Cargill Inc

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

The company has published a sustainable palm oil policy which covers all palm oil operations.

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.

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

The company reports that its CEO and Board Chair also joins its biannual Land Use and Forest Sustainability Advisory Panel, which is "designed to ensure that the strategies and resources underpinning Cargill's forest commitments are adequate to deliver positive socio-economic and environmental impact.".

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

46% - The company reports that women comprise 46% of its Executive Team.

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?

[Externally verified] UNGC, WBCSD, TFA, HCS, and Earthworm Foundation.

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

The company collaborates with multiple stakeholders such as High Carbon Stock Approach (HCSA) convergence, Decent Rural Living Initiative, Earthworm (formerly The Forest Trust), Solidaridad, and WildAsia.

9. Sustainability report published within last two years?

The company has published its 2020 sustainability report, and a progress update report for 2021.

10. Reports through standardised reporting systems?

The company has submitted multiple CDP questionnaires.

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's CDP climate questionnaire 2021 is publicly available and contains a comprehensive risk assessment.

13. Lists countries and operations?

The company shows the locations of its plantations, mills and refieries on a global map.

14. Lists countries sourcing from?

The company reports origin countries for its palm oil production.

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

188989 - The company reports the total land area managed for oil palm in its RSPO ACOP 2021.

16. Total oil palm planted area (ha)?

92413.8 - The company reports the total oil palm planted area in its RSPO ACOP 2021. This figure includes the infrastructure area.

17. Scheme smallholders planted area (ha)?

78797.8 - The company reports the plasma/scheme smallholders planted area in its RSPO ACOP 2021.

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

912.65 - The company reports the unplanted area in its RSPO ACOP 2021.

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

16865 - The company reports the conservation set-aside area, including High Conservation Value (HCV) area in its RSPO ACOP 2021.

20. Maps of estates/management units?

The company reports in its RSPO ACOP 2021 that maps represent 100% of concession sites.

21. Maps of scheme smallholders?

The company has various scheme smallholder maps across multiple audit reports. It is unclear if this covers all scheme smallholder operations and some information is between two and five years old.

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

The company only reports the total number of third-party supplying plantations.

23. Number of company-owned mills?

9 - The company reports a total number of mills and crushers operated as 12 in its sustainability report 2021. The RSPO ACOP 2021 reports 9 mills and 3 kernel crushers.

24. Names and locations of company-owned mills?

The company reports the name and location of its 9 mills in its Global Mill List.

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

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

27. Number of third party supplying mills?

1631 - The company has reported a total of 1631 third-party supplying mills in its sustainability report.

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

The company has published a list of all mills (own and third-party) along with their names and coordinates.

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

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

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

The company reports it sources from 1533 mills indirectly and 108 directly, however volumes are not reported.

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

The company has a commitment to 100% traceability to the plantation level for direct mills by 2025 and indirect mills by 2030.

33. Percentage of supply traceable to mill level?

The company states that 99% of its global supply is traceable to the mill level.

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

The company has a commitment to 100% traceability to the plantation level for direct mills by 2025 and indirect mills by 2030.

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

The company reports that its own plantations and mills in Indonesia are fully traceable.

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

The company reports that 65% of its global supply is traceable to plantations as of Q4 2021 but does not report separately for its own mills and supplier mills.

37. Publishes traceability data at refinery level?

38. Publishes traceability data at crusher level?

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

[Externally verified] 2004 - The company is a member of Roundtable on Sustainable Palm Oil (RSPO).

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] 2008 - The company became a member of the RSPO in 2004 and certified its first estate in 2008.

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

The company has submitted its 2020 ACOP.

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

[Externally verified] 68.84% - The company reports that 68.84% of its estates, excluding scheme smallholders, are RSPO certified.

43. Percentage of mills RSPO-certified?

[Externally verified] 100% - The company reports that all of its 9 mills are certified under RSPO.

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

2023 - The company reports a commitment to achieve 100% RSPO certification of estates and mills by 2023.

