Goodhope Asia Holdings 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?

The company reports it has a Head of Group Sustainability.

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

One member of the company's board is reported to have responsibility for sustainability.

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

4 (8.51%) - The company reports four female in its senior management team of 47 members.

6. Percentage or number of women board members?

1 (7.14%) - The company reports 1 female board member out of a total of 14 members.

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

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

The company reports evidence of multiple collaborations including working with Environmental Leadership and Training Initiative (ELTI), Aidenvironment Swaraowa, Aidenvironment and IDH Sustainable Trade Initiative to facilitate the delivery of capacity building initiatives and the development of livelihood programs. The company has also collaborated with Earthworm Foundation's CSE and Daemeter Consulting to supports the local communities, farmers and smallholders through a capacity building project and internship programme.

9. Sustainability report published within last two years?

The company has published a series of implementation reports covering multiple aspects of sustainability.

10. Reports through standardised reporting systems?

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

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

12. Climate risks assessment available?

The company has a climate risk assessment summary available which includes climate risks, potential impacts, and mitigation. However the company does not included metrics, targets, and processes used to assess or manage climate risks.

13. Lists countries and operations?

The company reports that its plantations and mills are in Indonesia and its two refineries are in Malaysia.

14. Lists countries sourcing from?

The company sources from Indonesia and Malaysia.

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

100041 - The company reports a total area of 100041 ha in its 2021 ACOP.

16. Total oil palm planted area (ha)?

69244 - The company reports total a total of 66,201 ha of planted area which includes infrastructure in its 2021 ACOP and 69,244 ha of planted area in its latest sustainability report. The figure in the Sustainability Report includes plasma and excludes infrastructure while the figure reported in ACOP excludes plasma and includes infrastructure.

17. Scheme smallholders planted area (ha)?

7304 - The company reports a total of 7,304 ha of land under scheme smallholder in its sustainability report and 7,488 ha in its 2021 ACOP. This disparity is less than 5%.

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

8038 - The company reports total 8,038 ha of total unplanted area in its 2021 ACOP.

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

18314 - The company reports that the total land designated and managed as HCV areas is 18,314 hectares in its 2021 ACOP.

20. Maps of estates/management units?

The company specifies that maps represent 100% of concession sites in RSPO 2021 ACOP. The company also has six concession on GFW.

21. Maps of scheme smallholders?

The boundaries of plasma estates for PT Agrajaya Baktitama, PT Batu Mas Sejahtera and PT Sawit Makmur Sejahtera are available in the company's HCS report, but maps of other plasma smallholders are not available. The company has not reported new planting in its ACOP since 2017 so although the data is also between two and five years old, it is not limited due to its age.

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

The company reports the names and locations of all third-party supplying plantations.

23. Number of company-owned mills?

8 - The company reports that it has eight palm oil mills.

24. Names and locations of company-owned mills?

The company has provided names and coordinates of all eight mills.

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

Five palm oil mills sourced FFB from the company's own plantations, scheme smallholders and third party suppliers. The remaining three mills only sourced from own plantations and scheme smallholders.

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

The company reports that 77.8% of the fresh fruit bunches (FFB) was cultivated in company-owned plantation, 17.1% was sourced from third party suppliers and 5.1% came from scheme smallholders.

27. Number of third party supplying mills?

64 - The company reports a total of 64 third party supplying mills.

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

The company provides name and location of all third party supplying mill in its traceability summary.

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

64% of third party supplying mills to Premium Vegetable Oils Sdn Bhd source their FFB from own plantation and third party supply (mixed), whereas 36% source from third party supply only.

30. 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 that 53% of FFB sourced from third-party supplying mills come from the supplying mills' own operations and 47% comes from third parties.

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

The company reports that 8% of volumes sourced for refineries come from intermediary traders and refiners, compared to 92% that come directly from mills.

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

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

33. Percentage of supply traceable to mill level?

The company reports that 100% of supply is traceable to mill level. One of the company's processing facilities (PT Agro Asia Pacific) is certified under the IP model, providing external verification for additional scoring.

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

The company commits to achieve 100% traceability to plantation level by the year 2025.

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

The company reports that overall 97.9% of all FFB sourced by its palm oil mills is traceable to plantation level. One of the companies mills (PT Agro Indomas - Sungai Purun Indonesia) is certified under the IP model, hence additional points.

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

The company reports that 24.4% of supply from third-party mills is traceable to plantation level.

37. Publishes traceability data at refinery level?

The company reports traceability to mill (99.4%) and to plantation (24.4%) for its integrated refineries.

38. Publishes traceability data at crusher level?

The company reports 81.64% of supply traceable to plantation level for its crusher as of May 2020.

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

[Externally verified] 2006 - The company is a member of RSPO since 2006.

