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Golden Agri Resources Ltd

Palm oil assessment
  • Latest update: November 2021
  • Next scheduled: November 2022

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  • Parent company:
    Flambo International Ltd.
  • Landbank (oil palm)
    578,244 hectares
  • Market cap:
    2,535,000,000 USD
  • Thomson Reuters ticker:
    GAGR.SI
  • Bloomberg ticker:
    GGR SP
  • ISIN:
    MU0117U00026
  • Sedol:
    6164472
  • RSPO member?
    Yes
  • Website:

Company assessment: Golden Agri Resources Ltd – November 2021

Assessment date:

Score by disclosure type:

Total: 78.4% 148.19 / 189
  • Organisation: 32.5 / 38 85.5%
  • Policy: 61.5 / 76 80.9%
  • Practice: 54.2 / 75 72.3%
  • Self-reported: 15.1 / 75 20.1%
  • External: 10.5 / 75 14%
  • Certified: 28.6 / 75 38.2%
  • Sustainability policy and leadership Sustainability policy and leadership
    10 / 11 90.9%
    • Organisation: 6 / 6 100%
    • Policy: 2 / 2 100%
    • Practice: 2 / 3 66.7%
    • Self-reported: 1 / 3 33.3%
    • External: 1 / 3 33.3%
    • Certified: 0 / 3 0%
    • Y
      1 / 1

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

      The company has a social and environmental policy which covers multiple dimensions of sustainability across the company's operations covering both social and environmental issues.

    • Y
      1 / 1

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

      The company's social and environmental policy applies to all its suppliers.

    • Y
      1 / 1

      3. High-level position of responsibility for sustainability?

      The company has a Sustainability Committee (SC), chaired by Ms Jesslyne Widjaja, Corporate Strategy and Business Development Director, oversees all matters related to responsible business. The SC comprises the senior leadership team from the upstream, downstream and corporate business units as well as the head and other staff members of the Sustainability Directorate. The SC reports directly to the Chairman and CEO and the Board.

    • Y
      1 / 1

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

      The company reports that its board and senior management are fully involved in and support company's sustainability commitments under the GSEP. Also, the company's Sustainability Committee (SC) reports directly to Chairman and Chief Executive Officer of the Board of Directors.

    • Y
      1 / 1

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

      25.2% - Data as of 2020.

    • Y
      1 / 1

      6. Percentage or number of women board members?

      0% - Data as of 2020.

    • Y
      1 / 1

      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 UNGC,TFA, HCS, HCVRN, GAA and NYDF.

    • Y
      1 / 1

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

      The company reports working with CSO stakeholders like Greenpeace to develop new guidelines and standards such as the High Carbon Stock Approach (HCSA) to address deforestation concerns. The company's main sustainability roadmap, the GSEP, was developed with feedback and input from key stakeholders including CSOs such as Greenpeace, Rainforest Action Network (RAN), Forest Peoples Programme (FPP) and the implementation partner, Earthworm Foundation (formerly The Forest Trust).

    • Y
      1 / 1

      9. Sustainability report published within last two years?

      Sustainability Report 2020 is published by the company.

    • Y
      1 / 1

      10. Reports through standardised reporting systems?

      The company's sustainability report has been prepared in accordance with GRI standards Core option. It has also submitted its CDP questionnaires.

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

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

    • N
      0 / 1

      12. Climate risks assessment available?

      The company has submitted a CDP Climate Change Questionnaire which is also published on the company's website. However this does not detail climate risks but states that it plans to introduce a climate related risk management process in the next two years, thus no points.

  • Landbank, maps and traceability Landbank, maps and traceability
    22.4 / 26 86.2%
    • Organisation: 14 / 16 87.5%
    • Policy: 2 / 2 100%
    • Practice: 6.4 / 8 80%
    • Self-reported: 1.5 / 8 18.8%
    • External: 0 / 8 0%
    • Certified: 4.9 / 8 61.3%
    • Y
      1 / 1

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

      578,244 - The company reports the total land area controlled for oil palm (ha) in its RSPO ACOP 2020.

    • Y
      1 / 1

      14. Total oil palm planted area (ha)?

      535,923 - This figure includes both nucleus and plasma areas.

    • Y
      1 / 1

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

      106,195 - The company reports the total scheme smallholders planted area (ha) in its RSPO ACOP 2020.

    • Y
      1 / 1

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

      0 - The company reports the unplanted area as '0 ha' in its RSPO ACOP 2020.

