The Yokohama Rubber Co Ltd

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

3. High-level position of responsibility for sustainability?

The company has a Head of Corporate Social Responsibility.

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

The head of 'Corporate Social Responsibility' division is a member of the board of directors.

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

The company reports 10.1% of managers at the "Managerial and general managerial level" were female in 2022. However, these stats do not cover the senior management team (what the company calls 'officers').

6. Percentage or number of women board members?

18.2% - The company reports that it has 2 (18.2%) 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] The company is a member of IRSG, WBCSD, WBCS Tire Industry Project and UNGC.

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

The company reports that in 2022, it conducted biodiversity conservation and social contribution activities in collaboration with local residents, local governments, schools and businesses. In addition to this, it has also collaborated with the Rubber Authority of Thailand (RAOT) to improve the quality of natural rubber and to support smallholders in Thailand.

9. Sustainability report published within last two years?

The company published an integrated report in 2023 which includes sustainability-related matters.

10. Reports through standardised reporting systems?

The company has published its Forest, Water, and Climate CDP Questionnaires for 2023.

11. Climate risks assessment available?

The company published a climate risk assessment including potential risks, metrics, targets, and processes used to assess or manage climate risks. However, the information is not externally verified.

12. Lists countries and operations?

Processing (Thailand), manufacturing (Japan, United States, China, Vietnam, Thailand, India, Russia, Israel, Philippines, Singapore).

13. Lists countries sourcing from?

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?

25. Number of company owned natural rubber processing facilities?

The company owns only one processing facility through its subsidiary Y.T. Rubber Co Ltd.

26. Maps of company owned natural rubber processing facilities?

The company provides a link to Google Maps and a written address for its only processing facility.

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?

The company has 47 natural rubber manufacturing facilities in 2022.

30. Maps of manufacturing facilities?

The company provides the names and addresses of its manufacturing facilities on its website. However, it is unclear if it includes all manufacturing facilities.

31. Number of third party supplying processing facilities?

32. Maps of all third party supplying processing facilities?

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

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

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

The company has a target to survey all tier 1 suppliers by 2023.

37. Percentage of supply traceable to processing facility level?

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

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

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

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

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

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

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?

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?

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

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?

The company's only processing facility is ISO 14001 certified. Information is not externally verified.

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?

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 commits all suppliers to zero deforestation in its own reporting.

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.

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 visited 437 farmers in Surat Thani, Thailand, and did not report any violation of deforestation. However, the information does not cover all deforestation on all supplier operations since the company's cut-off date of 1 April 2019.

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?

67. 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. No commitment or evidence of implenmentation could be found in the company's own reporting.

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 also does not apply 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?

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?

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's own reporting only commits to protect and conserve 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 all suppliers to apply the HCS Approach, as defined by the HCS Approach Toolkit.

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)?

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

The company has conducted supplier environmental and social impact assessments, however, it is unclear if this is applied to all suppliers.

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

The company published a supplier's environmental and social impact assessment. However, It does not cover its own operations.

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 also commits to no planting on peatland in its own reporting, however, it does not specify the depth or refer to a recognised definition of peat.

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?

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?

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 commits to reduce its GHG emissions by 28% by the year 2030, against 2019 baseline. However, it is unclear if 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 1,051 thousand tons for 2022.

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?

The company reports a decrease in its GHG emissions (including scope 1 and scope 2 emissions) from 1,099 thousand tons in 2021 to 1,051 thousand tons in 2022. However, the evidence is not externally verified.

108. Methodology used to calculate GHG emissions?

The company uses the GHG Protocol methodology to calculate GHG emissions.

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

The company has a general commitment to reduce its water usage by 1% from the previous year. However, no time-bound commitment to improve water use intensity could be found.

110. Water use intensity?

19173 - The company reports its water usage as 19,173 thousand m^3 in 2022. However, the intensity figure is not reported by the company.

111. Progress towards commitment on water use intensity?

The company reports its water usage as 19,102 thousand m^3 in 2021 and 19,173 thousand m^3 in 2022. However, the figures were neither reported as intensity nor improved from the previous year.

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

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

114. Treatment of effluents from processing facilities?

The company reports that it operates a 'complete water circulation system' at its processing facility and does not discharge any plant effluent into waterways. However, the information is not externally verified.

115. Treatment of effluents from manufacturing facilities?

The company reports that it has installed a water treatment system at all the sites and has circulating water treatment equipment to increase the ratio of circulating water use and reduce the amount of wastewater. However, the information is not externally verified.

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?

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 commits all suppliers to minimise the use of chemicals. However, it is unclear if the commitment requires the company to minimise chemical fertiliser and pesticide use.

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?

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?

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 Universal Declaration of Human Rights.