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

2012 - The company became an RSPO member in 2006, and had its first certification in 2012.

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

The company has submitted its 2021 ACOP.

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

[Externally verified] 48.87% - The company has 48.87% of its area certified.

43. Percentage of mills RSPO-certified?

[Externally verified] 62.5% - The company reports that 5 out of its 8 mills are RSPO certified.

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

2022 - The company plan for achieving 100% RSPO certification of estates and mills by 2022.

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

2026 - The company plan for achieving 100% RSPO certification of all palm product processing facilities by 2026.

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

[Externally verified] 2.4% - The company reports 2.40% of certified land under scheme smallholders in its 2021 RSPO ACOP.

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

2025 - The company plan for achieving 100% RSPO certification of scheme/plasma/associated smallholders and outgrowers by 2025.

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

0% of FFB supply from independent smallholders/outgrowers/third-party FFB suppliers is RSPO-certified.

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

[Externally verified] 19.3% - The company reports 19.30% of all palm oil and oil palm products handled/traded/processed (tonnes) that is RSPO-certified.

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

[Externally verified] The company sells approximately 32.2% RSPO-certified palm oil through Segregated or Identity Preserved supply chains.

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

[Externally verified] The company discloses 4.28% RSPO-certified palm oil through Segregated or Identity Preserved supply chains in 2021 RSPO ACOP.

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

The company states that two of its subsidiaries have ISPO certification. As this does not cover 100% of operations and the information is not externally verified, partial points have been awarded.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company's two refineries are MSPO certified. This does not cover all operations.

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

[Externally verified] The company has ISSC and ISO 14001 certification.

55. Commitment to zero conversion of natural ecosystems?

The company commits to zero conversion of natural ecosystems.

56. Commitment to zero deforestation?

The company commits to zero deforestation.

57. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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

The company defines deforestation as the development of HCV and HCS areas, and peat areas, and specifies any deforestation/conversion past June 2020 will not be accepted.

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

The company defines deforestation for suppliers as the development of HCV and HCS areas, and peat areas, and specifies any deforestation/conversion past June 2020 will not be accepted in supplier operations.

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

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

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

The company reports to use Radar Alerts for Detecting Deforestation (RADD) forest disturbance alerts which is publicly available on the Global Forest Watch (GFW) platform to monitor deforestation in supplier operations. The extent of area being monitored for deforestation and time-frames are unclear.

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

0 - The company reports that there has been no deforestation recorded in its own operations since the cut-off date.

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

The company reports estimated figures of deforestation in it supplier operations but this does not clearly cover all deforestation since the cut-off date. No overall figure is provided and information is reported in the company's grievances list.

64. Commitment to restoration of deforestation/conversion?

The company commits to restore ecosystems to their prior condition in cases of conversion within its own operations with a cut-off date of May 2017.

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

The company commits suppliers to restore ecosystems to their prior condition in cases of conversion within their own operations.

66. Implementing a landscape or jurisdictional level approach?

The company reports implementing a landscape level approach in Papua to establish a 'Kawasan Ecosystem Essential' (KEE) area of 107,581.66 ha that is outside of existing conservation areas. The company has worked with representatives of Papuan Customary Councils, Indigenous Peoples Institutions, universities, NGOs, companies, and village heads to deliver on this project.

67. Biodiversity policy?

68. Biodiversity policy applies to all suppliers?

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company states it used the IUCN referencing system to identify species of conservation concern but does not provide a list of the species.

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

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

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

The company commits to only allow sustainable hunting of species by local communities for subsistence purposes in its operations.

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

The company commits all suppliers to only allow sustainable hunting of species by local communities for subsistence purposes in their operations.

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

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

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

The company commits all suppliers to conduct HCV assessments.

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

[Externally verified] The company provides the HCV assessment for PT Agro Wana Lestari.

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

[Externally verified] The company provides the HCV assessments for the following: PT Nabire Baru, PT Agro Bukit (South Kalimantan), PT Agro Indomas (East Kalimantan) and PT Karya Makmur Sejahtera.

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

[Externally verified] The company provides HCV management and monitoring plans for the following: PT Nabire Baru, PT Agro Bukit (South Kalimantan), PT Agro Indomas (East Kalimantan), and PT Karya Makmur Sejahtera.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also commits to only use licensed HCV assessors accredited by the HCV Resource Network's ALS in its own reporting.

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

The company commits all suppliers to only use licensed HCV assessors accredited by the HCV Resource Network's ALS.

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

[Externally verified] All four of the company's HCV assessments have all received a satisfactory review by the HCV ALS Quality Panel.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also commits to apply the HCS Approach as defined by the HCS Approach Toolkit in its own reporting.

