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Golden Plantation Tbk PT

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

Show media reports (9) Show ESG scores Show supply chain scores Modify score weighting
  • Parent company:
    PT JOM Prawarsa Indonesia
  • Landbank (oil palm)
    63,441 hectares
  • Thomson Reuters ticker:
    GOLL.JK
  • Bloomberg ticker:
    GOLL IJ (Suspended)
  • ISIN:
    ID1000133200
  • RSPO member?
    No
  • Website:

Company assessment: Golden Plantation Tbk PT – November 2021

Assessment date:

Score by disclosure type:

Total: 11.5% 21.75 / 190
  • Organisation: 6 / 39 15.4%
  • Policy: 11 / 76 14.5%
  • Practice: 4.8 / 75 6.3%
  • Self-reported: 2.5 / 75 3.3%
  • External: 0 / 75 0%
  • Certified: 2.3 / 75 3%
  • Sustainability policy and leadership Sustainability policy and leadership
    1 / 11 9.1%
    • Organisation: 1 / 6 16.7%
    • Policy: 0 / 2 0%
    • Practice: 0 / 3 0%
    • Self-reported: 0 / 3 0%
    • External: 0 / 3 0%
    • Certified: 0 / 3 0%
    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      3. High-level position of responsibility for sustainability?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • P
      0.5 / 1

      6. Percentage or number of women board members?

      0 (0%) - The company's annual report published the profile of its board member but gender balance is not directly reported by the company.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • P
      0.5 / 1

      9. Sustainability report published within last two years?

      The requirements of the sustainability report are integrated into the annual report 2018.

    • N
      0 / 1

      10. Reports through standardised reporting systems?

    • 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?

  • Landbank, maps and traceability Landbank, maps and traceability
    3.5 / 27 13%
    • Organisation: 3.5 / 17 20.6%
    • Policy: 0 / 2 0%
    • Practice: 0 / 8 0%
    • Self-reported: 0 / 8 0%
    • External: 0 / 8 0%
    • Certified: 0 / 8 0%
    • P
      0.5 / 1

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

      63,441 - The company owns total of 63,441 hectares (ha) concession areas.

    • P
      0.5 / 1

      14. Total oil palm planted area (ha)?

      24,686 - The company reported total of 24,686 hectares (ha) of planted areas.

    • P
      0.5 / 1

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

      3,000 - The company's annual report disclose 3000 ha of smallholder planted area.

    • N
      0 / 1

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

    • N
      0 / 1

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

      197.04 - The company reported its conservation area for subsidiary PT Bumiraya Investindo.

    • P
      0.5 / 1

      18. Maps of estates/management units?

      A static image is available in the company's 2018 Annual Report.

    • N
      0 / 1

      19. Maps of scheme/plasma smallholders?

    • N
      0 / 1

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

    • P
      0.5 / 1

      21. Number of company-owned mills?

      1 - The company have one mill owned by its subsidiary PT Bumiraya Investindo.

    • Y
      1 / 1

      22. Names and locations of company-owned mills?

      The location of company owned mill PT Bumiraya Investindo is available in GFW.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      25. Number of third party supplying mills?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 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?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 2

      31. Percentage of supply traceable to mill level?

    • N
      0 / 1

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

    • N
      0 / 2

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

    • N
      0 / 2

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

    • N
      0 / 1

      35. Publishes traceability data at refinery level?

    • N
      0 / 1

      36. Publishes traceability data at crusher level?

  • Certification standards Certification standards
    0 / 16 0%
    • Organisation: 0 / 2 0%
    • Policy: 0 / 3 0%
    • Practice: 0 / 11 0%
    • Self-reported: 0 / 11 0%
    • External: 0 / 11 0%
    • Certified: 0 / 11 0%
    • N
      0 / 1

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

    • N
      0 / 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?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      42. Percentage of mills RSPO-certified?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

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

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

    • N
      0 / 1

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

  • Deforestation and biodiversity Deforestation and biodiversity
    1 / 18 5.6%
    • Organisation: 0 / 2 0%
    • Policy: 1 / 10 10%
    • Practice: 0 / 6 0%
    • Self-reported: 0 / 6 0%
    • External: 0 / 6 0%
    • Certified: 0 / 6 0%
    • N
      0 / 1

      54. Commitment to zero conversion of natural ecosystems?

      The company has a Commitment to Land Clearing Without Burning, however it does not report a commitment to zero conversion of natural ecosystems, and therefore no points can be awarded.

