Golden Agri Resources Ltd

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?

Chief Sustainability and Communications Officer.

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

The company reports that its board oversees its overall approach to sustainability.

5. Reports gender balance of senior management team?

21.47% - The company reports that 21.47% of women were part of its senior management team in 2023.

6. Reports gender balance of board members?

2 (25%) - The company reports that one (12.5%) woman was part of its board of directors in 2024. The company also reports titles and photos of board members for 2024, but does not directly report gender composition. It has been deduced that there are two women out of eight board members.

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

The company is a member of WBCSD, POCG, and NYDF.

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

The company reports multiple collaborations with stakeholders, some of which include collaboration with Cambridge and Southampton universities on the BEFTA (Biodiversity and Ecosystem Function in Tropical Agriculture) and RERTA (Riparian Ecosystem Restoration in Tropical Agriculture) projects, which explore ways to maximise biodiversity within palm oil plantations and riparian zones by increasing habitat complexity. In Jambi, in collaboration with Nestlé and PepsiCo, the company is expanding its rehabilitation efforts across 1,471 ha of peatland and 720 ha of mineral soil. Of the 1,471 ha of peatland being restored, 750 ha of reforestation will be carried out until 2027 to support long-term ecosystem recovery.

9. Sustainability report published within last two years?

The company published its latest sustainability report in 2025, covering the year 2024.

10. Reports through standardised reporting systems?

The company has submitted CDP questionnaires for forests, climate change, and water security in 2024.

11. Climate risks assessment available?

The company has submitted a CDP Climate Change Questionnaire which is also published on the company's website. However, this questionnaire does not detail climate risks and states that the company plans to introduce a climate-related risk management process in the next two years. The company's own reporting has identified some potential risks split into transition and physical risks and has also published a summary of mitigation. However, the processes used to assess/manage climate risks are unclear and climate-related responsibilities are not reported.

12. Lists countries and operations?

Indonesia (plantations, mills, crushing facilities, and refineries).

13. Lists countries sourcing from?

Indonesia.

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

616212 - The company reports the total land area controlled for oil palm (ha) in its RSPO ACOP 2024.

15. Total oil palm planted area (ha)?

536234 - This figure includes both the nucleus and plasma areas. Data as of December 2024.

16. Scheme smallholders planted area (ha)?

118026 - The company reports the total scheme smallholders' planted area (ha) in its RSPO ACOP 2024.

17. Unplanted area (areas designated for future planting) (ha)?

0 - The company reports the unplanted area as '0 ha' in its RSPO ACOP 2024.

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

79977 - The company reports that the total land designated and managed as HCV areas is 66,384 ha, and the other conservation land set aside is 13,593 ha. Data as of 2024.

19. Maps of estates/management units?

The company submitted the updated estate location concession maps to the RSPO in 2024.

20. Maps of all scheme smallholders?

21. Maps of all third-party supplying plantations?

The company states that it cannot report this information due to government regulations.

22. Number of company-owned mills?

49 - The company reports that it owns 49 mills as of 2024.

23. Names and locations of company-owned mills?

The names and locations of all company-owned mills are available on the company website.

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

The company reports the sourcing information for all of its mills on its website. However, the information reported is from December 2022 and is over two years old now.

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

The company reports the percentage of FFB sourced for each mill, broken down across the following three categories: GAR-owned estates, GAR plasma smallholders, and third-party suppliers. However, the information reported is from December 2022 and is over two years old now.

26. Number of third party supplying mills?

472 - The company reports that its procurement comprises crude palm oil (CPO) and palm kernel (PK) for its downstream business in Indonesia. In 2024, these raw materials were sourced from 423 third-party mills and 49 GAR-owned mills in Indonesia.

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

The names and coordinates of all supplier mills are provided on the company's website and can be accessed by clicking on the links in the map.

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

The company reports the percentage of supplier mills that source from own and third-party plantations. Data as of 2024.

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

The company reports the percentage of the volume of FFB for supplier mills coming from own and third-party plantations. Data as of 2024.

30. 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 sources only directly from mills.

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

The company has already achieved 100% traceability to mill level in December 2015.

