Apical Group

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

This indicator is disabled as the company is only a processor or trader.

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

The company has published a sustainable palm oil policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

Head of sustainability.

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

The company's president and executive director have responsibility for sustainability within the board.

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

17% - The company reports the percentage of females who are part of its senior management team as 17%. Data as of 2021.

6. Percentage or number of women board members?

0 (0%) - The company reports no females as a part of its board in 2022.

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

[Externally verified] TFA, Earthworm and NYDF.

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

The company works closely with the Earthworm Foundation to help conduct a deforestation risk analysis for all suppliers in East Kalimantan. The aim is to build a better understanding of social issues driving deforestation and improve livelihoods through community engagement. The company also collaborates with Jakarta's Park and Forest Service to support the Indonesian government's mangrove rehabilitation programme with a target of 600,000 ha by 2024. The company also reports information on several other collaborations.

9. Sustainability report published within last two years?

The company published its latest sustainability report in 2023, covering the year 2022.

10. Reports through standardised reporting systems?

The company has submitted a CDP response for climate change and forests in 2022 and 2023.

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

This indicator is disabled as the company is not a POIG member.

12. Climate risks assessment available?

The company has identified limited targets relating to climate risk and includes metrics and progress. The company also states that it recognises the recommendations made by the Task Force on Climate-related Financial Disclosure (TCFD) and is planning to address identified gaps by 2023 and report in line with the best practices recommended by the TCFD in 2024.

13. Lists countries and operations?

Indonesia (refineries, crushing facilities), Spain (refinery), and China (refinery).

14. Lists countries sourcing from?

Indonesia, China, Spain.

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

This indicator is disabled as the company is only a processor or trader.

16. Total oil palm planted area (ha)?

This indicator is disabled as the company is only a processor or trader.

17. Scheme smallholders planted area (ha)?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

20. Maps of estates/management units?

This indicator is disabled as the company is only a processor or trader.

21. Maps of all scheme smallholders?

This indicator is disabled as the company is only a processor or trader.

22. Maps of all third-party supplying plantations?

The company provides a map of its suppliers with coordinates, but estate boundaries are not provided.

23. Number of company-owned mills?

This indicator is disabled as the company does not own mills.

24. Names and locations of company-owned mills?

This indicator is disabled as the company does not own mills.

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

This indicator is disabled as the company does not own mills.

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

This indicator is disabled as the company does not own mills.

27. Number of third party supplying mills?

409 - The information on all third-party supplying mills to the company's refineries and crushing facilities is published on the company website. Data as of December 2022.

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

The information on names and locations of all third-party supplying mills to the company's refineries and crushing facilities is published on the company website.

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

The company reports that 59.7% of its third-party supplier mills source from their own plantations while 40.3% source from third-party plantations. Data as of December 2022.

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

The company reports that in terms of the volume of FFB supplied to it,49.4% is sourced from third-party supplier mills' own plantations while 50.6% is sourced from third-party plantations. Data as of December 2022.

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

The company reports that 93.91% of its palm oil products are sourced from supplying mills and the remainder is procured from a few trading companies. Data as of 2022.

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

The company has already achieved 100% traceability to mill level in 2015.

33. Percentage of supply traceable to mill level?

The company reports to have maintained 100% traceability to the supplying mills since 2015. Additional points are awarded as a few of the company's refineries have RSPO SCC under IP and SG.

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

The company reports a commitment to achieve 100% traceability to plantation level by 2025.

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

This indicator is disabled as the company does not own mills.

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

The company reports that as of December 2022, it has been able to trace 99.98% of its FFB sources to plantations. Additional points are awarded as a few of the company's refineries have RSPO SCC under IP.

37. Publishes traceability data at refinery level?

[Externally verified] The company reports traceability to the plantation for CPO and CPKO suppliers which is externally verified by Control Union. However, this data only covers the company's Indonesian operations.

38. Publishes traceability data at crusher level?

[Externally verified] The company has two crushing facilities which are 95.01% and 100% traceable to the plantation level. Information is externally verified by Control Union.

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

[Externally verified] 2011 - The company's subsidiary, AAA Oils & Fats Pte. Ltd. became a member of the RSPO in 2011.

40. 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] 2012 - The company's subsidiary, AAA Oils & Fats Pte. Ltd., obtained its first certification in 2012.

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

RSPO ACOP 2022 is submitted by the company.

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

This indicator is disabled as the company is only a processor or trader.

43. Percentage of mills RSPO-certified?

This indicator is disabled as the company does not own mills.

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

This indicator is disabled as the company is only a processor or trader.

45. Time-bound plan for achieving 100% RSPO certification of all palm product processing facilities within 5 years?

2023 - The company commits to achieving 100% RSPO certification of all palm product processing facilities by 2023. This is within 5 years.

