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 which is led by the CEO and comprises Executive Directors and Chief Operating Officers, among others.

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

The board oversees the management and monitoring of material ESG topics.

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

50 (12.47%) - The company reports a total of 50 female managers and senior managers.

6. Percentage or number of women board members?

0 (0%) - The company reports that all board members are male.

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 collaborates with external HCV and HCS certified experts and conducts fire prevention training in collaboration with the Ministry of Environment and Forestry (MoEF), the military, police, and the local government.

9. Sustainability report published within last two years?

The company has published its Sustainability Report 2021.

10. Reports through standardised reporting systems?

The company's sustainability report has been published in accordance with GRI standards Core option.

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?

13. Lists countries and operations?

The company has palm oil mills in Indonesia (East Kalimantan, West Kalimantan, Central Kalimantan, South Sumatra, North Sumatra, Riau).

14. Lists countries sourcing from?

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

356562 - The company states that 356,562 ha is managed for oil palm cultivation. However, data is between two and five years old.

16. Total oil palm planted area (ha)?

337585 - The company reports a group-wide figure of 250,615 ha oil palm nucleus planted area and 86,970 ha plasma planted area. Data as of 31 December 2021.

17. Scheme smallholders planted area (ha)?

86970 - The company states that 86,970 ha were planted in plasma holdings as of 31st December 2021.

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

20000 - 20,000 ha is designated for future planting, however, this data is between two and five years old.

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

23279 - The company reports a total of 23,279 ha of HCV areas across its sites.

20. Maps of estates/management units?

The company has given a geographical map for its estates. However, the map does not show estate boundaries.

21. Maps of scheme smallholders?

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

23. Number of company-owned mills?

27 - The company reports that it owns 27 mills.

24. Names and locations of company-owned mills?

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

The company states that 100% of FFB processed in its mills is from its 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 states that 100% of FFB processed in its own mills is from its nucleus and plasma estates.

27. Number of third party supplying mills?

15 - The company reports that it has 15 third-party mills supplying 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 CPO processed in its refineries is traceable from palm oil mills.

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

The company reports that 100% of the FFB processed in its own mills is traceable to its estates and aims to achieve full traceability in its value chain. However, the commitment is not time-bound.

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

The company reports that 100% of the FFB processed in its own mills is traceable to its nucleus estates and plasma smallholders. However, data was not externally verified.

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

37. Publishes traceability data at refinery level?

38. Publishes traceability data at crusher level?

The company has reported that 100% of PK processed in kernel crushers is traceable to estates. However, data was not externally verified.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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 withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

43. Percentage of mills RSPO-certified?

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO.

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

The company withdrew from RSPO in February 2019 before its membership was terminated by RSPO. Hence, awarded no points.

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

The company states that 83% of all estates' hectarage and 18 of their 27 mills are ISPO certified. However, no certificates were found, and data was not externally verified.

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 has ISO 14001 Certification for some of its operations. However, data was not externally verified.

55. Commitment to zero conversion of natural ecosystems?

56. Commitment to zero deforestation?

The company commits to no development in High Conservation Value (HCV), High Carbon Stock (HCS) and peatland areas.

57. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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

The company prevents deforestation in primary forests and HCV areas. However, no cut-off date was mentioned.

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

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

The company reports that the identified HCV areas are monitored and managed by a trained team of HCV managers and conducts annual audits to ensure that 100% of its plantations, including plasma smallholders, and suppliers comply with Sustainable Agriculture Policy. However, no timeframe is given and data is self-reported.

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

The company conducts annual audits to ensure that 100% of its plantations, including plasma smallholders and suppliers, comply with its sustainable agriculture policy, including commitments to no deforestation. The information was not externally verified and no time frame reported.

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

0 - The company reports 100% compliance with its policy of no deforestation and zero HCV loss in 2021.

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

64. Commitment to restoration of deforestation/conversion?

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

66. Implementing a landscape or jurisdictional level approach?

67. Biodiversity policy?

The company states that it conserves biodiversity. However, no policy including both commitment and time-bound targets on protecting biodiversity was found.

68. Biodiversity policy applies to all suppliers?

The company states that it conserves biodiversity. However, no policy on protecting biodiversity covering multiple dimensions was found.

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

The company has reported a list of IUCN Red List protected species. However, this data was not externally verified.

