Halcyon Agri

1. Sustainable natural rubber policy or commitment for all its operations?

The company has published a sustainable natural rubber policy that aligns with the GPSNR Policy Components. The policy applies to both the company's own operations and those of its suppliers.

2. Sustainable natural rubber policy or commitment applies to all suppliers?

The company has published a sustainable natural rubber policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The managing director of 'Halcyon Rubber Company' 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 the whole board bears responsibility for sustainability.

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

9.6% - The company reports that it has 9.6% women in the senior management team. Data as of 2022.

6. Percentage or number of women board members?

11.1% - The company reports that it has 11.1% women board members in 2022.

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

[Externally verified] UNGC, IRSG and Fair Rubber.

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with natural rubber production?

The company reports that it has a five-year plan with a social NGO in Cameroon to improve relationships with communities around rubber estates. Further, the company has also collaborated with key stakeholders, namely customers, suppliers, local authorities and NGOs, to develop a 'Farmer Partner Programme' through which it provided good agricultural practice training to farmers to encourage community empowerment.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2022.

10. Reports through standardised reporting systems?

The company reports that its latest sustainability report has been prepared in accordance with GRI 1: Foundation 2021.

11. Climate risks assessment available?

The company has only published a summary of its climate risk assessment. The information is self-reported.

12. Lists countries and operations?

Plantations (Cameroon, Côte d'Ivoire, Malaysia), processing (China, Cameroon, Côte d'Ivoire, Indonesia, Malaysia, Thailand).

13. Lists countries sourcing from?

The company sources natural rubber from (Asia) Cambodia, India, Indonesia, Malaysia, Myanmar, Philippines, Sri Lanka, Thailand, Vietnam, (Africa) Cameroon, Gabon, Ghana, Guinea, Ivory Coast, Liberia, Nigeria, (South America) Guatemala.

14. Total land area managed/controlled for natural rubber (ha)?

109 - The company reports that it has 109,150 ha of total land area managed/controlled for natural rubber. Data as of 2022.

15. Total natural rubber planted area (ha)?

39500 - The company has 39,500 ha of total natural rubber planted area in 2022. This does not include scheme smallholder areas.

16. Scheme smallholders/outgrowers planted area (ha)?

This indicator is disabled as the company reports that it does not source from scheme/outgrower smallholder suppliers.

17. Unplanted area (areas designated for future planting) (ha)?

0 - The company reports that it has no land designated for future planting. Data as of 2022.

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

66 - The company reports that it has 66,581.5 ha of conservation set-aside area, including the HCV area in 2022.

19. Maps of estates/management units?

The company provides maps for all estates, however not all maps have legible coordinates or clearly outline concession boundaries. Some maps are over two years old.

20. Management plans for natural rubber production are available for all estates/management units?

21. Monitoring of management plan implementation available for all estates/management units?

22. Maps of all scheme/outgrower smallholders?

This indicator is disabled as the company reports that it does not source from scheme/outgrower smallholder suppliers.

23. Maps of all third-party supplying industrial estates/management units?

24. List of jurisdictions where sourcing from smallholders?

The company reports that it sources from smallholders in Cameroon in the following jurisdictions: Central region, East region, South region, Littoral region. However, reporting does not cover all smallholder sourcing for the company.

25. Number of company owned natural rubber processing facilities?

The company has a total of 37 natural rubber processing facilities in 2022.

26. Maps of company owned natural rubber processing facilities?

The names, locations and coordinates of all-natural rubber processing facilities are available.

27. Number (or percentage) of company-owned processing facilities that source from company-owned operations and third parties?

The company reports that two Cameroon factories source rubber from its own plantations while the remaining factories source from third-party plantations. Data as of 2023.

28. Reports total volumes (or percentages) sourced by company-owned processing facilities that come from company's own operations and third-parties?

The company reports that 3% of rubber sourced by company-owned processing facilities comes from its own operations while the remaining 97% comes from third parties. Data as of 2023.

29. Number of company owned natural rubber manufacturing facilities?

This indicator is disabled as the company does not operate manufacturing facilities.

30. Maps of manufacturing facilities?

This indicator is disabled as the company does not operate manufacturing facilities.

31. Number of third party supplying processing facilities?

This indicator is disabled as the company reports that it does not have any third-party processing facility suppliers.