46. Percentage of scheme smallholders (ha) RSPO-certified?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

3.64% - The company reports the percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that is RSPO-certified as 3.64%.

50. Sells RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

This indicator is disabled as the company is only a processor or trader.

51. Processes/trades RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

The company processes/trades RSPO-certified palm oil through Identity Preserved and Segregated supply chains.

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

This indicator is disabled as the company is only a processor or trader.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

[Externally verified] ISCC.

55. Commitment to zero conversion of natural ecosystems?

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to zero conversion of natural ecosystems.

57. Commitment to zero deforestation?

This indicator is disabled as the company is only a processor or trader.

58. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to no development in High Conservation Value (HCV), and High Carbon Stock (HCS) areas.

59. Criteria and cut-off date for defining deforestation?

This indicator is disabled as the company is only a processor or trader.

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

The company defines deforestation for suppliers as the development of HCV and HCS areas and specifies any deforestation/conversion past 2015 will not be accepted in supplier operations.

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

This indicator is disabled as the company is only a processor or trader.

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

[Externally verified] The company reports using three monitoring tools to monitor deforestation in supplier operations; Global Forest Watch Pro Platform, Earthqualizer report monitoring, which provides bi-weekly reports to the company, and the company's own Satellite Monitoring System (ACTION) Report. The information reported is externally verified by the Control Union.

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

This indicator is disabled as the company is only a processor or trader.

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

65193.7 - The company reports the cut-off date for supplier operations as 'after December 2015' and reports that the total area of deforestation recorded from December 2015 until December 2022 for all suspended suppliers is approximately 65,193.71 hectares.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits suppliers to restore ecosystems to their prior condition in cases of conversion within their own operations.

67. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company has launched the Sustainable Living Village (SLV) Program in partnership with local partners and the government for Aceh Singkil and Kutai Region for supporting governance policies. The company also runs its own Traceability Outreach Programme (TOP) which assists suppliers in identifying and managing landscape-level issues based on the location of their FFBs source. The information reported is externally verified by Control Union.

68. Biodiversity policy?

This indicator is disabled as the company is only a processor or trader.

69. Biodiversity policy applies to all suppliers?

The company has published a biodiversity policy which applies to all suppliers, covers multiple dimensions of biodiversity protection and extends beyond HCV/HCS/set-asides.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to only allow sustainable hunting of species by local communities for subsistence purposes in their operations.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to conduct HCV assessments.

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

This indicator is disabled as the company is only a processor or trader.

77. High Conservation Value (HCV) assessments for all estates planted/planned planting since January 2015?

This indicator is disabled as the company is only a processor or trader.

78. High Conservation Value (HCV) or combined HCV/HCS management and monitoring plans for all estates planted/planned planting since January 2015?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

80. 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 company commits all suppliers to only use licensed HCV assessors accredited by the HCV Resource Network's ALS.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

83. 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.

84. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company is only a processor or trader.

85. 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 is only a processor or trader.

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

The company commits to conduct social and environmental impact assessments.

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

The company commits all suppliers to conduct social and environmental impact assessments.

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

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to no planting on peat of any depth.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to best management practices for soils and peat.

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

This indicator is disabled as the company is only a processor or trader.

96. Commitment to zero burning?

This indicator is disabled as the company is only a processor or trader.

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

98. Evidence of fire monitoring and management?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits to reducing GHG emissions intensity by 50% by the year 2030 and reaching net zero by 2050. Commitment includes scope 1 and scope 2 emissions.

102. GHG emissions intensity?

The company reports GHG Scope 1 and 2 emissions intensity (tCO2e/MT of oil processed) for all its refineries, crushing facilities, and oleochemical plants as 0.12 in 2022.

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

This indicator is disabled as the company is only a processor or trader.

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

105. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports the total emissions intensity for 2021 and 2022 as 0.09 and 0.12 tCO2e/MT of oil processed, respectively. The emissions intensity has increased in 2022 as compared to 2021, however, it is still less than the intensity reported for the company's baseline year (2020- 0.16). Also, the Control Union report does not cover all operations of the company under external verification.

106. Methodology used to calculate GHG emissions?

The company uses the ISO 14064-1 and GHG Protocol (Corporate Reporting Standard) methodology to calculate GHG emissions.

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

This indicator is disabled as the company is only a processor or trader.

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

The company reports a target to reduce water use intensity by 30% as compared to the 2020 baseline by 2030.

109. Water use intensity?

0.000456 - The company reports the water intensity of its operations in 2021 and 2022 as 0.00039 and 0.000456 ML/MT (Megalitres/Megatonnes), respectively.