45. Time-bound plan for achieving 100% RSPO certification of all palm product processing facilities within 5 years?

2025 - The company commits to achieve 100% RSPO certification of all palm product processing facilities by 2025.

46. Percentage of scheme smallholders (ha) RSPO-certified?

[Externally verified] 86.64% - The company reports the percentage of scheme/plasma smallholders RSPO-certified in its RSPO ACOP 2021.

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

2023 - The company commits to achieve 100% RSPO certification of scheme/associated smallholders and outgrowers by 2023.

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

[Externally verified] 17.48% - The company reports a percentage of FFB supply (tonnes) from independent smallholders/outgrowers/third-party FFB suppliers that is RSPO-certified in its RSPO ACOP 2021.

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

[Externally verified] 27.91% - The company reports that 31% of its global supply is RSPO certified on its webpage. However, the calculated figure from its 2021 ACOP is 27.91%.

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

[Externally verified] In the company 2021 ACOP, it is reported that the company sells 61.29% of RSPO-certified palm oil through Segregated supply chains and 0% through Identity Preserved.

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

[Externally verified] In the company's 2021 ACOP it is reported that the company processes/trades 18.75% RSPO-certified CPO + CSPKO through Segregated or Identity Preserved supply chains.

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

The company reports some of the company's plantations are ISPO certified which includes PT. Hindoli, PT. Poliplant Sejahtera, PT Harapan Sawit Lestari and PT Ayu Sawit Lestari.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

[Externally verified] ISCC.

55. Commitment to zero conversion of natural ecosystems?

The company is committed to preventing the clearance of ecologically and socially important forests, habitats, and hydrological systems however. It states it is committed to be "free of deforestation and land conversion by 2030" however the committment does not specify all natural ecosystems.

56. Commitment to zero deforestation?

The company commits to zero deforestation.

57. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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

The company has reported a goal to halve deforestation by 2020 and end it completely by 2030.

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

The company has reported a goal to halve deforestation by 2020 and end it completely by 2030.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also provides evidence of monitoring deforestation in its own reporting.

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

The company reports using satellite and radar technology to monitor deforestation in supplier operations however, the information is not externally verified.

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

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

4 - The company reports a total area of 4 ha of illegal or non-compliant deforestation recorded within the company's suppliers' operational area in its grievance list but a consolidated figure covering entire operations was not reported.

64. Commitment to restoration of deforestation/conversion?

The company reports that non-compliance with its policy to protect HCV and HCS areas in its estates and supply chain 'may' require remediation, however, it does not specify a cut-off date. The company has reported a goal to halve deforestation by 2020 and end it completely by 2030, but it is not clear if deforestation that occurs within its estates before 2030 will need to be restored/compensated.

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

The company reports that "suppliers with deforestation/peat development allegations as of January 2019 will have to remediate or compensate land cleared".

66. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company reports its landscape initiatives on its website. It also reports a Peat Care Village Programme in Sungai Linau which is externally verified by Proforest.

67. Biodiversity policy?

The company only provides a general statement that the company commits to biodiversity protection.

68. Biodiversity policy applies to all suppliers?

69. 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.

70. 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.

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

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

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also communicates this in its own reporting.

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

The company commits all suppliers to conduct HCV assessments.

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

[Externally verified] The HCV assessment summaries are available for PT Indo Sawit Kekal, PT Hindoli Mukut-Penuguan and PT Sumber Terang Agro Lestari.

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

[Externally verified] The HCV assessments for PT Andes Agro Investama, PT Poliplant Sejahtera, PT Maya Agro Investama (West Kalimatan), PT Andes Sawit Lestari, Indonesia, and PT Andes Sawit Mas are available on the HCVRN platform.

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

[Externally verified] The High Conservation Value (HCV) management and monitoring plans are available for PT Andes Agro Investama, PT Poliplant Sejahtera, PT Maya Agro Investama (West Kalimatan), PT Andes Sawit Lestari, Indonesia and PT Andes Sawit Mas.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also commits to implement the combined HCV-HCSA-FPIC methodologies which require an assessment to be conducted by HCV ALS licensed assessors.

