Agropalma Group

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

The company meets this indicator through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also has a responsible palm oil policy.

2. Sustainable palm oil policy or commitment applies to all suppliers?

The company's own policy is extended to suppliers.

3. High-level position of responsibility for sustainability?

The company reports it has a sustainability manager, however, data is between two and five years old.

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

One member of the board has responsibility for sustainability.

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

15% - The company reports the percentage of women in management positions but it is unclear if these are senior management positions.

6. Percentage or number of women board members?

0 (0%) - As of 2018 there were no women on the board.

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

[Externally verified] Palm Oil Innovation Group (POIG) and Coalizao Brasil Clima Florestas Agricultura.

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

The company is working with universities and Conservation International on biodiversity monitoring as part of its forest programs.

9. Sustainability report published within last two years?

The latest sustainability report was published in 2017.

10. Reports through standardised reporting systems?

The company's most recent sustainability report is available on GRI and in acordance with GRI standards, however the report is more than two years old.

11. Verification report on compliance with POIG Charter, if a POIG member?

12. Climate risks assessment available?

The company has identified reduced rainfall as a risk to operations and suggested three strategies to mitigate its impact. However, information is very limited.

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

117850

14. Total oil palm planted area (ha)?

42700

15. Plasma/scheme smallholders planted area (ha)?

10344

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

300

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

64000

18. Maps of estates/management units?

Concession boundaries have been made available to the RSPO and the company declares these represent 100% of its concession sites, but not all may be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO.

19. Maps of scheme/plasma smallholders?

20. Names and locations of all third-party supplying plantations?

The company provides the name and location of its only independent supplier, but no geo-referenced map clearly showing estate boundaries.

21. Number of company-owned mills?

5

22. Names and locations of company-owned mills?

Names and locations of company-owned mills can be found on the Global Forest Watch database.

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

Three mills source from company-owned operations only, whereas two mills source from company-owned, scheme smallholders, outgrowers and independent third-parties.

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

In 2019, 75% of all FFB processed in company mills came from the company's own plantations, 16% from integrated outgrowers, 6% from family farmers and 3% from one independent supplier.

25. Number of third party supplying mills?

81

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

Names and coordinates for all 81 supplying mills can be found in the company's responsible palm oil policy.

27. Number (or percentage) of third party supplying mills that source from their own plantations and/or third party plantations?

28. Reports total volume (or percentages) sourced from third-party supplying mills that come from the supplying mills' own operations and/or third parties?

29. Total volume (or percentage) sourced for refineries that comes from intermediary traders and/or refiners rather than directly from mills?

28.834 tons (17%) of the total volume sourced for refiners came from intermediary traders and/or refiners in 2019.

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

The company's target is for the year 2020.

31. Percentage of supply traceable to mill level?

100% of supply is traceable to mill level, an additional point has been awarded for a refinery with RSPO Identity Preserved certification.

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

The company makes this commitment for its own mills through a commitment to the POIG charter. Partial points have therefore been awarded on the basis of the company's POIG verification.

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

The company states 100% of its supply to its own mills is traceable to plantation level. An additional point has been awarded as all five company mills have RSPO Identity Preserved certifications.

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

The company reports that 22% of its supply from third-parties is traceable to plantation level. An additional point has been awarded for an RSPO Identity Preserved certification for one of the company's two refineries.

35. Publishes traceability data at refinery level?

36. Publishes traceability data at crusher level?

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

[Externally verified] 2004

38. RSPO-certified within three years of joining the RSPO or by November 2010, for companies joining prior to finalisation of the RSPO certification systems in November 2007?

[Externally verified] 2011 - The company joined the RSPO in 2004, but could only certify its first plantation estates in 2011 when the Local Interpretation of RSPO P&C for Brazil became available. The company certified all of its plantations in 2011.

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

The company has submitted its 2019 ACOP.

40. Listed all countries and regions in which operates in most recent RSPO Annual Communication of Progress (ACOP)?

The company only operates in Brazil.

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

42. Percentage of mills RSPO-certified?

100% - All of the company's five mills are RSPO certified.

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

2011 - The company has already achieved this target.

44. Year expected to achieve 100% RSPO certification of all palm product processing facilities?

2013

45. Percentage of scheme/plasma smallholders (ha) RSPO-certified?

100% - All 10,344 ha under scheme smallholders is certified.

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

2014

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

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

49. Sells or processes/trades RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

The company sells or processes/trades RSPO-certified palm oil through both Segregated, Identity Preserved and Mass balance supply chains.

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

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

51. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

[Externally verified] The company is certified IFOAM Organic and ISO TS 22002 (FSSC), certificates are available on its website.

53. Commitment to zero deforestation or zero conversion of natural ecosystems?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also commits independently to not develop on primary forest, HCV or HCS areas, or peatland.

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

The company's own policy is extended to suppliers.

