BEHIND THE VENEER

MAX SIZE = N/AMIN SIZE = 30mm

exclusion zone, white area to be kept clear DO NOT PRINT BOX

exclusion zone, white area to be kept clear DO NOT PRINT BOX

How Indonesia’s Last Rainforests are being Felled for Flooring

EIA/Telapak investigations, thisreport tracks the trade in merbaufrom Papua, via the factoriesprocessing merbau for theworld’s biggest flooring brands,to the shelves of the leading DIYand home improvement retailersof Europe and North America.

Providing case studies on some of the biggest players, the reportcontrasts the environmentalclaims touted by specificEuropean and Americancompanies with the realityinvestigators found behind theveneer. It reveals that – thoughthey are not themselves breakingany law – these global flooringcompanies do not know theprecise origin of all the merbauthey are selling, that much of thewood originates in Papua, andthere is no way of being certain it

was not illegally sourced. It alsooutlines specific examples ofillegal activities by Asiancompanies supplying some ofthese major brands.

While suppliers and retailers ofmerbau flooring must stop dupingtheir customers and take urgentsteps to ensure the legal origin oftheir wood, this briefingconcludes that it is ultimately theresponsibility of governments inwestern consuming countries toensure that stolen timber is notallowed to reach the shelves. Yetdespite repeated promises to act,there are currently no laws in theUS or Europe which prohibit theimport or sale of timber or woodproducts which were illegallysourced. Until such laws areenacted, western companies willcontinue to profit whileIndonesia’s and Papua’s lastfrontier forests are floored.

Demand-driven illegal logging inIndonesia is destroying one ofthe world’s most importantremaining tracts of undisturbedtropical forest. Despiteunprecedented enforcementoperations by the Indonesiangovernment, every day thousandsof hectares of Indonesia’s forestsare cut illegally to supply thethousands of factories acrossAsia. Much of this timber isdestined for the shelves of highstreet retailers and builder’smerchants in the EuropeanUnion and North America.

Merbau, a highly valuablehardwood, is being ruthlesslytargeted by illegal loggingsyndicates in Indonesian Papuato supply the booming demandfor tropical hardwood flooring.Outlining the results of recent

Theft of Indonesia’sRainforests 1

A Fashion for Flooring 3

Behind the Brand 4Case studies:

1. Armstrong/Bruce 4

2. Junckers 6

3. Tarkett 8

4. Kahrs 10

5. Goodfellow 1 1

Summary Tables 12

Conclusions and 13Recommendations

ACKNOWLEDGEMENTS

This document was produced with the financial assistance of the EuropeanUnion. The contents of this document are the sole responsibility of EIA/Telapakand can under no circumstances be regarded as reflecting the position of theEuropean Union. EIA/Telapak would also like to thank the Sigrid Rausing Trustand other donors for their generous support of our work.

This briefing was written by Jago Wadley, Pallavi Shah and Sam Lawson. It wasedited by Sam Lawson, Julian Newman and Arbi Valentinus. Additional researchby Sascha von Bismarck, David Groves, Vanessa Frey and Timer Manurung.Picture research by Tom Thistlethwaite.

Report design by fullstopdesign.co.ukMany thanks to Emmerson Press for the printing of this report. Emmerson Press +44 (0)1926 854400Printed on recycled paper.

March 2006 ISBN: 0-9540768-2-4

Executive Summary

contents

Top left: Map of Indonesia and Malaysia.

Front cover: Papuan merbau logs in the yard of Seng Fong, Indonesia, August 2005.© Sam Lawson / EIA / Telapak

Theft of Indonesia’s Last Rainforests

1

The Theft ofIndonesia’s LastRainforestsThe global scourge of illegal logging is one of themost pressing issues facing the planet today. Oneof the countries most affected is Indonesia, whereup to eighty per cent of logging is illegal.(1) Thisrampant timber theft has led to one of the highestrates of deforestation in the world – every year 2.8 million hectares are lost, an area almost aslarge as Belgium.(2)

The social and environmental implications ofthis criminal destruction are staggering. Everyyear illegal logging robs the Indonesiangovernment of an estimated $4.3 billion in much-needed revenue.(3) The loss of precious forests totimber thieves is leading to devastating floods andlandslides and driving rare plant and animalspecies ever closer to extinction.

The rampant looting of Indonesia’s forests isdirected by millionaire timber barons looking tomake easy profits. Hungry for cheap timber andheedless of its source, the consuming nations ofEurope and North America callously continue toconsume stolen wood, spurring the timber baronson in order to meet their demand.

Having already stripped the once emerald-green islands of Borneo and Sumatra of much oftheir jungle, the focus of the illegal loggers inIndonesia has now turned to the remote Papuaprovince on the island of New Guinea, home tothe largest single remaining tract of tropicalforest in Asia. Seventy per cent of New Guinea(divided between the Indonesian province ofPapua in the west and the country of Papua NewGuinea in the east) is still covered in rich denseforest thriving with unique flora and fauna.(4)

Recently a host of new species of plants andanimals were discovered deep in the forests ofPapua province by scientists who dubbed the areaas ‘the closest place to the Garden of Eden as you’regoing to find on Earth’.(5)

By far the most valuable timber in the Papuanforests is merbau (Intsia spp.). A dark, luxurious,red wood, merbau is primarily used for themanufacture of ‘exotic’ hardwood floors, whichcan command prices of up to $138 per squaremetre.(6) Though it is also found in nearbyMalaysia, most remaining commercial stands ofmerbau are confined to the island of New Guinea.

In February 2005, EIA/Telapak released areport, ‘The Last Frontier’, which exposedrampant illegal logging in Indonesian Papua anddocumented the mafia syndicates smuggling

300000 cubic metres of stolen merbau logs out ofthe province every month. The logs, accompaniedwith false paperwork, were departing aboardfleets of giant cargo vessels, in violation of a banon log exports enacted in 2001. Most of thetimber was going to feed China’s mammoth woodflooring industry. The report also revealed thecentral role of the Indonesian military in thetimber theft and the intimidation of Papuancommunities trying to protect their lands.(7)

EIA/Telapakhavedocumentedrampantillegallogging ofmerbau inPapua.

Above: The Smoky

Honeyeater: newly

discovered in Papua’s

‘Garden of Eden’.

Left: Forest resources

are being stolen from

traditional Papuan

communities.

