Eagle High Plantations Tbk PT

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

The company has published a sustainable palm oil policy which covers all palm oil operations.

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?

Head - Sustainability.

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

Division Head - Sustainability.

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

5 (6%) - The company reports that five (6%) female employees hold positions at the senior management level. Data as of 2021.

6. Percentage or number of women board members?

0 (0%) - The company reports zero females as a part of its board. Data as of 2021.

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 is a member of TFA. Some of the company's subsidiaries are a member of the Indonesia Global Compact Network (IGCN) and UNGC.

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

The company reports carrying out collaboration activities between the company and civil society. This includes working on 'Project AMOUR', an orangutan conservation project and the Rimba Raya compensation project, a habitat rehabilitation in the 1,500 ha of peatland currently deforested, through tree planting.

9. Sustainability report published within last two years?

The sustainability report for 2021 is published by the company.

10. Reports through standardised reporting systems?

The company reports having prepared its 2021 sustainability report referring to Global Reporting Initiative (GRI) Standards: CoreOption.

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?

A limited summary of risks and management strategy is available. However, this information has not been externally verified.

13. Lists countries and operations?

Indonesia (plantations and mills).

14. Lists countries sourcing from?

Indonesia.

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

183298 - The company reports the total land bank managed for oil palm in its RSPO ACOP 2021.

16. Total oil palm planted area (ha)?

34830 - The company's sustainability report mentions the planted area in 2021 as 34,830 ha, whereas its annual report mentions the total planted area as 97,218 ha. ACOP 2021 mentions the planted area as 116,000 ha, however, this also includes the infrastructure area. Contradictory figures are reported from the same time period.

17. Scheme smallholders planted area (ha)?

18309 - The company reports the total land under scheme smallholders in its RSPO ACOP 2021.

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

0 - The company reports the unplanted area as 0 ha in its RSPO ACOP 2021.

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

48989 - The company reports the conservation set-aside area as 0 ha and the High Conservation Value (HCV) area as 48,989 ha in its RSPO ACOP 2021.

20. Maps of estates/management units?

Concession boundaries have been made available to the RSPO in 2018 and the company declares no new concession acquisition or changes in the ownership of existing concessions were undertaken in 2019, 2020 or 2021.

21. Maps of scheme smallholders?

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

23. Number of company-owned mills?

8 - The company reports operating eight mills in 2021 and mentions having divested from a number of plantation assets and one palm oil mill in 2021 as compared to nine mills in 2020.

24. Names and locations of company-owned mills?

Names and coordinates of all eight company mills are available on the company website and GFW database.

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

The company reports that it currently operates eight mills that process FFB from its nucleus and plasma plantations, of which seven also process FFB from external suppliers.

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

The company has disclosed the percentage and volume of FFB supply that comes from its own operations and third-party plantations for all eight mills.

27. Number of third party supplying mills?

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not source from third-party supplying mills.

31. 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 the company does not own refineries.

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

This indicator is disabled as the company does not source from third-party supplying mills.

33. Percentage of supply traceable to mill level?

This indicator is disabled as the company does not source from third-party supplying mills.

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

The company commits to achieving 100% traceability to the plantation by 2026 for all its operations.

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

The company reports that all the sourcing from its own plantations, plasma smallholders and external suppliers was traceable to the plantation level in 2021.

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

This indicator is disabled as the company does not source from third-party supplying mills.

37. Publishes traceability data at refinery level?

This indicator is disabled as the company does not own 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] 2008 - The company is a member of the RSPO since March 2008.

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?

2019 - The company achieved its first certification in 2019 after becoming an RSPO member in 2008.

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

RSPO ACOP 2021 is submitted by the company.

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

[Externally verified] 5.28% - The company reports the percentage of area RSPO certified as 5.28%.

43. Percentage of mills RSPO-certified?

[Externally verified] 12.5% - One out of the total eight mills owned by the company is RSPO certified.

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

2026 - The company reports achieving 100% RSPO certification of estates and mills by 2026. The target reported is within 5 years.

45. Time-bound plan for achieving 100% RSPO certification of all palm product processing facilities within 5 years?

This indicator is disabled as the company is only a grower or miller.

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

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

2029 - The company reports to achieve 100% RSPO certification of scheme smallholders by 2029. The target reported is not within 5 years.

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

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

This indicator is disabled as the company is only a grower or miller.

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

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

This indicator is disabled as the company only reports a Grower ACOP.