32. Percentage of supply traceable to mill level?

The company reports that it achieved 100% traceability to palm oil mills in 2015, and this is maintained as of 2024. This information is externally verified by PricewaterhouseCoopers LLP. Also, many of the company's refineries and crushing facilities have RSPO SCC under SG and IP.

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

The company commits to achieving 100% traceability to the plantation level across its entire supply chain by 2025.

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

The company achieved 100% traceability to the plantation for company-owned mills in 2017. This is maintained as of 2024. Additionally, some of the company's mills have Identity Preserved certification.

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

The company reports that as of December 2024, it has achieved 99.5% TTP for its entire palm supply chain. This information is externally verified by PricewaterhouseCoopers LLP. Additionally, some of the company's refineries also have Identity Preserved certification.

36. Publishes traceability data at refinery level?

The company publishes traceability data at the refinery level for all its refineries on its website. However, the information reported is not externally verified.

37. Publishes traceability data at crusher level?

The company publishes traceability data at the crushing facility level on its website. However, the information reported is not externally verified.

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

2005 - The company is a Roundtable on Sustainable Palm Oil (RSPO) member since 2005.

39. 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?

2011 - The company became an RSPO member in 2005 and achieved its first RSPO P&C certification in 2011.

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

RSPO ACOP 2024 is submitted by the company.

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

47.03% - Data as of 2024.

42. Percentage of mills RSPO-certified?

75.51% - 37 of the total 49 mills owned by the company are RSPO-certified as of 2024.

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

2027 - The company commits to achieving 100% RSPO certification of estates and mills by 2027. This is within 5 years.

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

2017 - The company reports to have achieved100% RSPO certification of all palm product processing facilities in 2017.

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

42.59% - The company reports 42.59% of the land under scheme smallholders is RSPO certified as of 2024.

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

2027 - The company commits to achieving 100% RSPO certification of scheme/associated smallholders and outgrowers by 2027. This is within 5 years.

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

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

15.68% - The company reports 15.68% of palm oil and palm products handled/traded/processed (tonnes) as RSPO-certified in 2024.

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

39.10% of total CSPO and CSPK is sold through Identity Preserved supply chains in 2024.

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

Segregated supply chains- 2.88%.

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

The company reports that 276,080.21 ha of planted area and 39 mills have received ISPO certification as of September 2023. However, the certificates are not publicly available.

52. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

[Externally verified] ISCC.

54. Commitment to zero conversion of natural ecosystems?

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

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 and/or ecosystem conversion?

The company defines deforestation as the development of HCV and HCS areas and specifies that any deforestation/conversion past 2011 will not be accepted.

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

The company defines deforestation for suppliers as the development of HCV and HCS areas and specifies that any deforestation/conversion past 2011 will not be accepted in supplier operations.

60. Cross-commodity zero deforestation commitment?

The company reports a commitment to ""sourcing agri-commodities from regions that do not contribute to deforestation/peat land development". This is an unclear commitment with an undefined scope. The commitment has been in place since May 2025.

61. Cross-commodity zero deforestation commitment applies to all suppliers?

The company commits suppliers to ""sourcing agri-commodities from regions that do not contribute to deforestation/peat land development". This is an unclear commitment with an undefined scope. The commitment has been in place since May 2025.

62. Target date to achieve zero deforestation?

The company has set a target date to achieve zero deforestation across all its own operations by 2025.

63. Target date to achieve zero deforestation in supplier operations?

The company reports a commitment to 100% NDPE supply chains by 2025 under NDPE IRF v5.8.

64. 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. The company reports that it monitors 100% of its conservation areas through satellite-based monitoring and radar technology, where it uses MapHubs and Satelligence to monitor deforestation. Change alerts are generated every 24 days across all conservation areas.

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

The company reports it monitors deforestation in its operations and supply chain using satellite-based monitoring and radar technology that provides change alerts every 24 days for all conservation areas. The company is also working with Satelligence to deliver near real-time deforestation risk monitoring of its palm oil concessions and supply chain, covering all of Indonesia. However, the information reported is not externally verified.

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

The company reported no conversion of natural ecosystems in the last five years as of December 2021. However, the information reported is over two years old and the figures for conversion since the company's cut-off date of 2011 are not reported.

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

Some figures are available in the company's grievance list, however, a consolidated figure for all deforestation recorded in the supplier operations since the cut-off date is not reported.