© B

ruce

Bee

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/AP

/EM

PIC

S

© D

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Theft of Indonesia’s Last Rainforests

2

The following month, Indonesian PresidentSusilo Bambang Yudhoyono responded with acrackdown on illegal logging of unprecedentedscale. The enforcement operation in Papua resultedin the seizure of more than 400000 cubic metres ofstolen logs and sawntimber, plus a host of trucks,ships and logging equipment.(8) More than 170people were arrested, including police, army andforestry officials. Altogether, timber and equipmentworth almost a quarter of a billion dollars wasconfiscated, and the impacts of the enforcementoperation in Papua were felt in timber marketsaround the world. As supplies of merbau waned,prices rocketed: in February 2005 logs werechanging hands in China for as little as $278 – by October they were selling for up to $732.(9)

Yet Papua’s forests are still far from safe.Corruption surrounding the sale at auction of theseized timber has meant the government hasreceived only two per cent of the $216 million inrevenue which was expected.(10) In December 2005the National Police Chief admitted that evidenceexisted showing that the companies from whichthe logs were originally seized had in many casesmanaged to buy them back at artificially deflatedprices.(11) Since the special enforcement operationended in May 2005, the timber barons and theircorrupt cronies in the local bureaucracy andmilitary have adapted their cutting and smugglingoperations and are now back in business. InFebruary 2006 1000 illegal logs were seized froma company in the district of Bintuni, which policeclaimed had been regularly shipping logs illegallyto Java between September and December of theprevious year.(12) Though it has become more

difficult to export logs, new sawmills are nowspringing up to process the stolen wood in orderto ease its passage.(13) The situation in Papuaremains chaotic, there are no independentlycertified forests, and all wood which originatesthere must still be treated with suspicion.

The enforcement efforts in Papua have beencritically undermined. The return of illegallogging has been made almost inevitable by thefailure of the consuming countries of stolenmerbau in Asia, Europe and North America to haltimports and control demand. Shockingly, itremains perfectly legal in most instances inEurope and North America to import or selltimber which was illegally sourced in the countryof origin. Though the European Union hasrecognised this failing, so far they have onlycommitted to setting up voluntary bilateralschemes to exclude illegal timber from willingpartner countries. Even these will not coverprocessed wood products like flooring.Independent studies have shown that a broad-based ban on the import and sale of stolen woodis needed, and the call for such a law to beenacted is supported by much of the industry, byall the large NGOs, and by the UK’s ParliamentaryEnvironmental Audit Committee.(14) Three yearsago the EU promised to consider such ameasure,(15) yet so far it has failed to face thisurgent issue, clearly preferring a weakervoluntary approach.

In the meantime, as this briefingdemonstrates, companies in Europe and the US,their imports unregulated by government,continue – albeit unwillingly – to drive thedestruction of Papua’s forests, demanding woodat any cost and with few questions asked.

All wood fromPapua mustbe treatedwithsuspicion.

Top right: Illegal

logging in Wasur

National Park, Papua

January 2006.

Below: Illegal merbau

logs awaiting

collection, Seremuk,

Papua, February 2003.

© J

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/EIA

/Tel

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A Fashion for Flooring

3

A Fashion for FlooringAs carpet and linoleum have dropped out of fashion,over the last decade sales of wood flooring in Europeand North America have grown dramatically. Therecent proliferation of home improvement televisionshows has helped popularise wood flooring asfashionable, modern and practical, while designinnovations and a plentiful supply of cheap rawmaterials have served to bring down prices andbroaden the market. Though much of this growth ismade up of cheap laminate flooring (not generallyincluded in references to wood flooring), sales ofreal wood flooring have also more than doubledsince the mid-nineties.

More wood flooring was sold in 2004 than everbefore, with Europe and the US consuming anestimated 189.5 million square metres – enough tofloor the entire area of Washington DC.(16)

Consumption of wood flooring in the US alone roseby 40 per cent in the five years to 2004, when salesof $2.4 billion were recorded.(17) The figure for 2005is expected to be at least five percent higheragain.(18) Germany is the largest market for woodenflooring in Europe, followed by Spain, Italy and theNordic countries.(19) Sales in the UK were wortharound $118 million in 2004.(20)

In North America and Europe, sales of woodflooring are dominated by a small coterie of giantmanufacturer-distributors. These companies eithermanufacture flooring in their own factories orcontract out the production to facilities in Asia.They distribute the finished flooring in major retailoutlets under their own brand names. The top fourcompanies had combined worldwide sales of $1.46billion in 2004.(21) By far the largest wood flooringcompany in the world is the US company ArmstrongIndustries Inc., which recorded turnover in its woodflooring divisions of $832 million in 2004.(22) Thenext biggest company is German-based Tarkett,followed by Swedish outfit Kahrs. Danish companyJunckers, the largest supplier of solid wood flooring,completes the top four.

Although oak has traditionally been the mostcommonly used species for flooring in Europe andthe US, demand is shifting to darker and more‘exotic’ wood species – code for tropical wood. Allthe major floor manufacturers in Europe and the UShave ‘exotic’ ranges of flooring made with tropicaltimber. Merbau is the most common species used,and features in the ranges of all the major brands.Flooring is also available in teak, balau and kempasfrom SE Asia, jatoba from South America, and inAfrican woods such as iroko.

In every case there are numerous documentedexamples of illegal logging of these tropical speciesin source countries. Teak flooring is usually made

WOOD FLOORING FACTFILEThere are three different kinds of real wood flooring – solid,engineered and parquet. Though it is produced with woodfibre, cheap laminate flooring relies on photographicreproduction of wood grain for its appearance. References towood flooring in this report do not include laminates.

Solid wood floor – This is flooring with one piece of wood fromtop to bottom. Solid wood flooring is sold as single planks ofwood 14 to 22 mm thick.

Engineered floor/multilayer floor – This is flooring with a top-layer veneer of hardwood usually 3-7mm thick. Thislayer is glued on to lower layers of cheaper wood orfibreboard. The vast majority of real wood flooring soldworldwide is of the engineered variety.

Parquet/Mosaic – this refers to small blocks of solid woodwhich are laid in a pattern formation.

with timber from Burma, where two-thirds of timberexports are illegal.(23) Most of the kempas and balauin trade originates in Indonesia’s Sumatra andKalimantan where illegal logging is the norm.Brazilian jatoba supplied by companies suspected ofinvolvement in illegal activities has recently beenshown to have been used in a museum in Spain.(24)

Lesser-known African species doussie and iroko arelikely to have originated in Gabon or Cameroon,where at least half of all logging is estimated to beillegal.(25) Most of the temperate species used inflooring have also suffered from illegal felling, mostnotably in the Russian Far East.

