untangling the paper chain: how staples is managing transparency with suppliers

8/12/2019 Untangling the Paper Chain: How Staples Is Managing Transparency with Suppliers

1/22

CASE STUDY

UNTANGLING THE PAPERCHAIN: HOW STAPLES ISMANAGING TRANSPARENCYWITH SUPPLIERSRUTH NOGUERN WITH CONTRIBUTIONS FROM KERI HESS AND DAVID REFKIN

SUMMARY

This series of case studies is intended to show commercial buyers of wooand paper-based products, especially those who trade in species and/or sofrom places with a perceived risk of illegality, how their supply chains canconform with U.S. legal requirements on importing certain types of woodcase studies, compiled by the Forest Legality Alliance (FLA), draw lessonemerging best practices for managing risk in high-risk contexts. They discthe impacts of the U.S. Lacey Act (see Box 1) and other market demands wood products and identify and highlight potential problem areas as well pragmatic opportunities for reducing the complexity of compliance.

ISSUE BRIEF

WRI.ORG


2/222 |

required to report the make-up andorigin of the raw materials used tomanufacture the products. Lacey Act

violations can result in signi cantnes and jail time (U.S. Department

of Justice, 2012; EIA, 2009).

Staples overall strategy to meet boththe U.S. Lacey Act requirements andits own Sustainable Paper Procure -ment Policy is to increase trans-parency in its supply chains. Withthe assistance of the Rainforest

Alliances SmartSource Program,

Staples is deploying the tool Smart- Source360 to trace the origin of itsproducts and manage the risk ofsourcing unwanted or illegal materi-als. SmartSource360 is an internet-

based supply chain managementsystem designed to compile, analyze,store, and manage supply chaininformation and documentationdirectly from suppliers and sub- suppliers. This issue brief documentsthe pilot testing of SmartSource360 to trace the supply chains of veprivate label products that originatefrom China, the United States, andBrazil, through four suppliers.

The pilot testing revealed vekey lessons:

POSITION IN THE SUPPLY CHAINMATTERS. The longer the supplychain, the more dif cult it is forcompanies to obtain informationabout the origin of the rawmaterials. Pulp and paper manu -facturers, or integrated papercompanies, are better preparedto quickly answer speci c ques -

tions about the origin of their rawmaterials. Paper converters oftensource from multiple suppliersand brokers who could be verti -cally integrated pulp and papermanufacturers or non-integratedpaper manufacturers. In bothcases, paper manufacturers maysource wood from different sup-pliers, including on spot markets,at lower prices and without ask-ing questions about the origin of

the raw materials.BUYERS AND SUPPLIERS PRIORI-TIES NEED TO BE ALIGNED.High-level, direct, and consistent com-munication between the buyerand the supplier is critical to alignthe suppliers priorities with thepriorities of the buyer. Obtaining

EXECUTIVE SUMMARYStaples, Inc., the worlds largestreseller of of ce products, is in themidst of adapting its sourcing prac-

tices to ensure that its products meetnot only its own sustainable procure -ment policy, but the requirements ofthe U.S. Lacey Act. Under the Lacey Act, it is illegal to trade forest prod-ucts in the United States if they areof illegal origin, and importers are

This series of case studies aims to show commercial buyers of wood and paper-basedproducts, especially those who trade in species or source their materials from places with aperceived risk of illegality, how their supply chains can conform to U.S. legal requirementson importing certain types of wood.

The case studies, compiled by the Forest Legality Alliance (FLA) draw lessons from emerg-ing best practices for managing risk in high-risk contexts. They discuss the impacts of theU.S. Lacey Act (see Box 1) and other market demands for legal wood products, and identifyand highlight potential problem areas, as well as pragmatic opportunities for reducing thecomplexity of compliance.

The FLA hopes that the Lacey Act will encourage best practices in forest supply chains andprovide valuable information about the global ow of forest products, without imposingsignicant burdens on the private sector.

To that end, the FLA case studies of best practices in private sector procurement describe:

How the Lacey Act affects operations in countries that supply forest products to U.S.importers;

How to supply information consistent with the Acts intent, while reducing transactioncosts and unintended consequences for producers;

Best practices along supply chains to streamline the ow of information about forestproducts; and

How to scale up these best practices to support the private sector in complying withnew legality requirements, consistent with the FLAs goal of increasing the capacity ofsupply chains to deliver legal wood and paper and to help the private sector respond toemerging forest product legality assurance requirements.

The case studies do not attempt to assess the legality of the supply chains in question. Theyare not investigations, legality verications, product tracing, or chain-of-custody analyses.The FLA does not intend to suggest that the resources highlighted in the series are a modelfor supply chains, since supply chains differ vastly in size, location, and product. Nonethe-less, the case studies presented in this series offer examples and insights that might spuractions by other companies.

A B O U T T H E S E R I E S


3/22

Untangling the Paper Chain: How Staples is Managing Transparency with Suppliers

ISSUE BRIEF | October 2013| 3

accurate, detailed, suf cientsupply chain information andactive supplier participation ina data disclosure process takestime and effort. This is especially

true if supply chain transparencyis not a priority for the supplier,and in markets where there isno history of tracking the originof the raw materials or supplychain transactions.

IT IS CRITICAL TO OVERCOMECONCERNS ABOUT THE USEOF CONFIDENTIAL SUPPLIERINFORMATION. Direct suppliersor their sub-suppliers, who areasked to provide the most infor-mation about the origin of theraw materials, may be suspi -cious of the buyers motivation inrequesting information. Suppliersand sub-suppliers may considerthe information con dential, ormay believe the data could beused to circumvent them. Buyersneed to overcome this mistrust,communicate directly with theirsuppliers where needed, and

incentivize supplier participation.DIRECT COMMUNICATION WITHSUPPLIERS IS IMPORTANT.Relationship building and trustcan take years to develop and isin uenced by cultural differences.Direct, high-level communication with suppliers can be key toovercome concerns about the useof the supply chain information being disclosed and align thecorporate priorities.

INTERMEDIARIES CAN PLAY A ROLESUPPORTING THE IMPLEMENTATIONOF A PROCUREMENT POLICY. Anintermediary actor who supportsthe implementation of a procure-ment policy is useful in cases where the company does nothave in-house expertise on forest

THE U.S. LACEY ACT

The United States enacted the Lacey Act of 1900 to ban trafcking in illegal wilIn 2008, the Lacey Act was amended to include plants and plant products such a

and paper, making it the worlds rst ban on trade in illegally sourced wood prod2008 amendments also include a requirement that wood-product importers submration describing their product(s), including the scientic names of all tree speciein the product, the country of origin, the volume, and the value.

