Cargill Inc

1. Sustainable palm oil policy or commitment for all its operations?

The company meets this indicator through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has a sustainable palm oil policy.

2. Sustainable palm oil policy or commitment applies to all suppliers?

The company has published a sustainable palm oil policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has a Chief Sustainability Officer who has a high-level position of responsibility for sustainability.

4. One or more members within the board of the company have responsibility for sustainability?

The company reports that its CEO and Board Chair also joins its biannual Land Use and Forest Sustainability Advisory Panel, which is ''designed to ensure that the strategies and resources underpinning Cargill's forest commitments are adequate to deliver positive socio-economic and environmental impact.''.

5. Percentage or number of women in senior management team?

28.8% - The company reports that it has 20.8% women in the senior management team.

6. Percentage or number of women board members?

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with palm oil production?

[Externally verified] The company is a member of UNGC, WBCSD, TFA, NYDF, and Earthworm Foundation.

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with palm oil production?

The company has collaborated with 'Earthworm Foundation' to conduct human rights due diligence on its suppliers' recruitment processes via the 'Labour Transformation Program' and 'Ethical Recruitment Due Diligence Initiative'. In the Siak and Pelalawan districts, it has also collaborated with eight other companies to support the 'Siak and Pelalawan Landscape Program' which aims to protect forests and empower palm oil smallholders and surrounding local communities.

9. Sustainability report published within last two years?

The company has published its sustainability report 2022, and a progress update report for 2021.

10. Reports through standardised reporting systems?

The company has submitted multiple CDP questionnaires.

11. Verification report on compliance with POIG Charter, if a POIG member?

This indicator is disabled as the company is not a POIG member.

12. Climate risks assessment available?

The company has published a CDP climate questionnaire for 2022 which includes actual and potential impacts of climate change, metrics, targets and processes used to assess or manage climate risks and responsibilities.

13. Lists countries and operations?

Indonesia - (Plantations, Mills, Crushers), Australia, Belgium, Brazil, China, Germany, India, Malaysia, Mexico, Netherlands (the), Russian Federation, Turkey, United States of America (the) - (Refineries).

14. Lists countries sourcing from?

The company reports origin countries for its palm oil production.

15. Total land area managed/controlled for oil palm (ha)?

128788 - The company reports the total land area managed for oil palm as 128,788.09 ha in its RSPO ACOP 2022.

16. Total oil palm planted area (ha)?

82435.4 - The company reports that it has 82,435.39 ha of palm oil planted and infrastructure area in its RSPO ACOP 2022.

17. Scheme smallholders planted area (ha)?

28866.8 - The company reports the scheme smallholders planted area in its RSPO ACOP 2022.

18. Unplanted (areas designated for future planting) (ha)?

620.89 - The company reports the total unplanted area as 620.89 ha in its RSPO ACOP 2022.

19. Conservation set-aside area, including HCV area (ha)?

16865 - The company reports the total conservation set-aside area, including HCV area as 16,865 ha in its RSPO ACOP 2022.

20. Maps of estates/management units?

The company reports in its RSPO ACOP 2022 that maps represent 100% of concession sites. The company has also published maps of its concessions on the GFW database.

21. Maps of all scheme smallholders?

The company has various scheme smallholder maps across multiple audit reports. It is unclear if this covers all scheme smallholder operations and some information is between two and five years old.

22. Maps of all third-party supplying plantations?

23. Number of company-owned mills?

9 - The company reports that it has nine palm oil mills.

24. Names and locations of company-owned mills?

The company reports the name and location of its nine palm oil mills in its Global Mill List.

25. Number (or percentage) of company-owned mills that source from company-owned operations and third parties?

26. Reports total volumes (or percentages) sourced by company-owned mills that come from company-owned operations and third-parties?

27. Number of third party supplying mills?

1416 - The company has reported a total of 1,416 third-party supplying mills in its ESG report 2022.

