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I. Introduction This protocol sets the framework for assessing, remediating and mitigating the farms at risk of deforestation and non-compliance with the European Deforestation Regulation (EUDR) in the Tony’s Open Chain supply chain. The EUDR mandates that companies involved in the export and selling of key commodities (including cocoa) on the European market: (i) maintain traceability data for the plots where the materials are produced, (ii) provide evidence that these plots have been deforestation-free since December 31, 2020, and (iii) ensure that cocoa production on each plot adheres to the relevant legal frameworks regarding forest protection, labour rights, and human rights. Although Tony’s Open Chain is not mandated by EUDR to comply with these obligations, we are committed to environmental sustainability and aim to support our supply chain partners in the due diligence process. By implementing this protocol, Tony’s Open Chain seeks to (1) enhance transparency in its supply chain and contribute to responsible cocoa sourcing, (2) ensure farmers are not unfairly excluded from the cocoa supply chain due to European regulations, and (3) provide support to farmers to recover degraded forest areas and practice forest-positive cocoa production.
Scope
This protocol applies to: - All partner cooperatives that Tony's Open Chain has a signed agreement with. - All the farmers that are connected to these partner cooperatives. - Tony’s Open Chain supply chain partners who conduct deforestation risk analysis.
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Definitions
1.1.
Deforestation : Forest land: Land that covers over 0.5 hectares (ha), featuring trees taller than 5 meters and a canopy cover exceeding 10 percent, or trees capable of reaching these sizes in their natural setting. This definition excludes areas primarily used for agriculture or urban development. 1 Deforestation is the conversion of forest to other land uses or the long-term reduction of tree canopy cover below the minimum 10% threshold. 2 This definition, aligned with the Food and Agriculture Organization of the United Nations (FAO) definition, emphasizes the loss of forest cover due to human activities or natural causes, leading to significant ecological and environmental impacts. At TOC we select our deforestation risk analysis partners in line with their ability to carry out satellite monitoring that is aligned to FAO’s definition of forest and deforestation. We define deforestation as tree cover change of at least 0.5 ha in an area defined as forest. It is important to note that if the land was not a forest as per the “forest land” definition above, and it has undergone tree cover change of the size of 0.5m, then this tree cover change cannot be considered deforestation. Polygon mapping Polygon mapping is a technique used in geographic information systems (GIS) to represent areas or regions by defining the boundaries in the form of polygons. Polygons are geographic data—shapes formed by connecting a series of points (vertices) that enclose a specific area on a map. Each polygon is created by connecting multiple GPS coordinates, forming a closed shape that outlines a particular area. Polygon mapping is useful for representing various geographical features, such as cocoa plantations or forests.
1.2.
1 FAO, 2020. Global Forest Resources Assessment 2020. Terms and Definitions FRA 2020. Food and Agriculture Organization of the United Nations (FAO). Forest Resources Assessment Working Paper No. 188. 2 FAO, 2018. The State of the World’s Forests 2018 - Forest Pathways to Sustainable Development.
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1.3.
Protected Areas Protected areas are geographical spaces that are recognized, designated, and managed through legal or other effective measures to ensure the long- term conservation of nature, along with its associated ecosystem services and cultural values. These areas are classified into six categories, ranging from Category I, which restricts human access, to Category VI, which allows specific human activities. 3 Protected areas can include forest land, as defined by the forest land definition above. In Côte d’Ivoire 4 and Ghana 5 , protected areas include natural reserves, classified forests, national parks, wildlife reserves, and forest reserves, where specific regulations and legal frameworks are in place to safeguard the forests from logging, agricultural expansion, and other forms of exploitation. Ground-truthing : At Tony’s Open Chain, ground-truthing refers to the process of conducting farm and partner cooperative visits to validate and verify remote sensing data through field observations and data collection (photos, GPS coordinates, completion of questionnaires to partner cooperatives and farmers, etc.). This involves visiting locations to confirm the presence or absence of cocoa plantations in at-risk areas, assessing land-use changes on farm, and surveying partner cooperative staff and their farmer members to understand the potential factors that may influence the deforestation risk status of specific farms. Remediation : Remediation refers to action taken to restore a degraded environment, educate and raise awareness on the environmental laws and regulations, or provide any other support in response to deforestation detection in the
1.4.
1.5.
