PR080202 FSC FM public report TRC v22 [03 06 09] - Bureau Veritas

FSC CERTIFICATION SYSTEM 

CERTIFICATION PUBLIC REPORT 

FOREST MANAGEMENT CERTIFICATION 

Last audit date: from 10 th to 18 th February 2009 

Last update date: 19 th May 2009 

Forest Management Unit (UFA) n° 00 004 

TRC (Transformation REEF Cameroun) 

Forest location(s): Cameroun, Provinces du Centre et du Littoral 

Manager office address: BP. 3394 - Ndogbong 

Town : Douala - Countrys : Cameroun 

Contact Person: M. Jacques HULEUX (j.huleux@trcbois.com) 

BUREAU VERITAS CERTIFICATION 

60 avenue du Général de Gaulle - 92046 Paris - La Défense Cedex - FRANCE 

Tel: + 33 1 41 97 02 05 - Fax: + 33 1 41 97 02 04 

www.certification.bureauveritas.com / fr 

Contact in Africa: Caroline Duhesme (caroline.duhesme@fr.bureauveritas.com) 

Contact in other countries: Héloïse d’Huart (heloise.dhuart@fr.bureauveritas.com) 

Initial audit date: from the 9 th to the 13 th June 2006 

Last surveillance audit dates: from 10 th to 18 th February 2009 

Certificate number: BV-FM/COC-448849 - certification date: 12 th February 2008 

Lead auditor and report writer: Alain Valette 

Document ref.: PR080202 version 2.1

The present report is the English translation of the certification public report written in French by Bureau Veritas Certification. Should there be 

any doubt as to text interpretation, the French version will prevail. Do not hesitate to contact us for any question you may have.

Bureau Veritas Certification 

92046 Paris La Défense Cedex 

www.certification.bureauveritas.fr 

FSC Forest Management Certification 

Certification Public Summary Report 

TRC - FMU 00-004 

Last audit : 10-18/02/2009 

L.A. : Alain VALETTE 

Réf. : PR080202 

Version : 2.1 

CONTENT 

1 - Overview........................................................................................................................... 5 

1.1 - Main notable strengths of the forest applicant entity ..............................................................5 

1.2 - Main weak points of the forest applicant entity .......................................................................5 

1.3 - Recommendations and / or minor and major Corrective Actions Requests suggested in 

preparation for certification .....................................................................................................6 

2 - Legal, administrative and land use context ................................................................... 6 

3 - Description of the applicant forest entity....................................................................... 6 

3.1 - General Description ................................................................................................................6 

3.2 - Forest management system and plan description ..................................................................8 

3.3 - Production and harvesting ....................................................................................................10 

3.4 - Labour planning ....................................................................................................................10 

4 - Other activities............................................................................................................... 12 

4.1 - Description of the activities ...................................................................................................12 

4.2 - Potential Impact on forestry ..................................................................................................12 

5 - Base of evaluation ......................................................................................................... 12 

5.1 - Composition of the audit team ..............................................................................................12 

5.2 - Previous audits......................................................................................................................13 

5.3 - Forest management referential used for the initial audit ......................................................14 

5.4 - Stakeholders comments on referential .................................................................................15 

5.5 - Effective laws enforceable to the activities of the forest entity applicant ..............................15 

6 - Information collecting modalities ................................................................................. 16 

6.1 - Description of the audit program...........................................................................................16 

6.2 - Documents review.................................................................................................................16 

6.3 - Interview(s) of involved people met ......................................................................................16 

6.4 - On-site visit(s) .......................................................................................................................17 

6.5 - Stakeholders identification and consultation.........................................................................17 

6.6 - Identification, traceability and monitoring of products...........................................................20 

6.7 - Initial audit closing meeting...................................................................................................21 

7 - Audit team observations ............................................................................................... 21 

7.1 - Evaluation results with reference to the FSC referential / standard .....................................22 

7.2 - Systematic presentation of results ........................................................................................26 

7.3 - Elements subjects to controversy .........................................................................................26 

8 - Scope retained for the certification .............................................................................. 26 

8.1 - Geographical limitation at the level of the entity ...................................................................26 

8.2 - Limitation at the level of the forest products .........................................................................26 

9 - Proposals regarding the certification decision............................................................ 27 

9.1 - Explication on all rating, weighting systems or other systems used decisions taking ..........27 

9.2 - Clear description of all recommendations and conditions associated to the certification 

decision .................................................................................................................................27 

9.3 - Minor Corrective Action Requests ........................................................................................28 

9.4 - Major Corrective Action Requests ........................................................................................30 

9.5 - Proposal of conclusion on whether the candidate entity achieved or not the required level 

of conformance .....................................................................................................................35 

10 - Complementary audit n°1............................ .................................................................. 36 

10.1 - Base of evaluation ................................................................................................................36 

10.2 - Information collecting modalities...........................................................................................36 

10.3 - Audit team observations .......................................................................................................46 

10.4 - New Correctives Actions Requests resulting from the Complementary Audit......................59 

10.5 - Scope retained for the certification .......................................................................................67 

10.6 - Proposals regarding the certification decision ......................................................................67 

11 - Complementary audit n° 2........................... .................................................................. 69 


11.2 - Information collecting modalities...........................................................................................69 

11.3 - Audit team observations .......................................................................................................76 

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Version : 2.1 

11.4 - New Correctives Actions Requests resulting from the Complementary Audit......................84 

11.5 - Scope retained for the certification .......................................................................................85 

11.6 - Proposals regarding the certification decision ......................................................................85 

11.7 - Decision and associated conditions......................................................................................86 

12 - Surveillance Audit n° 1 ............................ ...................................................................... 87 


12.2 - Data collection’s approach....................................................................................................87 

12.3 - Observations from the audit team.........................................................................................98 

12.4 - Proposal concerning the certification decision....................................................................100 

12.5 - Certification decision...........................................................................................................109 

13 - Appendices .................................................................................................................. 110 

13.1 - Pairs review following the initial audit and the two complementary audits .........................110 

13.2 - Answers to Stake-Holders ..................................................................................................111 











Version : 2.1 

1 - Overview 

1.1 - Main notable strengths of the forest applicant entity 

The TRC company committed itself in the FSC certification process, and set up 

numerous procedures aiming at: 

- rationalizing its production; 

- improving populations and workers’ social conditions 

- reducing impacts of the exploitation on the environment. 

It has showed, since the scoping, great adaptibility while adjusting these inhouse 

procedures to FSC requirements: 

- Considerable improvement in work conditions in terms of comfort and 

safety; 

- taking into account the environment (considerable improvement in the living 

conditions, waste retrieval); 

- Improvement in means of signalling, demarcations and riparians awareness. 

The woodlands have a complete management scheme, surveys are started or 

formalized by contract, and the company maintains constructive relations with 

the local and international NGO. 

Forestry is carried out with an average impact, the personnel is well trained and 

knows its responsibilities. The personnel is sometimes recruited on the treefelling 

site, and in-house promotion is possible. 

The certification step has been integrated down to the bottom of the company's 

scale, TRC's policy is clear, and its procedures complete and globally well 

designed. 

1.2 - Main weak points of the forest applicant entity 

As a very general rule, certification procedures are not always applied and are 

rarely in total compliance with field practices. 

TRC set up very recently procedures of populations’ consultation in order to 

have sufficient knowledge of social issues on the sites where it operates. That 

process has not fully come off and needs a development. 

The environmental and social impact surveys need to be started. 

Certain points of forestry legislation are not respected; in particular the company 

does not fully comply with decree 222 regulating forest management by 

Cameroonian law. 

Certain points of labour legislation and the ILO (International Labour Office) 

texts are not respected. 

One of the chemical products used by the company is listed among the 

prohibited products within the scope of FSC certification. 

The management implementation as it is presented in the document endorsed 

by the administration is not lasting: 

- The renewal rate presented in the official management document only 

reaches 100% thanks to a directed choice of a limited number of species 

which do not correspond at all to species harvested by the company. 











Version : 2.1 

- The renewal rates for species mainly harvested are not calculated in the 

management document. 

The UFA 00-004 geographical zone is known for intense poaching and 

frequency in unlawful timber felling. 

1.3 - Recommendations and / or minor and major Corrective Actions 

Requests suggested in preparation for certification 

Seventeen minor corrective actions requests and seventeen major corrective 

actions requests have been expressed, to enable TRC to fully meet the FSC 

forest management referential adapted to Cameroon. They are explained at the 

end of the document. 

2 - Legal, administrative and land use context 

Cameroon has begun, since 1994, a profound reform of its legislative and regulation 

system as far as environment, forests, fauna and other natural resources management 

are concerned. The new laws (and their application texts) attempt to reconcile integrated 

and sustainable management of forestry, faunistic halieutic heritage and the need to get 

substantial incomes from their exploitation to ensure economic and social development. 

It consists in reinforcing the forest’s ecological role as well as its economic and social 

functions. These laws are meant to be more restrictive. The innovations made concern a 

greater involvement of the riparian populations while encouraging decentralized and 

participative management of forests, through the community forests principle for 

example. 

As such and as a forestry site company, TRC is submitted to these new “environmental’ 

aspects, as well as to social and tax aspects. We identified in a non exhaustive manner 

legislative texts which a forestry site company must respect (see paragraph 5.5). 

3 - Description of the applicant forest entity 

3.1 - General Description 

Identification of the forest entity: 

- Owner: 

In Cameroonian law, permanent forest estate is divided in one hundred or so 

Forestry Site Units ("UFA"), the exploitation and management of which are 

allocated on the basis of calls for tenders set by the the MINFOF (Ministry of 

forest and wild Fauna). 

These UFAs are divided in annual cutting areas, put forward by the successful 

bidder of the UFA, the surface area of which must legally be about 2,500 

hectares. 

The non permanent Forest Estate is exploited by felling sales that can be 

organized by 2,500 ha unit lot, sold by call for tenders. 

There are community forests too, the management of which is entrusted to local 

authorities. 

In any case, the Republic of Cameroon remains owner of the forest soil. 











Version : 2.1 

- Manager: 

The TRC Transformation Reef Cameroun company 

Transformation Reef Cameroun 

Incorporated company with a capital of 110,000,000 CFA Francs 

BP. 3394 - Ndogbong 

Douala -CAMEROON 

Phone: + 237 340 42 88 / Fax: + 237 340 39 92 

RC: 1156 DLA / N°. Taxpayer: M029900009462A 

As a structure ruled by Cameroonian law and a family company created in 1989 

and belonging to REEF HOUT B.V. (The Netherlands) company, TRC first 

specialized in the processing of Bongossi long poles bought or exploited in 

felling sales. The development of the company and the evolution of the 

Cameroonian forest context encouraged TRC to manage its supplies. TRC has 

therefore been for two years signatory to a Provisional Convention of 

Exploitation (see appendix) applying to a 125,490 ha territory in the Permanent 

Forest Estate referred to as concession nb 1,029 and the boundaries of which 

are set by that of UFA 00 004. 

Since the scoping, another UFA (11- 001) has been added to the company. In 

parallel, TRC exploits and processes the UFA 00-001/00-002 woodlands within 

the scope of a partnership agreement with SEPFCO (“Société d’Exploitation 

des Produits Forestiers et de Commerce” Trade and Forest Products 

Exploitation Company) which obtained the concession. 

TRC too has two sawmills located in Kumba and in Douala specialized in highdensity 

wood, and hired for a trial period of 3 years a rotary cutting factory in 

Douala. That factory will be running early in 2007 and will enable the company 

itself to use peeled veneer timber exploited on these UFAs. 

UFA 00 004 was transferred from the PROPALM Company to the TRC 

company through an official decision of the Ministry of Forestry and Water 

Resources on 24th July 2004. Propalm was up until then beneficiary of the 

concession on the basis of a call for tenders published on 21st February 2000. 

TRC has in addition signed a partnership agreement with WWF (World Wildlife 

Fund) in order to enter the “WWF Producer group” then the “Central Africa trade 

Network”, enabling to benefit from technical assistance in the setting up of 

impact surveys. 

Description of the forest stand(s) 

UFA 00-004 includes forest concession Nb 1,029. It is spanning two provinces; 

the Centre Province, County of Mbam and Inoubou, District of Ndikimineki; and 

the Littoral Province, County of Nkam, Districts of Nkondjock and Yingui. 

Administrative surface areas are allocated as follows: 

Province Centre 

County 

Mbam and Inoubou 

District 

Ndikimineki 

Village Ndikimineki 92,390 ha 

Province 

County 

Districts 

Villages 

Littoral 

Nkam 

Nkondjock 

Yingui 

Nkondjock 

Yingui 

20,400 ha 

12,700 ha 











Version : 2.1 

All the UFA is located on the INC Ndikimineki topographical map, sheet Nb. 

NB32V 

Surface and altitude 

The UFA has a surface area of 125,490 hectares at the signature of the 

provisional agreement. 

The concessionnaire considered it useful to take off from the forestry 

management area the nearest zone to the villages, in order to increase the 

surface area of the agroforestry zone and to limit territorial conflicts. A 

suggestion is in progress within the scope of the UFA management and has 

been officially authorized by the Forest Ministry. Therefore the managed surface 

area is 102,000 hectares. 

UFA 00-004 is located on one of the high plateau sides of the South-West and 

West provinces towards the sea. Thus one part of the UFA has high altitudes 

with quite great level differences, whereas another part is located on a relatively 

flat ground of low altitude. The forest altitude ranges from 492 to 4,264 feet. 

That ecological element is essential and conditions strongly forestry quality. 

Description of the forest stand 

Forest groups of which UFA 00-004 is a part, are the low altitude tropical 

rainforest in Lophira alata (Bongossi) and the average altitude atlantic tropical 

rainforest. 

The distribution is the following: 

- adult secondary forest: 50,060 ha 

- Agricultural surface area: 23,910 ha 

- young secondary forest: 4,587 ha 

- humid evergreen dense forest 41,080 ha 

- water 684 ha 

The UFA is virgin in its mountainous part southward, which is very difficult to 

exploit. On the other hand, the Northern part has already been exploited by 

another company. 

3.2 - Forest management system and plan description 

- Management and administration 

The UFA 00-004 forest management scheme was written by the research 

department “Form International” at the end of 2005. It has been approved by 

the Forestry Administration. It is established for 30 years, corresponding to 

the theoretical length of time of rotation, and is revisable every five years. It 

was established for the 2006-2036 period. 

The forest management scheme comes together with the first five-yearly 

management scheme as requested by the forestry regulation in force. 

There is no yearly operation scheme, detailing all the activities to be carried 

out during the year to come on all the UFA, with an associated budget. A 

yearly operation scheme cannot be summed up to a yearly cutting area 

certificate. 











Version : 2.1 

- Durability of the management 

The forest management scheme is based on the inventory carried out by 

AYUKEGBA FORESTRY and LIMBE's botanical gardens, from December 

2004 to April 2005. The inventory was carried out at the rate of 0,5 % and 

approved by the Forestry Administration. 

The inventory was carried out from small classes of diameter so as to take 

into consideration future harvests. The data analysis presents the histograms 

of the diameter classes for the principal species and the maps of distribution 

of these species in the UFA as presence/absence. 

The sylvicultural system used is one of a felling above the minimum logging 

diameter. The administration sets minimum diameters per species applicable 

to all the country, and the developers have to set minimum diameters per 

species and per UFA, superior or equal to Administration MLDs (Minimum 

Logging Diameter). The choice of these MLDs by the developer must allow a 

necessary renewal of the stands at the UFA level and is therefore a major 

parameter of the forest management durability. 

For the choice of the managed species, the TRC developer took 36 species 

(among the 50 of the top 50) representing more than 75 % of the total 

inventoried volume. It however excluded from the group of managed species, 

and therefore from the calculations of the renewal rate, several of the most 

exploited species and in particular timber for hydraulic use like Bongossi, Tali 

and Okan. 

That exclusion has been partially corrected in a note which has been passed 

on to us (however it is not included to the public summary of the 

management scheme) which justifies the renewal rate of the bongossi and 

its exploitation at a minimum diameter of 27.3 inches. 

It is not acceptable in the FSC process that the renewal rates of the 

harvested species should not be legible, and that should be shown renewal 

rates of species without commercial interest, chosen in the inventory 

because of the stand diameter structure of their tree populations, favourable 

to obtain reassuring calculations. 

The developer will then have to present, during the complementary audit, the 

calculations corresponding to the species really exploited by the company. 

He should aim for the best possible renewal of that species group and 

explain the poor renewals. That “real”calculation will be made public in the 

public summary of the forest management scheme. 

For managed species, the TRC developer has used the forest renewal 

formulas and the growth, mortality and exploitation damage hypotheses 

recommended at a national level for the MLDs calculation. 

The growth monitoring and forest reaction to exploitation is carried out 

through permanent seed spots (see below). 

- Boundaries 

The UFA and cutting areas boundaries are marked: 

The Northern boundary is natural; the cutting areas boundaries are neatly 

marked (clear track, distinctly marked and maintained). 

In order to fully meet legal requirements, these boundaries should be planted 

with fast-growing species. Local species plantations (Moabi) are planned 

within the UFA boundaries, so as to perpetuate them. An advantageous 

process of seedlings yield has to be set up (TRC nursery or village yield). 











Version : 2.1 

3.3 - Production and harvesting 

On the basis of the statistical inventory, the forest possibility is estimated at 

4,397,167 m 3 in managed species. Bongossi represents 229,753 m3 according 

to that same statistical inventory. 

• Exploitation 

The TRC company developed a low impact forestry training system (see in 

that respect “Forestry certification procedures”, TRC in-house document and 

the “Low impact forestry regional code” (FAO, 2003)). 

Good mastery of the directional felling technique is to be mentioned (hence 

decrease of the impact on the environment and significant reduction of 

losses in the forest and on site). 

• Forwarding 

The forwarding is carried out according to the most common protocol in 

African equatorial forest, system in which one carries out a very selective 

exploitation of the trees. 

- Layout of a primary track serving all the UFA, according to an optimum 

route to minimize difficult ways. That track is set and maintained during 

the UFA exploitation period. 

- Secondary layout going from the site (on main track) to the exploited 

blocks. In general, the secondary track, planned with the bulldozer, is only 

used for the exploitation of a (or even part of a) cutting area. These 

secondary tracks are planned according to the situation of the trees to 

forward, to the blocks, to the lie of the land. 

- Layout of logging drags going from the secondary track to the long pole to 

forward. These logging drags are opened up with a skidder (Caterpillar 

528) or with a bulldozer (in case of an exceptional long pole) and 

generally “visually” by the bulldozer driver, under the guidance of a help 

who indicates him the most direct way to reach the long pole, the driver 

being responsible for avoiding the big timber. The power of the track 

hauling machines enables to go through very difficult contexts, while 

crushing the vegetation, most of the time with minimum respect for the 

environment. In terms of impact, forwarding is the most critical phase: for 

the time being, there is no technical means likely to minimize its impacts 

significantly. 

- Back to site, the long pole is dragged by the vehicle with a steel cable 

(winch on bulldozer or hauling machine). 

3.4 - Labour planning 

• Exploitation of the cutting areas 

• Inventory of exploitation 

In addition to the cutting area perimeter, the Administration sets a limit per 

unit volume for the exploitation on each cutting area. That limit is set on the 

logger’s proposal too, according to a systematic inventory. 

That inventory is carried out by a prospecting technical team commissioned 

every year in the cutting area of the N+1 year. The team uses a chequering 

process of the cutting areas into a 3,280 by 492 feet “block”, within which the 











Version : 2.1 

exploitable stems are listed and mapped. The stems are measured with a 

forestry compass (problem for buttress species); a number is given to each 

stem preidentified during that phase (2 or 3 letters for the species and a 

continuous number are painted on the foot). The maps of the systematic 

inventories are copied out neatly at the office. 

When the exploitation of a block comes to an end, the exploitations 

monitoring is carried out, so as to check that there is not any inventoried 

timber not exploited or any felled stem not forwarded. 

During the exploitation, once the maximum limit volume of the cutting area 

for a given species is reached, that species’s exploitation in that cutting area 

becomes illegal. Considering a rigorous monitoring protocol, that measure is 

put into practice; an underestimation of the volume during the systematic 

inventories leads therefore to leave surplus timber standing. 

Any attempt to exploit a fenced in cutting area for the second time is strictly 

forbidden and monitored by the Administration. 

Within the scope of the temporary convention (set before definitive 

convention), the 2005 cutting area covers a 4,183 ha surface and an 

inventoried volume (according to the systematic inventory of the exploitation) 

of 80,573 m3 including 26,527 m3 of Bongossi. Only 62% of the volume 

concerns managed speciess (for which rates of adapted renewal have been 

presented in the official management: 

Speciess Amount volume Speciess amount volume 

“Abale” 57 

378 White Eyoum 15 116 

White Mahogany 90 

727 Red Eyoum 41 38 

“Agba” 2 

24 “Faro” 177 1998 

“Aiele / Abel” 176 

1584 “Fraké / Limba” 333 2078 

“Ako” 11 

69 “Framiré” 2 7 

“Alep” 613 

4655 Kapok tree / Ceiba 76 902 

“Angueuk” 131 

939 “latandza” 4 33 

“Asila” 5 

27 “Ilomba” 906 5943 

“Ayous” 2 

15 “Iroko” 26 256 

Bongossi 3346 

26527 “Kondroti” 2 16 

“Bahia” 138 

1112 “Kossipo” 44 471 

“Bilinga” 505 

4523 “Kotibé” 2 14 

“Bodioa” 33 

295 “Koto” 136 833 

“Bongo H (Olon)” 131 

869 “Koto” 

Light Bossé 25 

187 “Kumbi” 4 21 

Dark Bossé 14 

108 “Landa” 3 20 

Pink Bubinga 57 

472 “Lati” 4 33 

“Dabéma” 304 

2845 “Limbali” 206 1930 

“Dibetou” 13 

128 “Lotofa” 4 25 

White Doussie 5 

42 “Makoré” 8 57 

Red Doussie 362 

3010 “Mambodé” 199 1674 

“Ebiara” 2 

14 “Moabi” 9 95 

“Ekop” 37 

347 “Movingui” 114 792 

“Ekop andinding” 3 

22 “Mukulungu” 3 35 











Version : 2.1 

“Ekop G” 9 

“Ekop I” 2 

“Ekop J” 9 

“Ekop M” 121 

North-West Ekop Naga 194 

“Ekop ngombé” 17 

Bosom Ekop ngombé 4 

“Ekop ribi” 15 

“Emien” 8 

“Essesang” 65 

“Eyek” 112 

“Eyong” 2 

72 “Naga” 119 1093 

17 “Niové” 31 235 

67 “Oboto” 16 109 

1061 “Okan” 191 1729 

1706 “Onzabili K” 138 1071 

131 Red Padouk 90 702 

42 “Sapelli” 13 140 

117 “Sipo” 49 597 

39 “Sougué” 109 857 

528 “Tali” 323 2783 

1209 “Tchitola” 12 108 

13 “Tiama” 14 116 

“Wenge” 1 9 

Total 6620 53921 0 3424 26936 

General total 10044 80857 

Table taken from the 2005 cutting area annual certificate (results of the 

exploitation inventory beyond the MLD/MMD (Minimum Management 

Diameter). 

4 - Other activities 

4.1 - Description of the activities 

• Harvest 

• Traditional agricultural activities 

• Fishing 

• Hunting 

• “Wild timber” cutting 

4.2 - Potential Impact on forestry 

These aspects are dealt with in detail in the rest of the report. 

5 - Base of evaluation 

5.1 - Composition of the audit team 

Lead auditor: 

- Forest auditor specialized in forest management 

and forestry, EUROCERTIFOR - BVQI auditor in 

traceability and in forest management, forest expert, 

independent consultant. 











Version : 2.1 

Auditors: 



traceability, Timber Expert, independent consultant. 


and forestry, EUROCERTIFOR -BVQI Audits 

Managers. 



traceability and in forest management, forest 

engineer, independent consultant. 

- Forest auditor specialized in environment and social 

aspects, Agricultural engineer, JMN Consultant, 

environment and social aspects consultant. 

5.2 - Previous audits 

The scoping carried out 12 months before the initial audit allowed to set the 

preliminary setting to standard action requests as follows: 

Nb Preliminary setting to standard action requested Demand Number 

01 

02 

Improve, structure and complete the monitoring procedure of the legal 

and statutory information 

Formalize the detailed procedure with the monitoring protocols, to see 

to laws, regulations and international treaties enforcement and inform 

the employees and subcontractors about the implications 

1.1.1 ; 4.2.1 

1.1.3 ; 1.1.4 ; 1.1.5 ; 

1.3.3 

03 Set a list of taxes, rights and charges due 1.2.1 

04 

05 

06 

07 

08 

09 

Complete and implement a monitoring procedure and protocol of illegal 

timber exploitation on the UFA 

Complete the policy which commits the company in a sustainable forest 

management and according to the PCI FSC 

Carry out an inventory of fixtures of the village lands, rights and customs 

which are linked to them as well as a social impact survey of the forestry 

operations concerning the local populations and possible autochthonous 

people. 

Develop and set up a pro-active social policy including: 

- the setting up of permanent consultation and négociation bodies 

- conflicts resolution procedures including any type of conflicts 

Develop a training policy for the personnel while encouraging the 

employment of local recruits 

Set up and implement procedures covering all the safety and health 

aspects at work, including the safety instructions adapted to each 

activity and operations 

1.5 

1.6 

2.1 ; 2.2.1 ; 2.2.2 ; 

3.1.1 ; 3.2 ; 3.3.1 ; 

3.3.2 ; 4.1.5 ; 4.4 ; 

5.2.1.1 ; 5.5.1 

2.2.3 ; 2.3 ; 3.1.2 ; 

3.1.3 ; 3.1.4 ; 3.3.3 ; 

4.1.1 ; 4.1.4 . 4.1.5 ; 

4.3.4 ; 4.4 ; 4.5.2 

4.1.2 ; 7.3 

4.2 











Version : 2.1 

Nb Preliminary setting to standard action requested Demand Number 

10 Keep up to date statistics on accidents at work 4.2.3 

11 

12 

13 

14 

15 

16 

Supply the workers with appropriate and maintained safety and working 

equipments and see to the wearing and good use of these equipments 

Choose a member of the personnel in charge of health and safety 

aspects at work, and of the related trainings, on each site 

Set up procedures allowing to deal in a transparent and objective 

manner with the problems presented by the personnel 

Set up effective and documented procedures allowing to anticipate and 

manage the conflicts with the workers 

Estimate the social and environmental costs of the management and 

forestry operations 

Develop and complete the procedures and monitoring protocols of 

forestry operations with the aim of minimizing damage 

4.2.4 ; 4.2.5 

4.2.7 

4.3.3 

4.3.4 

5.1 

5.3 ; 5.5.3 ; 6.5 

17 Carry out an environmental impact survey 5.5.2 ; 6.1 ; 6.5.2 

18 

19 

20 

21 

22 

23 

Carry out a fauna survey and implement protective measures for 

speciess and measures against poaching 

Develop and update a list of chemical products used on sites and 

minimize their use. 

Set up and implement management procedures and monitoring 

protocols on the management of the chemical products respecting FSC 

directions for use and specific instructions. 

Put safety instructions and instructions for use as well as adapted 

protections at the disposal of the workers using chemical products 

Review the treatment of waste process apart from wood (oil filters, 

tyres, salvaged hydrocarbons...) and implement it. Insert monitoring 

protocols of these procedures 

Develop and implement a forest management scheme integrating 

sustainable management of the forest and the environmental and 

ecosystems elements- 

Develop and implement monitoring and assessment procedures for the 

concerned activities 

Study the pertinence of the classification in HVFC of certain zones of 

the UFA and, in case of need, plan adapted protection measures 

6.2 

4.2.6 ; 6.6 

6.7 

7 ; 5.6.3 ; 6.3 ; 6.4 

8.1 ; 8.2 ; 8.4 ; 8.5 

9 

5.3 - Forest management referential used for the initial audit 

For that initial audit, we referred to the verification list (ref. LVRF 010013 version 

1.0) from the FSC forest sustainable management adapted to Cameroon (Ref. 

RFNT 010012 version 1.0). 











Version : 2.1 

5.4 - Stakeholders comments on referential 

A stakeholders’ consultation meeting took place on Friday, 9th June 2006. A 

few speeches were recorded.jj Detailed answers have been given to the 

speakers, none of these points being likely to lead to changes in the referential. 

5.5 - Effective laws enforceable to the activities of the forest entity 

applicant 

Forests management: 

- “Forests, fauna and fishing regulations” Law. (1994) 

- Order completing certain clauses of the law on forests, fauna and fishing 

regulations. (1999) 

- Decree setting the modes of enforcement of forests regulations (1995) 

- Decree setting the modes of enforcement of article 71(1)(new) of the law on 

forests, fauna and fishing regulations (1999) 

- Decree relating to the scheme securing forest revenue (1999) 

- Decree modifying the decree setting the modes of enforcement of forests 

regulations (2000) 

- Order setting the modes of allocation in priority to village communities 

riparian to any forest which could be established as a community forest 

(2001) 

- Order setting the preselection criteria and the choice procedures of the 

forestry site titles tenderers 

- Development, approval, monitoring and control procedures of the 

implementation of the permanent forestry domain production management 

scheme 

- Circular letter specifying the participation conditions to invitations to tenders 

of forestry titles allocation 

Environment: 

- Framework law relating to environment management (1996) 

- Decree on organization and functioning of Interdepartmental environment 

committee (2001) 

Water: 

- “Water regulations” Law 

- Decree setting the allocations, the organization and the functioning of the 

National Water Committee 

Social and work: 

- Cameroon’s 14th August 1992 labour regulations and implementing decrees 

- National collective agreements of exploitation and forest products processing 

companies and related activities of 26th April 2002 

Tax system: 

- Tax regulations (January 2003) and implementing decrees 

- Financial act of the Republic of Cameroon (2004) 

The forest tax system plans a tax system intended among other things to a 

redistribution of the forestry income (Annual forest Royalty) to local populations 

(see appendix F list of the tax papers). 











Version : 2.1 

The Annual Forest Royalty (AFR) is redistributed: 

- For 50% to the State; 

- for 40% to the village councils; 

- for 10% to the villages of all the UFA. 

International agreements: 

The company too is submitted to the requirements of the international 

agreements ratified by the Republic of Cameroon, in particular: 

- Framework agreement on climatic changes 

- Kyoto Protocol 

- Agreement on biological diversity 

- Vienna Agreement for the protection of the Ozone layer 

- Agreement on the international trade of wild flora and fauna endangered 

speciess (ITWS) 

- Agreements and directives of the International Office of Work 

6 - Information collecting modalities 

6.1 - Description of the audit program 

6.2 - Documents review 

• Documents supplied to the Audit team as computer format 

• Paper documents collected during the audit 

6.3 - Interview(s) of involved people met 

The interviews concerned the members of the TRC DOUALA company; in 

particular the following people: 

- Mister REEF, REEF HOUT B.V Manager. 

- Mister QUARESMA, TRC Executive Officer 

- Mister EFFALLA, Assistant executive Officer 

- Mister Michel ALLAZ, interim forestry director 

- Mister WANDERS, FORM INTERNATIONAL 

- Mister Arnaud Tcho-komeni 

for the FORM International company: 

- Mister Mans VROOM 

These interviews were the subject of long and constructive discussions, led to 

handing in documents and to the presentation of the UFA and the company's 

functioning. 

Moreover, the audit team questionned many people, at any level of qualification 

and responsability, inside the TRC company and subcontracting companies, as 

well as numerous riparians, headmen, contractors, or simple citizens of the 

villages bordering the UTO. Moreover, it met the commissionner of the Campo 

Ma’an UTO. 











Version : 2.1 

The stakeholders’ consultation moreover allowed to meet key people who 

passed on to us pieces of information which have systematically been checked 

by the audit team. 

6.4 - On-site visit(s) 

UFA 00-004 was the subject of sites visits intended to monitor the management 

system efficiency, in particular the long pole traceability set up by TRC Douala. 

Moreover, its purpose was to check the reliability of a few remarks made by the 

stakeholders during the consultation meeting. 

The terms of boundary, marking and public warning have been checked. 

Several interviews have been carried out so as to determine the credibility level 

to give to the different pieces of information which have been given to us by 

TRC and FORM. 

6.5 - Stakeholders identification and consultation 

• Stakeholders’ consultation 

On 6th May 2006, an official consultation was launched by email and by letter to 

all the local, national and international stakeholders so as to inform about the 

TRC approach and to collect their different comments concerning the forest 

management practised by TRC. 

The main comments received following that consultation concern the following 

major themes: 

- Speed of the process 

- TRC illegal activity in Ebo forest: can an FSC certificate be issued if the 

company has illegal activities in other forests 

- Should not the other forests under TRC management be submitted to the 

FSC “Partial certification” and “controlled wood” text 

- If so pt 5, is one going to take into consideration the TRC activities on the 

SEPFCO concessions 

- Did TRC classify the UFA as HVFC (because the UFA is located in the Ebo- 

Ndokbou area, very rich ecologically and with hundreds of rare animal 

speciess) 

- What are the procedures planned and implemented to maintain the zone’s 

biodiversity 

- Are zones within the concession going to be protected 

- Are specific measures going to be taken to protect rare, protected and 

endangered speciess 

- Is a buffer zone planned in the area around Ebo forests and Mounts 

Nlonako 

- Besides the biological survey were there environmental and social impact 

surveys, and if so, are they public 

- Concern about poaching in Ndokbou forest: what measures did TRC take or 

implement to handle that problem 

- What means have been taken to consult the communities 

These points were systematically analysed during the audit. The recurrent point, 

relating to the constitution of Mount Ebo's reserve bordering the UFA was in 

particular subjected to a major and a minor corrective action requests. 

The written answers to the stakeholders will be given within the planned time by 

the certification protocol. 











Version : 2.1 

• Public consultation meeting: 

On 9th June 2006, EUROCERTIFOR BVQI organized in the meeting room of 

Douala’s IBIS hotel, a public information meeting within the scope of the TRC 

company’s FSC initial audit. 

Took part in that meeting around fifty participants representing the private 

sector, the non-trading Organizations, the village councils and the local 

authorities representatives. 

