Daabon Group

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

The company meets this indicator through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company has also published numerous policies covering issues related to the environment and society.

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

The company's corporate social responsibility, environmental sustainability, and human rights policies apply to suppliers.

3. High-level position of responsibility for sustainability?

Director of Sustainability.

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

Executive Corporate VP is responsible for Sustainability.

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

45.4% - The company reports 45.4% of its senior management team is made up of women.

6. Percentage or number of women board members?

2 - The company report 2 women board members.

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

[Externally verified] Member of POIG and signatory of UNGC.

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

The company works with local government, NGOs and Universities to improve the sustainability of crop production.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2019 and covers the period 2012-2018.

10. Reports through standardised reporting systems?

The company's latest sustainability report is reported to be "prepared according to GRI Standards: Essential Option", the company includes the GRI index for the core options.

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

[Externally verified] The company is a POIG member and verification reports have been published.

12. Climate risks assessment available?

The company publishes some information on climate risk in its CDP questionnaire.

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

13,384 - Data as of 2020.

14. Total oil palm planted area (ha)?

10,016.5 - The company has a planted area of 6925.4 ha, with an additional 3091.1 ha for smallholders, totalling 10,016.5 ha. This data is between two and five years old.

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

1,727.65 - Data as of 2020.

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

2,807.77 - Data as of 2020.

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

1,164.3 - Data as of 2020.

18. Maps of estates/management units?

Concession boundaries have been made available to the RSPO.

19. Maps of scheme/plasma smallholders?

The company provides a Google Earth Pro link which contains smallholder maps.

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

The company has published a list with the names and coordinates of all third-party supplying plantations.

21. Number of company-owned mills?

2 - The company reports to own two mills in its most recent RSPO ACOP.

22. Names and locations of company-owned mills?

Locations are available on RSPO certificates.

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

One mill (C.I. Tequendama) sources from company-owned and third party operations, while the other (Palma y Trabajo) sources only from company-owned operations.

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

The C.I. Tequendama mill sources 24% of FFB from suppliers and the rest from company-owned operations, while the Palma y Trabajo mill only sources from company-owned operations. Data as of 2019.

25. Number of third party supplying mills?

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

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

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

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

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

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

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

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

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

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

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

31. Percentage of supply traceable to mill level?

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

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

The company makes this commitment through commitment to the POIG charter. Full points have therefore been awarded on the basis of the company's POIG verification.

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

The company states all supply is traceable. Its two mills are certified as Identity Preserved, therefore additional points have been awarded.

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

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

35. Publishes traceability data at refinery level?

All sourcing is from company plantations or associated smallholders and is traceable to plantation level. Information is not externally verified.

36. Publishes traceability data at crusher level?

The company states that its crushing capacity is exclusively dedicated to its own operation and is 100% RSPO IP certified.

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

[Externally verified] 2,004 - The company changed from single membership in 2004 to group membership in 2012.

38. RSPO-certified within three years of joining the RSPO or by November 2010, for companies joining prior to finalisation of the RSPO certification systems in November 2007?

[Externally verified] 2,010 - The company's first certification was achieved in 2010.

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

2020 RSPO ACOP has been submitted.

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

Colombia.

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

[Externally verified] 100% - Data as of 2020.

42. Percentage of mills RSPO-certified?

[Externally verified] 100% - The company's two mills are RSPO certified.

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

2,018 - The company achieved 100% RSPO certification in 2018.

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

2,018 - The company achieved 100% RSPO certification in 2018 for all its palm product processing facilities.

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

[Externally verified] 100% - All scheme smallholders are RSPO certified.

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

2,024 - The company states that by 2024 all the scheme smallholders will be RSPO certified. It is also to be noted that 100% of the landbank held by the smallholders is already RSPO certified.

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

None of the company's supply from independent smallholders/outgrowers/third-party suppliers is RSPO-certified.

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

38.74% - Data as of 2020.

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

The company sold 57.42% of its palm oil through IP supply chains in 2020.

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

The company reports that it process/trades 38.5% of its RSPO certified palm oil through Identity Preserved supply chains.

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

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

52. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

[Externally verified] SAN.

54. Commitment to zero conversion of natural ecosystems?

The company makes this commitment in its Environmental Sustainability Policy.

55. Commitment to zero deforestation?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also commits to zero deforestation independently.

56. Commitment to zero deforestation applies to all suppliers?

The company has published this commitment.

