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- Tor Mooi See.

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

The company reports that its Board of Directors is the highest governing body responsible for driving direction and the journey towards sustainable growth.

5. Reports gender balance of senior management team?

21 (18.91%) - The company reports 21 females as a part of its senior management team of 111 people in 2024.

6. Reports gender balance of board members?

0 (0%) - The company reports three members as a part of its board in 2024, of which none is a female.

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

Earthworm, POCG, and NYDF.

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

The company has launched the Sustainable Living Village (SLV) Program since February 2023, in partnership with organisations such as Yayasan Ekosistem Lestari (YEL) and Forum Konservasi Leuser (FKL) for enhancing livelihoods, protecting forests, driving supply chain transformation and supporting landscape collaboration through the Production, Protection and Inclusion (PPI) Compact. In 2024, the company launched SLV in East Kutai, Kalimantan, in collaboration with Earthworm Foundation and the East Kutai District Government, with the targets of protecting 10,000 ha of land and planting 90,000 trees for forest conservation and restoration.

9. Sustainability report published within last two years?

The company published its latest sustainability report in 2025, covering the year 2024.

10. Reports through standardised reporting systems?

The company has submitted a CDP response for climate change and forests in 2024. Additionally, the company's latest sustainability report is prepared with GRI 1: Foundation 2021 requirements.

11. 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 acknowledges the recommendations made by the TCFD/ISSB and is currently in the process of concluding a climate risk assessment report. This includes scenario analyses covering short-, medium-, and long-term horizons.

12. Lists countries and operations?

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

13. Lists countries sourcing from?

Indonesia, China, Spain.

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

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

15. Total oil palm planted area (ha)?

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

16. Scheme smallholders planted area (ha)?

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

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

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

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

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

19. Maps of estates/management units?

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

20. Maps of all scheme smallholders?

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

21. Maps of all third-party supplying plantations?

22. Number of company-owned mills?

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

23. Names and locations of company-owned mills?

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

24. 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.

25. 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.

26. Number of third party supplying mills?

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 2024.

27. 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.

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

The company reports that 54.90% of its supplying mills sourced FFB from their own plantations and 45.10% sourced FFB from third-party plantations. Data as of 2024.

29. 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 22.51% of the total volume of FFB from the supplying mills is sourced from their own plantations, and 77.49% of the total volume of FFB from the supplying mills is sourced from third-party plantations. Data as of 2024.

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

The company reports that 7.09% of the total volume of CPO and 23.83% of the total volume of PK sourced comes from traders. Data as of 2024.

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

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

32. 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.

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

The company commits to achieve 100% traceability to plantation level by the year 2025.

34. 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.

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

The company reports that as of 2024, it has achieved 99.81% traceability to the plantation for Crude Palm Oil (CPO), 99.71% for Crude Palm Kernel Oil (CPKO) and 99.72% for Palm Kernel (PK). Additionally, a few of the company's refineries also have RSPO SCC under IP.

36. Publishes traceability data at refinery level?

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

37. Publishes traceability data at crusher level?

[Externally verified] The company has two crushing facilities, which are 99.46% and 100% traceable to the plantation level. Evidence is externally verified by Control Union.

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

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

39. 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?

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

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

RSPO ACOP 2024 is submitted by the company.

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

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

42. Percentage of mills RSPO-certified?

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

43. 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.

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

2023 - The company has already achieved 100% RSPO certification of all palm product processing facilities in March 2023.

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

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

46. 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.

47. 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.

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

6.93% - The company reports the percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that is RSPO-certified as 6.93%. Data as of 2024.

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

This indicator is disabled as the company only reports a Processor and Trader ACOP.

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

The company processes/trades 1.53% of RSPO-certified palm oil through Identity Preserved and Segregated supply chains. Data as of 2024.

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

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

52. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

[Externally verified] ISCC.

54. Commitment to zero conversion of natural ecosystems?

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

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

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

56. Commitment to zero deforestation?

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

57. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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

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

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

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

60. Cross-commodity zero deforestation commitment?

This indicator has been disabled as the company does not have operations in any other forest-risk commodities besides palm.

