Compliance

Summary of Compliance Policy

Verified Vendor Legality Assurance System

The aim of the Clarke Veneers and Plywood Regulatory Compliance Program is to enable a rigorous assessment and mitigation of supply chain risk, and a demonstrable and consistent basis for confidence in the products we buy and sell. To accomplish these objectives, we have developed and implemented an end-to-end regulatory compliance policy called our Verified Vendor Legality Assurance System.

 

Of the many features of the Verified Vendor System designed to ensure legal and sustainable business opportunities, some of the most significant include our Responsible Sourcing Policy, our supplier review, and our three-way risk assessment matrix methodology. These techniques have been developed by Clarke Veneers and Plywood to meet the unique challenges of our business environment and the information requirements of our customers. They closely follow industry guidelines and best practices.

 

Compliance Program Ethical Guidelines

Clarke Veneers and Plywood is committed to serving the wood industry by buying and selling legally and responsibly sourced products, and to representing these products with integrity in the marketplace. Furthermore, we are dedicated to fostering an accountable and ethical culture of business within our organization and our supply chain. To these ends, Clarke Veneers and Plywood has instituted a systematic approach to regulatory and environmental compliance that involves all employees in many different roles.

Responsible Sourcing Overview

Program Philosophy and Macro Components

Clarke Veneers and Plywood believes a culture of responsibility and regulatory compliance can be fostered through a program comprising three key elements: consistent documentation, conscientious sourcing, and intelligent leveraging of reputable certification resources.

 

In the service of these program elements, the Clarke Veneers and Plywood compliance program includes the following high-level components:

 

  • Legal Sourcing Due Diligence Procedure - Used as a supplier approval criterion to quantify and mitigate risk in our supply chain
  • Forest Stewardship Council Certification and Third-Party Audits - Used to standardize and evaluate legal and responsible trade practices
  • Emissions Compliance Standards Procedure - Used to standardize compliance with CARB and other regulations concerning emissions levels
  • Compliance Training Procedure - Used internally to educate Clarke Veneers and Plywood staff concerning compliance-related protocol

 

Decision-Making Criteria

In accordance with Clarke Veneers and Plywood’s ethical guidelines, our criteria for approving or denying a supplier include the following points:

 

A business opportunity is automatically denied if, to the best of our knowledge, it involves any of the following factors:

 

  • The purchase, sale, or brokerage of material of unknown origin.
  • The purchase, sale, or brokerage of material harvested or distributed illegally.
  • The purchase, sale, or brokerage of material from any individual, company, or nation against which OFAC sanctions exist.
  • The purchase, sale, or brokerage of material of a species not found in the alleged country or region of harvest.

 

The country or region of harvest is considered high-risk if, to the best of our knowledge, it involves any of the following factors:

 

  • The nation/region is extremely politically volatile or corrupt.
  • The nation/region is the subject of specific warnings from widely respected and credible sources.

 

The species is considered high-risk if, to the best of our knowledge, it involves any of the following factors:

 

  • The species is commonly subject to illegal logging or trading.
  • The species is subject to CITES regulation.

 

The supplier organization is considered high-risk if, to the best of our knowledge, it involves any of the following factors:

 

  • The supplier sells goods significantly below market value.
  • The supplier practices unusual sales methods or payment requirements (such as cash only, payments to unrelated third parties, etc.).
  • The supplier is unable to satisfactorily complete our C-SIQ voluntary disclosure.

 

The preceding risk factors are mitigated, to various extents, if the following conditions exist:

 

  • The supplier is currently certified under a reputable legal origin or chain of custody standard, such as OLB, PEFC, SFI, or FSC, for the product under review.
  • The supplier discloses a thoroughly-documented, legal supply chain from harvest to sale.
  • The supplier has a robust, clearly-communicated written legal sourcing program.

 

Summary

Clarke Veneers and Plywood takes responsible sourcing seriously, and continues to expand and reinforce our sourcing policy to affirm our commitment to legal and environmental compliance.