32. Maps of all third party supplying processing facilities?

This indicator is disabled as the company reports that it does not have any third-party processing facility suppliers.

33. Number (or percentage) of third party supplying processing facilities that source from their own plantations and third party plantations?

This indicator is disabled as the company reports that it does not have any third-party processing facility suppliers.

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

This indicator is disabled as the company reports that it does not have any third-party processing facility suppliers.

35. Total volume (or percentage) sourced for manufacturing that comes from intermediary traders rather than directly from processing facilities?

This indicator is disabled as the company does not operate manufacturing facilities.

36. Time-bound commitment to achieve 100% traceability to processing facility level?

This indicator is disabled as the company reports that it does not have any third-party processing facility suppliers.

37. Percentage of supply traceable to processing facility level?

This indicator is disabled as the company reports that it does not have any third-party processing facility suppliers.

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

The company reports that it has already achieved 100% traceability to industrial plantation level. However, It is unclear if the company sources from other industrial plantations.

39. Percentage of supply from own processing facilities traceable to industrial plantation level?

The company's subsidiary reports that 78% of its supply is traceable to industrial plantation level, however, no figure covering the whole company could be found.

40. Percentage of supply from third-party processing facilities traceable to industrial plantation level?

This indicator is disabled as the company reports that it does not have any third-party processing facility suppliers.

41. Time-bound commitment to achieve 100% traceability to jurisdictional level for smallholders?

The company states that it has started the journey to achieve 100% traceability to farm level but has not set a date for when it aims for this to be achieved. Another commitment states it will achieve 100% end-to-end traceability at district level to its Asian factories only by 2025 (26 factories).

42. Percentage of supply from own processing facilities traceable to smallholder at jurisdictional level?

The company reports that 97% of supply to company-owned processing facilities comes from third parties but does not state if any is traceable.

43. Percentage of supply from third party processing facilities traceable to smallholders at jurisdictional level?

This indicator is disabled as the company reports that it does not have any third-party processing facility suppliers.

44. Member of the Global Platform for Sustainable Natural Rubber (GPSNR)?

[Externally verified] The company is a member of GPSNR. This has been verified via the GPSNR website.

45. Submitted self-declaration form for the Sustainable Natural Rubber Initiative (SNR-i)?

The company has submitted a self-declaration form for SNR-i.

46. Percentage area (ha) FSC certified?

47. Time-bound plan for achieving FSC FM certification of estates/management units?

The company commits to certify 69.5% of one Cameroonian estate by Q4 2024.

48. Percentage of scheme/outgrower smallholders (ha) FSC-certified?

This indicator is disabled as the company reports that it does not source from scheme/outgrower smallholder suppliers.  .

49. Time-bound plan for achieving FSC certification of scheme/outgrower smallholders?

This indicator is disabled as the company reports that it does not source from scheme/outgrower smallholder suppliers.

50. Percentage of natural rubber supply (tonnes) from independent smallholders/outgrowers/third-party natural rubber suppliers that is FSC-certified?

The company reports that 2% of supply from smallholders, outgrowers and third-party natural rubber suppliers is FSC-certified.

51. Percentage of all natural rubber products handled/traded/processed (tonnes) that is FSC-certified?

The company reports that 2% of supply traded is FSC-certified.

52. Percentage area (ha) PEFC certified (excluding FSC certified area)?

53. Certified under voluntary sustainability certification scheme?

[Externally verified] The majority of production facilities are ISO 14001 certified and certificates are available.

54. Commitment to become 100% certified under voluntary sustainability certification scheme?

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 makes this commitment through the the FSC Policy for Association (FSC-POL-01-004 V2-0) and the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's FSC certification/membership and alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to no deforestation in its own reporting.

58. Commitment to zero deforestation applies to all suppliers?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to this in its own reporting.

59. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

The company makes this commitment through the GPSNR Policy Framework. GPSNR defines natural rubber sourced from deforested areas (previously primary forest, HCV or HCS) or where HCVs have been degraded after 1 April 2019 to be non-conformant with its policy.

60. Criteria and cut-off date for defining deforestation and/or ecosystem conversion in supplier operations?

The company makes this commitment through the GPSNR Policy Framework. GPSNR defines natural rubber sourced from deforested areas or where HCVs have been degraded after 1 April 2019 to be non-conformant with its policy.