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

[Externally verified] Six of the company's total eight mills are ISPO certified. ISPO certificates are available on the company website.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

55. Commitment to zero conversion of natural ecosystems?

56. Commitment to zero deforestation?

The company commits to no development in High Conservation Value (HCV), High Carbon Stock (HCS) and peatland areas.

57. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to no development in High Conservation Value (HCV), High Carbon Stock (HCS) and peatland areas.

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

The company defines deforestation as the development of HCV, HCS and peatland areas and specifies any deforestation/conversion past June 2018 will not be accepted.

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

The company defines deforestation for suppliers as the development of HCV, HCS and peatland areas and specifies any deforestation/conversion past June 2018 will not be accepted in supplier operations.

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

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

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

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

The company reports that no deforestation has been recorded from January 2019 to December 2021 in its operations. However, the cut-off date is reported as June 2018 by the company and no information is available for June 2018 to December 2018.

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

64. Commitment to restoration of deforestation/conversion?

The company commits to restoring ecosystems to their prior condition in cases of conversion within its own operations by stating 'In accordance with RSPO requirements, the company also carries out remediation and compensation activities based on the Land Use Change Analysis (LUCA) which was reviewed and approved by the RSPO'. The cut-off date beyond which deforestation would not be accepted is reported as June 2018.

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

66. Implementing a landscape or jurisdictional level approach?

67. Biodiversity policy?

68. Biodiversity policy applies to all suppliers?

The company mentions protecting biodiversity but only in relation to HCV/HCS areas.

69. 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. The company has also identified the species of conservation concern referencing the IUCN Red List and national law 'protection status under Law No. 5/1990 and PP No. 7/1999'.

70. 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. The company reports working on 'Project AMOUR', an orangutan conservation project and the Rimba Raya compensation project, a habitat rehabilitation in the 1,500 ha of peatland currently deforested, through tree planting.

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

The company reports that it is committed not to hunt other than sustainable hunting in its operating areas.

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

The company commits its suppliers to 'not to hunt other than sustainable hunting in its operating areas'.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also reports its own commitment to conduct High Conservation Value (HCV) assessments.

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?

[Externally verified] An HCV assessment of PT BUMILANGGENG PERDANATRADA conducted in 2013 is published on the company website.

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

[Externally verified] The following HCV assessments are publicly available: PT JMS, Kotabaru and Tanah Bumbu District, PT STP, Kotabaru District, PT. Manunggal Adi Jaya & Koperasi Kelumpang Bersama Cooperative at Desa Sekandis, Desa Talusi and Desa Gunung Calang and PT KAPAG, Kotabaru District.

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

[Externally verified] The management and monitoring plans are publicly available: PT JMS, Kotabaru and Tanah Bumbu District, PT STP, Kotabaru District, PT. Manunggal Adi Jaya & Koperasi Kelumpang Bersama Cooperative at Desa Sekandis, Desa Talusi and Desa Gunung Calang and PT KAPAG, Kotabaru District.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also reports its own commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS).

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?

[Externally verified] A satisfactory review of all five High Conservation Value (HCV) assessments undertaken since January 2015 by the HCV ALS Quality Panel is publicly available on the HCV database.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

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

The company only commits its suppliers to no development of areas classified as having High Carbon Stock (HCS).

83. High Carbon Stock (HCS) assessments available?

[Externally verified] HCS assessment of 'PT Varia Mitra Andalan' is publicly available on the HCSA database.

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

[Externally verified] Only HCS assessment of 'PT Varia Mitra Andalan' is publicly available on the HCSA database and its peer review report is published on the database.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company's own reporting only mentions its commitment to conduct social impact assessments.

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

The company only commits its suppliers to conduct social impact assessments.

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

[Externally verified] A brief summary of an EIA is available in the HCS summary report of 'PT Varia Mitra Andalan'.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also reports its own commitment to no planting on peat of any depth.

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)?

11679 - The company reports that until the end of 2021, a total of 11,679 ha of peatland is used as planting area and 7,000 ha as unplanted area.

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

The company reports the planted peat landbank figures from 2018-2020 as 20,334 ha. In 2021, the company reports the peat planted area as 11,679 ha which is less than previous years mainly because the company reports divesting from a few plantations in 2021. However, the information reported is not externally verified.

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

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

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

The company only commits its suppliers to best management practices for peat.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting states it applies best management practices for soils and peat by maintaining the groundwater level with dams/sandbags/stop drains in collection ditches and main drains, keeping the groundwater level in optimal conditions (40 cm below ground level), application of palm oil waste (liquid and solid) is carried out by utilising waste such as empty fruit bunches and Palm Oil Mill Effluent (POME).

