Emma Hatcher: That’s correct. Yep. So if you can confirm that they’re certified and your product is certified and at the same time you’re not aware of anything else that would indicate that product might be at risk of illegal harvesting, then that’s a method that you can undertake your risk assessment on. Nick Housego: So if this material comes back to us in Malaysian language as opposed to English, what would you suggest happens in that situation? Emma Hatcher: Well I think to reasonably rely on that information for yourself and of course to satisfy the laws, you should get that information translated to make sure that you can rely it and it actually links back to your product. Neil Garbutt: If I could just step in quickly as well. Both of those schemes that we talk about have got online claims portals, and they’re mainly in English. So you should be able to easily check any certification claims through those online claims portals, so that will help you support using this particular process. Nick Housego: Where do I access those portals? Neil Garbutt: Both of the websites are included on the relevant page on our illegal logging web pages. I can’t tell you off the top of my head. Nick Housego: But if you go into our website under illegal logging, and you’ll pick up the details. Neil Garbutt: You’ll find them there. Yep.
Emma Hatcher: So just to close off on that, there’s some really useful information about the steps and resources that you can use to use this pathway for certification, and as Neil said they will provide you links to those websites where you can put in the claim numbers and check to see that that’s all legitimate and straightforward. So that’s that pathway pretty much. Nick Housego: Okay. The Regulated Risk Factors? Emma Hatcher: Before we go to that one we’ll talk about the Country Specific Guidelines. So we’ve got a slide now showing. Now Country Specific Guidelines is something that’s pretty unique to our laws. As we touched on before Nick, the definition of illegal logging and what you’re really trying to assess the risk against is whether the timber was harvested in accordance with the laws in the country of harvest. So you need to understand I guess a little bit about what those laws are and what they require, and that’s what the heart of these documents are. They set out what the laws and frameworks are in key supply countries, and give you the tools and information to be able to identify what documents or evidence might be available to you to say ‘Okay. Then this supports that my product has been legally harvested’. We’ve got nine Country Specific Guidelines in place, and we’re always looking to negotiate further ones. They’re with our major supply countries. So we’re trying to cover off those key supply chains. And those nine countries are shown on the slide there. Nick Housego: Okay. Alright. So where can importers find the CSGs? Emma Hatcher: So again our website is the sort of single source of truth for these things. We’ve got a ‘Resources for Importers’ page, and that sets out the Country Specific Guidelines which people can download. Associated with each CSG is a document called a Quick Reference Guide, and that’s a quick two pager which will give you a really nice summary of the information that you might be looking for if you’re wanting to import through that pathway.
Nick Housego: You get quite used to it. It’s like doing your BAS statements. Once you get through those – okay. I’ve got a question here. Q: If we brought in printed material such as a paper or booklet or notebooks not intended for sale, only for company staff use and not for distribution, sometimes the value is more than $1,000, do we need to provide the same due diligence process? Neil Garbutt: Nick, I’ll answer that one. It’s probably something we should have touched on earlier, but we didn’t. Printed products, if they’re already printed, such as books, manuscripts, manuals, that sort of stuff, they fall under a separate set of tariff codes that aren’t regulated. So when you’re importing printed materials you don’t have to do due diligence. If you’re importing the raw materials, paper, to then turn into printed materials, you do have to do due diligence because it falls under our regulated tariff code. Nick Housego: Emma? Emma Hatcher: I guess just to add, I think the element of that question was also about if you’re looking to import a product for internal use or internal company use. The ultimate destination or use of the product doesn’t really matter. If it’s regulated or not regulated is the key element there. So if you’re looking just to do it as part of your internal business, then that is still going to be subject to due diligence if it’s a regulated product. Nick Housego: Okay. I’ve got a question here. It’s very open ended. Q: What is the start date for this? Margie Eddington: So the laws have been active for the last five years, and you have been required to comply with them for that period. However as we mentioned, they just went out of soft start on the 1st of January 2018, so this year, and we are now penalising people for non-compliance with the due diligence requirements of the laws.
Neil Garbutt: So there’s been quite a long lead in to this to allow importers to adjust to the laws. So the due diligence elements have been in for now three years, since the end of November 2014. So I think the answer to that is the laws are now live and we’re now expecting you to do due diligence on regulated products. Nick Housego: Okay. Here’s another one. Q: Is the term ‘reasonable risk conclusion’ akin to reasonable or limited assurance as used in the financial non-financial - - - Neil Garbutt: I think we touched on that one. Nick Housego: Believe it not. That’s amazing I’ve picked that up. Go to this one. We’ve got so many questions in here. Q: Suppliers may not want to divulge proof of purchase. What other options are there? Because they’re protecting their commercial in confidence. Margie Eddington: So you do require certain information in order to be able to conduct a proper risk assessment and reach a conclusion of low risk. So you will need to seek that information. Where your supplier is unwilling to give it to you, there might be a number of risk mitigation options available to you that I spoke about earlier, one of which might be seeking a different supplier for your product or requesting that the products have a chain of custody certification scheme such as Emma went through earlier, the FSC or the PEFC certified product. Nick Housego: Okay. Emma, we’ve run through a lot of this stuff fairly quickly today, but I’m getting a sense – and you being of legal background – that the devil’s in the detail, and I think there’s truth in that. I know that we’ll be doing deeper dives on the due diligence process in future webinars, but have we sorted out for example a date for that next webinar yet?