Cargill Inc

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

The company has a policy on sustainable palm oil which covers multiple dimensions of sustainability across the company's operations covering both social and environmental issues.

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

The company's sustainable palm oil policy applies to all of its suppliers.

3. High-level position of responsibility for sustainability?

The company reports Pilar Cruz as its Chief Sustainability Officer. However, the information is undated.

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

This indicator is disabled as it is not applicable to this company.

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

30% - The company reports that women comprised 30% of its leadership positions globally.

6. Percentage or number of women board members?

This indicator is disabled as it is not applicable to this company.

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, WildAsia, World Resources Institute, and Embode European Palm Oil Alliance (EPOA) to reduce negative environmental or social outcomes associated with the palm oil production.

9. Sustainability report published within last two years?

The sustainability Report for 2019 is published by the company.

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 it is not applicable to this company.

12. Climate risks assessment available?

The company is working for climate change, however, does not provide any risk assessment report for the same.

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

146136 - The company reports the total land area managed for oil palm in its RSPO ACOP 2020.

14. Total oil palm planted area (ha)?

92853.2 - The company reports the total oil palm planted area in its RSPO ACOP 2020. This figure includes the infrastructure area.

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

34766.1 - The company reports the plasma/scheme smallholders planted area in its RSPO ACOP 2020.

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

1651.44 - The company reports the unplanted area in its RSPO ACOP 2020.

17. 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 2020.

18. Maps of estates/management units?

The company reports in its RSPO ACOP 2020 that maps represent 100% of concession sites.

19. Maps of scheme/plasma smallholders?

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

21. Number of company-owned mills?

9 - The company reports the number of company-owned mills in its sustainable palm oil progress report and RSPO ACOP 2020.

22. Names and locations of company-owned mills?

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

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

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

25. Number of third party supplying mills?

1359 - The company has reported a total of 1,359 third-party supplying mills on its website.

26. 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.

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?

The company sources 86% of its volumes indirectly from mills through traders/refineries.

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

The company reports that 'we achieved full traceability to the mill level in 2015 and continue making progress in traceability to the plantation level'.

31. Percentage of supply traceable to mill level?

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

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

The company commits traceability to the plantation level only for all high-priority landscapes.

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

The company reports that 'our own plantations and mills in Indonesia are fully traceable, but most of the palm oil we trade and process comes from third-party refiners, aggregators or mills'.

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

The company reports that 48% of its global supply is traceable to plantation but does not report separately for own mills and supplier mills.

35. Publishes traceability data at refinery level?

36. Publishes traceability data at crusher level?

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

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

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?

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

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

The company has submitted its 2020 ACOP.

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

The company states all the countries and regions in which it operates as a palm oil grower: Indonesia (West Kalimantan and South Sumatra).

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

57.69% - The company reports that 57.71% of its estates, excluding scheme smallholders, are RSPO certified.

42. Percentage of mills RSPO-certified?

88.88% - The company reports 8 out of 9 mills are certified under RSPO.

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 reports to achieve 100% RSPO certification of estates and mills by 2022.

44. Time-bound plan for achieving 100% RSPO certification of all palm product processing facilities?

2030 - The company reports achieving 100% RSPO certification of all palm product processing facilities by 2030. However, the target is over five years.

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

70.76% - The company reports the percentage of scheme/plasma smallholders RSPO-certified in its RSPO ACOP 2020.

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

2022 - The company reports to achieve 100% RSPO certification of scheme/plasma/associated smallholders and outgrowers by 2022.

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

0% - The company reports a supply of 22,781.17 tonnes of FFB from independent smallholders in its ACOP 2020 and that none of this is RSPO certified. The company reports no sourcing from outgrowers or third-party suppliers.

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

22.27% - The company reports that 31% of its global supply is RSPO certified on its webpage. However, the calculated figure from its 2020 ACOP is 22.27%.

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

In the company 2020 ACOP it is reported that the company sells 48.24% of RSPO-certified palm oil through Segregated supply chains and 0% through Identity Preserved.

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

In the company's 2020 ACOP it is reported that the company processes/trades 13.84% RSPO-certified CPO + CSPKO through Segregated or Identity Preserved supply chains.

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

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.

52. Malaysia Sustainable Palm Oil (MSPO) certified?

This indicator is disabled as it is not applicable to this company.

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

[Externally verified] ISCC.