The Lacey Acts declaration requirement does not apply to all wood products. As2012, U.S. importers of paper products were not required to complete the Lacey requirement unless paper is part of a product that otherwise requires declarationexample, a wooden frame with paper backing (Lougee, 2012). In cases where pabe identied as part of a product, importers can use special codes assigned by thDepartment of Agricultures Animal and Plant Health Inspection Service, whichsubmission and reviews Lacey Act declaration forms (APHIS, 2012). It is uncleapaper importers will be required to complete the Lacey declaration form in the fu

What is illegal under the Lacey Act?

There are two elements of a Lacey Act violation. First, a plant must be taken, hapossessed, transported, sold, or exported in violation of anunderlying law in the UnitedStates or any foreign country that protects plants or regulates the following:

Stealing plants;

Taking plants from an ofcially protected area, such as a park or reserve;

Taking plants from other types of ofcially designated areas that are recognia countrys laws and regulations;

Taking plants without, or contrary to, the required authorization, or;

Failing to pay appropriate royalties, taxes, or fees associated with the plants htransport, or commerce; or

Laws governing export or trans-shipment, such as a log-export ban.

Second, an individual or company must trade this illegally sourced plant in the UStates to trigger a Lacey violation.

Penalties for unknowingly violating the prohibition are much less severe if a comcan show that it exercised due care to prevent illegal material from entering thStates as a result of its business transactions. The notion of due care may encompmany different factors depending on the circumstances of the forest managemenmanufacturing and trade. The Lacey Act does not prescribe how to exercise due

ever, the 2012 Criminal Enforcement Agreement between Gibson Guitar Corp. aDepartment of Justice offers insights that companies can consider in developing due care systems. The systems could include training for purchasing staff, commwith suppliers, verication of foreign laws and licenses with in-country legal proand/or knowledgeable third parties, requesting sample documentation from suppmaintenance of records (U.S. Department of Justice, 2012).

For more information about the Lacey Act, please visit www.aphis.usda.gov/planlacey_act/.

B O X 1


4/224 |

issues. Intermediaries can alsoprovide independent third-party veri cation and validationof the supply-chain informationsubmitted by the suppliers.

However, completely outsourcingimplementation is not advisable because direct involvement fromthe buyer is critical to reinforcethe importance of the policies,ensure that policy requirementsare well understood, andencourage suppliers to fullydisclose information.

The 2008 amendments to the U.S.Lacey Act are changing the wayStaples sources its paper products. While Staples has long recognizedthe connection between corporateresponsibility and business pro t -ability, the Lacey Act amendments,and the emergence of other regula-tions, such as the European UnionTimber Regulation, have helpedaccelerate the implementation ofStaples Sustainable Paper SourcingPolicy. With the pilot testing of SmartSource 360 , Staples managers

gained a better understandingof the complexity of their supplychains. The pilot test also informednext steps in the SmartSource 360 deployment. These steps includecontinuing to reach out and educatesuppliers and sub-suppliers, requir -ing new suppliers to participate inthe program, and implementingincentives to improve disclosure.

This issue brief draws on relevantdocuments and interviews withkey stakeholders. The FLA did notsystematically review all the docu-ments and information related to the

products discussed in this brief, nordid it audit the supply-chain controlsystem highlighted here.

CONTEXT ANDBACKGROUNDIn 2011, global paper and paper

board production reached a recordlevel of 399 million metric tons(UBM, 2012). People rely on paperproducts for communication, pack-

aging materials, sanitary needs, doc-umentation, and more. 1 The manygrades and applications of paperrely on ber from natural forests,recycled paper, wood byproducts,and increasingly, forest plantations(Figure 1).

Importers of pulp and paper prod-ucts face challenges complying

with the legality requirement of theU.S. Lacey Act. Identifying the raw

materials used to make paper andassessing their legality can posesigni cant dif culties for variousreasons. Papermaking is a complexprocess where the wood undergoesextensive transformation, involvinga wide variety of actors (Figure 2).

Also, raw materials are easy to blend, and nished products usu -ally involve multiple types of papers,including recycled bers. Finally,

paper products are global commodi -ties and the supply chains that bring

nished products to the store shelvescan originate in far-away countries. According to the UN Food and

Agriculture Organization (FAO),China emerged as a major producerof pulp and paper products overthe past decade. Other countrieslike Brazil, Indonesia, and SouthKorea have also increased produc-tion, while traditional European andNorth American producers havedecreased outputs (Appendix 1).

Pulp and paper importers face risksof encountering illegal wood in their

supply chains, and consequently,potential Lacey Act violations.Recent analyses and investigationslink paper products, particularlyfrom Asia, to controversial sources ortimber harvested illegally. Examplesof these claims include illegal log-ging in protected areas (Eyes on theForests, 2011); use of protected treespecies in papermaking (Greenpeace,2012); taking trees without authori-zation and/or overharvesting (Green -

peace, 2005; Satriastanti, 2011);establishing plantations in violationof the law and without the consent oflocal communities; and failing to payrequired taxes and fees (Gilbert andCortesi, 2011).

STAPLES APPROACH TOPAPER SOURCINGStaples is the worlds largest resellerof a wide range of solid wood andpaper-based of ce products. Withannual sales reaching $25 billionUSD, the company also providesservices and expertise to other of ce-goods suppliers, copy and printservices, and technology (Staples,2012). Presently, Staples operates in26 countries and employs more than88,000 people worldwide. 2 Since the

The many grades and applications ofpaper rely on ber from natural forests,recycled paper, wood byproducts, and

increasingly, forest plantations.


5/22


ISSUE BRIEF | October 2013|

early 2000s, Staples has recognizedthe connection between corporateresponsibility and business pro t -ability. The company has been visibly involved in efforts to improvecorporate environmental sustain-ability, 3 leveraging its role as a major buyer and retailer of wood productsand working with other corporateplayers to build momentum andaccelerate processes to achievecommon environmental goals. 4

To meet consumer demand,Staples sources its products from various countries, including Argen-tina, Brazil, Canada, China, and theUnited States. Many of Staplessuppliers have non-integrated,fragmented supply chains andcould be sourcing ber from manydifferent countries (Staples, 2011;Buckley, 2012).