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

The company commits all suppliers to only use licensed HCV assessors accredited by the HCV Resource Network's ALS.

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

[Externally verified] The HCV assessments for PT Andes Agro Investama, PT Poliplant Sejahtera, PT Maya Agro Investama (West Kalimantan), PT Andes Sawit Lestari, Indonesia, and PT Andes Sawit Mas are available on the HCVRN platform.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also communicates this in its own reporting.

82. 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.

83. High Carbon Stock (HCS) assessments available?

[Externally verified] The High Carbon Stock Forest Assessment for PT Ades Sawit Mas is available on the HCS website.

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

[Externally verified] The peer review of PT Ades Sawit Mas is available on the HCS website.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company only reports its own commitment to conducting a social impact assessment.

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

The company only reports a commitment to conducting a social impact assessment that applies to all its suppliers.

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

[Externally verified] The social and environmental impact assessments are publicly available for PT Harapan Sawit Lestari, PT Indo Sawit Kekal, and PT Sumber Terang Agro Lestari on the RSPO-NPP website.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also communicates this in its own reporting.

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

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

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

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

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

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

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

The company reports its commitment to BMPs only for peat in its sustainable palm oil policy that applies to all its suppliers.

94. 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. The company has also provided evidence of best management practices for soil and peat in its own reporting.

95. Commitment to zero burning?

The company commits to no burning.

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

97. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also communicates this in its own reporting.

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

The company reports that no hotspots were detected between October 24 to 28, 2021. It reports detailed hotspot monitoring data from August 2020 to October 2021.

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

0 - The company reports that no hotspots were detected between October 24 to 28, 2021 in its own plantations and up to a one kilometer boundary from its estates. It reports detailed hotspot monitoring data from August 2020 to October 2021.

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

The company has committed to reducing GHG emissions from its global supply chain by 30% per ton of product by 2030, using a 2017 baseline. However, this commitment only applies to scope 3 emissions. The company also has a commitment to reduce Scope 1 and 2 absolute greenhouse gas (GHG) emissions in its operations by 10% by 2025 against a 2017 baseline, however this target is not based on intensity.

101. GHG emissions intensity?

The company reports the average GHG footprint for all certified management units by hectare is 4.02 tCO2e/ha, and the average GHG footprint for all certified management units per tonne of crude palm oil is 1.43tCO2e/t CPO, in 2021.

102. GHG emissions from land use change?

103. Progress towards commitment to reduce GHG emissions intensity?

The company reports its progress to reduce GHG emissions intensity. However, the reported progress is not specific to palm oil operations.

104. Methodology used to calculate GHG emissions?

The company uses the RSPO endorsed palm GHG tool methodology to calculate GHG emissions.

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

The company reports two of its mills to have 100% methane capture. However, methan capture at the rest of the mills is still under development.

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

107. Water use intensity?

108. Progress towards commitment on water use intensity?

The company reports a 2.9% improvement in freshwater efficiency however, the information is dated 2017 and it is not clear if the figure is based on water use intensity.

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports information on the treatment of palm oil effluents on its website.

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

113. Commitment to protect natural waterways through buffer zones?

114. 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.

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

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

117. Commitment to no use of paraquat?

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

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

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

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

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

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

124. 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.

125. Integrated Pest Management (IPM) approach?

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

126. 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.

127. Commitment to human rights?

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

128. Commitment to human rights applies to all suppliers?

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

129. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports having an ethics open line for reporting and remedies.

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

The company commits to respect indigenous and local communities' rights but it does not refer to the UN Declaration/ILO Convention.

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

The company reports its commitment to indigenous and local communities' rights applies to all suppliers. However, it does not refer to the UN Declaration/ILO Convention.

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

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

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

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

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also communicates this in its own reporting.

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

The company commits all suppliers to respect FPIC.

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

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). Points have therefore been awarded on the basis of the company's commitments under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

137. Examples of local stakeholder engagement to prevent conflicts?

138. Details of process for addressing land conflicts available?

139. 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.

