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 has a Chief Sustainability Officer (CSO) who have high-level responsibility for sustainability.

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

The company's sustainability and technology committee consists of four board members including its chairman.

5. Reports gender balance of senior management team?

31% - The company's senior leadership team has 31% of women members.

6. Reports gender balance of board members?

4 (36.36%) - The company's board of directors includes four women members. Data as of December 2023.

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

[Externally verified] The company is a member of UNGC and WBCSD.

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

The company reports that it collaborated with the Earthworm Foundation on the 'Sabah Landscape co-funded Project' to sustainably transform palm supply chains. This collaboration focuses on sustainability practices, wildlife conflict, deforestation outside concessions, riparian zone management, and labor issues. Additionally, the company partnered with Solidaridad on the 'Palm Lab co-funded Project' to create a more inclusive palm oil value chain among small producers, processors, and the international market.

9. Sustainability report published within last two years?

The company published its latest Corporate Sustainability Report in 2023.

10. Reports through standardised reporting systems?

The company's latest Corporate Sustainability Report for 2023 was prepared in accordance with GRI 1: Foundation 2021. Additionally, it submitted CDP questionnaires in 2023.

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

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

12. Climate risks assessment available?

The company conducted scenario analysis based on three potential warming scenarios (1.5°C, 2°C, and 2.6°C) in line with TCFD guidelines. It has summarised key risks into physical and transitional categories and also reports a summary of opportunities. It does not report a comprehensive climate risk assessment.

13. Lists countries and operations?

The company reports palm oil refineries in the USA, UK, France, Germany and Poland.

14. Lists countries sourcing from?

The company reports that it sources from Indonesia, Malaysia, PNG & Solomon Islands, Latin America, Europe and USA. Not all country names are disclosed within continents.

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

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

16. Total oil palm planted area (ha)?

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

17. Scheme smallholders planted area (ha)?

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

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

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

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

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

20. Maps of estates/management units?

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

21. Maps of all scheme smallholders?

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

22. Maps of all third-party supplying plantations?

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?

1635 - The company reports 1635 third party supplying mills.

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

The company has published the lists of supplying mills for each location, including the names and coordinates 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 has published lists of supplying mills for each location, indicating that it sources 100% of its supply from refineries rather than directly from mills.

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

The company reports that it has achieved 99.9% traceability to palm oil mills against its target of 98%. However, it does not commit to achieving 100% traceability to the mill level.

33. Percentage of supply traceable to mill level?

The company reports that it has achieved 100% traceability to mills for PO and 99.97% for PKO. The company's refineries are certified under the RSPO Segregated (SG) certification.

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

The company states that it is working with its direct suppliers to increase traceability to the plantation of origin. However, it does not report a time-bound commitment to achieve 100% traceability to the 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 that it has achieved 96.1% traceability to plantation level of palm oil and 93.9% for palm kernel oil. As the company does not own mills, this covers third-party mills only. This has been externally verified by Control Union.

37. Publishes traceability data at refinery level?

[Externally verified] The company provides details on supply traceable to plantation level per refinery for all refineries. This has been externally verified by Control Union.

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 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 latest RSPO ACOP 2023.

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.

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?

10.45% - 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 is only a processor or trader.

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

The RSPO ACOP 2023 states that the company processes/trades 6.03% of RSPO-certified palm oil through segregated or identity-preserved 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] The company is certified under ISCC.

55. Commitment to zero conversion of natural ecosystems?

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

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

57. Commitment to zero deforestation?

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

58. Commitment to zero deforestation applies to all suppliers?

The company a future commitment to eliminate deforestation from all of our supply chains by 2025.

59. 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.

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

The company does not specify the criteria or types of forest/areas that are not to be deforested/converted by suppliers. It sets a future cut-off date for 2025 for no deforestation. Additionally the company aims to have all direct supply chains free of conversion of primary native vegetation in defined high-risk areas by December 31, 2025, and indirect supply chains free of conversion of primary native vegetation in defined high-risk areas by no later than December 31, 2027.

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

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

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

The company reports that it uses satellite monitoring in supplier concessions to detect deforestation and peat conversion. In 2023, all mills supplying raw materials to the company and 9,500 ha of supplier concessions in Sabah were monitored. Additionally, satellite monitoring is implemented within a 50 km radius of supplier boundaries to identify instances of deforestation and assess opportunities for reforestation.

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

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

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

The company reports examples of deforestation in its grievance log. However, the amount of deforestation recorded in supplier operations since the cut-off date is not reported.

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

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

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

The company reports that it focuses on restoring ecosystems that have been previously altered. However, it does not report a commitment to the restoration of deforestation in supplier operations since the cut-off date.

