Indofood Agri Resources Ltd

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

The company has published a sustainable palm oil policy which covers all palm oil operations.

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

The company has published a sustainable palm oil policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has a sustainability think tank led by the CEO and comprises Executive Directors and Chief Operating Officers responsible for sustainability. However, the CEO is among the board members.

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

The company reports that the board is responsible for the overall management and monitoring of sustainability governance.

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

61 (12.37%) - The company reports that it has 61 (12.37%) women senior managers and other managers. It does not report a separate figure for senior managers only.

6. Percentage or number of women board members?

0 (0%) - The company has all-male board members. However, gender balance was not directly reported, but calculated from photos and biographies of directors.

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 that it collaborates with the Ministry of Environment and Forestry, the military, police, and the local government to conduct firefighting training across 51 estates in 2022.

9. Sustainability report published within last two years?

The company publishes its latest sustainability Report in 2022.

10. Reports through standardised reporting systems?

The company publishes a GRI content index report which states that the Sustainability Report 2022 has been prepared in accordance with GRI 1: Foundation 2021.

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 reports aligning its existing climate risk analysis with the TCFD framework and incorporating additional physical and transition risks into its Enterprise Risk Management (ERM) process. A full climate risk assessment is not reported.

13. Lists countries and operations?

All of the company's operations (plantations, mills, crushers, and refineries) are located in Indonesia.

14. Lists countries sourcing from?

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

16. Total oil palm planted area (ha)?

335319 - The company reports that it has 244,768 ha of nucleus planted area and 90,551 ha of plasma planted area. However, the plasma planted area is the sum of the rubber and oil palm planted area.

17. Scheme smallholders planted area (ha)?

90551 - The company reports scheme smallholder planted areas as 90,551 ha in 2022. However, the scheme planted area is the sum of the rubber and oil palm planted area.

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

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

24936 - The company reports its conservation set-aside area, including HCV areas as 24,936 ha in 2022.

20. Maps of estates/management units?

The company publishes a static map for its estates. However, it is not georeferenced, does not includes coordinates, show estate boundaries.

21. Maps of all scheme smallholders?

22. Maps of all third-party supplying plantations?

23. Number of company-owned mills?

27 - The company reports that it has 27 mills.

24. Names and locations of company-owned mills?

The company publishes a static map for its mills. However, the map is not georeferenced and coordinates are not provided.

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

The company reports that all mill sources from its own nucleus and plasma estates.

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

The company reports that 100% of FFB sourced by mills comes from its own operations.

27. Number of third party supplying mills?

8 - The company reports that eight third-party mills supply CPO to its refineries.

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

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

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

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

This indicator is disabled as the company sources only 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 the supply is traceable to the mill level.

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

The company reports that it has already achieved 100% traceability to plantation level for its mills. It does not report a time-bound target for 100% traceability to plantation level for its refineries.

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

The company reports that 100% of the FFB supply to its own mills is traceable to the plantation level.

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

37. Publishes traceability data at refinery level?

The company reports that supply to refineries is 100% traceable to mill level. It does not report this information for each refinery, and traceability to planation level is not reported.

38. Publishes traceability data at crusher level?

The company reports that 100% of PK processed in kernel crushers is traceable to the plantation level.

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

The company reports that it has withdrawn from RSPO in February 2019.

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?

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

43. Percentage of mills RSPO-certified?

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that it has withdrawn from RSPO in February 2019.

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

The company reports that 86% of its estates and 20 out of 27 mills are ISPO certified. It does not publish its certificates.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

The company reports that it has ISO 14001 Certification for some of its mills, factories and refineries. However, the information is not externally verified.

55. Commitment to zero conversion of natural ecosystems?

The company reports a general statement for the protection of the ecosystem. However, no commitment to zero conversion of natural ecosystems is reported.

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

57. Commitment to zero deforestation?

The company commits to no development in High Conservation Value (HCV), High Carbon Stock (HCS) and peatland areas. However, the commitment is made after 1 Jan 2020.

58. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation. However, the commitment is made after 1 Jan 2020.

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

The company reports protecting primary forests and HCV areas against deforestation. However, no cut-off date was specified.

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

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

The company reports that it has an HCV management plan which is assessed and accredited by licensed assessors. It also conducts annual audits to ensure that all plantations, including plasma smallholders, and suppliers comply with its sustainable agriculture policy. However, the monitoring and auditing process is unclear.

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

The company reports to conducting an annual audit to ensure that all plantations, including plasma smallholders and suppliers, comply with its sustainable agriculture policy which includes commitments to no deforestation, conservation of High Conservation Value (HCV) and High Carbon Stock (HCS) areas and no planting on peat. However, the monitoring and auditing process is unclear.

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

0 - The company reports that there was zero deforestation 2021, figures are not reported for 2022. No cut-off date for deforestation is specified.

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

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

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

67. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company reports that it has started a research project, in conjunction with universities and the government, to help conserve the protected Bekantan (Proboscis) monkey within an existing concession are. It has also been working with the government to help protect Taman Nasional Meru Betiri in East Java, near one of its estates by supporting security patrols and by ensuring protection of its adjacent HCV areas which act as a buffer zone to the conservation area.

68. Biodiversity policy?

The company reports a commitment to protecting biodiversity. However, it does not have a policy or time-bound target.

69. Biodiversity policy applies to all suppliers?

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

The company has identified several species of conservation concern referencing IUCN.

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

The company has an HCV Management and Rehabilitation Plan to protect riparian areas and habitats for endangered species. It has also installed warning signs and set up boundary pits to protect HCV areas from logging, burning, and hunting of protected species and wildlife.

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

The company commits to no hunting of protected species only.

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

The company's commitment to no hunting of protected species applies to all suppliers. However, commitment does not cover all species.

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

The company commits to conduct HCV assessments.

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

The company commits all suppliers to conduct HCV assessments.

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

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

The company reports that its HCV Management plans have been assessed and accredited by licensed assessors. However, no HCV management plan could be found.

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

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

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

80. 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.

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

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

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

83. 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.

84. High Carbon Stock (HCS) assessments available?

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

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

The company commits to conduct social and environmental impact assessments.

87. 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.

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

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

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

90. 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.

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

The company reports that some of its estates are located in peat areas. However, no area figure is reported.

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

The company reports that it has not undertaken any new planting on peatland since 2013, however it does not report figures for its landbank on peat.

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

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

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

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

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

The company reports that it monitors water levels on estates using peat subsidence measurement, GIS remote sensing, and 3D flood risk modelling, and conducts hydrographic and topographic mapping of the peatland planting. It also uses leguminous cover crops, empty fruit bunches, and POME to improve the quality of the soil.

96. Commitment to zero burning?

The company commits to no burning.

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

98. Evidence of fire monitoring and management?

The company reports monitoring satellite images from NOAA and NASA of its concession to identify hotspots. The company also conducts fire prevention training and has installed 207 fire towers across all of its estates.

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

The company reports that in 2022, the number of fire incidents that took place in its operation was reduced from the previous year. However, no figure was reported.

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

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

102. GHG emissions intensity?

The company reports the total emissions per tonne of palm product as 1.59 in 2022. However, it does not clearly include Scope 1 and Scope 2 emissions.

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

The company reports emissions from land use change as 0.22 tCO2e/tonnes in 2022. However, the figure is not specific to palm oil but covers the whole scope of the company's operation.

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

105. Progress towards commitment to reduce GHG emissions intensity?

The company reports that GHG emission intensity has improved for its palm oil operations from 1.85 tCO2e/tonnes in 2021 to 1.59 tCO2e/tonnes in 2022, however, figures do not clearly cover scope 1 and 2 emissions.

106. Methodology used to calculate GHG emissions?

The company uses the ISPO GHG calculation methodology to calculate GHG emissions.

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

The company reports that it has installed methane capture at three of its 27 mills.