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

[Externally verified] The company reports that it uses satellite imagery from MapHubs to verify the no deforestation status annually in its Hevecam, Sudcam and JFL estates. Evidence is externally verified by the statement of the CEO of MapHubs.

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

The company reports that satellite imagery from MapHubs covers its outgrower programme. Images from december 2018 are compared to images at the time of onboarding and then re-assessed every five years. Monitoring covers the total land area included in the programme i.e., 150 ha of land. However, the information is not externally verified.

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

The company states that comparing the maps of 2019 and 2021 shows that it is compliant with its no-deforestation policy, however, it also mentions that there was some smallholder deforestation within its estates. This indicator scores on all deforestation within estates, regardless of the source. A total area affected by deforestation since the cut-off date (April 2019) has not been reported.

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

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

The company makes this commitment through the GPSNR Policy Framework. Partial points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that do not fully meet the SPOTT indicator criteria. The company also commits to restore deforested or degraded areas in its own reporting. However, no cut-off date was reported.

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

The company commits suppliers to protect and restore deforested or degraded areas. However, a cut-off date whereby areas deforested should be restored was not reported.

67. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company only reports the importance of a landscape-level approach to a project. Evidence is externally verified by Proforest, however, it is now over two years old.

68. Biodiversity policy?

69. Biodiversity policy applies to all suppliers?

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

The company reports that it has identified several species, such as the western lowland gorilla, chimpanzee, asian elephant and pangolin, referring to the IUCN Red List. However, the information is not externally verified.

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

[Externally verified] In 2022, the company renewed a five-year agreement to fight poaching in the Dja reserve with patrols, training and community engagement to protect endangered species. Evidence is externally verified by a document stamped by the Dja Reserve authority, however, details of the agreement's implementation are not available.

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

The company makes this commitment through the GPSNR Policy Framework. Partial points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that do not fully meet the SPOTT indicator criteria. The company also commits to protect forest areas from 'over-hunting' and allows sustainable hunting by indigenous communities for subsistence purposes that do not cause decline of local species populations. However, it is unclear if there is otherwise a ban on hunting.

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

The company commits suppliers to protect forest areas from 'over-hunting' which implies sustainable hunting is permitted. However, it is unclear who is allowed to hunt (employees or local communities) or if only forests are protected and hunting within plantations is permissible.

74. Commitment to protect areas from illegal activities?

The company commits to protect the natural ecosystems and plantations under its management from illegal activities.

75. Commitment to protect forest areas from illegal activities applies to all suppliers?

The company commits all suppliers to protect the natural ecosystems and plantations under their management from illegal activities.

76. Evidence of protecting forest areas from illegal activities?

The company reports that it regularly conducts patrols and employee awareness meetings as well as establishes buffer zones to prevent concessions against illegal activities. However, the information is not externally verified.

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

The company makes this commitment through the the FSC Policy for Association (FSC-POL-01-004 V2-0) and the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's FSC certification/membership and alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to conduct HCV assessments in its own reporting.

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

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits suppliers to conduct HCV assessments in its own reporting.

79. High Conservation Value (HCV) assessments available for all new plantings since 1st April 2019?

80. High Conservation Value (HCV) management and monitoring plans available for all new plantings since 1st April 2019?

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

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

82. 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.

83. High Carbon Stock (HCS) assessments available?

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

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

The company commits to conduct SEIAs for all its operations.

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

The company commits all suppliers to conduct SEIAs.

87. Social and environmental impact assessment (SEIAs) undertaken, and associated management and monitoring plans?

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

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to no planting on peat of any depth in its own reporting.

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

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits all suppliers to no planting on peat of any depth in its own reporting.

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

The company reports that it has no planted area on peat.

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

This indicator is disabled as the company has reported in the last two years that it has no peat in its operations.

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

The company makes this commitment through the GPSNR Policy Framework. Partial points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that do not fully meet the SPOTT indicator criteria. The company also commits to 'appropriate agricultural practices' for soil in its own reporting. However, it does not mention 'Good Agricultural Practices (GAP) or Best Management Practices (BMP)' in its commitment.

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

The company commits all suppliers to 'appropriate agricultural practices' for soil. However, it does not mention 'Good Agricultural Practices (GAP) or Best Management Practices (BMP)' in its commitment. No supplier commitment for peat soils could also be found.