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

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

70. Implementing a landscape or jurisdictional level approach?

The company reports it takes a landscape approach to conservation beyond the boundaries of its concessions by collaborating with local communities on conservation partnerships. This includes Participatory Mapping (PM) and Participatory Conservation Planning (PCP) programs, which, to date, have been successfully implemented across 200 villages and have resulted in agreements to protect around 43,000 ha of forests through community-led conservation agreements. However, the information reported is not externally verified.

71. Biodiversity policy?

72. Biodiversity policy applies to all suppliers?

73. 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 international and national systems of species classification (IUCN, CITES, and national regulations).

74. 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 also reports multiple examples of species and habitat conservation management, including the rehabilitation of 2,003 ha of degraded peatland in partnership with Nestlé in West Kalimantan and the expansion of its rehabilitation efforts across 1,471 ha of peatland and 720 ha of mineral soil in Jambi, in collaboration with Nestlé and PepsiCo. The company is also working in collaboration with Cambridge and Southampton universities on the BEFTA (Biodiversity and Ecosystem Function in Tropical Agriculture) and RERTA (Riparian Ecosystem Restoration in Tropical Agriculture) projects, which explore ways to maximise biodiversity within palm oil plantations and riparian zones by increasing habitat complexity.

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

The company commits to no hunting of all species in its operations.

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

The company commits all suppliers to no hunting of all species in their operations.

77. 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 commitment to conduct High Conservation Value (HCV) assessments.

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

The company commits all suppliers to conduct HCV assessments.

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

[Externally verified] The following HCV assessments and their associated management and monitoring plans are publicly available: PT Buana Artha Sejahtera, PT Aditunggal Mahajaya, PT Agrokarya Primalestari, PT Mitrakarya Agroindo, PT Agrolestari Sentosa, PT Buana Adhitama, PT Binasawit Abadi Pratama, PT Cahaya Nusa Gemilang, PT Agrolestari Mandiri, PT Bangun Nusa Mandiri, PT Persada Graha Mandiri, PT Paramitra Internusa Pratama, PT Kartika Prima Cipta, PT Kencana Graha Permai, PT Tapian Nadenggan, PT Kresna Duta Agroindo, and PT Bumi Sawit Permai.

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

[Externally verified] The HCV assessment of 'Scheme Smallholders of PT. Paramitra Internusa Pratama (PIP)' is publicly available.

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

[Externally verified] The HCV management and monitoring plan of 'Scheme Smallholders of PT. Paramitra Internusa Pratama (PIP)' is publicly available.

82. 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's reporting only mentions using qualified assessors; however, it does not explicitly mention assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS).

83. 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 its suppliers to use credible HCV assessors; however, it does not explicitly mention ALS.

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

[Externally verified] The HCV assessment of plasma area of PT. Paramitra Internusa Pratama is deemed satisfactory by the HCV ALS Quality Panel.

85. 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. The company also reports its commitment to the High Carbon Stock (HCS) Approach.

86. 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.

87. High Carbon Stock (HCS) assessments available?

[Externally verified] HCS and integrated HCV-HCS assessments of PT. Djuandasawit Lestari (Smallholder), PT. Djuandasawit Lestari (Partnership Plantation) , PT. Kresna Duta Agroindo, PT. Bumi Sawit Permai, PT. Tapian Nadenggan (Plantation Partnership), PT. Kresna Duta Agroindo (KDA), PT Tapian Nadenggan (Plasma), PT. Bumi Sawit Permai (Lahat Regency), PT. Bumi Sawit Permai (Muara Enim & Ogan Ilir), PT. Agrolestari Sentosa (ALS), PT. Cahaya Nusa Gemilang (CNG), PT. Paramitra Internusa Pratama (PIP), PT. Persada Graha Mandiri (PGM), PT. Kencana Graha Permai (KGP), PT. Agrolestari Mandiri (AMNL), PT. Bangun Nusa Mandiri (BNM), PT. Kartika Prima Cipta (KPC), PT. Aditunggal Mahajaya (ATM), PT. Agrokarya Prima Lestari (AKPL), PT. Binasawit Abadipratama (BAP), PT. Buana Adhitama (BAT), PT. Buana Artha Sejahtera (BAS), PT. Mitrakarya Agroindo (MKA), PT. Tapian Nadenggan, Koperasi Sawit Bina Sejahtera, Koperasi Sawit Karya Bersama Sejahtera, PT. Satya Kisma Usaha (SKU) Kemitraan, PTx. Ivo Mas Tunggal, PT. Buana Wiralestari Mas & PT. Ramajaya Pramukti is publicly available.