The meeting was aiming at the two following objectives: 

a) Answer the questions concerning the FSC certification activity and collect the 

observations, comments, remarks on the FSC referential and its adaptation; 

b) Collect the observations, comments, remarks on the TRC forest 

management in its UFA 00 004. 

That meeting took place without the presence of TRC, so that the accounts and 

requests could be collected with complete freedom and without the debate 

being started up. 

I. Presentations by the audit team on themes: 

The auditors firstly presented the purpose of the meeting, the ins and outs of 

the process opened at TRC’s request: 

• Audit team presentation 

• Presentation of the FSC certification system 

• EUROCERTIFOR - BVQI presentation 

• Presentation of the certification process 

• Presentation of the FSC referential and its adaptation 

• Presentation of the TRC approach 

• Presentation of the public meeting purpose and the stakeholders’ 

consultation 

During these interventions, the auditors specified the certification purposes, the 

notions of certification label (FSC) and certifier organization (EUROCERTIFOR 

- BVQI) and the auditors’ role. They reminded that the ties between 

EUROCERTIFOR - BVQI and TRC were contractual by nature within the scope 

of a contract of service, however that EUROCERTIFOR - BVQI was an external 

organization and totally independent from TRC. 

They insisted too on the fact that the certification corresponded to a global level 

of quality reached at the time of the audit, but that maintaining that label 

depended on numerous controls and on a yearly external surveillance protocol. 

II. Discussion questions on the certification and approach of TRC. 

The introductory presentations were carried out respectively by the audit team: 

It is to be noted that a fifth auditor, a developer engineer, absent at the meeting, 

joined the team for the rest of the audit. 

Following these informative presentations and the clarification of the meeting 

purposes, the participants asked numerous comprehension questions and told 

the auditors about their main expectations and concerns. 

The discussions took place in a warm atmosphere and the stakeholders’ 

opinions were expressed unhesitatingly; this has been eased by the statutory 

absence of TRC at that meeting. 











Version : 2.1 

Around twenty recording forms of the participants’ response have been filled in 

and handed in immediately. 

What emerges from these exchanges are the following concerns: 

As far as the FSC referential and its adaptation are concerned: 

Several remarks have been collected on the FSC referential and its adaptation 

to Cameroon. These questions tended towards the same wish to include more 

precise elements. It has been answered that it was desirable to give each 

company the possibility to set up means of responding to FSC constraints 

adapted to its own situation. 

Moreover, the auditors specified that the principles and criteria set up by the 

FSC could not be altered by the certification body, whose freedom is limited to 

the indicators definition. 

As far as TRC forest management is concerned 

The questions asked are repeated in the following points: 

- Expectations in terms of road construction in the villages 

- Need in furniture 

- Need in schemes monitoring 

- Would appreciate that the forest management scheme should be known by 

everybody 

- Problem of Myldem community forest: fraudulent exploitation (wild felling) 

and contentious files (management scheme not repected): that CF does not 

bring anything to the population. Is worried that that CF (and his former office 

which is questionned) goes into partnership with TRC 

- What level of the certification process are we at 

- Does the certification have a link with the authorization to exploit the forest 

- Wonders if TRC took into consideration populations’ grievances because did 

not have the knowledge of the “terms and conditions” 

- Question on the struggle against wild sawing 

- Question on the struggle against poaching 

- And what about non ligneous products 

- One must make the youths taken on by TRC subscribe to the CNPS (for their 

retirement pension) instead of employing them as temporary workers 

- Is the RFA transfered 

- Make sure that the management Committees are effectively set up (CSP ) 

- Make sure the boundaries with the different types of forests around the 00 

004 are respected 

- Finds that TRC consults the populations in a cavalier manner: FFC launched 

in 2 days, no explanation of the approach in the villages- 

- Problem of the “exiles” want to bury their dead in the villages of their 

ancestors (which they had to leave in the 60s) 

- Problem of communication with the populations to explain the respect of 

environmental and accompanying standards 

- Requests the setting up of a sawmill to create jobs 

The auditors provided elements of answers as far as the FSC Referential and 

its adaptation are concerned however, as far as the TRC management is 

concerned in accordance with the work methodology adopted, the questions, 











Version : 2.1 

observations, remarks and comments have been recorded and should be 

exploited by the mission during the audit. 

In accordance with the work methodology adopted, the questions, observations, 

remarks and comments have been recorded and exploited by the mission 

during the audit. 

As a synthesis one will note: 

- that certain elements collected during that meeting have not been confirmed 

on field (there are, for example, numerous skilled workers, including at 

responsibility posts, recruited and trained on the zone). 

- Other pieces of information seem to come from a lack of development of the 

process: The socioeconomic surveys are in progress, the committees are not 

all formed- 

- At last, most of the points from that meeting refer to the conflict relating to 

Mossé-Ndocbassaben road. It is therefore very important that that conflict 

should be managed, documented and resolved within the most profitable 

terms to all the parties. 

6.6 - Identification, traceability and monitoring of products 

• Marking, traceability 

The tree marking system is as follows: 

Each long pole and each butt receive a set of corresponding numbers: 

- number of the tree identified on the systematic inventory map (painted by the 

cutter, with his initials) 

- UFA and cutting area number 

- date and exploitation zone 

- DF 10 number (official nb given by the MINEF) 

- the number of logs 

- the company’s identification 

When the long poles are delivered on yard, they are marked off, scaled, 

reworked (elimination of the less neat butts, and so on). The long pole receives 

at arrival on yard a “DF10” number, which will describe it for the following 

operations. The DF10 yard book details the characteristics of the long pole 

(species, mensuration, FOB value), and allows the administrative and trade 

monitoring of the products. 

The long poles stored on yard are then loaded on a logging truck (in general, 

within 48 hours, particular consideration being taken for treating low-density 

wood as quickly as possible). 

- The yard officer fills in the car letter too which details the characteristics of 

the transported long poles, and will accompany the load, to the factory.The 

monitoring documents are controlled by: the Local forest Administration; 

- the Central forest Administration; 

- the Forests Ressources Reassuring Scheme (joint supervision Ministry of 

Finance -Ministry of Forestry) 

- numerous controls and weighings on the roads. 

Therefore, the permanent monitoring of the progress of a cutting area 

exploitation scheme is possible and really carried out. 











Version : 2.1 

• Description of the implemented system to ensure traceability 

• Description of the final location of taking in charge 

(See FSC traceability report) 

• Documentation or marking system description 

The DF10 number is marked on each long pole, legally and regardless of the 

protocols set up by the company. Therefore, a DF 10 number (hammered on 

the stump and on the long pole, therefore indelible) on each long pole, allows to 

know the fate of each short-log (sawmill where the short-log has been 

transported, date, and future). 

That research has been carried out for several long poles and gave convincing 

results. 

• Mixing risk assessment 

In the forest, and between UFAs, there is no risk of mix-up or mixing between 

the products considering the fact that each long pole is identified by its own 

unique number. 

6.7 - Initial audit closing meeting 

The audit team’s conclusions have been presented during a reconstruction and 

a closing meeting on 17th June 2006, in presence of: 



- Mister Jacques HULEUX, Forest management committee and certification 

step Manager 

- Mister Miguel DOUALA Sawmill site manager 

- Mister Eric SPANGERS, AFD 

- Mister Mans VROOM (Form) 

And of all the audit team. Despite the difficulty of the task to be accomplished, 

and the nature of the conclusions of the audit, the TRC company ratified all the 

auditors’ conclusions 

7 - Audit team observations 

Considering the major expectations which exist in relation to the result of that audit, 

pioneer in the geographical zone and therefore subjected to a lot of attention from 

everybody, TRC became aware that it is important to be extremely strict as for complete 

and detailed implementation of all the referential points. 

Despite major standards keeping up efforts, all the necessary actions have not been 

taken in that respect. Results of the assessment with regard to FSC – Certifor referential. 

It seems fit to remind that the scoping was carried out very prematurely and that the task 

to accomplish was a very important one. The great number of corrective actions 

requests are not at all an admission of failure, however they must form guidelines to start 

the work needed to reach the FSC standards. 











Version : 2.1 

7.1 - Evaluation results with reference to the FSC referential / standard 

7.1.1 - Principle 1 – Compliance with laws and FSC Principles 

One has to note: 

- That certain points of forestry legislation are not respected, in 

particular the company does not fully comply with decree 222 

regulating forest management by Cameroonian law; 

- That the legal monitoring is inadequate and not in compliance with 

the procedure as it limits itself to the reading of the Cameroon 

Tribune. It has to apply to the Gazette, to all the communications of 

the Forestry Producers’ Union (GFBC) 

- That international texts which concern the company’s activity are not 

available, and that all the more so, their impact on the company are 

not known. 

- That, as a general rule, there is no translation into operational terms 

of the legislative texts by which the company is concerned. 

7.1.2 - Principle 2 – Tenures, use rights and responsibilities. 

The TRC company did not have time to gain sufficient knowledge of 

the social issues on the sites on which it operates. 

Twelve Forest- Farmers committees have been formed on TRC’s 

initiative. These committees, representative enough of the different 

stakeholders only met once, and several stakeholders complained 

about the haste with which their setting up step was carried out. 

Nevertheless, the missions which have been assigned to them 

(arbitration in case of conflicts concerning the UFA - specifications 

setting up monitoring - activities planning - planned activities 

assessment) should allow, if they were functional to tackle a certain 

number of conflicts and all in a planned, participative and above all 

lasting manner. 

The communication of a forest management scheme summary 

(enhanced with FSC guidelines) to the different stakeholders, in 

particular the communities living next to the UFA, summary written in a 

an understandable language, has not been carried out. 

These committees will allow to refine the inventory of fixtures of the 

local villages, rights and customs which are linked to them, in particular 

in the eastern sector which is not yet well involved in the step. 

The stakeholders’ consultation brings out a persistant problem linked to 

the presence of ancient villages within the UFA, whose populations 

have been displaced and gathered in Ndokbassaben (East of the UFA) 

during the events linked to the independence of Cameroon. These 

villagers have never had the possibility to return to their territory, which 

is today included in the UFA. They consider therefore the opening of 

the road as a vital need. 

The progress of the State road is at present stopped, because the 

company is against its way through the UFA. 

It will matter to manage, resolve and document that conflict. 

As a more general rule, TRC should: 











Version : 2.1 

- Begin the social impact survey which terms have been approved 

- Apply development projects aiming at improving living conditions of 

the populations of the villages riparian to the UFA in accordance 

with appendix II to the definitive agreement which concerns the 

UFAs riparian to protected areas. 

It is to be noted that an interesting “village hunting survey” has been 

carried out with the support of the WWF and Nature +. It confirms the 

importance of income generated by poaching in the zone. 

The village lands emerging from that survey have been included in the 

agroforestry zone, nevertheless it is very important that TRC should 

consider that they remain responsible towards these lands and try as 

much as possible to limit there illegal tree felling and commercial 

poaching. An action scheme should be produced. 

7.1.3 - Principle 3 – Indigenous people’s rights 

The socioeconomic surveys vouch sufficiently for the absence of 

Pygmy on the zone in question. 

7.1.4 - Principle 4 – Community relations and worker’s rights 

Significant progress has been recorded concerning the quality of the 

living sites, as well as of the protective and safety equipment. 

Nevertheless, these efforts are very recent and deserve to be judged 

on a slightly longer term: the working clothes were new when we 

passed through the site, and the protective equipment was not 

everywhere in compliance with the procedures (safety boots expected, 

however not present on site, for example). 

Moreover, the subcontractors and contributors on the TRC sites are 

subjected to the same rules as the company workers: on the site of the 

Douala sawmill, the outside personnel who gathers the sawdust, 

passes permanently through the yard in unacceptable working 

conditions (direct and permanent contact with fine noxious sawdusts, 

without any protection, premises not equipped -). The resolution of that 

CAR which concerns all the company’s certification and labelling 

process is urgent 

TRC should make sure of the scrupulous respect of labour law within 

the company: A few contentious points have been raised during the 

initial audit: 

- Automatic promotion of the employees in accordance with labour law 

and collective agreement is not updated. 

- The disciplinary measure policy within the company is not always 

implemented in compliance with the labour law and collective 

agreements. 

- As a more general rule, there is no procedures allowing to treat in a 

transparent and an objective manner the problems presented by the 

personnel 

A great effort has been granted in terms of equipment, training and 

structuring of safety and care on the company's sites. One should set 

up initiatives of fight against HIV AIDS, and to check by the assistance 

of the doctor associated to the company the origin of the medicines in 

order to avoid fake medicines known to be abundant in Africa. 











Version : 2.1 

7.1.5 - Principle 5 – Benefits from the forest 

TRC should vouch for the economic viability of UFA 00-004 

exploitation. (principle 5.4) To do so, it will be fit to include into the 

calculations the processing activities, as well as the social and 

environmental aspects in a global budget including the certification 

direct and indirect costs. 

The social and environmental impact survey should bring out the non 

ligneous forest products uses on zone. The present drafting of the 

management scheme is in apparent contradiction with the P&C FSC as 

the management scheme specifies on page 84: 

“The non ligneous forest products promotion actions are not to be 

encouraged -”. 

When the FSC says, “Forest management operations should (-) 

diversify local economy (in order not to) depend on only one product.” 

If that contradiction is only apparent, it matters to do something on a 

local scale. 

7.1.6 - Principle 6 - Environmental impact 

Great efforts have been made by the company for equipment and 

waste management and for the general quality of the living sites. 

The works impact – in particular the tracks – is often important and we 

have been able to notice that if there are quality monitoring protocols 

for them (outlets management, control of the sedimentation in the river 

beds, pipes, and so on), the protocols are not followed, not known from 

the field operators, and therefore not implemented 

On the other hand, the secondary works should be closed after use 

(closure of cutting areas) A procedure of closure of cutting areas 

should be therefore implemented immediately after agreement from the 

administration. 

The use of chemical products by TRC is only done on the sawmill yard 

against insect and mushroom damage and at the time of the sawing 

treatment. 

TRC must try to use active matters that are the least dangerous for the 

environment and human health: SARPAGRUM used as treatment of 

the long poles and sawings, contains cypermethrin, a product which is 

since January 2006 on the new list of non authorized products by FSC. 

The postexploitation inventory, which allows control of the good 

implementation of the exploitation and of the yards’ complete emptying 

should be carried out and documented, in compliance with the TRC 

company’s procedures. 

It will also be fit to start the environmental impact survey the terms of 

which have been approved. 

As a general rule, TRC should appropriate these surveys, and not 

content itself with making them carried out by the NGO whose 

schemes and missions can change unpredictably and which will not be 

on site during all the time of the management. The surveys should 

conclude towards precise action schemes. 

TRC must implement development schemes aiming at improving living 

conditions of the populations of the villages riparian to the UFA in 

accordance with appendix II to the definitive agreement which 











Version : 2.1 

concerns the UFAs riparian to the protected areas in order to limit the 

financial impacts of the end of poaching and illegal fellings on zone. 

One stakeholder told us about the existence of a listing scheme of the 

Ebo-Ndokbou site, listed in priority zone for conservation in the Action 

Regional Scheme for the conservation of Gorillas and Chimpanzees in 

Western Africa. 

It should matter to know more precisely the arrangements of that 

scheme and to take adapted measures (setting buffer-zones, special 

measures of fight against poaching -) in order to ward off efficiently the 

criticism which could be made to TRC on that sensitive point. 

“Buffer-zones” should be planned next to the watercourses: drags are 

sometimes carried out and cause major damage which could be 

minimized by cable logging. 

Very big trees (diameter over 2 m) are sometimes exploited. These 

long poles are very expensive in logistical and environmental terms, 

and are badly developed because the sawmills are not adapted. It 

would therefore be fit to purely and simply forbid their exploitation for 

the sake of protection. 

7.1.7 - Principle 7 – Management plan 

Bongossi, which represents 33% of the harvest on the first cutting 

area, has been excluded from the management. 

The management scheme does not contain elements allowing to 

control its durability: it will be fit in particular to review the management 

calculations and to justify the harvesting rates on all the exploited 

species in a significant manner. 

All weak rates should be interpreted and argued. 

The global renewal rate should be close to 100%. During the 

management implementation, the species inventory diameter should 

correspond to FSCMD 

Moreover, and to comply with Cameroonian forestry law, TRC should 

write the 2007 yearly operation scheme, as well as, on the 2006 cutting 

area, the yearly forestry intervention report. 

Moreover it is recommended to simplify and optimize the forest 

traceability monitoring procedure, which complexity leads to risks of 

mistakes. The local executives should be associated to that simplifying 

work, and making the written procedure comply with the field practice. 

Finally, respect of principle 7 should impose to establish a collaboration 

with the international and national forestry research organizations to 

adjust the research schemes in progress. 

7.1.8 - Principle 8 – Monitoring and assessment 

Forest monitoring sample plots have been set on the UFA, according 

to traditional protocols, in a satisfactory manner, and are monitored 

within the scope of an agreement with university structures. However, 

that scheme lacks in practical purpose for TRC 

- the unexploited zones are overrepresented 

- the number of trees monitored belonging to the list of the species 

exploited by TRC is not significant within all the diameter classes. 

Therefore the company has to adapt the procedures so that they meet 

its needs, for example: 











Version : 2.1 

- from what diameter does such a species bear fruit (what allows to 

justify a harvest diameter- and therefore a renewal rate - not too low) 

- what is the growth of such a species on the zone 

- It is planned to monitor regularly a “phenologic range” among TRC’s 

“leading” species, allowing to know precisely their growth and their 

fruit formation cycle on a stastistic sample valid per species and per 

diameter class. 

As a general rule, TRC should work out and implement a long term 

monitoring scheme adapted to the needs of the company and 

monitoring procedures of all the monitoring and surveillance actions. 

These procedures will plan the writing of adapted reports. 

7.1.9 - Principle 9 – Maintenance of high conservation value forests 

TRC defined the HVFC of the different types in the zone, the support 

documents and the actions to be carried out. However, it matters to go 

further and to define the attributes, that is to say what makes that such 

or such zone can be considered as HVFC. (list of rare species present, 

social and cultural importance, and so on.) 

The social and environmental impact survey should define precisely 

the HVFC of the zone. 

7.1.10 - Principle 10 – Plantations 

Groundless 

7.1.11 - Principe 11 – Group certification approach 

Groundless 

7.2 - Systematic presentation of results 

See auditors verification list in appendix C of the report. 

7.3 - Elements subjects to controversy 

The results of the present audit have been discussed thoroughly between 

EUROCERTIFOR - BVQI and TRC. Despite the shortcomings noted during that 

audit, no debatable element has been mentioned by the audit team. 

8 - Scope retained for the certification 

8.1 - Geographical limitation at the level of the entity 

The certification applies to all of UFA 00-004. 

8.2 - Limitation at the level of the forest products 

All the timber forest products declared exploited on UFA 00-004. 











Version : 2.1 

9 - Proposals regarding the certification decision 

9.1 - Explication on all rating, weighting systems or other systems used 

decisions taking 

The audit team did not use a notation or balance system to lead the initial audit. 

Indeed, all the referential requirements have been considered of equivalent 

importance, each criteria having to be satisfied by the entity applying for the 

certification. The criterion compliance is defined when more than a third of the 

criterion keys (requirements) are not met, or, the audit team estimates that the 

unsatisfactory noted key(s) leads to the criterion nonconformity. 

The indexes, specified in the checking list, should be considered as a user’s 

guide for the auditors. 

9.2 - Clear description of all recommendations and conditions 

associated to the certification decision 

Auditors’ recommendation 

P&C 

concerned. 

A Set effective evacuation measures for the yards' evacuation 

at the end of the working days 

1.1.3.1 

B Equip the sites and vehicles with radio communication 

means 

1.1.3.1 

C Make workers’ representatives aware of labour regulations 

clauses, collective agreements and international agreements 1.1.3.1 

concerning them. 

D make the personnel aware of overtime marking off 1.1.3.1 

E Make sure of the medicines active principles authenticity 4.2 

F Exploit the statistics on accidents at work 4.2.3 

G simplify and optimize the forest traceability monitoring 

procedure, update the written procedure. 

5.3 

H Increase the boundaries visits frequency within the sensitive 

zones against poaching and illegal felling. 

6.1.2 

I Take measures to avoid the felling of very big trees having a 

patrimonial value and particular exploitation difficulties. 

6.1.2 

J Revise the procedure of compensation for farming damage 

to include in it a fair and equitable scale 

6.1.2 

K Ensure the site managers training or bringing to standard 

with regard to the company’s rules and regulations 

4.3 - 4.4 

L Set a system allowing to pass effectively pieces of 

information on the newly recruited personnel at the level of 4.3 - 4.4 

the TRC sites. 

M Organize the meetings allowing to make the workers’ 

consultation bodies function 

4.3 - 4.4 

Comments on the recommendations K, L and M: We consulted with the 

personnel department the personnel registration sheets and we noticed major 











Version : 2.1 

differences between the number of declared workers and workers in the 

process of being declared and the numbers of workers not yet registered 

(nearly one third of the number of workers at the time of the audit) (12th June 

2006). These differences would be attributable to the delay of different sites 

(Kumba and 00 004) in the transmission of pieces of information about the 

locally recruited personnel (on sites). The pieces of information on the 

personnel recruited at sites level do not reach effectively the level of Douala’s 

personnel department to ensure their immediate registration at the CNPS. The 

personnel officer realizes this during the employees’ payroll preparation, 

whereas the appointment should be followed by the worker’s registration. 

9.3 - Minor Corrective Action Requests 

Nb Minor corrective actions requested 

Realization delay 

suggested 

Demand Number 

18 Supply the definitive agreement and the constitution 

1.1 

February 2007 

order. 

19 Suggest an action scheme concerning a revision of 

1.6 5.5 5.6 

the MS (Management Scheme) on the basis of the 

new FSC guidelines and logging diameters, 

February 2007 

calculated according to FSC principles and criteria. 

20 Formalize the existing initiatives in a training policy for 

4.1.2 ; 7.3 

the personnel while encouraging the employment of February 2007 

local recruits 

21 set up fighting initiatives against HIV AIDS February 2007 4.2 

22 Keep the retention pans in working order February 2007 4.2.6 ; 6.6 

23 respect the procedures on the treatment of the 

polluted slash. 

24 Make sure that the workers' representatives meetings 

take place according to legal measures 

25 Draw up a complete economic report integrating the 

processing activities, as well as the social and 

environmental aspects 

26 Carry out the post exploitation inventory in 

compliance with the TRC company procedures 

27 Take into consideration the bordering zones 

constitution schemes and draw the consequences in 

terms of exploitation 

28 Argue and justify the choice of the conservation 

zones with regard to fauna surveys, and 

environmental surveys 

29 Set up 33 yard buffer zones around all the 

watercourses. 

30 Implement development schemes aiming at 

improving the living conditions of the populations of 

the villages riparian to the UFA (in particular to 

compensate the loss of income linked to poaching 

disappearance). 

31 Set up and implement control procedures of all the 

surveillance and monitoring actions planning the 

writing of adapted reports. 

February 2007 

February 2007 

February 2007 

February 2007 

February 2007 

February 2007 

February 2007 

February 2007 

February 2007 

4.2.6 ; 6.6 

4.3 4.4 

5.1 

5.3 

6.1 

6.1 

6.1.2 

6.2 

8.1 8.2 











Version : 2.1 

Nb 

Minor corrective actions requested 

32 Develop and implement a long term monitoring 

scheme adapted to the company’s needs 

33 take over all the survey and the short-, medium- and 

long-term monitoring actions 

34 On the basis of the scale set in the procedures 

manual, bring out the characteristics of the HVFC 

specific to the UFA. Detail the adapted measures 

planned by the company 

Comments concerning the minor CAR: 


suggested 

February 2007 

February 2007 

February 2007 

Demand Number 

8.1.1 

8.1.1 

CAR nb 19: meanwhile, a difference exists between the official MS and the FSC 

practice implemented on field as the scheme was ratified before the calculations 

allowing to ensure a more sustainable forest management were imposed on 

TRC. 

CAR nb 20: There is no clearly defined and formalized policy concerning 

personnel training and local recruits’ appointment. The way the company 

operates does not favour locals’ recruitment, even for unskilled jobs. 

CAR nb 21: prevention, granting of benefits - see texts ILO-HIV AIDS. 

(covenant 155 on the workers’ safety and health) 

In its fighting policy against HIV AIDS, the Cameroonian State through the 

national committee of fight against AIDS (NCFA) set up a policy that should 

allow and favour the companies’ support in the process. From this perspective 

in particular, the companies themselves are expected to set up initiatives 

allowing to follow the progression or control the prevalence of that pandemic 

and take steps to limit it. 

At the level of the forest living bases, we noted the absence of condoms in the 

site infirmary. Yet, the interviews held with certain employees of the site allow 

us to say there is a need. The spread and contamination hazards are major not 

only at the level of the living basis, but at the level of the villages in which the 

workers live too (Iboti for example). 

CAR nb 22: The retention pans developed at the level of the sites (Douala), by 

the company to limit accidental spillages and soil contamination by 

hydrocarbons are not properly maintained. The settling pits blocked up with 

sand do not allow a better settling/separation of the water and the hydrocarbons 

which overflow and flow over the soil. 

CAR nb 24: linked to the major CAR nb 14 

CAR nb 27: buffer zone next to Ebo park 

CAR nb 28: example: protection of endemic species: which ones 

Locating the conservation zones on the UFA (rocky zone in particular) does not 

corroborate with the results of the fauna survey which has been carried out by 

the WWF. This survey mostly shows zones rich in fauna in the loop formed by 

the Makombé river which runs through UFA 00 004. 

CAR nb 29: It consists in putting into practice the requirements of the 

intervention in the forest standards, in accordance with the measures of article 

25 of decree nb 531 from 23rd August 1995 setting the modes of enforcement 

of forestry regulations. 

CAR nb 30: UFA 00 004, as well as all the Inoubou basin to which it belongs, is 

a zone of intense poaching. Poaching represents for a lot of village residents of 

9 











Version : 2.1 

that basin a major activity, which feeds the great urban centres of Cameroon 

such as Yaoundé, Douala Bafia, and so on. The main axis of wild fauna 

haemorrhage are access roads from the South near Mossé, from the West on 

the Nkondjonck- Yabassi- Yingui axis and from the North East near 

Ndokbassaben. That last axis is the main one and the hunting survey results 

show it well (major density of human activity rating) 

Public awareness attempted by the company within the villages riparian to the 

UFA concerning the fight against poaching should be accompanied by 

strategies (reinforcement of capacities, trainings, and so on) allowing the 

populations to develop alternative activities which can ensure income, in order 

to take them away from poaching. 

CAR nb 33: TRC should direct the actions so that they meet its needs (For 

example, restocking of reduced renewal rate species). 

It is clear that the TRC company’s principal activity is timber exploitation and 

processing. The sustainable management process in which it is involved 

presupposes too and above all the mastery, not only of these surveys results, 

but also of the monitoring of the activities which are implemented and should 

allow to supply future directions. 

The outcome of the audit that we conducted shows that the different partakers 

of the operations and surveys that have been carried out retain control over 

their results and that no appropriation step is set up by the company to ensure 

itself (management committee) the in-house monitoring of the activities in time 

and space. 

CAR nb 34: Informal felling, poaching - 

Nb 

9.4 - Major Corrective Action Requests 

Major corrective actions requested 

1 Write and submit the 2006 operation annual scheme 

and the 2005 forestry intervention annual report. 

2 Apply the monitoring procedure of the legal and 

statutory pieces of information, 

3 Have all the procedures ratified and signed by the 

TRC management. 

4 Make public a MS summary presenting the guidelines 

linked to FSC 

5 Adjust the written procedures so as to make them 

comply with field practices, apply them. 

6 Refine the inventory of fixtures of the village lands, 

rights and customs which are linked to them; 

7 Make the forest-farmers committees work 

8 Manage, solve and document the conflict relating to 

the opening of the road serving old villages within the 

UFA. 


suggested 

February 2007 

February 2007 

February 2007 

February 2007 

February 2007 

February 2007 

February 2007 

February 2007 

Demand Number 

1.1 

1.1.3 ; 1.1.4 ; 1.1.5 ; 

1.3.3 

1.6 

1.6 5.5 5.6 

1.6 2.3 

2.1 ; 2.2.1 ; 2.2.2 ; 

3.1.1 ; 3.2 ; 3.3.1 ; 

3.3.2 ; 4.1.5 ; 4.4 ; 

5.2.1.1 ; 5.5.1 

2.2.3 ; 2.3 ; 3.1.2 ; 

3.1.3 ; 3.1.4 ; 3.3.3 ; 

4.1.1 ; 4.1.4 . 4.1.5 ; 

4.3.4 ; 4.4 ; 4.5.2 

2.3 











Version : 2.1 

Nb 


9 Supply the workers with appropriate and wellmaintained 

safety and working equipments and see 

that these equipments are worn and used correctly; 

See to the replacement of the workers’ individual 

protective equipments 

10 Make sure that all the contributors within the TRC 

process wear the appropriate and well-maintained 

safety and working equipments; See that these 

equipments are worn and used correctly. 

11 Find a substitution to the use of SERPAGRUM 

(containing cypermethrin, forbidden in the FSC 

process) 


suggested 

February 2007 

February 2007 

February 2007 

Demand Number 

4.2.4 ; 4.2.5 

4.2.4 ; 4.2.5 

4.2.6 ; 6.6 

12 Update the employees automatic promotion file February 2007 4.3 4.4 

13 define and implement disciplinary measures within 

4.3 4.4 

February 2007 

the company 

14 Set up procedures allowing to treat in a transparent 

4.3.3 

and objective manner the problems presented by the February 2007 

personnel 

15 Carry out an environmental and social impact survey February 2007 5.5.2 ; 6.1 ; 6.5.2 

16 Document the bordering zones constitution schemes February 2007 6.1 

17 The implemented management should aim at a 

sustainable maintaining of logging. 

Comments concerning the major CAR: 

February 2007 

7 ; 5.6.3 ; 6.3 ; 6.4 

CAR nb 1: in compliance with order 222 of the decree regulating forest 

management in Cameroonian law 

CAR nb 2: in particular while seeing to the practical translation of the 

consequences of the laws, decrees - 

CAR nb 3: The ratification and the signature of the procedures by the 

company’s management mostly reinforce and translate the company’s 

commitment expressed in its environmental policy. 

The application of the procedures set up is not always respected. The different 

opinions perceived by the different managers at different levels of the hierarchy 

and in charge of these procedures application seem varied. This results in 

differences in the implementation of these procedures on field. 

CAR nb 4: social, environmental, stand diameter guidelines - 

CAR nb 5: It consists for the company in reviewing its recommendations in 

particular in the document called “TRC- April 2006 certification procedure”. The 

activities or operations implemented on field should be in compliance with the 

recommendations of the company’s certification procedures document. 

We noted in particular during the audit major differences between the on field 

practices, supposed to be in compliance with the procedures. 

For example: solving of conflicts, exploitation inventories, road opening, legal 

monitoring, traceability - It is essential to involve the local executives in the 

protocols review work 











Version : 2.1 

CAR nb 6: It consists for the company in working in a participative manner with 

the riparian communities which should be consulted for the correct and precise 

identification of the village lands, including places of a cultural nature (sacred 

sites, and so on). 

The clear outcome of the exchanges with the populations of the brought 

together communities of Ndocbassaben Gathering was that they had not been 

consulted for their lands identification, which does not come out at all of the 

socioeconomical survey report, which ignored a problem which remains very 

profound and which should have cropped up within the scope of a survey or 

interviews/exchanges with the communities brought together on the UFA 

Western side. 

These communities brought together are in fact citizens of the villages dotted 

along the secondary road (old boundary of the UFA on the Eastern side) and 

that have been pushed and brought together by the administration of the time, 

during the independence unrest (1955-1970) with a view of ensuring a better 

control. 

These communities, although brought together, have carried on for decades to 

make incursions into their villages of origin, concerned by the rites and customs 

demands to which they are strongly connected. The main difficulty for them 

remains in the fact that that secondary road, not maintained since then has 

become nowadays a pedestrian track, but used all the same by these 

populations. 

CAR nb 7: The discussions and interviews conducted during the audit allow to 

say that the forest farmers committees (which should be used as negotiation 

and consultation permanent authority) set up are immature and not functional. 

The step of consultation, of construction of viable and lasting relationship 

between the two parts remains to be done. These committees are hardly 

informed of the company’s certification step itself and of their responsibility or 

their mission in that henceforth set up partnership (information on the 

boundaries, participative management of conflicts, consultation on the rights of 

users, and so on). We noted that preliminary statuses have been allocated to 

them by the company, however the members expect as promised by the 

company’s managers, during the meetings when the committees were set up 

(FFC) that the functioning of the aforementioned committees should be 

explained to them. 

CAR nb 8: The opening or reshaping of a road meets a need in socioeconomic 

development. It allows to improve the free flow of people and goods. The 

communities of the villages brought together (see table below), see in that 

scheme the opportunity which is given to them by the administration to serve 

the long-abandoned villages. 

One of the main reason for the disagreement betwen the company and the 

communities is probably the fact that the secondary road, Western side 

boundary, having become a pedestrian track serving the abandoned villages 

should fit in the road maintenance scheme for the roads of the priority road 

network of the Ministry of Public Works (MINPW) for the year 2005. 

Brought together communities village list: 

Nb Villages Observations 

1 Ndockbassaben Host Village 

2 Ndocbalemak Displaced community 

3 Ndockbakoumeck Displaced community 

4 Ndocbilack II Displaced community 











Version : 2.1 

Nb Villages Observations 

5 Ndockniok Displaced community 

6 Etong Displaced community 

7 Ndocbeck Displaced community 

8 Ndockbassiomi Displaced community 

9 Ndocbekom Displaced community/ village within 

the UFA 

10 Ndockon Displaced community/ village within 

the UFA 

11 Ndockounen Displaced community 

One part of the Mossé Ndokbassaben section (nearly ten kilometres), 

section granted in the public call for tenders and and won by JOE 

CONNER WATER, tenderer and today service provider , has certainly been 

redeveloped by the TRC company to make the UFA timber removal easier. 

