Sarawak Oil Palms Bhd

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

The company has published a sustainable palm oil policy which covers all palm oil operations.

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?

Mr Galau Melayong- Head of Sustainability.

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

The company reports its 'Sustainability Governance' structure is a top-down approach with oversight from the 'Board of Directors' who sets the policies and directions based on macroeconomic indicators in relation to the state of sustainability desired with the approval of sustainability policies.

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

0 (0%) - The company reports the gender of each senior management team member. All members are male as of December 2022.

6. Percentage or number of women board members?

5 (41.66%) - The company reports it has five female board members out of the total twelve board members as of 2022.

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

[Externally verified] Sarawak Oil Palm Plantation Owners Association (SOPPOA).

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

The company reports it collaborates with multiple universities and institutions on conservation and biodiversity. Additionally in 2022, the company participated in an outreach programme, AgriCop 2022, organized by the Sarawak Department of Agriculture where, practical experience on the application of technology and sustainability in oil palm plantations was shared, which is the adoption of Good Agricultural Practices ("GAP") and certification under the MSPO. The company also collaborates with Native Customary Rights (NCR) to elevate living standards.

9. Sustainability report published within last two years?

The company published its latest integrated Annual and Sustainability Report in 2023, covering the year 2022.

10. Reports through standardised reporting systems?

The company reports that its sustainability report is in line with Global Reporting Initiative ("GRI") Standards: Core Option. However, the company's sustainability report is published after 1st Jan 2023 and does not refer to GRI 101: Foundation requirements.

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?

13. Lists countries and operations?

Malaysia (oil palm plantations, palm oil mills, refinery, kernel crushing plant).

14. Lists countries sourcing from?

The company sources all its palm oil products from Malaysia.

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

123034 - The company's total land area managed for oil palm is 123,034 ha. Data as of December 2022.

16. Total oil palm planted area (ha)?

84487 - The company's total oil palm planted area is 84,487 ha. Data as of December 2022.

17. Scheme smallholders planted area (ha)?

This indicator is disabled as the company does not source from scheme/plasma smallholders.

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

30 - The company's total land held for future development is 30 ha. Data as of December 2022.

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

210 - The company reports it has a conservation project- Tinbarap Conservation Area (TCA) in Beluru (210ha). However, the information reported is from 2019 and is over two years old now.

20. Maps of estates/management units?

Maps for some company concessions are available on GFW, however, they do not cover all operations of the company. The company also has a dedicated webpage- SOPB Estates Location Map, however, this is not accessible without a request form.

21. Maps of all scheme smallholders?

This indicator is disabled as the company does not source from scheme/plasma smallholders.

22. Maps of all third-party supplying plantations?

23. Number of company-owned mills?

7 - The company operates seven mills.

24. Names and locations of company-owned mills?

The names and locations of all seven mills owned by the company are available.

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

The company reports that all company-owned mills source from company-owned and third-party operations.

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

The company reports that 61% of FFB sourced by company mills is from company-owned estates and the remaining 39% is sourced from third-party operations.

27. Number of third party supplying mills?

29 - The company reports it has 29 third-party supplying mills.

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

The names and locations of all 36 third-party supplying mills in 2020 are available on the company website. However, the data reported is from 2020 and is now over two years old.

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's refinery sources directly from mills.

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

The company has already achieved 100% traceability to mill level.

33. Percentage of supply traceable to mill level?

The company has already achieved 100% traceability to mill level.

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

The company has already achieved 100% traceability to plantation level.

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

The company reports all company-owned palm oil mills are 100% traceable to the plantation level.

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

37. Publishes traceability data at refinery level?

The company only publishes percentage of FFB supply traceable to mill level.

38. Publishes traceability data at crusher level?

The company only publishes percentage of FFB supply traceable to mill level.

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

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?

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

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

43. Percentage of mills RSPO-certified?

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

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

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

This indicator is disabled as the company does not source from scheme/plasma smallholders.