132. Progress on human rights commitment?

The company reports that it provided 2,522 hours of training on human rights to its employees in 2022, and has a due diligence process to assess human rights risks in its operations. However, the information is not externally verified.

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 UN Declaration on the Rights of Indigenous Peoples in its own reporting.

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

The company has published a commitment to respect Indigenous and local community rights for suppliers. However, it does not commit to the UN Declaration on the Rights of Indigenous Peoples or 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 commits to follow UN-REDD guidelines and provides details on the FPIC process.

140. Examples of local stakeholder engagement to prevent conflicts?

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 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. GPSNR does not reference all Fundamental ILO Conventions as amended in 2022 to include Occupational Safety and Health Convention, 1981 (No. 155) and the Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187). The company commits to the ILO's Declaration on Fundamental Principles and Rights at Work, however, it only lists a few of the principles.

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

The company only expects its suppliers to respect ILO's Declaration on Fundamental Principles and Rights at Work. However, it is unclear if it applies to suppliers.

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

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

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

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

The company has a 'Diversity & Inclusion Promotion Taskforce' to support career development for women, people with disabilities and LGBTQ+ people in the organisation. Further, in 2022, it has also conducted training on subjects like harassment, quality misconduct and diversity & inclusion. However, the information is not externally verified.

154. Percentage or number of temporary employees?

1.72% - The company reports that it has 491 temporary employees out of 28,468 total employees in 2022.

155. Percentage or number of women employees?

14% - The company reports that 14% of its workforce are women. Data as of 2022.

156. Commitment to pay a living wage?

The company commits to pay minimum wage to its employees. However, no commitment to pay a living wage could be found.

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

The company commits all suppliers to pay only minimum wage to all workers.

158. Progress on commitment to pay a living wage?

The company only reports that it pays above the regional minimum wage at all 145 production and sales companies in Japan and overseas in 2022. However, the information is not externally verified.

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?

The company reports that it provides personal protective equipment and hazard prediction training to all of its employees. However, the information is not externally verified.

163. Time lost due to work-based injuries?

The company reports a lost days injury frequency rate of 0.24 in 2022. Calculated as recordable injuries x 1000,000/total working hours.

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

The company reported zero work-related fatalities in its operations 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?

167. Programme to support scheme smallholders/outgrowers?

The company reports that it regularly holds seminar events on agroforestry to teach its benefits and to improve the economic conditions of smallholders. Additionally, it has partnered with processor Kirana Megatara to deliver smallholder trainings. However, the type of smallholders is unclear and it is not part of a defined smallholder programme.

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

The company reports that 50 farm households attended a workshop in which smallholders were taught agricultural practices and gifted fertiliser. However, it is not clear if these smallholders are independent or scheme smallholders.

169. Programme to support independent smallholders?

The company reports that it regularly holds seminar events on agroforestry to teach its benefits and to improve the economic conditions of smallholders. Additionally, it has partnered with processor Kirana Megatara to deliver smallholder trainings. However, the type of smallholders is unclear and it is not part of a defined smallholder programme.

170. Percentage of independent smallholders involved in programme?

The company reports that 50 farm households attended a workshop in which smallholders were taught agricultural practices and gifted fertiliser. However, it is not clear if these smallholders are independent or scheme smallholders.

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?

The company reports that it has surveyed 437 farmers since June 2019, which assesses compliance with the company's policy. However, the company does not specify what type of suppliers (industrial plantations or smallholders) were assessed. However, the information 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?

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 has surveyed 437 farmers since June 2019, which assesses compliance with the company's policy. However, the company does not specify what type of suppliers (industrial plantations or smallholders) were assessed. However, the information is not externally verified.

175. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not fully meet the SPOTT scoring criteria. The company independently reports that its entire supply chain must follow its procurement policy for sustainable natural rubber and provides steps to be taken if a supplier is not in compliance. However, no timeframes were reported by the company.

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

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 it has supported 57 farmers to adopt the agroforestry method in Thailand. However, it is unclear how much of the company's supply is sourced from agroforestry systems. However, the information is not externally verified.

179. Commitment to ethical conduct and prohibition of corruption?

The company commits to the prohibition of corruption. However, a commitment to ethical conduct could not be found.

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

The company commits all suppliers to the prohibition of corruption. However, a commitment to ethical conduct could not be found.

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

The company reports that it provides training on corruption and bribery and has a corruption risk assessment procedure to assess corruption-related risks in its business operations. However, the information is not externally verified.

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

The company has published a tax policy including a management approach to tax and a governance body which is responsible for its review.

183. Whistleblowing procedure?

The company has its own whistleblowing procedure.

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

The company has two corporate compliance hotlines for its internal and external stakeholders. It also receives complaints from all stakeholders through JaCER's complaint reporting desk.

185. Details of complaints and grievances disclosed?