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

[Externally verified] Peer review of PT. Cahaya Nusa Gemilang (CNG), PT. Paramitra Internusa Pratama (PIP), PT. Persada Graha Mandiri (PGM), PT. Kencana Graha Permai (KGP), Koperasi Sawit Bina Sejahtera, and Koperasi Sawit Karya Bersama Sejahtera are publicly available. The company also has many other standalone HCS assessments which were part of the pilot studies.

89. 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 also reports its commitment to conducting social and environmental impact assessments (SEIAs).

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

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

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

[Externally verified] The following SEIAs are publicly available: PT Buana Artha Sejahtera, PT Aditunggal Mahajaya, PT Agrokarya Primalestari, PT Mitrakarya Agroindo, PT Agrolestari Sentosa, PT Buana Adhitama, PT Binasawit Abadi Pratama, PT Cahaya Nusa Gemilang, PT Agrolestari Mandiri, PT Bangun Nusa Mandiri, PT Persada Graha Mandiri, PT Paramitra Internusa Pratama, PT Kartika Prima Cipta, PT Kencana Graha Permai, PT Tapian Nadenggan, PT Kresna Duta Agroindo, PT Bumi Sawit Permai, and Scheme Smallholders of PT. Paramitra Internusa Pratama (PIP), "Koperasi Kelapa Sawit Mitra Puyang Gana".

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

93. 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.

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

48384 (64%) - The company reports 48,384 ha of landbank on peat of which 64% is planted and 36% is non-planted. Data as of 2024.

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

The company reports 48,384 ha of landbank on peat in 2023 and 2024. There is no increase in the landbank on peat; however, the information reported is not externally verified.

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

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

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

The company only commits its suppliers to adopt and implement best management practices for peatland areas.

98. 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 reports that in areas where the land is showing signs of degradation, it applies techniques from Regenerative Agriculture, like planting cover crops and adding organic matter to restore soil health. The company also uses Precision Agriculture, which involves tools and technologies that help it apply the right amount of fertiliser and nutrients only where they are needed. For peat, the company states that it is implementing a water management plan to maintain optimal moisture levels in the peat, preventing it from igniting during dry seasons.

99. Commitment to zero burning?

The company commits to no burning.

100. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

101. 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 reporting states it uses GeoSMART app to identify potential fire hotspots three times faster and mentions that all its estates have fire-fighting equipment and a network of over 10,000 Emergency Response Team personnel, stationed across its plantations.

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

The company provides 'Fire Incident Reports' of its concessions, including smallholder areas, for each month from 2016-2025. 171 fire hotspots were recorded in 2024 in the company's operations.

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

5 - The company reports a total of five fire hotspots in Desa Makmur Peduli Api (DMPA) Villages in 2024.

104. Time-bound commitment to reduce absolute greenhouse gas (GHG) emissions?

The company reports a commitment to reduce absolute Scope 1 and 3 Forest, Land, and Agriculture (FLAG) emissions by 30% and Scope 1 and 2 non-FLAG emissions by 42% by 2030, from a 2022 baseline.

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

The company reports a commitment to reduce absolute Scope 1 and 3 Forest, Land, and Agriculture (FLAG) emissions by 30% and Scope 1 and 2 non-FLAG emissions by 42% by 2030, from a 2022 baseline.

106. Absolute GHG emissions?

35000000 - The company reports that its Scope 1, 2 and 3 emission were 35.0 million tonnes CO2e in 2024.

107. GHG emissions intensity?

2.77 - The company reports the GHG emissions intensity for 2024 as 2.77 tCO2e/tonne CPO produced. The figure includes Scope 1 and Scope 2 emissions.

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

The company reports its Scope 1 FLAG GHG emissions for all its operations in 2024 as 4,501,310. (tonsCO2e) and states that Land Use, Land-use Change, and Forestry (LULUCF) emissions are included in its Scope 1 FLAG emissions.

