Kirana Megatara

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

The company has published a sustainable natural rubber policy which covers all rubber operations.

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?

Corporate Sustainability Officer.

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

The company reports that the president director is the head of its 'Corporate Sustainability and Community Development Division'.

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

6. Percentage or number of women board members?

20% - The company reports five members on its board, out of which one is a female. The company has not reported the gender balance directly and was calculated from the staff profiles.

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

[Externally verified] The company is only a member of the 'Partnership for Indonesian Sustainable Agriculture (PISAgro)'.

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

The company reports collaboration with Earthworm Foundation (formerly TFT), in a capacity-building project to help improve rubber smallholder plantation management; collaboration with SNV Netherlands to implement a 'Responsible Sourcing from Smallholder (RSS)' programme to deliver training on Better Management Practices (BMP); partnership with Michellin and Porsche in "Project Cascade" which stands for Committed Action for Smallholder Capacity Development; and collaboration with Goodyear in supporting farmers with social aid.

9. Sustainability report published within last two years?

The company's latest Sustainability Report was published in 2021 integrated into its Annual Report 2021.

10. Reports through standardised reporting systems?

11. Climate risks assessment available?

12. Lists countries and operations?

Processing and plantations (Indonesia).

13. Lists countries sourcing from?

The company sources natural rubber from Indonesia.

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

20434.4 - In 2021, company reported a total of 20,434.37 ha landbank (PT Putra Katingan Pratama (PKP) 11,300 ha; PT Anugerah Alam Persada (AAP) 3,889 ha; PT Kilau Getah Kemuning (KGK) 5,245.37 ha). However, another source dated for 2022 states 8,286 ha.

15. Total natural rubber planted area (ha)?

3500 - Figure from 2022.

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)?

3985 - Figure from 2022.

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

852 - Figure from 2022.

19. Maps of estates/management units?

A map for PT Putra Katingan Pratama is available using details published in the annual report, but details for PT Anugerah Alam Persada and PT Kilau Getah Kemuningcan do not yield estate boundaries when used on Google Maps.

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 scheme/outgrower smallholders?

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

23. Names and locations of all third-party supplying industrial estates/management units?

24. List of jurisdictions where sourcing from smallholders?

The company provides a list of provinces where it is sourcing from smallholders comprising North Sumatera, Jambi, South Sumatera, Lampung, West Kalimantan, and "Others". The jurisdiction for the category of "others" is not reported. Also unclear if this covers all smallholders of the company.

25. Number of company owned natural rubber processing facilities?

16 - The company reports to own sixteen natural rubber processing facilities.

26. Names and locations of company owned natural rubber processing facilities?

The company reports the names and addresses of all company owned natural rubber processing facilities.

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

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

29. 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.

30. Names and locations 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.

31. 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.

32. 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.

33. 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.

34. 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.

35. 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.

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

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

38. 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.

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

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

41. 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.

42. 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.

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

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

44. Percentage area (ha) FSC certified?

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

46. 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.

47. 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.

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

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

This indicator is disabled as the company does manufacture or trade rubber products.

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

51. Certified under voluntary sustainability certification scheme?

[Externally verified] The company reports that all of its factories are certified against ISO 14001:2015 (Environmental Management System). Certificates are available on the company website.

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

53. Commitment to zero conversion of natural ecosystems?

The company only reports its commitment to preserving the ecosystems including biodiversity. A clear commitment to zero conversion of all natural ecosystems is not reported by the company.

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

The company only commits its suppliers to preserve ecosystems. A clear commitment to zero conversion of all natural ecosystems is not reported by the company.

55. Commitment to zero deforestation?

The company commits to no deforestation.

56. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to no deforestation.

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

The company defines deforestation as HCV and protected areas and specifies any deforestation/conversion past 1st April 2019 (in line with the GPSNR policy framework) will not be accepted.

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

The company defines deforestation as HCV and protected areas and specifies any deforestation/conversion past 1st April 2019 (in line with the GPSNR policy framework) will not be accepted. This applies to all suppliers of the company.

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

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

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

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

63. Commitment to restoration of deforestation/conversion?

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's own reporting states it will support landscape/jurisdictional programmes to restore forests and degraded landscapes however it is not clear if the company will restore all deforestation committed by itself or third parties within its operations.

64. Commitment to restoration of deforestation/conversion applies to all suppliers?

The company commits suppliers to support landscape/jurisdictional programmes to restore forests and degraded landscapes. However, it is unclear if suppliers are required to restore deforestation/conversion within their own operations caused by themselves or third parties.

