – 1778mm (>2000mm in places)

Sanyanga Hill Altitude : 1860 – 2170m

Rainfall : 1270 – 1778mm

Temperature : Max. 290C Min. 20C

Cool and wet with frost in winter.

Britannia Mountain Altitude : 1860 – 2015m

Rainfall : 1016 – 1270mm

Temperature : Max. 290C Min. 10C

Cool and moist with light frosts in winter

Minnehaha to Rupangu Altitude : 1550 – 1860m

Rainfall : 1270 – 1724mm

Temperature : Max. 290 Min 10C

Cool and moist to wet with light frosts in winter

Heavier frosts in the valleys of the Odzi, Nyakupinga, Duru and Nyamaropa River.

Climatic conditions for Dunsinane are described as follows:

Dunsinane Altitude : 1540 – 1848m

Rainfall : 900 - 1859mm

Temperature : Max 30°C Min 0°C

3.1.6 Rainfall

Most of the precipitation derives from the east. As moist air reaches the escarpment, which is orientated virtually to the perpendicular direction of air movement, the air is forced upward resulting in

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cooling and the disposition of rain. To the west there is a definite gradient of declining rainfall with increasing distance from the escarpment.

The seasonality of rainfall follows the same general pattern as the rest of the country with the bulk of rainfall being confined to the months of November to March inclusive. Small amounts of winter precipitation in the form of mist, guti and rainfall do occur on areas of high elevation. Although the overall quantity is minimal, in places it is sufficient to keep the subsoil from dying out. Mist occurs regularly. Hail occurs in association with thunderstorm activity.

3.1.7 Temperature

Temperatures on the Estates are pleasantly moderate with the lowest temperatures being experienced from May to August and the highest from October to February. Frost occurs in winter.

3.1.8 Wind

Calmest conditions are experienced during the latter part of the rainy season (January and February) and the most turbulent conditions occur during September and October leading up to the onset of rains.

The prevailing wind is easterly which blows dominantly during the months of November to May. A northeasterly wind during the period August to November generally means hot and dry periods when a low pressure has developed south of the country.

Southerly winds in association with a strong cold front advancing in South Africa could bring light rain or drizzle. A westerly wind from November is a strong indication of heavy rainfall developing as the Inter Tropical Convergence Zone (I.T.C.Z.) starts working.

3.2 History of use

An Early Iron Age Negroid folk, whose culture has been named Ziwa, abandoned the Nyanga area about the thirteenth century.

A Bantu people from the north who settled the highlands in the sixteenth century replaced them, they were principally pastoralists with small livestock including a breed of pygmy cattle. These new comers were well versed in building with stone, the abundant relics that we have today in the form of pit structures, fort enclosures and terraces. This late Iron Age tribe moved away from the highlands in the late seventeenth century and settled in the lowlands. These folk are spoken of as the Karanga or early Shona. They in turn moved away from the lowlands under pressure from marauding Nguni warrior armies from the south.

The highlands from then on, were temporarily unoccupied, possibly due to a period of heavy rainfall or pressure from invaders, making life unsupportable.

In the early 19th century with the movement of the Nguni tribes from Natal, South Africa into Mozambique, a general shift of the population occurred and the highlands became sparsely populated again, with the Manyika people. These Manyikas were under the rule of Chief Mutasa, as they are today, based near the present day Watsomba.

The District derived its name from the first administration post for the Nyanga District, which was at Sanyanga’s village in the vicinity of the farm Sanyanga’s garden. The administration post was named after a famous Herbalist Headman who lived in the area. This Herbalist was the Court Physician to Chief Mutasa.

Europeans settled in the district from 1891 and farms were developed throughout the present Nyanga Estates.

Past land use included the farming of sheep and cattle, seed potatoes, softwoods, wattle, berry fruits, apples and pears.

3.3 Planning process

All estates are fully developed and in rotation. Pine plantings are largely restricted to P. patula, but include P. taeda, P. elliottii, P. kesiya, P. tecunumannii and P. maximinoi. The proportion of area planted to non-patula species is increasing, except for elliottii, which has been excluded because of

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the resinous nature of the timber. The pine plantations are managed for sawlog production and the logs transferred to Nyanga Sawmill for conversion to various board products offered on the domestic and regional markets. Limited and fluctuating markets exist for pine pulpwood.

Rotation

Pine plantations are currently grown under the so-called "Banana regime" developed in Natal and designed to maximize sawlog recovery, minimise pulpwood recovery and reduce the number of Silviculture operations required for each stand. Compartments are established at 1 100 spha, then thinned at 4 years to 650 spha and at 12 years to 400 spha before clear felling at 25 years. Until 1985, the estates were managed on a 3-thinning programme aimed at a lower final stocking of larger trees.

Planning Constraints and Objectives

Because of an almost complete halt to planting operations between 1970 and 1976, and the purchase in 1996 of Mutarazi (then Chingamwe Estate) with a large area of very over-aged compartments, the area-age distribution of the plantation base is highly abnormal. This has had and will continue to have a number of effects on the estates. Principally it has reduced the productivity of the plantations as the older compartments continue to stand long after culmination of mean annual increment. MAI culminates at about 18 years after planting. It is felt that the loss of increment due to the delay between culmination of MAI and clear felling at 25 years is outweighed by the advantages of harvesting larger trees.

It is therefore an objective of the plan to balance the return to productivity of these over-age stands with the requirement to deliver a relatively constant annual volume to the mill and to move the area-age structure toward normality.

While the volume felled in the earlier part of the plan is higher than the current annual increment of the plantations, and as such may be considered to be unsustainable, the shift towards forest normality, which is a direct result of this, is considered to meet sustainability requirements.

Yield Forecasting

Wattle Company has until recently been using the Forestry Commission Research Division's PINEMOD growth model assuming that all stands are planted to P patula, thinned at 4 and 13 years according to the Banana Regime. Stands on Nyanga estates are assumed to have a Site Index (reference age 20yrs) of 26 and on Dunsinane of 28. The model predicts yields to 15cm-tip diameter, which the sawmill currently accepts. While these assumptions are obviously not universally true, they provide a basis for a long-term plan and can be adjusted in short-term plans as enumeration details become available. However, the accuracy of these figures will depend on harvesting efficiency in recovery of timber above 15cm and the severity of the increasing baboon damage, which is likely to increase mortality and reduce the volume of merchantable timber.

In an effort to improve yield forecasting and have an integrated planning approach, Wattle Company has acquired the Microforest program. The program has growth and yield simulating functions, which have been adopted from the Center for Scientific and Industrial Research (CSIR) in a program called Model Manager. It is this function that predicts yields and enables the felling schedule in the Harvesting Scheduling System program. The current 26 yr plan has been derived and scheduled using the Microforest program.

3.4 Harvest and regeneration

All estates are fully developed and in rotation, but about 2000ha have been converted from wattle to pine over the last 8 years,. The planted area comprises approximately 12 000 ha of pines, and a negligible area of eucalypts (12.1 ha). Pine plantings are largely restricted to P. patula, but include P. taeda, P.elliottii, P. kesiya and P. tecunumannii, P maximinoi. There is an increased focus on better site-species matching, involving a range of pine species, except P elliottii. P. elliottii plantings have been stopped because of the resinous nature of the timber and because alternative species have shown superior growth rates to P elliottii.

There is a total of 12474 hectares of plant-able land. As at 31 December 2005, 10271ha is already planted. The area age distribution is abnormal on the estates as a result of the cessation of planting between 1979 and 1986 and the purchase of Mutarazi in 1996, which had a high proportion of over aged compartments and lately the conversion of ex-wattle land to pine and the disastrous fires of September 2005 where a total of 2335ha was lost on both estates. The felling programme is

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designed to bring about normality to the age distribution. For further detail on sustainability and the normality of the plantation, refer to the Long term Felling plan.

Below is a graph showing the age class detail as of 31 December 2005.

Pine Division Sawlog Area/Age Analysis

0

500

1000

1500

2000

2500

1973

1975

1977

1979

1981

1983

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

2005

Planting Year

Are

a (h

a)

With the estates being fully developed the species are now fixed, except for the replacement at the time of re-planting.

Plantings are largely made up of P patula but areas being re-planted now are being carefully considered for species such as P. kesiya and P tecunumanii and P maximinoi.

Plantings of P elliottii have been curtailed due to the resinous nature of the wood. After the recent experience of Cyclone Eline, the effect on P taeda was considerably less than on other species, therefore this should be considered when selecting species, particularly for exposed site.

Nyanga District Species Breakdown as at March 2000 is given below:

P patula 8312.3

P taeda 781

P elliottii 413.7

P tecunumanii 379

P kesiya 367

T.U.P. 2203

12474 Hectares

Site Quality and Area Analysis

The site class indices on the estates are established from growth rates for each compartment, which are derived from enumeration data. This analysis is for the pine compartments only.

Clearfelling is conducted primarily by cable yarders, and also by skidders at both Nyanga and Dunsinane estates. Thinning operations are done mostly using oxen and manual operations. Some thinning operations are being done with highleads in the steeper areas on a trial basis.

A procedure for remedial thinning is under development to mitigate the effects of late thinning and baboon damage. This is expected to be implemented in 2006.