The brochures of the big European and NorthAmerican companies supplying merbau flooring arereplete with references to the supposedenvironmental credentials of their products. Theyprovide assurances to concerned consumers that thetimber used is all ‘carefully selected’, or comes from‘sustainably managed forests’. They may also statethat new trees are planted every time old ones arecut. Over the past year, EIA/Telapak sought to testthese claims. They did not stand up to close scrutiny.

Merbau isthe mostpopulartropicaltimber usedin flooring.

Above: hardwood

flooring sales are at

record levels.

© R

icha

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offk

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Case Study 1: Armstrong/Bruce

Behind the Brand

4

EIA/Telapak have explored the supply chains ofthe major merbau flooring brands from every angle.Investigators visited the high-street retail chains inEurope and the US where merbau flooring is onsale, called the big flooring companies in the guiseof consumers, and visited their suppliers’ factoriesin Indonesia and Malaysia posing as buyers.EIA/Telapak has also sent open letters to thecompanies requesting information.

EIA/Telapak’s investigations covered all thelargest flooring brand names, includingArmstrong/Bruce, Kahrs, Junckers, Tarkett, andmany smaller suppliers. The trail of merbauflooring supplied by these companies led onwardto the doors of leading EU and US retailers,including three of the world’s largest DIY chains.

There is no indication that any of thesecompanies have broken any law – nor is thereevidence that they are fully aware of the potentialorigin of the wood they are supplying. But ourinvestigations have shown that far from being‘carefully selected’ or ‘sustainably cut’, thesecompanies have no idea precisely where most ofthe merbau wood used in their flooring comesfrom – nor have they made much effort to findout. Moreover, our research shows that most ofthese companies are using merbau which comesfrom Indonesia’s Papua province, where the vastmajority of logging is illegal and where certifiedtimber is unheard of. In the absence of evidenceto the contrary, in all probability much of themerbau they are selling was illegally sourced.

• US-based Armstrong is the largestflooring company in the world, withworldwide sales of wood flooring in2004 of $832 million; Armstrong sellsmerbau flooring under the Bruce,Hartco and Robbins brands.

• Armstrong merbau flooring is supplied byIndonesian company PT Tanjung Kreasi.

• Kreasi buys all its merbau as logs fromPapua, purchased through agents on the spot market.

• Kreasi’s clients do not demand timberto be certified as sustainably harvested.

Armstrong World Industries Inc. is the world’sbiggest flooring company, holding a portfolio offlooring brands including leaders Bruce, Robbins,and Hartco, all of which include merbau flooring intheir ranges.(26) Despite claiming that the company’sflooring is ‘made from select lumber and harvestedresponsibly’,(27) Armstrong publish no evidence forthese claims. In a letter to EIA/Telapak, Chairmanand Chief Executive Michael D. Lockhart statedArmstrong’s supplier contracts ‘insist ondocumentation on the chain of custody for wood webuy’, and that ‘when we have requested it’ itssupplier provided such documents.(28) However, Mr Lockhart did not specify how often thesedocuments were actually requested, and notablyfailed to supply any examples.

Behind the Brand

• Kreasi admits that merbau trees arebecoming scarce in Papua through a lackof re-planting.

• Kreasi staff admit that they cannot besure where the company’s merbaucomes from or if it is legal.

• Armstrong merbau flooring is marketedin The Home Depot and Lowe’s homeimprovement stores in the US and inJewson and Allied Carpets stores in theUK. Leroy Merlin stores across Europealso market merbau flooring byTangung Kreasi.

EIA/Telapakhave exploredthe supplychains of themajor merbauflooringbrands fromevery angle.

Below: Armstrong’s

Bruce flooring, on sale

at The Home Depot,

USA, January 2006.

© E

IA/T

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Behind the Brand: Armstrong/Bruce

5

Data from the US Port Import ExportReporting Service (PIERS) reveals that Armstrongbuys merbau flooring from Indonesianmanufacturer PT Tanjung Kreasi Parquet Industry(Kreasi).(29) Kreasi is one of the world’s biggestengineered wood flooring manufacturers, andexport to 45 countries.(30) Kreasi markets itsflooring under the Teka brand name, though it alsoproduces private-label products for brands likeArmstrong. In the first ten months of 2005Armstrong imported almost three thousand tonnesof flooring from Kreasi into the US.(31)

EIA/Telapak undercover investigators visitedKreasi in August 2005 and met marketing executiveMs Titin Siswadi, who confirmed that around a tenthof their 5 million square metre annual output wasmerbau, and that the company supplies Armstrong.She stated that all of Kreasi’s merbau originates aslogs from Papua, which it buys on the spot marketfrom middlemen for shipment to their factory inJava. EIA/Telapak later documented a barge loadedwith Papuan merbau logs at Semarang port in Java,which dock workers stated were owned by Kreasi.Ms Titin explained how Kreasi buy about 3000 cubicmetres of merbau logs from Papua every 6-8 weeks,equivalent to around 24000 cubic metres per year.She admitted on camera that the company could notknow precisely where any of the company’s merbauwas harvested, or be sure it was legal – directlycontradicting claims Armstrong’s Chief Executivelater made to EIA.

EIA Investigator: ‘So when you buy the merbau onthe spot market, you won’t have any knowledge ofwhere it comes from at all?’Ms Titin: ‘No. No.’EIA Investigator: ‘So there is no way of proving itwas sustainable or legal even?’Ms Titin: ‘No, no.’

When Ms Titin was asked about timbercertification, she said that though the companycould do it, there was no demand from clients.

Buyers were far more concerned about prices, andknowing legal and certified timber costs more,few if any demanded high environmentalstandards. Even if its clients asked for certifiedmaterials Ms Titin pointed out that no certifiedmerbau was available to Kreasi.

Ms Titin said the prices Kreasi pay for itsPapuan merbau logs had more than doubled inrecent months, from $110 to $240 per cubicmetre. She cited government enforcement onmerbau smuggling from Papua and a scarcity dueto the lack of replanting as the reasons for thisincrease. As such, regardless of whether theywere knowingly buying illegal timber themselves,Kreasi, and in turn customers like Armstrong,certainly will have enjoyed the artificiallysuppressed prices that illegal Papuan merbaugenerated in the market for so long.(39)

Merbau flooring supplied by Armstrong is onsale in branches of the two largest homeimprovement chains in the US – The Home Depotand Lowe’s.(32) It is also sold in branches of Jewsonin the UK. Kreasi’s merbau flooring is sold inLeroy Merlin, Europe’s second largest DIY andhome improvement chain, which has stores acrossthe continent.(33)

Armstrong’sIndonesiansuppliersadmit theycannot besure wheretheir merbaucomes fromor if it islegal.