    • Y
      1 / 1

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

      75,732 - The company reports that the total land designated and managed as HCV areas is 58,512 ha and the other conservation land set aside is 17,220 ha.

    • Y
      1 / 1

      18. Maps of estates/management units?

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

    • N
      0 / 1

      19. Maps of scheme/plasma smallholders?

    • N
      0 / 1

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

    • Y
      1 / 1

      21. Number of company-owned mills?

      47 - The company reports the number of mills owned as 47.

    • Y
      1 / 1

      22. Names and locations of company-owned mills?

      The names and locations of 47 mills owned by the company are available on the company website.

    • Y
      1 / 1

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

      The company reports the sourcing information for all of its mills on its website.

    • Y
      1 / 1

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

      The company reports percentages FFB sourced for each mill, broken down across the following three categories: GAR owned estates, GAR plasma smallholders, and Third-party suppliers.

    • Y
      1 / 1

      25. Number of third party supplying mills?

      378 - The company reports to have 378 third-party supplier mills across Indonesia.

    • Y
      1 / 1

      26. 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.

    • Y
      1 / 1

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

      The company reports the % of supplier mills that source from own and third party plantations.

    • Y
      1 / 1

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

      The company reports the % volume of FFB for supplier mills coming from own and third party plantations.

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

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

    • Y
      1 / 1

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

      The company reports that it achieved 100% traceability to palm oil mills in December 2015.

    • Y
      +
      1 / 1
      1 / 1

      31. Percentage of supply traceable to mill level?

      The company reports that it achieved 100% traceability to palm oil mills in 2015. Also, many of the company's refineries and crushing facilities have RSPO SCC under SG and IP.

    • Y
      1 / 1

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

      The company had a time-bound plan to achieve 100% traceability to plantations by 2020, however this target could not be met due to the global pandemic which affected some of company's suppliers' ability to carry out fieldwork. The remaining suppliers are expected to complete their mapping in the coming months (as of June 2020).

    • Y
      +
      1 / 1
      1 / 1

      33. 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. Also, some of the company's mills have Identity Preserved certification.

    • P
      0.9 / 2

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

      The company reports that it has achieved 90 percent full TTP for its palm supply chain at the end of 2020.

    • P
      0.75 / 1

      35. Publishes traceability data at refinery level?

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

    • P
      0.75 / 1

      36. Publishes traceability data at crusher level?

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

  • Certification standards Certification standards
    10.55 / 16 65.9%
    • Organisation: 2 / 2 100%
    • Policy: 3 / 3 100%
    • Practice: 5.6 / 11 50.5%
    • Self-reported: 2.6 / 11 23.2%
    • External: 3 / 11 27.3%
    • Certified: 0 / 11 0%
    • Y
      1 / 1

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

      [Externally verified] 2,011 - The company is a Roundtable on Sustainable Palm Oil (RSPO) member since 2011.

    • Y
      1 / 1

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

      [Externally verified] 2,011 - The company became Roundtable on Sustainable Palm Oil (RSPO) member in 2011 and also achieved its first RSPO P&C certification in 2011.

    • Y
      1 / 1

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

      2020 RSPO ACOP is submitted by the company.

    • Y
      1 / 1

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

      Indonesia (Bangka Belitung, Central Kalimantan, East Kalimantan, Jambi, Lampung, North Sumatra, Papua, Riau, South Sumatra, West Kalimantan).

    • P
      0.46 / 1

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

      46.06% - The company reports percentage of area that is RSPO certified in its RSPO ACOP 2020.

    • P
      0.66 / 1

      42. Percentage of mills RSPO-certified?

      65.95% - The company has total 47 mills, out of which 31 mills are RSPO certified.

    • Y
      1 / 1

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

      2,023 - The company reported to achieve 100% RSPO certification of estates and mills by 2023.

    • Y
      1 / 1

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

      2,017 - The company reports to have achieved100% RSPO certification of all palm product processing facilities in 2017.

    • P
      0.49 / 1

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

      49.27% - The company reports 49.27% of land under scheme smallholders to be RSPO certified.

    • Y
      1 / 1

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

      2,023 - The company reported to achieve 100% RSPO certification of scheme smallholders by 2023.

    • N
      0 / 1

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

    • P
      0.15 / 1

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

      15.86% - The company reports 15.86% of palm oil and palm products handled/traded/processed (tonnes) as RSPO-certified.

    • P
      0.23 / 1

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

      Total CSPO,CSPK sold is reported as 1409748. Certified CSPO, CSPK sold under IP is reported as 328958.

