Bureau Veritas Certification
North America, Inc.
SFI Forest Management Audit Report
16800 Greenspoint Park Dr., Suite 300 S
Houston, TX 77060
Phone (281) 986-1300: Toll Free (800) 937-9311

Company Name
Contact Person
Address
Phone / Fax
PQC Code
Contract Number
Certification
Audit:

Manulife Investment Management Forest Management Inc
Natasha Wise
616 Hwy. 395 S.; Colville, WA, 99114
Phone: 509-680-1619 E-mail: nlwise@manulife.com
E01E
US4026579
Re-Certification
Audit:

Surveillance
Audit:

S1

Scope extension
audit:

Audit Summary
Introduction
This report summarizes the results of the first surveillance audit conducted on Manulife Investment
Management Forest Management Inc (MFM)’s SFI program in the Northwest and Northern Inland
Divisions. The audit was conducted by Mr. Richard Boitnott, Bureau Veritas Certification lead
auditor. Mr. Boitnott is an SAF certified forester and has wildlife management expertise. He worked
for forest industry for 22 years in a variety of forestry and wildlife management positions before
beginning his auditing career over 20 years ago.
Audit Scope, Objectives and Process
The scope of the audit is “management of forest lands in California, Oregon, Washington, Idaho, andBritish Columbia”. The audit was conducted against the SFI 2015-2019 FM Standard. SFIS
Objectives 1 through 12, 14 and 15 were covered during the audit. There was no substitution or
modification of indicators. Specifically, two objectives of the SFI audit were to verify that theProgram Participant’s SFI Program is in conformance with the SFI Objectives, Performance
Measures, and Indicators, and any additional indicators that the Program Participant chooses, and toverify whether the Program Participant has effectively implemented its SFI Standard program
requirements on the ground. Standard Bureau Veritas Certification protocols and forms were applied
throughout the audit as provided by the most recent version of the Bureau Veritas Certification SFI
Auditor Handbook available on the auditor portal.
Company Information
MFM is the property manager for investors in the United States, Canada, Australia, New Zealand,Brazil, and Chile. The scope of this certification is limited to its Northwest and Northern Inland
Divisions, consisting of approximately 1,337,309 acres of land in Oregon, Washington, Idaho,
California, and British Columbia.
This audit was conducted in the Western Oregon region out of Medford, Oregon, consisting ofproperties near Roseburg and Medford Oregon, and McCloud California. The Roseburg property is
typical of a northwest coniferous forest; primary species being Douglas-fir and western hemlock,with western red cedar, red alder, Sitka spruce, Noble fir, white fir and grand fir also present. The-7-

Bureau Veritas Certification SFI Forest Management Audit Report V.2.2 –March 2022

