Glenealy Plantations Sdn Bhd

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's policy states "All Sustainable Palm Oil Policy related commitments identified in paragraphs 4.1 ? 4.21 will be gradually extended to our Third Parties." However the company's NDPE policy states that it applies to all its third-party Fresh Fruit Bunches (FFB) supply base. Partial points have been awarded as it is unclear which parts of the policy currently apply to suppliers.

3. High-level position of responsibility for sustainability?

The company has a Group Head of Sustainability.

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?

2 (8.33%) - The company reports that there are 2 women in the senior management team of 24 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] The company's subsidiary Samling Plantation Sdn. Bhd. is a member of Sarawak Oil Plam Plantation Owners Association (SOPPOA).

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

The company has collaborated with major stakeholders and interested parties for the Belaga Recovery Project whose objectives were to compensate for areas with High Carbon Stock Loss in the development of GPSB oil palm plantations and to manage the recovery site for conservation, rehabilitation, and compensation offset. The company also collaborated with UPMKB to plant more than 400 saplings of two local species in 'Nurturing Nature' Programme.

9. Sustainability report published within last two years?

The company has published its first Sustainability Report in 2020.

10. Reports through standardised reporting systems?

The company has prepared its Sustainability Report 2020 in accordance with GRI standards: Core option.

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

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

12. Climate risks assessment available?

13. Lists countries and operations?

The company has 4 plantations (Lahad Datu, Jelalong, Belaga, Lana) in Malaysia and 1 plantation (Bulungan) in Indonesia. The company also reports that it has 4 mills in Malaysia and 1 mill in Indonesia.

14. Lists countries sourcing from?

The company report that is sources from Indonesia and Malaysia.

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

51302 - The company has a total 51,302 ha area managed for oil palm.

16. Total oil palm planted area (ha)?

39983 - The company states that 39,983 ha is the total oil palm planted area.

17. Scheme smallholders planted area (ha)?

1305 - The company has 1,305 ha area for plasma plantations in its Indonesian operations.

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

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

20. Maps of estates/management units?

The company publishes a static map and has some concessions mapped on GFW, listed under its parent company Samling. However, it is unclear if this represents 100% of the company's palm oil concessions.

21. Maps of scheme smallholders?

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

The company has provided the coordinates of third-party supplier plantations, However, it does not include estate boundaries.

23. Number of company-owned mills?

5 - The company states that it has 5 mills.

24. Names and locations of company-owned mills?

The company has provided the locations and coordinates of all company owned mills.

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

The company reports that each of the company's mills source from both its own and third-party plantations.

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

The company reports FFB from its own plantation 501,013 mton and FFB from others 60,216 mton.

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 has already achieved 100% traceability to plantation level.

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

The company reports 100% of FFB from its own mills traceable to plantation level.

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)?

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?

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

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

43. Percentage of mills RSPO-certified?

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

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?

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

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company has provided the MSPO certification for its mills and estates on its webpage.

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

55. Commitment to zero conversion of natural ecosystems?

The company states a commitment to zero conversion of natural, undisturbed ecosystems. However, this does not cover all natural ecosystems as defined by the AFI.

56. Commitment to zero deforestation?

The company has its own NDPE Policy. However, it was put in place in April 2020.

57. Commitment to zero deforestation applies to all suppliers?

The company has its own NDPE Policy that applies to its third-party suppliers. However, it was put in place in April 2020.

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

The company defines deforestation as removal of HCV and HCS areas and specifies any deforestation/conversion past 2020 will not be accepted.

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

The company defines deforestation for suppliers as removal of HCV and HCS areas and specifies any deforestation past April 2020 will not be accepted in supplier operations.

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

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?

1853 - The company reports a HCS loss of 1,853 ha from January 2016 to September 2020. The company also reports a deforestation cut-off date of April 2020 , so this date is outside of the cut-off date. However, the data only cover HCS areas.

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 "compensating its HCS liability in actively managed offset area that exceeds its losses" through its 'High Carbon Stock (HCS) Recovery Plan'. However, this does not cover all non-compliance.

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

66. Implementing a landscape or jurisdictional level approach?

The company reports that it is involved in The "Greening Sarawak" campaign in collaboration with the Forest Department of Sarawak to protect riparian zones.

67. Biodiversity policy?

The company has a commitment to the conservation of biodiversity, however, no target has been provided.

68. Biodiversity policy applies to all suppliers?

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

The company has identified species of conservation concern, referencing the IUCN and CITES system of classification. An audit report on the MSPO website is also externally verified by Control Union.