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

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

58. Evidence of monitoring deforestation?

[Externally verified] The company uses GIS software, WRI monitoring tools and drones to monitor deforestation. An area of 16,8005 ha is covered, monitoring takes place on a monthly basis and comparisons are made yearly.

59. Evidence of monitoring deforestation in supplier operations?

[Externally verified] Supplying smallholders are monitored using the same techniques as company estates.

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

0 - No illegal/non-compliant deforestation had been recorded as of September 2019. Data is over 2 years old.

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

0 (0%) - No illegal/non-compliant deforestation had been recorded as of September 2019. Data is over 2 years old.

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

The company commits to restoring all non-compliant conversion of HCV, HCS and natural ecosystems since 2011.

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

The company commits to restoring all non-compliant conversion of HCV, HCS and natural ecosystems since 2011.

64. Implementing a landscape or jurisdictional level approach?

The company commits to implementing a landscape level approach and is contributing to the creation of a water authority for the sustainable use of water for crops. Information is not externally verified.

65. Biodiversity policy?

The company commits to protection of biodiversity both within conservation areas and operational areas.

66. Biodiversity policy applies to all suppliers?

The company commits its suppliers to the protection of biodiversity both within and beyond HCV areas.

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

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

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

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

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

The company prohibits hunting.

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

The company's own commitment is extended to suppliers.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also reports this commitment independently.

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

The company's own commitment is extended to suppliers.

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

[Externally verified] The company has published three HCV assessments. Information is externally verified by consultants undertaking the assessments.

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

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

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

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

The company has published this commitment.

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

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also reports this commitment independently.

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

The company has published this commitment.

81. High Carbon Stock (HCS) assessments available?

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

82. 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/trader; or has had no new planting since April 2015, unless it has undertaken HCS assessments that are not for new planting; or all new planting is since November 2017 AND has all been covered under combined HCV-HCS assessments.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also reports this commitment independently.

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

The company makes these commitments in separate policies.

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

Multiple SEIAs are published, however it is not clear if any are externally verified.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

The company's own commitment is extended to suppliers.

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

0 (0%) - Data is over two years old but the company has had no new plantation since the figure was reported.

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

This indicator is disabled as the producer clearly states that it has no operations on peatland.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company has also made this commitment independently.

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

The company commits smallholder suppliers to best management practices for soils, but no such commitment could be found for peat.

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

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

93. Commitment to zero burning?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

94. Commitment to zero burning applies to all suppliers?

The company has published this commitment.

95. Evidence of fire monitoring and management?

The company uses GIS, WRI tools, and drones to regularly monitor fire risk.

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

The company states it has had no fire incidents as of September 2019. Data is over 2 years old.

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

0 - The company monitors fires in smallholder areas, no fires have been detected as of September 2019. Data is over 2 years old.

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

The company has separate reduction targets for its two mills.

99. GHG emissions intensity?

The company reports GHG intensity in 2020 for C.I. Tequendama S.A.S. as -2.08 tCO2e per t CPO/year, and 0.58 tCO2e per t CPO/year for Palma y Trabajo S.A.S. The figure for C.I. Tequendama S.A.S. does not separate emissions from sequestration.

100. GHG emissions from land use change?

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

101. Progress towards commitment to reduce GHG emissions intensity?

The company reports its mills' emissions over time (2015-2020), showing a reduction in emissions intensity, however figures are negative and take into account sequestration.

102. Methodology used to calculate GHG emissions?

The RSPO requires companies to assess their GHG emissions through the Palm GHG calculator. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

One of the company's two mills has methane capture.

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

The company commits to a 5% decrease in water use per ton/FFB per year.

105. Water use intensity?

The company reports figures for 2018 to 2020.

106. Progress towards commitment on water use intensity?

The company reports an overall improvement in water use intensity across all sites.

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

The company commits to ensuring BOD and COD are kept below certain limits permanently.

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

Since 2010 the company has re-used 100% of its effluent.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that effluent is treated it anaerobically and aerobically and eventually used on plantations.

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

[Externally verified] The company provides evidence of effluent treatment. Evidence is externally verified by the local government.

111. Commitment to protect natural waterways through buffer zones?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

The company commits suppliers to minimise chemical pesticides and fertilisers, "with the aim of promoting organic and sustainable production in our production centers and on the farms of our fruit supplier producers".

115. Commitment to no use of paraquat?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also publishes this commitment independently.