54. Commitment to zero conversion of natural ecosystems?

The company is committed to preventing the clearance of ecologically and socially important forests, habitats, hydrological systems, however it does not report a commitment to zero conversion of natural ecosystems, and therefore no points can be awarded.

55. Commitment to zero deforestation?

The company reports its commitment to zero deforestation in its Forest Policy.

56. Commitment to zero deforestation applies to all suppliers?

The company reports its commitment to zero deforestation in its Forest Policy extends to all suppliers.

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

The company reports the criteria and cut-off date for defining deforestation in its forest policy.

58. Evidence of monitoring deforestation?

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.

59. Evidence of monitoring deforestation in supplier operations?

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

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

The company monitors deforestation in its supply chain and also reports complaints of deforestation but does not report figures for non-compliant deforestation.

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

The company monitors deforestation in its supply chain and also reports complaints of deforestation but does not report figures for non-compliant deforestation.

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

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

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.

64. Implementing a landscape or jurisdictional level approach?

The company reports its landscape initiatives on its website and the information is not externally verified.

65. Biodiversity policy?

The company only provides a general statement that company commits to biodiversity protection with no detail given on scope.

66. Biodiversity policy applies to all suppliers?

67. 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.

68. 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.

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

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

71. 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 reports its own commitment in its policy on sustainable palm oil.

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

The company reports its commitment to conduct HCV assessment in its sustainable palm oil policy that applies to all suppliers.

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

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

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

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

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

[Externally verified] Management and monitoring plans are available for PT Andes Agro Investama, PT Andes Sawit Lestari, Indonesia, PT Andes Sawit Mas, PT Poliplant Sejahtera and PT Maya Agro Investama (West Kalimantan).

76. 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.

77. 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 reports its commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's ALS in its sustainable palm oil policy, which is applicable to all suppliers.

78. 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 Andes Sawit Lestari, Indonesia, PT Andes Sawit Mas, PT Poliplant Sejahtera and PT Maya Agro Investama (West Kalimantan) have been reviewed as satisfactory by the HCVRN.

79. 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 reports its commitment in its Sustainable Palm Oil Policy.

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

The company reports its commitment to the High Carbon Stock (HCS) Approach in its Sustainable Palm Oil Policy that applies to all suppliers.

81. High Carbon Stock (HCS) assessments available?

[Externally verified] High Carbon Stock Forest Assessment for PT Ades Sawit Mas is available.

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

[Externally verified] The company provides only one HCS peer review report for PT Andes Sawit Mas(2021).

83. 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.

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

The company is only committed to conducting a social impact assessment that applies to all its suppliers.

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

[Externally verified] Social and environmental impact assessments are publicly available of PT Harapan Sawit Lestari, PT Indo Sawit Kekal, and PT Sumber Terang Agro Lestari.

86. 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 reports its commitment in its Sustainable Palm Oil Policy.

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

The company reports its commitment in its Sustainable Palm Oil Policy that applies to all its suppliers.

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

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

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

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

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

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

92. 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.

93. Commitment to zero burning?

The company reports its commitment to zero burning in its Sustainable Palm Oil Policy.

94. Commitment to zero burning applies to all suppliers?

The company reports its commitment to zero burning in its Sustainable Palm Oil Policy that applies to all its suppliers.

95. 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 reports information in its sustainability reports.

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

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

98. 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 commits to reduce absolute GHG emissions by 10% by 2025, using a 2017 baseline.

99. GHG emissions intensity?

The company reports the average GHG footprint for all certified management units by hectare is 3.31 tCO2e/ha, and the average GHG footprint for all certified management units per tonne of crude palm oil is 1.32 tCO2e/tCPO, in 2019.

100. GHG emissions from land use change?

101. Progress towards commitment to reduce GHG emissions intensity?

The company only reports its progress towards its commitment to reduce GHG emissions intensity. However, the reported progress is not specific to palm oil operations and the information is not externally verified.

102. Methodology used to calculate GHG emissions?

RSPO endorsed palm GHG tool.

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

The company reports that two of its mills have methane capture.

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

105. Water use intensity?

106. Progress towards commitment on water use intensity?

The company reports a 2.9% improvement in freshwater efficiency improvement in its 2017 annual report.

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

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

109. 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.

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

111. Commitment to protect natural waterways through buffer zones?

112. 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.

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

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

115. Commitment to no use of paraquat?

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

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

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

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

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

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

122. 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.

123. Integrated Pest Management (IPM) approach?

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

124. 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.