55. Criteria for defining deforestation?

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also reports using these criterion independently as company policy.

56. Evidence of monitoring deforestation?

The company reports it monitors deforestation in its own and supplier estates with ground patrols and satellite images. This information is not externally verified.

57. Evidence of monitoring deforestation in supplier operations?

The company reports it monitors deforestation in its supply chain by visiting suppliers every two weeks and monitoring satellite images once a year. This information is not externally verified.

58. Amount of illegal/non-compliant deforestation recorded in own operations?

0 - The company reported 0 deforestation in its own operations in 2018.

59. Amount of illegal/non-compliant deforestation recorded in supplier operations?

0 - The company reported 0 deforestation in its supplier operations in 2018.

60. Commitment to restoration of non-compliant deforestation/conversion?

61. Commitment to restoration of non-compliant deforestation/conversion applies to all suppliers?

62. Implementing a landscape or jurisdictional level approach?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company states it collaborates with NGOs, for example it has completed a Conservation International report that provides guidelines on biodiversity management at the landscape level.

63. Commitment to biodiversity conservation?

64. Commitment to biodiversity conservation applies to all suppliers?

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also provides examples of species monitoring and reforestation.

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

Hunting is prohibited in forest areas.

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

The company's own policy also applies to suppliers.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes the same commitment.

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

The company's own commitment is extended to suppliers.

71. High Conservation Value (HCV) assessments for planting undertaken prior to January 2015, and associated management and monitoring plans?

[Externally verified] There is a public summary of an HCV/SEIA for Arauai and Calmaria II Smallholders.

72. High Conservation Value (HCV) assessments for all estates planted since January 2015?

[Externally verified] The following five HCV assessments are available: "HCV AGROPALMA S.A. Outgrowers. Moju, Tailândia and TTomé, Para, Brazil HCV AGROPALMA S.A. Outgrowers Tomé-Açu e Tailândia- Pará- BRAZIL Report of High Conservation Values AGROPALMA S.A. Tailándia Para, BRAZIL HCV Agropalma's Outgrowers. Paráná State. Brazil AVC Agropalma e Produtires Independentes, Tailandia - Para - Brasil" A sixth HCV-HCS assessment has been submitted to the HCVRN in 2019, however its evaluation status is delayed.

73. High Conservation Value (HCV) management and monitoring plans for all estates planted since January 2015?

[Externally verified] A summary is available for one HCV and recommendations are available for four HCVs. A sixth HCV-HCS assessment has been submitted to the HCVRN in 2019, however its evaluation status is delayed.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The commitment only applies to plantations established by family farmers and integrated outgrowers.

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

[Externally verified] One HCV assessment was deemed unsatisfactory.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

79. High Carbon Stock (HCS) assessments available?

[Externally verified] One HCS-HCV integrated assessment has been submitted but deemed unsatisfactory in 2019. The assessment has not been resubmitted since.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The commitment only applies to plantations established by family farmers and integrated outgrowers.

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

[Externally verified] There is one summary of SEIA management and planning for smallholders: Summary of HCV/SEIA Management and Planning for Arauai and Calmaria II Smallholder Communities.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment extends to suppliers.

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

0

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

This indicator is disabled as the company states it has no landbank on peat.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

90. Commitment to zero burning?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

91. Commitment to zero burning applies to all suppliers?

92. Evidence of fire monitoring and management?

The company reports monitoring fires via the alert service provided by RSPO and WRI (Fire Watch) and details firefighting measures.

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

In 2019, the company recorded 57 hotspots and 0 fires.

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

0 - In 2019, no fires were recorded in supplier areas.

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

The company aims to reduce mill emissions to 0.1 tons of CO2eq/ton of FFB processed by 2025.

96. GHG emissions intensity?

0.200 tons of CO2eq/ton of FFB processed in 2019.

97. GHG emissions from land use change?

In 2019, 491,171.78 tons of CO2eq were recorded for historical land use change.

98. Progress towards commitment to reduce GHG emissions intensity?

The company reports GHG emissions intensity for 2016, 2017 and 2019 but it is not clearly improving.

99. Methodology used to calculate GHG emissions?

The RSPO requires companies to assess their GHG emissions through the Palm GHG calculator. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

The company states it has installed new ponds at two of its mills in preparation for a methane capture system to be installed in 2021. No mills currently have methane capture.

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

The company has a target to use 4.5 m3 of water per ton of oil produced by 2023.

102. Water use intensity?

5.3 - In 2019, mills consumed 5.3 m3 of water per ton of oil produced.

103. Progress towards commitment on water use intensity?

The company reports water use intensity from 2015-2019. The construction of a new mill which has not yet reached optimal capacity has negatively impacted progress over time, but the company has achieved a small reduction from 2018-2019. Data has not been externally verified.

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

The company has met its commitment to re-use 100% of its effluent and not discharge any effluent.