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

The company states that it has HCV rehabilitation Plans to enhance riparian areas, tree planting schemes, signs erected at HCV sites that prohibit hunting, logging, or burning in the area, and boundary pits set up along the perimeters to prevent encroachment and monitor HCV areas. However, this data was not externally verified.

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

The company has a zero-tolerance policy across all operations and suppliers towards hunting wild animals or the collecting of rare/endangered species within them or adjacent to them. However, commitment does not cover all species.

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

The company's zero-tolerance policy towards hunting for wild animals or the collecting of rare/endangered species within them or adjacent to them applies to all suppliers. However, this commitment does not cover all species.

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

The company commits to conduct HCV assessments.

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?

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

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

The company has reported different practices for HCV management and monitoring and HCV management plans have been assessed by accredited licensed assessors. However, no HCV management and monitoring plans available.

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

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?

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

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

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?

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

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

The company commits to conduct social and environmental impact assessments.

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

The company's commitment to conducting social impact assessments applies to all suppliers. However, the company does not mention environmental impact assessments.

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

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

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

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)?

0 (0%) - The company stated that some of the estates included in its scope are in peat areas. However, no figure was mentioned.

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

The company reports no plantings on peatland since 2013. However, information was not externally verified.

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 for soils and peat.

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

The company states that it monitors water levels on estates using peat, conducts hydrographic and topographic mapping of peatland planting, uses leguminous cover crops to improve the soil and recycles empty fruit bunches (EFBs) and POME for use as a soil improver. However, this information was not externally verified.

95. Commitment to zero burning?

The company commits to no 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?

The company states that it monitors hotspots and educates stakeholders on fire prevention and satellite images compared with concession maps to identify hotspots. However, data was not externally verified.

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

The company states that the number of fire incidents in 2021 was reduced from previous years. However, no figure was given.

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

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

101. GHG emissions intensity?

The company reports total emissions in 2021 for each tonne of palm product were 1.85 tonnes of CO2e. However, does not cover the whole scope of palm oil operations.

102. GHG emissions from land use change?

The company reports emissions from land use change as 0.18 tCO2e/tonnes. However, the figure covers all of the company's operations and was not only specific to palm oil.

103. Progress towards commitment to reduce GHG emissions intensity?

The company reports improving GHG intensity but the information was not externally verified: 2.13 tCO2e/tonnes (2019), and 2.10 tCO2e/tonnes (2020), 1.85 tCO2e/tonnes (2021) . However, the figure was specific to palm oil operations.

104. Methodology used to calculate GHG emissions?

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

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

The company has reduced methane emissions at three of its aerated bunker composters by up to 80%. Hence, 11.11% of mills are with methane capture.

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

107. Water use intensity?

1.069 - The company reports water use intensity for mills is 1.00 m3 of water per tonne of FFB processed and for refineries is 0.069 m3 per tonne of material produced. However, data for 22/27 mills and 4/6 refineries was given.

108. Progress towards commitment on water use intensity?

The company reports water use intensity as 1.00 m3 of water per tonne of FFB processed in 2021 and 2020, and 1.01 m3 of water per tonne of FFB processed in 2019. The company also reports that water use intensity decreased by 2% for refineries compared to 2020 (0.071 m3 per tonne of material produced). However, data was for 22/27 mills and 4/6 refineries and also not externally verified.

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

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

The company has reported BOD and COD progress for mills and refineries. However, data was not externally verified.

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

The company reported that POME was managed in compliance with regulatory controls and treated on-site. However, data was not externally verified.

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

The company reported that all refinery effluents were treated. However, data was not externally verified.

113. Commitment to protect natural waterways through buffer zones?

The company reports that HCV areas include riparian areas. However, unclear whether it protects natural waterways.

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

The company reports that HCV areas include riparian areas. However, unclear whether it protects natural waterways.

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?

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

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

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

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

The company reports the consumption of pesticides and fertilisers in palm oil estates. However, figures only for some parts of the company's operations.

124. Implementation of commitment to minimise inorganic fertiliser use?

The company reports an increase in inorganic fertiliser use. However, data was not externally verified.

125. Integrated Pest Management (IPM) approach?

The company has an Integrated Pest Management (IPM) approach. However, data was not externally verified.

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

The company has a waste management system in place to avoid negative impacts in compliance with Indonesian regulations and is guided by PROPER and ISO 14001. However, data was not externally verified.

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?

The company has human rights assessments, training is delivered via our training centre, monitoring human rights violations in its supply chain and ensuring no child labour is present in its operations. However, data was not externally verified.