3 International Union for Conservation of Nature (IUCN), 2008 and 2013. Guidelines for Applying Protected Area Management Categories. 4 Biodiversité de Côte d'Ivoire 5 Ghana Wildlife Society, 2015. Abridged Legislative Report . Retrieved from https://www.ghanawildlifesociety.org/wp-content/uploads/2015/12/GWS-Abridged-Legislative-Report- 1.pdf
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Tony’s Open Chain supply chain. In the context of environmental restoration, remediation might include: reforestation (planting trees in deforested areas to restore forest cover), tree regeneration efforts (encouraging the natural regrowth of trees through practices like assisted natural regeneration, where existing native flora is nurtured to recover and thrive), or the implementation of sustainable agricultural practices (i.e. agroforestry). Remediation aimed at responding to social factors may encompass education and training programs to local communities, supporting fair land tenure and rights, facilitating access to social services, or implementing community-based conservation projects to promote sustainable resource management.
1.6.
Mitigation
Deforestation mitigation refers to efforts and strategies aimed at reducing or preventing the loss of forests. It involves actions such as investing in cocoa productivity, promoting agroforestry, community-led tree-planting, protecting forests and their ecosystems or direct investment in a farm (with a high probability risk of deforestation) to improve cocoa production and/or income. At Tony’s Open Chain, mitigation is targeted at any farm which is considered to have a high probability of deforestation after a satellite imagery analysis or field visits.
1.7.
Legal documents :
Legal documents in the context of ground-truthing for deforestation events are official papers that outline rights, responsibilities, and agreements related to land ownership, use, and practice of agriculture in permissible areas. These documents might include land titles, government permissions, government maps, concessions, permission agreements and others. Legal documents play a crucial role in the environmental traceability and ground-truthing process. Legality can also be agreed upon by verbal agreement in specific contexts. For example, in Ghana, verbal agreements are recognized as contractual, if there are witnesses. This is the most common form of
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landownership available. Predominantly, sharecropping agreements are also verbal. Our approach addresses the complexities of informal land agreements, providing administrative support to farmers to formalize verbal commitments into legally recognized documentation when relevant, thereby promoting greater transparency and security for all parties involved. Under EUDR, companies must provide evidence that cocoa is sourced from land that is managed in accordance with local laws, which includes land- ownership laws. In addition, both Côte d'Ivoire and Ghana have implemented policies which regulate the use of land for agriculture in some protected forested areas. It is therefore important to gather evidence of these permissions, in case farms are in these protected areas.
1.8.
Reintegration :
Reintegration refers to the process of re-adding a farm to the Tony’s Open Chain supply chain registry after it has been previously removed due to deforestation risk concerns. This process typically occurs once the farm has successfully completed deforestation remediation, demonstrating key performance indicators such as restoring targeted areas from bare soil to a developing forest within the expected timeframe. In such cases, the farm will be remapped and reintegrated into the supply chain, provided that the updated map is deforestation-free. Additionally, reintegration can take place when discrepancies arise between Tony’s Open Chain’s and its partners’ assessments of EUDR non-compliance. Following the reintegration protocol, all partners must agree that the farm should be reintegrated based on the methodology that provides the highest confidence in the compliance results, ensuring the integrity and sustainability of the supply chain.
1.9.
Tony’s Open Chain Supply Chain Network:
Tony’s Open Chain works with two types of core supply-chain partners: processing companies that transform beans into semi-finished cocoa
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products, and exporters that support traceability, responsible sourcing and exports. Our partners have a legal obligation to apply the EUDR, since the regulation targets companies placing cocoa on the EU market. Together, we enable our mission of traceable deforestation free cocoa.
II. Deforestation Risk Analysis Protocol
1. Completion of the Farmer Register and Farmer Master Dataset (FMD)
What? Tony’s Open Chain, together with partner cooperatives and partners in the Tony’s Open Chain Supply Network, aligns on a list of farmers that will be eligible to deliver cocoa prior to the start of every season. This list of farmers is based on validated data that allows Tony’s Open Chain to trace exactly which farmers and plots deliver cocoa into the supply chain, and to perform various analyses, including deforestation risk analysis.
When? Before the cocoa season begins
Key steps in the process: • Data request : Tony’s Open Chain requests partner cooperatives to submit farmer and farm data via email, with specific requirements for the Farmer Register. This includes assigning a unique code to each farmer and farm, recording their information in a single Excel row, and using a standardized format with structured names (Last Name, First Name). Geolocation data for all cocoa plots must be provided. Each polygon must be associated with the correct farmer code from the farmer/farm register. The productive cocoa area (in hectares) must be polygon-mapped and linked to a unique polygon in the polygon database. • Revision : The data submitted by partner cooperatives is reviewed for completeness, accuracy, and consistency by Tony's Open Chain and relevant partners in the Tony’s Open Chain Supply Network. Partner cooperatives will be asked to correct any data errors or issues identified through this process (for example, completing required information that may be missing, correcting inaccurate data formatting, or addressing polygon overlaps and re-mapping plots where applicable).