    • P
      0.06 / 1

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

      Identity Preserved and Segregated.

    • P
      0.5 / 1

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

      The company reports that 233,678 hectares of plantations and 35 mills have received ISPO certification. However, the information is not externally verified.

    • 52. Malaysia Sustainable Palm Oil (MSPO) certified?

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

    • Y
      1 / 1

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

      [Externally verified] ISCC.

  • Deforestation and biodiversity Deforestation and biodiversity
    10.96 / 18 60.9%
    • Organisation: 1 / 2 50%
    • Policy: 5 / 10 50%
    • Practice: 5 / 6 82.7%
    • Self-reported: 1.5 / 6 25%
    • External: 0 / 6 0%
    • Certified: 3.5 / 6 57.7%
    • N
      0 / 1

      54. Commitment to zero conversion of natural ecosystems?

    • Y
      1 / 1

      55. Commitment to zero deforestation?

      The company reports that in February 2011, it issued its Forest Conservation Policy (FCP), which committed it to de-linking palm oil production from deforestation.

    • Y
      1 / 1

      56. Commitment to zero deforestation applies to all suppliers?

      The company reports supporting its suppliers' commitments to protect over 100,000 hectares of HCS and HCV areas. The company does this by sharing the importance of complying with its no deforestation commitments as well as guiding them in best practices and helping them formalise their own no deforestation policies.

    • Y
      1 / 1

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

      The company reports the immediate need to ensure no further clearance of High Conservation Value areas, High Carbon Stock forests and peatlands in its supply chain in line with the adoption of company's Forest Conservation Policy (FCP) issued in 2011.

    • Y
      1 / 1

      58. Evidence of monitoring deforestation?

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that since 2017, it is using satellite-based monitoring and radar technology change alerts, which are provided every 24 days for all conservation areas, baseline mapping update in which drones take high-resolution imagery of all conservation areas once every semester and ground verification and reporting in which the plantation staff report directly from areas where the company has received change alerts through radar monitoring. The company, together with nine other major palm oil producers and buyers, is supporting and funding the development of a new radar-based forest monitoring system known as Radar Alerts for Detecting Deforestation (RADD).

    • P
      0.75 / 1

      59. Evidence of monitoring deforestation in supplier operations?

      The company is working with Satelligence to 'deliver near real-time deforestation risk monitoring of our palm oil concessions and supply chain, covering all of Indonesia'.

    • P
      0.5 / 1

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

      0 - The company reported no conversion of natural ecosystems in 2021. Figures for conversion since the company's cut-off date could not be found.

    • P
      0.5 / 1

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

      Some figures are available in the company's grievance list, however, figures are not clear for all logged grievances.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • P
      0.75 / 1

      64. Implementing a landscape or jurisdictional level approach?

      The company reports that through its landscape approach and work with the local community and suppliers, it currently supports, directly and indirectly, the conservation of over 220,000 hectares of forest. It also supports the Landscape Program in Siak Pelalawan District, Riau Province, Indonesia (SPLP) and Aceh Tamiang and Southern Aceh Landscape Program. However, the information reported is not externally verified.

    • N
      0 / 1

      65. Biodiversity policy?

    • N
      0 / 1

      66. Biodiversity policy applies to all suppliers?

    • Y
      +
      1 / 1
      0.46 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company has also identified the species of conservation concern, referencing international and national system of species classification (IUCN, CITES and national regulations).

    • Y
      1 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports to have collaborated with the Orangutan Foundation International (OFI) to help rehabilitate and release wild and ex-captive orangutans back into their natural habitats. From 2011 to 2020 it has released 127 primates. The company also reports that since 2015, it has been carrying out a riparian rehabilitation program in its 18 concessions. By 2018, it has completed the rehabilitation of over 2,700 hectares of riparian buffer zone. It also reports participating in the Riparian Ecosystem Restoration in Tropical Agriculture (RERTA) Project with Cambridge University.

    • Y
      1 / 1

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

      The company reports commitment to prohibit the hunting and poaching of wildlife, including rare, threatened and endangered species within its plantations.

    • Y
      1 / 1

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

      The company commits its suppliers to prohibit the hunting and poaching of wildlife, including rare, threatened and endangered species within their plantations.

  • HCV, HCS and impact assessments HCV, HCS and impact assessments
    12.75 / 15 85%
    • Organisation: 0 / 0 0%
    • Policy: 7 / 8 87.5%
    • Practice: 5.8 / 7 82.1%
    • Self-reported: 0 / 7 0%
    • External: 5.8 / 7 82.1%
    • Certified: 0 / 7 0%
    • Y
      1 / 1

      71. 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.

