Apical Group

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

This indicator is disabled as it is not applicable to this company.

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

The company has a sustainability policy which covers multiple dimensions of sustainability across all operations covering both social and environmental issues.

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 President and Director has responsibility for sustainability within the board.

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

0.15% - The company reports the percentage of female who are part of its senior management team as 0.15.

6. Percentage or number of women board members?

0.04% - The company reports the percentage of female who are part of its board as 0.04.

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 2020 and NYDF.

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

The company initiated 'SUSTAIN (Sustainability Assurance & Innovation Alliance)', together with a group of companies comprising oil palm growers, palm oil processors, consumer goods manufacturers, not-for-profit organisations and technology leaders. It aims to build collaborations, align efforts and help create an industry-wide solution for palm oil traceability and sustainability. The company also reports information on several other collaborations.

9. Sustainability report published within last two years?

The sustainability report for 2020 is published by the company.

10. Reports through standardised reporting systems?

The company has prepared its sustainability report for 2019 and 2020 in accordance with the GRI standards: Core option. The company has also submitted its forests CDP questionnaire for 2020 and 2021.

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

This indicator is disabled as it is not applicable to this company.

12. Climate risks assessment available?

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

This indicator is disabled as it is not applicable to this company.

14. Total oil palm planted area (ha)?

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

18. Maps of estates/management units?

This indicator is disabled as it is not applicable to this company.

19. Maps of scheme/plasma smallholders?

This indicator is disabled as it is not applicable to this company.

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

21. Number of company-owned mills?

This indicator is disabled as it is not applicable to this company.

22. Names and locations of company-owned mills?

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

25. Number of third party supplying mills?

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

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

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

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

The company reports that 59% of its supplier mills source FFB from their own estates, and 41% source FFB from 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?

The company reports that 29.4% MT is sourced from third party supplier mills' own plantations while 70.6% MT is sourced from third party plantations.

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

The company reports that about 99.6% of its palm oil products are sourced directly from supplying mills and only 0.4% of our palm oil products are sourced from a trading company.

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

The company reports to have achieved 100% traceability to mill level in 2015.

31. 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 company's refinery 'PT. SARI DUMAI SEJATI' has RSPO SCC under IP and SG.

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

The company reports a commitment to achieve 100% traceability to plantation level by 2022.

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

This indicator is disabled as it is not applicable to this company.

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

The company reports that it has been able to trace 99.28% of its FFB sources to plantations as of December 2020. Control Union has a verification statement referring to this question but does not include this figure. Therefore additional points cannot be awarded.

35. Publishes traceability data at refinery level?

[Externally verified] The company reports traceability to plantation for CPO as 99.28% and for CPKO as 92.49%. However, this data only covers the company's Indonesian operations and is externally verified by the Control Union.

36. Publishes traceability data at crusher level?

[Externally verified] The company has only one crushing facility which is 100% traceable to plantation level. This information is externally verified by the Control Union.

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

[Externally verified] 2,011 - The company's subsidiary, AAA Oils & Fats Pte. Ltd. became a member of the RSPO in 2011.

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] 2,012 - The company's subsidiary, AAA Oils & Fats Pte. Ltd., obtained its first certification in 2012.

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

2020 RSPO ACOP is submitted by the company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

42. Percentage of mills RSPO-certified?

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

2,020 - The company's subsidiary, AAA Oils & Fats Pte. Ltd., has a target of 2020. However, few of the company's refineries and biodiesel facilities are yet to be RSPO certified.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

3.11% - The company reports the percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that is RSPO-certified as 3.11.

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

This indicator is disabled as it is not applicable to this company.

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

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

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

This indicator is disabled as it is not applicable to this company.

52. Malaysia Sustainable Palm Oil (MSPO) certified?

This indicator is disabled as it is not applicable to this company.

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 it is not applicable to this company.

55. Commitment to zero deforestation?

This indicator is disabled as it is not applicable to this company.

56. Commitment to zero deforestation applies to all suppliers?

The company commits its suppliers to no deforestation.

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

HCV, HCS, and peatland. The company states it is effective immediately (September 2014) for its own operations.