Our investigations with the administrative authority state “a road-building ban” of 

the Mossé Ndokbassaben roadworks, section supposed to serve two villages 

located at the far South-West of UFA 00 004. 

Two letters sent by JOE CONNER WATER, service provider, to the ministry of 

public works (MINPW) and to the collective villages headmen located on the 

section make mention of the road-building ban by the TRC company. Hence the 

tensions that exist today between the communities of that zone and the TRC 

company. These communities consider that stopping the Mossé Ndokbassaben 

roadworks, which is “a godsend according to them", frustrate them further more 

due to the difficulties they have been living through for more than four decades. 

CAR nb 9: the procedure plans safety boots, absent on field. The cryptogyl 

sprayer was not subjected to a memorandum concerning the replacement of his 

equipment - 

CAR nb 10: At the Douala processing site level, two categories of participants 

can be distinguished: the company employees themselves, which more or less 

comply with wearing individual protective equipments (IPE) and a second 

category, buyers who remove the sawdusts, very much exposed to health 

hazards due to the nature of their activity and for which they do not have 

adapted individual protective equipments. The pictures taken concerning that 

category of people tell more on the subject. Indeed, the sawdusts removal 

system is not equipped with a cyclone allowing to reduce the pressure at the 

end of the pipes. These sawdusts emerge under pressure in a closed place 

where the salvage is carried out in a sawdust cloud. 

Besides, no safety measure is taken to protect the lives of the people who 

ensure the removal of the sawdust bags out of the company’s fence. These 

people walk under lumber lifts transporting timber waste. 

CAR nb 12: We noted in the course of multiple interviews with the workers that 

some did not benefit from the automatic promotion (three years’ service) 

planned by the regulation. 

Obviously, these workers left out by the system remained penalized without 

being able to receive their due. The reason mentioned by the company is the 

absence of software allowing to manage the workers’ automatic promotions 

after three years’ service. 

CAR nb 13: We listed with the personnel manager, the sites managers and the 

workers' representatives, the questions concerning the TRC company’s 

personnel. What emerges from our different interviews is that the different 











Version : 2.1 

company sites managers should be made aware of the referential content and 

everything it implies at personnel management level (employer/employee 

relationship, dialogue between the employees and the employers, application of 

the guidelines and measures set up by the hierarchy, labour regulations 

respect, scrupulous application of the company’s in-house regulations, and so 

on). The disciplinary measures taken by the sites managers are somewhat 

uncertain (suspensive disciplinary measures, redundancies, and so on) and do 

not always respect the approach prescribed by labour regulations. Nb 67/DG/05 

memorandum delivered to all the managers is not respected by the addressees. 

CAR nb 14: There are consultation authorities (Workers’ representative) and 

they are not functional. The problems posed by the personnel at sites level are 

not properly dealt with, even if the personnel department is represented 

(however not very much listened to by its direct hierarchy). The sites managers 

are not very much made aware of the dialogue that should take place between 

the employer and the workers. The different representatives of the different 

sites (Kumba, Douala and UFA 00 004) have no opportunity to meet in order to 

exchange on the concerns of the workers that they represent and to really 

consult with the company’s hierarchy and to deal in a transparent and objective 

manner with the problems posed by the workers. 

CAR nb 15: No environmental and social impact survey has been carried out by 

the company concerning the exploitation of UFA 00 004 and the timber 

processing on its Douala and Kumba industrial sites. Therefore there is up to 

now no identified impacts or environmental measures implemented by the 

company to reduce or compensate them. That survey should, in particular in its 

social part include the riparian communities’ concerns as far as the rights of 

users are concerned (sociocultural consideration, sacred sites, preservation of 

non ligneous forest products used by the communities, and so on) and plan 

measures allowing to limit the potential impacts, due to forestry. 

CAR nb 16: UFA 00 004 is located next to a forest, Ebo forest which has been 

subjected to the notice to the public nb 0219/AP/MINFOF/SG/DFAP of 3rd May 

2006 containing the public notice of part of that forest. 

As a matter of fact, in that notice to the public, the Government of Cameroon 

suggests to declare public notice one part of Ebo forest, of a 141,706 ha 

surface, with a view to using it as a national park. That forest is riparian to UFA 

00 004 in its Southern part. The nearness of that forest to the UFA, a future 

protected area, involves better consideration of the initiatives which could be 

taken and/or implemented. It should consist in this perspective to document the 

evolutions concerning that forest constitution. The various surveys taking place 

at the moment (fauna survey, shooting surveys and socioeconomic survey), 

carried out by the TRC company within the scope of the UFA 00 004 

management do not bring to light the importance of that zone which should 

probably be rich in wild fauna. It would be wise for the TRC company to exploit 

judiciously Dr ATANGA’s thesis on Ebo forest. 

CAR nb 17: The management scheme does not contain the elements allowing 

to control its durability: it will be fit in particular to review the management 

calculations and to justify the harvesting rates on all the species exploited in a 

significant manner. All the low rates should be interpreted and argued. The 

global renewal rate should be close to 100%. During the management 

implementation, the species inventory diameter should correspond to FSCMD 











Version : 2.1 

9.5 - Proposal of conclusion on whether the candidate entity achieved or 

not the required level of conformance 

Despite the major work carried out since the scoping, numerous fields 

concerned by TRC activity are not enough taken into consideration (social and 

environmental aspects, monitoring -) 

As a consequence, the entity did not reach the level of compliance required. 

Written on 18th June 2006, reviewed on 20th July 2006 

FSC Product Manager, Lead auditor, Report co-author 

Caroline DUHESME Alain VALETTE Erith NGATCHOU 











Version : 2.1 

10 - Complementary audit n°1 

10.1 - Base of evaluation 

10.1.1 - Composition of the audit team 

Lead auditor: 

Auditors: 



traceability and in forest management, forest expert, 

independent consultant. 



traceability, Timber Expert, independent consultant. 


and forestry, EUROCERTIFOR -BVQI Audits 

Managers. 



traceability and in forest management, forest 

engineer, independent consultant. 


aspects, Agricultural engineer, environment and 

social aspects consultant. 

10.1.2 - Used referential 

For the initial and complementary audits, the verification list was referred to (ref. 

SF03 FSC GF Cameroon 1.1 version) from the referential of FSC forest 

management adapted to Cameroon (Ref. RFNT 010012 version 1.0). 

10.2 - Information collecting modalities 

10.2.1 - Description of the audit program 

Audit from 15th to 20th January 2007 

“Social” team scheme 

Day Time Occupations 

Sunday 14th 16.00 Arrival at Douala 

January 

Night in Douala 

Monday 15th 8.30 Opening meeting 

January 

9.00 

11.00 

Complementary documentary review 

Interview with Mister EFFALA and Mister INOUSSA 

Social Manager and Personnel manager 

14.00 Departure for Nkondjock- 

Tuesday 

January 

16th 

Night in Bafang 

9.00 Arrival at Nkondjock (Makakam village) 

Working session with the North farmers-forest committee 











Version : 2.1 

Wednesday 

January 

Thursday 

January 

17th 

18th 

Interview with Nkondjock Mayor or town councillor 

13.00 Departure from Nkondjock for Nyokon 

17.00 Arrival at Nyokon 

Working session with Nyokon’s farmer forest committee 

Night in Ndikinimeki 

7.00 Departure from Ndikinimeki for Ndokbou 

Departure for Ndokbassaben meeting point 

9.00 Arrival at Ndokbou 

Working session with Ndokbou farmer forest committee 

12.00 Departure from Ndokbou 

14.00 Arrival at Ndokbassaben meeting point 

Working session with Ndokbassaben meeting point farmer forest 

committee 

17.00 Departure from Ndokbassaben meeting point 

Night in Bafang 

6.00 Departure from Bafang for Yingui 

12.00 

Arrival at Yingui 

Working session with the South farmer forest committee 

(Ndoktouna and Ndem District) 

Departure for Mossé 

14.30 

15.30 Arrival at Mossé 

Working session with the North farmer forest committee (grouping 

together Iboti, North Ndokmem and Mossé villages) 

Night on the TRC site 

Friday 19th January 7.00 Working session with the TRC forest personnel of UFA 00 004 

Saturday 

January 

20th 

10.00 Departure for Douala 

13.00 Arrival at Douala 

15.00 Working session with the TRC Social manager 


20.00 Meeting between auditors 

7.30 Working session with the TRC Personnel manager 


CARs preparation 

16.00 Reconstruction meeting 


“Forest” team scheme 

Day Time Occupations 

Sunday 14th 16.00 Arrival at Douala 

January 


Monday 15th 8.30 Opening meeting 

January 

9.00 

11.00 

Complementary documentary review 

Interview with Misters HULEUX (TRC) and WANDERS (Form 

International). Corrective action requests resolutions analysis 

14.00 Interview with Misters HULEUX (TRC) and WANDERS (Form 

International). Corrective action requests resolutions analysis 

Tuesday 16th 7.00 Departure for the UFA 

January 

10.00 

12.00 

Wednesday 17th 7.00 Departure for the UFA 

AV: Base camp visit: infirmary, company store 

Zones in progress of exploitation, logging yards, base camp visit 

JPG: riparian villages visit: poaching and hunting investigation 

Return to Douala 











Version : 2.1 

January 

Thursday 

January 

18th 

10.00 

17.00 

Friday 19th January 8.00 

10.00 

Saturday 

January 

20th 

10.2.2 - Documents review 

AV + JPG: Former cutting zones visit CA closing procedure, post 

exploitation monitoring - 

Meeting with the NGO representative in Iboti 

Return to Douala 

8.00 Data compilation, work session between auditors 

10.00 Meeting with Doctor Atanga Ekobo, WWF representative in charge 

of the sector and coordinating the actions on EBO forest. 

15.30 AV: meeting with the provincial representative of the Littoral 

forests, Mr Ebia Ndongo Samuel 

Meeting the TRC personnel (management committee, RDH, 

accountant) 

JPG: meeting with the personnel in charge of the in-house audits. 

AV + JPG: Future TRC factory site visit with Misters REEF, 

HULEUX and WANDERS. 

TRC factory visit in production with Misters HULEUX & 

WANDERS and the sawmill manager 

14.00 AV + JPG + EN: Meeting with the workers’ representatives, 

outside facilities visit (cantine, treatment of sawmill waste -) 

15.00 CD + AV + JPG + EN + CD: 

20.00 Working session between auditors 


CARs preparation 

15.00 Reconstruction meeting 

21.00 

All the documents issued by TRC in response to the recommendations and 

corrective ections requests set during the initial audit was subjected to an 

exhaustive documentary survey: 

Documents produced by TRC in response to the recommendations made by the 

audit team during the initial audit: 

• Memorandum Nb 52/DG/06, indicating to the logging yards managers to put 

the necessary means from 15.30 pm, for the evacuation of the personnel 

who does not work overtime. 

• Explanatory note (Nb 01/SP/DAF/DG/06) on the salaries and accessories 

calculation, has been delivered to all the personnel at the same time as the 

2006 October salaries. 

• 12/09/06 meeting report on the UFA 00 004 yard concerning certain salary 

complaints when an attempt of clarification of the explanatory note (Nb 

01/SP/DAF/DG/06) was made. 

• 20/12/06 meeting report on the UFA 00 004 logging yard, in presence of the 

NKAM Work Representative, the Management director, the logging yard and 

representatives management personnel manager, during which the way of 

calculating overtime was discussed. At the end of that meeting, it was 

unanimously decided to refer to the technical departments of the appropriate 

administration for final opinion. 

• Ministry of Work and National Health Service’s official answer on 29/12/06 

concerning the way of calculating the salaries and overtime. 

• 13/01/07 Minutes of meeting at the UFA 00 004 yard 

• TRC certification procedure concerning medicine quality checking. 











Version : 2.1 

• 17/10/06 request, with the infirmaries managers present on all the TRC 

sites, Dr TEKAM and Dr NZUME so that they commit themselves in writing 

on the the efficiency of their personnel as well as on the quality of the 

medicines at their disposal. 

• Quality charters and lists of medicines used are posted up in all the 

infirmaries. Memorandum (Nb 54/DG/06) presented on 03/11/06, to all the 

administrative managers so that the pieces of information concerning all the 

industrial accidents that occurred during the month reach DOUALA. 

• In-house analyses (September and October 2006) covering all the accidents 

that have occurred since January 2005. 

• Outside analyses by an expert office registered with Labour Law (September 

and October 2006) covering all the accidents that have occurred since 

January 2005. 

• Analysis procedure of industrial accidents 

• Minutes of boundaries surveillance missions and attendance sheets (Forest 

Farmers Committees). 

• TRC certification procedure concerning trees of very big diameters (>66.3 

inches). 

• Damage compensation procedures to the bordering lands under cultivation 

• Minutes of compensation (in June 06 on UFA 00 004). 

• The sites managers’ retraining and bringing up to standard meeting with 

regard to the in-house regulations took place in DOUALA on 16/10/06. At this 

meeting were gathered all the sites Managers with their production 

managers and employees in charge of the personnel as well as the 

Management and the personnel department. 

• TRC certification procedure at chapter 8.6 concerning the holding of the 

managers’ bringing up to standard yearly meeting (Distribution of a manual 

containing, the in-house regulations, the Disciplinary measures Scale table 

as well as the memoranda concerning mainly discipline). 

• Certification procedure relating to personnel management, and in particular 

to recruiting 

• Memorandum (Nb 59/DG/06) presented on 17/11/06, to all the sites 

managers and to all the personnel departments, concerning the compulsory 

existence of a work contract before any start of job activities. 

• 18/08/06 letter sent to all the sites requesting the timetable of the 

representatives’ meetings and the hygien and safety committees as well as 

copies of their reports of activity and in which there is a reminder of the 15 h 

per month legal franchise which enables the representatives to meet. 

• GM’s letter inviting all the workers’ representatives to a meeting gathering 

them all in DOUALA on 02/01/07. 

• Minutes written at the end of that meeting. 

In response to the minor corrective actions requests made by the audit team 

during the initial audit: 

• A request was addressed on 03/10/06 to the Minister of Forest and Fauna 

concerning the constitution of UFA 00 004. 

• TRC certification procedure (7.1) concerning the management scheme 

methods of modification (every 5 years). 

• TRC certification procedure (8.8) concerning the employees’ training 

scheme. 











Version : 2.1 

• TRC certification procedure (8.1) concerning the personnel management in 

which it is said that "for the recruitment of forest personnel, priority should be 

given to the riparians of each UFA”. 

• Data base of the available workforce in the riparian villages with the help of 

pieces of information gathered with the FFC. 

• Memorandum (Nb 56/DG/06) addressed on 15/11/06 to the UFA 00 004 

managers to remind them of the measures concerning priority recruitment of 

the riparians. 

• “Workforce request to the FFC" form. 

• Report of the opening meeting of the TRC committee fighting against HIV 

AIDS, on 21/12/06. 

• Memorandum (Nb 26/DG/06) addressed on 03/07/06 to the workshop 

managers indicating the need to regularly carry out inspections of the 

retention tanks. 

• Addendum to the 31/08/06 memorandum, instituting the obligation to fill in 

and to put up tanks inspection and cleaning sheets, in order to confirm the 

checking passages. 

• TRC certification procedures concerning household and medical waste. 

• Letters to the doctors in charge of the infirmaries whereby they are asked to 

see to the destruction of all the medical waste. 

• Memorandum (21/10/06 Nb 53/DG/06) to all the sites managers listing the 

different procedures of waste management. 

• Workers’ representatives training seminar report in presence of the local 

work representatives (KUMBA on 15/09/06, UFA 00 004 on 01/11/06 in 

IBOTI, UFA 00 001/002 on 03/11/06 in MAKOT) 

• Timetable of the workers’ representatives’ meetings until december 2006 on 

the different sites. 

• UFA 00 004 FSC return calculation 

• TRC certification procedures, of chapter (7.5.1) concerning the elements to 

be controlled during post-exploitation operations. 

• Memorandum (06/10/06 Nb 43/DG/06) which specifies to forestry managers 

the actions to be taken during post-exploitation operations. 

• Reports of the UFA 00 004 post-exploitation operations carried out on 

15/12/06 

• Mail to NKAM and MBAM's Prefects, asking them to inform TRC about the 

nearby UFA 00 004 schemes located in these two counties. 

• 10/31/06 WWF Yaoundé mail about a scheme concerning the setting up of a 

buffer zone between the UFA and EBO park. 

• WWF’s answer 

• Available protection zones choice justification and argumentation. 

• Memorandum (19/10/06 Nb 48/DG/06) addressed to the UFA 00 004 

exploitation managers reminding of the respect of the “standards of 

intervention in forests” measures which concern the lake banks protection. 

• Riparian communities micro schemes identification within the scope of FFC 

rounds (from 11/11/06 to 19/12/06). 

• Documents testifying to the creation of a Dutch foundation by the TRC 

managers, financed by the UFA 00 004 activities with the aim of assisting the 

realization of social schemes in the villages riparian to the UFA. 

• Memorandum (18/12/06 Nb 75/DG/CAR/06) addressed to all the sites 

managers, informing them about the in-house audits manager’s appointment 

and the aim of his mission. 











Version : 2.1 

• Report of UFA 00.004 in-house audit carried out from 20 to 24/12/06. 

• Report of DOUALA’s sawmill in-house audit carried out on 29/12/06. 

• Change in TRC certification procedures, of chapter (7.7) concerning the 

“Yield potential monitoring protocol”. 

• Report concerning the setting up and inventory of 6 permanent sample plots 

is available. 

• Certification procedure (7.7.5) 

• Mail exchanges with Mister Robert NASI from CIRAD about a possible 

collaboration. 

• Certification procedures 7.2 modified and developed to bring to light the 

HVFC characteristics specific to the UFA and the actions undertaken to 

protect them. 

In response to the major corrective actions requests made by the audit team 

during the initial audit: 

• TRC certification procedures, chapters concerning the development of yearly 

exploitation schemes (7.1.2) and yearly intervention reports (7.1.3) 

• UFA 00 004 2005 yearly exploitation report and 2006 yearly operations 

scheme 

• Memorandum (11/07/06 Nb 28/DG/06), changing the memoranda (10/01/05 

03/DG/CAR/05 and 10/01/05 012/DG/CAR/05) which concerns the 

appointment of the employees in charge of the legal and regulation 

monitoring and which describes the procedure more precisely. 

• Addendum into the TRC certification procedures, paragraph 6.2 about a legal 

advisor’s support to guarantee the assessment of the new texts 

consequences (10/07/06 Amendment to the contract of legal, judicial and 

administrative assistance with the NYEMB OFFICE, concerning the legal 

monitoring). 

• Summary of TRC Certification Procedures 

• Traceability procedures 

• Personnel management procedures within the certification procedures. 

• Report of Engineer TEICHEUGANG, “Contribution to the UFA 00 004 

management: Surveys of the High Value sites for Conservation”, concerning 

among others the identification of former villages are available. 

• Mission from 13 to 20/12/06: Marking of the sacred sites in the former 

villages towards IBOTI and in the cai (current annual increment) 1-3 (2007). 

• Timetable and attendance sheets of the meetings held with the FFC (from 

June to December 2006). 

• Various correspondances testifying to the FFCs existence and functioning 

• Meetings schedule with the FFC for 2007 

• Report of the working session held on 27th March 2006 in YABASSI at 

NKAM’s Civil Engineering Subdivision about the building of the MOSSE- 

NDOGBASSABEN road. 

• Minutes of the 30/09/06 meeting in NDIKINIMEKI with NDOGBASSABEN's 

FFC about the layout of MOSSE-NDOGBASSABEN road and TRC's 

position. 

• UFA 00.004 contentious road opening awareness mission Report Scheme 

by MINFOF. 

• DAT: Financial assessment of Yingui-Ndikinimeki road (1987). 

• Updating in the certification procedures of chapter 8.1.2 concerning safety 

equipments. 











Version : 2.1 

• Memorandum (20/06/06 Nb 24/DG/06) addressed to the sawmill managers 

concerning the Phyto sprayer’s safety equipment. 

• Memorandum (20/11/06 Nb 61/DG/06) addressed to the sites Managers, 

fixing the safety equipments replacement schedule in our yards. 

• Minutes of the meetings concerning among others the safety equipments, on 

6 and 8/7/06 in DOUALA, on 12/7/06 in MAKOT, on 14/7/06 in BAKOGO, on 

15/7/06 in KUMBA. 

• 06/7/06 letter addressed to the subcontractors asking them to equip their 

personnel in safety equipment. 

• Memorandum (20/07/06 Nb 33/DAF/06) addressed to the workshop and 

sawmill managers, concerning the supply of safety equipments to all our 

subcontractors’ employees. 

• Memorandum (25/7/06 Nb 35/DG/06) addressed to all the sites managers 

concerning the prohibition of access to the TRC facilities for the 

subcontractors’ employees without safety equipments. 

• Memorandum (25/7/06 Nb 37/DG/06), concerning the practical methods of 

distribution of working clothes to our hauliers’ personnel. 

• Information note of 22/11/06, addressed to the sawdusts removers 

concerning the replacement of their safety equipments. 

• 23/11/06 letter addressed to the hauliers intervening on forest yards to ask 

them to supply the drivers and their assitants with safety helmets;Research 

of a treatment product containing no cypermethrin, approved in Cameroon. 

• 11/10/06 dated dispensation request, for cypermethrin use for Cameroon 

addressed to EUROCERTIFOR BVQI signed by the GMs of the PALLISCO, 

WIJMA and TRC forestry companies 

• Replacement of the SEPARGRUM product on all the sites by the only 

product for long poles treatment approved in Cameroon containing no 

cypermethrin, DC6++. 

• Memorandum (05/01/07 Nb 02/DG/CAR/07) addressed to all the site 

managers concerning the replacement of SARPAGRUM by the DC6++ with 

the technical data sheets. 

• Memorandum (13/7/06 Nb 30/DG/06) addressed to the personnel manager, 

concerning the setting up of a function in the personnel Excel data base 

which permanently informs of the number of employees whose promotion is 

due. 

• Intervention report of the PROLOGIQ company in the setting up of the pay 

software concerning the automatic promotion (Invoice 008/1006 on 

17/10/06). 

• Memorandum (13/07/06 Nb 31/DG/06) addressed to all the site managers, 

all the section heads, all the personnel managers and the workers’ 

representatives, concerning the administration of disciplinary measures 

according to precise faults defined in an enclosed table. 

• Memorandum (06/11/06 Nb 55bis/SP/DAF/DG/06) addressed to all the site 

managers and to the administrative officers, concerning putting registers of 

grievances at the workers' disposal on all the sites. 

• Copy of registers of grievances signed by the General Management. 

• Copies of requests and answers of the personnel department. 

• Environmental Impact Survey of the UFA 00 004 exploitation. 

• Environmental management scheme (EMS) from 13/12/06 to 22/12/06. 

• Memorandum (08/12/06 Nb 70/DG/CAR/06) addressed to Inoussa 

DJUMBOKET, in charge of the socioeconomic questions concerning the 











Version : 2.1 

actions to be taken with the riparian populations in relation to the measures 

which concerns them in the EMS. 

• Memorandum (14/12/06 Nb 73/DG/CAR/06) changing the memorandum 

(14/03/06 Nb 12/SP/DAF/06) concerning the evolution of certain functioning 

methods of the UFA 00 004 yard staff store, to meet the resolution of 

measures concerning the staff store written down in the EMS. 

• Change in the UFA 00 004 staff store regulation. 

• On 22/12/07, letter to all the hauliers on TRC environmental policy 

containing, measures to be implemented, an extract of the UFA 00.004 EMS 

summary in relation with their activity and a commitment model. 

• Memorandum (02/01/07 Nb 01/DG/CAR/07) appointing the engineer of UFA 

00 004, Arnaud TCHOKOMENI, in charge of the yard environment. 

• Letter (11/01/07 nb 00042/L/MINEP/IG/l1) of the Minister of environment 

acknowledging receipt of the survey 

• On 16/6/06, email to Dr EKOBO ATANGA about EBO park creation and the 

big apes protection zone scheme incorporating UFA 00.004 

• mail to WWF YAOUNDE on 17/10/06 about the WWF/TRC collaboration 

following EBO park setting up. 

• Minutes of 26/10/06 meeting at the MINFOF Provincial delegation in 

DOUALA, with the WWF about poaching in UFA 00.004 and attendance 

sheet. 

• Report of the mission carried out in UFA 00 004 by an employee of the 

Littoral provincial delegation, a WWF employee and the yard engineer in 

order to collect pieces of information concerning poaching. 

• Report of the anti-poaching mission carried out in UFA 00 004 by a 

DOUALA’s MINFOF provincial delegation team, financed by TRC. 

• Increase of the felling minimum diameters for BONGOSSI, “OKAN” and 

“TALI”, Tieme WANDERS’ argumentation. 

• Memorandum (10/10/06 Nb 45/DSAC/06) addressed to the UFA 00.004 

exploitation managers, to cutters, prospectors and clerks, concerning the 

felling diameter and the list of protected trees. 

10.2.3 - Intervention scope 

That complementary audit took place within the scope of corrective actions 

checking set by the TRC company following the initial audit dating from 16 June 

2006. In accordance with uses, the work concentrated itself on the CAR 

resolution in progress, without limitation in the case of new nonconformities 

apparition or aspects not treated previously.and which could have been 

subjected to nonconformities. 

10.2.4 - Interview(s) of involved people met 

- Owner 

Mr EBIA NDONGO Samuel, Provincial Minister of State of the Ministry of 

Forestry and Fauna, representative of the Cameroonian State, permanent forest 

estate owner to which is included the UFA as issue, received us, and expressed 

his support to the TRC step. He also underlined the good quality of the 

relationship between TRC and the Forest Administration, on a local as well as 

on a central level. 

- Manager(s) 











Version : 2.1 


particular the following people within the management: 




- Mister Jacques HULEUX, Management committee manager 

- Mister Tieme WANDERS, FORM INTERNATIONAL 

- Mr Eric SPRANGERS, TRC Finance and accounting manager 

- Mr Gilbert OKON II, Human Resources Manager 

- Mister William WAINFOIN LAWYER, TRC in-house audits manager 

- Arnaud TCHOKOMENI, UFA 0004 yard engineer 

- Employee(s) 

On field, one consulted and interviewed the following people: 

- Mr Manuel, exploitation manager 

- Mr Paul BANG, yard scaler, workers’ representative 

- Mr BOUBAKARY Amadou, Head of UFA 00004 forest yard security guard 

post 

- Mr MESSE André Samson, Scaler, Workers’ representative 

- Mr MBIE Bienvenue, Cutter, Workers’ representative 

- Mr ELLA MVONDO, Scaler, Workers’ representative 

- Mr PIETA Louis Marie, Driver, Workers’ representative 

- Mr BANG Paul, Scaler, Workers’ representative 

- Mr NGUETCHUISSI Erith, Driver, 

- Mr Marcel ATEBA, TRC social mediator 

- Mr BITEGA BITEGA Antoine, staff store manager 

- Mr KAMWA David, UFA 0004 base nurse. 

- Mr TCHOUPO Serge, sawmill salaried employee, workers’ representative, 

as well as 6 other workers’ representatives in forest and in sawmill. 

- Moreover, numerous salaried employees were questionned on different 

points relating to their work conditions (cases of sawmill salaried employees 

and salaried employees in charge of treating timber with Cryptogyl). 

- Subcontractor(s) 

No subcontractor intervening on field (except the hauliers, who cannot, at first 

sight, have an impact on the certification procedures), no subcontractor 

representative’s interview was carried out. 

10.2.5 - On-site visit(s) 

The UFA 00 004 site was considered from different points by the audit team 

members: 

- Visit of the surrounding villages included in the UFA, meetings with the 

Farmers Forest Committees (FFC) by the auditor specifically in charge of 

that point. 

- Visit of the riparian villages particularly active in poaching 

- Visit of the cutting area in progress (survey on the working conditions) 

- Visit of Ndockagnak base camp (welcome and transport conditions, staff 

store, infirmary) 











Version : 2.1 

- Visit of the former cutting area, 

- Visit of the sawmill and the site planned for the setting up of the future 

sawmill. 

The in-house audit documents, which had allowed to list numerous 

nonconformity points as well as the reports of the different actions implemented 

by the company served as guiding information to the site visits. 

10.2.6 - Stakeholders identification and consultation 

As this is a complementary audit, the certification procedure does not plan any 

stakeholders’ plenary meeting comparable to the one which is carried out during 

the initial audit opening. Nevertheless, in order to validate the TRC actions and 

procedures inventory of fixtures, it was essential to carry out a series of 

meetings and interviews of numerous stakeholders. The following stakeholders’ 

representatives were met: 

Riparian populations and Farmers Forest Committees: 

- Nyokon’s FFC: 

Mr KIARI Jules, Chairman 

Mr BITCHA Johnny 

Mr BELOMBO Bruno 

Mr MBIRWANG Thomas 

Mr ABWA Eliba 

Mr BITEP KIARI Bertrand 

Mrs AMBANG Esther 

- North Nkondjock FFC 

Miss NDJATCHOU Sylvie 

Mr TCHOFA William, Chairman 

- South Nkondjock FFC 

Mr BOTHIA Emmanuel, Technical unit director 

- Ndocbou FFC 

Mr MAMBONG Jean, Chairman 

Mr YEMBE MBING Christophe, Ndokbou I Village Headman 

Mr BELOMBE Joseph 

Mr NDENGUE Albert 

Mr YETENA André Joseph 

- Ndocbassaben FFC 

Mr NGUILE Chairman 

Mr MOKUNDEZ Zacharie 

Mr MILOUMI Mathieu 

Mr IHONGOLOK NEWTON Isaac 

Mr BOUNDON BOUKILI Jean Calvin 

Mrs ONGMAKAGNE Régine 

Conservation NGO: 

- Doctor ATANGA EKOBO, WWF representative in charge of the sector and 

coordinating the actions on EBO forest. 

It was not possible to meet the CRES representative who works on EBO forest 

site in association with the WCS during the audit. 

Forest administration representatives: 

- Mr EBIA NDONG Samuel, Provincial Minister of State for the Ministry of 

Forestry and Fauna 











Version : 2.1 

Territorial Administration 

- Mr NJIKAM Aboubacar, Prefect of Nkam County 

- Mister the Sub-prefect of Yingui 

10.2.7 - Identification, traceability and monitoring of products 

The long poles traceability on field had been ratified during the initial audit. The 

company had been asked to write an improved procedure in full accord with 

field reality. That procedure was written and its validity checked by the audit 

team. No complementary control has been judged necessary. The squareedged 

traceability was subjected to an adapted procedure. 

However, corrective actions requests are expressed concerning the procedures 

relating to the STD-40-004 and STD-40-005 referentials respects. All these 

CAR will be subjected to checking during the next complementary audit which 

will be expressed in a specific report. 

10.2.8 - Initial audit closing meeting 

The reconstruction meeting took place on the TRC company premises, in 

presence of the following people: 






- Mr Eric SPRANGERS, TRC Administrative and finance manager 

- Mr Gilbert OKON II Personnel manager 

And the audit team 

As observer for TRC: 

- Mr Elie HAKIZUMWAMI, in Charge of forest for WWF Central Africa 

10.3 - Audit team observations 

10.3.1 - Action realised in response to the Correctives Actions Requests 

• Minor CAR 

CAR 

Nb 

Actions taken by the certified organization 

18 On 03/10/06, a request was addressed to the 

Minister of Forest and Fauna concerning the 

constitution of UFA 00 004. 

19 Addendum in the TRC certification procedure of a 

chapter (7.1) concerning the management scheme 

methods of modification (every 5 years). 

Audit team’s 

conclusions if these 

actions allow full 

conformity 

That 

request 

corresponded to a lack of 

documents, which has 

been completed. 

The CAR has been 

removed 

Audit team’s conclusions if the 

response is unsatisfactory and 

CAR status (in suspense or 

major) 

That Request cannot be lifted 

because the UFA definite constitution 

did not take place. Its resolution is 

linked to the Ministry action, and the 

company cannot be held responsible 

for the maintenance of that request. 

The CAR is therefore maintained as 

minor. 











Version : 2.1 

CAR 

Nb 


20 Addendum in the TRC certification procedure, of a 

chapter (8.8) concerning the employees’ training 

scheme. 

Addendum in the TRC certification procedure, of a 

chapter (8.1) concerning the personnel 

management in which it is said that "for the 

recruitment of forest personnel, priority should be 

given to the riparians of each UFA”. 

Creation in DOUALA of a data base of the 

available workfoce in the riparian villages with the 

help of pieces of information gathered with the 

FFC. 

A memorandum (Nb 56/DG/06) was addressed on 

15/11/06 to the UFA 00 004 managers to remind 

them of the measures concerning the riparians’ 

priority recruitment. 

Sending to the UFA 00 004 yard a “request of 

labours to the FFC” form. 

An awareness of the riparian communities through 

the FFC was carried out on the priority recruitment 

of young riparians. At the time of the 

complementary audit, we noted that further to that 

awareness, a first wave of young people had been 

recruited and put under contract at various posts 

within the company. Moreover, we also noted the 

withdrawal of certain local recruits who reckoned 

that the working conditions were difficult. 

21 Creation of a TRC committee of fight against HIV 

AIDS, on 30/11/06. 

Official setting up of the committee on 21/12/06. 

22 A memorandum (Nb 26/DG/06) was addressed on 

03/07/06 to the workshop managers indicating the 

need to regularly carry out inspections of the 

retention tanks. 

On 31/08/06, an addendum to the memorandum, 

institutes the obligation to fill in and to put up tanks 

inspection and cleaning sheets, in order to confirm 

the checking passages. 




conformity 

That CAR is removed. 

Nevertheless a training 

scheme remains to be 

set up in relation with the 

monitoring operations 

conclusions (in-house 

audit, industrial accidents 

analyses, and so on) 

That request is removed 

because the Committee 

has been created. 

However, it did not take 

any action and is not 

physically present on 

field (ignorance at the 

infirmaries and workers’ 

levels, no public 

awareness actions and 

test yet, and so on), 

hence a new nb 44 minor 

CAR 

An improvement has 

been noted on field and 

in the procedures. The 

CAR is therefore 

removed. 




major) 











Version : 2.1 

CAR 

Nb 


23 Change in the TRC certification procedures of the 

chapter concerning household and medical waste. 