28. Names and locations of all third-party supplying mills?

The company has published a list of all mills (own and third-party) along with their names and coordinates.

29. Number (or percentage) of third party supplying mills that source from their own plantations and third party plantations?

30. Reports total volume (or percentages) sourced from third-party supplying mills that come from the supplying mills' own operations and third parties?

31. Total volume (or percentage) sourced for refineries that comes from intermediary traders and/or refiners rather than directly from mills?

The company reports that it sources from 1300 indirect mills and 125 direct mills. However, volumes are not reported.

32. Time-bound commitment to achieve 100% traceability to mill level?

The company has a commitment to 100% traceability to the plantation level for direct mills by 2025 and indirect mills by 2030.

33. Percentage of supply traceable to mill level?

The company states that 99% of its global supply is traceable to the mill level. Additional points have been awarded based on RSPO SCC SG or IP certifications.

34. Time-bound commitment to achieve 100% traceability to plantation level?

The company has a commitment to 100% traceability to the plantation level for direct mills by 2025 and indirect mills by 2030.

35. Percentage of fresh fruit bunches (FFB) supply to own mills traceable to plantation level?

The company reports that its own plantations and mills in Indonesia are fully traceable to plantations. Additional points have been awarded based on the RSPO SCC IP certification.

36. Percentage of supply from third-party mills traceable to plantation level?

The company reports that 65% of its global supply is traceable to plantations as of Q4 2021 but does not report separately for its own mills and supplier mills. Additional points have been awarded based on the RSPO SCC IP certification.

37. Publishes traceability data at refinery level?

38. Publishes traceability data at crusher level?

39. Member of the Roundtable on Sustainable Palm Oil (RSPO)?

[Externally verified] 2004 - The company has been a member of RSPO since 2004.

40. RSPO-certified within three years of joining the RSPO or by November 2010, for companies joining prior to finalisation of the RSPO certification systems in November 2007?

[Externally verified] 2008 - The company became a member of the RSPO in 2004 and certified its first estate in 2008.

41. Submitted most recent RSPO Annual Communication of Progress (ACOP)?

The company has submitted its latest RSPO ACOP 2022.

42. Percentage of area (ha) RSPO-certified?

75.34% - The company reports that 75.34% of its estates, excluding scheme smallholders, are RSPO certified.

43. Percentage of mills RSPO-certified?

[Externally verified] 100% - The company reports that all of its nine mills are certified under RSPO.

44. Time-bound plan for achieving 100% RSPO certification of estates and mills within 5 years?

2023 - The company commits to achieve 100% RSPO certification of estates and mills by 2023. This is within 5 years.

45. Time-bound plan for achieving 100% RSPO certification of all palm product processing facilities within 5 years?

2030 - The company commits to achieving 100% RSPO certification of all palm product processing facilities by 2030. This is beyond 5 years.

46. Percentage of scheme smallholders (ha) RSPO-certified?

66.21% - The RSPO ACOP 2022 states that the scheme smallholders have 66.21% RSPO-certified landbank.

47. Time-bound plan for achieving 100% RSPO certification of scheme/associated smallholders and outgrowers within 5 years or target already achieved?

2023 - The company commits to achieve 100% RSPO certification of scheme/associated smallholders and outgrowers by 2023. This is within 5 years.

48. Percentage of FFB supply (tonnes) from independent smallholders/outgrowers/third-party FFB suppliers that is RSPO-certified?

0% - The company reports that 0% of FFB supply (tonnes) from independent smallholders is RSPO-certified.

49. Percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that is RSPO-certified?

27.62% - The company reports that 27.62% of all palm oil and oil palm products that is handled/traded/processed (tonnes) are RSPO-certified.

50. Sells RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

The RSPO ACOP 2022 states that the company sells 51.90% of RSPO-certified palm oil through segregated or identity-preserved supply chains.