61. Cross-commodity zero deforestation commitment applies to all suppliers?

This indicator has been disabled as company does not source or purchase any other forest-risk commodities besides palm oil.

62. Target date to achieve zero deforestation?

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

63. Target date to achieve zero deforestation in supplier operations?

The company reports a commitment to a supply chain which is 100% NDPE-compliant by December 2025.

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

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

65. 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; verification of GLAD/RADD alerts, 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. Evidence is externally verified by the Control Union.

66. 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.

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

67196 - The company reports the cut-off date for supplier operations as 'after December 2015' and reports that the total area of illegal/non-compliant deforestation recorded from January 2016 until December 2024 for all suspended suppliers is 67,196 ha.

68. 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.

69. 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.

70. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company has launched the Sustainable Living Village (SLV) Program since February 2023, in partnership with organisations such as Yayasan Ekosistem Lestari (YEL) and Forum Konservasi Leuser (FKL) for enhancing livelihoods, protecting forests, driving supply chain transformation and supporting landscape collaboration through the Production, Protection and Inclusion (PPI) Compact. In 2024, the company launched SLV in East Kutai, Kalimantan, in collaboration with Earthworm Foundation and the East Kutai District Government, with the targets of protecting 10,000 ha of land and planting 90,000 trees for forest conservation and restoration. Evidence is externally verified by the Control Union.

71. Biodiversity policy?

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

72. 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.

73. 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.

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

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

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

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

76. 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.

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

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

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

The company commits all suppliers to conduct HCV assessments.

79. 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.

80. 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.

81. 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.

82. 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.

83. 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.

84. 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.

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

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

86. 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.

87. High Carbon Stock (HCS) assessments available?

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

88. 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.

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

The company commits to conduct social and environmental impact assessments.

90. 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.

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

[Externally verified] The company reports that it has conducted a Social Impact Assessment (SIA) for its SDS and SDO (D) facilities in 2024, in addition to SIAs conducted for PRC in Padang and KRN in Balikpapan in 2023. Only the executive summaries of SIAs for PT. SARI DUMAI SEJATI and PT. SARI DUMAI OLEO, prepared by SAFORINDO, are publicly available. A complete SEIA, along with a management and monitoring plan, is not published by the company.

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

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

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

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

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

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

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

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

97. 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.

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

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

99. Commitment to zero burning?

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

100. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

101. Evidence of fire monitoring and management?

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

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

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

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

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

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

The company only commits to achieving net-zero emissions by 2050.

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

The company commits to reducing Scope 1 and Scope 2 GHG emissions intensity by 50% by 2030 (from a 2020 baseline) and achieving net-zero emissions by 2050.

106. Absolute GHG emissions?

107. GHG emissions intensity?

0.13 - 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 0.13 in 2024.

108. 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.

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

The company reports an estimated figure for all Scope 3 emissions derived from product-level cradle-to-gate GHG data (GHG Protocol Product Standard) of 51 million tCO2e, it estimates that 1% (510,000 tCO2e) of these supplier emissions are from land use change.

110. Progress towards commitment to reduce absolute GHG emissions?

111. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports the total emissions intensity for 2023 and 2024 as 0.14 and 0.13 tCO2e/MT of oil processed, respectively. The emissions intensity has improved in 2024 as compared to 2023. Additionally, the emissions intensity figures for the years 2023 and 2024 are externally verified by the Control Union.

112. Methodology used to calculate GHG emissions?

The company reports it uses the operational control consolidation approach and the GHG Protocol Corporate Standard for GHG emissions calculation. Additionally, some of the frameworks adopted in its calculations are ISO 14064-1 and GHG Protocol.

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

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

114. 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.

115. Water use intensity?

0.000599 - The company reports the water intensity of its operations as 0.000599 (ML/t) in 2024.