    • Y
      1 / 1

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

      The company commits its suppliers to conduct High Conservation Value (HCV) assessments.

    • Y
      1 / 1

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

      [Externally verified] The following HCV assessments 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, PT Satya Kisma Usaha.

    • Y
      1 / 1

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

      [Externally verified] The HCV assessment of 'Scheme Smallholders of PT. PIP- Koperasi Kelapa Sawit Mitra Puyang Gana' is publicly available.

    • Y
      1 / 1

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

      [Externally verified] The HCV management and monitoring plan of 'Scheme Smallholders of PT. PIP- Koperasi Kelapa Sawit Mitra Puyang Gana' is publicly available.

    • Y
      1 / 1

      76. 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.

    • P
      0.5 / 1

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

      The company commits its suppliers to using credible HCV assessors, however does not explicitly mention ALS.

    • N
      0 / 1

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

    • Y
      1 / 1

      79. 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 own commitment to the High Carbon Stock (HCS) Approach.

    • Y
      1 / 1

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

      The company commits to the High Carbon Stock (HCS) Approach.

    • Y
      1 / 1

      81. High Carbon Stock (HCS) assessments available?

      [Externally verified] HCS assessments of PT. Djuandasawit Lestari (Smallholder), PT. Djuandasawit Lestari (Partnership Plantation), PT. Cahaya Nusa Gemilang (CNG), PT. Paramitra Internusa Pratama (PIP), PT. Persada Graha Mandiri (PGM), PT. Kencana Graha Permai (KGP), PT. Agrolestari Sentosa (ALS), PT. Tapian Nadenggan (Plantation Partnership), PT. Kresna Duta Agroindo (KDA), PT Satya Kisma Usaha (SKU) Kemitraan, PT Tapian Nadenggan (Plasma), PT Bumi Sawit Permai (Lahat Regency), PT Bumi Sawit Permai (Muara Enim & Ogan Ilir) are publicly available.

    • P
      0.75 / 1

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

      [Externally verified] Peer review of only PT. Paramitra Internusa Pratama (PIP), PT. Persada Graha Mandiri (PGM), PT. Kencana Graha Permai (KGP), PT. Cahaya Nusa Gemilang (CNG) is publicly available.

    • Y
      1 / 1

      83. 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 to carry out Environmental and Social Impact Assessments (EIA and SIA) at the site of its operations prior to any new developments.

    • P
      0.5 / 1

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

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

    • Y
      1 / 1

      85. 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, PT Satya Kisma Usaha.

  • Peat, fire and GHG emissions Peat, fire and GHG emissions
    13.18 / 20 65.9%
    • Organisation: 3 / 5 60%
    • Policy: 6.5 / 8 81.3%
    • Practice: 3.7 / 7 52.6%
    • Self-reported: 1 / 7 14.3%
    • External: 0 / 7 0%
    • Certified: 2.7 / 7 38.3%
    • Y
      1 / 1

      86. 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 regardless of depth.

    • Y
      1 / 1

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

      The company commits its suppliers to no planting on peat regardless of depth.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • Y
      1 / 1

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

      The company reports commitment to adopt and implement best management practices for peatlands and implement best agricultural management practices to maintain and enhance soil fertility.

    • P
      0.5 / 1

      91. 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 peatlands.

    • Y
      +
      1 / 1
      0.46 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has SOPs which specify that the use of fertilisers should be tailored to the texture of the soil and its capacity for retaining nutrients. It also reports to recycle palm fronds and other organic products to increase the fixing capacity of soils. For peat, the company reports to strictly enforce its no development on peat policy by mapping and demarcating the peat areas in its concessions and making sure that no development takes place in those areas. The company's subsidiary PT SMART signed an MoU with the Peat Restoration Agency in 2020 to work together on peat rehabilitation and related community initiatives. Several educational activities are also carried out including education on peat conservation and peat restoration.

    • Y
      1 / 1

      93. Commitment to zero burning?

      The company reports its commitment to no burning for new plantings, replanting or any other development.

    • Y
      1 / 1

      94. Commitment to zero burning applies to all suppliers?

      The company commits its suppliers to no burning for new plantings, replanting or any other development.