65. Implementing a landscape or jurisdictional level approach?

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 only reports to implement "the use of proper land use plans with an integrated landscape approach". However, no further details are provided and it is unclear if this is been implemented by the company.

66. Biodiversity policy?

67. Biodiversity policy applies to all suppliers?

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

The company provides a list of species identified in its conservation areas, however the list does not reference an international or national system of species classification.

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

The company only mentions tree planting and reforestation activities around processing facilities, however, no details are provided. Information is not externally verified and is from 2018.

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

The company commits to sustainable hunting but does not specify if this applies to both employees and/or local communities.

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

The company commits its suppliers to sustainable hunting but does not specify if this applies to both employees and/or local communities.

72. Commitment to protect areas from illegal activities?

The company reports commitment to promoting the protection of forest, conservation and other designated protected areas from illegal activities.

73. 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.

74. Evidence of protecting forest areas from illegal activities?

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

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 reporting does not clearly state it commits to conduct HCV assessments.

76. 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's own reporting only commits its suppliers to promote the use of assessment tools based on HCV and HCS concepts. A clear commitment to conduct High Conservation Value (HCV) assessments is not reported.

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

This indicator is disabled as the company reports to have not planted new rubber plantations since April 2019.

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

This indicator is disabled as the company reports to have not planted new rubber plantations since April 2019.

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

The company only commits to supporting the use of assessment tools based on HCS concepts. A clear commitment to the High Carbon Stock (HCS) Approach is not reported.

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

The company only commits its suppliers to promote the use of assessment tools based on HCV and HCS concepts. A clear commitment to the High Carbon Stock (HCS) Approach is not reported.

81. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company reports to have not planted new rubber plantations since January 2015.

82. 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 reports to have not planted new rubber plantations since January 2015.

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

The company only reports commitment to conduct social impact assessments. A commitment to conduct environmental impact assessments is not reported.

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

The company only commits its suppliers to conduct social impact assessments. A commitment to conduct environmental impact assessments is not reported.

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

86. 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. However, the company's own reporting states a commitment to zero peatland use and prohibiting any form of exploitation of known peatland but the depth of peatland is not specificed and a recognised definition is not referenced.

87. 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. However, the company's own reporting commits suppliers to zero peatland use and prohibits any form of exploitation of known peatland but the depth of peatland is not specificed and a recognised definition is not referenced.

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

In 2022, the company reported no peatland exists in the management area.

89. 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.

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

The company commits to good agricultural practices for soils. A commitment for peat is not required as the company has reported in the last two years that its landbank contains 0 ha of peat.

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

The company commits its suppliers to best management practices for soil, however, a commitment to best management practices for peat is not reported.

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

93. Commitment to best/sustainable tapping practices?

The company commits to best sustainable tapping practices but this only seems to apply to smallholders.

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

The company commits its suppliers to the best sustainable tapping practices but the commitment only seems to apply to smallholders.

95. Evidence of best/sustainable tapping practices?

The company conducts a tapping competition which judges speed and "correct technique". However, it is unclear if the company is implementing best/sustainable tapping practices.

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?

Evidence relating to building fires was found, but nothing in relation to forest fires.

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

The company states no hotspots were detected in 2022.

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

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

102. GHG emissions intensity?

The company reports GHG emission intensity for 2021 as 0.15 ton CO2 eq/ton product.

103. GHG emissions from land use change?

This indicator is disabled as the company reports to have not planted new rubber plantations since January 2015.

104. Progress towards commitment to reduce GHG emissions intensity?

The company reports GHG emissions intensity for 2019-2021. However, the emissions intensity has increased in 2021 (0.15 ton CO2 eq./ton) as compared to 2019 (0.14 ton CO2 eq./ton) and 2020 (0.14 ton CO2 eq./ton).

105. Methodology used to calculate GHG emissions?

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

The company commits to reduce water intensity to below 20 m3/ton by 2030.

107. Water use intensity?

26.24 - The company reports water use intensity in 2021 as 26.24 m3 /ton of product.

108. Progress towards commitment on water use intensity?

The company's water intensity has decreased from 27.63 m3/ton in 2020 to 26.24 m3/ton of production in 2021.