51. Processes/trades RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

The RSPO ACOP 2022 states that the company processes/trades 18.57% of RSPO-certified palm oil through segregated or identity-preserved supply chains.

52. Indonesia Sustainable Palm Oil (ISPO) certified (100%)?

[Externally verified] The company reports that all but one mill and plantation are ISPO certified. All certificates are included.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

This indicator is disabled as the company does not operate in Malaysia.

54. Certified under voluntary sustainability certification scheme (e.g. ISCC, SAS, RSB)?

[Externally verified] The company is certified under ISCC.

55. Commitment to zero conversion of natural ecosystems?

The company is committed to preventing the clearance of ecologically and socially important forests, habitats, and hydrological systems. It states it is committed to being 'free of deforestation and land conversion by 2030'. However, the commitment does not specify all natural ecosystems.

56. Commitment to zero conversion of natural ecosystems applies to all suppliers?

The company's commitment to preventing the clearance of ecologically and socially important forests, habitats, and hydrological systems applies to all suppliers. It also states to make its agricultural supply chain 'free of deforestation and land conversion by 2030'. However, the commitment does not specify all natural ecosystems.

57. Commitment to zero deforestation?

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forests since November 2018, through the RSPO Principles and Criteria 2018. The company also commits to zero deforestation in its own reporting. This commitment has been in place since 2019.

58. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation. This commitment has been in place since 2019.

59. Criteria and cut-off date for defining deforestation?

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company has also reported criteria and cut-off date for defining deforestation in its own reporting.

60. Criteria and cut-off date for defining deforestation in supplier operations?

The company defines deforestation for suppliers as removal of HCV, HCS and peatland areas and specifies any deforestation/conversion past 2019 will not be accepted in supplier operations.

61. Evidence of monitoring deforestation and/or ecosystem conversion?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it uses satellite technology to monitor deforestation in its palm plantations and adjacent areas.

62. Evidence of monitoring deforestation and/or ecosystem conversion in supplier operations?

The company reports that it uses satellite and radar technology to monitor deforestation in supplier operations. It also states that it has monitored 96% of its palm oil supply chain till 2022, however, the time frame for monitoring deforestation is not reported.

63. Amount of deforestation and/or ecosystem conversion recorded in own operations since cut-off date?

64. Amount of deforestation and/or ecosystem conversion recorded in supplier operations since cut-off date?

4 - The company reports a total area of 4 ha of illegal or non-compliant deforestation recorded within the company's suppliers' operational area in its grievance list. However, a consolidated figure covering entire operations was not reported.

65. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

The company reports that non-compliance with its policy to protect HCV and HCS areas in its estates and supply chain 'may' require remediation, however, it does not specify a cut-off date. The company has reported a goal to halve deforestation by 2020 and end it completely by 2030, but it is not clear if deforestation that occurs within its estates before 2030 will need to be restored/compensated.

66. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

The company commits suppliers to restore ecosystems to their prior condition in cases of conversion within their own operations.

67. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company has reported its landscape-level initiatives such as collaboration with 'Tropical Forest Alliance' to address issues like deforestation and social exploitation. It also reports a 'Peat Care Village Programme' in Sungai Linau which is externally verified by Proforest.

68. Biodiversity policy?

The company only reports a general statement to protect biodiversity. However, no scope and time-bound targets are reported.

69. Biodiversity policy applies to all suppliers?

70. Identified species of conservation concern, referencing international or national system of species classification?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

71. Examples of species and/or habitat conservation management?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

72. Commitment to no hunting or only sustainable hunting of species?

73. Commitment to no hunting or only sustainable hunting of species applies to all suppliers?

74. Commitment to conduct High Conservation Value (HCV) assessments?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to conduct High Conservation Value (HCV) assessments in its own reporting.

75. Commitment to conduct High Conservation Value (HCV) assessments applies to all suppliers?

The company commits all suppliers to conduct HCV assessments.

76. High Conservation Value (HCV) assessments for planting undertaken prior to January 2015, and associated management and monitoring plans?