Medford property is drier than the coastal areas of Manulife ownership. This area contains more
Ponderosa pine than coastal areas, although Douglas Fir is also present. The commercial species on
the McCloud California property consists of Ponderosa Pine, Douglas Fir, White Fir, and Sugar Pine,
with a minor component of Incense Cedar. Logging systems in Oregon are a combination of groundbased logging and cable skidding depending on slope. California and Medford are more groundbased due to relatively gentler topography. Stands in Oregon are regenerated artificially using
herbicide site preparation and planting. Stands are regenerated with Douglas Fir in the Roseburgarea, and generally with a combination of Douglas Fir and Ponderosa Pine in Medford. Most
harvesting in California is single tree selection, although some even-aged management is practiced
within the strict requirements of the California forest practices act. Clearcuts are very small and are
generally regenerated with a combination of Douglas Fir and Ponderosa Pine. Clearcut stands are
pre-treated with herbicide prior to harvest.
Forest practices acts (FPAs) are in place in Oregon and California. The FPAs prescribes many
activities that support the company’s SFI program. Riparian protection is heavily regulated andmonitored by state agency forest practices foresters. Wildlife management practices are also
regulated in both states. A portion of the McCloud property is in a conservation easement thatproscribes a number of forest and wildlife management requirements.
Audit Plan
An opening meeting was held at 8:00 AM on Monday, June 11, 2022, followed by an off-site
document review of the company’s central office function. Field sites were visited in the Roseburgarea on July 18th and 19th. Field sites in the McCloud area were visited July 20th, and the Medford
area was audited July 21st and 22nd. A closing meeting was held at the close of business on July 22nd.
An audit plan was developed and is maintained on file by Bureau Veritas Certification.
Multi-Site Requirements
MFM maintains a multi-site certification consisting of a central office and nine regions, someassociated with several tree farms. Headquarters of the management system is at the Vancouver
Washington office. The company qualifies for multi-site sampling since the management system iscontrolled and directed by the Manager of Environmental Certification. The Northwest and Northern
Inland Divisions have specific procedures applicable to their operations, with oversight by theManager of Environmental Certification. MFM has an internal auditing and monitoring program.
On-site audits are conducted on a sample of regions each year. MFM also has an excellent
compliance monitoring program that is used by management to monitor all regions on an on-goingbasis. Regions are responsible for developing corrective actions and reporting to the central office.
The company’s auditing and monitoring system is robust and very effective.
Sites covered during the audit were selected based on a randomized schedule developed by Bureau
Veritas Certification at the time of renewal.
Sites
Vancouver Washington (central office)Nanaimo, BC
Coeur D’Alene, ID
Orting, WA (Kapowsin)
Orting, WA (MFC)
Cathlamet (Klickitat, Vernonia, Raymond)
Corvallis, OR
Medford, OR (Medford, Roseburg, McCloud, CA)-7-

Sites Audited
During this Event
X

X
Bureau Veritas Certification SFI Forest Management Audit Report V.2.2 –March 2022

La Grande, OR
Colville, WA
Audit Results
The document review was conducted to determine if MFM’s system documentation continues tomeet the requirements of the SFI 2015-2019 Standard. The central office audit also examined thecompany’s procedures for meeting multi-site requirements. The field audit consisted of a review often harvest sites, seven regeneration sites, all of which have been chemically site prepared, two
spring herbaceous applications, and three road construction/ culvert installation projects. Two
harvest sites were active at the time of the audit. Contractors were interviewed to determine training
requirements, spill and wildfire reporting and response, riparian protection, T&E species protection,and soil impact guidelines.
The audit included an assessment of the certified organization’s plan to transition to the 2022
standard by December 31, 2022. The plan is attached as a separate document.
Objective 1-Forest Management Planning:
MFM continues to operate a robust forest management program. Inventory data is divided byindividual properties. Inventory is stand-level, and a growth-and-yield model is in place to growstands between inventory cruises. The company continues to use a number of variants of FVS as its
growth and yield model. Inventory is now live and is conducted using Lidar. Woodstock andStanley are used for harvest scheduling. Harvest schedules are done when needed but is generally at abiannual basis now. A GIS is in place, with a number of layers needed for planning, including soils,
T&E species, FECVs, streams and other water resources, and sensitive sites. A review of non-timberissues consists of consideration of special sites, T&E species, and conservation easement
development. Stands can be classified in a number of ways, but a land use code provides a basic land
classification system.
Harvest summaries for each property demonstrated MFM is harvesting in accordance with theharvest schedule. Actual versus planned harvest levels were reviewed on a sample of properties
covered during this audit. In most instances, actual harvest levels have been below planned, although
there is some variation over time. In response to market conditions, there are years when harvest
levels are above planned, offset by years when it is below. On average, planned versus actual harvest
levels are fairly close. A review of projected future inventory levels shows some variation between
time periods due to age class distribution, but over time inventory is fairly constant on all properties
reviewed during the audit.
MFM does not generally convert forest cover types in the northwest. However, the company has
developed a procedure for the small amount of conversion it may do. The company reported 80 acresin 2021, a conversion from Douglas Fir to Red Alder due to a forest health issue.
Objective 2-Forest Productivity:
Artificial regeneration is accomplished quickly, well within two growing seasons after harvest. The
company reported 3 acres were regenerated beyond two growing seasons out of the approximately
17,866 acres planted in the 2021-2022 planting season. All artificially regenerated stands arereviewed for acceptable stocking. Douglas fir is the preferred species in Oregon, although Ponderosa
Pine is often in the mix in Medford and McCloud.