67. Implementing a landscape or jurisdictional level approach?

The company reports several landscape initiatives including the 'Sabah Landscape Project' which aims to sustainably transform palm supply chains, and the 'North Sumatra Landscape co-funded Project' which aims at developing alternative livelihoods through diversified agriculture and improving water, sanitation and hygiene standards for communities.

68. Biodiversity policy?

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

69. Biodiversity policy applies to all suppliers?

The company has a general statement for protecting biodiversity. However, it does not clearly apply both within and beyond HCV/HCS/set-asides.

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

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

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

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

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

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

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

The company only commits to no hunting of rare, threatened, or endangered species that applies to its suppliers.

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

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

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

The company's commitment to avoid development in High Conservation Value (HCV) areas extends to all suppliers. However, a clear commitment to conduct HCV assessments for all suppliers could not be found.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The company commits not to develop in High Carbon Stock areas, which applies to all suppliers. However, it does not specify the HCS Approach, as defined by the HCS Approach Toolkit.

84. High Carbon Stock (HCS) assessments available?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

96. Commitment to zero burning?

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

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

98. Evidence of fire monitoring and management?

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

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

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

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

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

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

The company commits to reducing absolute GHG emissions by 25% by the year 2035 from a 2019 baseline. This includes scope 1 and scope 2 emissions reduction. However, the target is not intensity-based.

102. GHG emissions intensity?

The company reports 14.1 mtCO2e of GHG emissions in 2023. However, this figure is not reported as an intensity metric and is not specific to palm oil operations.

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

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

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

The company reports 33.8 million mtCO2e of GHG emissions from land use change in supplier operations (scope 3). However, the figure is not specific to palm oil operations.

105. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports a 14.7% reduction in scope 1 and scope 2 GHG emissions in 2023 from the 2019 baseline. This information is externally verified by Apex. However, the figures are not reported as intensity metrics and is not specific to palm oil operations.

106. Methodology used to calculate GHG emissions?

The company uses the GHG Protocol methodology to calculate its GHG emissions.

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

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

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

The company commits to reducing its water use intensity by 10% by the year 2035 against a 2019 baseline.

109. Water use intensity?

2.56 - The company reports its water use intensity as 2.56 m3/ton of product produced in 2022. However, the figures are not specific to palm oil operations.

110. Progress towards commitment on water use intensity?

[Externally verified] The company reports a 9.9% increase in water use intensity for 2022 compared to the 2019 baseline. The information is externally verified by Apex. However, the figures are not specific to palm oil operations.

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

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

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

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

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

The company provides examples of wastewater treatment, primarily highlighting the recovery of water for reuse rather than the treatment of effluent before discharge. The company does not specifically mention palm oil refineries or PORE.

115. Commitment to protect natural waterways through buffer zones?

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

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

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

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

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

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

The company commits all suppliers to minimise the use of chemical fertilisers and pesticides.

119. Commitment to no use of paraquat?

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

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

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

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

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

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

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

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

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

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

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

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

126. Implementation of commitment to minimise inorganic fertiliser use?

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

127. Integrated Pest Management (IPM) approach?

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

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

[Externally verified] The company reports that process optimisation at oilseeds facilities in Windsor, Ontario; Lincoln, Nebraska; and Deerfield, Missouri, has reduced waste by 3,000 metric tons per year. Additionally, its Dharwad site in India partners with a cement manufacturer to divert approximately 100 metric tons per year from landfills. The information is externally verified by Apex. However, the system is in place only for certain operations.

129. Commitment to human rights?

The company commits to the UN Guiding Principles on Business and Human rights.

130. Commitment to human rights applies to all suppliers?

The company commits suppliers to the UN Guiding Principles on Business and Human rights.

131. Progress on human rights commitment?

The company reports that it has a supplier due diligence program to monitor human rights risks in its supply chain. In 2023, it collaborated with a third party to conduct a formal salience assessment, evaluating all human risks across its value chain. Additionally, the company received a perfect score of 100 on the Human Rights Campaign Foundation's 2022 Corporate Equality Index.

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

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

133. 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.

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

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

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

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

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

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

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

The company commits all suppliers to respect FPIC.

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

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

139. Examples of local stakeholder engagement to prevent conflicts?

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

140. Details of process for addressing land conflicts available?

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

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

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

142. Commitment to mitigate impacts on food security?

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

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

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

144. Commitment to provide essential community services and facilities?

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

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

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

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

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

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

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

148. 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.