116. Progress towards commitment on water use intensity?

[Externally verified] The company reports that its water consumption increased by 11.5% in 2024 as compared to 2023. The water consumption intensity (ML/t) is reported as 0.000530 in 2023 and 0.000599 in 2024. Evidence is externally verified by the Control Union.

117. 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. Additionally, the BOD and COD levels for all operations of the company are within the specified legal limits in 2024.

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

[Externally verified] The company reports BOD and COD levels for all operations, and as of 2024, these levels are within the specified legal limits. Evidence is externally verified by the Control Union.

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

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

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

[Externally verified] The company reports treating refinery effluents (PORE) at all its refineries in which it uses the activated sludge process, a biological treatment method utilising microorganisms and chemicals like coagulants, flocculants, caustic soda and biocide. Evidence is externally verified by the Control Union.

121. Commitment to protect natural waterways through buffer zones?

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

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

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

123. 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.

124. 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.

125. Commitment to no use of paraquat?

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

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

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

127. 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.

128. 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.

129. 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.

130. 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.

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

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

132. Implementation of commitment to minimise inorganic fertiliser use?

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

133. Integrated Pest Management (IPM) approach?

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

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

[Externally verified] The company reports it has a waste management plan implemented throughout all its operations, where all hazardous waste is stored in dedicated warehouses and both hazardous and non-hazardous wastes are collected and disposed of by licensed contractors. Evidence is externally verified by the Control Union.

135. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

136. Commitment to human rights applies to all suppliers?

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

137. Progress on human rights commitment?

[Externally verified] The company reports that it has implemented a robust action plan, which includes developing a governance structure for human rights implementation and monitoring (currently led by the Head of Sustainability and the Human Rights Manager), as well as conducting a Human Rights Impact Assessment (HRIA) and developing an action plan based on identified issues and risks. The company also provides training to employees on its human rights policies. Evidence is externally verified by the Control Union.

138. Commitment to respect Indigenous Peoples' and local communities' rights?

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

139. Commitment to respect Indigenous Peoples' and local communities' rights applies to all suppliers?

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

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

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

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

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

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

The company commits to respect FPIC.

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

The company commits all suppliers to respect FPIC.

144. 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.

145. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company reports it regularly holds dialogue with community groups and representatives facilitated by its General Affairs (GA) team and has a process designed to offer a transparent and equitable mechanism for resolving disputes and addressing the worries of the community. The details of their concerns are addressed through face-to-face meetings, telephone calls or WhatsApp. Evidence is externally verified by Control Union.

146. Details of process for addressing land conflicts available?

The company has published a land conflicts resolution process.

147. 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.

148. Commitment to mitigate impacts on food security?

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

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

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

150. Commitment to provide essential community services and facilities?

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

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

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

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

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

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

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

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

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

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

[Externally verified] The company reports providing training on workers' rights and states it conducts Sedex Members Ethical Trade Audit (SMETA) audits to ensure that all company facilities adhere to ethical labour practices, safeguard workers' rights and promote fair treatment and working conditions for all employees in the supply chain. The Control Union externally verifies some of this information.

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

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

157. 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.

158. 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. Evidence is externally verified by the Control Union.

159. Percentage or number of temporary employees?

988 (22.45%) - The company reports 988 (22.45%) temporary employees as a part of its total workforce in 2024.

160. Reports gender balance of employees?

801 (18.2%) - The company reports that 801 or 18.20% of women were part of its total workforce in 2024.

161. Commitment to pay a living wage?

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

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

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

163. 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. Additionally, the external verification by Control Union only verifies information that for some operations of the company, workers are paid above living wage.

164. 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.

165. Commitment to address occupational health and safety?

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

166. 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.

167. Provision of personal protective equipment and related training?

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

168. 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 2024.

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

0 - The company reports zero work-related fatalities in 2024.

170. Commitment to support smallholders?

The company has published a commitment to support smallholders.

171. 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. Information reported is externally verified by the Control Union, however, the information is from 2021 and is over two years old now.