58. Evidence of monitoring deforestation?

This indicator is disabled as it is not applicable to this company.

59. Evidence of monitoring deforestation in supplier operations?

[Externally verified] The company reports using Global Forest Watch (GFW) Pro which supports the company in making smarter decisions and ensuring greater transparency among its suppliers. The company also monitors any evidence of deforestation by suppliers through its Mill Prioritization Programme (MPP) based on both, the spatial and non-spatial data of suppliers. The information reported is externally verified by the Control Union.

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

This indicator is disabled as it is not applicable to this company.

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

60,000 - The company reports that "The total area of illegal/non-compliant deforestation recorded after December 2015 until December 2020 for all our suspended suppliers is about 60,000 hectares." It is unclear when the cut-off date in the operations of the company's direct or indirect suppliers was, and therefore partial points have been awarded.

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

This indicator is disabled as it is not applicable to this company.

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

The company commits its suppliers to restoration of non-compliant deforestation.

64. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company reports various collaborations with stakeholders including WWF, to halt deforestation and identify illegal suppliers in the Riau province, Yayasan Setara Jambi to increase traceability and strengthen smallholders engagement in Jambi and Riau provinces, hosting of Founder of 2030 Secretariat in Riau to provide deeper understanding on its sustainability initiatives and smallholder programmes. 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.

65. Biodiversity policy?

This indicator is disabled as it is not applicable to this company.

66. Biodiversity policy applies to all suppliers?

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

The company commits its suppliers to controlling any illegal or inappropriate hunting of all species across all their operation areas, including no hunting of endangered, rare or threatened species, other than hunting by local communities for subsistence purpose that does not cause a decline of local species populations.

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

This indicator is disabled as it is not applicable to this company.

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

The company commits its suppliers to conduct High Conservation Value (HCV) assessments.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

76. 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 it is not applicable to this company.

77. 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 reports to ensure "suppliers conduct independent HCV assessment, in which the independent HCV assessments will be peer reviewed by the ALS licensed assessors who are technical members of the HCV Resource Network".

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

The company commits its suppliers to the High Carbon Stock (HCS) Approach.

81. High Carbon Stock (HCS) assessments available?

This indicator is disabled as it is not applicable to this company.

82. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

This indicator is disabled as it is not applicable to this company.

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

The company reports its commitment to conduct social and environmental impact assessments (SEIAs).

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

The company commits its suppliers to conduct social and environmental impact assessments (SEIAs).

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

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

This indicator is disabled as it is not applicable to this company.

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

The company commits its suppliers to no planting on peat, regardless of depth.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

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

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

This indicator is disabled as it is not applicable to this company.

93. Commitment to zero burning?

This indicator is disabled as it is not applicable to this company.

94. Commitment to zero burning applies to all suppliers?

The company commits its suppliers to zero burning.

95. Evidence of fire monitoring and management?

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

The company reports a commitment to reduce GHG emissions by 29% "from the business-as-usual scenario by 2030 or 41% with international assistance", in line with "Indonesia's Climate Action Plan under the Paris Agreement". A baseline date is not provided and the commitment is not intensity based and therefore partial points have been awarded.

99. GHG emissions intensity?

The company reports GHG Scope 1 and 2 emissions intensity as 61 and 5 kgCO2e/MT of oil processed respectively, however these figures do not cover all operations of the company.

100. GHG emissions from land use change?

This indicator is disabled as it is not applicable to this company.

101. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports the total emissions intensity for 2019 and 2020 as 73 and 66 kgCO2e/MT of oil processed, respectively. Overall, its emissions intensity improved by 9.6% compared to 2019. This information is externally verified by the Control Union, however, it does not cover all operations of the company.

102. Methodology used to calculate GHG emissions?

The company reports using the 'ISCC GHG Emissions 205' methodology to calculate its GHG emissions.

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

This indicator is disabled as it is not applicable to this company.

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

The company reports a target to reduce water use intensity to 0.3 m3/MT of oil produced by 2025.

