COFCO Corp

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's subsidiary has published a sustainable palm oil policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company's subsidiary reports it has a Global Head of Sustainability to oversee sustainability strategy and manage the sustainability team. However, this does not cover all operations.

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

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

The company has published profiles of the senior management team on its website which shows no women on the team. However, the information is undated.

6. Percentage or number of women board members?

The company has published profiles of the Board of directors on its website which shows no women as the board members. However, the information is undated.

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

[Externally verified] The company's subsidiary is a member of UNGC, TFA, and WBCSD.

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

The company's subsidiary has participated in the Palm Oil Collaboration Group (POCG) to accelerate the effective implementation of NDPE commitments and promote sector-wide consistency in measuring and reporting progress and has also signed a memorandum of understanding under the Collaboration for Forests and Agriculture initiative (CFA).

9. Sustainability report published within last two years?

The company published a CSR report in 2020 and its subsidiary published a sustainability report in 2021.

10. Reports through standardised reporting systems?

The company's subsidiary is involved in palm oil operation reports through the GRI standard, Core option. However, the parent company states that its reports are in line with GRI standards but does not specify which kind.

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

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

12. Climate risks assessment available?

13. Lists countries and operations?

The company's subsidiary publishes a map which shows the countries where it operates. However, the nature of the operations are unknown and this does not cover all of the company's operations.

14. Lists countries sourcing 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 scheme smallholders?

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

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

23. Number of company-owned mills?

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

24. Names and locations of company-owned mills?

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

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

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

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

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

27. Number of third party supplying mills?

996 - The company's subsidiary reports that it has 996 supplying mills.

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

The company's subsidiary provides a list of supply chains with coordinates of each mill.

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?

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

The company's subsidiary commits to achieve 100% traceability to mill level by the year 2022 - 2023. This does not cover all sourcing.

33. Percentage of supply traceable to mill level?

The company's subsidiary reports that 87% of the supply is traceable to the mill level, however this does not cover all supply. Additional points have been awarded on the basis of SCC certification.

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

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

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

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

37. Publishes traceability data at refinery level?

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] 2005 - The company is member of the Roundtable on Sustainable Palm Oil (RSPO) since 2005.

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?

2013 - The company is a member of the Roundtable on Sustainable Palm Oil (RSPO) since 2005. However, it received its first RSPO Certification in 2013.

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

The company has submitted its most recent 2021 RSPO ACOP.

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?

2025 - The company commits to achieve 100% RSPO certification of all palm product processing facilities by 2025. This is within 5 years.

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?

[Externally verified] 6.08% - The company handled/traded/processed (tonnes) 6.08% of all palm oil and oil palm products that are RSPO-certified.

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

This indicator is disabled as the company only reports a Processor and Trader ACOP.

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

[Externally verified] The company processes/trades 3.45% RSPO-certified palm oil through Segregated or Identity Preserved supply chains.

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

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

53. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

[Externally verified] The company's subsidiary has ISCC certification and it's Environmental Management System is based on the ISO 14001 standard.

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 deforestation?

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

57. Commitment to zero deforestation applies to all suppliers?

The company's subsidiary commits all suppliers to no development in High Conservation Value (HCV), High Carbon Stock (HCS), and peatland areas. This does not cover all suppliers.

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

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

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

The company's subsidiary only specifies the areas that are not to be deforested and it applies to some but not all of its suppliers. No cut-off date is mentioned.

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

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

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

62. 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.

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

64. Commitment to restoration of deforestation/conversion?

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

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

66. Implementing a landscape or jurisdictional level approach?

The company's subsidiary only reports that it implements a landscape or jurisdictional level approach. However, no detailed information was found.

67. Biodiversity policy?

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

68. Biodiversity policy applies to all suppliers?

69. 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.

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

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

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

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

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

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

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

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

75. 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.

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

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

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

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

78. 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.

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?

80. 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.

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

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

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

The company's subsidiary commits all suppliers to apply the HCS Approach, as defined by the HCS Approach Toolkit. This does not cover all suppliers.

83. High Carbon Stock (HCS) assessments available?

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

84. 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.

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

The company's subsidiary only commits to conduct social and environmental impact assessments prior to all new site construction and acquisition. This does not cover all operations.

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

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

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

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

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

The company's subsidiary commits all suppliers to no planting on peat of any depth. This does not cover all suppliers.