Letters to the doctors in charge of the infirmaries 

whereby they are asked to see to the destruction 

of all the medical waste. 

Memorandum (21/10/06 Nb 53/DG/06) to all the 

sites managers listing the different procedures of 

waste management. 

24 Workers’ representatives’ training seminar 

organization in presence of the local work 

representatives (KUMBA on 15/09/06, UFA 00 

004 on 01/11/06 in IBOTI, UFA 00 001/002 on 

03/11/06 in MAKOT) 

Timetable of the workers’ representatives’ 

meetings until december 2006 on the different 

sites. 

We have checked with the workers’ 

representatives that the meetings all take place 

according to the timetable agreed between the 

parties. 




conformity 

The contracts survey, 

letters and memoranda, 

as well as the on field 

data validation testify to a 

satisfactory level. The 


removed. 

The consultation 

authorities functioning 

was checked on forestry 

site and sawmill. 

The CAR is therefore 

removed. 

25 There is a UFA 00 004 FSC return calculation A document has been 

drawn up, it corresponds 

to the FSC expectations 

in that field. 

26 Change in the TRC certification procedures, of 

chapter (7.5.1) concerning the elements to be 

controlled during the post-exploitation operations. 

Memorandum (06/10/06 Nb 43/DG/06) which 

specifies to forestry managers the actions to be 

taken during post-exploitation operations. 

Reports of the UFA 00 004 post-exploitation 

operations carried out on 15/12/06 

27 On 01/11/06, mail sent to NKAM and MBAM's 

Prefects, asking them to inform us about the 

schemes near UFA 00 004 located in these two 

counties. 

On 31/10/06, mail sent to WWF Yaoundé about a 

scheme concerning the setting up of a buffer zone 

between the UFA and EBO park. 

WWF’s answer 


removed. 

The post-exploitation 

operations were checked 

by a survey on field (visit 

of site for confirmation of 

noted elements and 

achievement of 

prescribed works. 


removed. 

However, the company 

must be vigilant for the 

control of its exploitation 

operations (see FAO 

Code) 




major) 

The step is not sufficient with regard 

to the site sensitivity. 

The CAR becomes therefore major. 

It will be fit among other things to: 

- Start an ecological monitoring in 

collaboration with the NGO linked to 

Ebo reserve. 

- Start in the surveillance (support 

the ecoguards’ intervention around 

the UFA in collaboration with the 

concerned NGOs). 

- Continue the search of documents 

and the contacts relating to Ebo 

reserve creation. 











Version : 2.1 

CAR 

Nb 


28 Available protection zones choice justification and 

argumentation 

29 Memorandum (19/10/06 Nb 48/DG/06) addressed 

to the UFA 00 004 exploitation managers 

reminding of the respect of the “standards of 

intervention in forests” steps which concern the 

lake banks protection. 

30 The TRC company continued reinforcement 

actions of the communities’ capacities through the 

FFC (riparian communities’ micro-schemes 

identification within the scope of the FFC rounds 

from 11/11/06 to 19/12/06). 

the TRC company is planning the creation of a 

Dutch foundation by the TRC managers too, 

financed by the UFA 00 004 activities with the aim 

of assisting the realization of social schemes in 

the villages riparian to the UFA. 

Alongside these training and awareness actions 

limited to the FFC members, the traditional 

activities like commercial hunting continue 

because there is no real alternative up to now. 

“Hunting continues without any distinction on 

species, the main thing is to bring something to 

sell and have a little income", says a villager of 

Ndockbou. 




conformity 

That action request is 

removed as it was, 

however its requirements 

level is going to be taken 

up again in the CAR 

relating to HVFC (CAR 

nb34) which is 

maintained. 

The request is 

satisfactory at the 

documentary level, its 

application has been 

noted on field. The 

prohibition on the 

exploitation of Baya trees 

which grow preferentially 

in that type of site 

reduces strongly the risk 

of exploitation in the 

humid zones 


removed. 

However, the company is 

highly recommended to 

make sure of the total 

respect of the document 

“intervention standards in 

forest” (see CAR 2 

recommmendation) 

That action request is 

removed as it was, 

however its requirements 

level will be taken up 

again in the CAR relating 

to HVFC (CAR nb 34) 

which is maintained. The 

complete implementation 

of the adopted schemes 

remains to be done to 

really reach the aimed 

goal, that is to say the 

reduction of pressure on 

the wild fauna. 




major) 

- Establish an ecological monitoring 

on site - genetic flux monitoring - 

The presence or absence of gorillas 

is not clear. The ecological 

monitoring is all the more justified 

as the populations migrate. 

(ecological corridor between Ebo 

and UFA.) 











Version : 2.1 

CAR 

Nb 


Moreover, we noted a lack of communication in 

the riparian villages on the different classes 

protected species. The hunters’ stays in the forest 

are organized and supply an evacuation circuit of 

the products towards the principal markets that 

are Makénéné, Douala and Yaoundé. 

31 Memorandum (18/12/06 Nb 75/DG/CAR/06) 

addressed to all the sites managers, informing 

them about an in-house audits manager’s 

appointment and the aim of his mission. 

UFA 00.004 in-house audit report carried out from 

20 to 24/12/06. 

DOUALA’s sawmill in-house audit report carried 

out on 29/12/06. 

Audit report transmission to the UFA 00 004 yard, 

for the implementation of the requested corrective 

actions. 

Audit report transmission to Douala's sawmill 

manager and to the personnel manager, for the 

implementation of the requested corrective 

actions. 

32 Change in TRC certification procedures, of 

chapter (7.7) concerning the “Yield potential 

monitoring protocol”. 

The report concerning the setting up and inventory 

of 6 permanent sample plots is available. 

33 Addendum in the certification procedures of a 

chapter (7.7.5) 

Mister Robert NASI from CIRAD has been 

contacted about a possible collaboration. 

34 Chapter 7.2 of the certification procedures 7.2 was 

modified and developed to bring to light the HVFC 

characteristics specific to the UFA and the actions 

undertaken to protect them are listed in it. 




conformity 

The quality of the inhouse 

audits is good and 

their conclusions have 

been ratified. The 

personnel in charge is 

efficient, the in-house 

audit protocols taking 

their conclusions into 

consideration are 

satisfactory. 


removed. 

One can also add the AW 

(Accident at Work) 

analyses the in-house 

audits - and other 

elements which 

constitute the long-term 

monitoring scheme. 


removed. 

However, it is highly 

recommended to 

introduce in the 

monitoring scheme all the 

activities, and to plan the 

results analysis (short-, 

medium-, long-term 

action). 

That corrective action 

request is removed, 

however it is partially 

taken back in the 

corrective action request 

nb 37 which will allow 

taking over the surveys 

and actions conclusions 

by TRC via the reinforced 

management committee. 




major) 

The step is not sufficient with regard 

to the requirements. 

The CAR becomes therefore major. 

It will consist among other things in: 

- Identifying and characterizing the 

zones according to more extensive 











Version : 2.1 

CAR 

Nb 





conformity 




major) 

criteria (altitude, slope, proximity of 

watercourses, proximity of 

protected area - Ebo’s Park). 

Identification of the conservation 

attributes in consultation with all the 

stakeholders. (NTFP, and so on). 

- Training the prospectors for the 

recognition of protected species. 

- Largely consulting (national, 

international organizations, and so 

on) on the choices made to ratify 

the choices of attributes, and the 

measures taken to protect them. 

- Documenting and giving arguments 

to the management options 

different phases of definition, 

produce proof (Evidences) of each 

element brought. 

- Going into details with the NTFP 

survey (identification, location, 

resource and market surveys) and 

draw from it a forestry and/or a 

picking development strategy. 

CAR 

Nb 

• Major CAR 


1 Addendum in the TRC certification procedures, of chapters 

concerning the development of yearly exploitation schemes (7.1.2) 

and yearly intervention reports (7.1.3) 

On 11/10/06, transmission to the Administration of the 2005 yearly 

exploitation report and the UFA 00 004 2006 yearly operations 

scheme 

2 Memorandum (11/07/06 Nb 28/DG/06), changing the memoranda 

(10/01/05 03/DG/CAR/05 and 10/01/05 012/DG/CAR/05) which 

concerns the appointment of the employees in charge of the legal 

and regulation monitoring and which describes the procedure 

more precisely. 

Addendum in the TRC certification procedures of a legal adviser’s 

support to guarantee the assessment of the new texts 

consequences. 

On 10/07/06, signature of an amendment to the legal aid and 

administrative assistance contract with the NYEMB OFFICE 

concerning the legal monitoring. 

We will all the same point out that, although the company 

developed and implemented a legal monitoring system (see 

above), the audit team noticed the absence of updating of the 

compensation scale according to the nb 2003/418 PM Decree of 

25th February 2003 concerning the compensation rates to grant to 

owners victims of destruction of land cultivation and cultivated 

trees and the absence of the Nb 039/MTPS/IMT order of 26th 


conclusions if 

these actions 

allow full 

conformity 

That request 

corresponded to a 

lack of documents, 

which has been 

completed. 


removed 

The procedures are 

adapted. Since the 

initial audit there has 

been no law or 

decree having a 

direct impact on the 

company’s life, and 

the efficiency of the 

procedure could not 

therefore be tested up 

to the end. 


removed. 

The company must 

be reminded to be 

constantly vigilant on 

the control of that 

monitoring. 


conclusions if the 

response is 

unsatisfactory and 

CAR status (in 

suspense or major) 











Version : 2.1 

CAR 

Nb 


November 1984 setting hygiene and safety measures in the 

workplaces. 

3 All the procedures and memoranda concerning sustainable 

management are systematically signed by the General Manager 

4 Writing of a “TRC Certification procedures Summary” and 

distribution at all the FFC meetings. 

Publication of the “certification procedures summary” on the 

website (www.trcbois.com). 

After checking carried out on field, the audit team noted that the 

management scheme public summary set at the FFC disposal is 

not signed and does not contain the guidelines linked to the FSC. 

5 Certification procedures rereading and harmonization with yard 

engineer Arnaud TCHOKOMENI, Tieme WANDERS and Jacques 

HULEUX. 

Development of traceability procedures by UFA 00 004 yard 

engineer, Arnaud TCHOKOMENI. 

Development by the human resources manager, Gilbert OKON of 

the personnel management procedures and addendum in the 

certification procedures. 

6 The report of Engineer TEICHEUGANG, “Contribution to the UFA 

00 004 management: Surveys of the “High Value sites for 



these actions 

allow full 

conformity 

A survey remains to 

be carried out on the 

intervention standard 

in forest environment 

which is a legal 

document, and all the 

measures remain to 

be taken to testify that 

the realistic points 

have been put into 

practice, and to the 

non-applicability of 

the other points (that 

last point has a 

recommendation 

value) 

That request 

corresponded to a 

lack of documents, 

which has been 

completed. 


removed 

That work was carried 

out satisfactorily. The 

procedures are more 

legible and the 

unpredictable controls 

carried out confirm 

that they are in 

compliance with the 

field practices. 

That CAR is therefore 

removed. 

The document in 

question correctly 



response is 




A confusion remains 

between 

the 

management scheme 

public summary which is 

the summary of the 

administrative document, 

and the certification 

procedures which are the 

TRC practices. To avoid 

that confusion, TRC will 

publish a public summary 

document which will take 

up the MS (Management 

Scheme) general data as 

it is applied on field (with 

the FSC guidelines). That 

document will invalidate 

and replace the former 

already distributed. 


maintained 











Version : 2.1 

CAR 

Nb 

7.the 


Conservation”, concerning among others the identification of 

former villages are available. 

Appointment of a “Social Mediator”, linked to the UFA 00 004 

which depends on the management committee. 

Mission from 13 to 20/12/06: Marking of the sacred sites in the 

former villages towards IBOTI and in the CAI (current annual 

increment) 1-3 (2007). 

The TRC company started a participative and concerted 

identification work with the communities riparian to UFA 00 004 of 

their lands (sacred sites and other sites with a cultural character, 

agricultural plots, and so on). That work was conducted under two 

angles that is to say: 

- (1) a survey entitled “Contribution to the UFA 00 004 

management: Surveys of sites with High Value for the 

Conservation” in which the identification of old villages 

particularly on the UFA Eastern side was carried out 

- (2) an identification and marking mission of the sacred sites. 

The interviews held with the populations during the 

complementary audit allowed to check the elements presented in 

the reports. The communities vouch for having indeed participated 

to the identification/marking of their cultural sites located in or next 

to the UFA bounderies. The TRC company also carried out 

training sessions of the different FFC members for Global 

Positioning System use. 

At the time of the initial audit (June 2006), the UFA 00 004 farmers 

forest committees had been implemented and had not been 

functional. The TRC company started to train these FFC members 

for daily management (elaboration of meeting reports, documents 

filing, and so on) and to ease their setting up by the local and 

administrative authorities. It consisted therefore in legitimizing the 

existence of these associations having to ensure from now on the 

interface between the forestry company and the communities 

riparian to the UFA. 

At each training and FFC setting up session, a report on the UFA 

management scheme was presented to the participants. The 

setting up minutes were consulted during the complementary 

audit. Then, activities concerted planning meetings were 

organised with the different FFC and a training for the identification 

of micro schemes that could be carried out by the micro schemes 

were done. It must be noted that at the time of the complementary 

audit, the FFC capacities reinforcement schedule was not yet 

finished. 

The reports consulting and particularly the interviews held with the 

stakeholders (local administrations, concerned communities, and 

so on) allowed us to check the effectiveness of the steps taken 

within the period of time separating the two audits (June 2006 - 

January 2007). These actions particularly aroused a fad within the 

bright communities who actually devoted their energies to work in 

that way with the company in order to respect the principles linked 

to sustainable management (fight against poaching and alternate 

strategies development through promoting activities which 

generate an income, and so on). 

We examined the exchanges of mail between FFC/communities 

and their villages concerning the real management of the yearly 

forest royalties, the exchanges of mail between the FFC and the 

TRC company concerning the means allocated to the fight against 

poaching still increasing fast on certain sides of the UFA – 



these actions 

allow full 

conformity 

defines the sacred 

sites and village lands 

on the basis of 

participative maps. 

The definition of the 

sacred sites on the 

zone is therefore 

finished. 


removed. 

The meeting 

conducted by the 

auditor allowed to 

conclude that the 

Farmers-Forest 

Committees are 

effective and living 

instances. 


removed. 

Considering the work 

started by the 

company to meet that 

request, the audit 

team estimated that 

efforts remain to be 

made concerning 

particularly the clear 

and concerted 

definition with the 

FFC of the future 

steps to be taken (in 

time and space), so 

as to urge the 

different parties to the 

monitoring and 

respect of the 

commitments made 

(see minor CAR 43). 



response is 














Version : 2.1 

CAR 

Nb 


Ndocbou, Ndocbassaben, Nkondjock, and so on). The interviews 

carried out by the audit team allowed to reveal an absence of 

social cohesion even within certain formed communities, which 

should constitute a handicap for the success of community 

schemes planned by the TRC company. 

Moreover, the capacity reinforcement actions started by the 

company really saw only the participation of FFC members, who 

do not always ensure a duplication at the level of their respective 

communities. 

We noted that these FFC’s mobilization efforts are quickly 

confronted to certain problems including: 

- (1) certain authorities’ resistance particularly the council 

authorities which carry out a completely impenetrable 

management of the yearly forest royalties 

- (2) an absence of support from certain technical department 

managers (local forest Posts) which do not feel the need to be 

accompanied in their regalian tasks by the communities who act 

within that scope as vigilant committees, which exposes them to 

the poachers’ threats. 

(3) an absence of concrete action developed by the company to 

meet the results expected that is to say the development of 

alternative activities generating incomes and aiming at diverting 

the riparians from direct or indirect poaching and as such preserve 

wild fauna. On that last point, article 6 of the in-house regulations 

suggested by the company to the FFC and already ratified by 

certain (FFC) remains vague as far as the FFC functioning 

resources are concerned. That article stipulates among others that 

“a financing project of the FFC functioning from the RFA will be 

introduced in the four villages” 

8 Report of the working session held on 27 March 2006 in YABASSI 

at NKAM’s Civil Engineering Subdivision about the building of the 

MOSSE-NDOGBASSABEN road. 

30/09/06 PV meeting in NDIKINIMEKI with NDOGBASSABEN's 

CPF about the layout of MOSSE-NDOGBASSABEN road and 

TRC's position. 

UFA00.004 contentious road opening awareness mission Report 

Scheme by MINFOF. 

DAT: Financial assessment of Yingui-Ndikinimeki road (1987). 

Following that corrective action request, the TRC company held 

consultations with the concerned stakeholders (Ministry of public 

works- roads subdivision, territorial administration concerned, 

communities brought together in the camp of Ndockbassaben 

represented by the FFC nb 3). These consultations allowed the 

concerned company and the appropriate technical departments 

and administrative authorities (MINFOF and MINTP) to clarify 

matters concerning the TRC position, as succesful bidder of UFA 

00 004 and guarantor of the surface submitted to sustainable 

management by the forest administration and of which a 

management scheme was devised and approved by the 

appropriate administration (MINFOF). The complementary works 

of lands knowledge and village boundaries allowed the company 

to reconsider the Eastern boundaries of the UFA and to make a 

proposition of review to the forest administration (See letter 

adressed to MINFOF) in order to integrate the resettlement by the 

brought together communities of the former villages, integrating 

therefore one of the commitments taken on 30th September 2006 

meeting with the FFC of Ndocbassaben (See minutes of the 



these actions 

allow full 

conformity 

The meetings 

conducted by the 

auditor allowed to 

conclude that that 

corrective action 

request had been 

met. 


removed. 



response is 














Version : 2.1 

CAR 

Nb 


meeting). 

It must be underlined that that step allowed to clarify the TRC 

company’s responsibilities which come down to the UFA 00 004 

sustainable management and exploitation and not to the 

opening/management of that axis which moreover is in the 2006- 

2008 triennial priority road network maintenance scheme. The 

communities, although convinced by the clarification made wish to 

see that axis built, which will allow them to get back to their 

ancestral lands to which they are attached. 

9 Updating in the certification procedures of chapter 8.1.2 

concerning safety equipments. 

Memorandum (20/06/06 Nb 24/DG/06) addressed to the sawmill 

managers concerning the safety equipment of the Phyto sprayer. 

Memorandum (20/11/06 Nb 61/DG/06) addressed to the sites 

Managers, fixing the safety equipments replacement schedule in 

our yards. 

10 Minutes of the meetings concerning among others the safety 

equipments, on 6 and 8/7/06 in DOUALA, on 12/7/06 in MAKOT, 

on 14/7/06 in BAKOGO, on 15/7/06 in KUMBA. 

On 06/7/06, letter to the subcontractors asking them to equip their 

personnel in safety equipment. 

Memorandum (20/07/06 Nb 33/DAF/06) addressed to the 

workshop and sawmill managers, concerning the supply in safety 

equipments to all our subcontractors’ employees. 

Memorandum (25/7/06 Nb 35/DG/06) addressed to all the sites 

managers concerning the prohibition of access to the TRC 

facilities for the subcontractors’ employees without safety 

equipments. 

Memorandum (25/7/06 Nb 37/DG/06), concerning the practical 

methods of distribution of working clothes to the hauliers’ 

personnel. 

On 22/11/06, information note, addressed to the sawdust 

removers concerning the replacement of their safety equipments. 

On 23/11/06, letter to the hauliers intervening on forest yards to 

ask them to supply the drivers and their assitants with safety 

helmets; 

11 Research of a treatment product containing no cypermethrin, 

approved in Cameroon. 

On 11/10/06, cypermethrin use dipensation request for Cameroon 

addressed to - EUROCERTIFOR Bureau Veritas Certification, 

signed by the GMs of the PALLISCO, WIJMA and TRC 

companies. 

Replacement of the SEPARGRUM product on all the sites by the 

only product for the long poles treatment approved in Cameroon 

containing no cypermethrin, DC6++. 

Memorandum (05/01/07 Nb 02/DG/CAR/07) addressed to all the 



these actions 

allow full 

conformity 

The safety equipment 

adapted to the work 

stations was 

distributed. It is in 

most of the cases 

worn by the 

personnel, the 

schedules are posted 

up and respected. 


removed. 

It is reminded to the 

company to be 

constantly vigilant on 

the monitoring of the 

strict respect of 

wearing safety 

equipments. 

The collective letter 

addressed to BV 

Certification is 

enough to remove 

that corrective action 

request; Moreover, 

the Cryptogyl DC6++ 

is the only one used 

by TRC and does not 

contain any 



response is 




Certain shortcomings 

endure: 

- At the sawmill, the 

gloves are not 

systematically worn 

- Vehicle drivers and 

cutters’ helpers should 

wear hearing 

protections 

- The employee in 

charge of the 

phytosanitary 

treatment should know 

the replacement 

conditions of the filter 

of his protection mask. 

- … 


maintained. 











Version : 2.1 

CAR 

Nb 


site managers concerning the replacement of SARPAGRUM by 

the DC6++ with the technical data sheets. 

12 Memorandum (13/7/06 Nb 30/DG/06) addressed to the personnel 

manager, concerning the setting of a function in the personnel 

Excel data base which permanently informs of the number of 

employees whose promotion is due. 

Intervention of the PROLOGIQ company in the setting of the pay 

software concerning the automatic promotion (Invoice 008/1006 of 

17/10/06). 

To meet that corrective action request, the company developed an 

Excel software package which allows updating in terms of 

workforce to be regraded according to the recruiting date and 

automatic promotion time (after three years’ seniority). In addition, 

the pay software was parameterized by the PROLOGIQ company 

to establish a direct relation with the personnel management Excel 

data bases. 

We moreover studied the case of a worker who experienced 

delays in promotion and we assessed the dealing with his case by 

the company. That employee was regraded and received an 

adjustment too because of the delay. 

13 Memorandum (13/07/06 Nb 31/DG/06) addressed to all the site 

managers, all the section heads, all the personnel managers and 

the workers’ representatives, concerning the administration of 

disciplinary measures according to precise faults defined in an 

enclosed table. 

Consultation meetings extended to the workers' representatives of 

the Douala site allowed to define and adopt a disciplinary policy 

(see memorandum (13/07/06 Nb 31/DG/06) addressed to all the 

sites managers, all the departments managers, the personnel 

manager and the workers’ representatives, concerning the 

administration of disciplinary measures according to the precise 

faults (defined in an attached table) within the TRC company. We 

checked that that disciplinary policy was displayed on the boards 

at the level of the sites we visited (Douala’s processing sites and 

UFA 00004 bases). 

The interviews held with a few workers allowed to check that 

awareness meetings had been organized by the company 

personnel department on the subject. 

On the other hand, a review of the company’s in-house regulation 

has to be considered to integrate that new disciplinary policy 

defined by the company and integrate too the changes that 

occurred in its commitment policy. 

14 Memorandum (06/11/06 Nb 55bis/SP/DAF/DG/06) addressed to 

all the site managers and to the administrative officers, concerning 

putting registers of grievances at the workers' disposal on all the 

sites. 

Copy of registers of grievances signed by the General 

Management. 

Copies of requests and answers of the personnel department. 

We checked, in accordance with the art. 25 (1) of the order of 26th 

May 1993 019/MTPS/SG/CJ that the registers of grievances were 

implemented. These are registers in which the personnel 

represented by the elected representatives record the different 

problems that they wish to discuss with the company’s hierarchy. 

In these registers there are columns in which the hierarchy should 

bring precise answers to the concerns expressed by the workers. 



these actions 

allow full 

conformity 

cypermethrin. 


removed. 

The steps correspond 

to the corrective 

action request. 


removed. 

The steps correspond 

to the corrective 

action request 

(information and 

implementation 

checked on field). 


removed. 



response is 




Apply scrupulously the 

procedures as far as 

social matters are 

concerned, 21% of the 

registration forms are not 

introduced. UFA 004 

36% of forms not 

introduced). No 

application of conflicts 

resolution procedures (no 

systematic answers to 

grievances), still 

problems of application of 

disciplinary procedures 











Version : 2.1 

CAR 

Nb 


These registers of grievances were consulted on forests sites as 

well as on processing unit. Concerns are regularly expressed by 

the workers and are particularly about: 

• The implementation of an independent fund for the UFA 

00004 workers allowing them to react effectively in case of 

emergency (to take into consideration the fact that most 

salaried employees are from now on payed by transfer at 

Douala and can take possession of their salary only a few 

days later); 

• The staff store accounts control in accordance with art. 78 

(2c) of labour regulations; 

• Abuse of authority of the UFA 00004 site manager and failure 

to respect the disciplinary scale defined by mutual agreement 

with the concerned parties (employers and employees); 

• The denial to present the clock cards to the workers before 

sending them for computerization to Douala (while agreed 

with the General manager); 

• The inadequacy of pharmaceutical products at the level of the 

site infirmary and the high price of marketed medicines. 

• The establishment of a days off weekly schedule; 

• The transportation of workers on holiday from the UFA to 

Yingui for transport facilities. 

• The payment of April and December salaries on 30 th of the 

month at the latest. 

• The workers’ transport conditions on the forest yards; 

• The allowances calculation (holidays and seniority bonuses); 

• Family allowances; 

• The definite schedule of pay and two weeks’ pay; 

• The production bonus; 

• Payment of the salaries before leaving on holidays; 

• The workers’ health and safety (agreement to bear medical 

costs and IPE costs, and so on). 

• And so on. 

The audit team noted a certain redundancy of the concerns 

expressed by the workers, which conveys a dissatisfaction in the 

answers provided by the company’s hierarchy. These different 

points should be treated appropriately and in accordance with the 

legislation in force. 

15 On 12/12/06, UFA 00 004’s exploitation Environmental Impact 

Survey report deposit for validation. 

Harmonization of the certification procedures with UFA 00 004’s 

Environmental Impact Survey results. 

Distribution to FFCs of the Environmental management scheme 

(EMS) from 13/12/06 to 22/12/06. 

Memorandum (08/12/06 Nb 70/DG/CAR/06) addressed to Inoussa 

DJUMBOKET, in charge of socioeconomic questions concerning 

the actions to be taken with the riparians in relation to the 

measures which concerns them in the EMS. 

Memorandum (14/12/06 Nb 73/DG/CAR/06) changing 

memorandum (14/03/06 Nb 12/SP/DAF/06) concerning the 

evolution of certain functioning methods of UFA 00 004’s yard staff 

store, to meet the resolution of measures concerning the staff 

store written down in the EMS. 

Change in the UFA 00 004’s staff store regulation. 

On 22/12/07, letter to all the hauliers on TRC environmental policy 

containing, measures to be implemented, an extract of UFA 



these actions 

allow full 

conformity 

There is an impact 

survey, it complies 

with what one should 

expect, and it was 

satisfactorily 

communicated. That 


removed. 



response is 




(see in-house audit). 


maintained. 











Version : 2.1 

CAR 

Nb 


00.004’s EMS summary in relation with their activity and a 

commitment model. 

Memorandum (02/01/07 Nb 01/DG/CAR/07) appointing engineer 

of UFA 00 004, Arnaud TCHOKOMENI, in charge of the yard 

environment. 

Letter (11/01/07 nb 00042/L/MINEP/IG/l1) of the Minister of 

environment acknowledging receipt of the survey 

16 On 16/6/06, email to Dr EKOBO ATANGA about EBO park 

creation and the big apes protection zone scheme incorporating 

UFA 00.004 

On 17/10/06 mail sent to WWF YAOUNDE about the WWF/TRC 

collaboration following EBO park setting up. 

Minutes of the 26/10/06 meeting at the MINFOF Provincial 

delegation in DOUALA, with the WWF about poaching in UFA 

00.004 and attendance sheet. 

Report of the mission carried out in UFA 00 004 by an employee 

of the Littoral provincial delegation, a WWF employee and a yard 

engineer in order to collect pieces of information concerning 

poaching. 

Report of the anti-poaching mission carried out in UFA 00 004 by 

DOUALA’s MINFOF provincial delegation team, financed by TRC. 

17 Increase of the felling minima diameters for BONGOSSI, “OKAN” 

and “TALI”, Tieme WANDERS’ argumentation. 

Memorandum (10/10/06 Nb 45/DSAC/06) addressed to the UFA 

00.004 exploitation managers, to cutters, prospectors and clerks, 

concerning the felling diameters and the list of protected trees. 



these actions 

allow full 

conformity 

The reference 

documents were 

actually gathered by 

TRC and are 

available. That 

documentary CAR is 

therefore removed. 

To be noted that a 

corrective action 

request relating to the 

bordering zones 

(CAR 27) and in 

particular those 

bordering EBO forest 

remains posed. 

The elements 

provided by TRC 

correspond to the 

auditors’ expectations 

and allow to improve 

the durability of the 

resource while 

maintaining economic 

and forestry viability. 


removed. 



response is 




10.3.2 - Conformity evaluation of implemented documents or process, refering to 

the FSC responsible forest management referential 

The procedures have been made to comply with numerous points with regard to 

the sustainable management referential. It is particularly the case as far as the 

working conditions (part of them) are concerned, of in-house and external 

consultation, the legality and the documentary bases which have been 

implemented. Shortcomings continue at the environmental level and as far as 

health and safety at work are concerned. 

• Main strong points of the applicant entity for certification 

The TRC company got involved in an FSC certification process and provided 

generally well documented answers to recommendations and corrective action 

requests (17 major, 17 minor) expressed during the initial audit. 

The relationship with the local populations is in general good, with regard to the 

recurrence of meetings and trainings carried out those last six months, the 

administration takes a benevolent look at the company. The company’s 

procedures are generally well adapted, clear and constitute a coherent whole. 











Version : 2.1 

Forestry is today carried out in satisfactory conditions, and the impact of this 

exploitation on the environment is minimized by adapted practices and 

measures. 

• Main weak points of the applicant entity for certification 

The company’s social, health and safety conditions at work continue to present 

certain nonconformity points (selling prices of medicines to the workers on 

forest sites, personnel transport, disciplinary measures according to the 

procedure, safety within the factory, CNPS registration, dealing with the 

workers’ grievances, and so on). 

The zone is of major interest at an ecological level on the worldwilde scale. The 

aspects relating to the determination of High Value Forests for conservation, 

and the monitoring and analysis work which should be implemented considering 

the constitution instance of EBO forest, bordering, are not taken enough into 

consideration. 

10.3.3 - Elements subjects to controversy which need to be detailed 

The results of the present audit have been discussed thoroughly between 

Bureau Veritas Certification and TRC. No element being debatable was 

mentioned by the audit team. 

10.4 - New Correctives Actions Requests resulting from the 

Complementary Audit 

10.4.1 - Minor Corrective Action Requests 

The CAR nb 18 is maintained as minor: 

18 

Supply the definitive agreement of the constitution 

order. 

Next Surveillance 

audit 

2.1, 1.5 

Nb 

Besides CAR nb 18, 10 new minor corrective action requests are expressed: 



suggested 

Demand Number 

37 Structure the management committee 3 months 7.3.3, 8.4, 9.4… 

38 

39 

40 

identify, locate and assess the impacts of 

nonconformities which can be observed on the cutting 

areas prior to 2007. Implement an action scheme 

aiming at compensating or softening the identified 

impacts and thereby draw a lesson in terms of 

procedure. 

Complete and improve the protocol of providing food 

to the workers and finalize the legal procedures into 

setting up the staff store (Labour regulations’ 

Article78 (2c)) 

Plan and apply a social policy bearing the workers 

and their family’s medical costs (apart from industrial 

accidents) The policy set up should be equitable and 

fair for all the workers of all the sites. 

3 months 

2.2.2, 6.1.3, 4.5.3, 

5.5.2 

3 months 6.2 

3 months 4.2 











Version : 2.1 

41 

42 

Set up a system of monitoring and assessment of the 

protocols; and thereby draw a lesson in terms of 

procedure. Adapt these protocols 

protect effectively the concession from illegal 

activities and poaching. 

3 months 8.1.5 

3 months 1.5.1; 1.5.2 

43 Plan a consulted action scheme of the TRC/FFC. 3 months 5.4 

44 maintain the HIV Aids fighting committee active 3 months 4.2 

45 use the updated compensation scale. 3 months 4.5 

46 

take appropriate measures to ensure hygiene, safety 

and cleanliness of the activities taking place outside 

the sawmill (cantine, waste management, safety of 

the people walking on the site) 


3 months 4.2 

CAR nb 18: That corrective action request will continue as long as the definitive 

agreement is not issued to the entity. Nevertheless, it is common knowledge 

that the issue of that document is most of the time a long formality in Cameroon. 

TRC displayed its willingness by writing officially to the Minister, and cannot do 

anything else to speed up the procedure. 

CAR nb 37: It is essential that TRC has in-house knowledge and know-how 

which will be constituted to acquire the quality level needed to be granted the 

FSC label. The Form international, WWF and all the service providers’ actions 

should be capitalized and an in-house appropriation should be carried out. 

It is therefore essential that the TRC team were strengthened, and that a 

national engineering pool capable of taking in charge in due time the monitoring 

of these works was constituted. The responsibilities of each one at the level of 

that committee should be clearly established (for example in the form of detailed 

post sheets). 

CAR nb 38: With regard to the procedure manual recommendations, the former 

cutting areas are characterized by numerous nonconformity points. Without 

being exhaustive, the following points were observed: 

- Point 744. Roads construction: 

The network setting up is not optimized, in particular in the first cutting 

areas, 

The widths of the main and minor tracks are sometimes bigger than 

recommended, 

The opening of the main track generated very big embankment slopes, 

not consolidated at present and which are source of erosion, 

- Point 746. Felling and forwarding 

The low impact felling technique was only partially implemented, the 

felling gaps being sometimes very big, 

Certain timber felled in too humid zones were abandonned in the cutting 

area, 

Dykes were constructed in humid zones. These dykes have only been 

partially reopened after exploitation. 

These nonconformities are obviously linked to the novelty of the certification 

process which started during the first months of year 2006. At the time of these 

cutting areas exploitation, although the process was already in progress within 











Version : 2.1 

the company, its operational application and its appropriation by the personnel 

on field were not yet completed. 