The primary objective of the silvicultural operations is to produce sawlogs on a sustainable basis for the Nyanga Sawmill. Pine compartments are established at 1100spha (3X3m spacing), then thinned

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at 4 years to 650 spha and at 13 years to 400spha before clearfelling at 25 years. There is therefore no 3rd thinning. Pulpwood is being exchanged with Mutare Board and Paper, where WACO supplies pulpwood in exchange for sawlogs. The annual volume of this agreements amounts to 24 000m3 for 2006. The current demand for pulpwood is good. This is based on the “Banana Regime” which is so called because of its early adoption in Natal (South Africa). Weed control (cleaning) around the trees is carried out for the first three years and thereafter at the discretion of the forester. Four prunings are carried out on the pine stands: at approximately 1.5, 3, 5 and 7 years. The timing of pruning is based on the average height of the stand and the age.

Silvicultural prescriptions are documented in the TPF Environmental Management Guidelines as well as the Silviculture Manual. These documents deal with soil preparation, residue disposal, species selection, planting restrictions, surface water management, control of weeds and pests as well as spatial management of compartments.

A well-developed network of national roads services the two estates. The tarred roads of Mutare to Juliasdale, the Honde Valley Road, service Nyanga. The Pungwe Scenic road is a national dirt road and the Rural District Council roads Nyakupinga and Brackenridge are also dirt roads. The tarred road to Stapleford estate from Christmas pass accesses the Dunsinane estate. There is one Rural District Council road that services the estate from the Smallbridge dam through to Watsomba. Internal forest roads within the plantations are classified into three classes depending on the usage of the road. The Estates have an average road density of 53 meters/hectare, which is slightly above that recommended by the South African Department of Environmental Affairs (50 meters/hectare) for steep terrain.

3.5 Monitoring processes

It is the responsibility of the forestry line managers to monitor the plantation for pests and diseases. Guidelines are available for this.

The forester in charge is responsible for general village management, but village health workers are employed to educate personnel in order to achieve desirable standards of hygiene. The personnel officer, with the assistance of village wardens runs an annual village competition to promote good house keeping.

Other forms of monitoring in place are as follows:

The annual TPF environmental management audits

Regular self-assessments (internal audits) at estate level

Annual re-establishment competition, run from head office and includes all estates.

Post-harvest assessment by the silviculture forester and harvesting forester.

Fibre waste assessment by the Divisional planning forester

Forest guards that patrol the plantations to check for unauthorised activities.

Baboon damage assessment is conducted by the Planning Forester

Stream flow research has been carried out in surrounding catchments including the Dunsinane area. Drinking water quality is monitored by Health Inspectors (external). The monitoring of the impact of forestry on water quality of streams and rivers as well as the monitoring of fauna and flora, specifically rare and threatened species, was found to be inadequate.

4. SOCIO-ECONOMIC AND ENVIRONMENTAL CONTEXT

4.1 Social aspects

Number of own workers 396

Number of contract workers 504

Minimum daily wage for agricultural/forestry workers Zim $1.1 million

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Infant mortality rates (under 5 years) 0.7%

Proportion of workers employed from the local population (%) 100%

Opportunities for formal employment in rural Manicaland are limited, and largely confined to the plantation forests, tourist facilities and remaining commercial agriculture, and most people in this highly populated region of the country are subsistence farmers living under traditional leadership. Agricultural capacity of most of the land is limited by steep terrain and soil quality. Large-scale commercial operations such as plantation forests offer access to education, skills training, basic health facilities as well as formal employment.

4.2 Environmental aspects

4.2.1 Flora

Six major vegetation types have been identified on the two Estates and these are described in the Conservation Manual.

Moist Evergreen Forest Woodland

Moist Broadleaf Forest Grassland

Dry Conifer Forest Wetland

A Botanical Reserve has been set aside by the Company for the preservation of a number of rare and potentially endangered species which include a recently discovered sedge (found by a Botanical Expedition from Kew Gardens) and a colony of very rare Protea asymetrica, one of only two sites in the world.

At least 30% of the estate is unplanted and these areas are managed as conservation compartments.

4.2.2 Fauna

A register of bird, mammals, amphibians, reptile, fish and insects is being compiled based on personal observation and reports from reliable sources. There is a rich diversity of fauna including the rare blue swallow, blue duiker and samango monkey. A large population of bushbuck is found within the estates.

4.2.2 Weeds and Invader Species

Exotic invader species appearing on the Estate are, in order of importance :

Acacia mearnsii

Pinus spp

Eucalyptus grandis

Lantana camara

Phytolacca octandra

Rubus spp

The rapid and largely uncontrolled spread of wattle and pine trees through large areas of Rhodes Nyanga National Park represents a major threat to the conservation of constituent species and ecosystem types, and detracts from the aesthetic value of the park.

4.2.3 Conservation Areas

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The Wattle Company’s Pine division estates has identified areas within its total land of unplanted area that should be conserved and managed so as to preserve them in a good state and encourage biodiversity within our plantations. These conservation areas provide habitats for special fauna and flora that have always been a part of the ecological system of these areas. These conservation areas have been identified, named and each conservation area has got long and short – term plans developed and management prescription given for each conservation area.

4.3 Administration, Legislation and Guidelines

Zimbabwe has a range of legislation that affects the commercial forestry sector. The "Criteria Reference Manual" compiled by the company lists 25 Acts which are pertinent to the forestry industry. Included in this list is the Forest Act, the Water Act, the Natural Resources Act, the Parks and Wildlife Act and the Labour Relations Act, which are probably the most well known. Zimbabwe is a signatory to the Convention of Biological Diversity, the Convention on the International Trade in Endangered Species (CITES) and the International Labour Organisation (ILO). These international agreements are addressed in the existing Zimbabwean legislation where relevant. Industry regulations and standards are listed below.

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.

A. NATIONAL LEGISLATION

National legislation governs many of the activities in forestry in Zimbabwe. Some of the applicable Acts are as follows

Factories and Works Act

RGN 262 of 1976 – Factory and works (Registration and control of factories)

RGN 263 of 1976 – Factory and Works (General) Regulations

RGN 279 of 1976 – Factory and Works (Boiler) Regulations

RGN 302 of 1976 – Factory and Works (Machinery) Regulations

RGN 303 of 1976 – Factory and Works (Pressure Vessels) Regulations

RGN 304 0f 1976 – Factory and Works (Electrical) Regulations

SI 68 of 1990 – NSSA (Accident prevention and worker compensation scheme)

Public Health Act

Water Act

Zimbabwe National Water Authority Act

Forest Act

Parks and Wildlife Act

Environmental Management Act 2007

Regulations: Statutory Instrument 7 of 2007 ( Impact Assessment and Ecosystem Protection)

Statutory Instrument 6 of 2007 Effluent and Solid waste disposal.

National Museums and Monuments Act

Protected Places and Areas Act

Labour Relations Act

Labour Relations Amendment Act No. 17 of 2002

SI 130 of 2003 – Labour Relations (General conditions of employment) (Termination of Employment) Regulations

SI 131 of 2003 – Labour Relations (Protection against any acts of interference between workers organisations and employers organisations) Regulations

SI 132 of 2003 – Labour Relations (Retrenchment) Regulations

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Collective Bargaining Agreements & General Conditions

Man Power Planning and Development Act, SI 74 of 1999

B. INTERNATIONAL AGREEMENTS PERTINENT TO FORESTRY

Zimbabwe is a signatory to the following, however, current 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)

C. LOCAL STANDARDS AND 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:

Guidelines for Environmental Conservation Management in Plantation Forests in Zimbabwe (Timber Producers Federation, 1997)

Engelbrecht, G. v. R. and Warkotsch, P.W. 1994. Chute Operating Manual – FESA Chute Project Group

Guidelines for Forest Engineering Practices in South Africa. Forest Engineering Working Group of South Africa (FESA), May 1999.

The South African Cable-yarding Safety and Operating handbook (FESA).

The South African Chainsaw Safety and Operating handbook January 2000. (FESA).

S.A. Institute of Forestry, 1994 - Forestry Handbook

Zaremba W, 1976 - Logging Reference Manual Vols. 1-3 Department of Forestry, Pretoria.

Zimbabwean National Environmental Policy (Draft)? Not sure what is happening with, but should be considered in what ever form it is in.

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

The Wattle Company now subscribe to “Forestry Solutions”, which will affect their practices and their management plan.

SURVEILLANCE 2

Edgar Maunganidze is the new Managing Director, and Simon van der Lingen has taken over as Divisional Manager for Forestry.

SURVEILLANCE 3

SURVEILLANCE 4

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Description of Change Notes

6. PREPARATION FOR THE EVALUATION

6.1 Schedule

The Evaluation was not preceded by a pre-evaluation as this is a recertification evaluation.

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 PhD in forestry and an MBA, 23 years experience in forestry both internationally and nationally, 96 days FSC auditing.

Local Specialist Has a Bachelor of Social Work Degree, Master of Business Administration (Final Dissertation stage), 14 years combined experience in rural and urban development work, participatory research, monitoring and evaluation, international, regionally or nationally. Have assisted with FSC auditing with SGS (UK), SGS Qualifor (SA).

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. Only comments received were from the Zimbabwean Forestry Industry. 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 adapted for Zimbabwe (AD33-ZM)

1 January 2006

03 The standard was significantly revised in response to changes in the generic SGS Standard.

FSC Draft National Standard for Zimbabwe

6.4 Stakeholder notification

A wide range of stakeholders were contacted 4 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. 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.

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7.1 Opening meeting

An opening meeting was held at Nyanga Estate. 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.

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.

As this was a reassessment, no preassessment was required. The reassessment evaluation took place over 4 days and included both Estates (Dunsinane and Nyanga). A full CoC evaluation was also conducted of the Nyanga sawmill, which is included in the scope of the FM/CoC certificate. Field assessments

2007 Update: Both Nyanga and Dunsinane Estates were visited, and the Nyanga and Mutarazi Sawmill were visited for Chain of Custody.