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

This indicator is disabled as the company has no scheme/plasma/associated smallholders or outgrowers.

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

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

50. Sells 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?

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

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

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company has achieved full MSPO certification for all estates, palm oil mills, refinery, and fractionation plant, kernel crushing plant, biodiesel plant, and phytonutrient plant in 2019.

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

[Externally verified] ISCC.

55. Commitment to zero conversion of natural ecosystems?

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

57. Commitment to zero deforestation?

The company commits to no deforestation of High Conservation Value (""HCV"") areas.

58. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to no deforestation of High Conservation Value (HCV) areas.

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

The company defines deforestation as the removal of HCV areas and specifies any deforestation past 2019 will not be accepted.

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

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

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

The company reports it has adopted a self-monitoring posture on any deforestation within its supply chain leveraging on the GFW platform. In 2022, it also used Satelligence as a way to monitor deforestation and fire in its landscape. However, the extent of the area monitored and timeframe is not reported.

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

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?

The company investigates grievances pertaining to deforestation in supplier operations reported via its grievance system and reports figures for these instances individually, however, a total figure for non-compliant deforestation could not be reliably calculated.

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

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

67. Implementing a landscape or jurisdictional level approach?

68. Biodiversity policy?

The company commits to environmental preservation through biodiversity conservation. However, no measurable, time-bound target is reported.

69. Biodiversity policy applies to all suppliers?

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

The company has identified species of conservation concern, referencing the IUCN red list system of species classification. However, the information reported is not externally verified.

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

The company reports it collaborates with multiple universities and institutions on conservation and biodiversity. Additionally, the company also has an ongoing project in collaboration with Sarawak Forestry Corporation, to rehabilitate its Tinbarap Conservation Forest. However, the information reported is not externally verified.

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 commits to conduct HCV assessments.

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?

The company reports it has conducted HCV assessments for all its post-2005 planting, however, no assessments are available publicly.

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

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

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

The company commits to only use licensed HCV assessors but does not refer to ALS specifically.

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?

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

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

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

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?

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

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

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

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

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

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

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)?

45% - The company reports it has 45% of its plantations on peatland.

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

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

The company commits to best management practices for soils and peat.

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

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

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

[Externally verified] The company provides examples on its website and in MSPO audit reports on the implementation of best management practices for soils and peat.

96. Commitment to zero burning?

The company commits to no burning.

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

98. Evidence of fire monitoring and management?

The company reports it has used Satelligence as a way to monitor deforestation and fire in its landscapes in 2022. However, details on monitoring or fire management activity are not reported.

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

The company reports that there were no hotspots/fires detected in the company estates and surrounding landscape or smallholders during the year.

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

0 - The company reports that there were no hotspots/fires detected in the company estates and surrounding landscape or smallholders during the year.

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

The company commits to reducing GHG emissions by 35% by the year 2024, however, the target is not intensity-based and only covers palm oil mills. Also, the target does not include at least scope 1 and/or scope 2 emissions.

102. GHG emissions intensity?

The company reports GHG emission intensity for plantations (0.09 MT CO2eq/MT Product), mills (0.25 MT CO2eq/MT Product), and refinery (0.04 MT CO2eq/ MT Product).

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

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

105. Progress towards commitment to reduce GHG emissions intensity?

The company reports GHG emissions intensity (scope 1 and scope 2) from 2020 to 2022, however, the intensity has not improved over time across all operating units.

106. Methodology used to calculate GHG emissions?

The company reports it uses the ISCC 205 methodology to calculate GHG emissions.

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

The company reports it has a methane capture facility at one of its mills and currently, the next methane capture facility is being constructed at Sabaju POM and is scheduled for commissioning in 2nd half of the year 2023. The company reports completing the installation of methane capture at all its seven mills by 2024.

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

109. Water use intensity?

The company reports the water (M3) per MT Refined Product Produced Ratio and FFB Processed ratio as 0.92 and 1.77, respectively in 2022.

