Purpose

Protecting forests is essential for preserving biodiversity, tackling climate change, and supporting livelihoods. As part of our broader commitment to sustainable sourcing and responsible business practices, IWG seeks to eliminate deforestation across our operations and supply chain before 1 January 2030.

IWG will seek to ensure that its direct operations and any production and sourcing activities within its supply chain do not knowingly cause or contribute to the loss or degradation of natural forests (deforestation). IWG will take reasonable measures consistent with applicable laws and recognised best practices. These measures cover not only illegal deforestation but also legally sanctioned activities that lead to deforestation.

IWG recognises the increasing regulatory, environmental, and stakeholder expectations associated with sustainable sourcing practices and is committed to ensuring that the company is appropriately positioned to respond to these developments.

This policy aims to ensure IWG complies with existing regulatory requirements, including but is not limited to, the European Union’s Deforestation Regulation (EUDR) and applicable regional requirements.

To support our goal, IWG aims to:

• Strengthen supply chain traceability and transparency, by requesting suppliers of high-risk commodities to provide origin information and demonstrate that materials are deforestation-free from 2020 in line with the expectations of EUDR;
• Use alternative verification methods, such as third-party certification (e.g., Forest Stewardship Council (FSC) certified goods) where direct traceability is not feasible;
• Utilise a risk-based approach based on sourcing region and impact of materials to prioritise actions;
• Align its practices and definitions with credible frameworks and regulatory requirements
• Respect and promote human rights, including the rights of workers, local communities, and indigenous peoples.

Scope

IWG will progressively extend this commitment to all high-risk suppliers and seek engagement from indirect suppliers using leverage where appropriate and within the limits of our influence and control consistent with recognised due diligence standards.

At present we consider the following materials for deforestation risk:

• Materials (and their byproducts) at risk of being linked to deforestation and ecosystem conversion, including but not limited to:
• Timber
• Paper
• Cotton
• Wool
• Coffee
• Tea
• Cocoa
• Rubber
• Palm oil & derivatives

To enforce this commitment, IWG requires all suppliers to adhere to its Supplier Code of Conduct.

We aim to source only from direct suppliers who comply with these requirements and expect them to pass on our deforestation-free commitments upstream to their own suppliers, ensuring compliance throughout the supply chain.

Additionally, we expect all suppliers to fully align with IWG Standards as soon as possible and no later than 1 January 2030.

Definitions

Cut-off date: This date specifies the permissibility of deforestation based on the timing of such events on the ground. Clearance of natural forest after the cut-off date renders the affected area or production unit, and the commodity produced there, non-compliant with no deforestation commitments.

Deforestation: Loss of natural forest as a result of: i) conversion to agriculture or other non-forest land use; ii) conversion to a tree plantation; or iii) severe and sustained degradation.

EUDR - EUDR is an EU law designed to stop products linked to deforestation being sold in Europe. The EUDR sets obligations for operators and traders who place commodities (cattle, wood, cocoa, soy, palm oil, coffee, rubber – collectively known as forest risk commodities) and derived products onto the EU market, or exports from it, to prove the product does not originate from recently deforested lands or have contributed to deforestation.

Ecosystem conversion: Loss of a natural ecosystem due to its replacement by other land uses (like agriculture) or severe, sustained changes in its species, structure, or function.

Natural forests: A forest that is a natural ecosystem.  Natural forests possess many or most of the characteristics of a forest native to the given site, including species composition, structure, and ecological function. Natural forests include:

• Primary forests that have not been subject to major human impacts in recent history.
• Regenerated (second-growth) forests that were subject to major impacts in the past (for instance by agriculture, livestock raising, tree plantations, or intensive logging), but where the main causes of impact have ceased or greatly diminished and the ecosystem has attained much of the species composition, structure, and ecological function of prior or other contemporary natural ecosystems.
• Managed natural forests where much of the ecosystem’s composition, structure, and ecological function exist in the presence of activities such as:
• Harvesting of timber or other forest products, including management to promote high-value species.
• Low intensity, small-scale cultivation within the forest, such as less-intensive forms of swidden agriculture in a forest mosaic.
• Forests that have been partially degraded by anthropogenic or natural causes (e.g., harvesting, fire, climate change, invasive species, or others) but where the land has not been converted to another use and where degradation does not result in the sustained reduction of tree cover below the thresholds that define a forest or sustained loss of other main elements of ecosystem composition, structure, and ecological function.

Target date: This date is the date by which IWG intends to have fully achieved or adhered to its commitment.

Compliance with Legal Requirements

IWG has adopted a deforestation-free cut-off date of 2020. Any area where natural forests have been cleared or degraded since this date is considered non-compliant, and raw materials from such areas may not enter IWG’s supply chains.

This cut-off does not override earlier dates set by specific biomes or certification schemes or specific regulatory obligations.

Mechanisms of Implementation

To implement and demonstrate progress towards our commitments, IWG further commits to:

Risk assessments

We leverage our existing data systems to conduct a high-level risk assessment, helping us prioritize actions where risks are highest.

Transparency and traceability

We continue working towards greater transparency and traceability across our supply chains to promote compliance with deforestation-free commitments, including indirect suppliers and incorporation of third-party verification.

Supplier engagement

We are strengthening supplier requirements and engagement mechanisms to support full implementation of our deforestation-free commitments by:

• Embedding these commitments within our IWG Supplier Code of Conduct, which are part of IWG’s supplier contracts. We expect our suppliers to establish their own policies to manage deforestation risks, in alignment with best practice industry guidance.
• Collaborating with suppliers to identify, address, prevent, mitigate, and, where necessary, remedy environmental and social harms. This includes measures such as restoration, compensation, or remediation of past impacts.
• Strengthening traceability across the supply chain, by maintaining digital records that align with EUDR requirements.

Restoration and compensation

In cases where deforestation or conversion has occurred after the cut-off date, IWG will encourage affected suppliers to pursue restoration or compensation measures where feasible.

Monitoring, verification and reporting

We will enhance our traceability systems and engage a third-party verified monitoring, verification, and reporting framework to assess and disclose progress regularly. We are committed to sharing updates on compliance and advancements toward our deforestation-free goals. Suppliers found to be non-compliant will be required to implement corrective action plans, and where material breaches persist, Suppliers may face contract suspension or termination.

Pathways for Compliance for Each Material Group

All of the materials outlined below form part of this policy. Priority will be given to those in descending order due to the associated higher risk based on our higher purchase volumes and/or disproportionate potential impact on natural ecosystems.

Roles and Responsibilities

IWG’s independent Board of Directors, regularly reviews and assesses performance and ensures alignment with its corporate strategy. The Board sets targets and frameworks to comply with, for the business, based on the business department and jurisdiction.

Compliance

Compliance with the no deforestation commitment will be monitored by IWG’s Procurement, Supply Chain, and Sustainability teams with progress reported annually through IWG’s Sustainability Report. Non-compliance will be escalated in accordance with IWG’s internal risk management and supplier governance process.

Sources

This commitment was created with consideration and input from the following:

• https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en
• Supplier Code of Conduct

Revision

This policy is reviewed annually and updated in line with evolving best practice, and regulatory requirements.