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

The company reports 22,854,472 tonnes CO2e from Scope 3 FLAG emissions. It does not specify emission from land use change only.

110. Progress towards commitment to reduce absolute GHG emissions?

The company reports that its Scope 1, 2 and 3 emission increased from 32.7 million tonnes CO2e in 2023 to 35.0 million tonnes CO2e in 2024.

111. Progress towards commitment to reduce GHG emissions intensity?

The company's reports GHG emission intensity (Scope 1 and Scope 2) for 2023 (2.69 tCO2e/tonne CPO produced) and 2024 (2.77 tCO2e/tonne CPO produced). The intensity has increased in 2024 as compared to 2023.

112. Methodology used to calculate GHG emissions?

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

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

The company reports it has methane capture at eight of its mills and states that three more mills will have these facilities by 2025.

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

115. Water use intensity?

4.32 - The company reports the water consumption for 2024 as 4.32m3 per metric ton of CPO.

116. Progress towards commitment on water use intensity?

The company reports the water intensity for 2023 as 3.85m3 per metric ton of CPO and for 2024 as 4.32m3 per metric ton of CPO. The intensity has increased in 2024 as compared to 2023.

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

The company reports that its Biological Oxygen Demand (BOD) and Chemical Oxygen Demand (COD) levels are consistently within regulatory thresholds, and it is committed to maintaining these levels.

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

The company reports that it complies with local regulation on BOD and COD levels, however it does not state the legal thresholds alongside own levels.

119. 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 100% of its POME is applied in the field after traditional anaerobic and aerobic treatment to render the chemical and physical characteristics compliant with national regulations.

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

The company reports that the wastewater from its refineries is treated in its wastewater treatment plants before it is released to water bodies or reused. However, the information reported does not explicitly mention PORE.

121. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways through buffer zones.

122. 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.

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

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

124. 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.

125. Commitment to no use of paraquat?

The company commits to not use paraquat.

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

The company's commitment for the suppliers states, 'we will stop the use of paraquat'. It is unclear if this has been implemented by all suppliers.

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

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

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

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

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

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

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

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

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

The company only reports the list of pesticides and bio-pesticides used per ha in 2024. A list of chemical fertilisers used by the company is not reported.

132. 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. The company's reporting states that solid waste such as Empty Fruit Bunches (EFB), fibre, and shells are collected and recycled into fuel or organic fertiliser. The company also states that it practises Precision Agriculture, which involves tools and technologies that help it apply the right amount of fertiliser and nutrients only where they are needed.

133. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's reporting also mentions using Integrated Pest Management (IPM), which combines mechanical, biological, and chemical means to control pests. Measures involve breeding barn owls to control the rat population, encouraging leopard cats, which prey on rodents, to stay within plantations, controlling leaf-eating caterpillars through the diversity of flora, promoting the growth of beneficial plants, and using pheromones to control rhinoceros beetles.

134. 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 reports it has a waste management system in place where it recovers all CPO organic production waste from its upstream operations, and hazardous waste from its downstream operations undergoes collection and disposal by authorised third parties.

135. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

136. Commitment to human rights applies to all suppliers?

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

137. 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 it conducts human rights workshops in collaboration with Civil Society Organisations (CSO) and major customers, and that its plantations are safeguarded by trained personnel who complete a 21-day programme at the Bhakti Manunggal Karya Centre, certified by the Indonesian National Police. The training covers human rights standards and professional ethics. In August 2024, the company held its first human rights training for upper and middle management, with 180 participants attending a hybrid awareness and capacity-building session. The company also established a Human Rights Steering Group, made up of seven Human Resources department heads, the Chief Sustainability and Communications Officer, and the Human Rights Officer.

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

The company reports it is committed to respecting the rights of indigenous and local communities; however, the commitment does not reference the UN Declaration/ILO Convention.

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

The company commits its suppliers to respect local communities and indigenous rights, but only in relation to FPIC.

140. 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.

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

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

142. 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 commitment to FPIC.

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

The company commits all suppliers to respect FPIC.

144. 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 procedure for implementing Free, Prior, and Informed Consent (FPIC).

