Commodities House Investments Ltd (HSA Group)

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

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

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

The company has published a sustainable palm oil policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company's subsidiary, Pacific Inter-Link, covers all sister companies and reports that the group managing director is responsible for overall management and holds the highest position in sustainability-related decisions.

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

This indicator has been disabled as the company is not publicly listed and does not have a board.

5. Reports gender balance of senior management team?

10% - The company reports that 10% of its senior management team are women.

6. Reports gender balance of board members?

This indicator has been disabled as the company is not publicly listed and does not have a board.

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

[Externally verified] The company's subsidiary, PIL, is a member of the Palm Oil Collaboration Group and UNGC.

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

9. Sustainability report published within last two years?

The company's subsidiary, Pacific Inter-Link Group, has published a sustainability report for 2022 that covers all sister companies.

10. Reports through standardised reporting systems?

The company's subsidiary, Pacific Inter-link Group, has published its sustainability report for 2022 that covers all sister companies. However, the report only states that it has been prepared in accordance with the GRI standards.

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?

Malaysia & Indonesia - (Four refineries).

14. Lists countries sourcing from?

The PIL Group reports that it sources indirectly from third-party mills located in Malaysia and Indonesia.

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

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

16. Total oil palm planted area (ha)?

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

17. Scheme smallholders planted area (ha)?

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

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

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

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

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

20. Maps of estates/management units?

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

21. Maps of all scheme smallholders?

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

22. Maps of all third-party supplying plantations?

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?

1407 - The company's subsidiaries, including Pacific Inter-Link Sdn Bhd, Pacific Oils & Fats Industries Sdn Bhd, PT. Pacific Medan Industri, PT. Pacific Palmindo Industri, PT. Pacific Indopalm Industries, and PT. Oleochem & Soap Industri, have published lists of all the third-party supplying mills.

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

The company's subsidiaries, including Pacific Inter-Link Sdn Bhd, Pacific Oils & Fats Industries Sdn Bhd, PT. Pacific Medan Industri, PT. Pacific Palmindo Industri, PT. Pacific Indopalm Industries, and PT. Oleochem & Soap Industri, have published the names and coordinates of all third-party supplying mills.

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

The company reports the percentage of third-party supplying mills that source from their own plantations and third-party plantations for each of its entities.

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

The company reports the percentage of FFB sourced from third-party supplying mills that come from their own operations and third parties for each of its entities.

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

The company's subsidiaries (Pacific Inter-Link Sdn Bhd, Pacific Oils & Fats Industries Sdn Bhd, PT. Pacific Medan Industri, PT. Pacific Palmindo Industri, PT. Pacific Indopalm Industries, and PT. Oleochem & Soap Industri) have published the percentage of volume sourced from direct mills and indirect traders for each sister company. However, the overall total volume sourced could not be calculated.

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

The company has already achieved 100% traceability to mill level.

33. Percentage of supply traceable to mill level?

The company's subsidiary, PIL group, states that all sister companies have already achieved 100% traceability to mill level. Additional points have been awarded based on RSPO SCC SG certification.

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

The company commits to achieve 100% traceability to plantation level by the year 2025.

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

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

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

The company's subsidiary, PIL group, states that all sister companies have achieved 66.63% traceability to plantation level.

37. Publishes traceability data at refinery level?

The company reports the percentage of supply traceable to plantation level per refinery for all four refineries.

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] 2009 - The subsidiaries Pacific Inter-Link Sdn. Bhd., Pacific Oils & Fats Industries Sdn. Bhd., PT. Pacific Palmindo Industri, PT. Pacific Indopalm Industries, PT. Pacific Medan Industri, and PT. Oleochem & Soap Industri are RSPO members operating under the name Commodities House Investments Limited.

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] 2015 - The group's sister companies were separate RSPO members before 2019. One of the sister companies, PT. Pacific Medan Industri, became RSPO-certified within three years of joining the RSPO (in 2015).

