Asian Agri Group

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

The company meets this indicator through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years. The company also has its own sustainability policy.

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

3. High-level position of responsibility for sustainability?

Director for Sustainability and Stakeholders Relations.

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

The Managing Director "oversees the entire sustainability implementation and provides strategic guidance to the team.".

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

7% - The company reports the percentage of women in management positions but it is unclear if these are senior management positions.

6. Percentage or number of women board members?

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

HCS, FFA, TFA 2020 and NYDF.

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

The company worked together with ISPO and UNDP to help its smallholders get the certification, launched Fire Free Village Program in collaboration with the government, collaborated with NGOs to help smallholders obtain land verification documents STD-B.

9. Sustainability report published within last two years?

10. Reports through standardised reporting systems?

CDP.

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

161,890 - Area reported pertains to the company's subsidiary PT Inti Indosawit Subur which manages all of the company's palm oil operations.

14. Total oil palm planted area (ha)?

93,574 - The figure excludes plasma smallholders.

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

52,917

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

0 - Data as of 2019.

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

0 - The company reports 0 ha in its 2019 ACOP, however, the company reports elsewhere having HCV areas, so the conservation area is unclear.

18. Maps of estates/management units?

The company's subsidiary PT Inti Indosawit Subur has submitted all its maps to the RSPO, and this covers all of the company's operations.

19. Maps of scheme/plasma smallholders?

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

21. Number of company-owned mills?

21

22. Names and locations of company-owned mills?

In ACOP 2019, the company reports a total of 21 mills, and names and locations are available on the company's website.

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

The company has disclosed the supply bases for its 21 mills.

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

The company has disclosed the percentage of FFB supply from its own and third-party plantations for its 21 mills.

25. Number of third party supplying mills?

The company reports the number of mills supplying each of its KCPs, but does not report an overall figure on number of third-party supplying mills.

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

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

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

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

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

31. Percentage of supply traceable to mill level?

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

The company has achieved 100% traceability to the plantation as of 2019.

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

The company has achieved 100% traceability to the plantation as of 2019.

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

35. Publishes traceability data at refinery level?

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

36. Publishes traceability data at crusher level?

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

2006 - The company's subsidiary, PT Inti Indosawit Subur, is an RSPO member and this covers all of the company's palm oil operations.

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?

2010 - The company's subsidiary, PT Inti Indosawit Subur, became an RSPO member in 2006 and had its first RSPO certification in 2010.

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

The company's subsidiary, PT Inti Indosawit Subur, has submitted its RSPO ACOP for 2019.

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

The company's subsidiary, PT Inti Indosawit Subur, in its ACOP 2019 has reported that it operates in Indonesia (Jambi, North Sumatra, Riau).

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

42. Percentage of mills RSPO-certified?

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

2022 - The company's subsidiary, PT Inti Indosawit Subur, in its ACOP 2019 has reported that it expects to achieve 100% RSPO certification by 2022. The company itself is not an RSPO member.

44. Year expected to achieve 100% RSPO certification of all palm product processing facilities?

2020

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

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

2019 - The company's subsidiary, PT Inti Indosawit Subur, in its ACOP 2019 has reported that it expects to achieve 100% RSPO certification of scheme/plasma/associated smallholders and outgrowers by 2019.

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

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

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

Identity Preserved and Mass Balance.

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

51. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

ISCC.

53. Commitment to zero deforestation or zero conversion of natural ecosystems?

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have been therefore awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

54. Commitment to zero deforestation or zero conversion of natural ecosystems applies to all suppliers?

The company has its own sustainability policy which applies to all suppliers.

55. Criteria for defining deforestation?

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

56. Evidence of monitoring deforestation?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

57. Evidence of monitoring deforestation in supplier operations?

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

The company has not undertaken any new planting since 2003.

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

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

The company commits to applying the RSPO Remediation and Compensation Procedure where there has been land clearing without prior HCV assessment since November 2005, or without prior HCV-HCSA assessment since November 2018, through the RSPO Principles and Criteria 2018. However, a commitment covering restoration of all non-compliant deforestation/conversion was not found. Partial points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

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

62. Implementing a landscape or jurisdictional level approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

63. Commitment to biodiversity conservation?

64. Commitment to biodiversity conservation applies to all suppliers?

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company has identified species of conservation concern referring to the IUCN Red list.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company states that it is committed to no hunting of protected or endangered species only.

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

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

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

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

There is public availability of the following HCV assessments: Sumatra: PT Usaha Sawit Unggul.

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

This indicator is disabled as the company has not undertaken any new planting since January 2015.