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Bureau Veritas Certification SFI Forest Management Audit Report V.2.2 –March 2022

MFM continues to operate a rigorous program to manage herbicide applications. Herbicideprescriptions are well below label maximums. All prescriptions are site specific, applying only theherbicides needed to control vegetation on the site. Aerial applications are very well done, with nodrift into off-target areas. Generous spray buffers are applied to anything that could have water. All
spray buffers met or exceeded state regulatory requirements.
MFM has a variance to use Rozol® to control mountain beavers and strychnine for pocket gopher in
portions of the Pacific Northwest. No Rozol has been used the past four years, and the use ofstrychnine is very limited.
Soil productivity was well protected, with no adverse impacts to soils observed on any of the sites
reviewed during the audit. All employees and contractors interviewed during the audit were wellversed in the company’s guidelines to protect soil productivity.
Objective 3-Protection and Maintenance of Water Resources:
Water quality protection is regulated by FPAs in both states. All harvest and road construction
activities reviewed during the audit met or exceeded state regulatory requirements. Riparian zones
were very well established. The company takes a very conservative approach to riparian protection,
erring on the site of caution when determining what water courses require buffers. All activities aremonitored for compliance with regulations and MFM procedures, with results recorded on an
inspection form.
Objective 4-Conservation of Biological Diversity:
MFM continues to operate an excellent wildlife management program. It has identified threatened
and endangered (T&E) species and Forests of Exceptional Conservation Value (FECVs) that could
occur on its land. The company is using the NCASI/NatureServe multijurisdictional license to gather
information on G1-G5 and S1-S5 species and communities. Company wildlife biologists are
responsible for reviewing this information to determine if species other than G1/G2 needmanagement considerations. The primary T&E species affected by the company’s operations in the
Pacific northwest are the Northern Spotted Owl, Marbled Murrelet, and anadromous fish species.
The company has entered a candidate conservation agreement with assurances (CCAA) for the
Pacific Fisher in Oregon. Among other things, it requires the company to retain three trees per acre
instead of the two required by the Oregon FPA, and to leave some slash piles unburned.
Documentation was provided demonstrating compliance with the tree trees per acre requirement
under the Pacific Fisher CCAA.
MFM is involved in a number of conservation easements. One was reviewed in McCloud. The
McCloud area went beyond the requirements of the conservation easement to improve riparian
habitat along a typed stream. This part of California has very little hardwood in its riparian areas,
particularly aspen. The McCloud area worked with Calfire to develop an “in-lieu” plan, whichallowed for a deviation from the California Forest Practices Act. This allowed the company toclearcut a portion of the riparian zone to propagate the presence of aspen. A visit to the site
confirmed there is an abundance of aspen present in the riparian area. Since the McCloud area
initiated this project on its own and had to jump through considerable loops to make it happen, it
warranted the issuance of a notable practice.
MFM has a landscape assessment program in place that assigns a diversity index to each ownership.
This index is evaluated during harvest scheduling to ensure diversity is maintained for each property.
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Bureau Veritas Certification SFI Forest Management Audit Report V.2.2 –March 2022