[Externally verified] The HCV assessment summaries for PT Indo Sawit Kekal, PT Hindoli Smallholder Scheme and PT Sumber Terang Agro Lestari are available on the RSPO NPP website.

77. High Conservation Value (HCV) assessments for all estates planted/planned planting since January 2015?

[Externally verified] The HCV assessments for PT Andes Agro Investama, PT Poliplant Sejahtera, PT Maya Agro Investama, PT Andes Sawit Lestari and PT Andes Sawit Mas are available on the HCVRN platform.

78. High Conservation Value (HCV) or combined HCV/HCS management and monitoring plans for all estates planted/planned planting since January 2015?

[Externally verified] The High Conservation Value (HCV) management and monitoring plans for PT Andes Agro Investama, PT Poliplant Sejahtera, PT Maya Agro Investama, PT Andes Sawit Lestari and PT Andes Sawit Mas are available on the HCVRN platform.

79. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS)?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS) in its own reporting.

80. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS) applies to all suppliers?

The company commits all suppliers to only use licensed HCV assessors accredited by the HCV Resource Network's ALS.

81. Satisfactory review of all High Conservation Value (HCV) assessments undertaken since January 2015 by the HCV ALS Quality Panel?

[Externally verified] The HCV assessments of PT Andes Agro Investama, PT Poliplant Sejahtera, PT Maya Agro Investama, PT Andes Sawit Lestari and PT Andes Sawit Mas have been Satisfactorily reviewed by the HCV ALS Quality Panel.

82. Commitment to the High Carbon Stock (HCS) Approach?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates this in its own reporting.

83. Commitment to the High Carbon Stock (HCS) Approach applies to all suppliers?

The company commits all suppliers to apply the HCS Approach, as defined by the HCS Approach Toolkit.

84. High Carbon Stock (HCS) assessments available?

[Externally verified] The High Carbon Stock (HCS) assessment for PT Ades Sawit Mas is available on the HCSA website.

85. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

[Externally verified] The company's only HCS assessment undertaken since April 2015 has been peer reviewed.

86. Commitment to conduct social and environmental impact assessments (SEIAs)?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to conduct social impact assessments in its own reporting.

87. Commitment to conduct social and environmental impact assessments (SEIAs) applies to all suppliers?

The company commits all suppliers to conduct social impact assessments only.

88. Social and environmental impact assessments (SEIAs) available, and associated management and monitoring plans?

[Externally verified] The social and environmental impact assessments for PT Harapan Sawit Lestari, PT Hindoli Smallholder Scheme, PT SumberTerang Agro Lestari and PT Indo Sawit Kekal are available on the RSPO NPP website.

89. Commitment to no planting on peat of any depth?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to no planting on peat of any depth in its own reporting.

90. Commitment to no planting on peat of any depth applies to all suppliers?

The company commits all suppliers to no planting on peat of any depth.

91. Landbank or planted area on peat (ha)?

92. Implementation of commitment to no planting on peat of any depth?

93. Commitment to best management practices for soils and peat?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to best management practices for peat in its own reporting.

94. Commitment to best management practices for soils and peat applies to all suppliers?

The company commits all suppliers to best management practices for peat only.

95. Evidence of best management practices for soils and peat?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it uses satellite technology to check the planting on peatlands and launched a new regenerative agriculture program (Cargill RegenConnect) which aims to reduce GHG emissions, improve water quality and build soil health by paying farmers for improved soil health and positive environmental outcomes.

96. Commitment to zero burning?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to no burning in its own reporting.

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

98. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that its all operations and surrounding communities are covered by a fire prevention and awareness program.

99. Details/number of hotspots/fires in company estates?

The company reports that no hotspots were detected between October 24 to 28, 2021. It reports detailed hotspot monitoring data from August 2020 to October 2021.