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

109. Water use intensity?

0.1 - The company reports water use intensity for mills as 1.00 m3 of water per tonne of FFB processed and for refineries as 0.10 m3 of water per tonne of material produced in 2022. However, the figures only cover data from 23 out of 27 mills and five out of six refineries.

110. Progress towards commitment on water use intensity?

The company reports water use intensity for mills was 1.00 m3 of water per tonne of FFB processed in 2021, and stay the same in 2022. For refineries it was 0.07 m3 of water per tonne of material produced in 2021, and 0.10 in 2022. The reported figures are not showing an improvement for refineries and the figures only cover data from 23 out of 27 mills and five out of six refineries.

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

The company reports to monitor BOD and COD levels to be in line with government limits, but does not make a clear commitment.

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

The company reports figures for BOD and COD levels of mills and refineries but they have not improved from 2021 to 2022. The company does not report legal limits.

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

The company reports that generated POME is managed in compliance with regulatory controls.

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

The company states that the quality of effluent remains in compliance with regulatory controls and all refinery effluents are sent to wastewater treatment plants before being released into water courses or municipal sewers.

115. Commitment to protect natural waterways through buffer zones?

The company only states that its HCV areas include riparian areas. A commitment to protect natural waterways through buffer zones is not reported.

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

The company only states that its HCV areas include riparian areas. No further information is reported.

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

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

118. 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.

119. Commitment to no use of paraquat?

The company commits to not use paraquat.

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

The company commits all suppliers to not use paraquat.

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

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

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

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

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

The company has reported organic and inorganic fertiliser and pesticide usage in thousand tonnes and thousand litres respectively. However, figures only cover some ISPO audited estates and are not specific to palm oil operations.

126. Implementation of commitment to minimise inorganic fertiliser use?

The company has reported an inorganic fertiliser usage of 86.9 (000 tonnes) for 2022 and 71.1(000 tonnes) for 2021. The reported figure shows an increase in fertiliser usage and figures only cover some ISPO audited estates and are not specific to palm oil operations.

127. Integrated Pest Management (IPM) approach?

The company has implemented several Integrated Pest Management (IPM) techniques like the use of barn owls to control rat populations in estates, and leguminous cover crops to suppress weeds and pathogens to control leaf-eating insects.

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

The company reports that all sites operate waste management systems compliant with Indonesian regulations, and are guided by PROPER and ISO 14001. In 2022, 64% of non-hazardous waste was sent for recycling while the other 36% was sent to landfill.

129. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

130. Commitment to human rights applies to all suppliers?

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

131. Progress on human rights commitment?

The company has conducted human rights assessments of all of its ISPO-certified units in 2022. The company also provides human rights training to security officers via its training centre, in partnership with military commando units and local police.

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

The company commits to respecting indigenous and local communities rights. However, it does not refer to the UN Declaration or the ILO Conventions.

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

The company's commitment to respecting indigenous and local communities rights applies to all suppliers. However, it does not refer to the UN Declaration or the ILO Conventions.

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

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

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

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

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

The company commits to respect FPIC.

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

The company commits all suppliers to respect FPIC.

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

The company reports having FPIC policies and processes which enable it to work with communities and governments on land tenure and rights. However, no further information could be found.

139. Examples of local stakeholder engagement to prevent conflicts?

140. Details of process for addressing land conflicts available?

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

The company reports a commitment to upholding the principle of equal opportunity and supporting the inclusion of women across its operations, including addressing any barriers. It states that it provides maternity and menstrual leave to all women employees but does not specify barriers that it is addressing.

142. Commitment to mitigate impacts on food security?

The company commits to ensuring food security for local communities through assisting with crop diversification.

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

The company reports benefiting local communities through crop diversification which leads to generating additional income and strengthened food security. No details on activities are reported.

144. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

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

The company reports that it has built medical clinics, day-care centres and schools.

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

The company states that it usually hires temporary employees from local areas. No clear commitment to provide business/work opportunities for local communities is reported.

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

The company commits to all Fundamental ILO Conventions.

148. 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.

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

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

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

151. 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.

