This particular company has done everything it can and is doing the right thing from an environmental point of view.” ~ Dr. Patrick Moore, Greenpeace Cofounder and Green Spirit Founder

Timber Holdings USA owners of the original Iron Woods® brand of Naturally Durable Hardwood building products, the 48th company FSC (Forest Stewardship Council) Chain of Custody certified by the Rain Forest Alliance, Founders of the Fields To Forests Tropical Reforestation Program™ and Green By Nature…Build with Conscience™ Environmental Compliance Program is taking building products certification to the next level with the implementation of independent third party NGO Verification of Legal Origin and Legal Compliance.

In the face of growing public concerns over the legal harvest of forest products prompted by U.S Department of Agriculture Lacey Act and investigations into two of the country’s largest guitar and flooring manufacturers, Timber Holdings USA, the owners of the Iron Woods brand of naturally durable hardwood building products has voluntarily taken “Environmental Due Care” to its highest level by engaging NGO Unifloresta™ to audit all of the companies procurement transactions in Brazil. Under Their Legal Verification Program, Unifloresta™ independently evaluates and verifies the authenticity and legality of all chain of custody documentation from harvest to export.

“Timber Holding’s demand for increased legal accountability was a driving force in the development of Unifloresta Consult’s Legal Verification program”  ~ Joris Mendes, Unifloresta

Since Timber Holdings first introduced naturally durable hardwood decking to Atlantic City in 1971, environmental ethics have stood as the cornerstone of the Iron Woods® brand of naturally durable hardwood decking, siding and lumber products.

Global forests sustainability requires a comprehensive approach, one that starts with Life Cycle Analysis or the process of determining how environmentally benign any given product is on the environment throughout the course of its life cycle. Naturally Durable Wood Products have some unique benefits when it comes to Life Cycle Analysis.

Forests by their nature when sustainably managed are a naturally occurring, renewable and sustainable resource. Sustainably managed forests support a host of other natural resources. Naturally durable products are100% organic growing without the use of genetic modification or chemical fertilization. Used in the appropriate application wood products have a useful service life which exceeds their natural growth cycle. Wood products sequester and store carbon throughout their useful service life cycle. Naturally durable wood products generate zero post-industrial and post-consumer non-biodegradable waste. Wood product production consumes less energy than the conversion of any other natural resource often using its own post industrial waste to generate the energy required for processing. Naturally durable wood products are 100 percent biodegradable at the end of their useful service life returning to nature as natural organic waste. Naturally durable wood products do not require for service any petroleum based or inorganic chemical treatments, bonding agents or coatings. Naturally durable wood products do not require for service any high energy consumptive thermal or chemical modification. Naturally Durable wood products are safe for contact with humans and

animals. Naturally durable wood products do not require for service, any specialized handling, storage or disposal procedures. Naturally Durable Wood Products meet Low VOC emission standards being free from any inorganic off-gassing. Naturally durable wood products can be used, reused or recycled without the use of chemical processing. In a holistic sense wood products and the forests they derive from are by their very nature environmentally benign if managed sustainably.

Sustainable management of tropical forests, the primary source of naturally durable wood products starts with the ITTO (International Tropical Timber Organization) and the ITTA (International Tropical Timber Trade Agreement). The ITTO is an international organization made up of member countries having signed the ITTA, an agreement committing those countries to the development and implementation and enforcement of international and domestic laws and regulations designed to promote forest sustainability. Procurement of wood products from countries are non-members of the ITTO, having signed the ITTA should be avoided.

The primary international law pertaining to sustainability is compliance with CITES (Convention on the International Trade of Endangered Species).  CITES through its appendixes identifies those species of plants and animals which are either endangered or at risk of becoming endangered. It is illegal to trade in any species listed in Appendixes I (Endangered) and species listed in Appendices II (At risk of becoming endangered) should be avoided. The starting point of sustainability is to direct purchases to those species which have been and continue to be sustainably managed.

As a member country of the ITTO the U.S Department of Commerce, U.S. Department of Agriculture and U.S Department of Justice collectively enforce both CITES and the U.S. Lacey Act. The U.S. Lacey Act is a federal law enacted in 2008 which makes it a federal crime to buy, sell or possess illegally harvested plant and forest products. The law requires “Due Care” be

exercised in the procurement and distribution of wood products. Eliminating the veil of corporate protection, the civil and criminal penalties are severe including the seizure of property, fines and incarceration. In a nut shell the USDA has the same powers as the USDEA has under its drug enforcement laws. Under the Lacey Act wood importers must declare species, volume, country of origin and verification that the materials imported were harvested legally and in compliance with all international and domestic laws pertaining to the legal trade of forest products. This not only includes chain of custody forest to import but also, social laws pertaining to traditional or civil rights,  financial laws including payment of taxes and any potential violation of the U.S.Foreign Corrupt Practices Act, a law which makes it a federal crime to engage in any act of bribery in the engagement of any act of commerce.

The U.S. Lacey Act puts the responsibility for Due Care squarely on the chain of distribution, and those who buy wood products at every level throughout the chain of custody. By it’s nature the U.S. Lacey Act demands that buyers of wood products use every resource available to verify the legality of the wood products we buy and sell. Self-policing by its nature is always suspect which is where independent third party verification comes in.

Engagement of third party NGO’s like Unifloresta, Rain Forest Alliance and the Forest Stewardship Council through their environmental auditing processes provide an impartial audit of chain of custody and verification of ‘Due Care’.

While these laws and regulations exist to protect our environment, ‘Due Care’ is in fact a moral obligation. We are in fact exactly what we do. Our ethics define the very nature of who we are as stewards of our planet.

While no system is fool proof Timber Holdings has and continues to maintain our commitment to leading our industry through example.

“Ethical business practices come at a cost and when it comes to Forest Stewardship you get exactly what you pay for. Our customers know that when they purchase an Iron Woods® brand product they are getting more than just a piece of wood…they get the peace of mind that comes from knowing that they have purchased sustainable building products that have been produced both legally and ethically.

Brian Lotz Director of Business Development THUSA.