105. Water use intensity?

The company reports water use intensity (m3 of water consumed per tonne of oil processed) for each of its refineries.

106. Progress towards commitment on water use intensity?

[Externally verified] The company reports figures on water use intensity for all its refineries and crushing plants. The figures for 2020 show improvement as compared to 2019 intensity figures. Also, the information is externally verified by the Control Union.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

[Externally verified] The company reports information on treatment of effluent discharge and discharge of waste water. The information is externally verified by the Control Union. The company also reports that it practices ""zero wastewater discharge to ensure proper management of palm oil refinery effluent (PORE)"".

111. Commitment to protect natural waterways through buffer zones?

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

The company commits its suppliers to minimise the use of chemicals, including pesticides and chemical fertilisers.

115. Commitment to no use of paraquat?

This indicator is disabled as it is not applicable to this company.

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

The company commits its suppliers to no use of paraquat, unless in exceptional circumstances, as validated by a due diligence process, or when authorised by government authorities for pest outbreaks.

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

This indicator is disabled as it is not applicable to this company.

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

The company commits its suppliers to no use of World Health Organisation (WHO) Class 1A and 1B pesticides, unless in exceptional circumstances, as validated by a due diligence process, or when authorised by government authorities for pest outbreaks.

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

This indicator is disabled as it is not applicable to this company.

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

The company commits its suppliers to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention, unless in exceptional circumstances, as validated by a due diligence process, or when authorised by government authorities for pest outbreaks.

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

This indicator is disabled as it is not applicable to this company.

122. Implementation of commitment to minimise inorganic fertiliser use?

This indicator is disabled as it is not applicable to this company.

123. Integrated Pest Management (IPM) approach?

This indicator is disabled as it is not applicable to this company.

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

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

125. Commitment to human rights?

The company reports its commitment to the UN Declaration on Human Rights.

126. Commitment to human rights applies to all suppliers?

The company commits its suppliers to the UN Declaration on Human Rights.

127. Progress on human rights commitment?

[Externally verified] The company reports its progress on 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.

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

The company reports its commitment to respect indigenous and local communities' rights.

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

The company commits its suppliers to respect indigenous and local communities' rights.

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

The company reports its commitment to respect the legal and customary (or traditional) rights of local community in land tenure and ownership.

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

The company commits its suppliers to respect the legal and customary (or traditional) rights of local community in land tenure and ownership.

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

The company reports its commitment to free, prior and informed consent (FPIC).

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

The company commits its suppliers to free, prior and informed consent (FPIC).

134. 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.

135. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company reports having a dedicated Social, Security and Licensing (SSL) department which has dialogues with community groups and representatives on regular basis. The SSL department is established at each of the company refineries to handle social and licensing matters according to national regulations and its Sustainability Policy. This information is externally verified by the Control Union.

136. Details of process for addressing land conflicts available?

The company reports to resolve social conflicts with all relevant parties in a fair and transparent manner through its grievance procedure. However, no further details of the process are reported by the company.

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

This indicator is disabled as it is not applicable to this company.

138. Commitment to mitigate impacts on food security?

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

140. Commitment to provide essential community services and facilities?

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

This indicator is disabled as it is not applicable to this company.

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

The company commits to all Fundamental or Core ILO Conventions, referring to ILO numbers.

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

The company commits its suppliers to all Fundamental or Core ILO Conventions, referring to ILO numbers.

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

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

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

The company reports its commitment to prevent employment and occupation-related discrimination based on gender.

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

The company commits its suppliers to prevent employment and occupation-related discrimination based on gender.

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

[Externally verified] The company reports having a sexual harassment procedure in place which includes reporting, investigation and disciplinary actions in case of any issue related to discrimination. The whistleblowing channel of the company can be used to report any complaints related to discrimination/harassment and as of 2020 no cases of discrimination on basis of gender were reported in the company operations. This information is externally verified by the Control Union.

149. Percentage or number of temporary employees?

753 (28.07%) - Temporary employees.

150. Percentage or number of women employees?

489 (18.23%) - The company reports the number of women employees across all its operations.