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

The company reports having gender committees and organises routine activities for employees to voice their concerns regarding discrimination and sexual harassment.

153. Percentage or number of temporary employees?

19602 (37.03%) - The company reports that it has a total of 19,602 (37.03%) non-permanent employees and seasonal workers across all operations.

154. Percentage or number of women employees?

9491 (17.93%) - The company reports having 9,491 (17.93%) women employees in 2022 across all operations.

155. Commitment to pay a Living Wage?

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

156. Commitment to pay a Living Wage applies to all suppliers?

The company's commitment to pay a minimum wage applies to all suppliers. However, no information on living wages could be found.

157. Progress on commitment to pay a Living Wage?

The company has reported that workers are paid minimum wage through reporting legal minimum wages alongside minimum wages paid to employees. However, no information on living wages could be found.

158. Reporting of salary by gender?

159. Commitment to address occupational health and safety?

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

160. 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.

161. Provision of personal protective equipment and related training?

The company reports that it regularly provides training sessions such as basic first aid delivery and holds daily meetings and safety briefings for employees to promote protection from hazards through the appropriate use of Personal Protective Equipment (PPE).

162. Time lost due to work-based injuries?

2.01 - The company has reported a rate of recordable work-related injuries as 2.01 in 2022. Calculated as the number of work-related injuries x 1,000,000/total working hours across all operations.

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

1 - The company has recorded 1 fatality in 2022 across all operations.

164. Commitment to support smallholders?

The company has published a commitment to support scheme smallholders, it does not report a commitment to support independent smallholders.

165. Programme to support scheme smallholders?

The company has an FFB Purchase Scheme, Rejuvenation Scheme and Seedling Provision Program which provide price assurance, replanting of matured plantations and access to high-quality seeds respectively. However, it is unclear what type of smallholders it includes.

166. Percentage of scheme smallholders involved in programme?

51 - The company reports that its Rejuvenation Scheme (Peremajaan Sawit Rakyat, PSR) helped 51 smallholders to replant mature plantation areas across 123 hectares. However, it is unclear what type of smallholders it includes.

167. Programme to support independent smallholders?

The company has an FFB Purchase Scheme, Rejuvenation Scheme and Seedling Provision Program which provide price assurance, replanting of matured plantations and access to high-quality seeds respectively. However, it is unclear what type of smallholders it includes.

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

51 - The company reports that its Rejuvenation Scheme (Peremajaan Sawit Rakyat, PSR) helped 51 smallholders to replant mature plantation areas across 123 hectares. However, it is unclear what type of smallholders it includes.

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

The company reports that its scheme smallholder suppliers are audited annually against the Sustainable Agriculture Policy. It also reports that it regularly engages with other third party suppliers to raise awareness of their obligations, but no clear process on assessment or engagement is reported.

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

100% - The company reports that 100% of CPO volume from suppliers was in compliance with the Sustainable Agriculture Policy. However, the information is between two to five years old. The company reports that in 2022 no sourcing from suppliers was disrupted due to reasons of non-compliance, however the number or percentage of non-compliance is unclear.

171. Suspension or exclusion criteria for suppliers?

The company reports that it will cease sourcing from non-compliant suppliers, however it does not clearly state the criteria by which suppliers are excluded, including steps that will be taken and timeframes for action.

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

The company reports that 100% of CPO volume from suppliers is already in compliance with the Sustainable Agriculture Policy. It is not clear if this is through self-assessment.

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

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

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

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

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

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

The company reports that it assesses the risk levels of all its own mills on an annual basis, it does not report on risk assessment of third party supplying mills.

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

180. Commitment to ethical conduct and prohibition of corruption?

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

181. 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.

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

The company reports that it provides training to new hires on its code of conduct which includes the prohibition of bribery and ethical conduct.

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

184. Whistleblowing procedure?

The company reports having a whistleblowing policy. However, no details are reported.

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

The company has a grievance-handling mechanism which is open to both internal and external stakeholders. It reports a flowchart of steps.

186. Details of complaints and grievances disclosed?