The companys overall approach toreducing the risk of sourcing illegalraw materials and implementing its

own Sustainable Paper ProcurementPolicy (Box 2) is to increase trans -parency in their paper supply chainsand work with buyers and suppliersto improve sourcing practices.Increasing transparency will enablethe identi cation of the origin of theproducts, to enable Staples manage -ment to assess and manage the risksof illegal wood, and eliminate it fromtheir supply chains. 5

Forest Plantation Area, 2010Thousands of hectares

Forest plantations are expanding to increase forest yields and productivity. Over the last 30 years, plantationshave become common in the tropics, often replacing natural forests. Eucalyptus (57 years to reach maturity),acacia (710 years) and pine (1020 years) are the most common species used in pulp plantations.

Sources: FAO Global Ecooristic ZonFAO Global Forest Resources Assessm

Less than 5,0005,0009,999

10,00019,999

20,000 and greater

NATURAL FORESTS AND FOREST PLANTATIONS AS FIBER SOURCES

F I G U R E 1

Boreal forest Species found in paper products includespruce, aspen, birch, and poplar. These slowgrowing trees (60+ years to maturity) yieldstrong, high quality ber, but are a costlysource of ber.

Temperate and subtropical forest Species found in paper products includemaples, oaks, pine, r and cedar.

Tropical forest Numerous species and very large treare found in tropical forests. Theseforests are under pressure from extenlogging and agricultural expansion.


6/226 |

F I G U R E 2

GENERIC PAPER MANUFACTURING SUPPLY CHAIN

WOOD HARVESTING

STEP

TRANSPORT (8) >>

TRANSPORT (8) >>

TRANSPORT (8) >>

TRANSPORT (8) >>

DESCRIPTION/ACTIVITIES

Logging

DISTRIBUTING Finished products distributed and sold.

PULP MAKING

Raw materials are sourced directly (1) or indirectly. (2) Logs are chipped; chips are mixed; wood bers are extracted through mechanical ochemical processes. (3) Fibers can be whitened to enhance visual features of paper. (4)

PAPER MAKING

Pulp sourcing. (5) Pulp is mixed with water and llers to enhance quality. (6)Mix is placed on a mesh screen where water is drained as bers go through pressindrying rolls.Paper rolls go through a calendaring process to remove imperfections. Coating can be added to improve paper quality. (7) Large paper reels might be slit into rolls or sheets of paper.

PAPER CONVERTING

Paper reels are converted into many types of end-use products. Converting operations include multiple processes including sheeting, slitting, foldibinding, gluing and printing among others. Depending on the country of sourcing,companies can use highly specialized machinery in this process.

Notes:1. For companies vertically integrated with forest companies.2. Pulp manufacturers suppliers can source from a number of sub-suppliers, including sawmills, logging companies, plantation owners, brokers, and private

these actors supply wood to both pulp and paper factories, and buy materials in the open markets and/or from smaller producers or intermediaries.3. Companies that are vertically integrated with pulp manufacturers source directly from them, although they could still purchase materials on the open mark

paper companies can source from a variety of sources, as in number 2.

4. Mechanical pulp: bers are physically pulled apart through mechanical processes. Compared to chemical pulping, the process is less expensive and with hi90%), but bers are not as strong. Chemical pulp: bers are pulled apart using chemicals. The process yields is less (approx. 50%) but bers are strong andpaper types.

5. Until the last 20 years, most of the bers were bleached using chlorine dioxide. The industry has now moved largely to other agents such as oxygen or ozoprocesses include Elemental Chlorine Free (EFC) or Total Chlorine Free (TCF).

6,7. Commonly used llers and coating pigments used include calcium carbonate, talc, clay, and titanium dioxide to enhance brightness and smoothness. Latecan be used to anchor coating pigments.

8. Depending on the level of vertical integration, there might be no transportation needs between pulp and paper manufacturing and/or between paper manufpaper conversion.


7/22


ISSUE BRIEF | October 2013|

IMPLEMENTATION ANDVERIFICATION OF THESOURCING POLICYStaples Sustainable Paper Procure -ment Policy applies to all papergrades and to all suppliers at eachstep along the supply chain. Staplesis rolling out its implementationof the policy in phases, beginning with markets in North America andmoving to Europe and other inter-national markets. The rolloutprioritizes areas of perceived poten-tial high risk based on the countryof origin, source, and transparencyof the supply chain. Supplierssourcing from areas identi ed aspotentially controversial are asked todemonstrate, through credible third-party certi cation, that the sourcedproducts are non-controversial.Top suppliers are also requestedto periodically report the environ-mental performance of their papermaking facilities, or the papermakersfurnishing purchased paper.

Since 2009, Staples has partnered with the Rainforest Alliance, andhas participated in its SmartSourceProgram to develop and implementits paper procurement policy, andto assess the supply chain of theproducts based on random auditsto validate information about itsproducts. Staples chose to work withthe Rainforest Alliance because ofthe Rainforest Alliances expertisein the forest sector, history working

with global companies on sustainablesourcing of forestry and agriculturalproducts, and record in develop-ing environmental standards andadvancing forest certi cation.

SmartSource programoverviewThrough its SmartSource program,Rainforest Alliance provides tailored

advice in developing and implement-ing forest-products sourcing policiesto eliminate illegal and unsustainableraw materials and promote certi edforest products (Rainforest Alliance,2013). 6 In addition to direct adviceand supply chain assessment, pro-gram participants receive corporatestaff and supplier training on forest-related issues, and support with sup-plier and stakeholder communica-tions (Rainforest Alliance, 2011B).

At the core of the SmartSourceprogram is SmartSource360. Smart- Source360 is an internet-basedapplication developed in collabora -tion with Credit 360. 7 It is designed

to trace supply chains by facilitat -ing data compilation, analysis, andreporting. SmartSource360 is aninteractive, automated replace-ment of manual, spreadsheet-basedsystems used to track, analyze, and validate supply-chain information. SmartSource360 is designed to be intuitive and user-friendly, andto accommodate varying levels ofknowledge about supply chains and

STAPLES SUSTAINABLE PAPER PROCUREMENT POLIC

The overall long-term goals of the Staples Sustainable Paper Procurement Policysource paper products that are certied under the Forest Stewardship Council (FSdard, or alternative certication standards when FSC is not available or feasible; products made with post-consumer recycled or sustainable alternative bers; andmaterials manufactured in ways that minimize life-cycle environmental and soci

Suppliers are asked to conrm the sources of the ber in the products, indicate thlegality of the bers harvest and trade, and demonstrate that products do not oricontroversial sources, including:

Wood harvested in violation of traditional and civil rights;

Wood harvested in forests where high conservation value forests are threatene

Wood harvested in forests being converted to plantations or non-forest use;

Wood harvested in forests that contain species that have been genetically modi

Where FSC products are not available, Staples accepts products certied under thProgramme for Endorsement of Forest Certication standards, the Sustainable FoInitiative, and the Canadian Standards Association systems.

