What is the Policy for Association?
The Policy for Association is a unique tool that allows us to clearly define FSC’s ability to take such action against companies that engage in any one of the activities listed as unacceptable. These unacceptable activities are:
- Destruction of High Conservation Values
- Illegal logging and illegal trade of timber
- Human and traditional rights violations
- Workers’ rights violations
- Use of genetically modified organisms
FSC is the only forest and forest product certification scheme that expects commitment to its core values by not only the certified companies, but also other companies who belong to the corporate group of a certified company. When a company gets certified with FSC, they agree to the terms of the Policy for Association, and can be held accountable for violations of the policy by any member of the corporate group.
To read the full policy document, click here.
Association: An association with FSC is formally established through any of the following contractual relationships: FSC membership agreement; FSC certificate holder license agreement; FSC certification body license agreement; FSC partnership agreement.
Affiliated group: The totality of legal entities to which an associated organization is affiliated in a corporate relationship in which either party controls the performance of the other (e.g. parent or sister company, subsidiary, holding company, joint venture) as described in Policy for Association FSC-POL-01-004.
Disassociation: The termination of all existing contractual relationships (member and license) between FSC and the associated organization (and its affiliated group). Disassociation also prevents entry into any new contractual relationships with FSC.
Ending disassociation: A disassociated organization may request to start a process to end disassociation by expressing interest to FSC. As part of that process, an organization-specific roadmap must be developed. A roadmap is a framework and plan of how to remedy, correct and prevent reoccurrence of previously identified violations of the FSC Policy for Association. It also includes other trust-building measures. Disassociation can be lifted only upon completion of the agreed conditions specified in the roadmap.
Addressing policy violations
FSC receives information about possible violations of the Policy for Association from various channels: official complaints from concerned stakeholders, media and NGO reports about companies engaging in unacceptable activities, ongoing legal cases against companies, etc.
Regardless of the source of the allegation, we collect and assess the evidence available to decide if there has indeed been a violation of the Policy for Association. If there is credible evidence of a violation, then FSC either begins a mediation process or launches an investigation.
Mediation: Alternative dispute resolution
In cases where FSC does not launch an investigation, we focus on finding solutions to concerns raised through other means, such as a mediation process. In this process, an independent mediator leads discussions between the complainant and the company accused of engaging in an unacceptable activity. The ultimate goal of this process is for all parties to agree on a remediation pathway that will bring about restitution and restoration.
All concerns we investigate are subject to the same rigorous process. We look for credible evidence of widespread wrongdoing before triggering an investigation. Based on the outcomes of the investigation, FSC’s Board decides if FSC should disassociate from the corporate group. Such action is only taken against an organization where credible allegations are confirmed by independent investigators.
For more details about the normative document determining how FSC manages Policy for Association violation allegations, please refer to FSC-PRO-01-009: Processing FSC Policy for Association Complaints.
For more information about how FSC manages Policy for Association violation cases, click here.
FSC constitutes a decision panel consisting of members whose expertise are relevant to the case. The decision panel reviews the available evidence and take a binding decision on the merits of the case. The decision panel can decide to maintain association with the corporate group, to maintain association with conditions, or to recommend to the FSC Board of Directors disassociation.
The FSC International Board of Directors makes the final binding decision about disassociation from a corporate group.
How to raise a concern
Our stakeholders play a vital role in alerting us to destructive forestry activities. If you are concerned about the activities of an organization connected to FSC, we want to hear from you. You can submit your complaint (including all the evidence) here.
Why are these activities unacceptable for FSC?
Our mission is to protect forests for future generations. And our membership is made up of companies striving for environmentally and socially responsible practices – of environmental defenders, trade unions, human rights campaigners and those fighting for indigenous peoples.
The activities we prohibit are totally opposed to the mission of our organization and the members who make it. There is no place for this behaviour in FSC, whether activities happen in the forests of a certified forestry company or the non-certified forests of one of their affiliates.
Who can raise concerns about destructive activities?
There are no requirements as to who can submit a complaint or raise concerns in the FSC system.
While anybody may share concerns, the information submitted must include necessary and relevant information and evidence for FSC to take the appropriate action. This required information is noted on the submission forms and processes, and defendants are encouraged to provide as much detailed information as possible so that FSC can make an informed decision as to whether the complaint will be accepted.
Who investigates when credible allegations are raised?
FSC assigns an investigation team comprising of experts from the field of allegations. In building an investigation team, each team member is selected and then approved by those raising concerns and the defendant organization to ensure impartiality.
While not a requirement, the investigation team will typically include experts from the country where wrongdoing is alleged. The investigation team is then not only uniquely qualified through their professional expertise, but also has a greater understanding of the national context.
Who decides whether an organization should be excluded from the FSC scheme?
The investigation team delivers their report to FSC, complete with the evidence and level to which each allegation was verified. This report is presented to the FSC Policy for Association Decision Panel who will assess the conclusions of the investigation. The Panel may decide to recommend that FSC Board of Directors make the decision on excluding organization from the FSC scheme.
What are the consequences of exclusion from the FSC scheme?
Upon being excluded from the FSC scheme the organization’s trademark license agreements are immediately terminated, all certificates are withdrawn and they are blocked from further certification and association such as membership.
This exclusion extends beyond the organization found to engage in unacceptable activities, applying to any parent, subsidiary or sister company connected by more than 51% ownership. All companies are blocked from any FSC certification until a complete remedy and reform process has been fulfilled and all requirements met.
Can excluded organizations re-enter the FSC scheme?
Excluded organizations can re-enter the FSC scheme after exhibiting the fulfilment of conditions addressing remedy caused by past harm and reformation. Only after concrete proof that these requirements have been fulfilled can the organizations potentially re-enter the FSC scheme.