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• Finalization of FMD : Any farmer/farm that misses or contains inconsistent data on the mandatory fields on the final date of submission will be excluded from delivering to Tony’s Open Chain in the next cocoa season, as they will not be included in the FMD. To ensure this data is available for use in various analyses, the final approved datasets together with all the intermediate datasets are locked and stored in a centralized location.
2. Deforestation Risk Analysis
What? All farms in the Farmer Register must be assessed for deforestation by Tony’s Open Chain’s Deforestation Risk Analysis partner(s).
When? Before the cocoa season begins.
Key steps in the process: • Data submission : The Tony’s Open Chain Data Team submits all polygon data from the Farmer Master Dataset with Enveritas, our third-party Deforestation Risk Analysis Partner. • Land cover change analysis : Enveritas conducts an analysis to answer several key questions, including the question: “Which farms have seen non-compliant deforestation after 2020?”. The methodology combines very high-resolution satellite imagery (0.5 meters) with ground-truthing, as well as a team of full time data labellers to review the satellite imagery and reduce risk of false positives. Enveritas relies on two in-house models: - 2020 Base Land Cover Model : This deep learning model uses diverse imagery sources at different resolutions to classify land types in local contexts, such as forest, cocoa, coffee, palm oil, rubber, and water. The model is designed to perform reliably across various sensors and resolutions, and to overcome challenges related to cloud cover or missing data. - Annual Change Detection Model : This takes as input the land cover outputs before and after a given year, along with a series of images in between. It then estimates whether deforestation occurred during the year of interest. Together, these models work to identify deforestation activity and establish the nature of any subsequent agricultural land use (cocoa farming, or another crop).
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• Manual review : The initial modelled results are subject to rigorous manual review by a team of trained Enveritas analysts with deep regional expertise in coffee, cocoa, and palm-producing origins. These reviews confirm that deforestation occurred and validate the subsequent land use. This process allows Enveritas to identify locations where forest was specifically converted to EUDR-restricted commodities, such as coffee or cocoa, after 2020. Enveritas also verifies that the polygons do not intersect or overlap with Protected Areas delimited maps provided by CFI 2019. If doubt persists, Enveritas is able to rapidly deploy field teams locally to conduct ground- truthing. • Probabilistic risk of deforestation : Enveritas also conducts an analysis to answer the question: “What is the probability of future deforestation for each farm?”. This analysis supports proactive risk mitigation by identifying farms that may require early outreach or agronomic support. Using this model, deforestation can be predicted by applying a spatial risk model that considers a variety of indicators around each plot. We assess the probability of future deforestation based on proximity to key risk factors. These include the presence of forest within a defined buffer, which may indicate potential encroachment zones, and historical deforestation within a wider radius, which can reveal patterns of nearby forest loss that signal ongoing or expanding threats. These spatial indicators are layered into a scoring system or model that outputs an annual risk estimate at the plot level.
3. Consequences
What? Tony’s Open Chain uses the Deforestation Risk Analysis results to determine next steps.
When? Before the cocoa season begins
Overview of consequences • If the deforestation risk analysis states a farm is compliant to EUDR The farm remains in Tony’s Open Chain’s Farm Register for the season and is allowed to deliver.
• If the deforestation risk analysis states a farm is non-compliant to EUDR
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The farm is removed from the season’s Farm Register and is not allowed to deliver. The ground-truthing and remediation protocol (see section III below) is enacted. • If the deforestation risk analysis results suggest a farm has a high future risk of deforestation, based on the probabilistic risk analysis A visit to the farm is conducted to develop a mitigation plan aimed at reducing the risk of deforestation. Mitigation includes adopting sustainable land-use practices, protecting forests and their ecosystems or making direct investment (i.e., inputs) to improve cocoa production.
4. Reconciling discrepancies with Supply Chain Partners
What? While Tony’s Open Chain and its supply chain partners share a common Farmer Registry, they employ different Deforestation Risk Analysis providers. Utilizing multiple systems within the same value chain enhances compliance verification and improves the accuracy of deforestation risk assessments thanks to a multi-faceted verification process. Tony’s Open Chain, as part of this process, will compare its data against that of supply chain partners.