Consistent with Staples Sustainable Paper Procurement Policy, suppliers are requcomply with all environmental and forestry laws and regulations as part of StaplCode of Conduct.

Sources:The Staples Supplier Code of Conduct. Online at: http://www.staples.com/sbd/cre/marketing/staplesdocuments/staples-supplier-code-of-conduct.pdf (4/27/12).Staples Sustainable Paper Procurement Policy. Online at http://www.staples.com/sbd/cre/marketing/soul/documents/staples-sustainable-paper-procurement-policy-1.pdf (4/17/12).Mark Buckley, Vice President of Environmental Affairs, Interview, July 2011.

B O X 2


8/228 |

forest issues. The reporting plat-form includes instructional support,including videos, documents, and wizards to guide users through thequestions asked.

The SmartSource360 platform is based on e-mail invitations whereprogram participants invite theirsuppliers and sub-suppliers tologin and provide information anddocumentation about the origin,legality, and sustainability of theproducts (Figure 3). Among otherdata, the information required fromsuppliers includes:

WEIGHT/VOLUME OF WOOD OR FIBERCONTAINED IN THE PRODUCT ASSOLD(i.e., per unit or total).

PRODUCT COMPONENT DETAILS,including the name, geographiclocation, and contact details ofeach sub-supplier, plus sourcecategories (e.g., unknown,known, legal, certi ed,

etc.), species, name, approximate volume/weight, and geographicorigin of each component of theinput material they supply.

SUPPORTING DOCUMENTATION,such as purchase invoices, for-est certi cation documents,and paper pro les. The Smart -Source program requires speci c

documentation for each sourcecategory listed by the suppliers.This data is uploaded onto the

SmartSource360 system by thesupplier, to directly correspond

with the speci c component inputmaterial it represents.

The platform is designed to securelycapture data about the product andproduct components along the sup-ply chain; suppliers only see theirproducts (or product components)and the information provided bytheir immediate sub-supplier. How -

ever, all the supply chain informationis available to Rainforest Alliancestaff and the program participantin this case, Staples.

The more information suppliersand sub-suppliers provide, the morecomplete and transparent the overallsupply chain is. Once the data isuploaded to the system, a productreport is automatically generatedfor each product, showing a break -

down of source category and sourcecountry. In addition, global reportscan be generated, with a variety of

views and data ndings; for instance,the system can separate data by thetotal volume/amount of wood/ ber,

broken down by source category orgeographical origin, for all productspurchased during designated time-frames. Rainforest Alliance staff then

evaluates and validates the informa-tion and supporting documentationprovided, including purchase orders,invoices, contracts, agreements,sustainable forest management

certi cates, and legality veri cationcerti cates, among others. The data validation is based on Rainforest Alliance staff expertise, and focusesmostly on the origin, legality, andcerti cation of the product and prod -uct components. In effect, the datacompiled and analysis generated by SmartSource360 can then be used bythe program participant to create anauditable supply chain, identify po -tential breaks in the chain of custody,

assess risk of sourcing illegal and/or unsustainable products, directsuppliers to locate new sources whennecessary, and thus, implement thecompanys procurement policy.

SmartSource360 is one of severalplatforms that have emerged toallow buyers and suppliers to collect,assess, and share information aboutpaper products. Other platformsinclude the Publishers database

for Responsible EnvironmentalPaper Sourcing (PREPS), and theEnvironmental Paper AssessmentTool (EPAT). 8

SmartSource360 pilot-testingand deploymentBetween 2011 and 2012, Staplesand Rainforest Alliance pilot tested SmartSource360 with ve private-label products that were supplied by four companies. Two products were supplied by a Chinese con - verter, two by a U.S. pulp and papermanufacturer, and one by a Brazilianconverter purchasing from verticallyintegrated pulp and paper manufac-turers. The objective of the pilot wasto assess the capabilities of the tool, with a future deployment to all ofStaples suppliers in mind.

The data validation focuses mostly on theorigin, legality, and certication of theproduct and product components.


9/22



F I G U R E 3

HOWSMARTSOURCE360 WORKS

PROGRAMPARTICIPANT

Program participants identify the products and suppliers. Rainforest Alliance uploads basic information about the products including product names, StockUnits (SKUs, a unique tracking number code to identify products), quantities purchased, suppliernames, supplier company contact information and purchasing channels. Rainforest Alliance e-mails direct suppliers inviting them to log into the system to provide informthe origin, legality and sustainability of the product. Reminders are sent as needed.

WOODHARVESTING

Wood suppliers access the system. Wood suppliers provide information and documentation about the raw materials. Reminders are sas needed.

DIRECTSUPPLIER

Direct supplier (converter, distributor) accesses the system. Supplier identies product components (e.g. board, writing paper and the binding tape in notepad Supplier provides information and documentation about the paper, pulp and bers used in the pro

component, or The supplier invites component manufacturer(s) to log into the system to provide information. Resent as needed.

PAPERMAKER

Paper manufacturers access the system. Paper manufacturers provide information and documentation about the pulp and bers used in the Paper manufacturers invite pulp supplier(s) to log into the system and provide the information. Rare sent as needed.

PULPMAKER

Pulp manufacturers access the system. Pulp manufacturers provide information and documentation about the bers used in the pulp, or Paper manufacturers invite wood supplier(s) to log into the system and provide the information. Rare sent as needed.

CostsFor paper/wood product buyers: Costs vary depending on the number of products and the level of support requested from Rainforest Alliance stexample, for handling up to 4,000 unique product types, the price could be approximately US$40,000 per year, plus additional costs for validatiocover the license fee for the use of the system, costs for training (staff and supplier training), internal operational alignment, and supplier managdata collection, analysis and reporting.

For paper/wood product suppliers: In principle, there should be no signicant additional expenses to suppliers to provide documentation about tprovided that requesting documentation about the product from the immediate sub-supplier is a common business practice. However, there coulimplications in implementing a traceability system and associated activities (i.e. educating and obtaining credible information from sub-supplier

More critically important than the cost of obtaining information from the supply chain to establish traceability is the cost (time and expense) to comply with the policy requirements. The cost of demonstrating compliance could be a barrier to compliance itself.