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

[Externally verified] The company provides multiple evidence including putting up signage that prohibits hunting in HCV areas and the application of chemicals near buffer zones, and also started a camera trapping project to monitor wildlife in high biodiversity areas. The company's annual surveillance report on the MSPO conducted by Control Union reports a tree planting procedure to restore a riparian zone. However, this was the only externally verified example could be found.

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

The company only prohibits hunting in HCV areas.

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

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

The company commits to conduct 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?

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

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

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

The company reports that "the HCV and HCSA identification procedure will be guided by HCVRN Common Guidance and HCSA Toolkits". However, it does not clearly commit to using ALS assessors.

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 reports that "the HCV and HCSA identification procedure will be guided by HCVRN Common Guidance and HCSA Toolkits". However, it does not clearly commit to using ALS assessors. This policy applies to all suppliers.

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

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

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

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

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

83. High Carbon Stock (HCS) assessments available?

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

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

The company only commits to conducting Social Impact Assessments in new plantation areas.

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

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

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

The company commits 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)?

0 (0%) - The company states that currently there is no planting on peat and also commits to no new development in peat areas of any depth.

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

This indicator is disabled as the company states it has no landbank on peat.

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 commitment to best management practices for peat only applies to suppliers.

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

The company reports that it implements best management practices in soil management to improve soil fertility, reduce soil erosion and address pollution management. The company also states that it prevents soil erosion in slope areas through terracing and practice no land clearing for steep slope with a gradient of more than 25 degrees. However, the information is not externally verified.

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?

The company publishes a fire hotspot monitoring flowchart on its website and states that it implemented initiatives to ensure a responsible fire management system in its operations. It also reports monthly hotspot figures using ASMC (Asian Specialised Meteorological Center) and Karhutla Monitoring System (SIPONGI) data.

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

The company reports that 0 hotspots were detected in its estates.

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

0 - The company reports that 0 hotspots were detected within surrounding landscape.

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

The company only has a general commitment to reduce its GHG emissions.

101. GHG emissions intensity?

The company reports GHG emissions intensity of 0.88 MT CO2e/ MT CPO across its 4 out of 5 mills.

102. GHG emissions from land use change?

103. Progress towards commitment to reduce GHG emissions intensity?

The company reports GHG emission intensity as 1.12 MT CO2e/ MT CPO in (2019/20) and 0.88 MT CO2e/ MT CPO in (2020/21). However, this only covers one mill GHG emissions.

104. Methodology used to calculate GHG emissions?

The company uses the RSPO PalmGHG 4.0 methodology to calculate GHG emissions.

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

The company states that only Timora palm oil mill has methane capture.

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

107. Water use intensity?

1.22 - The company reports its total water usage intensity as 1.22 water(MT)/ FFB(MT) in 2021/22.

108. Progress towards commitment on water use intensity?

The company reports its water usage intensity as 1.31 water(MT)/ FFB(MT) in 2019/20, as 1.29 water(MT)/ FFB(MT) in 2020/21, and as 1.22 water(MT)/ FFB(MT) in 2021/22. However, the figures are improving consistently but the information is self-reported.

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

The company's BOD levels are within legal limits.

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

The company reports BOD level as 10.7 ppm in 2019/20, as 10.5 ppm in 2020/21, and as 9.2 ppm in 2021/22. The figures shows improvement over years and are within legal limit of 20 ppm. However, the data is self-reported.

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

The company states a treatment plan for the disposal of all types of waste generated by its operational activities in its oil palm plantation area, including POME in its waste management and sustainable palm oil policy. The company's MSPO audit reports also verifies its 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?

The company has provided limited evidence for the implementation of protection of natural waterways through buffer zones. However, the information is also not externally verified.

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 has a commitment to reduce the use of chemicals, including pesticides and chemical fertilisers. However, this does not clearly apply to its suppliers.

117. Commitment to no use of paraquat?

The company commits to not use paraquat.

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

The company's policy does not clearly apply to its suppliers.

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

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

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

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

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

The company has published its chemical usage figures in (MT/ha).

124. Implementation of commitment to minimise inorganic fertiliser use?

The company reports to reduces the use of inorganic fertilisers with the use of compost. The company reports to reduces the use of inorganic fertilisers with the use of compost and reducing fossil fuel by substitution with biomass. The company also reports a reduction in chemical fertiliser usage over time.

125. Integrated Pest Management (IPM) approach?

The company has implemented an integrated pest management approach that has combined the use of compatible methods of pests and disease control including ecological, physical, biological, and chemical controls. The company also uses barn owls and snakes to control the rodent population, while predatory insects and parasitoids eliminate leaf-defoliating insects such as nettle caterpillars and bagworms. However, the information is self-reported.

