ITOCHU Corporation

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company's procurement policy expects its suppliers to promote activities that are consistent with this policy. However, it is not clear that all commitments within the policy are applied to all suppliers.

3. High-level position of responsibility for sustainability?

The Sustainability Management Division is headed by ESG officers and managers.

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

The company's Sustainability Committee is led by the Chief Administrative Officer.

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

9.8% - The company has four (9.8%) women on its senior management team as of March 31, 2023.

6. Percentage or number of women board members?

20% - The company has two (20%) female directors in a team of 10 board members as of March 31, 2023.

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.

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

The company reports that it has undertaken the 'Project Tree Initiative' with the aim of achieving traceability and sustainability of natural rubber. It has utilised the value chain, including PT. Aneka Bumi Pratama (ABP) natural rubber processing company, and European Tyre Enterprise Limited, to develop a blockchain system to trace natural rubber from smallholders. In addition, it collaborated with Proforest and SNV international NGOs to conduct modern slavery risk assessments on the supply chain.

9. Sustainability report published within last two years?

The company has published its latest ESG Report for 2023.

10. Reports through standardised reporting systems?

The company has published its Water and Climate CDP Questionnaire for 2023.

11. Climate risks assessment available?

The company has included its climate risk assessment, including potential risks, metrics, targets, and processes used to assess or manage climate risks, in its ESG Report 2023. Information is not externally verified.

12. Lists countries and operations?

Processing (Indonesia).

13. Lists countries sourcing from?

The company sources natural rubber from Indonesia.

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

This indicator is disabled as the company does not operate rubber plantations.

15. Total natural rubber planted area (ha)?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

19. Maps of estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

22. Maps of all scheme/outgrower smallholders?

This indicator is disabled as the company does not operate rubber plantations.

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

24. List of jurisdictions where sourcing from smallholders?

As of December 2023, the company sources rubber from smallholders and estates in Riau, West Sumatera, Jambi, Bengkulu, South Sumatera, Lampung, West Java and Central Java (Indonesia). However, the information includes both smallholders and estates so cannot be awarded full points.

25. Number of company owned natural rubber processing facilities?

The company has two natural rubber processing facilities through its subsidiary, PT Aneka Bumi Pratama.

26. Maps of company owned natural rubber processing facilities?

The names and locations are available for both the natural rubber processing facilities through its subsidiary, PT Aneka Bumi Pratama.

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

The company manages no plantations, therefore all natural rubber is sourced from third parties.

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

The company manages no plantations, therefore all natural rubber is sourced from third parties.

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 does not operate rubber plantations.

32. Maps of all third party supplying processing facilities?

This indicator is disabled as the company does not operate rubber plantations.

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 does not operate rubber plantations.

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 does not operate rubber plantations.

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 rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

37. Percentage of supply traceable to processing facility level?

This indicator is disabled as the company does not operate rubber plantations.

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

The company has reported a commitment to achieve 100% traceability of its natural rubber supply from industrial plantations by 2025.

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

The company reports 4.5% of supply in FYE 2023 was traceable. However, an individual figure for industrial plantation supply traceability is not stated and it is not clear whether traceability is to farm level.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company has reported a commitment to achieve 100% traceability to jurisdictional level of its natural rubber supply from smallholders by 2025.

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

The company reports 4.5% of supply in FYE 2023 was traceable. However, an individual figure for smallholder supply traceability is not stated and it is not clear whether traceability is to farm or jurisdictional level.

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

This indicator is disabled as the company does not operate rubber plantations.

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's subsidiary (PT. Aneka Bumi Pratama) has submitted a self-declaration form for SNR-i. This covers all-natural rubber operations.

46. Percentage area (ha) FSC certified?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company reports 0.1% of supply is FSC certified. However, the figure is undated and it is not clear if it represents all supply to PT ABP.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

53. Certified under voluntary sustainability certification scheme?

[Externally verified] The company has disclosed ISO 14001 certificates for its two factories. As the audit criteria is not publicly available for ISO certification, a higher score cannot be awarded.

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

55. Commitment to zero conversion of natural ecosystems?

This indicator is disabled as the company does not operate rubber plantations.

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

The company only states that it recognises the value of the benefits received from the natural ecosystem, minimises its impact on biodiversity, and contributes to its conservation. However, no commitment to zero conversion of natural ecosystems could be found.

57. Commitment to zero deforestation?

This indicator is disabled as the company does not operate rubber plantations.

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 reports not sourcing from suppliers who contribute to deforestation, degradation of HCV and HCS areas, or development on peat.

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

This indicator is disabled as the company does not operate rubber plantations.

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. The company also defines forests as HCV areas and specifies any deforestation/conversion past April 2019 will not be accepted.

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

This indicator is disabled as the company does not operate rubber plantations.

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?

This indicator is disabled as the company does not operate rubber plantations.