95. Commitment to zero burning?

The company commits to no burning.

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

97. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting mentions forming a fire brigade in each plantation which is tasked with monitoring and identifying hotspots due to land burning, or forest and land fires (karhutla) in the company's operational areas. The monitoring is carried out by the fire brigade with the Visible Infrared Imaging Radiometer Suite (VIIRS) satellite and the National Oceanic and Atmospheric Administration (NOAA). For hot spots that are detected, the fire brigade will verify directly in the field, then follow up with blackouts, making reports in the event of a land fire, and reporting to related parties.

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

The company reports 114 hotspots within its concessions in the year 2021.

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

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

The company reports in its RSPO ACOP 2021 that it is planning to develop a baseline for GHG reporting and is currently measuring the GHG footprint while identifying ways to reduce the GHG footprint. A time-bound commitment is not reported by the company.

101. GHG emissions intensity?

The company reports the average GHG footprint for all certified management units by hectares as 827.36(tCO2e/ha) and per tonne of crude palm oil as 89.82 tCO2e/tCPO. GHG emissions intensity for all company operations is not reported by the company.

102. GHG emissions from land use change?

103. Progress towards commitment to reduce GHG emissions intensity?

The company reports that the total emission generated by the company in 2021 was 385,886 tCO2e, a decrease from the previous year which was 434,049 tCO2e. However, the progress is not reported as intensity figures.

104. Methodology used to calculate GHG emissions?

The company uses the ISPO calculator which was adapted from the IPCC calculator to calculate GHG emissions.

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

The company reports it operates one biogas plant since September 2020.

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

The company commits to reducing water intensity by 10% per ton of FFB in the next three years. Commitment is reported in 2021.

107. Water use intensity?

1.82 - The company reports that 'Water Consumption Intensity (IPA) in 2021 was approximately 1.82 m3/ton Processed FFBs based on the average volume of water use in the subsidiaries'. However, it is unclear if this covers all operations of the company.

108. Progress towards commitment on water use intensity?

The company reports the water use intensity for 2020 and 2021 as 1.82 m3/ton. The intensity is not improving and also these figures only cover some operations of the company.

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

The company reports that it is committed to maintaining the quality of water used in the production process in accordance with the regulations of the Ministry of Environment, and maintains the quality standard for Biological Oxygen Demand (BOD) to be below 5,000 mg/l and Chemical Oxygen Demand (COD) in the range of 4,000-6,000 mg/l.

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

The company reports figures for BOD in 2021 and the figures are within the legal limits. However, these figures only cover some operations of the company.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports its own information on the treatment of POME.

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

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

113. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways through buffer zones.

114. 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. The company's own reporting mentions the installation of riparian boundary markers, installation of signboards and socialisation to build awareness of prohibitions against damaging, cutting down trees and using chemicals in riparian areas.

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

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

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?

The company commits to phasing out the use of paraquat by 2026.

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

The company commits suppliers to phasing out the use of paraquat by 2026.

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

The company commits to phase out the use of World Health Organisation (WHO) Class 1A and 1B pesticides by 2026.

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

The company commits suppliers to phase out the use of World Health Organisation (WHO) Class 1A and 1B pesticides by 2026.

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

The company commits to the phasing out of the use Stockholm and Rotterdam Convention chemicals by 2026.

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

The company commits suppliers to the phasing out of the use Stockholm and Rotterdam Convention chemicals by 2026.

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

The company provides a list of chemicals and pesticides used in 2021, however, it is unclear if this covers all operations of the company as details are only provided for some subsidiaries.

124. Implementation of commitment to minimise inorganic fertiliser use?

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

125. 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 information on its Integrated Pest Management approach.

126. 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 has a waste management system in place.

127. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

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

129. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports conducting training on human rights and also taking part in IGCN's Business and Human Rights Working Group (BHRWG). As of 2021, there were no human rights violations in the company.

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

The company commits to the UN Declaration on the Rights of Indigenous Peoples and the ILO Indigenous and Tribal Peoples Convention (no. 169).

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

The company commits its suppliers to respect the rights of indigenous people and local communities, however, does not reference the UN Declaration on the Rights of Indigenous Peoples or ILO 169.

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

The company commits to the FAO Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security.

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

The company commits suppliers to respect customary land tenure rights but not legal rights.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also reports its own commitment to free, prior and informed consent (FPIC).

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?

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). Points have therefore been awarded on the basis of the company's commitments under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company has also published its own FPIC process.