SUPPLY CHAIN STEP DESCRIPTION/ACTIVITIES


10/2210 |

Each supplier volunteered for thepilot after being approached byStaples. Suppliers received a one-hour, web-based training session by Rainforest Alliance. Through the

training, suppliers were introducedto the tool and learned to navigate itsfeatures using the live tool. The goalof the training was to familiarize sup-pliers with the types of informationrequested and the actions requiredfrom them as pilot participants.Once the trainings were complete( ve in total: one for the Staples staffinvolved in the project and one foreach of the suppliers), suppliers andStaples received login details for the

tool and a four-week timeline to en-ter data for products sold to Staplesduring calendar year 2010.

After the four-week period, Rain-forest Alliance staff evaluated theinformation submitted. The dataand documentation from the U.S.and Brazil-based suppliers was

relatively complete and containedfew errors. With support from aStaples authorized buyer, Rainfor -est Alliance staff followed up withthe suppliers via phone or e-mail torequest clari cation or additionalinformation and documentation.

The data and documentation fromthe Chinese supplier, however, wereincomplete and included errors.Based on their interactions withRainforest Alliance staff, the Chinesesuppliers appeared unaware of thelegality requirements and the impor-tance of supply chain transparency

for Staples. They also lacked materialtraceability systems. In addition, theChinese suppliers voiced concernthat Staples would use the con den -tial business information to circum -

vent the supplier and source directlyfrom sub-suppliers and brokers.

To address these shortcomings,Staples arranged a face-to-face meet -ing between Rainforest Alliance staffand high-level executives from bothStaples and the Chinese supplier.The purpose of the meeting was toexplain the importance of the data-disclosure process, discuss the useof the data collected, and explain the SmartSource360 platform. After themeeting, the Chinese supplier wasgiven an extended deadline to com-plete the reporting (Figure 4).

F I G U R E 4

SMARTSOURCE360 DEPLOYMENT AND DEVELOPMENT

1011/11Additional data

requests andsupplementary

guidanceprovided as

needed

Suppliersand productsidentied

In-persontrainingfor Chinesesupplier

Productdata entry

Data entry,second roundconcludes

SmartSource360 virtual trainings

Data entry,second round(Chinese supplier)starts

Datavalidationstarts

Data validatioconcludesPilot conclud

4/11 7/11 8/11 10/11 11/11 12/11 3/12 7/12


11/22



By the close of the second reportingperiod, the Chinese supplierhad provided additional informationand documentation, but it wasstill incomplete.

RESULTSThrough the SmartSource360 pilot, the U.S.-based supplier dem -onstrated that its ber originatedfrom non-controversial sources, andthe Brazil-based supplier demon -strated that all ber sourced for theproduct was FSC certi ed. However, because the information provided bythe Chinese supplier was inadequate,Rainforest Alliance was unable todetermine the speci c origin andspecies make-up for all of the ber inits products.

Since the conclusion of the pilot,Staples has launched Smart- Source360 with existing private labelsuppliers, focusing on suppliers in Asia rst. As part of the deployment,Staples and Rainforest Alliance havelaunched several training sessions tohelp build capacity within the Staples

team that sources private label prod -ucts out of Asia and direct Staplessuppliers based in Asia. Capacity building so far has included organiz -ing and participating in a responsiblesourcing supplier event at Paper - World China in Shanghai in 2012;delivering web-based and in-persontraining (bilingual) for Staples staffin 2013; bilingual and interactive in-person training for Staples suppliersin 2013; and providing a recorded bilingual web-based training for sup -pliers for ongoing use.

At the time of publication, sixmonths after the pilot concluded,Staples was tracking approximately100 products in the SmartSource360 platform. Fifteen Asia-based sup -pliers were reporting through SmartSource360 , including the

China-based supplier from the pilot

test. Staples and Rainforest Alliancehope that this supplier will close thegaps in the products piloted, as itcontinues to work through its sup-ply chains. In general, the amountand quality of data and supportingdocumentation from the Asia-basedsuppliers for the additional productsis in most cases better than thatexperienced during the pilot, and itcontinues to improve over time.

As more companies ask suppliers

for product data, suppliers will be -come more pro cient at furnishingthe information.

ANALYSIS AND FINDINGSThe pilot highlighted challenges,identi ed areas critical to success,and yielded lessons to both improvethe functionality of SmartSource360 and shape the tools deploymentamong Staples suppliers.

Five key lessons emerged fromthe pilot:

Position in the supply chainmattersPosition in the supply chain is animportant consideration in the con-text of the U.S. Lacey Act; the moreactors involved in the supply-chain,

the more challenging it is to trace

and exercise control over thesupply chain, and the greater the riskof procuring illegally sourced rawmaterials. Compared with convert-ers, distributors or printers, papermanufacturers or integrated papercompanies are better prepared toquickly answer speci c questionsabout the origin of their raw ma -terials and the associated supplychain because they are closer to thesource(s) of the raw materials.

In the pilot, the China-based supplier was a converter, and thus, it wasmore removed from the source of theraw materials. The company had torequest its suppliers to provide infor-mation about their sub-suppliers inorder to gather details and evidenceabout the origin and legality of thepaper and the pulp. This took moretime and additional effort comparedto vertically integrated suppliers.

Buyers and supplierspriorities need to be alignedEnsuring that buyers and suppliersshare the same priorities is critical toensuring that supply chain transpar-ency initiatives work. The U.S. andBrazil-based companies that partici -pated in the pilot test were most

Because the information provby the Chinese supplier w

inadequate, Rainforest Allianceunable to determine the spec

origin and species make-up foof the ber in its produ


12/2212 |

responsive to Staples sourcing prior -ities because they have a long historyof selling into developed markets andare likely accustomed to answeringsupply chain questions.

Staples experience with its China- based supplier is not an exception. Infact, based on Rainforest Alliancesexperience, obtaining good data andactive participation by both the buy -ing company staff and direct supplierduring the rst year of implementa -tion is a common issue, regardless ofthe data collection tools used or theamount of hand-holding that has

occurred. There have been situationsin which the direct suppliers agreeto disclose information and af rmthat they understand the importanceof these requests but the informationdisclosure is, in fact, poor. It may bethat suppliers in some regions of the world are not accustomed to detailedquestions about the sourcing of theirproducts, or requests to provide sup-porting documentation. Also, suppli-ers may not be accustomed to nding

or requesting information from theirsub-suppliers about the origin of theproducts.