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

The company states no deforestation found as of December 2023. However, it is unclear if this includes all deforestation since the company's April 2019 cut-off date.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company commits suppliers to restoring degraded rubber landscapes. However, it is not clear if the policy applies to all suppliers, and it is also not clear if suppliers are obligated to restore deforestation/conversion within their own operations caused by themselves or third parties. Further, a cut-off date beyond which deforestation/conversion has to be restored is also not reported.

67. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company reports that it is working with supply chain actors to create a blockchain traceability system for natural rubber. Further, it has also conducted a risk mapping of smallholder farmers. Evidence is externally verified by quotes from external organisations involved in the project. However, the externally verified information is between two and five years old.

68. Biodiversity policy?

This indicator is disabled as the company does not operate rubber plantations.

69. Biodiversity policy applies to all suppliers?

The company only mentions biodiversity with no details on target and scope. It is also not applicable to suppliers.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company commits to protecting wildlife, including rare, threatened, endangered and critically endangered species from over-hunting, and also states that it allows hunting only for local community subsistence. However, it is not clear if hunting is banned in all other circumstances.

74. Commitment to protect areas from illegal activities?

This indicator is disabled as the company does not operate rubber plantations.

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

The company commits to source from suppliers who protect wildlife from poaching. However, no reference was found to other illegal activities.

76. Evidence of protecting forest areas from illegal activities?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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 to source from producers that do not contribute to the degradation of HCV areas.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company commits to not source from suppliers who degrade HCS areas, as defined by the HSC Approach.

83. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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 to conduct social and environmental assessment to all suppliers through Project TREE. However, it is not clear if all suppliers are part of Project TREE.

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

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

This indicator is disabled as the company does not operate rubber plantations.

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's own procurement policy does not clearly apply to all suppliers but does mention prohibiting rubber production on peatland of any depth.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company ""encourages"" suppliers to commit to best management practices for soils and peat. The commitment is not strong enough for full points.

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

This indicator is disabled as the company does not operate rubber plantations.

95. Commitment to best/sustainable tapping practices?

This indicator is disabled as the company does not operate rubber plantations.

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

The company commits suppliers to provide training to producers on sustainable tapping practices, however, the policy does not clearly cover all suppliers.

97. Evidence of best/sustainable tapping practices?

This indicator is disabled as the company does not operate rubber plantations.

98. Commitment to zero burning?

This indicator is disabled as the company does not operate rubber plantations.

99. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

100. Evidence of fire monitoring and management?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

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

The company reports a commitment to achieve a 40% reduction in GHG emissions from 2018 levels by 2030. However, it does not specify that the target includes scope 1 and scope 2 emissions.

104. GHG emissions?

The company reports its GHG emissions (including scope 1 and scope 2 emissions) as 1766 (thousand t-CO2e) in 2023. However, the figures are not specific to the natural rubber operations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

107. Progress towards commitment to reduce GHG emissions?

[Externally verified] The company reports progress in the reduction of its total GHG emissions (including scope 1 and scope 2 emissions) for the whole group from 2201 (thousand t-CO2e) in 2022 to 1766 (thousand t-CO2e) in 2023. However, the figures are not specific to the natural rubber operations. Evidence is externally verified by KPMG.

108. Methodology used to calculate GHG emissions?

The company uses the GHG Protocol developed by WRI (the World Resources Institute) and WBCSD (the World Business Council for Sustainable Development) to calculate GHG emissions.

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

110. Water use intensity?

The company reports its water use intensity as 1.83 m3/KL in 2023. However, this is specific to beverage manufacturing only.

111. Progress towards commitment on water use intensity?

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

The company reports that no serious legal violations related to water withdrawal and discharge have been recorded in 2023. However, this information is not specific to natural rubber operations.

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

The company reports an increase in its BOD and COD levels from 28,622 t and 135,710 t in 2022 to 52,612 t and 231,914 t in 2023, respectively. However, the figures are not specific to rubber operations.

114. Treatment of effluents from processing facilities?

The company reports that it makes efforts to reduce its water consumption through efficient water use and recycling, as well as taking necessary measures to appropriately treat effluents in its operations. However, no specific mention of effluent treatment at natural rubber facilities was found.

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?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company states it reduces the odor via spraying Deorub chemical. However, the information is not dated.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company only 'encourages' suppliers to minimise the use of chemical fertilisers and pesticides. Also, it is not clear if the policy applies to all suppliers.

121. Commitment to no use of paraquat?

This indicator is disabled as the company does not operate rubber plantations.

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

The company only 'expects' suppliers to not use paraquat. Also, it is not clear if the policy applies to all suppliers.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company only 'encourages' suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides. Also, it is not clear if the policy applies to all suppliers.

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

This indicator is disabled as the company does not operate rubber plantations.

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

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

This indicator is disabled as the company does not operate rubber plantations.

128. Implementation of commitment to minimise inorganic fertiliser usage?

This indicator is disabled as the company does not operate rubber plantations.

129. Integrated Pest Management (IPM) approach?

This indicator is disabled as the company does not operate rubber plantations.

