Archer Daniels Midland Company (ADM)

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?

The company reports to have a Vice president, Chief Sustainability Officer (CSO) with sustainability responsibility.

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

The company's Sustainability and Corporate Responsibility Committee includes four board members (including its chair).

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

26% - The company reports 26% women in its senior leadership positions. Figure as of 2021.

6. Percentage or number of women board members?

3 (25%) - The company reports that out of its twelve board members, three are women. Data as of December 2021.

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

[Externally verified] Member of UNGC and WBCSD.

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

The company works with Solaridad in Colombia to build more inclusive value chains for smallholders, has created a Child Risk Assessment Framework with Earthworm Foundation in Malaysia, and collaborates with Conservation International Singapore to increase smallholder productivity while preserving forests.

9. Sustainability report published within last two years?

The company has published a 2021 Corporate Sustainability Report.

10. Reports through standardised reporting systems?

The Corporate Sustainability Report 2021 is reported to be prepared in accordance with GRI standards, but the company does not specify which standard is used. The company has submitted CDP questionnaires in 2021.

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?

13. Lists countries and operations?

The company has processing facilities (refineries) in the following continents- North America, South America, Africa, Asia and Europe.

14. Lists countries sourcing from?

Indonesia, Malaysia, PNG & Solomon Islands, Latin America, Europe and USA.

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 scheme smallholders?

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

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

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?

The company reports a list of supplying mills for crude palm oil (CPO) and palm kernel oil (PKO). CPO and PKO are sourced indirectly through refineries.

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

The list of supplying mills published by the company contains the coordinates and names of all mills.

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

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

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 100% of its supply was sourced from refineries rather than directly from mills from Jan-June 2021.

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

The company commits to improving traceability but does not explicitly reference a 100% traceability to mill-level goal. It should be noted that the company's current traceability to the mill is 99.90%.

33. Percentage of supply traceable to mill level?

The company reports traceability to mill as 99.9% for Palm Oil and 98.6% for Palm Kernel Oil in its traceability report for Q3 to Q4 2021.

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

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 traceability to the plantation as 54.5% for Q3 and Q2 2024.

37. Publishes traceability data at refinery level?

The company provides details on plantation traceability per refinery. However, this information is not externally verified.

38. Publishes traceability data at crusher level?

This indicator is disabled as the company does not own palm kernel crushing facilities.

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

[Externally verified] 2007 - The company has been a member of the Roundtable on Sustainable Palm Oil (RSPO) since March 2007.

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] 2010 - The company reports the year of first supply chain certification as 2010.

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

The company has submitted its RSPO ACOP 2021.

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?

2014 - The company has already achieved 100% RSPO certification of all palm product processing facilities in 2014.

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?

[Externally verified] 11.86% - The company reports the percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that is RSPO-certified.

50. 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.

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

[Externally verified] The company processes/trades in segregated supply chains. 2.93% of its volume was processed through 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 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 reports that it is working towards a completely deforestation-free supply chain by 2025. A clear commitment to no/zero deforestation is not reported by the company.

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

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

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

The company uses High Carbon Stock (HCS) and High Conservation Value (HCV) definitions for areas where development is prohibited but a clear cut-off date beyond which deforestation (using the beforementioned definition) would be prohibited is not reported by the company.

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

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

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

The company only reports that 97.5% of suppliers are "part of a system that conducts deforestation monitoring". The details on methodology used for monitoring deforestation is not found. Information has not been externally verified.

62. 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.

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

Examples of deforestation can be found in the company's grievance log, however affected areas are not detailed.

64. Commitment to restoration of deforestation/conversion?

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

65. Commitment to restoration of deforestation/conversion applies to all suppliers?

66. Implementing a landscape or jurisdictional level approach?

The company reports that it implements several landscape initiatives, in the Sabah Landscape, Leuser Ecosystem (Malaysia), and Aceh Province (Indonesia). The company mentions conducting field investigations to improve resilience and reports working with local communities. However, the information reported is not externally verified.

67. Biodiversity policy?

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

68. Biodiversity policy applies to all suppliers?

69. 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.

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

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

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

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

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

The company commits suppliers to no hunting of rare, threatened or endangered species. However, a clear commitment stating no hunting of all species or only sustainable hunting by local communities for subsistence purposes is not reported by the company.

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

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

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

The company commits all suppliers to conduct HCV assessments.

75. 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.

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

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

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

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

78. 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.

79. 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?

80. 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.