125. Commitment to human rights?

The company reports its commitment to human rights in its Human Rights Policy and its Sustainable Palm Oil Policy.

126. Commitment to human rights applies to all suppliers?

The company reports its commitment to human rights in its Human Rights and Sustainable Palm Oil Policy that applies to all its suppliers.

127. 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 a ethics open line for reporting and remedies.

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

The company reports its commitment to respect indigenous and local communities' rights in its Sustainable Palm Oil Policy. However, does not refer to UN Declaration/ILO Convention.

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

The company reports its commitment in its Sustainable Palm Oil Policy. However, does not refer to the UN Declaration/ILO Convention. The policy applies to all suppliers.

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

The company reports its commitment to respect legal and customary land tenure rights in its Sustainable Palm Oil Policy.

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

The company reports its commitment to respect legal and customary land tenure rights in its Sustainable Palm Oil Policy, extends to all suppliers.

132. 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 has its own commitment to FPIC in its own reporting.

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

The company reports its commitment to FPIC in its Sustainable Palm Oil Policy, which applies to all suppliers.

134. 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.

135. Examples of local stakeholder engagement to prevent conflicts?

The company reports an example: 'pilot implementation of the Ulula worker voice system in two mills and three plantations to identify critical social risks related to palm oil production and conduct analysis of social conflict related to land use'.

136. Details of process for addressing land conflicts available?

137. 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.

138. Commitment to mitigate impacts on food security?

The company is committed to mitigating impacts on food security.

139. 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. The company also reports multiple examples of appropriate activities conducted to mitigate impacts on food security for local communities.

140. Commitment to provide essential community services and facilities?

The company has published a commitment to provide essential services and facilities on its website.

141. 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 progress on providing essential community services on its webpage.

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

143. 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 Core Conventions.

144. 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 Core Conventions. This applies to all suppliers of the company.

145. 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.

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

The company is committed to eliminate gender-related discrimination with regard to employment in its Human Rights Policy.

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

The company reports its commitment in its human rights policy, which applies to all supply chains of the company.

148. 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.

149. Percentage or number of temporary employees?

150. Percentage or number of women employees?

151. Commitment to pay a Decent Living wage?

The company only commits to paying the legal minimum wage.

152. 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.

153. 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.

154. Reporting of salary by gender?

155. Commitment to address occupational health and safety?

The company has a commitment to address occupational health and safety.

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

The company has published a commitment to address occupational health and safety. This commitment applies to all suppliers of the company.

157. 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.

158. Time lost due to work-based injuries?

1.05 - The company states an Injury Frequency Rate (RIFR) of 1.05 for the year 2020.

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

3 - The company reports three fatalities in the fiscal year 2020.

160. Commitment to support smallholders?

The company reports its commitment to supports smallholders in its Sustainable Palm Oil Policy.

161. Programme to support scheme/plasma 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.

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

The company reports to partner with total 22,000 smallholders. Different programs have different number of smallholders involved.

163. Programme to support independent smallholders?

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

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

The company reports in ACOP 2018 that "It has a 2 year contract agreement with about 3,000 independent smallholders located in Ketapang to receive their FFB crop", but a percentage could not be calculated as only an approximate figure is reported.

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

Aggregator/Refiner Transformation (ART) plan, Supplier Assessments, Sustainability improvement programs.

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

50% - The company reports that 50% of its suppliers were conducted field assessments in 2019.

167. 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. However, a time frame of action is not reported by the company.

168. 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 palm oil sourcing commitments.

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

The company only reports the total volume (93%) that is covered by NDPE policy. The proportion of direct and indirect supply is not reported.

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

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

171. 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 Proforest Supplier engagement approach.

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

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

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

The company is using the Global Forest Watch Pro Palm Risk Tool Methodology to categorize the mills from high to low.

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

The company uses Global Forest Watch Pro Palm Risk Tool Methodology to assess the risk levels of mills and reports the percentage or number of low, medium and high-risk mills on an annual basis.

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

The company uses Global Forest Watch Pro Palm Risk Tool Methodology to assess the risk levels of mills and reports the percentage or number of low, medium and high-risk mills on an annual basis.

176. Commitment to ethical conduct and prohibition of corruption?

The company reports its commitment to ethical conduct and prohibition of corruption in its Code of Conduct.

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

The company has published a commitment to ethical conduct and prohibition of corruption, which applies to all suppliers.

178. 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.

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

180. Whistleblowing procedure?

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

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

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

182. Details of complaints and grievances disclosed?

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