IOI Corporation Bhd
Palm oil assessment- Latest update: November 2023
- Next scheduled: November 2024
ESG scores:
The following scores are based on the totals of all environmental, social and governance (ESG) indicators. Some indicators apply to more than one E, S or G issue.
Supply chain scores:
The following scores are based on ESG indicators relevant to specific segments of the palm oil supply chain.
Some indicators apply to multiple segments. Please refer to the scoring criteria for further details.
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Landbank (oil palm)207,113 hectares
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Market cap:5,441,900,000 USD
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Thomson Reuters ticker:IOIB.KL
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Bloomberg ticker:IOI MK Equity
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Sedol:B1Y3WG1
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LEI:
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RSPO member?Yes - Note that the company was suspended from the RSPO for five months in 2016.
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Other initiatives:Malaysian Sustainable Palm Oil (MSPO), International Sustainability and Carbon Certification (ISCC), Sustainable Palm Oil Manifesto (SPOM)
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Activities:Oil palm cultivation, milling, palm kernel crushing, palm oil refining, trading and distribution
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Locations:Malaysia (Johor, Malacca, Negeri Sembilan, Pahang, Sabah, and Sarawak) and Indonesia (West Kalimantan and Central Kalimantan).
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Headquarters:Malaysia
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Related companies:IOI has a 32.1% stake in Bumitama Agri Ltd. IOI has a 30% stake in Bunge Loders Croklaan (formerly known as IOI Loders Croklaan) with Bunge Ltd controlling the remaining 70%.
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Notes:IOI Group's RSPO certificates were suspended on 4th April 2016. As of 8th August 2016 the company's certificates have been reinstated.
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Website:
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Company assessment: IOI Corporation Bhd – November 2023
Assessment date:
- Organisation: 32.5 / 39 83.3%
- Policy: 68 / 78 87.2%
- Practice: 63.3 / 75 84.4%
- Self-reported: 15.3 / 75 20.4%
- External: 28.8 / 75 38.3%
- Certified: 19.3 / 75 25.7%
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Sustainability policy and leadership10.75 / 11 97.7%
- Organisation: 6 / 6 100%
- Policy: 2 / 2 100%
- Practice: 2.8 / 3 91.7%
- Self-reported: 1.8 / 3 58.3%
- External: 1 / 3 33.3%
- Certified: 0 / 3 0%
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1. Sustainable palm oil policy or commitment for all its operations?
The company meets this indicator through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company has also published a sustainable palm oil policy.
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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.
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3. High-level position of responsibility for sustainability?
Dr Surina binti Ismail - Group Head of Sustainability.
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4. One or more members within the board of the company have responsibility for sustainability?
The company's Group Sustainability Steering Committee (GSSC) is chaired by the group's Managing Director and Chief Executive. It also has a Board Sustainability Committee.
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5. Percentage or number of women in senior management team?
1 (7%) - The company has one female member as a part of its senior management team of 15 members in 2022.
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6. Percentage or number of women board members?
3 (38%) - The company reports that three out of the total eight board members are female (38%) in 2022.
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7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with palm oil production?
[Externally verified] The company is a member of the Fire Free Alliance and POCG.
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8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with palm oil production?
The company collaborates with Earthworm Foundation (EF) to undertake a pilot project at Bukit Senorang estate and mill, Pahang. This project is about capacity building regarding workers' rights and avoidance of human rights violations in their operations by using EF's Ethical Recruitment & Human Rights Due Diligence Tool ("ERDD"). The company is also working with EF regarding environmental and social risks within its suppliers. The company also collaborates with Seratu Aatai, SWD, and HUTAN-KOCP to conduct regular elephant behaviour monitoring. Apart from monitoring and tracking, the collaboration seeks to spread awareness of elephant behaviour among the local communities to reduce human-elephant conflicts around its estates.
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9. Sustainability report published within last two years?
The latest sustainability report was published in 2023, covering the year 2022.
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10. Reports through standardised reporting systems?
The company has submitted CDP questionnaires for Forests, Water Security, and Climate Change in 2022.
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11. Verification report on compliance with POIG Charter, if a POIG member?
This indicator is disabled as the company is not a POIG member.
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12. Climate risks assessment available?
The company reports climate-related risk, mitigation, and adaptation strategies which have been conducted in accordance with TCFD guidance. However, the information reported is not externally verified.