Far left: Ms Titin Siswadi

of Tanjung Kreasi,

supplier of merbau

flooring to Armstrong,

August 2005.

Middle: Bruce merbau

flooring on display in

Lowe’s, USA, January

2006.

Left: Jewson in the UK

also market Bruce

merbau flooring.

Below: Barge loaded

with merbau logs

from Papua owned

by Tanjung Kreasi,

Semarang port,

Java, Indonesia,

September 2005.

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/Tel

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© E

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© Victor Wu / EIA / Telapak

Danish company Junckers Industrier A/S isEurope’s largest manufacturer of solid hardwoodflooring, and Denmark’s biggest wood processingcompany.(34) The company sold €91 million of woodflooring in 2004, a significant proportion of itmerbau.(35) Junckers’ publicity materials state thatthe company ‘select wood only from carefullymanaged forests’.(36) In a letter to EIA/Telapak,Junckers also said that the company ‘encourage[their] suppliers to deliver environmentally soundraw materials.’(37)

The truth of such statements was originallycalled into question in 2004, when environmentalgroup Greenpeace discovered that up to 30 per

Behind the Brand: Junckers

6

Case Study 2: Junckers

• Danish company Junckers are the fourth largest wood flooring company in the worldand the largest distributor of solid merbau flooring.

• All Junckers’ merbau flooring is manufactured by Malaysian company Kim Teck Lee (KTL).

• 80-90% is bought on the spot market in Indonesia and cannot be traced to source.

• KTL supplied no proof of legal origin, other than that the timber is ‘containerised’.

• Illegally exported rough sawn Indonesian merbau was seen in KTL’s Malaysian factory.

• Junckers resisted a request by KTL to halt sales of merbau due to supply shortages,and has instead pushed them to ‘take risks‘ to meet demand.

• Junckers merbau flooring is marketed in John Lewis, Travis Perkins and Jewson storesin the UK, in numerous independent retail outlets in the US, and through many web-based distributors.

cent of Junckers’ merbau originated in Indonesia,rather than in Malaysia as Junckers had claimedin response to requests for information fromarchitects.(38) EIA/Telapak investigations havesince confirmed that Junckers’ Malaysian merbauflooring suppliers actually source up to 90 percent of their raw materials in Indonesia, that theyhave no idea of the precise origin, and that theyhave traded the wood illegally.(39)

In August 2005, EIA/Telapak investigatorsposing as traders visited Malaysian flooringmanufacturer Kim Teck Lee Timber FlooringSdn.Bhd.(KTL), which manufactures all ofJunckers’ merbau flooring. KTL’s marketingdirector Mr Lee Ah Keat revealed how thecompany supplies about 23000 square metres ofmerbau flooring a month to Junckers, and thateighty to ninety per cent of the merbau usedoriginates in Indonesia. Lee explained how hesourced the Indonesian wood through agents inthe town of Surabaya who in turn purchase woodon the open spot market.

It is practically impossible to know the preciseorigin of timber purchased in this manner, thoughone of Lee’s colleagues stated that the companycertainly buys merbau from the province of Papua.When Lee was asked whether he could prove thelegality of his Indonesian merbau supplies, he wouldnot say he could strictly prove it, but insteadmentioned that most illegally traded merbau ismoved as logs on barges, whereas ‘… at least whenwe bring in, it is in container loads…’, implying thatsince it was not logs, it was legal. In fact Indonesiahad implemented a ban on exports of sawn timbernearly a year before our visit, meaning KTL’simports of sawn merbau were more likely proof of

Illegallyexportedrough sawnIndonesianmerbau wasseen beingunloaded.

Below: Smuggled

Indonesian rough

sawn merbau at the

factory of Junckers’

Malaysian suppliers,

August 2005.

© E

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Behind the Brand: Junckers

7

illegality. Indeed, though Mr Lee had admitted tobeing aware of the Indonesian ban, during a tour ofthe KTL factory EIA/Telapak saw rough sawnmerbau being unloaded from a container which wewere told had just arrived from Indonesia. Thistimber must have been illegally exported.

In a letter to EIA/Telapak, Junckers enclosedan Indonesian ‘BRIK’ export document for ashipment of ‘merbau ship decking’ issued to anIndonesian company called PT Indo FurnitamaRaya (Ifura), claiming this as proof of the legalityof its raw material supplies.(40) While thedocument only relates to a tiny proportion of themerbau used in Junckers flooring, even that whichis covered remains of questionable origin. The UKTimber Trade Federation has previously statedthat BRIK documents alone are insufficient toguarantee legality(41).

Mr Lee was aware of the enforcementcrackdown against illegal merbau cutting inIndonesia, and cited this as a reason he was nowhaving great difficulty in finding enough merbautimber to supply Junckers’ demands, furtherimplying that much of his merbau had beenillegally sourced in the past. Junckers wereapparently unimpressed with his recent sourcingdifficulties and resisted his request that thecompany stop marketing merbau for at least amonth. Indeed, Mr Lee revealed that KTL isconsistently pressured into taking risks to meetorders of uncertified merbau for contracts pre-soldthrough Junckers’ huge marketing machine. Thispressure was reiterated when Lee highlightedJunckers’ recent order for 45000 square metres ofmerbau flooring for just one building project inAmerica. Lee related to EIA/Telapak investigatorshow he told Junckers ‘no, forget about it’, againblaming supply shortages, to which Junckersreplied ‘…you take the risk…’, according to Lee.(42)

Junckers’ solid merbau flooring is marketed inJohn Lewis, Travis Perkins and Jewson stores in theUK, in hundreds of independent retail outlets in theUS, and through many web-based distributors.(43)

Top: UK Builders’

merchant Travis

Perkins sells

Junckers’ merbau

flooring.

Above: Inside Kim

Teck Lee's factory,

Selangor, Malaysia,

August 2005.

Left: Merbau flooring

in Junckers’

packaging awaiting

shipment at KTL

factory, Malaysia,

August 2005.

Far left: Mr Lee Ah

Keat of Kim Teck Lee,

Junckers' Malaysian

merbau flooring

supplier, Malaysia,

August 2005.

