Wood Procurement Policy

Background and Purpose:

As New York states largest furniture grade hardwood processing business, The Wagner Companies purchase and process tens of millions of board feet of logs and timber annually. Logs and standing timber are purchased from independent loggers, other hardwood mills, professional log brokers, consultant foresters and private landowners throughout New York and Northern Pennsylvania. There is an increased need for purchasers of raw materials to be acutely aware of the origination point of the products they procure. At the very least, users of wood products should be aware of the ethical standards of the persons and businesses they purchase from.

The threat of unauthorized harvesting of trees and selling of logs looms large in our industry due to:
• the relatively poor economy in Upstate New York and Pennsylvania
• the unregulated nature of the hardwood timber industry
• the diversified nature of the supplier chain which brings wood products to market
• changes in land ownership patterns

Therefore, to stem the tide of further regulation from outside our industry; as well as, our obligation to society to operate a legitimate, ethical business; Wagner has adopted the following as a policy and guide to procuring wood products.

The Policy:

• Wagner only wants to buy logs from legitimate and legally operating businesses and individuals.
• Wagner will keep on file current contact information on all suppliers of raw materials to our operations.
• Wagner will stay engaged, to the extent possible, with all suppliers to assure the quality and legitimacy of the suppliers'operations.
• Wagner will not purchase logs knowingly from individuals or businesses which have been convicted of the intentional stealing of wood products.
• Wagner will not purchase logs from a supplier where we have had three separate complaints due to non-payment of raw materials that the supplier is known to have received payment.
• Wagner will not purchase any logs from a supplier where a complaint of non-payment has been made and has not been satisfied.
• Wagner will cooperate completely with any investigation into the theft of forest products with the following conditions:
   - Wagner will provide public law enforcement authorities with any information requested in a timely manner, when possible.
   - Wagner will release information regarding specific purchases to second or third parties in that transaction (or series of transactions) to an attorney handling the matter for these parties. This request must come in writing on the letterhead of the affected parties' attorney. Exceptions would be when Wagner has specific knowledge that the second or third party is, in fact, the aggrieved party of record.
   - All complaints due to illegitimate operations, as well as, all requests for information of a specific transaction must be directed to the Head of Procurement.