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Landbank, maps and traceability23.65 / 29 81.6%
- Organisation: 14.5 / 19 76.3%
- Policy: 2 / 2 100%
- Practice: 7.1 / 8 89.4%
- Self-reported: 1.5 / 8 18.8%
- External: 0 / 8 0%
- Certified: 5.6 / 8 70.6%
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13. Lists countries and operations?
Indonesia (plantations, mills), Malaysia (plantations, mills, and refineries).
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14. Lists countries sourcing from?
The company reports that 46% is sourced from Peninsular Malaysia, 50% from Sabah Malaysia, and the remaining 3% from 'others'. It is unclear what locations 'others' includes. The company also reports a mill list which includes mills located in Malaysia, Indonesia, and Thailand. The countries sourcing from are not reported directly.
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15. Total land area managed/controlled for oil palm (ha)?
207113 - The company reports 207,113 ha as its total landbank. However, the RSPO ACOP 2022 reports that the company has 214631.25 ha of land area managed/controlled for oil palm.
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16. Total oil palm planted area (ha)?
176980 - The company reports its total oil palm planted area as 176,980 ha in 2022.
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17. Scheme smallholders planted area (ha)?
5440.85 - The RSPO ACOP 2022 reports the total land under scheme smallholders as 5440.85 ha in 2022.
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18. Unplanted (areas designated for future planting) (ha)?
11031.4 - The RSPO ACOP 2022 reports the total unplanted planted area as 11031.42 ha in 2022.
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19. Conservation set-aside area, including HCV area (ha)?
9103.07 - The company reports the total HCV area ss 2,742.97 ha and other conservation land set aside, excluding HCV areas, as 6,360.10 ha in its RSPO ACOP 2022.
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20. Maps of estates/management units?
Concession boundaries have been made available to the RSPO.
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0 / 1
21. Maps of all scheme smallholders?
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0 / 1
22. Maps of all third-party supplying plantations?
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23. Number of company-owned mills?
15 - The company reports it owns 15 mills.
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24. Names and locations of company-owned mills?
The names and locations of all 15 mills owned by the company are available on the GFW database.
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25. Number (or percentage) of company-owned mills that source from company-owned operations and third parties?
The company only states that 98.98% of the supply to its own mills came from its own plantations and 1.02% came from external suppliers (plantations, dealers, and smallholders) in 2022. The information is not split per individual mills that source from their own plantations and/or third-party suppliers.
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26. Reports total volumes (or percentages) sourced by company-owned mills that come from company-owned operations and third-parties?
The company states that 98.98% of the supply volume to its own mills came from its own plantations and 1.02% came from external suppliers (plantations, dealers, and smallholders) in 2022.
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27. Number of third party supplying mills?
355 - The company reports having 355 supplying mills as of 2022.
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28. Names and locations of all third-party supplying mills?
The company publishes a full list of mills that state the mill name, parent company name, country, longitude, latitude, and sourcing category.
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29. Number (or percentage) of third party supplying mills that source from their own plantations and third party plantations?
The company only states that 68.03% of the supply to its supplying mills came from supplying mills' own plantations and 31.97% came from external suppliers (plantations, dealers, and smallholders) in 2022. The information is not split per individual supplier mills that source from their own plantations and/or third-party suppliers.
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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 states that 68.03% of the supply to its supplying mills came from supplying mills' own plantations and 31.97% came from external suppliers (plantations, dealers, and smallholders) in 2022.
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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 76% of oil is sourced directly from mills whilst 24% is from intermediary traders and refiners.
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32. Time-bound commitment to achieve 100% traceability to mill level?
The company reports that as of December 2021, palm oil sourced by the company is fully traceable (i.e.,100%) to the supplying mills and 83% traceable to the plantation.
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33. Percentage of supply traceable to mill level?
The company reports that as of December 2021, palm oil sourced by the company is fully traceable (i.e.,100%) to the supplying mills. Additionally, the company's refineries have RSPO SCC under IP and SG.
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34. Time-bound commitment to achieve 100% traceability to plantation level?
As of June 2022, the company has already achieved 100% traceability to the plantation level.
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35. Percentage of fresh fruit bunches (FFB) supply to own mills traceable to plantation level?
As of June 2022, 100% of the supply to the company's own mills is traceable to the plantation level. Additionally, 13 of the total 15 mills owned by the company have Identity Preserved certification.
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36. Percentage of supply from third-party mills traceable to plantation level?