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

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

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

The company commits suppliers to not develop on High Carbon Stock land but does not specify the High Carbon Stock Approach, as defined by the HCS Approach Toolkit.

83. High Carbon Stock (HCS) assessments available?

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

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

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

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

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

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

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

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

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

89. 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.

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

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

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

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

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

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

93. 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.

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

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

95. Commitment to zero burning?

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

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

97. Evidence of fire monitoring and management?

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

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

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

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

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

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

The company commits to reducing GHG emissions intensity by 25% by the year 2035 over 2019 baseline.

101. GHG emissions intensity?

The company reports its GHG emission intensity figure as 0.266 MT CO2e/MT processed. However, this figure is between two and five years old now and does not just relate to palm oil operations.

102. GHG emissions from land use change?

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

103. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports progress (6.0% reduction in 2021) for absolute emissions but it is not measured in intensity and figures are aggregated across all company operations, rather than specific to palm oil. Data has been verified by Apex Companies, LLC (Apex) via a verification statement.

104. Methodology used to calculate GHG emissions?

The company uses the 'Climate Registry General Reporting Protocol' methodology to calculate GHG emissions.

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

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

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

The company reports reducing water use by 10% by the year 2035 from a 2019 baseline. This figure is aggregated across all company operations.

107. Water use intensity?

2.48 - The company reported water intensity across all operations in 2021 as 2.48 m3/ton of product produced, compared to 2.32 m3/ton in 2020. A separate figure for palm oil operations only could not be found.

108. Progress towards commitment on water use intensity?

The company reported water intensity across all operations in 2021 as 2.48 m3/ton of product produced compared to 2.32 in 2020, an increase of 6.5%. A separate figure for palm oil operations only could not be found and also the data is not externally verified.

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

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

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

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

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

113. Commitment to protect natural waterways through buffer zones?

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

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

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

115. 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.

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

117. Commitment to no use of paraquat?

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

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

119. 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.

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

The company commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

121. 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.

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

The company commits suppliers to not use Stockholm and Rotterdam Convention chemicals.

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

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

124. Implementation of commitment to minimise inorganic fertiliser use?

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

125. Integrated Pest Management (IPM) approach?

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

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

The company publishes multiple examples of waste management such as reusing wastewater and reducing waste sent to landfills. Information is not externally verified.

127. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

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

129. Progress on human rights commitment?

The company provides examples of assessing and mitigating human rights exposures across its palm oil supply chain. Information has not been externally verified.

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

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

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

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

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

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

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

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

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

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

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

The company commits all suppliers to respect FPIC.

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

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

137. Examples of local stakeholder engagement to prevent conflicts?

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

138. Details of process for addressing land conflicts available?

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

139. 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.

140. Commitment to mitigate impacts on food security?

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

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

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

142. Commitment to provide essential community services and facilities?

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

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

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

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

This indicator is disabled as the company is not a grower or miller.

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

The company commits to the following ILO conventions: Freedom of Association (#87), Collective Bargaining (#98) Forced Labor (#29 and #105), Minimum Age (138) and Harassment and Discrimination (111). However, these don't cover all eight Fundamental Conventions.

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

The company commits its suppliers to the following ILO conventions: Freedom of Association (#87), Collective Bargaining (#98) Forced Labor (#29 and #105), Minimum Age (138) and Harassment and Discrimination (111). However, these don't cover all eight Fundamental Conventions.

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

[Externally verified] One example can be found where the company has worked with the Earthworm Foundation (EF) to create a Child Risk Assessment Framework (CRAF) for use by Malaysian palm oil producers. No other examples relating specifically to workers' rights could be found. Information is externally verified by the company being referenced in the CRAF report created by EF.

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

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

149. 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.

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

The company reports that it has a process in place to report discrimination, however, no other examples could be found. Evidence is over two years old and is not externally verified.

151. Percentage or number of temporary employees?

1521 (3.73%) - The company provides figures for part-time/seasonal employees in 2021. A separate figure for palm oil operations was not available. Total employees: 40,739.

152. Percentage or number of women employees?

9751 (24%) - The company provides figures for female employees in 2021. A separate figure for palm oil operations was not available. Total employees: 40,739.

153. Commitment to pay a Decent Living wage?

The company only states that all employees in its operations and supply chain will be compensated in accordance with all applicable local laws and regulations including those related to minimum wage and overtime pay.

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

The company only states that all employees in its operations and supply chain will be compensated in accordance with all applicable local laws and regulations including those related to minimum wage and overtime pay.

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

156. Reporting of salary by gender?

157. Commitment to address occupational health and safety?

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

158. 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.