    • Y
      1 / 1

      55. Commitment to zero deforestation?

      The company specifies a commitment to clear lands without deforestation.

    • N
      0 / 1

      56. Commitment to zero deforestation applies to all suppliers?

    • N
      0 / 1

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

    • N
      0 / 1

      58. Evidence of monitoring deforestation?

    • N
      0 / 1

      59. Evidence of monitoring deforestation in supplier operations?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • 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?

    • N
      0 / 1

      64. Implementing a landscape or jurisdictional level approach?

    • N
      0 / 1

      65. Biodiversity policy?

    • N
      0 / 1

      66. Biodiversity policy applies to all suppliers?

    • N
      0 / 2

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

  • HCV, HCS and impact assessments HCV, HCS and impact assessments
    1 / 15 6.7%
    • Organisation: 0 / 0 0%
    • Policy: 1 / 8 12.5%
    • Practice: 0 / 7 0%
    • Self-reported: 0 / 7 0%
    • External: 0 / 7 0%
    • Certified: 0 / 7 0%
    • P
      0.5 / 1

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

      The company conducts a series of High Conservation Value (HCV) assessments as part of its commitment to sustainable oil palm plantation development.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 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?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      81. High Carbon Stock (HCS) assessments available?

    • N
      0 / 1

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

    • P
      0.5 / 1

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

      The company reports that it embodies the commitment to realizing sustainable palm oil industry management in accordance with RSPO and ISPO principles and criteria by conducting social impact assessments (SIA) in Kalimantan and Sumatera only.

    • N
      0 / 1

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

    • N
      0 / 1

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

  • Peat, fire and GHG emissions Peat, fire and GHG emissions
    2 / 20 10%
    • Organisation: 0 / 5 0%
    • Policy: 1.5 / 8 18.8%
    • Practice: 0.5 / 7 7.1%
    • Self-reported: 0 / 7 0%
    • External: 0 / 7 0%
    • Certified: 0.5 / 7 7.1%
    • P
      0.5 / 1

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

      The company commits to clear lands without planting in peatlands, and without burning, however the depth of peatlands is not specified by the company.

    • N
      0 / 1

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

    • 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?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 2

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

    • Y
      1 / 1

      93. Commitment to zero burning?

      The company provide commitment for no or zero burning.

    • N
      0 / 1

      94. Commitment to zero burning applies to all suppliers?

    • P
      0.5 / 2

      95. Evidence of fire monitoring and management?

      The company provides limited information regarding fire monitoring plans.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      99. GHG emissions intensity?

    • N
      0 / 1

      100. GHG emissions from land use change?

    • N
      0 / 1

      101. Progress towards commitment to reduce GHG emissions intensity?

    • N
      0 / 1

      102. Methodology used to calculate GHG emissions?

    • N
      0 / 1

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

  • Water, chemical and pest management Water, chemical and pest management
    2.75 / 25 11%
    • Organisation: 0 / 2 0%
    • Policy: 0.5 / 11 4.6%
    • Practice: 2.3 / 12 18.8%
    • Self-reported: 0.5 / 12 4.2%
    • External: 0 / 12 0%
    • Certified: 1.8 / 12 14.6%
    • N
      0 / 1

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

    • N
      0 / 1

      105. Water use intensity?

    • N
      0 / 1

      106. Progress towards commitment on water use intensity?

    • 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)?

    • P
      0.75 / 2

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

      The company treat the Palm Oil Mill Effluent (POME) through the development of Land Application in the form of 14 waste storage ponds.

    • N
      0 / 1

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

    • N
      0 / 1

      111. Commitment to protect natural waterways through buffer zones?

    • N
      0 / 2

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

    • P
      0.5 / 1

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

      The company only commits to reduce fertilizer and not pesticides.

    • N
      0 / 1

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

    • N
      0 / 1

      115. Commitment to no use of paraquat?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • P
      0.5 / 2

      122. Implementation of commitment to minimise inorganic fertiliser use?

      The company replace the fertilizer with solid nutrient-enriched waste from harvested fruit bunches.

    • P
      0.5 / 2

      123. Integrated Pest Management (IPM) approach?

      The company reports that 'to reduce and control pests, it implements integrated pest control that is safe for humans and the environment by using natural predators, for example, owl for rats, and through periodic observation to monitor pest infestation to accommodate early preventive measures if necessary.