172. Percentage of scheme smallholders involved in programme?

[Externally verified] 15.48% - The company reports that 15.48% out of 6 plasma smallholders' groups (KUDs) are involved in the rurality project. This information is externally verified by the Control Union. However, the information reported is from 2021 and is over two years old now.

173. Programme to support independent smallholders?

[Externally verified] The company reports running an initiative, 'Smallholder Inclusion for Better Livelihood & Empowerment Programme' or SMILE, to help independent smallholders by educating them on increasing yields using sustainable management practices such as reducing herbicide use and the significance of adhering to no deforestation, no burning and no exploitation policies. The SMILE programme has a team of experts in agronomy and plantation management to train 5,000 ISH overseeing approximately 18,000 ha of plantations across North Sumatra, Riau and Jambi. Evidence is externally verified by the Control Union.

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

[Externally verified] 3489 (70%) - The company reports that it has engaged 3,489 (70%) smallholders through its SMILE programme in 2024. Evidence is externally verified by Control Union.

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

The company reports it fosters supplier engagement through its supplier Anchor programmes to work with suppliers and ensure they meet commitments and standards set out in its Sustainability Policy. This is comprised of the Priority Supplier Engagement Programme (PSEP), the Shared Value Programme (SVP), and the Traceability Outreach Programme (TOP). The company has also developed the Suppliers Self-Assessment (SFA) tool to help suppliers identify any gaps with its NDPE policy.

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

[Externally verified] 459 - The company reports that 459 mills have been assessed for compliance in 2024. Information is externally verified by Control Union.

177. Suspension or exclusion criteria for suppliers?

The company states it "does not knowingly source from non-compliant 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.".

178. 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". The company used the NDPE IRF framework to assess compliance, the supplier profiles are externally verified by Control Union.

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

[Externally verified] 98.01% - The company reports "sighted the No Deforestation for CPO and PKO Supplier Profile for the year 2024, which is based on the NDPE IRF chart, stated that 98.01% and 97.68% respectively of the suppliers are in delivering status for no deforestation". Evidence is externally verified by the Control Union.

180. 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 recommend improvement opportunities and build strong relationships. As part of these visits, detailed guidance to help suppliers develop robust Standard Operating Procedures (SOPs) and sustainability frameworks is offered. The company also states that PSEP is an ongoing process, and while it aims to visit all the identified potential high-risk mills, its target is a minimum of 10 mills annually. In 2024, the company identified 51 mills that were found to have significant actual and potential social and environmental risks, of which 33.33% were selected for priority engagement under PSEP.

181. 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 recommend improvement opportunities and build strong relationships. As part of these visits, detailed guidance to help suppliers develop robust Standard Operating Procedures (SOPs) and sustainability frameworks is offered. The company also states that PSEP is an ongoing process, and while it aims to visit all the identified potential high-risk mills, its target is a minimum of 10 mills annually. Evidence is not externally verified by the Control Union.

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

[Externally verified] The company reports engaging with high-risk mills regularly through its 'Anchor Program', with a minimum target of a minimum of 10 mills annually. The company reports that it engaged six high-risk mills through its Priority Supplier Engagement Programme (PSEP) in 2024. Evidence is externally verified by the Control Union.

183. 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.

184. 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. Evidence is externally verified by the Control Union.

185. 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%) in 2023. This information is externally verified by Control Union.

186. Commitment to ethical conduct and prohibition of corruption?

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

187. 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.

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

[Externally verified] The company reports it has an Anti-Bribery and Anti-Corruption (ABC) Policy in place, and all employees receive ABC Policy training and are also encouraged to raise concerns about suspected misconduct or malpractices. In 2024, 100% of the company's employees received training on its ABC policy and no incidents of corruption were reported in the respective year. Evidence is externally verified by the Control Union.

189. 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. However, no tax policy is available.

190. Whistleblowing procedure?

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

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

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

192. Details of complaints and grievances disclosed?

The details of complaints and grievances are disclosed by the company. Details are updated till May 2025.