Despite these initial challenges, and building on the experience from thepilot, a major focus of the Staplesprocurement policy implementationprocess is outreach and training.To date, Staples has sponsored two

Rainforest Alliance training events with Staples purchasing staff andStaples suppliers to introduce Smart-

Source360 . These trainings aim to build understanding of whyit is important to increase supplychain transparency.

It is critical to overcomesupplier concerns about theuse of condential sourcinginformationSuppliers might worry that by reveal -ing supply chain information, theymight enable their buyers to bypassthem and source directly from sub-suppliers and brokers instead. This isa critical issue buyers need to over -come in order for tools like Smart-

Source360 to work as intended. Evenif direct suppliers are willing to pro-

vide supply-chain information, theirsub-suppliers might be less trust -ing and feel that their supply chainshould remain con dential. Lack ofsupplier and sub-supplier motivationto voluntarily engage in data disclo-sureoften born from a reluctanceto reveal con dential information is a major challenge to supplychain transparency.

The buyer can incentivize supplierparticipation through positive recog-nition. At the same time, the buyercould create negative consequences

for failing to participate or fully dis-close data. To be effective, this typeof reward/consequence incentivemust be made at the highest levelsof the company and communicated

to all purchasing staff and suppliersintegral to purchasing decisions.

Staples is currently developing re -quirements for new suppliers, staffguidelines, and recommended actionsteps for existing suppliers who havenot been able to adequately discloseat the end of the disclosure period.Staples expects to continue to focuson building capacity and transpar -ency among existing suppliers but will take steps to ensure the suppliersmeet disclosure requirements overtime, including requiring third partylegality veri cation or other methods.

From a broader perspective, supply-chain data requests from multiple buyers could be an important reasonfor suppliers to use tools like Smart- Source360 . Instead of responding toone data request, the supplier wouldcompile data to answer to multiplerequests. More information demandfrom buyers could make companieslike Staples more in uential withtheir suppliers, and better able toobtain better data. Some suppliersin the pilot stated that they had notreceived similar information requestsfrom other buyers, including globalcompanies that have made responsible procurement commitments, aboutthe origin of the raw materials at thelevel of detail required by Staples inthe pilot.

Direct communication withsuppliers is importantRelationship building and trust cantake years to develop and can bein uenced by cultural differences. Di -rect communication between buyersand suppliers is critical to overcomingconcerns about the use of disclosed

It may be that suppliers in some regionsof the world are not accustomed to

detailed questions about the sourcingof their products, or requests to providesupporting documentation.


13/22



information. Direct communicationcan also help to align corporate prior-ities. In the pilot, Rainforest Alliance was the direct point of contact withthe suppliers during the data col-

lection stage. This arrangement wasdesigned to expedite the pilot; Staples would be the main point of contactupon implementation of the toolmore broadly. Although unplanned,Rainforest Alliance happened to havea direct relationship with the U.S.-and Brazil-based supplier prior to thepilot, but no prior relationship withthe China-based supplier. Althoughthe information provided by theChinese supplier remained incom-

plete, progress was made only afteran in-person meeting facilitated byStaples China. The meeting empha -sized the importance of the supplierparticipation, and helped build trust between the two corporations. Evenafter the meeting, the China-basedsupplier was unable to obtain all therequested information. It is possiblethat trust issues and relationshipsfarther down the chain to the forestsource may have ultimately affectedthe suppliers ability to obtain therequested information.

Intermediaries can playa role supporting theimplementation of aprocurement policyThe presence of an intermediaryactor to support the implementationof sourcing policies can be useful,especially if the buyers lack the in-house capacity to address legal andenvironmental issues related to forestproducts in the global context. TheStaples-Rainforest Alliance partner -ship has worked in designing StaplesSustainable Paper ProcurementPolicy and rolling up its implemen-tation, but also in reviewing and validating the legality and sustain-

ability features of the products. Yet,completely outsourcing procurementpolicy implementation and control isnot advisable. In the pilot project, forinstance, Staples involvement was

required for reinforcing the impor-tance of its procurement policies withits suppliers, ensuring policy require-ments are well understood, and en-couraging suppliers to fully disclosethe information.

CONCLUSIONThe 2008 amendments to the U.S.Lacey Act are changing the way Sta -ples sources its paper products. Thecompany already had a procurementpolicy in place and was interestedin tracing the supply chain to revealthe source of the ber used to maketwo paper products. The Lacey Actamendments, and the emergence ofother regulations (such as the Euro -pean Union Timber Regulation), havehelped accelerate Staples process.These legality requirements havefocused Staples overall sustainabil -ity agenda to take steps to increasetransparency in their supply chains,exercise due care, address the riskof illegal wood in its products, andprepare for declaration requirements.

According to Mark Buckley, the VPof Environmental Affairs at Staples:The Lacey legality requirementshelp focus attention on sustainabilityand gain visibility; when the legal

department gets involved, people atall levels pay attention. We now needto accelerate the process and involveother companies.

Through the pilot, Staples devel -oped a better understanding of thecomplexity of its supply chains anda clearer vision of next steps. In theshort term, these include reachingout to suppliers and sub-suppliers,and incorporating legality require-ments into purchasing agreements.Staples is committed to use Smart- Source360 with its supplier base. Ifproperly implemented, the system isexpected to yield information at thelevel of detail required for the Lacey Act declaration requirements, shouldpaper products be phased in in thefuture, and to support continued im-provements against the commitmentsin Staples Sustainable Paper Procure -ment Policy.

Although progress is being made,challenges remain. Starting withcommunication, information andeducation, Staples intends to work with its suppliers and bring them to aposition where they are able to meetStaples legality requirements. A par -allel approach that Staples has identi -

ed is to engage with other corporateactors with similar interests to buildmore collective demand for supplychain information. This would, inturn, incentivize data sharing andimprove the quality of the data.

The Lacey legality requiremhelp focus attention on sustainab

and gain visibility; when the ldepartment gets involved, people

levels pay attention.Mark Bu


14/2214 |

Animal and Plant Health Inspection Service(APHIS), 2012. Lacey Act Plant and Plant ProductDeclaration, Special Use Designations. Wash-ington DC: US Department of Agriculture: Online

at http://www.aphis.usda.gov/plant_health/lacey_act/ (1/22/13).

Environmental Investigation Agency (EIA). 2009.The U.S. Lacey Act: Frequently Asked Questionabout the Worlds First Ban on Trade in IllegalWood.Washington DC: Environmental Investiga-tion Agency: Online at http://www.eia-global.org/PDF/EIA.LaceyReport.English.pdf (5/20/13).