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

The company reports that it grows plants such as vetiver grass and mucuna bracteate to prevent soil erosion and states that it provides Good Agricultural Practices (GAP) training to farmers in Indonesia. Evidence is not externally verified.

95. Commitment to best/sustainable tapping practices?

The company commits to best tapping practices.

96. Commitment to best/sustainable tapping practices applies to all suppliers?

97. Evidence of best/sustainable tapping practices?

The company provides a SOP for tapping practices for its operations. In 2023, 220 employees were trained on tapping practices. However, no examples of implementation were reported.

98. Commitment to zero burning?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to no burning in its own reporting.

99. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

100. Evidence of fire monitoring and management?

The company reports that it has a firefighting team to monitor fire incidents daily. Further, it has also installed a weather station at the Hevecam plantation for close monitoring of weather and conducts firefighting training activities to maintain the preparedness of its team against fires. Evidence is not externally verified.

101. Details/number of hotspots/fires in company estates/management units?

In 2022, the company recorded 23 fire incidents in its Cameroonian concessions.

102. Details/number of hotspots/fires in suppliers operations/jurisdictions?

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

The company commits to become net zero by 2025. However, the target does not include scope 1 and scope 2 emissions.

104. GHG emissions?

The company reports its GHG emissions intensity (inclusive of scope 1 & 2) as 197.8 kgCO2/tonne of product for factories and 238.9 tCO2e/hectare of cultivated area for plantations in 2022.

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

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

107. Progress towards commitment to reduce GHG emissions?

The company reports a decrease in its GHG emissions (scope 1) from 60,366 (tCO2e) in 2021 to 55,669 (tCO2e) in 2022. However, the figure does not include scope 2 emissions. However, the information is not externally verified.

108. Methodology used to calculate GHG emissions?

The company uses the GHG Protocol to calculate GHG emissions.

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

The company commits to reduce its water use intensity by 5% by the year 2025, compared to the baseline in 2021. However, it only applies to the 26 factories in Asia and not other operations.

110. Water use intensity?

The company reports its water withdrawal intensity as 10.1 ('000 m3/mT of product) and 14.4 ('000 m3/mT of cultivated area) for processing facilities and plantations, respectively.

111. Progress towards commitment on water use intensity?

The company reports an improvement in its water withdrawal intensity for plantations from 14.9 (m3/ha of cultivated area) in 2021 to 14.4 (m3/ha of cultivated area) in 2022. However, water withdrawal intensity for processing facilities increased from 9.2 (?000 m3/mT of product) in 2021 to 10.1 (?000 m3/mT of product) in 2022. Information is not externally verified.

112. Time-bound commitment to improve water quality (BOD or COD)?

The company has a commitment to be 5% below local legal limits regarding both BOD and COD. However, this commitment is not time-bound and it is unclear if levels are already below legal limits.

113. Progress towards commitment on water quality (BOD or COD)?

The company reports the data on BOD and COD from 2017 to 2019, but figures were not improving. The evidence is not externally verified and is over two years old.

114. Treatment of effluents from processing facilities?

The company reports that it treats effluents through anaerobic and aerobic processes and has developed an action plan to upgrade effluent treatment at facilities to reduce effluent discharge to zero. However, the information is not externally verified.

115. Treatment of effluents from manufacturing facilities?

This indicator is disabled as the company does not operate manufacturing facilities.

116. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways through buffer zones.

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

The company reports that it protects the natural waterways of Cameroon and Malaysian plantations through buffer zones. However, the information is not externally verified.

118. Reducing odours from natural rubber processing or manufacuring facilities?

The company reports that it has installed a bio-filter system that uses a bed of woodchips to break down malodour through a biological process. It also applies a 'Deorub' and 'wet line scrubber system' to reduce odours from natural rubber processing facilities. However, the information is not externally verified.

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

The company commits to minimise the use of chemical fertilisers and pesticides.

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

The company commits all suppliers to minimise the use of chemical fertilisers and pesticides.

121. Commitment to no use of paraquat?

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

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

The company commits to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits to not use Stockholm and Rotterdam Convention chemicals.

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

The company commits all suppliers to not use Stockholm and Rotterdam Convention chemicals.

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

The company provides a list of pesticides used in plantations in its 2022 sustainability report. Fertiliser information from 2021 is reported but information needs to be under two years old to score higher.