It is suggested that an environmental survey should be carried out with 

hindsight on all the former cutting areas. That survey will aim at: 

- identifying all the nonconformity points with regard to the procedure manual 

in force, 

- suggesting solution elements aiming at suppressing, softening or 

compensating the negative impacts on the environment, 

- setting up an action scheme backed up by figures and a schedule of works 

aiming at implementing suggested solutions. 

CAR nb 39: A staff store implementation is a legal requirement of Cameroonian 

labour laws. There is a staff store at Ndokagnak TRC forest base, however the 

conditions of goods supply are not sufficient. There is no precise schedule for 

supplies. These latter are based rather on the pay and two-weeks’ pay periods 

which vary whereas the working class and their family consumption rhythm 

remains constant. We noted that during our visit the freezers installed for 

preserving fresh goods were practically empty (no fish, no meat). 

On the other hand, fresh goods, when bought in Douala are not transported in 

appropriate conditions. The duration of the journey between the purchase in 

Douala and the staff store does not allow better preserving of these goods in 

the absence of suitable preserving means (cold chain notion). 

We noted the absence of a surveillance committee elected by the workers, 

committee having to monitor the staff store accounts as stipulated by labour 

regulations art. 78c. 

Moreover, we noted that the goods are actually sold at cost price (Douala’s 

market), the workers are creditworthy, which could be a reason to increase the 

stocks according to the needs. 

It is therefore important that TRC sees to the full respect of the labour 

regulations articles relating to the staff stores, as well as to the improvement of 

the management and transport of fresh goods and frozen food. 

CAR nb 40: The forestry management operations should meet or go beyond 

the demands of the laws and other applicable regulations in matter of health 

and safety of the employees and their family: TRC should therefore set up an 

equitable and fair policy to allow equal medical access to everybody. 

Ndokagnak’s TRC site infirmary visit allows to note that the prices of the 

medicines sold to the workers are high, compared to the prices at the level of 

the pharmacies in Douala (actually, the supply of medicines at sites level is 

ensured by Dr TEKAM’s clinic, whereas the agreement made between 

Koumassi’s Clinic (Olympe’s Health centre) and the TRC company does not 

plan formally a clause on that subject): The guarantees obtained concerning the 

origin and the quality of the medicines have as a consequence an increase in 

the price of the aforementioned medicines and that additional cost is particularly 

distinct at the infirmaries on forestry sites. 

Moreover, no specification is made about the company’s own responsibility and 

efforts to reduce the prices for the workers. Belonging to an equal socioprofessional 

group within the same company, Ndokagnak’s TRC site workers 

and possibly workers from other forest yard sites are penalized by such a 

system. That problem may lead as a pernicious effect to the use of medicines 

bought through other means, and therefore potentially adulterated. 











Version : 2.1 

TRC should work in order that all the salaried employees and their families have 

access to medical care in favourable conditions of safety, and cost too, for 

example by taking directly care of all or part of the expenses resulting from the 

clinic. 

CAR nb 41: The procedures set up for the certification are in essence 

perfectible. It is therefore useful that TRC should set a regular monitoring 

system of those procedures, to check that they are well adapted, applied 

intelligently and meet as best as possible the field realities. For example, the 

tree marking of the stems of the future is as such a very good operation, 

because it contributes to the sustainability of the resource. However, while 

wanting to avoid a maximum of stems of the future, the cable skidder drivers 

sometimes extend considerably the forwarding tracks routes, which obviously 

constitutes a pernicious effect. (There are other examples in which custom will 

allow an adaptation of the procedure) 

It consists for the company in designing, for each protocol, an assessment tool 

allowing to define and implement corrective actions aiming at improving the 

protocols and adapting in them the field practices. 

CAR nb 42: The boundary surveillance protocols are not sufficient with regard 

to the threats which weigh on the zone (illegal timber cutting, and mostly 

poaching). The local populations should be involved in boundaries recognition, 

however they are probably not the best actors to carry out the surveillance, 

because they are most certainly involved themselves in the possible offences 

that they would have to note. 

Our reports on field (riparian villages- the UFA North-East sides, North and 

West sides) allow us to testify to the increase in poaching at the UFA level. 

Awareness sessions were carried out by the company through many meetings 

with the forests farmers committees (FFC), however there is cause for stressing 

upon the fact that awareness alone is not sufficient to divert the communities 

from that unique activity (great source of income) very much anchored in the 

UFA zone at present. 

On the UFA Western side (Yingui Iboti axis), the remarks and interviews 

conducted with the county authorities as well as the riparian communities testify 

that small-scale sawing is significant and constitutes a threat to the UFA’s 

ligneous resource protection. 

TRC should therefore get more strongly involved to control its boundaries, set a 

regular monitor procedure at a reasonable rhythm by a halogen officer (i.e. not 

coming from or not linked to the local populations) 

CAR nb 43: In answer to the major CAR nb 7, the TRC company defined a 

scheme of awareness and reinforcement of the communities’ capacities 

(through forests farmers committees) of identifying and carrying out microschemes 

which generate incomes. It consists in time through these actions, in 

diverting the UFA riparian communities from commercial hunting and poaching, 

their main sources of income in the zone up to now. 

We checked that the actions of capacity reinforcement were actually carried out, 

even if these actions only saw a very limited participation of forests farmers 

committee members (who were supposed to duplicate the trainings at the level 

of their respective communities) they are not sufficient to divert the communities 

from commercial traditional hunting. 

The training steps should be followed by implementing concrete schemes 

according to a defined and concerted schedule with the communities. 











Version : 2.1 

CAR nb 44: The HIV committee is an interesting initiative, which however is 

difficult to judge because it has for the time being an impact value only. That 

initiative should therefore take shape quickly and on a permanent basis to meet 

the requirements of the CAR issued during the initial audit, on the international 

requirements basis. 

CAR nb 45: A compensation scale of damage done to the crops by reason of 

public benefit was published by the MINFOF in 2002. Yet the TRC procedures 

are based on the 1981 scale, manifestly obsolete. 

TRC should therefore replace the basic scale, while giving space for 

consultation and arbitration in the resolution of conflicts linked to crop 

destruction. 

CAR nb 46: The TRC factory is very old. A scheme of site relocation and 

creation of a new processing unit on an adpated site is making good progress 

and should see the light within 2 years. Yet, realistic adaptations in accordance 

with the FSC requirements must be carried out on the present factory. 

In particular, TRC cannot clear itself of responsibility on the additional activities 

which are undertaken outside the factory compound. The edgings are 

transported outside that compound and are straight away shared in utter chaos 

to supply the unofficial market. 

Moreover, pedestrians carry on walking and children carry on playing on the 

stock yard in the vicinity of the TRC compound, between the long poles and 

vehicles, with permanent risks of accident. 

The workers’ "canteen meals" prepared at the formers’ own expenses by village 

women who come every lunch and dinner time to feed the workers should 

benefit too, according to the workers’ representatives, from a surveillance and a 

support from TRC. 

Generally, the present impression is that TRC does not fully take its 

responsibilities on what takes place outside its compound. 

TRC should therefore take in charge with more attention the activities that result 

from its production and take place just nearby its compound and its timber yard. 

10.4.2 - Major Corrective Action Requests 

Minor CARs 27 and 34 are reconsidered as major, and CARs 4, 10 and 14 are 

maintained. 

4 

10 

14 

27 

Make public a MS summary presenting the guidelines 

linked to FSC. 

Make sure that all the contributors within the TRC process 

wear appropriate and well-maintained safety and working 

equipments; see that these equipments are worn and 

used correctly. 

Set up procedures allowing to treat in a transparent and 

objective manner the problems presented by the 

personnel. 

Take into consideration the bordering zones constitution 

schemes and draw the consequences in terms of 

exploitation. 

3 months 

3 months 

3 months 4.3 4.4 

3 months 6.2.5 9.4 











Version : 2.1 

34 

On the basis of the grid set in the procedures manual, 

bring out the characteristics of the HVFC specific to the 

UFA. Detail the adapted measures planned by the 

company. 

3 months 

9.1.2 9.3 9.1.1 

5.4.2 

Nb 

In addition to these CARs, 2 new major corrective action requests are 

expressed: 



suggested 

Demand Number 

35 Make the workers’ mode of transport on site more secure. 2 months 4.2 

36 

formalize, communicate (to all the stakeholders) and 

implement a procedure aiming at making the evacuation 

of the injured between the operational sites, the bases 

and the hospital more secure. 

Comments concerning the major CARs: 

2 months 

CAR nb 4: A confusion remains between the management scheme public 

summary which is the summary of the administrative document, and the 

certification procedures which are the TRC practices. 

To avoid that confusion, TRC will publish a public summary document which will 

take up the MS general data as it is applied on field (with the FSC guidelines 

and the elements listed in criterion 7.1). That document will invalidate and 

replace the former already distributed. The integration of the yearly monitoring 

elements should be planned too (see criterion 8.5). (CORRECTIVE ACTION 

REQUEST MAINTAINED). 

CAR nb 10: Certain shortcomings endure: 

- At the sawmill, gloves are not systematically worn 

- Vehicle drivers in forest and cutters’ helpers should wear hearing protections 

- The employee in charge of the phytosanitary treatment should know the 

replacement conditions of his protection mask filter. 

- The back-up warning alarms do not function on certain vehicles in the 

factory. 

The age of the TRC factory, and the fact that a factory scheme has been 

already elaborated, cannot be a reason to tolerate significant differences at the 

FSC referential level. The company should therefore see to personnel safety 

and comfort, when the equipment is worn out, old, and sometimes obsolete. 

In a state of transition, and pending the replacement of the most dangerous 

machines, one should see to equip the most dangerous machines (jointers, 

secondary breakdown machines) with adapted protections. 

TRC should see to make up for the shortcomings concerning wearing adapted 

equipment and, more generally, personnel safety in forest in factory. 

CAR nb 14: Strictly implement the procedures in social matters. Following 

difficulties which are, it seems, linked to the Administration, 21% of the 

registration requests to the CNPS are not yet submitted (or were submitted 

once and have to be submitted again, following requests of complementary 

pieces of information by the Administration). On UFA 004, that figure reaches 

36%. That question is very sensitive within the personnel who do not distinguish 

the responsibilities, however they note that in the end, many salaried 

employees still do not benefit from social security cover. 











Version : 2.1 

The surveys carried out among the workers' representatives show that 

progresses remain to be made to implement procedures of resolution of 

conflicts (no systematic answer to grievances). 

One still notes problems of application of disciplinary procedures (SEE in-house 

audit). A reminder in that direction should therefore be made to all the 

concerned people. 

TRC should see to the full and entire implementation of its certification protocols 

relating to social points. 

CAR nb 27: Generally, several surveys testify to the biological wealth of the 

forests located South of UFA 00-004. That diagnostic was recently reinforced by 

the discovery of a large population of gorillas in the Békop sector which, 

according to the available pieces of information would belong to the subspecies 

called “River Cross”, which as far as biodiversity is concerned, constitutes a 

remarkable distinctive characteristic. The biological quality of the forests and the 

need to protect them as they are faced with increasing anthropic pressure 

exerted on them logically led the MINFOF to suggest the creation of a National 

Park in Ebo Forest. Following the emergence of sharp contentions from one 

part of the local populations, that scheme is presently in the process of being 

negociated between the different stakeholders. 

UFA 006004 being in direct contact with the clump concerned by the 

constitution scheme, it is evident that it has a strategic importance with regard 

to the protection of genetic influxes at the natural zone scale. 

The field observation and the consultation of the available documents testify to 

the presence in the UFA of emblematic species, of high patrimonial value 

protected on the international scale, as the chimpanzee or the elephant. As far 

as the gorilla is concerned the data seem contradictory: 

- the presence of the species appears in the 2005 WWF inventory and in the 

impact survey on the environment, however the ICK are not defined in the 

fauna survey and its presence is surprisingly enough not repeated in the 

procedure manual, 

- if certain pieces of field information (collected among the hunters) seem to 

confirm the gorilla’s presence in the UFA, others deny it. 

Generally, it seems that the importance of the forest zones covered by the UFA 

as: 

- potential habitat for remarkable species, 

- influx and genetic intermixing zone, 

- strategic zone for the general functioning of the forest ecosystem, 

- buffer zone to a national park, 

was not surveyed enough and obviously underestimated. 

It is suggested that a procedure should be set and implemented in order to: 

- complete fauna knowledge on the UFA, 

- identify the strategic zones with regard to maintaining influx of migratory 

animals and to integrate them in the HVFC approach, 

- set a device of monitoring/assessment of habitats quality in the UFA with 

regard to maintaining biodiversity and the amount of emblematic species it 

can shelter. 

CAR nb 34: The established document, concerning High Value Forests for 

Conservation remains insufficient, in particular, the attributes remain defined too 

vaguely, while defining, within the scope of a standard table the different High 

Value Forests, the attributes of these values and the measures taken to protect 

them. 











Version : 2.1 

That table was established on the basis of PROFOREST’s works, on the basis 

of and in answer to the first corrective action request put to TRC on that subject. 

The shortcomings noted concern several points: 

- TRC did not consult enough (local and international NGO in particular) for 

validation of the work carried out (or did not provide proof for that 

consultation). 

- TRC should start, in consultation with representatives of the populations, 

schemes of identification, assessment, inventory and conservation of 

resource species for the population (Non Ligneous By-Products), draw from 

them a forestry and/or picking development strategy. 

- Where high values are identified, they should deserve to be so in a more 

explicit manner and according to more extensive criteria (altitude, slope, 

proximity to watercourses, proximity to protected area - Ebo Park). 

Identification of the conservation attributes should be carried out in 

consultation with all the stakeholders. 

- One can even, in certain repects, doubt about the validity of the HVFC 

choices carried out by FORM International and about the existence of 

motivations for setting up a reserve (barren rocky zone in particular): That 

last point is not well brought to light in the document established by Form 

International for TRC. 

- A list of protected species and species voluntarily unexploited and protected 

by TRC on its concession was drawn up, however the prospectors must be 

trained in the recognition of protected species and a specific procedure for 

locating these plants must be elaborated. 

- The bibliographical aids serving as proof of assertions carried out in the 

document (scientific surveys, theses, and so on) should be quoted and 

extracts appended to the document. 

- The HVFC survey could detail the procedure for the determination, the 

location and the measures of conservation taken concerning the cultural 

sites and places of worship, which were identified through interviewing 

populations of the concerned villages. 

- Generally, the presentation of the documents should be more attractive, to 

be a first choice communication medium (to be put on line). 

- The work started within the scope of CAR 27 should be partly taken up in 

that CAR. 

CAR nb 35: The workers are still transported from their place of residence to 

the base and from the base to the yard in the TRC skips and pick-up vans, with 

no safety or comfort measures. The vehicles transporting the personnel on site 

(living base and exploitation yard) are inappropriate. The dump trucks equipped 

with vessels to transport and supply the machines with fuel. The workers 

transported sit on the vessel which is leaking fuel. 

These transport conditions with great hazards (numerous fatal accidents known 

in other companies) cannot be tolerated within the scope of FSC, where “Forest 

management operations should meet or go beyong the requirements of law or 

other regulations applicable as far as employees and their family’s health and 

safety are concerned”. (Criterion 4.2). 

Therefore, it is imperative that these transport conditions should be made safer 

and more comfortable for the personnel: seats, crushproof safety bonnet and 

tarpaulins and systematic respect of the number of transportable passengers 

are imperative. The company should for example be equipped with converted 

military skips, or even equip its own vehicles. These skips should be, from then 

on, only dedicated to personnel transport. 











Version : 2.1 

CAR nb 36: The company should see to ensure the evacuation conditions 

within satisfactory time and in decent conditions of comfort and safety from all 

the sites (zones in the process of being exploited, reprocessing yard, and so 

on). At any time, an adapted means should therefore be planned to evacuate 

possible injured from the exploited site to the base (vehicles ready to intervene 

at any moment), then from the base to the clinic. These measures should, of 

course, be subjected to adapted protocols. 

There is no clearly defined procedure for an evacuation of the injured in case of 

emergency. The medical personnel on the sites do not master the steps to 

follow in case of emergency. The certification procedure (version 8) exclusively 

tells at paragraph 8.2.8 of people to contact with their phone numbers, however 

no mention is made concerning either the management of the injured person 

from the forest yard (place of accident) to the infirmary, or the evacuation 

means, or the intervention of the workers trained for first aid gestures before the 

intervention of a male nurse. The evacuation vehicles of the seriously injured 

should be equipped with stretchers. The procedure to be devised should clearly 

indicate the steps to follow and the necessary means to manage it. 

Finally that procedure should be largely spread among the stakeholders for a 

better appropriation. 

The workers are not satisfied with TEKAM clinic service: according to them, the 

death of one of them (systematic team) at the level of the South West TRC site 

casts doubt concerning the responsibility of the clinic, hence a general 

uneasiness which could be source of conflicts. 

The agreement plans at the date of the signature (March 2004) two hours per 

day for a number of 250 workers, however does not plan putting male nurses at 

disposal on the TRC sites. That agreement should be reviewed to include the 

supply conditions of medicines to the workers, putting at disposal medical 

personnel meeting the requirements prescribed by Cameroonian labour 

regulations considering the growth of the numbers of workers on the TRC sites. 

10.5 - Scope retained for the certification 

10.5.1 - Geographical limitation at the level of the entity 

The certification applies to all UFA 00-004. 

10.5.2 - Limitation at the level of the forest products 

All timber forest products declared exploited on UFA 00-004. 

10.6 - Proposals regarding the certification decision 

10.6.1 - Explication on all rating, weighting systems or other systems used 


No notation system was used to weight the referential criteria and requirements, 

each criterion of the referential having to be met by the forest entity. A 

nonconformity is therefore expressed at the level of a criterion, the former is 

noted when: 

- more than a third of the criterion indicators are not met; 

- or the audit team considers that noted failure(s) to meet indicator(s) lead(s) 

to a criterion not being met. 











Version : 2.1 

10.6.2 - Clear description of all recommendations and conditions associated to 

the certification decision 

That audit only concerned the forest management part. However, points 

concerning the timber monitoring chain were tackled. 

Within the scope of forest products traceability guarantee and the possibility to 

produce mixed or pure FSC timber, corrective action requests relating to the 

FSC COC certificate were removed. Although these elements are not subjected 

to a distinct report, it should be agreed to take them up again during the next 

Monitoring chain complementary audit, which should be subjected to a specific 

report. These CARs should then be taken up again, as well as those expressed 

in the initial audit report: 

Status 

Major 

Minor 

Minor 

Corrective actions 

requested 

Check that the OLB timber and 

declared as “Controlled timber” 

really comply with 

40 005 referential 

Get supplies of FSC products and 

generate FSC products 

Improve volume credit 

management procedures 

Comments 

define high value attributes for conservation of each of 

the UFAs, prove that they are not endangered by 

forestry for the UFAs exploited by the company. 

Formulate a commitment to complete respect of 

40 005 standard, set up the checking scheme, train 

the concerned people - In case of Controlled timber 

not used, plan real adapted and complete traceability 

measures. 

define product groups according to the FSC 40 004. 

Formulate and issue a monitoring procedure of the 

FSC/Monitored/Not monitored character. 

10.6.3 - Conclusion of the audit team 

The entity did not reach the required conformity level and should therefore be 

subjected to a new complementary audit. 











Version : 2.1 

11 - Complementary audit n° 2 


11.1.1 - Audit team composition 

Lead auditor: - 

Auditors: 

Forest auditor specialized in management and forestry, 

Auditor in traceability and in forest management, 

forest expert, independent consultant. 


aspects, qualified FSC forest management and CoC 

auditor on behalf of Bureau Veritas certification, 

specialized in social and environmental themes, 

salaried employee of Bureau Veritas Douala. 

- Forest auditor specialized in management and 

forest exploitation, Bureau Veritas, qualified Forest 

Management and monitoring chain auditor on behalf 

of Bureau Veritas Certification - Eurocertifor, Africa 

Zone Manager for Bureau Veritas Douala, ESB 

engineer. 

During that audit, the tasks were shared out as follows: 

- social aspects analysis relationship with the populations and personnel in 

part: Erith NGATCHOU TOWO 

- analysis of forest management, working conditions, environment, fauna and 

HVFC aspects: Caroline DUHESME & Alain VALETTE 

11.1.2 - Referentiel used 

For the initial and complementary audits, the verification list was referred to (ref. 

SF03 FSC GF Cameroon 1.3 version) from the referential of FSC forest 

management adapted to Cameroon (Ref. RF03 FSC GF Cameroon version 

1.3). 

11.2 - Information collecting modalities 

11.2.1 - Description of the audit programme 

Sunday, 18 th November 2007 

Douala Afternoon - 18.30: Opening meeting (in presence of: 



- Mister Jacques HULEUX, Management committee 

manager 


- Mrs Eléonore SCHMIDT, international consultant 

- 20.00: Meeting between auditors: documentary survey, 

preparation of the actions to be carried out by each one 

during the field visits. 











Version : 2.1 

Monday, 19th November 2007 

TRC 

UFA 00 004 

Morning 

AV + CD + EN 

Afternoon 

EN 

CD + AV: 

CD +AV + EN 

- 05.00: Departure for UFA 00 004 (about 3 hours) 

- 08.00: Arrival on the UFA site: 

- Former exploitation visit (post exploitation operation, 

rehabilitation of the damaged sites -) 

- 14.00: Interview with Yingui's Sub-prefect and Mayor 

and visit of Yingui’s DHC. 

- 15.30: Visit of the riparian villages (main Mossé - Yingui 

road). 

- 17.00: Back in Ndokagnak 

- 15.30: Visit of Ndokagnak TRC base (Staff store, 

Infirmary) 

- 14.00: Meeting with the TRC certification manager: 

presentation of the responses to the CARs formulated 

during the latest FSC complementary audit 

- Documentary survey of the protocol, responses 

documents to the CARs (surveys, report, procedures -) 

- 17.00: Meeting between auditors: complementary 

documentary survey, preparation of the actions to be 

carried out by each one during the next field visits. 

Tuesday, 20th November 2007 


UFA 00 004 

Day 

AV + CD 

Day 

EN 

- 07.30: Departure for UFA 00 004 

- 09.00: Forest base visit (waste management, ambulance, 

safety) 

- Visit of the exploitation, emergency evacuation procedure 

control 

- Recent post exploitation visit: watercourses clearing, 

respect of post exploitation control recommendations 

- 17.00: Departure for Douala 

- 20.30: Arrival at Douala 

- 07.30: Visit of the riparian villages - main Mossé - Yingui 

road (continued). 

- 10.00: Departure for Nkondjock 

- 15.00: Arrival at Nkondjock - Working session with the 

FFC of the zone from Nkondjock at Nkondjock. 

- 17.00: Departure for Bafang 

- 18.30: Night in Bafang 











Version : 2.1 

Wednesday, 21st November 2007 


Douala 

Day 

AV + CD 

- 8.00: Visit of Douala’s industrial sites 

- meeting with the traceability manager and Douala’s 

sawmill manager: collecting pieces of information on the 

processing monitoring 

- site visit (AV: Ndokbong, CD: IZ: “Industrial Zone”) and 

interview of the personnel (respect and knowledge of the 

monitoring chain procedures, assessment of the critical 

monitoring points -) 

- 12.00: ratification meeting with Douala’s sawmill 

manager: collecting complementary pieces of information 

- 14.30: visit of Bonaberi’s processing site 

- 18.00: Auditors working session 

- Complementary documentary review 


UFA 00 004 

Day 

EN 

- 05.00: Departure for Ndockbassaben 

- 09.00: Arrival at Ndockbassaben - Working session with 

nb 3 FFC 

- 11.00: Departure from Ndockbassaben for Nyokon 

- 13.30: Arrival at Nyokon - Working session with Nyokon’s 

FFC. 

- 15.00: Departure from Nyokon for Douala 

- 19.30: Arrival at Douala 

Thursday, 22nd November 2007 


Douala 

Morning 

AV + CD 

Afternoon 

AV + CD + EN 

- 09.00: Auditors’ summary meeting: complete the 

checking lists, elaborate the first results and identify the 

complementary pieces of information to be collected. 

- 11.30: Appointment with Dr Atanga (WWF) 

- 14.30: collecting complementary pieces of information 

- 15.00: Appointment with Dr Peguy 

- 16.00: Appointment with Mr Boukong 

- 17.00: collecting complementary pieces of information 

- By: interviewing Misters Okon, Effala, and the sociologist 

for the social aspects 











Version : 2.1 

Friday, 23rd November 2007 


Douala 

Morning 

Afternoon 

- 08.00: Meeting between auditors: assess the response to 

Corrective Actions Requests expressed previously, rule 

on the closure or the persistence of the previous CARs 

and define possible new CARs 

- 14.30: Reconstruction and closing meeting of the FSC 

complementary audit 

- 17.00: signature of the documents 

- 17.30: End of the complementary audit 

11.2.2 - Documents review 

All the documents collected and the works carried out by the company were 

surveyed by the audit team: new procedures, organization charts, official mails 

and independent experts’ reports were monitored and their application tested on 

field. It was also checked that the documents had been transmitted to the 

stakeholders (forest farmers committees), and that the documents were 

subjected to an appropriate communication allowing their application. 

The table below lists the documentary pieces provided by the applicant 

company 

Piece nb CAR N° Identification of the analysed piece. 

1 4 Updating of the complementary public document to FSC guidelines and 

management scheme summary 

2 4 FSC guidelines management scheme summary 

3 4 Updating of the complementary public document to FSC guidelines and 

management scheme summary for UFA 00 004 

4 10 TRC health safety charter 

5 10 Training on safety and IPE wearing 

6 10 Memorandum concerning IPE wearing 30/DG/CAR/O7 

7 14 Training of the management executives IFC Company 

8 14 CNPS registrations monitoring 

9 14 Nb 45/SP/DG/07 memorandum 

Concerns: Handling of personnel’s grievances. 

10 18 MINFOF mail to TRC concerning the UFA 00004’s Constitution testifying 

that UFA00 004’s constitution process is finished on field and the relative 

file follows the statutory procedure in force. 

11 27 Survey On the Faunistic Potentiality of UFA 00-004 Centre and Littoral 

Province, Cameroon October 2007 Dr Atanga EKOBO (WWF) Financed 

by Transformation Reef Cameroon (TRC) and WWF 

12 27 Survey on big mammals in Yearly Cutting Area 1- 4 of UFA 00-004 

Littoral Province, Cameroon September 2007 Dr Atanga EKOBO 

13 34 High Value Forests for Conservation within UFA 00-004 Douala, October 

2007 

14 34 Transmission of HVFC file to Dr G. Péguy TCHOUTO MBA TCHOU 

National School of Forestry BP 69 MBALMA YO CAMEROUN 

15 35 Personnel transport procedure (text and photos) 

16 36 First-aid training by social protection centre: marking sheets of the 











Version : 2.1 

Piece nb CAR N° Identification of the analysed piece. 

trained personnel 

17 36 NB 53 CAR/DG/O7 MEMORANDUM concerning the ambulance 

18 36 Evacuation procedure in case of emergency 

19 36 Procedure of use for the ambulance 

20 37 Management committee posts description 

20 bis 37 Management committee organization chart 

21 37 Management committee personnels’ trainings report 

22 38 Post exploitation operations procedure 

23 38 Protection of the soils in UFA 00 004. BOUKONG Alexis 

24 38 Post exploitation audit report: example 

25 38 Minutes of reconstruction meeting post exploitation audit report in the 1-2 

and 1-3 AAC of ufa 00-004 

26 39 Mail to Mister the Departemental Representative of Work and National 

Health Security 

of NKAM in YABASSI Subject: Staff store opening declaration 

27 39 Staff store management procedure 

28 40 agreement of visits and care between YINGUI's District Health Centre 

and the T.R.C Company. 

29 40 Ways of access procedure to medical care at Yingui’s DHC 

30 40 Nb SI/DGICAR/SP/07 memorandum concerning access to medical care 

and the appointment of Miss Pauline ZEH MBIAM, social worker 

31 40 Report on the renovation of Yingui’s care centre 

32 41 In-house audit procedures 

33 41 Monitoring of in-house audit results 

34 42 FGF financing agreement for the scheme set up by TRC to involve the 

local populations. The main objective of that project is to manage in a 

sustainable way the faunistic resources of UFA 00-004 and 

surrounding forests to its ecosystem. 

35 42 The UFA’s boundaries monitoring procedure 

36 42 The socioeconomic alternatives to poaching in the (“unité forestière 

d’aménagement”) (ufa) forest management unit of the TRC forestry 

company by Benjamin Ngonde, Christine Nkene Anjembe and Patrice 

Bigombe Logo (“cerad”) report complete survey 

37 42 Local strategy of anti-poaching fight in the ebo zone (ufa 00-004 and Ebo 

national park) (wwf) 

38 43 Action scheme assessment with the FFC 

39 43 Letters sent to the Mayors concerning AFR (Annual Forest Royalty) 

payment and the actions relating to it 

40 43 Report concerning the micro-schemes started with the FFCs 

41 43 Action scheme with the FFCs second phase 

42 43 Transmission mail of above document. 

43 44 Nb 50/DG/CAR/SP/07 MEMORANDUM relating to educative peers’ 

training as far as fight against AIDS is concerned 

44 44 HIV AIDS committee action scheme 

45 45 New compensation scale of damage to crops 

46 45 Compensation procedure of damage to crops 

11.2.3 - Intervention scope 











Version : 2.1 

That complementary audit took place within the scope of corrective actions 

checking set by the TRC company following the complementary audit dating 

from 20th January 2007 In accordance with uses, the work concentrated itself 

on the CAR resolution in progress, without limitation in the case of new 

nonconformities apparition or aspects not treated previously.and which could 

have been subjected to nonconformities. 

11.2.4 - Interview(s) of involved people met 

- Owner 

The State representatives having been met during the previous complementary 

audit, (and their opinion of the company being positive) were not contacted 

during that audit 

- Manager(s) 


particular the following people within the management: 






- Mrs Eléonore SCHMIDT, international consultant 

- Mr Eric SPRANGERS, TRC Finance and accounting manager 


- Mister William WAINFOIN LAWYER, TRC in-house audits manager 

- Arnaud TCHOKOMENI, UFA 00 004 yard engineer 

- Pauline ZEH-MBIAM Social Manager 

- Inoussa NJUMBOKET Socioeconomic Manager 

- Employee(s) 

Many employees were interviewed during that audit, at all the key posts of FSC 

process: cutters, technicians, personnel in charge of social and health issues, 

ambulance driver, first-aid worker - 

- Subcontractor(s) 

No subcontractor was interviewed insofar as the corrective actions requests did 

not concern the subcontractors 

11.2.5 - On-site visit(s) 

The UFA 00 004 site was tackled according to different points by the audit team 

members: 

- Visit of the surrounding villages and included in the UFA, meeting with the 

Farmers Forest Committees (FFC) by the auditor specifically in charge of 

that point. 

- Visit of riparian villages 

- Visit of the cutting area in progress (survey on working and emergency 

conditions, environmental audit of recent exploitations consequences on 

steep slope) 

- Visit of Ndockagnak base camp (welcome and transport conditions, staff 

store, infirmary) 

- Visit of prior cutting areas and rehabilitation actions started 











Version : 2.1 

- The in-house audit documents, which had allowed to list numerous 

nonconformity points as well as the reports of the different actions 

implemented by the company served as guiding information to the site visits. 

11.2.6 - Stakeholders identification and consultation 

Concerning a complementary audit, the certification procedure does not plan a 

stakeholders’ plenary meeting comparable to the one which is carried out during 

the initial audit opening. Nevertheless, in order to validate the TRC actions and 

procedures inventory of fixtures, it was essential to carry out a set of meetings 

and interviews of numerous stakeholders. The following stakeholders’ 

representatives were met: 

Riparians and Farmers Forest Committees: 

Ndocktouna and Ndem’s FFC 

- Mr EKOKO Isaac, Village headmen representative; 

- Mr NGOCK Pierre François, planters’ representative 

- Mrs NDOUIN Lydienne, GIC and associations’ representative 

- Mrs TAMBO Berthe, Representative of women’s associations; 

Nyokon’s FFC: 

- Mr KIARI Jules, Chairman 

- Mr BITCHA Johnny 

- Mr BELOMBO Bruno 

- Mr MBIRWANG Thomas 

- Mr BITEP KIARI Bertrand 

- Mrs AMBANG Esther 

North Nkondjock FFC 

- Mr TCHOFA William, Chairman 

South Nkondjock FFC 

- Mr BOTHIA Emmanuel, Chairman (former technical unit director) 

Ndocbassaben FFC 

- Mr NGUILE Chairman 

- Mr MOKUNDEZ Zacharie 

- Mr MILOUMI Mathieu 

Conservation NGO: 

- Dr Atanga EKOBO 

WWF coastal forest scheme coordinator 

TRC Consultants: 

- Mr BOUKONG Alexis 

Lecturer, Soil Sciences Department, FASA, DSCHANG University 

- Mr Péguy TCHOUTO MBA TCHOU 

National School of Forestry 

11.2.7 - Identification, traceability and monitoring of products 

The long poles traceability on field was ratified during the previous audit. 











Version : 2.1 

11.3 - Audit team observations 

11.3.1 - Action realised in response to the Correctives Actions Requests 

CAR 

Nb 

18 

37 

38 

39 

40 

41 

42 

• Minor CARs 


UFA 00 004’s constitution process is finished on 

field and the statutory procedure in force follows. 

Moreover the company started bounderies opening 

in accordance with the legislation in force. 

TRC recruited several engineers, a female social 

worker, and so on. One of the qualities of TRC as 

far as human being management is to know well 

how to spot in each one the potential to be put to 

advantage. 

TRC started a survey carried out by Pr BOUKONG 

from Dschang University. The latter gave a 

technical advice relating to soils restoration works 

started by TRC and, more globally, to the sectors 

sensitive to erosion. 

The administrative formalities were carried out, the 

prices and supplying were defined 

Thanks to the charging protocol applied by the 

company, there is no real difference in prices for 

the salaried employee whatever his workplace 

should be. 

The in-house audits, set as early as January 2007, 

were followed and extended over different fields of 

activity 

TRC set a “platform” involving the MINFOF, TRC 

and WWF. 