100. Details/number of hotspots/fires within surrounding landscape/smallholders?

0 - The company reports that no hotspots were detected between October 24 to 28, 2021 in its own plantations and up to a one kilometre boundary from its estates. It reports detailed hotspot monitoring data from August 2020 to October 2021.

101. Time-bound commitment to reduce greenhouse gas (GHG) emissions intensity?

The company has committed to reducing GHG emissions from its global supply chain by 30% per ton of product by 2030, using a 2017 baseline. However, this commitment only applies to scope 3 emissions. The company also has a commitment to reduce Scope 1 and 2 absolute greenhouse gas (GHG) emissions in its operations by 10% by 2025 against a 2017 baseline, however this target is not based on intensity.

102. GHG emissions intensity?

The company reports the average GHG footprint for all certified management units by hectare is 3.22 tCO2e/ha, and the average GHG footprint for all certified management units per tonne of crude palm oil is 1.30 tCO2e/t CPO, in 2022. However, it does not include Scope 1 and Scope 2 emissions.

103. GHG emissions from land use change in company's own operations (scope 1)?

The company reports separate figures for each RSPO certified area. No overall figure is reported.

104. GHG emissions from land use change in supplier operations (scope 3)?

105. Progress towards commitment to reduce GHG emissions intensity?

The company reports that its GHG emissions have been reduced by 1.6% from 2020 to 2021. However, the figures are not reported as intensity and are also not specific to palm oil operations.

106. Methodology used to calculate GHG emissions?

The RSPO requires companies to assess their GHG emissions through the Palm GHG calculator. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports that it uses the RSPO-endorsed palm GHG tool methodology to calculate GHG emissions.

107. Percentage of mills with methane capture (100%)?

The company reports that two out of nine (22.22%) company-owned mills have methane capture.

108. Time-bound commitment to improve water use intensity?

109. Water use intensity?

0.2 - The company states its water use intensity is 0.2 for palm oil. It does not include a unit of measure.

110. Progress towards commitment on water use intensity?

The company reports a 2.9% improvement in freshwater efficiency however, the information is dated 2017 and it is not clear if the figure is based on water use intensity. The company also reports a water use intensity for palm oil in 2023 of 0.2 (no metric provided), as this is just one year of data, progress cannot be measured.

111. Time-bound commitment to improve water quality (BOD and COD)?

The company reports a target to reduce 5000MT of water pollutants in priority areas by 2030 from a 2020 base year. BOD or COD are not specified.

112. Progress towards commitment on water quality (BOD and COD)?

The company reports to have achieved 6.36% of its target to reduce 5000MT of water pollutants in priority areas by 2030 from a 2020 baseline. BOD or COD are not specified.

113. Treatment of palm oil mill effluent (POME)?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it uses treated palm oil mill effluent as fertiliser. However, this is undated information.

114. Treatment of palm oil refinery effluent (PORE)?

115. Commitment to protect natural waterways through buffer zones?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

116. Implementation of commitment to protect natural waterways through buffer zones?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

117. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

118. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers, applies to all suppliers?

119. Commitment to no use of paraquat?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

120. Commitment to no use of paraquat applies to all suppliers?

121. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

122. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers?

123. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

124. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers?

125. Chemical usage per ha or list of chemicals used?

126. Implementation of commitment to minimise inorganic fertiliser use?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

127. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

128. Waste management system in place to avoid negative impacts?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

129. Commitment to human rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to the UN Guiding Principles on Business and Human Rights in its own reporting.

130. Commitment to human rights applies to all suppliers?

The company commits suppliers to the UN Guiding Principles on Business and Human rights.

131. Progress on human rights commitment?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has successfully completed its first pilot project for the 'Ulula Worker Voice Tool' which aims to protect the human rights of workers, indigenous peoples and local communities in its supply chains. It also reports that it implements projects to strengthen its own and suppliers' processes to make sure human rights are respected, including through participation in the 'Labor Transformation Program' in Malaysia and the 'Social Performance Program' in Guatemala.

