Bunge Ltd

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 and Government Affairs.

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

The company reports that the sustainability and corporate responsibility committee is responsible to oversee sustainability-related topics, this committee consists of four board members.

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

21% - The company reports that it has 21% of women in senior leadership team.

6. Percentage or number of women board members?

4 (36%) - The company reports that it has four (36%) women on its board.

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

[Externally verified] WBCSD, UNGC, and PONGO Alliance.

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

The company Bunge Loders Croklaan and the Earthworm Foundation have been working towards improving the welfare of workers in the company's supply chain in Malaysia, aligning with its 'No Exploitation' policy commitments. Additionally, the company reports that it supports phase 2 of the Social Excellence in the 'Guatemalan Palm Oil Sector' project, led by the Earthworm Foundation and executed in partnership with the 'Gremial de Palmicultores de Guatemala' (GREPALMA) that promotes more responsible social management of palm oil companies' operations in Guatemalan region. Further, it also has a collaboration with Earth Equalizer, to check for and act on instances of suspected deforestation.

9. Sustainability report published within last two years?

The company has published its latest global sustainability report for 2023.

10. Reports through standardised reporting systems?

The company states that its global sustainability report is prepared in accordance with GRI Standards: Core option and the company has also submitted its CDP questionnaires for 2022.

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 has submitted its CDP climate change questionnaire which is publicly available. However, it contains only limited information on climate risk assessment.

13. Lists countries and operations?

The company lists the company has refineries in: Brazil; Canada; Finland; Germany; Italy; Malaysia; Mexico; the Netherlands; Poland; Spain; the United States of America.

14. Lists countries sourcing from?

The company lists the countries in its mill list that it sources from.

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?

The company shared with ZSL that it has mapped the concessions of direct and indirect suppliers but cannot publicly share these due to non disclosure agreements.

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?

1723 - The company reports that it has 1,723 third-party supplying mills.

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

The company provides an integrated mill list with names and coordinates of all third-party supplying 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 states that 10% of its total palm oil volume is directly sourced from third-party mills and that 85% is indirectly sourced through trading partners with NDPE policies in place. Data is between two and five years old.

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

The company states that it had a commitment to achieve 100% traceability to mill level by 2018, however, the target was not achieved.

33. Percentage of supply traceable to mill level?

The company reports that 95% of its supply is traceable to the mill level. Additional points were awarded as some of the company's facilities have IP and SG certifications.

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

The company has a commitment to achieve 100% traceability to plantation level by 2025.

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 90% of its supply is traceable to the plantation level. Additional points were awarded as some of the company's facilities have IP and SG certifications.

37. Publishes traceability data at refinery level?

[Externally verified] The company publishes traceability data at the refinery level. The information is externally verified by Control Union Certifications B.V.

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] 2004 - The company became an RSPO member in September 2004.

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?

2011 - The company became an RSPO member in 2004, and reports that it achieved its first supply chain certification in 2011.

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

The company's recent RSPO ACOP was submitted in 2022.

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?

2016 - 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?

32.54% - The company reports 32.54% of certified palm oil and palm oil products processed in its RSPO ACOP 2022.

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 company discloses it processed/traded 18.78% RSPO-certified palm oil through segregated or identity-preserved supply chains in its RSPO ACOP 2022.

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?

[Externally verified] The company has MSPO certificates for two of its entities.

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

[Externally verified] The company is ISCC certified.

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 commits all suppliers to zero deforestation. This commitment has been in place since 2018.

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

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

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

The company defines deforestation for suppliers as the removal of HCV and HCS areas. Further, the company states that it will conduct appropriate due diligence to assess whether prospective suppliers have complied with its policy from February 2017.

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?

[Externally verified] The company states that it receives land use change alerts from Satelligence to detect if there is deforestation taking place on a biweekly basis. In addition to this, the company also reports that it actively monitors more than 30 million ha of land and has a collaboration with Earth Equalizer, to check for, and act on, instances of suspected deforestation.

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 instances of deforestation in its grievance list. However, the area deforested is not clear for each grievance and a total a figure for all non-compliant deforestation since the cut-off date is also 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 commits suppliers to restore ecosystems to their prior condition in cases of conversion within their own operations.

67. Implementing a landscape or jurisdictional level approach?

The company reports implementing its landscape-level approaches including partnerships with Chevron, CoverCress, and Bayer to replace traditional fossil fuels with renewable energy sources. Further, it has collaborated with local farmers to preserve native vegetation that might otherwise be cleared for agricultural expansion.

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 'Land Use and Biodiversity Policy'. However, the policy does not include information of the scope of biodiversity protected. It is also not applicable to suppliers.

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?

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 commits all suppliers to conduct HCV assessments.

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 all suppliers to apply 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 environmental impact assessments only.

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 peat only.

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 reduce its greenhouse gas (GHG) emissions by over 13,000,000 metric tons by 2030. However, the figures are not specific to palm oil operations, and the figures were not reported as intensity, and do not clearly cover both scope 1 and 2 emissions.

102. GHG emissions intensity?

The company reports its GHG emissions intensity ratio (scope 1 and 2) as 49.35 (KgCO2e/MT) in 2022. However, the figure was 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)?

105. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports a reduction in its GHG emissions (scope 1 and 2) from 3,199,482 metric tons CO2e (2020) to 2,868,378 metric tons CO2e (2022). However, the figures were not reported as intensity and were specific to palm oil operations.