The company reports that as of December 2021, 80% of the palm oil and 65% of the palm kernel sourced by the supplying mills is traceable to the plantation level. Additionally, the company's refineries have RSPO SCC under IP and SG.
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37. Publishes traceability data at refinery level?
The company reports that the traceability for the refiner (IOI Edible Oils Sandakan) to the plantation level is 80% for palm oil and 65% for palm kernel oil. However, the information reported is not externally verified.
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38. Publishes traceability data at crusher level?
The company reports that the traceability of the refiner which is also the company's kernel crusher (IOI Edible Oils Sandakan), to the plantation level for palm oil is 80% and for palm kernel oil is 65%. However, the information reported is not externally verified.
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Certification standards11.51 / 16 71.9%
- Organisation: 1 / 1 100%
- Policy: 3 / 3 100%
- Practice: 7.5 / 12 62.6%
- Self-reported: 2.5 / 12 20.9%
- External: 5 / 12 41.7%
- Certified: 0 / 12 0%
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39. Member of the Roundtable on Sustainable Palm Oil (RSPO)?
[Externally verified] 2004 - The company is a member of the Roundtable on Sustainable Palm Oil (RSPO) since 2004. Note that the company was suspended from the RSPO for five months in 2016.
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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?
[Externally verified] 2009 - The company achieved certification before November 2010.
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41. Submitted most recent RSPO Annual Communication of Progress (ACOP)?
RSPO ACOP 2022 is submitted by the company.
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42. Percentage of area (ha) RSPO-certified?
94.89% - Data as of 2023.
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43. Percentage of mills RSPO-certified?
[Externally verified] 100% - All 15 mills owned by the company are RSPO-certified.
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44. Time-bound plan for achieving 100% RSPO certification of estates and mills within 5 years?
2025 - The company commits to achieving 100% RSPO certification of estates and mills by 2025. This is within 5 years.
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45. Time-bound plan for achieving 100% RSPO certification of all palm product processing facilities within 5 years?
2013 - The company has already achieved 100% RSPO-certification of all palm product processing facilities.
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46. Percentage of scheme smallholders (ha) RSPO-certified?
0% - The RSPO ACOP 2022 reports that 0% of the scheme smallholders area is RSPO-certified.
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47. Time-bound plan for achieving 100% RSPO certification of scheme/associated smallholders and outgrowers within 5 years or target already achieved?
2024 - The company commits to achieving 100% RSPO certification of scheme/associated smallholders and out-growers by 2024. This is within 5 years.
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48. Percentage of FFB supply (tonnes) from independent smallholders/outgrowers/third-party FFB suppliers that is RSPO-certified?
0% - The RSPO ACOP 2022 reports that 0% of the FFB supply from independent smallholders/out-growers/third-party FFB suppliers is RSPO-certified.
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49. Percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that is RSPO-certified?
37.53% - The RSPO ACOP 2022 reports that 37.53% of all palm oil and oil palm products handled/traded/processed are RSPO-certified.
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50. Sells RSPO-certified palm oil through Segregated or Identity Preserved supply chains?
The company's RSPO ACOP 2022 reports that the company sold 91.14% of RSPO-certified palm oil through Segregated or Identity Preserved supply chains in 2022.
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51. Processes/trades RSPO-certified palm oil through Segregated or Identity Preserved supply chains?
The company's RSPO ACOP 2022 reports that the company processed/traded 27.11% of RSPO-certified palm oil through Segregated or Identity Preserved supply chains in 2022.
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52. Indonesia Sustainable Palm Oil (ISPO) certified (100%)?
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53. Malaysia Sustainable Palm Oil (MSPO) certified?
[Externally verified] The company reports that all of its Malaysian estates and mills are MSPO certified. Certificates are publicly available on the MSPO database.
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54. Certified under voluntary sustainability certification scheme (e.g. ISCC, SAS, RSB)?
[Externally verified] ISCC.
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Deforestation and biodiversity13.7 / 20 68.5%
- Organisation: 1.5 / 2 75%
- Policy: 7 / 12 58.3%
- Practice: 5.2 / 6 86.7%
- Self-reported: 1.3 / 6 20.8%
- External: 2 / 6 33.3%
- Certified: 1.9 / 6 32.5%
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55. Commitment to zero conversion of natural ecosystems?
The company commits to zero conversion of natural ecosystems.