43 Many short and medium-term actions 

44 

Recruitment of a person in charge of following that 

issue, awareness organization. 

45 Application of a new scale, issued to the FFC 

46 

the company chose to separate the forest 

certificate and the COC certificate. These aspects 

are therefore not audited. Nevertheless, we 

checked that there is no point giving rise to 

controversy on the TRC industrial sites. 



these actions allow 

full conformity 

yes 

Satisfactory answer, 

the CAR is removed 





















response is 




the CAR is 

maintained as minor 

(see below). 

Comments relating to Minor CAR resolution: 











Version : 2.1 

CAR 18 Supply the definitive agreement of the constitution order. 

On 23rd October 2007, the UFA constitution file was transmitted by YABASSI 

(for the NKAM) and BAFIA’s prefectures (for the MBAM and INOUBOU) to Mr 

the Minister of Forestry and Fauna. On 5th November 2007, the Forests 

Management transmitted to Mr the General Manager of TRC a letter informing 

him that "UFA 00 004’s constitution process was finished on field and that the 

relating file follows the statutory procedure in force”. Moreover the company 

started bounderies opening in accordance with the legislation in force. For the 

reasons already underlined during the previous audits, and in accordance with 

the work accomplished since january, bringing tangible elements of progress, 

the CAR is maintained as minor pending the constitution order which deadline 

now depends on the administration. 

Documents supporting the resolution of the CAR (see table at chapter 3.3 

documentary journal): 10. 

DAC 37 Structure the management committee 


documentary journal): 20, 20 bis, 21. Interviews were carried out on that point 

with the concerned members of the company. 

CAR 38 identify, locate and assess the impacts of nonconformities which 

can be observed on the cutting areas prior to 2007. Implement an action 

scheme aiming at compensating or softening the identified impacts and 

draw a lesson from them in terms of procedure. 

TRC started a survey carried out by Pr BOUKONG from Dschang University. 

The latter gave a technical advice relating to soils restoration works started by 

TRC and, more globally, to the sectors sensitive to erosion. That report led to 

an improvement of procedures aiming at limiting the impacts of forestry 

operations beforehand (slopes limitation for example) and curative (installation 

of plaited mats on the forwarding tracks of the steepest slopes). That 

collaboration will be followed in order to supply an analysis tool: monitoring 

means-action-diagnostic elements (see N and U recommendation). According 

to these analyses results, the evolution elements of exploitation and impacts 

reduction procedures should be included into HVFC work. One should make 

sure that particular care is given to the permanent appropriateness between the 

exploitation procedures and the field reality, which should evolve in the direction 

of a greater consideration of the environment (slope). 


documentary journal): 22, 23, 24, 25. A field visit was devoted to going back to 

the identified sites in january, and to the analysis of the actions started (eroded 

embankment on IBOTI's road and forwarding tracks in steep zone). The slopes 

were measured with a clinometer by the audit team. 

CAR 39 Complete and improve the protocol of providing food to the 

workers and finalize the legal procedures in setting up the staff store 

(Labour regulations’ Article 78 C) 

A monitoring committee of the staff store accounts was set and functions 

properly. Vital commodities are marketed at cost price (Douala purchase price) 

and after each supply, the products price list is subjected to the committee’s 

assessment which ratifies it before putting it up. The supplying is done twice a 

month (two weeks and pay day) and in case of need, exceptional supplies can 

be provided to ensure a sufficient stock of products. 











Version : 2.1 

CAR 40 Plan and apply a social policy bearing medical costs for the 

workers and their family (apart from industrial accidents) The policy set 

up should be equitable and fair for all the workers of all the sites. 

It had been noted that medical expenses were higher for the workers in forest, 

due to the prices asked by the regional clinics. 

A mechanism taking in charge the workers and their family (defined by the 

family clusters concept = workers, 1 st spouse and declared children) was 

surveyed. A comparative survey of the services costs was carried out by the 

company with three health facilities of different levels (Yingui’s DHC (level 2), 

Bonasama District Hospital (level 3) and Douala’s Laquintinie Hospital (Level 

4)). One means to enable the workers in particular those displaced, to benefit 

from services at reduced costs (generally more expensive for certain items at 

the level of Yingui's DHC). That comparative survey allowed to make the 

decision of taking in charge the extra cost if ever the worker (or the family 

member) was treated in Yingui. 

The company bears the medical expenses, which are then attributed to each 

salaried employee at the reference hospitals rates. Therefore, there is no 

difference between the rates paid by each worker whatever site he was treated 

in. The company started Yingui's DHC refurbishment (openings, painting, 

ceilings redoing, endowment of fifteen hospitalization matresses, two desks and 

six chairs, a 7,5 KVA electricity generator, and so on) and recruitment of 

medical staff for Yingui’s DHC (including 1QN (Qualified Nurse), 1 Laboratory 

assistant, 1 nursing auxiliary) was carried out through the Olympe Health 

Centre. 

Thanks to the charging protocol applied by the company, there is no real 

difference in prices for the salaried employee whatever his workplace should 

be. The system can therefore be considered as fair and equitable, in the 

absence of a “mutual insurance” type solution, envisaged by the company, 

however not very practicable in Cameroonian reality. 


documentary journal): 28, 29, 30, 31. That measure was discussed on field 

during interviews with the workers, who declared themselves satisfied with it. 

CAR 41 Setting up a protocols monitoring and assessment system; and 

draw a lesson in terms of procedure. Adapt these protocols 

The in-house audits, set as soon as January 2007, were followed and extended 

over different fields of activity (social, medical, environmental). Moreover, in 

order to ensure a monitoring of the conclusions, TRC created a job and 

appointed an engineer in charge of conformity with regard to in-house audits. 

The R and S recommendations were made to make sure these points were 

taken into account by TRC. 


documentary journal): Documents 32 and 33. 

CAR 42 Protect effectively the concession from illegal activities and 

poaching. 

TRC set a “platform” involving the MINFOF, TRC and WWF. Its missions 

consist in conceiving, following and assessing the strategies and actions 

relating to the management of fauna and anti poaching fight, in mobilizing the 

necessary financing to the management of fauna and anti poaching fight, in 

encouraging information exchange, in spreading the information. That creation, 

very much appreciated by NGO local representations (in particular Dr Atanga 











Version : 2.1 

Ekobo WWF), appears as very positive to the audit team. Two "crackdown 

actions" were carried out, allowing the seizure of a major stock of bush meat in 

the villages from the South of the massif. The CAR is removed and the results 

of that platform should be checked carefully during each surveillance audit. 

Moreover, TRC started an action, on the basis of an FGF international financing 

obtained within the scope of a call for project. That project main objective is to 

involve the local populations in the sustainable management of the bordering 

forests’ and UFA 00-004’s faunistic resources, on the observation that poaching 

makes unsustainable takings on the fauna, upon which the populations benefit 

from gaming rights. Therefore, poaching is not only against the law but against 

the well thought about interests of the local populations too. 

The periodic monitoring procedures of boundaries (with research of trap, 

cartridges, stocks of wild timber), and systematic report of offence elements to 

the authorities continue to be appropriate. 


documentary journal): 34, 35, 36, 37. 

CAR 43 Plan a consulted action scheme of the TRC/FFC scheme. 

An action scheme was elaborated in consultation with the Forests Farmers 

Committees (FFC). (First and second generation) microprojects were adopted 

(see microprojects adoption Minutes). During the year 2007, first generation 

microprojects (agricultural yield) were carried out and the implementation was 

effective at the level of the majority of FFCs, in spite of a few delays noted 

considering the agricultural schedule for some of the adopted speculations. The 

local communities’ craze and/or mobilization for these projects was not the 

same at first, which partly explains the differences noted in terms of results 

obtained. Lack of social cohesion and community spirit were not favourable for 

the starting of first generation projects, which remained for the moment only 

those of FFC members, even if one notes a progressive support from the 

communities. 

Putting at disposal FFC running costs by the company (Fcfa 50 000 per quarter 

since September 2007) allowed to increase communities’ 

mobilization/awareness by the FFCs. 

These projects are mainly targeted at the riparian communities’ poverty fighting 

problems. At the end of first generation projects, a diagnostic of these actions’ 

strength and weaknesses should be carried out in order to improve the 

intervention strategies that should allow to increase or meet the expected 

results (massive support from the local communities, number of agricultural 

plots or individual livestock farming implemented, evolution of tonnages and 

livestocks, income generated by the communities, and so on). 

A survey on the socioeconomic alternatives to poaching was conducted by the 

CERAD research department in collaboration with TRC management 

committee. 

That survey in particular aimed at (1) identifying and analysing the different 

deep causes and motivations for practising commercial gaming, (2) identifying 

and analysing the other different possible and profitable economic alternatives 

in the short, medium and long term in each village and (3) suggesting the 

working-out of an exchange platform with the different parties (TRC, MINFOF, 

FFC, NGOs, other) about poaching in the UFA and its periphery. That survey 

conducted by the CERAD was entirely financed on TRC own funds. On the 

other hand, a participative diagnostic with the riparian communities on the 

projects which can enable to improve their living conditions (access to drinking 











Version : 2.1 

CA 

R 

Nb 

4 

water, and so on) was carried out. The company means to support the projects 

which will be adopted with funds of the REEF Foundation, funds generated by a 

budget of Fcfa 500/m³of ring shaken wood since January 2007. 

CAR 44 maintain the HIV Aids fighting committee active 

The company undertook the recruitment (in August 2007) of a social manager, 

linked to the management committee and in charge of working on the issues of 

improvement of the workers’ living conditions. Within the scope of his activities, 

contacts were established with structures such as AIDS/company and the 

representative committe of the Programme of fight against HIV/AIDS in forest of 

GCTF (Group of Cameroon's Timber Field). A first training of the peer educators 

was organized and about 24 employees were trained. An awareness working 

group (Africa’s scenario) is planned in the near future for all the workers on all 

the sites. 

CAR 45 use the updated compensation scale. 

The company set a new compensation scale based on the 2003/418/PM order 

of 25th February 2003. That new scale was spread through the public report in 

direction of the stakeholders and in particular the communities (FFC). 

CAR 46 take appropriate measures to ensure hygiene, safety and 

cleanliness of the activities taking place outside the sawmill (cantine, 

waste management, safety of the people walking on the site) 

The company chose to separate the forest certificate and the COC certificate 

(see January 2007 report). The purely social aspects – hygiene and safety are 

therefore not audited systematically. Nevertheless, we checked that there is no 

point giving rise to controversy on the TRC industrial sites and that the level met 

in January 2007 had been at least maintained. One should point out too that the 

company is going to move in a few months to set up its new factory on the site 

of the industrial estate. The visit of that site allowed to note that the personnel’s 

and riparians’ hygiene and safety aspects, as well as environmental respect had 

been taken into consideration as soon as the design stage of the site. 

• Major CARs 


The summary of the management scheme 

including the FSC guidelines was distributed (April 

2007) against discharge to the 11 FFCs 

10 Awareness, charter, report on field. 

14 

Registration at the CNPS all introduced 

Better managed personnel’s grievances. 













response is 














Version : 2.1 

CA 

R 

Nb 

27 

34 

35 

36 


The fauna survey allowed an inventory of the UFA 

fauna on reliable bases, the conclusions of which 

are that the animal population densities are globally 

low and mostly confined in the mountainous zones. 

It concluded too that there were no gorillas in the 

UFA. The survey on genetic influxes concluded 

firstly that there are migrations between the park 

and the UFA, however considering the new 

boundaries (following the local populations’ 

request), EBO park and the UFA are no longer 

bordering each other. 

The HVFC document is complete and well 

designed. Included in it are a PFNL survey, a work 

on fauna, and many keys. The consultation was 

carried out 

The transport of the personnel is carried out in 

better conditions and in vehicles put to safety; 

There is a procedure, which could not be tested, 

which is however well designed and corresponds to 

what can be done on yards of such nature 















response is 




Comments relating to Major CARs resolution: 

CAR 4 Make public a MS summary presenting the guidelines linked to 

FSC. 

The summary of the management scheme including the FSC guidelines was 

distributed (April 2007) against discharge to the 11 FFCs, and it is present on 

field. An updated document was distributed too on 16th October 2007, including 

the results of the impact survey and those of the FFC microprojects. 


documentary journal): 1, 2, 3 ; Our reprots on field, and the reports carried out 

during the in-house audits are positive (documents present at the level of the 

FFC). 

CAR 10 Make sure that all the contributors within the TRC process wear 

appropriate and well-maintained safety and working equipments; see that 

these equipments are worn and used correctly. 

Awareness sessions took place, a charter was elaborated by TRC, and the 

recruitment of the Health Hygiene Safety manager took place. 

The base administrative employee (who can act as an intermediary to the 

Health hygiene and safety manager) is nevertheless not yet ready as far as the 

procedures are concerned, which are not well known and the application of 

which is not monitored. A training is essential for that employee (and a 

substitute) so that they should have full knowledge of the company's hygiene 

safety, sanitary and social procedures (Nb 47 minor car). 











Version : 2.1 


documentary journal): 4,5, 6. Our reports on field and those made during inhouse 

audits are positive (systematic wearing of the IPE: the IPEs seem to 

have "become part of everyday life" for the TRC salaried employees). 

CAR 14 Set up procedures allowing to treat in a transparent and objective 

manner the problems presented by the personnel. 

Registration of the personnel: 

The company set up means (memorandum and reminder, simplification of the 

procedure, and so on) allowing to register the workers in an effective manner. 

Recruitments continue (a 13% increase in the number of personnel between 

May and October 2007 and a 3% increase between October and November 

2007) and the company’s strategy is to include systematically the registration 

requests at the CNPS. On 22nd November 2007, the company is at 88 % (65% 

of the personnel really registered and 23% of requests introduced (certified 

files)). 

It must be underlined that the administrative procedures for the treatment of the 

registration files are not effective, which explains certain differences observed. 

We checked and noticed that the new recruits continue preparing the files, 

which should allow the personnel department to forward them 

Procedure of resolution of conflict and personnel's grievance: 

The interview carried out with the workers and the checkings made show that 

the grievances treatment mechanism is improved and that the workers’ 

grievances are dealt with in a better way. 

CAR 27 Take into consideration the bordering zones constitution 

schemes and draw the consequences in terms of exploitation 

TRC initiated a survey on genetic influxes between the UFA and EBO park and 

a fauna survey, conducted by Dr Atanga EKOBO from WWF. The fauna survey 

allowed an inventory of the UFA fauna on reliable bases, the conclusions of 

which are that the animal population densities are globally low and above all 

confined in the mountainous zones. It concluded too that there were no gorillas 

in the UFA. The survey on genetic influxes concluded firstly that there are 

migrations between the park and the UFA, however considering the new 

boundaries (following the local populations’ request), EBO park and the UFA 

are no longer bordering each other. WWF therefore concluded that there is no 

contact between the animal populations of the two forestry sites. Dr ATANGA 

insists moreover on the importance of the anti poaching fight and on the quality 

of the initiatives started by TRC and co-financed with FGF. 


documentary journal): 11 and 12. It consists in surveys carried out by Dr Atanga 

Ekobo, who presented the conclusions and answered our questions during a 

meeting. 

CAR 34 On the basis of the grid set in the procedures manual, bring out 

the characteristics of the HVFC specific to the UFA. Detail the adapted 

measures planned by the company. 

The HVFC document is complete and well designed. Included in it Are a PFNL 

survey, a work on fauna, and many keys. 

The attributes were defined, the consultation was carried out, and all the 

comments made in the latest audit report and by the stakeholders were taken 

into consideration. The document is satisfactory as it is and the CAR is 

removed. 











Version : 2.1 

Nb 

O 

P 

It is advisable to regularly link up with the operational procedures (in the 

maintaining and monitoring chapters). 

A question remains as for the two zones put in full reserve: due to the 

invalidation of the first fauna survey, these zones’ boundaries are no longer 

valid (the new fauna survey does not seem to validate the importance of these 

zones). Nevertheless, they were kept because they appear as sets of protection 

within the official management scheme. 

That work on the HVFC should be included within the revised management 

scheme which will be handed in next year after 5 cutting areas (including 1-1 

cutting area which was abandoned at the time of the transfer, before starting the 

exploitation, after Administration’s authorization, that zone having been illegally 

exploited (plundered) one year before). 


documentary journal): 13 and 14. 

CAR 35 Make the workers’ mode of transport on site more secure. 

Personnel transport is carried out in better conditions and in vehicles put to 

safety (skips equipped with crushproof safety bonnets, seats in bedliner, 

tarpaulin in case of rain -); the transport procedures could nevertheless specify 

in a better manner the conditions of use of each vehicle (Skip for house to base 

transport, UNIMOG for base to yard transport) and so on - Moreover, it seems 

that pickup trucks may be used occasionally to transport smaller teams on site. 

If such is the case, a conversion of the pickup trucks should be planned. 


documentary journal): 15. Its application was controlled on field. 

CAR 36 formalize, communicate (to all the stakeholders) and implement a 

procedure aiming at making the evacuation of the injured between the 

operational sites, the bases and the hospital more secure. 

There is a procedure, which could not be tested, however which is in the nature 

of things and corresponds to what can be done on yards of such nature. That 

procedure plans the link between the workers of the exploitation site with the 

help of whistles, contact with the outside (forest base) thanks to air-powered 

horns, and presence of an ambulance on forest base. Two reserves led to nb 

47 corrective action request (ad hoc training of the administrative employee for 

the monitoring of IA (Industrial Accidents , IPE and medicine stocks), to P 

recommendations (case of the outside teams for which the procedure can be 

completed) and T (regular test of that procedure). 

That procedure seems effective, however, it is based on a good planning of the 

activity places (which should remain within distances allowing to transmit chirp 

alerts). One should see to the effectiveness of these steps in any situation. 


documentary journal): 16, 17, 18, 19. 

• Recommendations 

Bring about some regular changes in the procedures of exploitation and 

reduction of impacts in function of the monitoring results. The exploitation 

procedures should remain set on field reality, which should evolve towards a 

better consideration for the environment (see CAR 38 comment) 

plan an appropriate polluted waste reprocessing in the new base (household 

refuse composting, plastic and hydrocarbon reprocessing -) 

test regularly the evacuation procedure by simulations (see CAR 36 comment) 











Version : 2.1 

Q 

R 

S 

T 

U 

V 

W 

X 

update the IAs treatment and draw conclusions from them in terms of first-aid 

Continue an operational monitoring of corrective actions for all the 

nonconformities spotted during the monitoring operations (see CAR 41 

comment) 

complete the keys definition for the in-house audits, and post-exploitation 

monitoring operations (monitoring) (see CAR 41 comment) 

see to a strict application of the safety instructions (presence of first-aid 

workers, ad hoc medical equipment -) in the case of all the teams far from the 

base (in particular inventory teams) (See CAR 36 comment) 

perpetuate the collaborations with all university and scientific skills involved by 

TRC. See CAR 38 comment. 

maintain the consultation with Ndokbassaben’s community, concerning the 

construction of IBOTI NDKBSB road. 

Complete the personnel’s training scheme on the monitoring basis 

assess the strengths and weaknesses of the FFC projects 

11.3.2 - Conformity evaluation of implemented documents or process, refering to 

FSC responsible forest management referential 

• Main strong points of the applicant entity for certification 

The company has a good expertise in timber exploitation and processing. It is 

reactive, well equipped (major investments in progress with the building of a 

forest living base and equipment of a new factory on the industrial estate). It has 

been booming since its creation (see presentation of the company). 

With the efforts made to obtain the OLB label, then the FSC certification, the 

company moved towards taking into included consideration the procedures 

which it set up and adapted to its practices. 

Personnel management is satisfactory, and the company knows how to spot 

and value the expertise of its team. 

• Main weak points of the applicant entity for certification 

The step remains new, and should be controlled carefully. It still relies on a 

small number of people. 

11.3.3 - Elements subjects to controversy which need to be detailed 

No debatable element has been noted during that audit. 

11.4 - New Correctives Actions Requests resulting from the 

Complementary Audit 

11.4.1 - Minor Corrective Action Requests 

A minor corrective action request was set, following the shortcomings noted at 

the administrative employee post of the forest base (bad knowledge of the 

procedures, inadequate organization, and shortcomings of the IPE and 

medicine monitoring). That major post should not be neglected by TRC because 

the administrative employee is the intermediary of many certification procedures 

on field. 











Version : 2.1 

Nb 

47 


Complete the administrative employee’s training with 

the procedures which concern him in particular: IPE 

management, medicine and medical equipment 

management, management and monitoring of 

industrial accidents and more generally, of what 

concerns hygiene and safety. 


See CAR 10 comment. 


suggested 

Demand Number 

2 months 4.2 

11.4.2 - Major Corrective Action Requests 

No nonconformity was expressed during that audit. 

11.5 - Scope retained for the certification 

11.5.1 - Geographical limitation at the level of the entity 

The certification applies to all UFA 00-004. 

11.5.2 - Limitation at the level of the forest products 

All the timber forest products declared exploited on UFA 00-004 (long poles) 

11.6 - Proposals regarding the certification decision 

11.6.1 - Explication on all rating, weighting systems or other systems used 


No notation system was used to weight the referential criteria and requirements, 

each criterion of the referential having to be met by the forest entity. A 

nonconformity is therefore expressed at the level of a criterion, the former is 

noted when: 

- more than a third of the criterion keys are not met; 

or 

- the audit team considers that the key(s) noted as not met lead(s) to a criterion 

not met. 

11.6.2 - Clear description of all recommendations and conditions associated to 

the certification decision 

Groundless 


The company reached, on UFA 00-004, the conformity level required to obtain 

the FSC certificate. 

However, the company must be reminded that that level of conformity should be 

maintained in the future and that the efforts expended to reach that level should 

be continued with rigour. The company’s attention is drawn to the need to 

promote at any level the frame of mind allowing to maintain FSC requirements. 

The monitoring audits should set out to check the permanence of all the 

monitoring and correction systems set up within the scope of the step, and 

maintaining the forestry work quality. 











Version : 2.1 

Written on 17 th December 2007 

FSC Product Manager, 

Audit Manager, 

Nicolas BARRIERE 

Alain VALETTE 

11.7 - Decision and associated conditions 

Following the complementary audit carried out from 18th to 23rd November 2007 for 

UFA 000 004, the Forest Wood certification Committee met on 12 th February and 

delivered the following decision: 

Decision: 

Following the examination of the AR071205 1.2 version referenced 

audit report, the Forest - timber certification committee decides 

unanimously to grant a conditional certificate to the TRC company, 

under suspensive condition to meet minor corrective actions 

requests specified in the report. 

Moreover, the certification committee insists on the importance of a 

better definition, on scientific bases, of the conservation sets and 

wishes to be informed as soon as possible and for the next 

committee of the advance of the surveys in progress on this subject. 











Version : 2.1 

12 - Surveillance Audit n° 1 


12.1.1 - Date of the surveillance audit 

From 10 th to 18 th , February 2009 

12.1.2 - Composition of the audit team 

Audit Manager: 

Auditors: 

- Forest Management FSC qualified auditor on behalf 

of Bureau Veritas Certification / Eurocertifor, forest 

expert, independent consultant. 

- Forest Management FSC qualified auditor on behalf 

of Bureau Veritas Certification / Eurocertifor, forest 

expert specialised in environment, independent 

consultant. 

- Forest Management FSC qualified auditor for 

Bureau Veritas Certification / Eurocertifor, Forest 

Engineer specialised in social aspects, Employee. 

12.1.3 - Standard(s) used 

During the audits, we referred to the checklist (ref. SF03 FSC GF Cameroon 

checklist version 1.3) excerpt from FSC forest management standards adapted 

to Cameroon (ref. RF03 FSC GF Cameroon v1.3). 

The latest version was updated on the 10/06/08, and is available on the website 

www.certification.bureauveritas.com or at Bureau Veritas Certification France 

on request. 

12.2 - Data collection’s approach 

12.2.1 - Description of the audit’s program 

The audit program was the following: 

Monday, 9 th February 2009 

Douala 8.00 a.m. Auditors’ preparation meeting 











Version : 2.1 

Audit Team 

AV 

JP 

AV 

+ JP 

EN 

10.00 

to 

11.30 

a.m. 

11.30 a.m. 

Scoping opening meeting in the presence of 

- Mr Herbert REEF, REEF Share-holder, 

Netherlands 

- Mr José Quaresma, TRC General Manager; 

- Mr Jacques Huleux, Forest Management and 

Certification Manager 

- Mr Arnaud Tchokomeni, Manager of the Forest 

Management Department 

- Fasu, Traceability Manager 

- Mr William Lawyer, Responsible for Quality and 

Internal Audits 

- Mr Koupwa Théophile, SEPFCO Manager 

- Mr Jean Effalla, Deputy General Manager 

- Mr Erik Jan Sprangers, Financial and 

Administrative Manager 

- Mr Okon II Gilbert, Personnel Manager 

- Mr Njumboket Inoussa, Socio-economic Manager 

- Mrs Judith Tchouateu Fasu, Traceability Manager 

Adjustments to the audit program and documentary 

review (internal audits and procedures) 

3.30 p.m. Meeting with the traceability Manager 

4.30 p.m. 

2.00 p.m. 

3.00 p.m. 

4.00 p.m. 

7.00 p.m. 

Visit of the Industrial Estate factory: traceability 

monitoring and general state of the sawmill (changes 

observed since OLB audit in November); interview 

with various actors of the monitoring and traceability 

process 

Meeting with the traceability Manager and Ndogbong 

sawmill Manager: collection of information concerning 

the monitoring of processing activities. 

Visit of Ndogbong TRC factory. Work session with 

the Manager of the Industrial Estate Sawmill 

Visit of TRC sawmill in the industrial estate, and 

interview with the various actors of the monitoring of 

the traceability process 

Auditors’ summary meeting 

11.00 a.m. Work session with Personnel Manager 

4.00 p.m. Departure for Bangangté 

9.00 p.m. Arrival and Night in Bangangté 

Wednesday, 11 th February 2009 

AV 

AV 

+ 

JP 

Douala 

9.00 a.m. 

11.00 a.m. 

Work session with traceability Manager (approval of 

yield figures, review of FSC and OLB CARs) 

Work session with Jacques HULEUX and William 

LAWYER: answers to CARs and recommendations. 

Preparation of the necessary documents for the visit 

of FMU 004. 

3.00 p.m. Auditors’ departure to Ndokagnak 

6.30 p.m. 

Arrival in Ndokagnak and briefing meeting with TRC 

site Manager of FMU 00 004; interview with Mr. Cyril 

DUFOUR, ONF (RIL) trainer. 











Version : 2.1 

EN 

Thursday 12 th February, 2009 

AV 

JPG 

AV 

+ 

JPG 

EN 

UFA 00 

004 

11.00 p.m. Auditors’ summary meeting 

5.30 a.m. Departure to Ndokbassaben 

8.30 a.m. 

Arrival in Ndokbassaben and work session with 

Ndokbassaben FFC 

11.00 a.m. Departure to Ndjikinemeki 

12.30 a.m. 

Arrival in Ndjikinemeki and work session with 

Ndokbou FFC 

1.00 p.m. Departure to Nyokon 

2.00 p.m. 

Arrival in Nyokon. Work and approval session with 

TRC socio-economic Manager 

4.00 p.m. Work session with Nyokon FFC 

5.30 p.m. Departure to Nkongsamba 

9.30 p.m. Arrival and night in Nkongsamba 

7.00 a.m. 

7.00 a.m. 

1.00 p.m. 

4.00 p.m. 

- Visit of the ongoing exploitation (respect of forest 

management, RIL training, markings’ control and 

so on), documentary checking, Interview with 

workers, 

- Interview with workers (Administrative agent, 

cutters, truck drivers) 

- Interview with the Forest Economy agent in 

charge of the control and marking on TRC004 

site. 

- Visit of the forest base and timber yards 

Visit of the future life base (which should be used as 

from April 2009) in the presence of Eléonore Schmidt 

and Manuel Domingues 

Visit of ACA 1-4 (exploitation 2008) and 1-5 

(exploitation 2007): traceability control, respect of 

reduced impact logging methods, analysis of 

procedures for cutting areas closure and postexploitation 

assessment, assessment of the good 

implementation of RIL procedures. Presence of 

Jacques Huleux, Arnaud Tchokomeni, traceability 

department and post-exploitation monitoring 

department. 

Visit of the building site and of engineering structures, 

ACA 2-1. Presence of Jacques Huleux, Arnaud 

Tchokomeni, traceability department and postexploitation 

monitoring department. 

Meeting with the site Manager and Mrs Eléonore 

Schmidt, consultant, advisor for certification actions 

5.30 a.m. Departure to Ndokagnak 

10.00 a.m. Arrival in Ndokagnak and visit of Ndokagnak base 

11.00 a.m. Departure to FMU 00 004 

Arrival in FMU 00 004 – Visit of the former base and 

the three sites of the camp that are being built. 

11.50 a.m. Interview with the workers in charge of the building 

and the Manager of the mechanics’ base of the new 

camp. 











Version : 2.1 

Friday, 13 th February 2009 

AV 

JPG 

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+ 

JPG 

EN 

Audi 

t 

Tea 

m 

UFA 

00 004 

2.30 p.m. 

Work session with the administrative agent of FMU 

00 004 

4.00 p.m. 

Return to Ndokagnak base and work session with the 

staff store Manager. 

6.45 p.m. Work session with workers’ representative 

6.15 a.m. 

7.00 a.m. 

7.00 a.m. 

Departure to FMU 00 004 

Arrival in FMU 00 004 – boundaries’ control for 

currently exploited ACA, stumps’ control, Visit of the 

ongoing exploitation 

Departure to Iboti: Closure of ACA 1.2: operation of 

grounds fixation and erosion fighting on batters of fills 

along the road to Iboti. Presence of Jacques Huleux 

and Arnaud Tchokomeni. 

12.00 a.m. Return to Ndokagnak base 

8.30 a.m. 

Work session with Yingui FFC president 

(Cantonment of Ndem and Ndocktouna) 

9.50 a.m. Work session with Yingui DHC doctor 

11.00 a.m. Visit of Ndokagnak infirmary 

1.00 p.m. Auditors’ departure to Douala 

4.00 p.m. Auditors’ arrival in Douala 

4.45 p.m. 

Saturday, 14 th February 2009 

Auditors’ work session 

Douala 9.00 a.m. Auditors’ departure to KUMBA 

12.00 a.m. Auditors’ arrival in KUMBA 

AV Kumba 1.30 p.m. KUMBA Traceability and controlled wood 

Analysis of the industrial site’s conformity and 

assessment of how ongoing CARs are being 

JPG 

answered (environmental aspects): visit of the 

2.30 p.m. 

garage, the log yards, the sawmill, the waste yards, 

the sharpening unit, the unloading station, the 

infirmary, the store and so on. 

EN 

2.30 p.m. Visit of the industrial site and interview with workers 

4.30 p.m. Work session with the administrative agent 

Sunday, 15 th February 2009 

UFA 

11 001 6.00 a.m. Auditors’ departure to KUMBA FMU 11 001 

10.30 a.m. Auditors’ arrival in OKOROBA base 











Version : 2.1 

AV 

JPG 

EN 

Audi 

t 

Tea 

m 

10.30 a.m. 

10.30 a.m. 

1030 a.m. 

1.30 p.m. 

Visit of the ongoing exploitation (respect of forest 

management, exploitation methods, surveillance of 

ACA boundaries, stumps control, markings control 

and so on) documentary checking, personnel 

interview (work laws, health and safety and so on). 

Visit of the forest base 

Presence of Eleonore Schmidt and Patrice NGOKOY 

Visit of ACAs 1-2 and 1-3. RIL, road opening, 

engineering structure, ACA closure, HCVF 

procedures. Presence of Jacques Huleux, Arnaud 

Tchokomeni, traceability department 

Work session with local communities of OSSELE and 

OKOROBA 

Approval meeting with site Manager 

Kumba 2.30 p.m. Return to Kumba 

6.00 p.m. Arrival in Kumba 

6.30 p.m. Summary meeting with auditors 

Monday, 16 th February 2009 

Audit Team 

Bonaberi 

Industria 

l Site 

7.00 a.m. 

9.30 a.m. 

Auditors’ departure to Bonaberi 

Arrival in the industrial site of Bonabéri and meeting 

with the traceability Manager and the site Manager: 

collection of information on processing monitoring 

11.00 a.m. Auditors’ departure to Douala 

11.30 a.m. 

2.00 to 6.30 

p.m. 

Tuesday, 17 th February 2009 

Audi 

t 

Tea 

m 

AV 

+ 

JPG 

Douala 

8.00 a.m. 

10.00 a.m. 

Auditors’ work session, listing of all documents 

required from the company, first draft 

Auditors’ summary meeting, documentary review 

Visit of Douala Harbour 

Work session with the certification manager and 

collection of complementary information 

EN 

11.00 a.m. Work session with the social Manager 

EN 2.00 p.m. Approval meeting with the personnel Manager 

3.00 p.m. 

Work session with the certification Manager and 

collection of complementary information. Definition of 

FSC and OLB Corrective Action Requests 











Version : 2.1 

Audi 

t 

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4.00 p.m. 

Wednesday, 18 th February 2009 

Audi 

t 

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EN 

8.00 a.m. 

Debriefing meeting with management 

Consolidation of corrective action requests 

9.15 a.m. Approval meeting with personnel Manager 

10.00 a.m. Work session with the Deputy Manager 

2.30 to 5.30 

p.m. 

5.30 p.m. 

Debriefing meeting and closure of FSC surveillance 

audit, FSC scoping, FSC CW extension audit and 

OLB complementary audit in the presence of: 

- Mr José Quaresma, TRC General Manager; 

- Mr Jacques Huleux, Forest Management and 

Certification Manager 

- Mr Jean Effalla, Deputy General Manager 

- Mr Koupwa Théophile, SEPFCO Manager 

- Mr FRAGONARD Arthur, Rotary Cutting Factory 

Manager 

- Mr TCHOUPO Serge, Deputy Production 

Manager of Ndogbong sawmill 

- Mr Arnaud Tchokomeni, Assistant Manager of the 

Forest Management Department 

- Mr William Lawyer, Internal Audit and Quality 

Manager 

- Mr Erik Jan Sprangers, Financial and 

Administrative Manager 

- Mr Okon II Gilbert, Personnel Manager 

- Mr NGOKOY N. Patrice, FMU 11 001 Exploitation 

Manager 

- Mr RUI DA TRIUDADE COSTA, FMU 11-001 

Site Manager 

- Mr Njumboket Inoussa, Socio-economic Manager 

- Mrs Judith Tchouateu Fasu, Traceability Manager 

- Mr EBONDA Georges, IE Sawmill Yield Manager 

End of the FSC surveillance audit, the FSC CW 

extension audit, and the OLB complementary audit. 