    • Y
      +
      1 / 1
      0.22 / 1

      95. 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 reports that all its estates have fire-fighting equipment and it has also trained more than 10,000 Emergency Response Team personnel, stationed across its plantations, ready to deploy at a moment's notice. However, information on how the company monitors and manages fires in not reported.

    • Y
      1 / 1

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

      The company provides 'Fire Incident Reports' of its concessions including smallholder areas for each month from 2016-2021.

    • Y
      1 / 1

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

      19 - The company reports total 19 fire incidents in Desa Makmur Peduli Api (DMPA) Villages in 2020.

    • N
      0 / 1

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

    • Y
      1 / 1

      99. GHG emissions intensity?

      The company reports the GHG emissions intensity for 2020 as 0.99 tCO2e/tonne CPO produced.

    • N
      0 / 1

      100. GHG emissions from land use change?

    • P
      0.5 / 1

      101. Progress towards commitment to reduce GHG emissions intensity?

      The company reports its progress in GHG emissions intensity but there is no improvement since 2018. The company reports GHG emissions intensity for 2018 as 0.84 (tCO2e/tonne CPO produced), for 2019 as 0.91 (tCO2e/tonne CPO produced) and for 2020 as 0.99 (tCO2e/tonne CPO produced).

    • Y
      1 / 1

      102. Methodology used to calculate GHG emissions?

      The company reports that its GHG emissions are calculated following the ISO 14064-1:2006 standard.

    • P
      0.5 / 1

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

      The company reports seven mills with methane capture.

  • Water, chemical and pest management Water, chemical and pest management
    17.35 / 25 69.4%
    • Organisation: 2 / 2 100%
    • Policy: 8 / 11 72.7%
    • Practice: 7.4 / 12 61.3%
    • Self-reported: 0.8 / 12 6.3%
    • External: 0 / 12 0%
    • Certified: 6.6 / 12 55%
    • N
      0 / 1

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

    • Y
      1 / 1

      105. Water use intensity?

      4.11 - The company reports the water consumption for 2020 as 4.11m3 per metric ton of CPO.

    • P
      0.75 / 1

      106. Progress towards commitment on water use intensity?

      The company reports the water intensity for 2019 as 4.27m3 per metric ton of CPO and for 2020 as 4.11m3 per metric ton of CPO. The figures for 2020 show improvement as compared to figures reported in 2019. However, the information is not externally verified.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • Y
      +
      1 / 1
      0.46 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that POME is treated at its waste water treatment pond to reduce acidity, Biological Oxygen Demand (BOD) & Chemical Oxygen Demand (COD) levels so that it becomes safe for use as an organic land fertiliser. To treat POME, the company mixes it with shredded empty fruit bunches to produce compost, which is used as organic fertiliser in some of its estates.

    • N
      0 / 1

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

    • Y
      1 / 1

      111. Commitment to protect natural waterways through buffer zones?

      The company reports its commitment to conserve and protect riparian zones, water catchment areas and other environmental services.

    • Y
      +
      1 / 1
      0.46 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports carrying out a riparian rehabilitation program in its 18 concessions since 2015. Till date (2020), company has maintained over 2,700 hectares of rehabilitated riparian buffer zones. The company also reports participating in the Riparian Ecosystem Restoration in Tropical Agriculture (RERTA) Project with Cambridge University.

    • Y
      1 / 1

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

      The company reports that it recognises concerns over the use of chemical fertilisers and pesticides and aims to reduce and minimise their use.

    • Y
      1 / 1

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

      The company commits its suppliers to minimise the use of chemicals, including pesticides and chemical fertilisers.

    • Y
      1 / 1

      115. Commitment to no use of paraquat?

      The company reports that it stopped using paraquat in 2016.

    • N
      0 / 1

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

      The company only mentions in its social and environmental policy that it will stop the use of paraquat. This policy applies to all suppliers of the company, however, the commitment reported is not time-bound.

    • Y
      1 / 1

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

      The company reports its commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides, except in specific situations.

    • Y
      1 / 1

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

      The company commits its suppliers to no use of World Health Organisation (WHO) Class 1A and 1B pesticides, except in specific situations.

    • Y
      1 / 1

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

      The company reports its commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention, except in specific situations.

    • Y
      1 / 1

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

      The company commits its suppliers to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention, except in specific situations.

    • Y
      1 / 1

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

      The company provides a list of pesticides and bio-pesticides used per ha.

    • Y
      +
      1 / 1
      0.22 / 1

      122. 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 also reports that in order to minimise the use of chemical pesticides, it is promoting the use of biopesticides to enhance the health condition of the soils and the palm trees. The company is also pursuing intensification of oil palm cultivation through a progressive implementation of precision agriculture.