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56. Commitment to zero conversion of natural ecosystems applies to all suppliers?
The company reports that it supports zero conversion of natural ecosystems in supplier operations. This is an unclear commitment.
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57. Commitment to zero deforestation?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have been therefore awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to no deforestation.
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58. Commitment to zero deforestation applies to all suppliers?
The company commits all suppliers to no deforestation.
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59. Criteria and cut-off date for defining deforestation?
The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own reporting defines deforestation as the development of High Carbon Stock ("HCS") Forests and High Conservation Value ("HCV") Areas and states the cut-off date of 2016.
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60. Criteria and cut-off date for defining deforestation in supplier operations?
The company commits all suppliers to no deforestation with a cut-off date of May 2020. It defines deforestation and clearance of HCV and HCS areas.
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61. Evidence of monitoring deforestation and/or ecosystem conversion?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting only states that to ensure its no deforestation commitment is not breached, the company utilises Starling remote sensing instruments, providing near real-time geospatial data of its concessions to supplement patrols on the ground. The extent of the area monitored and the timeframe is not reported.
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62. Evidence of monitoring deforestation and/or ecosystem conversion in supplier operations?
The company reports communicating its NDPE commitments to its third-party suppliers via an online self-assessment Tools for Transformation ("T4T"), a platform designed through cooperation between the company, Earthworm Foundation ("EF"), and other oil palm companies. The self-reporting on land clearance by the company's suppliers is supported by a monthly monitoring report by the company's consultants- Aidenvironment and Starling, to confirm its accuracy. However, the extent of supplier area monitored through this programme is not reported.
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63. Amount of deforestation and/or ecosystem conversion recorded in own operations since cut-off date?
0 - The company reports zero deforestation in its own operation since its cut-off date of 2016.
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64. Amount of deforestation and/or ecosystem conversion recorded in supplier operations since cut-off date?
The company reports no cases of deforestation in supplier operations in 2022. However, the 'Supplier NDPE Monitoring And 2022 T4T Update" published by the company reflects that 1.41% of its suppliers were associated with deforestation activities in 2022. Contradictory information is reported for the same time period.
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65. Commitment to restoration of deforestation/conversion in own operations since cut-off date?
The company commits to applying the RSPO Remediation and Compensation Procedure where there has been land clearing without prior HCV assessment since November 2005, or without prior HCV-HCSA assessment since November 2018, through the RSPO Principles and Criteria 2018. However, a commitment covering restoration of all non-compliant deforestation/conversion was not found. Partial points have therefore been awarded on the basis of the company's RSPO-certified landbank (100%).
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66. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?
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67. Implementing a landscape or jurisdictional level approach?
The company reports partnerships with external stakeholders including communities, local authorities, and neighbouring plantations for the Ketapang landscape-level programme for biodiversity protection, fire prevention as well as community livelihood development.
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68. Biodiversity policy?
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0 / 1
69. Biodiversity policy applies to all suppliers?
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70. 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.
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71. Examples of species and/or habitat conservation management?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting also mentions multiple examples of habitat conservation management including the RELeaf project in collaboration with Nestlé to rehabilitate degraded forest and riparian buffers in Sabah.
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72. Commitment to no hunting or only sustainable hunting of species?
The company commits to no hunting of animals.
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73. Commitment to no hunting or only sustainable hunting of species applies to all suppliers?
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HCV, HCS and impact assessments14 / 15 93.3%
- Organisation: 0 / 0 0%
- Policy: 7 / 8 87.5%
- Practice: 7 / 7 100%
- Self-reported: 0 / 7 0%
- External: 7 / 7 100%
- Certified: 0 / 7 0%
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74. Commitment to conduct High Conservation Value (HCV) assessments?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to conduct High Conservation Value (HCV) assessments.
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75. Commitment to conduct High Conservation Value (HCV) assessments applies to all suppliers?
The company commits all suppliers to conduct HCV assessments.
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76. High Conservation Value (HCV) assessments for planting undertaken prior to January 2015, and associated management and monitoring plans?
[Externally verified] The summary of HCV assessment for PT. Bumi Sawit Sejahtera is available on the RSPO website.
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77. High Conservation Value (HCV) assessments for all estates planted/planned planting since January 2015?
[Externally verified] The HCV public summary report of PT Kalimantan Prima Agro Mandiri is publicly available.