110. Progress towards commitment on water use intensity?

The company reports the ratio of water consumption/FFB processed from 2020 to 2022, however, the units of measurement are not clear and the figures are increasing over time.

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

The company reports that all POME waste is properly treated in treatment ponds to meet the BOD and COD discharge limits as required by EQ (Prescribed Premises) (Crude Palm Oil) Regulations 1977 - EQ (Prescribed Premises) (Crude Palm Oil) Amendment Regulation 1982 before being released into the waterways.

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

The company reports the average BOD levels of its mills, refineries, and bio-diesel plants however, it does not specify the required legal limits for BOD.

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

The company reports that all POME waste is properly treated in treatment ponds to meet the BOD and COD discharge limits before being released into the waterways. However, the information reported is not externally verified.

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

115. Commitment to protect natural waterways through buffer zones?

The company has formally reviewed and established group guidance on the Protection of Riparian Buffer Zone and Slope Policy (2016) for the plantations to maintain buffer zones, however, it only specifies along "main rivers", and not all waterways.

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

[Externally verified] The company provides photographs of its buffer zones with relevant signage in its annual reports and further evidence is available in the company's MSPO audit report on maintenance of buffer zones. However, limited details are reported.

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

The company commits to a gradual reduction in chemicals, however, it is unclear if the commitment requires the company to minimise chemical fertiliser and pesticide use.

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 commits to not use paraquat.

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?

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?

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?

The company reports using empty fruit bunches and organic residues as a source of nutrients. However, the information reported is not externally verified.

127. Integrated Pest Management (IPM) approach?

The company reports it adopts the IPM approach in pest management which involves biological control of pests with the introduction of beneficial nectar-producing plants namely Cassia cobanensis, Tunera subulata, and Antigonon leptopus to provide natural food sources and shelters for predators of insects. However, the information reported is not externally verified.

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

[Externally verified] The company has a waste management system in place. This has been externally verified through an MSPO audit report.

129. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

130. Commitment to human rights applies to all suppliers?

The company commits suppliers to the Universal Declaration of Human Rights.

131. Progress on human rights commitment?

The company reports it conducts training sessions on company policies such as Social and Community Policies relevant to Human Rights and states that no substantiated complaints concerning human rights violations were recorded in 2022. However, the information reported is not externally verified.

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

The company commits to respecting indigenous and local communities' rights. However, the commitment does not reference the UN Declaration/ILO Convention and is only reported in relation to FPIC.

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

The company commits suppliers to respect indigenous and local communities' rights. However, the commitment does not reference the UN Declaration/ILO Convention and is only reported in relation to FPIC.

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

The company commits to respect legal and customary land tenure rights. However, the commitment is only reported in relation to FPIC.

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

The company commits all suppliers to respect legal and customary land tenure rights. However, the commitment is only reported in relation to FPIC.

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

The company commits to respect FPIC.

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 details of the free, prior, and informed consent (FPIC) process is available.

139. Examples of local stakeholder engagement to prevent conflicts?

The company reports engagement with local communities through CSR activities, dialogues, and workshops which are conducted annually or as needed. However, no further details on engagement are reported.

140. Details of process for addressing land conflicts available?

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

142. Commitment to mitigate impacts on food security?

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

144. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

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

The company reports multiple examples of facilities and services that have been provided to communities. This includes access roads for local communities, disaster relief aid to the local communities in its landscape who suffer losses due to natural disasters, etc. However, the information reported is not externally verified.

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

The company commits to providing work opportunities for local communities.

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

The company commits to five or more ILO Conventions, however, the commitments do not refer to the same language as the ILO titles.

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

The company only commits suppliers to less than five ILO conventions. Also, the commitments do not refer to the same language as the ILO titles.

