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-Interlink covers all sister companies and reports that the group managing director is responsible for the 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. Percentage or number of women in senior management team?

9 (25%) - The company reports 9 women in its senior management teams out of a total of 36 people.

6. Percentage or number of women 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] Palm Oil Collaboration Group (POCG).

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-Interlink has published its Sustainability Report 2020 & 2021 which covers all sister companies.

10. Reports through standardised reporting systems?

The company's subsidiary Pacific-Interlink has published its Sustainability Report 2020 & 2021 which covers all sister companies. However, it only states that the report has been prepared in accordance with the GRI Standards but it's unclear if prepared in accordance with GRI Core or Comprehensive 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 - Refineries.

14. Lists countries sourcing from?

The PIL Group reports that it sources indirectly from third-party mills across Malaysia and Indonesia, however this does not clearly cover all sister companies.

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?

The company's subsidiaries, Pacific Oils & Fats Industries Sdn Bhd, PT. Pacific Medan Industri, PT. Oleochem and Soap Industri, PT Pacific Indopalm Industries, PT. Pacific Palmindo Industri has published the mills' list, however, no list for PIL Group external suppliers was found.

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

The company's subsidiaries, Pacific Oils & Fats Industries Sdn Bhd, PT. Pacific Medan Industri, PT. Oleochem and Soap Industri, PT Pacific Indopalm Industries, PT. Pacific Palmindo Industri has published the mills' list, however, no list for PIL Group external suppliers was found.

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

The company reports this information for each of its entities apart from PT Oleochem & Soap Industri.

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 this information for each of its entities apart from PT Oleochem & Soap Industri.

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, PIL Group sister companies, Pacific Oils & Fats Industries Sdn Bhd, PT Pacific Indopalm Industries, PT. Pacific Palmindo Industri, PT. Pacific Medan Industri, and PT. Oleochem and Soap Industri have published the percentage of volume sourced from direct mills and indirect traders for each sister company, no total could be calculated.

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

The PIL dashboard states all sister companies have 100% traceability to the mill level.

33. Percentage of supply traceable to mill level?

The PIL dashboard states all sister companies have 100% traceability to mill level.

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

All of the company's subsidiaries have a time-bound commitment to achieve 100% traceability to plantation level by 2025.

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

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

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

The companies reports a combined traceability percentage to plantation of 34.98%.

37. Publishes traceability data at refinery level?

The company reports this information for each of its entities apart from PT Oleochem & Soap Industri.

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 - Pacific Inter-Link Sdn. Bhd., Pacific Oils & Fats Industries Sdn. Bhd., PT. Pacific Palmindo Industri, PT. Pacific Indopalm Industries, PT. Pacific Medan Industri, PT. Oleochem & Soap Industri are subsidiaries of the group which are RSPO members 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)?

Pacific Inter-Link Sdn. Bhd., Pacific Oils & Fats Industries Sdn. Bhd., PT. Pacific Palmindo Industri, PT. Pacific Indopalm Industries, PT. Pacific Medan Industri, PT. Oleochem & Soap Industri are subsidiaries of the group which are RSPO members under the name Commodities House Investments Limited. A 2021 ACOP was submitted.

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?

[Externally verified] 1.75% - The company reports that 1.75% of all palm oil and oil palm products 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 only reports a Processor and Trader ACOP.

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] Pacific Oils & Fats Industries Sdn. Bhd is MSPO certified. However, PIL group is not able to become a member as it is a trader.

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

[Externally verified] PT. Pacific Indopalm Industries and Pacific Oils & Fats Industries Sdn. Bhd 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 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 commits all suppliers to zero deforestation.

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 defines deforestation for suppliers as the removal of HCV and HCS areas and specifies any deforestation/conversion past July 2018 will not be accepted in supplier operations.

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?

One of the company's subsidiaries Pacoil has commenced a collaboration with Earthworm Foundation in 2021 to monitor supplier compliance against NDPE commitments. It also assists in quarterly reporting of high-risk suppliers associated with potential deforestation. However, the extent of area being monitored for deforestation and time frame is unclear.

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?

The PIL group has reported 0 ha of total non-compliant deforestation and that this data covers all sister companies. However, this is not clearly since the cut-off date of July 2018.

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?

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?

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

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?

The company commits all suppliers to conduct HCV assessments.

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

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?

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

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

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?

These assessments must be led by licensed HCV assessors accredited by the HCV
Resource Network's Assessor Licensing Scheme (HCVRN-ALS) and HCSA registered
practitioners. HCS areas are protected using Carbon Stock Approach as defined by the
HCS Approach Toolkit.

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)?

86. 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.

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

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 companies commit all suppliers to best management practices for soils and peat.

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 commits all suppliers to no burning.

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?

Four of the sister companies report varying time-bound commitments to reduce its 'carbon footprint'. The commitments are not intensity based.

101. GHG emissions intensity?

The GHG emission at Pacific Oils & Fats Industries Sdn Bhd is 43.03 CO2 e/MT of CPO processed in 2021and in Indonesia, PT. Pacific Indopalm Industries measures GHG emission at 21.7 CO2 e/MT of CPO processed in 2021. However, it does not cover all palm oil 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 GHG emissions were reduced by 12.9 % at Pacific Oils & Fats Industries Sdn Bhd and 0.9% at PT. Pacific Indopalm Industries. However, it does not cover all palm oil operations and no time-bound target is provided.

104. Methodology used to calculate GHG emissions?

The company uses the ISCC GHG calculation methodology 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 sister companies with refining operation report time-bound commitments to reduce water use intensity by varying percentages.