132. Commitment to respect indigenous and local communities' rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to respect indigenous and local communities' rights in its own reporting. However, the commitment does not refer to the UN Declaration/ILO Convention.

133. Commitment to respect indigenous and local communities' rights applies to all suppliers?

The company's commitment to indigenous and local communities' rights applies to all suppliers. However, it does not refer to the UN Declaration/ILO Convention.

134. Commitment to respect legal and customary land tenure rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to respect legal and customary land tenure rights in its own reporting.

135. Commitment to respect legal and customary land rights applies to all suppliers?

The company commits suppliers to respect legal and customary land tenure rights.

136. Commitment to free, prior and informed consent (FPIC)?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to free, prior and informed consent (FPIC) in its own reporting.

137. Commitment to free, prior and informed consent (FPIC) applies to all suppliers?

The company commits all suppliers to respect FPIC.

138. Details of free, prior and informed consent (FPIC) process available?

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior, and informed consent (FPIC). Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

139. Examples of local stakeholder engagement to prevent conflicts?

140. Details of process for addressing land conflicts available?

The RSPO Principles and Criteria 2018 contain requirements for addressing land conflicts. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

141. Supports the inclusion of women across palm oil operations, including addressing barriers faced?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

142. Commitment to mitigate impacts on food security?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to ensuring food security in its own reporting. However, the commitment is not in relation to local communities.

143. Progress on commitment to mitigate impacts on food security?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has invested $20 million to improve the food security of local communities.

144. Commitment to provide essential community services and facilities?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to providing essential community services and facilities in its own reporting.

145. Progress on commitment to provide essential community services and facilities?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has built 96 schools in Vietnam and provided education, nutrition, water access, sanitation and economic support to two million people across Central America, Africa and Asia. However, the information is between two to five years old.

146. Commitment to provide business/work opportunities for local communities?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

147. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates this in its own reporting.

148. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies to all suppliers?

The company commits to freedom of association, right to collective bargaining, no forced labour, equal wage, and no discrimination referencing ILO's Declaration on Fundamental Principles and Rights at Work, but does not commit to all 10 Core Conventions. This applies to all suppliers.

149. Progress on commitment to respect all workers' rights?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

150. Commitment to eliminate gender related discrimination with regards to employment?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to prevent employment-related discrimination based on gender in its own reporting.

151. Commitment to eliminate gender related discrimination with regards to employment applies to all suppliers?

The company commits all suppliers to prevent employment-related discrimination based on gender.

152. Progress on commitment to eliminate gender related discrimination with regards to employment?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

153. Percentage or number of temporary employees?

154. Percentage or number of women employees?

17.7% - The company reports that it has 17.7% of female employees in 2022.

155. Commitment to pay a Living Wage?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to pay the legal minimum wage in its own reporting.

156. Commitment to pay a Living Wage applies to all suppliers?

The company only commits to paying the legal minimum wage. This applies to all suppliers of the company.

157. Progress on commitment to pay a Living Wage?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

158. Reporting of salary by gender?

159. Commitment to address occupational health and safety?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to address health and safety at work in its own reporting.

160. Commitment to address occupational health and safety applies to all suppliers?

The company commits all suppliers to address health and safety at work for all workers.

161. Provision of personal protective equipment and related training?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

162. Time lost due to work-based injuries?

1.1 - The company reports an injury frequency rate of 1.1 for the year 2022. Calculated as recordable injuries x 200,000/total working hours.

163. Number of fatalities as a result of work-based accidents?

4 - The company reports four fatalities as a result of work-based accidents in 2022.

164. Commitment to support smallholders?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates this in its own reporting.

165. Programme to support scheme smallholders?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports supporting smallholders through its smallholder programmes. However, it is unclear what type of smallholders it supports.

166. Percentage of scheme smallholders involved in programme?

1215 - The company reports partnering with 24,000 smallholders as well as the involvement of different numbers of smallholders in different programmes. However, it is unclear what type of smallholders it includes.