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

The company has published this commitment.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also published this commitment independently.

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

The company has published this commitment.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

The company has published this commitment.

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

The company states that palm oil production is organic, which includes no use of chemical pesticides or chemical fertilizers.

122. Implementation of commitment to minimise inorganic fertiliser use?

Points for external verification have been awarded on the basis of the company's POIG verification. The company also reports examples, e.g. cover crops, the use of biological controls, independently. Additional points for POIG have no been awarded as it is unclear what percentage of land has been verified.

123. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports examples, e.g. cover crops, the use of biological controls, independently.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports examples of waste management independently.

125. Commitment to human rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company independently commits to the Universal Declaration of Human Rights, and is also a member of UN Global Compact.

126. Commitment to human rights applies to all suppliers?

The company has published this commitment.

127. Progress on human rights commitment?

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company has published this commitment.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company commits its suppliers to respecting customary and legal land rights.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also publishes this commitment independently.

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

The company commits its suppliers to respecting FPIC.

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

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

135. Examples of local stakeholder engagement to prevent conflicts?

The company states it conducts due diligence including participatory methodologies when acquiring new areas, however examples of ongoing activities to prevent conflicts could not be found.

136. Details of process for addressing land conflicts available?

The RSPO Principles and Criteria 2018 contain requirements for addressing land conflicts. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company has also published a procedure for managing conflicts.

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

The company is committed to the inclusion of women but does not highlight the barriers faced. Also, the information is not externally verified.

138. Commitment to mitigate impacts on food security?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

Points for external verification have been awarded on the basis of the company's POIG verification.

140. Commitment to provide essential community services and facilities?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that in 2018, 728 families of the local community benefitted from its programs.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

The company commits to some ILO conventions in its Human Rights Policy, and the same applies to the suppliers.

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

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

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

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

149. Percentage or number of temporary employees?

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

150. Percentage or number of women employees?

13.1% - Data as of September 2019. Data is over 2 years old.

151. Commitment to pay a Decent Living wage?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

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

154. Reporting of salary by gender?

155. Commitment to address occupational health and safety?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

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

The company has a purchasing policy which states this commitment.

157. Provision of personal protective equipment and related training?

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

158. Time lost due to work-based injuries?

0.64 - The company reported a Lost time accident rate (ILI) for September 2019. Data is over 2 years old.

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

0 - The company reported zero fatalities in 2019. Data is over 2 years old.

160. Commitment to support smallholders?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

161. Programme to support scheme/plasma smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also has a programme supporting scheme smallholders with guidance on best agricultural practices, financial support, and subsidised transport.

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

50 - Data as of December 2020.

163. Programme to support independent smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also has a programme supporting scheme smallholders with guidance on best agricultural practices, financial support, and subsidised transport.

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

50 - Data as of December 2020.

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

The company states that supplier management is carried out through independent processes for each company and that 100% of the new suppliers are evaluated according to a risk matrix, which is adapted to the nature of each company according to its products, services, and criticality. The company also has a due diligence procedure for human rights.

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

100% - The company states that all suppliers are monitored annually.

167. Suspension or exclusion criteria for suppliers?

The company states timeframes and steps taken for suppliers that do not meet their desired classification, but the criteria that suppliers are evaluated against are unclear.

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

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

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

The company states that no high-risk mills are identified as of December 2020. Risk is assessed quarterly.

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

The company states that no high-risk mills are identified as of December 2020. Risk is assessed quarterly. However, the information is not externally verified.

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

The company states that no high-risk mills are identified. Risk is assessed quarterly. However, the information is not externally verified.

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

The company states that its mills are assessed quarterly for risk, defined as "related directly to any human rights, environmental, labor or community issue having arisen in the long (10+years) / short term (1 year)". However, the procedure for assessing this is unclear.

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

The company states that it has no high-risk mills and that its mills are assessed quarterly for risk. Information is not externally verified.

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

The company states it has no high-risk mills in its supply chain.

176. Commitment to ethical conduct and prohibition of corruption?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also makes this commitment independently.

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

The company has published this commitment.

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

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

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

180. Whistleblowing procedure?

The RSPO Principles and Criteria 2018 contain guidance and requirements on whistleblowing procedures. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%). The company also reports its own complaints procedure which protects complainant anonymity.

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

The company adheres to this criteria through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).

182. Details of complaints and grievances disclosed?