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

The company has a commitment to respecting indigenous and local communities' rights. However, no reference to the UN Declaration or the ILO conventions.

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

The company has a commitment to indigenous and local communities' rights which applies to all suppliers. However, no reference to the UN Declaration/ILO.

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 to respect FPIC.

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 company has FPIC policies and processes for working with communities and governments on land tenure and rights. However, no details were given.

137. Examples of local stakeholder engagement to prevent conflicts?

The company has community collaboration programs to build local capacity and knowledge to prevent fires and has a grievance mechanism available where company representatives resolve issues. However, this information was not externally verified.

138. Details of process for addressing land conflicts available?

The company has a grievance mechanism. However, limited details were given.

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

The company has a commitment to upholding the principle of equal opportunity and supporting the inclusion of women across its operations, including addressing barriers faced. However, the information was self-reported.

140. Commitment to mitigate impacts on food security?

The company commitment to mitigate impacts on food security.

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

The company has benefitted local communities including diversification of crops that lead to additional income and strengthened food security However, data is limited and self-reported.

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?

The company reports multiple examples of facilities/services provided including healthcare, community centers, and schools. However, data is not externally verified.

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

The company has given an example of a business it has supported through its PROKLIM projects, However, the unclear commitment was given.

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?

The company reported progress on its commitment to respect all workers' rights. However data was limited and self-reported.

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?

The company has set out Gender Committees in all our work units organising routine activities for employees to voice their concerns regarding discrimination and sexual harassment. However, data was not externally verified.

151. Percentage or number of temporary employees?

17022 (33.03%) - The company reports a total of 17,022 non-permanent and seasonal workers, out of a total workforce of 51,532 workers. This figure represents the company's whole operations, not just palm oil.

152. Percentage or number of women employees?

9277 (18%) - The company reports that 9,277 out of 51,532 of its 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 has a commitment to pay a minimum wage that applies to all suppliers. However, no information on decent living wages was provided.

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

The company reports that it provides a decent living wage. However, no ratio or calculation method of DLW was reported and data was not externally verified.

156. Reporting of salary by gender?

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?

The company provides personal protective equipment (PPE) and related training. However, data was not externally verified.

160. Time lost due to work-based injuries?

1.92 - The company reports the rate of recordable work-related injuries as 1.92.

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

2 - The company reports 2 fatalities in 2021, and 1 in 2020.

162. Commitment to support smallholders?

The company has published a commitment to support smallholders.

163. Programme to support scheme smallholders?

The company has a smallholder programme that provides financial loans, technical support, subsidised seed stocks. However, data was not externally verified.

164. Percentage of scheme smallholders involved in programme?

165. Programme to support independent smallholders?

The company has a smallholder programme that provides financial loans, technical support, and subsidised seed stocks. However, data is not externally verified.

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

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

The company states that suppliers are required to adhere to the Sustainable Agriculture Policy and are annually audited, also engages with them on major findings and recommendations and in case of the non-compliant company ceases sourcing from those suppliers.

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

100% - The company achieved 100% of CPO volume from suppliers in compliance with the Sustainable Agriculture Policy in 2020. However, information was not externally verified.

169. Suspension or exclusion criteria for suppliers?

The company states that suppliers are required to adhere to the Sustainable Agriculture Policy and are annually audited, also company engages with them on major findings and recommendations, and in case of the non-compliant company ceases sourcing from those suppliers.

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

The company reported that in 2020, achieved 100% of CPO volume from suppliers in compliance with the Sustainable Agriculture Policy.

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

The company achieved its goal of having 100% of CPO volume from suppliers in compliance with our Sustainable Agriculture Policy. However, the proportion of direct and indirect supply was unclear and data was not externally verified.

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

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

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?

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

The company states that it assesses the risk levels of all its own mills on an annual basis as part of its risk management and audit process. However, data was not externally verified.

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

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?

The company reports that all new employees receive induction training on its Code of Conduct policies which includes the prohibition of bribery. However, data was limited and self-reported.

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

182. Whistleblowing procedure?

The company states that it has a whistleblowing policy but only limited details are provided on the procedures.

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

The company clearly has its own grievance mechanism open to all stakeholders.

184. Details of complaints and grievances disclosed?

The company provides all details of a complaint from 2016 regarding labour and human rights issues and provides summary information on other types of grievances. However, data over two years.