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

The company has submitted its latest RSPO ACOP 2023.

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?

2019 - The company has already achieved 100% RSPO-certification of all palm product processing facilities.

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

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

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

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

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

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

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

2.75% - The company reports that 2.75% of all palm oil and oil palm products that are handled/traded/processed (tonnes) are RSPO-certified.

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

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

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

The company reports that 0% of RSPO-certified palm oil is processed/traded 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?

[Externally verified] The Pacific Oils & Fats Industries Sdn. Bhd is MSPO certified. However, the PIL group is not an MSPO member as it is a trader.

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

[Externally verified] The company's subsidiaries (Pacific Oils & Fats Industries Sdn. Bhd and PT Pacific Indopalm Industries) are ISCC certified.

55. Commitment to zero conversion of natural ecosystems?

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

56. Commitment to zero conversion of natural ecosystems applies to all suppliers?

The company states that it expects its suppliers to adhere to zero conversion of natural ecosystems. This commitment is unclear.

57. Commitment to zero deforestation?

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

58. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation. However, this commitment has been placed after 1 Jan 2020.

59. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

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

60. Criteria and cut-off date for defining deforestation and/or ecosystem conversion in supplier operations?

The company defines deforestation for suppliers as removal of HCV and HCS areas and specifies any deforestation/conversion past 2021 will not be accepted in supplier operations.

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

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

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

The company reports that it uses satellite imagery, specifically palmoil.io, to monitor deforestation within its supplier operations. Palmoil.io provides real-time monthly deforestation notifications, which the company uses to engage with non-compliant suppliers. The company monitors 10.3932 million ha of its suppliers' operations in Malaysia and 30.6361 million ha in Indonesia.

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

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

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

0 (0%) - The PIL group has reported zero ha of total non-compliant deforestation since the cut-off date of 2021. This data covers all sister companies.

65. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

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

66. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

The company commits suppliers to restore ecosystems to their prior condition in cases of deforestation within their own operations.

67. Implementing a landscape or jurisdictional level approach?

68. Biodiversity policy?

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

69. Biodiversity policy applies to all suppliers?

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

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

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

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

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

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

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

The company commits all suppliers to only allow sustainable hunting of species by local communities for subsistence purposes in their operations.

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

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

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

The company commits all suppliers to conduct HCV assessments.

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

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

77. High Conservation Value (HCV) assessments for all estates planted/planned planting since January 2015?

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

78. High Conservation Value (HCV) or combined HCV/HCS management and monitoring plans for all estates planted/planned planting since January 2015?

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

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

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

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

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

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

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

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

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

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

The company commits all suppliers to apply the HCS Approach, as defined by the HCS Approach Toolkit.

84. High Carbon Stock (HCS) assessments available?

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

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

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

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

The company commits to conduct social and environmental impact assessments.

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

The company commits all suppliers to conduct social and environmental impact assessments.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

96. Commitment to zero burning?

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

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

98. Evidence of fire monitoring and management?

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

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

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

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

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

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

All of the company's sister companies report different time-bound commitments to reduce their GHG emission intensity, including Scope 1 and Scope 2 emissions.

102. GHG emissions intensity?

The company reports the GHG emission intensity for five entities in kg CO2e/MT of CPO processed in 2022.

103. GHG emissions from land use change in company's own operations (scope 1)?

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

104. GHG emissions from land use change in supplier operations (scope 3)?

105. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports an increase in GHG emission intensity at Pacoil, from 43.03 CO2e/MT of CPO processed in 2021 to 44.39 CO2e/MT of CPO processed in 2022, and at Indopalm, from 23.00 CO2e/MT of CPO processed in 2021 to 31.99 CO2e/MT of CPO processed in 2022. This information is externally verified by the Control Union but does not cover all palm oil operations.

106. Methodology used to calculate GHG emissions?

The company uses the ISCC GHG methodology to calculate GHG emissions.