137. Examples of local stakeholder engagement to prevent conflicts?

138. Details of process for addressing land conflicts available?

The company reports the details of the process for addressing land conflicts in its latest sustainability report.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it values diversity by supporting the involvement of women in all palm oil operations, including overcoming the obstacles by establishing a Gender Committee. However, limited details are reported.

140. Commitment to mitigate impacts on food security?

The company commits to ensuring food security for local communities by assisting with cultivating horticultural crops (seasonal vegetables and fruits), annual fruit crops, and industrial plants (plasma oil palm plantations). In addition, the company also conducts animal husbandry and fishery cultivation, which consist of poultry (chicken and duck) farming, small ruminants (goats, pigs) large ruminants (cows), as well as fast-water fisheries, ponds, and captive fisheries.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports its own progress on its commitment to mitigating impacts on food security, however, the information is not dated.

142. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

143. 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 its own progress on its commitment to provide essential community services and facilities.

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

The company commits to providing job opportunities for local residents, those who live in the area within the province where the subsidiary's operating area is located.

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

The company commits to respect ILO Core Conventions and mentions that it shall be guided by the guidelines set by the International Labor Organization for matters pertaining to the fundamental rights of all its employees.

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

The company commits its suppliers to respect ILO Core Conventions and to be guided by the guidelines set by the International Labor Organization for matters pertaining to the fundamental rights of all its employees.

147. 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.

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?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports having a Gender Committee in place which is tasked with responding to complaints of employees at plantations, as well as taking action in cases of inequality at work, including harassment.

151. Percentage or number of temporary employees?

9281 (57.87%) - The company reports 74 contract employees and 9,207 casual daily workers (BHL) in 2021.

152. Percentage or number of women employees?

4507 (28%) - The company reports 4,507 female employees or 28% of total employees. Data as of 2021.

153. Commitment to pay a Decent Living wage?

The company reports an unclear commitment to pay workers a Decent Living Wage. It is not reported that all workers are paid a DLW.

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

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

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

156. Reporting of salary by gender?

The company reports that it provides remuneration for employees according to the provisions of laws and the standard rules for the Provincial Minimum Wage (UMP) and mentions that all employees (100%) receive wages equivalent to the UMP and remuneration with a ratio of 1:1 regardless of gender. However, the information is not split as per each employee category or by significant locations of operation.

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?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports it provides Personal Protective Equipment (PPE) e.g. apron, rubber gloves, masks, and boots and facilitates training for spraying staff by chemical suppliers.

160. Time lost due to work-based injuries?

The company reports the 'Number and Level of Work Accidents ' categorising them as mild, severe and fatal. However, it is unclear what this data relates to and also it only covers some operations of the company.

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

2 - The company reports two fatalities in 2021.

162. Commitment to support smallholders?

The company has published a commitment to support smallholders.

163. Programme to support scheme smallholders?

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

164. Percentage of scheme smallholders involved in programme?

10000 - The company reports the number of plasma farmers as 10,000 in 2021, however, it is unclear if the company is supporting all of them.

165. Programme to support independent smallholders?

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

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 company reports that it 'conducts environmental and social assessments of local suppliers, to identify whether or not legal violation occurred, forest land encroachment, conservation areas, nature reserves and other prohibited locations, as well as to improve the traceability of raw materials for palm oil products from areas that comply with sustainability commitments'. However, only limited details are provided.

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

169. Suspension or exclusion criteria for suppliers?

The company reports that it 'conducts environmental and social assessments of local suppliers, to identify whether or not legal violation occurred, forest land encroachment, conservation areas, nature reserves and other prohibited locations, as well as to improve the traceability of raw materials for palm oil products from areas that comply with sustainability commitments'. However, it is unclear if this criteria refers to exclusion/suspension of suppliers.

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?

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

This indicator is disabled as the company does not source from mills.

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

This indicator is disabled as the company does not source from mills.

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

This indicator is disabled as the company does not source from mills.

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

This indicator is disabled as the company is only a grower or miller.

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

This indicator is disabled as the company is only a grower or miller.

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

This indicator is disabled as the company is only a grower or miller.

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?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting only mentions having an ethics committee.

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

The company reports that it reviews its tax strategy annually and that the Chief Finance Officer is responsible for compliance. However, the tax strategy is not publicly available.

182. Whistleblowing procedure?

The company has a whistleblowing policy in place.

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

The company has a complaints form open to all stakeholders.

184. Details of complaints and grievances disclosed?

The company reports the date; issue; actions taken; status. The company does not report complainant category.