159. Provision of personal protective equipment and related training?

The company spent more than 315,500 hours in training on occupational health and safety-related topics in 2020, but evidence that PPE is given to all employees could not be found.

160. Time lost due to work-based injuries?

0.21 - The company's Lost Workday Incident Rate increased from 0.17 in 2020 to 0.21 in 2021.

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

0 - The company reports no fatalities in 2021.

162. Commitment to support smallholders?

The company reports facilitating the inclusion of smallholders into the supply chain, however, it is unclear if it covers smallholders across all palm oil operations.

163. Programme to support scheme smallholders?

[Externally verified] The company assists smallholders in Colombia to identify and mitigate human rights and workers' rights issues (this, in turn, assists the smallholder to achieve RSPO certification), assists smallholders in Malaysia with income diversification and identifying child labour risks, and assists smallholders in Indonesia to improving yield and conserve forests, and in Latin America smallholders are trained in sustainable agricultural practices. The example of identifying child labour risks in Malaysia has been externally verified by the Earthworm Foundation which wrote a report referencing the company. It is unclear if smallholders in programmes are independent or scheme smallholders.

164. Percentage of scheme smallholders involved in programme?

8145 - The company details that 8145 smallholders have been impacted by its programmes, but it is not clear what percentage of smallholder supply to the company is covered by these programmes or if smallholders are scheme or independent. Evidence is not externally verified.

165. Programme to support independent smallholders?

[Externally verified] The company assists smallholders in Colombia to identify and mitigate human rights and workers' rights issues (this, in turn, assists the smallholder to achieve RSPO certification), assists smallholders in Malaysia with income diversification and identifying child labour risks, and assists smallholders in Indonesia to improving yield and conserve forests, and in Latin America smallholders are trained in sustainable agricultural practices. The example of identifying child labour risks in Malaysia has been externally verified by the Earthworm Foundation which wrote a report referencing the company. It is unclear if smallholders in programmes are independent or scheme smallholders.

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

8145 - The company details that 8145 smallholders have been impacted by its programmes, but it is not clear what percentage of smallholder supply to the company is covered by these programmes or if smallholders are scheme or independent. Evidence is not externally verified.

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

The company uses a third-party assessor to assess performance on a scorecard tool but limited detail is given on the process used to assess suppliers on compliance with company policies.

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

The company reports results from its scorecard but does not stipulate the number or percentage of suppliers engaged in the process. The company also reports that 100% of direct suppliers have a publicly available 'No Deforestation' policy in place. It is unclear if this is due to company engagement and if these policies align with the company's own policy. Information is not externally verified.

169. Suspension or exclusion criteria for suppliers?

The company requires compliance with its Human Right's policy and Policy to Protect Forests, Biodiversity and Communities, as well as it's Code of Conduct and Suppler Expectations documents. Non-compliances are assessed on scale, scope and irremediability before action is taken. The company reports the timeframes for grievances.

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

The company has published an action plan for 2020-2023 which outlines how it will achieve its commitments and implement its policies through various goals, actions, and structured reporting and tracking of KPIs.

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

The company reports that 97.46% of direct suppliers follow an implementation plan for the responsible sourcing of palm oil. However, figures for indirect supply are not provided. In addition, this information is not externally verified.

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

The company commits to engage with suppliers in high risk areas but does not specify a time-bound plan.

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

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

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

The company has published an action plan to assess mills for risk level. The company has also published data for Q1 & Q2 2021 using the Global Forest Watch Pro Palm Risk Analysis Tool.

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

Mills are assessed for risk on a semi-annual basis. Data has not been externally verified.

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

Data is reported on a semi-annual basis, however, it is not externally verified.

178. Commitment to ethical conduct and prohibition of corruption?

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

179. 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.

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

The company reports that its 'Law Department and Compliance Office' are responsible for taking prompt and appropriate action to investigate reports of possible ethical or legal misconduct. Complaints can be raised through various channels as mentioned in the company's code of conduct. The company also reports that it trains employees and third parties to raise awareness of corruption risks and applicable anti-corruption laws in order to both avoid inadvertent violations of the law and enable early recognition and handling of potential issues. However, the information reported is not externally verified.

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

The company has published its 'Tax Policy'.

182. Whistleblowing procedure?

The company has a helpline which allows whistleblowing and secures anonymity.

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

The company has a grievance system that is open to all stakeholders.

184. Details of complaints and grievances disclosed?

The company has disclosed the details of complaints and grievances. However, it does not publish the date on which the grievances were raised.