7.4 Stakeholder interviews

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.

Letters were sent (faxed/posted) to twenty one stakeholders who are listed in the Stakeholder list provided by Wattle Company. The response was very poor. Some of the contacts provided had changed e.g. Provincial Medical Office, Mutare Paper and Board. Below are issues raised by stakeholders and management response.

Nr of Interviews with Nr of Stakeholders contacted:

NGOs Government Other

MAIN EVALUATION

21 1 0 4

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Nr of Interviews with Nr of Stakeholders contacted:

NGOs Government Other

SURVEILLANCE 1

7 4 1 1

SURVEILLANCE 2

10 1 2 4

SURVEILLANCE 3

SURVEILLANCE 4

Responses received and comments from interviews are recorded under paragraph 13 of this Public Summary.

7.5 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.

Strengths Weaknesses Compliance with criterion

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Criterion 1.1 Respect for national and local laws and administrative requirements

Exploitation of timber and other forest products is controlled by the Forest Act 1982, the Communal Land Act 1982, and the Communal Land Forest Produce Act (CLFPA) 1987.

The management plan shows that the company complies with the Environmental Management Act, Rural District Councils Act that governs forests, the Forest Act, the Labour Relations Act.

There was no evidence of legal non-compliance.

Criterion 1.2 Payment of legally prescribed fees, royalties, taxes and other charges

Prescribed payments not always done on time, operating licence had expired and an invoice had to be raised during the audit.

Evidence of required payments made by the company include:

• Unit tax licence payment for timber products Zimbabwe

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Strengths Weaknesses Compliance with criterion

• National Water Authority Sawmill shop licence renewal

• Charcoal processing licence

• NPS and WCIF monthly returns for January, Nyanga Pine – dated 26/01/06

• NSSA boiler inspection

Liquor licence for Selbourne Sports Club – Nyanga RDC

Criterion 1.3 Respect for provisions of international agreements

Through NSSA guidelines and periodic inspections, the company is continuously guided to ensure compliance.

Some non-compliance noted in respect of provision of adequate accommodation to employees noted and CAR raised to this effect.

Management demonstrated knowledge of CITES, ILO and other important provisions. The National Social Security Authority, through their periodic inspections check compliance to these, as they themselves are guided by international conventions.

Criterion 1.4 Conflicts between laws and regulations, and the FSC P&C

Consultations with stakeholders that include the community members take place before any major operations began.

No conflicts between laws and FSC P and C noted.

FSC P & C communicated across structures

Criterion 1.5 Protection of forests from illegal activities

Management has taken steps to protect the forest management areas from illegal activities.

Unauthorised activities reported (setting up snares)

Offenders have been dealt with under guidance from law enforcement agents

Criterion 1.6 Demonstration of a long-term commitment to the FSC P&C

5 Year plan clearly highlights FSC training for all employees. New employees and contractors inducted in FSC P& C.

Induction reports, training reports, interviews with managers and employees shows knowledge of FSC

The Wattle Company remains committed to manage its non certified landholdings in the spirit of the principles and criteria of the FSC

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Criterion 2.1 Demonstration of land tenure and forest use rights

Evidence of land tenure and use rights. Management, traditional leadership confirmed this

Title deeds for Nyanga “by plantation” available. Detailed on page 3 of the Overview and Management Plan of the Pine Division Estates. Map clearly indicating boundaries.

Refer section 2.1 above for information on land that is being ceded to the Zimbabwean Government.

Criterion 2.3 Disputes over tenure claims and use rights

None exist. Company maintains a stable relationship with the communities and acknowledges their claims and use rights.

Community members have forest use rights that include grazing and collecting of non-timber forest products.

Interviews with the Headman Samanyandwe, management and employees

Criterion 2.4 Indigenous peoples’ control of forest management

As for 2.3 above Community contribute to forest management through consultations and

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Strengths Weaknesses Compliance with criterion their control of special sites

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Criterion 3.1 Indigenous peoples’ control of forest management

Control of forest management is delegated to the company and the responsible authority and there is a common understanding from the community about this arrangement.

Community has forest use rights (controlled)

The company has identified the communities with use and access rights and their entitlements are recognised in management plans and according to management representatives, concerned areas are clearly demarcated on maps.

Criterion 3.2 Maintenance of indigenous peoples’ resources or tenure rights

There is no evidence that forest management threatens the use and access rights of communities.

Communities have access to sacred areas and can use forest resources.

As for 3.1

Criterion 3.3 Protection of sites of special cultural, ecological, economic or religious significance to indigenous peoples

Sites of special cultural significance have been identified in consultation with the community members and they are well managed and protected.

The community is responsible for maintaining the graves of their departed, and any other sites of cultural significance. Access is granted for such activities without limitations. Interviews with the headman and community members.

Criterion 3.4 Compensation of indigenous peoples for the application of their traditional knowledge

The company does not utilise indigenous knowledge for commercial purposes.

Information from the Headman, community members and management.

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Criterion 4.1 Employment, training, and other services for local communities

More needs to be done to check whether the system to monitor and assess the effectiveness of training is fully implemented. Some of this was checked (see 7.3), this needs to be checked in more detail at the first surveillance - Observation.

Internal Audit recommendations not monitored even though audit follow up reveal that employees not acting on CARs raised

The communities within or adjacent to the forest management area is given opportunities for employment, training and other services.

The majority of employees are from the local community. According to the HR Officer, training is given to workers according to needs that are identified by the various supervisors. Training in FSC, first aid, chainsaw operators and other skilled tasks were examples given and the auditor verified this from available records.

Criterion 4.2 Compliance with health and safety regulations

Forest management does not meet all applicable laws/regulations covering the health and safety of employees.

Noise levels have not been monitored since 2001. CAR raised in this respect.

Medical facilities provided meet health regulations.

Criterion 4.3 Workers’ rights to organise and negotiate with employers

The company has guaranteed the rights of workers to organise and voluntarily negotiate with their employers as outlined in ILO conventions and the Labour Relations Act.

There is evidence that workers are given the opportunity to organise themselves and negotiate with management about issues that affect them. All workers are represented by the National Employment Council.

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Strengths Weaknesses Compliance with criterion Membership to a trade union is an individual worker’s choice. However the workers are able to channel any grievances into the organised workers’ committees comprising on Workers’ leaders and the Works Council which comprises management and community representatives.

Criterion 4.4 Social impact evaluations and consultation

Management plan

The management plans and operations do incorporate results of evaluations and they do maintain some level of consultation with communities.

Criterion 4.5 Resolution of grievances and settlement of compensation claims

No grievances in relation to loss or damage affecting the legal or customary rights of local people.

No documented mechanism to handle communities, but workers are covered through the grievance procedure.

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Criterion 5.1 Economic viability taking full environmental, social, and operational costs into

account

Social investments are made into clinic, school. Condition of villages is good

Third pruning at some compartments at Dunsinane was postponed unnecessarily. Should be on the 2005/06 APO - observation

The following documents describe the economic viability:

APO’s for conservation

APO’s for silviculture and harvesting

APO for conservation makes provision for maintenance of ecological productivity.

Long term fibre plan (26 years)

Criterion 5.2 Optimal use and local processing of forest products

Wattle company has introduced 2 new pine species: P teconumanii and P maximinoi. No native species are planted for commercial use.

All logs are processed locally at Nyanga sawmill and Mutare Board and Paper.

Criterion 5.3 Waste minimisation and avoidance of damage to forest resources

Over 70% of clearfelling is done with cable yarders. Thinning mostly done manually and by oxen.

Low felling stumps at compartment A7A.

Very little waste seen next to roads and landings of clearfelling sites

The new hi-lead thinning operation at Dunsinane DUE 64 is showing signs of excessive tree damage. This needs to be monitored over the next few months to determine the extent of the damage and the feasibility of continuing with high leading extraction in thinnings in its current form. Alternative s could be considered like extraction of logs instead of tree lengths – observation

Some damage may be caused by consistent downhill felling of clearfelling trees. Investigate felling with the contour or up-hill - observation.

Following documents are available:

26 year felling plan

5 year tactical plans

APO’s for all operations

operational harvesting plans

5 logs were measured to review over cut :– all were correct (within the 8 to 10 cm margin of error), with the exception of 1 log, which was 13 cm.

No evidence of blueing seen in Nyanga sawmill log yard or in the field

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Strengths Weaknesses Compliance with criterion

Criterion 5.4 Forest management and the local economy

Currently the forest is managed for saw timber (primary product) and pulpwood (secondary product) and charcoal (limited). Charcoal not certified.

Communities are allowed to collect thatch and graze their cattle.

Criterion 5.5 Maintenance of the value of forest services and resources

Check that reestablishment of fire-damaged areas is on schedule at the next surveillance visit - observation

Foresters interviewed at Dunsinane Estate were aware of forest services offered at their estate

Environmental impacts Register for Pine Division describes this.

Criterion 5.6 Harvest levels

Reconciliation of planned verses actual shown in operation harvesting plan

Monthly reconciliation in monthly reports for both estates

Annual reconciliation send by Planning manager to Estate managers (interview with planning manager)

Harvest and thinning intensities for the pine division has been based on the 26 year felling plan. Harvesting rates planned will not exceed the calculated replenishment rates. See also 5.6.3

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Criterion 6.1 Environmental impacts evaluation

Dunsinane Estate CARs closed out correctly

Internal corrective action requests are not closed out adequately.

Internal auditing of villages recorded several shortcomings. It was not recorded as CARs but not followed through to verify progress made.

Pine Division: Environmenatal impacts Register.

