Integrating TVD Audits into Ghana Wood Tracking System to ... · CERTIFICATE EU Destinations Other...
Transcript of Integrating TVD Audits into Ghana Wood Tracking System to ... · CERTIFICATE EU Destinations Other...
Integrating TVD Audits into Ghana Wood Tracking System to Improve Legality and
Forest Governance
RICHARD GYIMAH (PhD)
Verification/Audit Manager, TVD-FC
Presentation outline
Brief Illustration of Ghana’s Timber Legality Assurance System (GhLAS) Highlights of chain of custody system- GWTS
Key institutional roles
Legal Timber Audit Approach Scope of Timber Legality Verification
How it operates and at what levels
Legality verification outputs and corrective actions mechanisms to improve compliance
Access to TVD Audits
BRIEF ILLUSTRATION OF GHANA’S LAS WITH HIGHLIGHTS ON GWTS + KEY INSTITUTIONAL ROLES
Ghana’s Timber Legality Assurance System
Aim:
Provide assurance to the Legality of all Timber exports to International market destinations, especially the EU and also the domestic market
Components of GhLAS:
Legal timber definition
Chain of custody system driven by a Wood Tracking System (WTS)
Verification system
Independent Monitoring
FLEGT License Issuance
LEGALITY (FLEGT) LICENSING SYSTEM
FLEGT License
EU
Exports
Domestic
ALL destinations must satisfy full legality qualities
EXPORTPERMIT
Timber SalesTimber Sales
INSPECTION CERTIFICATE
EU Destinations
Other Export Destinations
COC & LAS TOOLKIT CORE MODULES
Sources – Forests / plantations /salvage & confiscated timber/ imports
Processes – Transformation of timber / movement of products
Reconciliation – Monitoring changes along the supply chain & validation
Legality audit – Monitoring legal compliance through the supply chain
GWTS Forest Info
Source Documentation
Forest Measurement
Log production
Log transport
GWTS Industrial Timber Processing
Wood material
Sawn timber
Plywood
Finished Products
GWTS Sales
Domestic Trade
Export Trade
Customs
GWTS Audit
Legality standards
Audit planning
Reconciliation & Legality checks
FLEGT Licensing
Ghana’s Wood Tracking System - Supply Chain & Legality Applications
Key Institutional Roles under Forestry Supply ChainForest Reserves Map of Ghana
Forest Service Division
(FSD)
• Forest Management & Development
• Regulation of Harvesting
Timber Industry Development Division
(TIDD)
• Monitor flow of timber from forest to mill
• Implement all national timber trade practices
• Industry Regulation & Development
FC-HQ(TRAU & FINANCE)
• TRAU- Assist CE in timber rights allocation procedures
• FINANCE- Revenue collection & disbursement
Timber Validation Department (TVD)
• Internally placed auditor
• Compliance monitoring and reporting
Resource Management Support
Centre (RMSC)
• Sets standards for Forest Management
• Forest quality assurance
London Office (LO)
• Trade Promotion
Ministry of Lands & Natural Resources
(MLNR)
• Forest Policy & Legislation
• Grant of Timber Rights (TUC)
• Overall monitoring of the forestry sector
FORESTRY COMMISSION
Timber industry• Logging
• Transformation• Trade data
LEGAL TIMBER AUDIT SCOPE/METHODS/APPROACH
Legal Timber Audit by the Forestry CommissionA new Timber Validation Department (TVD) in the Forestry Commission (FC) is responsible for legality audits
Key roles of TVD include:
Remains at arm’s length as a verifier (i.e. “internal auditor”)
Validate control processes and outputs of the divisions/units of FC at the critical supply chain control points from source of timber to point of export or sale via WTS platform and periodic conventional audit
Application of auditing principles and protocols in performing the verification and validating functions
SCOPE OF TIMBER LEGALITY VERIFICATION
Principle Control Points (Legality Areas) No. of Criteria
1 Source of Timber 2
2 Timber Rights Allocation 4
3 Timber Harvesting Operations 7
4 Transportation 2
5 Processing 2
6 Trade 2
7 Fiscal Obligation 4
Legality matrix guides the determination of legality of timber for export
or domestic market
Consists of 7 Principles and 23 key Criteria
Ghana’s Timber Verification Approach
Level 4:
External audit requirements
Level 3:
Internal audit requirements
Level 2:
Inspection/enforcement requirements
Level 1:
Execution requirementsDivisions/Dept/Units of FC and Timber Companies performing assigned roles
Checks within Divisions, Dept./Units of FC to ensure level 1 requirements are done
TVD conducts sample verification & validation of outputs from FSD, TIDD, Timber Companies through routine audit
Independent Monitor conducts sample checks of the entire system annuallyCivil society groups have
opportunities to be involved in these audits
Compliance evidence available at
divisional level
Legality
Standard
requirements
Compliance to
requirements
by operators,
or FC divisions
Inspection of
compliance at
divisional level
Verification of mandatory requirements
Supply Chain
(WTS)
requirements
Ghana Legality Assurance System (GhLAS)
Requirements
Independent Monitor of the GhLAS (External Auditor)
Licensing Internal Audit
Verification Licensing mandatory
Schematic Illustration of Ghana’s Verification Approach
1ST level Verification
2nd level Verification
3rd level VerificationBy TVD
HOW THE 3RD LEVEL VERIFICATION BY TVD AUDITORS IS DONE
A hybrid application of field audits by TVD Auditors and a Wood Tracking System (WTS) for data reconciliation and validation
Documented Audit system in place which comprise of:
▪ Verification protocols (e.g. Sanctions & CAR, Audit protocols, Complaints, IM, etc.)