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

This indicator is disabled as the company has not undertaken any new planting since January 2015.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

75. 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?

76. 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 has not undertaken any new planting since January 2015.

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

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

79. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company has not undertaken any new planting since Januray 2016.

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

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

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

There is public availability of the following SEIA: Sumatra: PT Usaha Sawit Unggul.

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

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

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

27,409 - Data as of 2018.

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

The current peat landbank of the company is 27,409 and peatland has not increased since the previous year.

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

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

The company is committed to the best management practice for peatland. However, no information found regarding soil. The commitment applies to all suppliers.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

90. Commitment to zero burning?

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

91. Commitment to zero burning applies to all suppliers?

92. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company reports that "since the start of 2020, there have been zero forest and land fires reported in the Pelalawan Regency", however this does not cover all of the company's operations.

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

The company reports that 10 of its villages are fire-free with the implementation of a Fire-Free Village Programme. However, information regarding number of hotspots/fires is not specified.

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

96. GHG emissions intensity?

13.05 tCO2e/ha.

97. GHG emissions from land use change?

This indicator is disabled as the company has not undertaken any new planting since January 2015.

98. Progress towards commitment to reduce GHG emissions intensity?

99. Methodology used to calculate GHG emissions?

The RSPO requires companies to assess their GHG emissions through the Palm GHG calculator. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

The company has 10 biogas plants out of 21 mills.

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

102. Water use intensity?

1.23 - m3/Ton FFB Processed in 2019.

103. Progress towards commitment on water use intensity?

The company reports an improvement in water use intensity between 2017 and 2019, from 1.24 to 1.23 m3/Ton FFB Processed.

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

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

The company reports improvement in its BOD level and it is also working towards reducing it further.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

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

108. Commitment to protect natural waterways through buffer zones?

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

112. Commitment to no use of paraquat?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

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

The company reports average fertiliser usage for Mature and Immature oil palm in all three regions.

119. Implementation of commitment to minimise inorganic fertiliser use?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

120. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

122. Commitment to human rights?

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

123. Commitment to human rights applies to all suppliers?

124. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

The company commits to respect and recognise the rights of indigenous and local communities, but does not reference the UN Declaration or ILO. The policy applies to all suppliers.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

The company only commits to land use rights in relation to FPIC.

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

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

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

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

132. Examples of local stakeholder engagement to prevent conflicts?

133. Details of process for addressing land conflicts available?

The RSPO Principles and Criteria 2018 contain requirements for addressing land conflicts. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

135. Commitment to mitigate impacts on food security?

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

136. Commitment to mitigate impacts on food security applies to all suppliers?

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

138. Commitment to provide essential community services and facilities?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

The company does not refer to freedom of association, equal remuneration, minimum age, and no forced labour principles of fundamental ILO conventions. The policy applies to all suppliers.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

147. Percentage or number of temporary employees?

40% - Data as of 2018.

148. Percentage or number of women employees?

6,434.5 (27.12%) - Data as of 2018.

149. Commitment to pay at least minimum wage?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

150. Commitment to pay at least minimum wage applies to all suppliers?

151. Progress on commitment to pay at least minimum wage?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

152. Reporting of salary by gender?

153. Commitment to address occupational health and safety?

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

155. Provision of personal protective equipment and related training?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

156. Time lost due to work-based injuries?

The company reports a lost day rate for North Sumatra, Riau, and Jambi as (Male/Female) 1.64/0.02, 18.29/1.02, 9.12/0.02 respectively. Data as of 2018.

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

0 - Data as of 2018.

158. Commitment to support smallholders?

The company has its own commitment and also makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

159. Programme to support scheme/plasma smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

160. Percentage of scheme/plasma smallholders involved in programme?

The company reports the number of smallholders involved in its programme. Data as of 2018.

161. Programme to support independent smallholders/outgrowers?

The company also supports independent smallholders by conducting Corporate Social Responsibility (CSR) programmes. Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

[Externally verified] The company states it partners with 30,000 smallholders who manage 60,000 ha. Data as of 2018.

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

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

165. Suspension or exclusion criteria for suppliers?

The company mentions ceasing the business with any suppliers who breach the policy. However, no information found regarding the timeframe for any actions.

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

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

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

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

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

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

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

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

174. Commitment to ethical conduct and prohibition of corruption?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

178. Whistleblowing procedure?

The RSPO Principles and Criteria 2018 contain guidance and requirements on whistleblowing procedures. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years.

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

The company adheres to this criteria through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within five years. The company also has a grievance mechanism that is applicable to both internal and external stakeholders.

180. Details of complaints and grievances disclosed?

The company discloses details of two grievances.