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

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

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

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

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

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

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

The company's subsidiary commits all suppliers to best management practices for soils and peat. This does not cover all suppliers.

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

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

95. Commitment to zero burning?

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

96. Commitment to zero burning applies to all suppliers?

The company's subsidiary commits all suppliers to no burning. This does not cover all suppliers.

97. Evidence of fire monitoring and management?

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

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

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

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

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

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

The company's subsidiary commits to reduce its GHG emissions by 2030. However, this commitment is not target-based, is not specific to palm oil operations, and does not cover all operations.

101. GHG emissions intensity?

The company reports a 39.20 kg CO2eq/tonne processed carbon intensity indicator for the year 2021. However, this information is not specific to palm oil operations and does not cover all operations.

102. GHG emissions from land use change?

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

103. Progress towards commitment to reduce GHG emissions intensity?

The company's subsidiary reports carbon intensity indicator in 2019 as 37.6 kg CO2eq/tonne processed, in 2020 as 35.9 kg CO2eq/tonne processed, and in 2021 as 39.2 kg CO2eq/tonne processed. However, the intensity figures have not improved, are not specific to palm oil operations, and do not cover all operations.

104. Methodology used to calculate GHG emissions?

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

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

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

The company's subsidiary commits to reduce its water intensity by 10% by the year 2025. However, this commitment is not specific to palm oil operations, and does not cover all operations.

107. Water use intensity?

0.56 - The company's subsidiary reports its water use intensity for 2021 as 0.56 (m3 /tonne of production). However, this data is not specific to palm oil operations, and does not cover all operations.

108. Progress towards commitment on water use intensity?

The company's subsidiary reports its water usage intensity in 2019 as 0.58 (m3 /tonne of production), in 2020 as 0.59 (m3 /tonne of production), and in 2021 as 0.56 (m3 /tonne of production). This is not specific to palm oil operations and does not cover all operations.

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)?

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

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

The company's subsidiary reports to treat PORE.

113. Commitment to protect natural waterways through buffer zones?

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

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

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

115. 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.

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

The company's subsidiary only commits to minimise the use of pesticides, however this does not cover all suppliers.

117. Commitment to no use of paraquat?

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

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

The company's subsidiary commits all suppliers to not use paraquat. This does not cover all suppliers.

119. 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.

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

The company's subsidiary commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides. This does not cover all suppliers.

121. 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.

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

The company's subsidiary commits suppliers to not use Stockholm and Rotterdam Convention chemicals. This does not cover all suppliers.

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

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

124. Implementation of commitment to minimise inorganic fertiliser use?

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

125. Integrated Pest Management (IPM) approach?

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

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

The company's subsidiary reports a plastic recycling scheme and states that in 2021, 53% of its waste was either recycled, reused, composted or recovered.

127. Commitment to human rights?

The company's subsidiary commits to the Universal Declaration of Human Rights. This does not cover all operations.

128. Commitment to human rights applies to all suppliers?

The company's subsidiary commits suppliers to the UN Guiding Principles on Business and Human rights. This does not cover all suppliers.

129. Progress on human rights commitment?

The company's subsidiary reports that it has conducted a human rights risk assessment of suppliers, however limited details are provided.

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

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

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

The company's subsidiary commits suppliers to indigenous and local communities' rights in relation to land tenure and FPIC, no reference is made to the UN Declaration on the Rights of Indigenous Peoples or ILO Indigenous and Tribal Peoples Convention (no. 169). This does not cover all suppliers.

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

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

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

The company's subsidiary commits suppliers to respect legal and customary land tenure rights. This does not cover all suppliers.

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

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

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

The company's subsidiary commits all suppliers to respect FPIC. This does not cover all suppliers.

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

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

137. Examples of local stakeholder engagement to prevent conflicts?

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

138. Details of process for addressing land conflicts available?

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

139. 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.

140. Commitment to mitigate impacts on food security?

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

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

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

142. Commitment to provide essential community services and facilities?

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

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

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

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

This indicator is disabled as the company is not a grower or miller.

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

The company's subsidiary commits to all Fundamental ILO Conventions. This does not cover all operations.

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

The company's subsidiary commits all suppliers to all Fundamental ILO Conventions. This does not cover all suppliers.

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

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

The company's subsidiary commits to prevent employment-related discrimination based on gender. This does not cover all operations.