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

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

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

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

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

The company reports that when a harassment case is reported, the group's Human Resource Department would investigate to determine if further sanctions are needed or if law enforcement actions need to be taken. In 2022, there were no incidents of discrimination. However, limited details are reported.

153. Percentage or number of temporary employees?

48 (2%) - The company reports the total contractors or temporary staff as 48 (2% of the total workforce) in 2022.

154. Percentage or number of women employees?

2409 (33%) - The company reports it has a total of 2,409 female employees in 2022.

155. Commitment to pay a Living Wage?

The company only commits to paying the minimum wage.

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

157. Progress on commitment to pay a Living Wage?

158. Reporting of salary by gender?

The company reports the ratio of basic salary and remuneration of female employees to male employees for each employee category, by region.

159. Commitment to address occupational health and safety?

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

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

161. Provision of personal protective equipment and related training?

[Externally verified] The company provides PPE and related training to all employees. This information is externally verified through the MSPO audit report.

162. Time lost due to work-based injuries?

For 2022, the company reports a lost-time injury rate (number of lost-time injuries per one million man-hours worked) for its plantations (2.65), milling (3.42), and downstream operations (1.79).

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

0 - The company reports no fatalities in 2022.

164. Commitment to support smallholders?

The company has published a commitment to support smallholders. However, the type of smallholders supported or the type of support provided other than assisting with MSPO certification is not reported.

165. Programme to support scheme smallholders?

The company reports it supports the smallholders to be MSPO certified. However, the type of smallholders supported is not reported and the company only reports limited details on the support provided.

166. Percentage of scheme smallholders involved in programme?

350 - The company provided training to 350 participants on the application of technology in oil palm plantations. However, it is unclear if this is an ongoing program or a one-off engagement. Also, the type of smallholders supported through this training is unclear.

167. Programme to support independent smallholders?

The company reports it supports the smallholders to be MSPO certified. However, the type of smallholders supported is not reported and the company only reports limited details on the support provided.

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

350 - The company provided training to 350 participants on the application of technology in oil palm plantations. However, it is unclear if this is an ongoing program or a one-off engagement. Also, the type of smallholders supported through this training is unclear.

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

The company has a ""Supplier Engagement Procedure"" to ensure that its suppliers (including smallholders and out-growers) comply with company's sourcing policy.

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

62 - The company states that 134 senior representatives from 71 major plantation companies, refiners, and suppliers attended the Inaugural Dialogue on SOPB Oil Palms Sustainability Policy 2019. However, this information is from 2019 and is over two years old now.

171. Suspension or exclusion criteria for suppliers?

The company reports in its Supplier Engagement Procedure that if a supplier fails to comply with the company's Sustainability Policy, the engagement process will be initiated and a follow-up assessment will be carried out within six months to track progress. If there is no verifiable progress on sustainability compliance by the suppliers, the Engagement Committee will make proposals to the top management who would make a final decision on whether to maintain or terminate the suppliers.

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

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?

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

The company reports a one-off workshop for suppliers relating to compliance with sourcing policies. However, no further details on the type of support provided are reported and it is unclear if this covers both own and third-party mills.

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

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

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

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

180. Commitment to ethical conduct and prohibition of corruption?

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

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

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

The company reports it conducts training sessions on anti-bribery and corruption. In 2022, 77% of the company's operations have been assessed for corruption-related risks and there were no confirmed incidents of corruption. However, the information reported is not externally verified.

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

The company has disclosed its approach to tax/payments to the government and states that its "Accounting & Financial Technical Committee ("AFTC")", headed by its Chief Financial Officer, with committee members comprised of senior members of the accounts & finance team is responsible for assessing and monitoring tax risks and other tax-related matters of the company.

184. Whistleblowing procedure?

The company has a whistleblowing procedure in place.

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

The company reports that grievances can be lodged through its whistleblowing mechanism which is open to all stakeholders.

186. Details of complaints and grievances disclosed?

[Externally verified] The company has a grievance list including details of complaints and grievances disclosed.