Procedure : Stages in Developing an EIA.

EIA at Dunsinane: Roads widening and upgrading – Dunsinane Estate. Environmental Impact Assessment.

Results of environmental impact assessments, and general assessment of impacts (significant) have been integrated into management systems:

Silviculture manual

TPF Timber harvesting code of practice

TPF Environmental management guidelines

Conservation manual

Species used by Wattle Company are based on acknowledged research, including, but not limited to:

“The Rhodesia Bulletin of Forestry Research no. 1 A review of the introduction of forest trees in Rhodesia.” RL barrel and LJ Mullin. Rhodesia Forestry Commission 1968.

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Strengths Weaknesses Compliance with criterion

Criterion 6.2 Protection of rare, threatened and endangered species

Dunsinane Estate is much smaller than Nyanga and the focus has been on Nyanga (see also 6.2.2). Also report written by Mary Clarke (The Wattle Company – Nyanga Estates. A stakeholder feedback) – locally recognised botanist – observation.

Consultancy on the Distribution Classification and Conservation of Rainforests in Eastern Zimbabwe.

RTE’s are covered in the conservation Manual of WACO, demonstrating compliance with this criterion.

Cattle grazing allowed at all estates. Based on this, the number of cattle per estate is calculated by the senior forester: Cattle Grazing guidelines. Permit system used to manage and monitor cattle. Cattle grazing permits viewed

Conservation APO demonstrates compliance with this criterion. This document focuses specifically on wetland delineation, which is a key requirement in the protection of RTE’s in plantation forestry.

Maps viewed of conservation activities on Dunsinane Estate

Criterion 6.3 Maintenance of ecological functions and values

Investigate the feasibility of biannual burning of fire breaks on borders where this will be appropriate - observation

Soil erosion monitored through annual checks of the relevant areas (fire breaks, gravel pits, conservation areas) that are required to complete the APO.

Acknowledged southern African silvicultural and management systems are applied throughout the pine Division.

Restoration of degraded sites is included in environmental APO.

Criterion 6.4 Protection of representative samples of existing ecosystems

See 6.2

Criterion 6.5 Protection against damage to soils, residual forest and water resources during

operations

Conservation manual, fire protection manual and silviculture manual are not always kept up-to-date with forestry practices - CAR

Buffer zones are generally well maintained:

One example where wetland delineation was overstepped during planting was seen at Dunsinane – observation

Road maintenance plans are in place, including APO - Several roads need maintenance, e.g.:

- Nyanga Shannon road

- Nyanga N046 road

Observation

Dunsinane Nyambwa river conservation area is up for weed

TPF Forest Harvest Code of Practice

TPF Guidelines for Environmental Conservation Management in Plantation Forests in Zimbabwe

Silviculture manual

Conservation manual

Treating of contaminated oil viewed at Dunsinane workshop. Chemical spillages procedure checked at Dunsinane. Also chemicals storeman knows the procedure.

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Strengths Weaknesses Compliance with criterion clearing in June 2006. This needs to be checked at the next surveillance – area opposite compartment DuS012. - observation

Criterion 6.6 Chemical pest management

Chemical storeman has a very sound knowledge of his responsibilities

Bird perches very effective in newly planted compartments

Good assessment of weeding requirements at Nyakopinga avoided unnecessary chemical application

Clinic has a copy of all chemicals that are kept in the chemical store, but First aid labels not available for all chemicals kept in the chemical store – observation

Up-to-date chemical lists were viewed at Dunsinane chemical store;

No prohibited chemicals are used

List of required PPE is available at the chemical store and store man has all PPE available.

Chemical use in the Pine division is negligibly low.

No pesticides are used, except those mentioned in 6.6.1 to dip and dose cattle

Chemical store man explained the disposal of chemical containers as per procedure “Procedure for the disposal of used chemical containers”

Empty containers are rinsed (3X) and thrown into a pit, complying with ILO requirements.

Criterion 6.7 Use and disposal of chemicals, containers, liquid and solid non-organic wastes

First aid labels not available at the Dunsinane clinic for all chemicals kept in the chemical store (Berenal, Fuzone tabs, Systemex Liquid) - observation

Waste is disposed of in pits that comply with ILO publications ‘Safety & Health in the Use of Agrochemicals: A Guide’, and ‘Safety in the Use of Chemicals at Work’

Only possibility of recycling is used oil – see 6.7.4

Only oil is recycled. This is sold to Eastern Districts Engineers.

Criterion 6.8 Use of biological control agents and genetically modified organisms

Not used

Criterion 6.9 The use of exotic species

The pine division has converted all their landholdings from wattle to pine over the last few years, thereby substantially reducing the ecological impacts through the spread of wattle.

Conservation APO. Pine ring barked in riparian zones .

Criterion 6.10 Forest conversion to plantations or non-forest land uses

Not applicable – no conversions have taken place.

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Criterion 7.1 Management plan requirements

Letter written by forestry planner on 23.08.05 to The Senior Warden

Management plan is available: Overview and management plan of the

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Strengths Weaknesses Compliance with criterion (National Parks) to apply for a game survey on the two pine estates – check that this has occurred by the next surveillance visit - observation

pine division estates. Revised on 26 January

Pine division 26 year felling plan (also contains harvesting and planting plan). Revised in January 2006. Tactical 5-year refinement completed manually also in January by Company Planning Manager.

Management objectives are clearly described in Overview and management plan of the pine division estates

Conservation manual for pine division contains HCVF, special characteristics of the forest. In addition, asset register per Estate Land use and ownership status is given in Overview and management plan of the pine division estates (paragraph 1.1 and 1.2.)

Adjacent lands are described in Overview and management plan of the pine division estates paragraph 1.1.

Overview and management plan of the pine division estates paragraph 4.1.5

Pine division 26 year felling plan (whole document)

Overview and management plan of the pine division estates paragraph 4.1.4 describes the method used for yield forecasting. The actual application for completing enumerations is contained. In the silviculture manual, a description and frequency of monitoring is given: “APO’s should be prepared annually to enumerate all 18-year stands and all compartments due for clearfelling within the next financial year”.

Baboon control is being managed at Industry level. Dr. Richard Fergusson of AST (has been hired by TPF to produce and implement a strategy to control baboons. See quarterly reports

Maps are available and can be generated upon request. Objective evidence: Harvesting planning file. 5-year roads and harvesting plan. Estate map – Mutarazi.

TPF Forest Harvest Code of Practice and TPF Guidelines for Environmental Conservation Management in Plantation Forests in Zimbabwe (prescribed in 6.4.2 of the Overview and management plan of the pine division estates).

Nyanga and Dunsinane Harvesting

Roads 5-year plan. Plan is being updated after the Nyanga fire: 25/26 September & Dunsinane fire: 4 October, however an APO has already been compiled for harvesting of burnt compartments.

2005/06: APO available and actuals have been entered for October to December.

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Strengths Weaknesses Compliance with criterion

Silviculture:

Planned activities are mostly completed, with exception of 159.5 ha of 2nd thinning behind at Nyanga, but has been budgeted for the 2005/06 financial. Two compartments were not pruned in 04/05, constituting 18 ha.

Roads are planned by year in the 5-year plan maintenance programme slightly behind due to excessive rain – 11.2 km of maintenance grading in burnt area on Nyanga has been completed of a targeted 16 km. 1.1 km of 6 km completed for gravelling - access to compartments Reenen 57 AND 58 For harvesting.

Criterion 7.2 Management plan revision

Staff members with responsibility for the overall compilation and updating of the management plan are not clearly identified. No clear instruction to indicate who is responsible for revision of management plans – CAR

No timetable for the periodic revision of the management plan is documented and adhered to – CAR.

Taskforce for revision of management plan in Minutes of FSC meeting held at the administration boardroom on 17 November 2005.

Site/species matching is achieved by using the document: “Species Selection Guide for Nyanga and Dunsinane Estates” before re-establishing a compartment. P maximinoi was introduced in 2005.

Baboons: A local expert is hired by the Industry to coordinate the baboon control research programme. Trials were conducted where trapping methodology was changed. Shooting trail did not work. Repellent was tried where grease was mixed with chilli to prevent chewing of bark. Bendura University students monitoring behavioural patterns.

A local expert pays annual visits to Wattle Company (Forestry Consultants Report 13 to 22 February 2005)

P. maximinoi was introduced in 2005 as species that may be less subject to baboon damage.

Criterion 7.3 Training and supervision of forest workers

Supervisor at Dunsinane has very good knowledge of activities on plantation

There is a lack of training in the field

Nurses at Nyanga pine clinic were not aware of their responsibilities related to water monitoring results which reveal problems – CAR

Conflicting statements between managers in terms of who is responsible for identifying training needs – see minor CAR in this regard.

The S.H.E. induction Lecture (undated) provides a useful guide on the areas that require specific training for task assigned to workers. FSC training is provided for all staff members and new members are inducted on the procedures.

Relevant training is a prerequisite for new appointees. Those that are promoted are given on the job training as necessary. Specific training is given as per assessment by the HOD/Supervisor. Training records and interviews with staff who have been promoted

A Training needs/Evaluation Procedure has been developed on 25/01/2006

Interviews with workers confirmed that formal and informal training is given.