When? 1 October – 1 January
Key steps in the process: • Compilation of non-compliant farms across all partners : Tony’s Open Chain will compile a list of all EUDR-non-compliant farms: from its supply chain partners and from its own Deforestation Risk Analysis partner. All the farms for which there is discrepancy, meaning one partner believes the farm is compliant, and the other partner believes the farm is non-compliant—will be further evaluated through the reintegration protocol. • Reintegration Protocol : In the case of discrepancies between the results of Tony’s Open Chain and its supply chain partners, the Tony’s Open Chain reintegration protocol will be implemented to evaluate, on a case-by-case basis, which methodology provides the most reliable results, to reduce the chance of farmers being unfairly excluded and non-compliant farms entering the supply chain. This reintegration protocol involves a comparative analysis of methodologies— focusing on data collection, processing techniques, validation steps, and data accuracy. It will also involve a farm-level review, assessing individual plots with
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historical images, forest overlap, and when relevant, ground-truthing. At the end of the review, Tony’s Open Chain will share these findings with its supply chain partners, offering an informed opinion on the most reliable methodology for each specific case. Farmers will be reintegrated into the supply chain upon agreement from all partners. For more information on the reintegration process, see the Reintegration Protocol below.
III. Groun-tdruthinagndRemediatPiornotocol Ground-truthing is an essential element of the due diligence required to address the issue of deforestation in the cocoa sector. Tony’s Open Chain uses ground- truthing to validate deforestation alerts generated from satellite land use analysis, which is carried out by our Deforestation Risk Analysis Partners. Ground-truthing helps us collect the information we need to perform risk mitigation activities or provide support for the remediation of proven cases of deforestation. Tony’s Open Chain makes use of ground-truthing to provide additional (observable) information to its partner cooperatives and Supply Chain Partner Network. Remote sensing technologies, including satellite imagery and aerial photography, offer important information about land use. However, this data can occasionally be inaccurate due to issues such as cloud cover, seasonal variations, or misclassifications. Ground- truthing enables Tony’s Open Chain and its partners to gather firsthand observations that build a more complete picture than remote sensing data can offer on its own.. We believe ground-truthing can play a key role in the deforestation monitoring processes of companies, as satellite monitoring methodologies—commonly used to check EUDR compliance—may also have errors or there may simply be errors in farm mapping. Correcting these misclassifications (false positives) is crucial to prevent unfair penalties for farmers. Legal Considerations: It is important to note that Tony’s Open Chain cannot guarantee that farms identified as having been erroneously flagged for deforestation through our ground-truthing process will be allowed back into the supply chain of Tony’s Open Chain. Approval by respective Deforestation Risk Analysis Partners and Supply Chain Partners liable for EUDR compliance upon entry
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to the EU market is required for modifications to a farm’s compliance status. This approval can only be granted based on verifiable evidence. This process is necessary to ensure data credibility and validation through triangulation, adhering to the four-eyes principle. 6
1. Identification & planning (1 October – 1 January)
1. Identification of cases. EUDR non-compliant cases are automatically a priority for ground-truthing. During the first quarter of the season (1 October – 1 January), Tony’s Open Chain identifies which other cases flagged in the deforestation risk analysis are a priority for ground-truthing. To optimize ground-truthing efforts, Tony’s Open Chain will coordinate ground-truthing activities with its Supply Chain Network who conduct similar assessments to prevent duplication and ensure efficient use of resources. On a case-by-case basis, partners may choose to split the scope of work for visits or conduct joint assessments when appropriate, fostering collaboration for greater impact. 2. Identification of case-by-case needs: A ground-truthing application, including a question form, has been developed to enable consistency in data collection. The form includes key questions to be answered during the ground-truthing process as part of the standard protocol. However, there may be additional, case-specific questions (e.g. relating to proof of the legality of agriculture in a specific protected area) or technical requirements (e.g. drone imagery) that need to be provided which fall outside of this. Tony’s Open Chain’s specialists will identify any such additional questions/requirements prior to the ground- truthing mission.
3. Scheduling visits: Tony’s Open Chain, in consultation with partner cooperatives, establishes appropriate dates for the ground-truthing missions.
6 The four eyes principle requires at least two parties to provide their approval, increasing transparency and credibility.