106. Methodology used to calculate GHG emissions?

The company uses the GHG Protocol Corporate Value Chain (Scope 3) accounting and reporting standard methodology to calculate GHG emissions for its supply chain, it does not report a methodology for its own operations.

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 reports a target to reduce freshwater consumption by 10% per mt of production by the end of 2026. However, the commitment is not specific to palm oil operations.

109. Water use intensity?

87538900 - The company reports the total volume of water withdrawal as 87,538,946 m3 in 2022. However, the figure is not reported for water consumption, is not an intensity figure, and is not specific to palm oil.

110. Progress towards commitment on water use intensity?

The company has achieved a 15% reduction in its water use intensity since 2016. However, the figures only include palm oil operations as part of aggregate figure.

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)?

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?

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?

The company commits all suppliers to not use paraquat.

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?

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?

The company states that it conducts critical analysis tests to verify performance, with measurement on scales and laboratory analysis of effluents. In 2021, the company made considerable reductions in waste disposal by achieving a 27% decrease as compared to the previous year. Further, the company has also achieved zero-waste landfill status in Xiamen, China through its robust waste management processes and systems.

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?

[Externally verified] The company reports that it established a human rights team in 2022 to deepen its governance and implementation linked to its human rights program and its respect for human rights. Further, it has also launched a training module focused on recognising and acting to eradicate modern slavery for staff in key functions and regions. In addition to this, the company also reports that Bunge Loders Croklaan (BLC) in collaboration with Earthworm Foundation (EF) has been working towards improving key human and labour rights of workers in its supply chain in Malaysia.

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

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

133. Commitment to respect indigenous 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 has implemented a 'Labor Transformation Program' (LTP) in partnership with the Earthworm Foundation to address labour concerns in its supply chain in Malaysia.

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?

154. Percentage or number of women employees?

5530 (24%) - The company reports that it has 5,530 (24%) women employees in 2022.

155. Commitment to pay a Living Wage?

The company only commits to paying the minimum wage only.

156. Commitment to pay a Living Wage applies to all suppliers?

The only commits to paying the minimum wage that applies to all suppliers.

157. Progress on commitment to pay a Living Wage?

158. Reporting of 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?

162. Time lost due to work-based injuries?

0.2 - The company reports a Lost Time Injury Rate (LTIR) as 0.20 in 2022.

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

2 - The company reports two fatalities as a result of work-based accidents in 2022.

164. Commitment to support smallholders?

The company has published a commitment to support smallholders.

165. Programme to support scheme smallholders?

The company reports that it has a smallholder programme 'ILHAM' that helps to boost the productivity of smallholder farmers and helps them to implement sustainable agricultural practices. However, the details of the programme implementation were not provided and also the type of smallholders involved is unclear.

166. Percentage of scheme smallholders involved in programme?

232 - The company reports that the 'ILHAM' programme involves 232 smallholders. However, the type of smallholder involved is unclear.

167. Programme to support independent smallholders?

The company reports that it has a smallholder programme 'ILHAM' that helps to boost the productivity of smallholder farmers and helps them to implement sustainable agricultural practices. However, the details of the programme implementation were not provided and also the type of smallholders involved is unclear.

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

232 - The company reports that the 'ILHAM' programme involves 232 smallholders. However, the type of smallholder involved is unclear.

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

The company reports that it conducts mill risk assessments, develops a monitoring system for all mills, and engages with all suppliers. It also states that if non-compliance is identified, the company will initiate the grievance procedure.

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

[Externally verified] 94% - The company reports that 94% of its suppliers were assessed on compliance with the company's NDPE commitments. This information is externally verified by Control Union.

171. Suspension or exclusion criteria for suppliers?

The company states that it will cease business with suppliers where the clearing of potential HCV, HCS, or peat areas is detected by following engagement steps described in the grievance procedure. The company also specifies that suspended suppliers who do not provide appropriate plans will remain suspended.

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

The company lists some actions for ensuring policy compliance by potential new suppliers. However, these action plans are not time-bound.

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

The company reports that 53% of supply from third-party suppliers were verified as DCF. The company verified DCF volumes through NDPE IRF methodology.

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

The company reports that it will work with independent experts to develop a program of mill-level verification assessments, using risk assessment tools to identify high-risk mills and ensure their adherence to the stated sustainability commitments. However, no time-bound commitment was found.

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

The company states that it will continue to engage with suppliers to promote its policy commitments and ensure compliance, but limited details are provided on the type of support provided.

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

The company conducts mill-level engagement visits and mill workshops. However, it is unclear if covers both own and third-party mills. The policy also does not report how often mills are be engaged.

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

The company uses spatial data, remote sensing information, and satellite technology to assess all supplying palm oil mills for risk levels.

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

The company reports that it conducts a proactive mill risk assessment for all mills in its supply chain. However, no information is provided on how often mills are assessed.

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

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 provides mandatory annual training on its code of conduct that was attended by 99% of its employees, officers, and directors in 2022. Further, it has also established an ethics and compliance helpline to report issues such as theft, fraud, and bribery or corruption.

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

The company has a UK tax strategy which states that the audit committee of its board of directors is responsible for oversight of tax risk management practices. However, this does not cover the full scope of the company's operations.

184. Whistleblowing procedure?

The company has its own helpline to anonymously report unethical conduct and reports how whistleblowers are protected.

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

The company has a grievance procedure which is open to all stakeholders.

186. Details of complaints and grievances disclosed?

[Externally verified] The company reports the details of complaints received such as date, issue, category, actions taken and status through its own grievance mechanism.