    • P
      0.5 / 1

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

      The company have a waste management system in line with the environmental regulations.

  • Community, land and labour rights Community, land and labour rights
    6.5 / 35 18.6%
    • Organisation: 1.5 / 5 30%
    • Policy: 3.5 / 21 16.7%
    • Practice: 1.5 / 9 16.7%
    • Self-reported: 1.5 / 9 16.7%
    • External: 0 / 9 0%
    • Certified: 0 / 9 0%
    • N
      0 / 1

      125. Commitment to human rights?

    • N
      0 / 1

      126. Commitment to human rights applies to all suppliers?

    • N
      0 / 1

      127. Progress on human rights commitment?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • P
      0.5 / 1

      135. Examples of local stakeholder engagement to prevent conflicts?

      The company lists only one example to prevent conflict by local stakeholder engagement in its annual report 2017.

    • N
      0 / 1

      136. Details of process for addressing land conflicts available?

    • N
      0 / 1

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

    • N
      0 / 1

      138. Commitment to mitigate impacts on food security?

    • N
      0 / 1

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

    • P
      0.5 / 1

      140. Commitment to provide essential community services and facilities?

      The company provides an unclear commitment towards community services and facilities.

    • P
      0.5 / 1

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

      The company is involved in infrastructure repair and road repair.

    • Y
      1 / 1

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

      The company has a policy to hire and empower local workers from its operational areas.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • Y
      1 / 1

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

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • P
      0.5 / 1

      149. Percentage or number of temporary employees?

      310 (34.44%) - The company reports the total number of non-permanent employees in its annual report 2018.

    • P
      0.5 / 1

      150. Percentage or number of women employees?

      92 (10.22%) - The company reports the total number of women employees in its annual report 2018.

    • N
      0 / 1

      151. Commitment to pay a Decent Living wage?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      154. Reporting of salary by gender?

    • Y
      1 / 1

      155. Commitment to address occupational health and safety?

      The company mention about Occupational Safety and Health Development Committee in its annual report.

    • N
      0 / 1

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

    • P
      0.5 / 1

      157. Provision of personal protective equipment and related training?

      The company only reports that it provides all safety equipment and facilities, including Personal Protective Equipment, and healthcare facilities to all employees at the Estates and mill. Training provision is not reported.

    • N
      0 / 1

      158. Time lost due to work-based injuries?

    • P
      0.5 / 1

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

      0 - The company reports that in 2018, there was no minor, major or fatal work accidents.

  • Smallholders and suppliers Smallholders and suppliers
    1 / 16 6.3%
    • Organisation: 0 / 0 0%
    • Policy: 0.5 / 6 8.3%
    • Practice: 0.5 / 10 5%
    • Self-reported: 0.5 / 10 5%
    • External: 0 / 10 0%
    • Certified: 0 / 10 0%
    • P
      0.5 / 1

      160. Commitment to support smallholders?

      The company conduct training, improve the welfare of surrounding smallholder, which does not seems to be strong commitment.

    • P
      0.5 / 1

      161. Programme to support scheme/plasma smallholders?

      The company only reports to improve the welfare of surrounding smallholders, and conduct training for and dissemination to smallholders.

    • N
      0 / 1

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

    • N
      0 / 1

      163. Programme to support independent smallholders?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

      167. Suspension or exclusion criteria for suppliers?

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

  • Governance and grievances Governance and grievances
    3 / 7 42.9%
    • Organisation: 0 / 0 0%
    • Policy: 3 / 5 60%
    • Practice: 0 / 2 0%
    • Self-reported: 0 / 2 0%
    • External: 0 / 2 0%
    • Certified: 0 / 2 0%
    • Y
      1 / 1

      176. Commitment to ethical conduct and prohibition of corruption?

      The company reports to have anti-corruption policies and covers fair practices under its Good Corporate Governance (GCG) guidelines.

    • N
      0 / 1

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

    • N
      0 / 1

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

    • N
      0 / 1

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

    • Y
      1 / 1

      180. Whistleblowing procedure?

      The company reports having a whistleblowing system with clear description of steps taken.

    • Y
      1 / 1

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

      The company do have an employee grievance mechanism along with a system for external complaints.

    • N
      0 / 1

      182. Details of complaints and grievances disclosed?

Media monitor: Golden Plantation Tbk PT

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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