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Strengths Weaknesses Compliance with criterion Supervisors offer informal training in their day to day supervision as well as on the job training

Five Year Training Plan 2006-2010 Nyanga Pine Division was seen. The Training Manager consolidates internal and external training needs

Criterion 7.4 Public availability of the management plan elements

Overview and Management Plan of the Pine Division Estates is the publicly available document. Wattle Company has provided a copy to TPF

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Criterion 8.1 Frequency, intensity and consistency of monitoring

Consistent and replicable monitoring procedures for each activity are not implemented to allow for comparison and change over time. Dunsinane Donga 1 in compartment DUS 31 has not been monitored annually as per Wattle Company procedures. There is only evidence of monitoring in 2001 and 2002 – CAR

Corrective actions identified through the monitoring process are not appropriately implemented and closed out

Many CAR’s raised during the internal audits from January have close-out dates for January, but have not been closed –CAR.

Monitoring and Assessment Directory of monitoring documents (02.04.2005), based on results of Environmental Impacts register and mitigation programmes

Criterion 8.2 Research and data collection for monitoring

Compartment operational plan showed planned and actual volumes. Reasons are given for deviations.

Inventory is done at 18 years and at final felling. This is also described under chapter 5 of the silviculture manual

Mushrooms are sold on a limited scale – no inventory of fungi is required.

Fauna register. Last completed on 22.01.06.

Dunsinane Estate: Game sighting register

Letter written by forestry planner on 23.08.05 to The Senior Warden (National Parks) to apply for a game survey on the two pine estates.

One baboon was culled in the trapping programme on Selborne. Register is kept.

Monthly report on machine productivity, manpower productivity and efficiencies.

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Strengths Weaknesses Compliance with criterion

Criterion 8.4 Chain of custody

All certified logs are sold internally only. All of this is certified and goes to the Nyanga sawmill.

Chain of custody for timber is maintained through a system of weekly, monthly and quarterly reports, using data from in-field tally sheets.

This is described for mushrooms in the contract with the client: Edulis Zimbabwe (Private) Ltd. For the period 1 February 2006 to 31 January 2007.

FSC trademark is on the company website – approved by Qualifor Programme Director.

Criterion 8.5 Incorporation of monitoring results into the management plan

See examples given under 7. Also gully monitoring, fire breaks monitored and results used to plan. Road inspection reports are used to plan road maintenance.

Monthly report on machine productivity, manpower productivity and efficiencies.

Criterion 8.6 Publicly available summary of monitoring

Summary of monitoring results are publicly available, but it is recommended that more information is incorporated into the public summary of the monitoring results, e.g. water monitoring results, accident frequency rating - observation

Public summary is available

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Criterion 9.1 Evaluation to determine high conservation value attributes

Nyanga Estate’s special assets and cultural site register describes HCVF. Ringing Rocks on p19 of register.

Criterion 9.2 Consultation process

Memorandum from Estates Manager: Nyanga. ICA (Intensive Conservation Area) Proposal – Ringing Rock Area (3.8.98). No longer valid, but application was positive. ICA was established under the Natural Resources Act – which has been superseded by the Environmental management act.

There are no stakeholders directly affected. Wattle Company requested the inputs from an acknowledged local botanist – see 9.1.1

Criterion 9.3 Measures to maintain and enhance high conservation value attributes

All biological and/or social attributes of any HCVF identified are described in

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Strengths Weaknesses Compliance with criterion the Ringing Rocks compartment file

Conservation APO contains activities required at Ringing Rocks

HCVF is described in the management plan

The total area is fully protected and no harvesting or other forestry activities take place within the boundaries of the conservation area

Criterion 9.4 Monitoring to assess effectiveness

Conservation register; record of operations for Ringing rock (compartment M213)

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Criterion 10.1 Statement of objectives in the management plan

See 7.1

Criterion 10.2 Plantation design and layout

Each conservation area is treated as a compartment, with a 5-year plan, APO for conservation areas. Mary Clarke (2001) and Willie Macheka (July 2002). Rare species identified for all major conservation areas for Nyanga.

All natural forest is protected on the estates. No logging is thus taking place in natural forests.

Silviculture manual paragraph 3.1.3. Checked wetland delineation at compartment MUE 012b – supervisor trained in wetland delineation through auguring. Clear understanding of the required procedure. Replanting at compartment R063 was correctly delineated

The requirement that the scale and layout of existing and new plantation blocks are consistent with the patterns of forest stands within the natural landscape is discussed in Chapter 11 of the Conservation manual.

Criterion 10.3 Diversity in composition

Input from the Forestry Commission Tree Breeder: “Checking both the methodology and Practical application of species/site matching procedures of the Wattle Company Limited on its Nyanga and Dunsinane Estates” Report dated 18 to 21.07.05. Two new species have been introduced: P. teconumanii and P. maximinoi.

Silviculture manual and Conservation Manual states clear-cut area shall not exceed 100ha.

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Strengths Weaknesses Compliance with criterion

Criterion 10.4 Species selection

Information is not available on seed sources and these cannot be traced to the stand data. Verbal communication has taken place to Forestry Commission to supply this, but they have refused to date. More effort is required to obtain this information - observation

Species Introduction trials from FRC, plus document titled: “Checking both the methodology and Practical application of species/site matching procedures of the Wattle Company Limited on its Nyanga and Dunsinane Estates”

Pine plantings are based on:

The Rhodesia Bulletin of Forestry Research no. 1. A review of the introduction of forest trees in Rhodesia. RL barrel and LJ Mullin. Rhodesia Forestry Commission 1968.

Criterion 10.5 Restoration of natural forest

Restoration of natural forest is not applicable to plantation forestry. The total FMU has conservation areas, as described elsewhere in the report and the plantations were established on what was formally grasslands

Criterion 10.6 Impacts on soil and water

Soil type information is captured at the time of preparation of the operational harvesting plan. The information relates to key site information required to decide on sensitivity of the site

Soil erosion is monitored in May every year. Results are captured on donga monitoring form. Donga monitoring form is then managed through the Senior Foresters on the Estate.

Maps available with all water sources

Criterion 10.7 Pests and diseases

Rodent damage managed through perches in young compartments – very effective – bones of rodents seen at base of some perches. No visible rodent damage in any of the compartments

Follow-up after large fire has been good – important to ensure that planting targets are met - observation

Investigate the feasibility of biannual burning of fire breaks on borders where this will be appropriate - observation

No visible rodent damage in any of the compartments

Criterion 10.8 Monitoring of impacts, species testing and tenure rights

See 2.1, 2.2, 6.1, 6.5, 10.4

Criterion 10.9 Monitoring of impacts, species testing and tenure rights

Not applicable – no conversions have taken place.

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9. CERTIFICATION DECISION

SGS considers that The Wattle Company Limited’s forest management of the Pine Division, Nyanga, 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 Wattle Company is required to take the agreed actions before February 2006. These will be verified by SGS QUALIFOR at the first surveillance to be carried out about 6 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.

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 (2007)

Issues that were hard to assess

None

Number of CARs closed Nine Outstanding CARs were closed.

Nr of CARs remaining open None

New CARs raised One New Major CAR was raised and six Minor CARs were raised.

Certification Decision The forest management of the forests of The Wattle Company remains 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

The housing issue is a complex issue that needs an understanding of the situation as well as the measures taken to achieve compliance. The CAR on this is open since 2006 (suspended in 2008) but weighed against the progress

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made not raised as a major.

Number of CARs closed 6

Nr of CARs remaining open 1

Nr of New CARs raised 4

Certification Decision The forest management of the forests of The Wattle Company remains 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

Number of CARs closed

Nr of CARs remaining open

Nr of New CARs raised

Certification Decision

SURVEILLANCE 4

Issues that were hard to assess

Number of CARs closed

Nr of CARs remaining open

Nr of New CARs raised

Certification Decision

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11. RECORD OF CORRECTIVE ACTION REQUESTS (CARS)

11.1 CAR’s open from the previous certificate

Date Recorded> 2005/09/07 Due Date> Reassessm

ent Date Closed> 2 Feb. 06

Non-Conformance:

Internal corrective action requests are not closed out adequately.

Objective Evidence:

Internal auditing of villages recorded several shortcomings. It was not recorded as CARs neither followed through to verify progress made.

Close-out evidence:

32 6.1.5

A procedure was developed to ensure that the reoccurrence of this is avoided. Procedure Title: Stages in Developing an EIA. Dated 25.01.2006.

Date Recorded> 2005 / 09 / 07 Due Date> Reassess

ment Date Closed> 2 Feb. 06

Non-Conformance:

EIAs are not appropriately done to the scale and intensity of the operations.

Objective Evidence:

The EIA that was done for the recently build airstrip was not authorized. EIA guidelines unclear to the use and implementation thereof.

Close-out evidence:

33 6.1.1

6.1.2

10.8.2

A procedure was developed to ensure that the reoccurrence of this is avoided. Procedure Title: Stages in Developing an EIA. Dated 25.01.2006.

11.2 New CARs raised during the reassessment:

CAR # Indicator CAR Detail

Date Recorded> 02.02.06 Due Date> Next SA Date Closed> 07 Mar 2007

Non-Conformance:

Worker accommodation and nutrition do not comply, as a minimum, with the ILO Code of Practice on Safety and Health in Forestry.

Objective Evidence:

Village 2b has inadequate lighting in some housing units. Wooden kitchen structures are sub standard, as wooden panels are missing from the structure. Communal toilets are not clean

Close-out evidence:

01

4.2.9

There were still problems with the worker’s accommodation. This CAR is closed and replaced with Major CAR 10.

Date Recorded> 02.02.06 Due Date> Next SA Date Closed> 07 Mar 2007

Non-Conformance:

Forest Managers do not comply with laws and/or regulations covering heath and safety of employees and their families.

Objective Evidence:

02 4.2.1

Noise levels of activities on the estate have not been monitored since 2001. Monitoring of hearing of employees has not occurred since 2001.