© S

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© E

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© Sam Lawson / EIA / Telapak

© J

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/Tel

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Junckerspressures its supplierto take risksto meetdemand.

Tarkett is the largest wood flooring company inEurope, and merbau engineered flooring is one ofthe company’s top five sellers.(44) Tarkettadvertises on its company website that it buystimber independently certified as sustainablysourced by the Forest Stewardship Council (FSC),citing this as proof of the company’senvironmental credentials.(45) FSC are the best

known and most trusted environmentalcertification system for wood products, and thename and logo can earn significant additionalsales in sensitive markets.

In August 2005 undercover EIA/Telapakinvestigators contacted the head office of thecompany’s flooring arm and requested informationabout their merbau range. Marketing managerCarsten Bertelsen subsequently emailed a copy ofan FSC chain-of custody certificate verifying thatthe company is qualified to handle FSC wood, andstated that ‘our products – sold under the chain ofcustody certificate – contain minimum 70 % FSCcertified raw material, and the remaining 30% arefrom controlled sources. Our merbau is sourcedfrom Temenggor lake in Malaysia. We can ensure[sic] you it is from controlled sources’. Staff at anAllied Carpets branch in the UK, enquiring aboutFSC certification of Tarkett wood flooring onbehalf of EIA/Telapak investigators, stated that

Behind the Brand: Tarkett

8

• Headquartered in Germany, Tarkett are the second largest wood flooring company inthe world and the largest in Europe, with global sales of $329 million in 2004.

• Tarkett staff stated in August 2005 that the company’s merbau is legally sourced from Temenggor Lake, Malaysia.

• In fact all logging at Temenggor has been halted since the end of May 2005 after the companies involved were shown to have been cutting merbau trees illegally inadjacent protected forests.

• Tarkett continues to sell merbau flooring though this source of raw materials no longer exists.

• Tarkett staff falsely claimed to currently sell wood flooring certified as legal andsustainable by the Forest Stewardship Council (FSC).

• Tarkett failed to respond to a formal request from EIA/Telapak for information ontheir merbau supplies.

• Tarkett branded merbau flooring is marketed in branches of The Home Depot in theUS, Allied Carpets in the UK and in numerous other retail outlets across Europe.

Case Study 3: Tarkett

Tarkett is thelargest woodflooringcompany inEurope.

Below right: Tarkett

branded merbau

flooring marketing

display at Lowe's,

January 2006.

Below: US retail giant

The Home Depot sells

Bruce & Tarkett

merbau flooring.

© E

IA/T

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© E

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Behind the Brand: Tarkett

9

Tarkett had also told them that ‘all Tarkett woodproducts are FSC certified’.(39)

EIA/Telapak investigators, unable to findTarkett flooring on sale with FSC labels, latertelephoned Mr Bertelsen under another guise toask about current availability of FSC certifiedflooring. Though he initially claimed that only‘certain ranges’ of their wood flooring wereavailable with seventy per cent FSC content,Bertelsen eventually conceded that in fact Tarkettdo not currently stock or sell any FSC-certifiedflooring products – though he claimed it had atsome point in the past. This directly contradictsthe claims made to Allied Carpets and toEIA/Telapak investigators posing as buyers,proving that the company are deliberatelymisleading customers over their environmentalcredentials. EIA/Telapak have forwardedinformation regarding the apparent misuse of theFSC trademark by Tarkett to the relevantauthorities.(39)

Mr Bertelsen’s claims in relation to the originof Tarkett’s merbau timber are also in doubt. It istrue that in the past there has been a small supplyof merbau logs from underwater cutting of treessubmerged when Temenggor lake was created aspart of a hydroelectric project in the 1970s.However, two months before Tarkett claimed to beusing merbau from the lake all cutting there wassuspended indefinitely. The logging companiesinvolved had been accused of illegally cuttingmerbau trees in protected forests adjacent to thelake (see box on right).(46) Ten months on, thecompany is still selling merbau flooring, yet it is unclear where it is getting its ‘controlled’ timber supplies.

In January 2006 EIA wrote to Tarkettformally asking for information about the currentsourcing of its merbau timber. Two months laterno reply had been received. Tarkett merbau woodflooring is marketed in branches of The HomeDepot across the US, in branches of AlliedCarpets in the UK and in numerous other retailoutlets across Europe and North America.(47)

TEMENGGOR LAKE:THE BOTTOMLESS‘SUSTAINABLE‘ MERBAUSUPPLYTwo of the largest merbau flooringsuppliers, Kahrs and Tarkett, have bothclaimed to buy much of their merbauraw material from trees which lieunderwater in an artificial lake createdas part of a hydroelectric project. Theygive this as evidence that their merbauis legally sourced. The lake in questionis at Temenggor in Peninsular Malaysia,and it is true that in the past a smallquantity of old merbau logs were beingcut by divers at the lake each year. Butthe amount of timber involved is far toolittle to meet the combined demand ofthese two giant flooring suppliers, whilerecent revelations have shown that evensome of this timber is likely to havebeen illegally sourced.

In April 2005 investigations by aMalaysian newspaper exposed how thetwo companies licensed to log theunderwater trees at Temenggor wereresponsible for rampant illegal logging ofmerbau trees in the protected forestsadjacent to the lake.(48) Malaysian forestryofficials confirmed the claims, andsubsequently refused to renew thelicenses of the two companies for loggingat the lake.(49) The last of these licensesexpired at the end of May 2005 andsince then no legal merbau has beensourced from the area.

Both Tarkett and Kahrs continue to sellmerbau flooring, though the only sourceof raw materials they can point to –dubious as it already was – has nowdried up entirely.

The loggingcompanies atTemenggorare accusedof illegallycuttingmerbau treesin protectedforests.

Below: Illegally logged

merbau tree,

Temenggor, Peninsular

Malaysia, May 2005.

Below left: FSC Chain

of Custody certificate

issued to Tarkett

in 2004.

© T

he S

tar,

Mal

aysi

a

Behind the Brand: Kahrs

10

After EIA/Telapak’s February 2005 report The LastFrontier highlighted Papua’s illegal merbau loggingcrisis the second largest wood flooring producer inEurope – Swedish company Kahrs – published astatement in an industry journal in a pre-emptivebid to clear the company’s name.(50) In it thecompany claimed to be buying its merbau from asustainable ‘underwater’ source. However, in aletter sent to EIA/Telapak in February 2006 Kahrsadmitted that only 36 per cent of its merbau wassourced from Temenggor lake in Malaysia in2005.(51) Added to this, all logging had in fact beenhalted there nine months earlier followingallegations of illegal cutting (see box on page 9).