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78. High Conservation Value (HCV) or combined HCV/HCS management and monitoring plans for all estates planted/planned planting since January 2015?
[Externally verified] The HCV management and monitoring plan for PT Kalimantan Prima Agro Mandiri is publicly available.
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79. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS)?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.
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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?
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81. Satisfactory review of all High Conservation Value (HCV) assessments undertaken since January 2015 by the HCV ALS Quality Panel?
[Externally verified] The HCV assessment undertaken since January 2015 has been deemed satisfactory by the HCV ALS Quality Panel.
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82. Commitment to the High Carbon Stock (HCS) Approach?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to the High Carbon Stock (HCS) Approach.
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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.
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84. High Carbon Stock (HCS) assessments available?
[Externally verified] HCS assessment of PT. Kalimantan Prima Agro Mandiri (KPAM) is publicly available.
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85. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?
[Externally verified] The HCSA Peer Review Report of PT. Kalimantan Prima Agro Mandiri (KPAM) is published on the HCSA website.
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86. Commitment to conduct social and environmental impact assessments (SEIAs)?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to conducting social and environmental impact assessments (SEIAs).
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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.
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88. Social and environmental impact assessments (SEIAs) available, and associated management and monitoring plans?
[Externally verified] The company has published a summary of the SEIA assessment for PT. Bumi Sawit Sejahtera.
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Peat, fire and GHG emissions18.4 / 20 92%
- Organisation: 5 / 5 100%
- Policy: 7.5 / 8 93.8%
- Practice: 5.9 / 7 84.3%
- Self-reported: 2 / 7 28.6%
- External: 0 / 7 0%
- Certified: 3.9 / 7 55.7%
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89. Commitment to no planting on peat of any depth?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to no planting on peat of any depth.
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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.
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91. Landbank or planted area on peat (ha)?
3767 - The company reports to manage 3,767 ha of peatland within its existing plantations.
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92. Implementation of commitment to no planting on peat of any depth?
The company reported a landbank on peat figure of 3,767 ha in 2022, 3,767 ha in 2021, and 3,850 ha in 2020. However, the information reported is not externally verified.
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93. Commitment to best management practices for soils and peat?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own commitment only covers best management practices for peat.
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94. Commitment to best management practices for soils and peat applies to all suppliers?
The company only commits its suppliers to best management practices for peat.
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95. 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 multiple examples of best management practices for soil and peat, which include the usage of natural nutrient replenishment methods by planting leguminous cover crops like Calopogonium Caereleum, Calopogonium Mucunoides, Pueraria Javanica, etc., to prevent soils from degradation and installation of water gates in the vicinity or close to peatlands in the company's existing plantations to prevent excessive water loss from the peatlands.
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96. Commitment to zero burning?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to zero burning.
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97. Commitment to zero burning applies to all suppliers?
The company commits all suppliers to zero burning.
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98. 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's own reporting states to regularly carry out fire prevention measures that adhere closely to the Fire Management Guidelines. This includes proactive identification of fire-prone areas, continuous monitoring using drones, and consistent collaboration with the local communities, agencies, and government.
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99. Details/number of hotspots/fires in company estates?
In 2022, the company reports there was 1 fire incident within company concessions in Sabah, and none in Sarawak, Peninsular Malaysia, or Indonesia.
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100. Details/number of hotspots/fires within surrounding landscape/smallholders?
20 - In 2022, the company reports 20 fire Incidents outside its concessions.
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101. Time-bound commitment to reduce greenhouse gas (GHG) emissions intensity?
The company reports a target based on scopes 1 and 2 to reduce operational GHG emission intensity by 40% by 2025 based on a 2015 baseline.
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102. GHG emissions intensity?
The company reports GHG Emission Intensity (scope 1 and scope 2) as 1.804 tCO2e/MT Product.
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103. GHG emissions from land use change in company's own operations (scope 1)?
The company states its and use change emissions were 1,726,965.70 tCO2e for FY2023.
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(NEW: not scored this year)-
104. GHG emissions from land use change in supplier operations (scope 3)?
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105. Progress towards commitment to reduce GHG emissions intensity?
The company reports a reduction in its GHG emission intensity for the whole group in 2021 (1.703 (-24.2%)) as compared to 2020 (1.930 (-14.1%)). However, the information reported is not externally verified.
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106. Methodology used to calculate GHG emissions?