110. Progress towards commitment on water use intensity?

[Externally verified] The company reports that its total water consumption increased by 21% in 2022 as compared to 2021. This information is externally verified by Control Union.

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

The company reports it ensures that the BOD or COD of its operations are within the legal threshold based on the regulations where the operations are located; which is below 75 mg/L and 150 mg/L for BOD and COD respectively.

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

[Externally verified] The company reports BOD and COD levels for all its operations and the levels are within the local legal limits. However, the Control Union report does not cover all operations under external verification.

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

This indicator is disabled as the company does not own mills.

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

[Externally verified] The company reports treating effluents at all its refineries. This information is externally verified by Control Union.

115. Commitment to protect natural waterways through buffer zones?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

118. 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.

119. Commitment to no use of paraquat?

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to only use paraquat in exceptional circumstances.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to only use World Health Organisation (WHO) Class 1A and 1B pesticides in exceptional circumstances.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits suppliers to only use Stockholm and Rotterdam Convention chemicals in exceptional circumstances.

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

This indicator is disabled as the company is only a processor or trader.

126. Implementation of commitment to minimise inorganic fertiliser use?

This indicator is disabled as the company is only a processor or trader.

127. Integrated Pest Management (IPM) approach?

This indicator is disabled as the company is only a processor or trader.

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

[Externally verified] The company has a robust waste management system in place. This information is externally verified by the Control Union.

129. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

130. Commitment to human rights applies to all suppliers?

The company commits suppliers to the Universal Declaration of Human Rights.

131. Progress on human rights commitment?

[Externally verified] The company reports its progress on the commitment to human rights which includes giving training to employees on its human rights policies, workers' rights and grievance handling. The information reported is externally verified by the Control Union.

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

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

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

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

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

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

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

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

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

The company commits to respect FPIC.

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

The company commits all suppliers to respect FPIC.

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

The company has published its free, prior and informed consent (FPIC) process on its website.

139. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company reports multiple examples of local stakeholder engagement to prevent conflicts including its Sustainable Living Village (SLV) Programme which is a stakeholder-inclusive program that nurtures sustainable livelihood models through working with partners, communities, and villagers. This information is externally verified by Control Union.

140. Details of process for addressing land conflicts available?

The company has published a land conflicts resolution process.

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

This indicator is disabled as the company is only a processor or trader.

142. Commitment to mitigate impacts on food security?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

144. Commitment to provide essential community services and facilities?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits to all Fundamental ILO Conventions.

148. 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.

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

[Externally verified] The company reports its progress on its commitment to respect all workers' rights. This information is also externally verified by Control Union.

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

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

151. 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.

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

[Externally verified] The company reports having a special committee (Employee Industrial Relations) that will investigate sexual harassment towards the workers if any of the cases are reported and also mentions providing training to employees on preventing discrimination and harassment. This information is externally verified by the Control Union.

153. Percentage or number of temporary employees?

25% - The company reports 25% of its total workforce are temporary employees. Data as of 2022.

154. Percentage or number of women employees?

17.86% - The company reports that women contribute 17.86% of its total workforce in 2022.

155. Commitment to pay a Living Wage?

The company commits to pay a Decent Living Wage to all workers.

156. Commitment to pay a Living Wage applies to all suppliers?

The company commits all suppliers to pay a Decent Living Wage to all workers.

157. Progress on commitment to pay a Living Wage?

[Externally verified] The company only reports its progress on paying the minimum wage by reporting legal minimum wages alongside minimum wages paid by the company. This information is externally verified by the Control Union.

158. Reporting of salary by gender?

The company reports the ratio of the basic salary and remuneration of women to men for all locations of company operations as per each employee category.

159. Commitment to address occupational health and safety?

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

160. 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.

161. Provision of personal protective equipment and related training?

[Externally verified] The company reports evidence that it provides personal protective equipment (PPE) and related training. This information is externally verified by the Control Union.

162. Time lost due to work-based injuries?

The company reports a high consequence work-related injury rate and recordable work-related injury rate for both employees and contractors. Data as of 2022.

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

1 - The company reports one work-related fatality for its contractors in 2022.

164. Commitment to support smallholders?

The company has published a commitment to support smallholders.

165. Programme to support scheme smallholders?

[Externally verified] The company reports having a 'Rurality' project to support the scheme/plasma smallholders. This project with Earthworm Foundation aims to drive transformation and innovation at the farmer level and empowers farmers to create, tap into and own the mechanisms that will ultimately strengthen their resilience and improve their livelihoods. All the information reported is externally verified by Control Union.

166. Percentage of scheme smallholders involved in programme?

[Externally verified] 15.48% - The company reports that 15.48% out of 6 plasma smallholders' groups (KUD's) are involved in the rurality project. This information is externally verified by the Control Union.