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2. Ground-truthing (1 January – 1 April) 1. The ground-truthing mission—led by the Tony’s Open Chain country
productivity lead—consist of two parts (cooperative level investigation and farm level investigation). Both investigations consist of questionnaires to the cooperative and the farmer that are completed digitally to facilitate data sharing and data quality. a. During the cooperative level investigation, Tony’s Open Chain aims to confirm the farm ownership, verify the existence of multiple farms for this producer (if applicable), and the size of all farms, among other checks. b. During the farm level investigation, a farm level questionnaire will gather detailed, site-specific information about farming practices, land use, any changes in vegetation cover on individual farms and potential overlap with protected and deforested areas. If a farmer or cooperative does not wish to participate in the ground-truthing process, the farmer concerned will remain excluded from the Tony’s Open Chain supply chain. In such cases, there will be no remediation support. 2. A consultation with competent authorities in Ghana and Côte d'Ivoire responsible for the management of the cocoa sector and for protection of protected areas will also take place when relevant, to verify the farm’s deforestation status according to their deforestation risk assessments. This will also include a check on whether the farm is compliant with forest protection laws, in case the farm is in a protected areas with legal permission to practice agriculture. 3. Remediation decisions are made by the Tony’s Open Chain country productivity lead and relevant specialists, in consultation with the farmer, and documented. The decision is reviewed by the Tony’s Open Chain “productivity and environment triangle” to align with the four eyes principle for best practice in assurance processes. At least one—different—member of the productivity and environment triangle reviews and approves the conclusions, ensuring thorough oversight and consensus. The productivity and environment triangle consists of: the environment & climate change specialist based in the
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Netherlands, the productivity lead based in Ghana and the productivity lead based in Côte d’Ivoire.
A plan on how the farm will be remediated is designed by the triangle. This includes a set of key performance indicators to be used to monitor remediation progress. It is submitted to the farmer for their validation. An agreement on the remediation plans must be reached between Tony’s Open Chain and the farmer. If no agreements can be made after 3 revisions of the proposal, the productivity and environment triangle close the case for lack of consensus, and the farm remains excluded from the Tony’s Open Chain supply chain. 3. Consequences: exclusion or remediation If, following the ground-truthing process, EUDR non-compliance is confirmed for a farm: ▪ The farm remains excluded from the Tony’s Open Chain supply chain. ▪ In case an agreement is reached between Tony’s Open Chain and the farmer on a remediation plan, Tony’s Open Chain will provide the agreed support and monitor the progress of the remediation effort. The timeframe and frequency of monitoring will be defined. ▪ Remediation activities usually take place in the period of April 1 st to July 1 st , which is the most appropriate time to plant trees in both countries. Remediation encompasses any activity to restore a degraded environment, educate and raise awareness on the environmental laws and regulations, or provide farm management support in response to deforestation detection. Remediation can include: reforestation (planting trees in deforested areas to restore forest cover), tree regeneration efforts (encouraging the natural regrowth of trees through practices like assisted natural regeneration, where existing native flora is nurtured to recover and thrive), or the implementation of sustainable agricultural practices (i.e. agroforestry). Remediation aimed at responding to social or human aspects may encompass education and training programs to local communities, supporting fair land tenure and rights, facilitating access to social services, or implementing community-based conservation projects to promote sustainable resource management. ▪ If the farmer-dependent key performance indicators are reached in the expected timeframe (for example, 80% of re-planted trees survive within 4
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years) the farm will be remapped and reintegrated into the Tony’s Open Chain supply chain, provided that the newly mapped farm is confirmed as deforestation-free by our external Deforestation Risk Analysis providers. ▪ If the farmer-dependent remediation key performance indicators are not reached in the expected timeframe, the farmer remains excluded. However, there is a possibility for reintegration if progress towards the KPIs are observable the following year. If not, the case will be closed permanently. If, following the ground-truthing process a farm is believed to overlap with protected areas without legal permission: ▪ The farm remains excluded from the Tony’s Open Chain supply chain. ▪ Tony’s Open Chain proposes remediation support to the concerned forest authorities, with the objective of restoring the encroached protected area. ▪ If no agreement is reached with forest authorities by July 1 st , the case is closed. If the forest authorities agree with the support, Tony’s Open Chain enacts the remediation activity in the protected area, in collaboration with forest authorities. If, following the ground-truthing process, a farm is deemed to be compliant with EUDR and does not overlap with protected areas without legal permission: ▪ The findings will be submitted to Enveritas and Tony’s Open Chain’s supply chain partners (as per the reintegration protocol in section IV). These partners will be requested to consider the ground-truthing evidence provided by Tony’s Open Chain and confirm whether it is sufficient to warrant a revision of a farmer’s compliance status following the initial deforestation alert. The EUDR mandates that some of Tony’s Open Chain’s supply chain partners must (i) maintain traceability data for the plots where the materials are produced, (ii) provide evidence that these plots have been deforestation-free since December 31, 2020, and (iii) ensure that cocoa production on each plot adheres to the relevant legal frameworks regarding forest protection, labour rights, and human rights. Their agreement to the findings of the ground-truthing process is therefore key to modifying the compliance status of a farmer.