The RSPO requires companies to assess their GHG emissions through the Palm GHG calculator. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own reporting mentions using science-based methodologies such as RSPO PalmGHG and ISCC (International Sustainability and Carbon Certification) to calculate its GHG emissions.
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107. Percentage of mills with methane capture (100%)?
The company reports that 10 of its total 15 mills have methane capture facilities.
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Water, chemical and pest management22.3 / 25 89.2%
- Organisation: 1.5 / 2 75%
- Policy: 10 / 11 90.9%
- Practice: 10.8 / 12 90%
- Self-reported: 2 / 12 16.7%
- External: 1 / 12 8.3%
- Certified: 7.8 / 12 65%
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108. Time-bound commitment to improve water use intensity?
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109. Water use intensity?
3.7 - The company reports a water consumption intensity for the whole group as 3.7 m3/MT Product in 2022.
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110. Progress towards commitment on water use intensity?
The company reports a reduction in its water consumption intensity for the whole group in 2022 (3.7 (m3/MTProduct)) as compared to 2021 (3.9 (m3/MTProduct)). However, the information reported is not externally verified.
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111. Time-bound commitment to improve water quality (BOD and COD)?
The company commits to maintain BOD and COD levels within legal limits.
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112. Progress towards commitment on water quality (BOD and COD)?
The company reports that it keeps BOD levels ranging between 20 mg/l to 100 mg/l, depending on the license issued to the respective mill by the Department of Environment ("DOE"). However, it is unclear what the legal limits are compared to the company's BOD levels.
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113. 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's own reporting also states that the POME is treated in wastewater ponds to reduce its Biological Oxygen Demand ("BOD") and Chemical Oxygen Demand ("COD").
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114. Treatment of palm oil refinery effluent (PORE)?
The company states it treats PORE before discharge. However, the information reported is not externally verified.
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115. Commitment to protect natural waterways through buffer zones?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to protect natural waterways through buffer zones.
-
116. 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.
-
117. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to minimise the use of chemicals, including pesticides and chemical fertilisers.
-
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 makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to no use of 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?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own 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?
The company commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides.
-
123. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own 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?
The company commits suppliers to not use Stockholm and Rotterdam Convention chemicals.
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125. Chemical usage per ha or list of chemicals used?
The company lists the names of pesticides and fertilisers. However, per-hectare usage figures are not reported.
-
126. 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's own reporting mentions using palm waste by-products as organic fertilisers.
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127. 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 reports using the Integrated Pest Management (IPM) approach which includes incorporating biological controls like the use of barn owls for rat population control and the planting of nectariferous plants like Tunerra Subulata and Antigonon Leptopus.
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128. Waste management system in place to avoid negative impacts?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The .company also has its own waste management system in place.
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Community, land and labour rights32 / 34 94.1%
- Organisation: 3 / 4 75%
- Policy: 20.5 / 21 97.6%
- Practice: 8.5 / 9 94.4%
- Self-reported: 0.5 / 9 5.6%
- External: 8 / 9 88.9%
- Certified: 0 / 9 0%
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129. Commitment to human rights?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to the Universal Declaration of Human Rights.
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130. Commitment to human rights applies to all suppliers?
The company commits suppliers to the Universal Declaration of Human Rights.
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131. Progress on human rights commitment?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting states that ESG risks including human rights-related risks are overseen by the GSSC and divisional Risk Management Committee and are reviewed twice a year. Human Rights due diligence was also developed and conducted through collaboration and engagement with internal and external organisations in 2022.
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132. Commitment to respect indigenous and local communities' rights?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to the United Nations Declaration on the Rights of Indigenous Peoples ("UNDRIP").
-
133. Commitment to respect indigenous and local communities' rights applies to all suppliers?
The company commits suppliers to the UN Declaration on the Rights of Indigenous Peoples.
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134. Commitment to respect legal and customary land tenure rights?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment 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 makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to free, prior and informed consent (FPIC).
-
137. Commitment to free, prior and informed consent (FPIC) applies to all suppliers?
The company commits all suppliers to respect FPIC.
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138. 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). Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company has also published its own free, prior, and informed consent (FPIC) process.
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139. Examples of local stakeholder engagement to prevent conflicts?
The company established a stakeholder engagement team to take the role of identifying stakeholders' concerns and areas of interest. However, the information reported is over two years old now.
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140. Details of process for addressing land conflicts available?
The RSPO Principles and Criteria 2018 contain requirements for addressing land conflicts. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.