151. Commitment to pay a Decent Living wage?

The company reports that in accordance with RSPO P&C 6.2, pay and conditions for staff and workers (including contract workers) of company's operations always meet at least legal or industry minimum standards and are sufficient to provide decent living wages (DLW).

152. Commitment to pay a Decent Living wage applies to all suppliers?

The company commits to ""meet at least legal or industry minimum standards and are sufficient to provide decent living wages (DLW). This also applies to our operations and suppliers."".

153. Progress on commitment to pay a Decent Living wage?

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

154. Reporting of salary by gender?

The company reports the ratio of the basic salary and remuneration of women to men for each employee category. However, only Indonesian operations of the company are covered in the reporting.

155. Commitment to address occupational health and safety?

The company reports its commitment to provide a safe and healthy working environment.

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

The company commits its suppliers to provide a safe and healthy working environment.

157. 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.

158. Time lost due to work-based injuries?

The company reports high consequence work-related injury rate and recordable work-related injury rate for both employees and contractors. Data as of 2020.

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

0 - The company reports zero work-related fatalities in the past five years.

160. Commitment to support smallholders?

The company reports that it is committed to helping smallholders adopt sustainable practices and facilitating their inclusion in its supply chain.

161. Programme to support scheme/plasma smallholders?

[Externally verified] The company reports to have 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.

162. Percentage of scheme/plasma 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.

163. Programme to support independent smallholders?

[Externally verified] The company reports to run a 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.

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

The company reports that there are three phases of the SMILE program, out of which the phase 1 has a timeline from 2020-2025 and a total of 781 independent smallholders have been engaged so far as of October 2021. Control Union has externally verified that it expected 781 independent smallholders to be involved but has not confirmed that his number have been engaged.

165. 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.

166. 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 45 suppliers are involved in the 'Priority Supplier Engagement Programme (PSEP)', 346 suppliers engaged in its 'Shared Value Programme (SVP)', 412 suppliers engaged in its 'Traceability Outreach Programme (TOP)', 366 suppliers in its 'Suppliers Self-Assessment (SFA)' and 14 suppliers in its CARE program. As of 2020 100% of the CPO mills are engaged through at least one of the programs under the 'Anchor Program' of the company. All the information reported is externally verified by Control Union.

167. 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.".

168. 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: "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.".

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

[Externally verified] The company states ""100% of our direct and indirect supply within our supply chain comes from mills and plantations that are compliant with Apical's palm oil sourcing policy"". This information is externally verified by Control Union.

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

The company has a ' Mill Prioritisation Process (MPP)' for a risk-based assessment of its suppliers to identify priority mills for deeper engagement. In the event of a supplier being identified as high risk via the MPP, the company will enter the supplier into the Priority Supplier Engagement Programme. As of March 2021, the company has conducted PSEP visits to 45 mills.

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

[Externally verified] The company reports to have a 'Priority Supplier Engagement Programme (PSEP)' which supports the high risk mills to become compliant with the company's sourcing policies. This information is externally verified by the Control Union.

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

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

173. 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.

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

[Externally verified] The company using its 'Mill Prioritisation Process (MPP)' for a risk-based assessment of its suppliers to identify priority mills for deeper engagement, which is done on a monthly basis. All the information reported is externally verified by the Control Union.

175. 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 60 high risk mills, 223 medium risk mills and 195 low risk mills as of December 2020. This information is externally verified by the Control Union.

176. Commitment to ethical conduct and prohibition of corruption?

The company reports its commitment to ethical conduct and prohibition of corruption.

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

The company reports that it ""ensures the commitment to ethical conduct and prohibition of corruption is abided by their suppliers through the Code of Procurement Ethics (COPE)."".

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

[Externally verified] The company reports its progress on commitment to ethical conduct and prohibition of corruption. As of 2020, no incidences of corruption were reported by the company. This information is externally verified by the Control Union.

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

180. Whistleblowing procedure?

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

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

The company reports to have a 'Grievance Procedure' open to all its stakeholders.

182. Details of complaints and grievances disclosed?

The details of complaints and grievances are disclosed by the company. Details updated till June 2021.