107. Water use intensity?

Each sister company reports water use intensity for the year 2021.

108. Progress towards commitment on water use intensity?

PIL Group reports water intensity across all refineries was 2.0m3/MT CPO processed in 2021 compared to 3.7m3/MT CPO processed in 2020.

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

All sister companies report a target to maintain BOD and COD levels within the legal limits which the companies are already achieving.

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

All sister companies report BOD and COD levels which are within the stated legal limits.

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 PIL Group reports that all four refineries treat PORE before discharging into waterways. The company states that this information is externally verified by annual certification audits and the Malaysian Ministry of Health, but not evidence of this verification is provided.

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

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 commits all suppliers to only use paraquat in exceptional circumstances.

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

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

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 companies report a waste management system in place that covers various aspects of production and processing to ensure that waste storage, treatment, and disposal practices do not pose health or safety risks to workers. The company states that this information is externally verified by annual certification audits and the Malaysian Ministry of Health, but no evidence of this verification is provided.

127. Commitment to human rights?

The companies commit to the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

The companies commit suppliers to the Universal Declaration of Human Rights.

129. Progress on human rights commitment?

The companies report that employees are given training on human rights but no details are provided.

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

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

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

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

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 commits suppliers to respect legal and customary land tenure rights.

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

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

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

The company commits all suppliers to respect FPIC.

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

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

137. Examples of local stakeholder engagement to prevent conflicts?

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

138. Details of process for addressing land conflicts available?

This indicator is disabled as the company is only a refiner or 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 companies commit to five of eight Fundamental ILO Conventions.

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

The companies commit suppliers to five out of eight Fundamental ILO Conventions.

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

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

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

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

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

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

The companies report to conduct training to prevent discrimination and harassment, but no details are provided.

151. Percentage or number of temporary employees?

238 (11.35%) - PIL Group reports the number of temporary employees for all six sister companies as 343 employees.

152. Percentage or number of women employees?

346 (16.5%) - PIL Group reports the number of female employees for all six sister companies on its website.

153. Commitment to pay a Decent Living wage?

All six sister companies commit to pay the minimum wage.

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

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

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

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

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

159. Provision of personal protective equipment and related training?

The companies report that they provide PPE and related training.

160. Time lost due to work-based injuries?

PIL Group reports the lost time accident rate of each sister subsidiary company respectively. However, the consolidated figure was not provided.

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

0 - PIL Group reports that there were ""no fatalities reported in 2021 across all our entities"".

162. Commitment to support smallholders?

All six of the company's sister companies commit to support scheme and independent smallholders.

163. Programme to support scheme smallholders?

PT OSI commits to support smallholders' livelihoods through "programs such as yield improvement programs, guideline, responsible farm development and etc". The company does not specify which type of smallholders are supported. This information is undated.

164. Percentage of scheme smallholders involved in programme?

165. Programme to support independent smallholders?

PT OSI commits to support smallholders' livelihoods through "programs such as yield improvement programs, guideline, responsible farm development and etc". The company does not specify which type of smallholders are supported. This information is undated.

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

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

The companies report that they have implemented standard operating procedures to to verify and monitor new and existing suppliers against its NDPE policy commitments. The details of these processes are not reported.

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

259 (83%) - PIL Group reports that as of December 2021, 259 out of 311 mill suppliers have signed the supplier code of conduct to commit only to NDPE commitments.

169. Suspension or exclusion criteria for suppliers?

The PIL Group only states criteria with no timeframes for action or steps taken.

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

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

One of the sister companies reports that 29 supplying mills were complaint with sourcing policies in 2021 through a self-assessment, it is not clear what percentage this accounts for. This does not cover all operations.

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

One of the sister companies reports that it will engage with all high risk mills within 3 years, however this does not cover all operations.

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

One of the company's entites reports having a self-Assessment platform "to measure the compliance level of their operations with Pacoil's - No Deforestation, No Peat and No Exploitation commitments.The outcome from the Self-Assessment is captured in a system, which acts as a guidance for our suppliers to further focus on the areas which they had scored poorly. The system is an interactive platform that provides suggestions to our suppliers to improve their scores". However, this does not cover the whole scope of company operations.

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

One of the company's entites reports that it engages with high-risk mills annually, however this does not cover the full scope of the company's operations.

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

One of the company's entities reports using a self-assessment tool to prioritise supplying mills as high, medium and low risk. Partial points have been awarded as this is based on self-assessment by suppliers and does not cover all of the company's supplying mills.

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

One of the company's entities reports using a self-assessment tool to prioritise supplying mills as high, medium and low risk on an annual basis. Partial points have been awarded as this is based on self-assessment by suppliers and does not cover all of the company's supplying mills.

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

One of the sister companies assesses mill risk level on an annual basis. This does not cover all supplying mills.

178. Commitment to ethical conduct and prohibition of corruption?

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

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

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

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

The company reports that its Code of Conduct and Business Ethics has been shared with all staff at one of its entities with employee engagement to ensure familiarity, however no further details are given.

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

One of the sister companies reports that the Corporate Finance and Accounting Department is responsible for tax payments to governments. No tax policy is reported and this does not cover all operations.

182. Whistleblowing procedure?

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

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

PIL Group has its own grievance system open to all stakeholders including a flowchart and steps of the procedure that cover grievances from all stakeholders in relation to the operations of PIL, its sister refineries and its suppliers.

184. Details of complaints and grievances disclosed?

PIL Group has a grievance tracker on its website with the details of complaints and grievances up until 2022. This also covers all sister companies.