Eyes on the Forest. 2011. APP/SMG SupplierClearcuts forest in Biosphere Reserve Zone. Riau,Sumatra: Eyes on the Forest. Online at http://www.eyesontheforest.or.id/index.php?page=news&action=view&id=340 (4/24/11).

Gilber, D. and L. Cortesi. 2011.Corruption, landconict and forest destruction: an Asia Pulp andPaper case study from Sumatra, Indonesia. SanFrancisco: Rainforest Action Network. Online athttp://ran.org/sites/default/les/ran_kerumutan-casestudy.pdf (1/8/13).

Greenpeace. 2012.The ramin paper trail: AsiaPulp and Paper under investigation. Amsterdam:Greenpeace International. Online at http://www.greenpeace.org/international/en/publications/

Campaign-reports/Forests-Reports/The-Ramin-Paper-Trail/ (4/24/12).

Greenpeace. 2005. Illegal logging continues inChina and Asia Pulp and Paper is held respon-sible. Press release. Hong Kong: GreenpeaceEast Asia. Online at http://www.greenpeace.org/eastasia/press/releases/forests/2005/app_ hainan_20050525_html/ (4/25/12).

Rainforest Alliance. 2011A.SmartSource:Rainforest Alliance solutions for responsiblepurchasing. Rainforest Alliance.

Rainforest Alliance. 2011B.SmartSource360: a

web-based tool for supplier reporting required aspart of the SmartSource Responsible SourcingProgram. PowerPoint Presentation.

Rainforest Alliance. 2013.Supply-chain analysisand assistance for legal, traceable and sustain-able supply-chains. Rainforest Alliance website:Online at http://www.rainforest-alliance.org/forestry/sourcing (4/27/12).

REFERENCESSatriastanti. F.E. 2011. Special repor t: how $115b illegal logging probe was felled.TheJakarta Globe : Online at http://www.thejakartglobe.com/archive/special-report-how-a-11

illegal-logging-probe-was-felled/ (10/03/13Staples. 2012. Staples Corporate Prole:Online at http://investor.staples.com/phoenizhtml?c=96244&p=irol-IRHome (4/27/12)

Staples. 2011. Staples and Sustainability. Prtation at the BizNGO annual meeting (Nov 1, 2011): Online at http://www.bizngo.org/pbizngo-agm2011-markbuckley-bizngo-stapand-sustainability.pdf (4/27/12).

United Business Media (UBM). 2012.GlobalPaper and Board Production at Record Levels.UBM Businesses. Online at: http://news.ub

com/index.php?s=2429&item=123825 (5/2U.S. Department of Justice. 2012.Gibson GuitarCorp. Agrees to Resolve Investigation into La Act Violation. Press Release. Washington, D.CU.S. Department of Justice. Online at http:// justice.gov/opa/pr/2012/August/12-enrd-97html (5/20/13).


15/22



1 Paper products can be classied into fourmajor grades: graphic, packaging, hygienicand specialty papers. Graphic papers areprimarily used in newspapers, magazines,

catalogs, promotional materials and generalofce paper. Many of these grades utilizespecial clays and coatings to enhancereadability, gloss or other desired qualityrequirements. Packaging papers are papersof multiple grades used for shipping, foodpackaging, and grocery/shopping bags. Theuse of these grades is rising due to increas-ing global manufacturing and shipping,as well as rising consumption of preparedfoods. Hygienic papers include tissues,toilet paper, kitchen towels, and diapers.Rising incomes in developing countrieshave increased the global use of these paperproducts. Specialty papers are essentiallya catch-all category, including all othergrades of paper used for a wide variety ofpurposes such as cigarette paper, wallpa-per, paperware, wax paper, and paper forindustrial use.

2. Jake Swenson, Director of SustainableProducts and Services, Staples.Review comment.

3. Efforts include: the Environmental Paper

Working Group and the EnvironmentalPaper Assessment Tool (www.epat.org),the Greenhouse Gas Protocol (www.ghgprotocol.org), the Green Power MarketDevelopment Group (www.wri.org/project/next-practice/history), the Forest ProductsWorking Group (www.greenblue.org/activi-ties/forest-products/forest-products-work-ing-group/), and the Carbon Canopy project(www.carboncanopy.com).

4. Mark Buckley, Vice President of Environ-mental Affairs, Staples. Interview, July 2011.

5. Mark Buckley, interview, July 2011.6. The Rainforest Alliance (RA) works to

conserve biodiversity and ensure sustain-able livelihoods by transforming land-usepractices, business practices and consumerbehavior. RA has over 20 years of experi-ence working in over 65 countries with

ENDNOTEScompanies, farmers, and communities sustainable agricultural production andsustainable forest management. For moinformation on the Rainforest Alliance

projects, visit www.rainforest-alliance.7. Credit 360 is a service provider specia

on corporate sustainability data compiltion, management and analysis. For moinformation about Credit 360, please vhttp://www.credit360.com/credit/site/hacds (5/15/12).

8. For more information about PREPS anEPAT, visit http://prepsgroup.com/homphp and https://www.epat.org/EPATHoaspx?request=119.

9. Mark Buckley, interview, July, 2011.


16/2216 |

APPENDIX 1 GLOBAL TRENDS IN PULP AND PAPER PRODUCTIONHistorically the large majority ofpaper was manufactured nearforests. The United States, Canada,

the Nordic countries (Sweden,Finland) China and Japan were largeproducers of pulp. These countries,as well as Germany, have been the

major producers of paper and paper board. In 2000, pulp manufacturedin the US, Canada, China, Japan, and

the Nordic countries represented73% of total global pulp production,per Figure A. For paper and paper

board, per Figure B below, the US,

Canada, Nordic countries, China,Germany and Japan represented 67%of the total global paper and paper

board production. In both of thesecategories, Brazil, Indonesia andIndia were relatively minor players.