128. Implementation of commitment to minimise inorganic fertiliser usage?

The company reports that there has been a reduction in chemical fertiliser application due to precision agriculture and targeted soil and leaf analysis to optimise yield. However, no other details could be found.

129. Integrated Pest Management (IPM) approach?

The company reports that it has an integrated pest management approach, including harnessing cover crops such as pueraria javanica and centosema pubescens, whose flowers attract beneficial insects like wasps that help control insect pest populations, and the introduction of turnera subulate and antigonom leptopus plants that prevent invasion of beetles and caterpillars in plantations. However, the information is not externally verified.

130. Commitment to human rights?

The company makes this commitment through the the FSC Policy for Association (FSC-POL-01-004 V2-0) and the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's FSC certification/membership and alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to UN Guiding Principles on Business and Human Rights in its own reporting.

131. Commitment to human rights applies to all suppliers?

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

132. Progress on human rights commitment?

[Externally verified] The company has established a global grievance resolution mechanism to address issues related to human rights. Evidence is externally verified by Mighty Earth in a progress report. However, the information is between two to five years old.

133. Commitment to respect Indigenous and local communities' rights?

The company makes this commitment through the the FSC Policy for Association (FSC-POL-01-004 V2-0) and the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's FSC certification/membership and alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to the ILO Indigenous and Tribal Peoples Convention (no. 169) in its own reporting.

134. Commitment to Indigenous and local communities' rights applies to all suppliers?

The company commits suppliers to the ILO Indigenous and Tribal Peoples Convention (no. 169).

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

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to respect customary land tenure rights in its own reporting.

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

The company commits all suppliers to respect customary land tenure rights. However, a commitment to respect legal land rights could not be found.

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

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. In addition, the company commits to respect FPIC in its own reporting.

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

The company commits all suppliers to respect FPIC.

139. Details on Free, prior and informed consent (FPIC) process available?

The company commits to the FPIC process in accordance with UN-REDD.

140. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company reports that it is working with APIFED, a local NGO in Cameroon, on a five-year social action plan to support local communities and develop a framework to incorporate community concerns. Evidence is externally verified via quotes from the NGO.

141. Details of process for addressing land conflicts available?

The company's grievance procedure covers the land conflict resolution process.

142. Supports the inclusion of women across natural rubber operations, including addressing barriers faced?

The company reports that it is developing training programmes and childcare facilities to support the inclusion and professional development of women. However, no other details could be found. Evidence is over two years old and self-reported.

143. Commitment to mitigate impacts on food security?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to ensure food security for local communities in its own reporting.

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

[Externally verified] The company reports that it implemented 'Food Security' and 'Vegetable Gardening' programmes which enable the local community to earn additional income by planting vegetables on the lands owned by them and later the plantation outcome can be sold to employees of the factories. A company programme supplying maize seeds and phytosanitary equipment to communities has been externally verified by the NGO APIFED, however, detail is limited.

145. Commitment to provide essential community services and facilities?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to provide essential services and facilities to communities in its own reporting.

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

[Externally verified] The company reports that it has supported the maintenance of roads and bridges, the construction of religious places and community buildings and the improvement of building infrastructure of schools. Brickmaking presses have been donated to communities, this information is externally verified by the NGO APIFED, however, detail is limited.

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

The company commits to provide business opportunities for local communities.

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

The company makes this commitment through the the FSC Policy for Association (FSC-POL-01-004 V2-0) and the GPSNR Policy Framework. Both policies do not reference the 2022 amendments to the ILO Conventions, therefore partial points have been awarded on the basis of the company's FSC certification/membership and alignment with GPSNR Policy Components. The company only commits to eight fundamental ILO Conventions in its own reporting.

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

The company commits all suppliers to only eight fundamental ILO Conventions.

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

Limited, externally verified points have been awarded on the basis of the company's PEFC CoC certification (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not fully meet the SPOTT scoring criteria.

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

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

152. 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.

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

The company reports that it trains employees on anti-discrimination in regards to gender. However, no details on the training are provided. Information is not externally verified.

154. Percentage or number of temporary employees?

9.96% - The company has 1,533 (9.96%) temporary employees in 2022.

155. Percentage or number of women employees?

26% - The company has 3,999 (26%) women employees in 2022.