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CAR # Indicator CAR Detail

Close-out evidence:

The above CAR refers to noise levels at the sawmill. On 5/7/2006 the noise levels were measured at 15 sites. At each of these sites the decibel reading is written onto the machine e.g at the Hogger the reading of 90-110 is displayed (85db cut off for ear protection). NSSA was contacted and asked if they could carry out audiometric testing before November 2006, but they still have not responded positively, so the company has ordered an Audiometric Testing machine from South Africa (order # 233163 dated 25 November 2006). This CAR is closed

Date Recorded> 02.02.06 Due Date> 30.08.06 Date Closed> 07 Mar 2007

Non-Conformance:

There is a lack of training in the field

Objective Evidence:

Nurses at Nyanga pine clinic were not aware of their responsibilities related to water monitoring results which reveal problems

Close-out evidence:

03 7.3.4

A new procedure “Management of Water Results” has been written, which defines the responsibilities and the steps that need to be taken in the case of problems with drinking water in order to remedy the situation (Procedure dated 25/1/2007). For example, in the case of faecal contamination, all drinking from the source must be stopped, and the people who accessed the source isolated and warned of the symptoms of water borne diseases, and the water treated. The Nursing Sister at Nyanga Pine Clinic clearly articulates the procedure which outlines steps to be taken in the event of unfavourable water testing results are received and who is responsible for taking action. Testing for twelve sites is documented and eleven out of those twelve had excellent results. Dunsinane Simla had high levels of feacal contamination on 14/06/06. Corrective action was taken and it was retested on 04/11/06 and posted excellent results.

This CAR is closed.

Date Recorded> 02.02.06 Due Date> Next SA Date Closed> 07 Mar 2007

Non-Conformance:

Consistent and replicable monitoring procedures for each activity are not implemented to allow for comparison and change over time.

Objective Evidence:

Dunsinane Donga 1 in compartment DUS 31 has not been monitored annually as per Wattle Company procedures. There is only evidence of monitoring in 2001 and 2002.

Close-out evidence:

04 8.1.3

Monitoring of this Donga (size measurements) was carried out in February 2006, and the donga is not growing in size. A site visit revealed that it was fairly stable, especially after the potential problems of the Oct 2005 fire through the area. This CAR is closed.

Date Recorded> 02.02.06 Due Date> Next SA Date Closed> 07 Mar 2007

Non-Conformance:

All necessary machines and equipment are not in safe and serviceable condition

Objective Evidence:

At Nyanga (compartment A7a) the Urus cable yarder was incorrectly rigged: • anchor trees not felled

• tail tree support guy-lines not correctly rigged

• middle guy-line on tower too tight

05 4.2.5

Close-out evidence:

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CAR # Indicator CAR Detail

At Mutarazi compartment M1 the cable yarding harvest operation was inspected and guy lines were correctly rigged, and the harvesting manager provided a very clear explanation of the system and the role of the middle guy line, and the overall safety aspects of the operation. This CAR is closed.

Date Recorded> 02.02.06 Due Date> Next Sa Date Closed> 07 Mar 2007

Non-Conformance:

Staff members with responsibility for the overall compilation and updating of the management plan are not clearly identified

Objective Evidence:

No clear instruction to indicate who is responsible for revision of management plans.

Close-out evidence:

06 7.2.1

An organogram and flow chart has been prepared, which lists each discipline. Within each discipline, the documentation and processes are listed, as well as the responsible person (the champion for that discipline). The flow chart shows the flow of information that is required. Champions for each discipline have been identified. The Wattle Company has now also subscribed to Forestry Solutions, which provides continually updated information. This CAR is closed.

Date Recorded> 02.02.06 Due Date> Next SA Date Closed> 07 Mar 2007

Non-Conformance:

Guidelines developed in terms of indicator 6.5.1 are not always implemented during operations and planning

Objective Evidence:

Conservation manual, fire protection manual and silviculture manual are not always kept up-to-date with forestry practices.

Official status of documents are not always known, e.g.:

EIA at Dunsinane: Roads widening and upgrading – Dunsinane Estate is not dated

The S.H.E. induction Lecture is undated

Close-out evidence:

07 6.5.2

The Wattle Company has now subscribed to “Forestry Solutions”, which provides up-to-date information, guidelines and Best Operating Practices. See Close-out details for Minor CAR 06, with allocation of champions and responsibilities, which includes document control. This CAR is closed.

Date Recorded> 02.02.06 Due Date> Next SA Date Closed> 07 Mar 2007

Non-Conformance:

No timetable for the periodic revision of the management plan is documented and adhered to

Objective Evidence:

No time table available

Close-out evidence:

08 7.2.5

Every aspect of the Management Plan has been identified, and allocated to a “Champion”. For example the Silvicultural Manual is the responsibility of the Planning Forester and is planned for a 3-yearly revision, the Tactical Silvicultural Plan is the responsibility of the Estate Manager, and is reviewed and updated annually. The overview of the Management Plan is the responsibility of the Planning Manager, and is updated annually. There was evidence of updated plans (e.g. public summary, weed control, APOs etc). This CAR is closed.

Date Recorded> 02.02.06 Due Date> Next SA Date Closed> 07 Mar 2007 09 8.1.5

Non-Conformance:

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CAR # Indicator CAR Detail

Corrective actions identified through the monitoring process are not appropriately implemented and closed out

Objective Evidence:

Many CAR’s raised during the internal audits from January have close-out dates for January, but have not been closed.

Close-out evidence:

Internal auditing in harvesting, silviculture, H&S, villages, workshops, roads, conservation etc has taken place internally. In the event of non-conformances identified, CARs are raised and then signed off once the corrective action has been implemented. Harvesting CARs 74-78 were checked and found to be adequately closed out. The Conservation audit of 2/2/2007 was checked and CARs were raised with a due date of April 2007. In addition, CARs 82, 83 & 84 on Mutarazi dealing with site species selection and updating of compartment registers were followed up on and closed out. The system appears to be working very well. This CAR is closed.

Date Recorded> 7 Mar 2007 Due Date> April 2007 Date Closed> 7 Apr. 2007

Non-Conformance:

Worker’s accommodation does not comply, as a minimum, with the ILO Code of Practice on Safety and Health in Forestry.

Objective Evidence:

See Minor CAR 01 which could not be closed based on the following evidence:

1. At the Sawmill Village 3 the communal bathrooms were dirty and unhygienic (not cleaned). The bathroom floors need re-surfacing and the walls need structural repair. The kitchen walls need structural repair and the toilets are full. Plans to drain these toilets have not yet materialised and a new toilet hole dug adjacent to one of the toilets has been abandoned and is a safety risk.

2. At Nyangani Village the gulley grids are missing in the bathrooms which will result in drainage problems and at House # 34 the chimney is not functioning, resulting in smoke filling the house.

Close-out evidence:

M10 4.2.9

The SHE Manager (Roderick Madhembo) has produced a village checklist based on appropriate ILO recommendations, and all three sawmill villages have been audited against this checklist (submitted to SGS). As a result of these audits, a “Villages Action plan 2007” has been drawn up (submitted to SGS) for the necessary remedial action for village improvement, as well as the due dates. This action plan includes provisional due dates and is auditable. This Major CAR is closed on the basis of this action, but is replaced with Minor CAR 17, and a Clearance of Findings (CoF) interim surveillance visit has been scheduled for November 2007 in order to verify the village improvements.

Date Recorded> 7 Mar 2007 Due Date> Next Surv. Date Closed> 25/2/2009

Non-Conformance:

There is no Waste Management Plan for the Nyanga sawmill bark and Mutarazi Sawmill sawdust and off-cuts, and waste is not disposed of in environmentally appropriate ways, resulting in severe environmental impacts.

Objective Evidence:

The bark dumps at the Nyanga Sawmill are growing and poorly located above the worker’s accommodation, and an eyesore to the sawmill. There is no long-term management plan.

The Sawdust dumps below the Mutarazi Sawmill are on the edge of a wetland and stream area, and are creeping into this sensitive zone. In the first certification period, the Wattle Company undertook to rehabilitate this area and carry out water monitoring, but now this dump has become active and the environmental impact compounded. There is no programme for the restoration of this degraded site.

11 6.7.2;

6.3.3

7.1.6

Close-out evidence:

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CAR # Indicator CAR Detail

The Mutarazi sawmill was closed down and the rehabilitation of the sawdust and the erosion is in progress. There is also a decommissioning and rehab plan in place. With the Nyanga Mill the company is busy with investigations for a biomass plant. Feasibility studies and EIA studies have been done. The project is approved and a Memorandum of Understanding drafted for the suppliers. Construction will take less than a year. CAR 11 closed.

Date Recorded> 7 Mar 2007 Due Date> Next Surv. Date Closed> 25/2/2009

Non-Conformance:

The potential environmental impacts of on site processing facilities have not been assessed and incorporated into management plans.

Objective Evidence:

The within the Mutarazi Sawmill grounds is eroding very badly and there is no road maintenance plan. Historical erosion is evident and there is not monitoring.

The Mutarazi Sawmill grounds are very weed infested, and there is not a weed control plan which includes regular follow up. The status is not improving and is not monitored.

Waste disposal has not been assessed as an impact and there is no waste management planning or monitoring (See CAR 11).

Close-out evidence:

12 6.1.1

Roads in the vicinity of the Mutarazi mill were well maintained and mitre drains constructed. There are old erosion gullies behind the sawmill. The rehabilitation plan indicates that they will be contained to prevent further erosion, but that they will remain as gullies. They are huge erosion walls and would probably do more damage than good in trying anything else. The mill has been stopped and there is a rehabilitation plan to rehab the whole area. Rehabilitation works were in progress at the time of the audit. CAR 12 Closed.