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

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

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

The sister companies with refining operations report varying time-bound commitments to improve water use intensity by the year 2030 from a baseline of 2022.

109. Water use intensity?

3.81 - The water consumption intensity for all sister companies with refining operations was 3.81 m3/MT of CPO processed in 2022.

110. Progress towards commitment on water use intensity?

[Externally verified] The PIL Group reports a decrease in water intensity across all refineries, from 3.88 m³/MT of CPO processed in 2021 to 3.81 m³/MT of CPO processed in 2022. This information is externally verified by the Control Union.

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

The company's BOD and COD levels are within legal limits.

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

[Externally verified] The PIL Group reports that the BOD levels of all sister companies were within the legal limits of their respective regions in 2022. This information is externally verified by the Control Union.

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

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

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

[Externally verified] The PIL Group reports that all refineries use biological and chemical processes to maintain pollutant levels within regulatory thresholds. They employ aeration, coagulation, and filtration treatment methods to treat PORE before discharging it into waterways.

115. Commitment to protect natural waterways through buffer zones?

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

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

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

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

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

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

The company commits all suppliers to minimise the use of chemical fertilisers and pesticides.

119. Commitment to no use of paraquat?

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

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

The company commits all suppliers to only use paraquat in exceptional circumstances.

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

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

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

The company commits all suppliers to only use World Health Organisation (WHO) Class 1A and 1B pesticides in exceptional circumstances.

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

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

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

The company commits suppliers to only use Stockholm and Rotterdam Convention chemicals in exceptional circumstances.

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

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

126. Implementation of commitment to minimise inorganic fertiliser use?

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

127. Integrated Pest Management (IPM) approach?

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

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

[Externally verified] The company has a waste management system to handle both scheduled and non-scheduled waste. It reports that all waste types are disposed of through licensed contractors approved by national authorities and verified by government bodies. This information is externally verified by the Control Union.

129. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

130. Commitment to human rights applies to all suppliers?

The company commits suppliers to the Universal Declaration of Human Rights.

131. Progress on human rights commitment?

[Externally verified] The company reports that it conducted a sustainability awareness talk under the 'Social Sustainability' module, communicated to all personnel across all departments. Additionally, it organises workshops to highlight the content of the Universal Declaration of Human Rights (UDHR) and to raise awareness of human rights. This information is externally verified by the Control Union.

132. Commitment to respect Indigenous Peoples' and local communities' rights?

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

133. Commitment to respect Indigenous Peoples' and local communities' rights applies to all suppliers?

The company commits suppliers to the UN Declaration on the Rights of Indigenous Peoples.

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

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

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

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

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

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

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

The company commits all suppliers to respect FPIC.

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

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

139. Examples of local stakeholder engagement to prevent conflicts?

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

140. Details of process for addressing land conflicts available?

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

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

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

142. Commitment to mitigate impacts on food security?

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

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

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

144. Commitment to provide essential community services and facilities?

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

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

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

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

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

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

The company commits to five Fundamental ILO conventions only.

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

The company commits all suppliers to five Fundamental ILO Conventions only.

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

[Externally verified] The company reports that it provides workers' rights training to its employees to prevent inequity, discrimination, and harassment in the workplace. As of 2022, all employees across the PIL Group have attended in-house training on labor rights. This information is externally verified by Control Union.

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

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

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

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

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

[Externally verified] The company reports that it provides workers' rights training to its employees to prevent inequity, discrimination, and harassment in the workplace. This information is externally verified by Control Union.

153. Percentage or number of temporary employees?

60 (3%) - The PIL Group reports the number of temporary employees for all six sister companies as 60 (3%) in 2022.

154. Reports gender balance of employees?

329 (18%) - The PIL Group reports the number of female employees for all six sister companies as 329 (18%) in 2022.

155. Commitment to pay a living wage?

All six sister companies commit to paying at least the minimum wage to all workers.