156. Commitment to pay a living wage?

The company mentions a living wage but only reports a commitment to pay at least minimum wage.

157. Commitment to pay a living wage applies to all suppliers?

The company commits suppliers to pay at least minimum wage to all workers.

158. Progress on commitment to pay a living wage?

[Externally verified] In 2021 and 2020 the company reported a 1:1 ratio on employee entry wage with legislated minimum wage. The information from 2020 is externally verified via assurance from TÜV SÜD, however, it is over two years old.

159. Reporting of salary by gender?

In 2020, the company reported that the ratio of entry-level wages for male and female staff was 1:1. However, no mention of salary reporting at other levels of employment could be found. Evidence is over two years old.

160. Commitment to address occupational health and safety?

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

161. 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.

162. Provision of personal protective equipment and related training?

Limited, externally verified points have been awarded on the basis of the company's FSC Chain of Custody certification (FSC-STD-40-004 V3-1) as the requirements do not fully meet the SPOTT indicator criteria. The company also reports that it provides PPE and training on health and safety to its employees. However, information is not externally verified.

163. Time lost due to work-based injuries?

The company reports the rate of recordable work-related injuries as 12.2 in 2022. Calculated as the number of employees with work-related injury x 1,000,000/total working hours.

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

The company reported one fatality in 2022.

165. Commitment to support smallholders?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to support smallholders in its own reporting.

166. Percentage of supply from smallholders?

The company reports that it sources approximately 76% of natural rubber raw materials from smallholder farmers. The company cannot score higher as the figure is approximate.

167. Programme to support scheme smallholders/outgrowers?

This indicator is disabled as the company reports that it does not source from scheme/outgrower smallholder suppliers.

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

This indicator is disabled as the company reports that it does not source from scheme/outgrower smallholder suppliers.

169. Programme to support independent smallholders?

[Externally verified] The company has an 'Outgrower Programme' to support smallholders in Cameroon. The programme offers livelihood support to smallholders through assisting with intercropping model and partnering on ecological conservation. The programme is called an 'Outgrower Programme' in name only, as all smallholders remain independent. Information is externally verified by Proforest but is now over two years old.

170. Percentage of independent smallholders involved in programme?

The company reports that 467 smallholders have been onboarded onto the programme by January 2023. However, the evidence is not externally verified.

171. Process used to engage smallholder suppliers on compliance with company's policy and/or legal requirements?

The company reports that its sites largely communicated policies verbally with suppliers and smallholders and records keeping was not consistently practised. Further details on the process used were not disclosed.

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

The company reports that 467 smallholders have been assessed on compliance with social and environmental criteria to take part in the company's smallholder programme. However, the evidence is not externally verified.

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

The suppliers are required to report compliance with the company's sustainable sourcing policy on an annual basis, however, this only applies to the company's subsidiary.

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

The company reports that 129 suppliers have shown compliance with the company's policy. Information is not externally verified.

175. Suspension or exclusion criteria for suppliers?

The company states that those suppliers who show non-compliance with its sustainable sourcing policy or refuse to set a recovery plan for this will be terminated or excluded from the business relationship, however, it does not give timeframes for the implementation of corrective action plans.

176. Time-bound action plans (including Key Performance Indicators) for suppliers to be in compliance with natural rubber sourcing commitments?

The company has time-bound action plans to ensure compliance from suppliers with its sustainable sourcing policy, but does not include KPIs and compliance is based on self-assessment from suppliers only. Plans only cover the company's suppliers in Africa.

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

178. Percentage of supply coming from agroforestry?

The company reports that its supply contained no rubber from agroforestry in 2020. Evidence is over two years old.

179. Commitment to ethical conduct and prohibition of corruption?

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

180. 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.

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

The company has established a grievance mechanism to report misconduct related to fraud, bribery and corruption and has not received any cases of bribery or corruption in 2022. Policies are made available to employees. Evidence is not externally verified.

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

The company provides limited details on tax management but discloses that the Chief Financial Officer has overall responsibility in managing this area.

183. Whistleblowing procedure?

The company has a whistleblowing procedure including how whistleblowers can report unethical conduct and how they are protected.

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

The company has its own grievance system that is open to all stakeholders.

185. Details of complaints and grievances disclosed?

The company has reported the details of grievances such as date, category, progress, stakeholder's name and status.