Date Recorded> 7 Mar 2007 Due Date> Next Surv. Date Closed> 25/2/2009

Non-Conformance:

Wetland Delineation has not been adequately implemented, and guideline needs revision.

Objective Evidence:

At Selborne Compartments 88 and 89, in numerous places trees were planted < 10m from the wetland edge. There was no soil augering to determine boundaries. This is contrary to own procedure which states 10-20m. The Wattle Co Wetland delineation procedure needs revision in terms of new legislation, and National acceptance with environmental bodies and stakeholders.

Close-out evidence:

13 6.5.1

6.5.3

Delineation area along the wetland below the Charity land was visited and found to be done. Dunsinane Compartment 64 delineated and replanted, The Timber Producers Federation guidelines are followed. CAR 13 closed.

Date Recorded> 7 Mar 2007 Due Date> Next Surv. Date Closed> 25/2/2009

Non-Conformance:

Certain ILO Code of Practice on Safety and Health in Forestry are not being met.

Objective Evidence:

Drinking water was not provided at the working sites: This was the case at the M1 Cable yarding site on Mutarazi (Nyanga) and at DuS047 spot weeding and DuS107 thinning operation on Dunsinane. Provision of water is also necessary in the event of first aid (e.g. cleaning injuries).

Close-out evidence:

14 4.2.4

Drinking and cooking water was provided on sites. There are guards placed to guard the machines 24hrs and they have water provided. The lookout has an additional member tasked to carry the water to the tower, the lookout has at least 20 l water available at any time. CAR 14 closed.

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CAR # Indicator CAR Detail

Date Recorded> 7 Mar 2007 Due Date> Next Surv. Date Closed> 25/2/2009

Non-Conformance:

Access to medical facilities was lacking at the work site

Objective Evidence:

There was no first aid kit available at the Dunsinane DuS107 Cable thinning operation, and there was no trained first aider on site.

Close-out evidence:

15 4.2.8

First Aid boxes were available at the operational sites at harvesting compartments Dunsinane 64 & 65. Medical boxes were adequately stocked and trained first aider available on site. First aid certificates were available and were still valid. First Aiders are trained by the Red Cross. CAR closed.

Date Recorded> 7 Mar 2007 Due Date> Next Surv. Date Closed> 25/2/2009

Non-Conformance:

There is no updated stakeholder list on Dunsinane and the Stakeholder consultation policy is not being implemented

Objective Evidence:

The Stakeholder list on Dunsinane is dated 2002. The Stakeholder Policy (dated Jan 2006) is not implemented as follows:

1. The list needs to be displayed in the offices, which is was not

2. Communication through Boka Redu, which is no longer published is specified in the policy

3. Communication with stakeholders is supposed to take place biannually, but there is no evidence of such communication.

Close-out evidence:

16 4.4.3

Stakeholder list was updated in January 2009 and was available at the estates.

Date Recorded> 7 Apr 2007 Due Date> Nov 2007 Date Closed> dd MMM yy

Non-Conformance:

Worker’s accommodation does not comply, as a minimum, with the ILO Code of Practice on Safety and Health in Forestry.

Objective Evidence:

See Major CAR 10.

17 4.2.9

Close-out evidence:

AD 36-A-01 Page 43 of 53

CAR # Indicator CAR Detail

This CAR has a long history since it was initially raised in 2006 during the re-assessment. It was raised as Major in 2007, closed again based on the action plan provided by the company but remained open as this minor CAR 17. During 2008 the company was suspended and therefore progress is only now monitored during the SA 2009.22 audit. The company is housing approximately a 1000 families in various types of houses. Those include standard brick houses, wooden houses, pole & dagga houses and old style wattle block houses, all in various conditions. Compliance would therefore not be achieved overnight and a timeframe has been set by the company to address the issue over the remaining years within this certificate period. The program includes the building of new houses to supply the demand. The replacement of those houses that cannot be viably repaired. Upgrading of facilities where needed and the general maintenance of all the buildings. To confirm that the proposed action plan is still in place and upheld, the following documents were verified:

• The Wattle Company village upgrade policy and standard. (undated)

• Memorandum of the action plan for housing and related infrastructure. 16/10/2008.

• Quotations

• Approved budgets for current year.

• Capital expenditure Authority

• Board resolution for the prioritisation of the housing issue 28/11/2008.

• Timeframe for the implementation of the program, signed by the engineers and CEO.

From that it is clear that the company is actively managing the problem. It is further emphasized by the material that has been ordered for the current year’s program and evident in the construction of some of the units that was already in progress. Progress is hampered by the fact that the suppliers haven’t opened since the beginning of the year, due to the prevailing situation in Zimbabwe. Reality is, that in large there are still non-compliances that require attention and compared with the big picture, the physical progress made seems small. Based on the physical evidence the CAR remains open, but based on the proven commitment and above mentioned documents, it remains as a minor and is not raised to a major. The company further committed to a more than annual third party assessment to evaluate the rate of progress with the implementation of the housing action plan. Reference is also made to the positive observation about the company’s social responsibility.

Progress October 2009:

The housing progress report received from the company.

The company went through a restructuring process since the last audit. Although the responsibilities changed and the persons responsible and reporting lines changed, the commitment to upgrade the villages were maintained and is again re-emphasized in the new structure. New houses are in various stages of completion. Scheduled work is on time, but serious consideration is still needed to ensure that the two year company goals are achieved. The completion of the Tafara units and the completion of the garage units will help in this process. Both these are in advance stages of completion.

The power generator biomass burner of the saw mill is also essential. It is being delayed for some time now and the saw dust is blown over a portion of the village.

It appears that many of the toilets are moved to the 4th quarter and only 35 % completed to date. In reality the work is relative quick and can be done in-house. It will be possible to complete in the scheduled timeframe. The new houses are more than 70% completed and on schedule. Maintenance and painting is more than 70 % completed and on schedule.

AD 36-A-01 Page 44 of 53

CAR # Indicator CAR Detail

Date Recorded> 25/2/2009 Due Date> Next Surv. Date Closed> dd MMM yy

Non-Conformance:

The social Impacts of forest operations are not adequately evaluated in conjunction with the local stakeholders affected and in accordance with the scale and intensity of management,

Objective Evidence:

With reference to the congestion in the villages At Dunisane Eastbourne village as well as sawmill villages 3 & 4, families were living together in single rooms.

Inadequate toilet facilities at Selbourne village 3 Selbourne farm village where up to 22 families sharing 3 pit toilets

The company has engaged on a decongestion program for the villages, but social impacts relating to this program were not adequately assessed.

Close-out evidence:

18 4.4.1

Date Recorded> 25/2/2009 Due Date> Next Surv. Date Closed> dd MMM yy

Non-Conformance:

Silvicultural and other management systems are not appropriate to the ecology of the forest resources and in meeting management objectives.

Objective Evidence:

Compartments on Dunsinane were allowed to be intercropped with maize. These compartments were visibly poorly stocked, but monitoring data was not available. The maize cultivation might also exceed the slope requirements of agricultural legislation.

Close-out evidence:

19 6.3.2

Date Recorded> 25/2/2009 Due Date> Next surveilance Date Closed> dd MMM yy

Non-Conformance:

Conservation management and protection activities are demarcated on maps, but implemention and impacts of management actions are not adequately monitored.

Objective Evidence:

Open areas CA 1 & CA 2 on Dunsinane were infested with pine re-growth and other weeds. Some of which has been ring barked but with poor results and not effective at all. Areas appear on the APO but no long term program attached to ensure the completion of the whole area within a specific timeline.

Close-out evidence:

20 6.2.5

Date Recorded> 25/2/2009 Due Date> Next surveilance Date Closed> dd MMM yy

Non-Conformance:

The company has not ensured the proper handling and storage of chemical and oil containers.

21 6.7.3

Objective Evidence:

AD 36-A-01 Page 45 of 53

CAR # Indicator CAR Detail

Diesel Oil and lubricants are not handled and stored according to environmental best practices at the Sawmill.

Close-out evidence:

AD 36-A-01 Page 46 of 53

12. RECORD OF OBSERVATIONS

OBS # Indicator Observation Detail

Date Recorded> 02.02.06 Date Closed> 7 Mar 2007

Observation:

There seems to be a lack of commitment to the FSC principles and criteria in the Southern Division of the Wattle Company. It is recommended that management gives a clear message of commitment to the FSC philosophy throughout their landholdings

Follow-up evidence:

01 1.6

It is planned to extend the scope to include the Vumba Plantation area of 1958ha at the first surveillance visit.

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

Investigate the feasibility of biannual burning of fire breaks on borders where this will be appropriate.

Follow-up evidence:

02 10.7.4.2

The feasibility of biennial burning has been investigated, and will be implemented in some places such as along the main road of Selborne Estate, with a low fire risk. There is a memo dated 1 Sep 2006 from S Nyakanda listing three places where it will be possible to implement biennial burning (namely Makomva Boundary fireguard; Nyanga tarmac servitude; and P taeda compartments over 13 years old on the eastern side).

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

Wetland delineation lines at compartment DUE 003 (Dunsinane) were ignored during planting

Follow-up evidence:

03 6.5.3

Still a problem. See Minor CAR 11.

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

Third pruning at compartments DUS 30, 33 & 34 was postponed unnecessarily. Should be on the 2005/06 APO.

Follow-up evidence:

04 5.1.1

Third pruning at compartments DUS 30, 33 & 34 has been done. All pruning to date in on target. There are no compartments which are behind target. The planting schedules are ahead of target and the weed control is also on target.