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

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

83. High Carbon Stock (HCS) assessments available?

[Externally verified] The company has four HCS reports available through the HCS Approach website.

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

[Externally verified] The company's four HCS assessments undertaken since April 2015 have been peer reviewed by the HCSA Quality Assurance Process.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also commits to conduct social and environmental impact assessments in its own reporting.

86. 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.

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

[Externally verified] The company provides SEIAs for the following: PT Agro Indomas (East Kalimantan), PT Karya Makmur Sejahtera, PT Agro Bukit (South Kalimantan) and PT Agro Wana Lestari. All have management and monitoring plans.

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

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

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

The company commits all suppliers to no planting on peat of any depth.

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

8037 - The company reports a total of 8,037 hectares of oil palm planted on peatland.

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

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

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

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

The company commits all suppliers to best management practices peat and good agricultural practices for soils.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to implement water and soil management and monitoring systems as well as capacity building activities to promote best management practices, however this information is between two and five years old.

95. Commitment to zero burning?

The company commits to zero burning.

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

97. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to have a hotspot monitoring system to alert fire response teams, and to have conducted a Fire Fighting Training Program across three locations in 2021.

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

The company reports 66 in company concessions in 2021.

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

425 - The company reports that in 2021, 425 fires were recorded within the proximity of concessions.

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

The company commits to reduce GHG intensity by 10% by 2022 from 2019 levels.

101. GHG emissions intensity?

The company reports that its GHG emissions intensity was 1.12 MT CO2 e/MT CPO in 2020 for mills and estates and 0.23 MT CO2/ MT product for its refinery.

102. GHG emissions from land use change?

The company states that 816,736 MT CO2e (50%) of its emissions come from land conversion.

103. Progress towards commitment to reduce GHG emissions intensity?

The company reports that its GHG emissions intensity has improved from 2019 to 2020 for both downstream (refinery) and upstream operations.

104. Methodology used to calculate GHG emissions?

The company uses the RSPO Palm Oil GHG Calculator methodology to calculate GHG emissions.

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

The company reports to have installed its first methane capture facility in 2021. One out of seven (14%) mills have methane capture.

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

The company commits to reduce water intensity by 10% by the year 2022.

107. Water use intensity?

1.07 - The company reports its water use intensity in FY 2020/21 as 1.07 m³ of water per MT of FFB processed.

108. Progress towards commitment on water use intensity?

The company reports that its water use intensity has increased from 2018/19 to 2019/20 and again in 2020/21. Information is not externally verified and water use intensity has not improved.

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

The company's BOD and COD levels are within legal limits.

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

The company reports a reduction in BOD levels COD levels in 2018/19 to 2019/20 and again in 2020/21. This information has not been externally verified.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to to treat POME through a POME pond management program.

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

The company reports that PORE is treated at a wastewater treatment facility at its palm kernel extraction plant and refinery. This information is not externally verified.

113. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways through riparian zones.

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

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

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

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

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

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

117. Commitment to no use of paraquat?

The company commits to not use paraquat.

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

The company commits all suppliers to not use paraquat.

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

The company commits to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits to not use Stockholm and Rotterdam Convention chemicals.

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

The company commits suppliers to not use Stockholm and Rotterdam Convention chemicals.

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

The company has reported inorganic fertiliser use at 0.47 kg per ha and pesticide use of 0.136 kg per ha in FY 2020/2021.

124. Implementation of commitment to minimise inorganic fertiliser use?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to use organic waste from palm oil mill waste as a natural fertiliser to reduce use of inorganic fertiliser.

125. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also communicates this in its own reporting.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that its boilers for palm oil processing are powered primarily by organic waste products (palm kernel shells and mesocarp fibres). Empty fruit bunches are composted or applied as mulch for weed control, provision of nutrients, prevention of soil erosion, and maintenance of moisture in the soil.

127. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

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

129. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to conducts training on human rights.

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

The company commits to the UN Declaration on the Rights of Indigenous Peoples.

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

The company commits suppliers to the UN Declaration on the Rights of Indigenous Peoples.

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

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

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

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

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also commits to FPIC in its own reporting.

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

The company commits all suppliers to respect FPIC.

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

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

137. Examples of local stakeholder engagement to prevent conflicts?

The company reports to conduct Focus Group Discussions (FGD), Participatory Mapping, Participatory Rural Appraisal (PRA), and Community communication forums to prevent conflicts with local stakeholders. No specific examples are includes.

138. Details of process for addressing land conflicts available?

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

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

140. Commitment to mitigate impacts on food security?

The company commits to ensure food security for local communities through donating food, protecting food cultivation areas as HCV areas, and providing agricultural training and resources for food cultivation.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports to donate food including rice and cooking oil to local communities, to have mapped areas of food cultivation areas as HCV areas to conserve them. The company has a collaboration established in 2016 with Al-Azhar Foundation which provides agricultural training and resources to support fish farming, vegetable farming, fruit farming and homestead gardening in local communities.

142. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it has provided clean water programs and improvement of road infrastructure to facilitate better mobility between neighbouring districts or villages. The company also reports to have set up 11 community clinics in collaboration with local health authorities.

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

The company commits to provide business and work communities.

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

The company commits to all Fundamental ILO Conventions.

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

The company commits all suppliers to all Fundamental ILO Conventions.

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

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

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

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

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to have established gender committees to coordinate training on gender related issues, address needs of new mothers e.g. nursing stations, and proving day care opportunities for women with children.

151. Percentage or number of temporary employees?

2555 - The company reports that it has 2,555 temporary employees.

152. Percentage or number of women employees?

24% - The company reports that 24% of the Group's workforce are women.

153. Commitment to pay a Decent Living wage?

The company commits to pay a Decent Living Wage to all workers.

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

The company commits all suppliers to pay a Decent Living Wage to all workers.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports starting salaries at palm oil plantation locations against the local minimum wage. each location has a ratio of 1:1.

156. Reporting of salary by gender?

The company reports the entry level wage ratio for male and female employees. This is not reported for each employee category, by significant locations of operation.

157. Commitment to address occupational health and safety?

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

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

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

159. Provision of personal protective equipment and related training?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also communicates that it provide PPE in its own reporting.

160. Time lost due to work-based injuries?

2.51 - The company reports a total lost time accident rate of 2.51 and the total lost workdays are 473.

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

0 - The company reports zero fatalities in the year 2020/21.

162. Commitment to support smallholders?

The company has published a commitment to support smallholders.

163. Programme to support scheme smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to have PLASMA scheme smallholder support programmes in a total of 27 cooperatives. These support programmes provide training on financial management with monthly meetings held for members.

164. Percentage of scheme smallholders involved in programme?

7882 (100%) - The company states it has 7,882 members in its PLASMA schemes, across a total of 27 cooperatives which covers 100% of scheme smallholders.

165. Programme to support independent smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to have a Farmer Field School program which provides training to independent smallholder farmers to improve crop productivity and adopt good agricultural practices.

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

267 (19.45%) - 267 farmers have participated in the programme out of a total 1,370 Independent Smallholders. This information has not been externally verified.

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

The company engages with suppliers to promote and evaluate compliance with the company's sustainability policy. The company carries supplier evaluations which also includes risk assessments relating to supplying plantations and FFB sourcing by supplying palm oil mills.

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

38% - The company reports that 38% of supplying mills have completed a Self-Assessment Tool on NDPE requirements compliance.

169. Suspension or exclusion criteria for suppliers?

The company reports that suppliers must follow NDPE principles. It also provides timeframes and actions taken when suppliers do not comply with these principles as well as a suspension procedure.

170. 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 all suppliers to be in compliance with sustainable palm oil sourcing commitments.

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

The company reports two separate figures for supplier compliance with 'progress on no deforestation' and 'no development on peat commitments', with 95% and 96% of suppliers achieving a compliance level of 'commitment and starting action' or above respectively. The company does not provide figures for direct and indirect supply from third-parties and this is monitored through a self-assessment.

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

The company commits to engage with all high risk mills by the year 2024. This is within 3 years.

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

The company reports to conduct risk assessments of its supply chain to identify high risk areas. From here the company develops risk management plans. Details of these plans are not provided. The company reports to have conducted a "Responsible Sourcing and Traceability Webinar for Downstream Suppliers" in 2022, however this was for third-party suppliers only and does not specify that it was targeted for high risk mills.

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

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

The company reports that it classifies all own and third party supplying palm oil mills as low, medium, or high risk. This is achieved through the company conducting sustainability due diligence evaluations for its suppliers including a desktop spatial risk analysis, which uses maps from official databases to assess the risk of deforestation and peatland development.

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

The company states it assesses and categorises the risk level of all its own and third party supplying mills annually.

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

The company reported that in 2022, 26% of supplying mills were low risk, 36% were medium risk, and 38% were high risk.

178. Commitment to ethical conduct and prohibition of corruption?

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

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to conduct anti-corruption training for employees.

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

The company reports a tax strategy and that the Group Tax department oversees and monitors the tax risks of all companies within the Group.

182. Whistleblowing procedure?

The company reports a whistleblowing procedure including a flowchart of steps taken and information about how whistleblowers are protected.

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

The company has disclosed its grievance system in a flowchart.

184. Details of complaints and grievances disclosed?

The company disclosed details of complaints received through the company's own grievance mechanism, these include: date; issue; complainant category; actions taken; status.