Total number of worked days for the surveillance audit: 

Declaration of the number of worked days spent assessing the forestry 

organisation 

- Scoping and preparation work: 3 days 

- Time spent assessing the recording documents, interviewing people and 

stakeholders and visiting sites: 15 days 

- Time spent travelling to/back from the region of the assessed forest: 4,5 

days 

- Layout and debriefing 4,5 days 











Version : 2.1 

12.2.2 - Site Visit(s) 

Control points were chosen according to the weaknesses of the company, 

notably identified during the OLB audit of November 2008. Other points were 

assessed, such as forest traceability or points that could bring further 

information concerning the corrective actions requests and recommendations 

expressed during the previous FSC audit. 

Place Controlled Points Justification 

FMU 004 

- RIL training, markings control and 

so on, documentary checking, 

interview with workers 

- Interview with workers 

(Administrative agent, cutters, 

dump truck drivers) 

- Interview with the Forest Economy 

Agent in charge of control and 

marking on TRC 004 site. 

FMU 004 

Villages 

neighbouring the 

FMU 

Visit of the forest base 

12.2.3 - Documentary Review 

- Visit of timber yards 

- Visit of the ongoing exploitation 

(respect of forest management) 

- Visit of the future life base (which 

should be finalised as from April 

2009) 

- Visit of the former cutting area and 

closed ones 

- Social conflit resolution status 

- Project to support the 

development of local resident 

communities 

Checking that TRC certification 

procedures are respected and the 

implementation of the ongoing 

CAR. 

Respect of procedures and 

overall state 

Respect of forest management 

procedures, interview with 

workers 

Social interviews 

Respect of the procedure for 

cutting areas’ closure 

Assessment on whether the 

conflict management procedure is 

respected 

Assessment of actions taken by 

the company 

Exploitation, forest management, environmental and internal audits 

- Internal audit report. Anti-erosion fighting device, FMU 00-004, from October 

28 th to November 2 nd , 2009 

- Internal audit report and debriefing report. FMU 00-004, from January 20 th to 

25 th , 2009 

- Monitoring form for the implementation of corrective actions requested 

during the internal audit of January 2009 

- Identification of High Conservation Value Forests within FMU 00-004, WWF 

Doctor ATANGA, August 2008 

- High Conservation Value Forests within FMU 00-004, Version 6, January 

2009. 

- Hygiene and Safety Procedures (9 procedures) 

- Forest Management procedures (13 procedures) 

- Environmental Impact Assessments and EMS of FMU 00-004, December 

2006 











Version : 2.1 

- Assessment of the implementation of EMS in FMU 004, TRC, December 

2008 

- Rescuers training of to first aid, TRC social department December 2008 

- Work rescue team training report, TRC 2008 

- Closure authorisation for cutting area 1.5 in FMU 00 004, MINFOF, 17 th 

June 2008 

- Botanical inventory mission report in FMU 00 004 AAC 1.4, September 2007 

- Monitoring and assessment protocol of forestry exploitation’s impact on 

plants with high conservation value, NTFPs and promising stalks, Forest 

Management Department 

- Inventory of phytosanitary products used by the company: SARPAGRUM 

AF200B, concentrated SARPAGRUM, SARPALO 

- Evacuation simulation report in case of emergency arising on the site of 

FMU 00-004 December 2008 

- Monitoring report on safety instructions – FMU 004, from 28/10 to 

02/11/2008 

Social Aspect 

- Minutes of the meeting concerning the classification and exploitation of FMU 

00 004 held on 31 st October 2007, at ONIMAR Motel, Ndjikinimeki. 

- Minutes of the consultation meeting between the administration and resident 

communities of FMU 00 004 about road issues held on 31 st October, 2007 in 

Ndjikinimeki 

- Assessment of the implementation of the environmental management plan – 

FMU 00 004 Campsite 

- Correspondence from workers’ representatives of FMU 00 004 dated 28 th , 

January 2009, concerning the grievances prior to moving in the campsite 

- Correspondence from the Forest Management and Certification Manager to 

workers’ representatives, dated 16 th January, 2009, concerning the draft 

internal rules for FMU 00 004 campsite 

- Draft internal rules for life in FMU 00 004 campsite 

- Minutes from workers’ visit of the campsite, dated 18 th July 2008 

- Expert’s report of Maître NGUEMNANG Jean Paul concerning the dismissal 

of two TRC workers’ representatives dated 13 th August, 2008 

- Correspondence MINFOF n° 410/NDT/MINFOF/DPLT/SPF o f 28 th March, 

2008, notifying the start-up of construction works for a bridge and a 

campsite in FMU 00 004 

- Correspondence n° 0610/L/MINFOF/SG/DF/SDIAF/SA of 13 th March, 2008, 

concerning the authorisation of wood felling in cutting areas 1-1, 1-5 and 2-1 

for the building of the bridge crossing the Makombé river and the settlement 

of a campsite in ACA 4-4. 

- TRC correspondence to Littoral DP MINOF, concerning documents’ 

transmission for the monitoring of construction works of the bridge and the 

campsite in FMU 00 004 dated 19 th March, 2008, 

- Information note to all workers of FMU 00 004 concerning - 

Environmental Impact Assessments campsite project, dated 19 th January, 

2008. 

- TRC correspondence to MINFOF concerning the settlement of a campsite in 

FMU 00 004, dated 26 th July, 2007 











Version : 2.1 

- Minutes of the meeting held on 19 th April, 2008 with the staff of FMU 00 004, 

to reactivate the social dialogue 

- Correspondence from the workers concerning the preliminary grievances 

before entering FMU 00 004’s campsite, dated 24 th January, 2008 

- Environmental impact survey of the workers’ campsite construction project 

in FMU 00 004. 

- - Environmental Impact Assessments specifications for the construction 

project of a workers’ campsite in FMU 00 004. 

- FMU 00 004 workers’ memorandum dated 24 th January, 2008 

- Social and environmental feasibility survey for the building of a workers’ 

campsite in FMU 00 004, dated 4 th February, 2008. 

- Specifications of the social and environmental survey for the building of a 

workers’ campsite in FMU 00 004. 

- Construction plans for the accommodation of FMU 00 004 campsite 

- Minutes of the total conciliation of workers made redundant on FMU 00 004 

site 

- Statement from the Hygiene, Safety and Environment Manager, and the 

Social Manager, Dated 24 th March, 2008 

12.2.4 - Consultation with stakeholders since last audit, and during this audit 

Prior to the surveillance audit, we received comments from the following 

stakeholders: 

Administration 

- Mr Henri Charles AKAGOU ZEDONG, Inventory and Forest Management 

Division 

Research Organisation 

- Mr Paolo Cerutti, CIFOR Researcher, Yaoundé 

Local Communities 

- Mr BISSEMOU Joël, President of the monitoring committee for the project of 

the province road n°16 Ndjikinimeki-Yabassi. 

- Mr Oscar BELIAS, General Secretary of FFC n°3 (Ndo ckbassaben) 

During the audit, we held interviews with the following stakeholders: 

- Mr MALOUME MAMA, Head Doctor of Yingui DHC 

- Mr OBIENGNI Thomas Dupont, Ndjikinimeki Mayor (on the phone) 

Local Communities 

Ndockbou FFC 

- Mr YETENA André, FFC member 

Ndocktouna and Ndem FFC 

- Mr EKOKO Isaac, Representative of villages’ headmen and FFC President; 

Nyokon FFC: 

- Mr KIARI Jules, Nyokon FFC President 

- Mr BITCHA Johnny, Nyokon FFC Member 

- Mr BELOMBO Bruno, Nyokon FFC Member 











Version : 2.1 

- Mr MBIRWANG Thomas, Nyokon FFC Member 

- Mr BITEP KIARI Bertrand, Nyokon FFC Member 

- Mrs AMBANG Esther, Nyokon FFC Member 

- Mr PIAH Thomas, Nyokon FFC Member 

- Mr NGAGNI Emmanuel, Nyokon FFC Member 

- Mrs KITHABO Julienne, Deputy Mayor of Makénéné commune 

Administration 

- Mrs GUIMBANG Rose, Administration Forest Agent, in charge of traceability 

controls in FMU 004. 

12.2.5 - Interviews with key employees during this audit 

During this audit, we interviewed the following members of staff: 

Douala Site 

- Mr EFFALLA, Deputy General Manager 


- Mr Arnaud TCHOKOMENI, Site Engineer for FMU 0004 

- Mrs Pauline ZEH-MBIAM, Social Manager 

- Mr Inoussa NJUMBOKET Socio-economic Manager 

FMU 00 004 Forest Site 

- Mr Manuel DOMINGUES, Site Manager 

- Mr Georges AZANGUE, Exploitation Manager 

- Mr Jean Yves BOUKONG, Monitoring Manager 

- Mr MOUNGANG Alain Mathurin, Administrative Agent 

- Mr Cypra EBAI – Driver of Truck 05/23 

- Mr Ernest VINA - Cutter 

- Mr Jean Yves BOUKONG - Engineer 

- Mr Olivier BIKOY – Post Exploitation Team 

- Mr Adolphe MAKA - Post Exploitation Team 

- Mr Paul NLEND – Building site Cutter 

- Mr Eben EBENEZER – Road Team Headman 

- Mr Oscar ZANGA – Bull Driver 

- Mr MBIE Bienvenu, Cutter (prospector), Workers’ Representative 

- Mr OLOM Prosper, D7 Driver, Workers’ Representative 

- Mr NSOKE Maurice, Prospector, Deputy Workers’ Representative 

- Mr ATANGANA MBARGA, Prospector, Deputy Workers’ Representative 

Ndockagnack Base 

- Mr OKO BALEMBA Jean Louis, TRC staff store Manager 

- Mr FOSSOUO Charles Amély, TRC Nurse 

FMU 00 004 new Mechanics base 

- Mr TOUCK BATOUM Michel, mechanics workshop Manager 











Version : 2.1 

FMU 00 004 Campsite construction team 

- Mr DJONTU Pierre, campsite construction team Headman 

- Mr EPOH Moïse Joël, Carpenter 

TRC Dibeng Fence 

- Mr DJAKTOING DJAOKAMLA, Guard 

- Mr DOURMOUSSOU WAIDANDI, Guard 

- Mr BAYANG Emmanuel, Guard 

- Mr IGRE MENKREO, Guard 

The main goals of the interviews with the various actors were to assess the 

awareness and mastery of procedures following from the requirements, and to 

inform the auditors on the social climate in TRC. 

Overall, strong tensions remain within the company, partly due to the economic 

crisis that prevented the payment of yield bonuses in November 2008, and the 

uncertainties linked to the settlement in the new forest base. Numerous 

employees left the company, on the FMU 00 004 site in particular (see below). 

12.2.6 - Other Audit Techniques 

Not applicable 

12.2.7 - Change in the management of the certified organisation 

Since last audit, assignments’ changes were carried out. The overall structure 

of the company is maintained. As for the general organisation, there are a few 

major changes: 

- Mr Fernando ALVES replaces Mr PINTO as Exploitation Manager for FMU 

11 001 

- Mr Georges AZENGUE (Yield Engineer) and Mr Jean Yves BOUKONG 

(Monitoring Engineer) were assigned to the management of FMU 00 004 

- Mr William LAWYER is now responsible for internal audits as well as safety 

with the assistance of a person in charge of forest safety, and another in 

charge of factory safety. 

TURN OVER 2006 

TURN OVER 2007 

FORECASTED TURN OVER 2008 

8 260 000 000 FCFA 

11 030 000 000 FCFA 

13 540 000 000 FCFA 

EMPLOYEES 2008 1 393 

Logging Sites Yield 117 460 m 3 

Long Poles Purchase 11 290 m 3 

Entries Sawmills / Factories 79 929 m 3 

Sawn Timber 28 936 m 3 

Material Productivity 36,20 % 

Entries Rotary Cutting Factory 26 690 m 3 

Veneering Yield 10 234 m 3 

Material Productivity 38,30% 











Version : 2.1 

Significant Evolutions 

Installation of the head office in the Industrial Estate 

Rotary Cutting in Bonaberi 

12.2.8 - Surveillance audit debriefing 

The debriefing of the surveillance audit took place in Douala, on 19 th February, 

2009, in the presence of the TRC management team. The audit’s conclusions 

were accepted by the company, who acknowledged the observed lapses. 

Those lapses are the consequence of a loss of speed, owing to the significant 

developments carried out the previous year to the detriment of the consolidation 

of what was already acquired. As the audit’s preliminary conclusions were 

communicated to the hierarchy as soon as the audit team returned to Douala, 

measures were announced during the debriefing meeting. One of the important 

decisions following from this audit was the appointment of Mrs Eléonore 

SCHMITT as permanent delegate for REEF Netherlands for questions related 

to certification. 

12.3 - Observations from the audit team 

12.3.1 - Actions taken to answer Corrective Actions Requests previously 

expressed 

DAC 

N° 

CAR title 

Demand 

N° 

Actions taken by the certified 

organisation to withdraw the 

CAR 

Withdrawn 

/ 

Maintained 

Withdrawal 

Date 

18 

47 

Supply the final 

convention and the 

classification decision 

Complete the training of 

the administrative agent 

to the procedures related 

to: IPE management, 

medicines and medical 

material management, 

industrial accidents’ 

monitoring and 

management, and more 

globally, all that is related 

to hygiene and safety. 

1.1 

4.2 

This corrective action request will 

be maintained until the final 

convention is delivered to the 

entity. However, it is public 

knowledge that the delivery of 

such document can be a lengthy 

formality in Cameroon. TRC 

proved its good will by officially 

writing to the Ministry, and 

nothing else can be done to 

speed up the procedure. 

The training was carried out. The 

administrative agent was 

interviewed. His knowledge of 

the requirements of his post has 

improved. The procedure related 

to his post was improved. 

Minor 

maintained 

Withdrawn 18/02/09 











Version : 2.1 

12.3.2 - Assessment of the global conformity level of the forestry organisation 

Until recently, there were two management levels within the company (i) in FMU 

00 004, procedures matched the requirements of FSC standards, and (ii) in 

other sites, a quality manual summarised the practices in force. The company 

transposed the FMU 00 004 procedures to other sites, and adapted them into 

the “TRC procedures”, which are split into 5 documents - forest management, 

HSE, human resources management, quality, traceability - which allow the 

implementation of the same procedures on all sites. Special cases are dealt 

with through specific procedures. A preliminary consultation with operational 

staff on all sites allowed adapting all the procedures during this operation. 

Beyond the alteration of the confidence level among the staff, the development 

of the company through the extension/installation of new sites did not allow 

consolidating the experience that would have maintained the evolution trend 

trigged when the certification was awarded. The observations made and the 

communication throughout the audit made all the management team aware of 

the situation and allowed them to take the necessary steps to catch up with the 

required conformity level. 

Results from the company’s monitoring activities remain too superficial and give 

the impression that the monitoring is only used to prepare audits rather than to 

work thoroughly to improve actions’ efficiency. In January 2009, the company 

carried out an internal audit related to the implementation of certification 

procedures. This audit helped identify a number of corrective actions to be 

carried out. A form for those actions’ monitoring provides a clear vision of the 

implementation status at the end of January 2009 and shows that most of those 

measures were implemented at the time of the audit, as observed by the audit 

team. 

Although it was improved by defining responsibilities and lead-times for the 

implementation of each task, the monitoring-assessment lacks objectives. It is 

essential to create monitoring and piloting tools with detailed objectives and 

indicators. On the other hand, the department for monitoring-traceability and 

products’ identification is efficient within the company. 

The company implemented a procedure for the monitoring of post-exploitation 

that covers most of the company’s exploitation activities. A department with 5 

employees is responsible for this monitoring. Assessment reports are regularly 

issued and transferred to the forest management and certification department. 

Corrective actions are implemented when dysfunctions appear. However, 

results are not yet analysed to obtain a synthesis of activities results and to 

assess the efficiency of the actions carried out. 

More specifically, after observing various non-conformities in former cutting 

areas (see CAR 38 following from the complementary audit n°1), the company 

implemented operational and monitoring measures to limit erosion in the most 

sensitive areas, in partnership with Dschang University. Within the scope of this 

process, two sites were identified along the road to Iboti (significant fills 

downstream from the road ahead of the catchments area). 

In 2007, a contract signed with Iboti FFC planned the involvement of local 

populations in the revegetation of those batters, based on Pennysetum and 

Pannicum. For technical reasons, those results were not satisfactory. In 2008, 

the company carried out the same works by its own, adapting plantation 

techniques, but the failure rate remained significant. In collaboration with 

Dschang University, a new project is being studied. It includes the batters’ 











Version : 2.1 

fixation with an exotic plant (the Vetiver) and then the introduction of local 

species to rebuild the forest crown. 

All the HCVFs were identified and mapped. The committee’s request expressed 

when the certification was awarded is therefore satisfied. 

The available documents identify 5 conservation values out of the six existing 

ones. The definition of HCVFs was carried out based on a solid scientific 

background 1 . Occasionally, HCVFs’ definition and their combination with daily 

operations could be further detailed. There are no specific measures for the 

monitoring of HCVFs, which are actually monitored via reports related to (i) 

post-exploitation, (ii) bridges destruction, (iii) soils protection, (iv) multiresources 

inventory, (v) conflicts management and so on. The document related 

to HCVFs 2 suggests monitoring indicators, but those actually are monitoring 

tools (reports’ consultation, see above). There should be an HCVFs’ monitoring 

tool detailing all the conservation values, indicators, monitoring frequency, and 

possibly threshold values and so on. 

The standard control of FSC brand use was carried out and lead to a positive 

result. 

12.3.3 - Potential change in the field of application of the certificate 

No change is required concerning the field of application of the certificate. 

12.4 - Proposal concerning the certification decision 

12.4.1 - New recommendations 

Y 

Z 

AA 

AB 

AC 

Plan and communicate sufficiently on workforce needs related to the 

recruitment procedure for local staff. 

Interviews with local communities and the company evidenced the fact 

that the workforce needs (related to the procedure for the recruitment 

of local staff) are often expressed by the company through FFCs and 

are not communicated well enough and in due time. This would avoid 

misunderstandings and possible tensions within the communities. 

Open a register for wood treatment and chemical products use (dates, 

quantities used, product used, sites, volumes treated, IPE, and so on). 

Continue the efforts to ensure PPEs are worn on posts. On the road 

opening site, the D7 driver did not wear hearing protection. 

Maintain the partnership with Dschang University to implement the 

relevant measures to fight against erosion on Iboti roads’ batter, while 

seeing to the control of the impact of exotic plants that might be 

introduced (such as Vetiver) and the strict respect of criteria 10.4. 

Progressively detail the HCVFs definition by integrating the main 

waterways (forest galleries), wet areas, cliffs and so on and by 

adapting daily management measures according to sites’ sensitivity 

(notion of gradients’ constraints) 

1 Identification of High Conservation Value Forests in FMU 00-004, WWF Dr ATANGA EKOBO, 

August 2008. 

2 The High Conservation Value Forests in FMU 00-004, Version 6, January 2009. 











Version : 2.1 

AD 

AE 

AF 

AG 

AH 

AI 

Improve the identification of waste wood volumes resulting from 

exploitation operations and implement waste monitoring measures. 

See to the regular control of emergency evacuation procedure and the 

correction of any observed lapse. 

See to the scrupulous monitoring of sanctions procedure and the filling 

of all planned boxes. 

Monitor the operational consequences of industrial accidents’ surveys. 

Make all the staff aware of the need to implement staff management 

procedures, especially site managers. 

While analysing sanction forms, some cases of unjustified and 

hazardous sanctions were observed (lapse between the technical 

opinion of the administrative agent, the sanction suggested, and the 

final sanction suggested by the site manager). Several cases of final 

sanction refusal were reported. Work legal texts in force and the 

internal rules are not exhaustive as to faults’ types. However, from the 

interviews carried out, it seems that some faults are qualified 

differently, according to the day, and the person concerned. In that 

respect, sites management teams’ abilities must be reinforced (site 

managers and administrative agents). Obviously, all the staff will have 

to be made aware of the themes dealt with. 

Overall in the company, both in factories and in forest sites, we 

observed that workers’ management hardly considers some of the 

legal prescriptions and even internal procedures developed and 

implemented to limit confusion and abuses. This staff management 

leaves aside the administrative managers recruited to assist site 

managers in their daily tasks. 

Several cases of sanctions tied to the yield bonus were reported in the 

company. It should be reminded that workers’ sanctions should not be 

tied to their bonus, as bonuses are set according to a fixed threshold 

for a given activity sector and in proportion to the professional 

classification. This bonus is fully paid to a worker if the set yield 

threshold is achieved and the worker is present during the entire 

period. It is therefore not justified to cut the bonus down if those two 

conditions are fulfilled. A few days’ suspension would be sufficient. 

This would have an impact on the worker’s effective participation and 

hence, on his/her bonus. 

Identify formally the territorial Take Charge Units of TRC sites and 

assess the monitoring of Workers living with AIDS/HIV treatment. 

As part of the collaboration between TRC and the GFBC AIDS/HIV 

Program, voluntary detection campaigns were organised. The 

participation rate is of approximately 30% (50 people more than in 

2008). Knowing the HIV prevalence rate within the company after the 

detection campaigns, the actions can be reinforced. As part of this 

collaboration with the AIDS program, confirmation tests were supplied 

to the social department in order to make the procedure more efficient. 

The company takes charge of 50% of the inherent medical cost, but 

cases revealed at the level of the social department are not numerous, 

which constitutes a weakness in the treatment and monitoring of 

TVVS. The detected and declared HIV positive cases were directed 

towards the relevant Take Charge Unit for each site (Nylon Take 











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AJ 

AK 

Charge Unit (IZ), Bonassama Take Charge Unit and CEBEC hospital 

(Bonabéri), Eséka Take Charge Unit, Kumba Take Charge Unit, Manfé 

Take Charge Unit). The collaboration with those Take Charge Units 

can allow an assessment of how efficient the company is in taking 

charge of the Workers living with AIDS/HIV. 

Extend the training of educative pairs to other sites and increase 

awareness among workers concerning the fact that the company can 

take charge of Workers living with AIDS/HIV. 

As for now, the training of educative pairs is limited to Douala industrial 

sites and FMU 00 004. This choice was made considering that Douala 

was close. Awareness-building actions were carried out within the 

company by the social department with trained educative pairs in 

collaboration with GFBC HIV/AIDS program. 

Assess workers’ involvement in the family clusters’ program and 

identify actions that would help increase the number of workers 

registered for the program. 

Thanks to the family clusters’ program, the company sets up cash flow 

facilities for workers and their family, for the costs of illnesses or 

accident not linked to their work. After several months of existence, it 

seems the registration is globally slow. There is confusion in workers’ 

mind between the notions of family cluster and child benefit. 

The low registration rate is also caused by a significant turn-over 

among the staff on the company’s sites. Staff transfers from site to site 

make it difficult to take charge of the families, mostly those who didn’t 

register for the family cluster program. 

For the time being, this notion is almost perfectly operational in FMU 

00 004, but not in other sites. 

12.4.2 - New Minor Corrective Action Requests 

In the current context, TRC certification deserves the greatest attention and 

rigour. 

Some commitments were not fully respected. In addition, the company was 

disrupted by the crisis, the social outburst of February 2008, and the 

implantation of the factory in the industrial estate. 

Therefore, the audit team reported numerous lapses related to: 

- The consideration of social and ecological environment 

- Compliance with TRC procedures 

- Overall, legality and complete respect of FSC requirements listed point by 

point. 

N° Minor Corrective Action Requests expressed 

Keep an updated list of chemical products used within 

48 

the company (treatment products and glues as well) 

Complete the closure procedure for cutting areas and 

49 

systematically implement it 

50 Pursue efforts to generalise RIL practices in the FMU 

Suggested 

Realisation Leadtime 

Next surveillance 

audit 


audit 


audit 

Demand Number 

6.6.1 

1.5 

6.2 

5.3 

6.5 











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N° Minor Corrective Action Requests expressed 

51 

52 

53 

54 

55 

56 

Control the impacts linked to the sedimentation 

phenomenon in waterways during civil engineering 

construction works 

Complete and apply the annual monitoring procedure 

for HCVFs in order to assess the efficiency of forest 

management measures 

Develop and produce the monitoring balance for 

HCVFs 

Produce a summary of the indicators’ monitoring 

results. 

Improve the indicators for the monitoring of forest 

management 

Set up a training schedule based on monitoring 

results, and including all the company’s actions 

Set up a supervision tool for the monitoring 

57 

(frequency, modality, indicator, objective, monitoring) 

Increase workers’ awareness of emergency 

58 measures, chiefly concerning chemical products 

dumping 

Sensitise all workers, including the management 

59 

team, to the strict application of procedures 

Define the company’s intervention policy concerning 

the support to local resident communities (and 

60 communes) and clarify the concrete and operational 

modalities for the implementation of started/pending 

actions in a concerted manner. 

Define indicators (performance and impact) for the 

61 implementation of the social policy (initiatives started 

as part of the actions supporting rural development) 

62 

63 

64 

65 

Continue the implementation of measures planned in 

the EMS 

Harmonise the professional classification of 

administrative agents operating on all the company’s 

sites 

Approve the job descriptions and implement an 

efficient system for staff assessment 

Maintain the mediation with Ndockbassaben local 

communities in order to clear misunderstandings 

Suggested 

Realisation Leadtime 


audit 


audit 

Demand Number 

6.5 

9.3 

9.4 


6 months 8.5 


audit 

6 months 


audit 


audit 

8.1 

4.1 

4.2 

6.6.3 

7.3 

8 

8 

6.6.8 



audit 


audit 


audit 

6 months 


audit 


audit 

4.1.4 

4.1.5 

5.4.2 

4.1.5 

5.4.2 

8.5 

6 5.1 

7.1 

8.2 

1 

4.3 

1 

4.3 

1 

4.3 

Comments on Minor CARs 

Minor CAR 48: 

There is no updated exhaustive list of the chemical products used in the 

company (see complementary recommendation). 

PR080202 FSC FM public report TRC v22 [03 06 09].doc Page 103 of 132










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There is a list of chemical products, but it is not up to date (insert new products), 

which is why this CAR is minor. 

Minor CAR 49: 

The current procedure includes the systematic dismantling of civil engineering 

structures (bridges, pipes and so on) which are likely to block water draining 

once the cutting area is closed. As observed, this procedure is not implemented 

in a fully satisfactory manner, chiefly when the dismantling concerns old tracks 

that were re-opened for exploitation, which is why this CAR is minor (see 

example AC 1.4, track 89= former Ndiki track). 

Minor CAR 50: 

Some lapses were observed, notably concerning reduced impact skidding and 

hauling, which may still be improved in sharp slope areas where soils are still 

systematically exposed, and even at times, according to the sharpest slope line. 

Overall, excavations remain significant. However, the width and the location of 

skidding tracks are to be improved. Reduced impact exploitation is globally well 

implemented, but some improvements remain to be carried out, which is why 

this CAR is minor. 

Minor CAR 51: 

Although roads are built in a satisfactory manner, some technical inadequacies 

were noted concerning water passages, and waterway preservation. Bridges’ 

making is not satisfactory as it doesn’t allow the full monitoring of sedimentation 

risks. There is a need for a procedure for the monitoring of erosion 

phenomenon and sedimentation in waterways during civil engineering building 

operations: (i) procedures complying with international good practices in this 

area, (ii) reinforcement of staff training on track opening and civil engineering, 

(iii) works’ monitoring indicators and procedure, (iv) identification of points of 

non-conformity, with regards to the code of good practices, on the network of 

main and secondary tracks, which are to remain open, (v) identification of 

monitoring and management measures for non-conformities. 

Minor CAR 52: 

The document referring to HCVF 3 supplies monitoring results, but in fact, those 

are the documentary resources needed for the monitoring (post-exploitation 

reports, bridges’ destruction reports, soils’ protection annual report and so on). 

This document does not clearly define monitoring indicators for the objective 

measurement and verification of implemented actions’ efficiency. The company 

developed the monitoring tools but a global monitoring spreadsheet is 

necessary to follow up exploitation impact on HCVs, which is why this CAR is 

minor. 

Minor CAR 53: 

HCVF monitoring report is not available and was therefore not made public. 

Minor CARs 54- 55- 56- 57: 

See comment below. 

Minor CAR 58: 

Operators were not sufficiently sensitised and trained to taking emergency 

measures in case of hydrocarbon accidental dumping (if the tank falls over, for 

instance) or other incidents likely to cause pollution. 

3 Forests with High Conservation Values within FMU 00-004, Version 6, January 2009. 











Version : 2.1 

Minor CAR 59: 

The audit team spotted lapses caused by the non-application of some 

procedures which were developed by the company to suitably meet the 

requirements. Staff, and chiefly management teams, should see to the 

implementation of procedures under any circumstances, so as to maintain the 

conformity level required by FSC standards’ requirements. 

Minor CAR 60: 

Currently, there are two company intervention levels: intervention at local level 

through FFCs, and intervention at communes’ level. 

Concerning intervention at local communities’ level through FFCs, several 

activities were carried out by the company. It consists in actions for abilities’ 

reinforcement (training to agricultural yield, breeding, micro projects’ 

management and so on) and actions supporting micro projects identified and 

accepted as part of the consultation with communities. Although the trainings 

carried out by the forest management department seem to have had an effect 

on beneficiaries (concerning the improvement of production techniques), the 

information received during the training is not spread out to the communities. 

Overall, the actions now undertaken with FFCs do not go beyond that frame. As 

for trainings, efforts have to be made to broaden the diffusion of techniques and 

information received by FFC members. 

After approximately 15 months, there appears an inadequacy between the 

means used (human and material) and the results achieved for the first 

generation projects. This assessment should contribute to a reorientation of 

choices, notably for second generation projects, mostly consisting in pig 

breeding. The company’s choice was to support communities in the installation 

of one pigsty per FFC. Once again, those pigsties will have a community 

aspect, but the practical management methods (example of animals giving 

birth) are not formally developed nor defined, which may lead to conflict within 

the communities and even with the company. 

From the communication between the company and local communities through 

the FFCs, there appeared an ambiguity that should be clarified. The company 

chose to use FFCs as the authority for consultation with the company, which is 

ambiguous as FFCs’ powers are clearly defined by the decision that established 

them, but debates are limited concerning other questions that could be clarified 

in a protocol/convention with local communities. FFCs acting as consultation 

and participative management authorities have competences that go way 

beyond the strict competences planned by the law, mostly concerning the 

sustainable management approach. The responsibilities of the company and 

the communities should be clarified as part of participative management. This 

observation leads to tackle the question of a clear and detailed frame for the 

consultation between the company and communities, with priority to the 

strategy for the support of resident communities’ development. Until now, the 

latter was not objectively defined. 

Concerning the intervention at communes’ level, two actions were reported: the 

signature of collaboration conventions (delegation contracts for works 

coordination with Ndjikinimeki commune) and the drawing up of a master 

arrangement with Yingui commune. 

This second section is orientated towards the partial contribution to the 

concretisation of micro-projects such as the building of a classroom in 

Ndockwanen high school, the building of latrines in Ndikoko high school 











Version : 2.1 

(Ndjikinimeki arrondissement). Note that those interventions, as part of the 

conventions signed with the communes, will have to be focused and resulting 

from the priorities expressed via the local development plans, or at least from 

carefully elaborated choices answering the local communities’ concerns. On the 

other hand, the socio-economic achievements, which expenses were shared 

with the communities, cloud the company’s contribution and the current sociopolitical 

context. It would be judicious to clarify responsibilities for stakeholders 

and chiefly local communities, which will be supported in their development, and 

to communicate about decisions made in agreement with stakeholders (mostly 

at local communities’ level). 

As a conclusion, this CAR is minor given that the company initiated actions to 

support the development of local communities, but now interventions should be 

revised as part of a clearly defined policy. 

Minor CAR 61 

Regardless of the type of project to be implemented by the company for local 

communities’ development, this should be part of a global policy clearly 

developed and possibly communicated to stakeholders (chosen project type, 

reasons, implementation schedule, finance resources, performance indicators, 

impact indicators, and so on). 

For instance, the technical and human capital of the Medical Center of Yingi 

district was improved thanks to TRC support. After one year, this support 

notably led to a significant increase in the attendance rate (performance 

indicator) of this sanitary structure from neighbouring communities (distant from 

10 to 15 km) and a decrease in the transfer of patients to Douala (impact 

indicator) for health reasons (implying a reduction of various related expenses). 

It is undeniable that such initiatives have a quick and instant impact in a context 

stricken by isolation and poverty. 

Equally, the company could select priority projects to be carried out after an 

analysis of local development plans or socio-economic diagnosis reports. It is 

obvious that the chosen projects can only be carried out according to the 

amount available in the pool. 

Minor CAR 62 

The assessment of the environmental management plan’s implementation 

shows that several measures presented in the EMS are not thoroughly 

implemented yet. Ongoing efforts should be pursued so that all the measures 

defined in the EMS can be progressively implemented. Several actions were 

initiated but not fully implemented, which justifies the minor character of this 

CAR. 

Minor CAR 63 

The category allocated to administrative agents depends on the importance 

granted internally to the post. All administrative agents match a single 

elaborated definition of their remit appearing on the job descriptions that are not 

approved yet. The required level for this position and the place in the hierarchy 

would imply that those posts would be suitably valued, which isn’t the case in 

the company. 











Version : 2.1 

Minor CAR 64 

Job descriptions are one of the main tools for staff assessment. Those 

documents are developed for superior managers of the company only (see 

document dated 30 th January 2009). 