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

The company reuses 100% of its effluent and does not discharge any into water. This information is not externally verified.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

All PORE is treated before discharge. This information is not externally verified.

108. Commitment to protect natural waterways through buffer zones?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

112. Commitment to no use of paraquat?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

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

The company uses minimal chemicals in its operations. In 2019, figures for Glyphosate, Flumioxazin and Metsulfuron-methyl applied per ha are available.

119. Implementation of commitment to minimise inorganic fertiliser use?

Points for external verification have been awarded on the basis of the company's POIG verification. The company utilises 100% of POME as organic fertiliser.

120. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

122. Commitment to human rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also commits to the UNDHR.

123. Commitment to human rights applies to all suppliers?

The company's own policy is extended to suppliers.

124. Progress on human rights commitment?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to its FFB suppliers only.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also publishes this commitment independently.

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

The company's own commitment is extended to suppliers.

131. Details of free, prior and informed consent (FPIC) process available?

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

132. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company regularly visits suppliers and allows them to voice concerns, it has a team responsible for stakeholder engagement, and also conducts participatory mapping. Information is externally verified in RSPO public summary reports.

133. Details of process for addressing land conflicts available?

The RSPO Principles and Criteria 2018 contain requirements for addressing land conflicts. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also published its process for addressing land conflicts online.

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

The company has a commitment to increase the participation of women in "several areas of the company". Mechanisation has reduced the roles of women in plantations so the company began a programme to train women harvesters - which in 2017 employed 120 women. The company also has addressed the gender pay gap but only for employees on its basic salary (company minimum wage), where the ratio amongst men and women is equal to 1. This information is not externally verified.

135. Commitment to mitigate impacts on food security?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

136. Commitment to mitigate impacts on food security applies to all suppliers?

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

[Externally verified] Points for external verification have been awarded on the basis of the company's POIG verification.

138. Commitment to provide essential community services and facilities?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also commits to all ILO Core Conventions.

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

The company's own commitment is extended to suppliers.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also states it has robust policies and reporting systems in respone to sexual harassment of female employees.

147. Percentage or number of temporary employees?

The company reports that during its peak season in 2019 13-26% of its workforce was on fixed-term contracts.

148. Percentage or number of women employees?

594 (14%) - The company reports 594 employees out of 4,259.5 FTE were female in 2019.

149. Commitment to pay at least minimum wage?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

150. Commitment to pay at least minimum wage applies to all suppliers?

The company's own commitment is extended to suppliers.

151. Progress on commitment to pay at least minimum wage?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

152. Reporting of salary by gender?

The company only reports the basic salary ratio for men and women was equal to 1 in 2019.

153. Commitment to address occupational health and safety?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

155. Provision of personal protective equipment and related training?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

156. Time lost due to work-based injuries?

1.74 - Lost time accident rate (per 200,000 working hours) in 2019. The company's accident severity rate was 5.87 lost days per accident on average for 2019.

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

0 - The company reported 0 fatalities in 2019.

158. Commitment to support smallholders?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

159. Programme to support scheme/plasma smallholders?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

160. Percentage of scheme/plasma smallholders involved in programme?

[Externally verified] 192 (100%) - The company supports 192 (100%) family farmers.

161. Programme to support independent smallholders/outgrowers?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. Outgrowers are part of the same programme as scheme smallholders.

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

[Externally verified] 42 (100%) - The company states 42 outgrowers (100%) participated in its POIG verification report 2019.

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

The company assesses suppliers every three months and contracts will be suspended or terminated within a maximum of two years, depending on the issue. The company conducts due diligence for legality and compliance with RSPO deforestation rules prior to inclusion in smallholder programs.

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

[Externally verified] 100% - All growers are assessed on legal compliance monthly.

165. Suspension or exclusion criteria for suppliers?

The company assesses suppliers every three months and contracts will be suspended or terminated within a maximum of two years, depending on the issue. In the cases of deforestation, forced and child labour suppliers are immediately suspended and contracts can be terminated within a month if violations continue.

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

100% of the company's smallholders and outgrowers are RSPO certified, if new suppliers are integrated they need to be certified within three years.

167. Proportion of direct and indirect supply that comes from palm oil plantations which are compliant with palm oil sourcing policies?

The company reports that 83% of its supply (direct) is compliant and the remaining 17% (indirect) has not been assessed.

168. Time-bound plan to engage with all high risk mills within 3 years?

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

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

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

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

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

174. Commitment to ethical conduct and prohibition of corruption?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company discloses that it has a specialised manager responsible for its tax plan.

178. Whistleblowing procedure?

The RSPO Principles and Criteria 2018 contain guidance and requirements on whistleblowing procedures. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

The company adheres to this criteria through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company has published its complaints system procedure which is open to internal and external stakeholders.

180. Details of complaints and grievances disclosed?

Details of grievances are published, however they have not been updated since 2016.