130. Commitment to human 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 the Universal Declaration of 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 reports that it has a human rights due diligence process in place to identify and mitigate negative impacts on human rights. It has also conducted training and workshops to raise awareness on human rights issues. This information is externally verified by KPMG.

133. Commitment to respect Indigenous and local communities' 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 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 legal and 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 legal and customary land tenure rights.

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. The company also 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's subsidiary reports a flowchart of the FPIC process.

140. Examples of local stakeholder engagement to prevent conflicts?

The company provides land legality training workshops to smallholders. However, the information is not externally verified and is between two and five years old.

141. Details of process for addressing land conflicts available?

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

This indicator is disabled as the company does not operate rubber plantations.

143. Commitment to mitigate impacts on food security?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

145. Commitment to provide essential community services and facilities?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

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

The company commits to provide work opportunities for local communities.

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

The company commits to the ILO's Declaration on Fundamental Principles and Rights at Work.

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

The company commits all suppliers to the ILO's Declaration on Fundamental Principles and Rights at Work.

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

The company reports that it is mandatory for employees upon recruitment to complete training on working conditions, which includes issues related to salary, working hours and holidays, occupational safety and health, benefits, and service regulations. The company also ensures that all employees must comply with the labour standards and be available at all times on the intranet. This information is not externally verified.

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

The company commits all suppliers 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 provides training to employees to acquire consideration for nationality, age, and gender. Further, it also raises the problem of sexual harassment (including discriminatory behaviour and harassment toward sexual orientation and gender identity) and abuse of authority in internal training aimed at organisational heads. Additionally, the company has also established a Women's Advancement Committee as a voluntary advisory committee of the Board of Directors to accelerate the pace of its support for the success of female employees. This information is not externally verified.

154. Percentage or number of temporary employees?

The company reports that it has 44,705 temporary employees. Data as of March 2023.

155. Percentage or number of women employees?

11.3% - The company reports that it has 375 women employees. Data as of March 2023.

156. Commitment to pay a living wage?

The company commits to pay the living wage to all workers.

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

The company reports that its suppliers shall comply with statutory minimum wages and strive to exceed living wages. However, a clear commitment to pay living wage that applies to all suppliers was not found.

158. Progress on commitment to pay a living wage?

159. Reporting of salary by gender?

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 health and safety-related training to its employees.

163. Time lost due to work-based injuries?

The company reports LTIFR (Lost Time Injury Frequency Rate) for full-time employees as 0.0 and for part-time employees as 0.0 in 2023. Calculated as the number of employees with LTI x 1,000,000/total working hours.

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

The company reports zero fatalities in 2023.

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 states that 95% of supply comes from smallholders. However, the information is undated.

167. Programme to support scheme smallholders/outgrowers?

This indicator is disabled as the company does not operate rubber plantations.

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

This indicator is disabled as the company does not operate rubber plantations.

169. Programme to support independent smallholders?

The company reports to support smallholders through the initiative 'PROJECT TREE', which aims to assess supply chain risks and design a training program based on the risk analysis.

170. Percentage of independent smallholders involved in programme?

The company reports that it has trained 2,027 farmers until 1H of 2022 to provide added economic value for farmers. However, it is unclear what percentage of the company's supply this represents.

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

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

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

The company discloses its "Sustainability Action Guidelines for Supply Chains" and states that the guideline includes sustainability surveys, environment risk assessments by-products, etc.

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 it surveyed a total of 320 companies in FYE 2022. This includes 48 suppliers from 'General Products & Realty Company', including the rubber operations of the company. However, it is unclear if these figures represent all natural rubber non-smallholder suppliers that were assessed by the company.

175. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria. The company also reports that if a violation of its procurement policy is identified, it immediately suspends any transaction with that supplier and is then required to take corrective action, along with providing guidance and support to the supplier. However, no timeline for action was reported.

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

The company reports a time-bound commitment to compliance with the 'policy components of GPSNR in the whole supply chain by 2050'. No milestones or KPIs were provided, and it is unclear if compliance is based on self-assessment by suppliers.

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

178. Percentage of supply coming from agroforestry?

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 reports to conduct on-site compliance training for all officers and employees every year, raising awareness of compliance, including anti-corruption, anti-bribery, and antimonopoly acts. Further, the company also implements a 'Compliance Awareness Survey' every two years with all group employees. In addition to this, the company has an internal reporting system supporting the prompt discovery and rectification of any incidents of corruption, including bribery. The information is not externally verified.

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

The company has a tax policy in place which includes its managerial approach to tax payments and a governance body which is responsible for the tax policy and its review. However, it is specific to UK operations only.

183. Whistleblowing procedure?

The company reports a flowchart including a clear description on how whistleblowers can report unethical conduct and how they are protected.

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

The company has a grievance system open to all stakeholders. The company uses an external grievance platform, JaCER which includes information on the grievance process.

185. Details of complaints and grievances disclosed?