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o If supply chain partners agree to modify the farm’s status to deforestation-free based on Tony’s Open Chain ground-truthing evidence: the farm will be reintegrated to Tony’s Open Chain supply chain. o If supply chain partners disagree to modify the farm’s status: Tony’s Open Chain will explore whether re-mapping of the farm is feasible— based on causes of the non-compliance status—to ensure that farmers are not unfairly excluded. ▪ In the case that a farm is remapped and the newly mapped plot is considered deforestation-free, the farm will be reintegrated into Tony’s Open Chain’s supply chain and can deliver cocoa in the following cocoa season . ▪ In the case that remapping is not done, the farm remains excluded from the supply chain. If a farm is deemed to be deforestation-free because the deforestation alert was due to a technical error (including an error in the mapping) ▪ The farm and farmer will benefit from the following remediation: reintegration of the farm and farmer in the Tony’s Open Chain register. ▪ If the technical error was caused by Tony’s Open Chain, and the farmer was not allowed to deliver during the main or mid-crop cocoa seasons, the farmer will receive monetary compensation of EUR 100 to support him/her in hiring labour services or accomplishing other farm-related needs.
IV. Reintegration protocol
The Tony’s Open Chain reintegration protocol applies in the following cases:
1. A ground-truthing process resulted in convincing evidence that a farm was erroneously flagged for deforestation during the deforestation risk analysis procedure and should be reintegrated into the supply chain. 2. The farm was non-compliant, but the farmer achieved the objective of his/her remediation plan, the farm was remapped, and it is considered EUDR compliant by deforestation risk analysis.
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3. There are discrepancies between the deforestation risk analysis results of supply chain partners and Tony’s Open Chain.
In the cases described above, Tony’s Open Chain will take the following steps:
1. Collect all relevant data of Tony’s Open Chain and its supply chain partners to create a shared baseline, using a dedicated form.
2. Compare methodologies and results of Tony’s Open Chain and its supply chain partners a. High-level review: Review how each provider collects and processes data, including validation steps, analysis, and input data types. Consider data accuracy, the definition of forest used, and the resolution of imagery gathered as evidence. b. Farm-level review: Examine individual plots’ status: historical high- resolution images, forest overlap, alerts, and farm level result reliability, as well as results of ground-truthing/field visits, if relevant. Tony’s Open Chain will share the findings from steps 1-2 with its supply chain partners, offering its assessment of which methodology provides the highest level of confidence, and will request their input and perspective on each case accordingly. If, following completion of steps 1 and 2, partners unanimously agree on the methodology which gives the greatest confidence: • The methodology with the greatest confidence has been identified and is therefore acted upon. • If the methodology concludes the farm is compliant to EUDR, the farmer is reintegrated into the Tony’s Open Chain supply chain and can deliver in the following season. • If the methodology concludes that the farm is non-compliant to EUDR, the farmer remains excluded from the Tony’s Open Chain supply chain.
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• Tony’s Open Chain will write a summary report covering the conclusion and how it was reached, which will be shared with the supply chain partners that were involved in the process.
If, following completion of steps 1 and 2, partners do not unanimously agree about the methodology which gives the greatest confidence, the third step is enacted:
3. Tony’s Open Chain and/or partners will make use of a third resource—high resolution imagery repositories (like OneAtlas) or other additional data sources to clarify unclear plots and identify the methodology that the third resources corroborate. If the additional data supports the conclusion that the farm is compliant to EUDR, the farmer is reintegrated. If the additional data supports the conclusion that the farmer is uncompliant, the farmer remains excluded. If, following completion of the 3 steps, the partners do not unanimously agree about which results gives the greatest confidence: • The methodology of the partners responsible for completing the Due Diligence Statement (DDS) in accordance with European law, is acted upon. • Tony’s Open Chain will write a summary report covering the conclusion and how it was reached, which will be shared with the supply chain partners that were involved in the process.
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Annex 1: Ground-truthing decision tree
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