    • Y
      +
      1 / 1
      0.46 / 1

      123. Integrated Pest Management (IPM) approach?

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also has an integrated pest management (IPM) approach which combines cultural, mechanical, biological and chemical means to control pests while minimising economic, public health and environmental risks. Examples of this include breeding barn owls to control the rat population; encouraging leopard cats which also prey on rodents to stay within its plantations; controlling leaf-eating caterpillars through diversity of flora; and encouraging the growth of beneficial plants and using pheromones to control rhinoceros beetles.

    • Y
      1 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports having zero waste policy in place.

  • Community, land and labour rights Community, land and labour rights
    31.75 / 35 90.7%
    • Organisation: 4.5 / 5 90%
    • Policy: 18.5 / 21 88.1%
    • Practice: 8.8 / 9 97.2%
    • Self-reported: 0.8 / 9 8.3%
    • External: 0 / 9 0%
    • Certified: 8 / 9 88.9%
    • Y
      1 / 1

      125. Commitment to human rights?

      The company reports its commitment to upholding and promoting the United Nations Universal Declaration of Human Rights for all workers, contractors, indigenous peoples and local communities in all company operations.

    • Y
      1 / 1

      126. Commitment to human rights applies to all suppliers?

      The company commits its suppliers to upholding and promoting the United Nations Universal Declaration of Human Rights for all workers, contractors, indigenous peoples and local communities in all their operations.

    • Y
      1 / 1

      127. 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 participating in the RSPO working groups on human rights and in 2020, as part of the Global Agribusiness Alliance, it also helped to produce a toolkit to advance human rights policy and practice in the agribusiness sector.

    • P
      0.5 / 1

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

      The company reports its commitment to respect local communities and indigenous rights but only in relation to FPIC.

    • P
      0.5 / 1

      129. Commitment to indigenous 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.

    • Y
      1 / 1

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

      The company reports commitment to respecting land tenure rights by stating that it supports the Food and Agriculture Organisation's Voluntary Guidelines on the Responsible Governance of Tenure which promotes secure tenure rights and equitable access to land, fisheries and forests as a means of eradicating hunger and poverty, supporting sustainable development and protecting the environment.

    • Y
      1 / 1

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

      The company commits its suppliers to support the Food and Agriculture Organisation's Voluntary Guidelines on the Responsible Governance of Tenure which promotes secure tenure rights and equitable access to land, fisheries and forests as a means of eradicating hunger and poverty, supporting sustainable development and protecting the environment.

    • Y
      1 / 1

      132. 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).

    • Y
      1 / 1

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

      The company commits its suppliers to free, prior and informed consent (FPIC).

    • Y
      1 / 1

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

      The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). 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 procedure for the Implementation of Free, Prior, and Informed Consent (FPIC).

    • P
      0.75 / 1

      135. Examples of local stakeholder engagement to prevent conflicts?

      The company reports that its conflict management system maps all conflicts related to its operations and develops action plans to address them. It incorporates: transparent monitoring and reporting; the option for local community and customary groups to access independent legal and technical advice; the ability for complainants to choose individuals or groups to support them or act as observers; as well as the option of a third-party mediator. The company has also published a guideline on participatory mapping and also reports information on participatory mapping in its latest sustainability report.. However, the information reported is not externally verified.

    • Y
      1 / 1

      136. Details of process for addressing land conflicts available?

      The company has a 'Procedure for Social Conflict Handling'.

    • Y
      1 / 1

      137. 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 own reporting has limited details on the inclusion of women across palm oil operations.

    • Y
      1 / 1

      138. Commitment to mitigate impacts on food security?

      The company reports that before any new development, it will assess their food security and ensure that land used for food crops to fulfil community needs will not be converted and planted on by the company.

    • Y
      1 / 1

      139. 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 to have 'The Alternative Livelihood Programme' through which it approaches food security for communities under its Desa Makmur Peduli Api initiative. It typically assists communities in funding pilot plots and providing planting materials. It also help train local farmers in good agricultural practices and provide ongoing support including access to experts in modern agriculture. In some cases, where communities have successfully grown cash crops or enough food crops to have sustained surpluses for sale, the company trains community members in the fundamentals of managing small businesses and links these emerging community enterprises to buyers of their produce and sources of financing.

    • Y
      1 / 1

      140. Commitment to provide essential community services and facilities?

      The company reports its commitment to provide essential community services and facilities.