As for the remaining 64 per cent of themerbau used in Kahrs’ flooring, the company’senvironmental manager admitted in his letter thatthere were indeed issues in the tropical timbertrade, which he called a ‘market full of problems’.He also conceded the company could not be sureits supply was legal, stating ‘we can’t give [a]100% guarantee of being free of wood materialfrom illegal logging’. This is in directcontradiction to claims Kahrs makes toconsumers that all the trees used to make itsflooring are ‘felled selectively’ and that ‘new treesare planted to replace those felled’.(52) Suchassurances are patently misleading.

Interestingly, while visiting Indonesianmanufacturer Tanjung Kreasi, whichmanufactures merbau flooring for Armstrong’sBruce brand (see earlier case study), EIA/Telapaklearned that Kahrs had approached Kreasi tomanufacture merbau flooring on their behalf.

Case Study 4: Kahrs

• Swedish company Kahrs is the thirdlargest wood flooring company inthe world, with global sales worth$256 million in 2004.

• Kahrs admit in writing that it cannotbe sure illegal merbau is notentering its supply chain.

• Malaysian companies cutting someof the merbau Kahrs says it uses inits flooring have lost their licensesdue to links with illegal logging inprotected forests.

• The source of the remainder of Kahrs’merbau raw materials is unclear.

• Kahrs merbau flooring is on sale inJohn Lewis stores in the UK andmarketed in numerous independentshops and web-based internetoutlets in Europe and the US.

Obviously Kahrs could not buy enough merbaufrom the company’s ‘legal’ Lake Temenggor source,and were keen to buy into Kreasi’s Papuan supply,despite there being no evidence of legality of thetimber. Kreasi turned Kahrs down, presumably dueto a conflict of interest with Armstrong.

Kahrs’ engineered merbau flooring is on sale inJohn Lewis in the UK, and marketed in numerousindependent retail outlets and web-baseddistributors across Europe and North America.(53)

Below left and middle:

Kahrs’ merbau flooring

is on display at John

Lewis, London,

February 2006.

Below right: Kahrs sold

$256 million of

flooring in 2004.

© P

alla

vi S

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/EIA

/Tel

apak

© T

om T

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leth

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© T

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Behind the Brand: Goodfellow

11

While the giant brand-name flooring companiesfeatured above dominate the market in merbauflooring in Europe and North America, there arenumerous other large companies engaged in thetrade. One such company, Canadian firmGoodfellow Inc., were previously exposed byEIA/Telapak for selling merbau flooring from aChinese supplier which was buying merbau logs ofdubious and uncertain origin.(54) The companyresponded in April 2005, stating that it would seekassurances from its suppliers that the merbau usedwas ‘logged legally and ethically’.(55) Goodfellowalso publicly committed to ‘market products onlywhere there is a complete and documented legalchain of custody’.

US import records show that Goodfellow hassince moved the sourcing of its merbau flooring toan Indonesian company, PT Seng Fong MouldingsPerkasa.(56) In August 2005 EIA/Telapakundercover investigators visited Seng Fong’s largefactory in Java. The owner, Mr Goh, and hiscolleague Ms Lin explained that, far from havinga legal chain of custody, Seng Fong’s merbau isbought on the spot market from traders who bringlogs in from Papua province, so the companycannot say for certain where the timber was cutor if it was legally sourced. Indeed, Ms Linadmitted that ‘… in Indonesia if you really wantsustainable forest or certification it’s not possible.It just isn’t.’ Ms Lin also told investigators thatSeng Fong had recently paid bribes to Indonesiannavy officials to secure the purchase of 10000cubic metres of illegal merbau logs being sold atauction. She said such ‘under the table payments’often ‘cost more than the logs’. Nevertheless itwas good business, since the bribes had ensuredthe agreed price of the logs was only $90 percubic metre – less than half their true value.

Since EIA/Telapak’s visit to Seng Fong, thecompany has continued to supply shipments ofsolid merbau wood flooring to Goodfellow, the most

recent record being for a shipment of twentytonnes which arrived in November 2005.(57) Inaddition to Goodfellow, Seng Fong also stated thatthe company supplies merbau flooring for Frenchflooring brand Soboplac. Soboplac’s merbauflooring is marketed in Point P stores in France.(58)

Case Study 5: Goodfellow

• Goodfellow is the largest hardwood flooring distributor in Canada, and currentlysources its solid merbau wood flooring from Indonesian company PT Seng Fong.

• After being exposed for selling suspicious merbau in February 2005, Goodfellowcommitted to ensure its merbau was legally sourced.

• Seng Fong’s merbau is all from Indonesia’s Papua province, is bought through dealersand cannot be traced to source or guaranteed as legal.

• Seng Fong admitted to paying bribes to officials in June 2005 to obtain 10000 cubicmetres of seized illegal merbau logs at auction.

Seng Fongadmitted topayingbribes toobtainseizedmerbau logsat auction.

Top: Mr Goh and

Ms Lin of Seng Fong,

Indonesia, August

2005.

Above left: Papuan

merbau being

processed into

flooring at Seng

Fong's factory,

Indonesia, August

2005.

Left: Papuan merbau

logs in the yard of

Seng Fong, Indonesia,

August 2005.

© S

am L

awso

n/E

IA/T

elap

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Sam

Law

son

/EIA

/Tel

apak

© E

IA/T

elap

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12

Use merbau timber in their wood flooring which comes from Indonesian Papua • • ? ? •Do not know the precise forest source of all their merbau and cannot show it waslegally sourced • • ? • •Provide false or misleading assurances to customers regarding the environmentalcredentials of their flooring • • • • •Have used merbau sourced from companies in Malaysia which have recently been accused of cutting merbau trees illegally in protected forests • •Supplier admits paying bribes to buy seized illegal merbau logs at auction •

Behind the Brand: Summary Tables

Table: Summary of case study findingsFLOORING BRAND

Bruce (Armstrong)

Junckers Tarkett Kahrs Goodfellow

Papuan merbau – on sale in a store near youPapuan merbau flooring of dubious origin is sold in many of the biggest DIY, home improvement, and builders merchant’schains across Europe and North America. Brands like Bruce, Junckers, Kahrs and Tarkett have secured high profile in-storeproduct representation in return for commissions on sales of their products. The examples outlined below include three ofthe world’s four largest DIY retail chains.