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

The company reports the average BOD (22 mg/L) and COD (57 mg/L) levels for all its factories and the figures are within legal limits (BOD- 60 mg/L and COD- 200 mg/L). However, this information is from 2019.

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

The company reports the average BOD (22 mg/L) and COD (57 mg/L) levels for all its factories and the figures reported are within legal limits (BOD- 60 mg/L and COD- 200 mg/L). However, the information reported is from 2019.

111. Treatment of effluents from processing facilities?

The company reports that it has constructed waste-water treatment plants in all factories. However, the information reported is not externally verified.

112. Treatment of effluents from manufacturing facilities?

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

113. Commitment to protect natural waterways through buffer zones?

The company only reports commitment "promoting" the use of buffer zones. A clear commitment to protect natural waterways through buffer zones is not reported.

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

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

The company reports having a principle for adopting cleaner processing methods which include reducing odour produced from rubber storage and processing. However, this information is not externally verified.

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

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

117. 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.

118. Commitment to no use of paraquat?

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

120. 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.

121. 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.

122. 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.

123. 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.

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

125. Implementation of commitment to minimise inorganic fertiliser usage?

126. Integrated Pest Management (IPM) approach?

The company reports to "promote" the use of biological pest control methods, however no reference to IPM is made and no details of such methods are provided. It is unclear if this is being implemented.

127. 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's own reporting commits to UN Guiding Principles of Human Rights.

128. Commitment to human rights applies to all suppliers?

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

129. Progress on human rights commitment ?

130. 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's own reporting references UN Declaration on the Rights of Indigenous Peoples.

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

The company commits suppliers to the UN Declaration on the Rights of Indigenous Peoples.

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

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

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

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

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

The company commits to respect FPIC.

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

The company commits all suppliers to respect FPIC.

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

137. Examples of local stakeholder engagement to prevent conflicts?

138. Details of process for addressing land conflicts available?

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

140. 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 reports this commitment on its website.

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

142. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

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

The company provides multiple examples of facilities and services provided to communities including education, health and religious facilities. However, the information provided is not externally verified.

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

The company commits to provide work opportunities for local communities.

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

The company commits to all Fundamental ILO Conventions.

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

The company commits all suppliers to all Fundamental ILO Conventions.

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

The company has established a relationship with the labor union and regularly distributes information on employment regulations to all employees. Evidence is limited in detail.

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

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

149. 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.

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

151. Percentage or number of temporary employees?

9% - The company reports that out of the total employees in 2021, 9% of its employees were contract employees.

152. Percentage or number of women employees?

9% - The company reports that out of the total employees in 2021, 9% of its employees were female.

153. Commitment to pay a living wage?

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

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

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

155. Progress on commitment to pay a living wage?

156. Reporting of salary by gender?

157. Commitment to address occupational health and safety?

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

158. 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.

159. Provision of personal protective equipment and related training?

160. Time lost due to work-based injuries?

The company reports an 'Accident Frequency Rate' of 1.32 in 2020. However, this information is over two years old now.

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

162. Commitment to support smallholders?

The company commits to support smallholders.

163. Percentage of supply from smallholders?

The company reports that as of 2021, 30% of its raw material supply comes directly from smallholder rubber gardens.

164. Programme to support scheme smallholders/outgrowers?

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

165. 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.

166. Programme to support independent smallholders?

The company reports information on supporting smallholders through its smallholder partnership program. The company together with Michellin, and Porsche has also jointly prepared a project called "Project Cascade" which stands for Committed Action for Smallholder Capacity Development.

167. Percentage of independent smallholders involved in programme?

15959 - The company reports the number of smallholders supported in 2021.

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

Suppliers are required to comply with a code of ethics but the method by which suppliers are engaged on compliance is unclear.

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

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

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

172. Suspension or exclusion criteria for non-smallholder suppliers?

The company reports that the suppliers are obliged to accept that violation of the supplier code of ethics will result in termination of business relationship. However, steps taken before termination are not reported.

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

174. Proportion of direct and indirect supply from third-parties that comes from natural rubber plantations which are compliant with natural rubber sourcing policies?

175. Percentage of supply coming from agroforestry?

176. Commitment to ethical conduct and prohibition of corruption?

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

177. 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.

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

179. Disclosure of the company’s management approach to tax and payments to governments?

180. Whistleblowing procedure?

The company has a whistleblowing system in place.

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

The company uses its whistle blowing system as a grievance system which is open to all internal and external stakeholders.

182. Details of complaints and grievances disclosed?