Long-term trends in the index are reviewed, with variances of more than 10% analyzed for causes
and potential corrective actions.
Employees interviewed during the audit were well aware of the potential invasive species that could
occur in their area of operations, the most significant being scotch broom, although there are manyother invasive species on the west coast.
MFM has a number of wildlife biologists on staff whose job includes monitoring biodiversity-related
research and working to incorporate those learnings into management activities where appropriate.
Objective 5-Management of Visual Quality and Recreational Benefits:
MFM has a program to provide for visual quality considerations. A visual sensitivity layer is
included in the GIS. Employees are required to review potential visual impacts if a timber saleoverlaps this layer and make adjustments in sale design or take other steps to address the impact.
Considerations includes providing buffers along well-traveled roads, limiting the amount of harvest
area viewable from public roads, and leaving ample retention to break up the harvest block. No
harvest sites reviewed during this audit required any special visual management considerations, as all
were well out of view of the general public
Average clearcut size for 2021 was 51 acres for the Pacific Northwest. All harvest sites reviewed
during the audit met the company’s and state FPA’s green-up requirements. Green-up is also
monitored by forest practices foresters in Oregon. Green-up is a bit of a moot point in California dueto the strict requirements of the California FPA.
Objective 6-Protection of Special Sites:
MFM has a sensitive sites program to protect sites on its property with cultural, historical, or
geological uniqueness. These sites are identified on the GIS, which is used during the planning
process to determine if any of these sites are located within harvest unit boundaries.
Objective 7-Efficient Use of Fiber Resources:
Utilization was acceptable on all harvest units observed during the audit. Utilization is monitored,with results recorded on an inspection form.
Objective 8: Recognize and Respect Indigenous People’s Rights:
MFM has a statement in its policy to respect the rights of indigenous peoples, and to respond toinquiries. The company has historically done an excellent job of communicating with local
indigenous peoples.
Objective 9-Legal and Regulatory Compliance:Primary legal requirements are contained in state FPAs. The system to achieve regulatorycompliance consists of pre-activity planning and in-process inspections. The FPA notification
process in Oregon and the Timber Harvest Plan (THP) process in California also ensures regulatorycompliance. MFM also has a procedure for handling circumstances where a possible noncompliance is identified. A review of publicly available Oregon ODF compliance website indicatedMFM has had no regulatory issues in the past year.
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Bureau Veritas Certification SFI Forest Management Audit Report V.2.2 –March 2022

Objective 10-Forestry Research, Science and Technology:
MFM is a member of NCASI, which provides considerable contribution towards a variety of forestry
and wildlife related research. MFM provided ample evidence the company is contributing toresearch, both directly and through in-kind contributions.
MFM has been a member of the Climate Smart Land Network, which provides data on the potential
impact of climate change on forests and forest productivity, and wildlife and wildlife habitat. The
company also obtains information on the potential impacts of climate change through NCASI.
Objective 11-Training and Education:
Training requirements are identified in the training procedure. However, the company uses a forestry
consulting manager on its McCloud property. There are no MFM specific training requirements that
address a forestry consulting manager. Since this is currently an isolated incident in the PacificNorthwest, the lead auditor determined a non-conformance was not warranted. However, an
opportunity for improvement was issued to encourage the company do develop procedures to address
the use of a forestry consulting manager.
Assignment of roles is found in each procedure. Employees interviewed during the audit were awareof their responsibility for implementing the company’s SFI program. Training records verified
training has occurred as required by the company’s procedures.
All logging contractors are required to have at least one person on each job who is considered
qualified by the SICs. The two contractors interviewed during the audit provided evidence of logger
training. Logging contracts include language requiring contractors to be trained.
Objective 12-Community Involvement and Landowner Outreach:
MFM participates and financially contributes to the SICs in the states/ province in which it operates.
The company’s involvement includes the establishment of inconsistent practices policies for all SICs
within the company’s ownership. MFM has a process to receive and respond to any inquiries. No
reports of inconsistent practice have been received by the company. The company produced ample
evidence of its involvement in public outreach efforts. Some examples have been local involvementwith the Coquille and Douglas County watershed boards. Some activities have been put off the past
couple of years due to COVID but are slowly being resurrected. The company is also working on
setting up a scholarship program for graduating high school kids. MFM remains very engaged inoutreach with the public even with the obstacles posed by COVID-19.
Objective 13: Public Land Management Responsibilities: N/A
Objective 14-Communications and Public Reporting:The 2021 renewal audit report contained all the requirements of the standard. The report was foundon the SFI, Inc. website as required for public posting. Submission of the SFI annual progress reporthas been delayed by SFI, Inc. The company has the accounting and GIS capabilities to complete theprogress report.
Objective 15-Management Review:-7-

Bureau Veritas Certification SFI Forest Management Audit Report V.2.2 –March 2022