    • Y
      1 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports its own progress on commitment to provide essential community services and facilities in its latest sustainability report and on its website.

    • Y
      1 / 1

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

      The company reports its commitment to provide work opportunities for local communities.

    • P
      0.5 / 1

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

      The company only reports its commitment to freedom of association, right to organise and collective bargaining, no discrimination, prohibition of forced and child labour. Commitment to equal remuneration is not reported.

    • P
      0.5 / 1

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

      The company only commits its suppliers to freedom of association, right to organise and collective bargaining, no discrimination, prohibition of forced and child labour. Commitment to minimum age and equal remuneration is not reported.

    • Y
      1 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting provides limited details on the company's progress on commitment to respect all workers' rights.

    • Y
      1 / 1

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

      The company reports its commitment to eliminate gender related discrimination with regards to employment.

    • Y
      1 / 1

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

      The company commits its suppliers to eliminate gender related discrimination with regards to employment.

    • Y
      1 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to have zero tolerance for sexual harassment and conducts extensive training and socialisation for all estate and mill workers to ensure this is understood. Gender committees with representatives from labour unions and management have been set up to promote female participation and advancement in the workplace. These committees also handle sexual harassment complaints. The company reports that in 2020, no cases of discrimination, harassment or abuse were reported.

    • Y
      1 / 1

      149. Percentage or number of temporary employees?

      8,654 (4.16%) - The company reports the total number of part-time employees in 2020 as 8654 (Male- 4012, Female- 4642).

    • Y
      1 / 1

      150. Percentage or number of women employees?

      61,570 (29.64%) - The company reports total number of women employees in 2020 as 61570. Figure includes permanent- 18,277, fixed-term- 12,239, full-time- 25,874, part-time- 4,642 and new hires- 538.

    • Y
      1 / 1

      151. Commitment to pay a Decent Living wage?

      The company reports that it adheres to all Indonesian labour laws covering areas such as freedom of association for our employees, decent pay and working hours, non-discrimination and the complete elimination of child and forced labour.

    • P
      0.5 / 1

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

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

    • Y
      1 / 1

      153. 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. The company's own reporting only mentions the ratio of company's lowest monthly wage and provincial minimum wage for Sumatra, Kalimantan and Papua as 1:1.

    • P
      0.5 / 1

      154. Reporting of salary by gender?

      The company reports the ratio of average basic salary of women to men for its staff, middle management and senior management. However, the reporting does not cover all employees and significant locations of company's operations.

    • Y
      1 / 1

      155. Commitment to address occupational health and safety?

      The company reports commitment to ensure that its plantations and mills have an OHS policy in place.

    • Y
      1 / 1

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

      The company commits its suppliers to address occupational health and safety.

    • Y
      1 / 1

      157. Provision of personal protective equipment and related training?

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting mentions that it assess work-related hazards through Hazard Identification and Risk Analysis, and by conducting OHS Cross Inspection to record unsafe actions and conditions. The Safety Committee considers the hazards and risks and determines suitable action to address gaps such as additional training; reviewing and strengthening safety SOPs; and ensuring Personal Protective Equipment (PPE) is adequate and worn by employees.

    • Y
      1 / 1

      158. Time lost due to work-based injuries?

      The company reports Lost Time Injury Frequency Rate for upstream operations as 2.09 and Lost Time Injury Frequency Rate for downstream operations as 0.43.

    • Y
      1 / 1

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

      4 - The company reports two (2) fatalities in upstream operations and two (2) fatalities in contractors of downstream operations.

  • Smallholders and suppliers Smallholders and suppliers
    12.75 / 16 79.7%
    • Organisation: 0 / 0 0%
    • Policy: 5 / 6 83.3%
    • Practice: 7.8 / 10 77.5%
    • Self-reported: 5 / 10 50%
    • External: 0.8 / 10 7.5%
    • Certified: 2 / 10 20%
    • Y
      1 / 1

      160. Commitment to support smallholders?

      The company report its commitment to support the inclusion of smallholders and local businesses into its sustainable supply chain and aims to help them comply with its sustainability policy in fair, transparent and accountable partnerships.

    • Y
      1 / 1

      161. Programme to support scheme/plasma smallholders?

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports to fully support the development of plasma smallholders and is committed to improving the productivity of plasma smallholders by providing them with high yielding seeds, transfer of knowledge and capacity building through training on best agricultural practices.