167. Programme to support independent smallholders?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports supporting independent smallholders to achieve ISPO and RSPO certification through its 'landscape program' and 'Wild Asia Group Scheme (WAGS)' program.

168. Percentage of independent smallholders/outgrowers involved in programme?

6089 - The company reports that 570 smallholders have achieved RSPO certification through its 'Wild Asia Group Scheme (WAGS)' program and 5,519 smallholders have participated in the 'landscape program' to get ISPO and RSPO certified.

169. Process used to prioritise, assess and/or engage suppliers on compliance with company's policy and/or legal requirements?

The company reports having an Aggregator/Refiner Transformation (ART) plan, supplier assessments, and sustainability improvement programs to prioritise and engage suppliers on compliance with its policy or legal requirements.

170. Number or percentage of suppliers assessed and/or engaged on compliance with company's policy and/or legal requirements?

The company reports that 93% of its direct mill suppliers attended an NDPE workshop in 2021. 72% conducted field assessments and 82% conducted self-assessments.

171. Suspension or exclusion criteria for suppliers?

The company reserves the right to end its relationship with the supplier when an issue cannot be corrected or a supplier partner is unwilling to engage. Time-frames for action are included in the company's grievance procedure.

172. Time-bound action plans (including Key Performance Indicators) for suppliers to be in compliance with palm oil sourcing commitments?

The company reports time bound action plans with KPIs for suppliers to be in compliance with its NDPE policy.

173. Proportion of supply from suppliers that is verified as deforestation- and/or conversion-free (DCF)?

174. Time-bound plan to engage with all high risk mills within 3 years?

The company conducts field visits to high-risk mills, however, it does not commit to engaging with all its high-risk mills over a three-year period.

175. Programme to support high risk mills to become compliant with sourcing policies?

Global Forest Watch Commodities (GFWC) PALM Risk Tool, Aggregator/Refiner Transformation (ART) plan and Proforest supplier engagement approach are the programmes used to support high-risk mills to become compliant with sourcing policies.

176. Regularly engages with a subset of high risk mills?

The company reports its engagement and field assessments with high-risk mills on an annual basis.

177. Procedures in place to assess all own and third party supplying palm oil mills for risk level?

The company reports that it uses the Global Forest Watch Pro Palm Risk Tool Methodology to categorize the mills from high to low, however no further details on the methodology are given and it is unclear if this includes the company's own mills as well.

178. Regularly assesses and categorises the risk level of all their own and third party supplying mills?

The company reports the risk level of its mills on an annual basis.

179. Regularly reports the risk level of all own and third party supplying mills identified in its supply chain?

The company reports that it has 338 high, 513 medium, and 574 low-risk mills.

180. Commitment to ethical conduct and prohibition of corruption?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to ethical conduct and the prohibition of corruption in its own reporting.

181. Commitment to ethical conduct and prohibition of corruption applies to all suppliers?

The company commits all suppliers to ethical conduct and the prohibition of corruption.

182. Progress on commitment to ethical conduct and prohibition of corruption?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports to conduct additional instructor-led compliance training for employees on issues of corruption and bribery. In January 2022, it celebrated 'Ethics Week', an entire week dedicated to promoting ethics among its employees worldwide.

183. Disclosure of the company's management approach to tax and payments to governments?

The company has published a UK Tax Strategy. However, neither it covers all operations nor does it report a governance body that is responsible for its review.

184. Whistleblowing procedure?

The RSPO Principles and Criteria 2018 contain guidance and requirements on whistleblowing procedures. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own whistleblower procedure.

185. Own grievance or complaints system open to all stakeholders?

The company adheres to this criteria through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own grievance system open to all stakeholders.

186. Details of complaints and grievances disclosed?

[Externally verified] The company has published the details of grievances which include issue, name of the company, date, status and action taken.