The Home DepotThe world’s largest homeimprovement chain, withover 2000 stores.

The Home Depot claims to ‘trace the origin of eachand every wood product on our shelves’ and ‘knowitem by item . . . where our wood products areharvested’.(59) The company’s wood purchasing policyalso stated in 1999 that it would ‘eliminate woodpurchases from endangered regions of the world bythe end of 2002 . . .’(60)

The Home Depot market merbau flooring by Bruce (Armstrong).Bruce’s supplier Kreasi buys all it’s merbau from Papua, whereillegal logging is rampant. The company admits that merbau treesin Papua are getting scarcer because there is no replanting, andconfessed that it did not know where in Papua its merbau comesfrom or even if it is legal (see case study on page 4).

Lowe’s The world’s second largesthome improvement chain,with over 1200 stores inNorth America.

Lowe’s claims to be ‘concerned ’ about the protectionof endangered forests, and committed to working withsuppliers to ensure this protection.(61)

Lowe’s markets Bruce (Armstrong) merbau flooring in dedicated in-store displays. Bruce’s supplier Kreasi buys all it’s merbau fromPapua, where illegal logging is rampant. The company admits thatmerbau trees in Papua are getting scarcer because there is noreplanting, and confessed that it did not know where in Papua itsmerbau comes from or even if it is legal (see case study on page 4).

John Lewis 27 branches in the UK, &recently voted UK’sFavorite Retailer.

John Lewis’ Responsible Sourcing Code states:‘Suppliers shall seek to make continuousimprovements in their environmental performanceand, as a minimum, comply with the requirements oflocal and international laws and regulations.’(62)

John Lewis markets merbau flooring by Junckers. Junckers’supplier (KTL) buys merbau from Papua, did not know the originof its merbau, cannot prove it is legal, and is pushed byJunckers to ‘take risks’ to meet demand. Illegally exportedIndonesian sawn merbau was seen in KTL’s yards (see case studyon page 6).

Travis Perkins With 750 stores, TravisPerkins is probably theUK’s largest chain oftimber and builder’smerchants.

In 2004 Travis Perkins pledged to ‘eliminate . . . timberand forest products that originate from illegallyharvested timber’,(63) and to avoid Indonesian timberproducts until legality could be guaranteed.

Travis Perkins markets Junckers merbau flooring. Junckers’supplier (KTL) buys merbau from Papua, did not know the originof its merbau, cannot prove it is legal, and is pushed byJunckers to ‘take risks’ to meet demand. Illegally exportedIndonesian sawn merbau was seen in KTL’s yards (see case studyon page 6).

Jewson With over 450 stores,Jewson is one of the UK’sleading timber andbuilders merchants.

Jewson’s Timber Procurement Policy states: ‘We seekto obtain clear evidence of good forest managementpractice at the original source.’(64)

Jewson markets Bruce (Armstrong) merbau flooring in dedicated in-store displays. Bruce’s supplier Kreasi buys all it’s merbau fromPapua, where illegal logging is rampant. The company admits thatmerbau trees in Papua are getting scarcer because there is noreplanting, and confessed that it did not know where in Papua itsmerbau comes from or even if it is legal (see case study on page 4).

Leroy MerlinEurope’s second biggestDIY chain. Focused inEurope, but with 298outlets worldwide.

Leroy Merlin is a signatory of Club Proforet, the Frenchmember organization of WWF’s Global Forest & TradeNetwork (GFTN).(65)

Leroy Merlin markets merbau flooring produced by Indonesiancompany Tanjung Kreasi. All of Kreasi’s merbau is from Papua,where illegal logging is rampant. The company was unable tosay where in Papua its merbau comes from or if it was legallysourced (see case study on page 4).

RETAILER ENVIRONMENTAL CLAIMS THE REALITY

Conclusions and Recommendations

13

ConclusionsRampant illegal logging of merbau trees is drivingthe destruction of the largest remaining tract ofvirgin tropical forest in Asia – the jungles of theremote Indonesian province of Papua. Thisdestruction is being driven by international demandfor cheap merbau timber for use in wood flooring.

EIA/Telapak investigations into the merbausupplies of five global brand-name flooringcompanies, including the four largest in theworld, reveal that:

• None of these companies knows preciselywhere all their merbau comes from or canprove it is legally sourced – directlycontradicting environmental assurances givento consumers.

• The vast majority of the merbau used by atleast three of these companies originates inIndonesian Papua.

• Two of the largest flooring brand names havesupplied flooring made with merbau cut byMalaysian companies recently accused ofillegal logging in protected areas.

• The Indonesian supplier of one major flooringcompany admits to paying bribes to obtainseized illegal merbau logs at auction, while theMalaysian supplier of another has importedillegal merbau sawntimber from Indonesia.

• Merbau flooring supplied by these companiesis on sale across Europe and North America,including in the world’s largest DIY chainstores.

• The flooring manufacturing companies and theretailers they supply have failed to invest inauditing their supply chain to ensure illegaltimber is excluded, and are instead content totake the word of suppliers at face value.

• Though importing companies and retailersmust take immediate action to clean up theirsupply chains, new laws are ultimately neededin the EU and US which specifically prohibitthe import and sale of timber and woodproducts which have been illegally sourced.

RecommendationsGovernmentsIndonesia

• Improve enforcement against illegal loggingand associated trade and prosecute thepowerful syndicate leaders and their backersin the military and police.

• Reform laws and regulations where necessaryto ensure that logging is sustainable andbenefits indigenous communities.

• List merbau (Intsia spp.) on Appendix III ofthe Convention on International Trade inEndangered Species (CITES), with a limitedexport quota for merbau products.

• Call on consuming countries to halt imports ofillegally sourced Indonesian timber and woodproducts.

Malaysia

• Accede to Indonesia’s request for the countryto enact reciprocal controls to ban the importfrom Indonesia of sawntimber productsprohibited from export from Indonesia. Othercountries such as China and Vietnam shouldalso take similar steps.

The European Union

• Include processed wood products in thevoluntary legality licensing schemes to be setup with producer countries under the plannedForest Law Enforcement Governance andTrade (FLEGT) partnership agreements.

All consumer countries, including the EU and US

• Enact legislation to prohibit the import andsale of timber and wood products which havebeen illegally sourced.

Companies• Cease manufacturing, distributing or selling

merbau wood flooring until the timber usedhas been verified as legal by an independentassessor and a full chain of custody can besupplied.