167. Programme to support independent smallholders?

[Externally verified] The company reports running an initiative, named 'Smallholder Inclusion for Better Livelihood & Empowerment Programme or SMILE', to help independent smallholders improve their yields, obtain sustainability certification, and eventually secure premiums from selling certified palm oil, in order to increase their income. This information is externally verified by the Control Union.

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

[Externally verified] 3018 (89%) - The company reports that there are three phases of the SMILE program, out of which Phase 1 has been completed and the company is continuing to engage with smallholders under Phase 2 (2022 to 2027) and Phase 3 (2025 - 2030) of the SMILE programme. As of the end of 2022, the SMILE program has benefited approximately 3,018 independent smallholders.

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

The company assesses suppliers through its Mill Prioritisation Process and engages with them through its Priority Supplier Engagement Programme, Traceability Outreach Programme, and Shared Value Programme. The company also reports to use its "Apical Sustainability IMPLEmentation (A-SIMPLE) Framework", to help suppliers achieve supply chain transparency and compliance with NDPE policy.

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

[Externally verified] 100% - The company reports that 7 suppliers are involved in the 'Priority Supplier Engagement Programme (PSEP)', 55 suppliers in its Collaborative Action Remote Engagement (CARE) program, and 540 suppliers in its Mill Prioritization Process (MPP). As of 2022, 100% of the CPO mills are engaged through the company's MPP program. All the information reported is externally verified by Control Union.

171. Suspension or exclusion criteria for suppliers?

The company states it "does not knowingly source from problematic suppliers such as those that engage in illegal activities or violate community rights". For any proven violations raised through the company's grievance system, the company states "Suppliers are required to provide a concrete corrective action plan with clear timelines. Failure to respond and commit towards remedial action triggers a suspension of contracts until progress has been made or the issue has been resolved.".

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

The company specifies the following KPIs for suppliers to comply with its sourcing policy: "all suppliers must commit to Apical Sustainability Policy, Suppliers must be fully traceable within 1 year of doing business with Apical, All suppliers to be NDPE compliant by 2025, Suppliers must cooperate with Apical on any grievance matters within the stipulated timeline in accordance to Apical's Grievance Protocol".

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

The company reports ""sighted the No Deforestation for CPO and PKO Supplier Profile for the year 2022 which is based on the NDPE IRF chart stated that 91.4% and 89.0% respectively of the suppliers are in delivering status for no deforestation"". This information is externally verified by Control Union.

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

The company reports that all its suppliers are assessed under the MPP, and high-risk mills with long-term business relations are prioritised for engagement through the PSEP. The company conducts field visits for suppliers identified under the PSEP to build rapport and identify gaps for improvement. As part of these visits, detailed guidance to help suppliers develop robust Standard Operating Procedures (SOPs) and sustainability management systems is offered. Since the introduction of PSEP in 2015, the company's sustainability team has visited 53 mills.

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

[Externally verified] The company reports that all its suppliers are assessed under the MPP, and high-risk mills with long-term business relations are prioritised for engagement through the PSEP. The company conducts field visits for suppliers identified under the PSEP to build rapport and identify gaps for improvement. As part of these visits, detailed guidance to help suppliers develop robust Standard Operating Procedures (SOPs) and sustainability management systems is offered. This information is externally verified by Control Union.

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

[Externally verified] The company reports engaging with high-risk mills on a regular basis through different programs under its 'Anchor Program'. This information is externally verified by the Control Union.

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

The company reports using its 'Mill Prioritisation Process (MPP)' for a risk-based assessment of its suppliers to identify priority mills for deeper engagement.

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

[Externally verified] The company reports that risk levels are updated monthly based on the parameters of the MPP. This information is externally verified by Control Union.

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

[Externally verified] Based on the company's 'Mill Prioritisation Process (MPP)', the company has identified and classified its suppliers under 3 categories: High-risk mills (10%), medium-risk mills (22%), and low-risk mills (67%). This information is externally verified by the Control Union.

180. Commitment to ethical conduct and prohibition of corruption?

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

181. 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.

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

[Externally verified] The company reports that all employees receive Anti-Bribery and Corruption (ABC) training and are encouraged to raise concerns about suspected misconduct or malpractice to either the relevant department heads or in accordance with its Whistleblowing Policy. This information is externally verified by Control Union.

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

The company reports that the Business Group President or Managing Director have overall responsibility for the tax strategy. No tax policy is reported.

184. Whistleblowing procedure?

The company reports that its grievance process includes a whistleblowing channel, details of which are published on the company website.

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

The company reports having a 'Grievance Procedure' which can be used by all its stakeholders.

186. Details of complaints and grievances disclosed?

[Externally verified] The details of complaints and grievances are disclosed by the company. Details are updated till September 2022.