MFM has a management review process in place. The review includes an analysis of internal andexternal audit results, and data gathered from the company’s environmental performance program.
The company conducts a management review on at least an annual basis as required by the standard.
Findings
Previous non-conformances:
No non-conformances were issued during the previous audit.
Non-conformances:
No non-conformances were issued during this audit.
Opportunities for Improvement:
One opportunity for improvement was issued. This should be considered in light of how it may
affect conformance in the future.
1. PM 11.1, Ind. 4: MFM may want to add MFM specified training requirements for consulting
managers in the training procedure and providing evidence this training has occurred. The
company only has one consulting manager in the northwest, so this is not considered a nonconformance.
Notable Practices:
One notable practice was issued.
1. PM 4.1; Ind 1: The McCloud area of the Western Oregon region initiated a program to
improve riparian habitat along a typed stream. This part of California has very little
hardwood in its riparian areas, particularly aspen. The McCloud area worked with Calfire todevelop an “in-lieu” plan, which allowed for a deviation from the California Forest Practices
Act. This allowed the company to clearcut a portion of the riparian zone to propagate thepresence of aspen. This portion of McCloud is in a conservation easement but conducting
this kind of habitat restoration is not required. The McCloud area initiated this project on its
own, and had to conduct considerable reviews with Calfire and other entities, thus warranting
the issuance of a notable practice.
Logo/label use:
MFM is using the SFI logo on the HTRG website with approval from SFI, Inc. The company does
not use the BVC logo.
SFI reporting:A review of the SFI website provided evidence MFM submitted its 2021 renewal audit report as
required for public review.
Review of Previous Audit Cycle
N/A

Conclusions

Results of the audit indicate MFM’s Northwest division continues to implement a management
system that meets the requirements of the SFI 2015-2019 FM Standard. The company isrecommended for continued certification to the SFI 2015-2019 FM Standard.

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Bureau Veritas Certification SFI Forest Management Audit Report V.2.2 –March 2022

SEE SF61s FOR AUDIT NOTES

Summary of Audit Findings:
From: July 11, 2022 (HQ)
To: July 11, 2022 (HQ)
July 18, 2022 (Roseburg)
July 19, 2022 (Rosburg)
Audit Date(s):July 20, 2022 (McCloud)July 20, 2022 (McCloud)July 21, 2022 (Medford)
July 22, 2022 (Medford)
Number of SF02’s Raised:
Major:
0
Minor:
0
Is a follow up visit required:
Yes
No
X Date(s) of follow up visit:
Follow-up visit remarks:

Team Leader Recommendation:
Corrective Action Plan(s) Accepted Yes
No
N/A X Date:
Proceed to/Continue Certification
Yes
X No
N/A
Date:
7/22/2022
All NCR’s Closed
YesNo
N/A X Date:
Standard audit conducted against:
1) SFIS 2015-2019 FM Standard
3)
2)
4)Team Leader (1):Team Members (2,3,4…)
Richard Boitnott; CF, TX AF 2)
3)
4)
5)
Scope of Supply: (scope statement must be verified and appear in the space below)
Management of forest lands in California, Oregon, Washington, Idaho, and British Columbia
Accreditation's
Number of Certificates
Date

TBD

ANAB
1
Proposed Date for Next Audit Event

Audit Report Distribution
MFM: Natasha Wise-nlwise@manulife.com
BVC: Lorisa Love-lorisa.love@us.bureauveritas.com-7-

Bureau Veritas Certification SFI Forest Management Audit Report V.2.2 –March 2022

ClauseOpening
Meeting

Closing
Meeting-7-

Audit Report
See attached list
Introductions
 Scope of the audit Audit schedule/plan Nonconformance types – Major / Minor
 Review of previous nonconformances - 0.
Discussions:  Process approach to auditing and audit sampling Confidentiality agreement
 Termination of the audit
 Appeals process Closing meeting timing
Participants: See attached list Introductions and appreciation for selecting Bureau Veritas Certification.
 Review of audit process - process approach and sampling.
 Review of OFIs and System Strengths
 Nonconformances - 0
 Date for next audit.
Discussions:  Reporting protocol and timing
Participants:

Bureau Veritas Certification SFI Forest Management Audit Report V.2.2 –March 2022