    • P
      0.75 / 1

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

      70,800 - The company reports that in 2020, around 70,800 plasma smallholders supplied FFB to the company, about 19 percent of its total intake of FFB. However, the information reported is not externally verified.

    • Y
      1 / 1

      163. Programme to support independent smallholders?

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports to extend its support to independent smallholders and has been a strong supporter of the Independent Farmers Replanting Scheme since its launch in 2014. The program was set up to encourage independent smallholders to replant with better quality, higher-yielding seeds which will help boost productivity and incomes, while potentially reducing the demand for new agricultural land. It gives farmers access to financing, helping them sustain their livelihoods during the four years it takes for the new seedlings to mature.

    • P
      0.5 / 1

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

      4,200 - The company reports it supported 4200 independent smallholders in 2018.

    • Y
      1 / 1

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

      The company reports that it engages intensively and extensively with its critical suppliers through multiple avenues, gaining their trust and confidence. 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.

    • P
      0.75 / 1

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

      The company reports that in 2020, 29 direct and 16 indirect potential suppliers were screened based on environmental and social criteria, 31(7.2%) of the existing suppliers were assessed through site visits and remote assessments, 425(100%) suppliers were assessed through spatial analysis and publicly reported information. All the information is self reported.

    • Y
      1 / 1

      167. Suspension or exclusion criteria for suppliers?

      The company reports that the suppliers deemed non-compliant will no longer form part of the company's supply chain. The company reports to have 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.

    • P
      0.5 / 1

      168. 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.

    • P
      0.75 / 1

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

      [Externally verified] The company reports the number of suppliers that are compliant with its sustainability policies. The company separately reports the proportion of its direct supply that complies with its no-deforestation and no-peat commitments. Indirect supply is not reported.

    • P
      0.5 / 1

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

      The company only reports it carries out site visits to suppliers, especially those deemed high-risk, to document and understand the gaps and difficulties they face in adopting responsible practices. Based on the company findings, it then determines a risk ranking for each supplier. High-risk suppliers are prioritised for site visits and deep engagement. Every year, the company aims to visit at least 20 critical, high-risk suppliers. However, a time-bound plan to engage with all high risk mills is not reported by the company.

    • P
      0.75 / 1

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

      The company reports that it details the findings from the site visits, including recommendations and actions for improvement, in a report that is shared with the supplier. Then, the company works with the mills to develop and implement time-bound action plans for it to monitor progress against. By conducting these assessments, the company is able to help its suppliers improve through capacity building and sharing of best practices. Based on assessments of its suppliers' most pressing needs, it continued to help them with training in traceability; responsible labour practices; and implementation of FPIC and human rights.

    • P
      0.75 / 1

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

      The company prioritizes high-risk mills for site visits and deep engagement and reports that it aims to visit at least 20 critical, high-risk suppliers every year.

    • Y
      1 / 1

      173. 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 level.

    • P
      0.75 / 1

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

      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.

    • P
      0.75 / 1

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

      High risk: 109 mills (26%) Medium risk: 184 mills (43%) Low risk: 132 mills (31%). Types of risk- Potential deforestation, waste management, GHG emissions, labour practices, OHS and FPIC implementation.

  • Governance and grievances Governance and grievances
    6.5 / 7 92.9%
    • Organisation: 0 / 0 0%
    • Policy: 4.5 / 5 90%
    • Practice: 2 / 2 100%
    • Self-reported: 1 / 2 50%
    • External: 0 / 2 0%
    • Certified: 1 / 2 50%
    • Y
      1 / 1

      176. Commitment to ethical conduct and prohibition of corruption?

      The company reports its commitment to ethical conduct and prohibition of corruption.

    • Y
      1 / 1

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

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

    • Y
      1 / 1

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

      Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that no cases of bribery or corruption were reported in 2020.

    • P
      0.5 / 1

      179. 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 issues.

    • Y
      1 / 1

      180. Whistleblowing procedure?

      The company has a whistleblowing mechanism in place.

    • Y
      1 / 1

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

      The company has a grievance procedure open to all stakeholders.

    • Y
      1 / 1

      182. Details of complaints and grievances disclosed?

      Details of complaints and grievances are disclosed by the company.

Media monitor: Golden Agri Resources Ltd

SPOTT monitors global media sources for coverage of assessed companies. The media monitor gathers reports about specific activities related to the assessment indicator categories. ZSL does not assess or score the validity of media coverage, but users can explore the media monitor to provide context on implementation, and infer risks associated with reported operations on the ground.

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