145. Examples of local stakeholder engagement to prevent conflicts?

The company reports maintaining open and constructive engagement with communities to avoid social conflicts. The company has a conflict management framework to track concerns, develop tailored action plans, and ensure ongoing dialogue. The process allows complainants to appoint representatives or observers, including the option of a third-party mediator to ensure fair and impartial discussions. The company has also published a guideline on participatory mapping and procedures for handling social conflicts. However, the information reported is not externally verified.

146. Details of process for addressing land conflicts available?

The company has a 'Procedure for Social Conflict Handling' which covers land conflicts as well.

147. 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's reporting states that it provides opportunities for women, especially in its upstream operations, where women operate heavy machinery like tractors and also manage harvesting tasks.

148. Commitment to mitigate impacts on food security?

The company commits to ensuring food security for local communities.

149. 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's reporting states it supports food security for local communities through its Bright Future Initiative. As of 2024, there are over 189 Bright Future Initiative (BFI) projects in over 140 villages across the company's operations, ranging from organic vegetable farming to fish and livestock rearing and planting cash crops. The projects have enhanced local food security and resilience.

150. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

151. 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 progress on its commitment to providing essential community services and facilities, which range from education to healthcare support.

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

The company commits to providing employment opportunities for local communities.

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

The company commits to the ILO's Declaration on Fundamental Principles and Rights at Work.

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

The company only commits suppliers to six ILO conventions, including freedom of association, right to organise and collective bargaining, no discrimination, minimum age, and prohibition of forced and child labour. Commitment to minimum age, equal remuneration, Occupational Safety and Health, and Promotional Framework for Occupational Safety and Health are not reported.

155. 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.

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

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

157. 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.

158. 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's reporting states that its training programmes equip estate and mill workers with the knowledge and tools to uphold zero-tolerance towards sexual harassment. Additionally, gender committees have been established across both its upstream and downstream operations, which serve as trusted platforms for handling concerns, investigating complaints, and ensuring appropriate action is taken. In 2024, the company recorded a single case of harassment, which was addressed internally, and the individual involved was terminated.

159. Percentage or number of temporary employees?

34994 - The company reports the total number of fixed-term employees in 2024 as 34,994 (Male: 19,136, Female: 15,858).

160. Reports gender balance of employees?

29106 (29%) - The company reports 29,106 or 29% women as a part of its workforce in 2024.

161. Commitment to pay a living wage?

The company only commits to paying a wage equal to or above the minimum wage.

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

The company only commits its suppliers to pay the minimum wage.

163. Progress on commitment to pay a living wage?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's reporting only mentions the ratio of its lowest monthly wage to the provincial minimum wage for all its operations.

164. Reporting of salary by gender?

The company reports the ratio of the average basic salary of women to men for its staff, middle management, and senior management across all countries of operations.

165. Commitment to address occupational health and safety?

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

166. 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.

167. 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.

168. Time lost due to work-based injuries?

The company reports the Lost Time Injury Frequency Rate for upstream operations as 3.12 and the Lost Time Injury Frequency Rate for downstream operations as 0.84 in 2024.

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

8 - The company reports eight (8) fatalities across all its operations in 2024.

170. Commitment to support smallholders?

The company has published a commitment to support smallholders.

171. Programme to support scheme smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company supports plasma smallholders by providing access to certified seeds, fertilisers, and agronomic support. The company also regularly delivers in-house sessions and field visits to equip smallholders with best practices in Good Agricultural Practices, integrated pest and fertiliser management, and sustainable land stewardship.

172. Percentage of scheme smallholders involved in programme?

77302 - The company reports that in 2024, it supported 77,302 plasma smallholders by providing access to certified seeds, fertilisers, and agronomic support, enabling yields of 3.6 tonnes of CPO per hectare. However, the total number of smallholders managed or contracted in the reporting year is not available to calculate the percentage of smallholders supported.

173. Programme to support independent smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's reporting states that its Sawit Terampil programme, conducted in partnership with major customers like MARS and Fuji Oil, focuses on upskilling independent smallholders in the Leuser Ecosystem region in Aceh and North Sumatra. Participants benefit from group coaching and individualised support on Good Agricultural Practices. The company's R&D division, SMARTRI, conducts regular training programmes for smallholders, training several hundred farmers annually in agronomic practices focusing on integrated pest management and fertiliser management.