F I G U R E A

TOP PRODUCERS OF PULP FOR PAPER* IN 2000

*Pulp for paper includes all pulp (mechanical, semi-chemical, chemical) except dissolving pulp, which is not used for paper (Lev

2013. Personal comment).

18%

3%29%

14%

6%

4%

7%7% 8%

2%

1%

1%

USA

Canada China

Finland

Sweden

Japan

Brazil

Indonesia India

Russia

Chile

Other

F I G U R E B

TOP PRODUCERS OF PAPER AND PAPER BOARD IN 2000

10%6%7%

26%

21%

11%

6%

5%

3%

3%

2%

USA

China

Canada

Brazil Sweden

Finland

Japan

Russia

Indonesia

Chile Other


17/22



F I G U R E C

TOP PRODUCERS OF PULP FOR PAPER* IN 2010

26%

10%

27%

11%

6%6%4%3%

3%

2%2%

USA

China Canada

Germany

Finland

Sweden

Japan

Brazil Indonesia

South Korea

Other

There have been very signi cantchanges in pulp and paper and paper board production in the last decade.China is now the second largestglobal producer of pulp, surpassing

Canada and following the UnitedStates. Brazil has become a signi cantpulp producer (4th largest, nearly

doubling its capacity), and Indonesia,Chile and India are all in the top 11countries. Per Figure C, these veemerging countries now represent24% of total pulp production. The

numbers for paper and paper boardare even more startling. China hassurpassed the United States, growing

from 34.7 to 96.5 million tons andis now the worlds largest producer.South Korea, Indonesia and Brazilare all in the top 10 countries. Thesefour countries, per Figure D, now

represent 33% of global paper andpaper board production.

F I G U R E D

*Pulp for paper includes all pulp (mechanical, semi-chemical, chemical) except dissolving pulp, which is not used for paper (Lev

2013. Personal comment).

TOP PRODUCERS OF PAPER AND PAPER BOARD IN 2010

19%

3%

3%3%

3%24%

27%

6%

6%

3%3%

USA China

Canada Germany

Finland

Sweden

Japan Brazil

Indonesia South Korea

Other


18/2218 |

Demand for pulp and paper andpaper board is signi cant in WesternEurope and North America, althoughgrowth rates have slowed substan -tially since 2007, due to poor eco-nomic conditions and increased useof electronics. Demand is growing

in the developing world, especiallyChina, India and Brazil, due togenerally improving economicconditions, increased literacy anda growing consumer culture thattypically uses more packaging mate-rials. Yet, per capita consumption inthese countries is still considerablyless than in Europe, North Americaand Japan.

There has been a dramatic shift oftrade ows over the last ten years.China has become by far the larg -est market for pulp, with close to 14million tons now being imported tosupport its vast paper manufactur-ing operations. Major exporters into

China include Canada and Indonesia.In addition, Brazil, Chile, Indone-sia and Uruguay have now joinedCanada, the U.S., the Nordic coun -tries and Russia as major exportersof pulp. See Figure E comparing pulptrade ows from 2000 and 2010.

The shift for paper and paper boardis less dramatic. However, the UnitedStates is now importing large quanti -ties of paper and paper board from

new manufacturers in China, Koreaand Indonesia. Other major importmarkets include Western Europe(especially Germany), and develop -ing countries. For exports, whileGermany, the U.S., Canada and theNordic countries remain the top ve

exporters, China, Indonesia, Italy,Spain and Brazil have grown sub -stantially since 2000. See Figure F,comparing paper and paper boardtrends in 2000 and 2010.

Another emerging trend is theincreased reliance on pulp fromplantations, particularly Indonesiaand Brazil. As production capac-ity increases in Asia, particularly

F I G U R E E

TRADE FLOW OF PULP FOR PAPER

12

-9

-6

-3

0

3

6

9

12

15

U S A C h i n a C a n a d a B r a z i

l

S w e d e n

F i n l a n d J a p a n R u s s i a

I n d o n e s i a C h i l e S p a i n G e

r m a n y I t a l y

N e t h e

r l a n d s

Pulp Imports, 2000

Pulp Imports, 2010

Pulp Exports, 2000

Pulp Exports, 2010


19/22


20/2220 |

ABOUT THE AUTHORSRuth Noguern is an Associate at the WorldResources Institute.Contact: [email protected]

David Refkin , is the President of GreenPathSustainability Consultants.Contact: [email protected]

Keri Hess, is a Senior Manager, Markets,Sustainable Forestry Division with Rainforest Alliance.Contact: [email protected]

ABOUT WRIWRI focuses on the intersection of the envirand socio-economic development. We go beresearch to put ideas into action, working glwith governments, business, and civil socie

build transformative solutions that protect thand improve peoples lives.

Solutions to Urgent Sustainability ChallengesWRIs transformative ideas protect the earth,development, and advance social equity becasustainability is essential to meeting human ntoday, and fullling human aspirations tomor

Practical Strategies for ChangeWRI spurs progress by providing practical stfor change and effective tools to implement tWe measure our success in the form of new pproducts, and practices that shift the ways go

ments work, businesses operate, and people

Global ActionWe operate globally because todays probleknow no boundaries. We are avid communibecause people everywhere are inspired by empowered by knowledge, and moved to chby greater understanding. We provide innovpaths to a sustainable planet through work taccurate, fair, and independent.

ACKNOWLEDGMENTSThe following stakeholders were interviewed andconsulted for this issue brief: Bernard Lombard(CEPI); Arvydas Lebedys (FAO); Mark Comolli(Rainforest Alliance); and Mark Buckley and Jake

Swenson (Staples).We thank our colleagues at the World ResourcesInstitute: Loretta Cheung, Hyacinth Billings,Caitlin Clarke, Daryl Ditz, Laura Draucker, AdamGrant, Andrew Leach, Suzanne Ozment, NickPrice, Ashleigh Rich, Tien Shiao, Nigel Sizer andDavid Tomberlin.

We thank the following reviewers who contributedto the development of this case study: MeganDickie (formerly with the Environmental Investiga-tion Agency), Marialyce Pedersen (The WaltDisney Company), Phil Riebel (TwoSides U.S.)and Nick Sammons (Carnstone Partners LLP).

The authors retain full responsibility for anyremaining errors of fact or interpretation.

Editor, Emily Shabacker.

This study is made possible by the generous support of the American people through the United States Agency for International DevelopmeThe contents are the responsibility of the World Resources Institute and the Environmental Investigation Agency and do not necessar

reect the views of USAID or the United States Government.


21/22

Each World Resources Institute issue brief represents a timely, scholarly treatment of a subject of public concern. WRI takes responsibilitythe study topics and guaranteeing its authors and researchers freedom of inquiry. It also solicits and responds to the guidance of advisory

expert reviewers. Unless otherwise stated, however, all the interpretation and ndings set forth in WRI publications are those of the a

Copyright 2013 World Resources Institute. This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivativeWorks 3.0 License. To view a copy of the license, visit http://creativecommons. org/licenses/by-nc-nd/3.0/


22/22

10 G STREET NESUITE 800WASHINGTON, DC 20002, USA+1 (202) 729-7600WWW.WRI.ORG ISBN 978-1-56973-814-6

untangling the paper chain: how staples is managing transparency with suppliers

Documents