▪ Supporting documents (e.g. Administration, Forest, Transport, Mill Processing & Trade checklist)
▪ Contract documents (e.g. Observer role of Civil Society)
▪ Work instruction
▪ Guidance documents
▪ Policy documents
Application of Audit principles in the conduct of legality verification
Use of WTS platform to upload legality verification results which will enable the issuance of FLEGT License
3RD LEVEL LEGALITY VERIFICATION OUTPUT & CORRECTIVE ACTION MECHANISM TO
IMPROVE COMPLIANCE
What does the Field Legality Verification Audit Do?
Raises Corrective Action Requirements (CARs) against practices that have not conformed to the list of VPA legality criteria and indicators
Communicates the CARs to all Auditees – Industry and FC actors
Requires all Auditees to close the CARs raised and communicated to them within a given time frame to assure compliance for legality licensing
Licensing
Forest offence
Compliance with
Legality Standard
Non-compliance
management
Not resolved through Non-compliance
management process
Resolved through Non-
compliance management
Compliance with WTS
X No License
Failure to comply
with administrative
duty
Non-compliance
detected
√ License
LEGALITY VERIFICATION OUTPUTS RECORDED & KEPT ELECTRONICALLY
✓ Results of timber legality verification are now properly stored and can be easily retrieved for FLEGT license decision by the Licensing Authority
Example of a CAR addressed to a Company 01/08/2016
THE MANAGING DIRECTOR,
XXX COMPANY LTD
ODA
Dear Sir/Madam,
Corrective Action Requirements: TVD Legality Audit in the Kade Forest District in April 2016
Please find below company-specific legal timber non-compliance observed through TVD audit for your
information. Kindly take steps to effect the necessary corrective measure before TVD’s next audit cycle
during the last quarter of 2016.
Yours sincerely,
Chris Beeko
Director, TVD
cc: Chief Executive, FC
Forest
District
Geographic scope Non-compliance(s) Criteria/Indicator Responsible FC
Div./Organization
Kade Nsuensa Forest Reserve -Compartment 12
Criterion 3.2.2: Logger did not observe correct logging practices as outlined in the FC-Logging Manual.
In compartment 12 of XXX felling area, tree numbers 334-Sapele, and 1545-Edinam were found to have been felled outside the approved yield by the company without authorization.
FSD
Examples of Non-Compliance Identified for Corrective Action
“Red flags”- showing data inconsistency
Bad environmental logging practice
Incorrect metric data measurements
Bad health & safety in the mills
There is greater awareness of legality compliance requirements by both FC Divisions and Timber CompaniesAreas of compliance improvements include:- Efforts at addressing social issues through SRA documentation and reporting- Forest hygiene- Payment of stumpage fees (statutory taxes for Government & Landowners)
0
10
20
30
40
50
60
70
80
2015 2016
6961
78
50
SUMMARY OF AUDITEE NON-COMPLIANCES IDENTIFIED FOR 2015 & 2016 AUDIT CYLES
FC CAR Company-related CAR
SUMMARY OF LEGAL COMPLIANCE TRENDS FROM TVD AUDITS
ACCESS TO TVD AUDITS
How to Access TVD Audits - Current Opportunities
The Ghana’s wood tracking system is a data source for accessing TVD Legality Audits Civil society is exploring the possibility of a web portal to interface with GWTS under a EU-sponsored
project
Summarized TVD audit reports can also be made available to stakeholders upon request to the Forestry Commission
Public summary reports from the Independent Monitor on the entire GhLAS including TVD audits to the JMRM will be available to all stakeholders
VPA annual reports submitted to the JMRM will contain information on TVD audits and how non-compliances have been or are being addressed
It is important to note that as the VPA implementation becomes fully operational in Ghana, not only will access to information become key but also security & interpretation of data as well as confidentiality of information
THANK YOU