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

Several roads need maintenance:

- Nyanga Shannon road

- Nyanga N046 road

Follow-up evidence:

05 6.5.2

The above roads on Nyanga have been scheduled for maintenance: Rd 220, 3.9km and Rd 132 1km. Other problematic roads and drains that were encountered had also been placed on the maintenance schedule.

06 6.7.3 Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

AD 36-A-01 Page 47 of 53

OBS # Indicator Observation Detail

Observation:

First aid labels not available at the Dunsinane clinic for all chemicals kept in the chemical store (Berenal, Fuzone tabs, Systemex Liquid)

Follow-up evidence:

All of the above pesticides are for cattle (tick control), and have been removed from the chemical store and disposed of (see 6.6.1 of checklist).

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

Dunsinane Nywambwa river conservation area is up for weed clearing in June 2006. This needs to be checked at the next surveillance – area opposite compartment DUS 12.

Follow-up evidence:

07 6.5.3

This conservation area Ca11 was done in April 2006. This area was 9ha, and is clean now.

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

The new hi lead thinning operation at Dunsinane DUE 64 is showing signs of excessive tree damage. This needs to be monitored over the next few months to determine the extent of the damage and the feasibility of continuing with high leading extraction in thinnings in its current form. Alternatives could be considered like extraction of logs instead of tree lengths.

Follow-up evidence:

08 5.3.2

The DuS107 line thinning cable yarding operation was checked, and there was no evidence of damage to trees. Logs hauled are a maximum of 6m, thereby also reducing chance of damage to the stand.

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

Some damage may be caused by consistent downhill felling of clearfelling trees. Investigate felling with the contour or up-hill.

Follow-up evidence:

09 5.3.2

A memo dated 12/1/2007 details an investigation that was carried out on MuM003 directional felling. The outcome was that felling on contour was a success. It was recommended that felling on contour should be adopted as a Best Operating Practice on slopes.

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

There is a lack of focus on RTE’s on Dunsinane. More work should be done to the same level as what has taken place at Nyanga estate

10 6.2.1

Follow-up evidence:

AD 36-A-01 Page 48 of 53

OBS # Indicator Observation Detail

A biodiversity assessment of Dunsinane was carried out by Stu Valintine on 18/12/2006. Some of the recommendations of this assessment are summarised as follows: Conservation value areas The riparian zones along the upper Nyambwa and Ruwenya can be considered for high conservation status. The current pristine appearance and species composition in these areas indicates that management plans are effective, and should therefore be maintained.

Some of the woodland areas and rocky outcrops contain protected aloe and epiphytic orchid species. These areas are now under an effective invasive weed management programme.

Open Area Management Maintain and update the current conservation register. Map and assign management plans to open areas not currently identified, for examples see the attached map (red dotted areas), and the Makanga river. Current informal management of the open areas is good, but due to it not being documented it is difficult to track which areas have been done when, and when these areas are scheduled to be done, reviewed, or re-worked. This informal management is acceptable as long as this forms part of the companies forest management plans, and work completed is documented, and effectiveness monitored.

Wattle Company needs to review the damage being done to indigenous fauna and flora by baboons and where possible document and photograph evidence of this conflict between natural species. This could then be used by researchers to determine whether this conflict is detrimental to other species, or part of the natural cycle.

Date Recorded> 02.02.2006 Date Closed> 25/2/2009

Observation:

Summary of monitoring results are publicly available, but it is recommended that more information is incorporated into the public summary of the monitoring results, e.g. water monitoring results, accident frequency rating.

2007 Update: This was inadequately checked and needs to be followed up on. The TPF pamphlets were quoted as containing such results, but such pamphlets were not available.

Follow-up evidence:

11 8.5.1

The issues refer to in the management plan are monitored. And are publically available. No further action required.

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

Information is not available on seed sources and these cannot be traced to the stand data. Verbal communication has taken place to Forestry Commission to supply this, but they have refused to date. More effort is required to obtain this information.

Follow-up evidence:

12 10.4.3

Seeds are purchased from the Forestry Commission. The batch number of the seeds is included on the invoice, and this can be traced back to the breeding programmes.

Date Recorded> 02.02.2006 Date Closed> 25/2/2009

Observation:

Letter written by forestry planner on 23.08.05 to The Senior Warden (National Parks) to apply for a game survey on the two pine estates – check that this has occurred by the next surveillance visit.

2007 Update: There has not yet been a game survey. This was postponed due to various reasons. Needs to be followed up on.

Follow-up evidence:

13 7.1.9

The company keeps record of all internal sightings of any special species. The records were confirmed at Dunsinane office. A mammal survey was conducted by the Lamic Chirimuta during September 2007. Further studies were applied for but without success due to the current uncertainty in Zimbabwe.

AD 36-A-01 Page 49 of 53

OBS # Indicator Observation Detail

Date Recorded> 02.02.2006 Date Closed> 7 Mar 2007

Observation:

Check that reestablishment of fire-damaged areas is on schedule at the next surveillance visit.

2007 Update: The re-establishment is ahead of schedule, but should continue to be monitored. TUP on Nyanga is 1354ha or 14% of the total plantable area of 9671ha. On Dunsinane, the TUP is 50ha or 1.8% of the total plantable area of 2822ha.

Follow-up evidence:

14 5.1.1

No further follow-up

Date Recorded> 02.02.2006 Date Closed> 25/2/2009

Observation:

More needs to be done to check whether the system to monitor and assess the effectiveness of training is fully implemented. Some of this was checked (see 7.3), this needs to be checked in more detail at the first surveillance.

2007 Update: This was inadequately checked, but interviews in terms of wetland delineation revealed that there was inconsistency in terms of the determination of buffer zone size. Further follow-up is necessary.

Follow-up evidence:

15 7.3.1

Evidence of the effectiveness is difficult to evaluate, but measured against the decline in injuries, the training was effective.

Date Recorded> 07 Mar 2007 Date Closed> 25/2/2009

Observation:

Drainage of water from roads directly into streams (without filtering through vegetation) at the crossings appears to be a common problem, specifically noted at two crossings on Dunsinane (en route to DuS30, 33 34 3rd pruning), but also on Nyanga. This needs careful monitoring and corrective action.

Follow-up evidence:

16 6.5.2

Road works were busy at the time of the audit and the drains were not all opened up. No areas were seen where the water is drained straight into the streams. Observation 16 closed.

Date Recorded> 07 Mar 2007 Date Closed> 25/2/2009

Observation:

On Dunsinane, there are 10 trained first aiders, and all of their Certificates of Competence have expired (expiry Feb 2007). Apparently re-training was carried out on 15/12/2006 and the certificates are not yet available from the Red Cross. This should be followed up on. Observation 17 was raised.

Follow-up evidence:

17 4.2.3

All first aiders checked at harvesting and other sites had valid first aid certificates. Observation 17 closed.

Date Recorded> 25/2/2009 Date Closed> 18

Observation:

AD 36-A-01 Page 50 of 53

OBS # Indicator Observation Detail

A positive observation is made on the role the company played in alleviating the difficult conditions many Zimbabweans had gone through the past months. Through the help of the company many families had food to eat and schools maintained the education of the kids that would otherwise have not been possible.

Follow-up evidence:

AD 36-A-01 Page 51 of 53

13. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS

Nr Comment Response

Main Evaluation

01 Wattle company had a very disturbing record of injuries on duty, it contributed 15% of workman’s compensation claims in the region. They have not adopted a health management system (it is not mandatory, but they are encouraged to consider this).

The trend has gone down significantly in the past year. The company has developed its own system, taking some standards from NOSA and it is working well – S.H.E. and Training Manager, Personnel Officer

02 The state of the roads in the company’s forests is bad, they are not properly maintained.

The company will do its best to ensure that this situation is controlled. The general economic situation in the country is bad, but the company has tried its best to maintain a certain standard in terms of infrastructural development. Tactical road plans were viewed, as well as APO for roads – this is addressed in the public summary

03 The company management did not consult traditional leaders about cutting down trees with special cultural significance such as Muwuyu, destroying a special ant hill

The company has not cut down any such trees. There is a system to consult with traditional leaders in the identification of culturally significant sites and trees. The management representatives would further consult with the headman and chief to address their particular concerns. It seems to be a question of misinformation on the part of the community leaders.

Surveillance 1

04 There has been good co-operation between Border Timbers, The Wattle Company and Mutare Board and Paper in terms of a catchment based approach to water quality monitoring. This was initiated by Border Timbers, who stated that they were very pleased with the cooperation of the Wattle Company.

This is an excellent initiative by the forestry companies, and first for Zimbabwe.

Surveillance 2

05 There is good appreciation for the way Wattle company has helped and supported the schools and scholars during the difficult times in Zimbabwe.

Response acknowledged. No further comment required.

06 Good interaction and cooperation with government and local government offices were confirmed by officials.

Response acknowledged. No further comment required.

07 Gratitude was expressed for the Wattle company that maintained a high level of local employment in the region during the economic recession.

Response acknowledged. No further comment required.

08 Appreciation was expressed for the medical facilities that the company provided in the region and the emergency services that is provided.

Response acknowledged. No further comment required.

Surveillance 3

Surveillance 4

AD 36-A-01 Page 52 of 53

Nr Comment Response

Main Evaluation

AD 36-A-01 Page 53 of 53

14. RECORD OF COMPLAINTS

Detail

Complaint: Date Recorded > dd MMM yy

Objective evidence obtained:

Close-out information: Date Closed > dd MMM yy

End of Public Summary