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

[Externally verified] The company reports that it provides smallholders with NDPE training, covering workers' and community rights. Additionally, it collaborated with the Earthworm Foundation (EF) to develop a Child Risk Assessment Framework (CRAF) to address child labor issues in Malaysia. This information is externally verified by EF.

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

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

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

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

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

153. Percentage or number of temporary employees?

1589 (3.8%) - The company reports that it has 1,589 (3.80%) part-time employees in 2023.

154. Reports gender balance of employees?

10702 (25.6%) - The company reports that it has 10,702 (25.6%) women employees in 2023.

155. Commitment to pay a living wage?

The company only commits to paying the minimum wage.

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

The company's commitment to paying a minimum wage also applies to its suppliers.

157. Progress on commitment to pay a living wage?

158. Reporting of salary by gender?

The company reports the percentage of salaried colleagues. However, it does not report salary by gender.

159. Commitment to address occupational health and safety?

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

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

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

161. Provision of personal protective equipment and related training?

The company only reports that it spent more than 315,500 hours on training on occupational health and safety-related topics in 2020. However, this information is between two to five years old.

162. Time lost due to work-based injuries?

0.23 - The company reports a Lost Workday Incident Rate (LWIR) of 0.23 in 2023.

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

2 - The company reports two fatalities in 2023.

164. Commitment to support smallholders?

The company has published a commitment to support smallholders.

165. Programme to support scheme smallholders?

[Externally verified] The company reports that it runs a smallholder programme in India that focuses on regenerative practices including fertiliser efficiency, crop rotation and cover crops in addition to social sustainability, it is unclear if this relates to smallholders in oil palm supply chains. It also assists smallholders in Malaysia in identifying child labour risks, this has been externally verified by Earthworm Foundation. However, it is unclear what type of smallholders are supported in these programmes.

166. Percentage of scheme smallholders involved in programme?

25500 - The company reports that 25,500 smallholders were engaged in the smallholder programme in India. However, it is unclear what type of smallholders this figure refers to and if it is specific to oil palm smallholders.

167. Programme to support independent smallholders?

[Externally verified] The company reports that it runs a smallholder programme in India that focuses on regenerative practices including fertiliser efficiency, crop rotation and cover crops in addition to social sustainability, it is unclear if this relates to smallholders in oil palm supply chains. It also assists smallholders in Malaysia in identifying child labour risks, this has been externally verified by Earthworm Foundation. However, it is unclear what type of smallholders are supported in these programmes.

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

25500 - The company reports that 25,500 smallholders were engaged in the smallholder programme in India. However, it is unclear what type of smallholders this figure refers to and if it is specific to oil palm smallholders.

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

The company states that it uses third-party assessors to evaluate its direct suppliers' performance on the palm scorecard. However, it provides limited details on the process used to assess supplier compliance with company policies.

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

100% - The company reports that 100% of direct suppliers are committed to its Human Rights Policy and its Policy to Protect Forests, Biodiversity, and Communities. Additionally, all direct suppliers are included in the scorecard for assessing NDPE and Human Rights.

171. Suspension or exclusion criteria for suppliers?

The company requires compliance with its Human Rights Policy, Policy to Protect Forests, Biodiversity, and Communities, Code of Conduct and Supplier Expectations document. Non-compliances are evaluated based on scale, scope, and remediability before action is taken. The company also reports grievance time-frames.

172. 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.

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

[Externally verified] The company reports that 95.2% of palm oil products, and 89.4% of palm kernel oil product were sourced from supplier 'delivering' on no deforestation commitments. This is externally verified but Control Union. However, no total percentage is provided.

174. 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.

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

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

177. 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 the risk levels of mills and has also released data for 2022 using the Global Forest Watch Pro Palm Risk Analysis Tool.

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

The company reports that the risk levels for all mills are assessed annually.

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

The company reports that the risk levels for all mills are assessed annually.

180. Commitment to ethical conduct and prohibition of corruption?

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

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

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

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

The company reports that it has an 'anti-corruption program' that includes a global Anti-Corruption Policy and various compliance procedures and controls aimed at mitigating corruption risks in its global business operations. Additionally, the company conducts training sessions for employees and third parties to enhance awareness of corruption risks and relevant anti-corruption laws.

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

The company discloses its management approach to tax to the government through its Tax Policy which the Tax Team has responsibility for.

184. Whistleblowing procedure?

The company has a whistleblowing procedure that clearly outlines the steps taken, including how whistleblowers can report unethical conduct and the measures in place to protect them.

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

The company has its own grievance system open to all stakeholders.

186. Details of complaints and grievances disclosed?

[Externally verified] The company publishes a list of grievances including grievance no, group, issues, reported by, relationship, progress along with date.