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

[Externally verified] The company is trying to reduce waste in plantation and milling operations and prohibits the burning of domestic waste. The company also reports that all the scheduled waste is disposed of by a licensed contractor and promoting 3R campaign reduce, reuse and recycle as part of the waste management program. Control Union externally verifies the waste management plan for one of the company's mills.

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?

[Externally verified] The company has only provided photos of training on its webpage. However, the company's MSPO audit report confirms training sessions have been provided on the company's policies.

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

The company commits to the ILO Indigenous and Tribal Peoples Convention (no. 169).

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

The company's Human Rights Policy does not clearly apply to all of its suppliers, however it says the policy is distributed to them.

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

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

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

The company's Human Rights Policy does not clearly apply to all of its suppliers, however it says the policy is distributed to them.

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

The company commits to respect 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?

137. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company states it conducts regular engagement with local communities to prevent conflict, but limited details are given. The company's MSPO audit reports include examples of stakeholder meetings, these are externally verified by Control Union.

138. Details of process for addressing land conflicts available?

The company states that any land conflict raised will be resolved through a functional unbiased grievance mechanism. A detailed procedure for addressing land conflicts is not reported by the company.

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

The company reports that it prevents sexual harassment and all other forms of violence against women, and creates opportunities for the development of women's leadership at all levels. It ensures effective participation of women in decision-making by enrolling them as members of various committees, such as the Sustainability Committee and Occupational Safety and Health (OSH) Committee. However, limited information is provided.

140. Commitment to mitigate impacts on food security?

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

[Externally verified] The company has started a food security program with the involvement of employers and workers.This information is externally verified by Control Union in an MSPO audit report. However, only limited information is provided.

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?

[Externally verified] The company reports donating to victims Of Fire Incident at UMA Sambop, provides Internship training to the students of University Putra Malaysia's (Bintulu) in Jelalong East Estate, setting up Community Learning Centres (CLC) for children of the Indonesian workers for providing basic education and has repaired the roads at Rh. Jeranding and Rh. Awan near Jelalong plantation. The repair activities and fogging programmes has been externally verified by Control Union.

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

The company states to provide business opportunities to the local community. However, no clear commitment was found.

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

The company commits to all Fundamental ILO Conventions.

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

The company commits all suppliers to all Fundamental ILO Conventions.

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

[Externally verified] The company provides photos of training in its sustainability report and the company's MSPO audit reports confirm training sessions have been provided on the company's policies. However, limited details were provided.

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?

[Externally verified] The company provides a reporting mechanism for gender-related and discrimination-related issues and also has training and communication programs for the same. However, Control Union has externally verified the establishment of a Gender Committee and annual general meetings.

151. Percentage or number of temporary employees?

This indicator is disabled as the company has no temporary employees.

152. Percentage or number of women employees?

1682 - The company reports that it employs 1,682 women in 2022.

153. Commitment to pay a Decent Living wage?

The company only commits to pay a minimum wage.

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

The company only commits to pay a minimum wage. This applies to all suppliers.

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

The company reports both legal daily minimum wages and actual daily average wages for its employees. The figures for actual wages are higher than the minimum wage for male and female workers. However, this information is not in relation to DLW.

156. Reporting of salary by gender?

The company reports the average daily wage for male and female workers, However, it is unclear if this covers the company's entire operations.

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?

[Externally verified] The company reports to provide personal protective equipment (PPE) and related training to its employees and the Control Union verifies that PPE equipment is provided and that training is planned.

160. Time lost due to work-based injuries?

5.5 - The company reports 5.5 LTI per 1 million manhours for estates and 1.1 LTI per 1 million manhours for mills in 2021.

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

0 - The company reports 0 fatalities in 2021.

162. Commitment to support smallholders?

The company has published a commitment to support smallholders.

163. Programme to support scheme smallholders?

The company states it has a programme to support plasma smallholders, no details are reported on the support provided.

164. Percentage of scheme smallholders involved in programme?

165. Programme to support independent smallholders?

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?

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 states"it maintains the right to conduct third-party due diligence before entering into a business partnership with a Third Party." However, no details on due diligence were provided.

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?

The company's policy reports providing training to all its new employees, existing employees, and directors. The company also provides photos of training sessions conducted in 2021 which includes the Anti-Bribery and Anti-Corruption Policy. However, limited and self-reported information were provided.

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

182. Whistleblowing procedure?

The company has its own Whistleblower Policy.

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

The company has an unbiased grievance mechanism open to all stakeholders.

184. Details of complaints and grievances disclosed?

The company provides details of all grievances received through the company's own grievance mechanism.