• Introduce and implement wood purchasingpolicies requiring that all wood is verified aslegally sourced by independent assessors,including a full chain of custody.

• Refrain from making environmental claims inrelation to wood products unless these can bebacked up in the manner described above.

Consumers• Do not trust the environmental assurances of

retailers and manufacturers about the legalityor sustainability of wood products unlessthese can be backed up by independentverification with a full chain-of-custody.

• Only buy wood products which have beenindependently verified as legally sourced, with a full chain of custody, such as wood sold under the Forest Stewardship Council (FSC) scheme.

• Stop buying merbau flooring until it isavailable with the assurances given above.

All consumercountriesshould enactlegislation toprohibit theimport andsale oftimber andwoodproductswhich havebeen illegallysourced.

1. Seneca Creek Associates, LLC andWood Resources International, LLC,prepared for AF&PA, Illegal loggingand Global Wood Markets: TheCompetitive Impacts on the US WoodProducts Industry, Nov 2004

2. Jakarta Post, Wild cancer' takes toll onforests, minister says, 22 August 2005

3. The Jakarta Post, Bad cops undermineillegal logging raids, 19 December 2005

4. Conservation International, WildernessArea Facts: New Guinea, 2003

5. BBC News Online, Science team finds'lost world', 7 February 2006

6. The Guardian, Money supplement, 4 February 2006

7. EIA/Telapak, The Last Frontier,February 2005

8. Ministry of Forestry Indonesia, OperasiHutan Lestari II report, May 2005

9. ITTO, Market Information ServiceReports, Feb-Oct 2005

10. The Jakarta Post, Bad cops undermineillegal logging raids, 19 December 2005

1 1. ibid.12. The Jakarta Post, 1000 illegal logs

confiscated in Papua, 11 February 2006

13. EIA/Telapak, Pers. comm, confidential,December 2005

14. House of Commons EnvironmentalAudit Committee, Sustainable Timber,Second Report of Session 2004-5, 18January 2006

15. European Commission, Forest LawEnforcement, Governance and Trade(FLEGT), Proposal for an Action Plan,May 2003

16. FEP Statistics 2004; Floor CoveringWeekly, 25 July 2005

17. Floor Covering Weekly, 18/25 July2005

18. ibid.19. European Federation of the Parquet

Industry, website,www.parquet.net/eng/setfep.htm

20. MSI Report, Domestic FloorcoveringsUK, 2003

21. Company annual reports, 200422. Armstrong World Industries Inc,

Annual Report, 200423. Global Witness, A Choice for China,

October 200524. Greenpeace, Briefing: Rainforest

Destruction at the Queen SofiaMuseum, September 2005

25. Seneca Creek Associates and WoodResources International, Nov 2004,op.cit.

26. Armstrong website, February 200627. Armstrong environment report on

Armstrong website. February 200628. Letter to EIA/Telapak from Armstrong

World Industries Inc., 9th February2006

29. Port Import Export Reporting Service(PIERS) data, 2005

30. Pers.comm, PT Tanjung Kreasi ParquetIndustry, August 2005

31. PIERS, 2005, op.cit.32. Home Depot & Lowes websites and

EIA/Telapak store survey, January 2006

33. Jewson & Leroy Merlin websites andEIA/Telapak Jewson store survey,February 2006

34. Junckers website:http://www.junckers.co.uk/, February2006

35. Kompass, Junckers’ financial summary,2005

36. Junckers website:http://www.junckershardwood.com/swf/homepage.swf, February 2006

37. Letter to EIA/Telapak from Junckers,26 January 2006

38. Letter from Junckers Industrier A/S toGreenpeace UK, 16 September 2004 & MTIB documentissued by Junckers.

39. EIA/Telepak Internal Report of FieldInvestigation, August 2005

40. Letter to EIA/Telapak from Junckers,26 January 2006

41. Timber Trade Federation, TTF ReportsProgress Sourcing Legal Timber fromIndonesia, 30 September 2004

42. EIA/Telepak Internal Report of Field Investigation, August 2005

43. Junckers websites and EIA/Telapakstore survey, January 2006

44. Tarkett website45. Tarkett website:

http://www.tarkett-sports.com/html/uk/environnement.php, February2006

46. The Star, Rampant illegal felling oftimber at Tasik Temenggor, 21 April2005; The Star, Illegal Felling OfMerbau Trees In Perak, 13 May 2005

47. Tarkett website and EIA/Telapak storesurvey, January 2006

48. The Star, Rampant illegal felling oftimber at Tasik Temenggor, 21 April 2005; The Star, Illegal FellingOf Merbau Trees In Perak, 13 May 2005

49. The Star, Perak orders halt to loggingat Tasik Temenggor, 22 April, 2005;Bernama, Perak Bans Logging InTemenggor Reserve Forest, 18th May2005; Bernama, Heli To Be Used ToCheck Timber Thefts In Perak, 27 May 2005

50. Contract Flooring Journal, “We Never Take Merbau Logs”, 20 May 2005

51. Letter to EIA/Telapak from Kahrs, 15February 2006

52. Kahrs Catalogue, p16, & KahrsSubsidiary website:http://www.kahrs.co.za/about.html,January 2006

53. EIA/Telapak store survey, January2006

54. EIA/Telapak, The Last Frontier,February 2005

55. Goodfellow Inc., Statement on Merbau Flooring, 18 April 2005

56. PIERS, 2005, op.cit.57. ibid.58. Point P Website:

http://www.pointp.fr/pp_catal_V1/jsp/CataMoteurRechercheV1.srvl?type=CALB

59. The Home Depot Website:www.homedepot.com/HDUS/EN_US/corporate/corp_respon/wood_purchasing_policy.shtml, Jan 2006

60. The Home Depot Corporate Website:http://corporate.homedepot.com/wps/portal/Wood_Purchasing, Jan 2006

61. Lowe’s Website:www.lowes.com/lowes/lkn?action=pg&p=PressReleases/wood_policy.html,Feb 2006

62. John Lewis Website:www.johnlewispartnership.co.uk/assets/pdf/rscode2005.pdf, Feb 2006

63. Travis Perkins Website:www.travisperkins.co.uk/information/environmental/Environment-2004.pdf,Feb 2006

64. Jewson Website:www.jewson.co.uk/en/download/2006TimberProcurementPolicy.doc, Feb 2006

65. WWF Forest & Trade Asia Website:www.forestandtradeasia.org/files/GFTN%20Participant.pdf, Feb 2006

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References

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