156. Commitment to pay a living wage applies to all suppliers?

All six sister companies commit all suppliers to pay the minimum wage.

157. Progress on commitment to pay a living wage?

[Externally verified] The company provides evidence that its workers in Malaysia and Indonesia receive wages above the minimum wage requirements for those regions. This information is externally verified by Control Union.

158. Reporting of salary by gender?

The company reports that women and men are paid on a 1:1 ratio across all employment categories and function.

159. Commitment to address occupational health and safety?

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

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

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

161. Provision of personal protective equipment and related training?

[Externally verified] The company reports that it provides personal protective equipment (PPE) and related safety training to all employees. The information is externally verified by Control Union.

162. Time lost due to work-based injuries?

The PIL Group reports the lost time accident rates for each sister company individually. However, the consolidated figure combining these rates was not provided. Calculated as recordable accident x 1,000,000/total working hours.

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

0 - The PIL Group reports that there were no fatalities reported in 2022 across all entities.

164. Commitment to support smallholders?

The company has published a commitment to support smallholders.

165. Programme to support scheme smallholders?

The sister companies commit to supporting smallholders' livelihoods through initiatives such as implementing good agricultural practices, certification processes, and programmes aimed at improving yields. However, they have not specified the specific types of smallholders supported, and the information provided is not dated.

166. Percentage of scheme smallholders involved in programme?

167. Programme to support independent smallholders?

The sister companies commit to supporting smallholders' livelihoods through initiatives such as implementing good agricultural practices, certification processes, and programmes aimed at improving yields. However, they have not specified the specific types of smallholders supported, and the information provided is not dated.

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

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

The company reports the methods used to prioritise, assess and/or engage suppliers on legal and policy compliance.

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

[Externally verified] 365 (95%) - The PIL Group reports that as of December 2022, 365 mill suppliers have signed the supplier code of conduct to commit only to NDPE commitments.

171. Suspension or exclusion criteria for suppliers?

The PIL Group reports that those suppliers who do not comply with its sustainable palm oil sourcing policy are subjected to its grievance procedure and if they fail to respond to the grievance procedure then the contract will be terminated, this includes timeframes for action.

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

The company states that it has set a time-bound commitment to ensure all its suppliers are NDPE compliant by 2030.

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

The company reports that in 2022, 55.4% of FFB sourced directly and indirectly from third parties have been verified as deforestation-free.

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

The company reports that it aims to engage with all high risk mills within a three year period.

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

The company reports that it has a Supplier Outreach & Engagement Program (SOEPro) to support suppliers on areas they have reported poorly, including providing guidance to establish policies, technical advice, manage grievances, and rectify non-compliance.

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

The company reports that it engages with high-risk mills annually.

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

The company reports that it uses information from its NDPE profile and palmoil.io to categorise each company's risk level.

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

The company reports that it assesses and categorises supplying mills on an annual basis.

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

In 2022, the company assessed the risk levels of all its supplying mills, finding that 64.4% were classified as low risk, 19.3% as medium risk, and 16.3% as high risk.

180. Commitment to ethical conduct and prohibition of corruption?

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

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

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

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

[Externally verified] The company reports that it includes anti-corruption training as part of its new orientation program for workers, addressing policy and procedures that cover 13 company policies, including anti-corruption measures. This information is externally verified by the Control Union.

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

The company has published a tax policy which covers all sister companies and reports that the Corporate Finance and Accounting Department is responsible for tax payments to governments.

184. Whistleblowing procedure?

The company reports that in 2014, it established an internal whistleblowing policy for its employees and stakeholders. However, no details on the process are available.

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

The PIL Group has its own grievance system open to all stakeholders. It covers all six entities.

186. Details of complaints and grievances disclosed?

[Externally verified] The PIL Group maintains a grievance tracker on its website, detailing complaints and grievances recorded up until 2024. This also covers all sister companies.