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

The company's subsidiary commits all suppliers to prevent employment-related discrimination based on gender. This does not cover all suppliers.

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

The company's subsidiary reports that in 2021, it launched an internal procedure with guidelines to help increase trust in the Hotline as a mechanism for reporting discrimination and harassment issues. However, only limited details were provided.

151. Percentage or number of temporary employees?

The company's subsidiary reports temporary employees, however this does not cover all operations.

152. Percentage or number of women employees?

The company's subsidiary reports the number of female employees in its workforce, however this does not cover all operations.

153. Commitment to pay a Decent Living wage?

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

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

156. Reporting of salary by gender?

157. Commitment to address occupational health and safety?

The company and its subsidiary commit to address health and safety at work for all workers.

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

The company's subsidiary commits all suppliers to address health and safety at work for all workers. This does not cover all suppliers.

159. Provision of personal protective equipment and related training?

The company's subsidiary reports that it provides training to employees and on-site contractors on applicable health and safety laws, regulations, and procedures, and provides the necessary personal protective equipment. However, the information is between two to five years and does not cover all operations.

160. Time lost due to work-based injuries?

0.3 - The company's subsidiary reports its lost-time injury frequency rate as 0.30 in 2021. However, this does not cover all operations and it is unclear if it is for palm oil operations only.

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

0 - The company's subsidiary reports 0 fatalities in 2021. However, this does not cover all operations and it is unclear if it is for palm oil operations only.

162. Commitment to support smallholders?

The company's subsidiary states supporting smallholders. However, it is unclear whether it includes both plasma and scheme smallholders. This does not cover all operations.

163. Programme to support scheme smallholders?

The company's subsidiary states that it empowers smallholder farmers to adopt sustainable practices, continue to monitor its impact on local communities, raise their employment prospects, improve lives through relevant social programmes, and contributed with the acquisition and donation of seedlings to allow farmers to overcome supply challenges. However, it is unclear what type of smallholders and no details are given.

164. Percentage of scheme smallholders involved in programme?

36000 - The company's subsidiary reports that around 36,000 smallholders benefited from its community programmes. However, it is unclear what type of smallholders figure refers to. This does not cover all operations.

165. Programme to support independent smallholders?

The company's subsidiary states that it empowers smallholder farmers to adopt sustainable practices, continue to monitor its impact on local communities, raise their employment prospects, improve lives through relevant social programmes, and contributed with the acquisition and donation of seedlings to allow farmers to overcome supply challenges. However, it is unclear what type of smallholders and no details are given. This does not cover all operations.

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

36000 - The company's subsidiary reports that around 36,000 smallholders benefited from its community programmes. However, it is unclear what type of smallholders figure refers to. This does not cover all operations.

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

The company's subsidiary reports rating supplier performance against company policy "every two years using supplier scorecards (with the most recent evaluation in 2019), prioritising suppliers with lower performance scores for improvement effort". However, this does not cover all operations and suppliers.

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

The company's subsidiary reports that 97% of suppliers were assessed in 2021. This does not cover all operations.

169. Suspension or exclusion criteria for suppliers?

The company's subsidiary states to terminate the business relationship in case of any failure or unwillingness to implement its sourcing policy. However, no steps to be taken, and a time frame for action is given. This does not cover all suppliers.

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

The company's subsidiary has published its action plans including KPIs for suppliers to be in compliance with palm oil sourcing policy and time-bound action plans for suppliers to be in compliance with NDPE policy. This does not cover all suppliers.

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

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

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

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

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

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

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

178. Commitment to ethical conduct and prohibition of corruption?

The company's subsidiary commits to ethical conduct and the prohibition of corruption. This does not cover all operations.

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

The company's subsidiary commits all suppliers to ethical conduct and the prohibition of corruption. This does not cover all suppliers.

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

The company's subsidiary reports that it provides training to employees with a particular focus on topics including anti-bribery and corruption.

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

182. Whistleblowing procedure?

The company's subsidiary states that it has a whistleblowing procedure and a detailed "Integrity Hotline Procedure", which includes information on how whistleblowers are protected. However, it does not cover all company's operations.

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

The company's subsidiary has its own grievance or complaints system with flowchart which is open to all stakeholders. This does not cover all operations.

184. Details of complaints and grievances disclosed?

The company's subsidiary only provides a summary table on the number and type of grievances.