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141. Supports the inclusion of women across palm oil operations, including addressing barriers faced?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting mentions having a women empowerment programme and a Women Empowerment Committee ("WEC") in place that regularly discusses issues related to women employees and their dependents including women's rights, harassment, as well as capacity building initiatives.
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142. Commitment to mitigate impacts on food security?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.
-
143. Progress on commitment to mitigate impacts on food security?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.
-
144. Commitment to provide essential community services and facilities?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to providing essential community services and facilities.
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145. Progress on commitment to provide essential community services and facilities?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to contribute to the community by providing funding for hospital buildings, the development of schools, and medical aids.
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146. Commitment to provide business/work opportunities for local communities?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.
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147. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to Free and Fair Labour Principles.
-
148. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies to all suppliers?
The company commits all suppliers to Free and Fair Labour Principles.
-
149. Progress on commitment to respect all workers' rights?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting also provides multiple examples of how its commitment to respecting all workers' rights is implemented.
-
150. Commitment to eliminate gender related discrimination with regards to employment?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to eliminate gender-related discrimination with regards to employment.
-
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?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting states that on matters of harassment, the training department from the company's HQ conducted training on "Understanding & Preventing Harassment at The Workplace" and "Understanding & Preliminary Investigation on Sexual Harassment at The Workplace" in 2021. Additionally, the company reports zero cases of discrimination during 2021-2022.
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153. Percentage or number of temporary employees?
This indicator is disabled as the company has no temporary employees.
-
154. Percentage or number of women employees?
6780 (27.96%) - The company has 6,780 women employees as of 2022.
-
155. Commitment to pay a Living Wage?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own commitment only covers paying minimum wage.
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156. Commitment to pay a Living Wage applies to all suppliers?
The company only commits suppliers to pay minimum wage.
-
157. Progress on commitment to pay a Living Wage?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.
-
0 / 1
158. Reporting of salary by gender?
-
159. Commitment to address occupational health and safety?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to addressing occupational health and safety.
-
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?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.
-
162. Time lost due to work-based injuries?
The company reports that the lost time injury frequency rate (Number/Million Hours) for its plantation and refinery divisions was 25.97 and 3.03, respectively.
-
163. Number of fatalities as a result of work-based accidents?
2 - The company reports two fatalities in its plantations in 2022.
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Smallholders and suppliers11.5 / 15 76.7%
- Organisation: 0 / 0 0%
- Policy: 5 / 6 83.3%
- Practice: 6.5 / 9 72.2%
- Self-reported: 3.8 / 9 41.7%
- External: 2.8 / 9 30.6%
- Certified: 0 / 9 0%
-
164. Commitment to support smallholders?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to support smallholders.
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165. Programme to support scheme smallholders?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also has a plasma scheme in Indonesia where the local smallholders are benefited by equipping them with knowledge and skills on initial preparation for land development and good agriculture practices.
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166. Percentage of scheme smallholders involved in programme?
The company reports that it has seven plasma cooperatives, with 3,690 participating families. It is unclear what the percentage of all scheme smallholders this represents.
-
167. Programme to support independent smallholders?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's own reporting states to have Smallholders Engagement Programmes where it provides capacity and empowerment programmes where the smallholders and out growers were provided with training mostly related to environmental management such as on Rare, Threatened, and Endangered ("RTE") species, water management on peat, waste management, conservation of forest buffer and riparian reserves. Operational training on FFB grading was also conducted with the smallholders.
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168. Percentage of independent smallholders/outgrowers involved in programme?
The company reports that 49 smallholders and outgrowers were involved in a training programme. It is not clear what smallholders this is referring to and it is unclear what the percentage of all independent smallholders this represents.
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169. Process used to prioritise, assess and/or engage suppliers on compliance with company's policy and/or legal requirements?
The company states that it risk-assesses all palm oil supplier mills using tools such as spatial data and remote sensing information in order to facilitate monitoring of the palm oil supply chain to establish priorities for conducting mill-level verification assessments. The company also assesses and prioritises suppliers on their NDPE compliance via the Tools for Transformation (T4T) tool by Earthworm.
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170. Number or percentage of suppliers assessed and/or engaged on compliance with company's policy and/or legal requirements?
83 (85.54%) - The company reports that in 2022, 85.54% or 83 mills participated in a self-assessment against NDPE requirements. However, the information reported is not externally verified.