140. Commitment to mitigate impacts on food security?

The company commits to ensuring food security but not clearly in relation to local communities.

141. 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.

142. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

143. 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. The company also reports multiple examples of providing essential community services and facilities.

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

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

The company commits to freedom of association, right to collective bargaining, no forced labour, equal wage, and no discrimination referencing ILO's Declaration on Fundamental Principles and Rights at Work, but does not commit to all eight Core Conventions.

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

The company commits to freedom of association, right to collective bargaining, no forced labour, equal wage, and no discrimination referencing ILO's Declaration on Fundamental Principles and Rights at Work, but does not commit to all eight Core Conventions. This applies to all suppliers.

147. 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.

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

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

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

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

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

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

151. Percentage or number of temporary employees?

152. Percentage or number of women employees?

153. Commitment to pay a Decent Living wage?

The company only commits to paying the legal minimum wage, however it states it will conduct a living wage assessment initially for its oil palm plantation operations with the 'goal of ensuring workers have access to decent living wages'.

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

The company only commits to paying the legal minimum wage. This applies to all suppliers of the company.

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

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

156. Reporting of salary by gender?

157. Commitment to address occupational health and safety?

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

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

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

159. Provision of personal protective equipment and related training?

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

160. Time lost due to work-based injuries?

1.17 - The company reports an injury frequency rate of 1.17 for the year 2021.

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

4 - The company reports four fatalities as a result of work-based accidents in 2022.

162. Commitment to support smallholders?

The company has published a commitment to support smallholders.

163. Programme to support scheme smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports programmes to support smallholders in its own reporting.

164. Percentage of scheme smallholders involved in programme?

22000 - The company reports partnering with 22,000 smallholders as well as the involvement of different numbers of smallholders in different programmes.

165. Programme to support independent smallholders?

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

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

The company reports in its 2018 ACOP that "it has a 2-year contract agreement with about 3,000 independent smallholders located in Ketapang to receive their FFB crop" however, the percentage could not be calculated as only an approximate figure is reported. Also, the information is between two to five years old.

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

The company reports having an Aggregator/Refiner Transformation (ART) plan, Supplier Assessments, and sustainability improvement programs.

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

The company reports that 93% of its direct mill suppliers attended an NDPE workshop in 2021. 72% conducted field assessments and 82% conducted self-assessments.

169. Suspension or exclusion criteria for suppliers?

The company reserves the right to end its relationship with the supplier when an issue cannot be corrected or a supplier partner is unwilling to engage. Time-frames for action are included in the company's grievance procedure.

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

The company reports time bound action plans with KPIs for suppliers to be in compliance with its NDPE policy.

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

The company reports the total volume of supply from direct trader/refiners that is covered by an NDPE policy (93%). However, it is not clear if this relates only to third-party supply, and indirect supply that is compliant is not reported.

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

The company conducts field visits to high-risk mills, however, it does not commit to engaging with all its high-risk mills over a three-year period.

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

Global Forest Watch Commodities (GFWC) PALM Risk Tool, Aggregator/Refiner Transformation (ART) plan, and Profest Supplier engagement approach are the programmes used to support high-risk mills to become compliant with sourcing policies. The information is self-reported.

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

The company reports its engagement and field assessments with high-risk mills on an annual basis.

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

The company reports that it uses the Global Forest Watch Pro Palm Risk Tool Methodology to categorize the mills from high to low, however no further details on the methodology are given and it is unclear if this includes the company's own mills as well.

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

The company reports the risk level of its mills on an annual basis.

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

The company reports havng 338 high, 513 medium and 574 low risk mills.

178. Commitment to ethical conduct and prohibition of corruption?

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

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

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

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

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

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

182. Whistleblowing procedure?

The company has an Ethics Open Line for reporting any misconduct and sets out how whistleblowers are protected.

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

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

184. Details of complaints and grievances disclosed?

The company has published the details of complaints and grievances on its website.