Overall, this CAR aims at ensuring that the current personnel management 

team has sufficient means and power available to play its role in staff 

management and to comply with legal work requirements and FSC-applicable 

international conventions under any circumstances. 

The functional and structural flowchart of the company must be reviewed and 

the responsibilities of the personnel department team will have to be clarified. 

Minor CAR 65 

CERAD consultancy was appointed as mediator by the company during the 

conflict between TRC and Ndockbassaben community. After this mission, some 

recommendations were expressed (see preliminary report from the analysis of 

the conflict between TRC and Ndockbassaben village, dated 30 th August, 

2007). 

It is obvious that this mediation mostly contributed to appease stakeholders 

while orientating them towards a clarification of the communities’ concerns. 

However, it now appears that the approach promoting dialogue, consultation 

and solution-seeking has not been thoroughly applied. The possible implication 

of the administration in the conflict resolution, to the detriment of the means 

chosen, would simply aggravate the situation 

On the other hand, it should be emphasized that in the current context of a 

divided community in Ndockbassaben (situation foreseen by the mediator after 

his mission), there could not be a serene participative initiative of any kind. 

Negotiation must urgently resume as part of the mediation initiated, so as to 

clear misunderstandings and to refocus the relations between the company and 

Ndockbassaben communities with a sound and sustainable perspective. 

This CAR is minor as the approach initiated by the company to deal with the 

topics, according to the process suggested by the mediation, is not finalised. 

12.4.3 - New Major Corrective Actions Request 

N° Major Corrective Actions Request Expressed 

66 

Set up the consultation with staff representatives and 

all workers, and deal objectively with the concerns 

expressed. 

Suggested 

realization lead-time 

3 months 

Demand Number 

4.3 

4.4.4 

4.4.5 

Comments on the major CAR: 

Considering the observations made concerning the negotiations between 

workers and Management, drifts were reported in the application of conventions 

87 and 98 of WIO and even of some national legal work measures. 

From the analysis of the documents relating chronologically the facts from the 

idea to the settlement of the problematic workers campsite in FMU 00 004, it 

appears that the concerns shared with various levels of management were not 

considered as such. 











Version : 2.1 

Beyond standard complaints appearing in the notebook for this purpose, the 

writing of the memorandum concerning the campsite in FMU 00 004 can be 

considered as the result of accumulated frustrations and the workers’ 

experience of such situations (Iboti and Mossé campsites). Although workers 

and mostly workers’ representatives can be reproached for not using the formal 

means of transmission of concerns to hierarchy planned by the company’s 

internal uses, this memorandum has dully been handed out to the consultant 

appointed for the environmental and social feasibility survey in January 2008. 

This memorandum is attached to the report of the aforementioned mission. 

The approach implemented to deal with such situations led to the dismissal of 

two workers’ representatives, to the resignation of another two, and to the 

deterioration of the global atmosphere within the company. This simply shows 

that the consultation and dialogue means recommended in criteria 4.3 of forest 

management standards were not prioritised. 

The decision to dismiss two workers’ representatives after the publication of the 

memorandum of FMU 00 004’s workers contributed to reinforce the frustration 

of the remaining workers’ representatives, who no longer felt free to negotiate or 

share concerns with Management. 

The draft internal rules for the campsite were developed and submitted to 

workers and to workers’ representatives in particular for their comments. It does 

not deal with all the concerns expressed in the memorandum. For instance, 

paragraph (d) of art.3 of the draft internal rules is one of the points that led to a 

ration’s request. We could imagine that married workers with children old 

enough to be sent to school would now have three households (campsite, 

Yingui for wives and Douala where children go to school). 

A meeting was held on 19 th April, 2008 with workers of FMU 00 004, organised 

for the social dialogue to resume. The agenda was “the management of a crisis 

linked to workers’ representatives, the campsite project justifications, and 

debates concerning the moving in of workers into the campsite”. It did not allow 

tackling thoroughly and serenely the existing unrest. 

Given all the consequences it could create and the fact that it is general and 

recurrent, this corrective action request is essential, and the sustainability of 

TRC certification approach depends on the actions taken. This is therefore a 

major corrective action request. 


In the past, the company showed capacity to innovate and progress. Structural 

measures taken by the company following from the observations expressed 

during present audit confirms this reactivity. 

However, lapses were observed, including one that is major, which proves that 

the conformity level is not sufficient with regards to FSC standards requirements 

and the system that was implemented to meet them. The company must reach 

conformity within three months and achieve the requested level for the 

certificate to be maintained. A complementary audit will be carried out in this 

lead-time in order to assess the answers brought and the actions implemented. 

Nevertheless, the audit team continues awarding its full trust to TRC and is 

confident that the situation’s realization and the General Management’s 

declaration following the audit’s results’ debriefing will lead to the necessary 

improvements to maintain the FSC certificate. 











Version : 2.1 

Drafted on 5 th March, 2009, reviewed on 4 th May 2009 and on 19 th May 2009 

Forest Product Manager, 

Audit Manager, 

Héloise D'HUART 

Alain VALETTE 

12.5 - Certification decision 

After analysis of the conclusions of the audit team and after revision of the 

Corrective Action Request, the Wood and Forestry department requests the 

company to close the Major CAR in the 3 months following the surveillance 

audit n°1. A complementary audit on site will be ne eded to assess the action 

taken by the company to in compliance with FSC requirements. 











Version : 2.1 

13 - Appendices 

13.1 - Pairs review following the initial audit and the two complementary 

audits 

To be translated 








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13.2 - Answers to Stake-Holders 

These comments are classified by theme (grey lines) 

Date comments Com. N° Comment received Company’s answer Answer 

Population 

01/06/2006 14 What means have been taken to 

consult the communities 

09/06/2006 18 Criterion 3.1: Incompatibility between 

the concepts of “native populations" 

and “controlled territories” 

A permanent instance of population 

consultation was set up. Within that 

scope 11 FFCs representing all the 

riparian villages were created. 

Through these FFCs, the 

populations are regularly informed of 

the different activities linked to the 

UFA management. These FFCs 

function very actively. The 

consultation schedule with the FFCs 

plans a monthly meeting with TRC. 

The communities were consulted systematically during all the 

audits. The consultations results and the assessment of TRC’s 

consultation mechanisms is specified in the report. 

Non modifiable FSC criteria. 

09/06/2006 19 3.2 criterion keys: non operational: the 

negative impacts are only identified 

and the measures are simply 

documented. 

An impact survey is carried out with an environmental and social 

management scheme. The implementation of that survey 

recommendations and the management scheme allow to reduce 

or compensate the identified impacts. Similarly, the defined 

procedures are applied and allow to limit the negative impacts of 

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09/06/2006 22 Expectations in terms of road The exploitation evolves on the Checked during the audits 

construction in the villages 

basis of a division of the UFA in 

cutting areas (30 years to cover the 

area), it is not possible for the road 

construction to progress at another 

rhythm. The Douala-Yingui road was 

reopened and is regularly 

maintained by TRC, as well as all 

the Yingui roads. TRC does not 

have the right to open roads other 

than those needed for the 

exploitation of the Yearly Cutting 

Area in progress and those needed 

for timber evacuation. The Yingui 

road was reopened within that 

scope. 

09/06/2006 23 Need in furniture Inadequate question 

09/06/2006 24 need in schemes monitoring The FFCs set up by TRC allow to do a monitoring of the projects 

implemented by TRC (see report). 

09/06/2006 25 Does not give its opinion on the 

management implemented on the 

UFA because not enough hindsight 

and encourages the involvement of all 

the parties 

09/06/2006 26 The different people who run certain 

structures do not know their role 

The public summary of the management scheme is distributed to 

all the stakeholders including the riparian communities. 

Consultations are regularly carried out with the communities 

through the FFCs; 

The FFCs were trained and are regularly consulted to make clear 

the roles of all the parties involved 

09/06/2006 31 Wonders if TRC took into 

consideration the populations’ 

grievances because did not have the 

knowledge of the “specifications” 

See answer to point 14. 

The "specifications" notion is no longer in the law.However, the 

company consulted the riparian communities to take their need 

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09/06/2006 35 One must make the youths taken on All TRC employees are declared at Checked during the audits 

by TRC subscribe to the CNPS (for the CNPS, including those from the 

their old-age pension) instead of riparian villages. 

employing them as temporary workers 

09/06/2006 37 Setting up of CSP If CSP means FFC see answer point 

14 

09/06/2006 38 Willingness to include the 

development notion of the "gender" 

approach (distribution between the 

different categories of population: 

youths / old, men / women) in the 

management referential 

The referential takes into consideration all the social classes and 

includes the gender aspects too 

09/06/2006 40 specifications see point 31 

09/06/2006 41 Make sure of the effective setting up If it consists here in the RFA Checked during the audits 

of the management Committees (CSP management committees, the joint 

) 

order plans that the economic 

operator attends as observer. TRC 

wrote to all the concerned Mayors in 

order to be informed about the 

opening of these committee 

09/06/2006 44 Finds that TRC consults the 

populations in a cavalier manner: CPF 

launched in 2 days, no explanation of 

the step in the villages- 

meetings. 

Since the setting up of the FFCs, the 

meetings with the villages intensified 

a lot and the relationship with the 

riparian populations improved a lot. 

noted as the audits are in progress 








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09/06/2006 45 Main Mosse - Ndokbassa road: TRC TRC is not opposed to the roads Checked during the audits 

is opposed to the road crossing the construction however cannot accept 

UFA 

that a public works company 

ventures into creating a road without 

pre-established plans in the UFA 

because it is “easier” to use an 

exploitation track rather than repair 

the former road or to open a new 

one, task for which it nevertheless 

signed a contract with the 

Cameroonian State. Nevertheless, 

considering the anthropogenic 

pressure and socioeconomic results 

from surveys carried out by TRC, 

that zone was excluded from the 

UFA to the populations’ benefit 

during the definitive constitution. 

09/06/2006 46 “Exiles” problem: want to bury their 

dead in the villages of their ancestors 

(which they had to leave in the 60s) 

That problem was solved during the 

UFA definitive constitution, as it is 

the zone cited above. 

Checked during the audits 

09/06/2006 47 The term Forest Farmer Committee is 

pejorative 

That name is given by Cameroonian 

forestry law 

09/06/2006 48 Problem of communication with the 

populations to explain the respect of 

environmental and accompanying 

standards 

See answer to point 14. Summaries 

of various documents (management 

scheme, certification procedures, 

results of the impact survey) were 

distributed in all the FFCs. 

09/06/2006 49 Specifications respected see point 31 

09/06/2006 50 CNPS registration of the recruits All TRC employees are declared at Checked during the audits 

the CNPS 








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09/06/2006 51 Requests the setting up of a sawmill TRC does not plan the setting up of 

to create jobs 

a sawmill there. 

09/06/2006 52 Problem with the main Mosse - 

Ndikinimeni road 


09/06/2006 53 Insufficient consultation problem See answer to point 14. 

09/06/2006 54 Road problem See answer to point 45. 

09/06/2006 56 pejorative “CSP” term see point 47 

09/06/2006 57 Association of all the parties The forests farmers committees set up also serve as consultation 

framework with the company to tackle the local communities’ 

concerns 

09/06/2006 58 See point 42 orally (insufficient 

consultation problem) 


09/06/2006 63 Orally: Road problem See answer to point 45. 

09/06/2006 64 Orally: insufficient consultation 

problem 

09/06/2006 65 Orally: problem with the main Yabassi 

- Yingui road 

09/06/2006 66 Confrontation with Manuel (site 

manager of UFA 00 004) 


As far as we know, there is no 

problem in the Yabassi zone. TRC 

regularly ensures the reshaping of 

the main Yabassi Yingui road 

through which its timber is 

evacuated. 


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15/11/2007 73 The NGO underlines that, according The proportion of the population who Checked during the audits 

to socioeconomic surveys, the is interested in "Moabi" tree as 

“moabi” appears as a major tree for NTFP is relatively low. The surveys 

the local populations as NTFP: why rather showed that these 

fell it in that case TRC suggests to populations mostly exploit the feet of 

consider stopping felling the “moabi” the "Moabi" trees in the near vicinity 

trees. 

of the villages. TRC suggests to 

consider with them a participative 

management system for that 

species. 

15/11/2007 77 TRC is not opposed to the creation of 

the Mossi - Ndokbassaben road 

however explains that it is the 

administration which stops the 

scheme. 









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15/11/2007 78 They explain that, on the social level, Beyond the AFR payment, the Checked during the audits 

the main identifiable obstacle to a company cannot, on behalf of the 

FSC certification is the absence of Cameroonian State, act upon the 

visible economic consequences for real use of that godsend for the 

the local populations.Facilities such as socioeconomic development of the 

wells, schools or health centres are riparian communities. The 

practically nonexistent in the riparian implementation of the rural 

villages. The economic development development schemes cannot be 

microprojects are embryonic.TRC done without the participation and 

explains that the company pays the approval of the beneficiaries and the 

annual forest royalty and that it is up Administration. TRC is committed to 

to the local administration and the participate to the convention set up 

Cameroonian State to take care of by YINGUI’s new Mayor, for the 

building these facilities.They share, elaboration of a development 

partly, that view: the company must scheme for the region. TRC wrote to 

not do everything and place the all the Mayors in order to really take 

villagers in a situation of dependency. part (as provided for by the law) in 

Nevertheless, we think that TRC must the AFR different management 

play a more active role to ensure that committees. TRC set a Support fund 

the AFR is used correctly by the local for the development of the UFA’s 

administration for the villagers’ riparian village communities, 

benefit. 

financed by “GREEN SOURCE 

Foundation”. That “foundation” is 

funded by a debit of 500FCFA per 

m3 of timber exploited in the UFA 

(since 01/01/07). 








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15/11/2007 79 They wish that TRC should formalize For the populations, TRC started the see point 14 too 

further its relationship with the following actions: Local 

villagers by establishing appointments (about 25 people up to 

specifications. The writing of these now, including 1 forest engineer). 

specifications should associate the Refurbishment of Yingui’s health 

local administration. During our centre. Strengthening of Yingui's 

mission, in September 2007, we noted health centre by taking in charge 2 

that the Monitoring Committees male nurses (including 1 laboratory 

created by TRC only have a small assistant). Taking part in Yingui’s 

operating budget (per diem, transport Town Hall refurbishment. Creation of 

allowance to the meetings -) however communittee fields in each village 

no investing budget for concrete (16). Reinforcement of the agrosylvo-pastoral 

capacities through the 

schemes. They recommend to TRC to 

rely on these Monitoring Committees FFCs. 

to write contractual specifications. 

Financing of identified schemes could 

be first taken on by TRC (via REEF 

foundation) however progressively 

taken care of by the local 

administration (via the AFR). 

15/11/2007 80 They admit that TRC took initiatives 

for the UFA riparian communities 

however it seems to be very 

premature to judge the effectiveness 

and impact of these measures. Yet, 

the FSC certification is a performance 

certification which should only be 

issued when forest management will 

in concrete terms benefit to the 

riparian populations. 

Fauna & flora 

There are already concrete results: 

employment for about 25 riparians, 

economic effects for about 5000 

people through the setting up of 

microschemes. TRC thinks that the 

FSC certification for UFA 00-004, 

would give salutary impetus to the 

company and would allow it to set 

up other initiatives in favour of 

sustainable management in all its 

activities. 

The support initiatives to improve the standard of living of the 

local communities riparian to the UFA were really set by the 

company. To start with, these initiatives experienced very few 

commitments from the communities (apart from members of the 

FFC board), however the assessments and continuation of the 

actions started allowed in particular to give rise to more interest 

or progressive commitment from these communities. The initiated 

schemes need a reinforcement of the communities’ capacities, 

which is done, as well as a real commitment from the latter too 

(which is not everywhere the case). 








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01/06/2006 7 Did TRC classify the UFA as HVFC TRC produced a text describing the 

(because the UFA is located in the high value conservation attributes in 

Ebo-Ndokbou area, very rich UFA 00-004. That text is available 

ecologically and with certain rare on the TRC website. 

animal species) 

01/06/2006 8 What are the procedures planned and 

implemented to maintain the zone’s 

biodiversity 

In addition to the surveys prior to the 

elaboration of the management 

scheme, complementary surveys 

concerning biodiversity in the UFA 

were carried out in partnership with 

different specialists: Dr ATANGA 

EKOBO from WWF for fauna, Dr 

PEGUY TCHOUTO from 

MBALMAYO's National School of 

Forestry and Water Ressources and 

Dr ONANA from Cameroon's 

National Herbarium for flora and 

biodiversity in part. The results of 

these surveys allowed to elaborate 

specific procedures for all of TRC 

activities in the UFA. These 

procedures allow to include the 

considerations 

and 

recommendations of the different 

surveys carried out and to protect 

biodiversity at best. 

An identification and definition work of HVFC attributes was 

actually carried out in that UFA in collaboration with the 

stakeholders (local communities and national and international 

organizations). 

These surveys were monitored, and the resource people were 

consulted during the audits 








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01/06/2006 9 Are zones within the concession going 

to be protected 

01/06/2006 10 Are specific measures going to be 

taken to protect rare, protected and 

endangered species 

01/06/2006 11 Is a buffer zone planned in the area 

around Ebo forests and Mounts 

Nlonako 

A protection set made up of two 

zones (1859 ha altogether) is 

defined in the management scheme 

according to the results of the first 

fauna survey carried out jointly by 

WWF and Nature+. The criteria of 

choice of these zones were dictated 

on one hand by their biodiversity 

wealth and on the other hand 

because they are far away (low 

impact of poaching). 

The surveys mentionned at points 7 

and 8 allowed to identify rare and 

endangered species. Specific 

procedures were elaborated and are 

applied for the protection of these 

species. For each yearly cutting 

area, pre-exploitation multiresources 

surveys allow to identify new 

species to be protected and lead to 

the evolution of procedures to adapt 

them to new data 

The proposition of UFA 00-004 

definitive constitution as well as 

EBO park new definition put the two 

zones more than 1.863 miles away 

from one another. That intermediate 

zone is assigned to agroforestry. 

Mount NLONAKO forest reserve is 

not bordering UFA 00-004. 

Following the audits, precisions were asked on the identification 

of the HVFC attributes, by complementary surveys.New HVFC 

zones were redefined following complementary and specific flora 

and fauna surveys and are correctly described (as well as their 

conservation measures) in the TRC HVFC document. 

The conservation measures were assessed, and were subjected 

to stakeholders’ consultation 









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01/06/2006 12 Besides the biological survey were An environmental and social impact Checked during the audits 

there environmental and social impact survey was carried out by the 

surveys, and if so, are they public CARFAD and approved by the 

administration. The environmental 

management scheme which follows 

from it was translated into 

procedures. That management 

scheme was communicated to the 

riparian populations through the 

Forests Farmer Committees. All 

these documents are made public 

on the TRC website. 

01/06/2006 13 Concern about poaching in Ndokbou See tab “Detailed comment nb 13” Checked during the audits 

forest: what measures did TRC take 

or implement to handle that problem 

09/06/2006 33 Question on the struggle against See answer to point 13. 


poaching 








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09/06/2006 34 And what about non ligneous Within the scope of the Checked during the audits 

products 

socioeconomic surveys and during 

complementary surveys on flora, 

TRC assessed the level of use of 

the NTFP by the riparians. The 

populations’ capacities were 

reinforced on legal aspects of the 

exploitation and on the promotion of 

these products. The concerted step 

scheme plans trainings on NTFP 

tree nurseries implementation with 

the aim of diversifying sources of 

income and bringing alternatives to 

poaching. These trainings have 

actually started and the concerned 

species are those having a certain 

interest for the communities 

(example: the njansang 

(“Ricinodendron heudelotii”), and so 

on) 

15/11/2007 74 They explain that poaching is major in 

the UFA and that the measures taken 

by TRC are too recent to be able to 

make sure of their effectiveness. The 

NGO does not understand why CAR 

30 (to be checked) could be removed 

so quickly by Eurocertifor. 

15/11/2007 75 TRC admits that the first survey on 

fauna was badly carried out however 

it has since been carried out again. 

The results show that the presence of 

gorillas and endangered species is 

more definite in the national park than 

in the UFA. 


The auditors are aware of the gravity of poaching on the zone; 

the audit team insisted on that point, and collected contributors’ 

opinion on that point. The WWF itself in particular was very 

satisfied with the steps started. The steps seem to us to 

constitute a varied and coherent scheme: monitoringsuppression-awareness. 

The fauna survey was carried out again in effect, under the 

supervision of Dr ATANGA from WWF. 








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15/11/2007 76 Moreover, they think that the survey A new HVFC document was carried Following corrective action request 34, the work on the HVFC 

on high value forest conservation out, largely spread (visible on the was completely reviewed, which allowed to remove that CAR. 

carried out by the FORM firm is very TRC website) which already The work has nothing much in common with the Form document 

poor and not translated in concrete provoked positive reactions while (many references, consultations, appended surveys, clear keys) 

terms in the exploitation guidelines waiting for the impending validation 

and procedures. 

meeting. 

Management 

09/06/2006 20 Bongossi is the most exploited 

species in UFA 00 004 however it is 

not managed, which allows the logger 

to fell to administration MLD: can one 

talk about sustainable management if 

the main species is not included in the 

management scheme 

09/06/2006 27 Would appreciate that the forest 

management scheme should be 

known by everybody 

09/06/2006 42 Make sure of respecting the 

boundaries with the different types of 

forests around the 00 004 

Following the FSC initial audit, the 

minimum logging diameter of 

BONGOSSI was put up from 23.4 to 

27.3 inches. The management 

scheme must now be reviewed (end 

of first five-yearly block and new 

surface area) and these species will 

be included in the management 

scheme to be in harmony with the 

measures taken following the FSC 

initial audit. 

Concerning Bongossi, TRC put up the logging diameters 

following the remarks expressed by the auditors during the 

scoping. The present logging diameters of Bongossi are not 

those on the management scheme approved by the 

administration.These “FSC Diameters” are mentionned in the 

company’s procedures. 

It is an FSC requirement (8.5) It is an obligation of the FSC referential (8.5) 

Only one type of forest surrounds 

UFA 00-004, there are agroforestry 

zones. As it is said above, the 

boundaries are regularly monitored 

(point 32) 









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15/11/2007 69 They explain that, on a silvicultural See answer to point 20. 

It is completely true that the forest renewal rate of objective 

level, the main obstacle that we can 

identify to a FSC certification is the 

low rates of forest renewal (RFR) of 

the main species exploited that is to 

say bongossi (RFR 28%), tali (18%) 

and okan (24%). These species 

management cannot henceforth be 

described as sustainable because no 

volume commercially sufficient will 

remain as soon as the next rotation 

starts. They criticize TRC, as welle as 

many other companies, for having 

species is low. TRC made public these rates (which do not 

appear in the management scheme before certification) and 

changed the diameters to improve things. It is fit to remind here 

that according to principle 5 the management of a certified forest 

should be economically viable: if one harvests bongossi at a 

diameter which does not allow full forest renewal of stands, this 

will not be the case. The FSC MD used is therefore a 

compromise. The species promotion and the scientific surveys 

(on the fructification diameter and the average yearly growth) can 

be admitted as partially compensating a low forest renewal rate. 

taken advantage of a flaw in 

Cameroonian law (order 222) to 

exclude these species from the 

management scheme. 

15/11/2007 70 TRC explains to have already 

increased the felling diameters after 

Eurocertifor’s first audit however this 

remains very insufficient. 

The present data do not 

automatically require a change in 

minimum diameters. TRC set 

permanent sample plots and 

phenologic paths supervised by Dr 

PEGUY and the National Herbarium. 

The results of these surveys will 

allow to have extra data and a 

scientific basis on the management 

diameters of several species. It is to 

be noted that the mentioned species 

are neither rare nor endangered and 

that for the moment a management 

approach of the complete unit 

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15/11/2007 71 They suggest to TRC:- to have an See answer 70About promoting Checked during the audits 

“honest” commercial communication secondary species, TRC already 

towards its clients and to admit that started to promote (sheet piles in 

today’s marketed species are OKAN, Nonskid in "SOUGUE" and 

overexploited.- to have an active LIMBALI, fence for horses in NIOVE, 

policy of research and promotion of sawings in "EVEUSS" and 

secondary species to stop "EKOBEM"). TRC thinks that the 

overexploiting key species.- To think FSC certification will allow to offer to 

about an innovative forestry: rather the consumers wishing for a certified 

than felling all the trees above the product, a greater variety of timber 

MLD/MMD keep from it enough species. 

percentage to improve the forest 

renewal rate. 

15/11/2007 72 TRC pays attention to these 

suggestions and explains that the 

management scheme is not frozen: 

new surveys are regularly carried out 

and the procedures updated. TRC 

also explains the work which is carried 

out to fight against erosion (the UFA 

having a very hilly landscape): 

reforestation, road planning, reduction 

of impacts at felling and forwarding. 

Illegality 

01/06/2006 4 TRC’s illegal activity in Ebo forest: can 

an FSC certificate be issued if the 

company has illegal activities in other 

forests 

A particular procedure concerning 

soils protection was elaborated with 

the assistance of Professor 

BOKONG, teaching at DSCHANG 

University, department of soil 

sciences. In the 2008 cutting area 

(1-4), the most hilly zones were 

banned from any exploitation and it 

will be the same on all the cutting 

areas. In the document concerning 

the HVFC, these zones are included 

in the HVC 4 for which protective 

measures are taken. 

TRC has no activity in EBO forest. 

These points were monitored and validated during the audit in 

November 2008, by field visits and interviews of the operators 

and scientists involved. 

Indeed, TRC has no production activity in that forest (which is not 

listed as UFA). There should be more factual information on the 

illegal activities quoted. 

In general, a company cannot have a certificate if it practises 

activities which can give rise to controversy in other forests or 

activities. 








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09/06/2006 28 Problem with Ndem community forest: TRC plans no collaboration with 

fraudulent exploitation (wild felling) Ndem community forest, even if for 

and contentious files (management the moment, the management of 

scheme not repected): that CF does that forest did nothing but generate 

not bring anything to the population. Is conflicts within the community. On 

worried that that CF (and its former the other hand, TRC intends to 

office which is questionned) goes into assist Yingui’s municipality in 

partnership with TRC 

consultation with the successful 

community bidder of that CF in a 

communal forest scheme which 

could be a source of income for the 

populations and therefore take part 

in the fight against poverty. 

15/11/2007 68 They explain having had access to 

pieces of information proving that 

TRC bought timber coming from a 

cutting area sale (CAS) located in Ebo 

national park. TRC denies and 

explains having stopped since 2003 

the supply from the CAS. 

09/06/2006 32 Question on the fight against wild 

sawing 

After having noted irregularities in 

the exploitation of that CAS, TRC 

interceded continually with the 

administration in order that that 

activity not in conformity near the 

UFA should stop. 

A boundaries surveillance procedure 

against illegal activities (including 

wild sawing) was elaborated. The 

boundaries surveillance is carried 

out at least four times a year. The 

riparian communities, through the 

FFCs, as well as the forests 

administration are associated with 

that step. With the administration’s 

agreement, TRC established a 

guarded gate on the main Yingui- 

Douala road which filters all the 

vehicles going through and 

transporting illegal sawing. 

TRC documented that event, the elements which were presented 

to the auditors seem reliable 









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09/06/2006 36 Is the AFR paid back The list of payments, amounts and Checked during the audits 

due dates is visible by everybody on 

the TRC website. 

15/11/2007 67 They underline that UFA 00 004 is 

always in temporary agreement 

whichseems an obstacle to the 

certification. TRC answers that it is 

not contrary to FSC rulesand that the 

definitive agreement is expected for 

the end of year 2007 (the second 

meetingof constitution took place in 

September 2007). 

Referential / process 

09/06/2006 18 Criterion 3.1: Incompatibility between 

the concepts of “native populations" 

and “controlled territories” 

09/06/2006 19 3.2 criterion keys: non operational: the 

negative impacts are only identified 

and the measures are simply 

documented. 

All the meetings took place and TRC 

already received a letter from the 

Minister of Forestry and Fauna 

which informs them that “UFA 00- 

004’s constitution process is (totally) 

finished on field" and that “the file 

relating to it follows the statutory 

procedure”, that is to say it is 

transmitted to the Prime Minister’s 

signature. In that letter it is also 

indicated that the UFA surface area 

is now: 94,917 ha. 

The auditors confirm that the documents to which TRC refers 

were controlled and that following contacts made at the ministry, 

the process is nearing completion. 

Non modifiable FSC criteria. 

An impact survey is carried out with an environmental and social 

management scheme. The implementation of that survey’s 

recommendations and of the management scheme allow to 

reduce or compensate the identified impacts. Similarly, the 

defined procedures are applied and allow to reduce the negative 

impacts of forest management operations, the implementation of 

which is monitored during the audits. 








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01/06/2006 3 10/05/06 CED remark: key 1.1.6 (the 

absence of noncoformity does not 

mean that all the legislation is really 

respected) + law texts list (E3) 

Respecting the law is a complex subject, moreover often left in 

the hands of lawyers, and it is nearly impossible to prove that all 

the laws of a country are respected.Such a step would take 

several months of work for our clients and an excessive time to 

control it during our audits, we consider that the different keys of 

criterion 1.1 address correctly the global respect of the 

criterion.The aim is to control that the forest manager respects 

the law however, the audit is not reduced to that.In the same 

way, it is probable that appendix E3 does not list all the 

applicable laws, however there again, there is no question of 

being exhaustive but rather of giving the legislative basis that the 

manager should respect and that we monitor during the 

audits.Moreover, during the revision of our referential, the key 

was changed as follows (to take into consideration that 

complexity):“1.1.6 There is no proof of offences, relatively 

01/06/2006 1 Make a good and transparent 

management of the stakeholders 

05/06/2006 17 Taking into consideration the pieces 

of information transmitted by the 

stakeholders (example: GPS points 

transmitted for another file) 

09/06/2006 55 Complains about having had the 

documents of the meeting too late 

significant and frequent, against legal requirements” 

New measures were taken: 

- information mail before the audits- monitoring mail if the 

process is postponed because of complementary audit- appendix 

of answers to stakeholders with the public certification report, 

updated at each audit (if necessary) 

The elements supplied were taken into consideration during our 

audits and the FSC audited us regularly to check it. Simply at the 

level of communication (answer to people who made remarks to 

us) we fell behind with the file in question. It should be noted 

however that our auditors can have a different point of view on 

the elements transmitted by the stakeholders, some of them 

being not acceptable or having no impact. A precise answer is 

systematically expressed in the appendix of our public reports. 

Documents distributed in the villages by TRC (one has 

acknowledgements of receipt). The representatives of the 

riparian communities were met during the audits in the course of 

the process 








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01/06/2006 2 Speed of the process There is no rule on the subject, companies are free to bring 

themselves up to standard according to the means that they 

implement. In the case of TRC, the company made a scoping in 

May 2005, and its latest audit dates from November 2007, that is 

2 and a ½ years of process, which is a generally noted average. 

01/06/2006 5 Should the other forests under TRC 

management not be submitted to the 

FSC “Partial certification” and 

“controlled wood” text 

01/06/2006 6 If so at pt 5, is one going to take into 

consideration the TRC activities on 

the SEPFCO concessions 

05/06/2006 16 Question on the confidentiality of the 

auditors’ names 

09/06/2006 21 Orally: question on the certification 

cost (provision of certification) 

SEPFCO’s UFA 00-001/002 

exploited in partnership by TRC, as 

well as TRC’s UFA 11-001 are OLB 

certified. TRC chose to firstly certify 

FSC UFA 00-004 and to produce 

pure (and not mixed) FSC, therefore 

at the moment, a controlled wood 

certificate is not necessary. 

TRC opted for the production of "pure FSC" products, that is to 

say with FSC certified raw material, timber coming exclusively 

from the certified UFA 00 004. 

On other forests, there should not be any activity giving rise to 

controversy (these forests were already subjected to an FSC 

scoping, it was possible to note that the management practised 

on these forests respect that requirement) 

see point 5 answer 

We decided to keep the auditors’ names confidential because:- 

the FSC authorizes it, however above all- we have without any 

doubt the most competent auditors as far as forest management 

in Central Africa is concerned and we do not wish to divulge that 

information to our competitors.We understand that that can be 

surprising however certification is also an economic activity with 

its own constraints and difficulties that we must manage and we 

will keep maintaining that information confidential. 

Question not concerning the certification process concerned by 

the consultation 








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09/06/2006 29 What level of the certification process 

TRC is in initial audit (therefore final consideration) however had 

are we at 

to set things concerning the consultations and taking 

expectations into consideration. The initial audit aimed to check 

it. Afterwards, TRC undertook two other complementary audits, in 

order to check all their steps. 

09/06/2006 39 The referential should be conform to 

the draft of the assessment monitoring 

manual (Ref PD23/99 Rev (F)) 

09/06/2006 43 Have several experts in the audit 

team 

09/06/2006 59 Orally: How explain TRC / BVQI 

“complicity” 

09/06/2006 60 Orally: are the remarks and reports of 

the populations going to be taken into 

consideration 

09/06/2006 61 Orally: request that the keys should 

be more detailed 

All the populations’ remarks and 

reports are surveyed during the 

frequent meetings with the FFCs. A 

particular procedure was moreover 

elaborated in order to guarantee the 

populations’ commitment in the UFA 

management. 

The referential and the audit procedures meet FSC requirements 

as far as certification process is concerned. 

During the 4 audits which TRC was subjected to, 6 auditors 

participated to the audit among whom were: 

- a forest expert (audit manager) 

- an expert on social and environmental questions 

- a developer specialist of the Congo Basin 

- a specialist of forest exploitation 

- a specialist of environment and ecosystems 

- a specialist of timber processing 

There is no “complicity”, Bureau Veritas Certification (ex-BVQI) is 

an independent structure, FSC accredited, and which is in 

relation with TRC within the scope of the certification process of 

the latter. 


This is impossible because the requirements would become 

inaccessible and unverifiable and the answers to the 

requirements would become over restricted and standardized 








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09/06/2006 62 Orally: request that the keys should 

be more detailed 

see point 61

PR080202 FSC FM public report TRC v22 [03 06 09] - Bureau Veritas

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