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

10000 - The company reports running a programme that assists independent smallholders in Aceh and North Sumatra. The company is currently supported by Mars and Fuji Oil in this programme and as of the end of 2024, the company has helped to upskill more than 10,000 independent smallholders. However, it is unclear if this figure represents all independent smallholders supported by the company under its different independent smallholder support programs.

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

The company reports that all new suppliers are screened using environmental and social criteria, in line with its commitments in the GSEP. For existing suppliers, all company-owned and third-party mills are assessed for GSEP compliance on an annual basis through desk research and spatial analysis. Site visits are also carried out to suppliers, especially those deemed high-risk, to document and understand the gaps and difficulties they face in adopting responsible practices.

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

[Externally verified] 472 (100%) - The company reports that 100% (472) of suppliers were assessed based on social and environmental criteria in 2024. Evidence is externally verified by PricewaterhouseCoopers LLP.

177. Suspension or exclusion criteria for suppliers?

The company reports that the suppliers deemed non-compliant with company policies will no longer form part of the company's supply chain. The company reports having designed guidelines with its industry peers and several CSOs including Mighty Earth, Aidenvironment and Earthworm Foundation for re-engagement with suspended suppliers. Minimum requirements include conditions like moratoriums on land clearing; conducting HCS and HCV assessments prior to new development and developing SOPs in line with NDPE policies. However, the timeframes for action are not reported.

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

The company publishes time-bound action plans for some of its suppliers.

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

[Externally verified] 99% - The company reports the percentage of CPO and PKO volume of supply classified by NDPE criteria using the No Deforestation, No Peat, and No Exploitation Implementation Reporting Framework (NDPE IRF). This information is externally verified by the Control Union.

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

The company reports that its own and third-party mills are assessed annually to determine continued compliance with the GSEP. First, desk research and spatial analysis assessments are carried out to prioritise mills for further analysis. This mill prioritisation process identifies high-risk suppliers for site visits and deeper engagement. However, a time-bound plan to engage with all high-risk mills is not reported by the company.

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

The company reports that its own and third-party mills are assessed annually to determine continued compliance with the GSEP. First, desk research and spatial analysis assessments are carried out to prioritise mills for further analysis. This mill prioritisation process of the company identifies high-risk suppliers for site visits and deeper engagement. PWC have externally verified that the company has time-bound action plans to address social and environmental issues for 82% of suppliers. The composition that are high risk is not reported, the company does not clearly report a programme to support high risk mills to become compliant with sourcing policies.

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

The company reports that its own and third-party mills are assessed annually to determine continued compliance with the GSEP. First, desk research and spatial analysis assessments are carried out to prioritise mills for further analysis. This mill prioritisation process of the company identifies high-risk suppliers for site visits and deeper engagement. However, the information reported is not externally verified.

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

The company has procedures in place to assess all own and third-party supplying palm oil mills for risk levels.

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

[Externally verified] The company reports that all its own and third-party mills are assessed for GSEP compliance on an annual basis through desk research and spatial analysis. The company has also published the number of mills as per their risk levels in its latest sustainability report. This information is externally verified by PricewaterhouseCoopers LLP.

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

[Externally verified] All Suppliers: Low Risk: 444 (94%), Medium Risk: 22 (5%), High Risk: 6 (1%). Types of risk- Environmental: potential deforestation, peat management, fire, GHG emissions, waste management; Social and labour: human rights, community development, land tenure, OHS, workplace diversity, grievance handling. Evidence is externally verified by PricewaterhouseCoopers LLP.

186. Commitment to ethical conduct and prohibition of corruption?

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

187. 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.

188. 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 reports that it provides mandatory annual training for all employees on its code of conduct, which sets clear expectations for ethical behaviour and is communicated annually to all employees, board members, contractors, suppliers, and business partners. In 2024, the company reported no significant cases of bribery or corruption.

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

The company has a Responsible Tax Policy, however, it does not report an executive level position or governance body responsible for tax policy and its review.

190. Whistleblowing procedure?

The company reports that it allows whistleblowing and has published information on the channels to raise complaints, and how whistleblowers are protected. However, a clear description of the steps taken is not available.

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

The company has a grievance procedure in place, which is open to all stakeholders.

192. Details of complaints and grievances disclosed?

Details of complaints and grievances are disclosed by the company.