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171. Suspension or exclusion criteria for suppliers?
The company reports that it conducts appropriate due diligence on prospective suppliers to assess compliance with the policy and also identifies appropriate measures to be carried out prior to entering into any contract. If suppliers miss targets in time-bound plans then the company will cease to do business with them. However, no timeframes of actions are provided.
-
172. Time-bound action plans (including Key Performance Indicators) for suppliers to be in compliance with palm oil sourcing commitments?
The company publishes KPIs for compliance, however, no time-bound target was reported and data does not cover all sourcing.
-
(NEW: not scored this year)-
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?
The company commits to engage with all high risk mills within 3 years.
-
175. Programme to support high risk mills to become compliant with sourcing policies?
The company has a Mill Prioritisation Profile to identify and prioritise suppliers for engagement activities. As such, priority in engagement is given to suppliers with scores of less than 100% or no TTP data provided, with the aim to improve their scoring. Subsequent engagement activities are planned based on the assessment results. The company collaborates with stakeholders, to conduct transformation programmes and joint focus sessions with supplier groups or individual suppliers on labour, traceability, and deforestation issues through a mixed remote and face-to-face method.
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176. Regularly engages with a subset of high risk mills?
In 2023, the company reports having engaged a combination of high-medium-low supplier categories in its engagement programmes as guided by the Mill Prioritisation Profiling. The objective of the company's engagement was to minimise gaps and enhance its suppliers' practices to deliver the company's NDPE requirements. However, it is unclear if this is practiced on a regular basis and covers all suppliers of the company.
-
177. Procedures in place to assess all own and third party supplying palm oil mills for risk level?
The company has a Mill Prioritisation Profile to assess the mills for risk level.
-
178. Regularly assesses and categorises the risk level of all their own and third party supplying mills?
The company assesses the risk level for all supplying mills on an annual basis.
-
179. Regularly reports the risk level of all own and third party supplying mills identified in its supply chain?
[Externally verified] The company reports the risk level for all supplying mills on an annual basis as either low, medium, or high risk.
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Governance and grievances6 / 7 85.7%
- Organisation: 0 / 0 0%
- Policy: 4 / 5 80%
- Practice: 2 / 2 100%
- Self-reported: 0 / 2 0%
- External: 2 / 2 100%
- Certified: 0 / 2 0%
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180. Commitment to ethical conduct and prohibition of corruption?
The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to ethical conduct and 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?
[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.
-
0 / 1
183. Disclosure of the company's management approach to tax and payments to governments?
-
184. Whistleblowing procedure?
The RSPO Principles and Criteria 2018 contain guidance and requirements on whistleblowing procedures. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own whistle-blowing policy in place.
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185. Own grievance or complaints system open to all stakeholders?
The company adheres to these criteria through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own grievance procedure that is open to all stakeholders.
-
186. Details of complaints and grievances disclosed?
[Externally verified] The company discloses details about individual grievances from stakeholders regarding suppliers and its own operations.
SPOTT scores are based on the presence of external evidence made available by the company or third-parties.
-
2022
ACOP 2022
-
No date
Membership - RSPO - WEBPAGE
-
October 2020
Sustainable Palm Oil Policy
-
2022
Annual Report
-
2022
Sustainability Report
-
June 2023
Terms of Reference Board Sustainability Committee
-
No date
Members - FFA - WEBPAGE
-
No date
Home - Palm Oil Collaboration Group - WEBPAGE
-
No date
Response - CDP - WEBPAGE
-
June 2022
Plantation - IOI - WEBPAGE
-
No date
Refining - IOI - WEBPAGE
-
December 2022
Palm Oil Dashboard and Traceability - IOI - WEBPAGE
-
No date
Universal Mill List - GFW - WEBPAGE
-
2022
IOI Full Mill List
-
No date
CERTIFIED COMPANIES (Supply Chain)
-
No date
CERTIFIED COMPANIES (PRINCIPLES AND CRITERIA)
-
2023
Sustainability Report 2023
-
No date
Complete List of Certified Entities Under MSPO - MSPO - WEBPAGE
-
No date
Archer Daniels Midland Company (ADM) - ISCC Certificates - WEBPAGE
-
No date
Environment Management Guidelines
-
May 2020
Responsible Sourcing Guidelines
-
2023
Supplier NDPE Monitoring And 2022 T4T Update
-
2020
Supplier NDPE T4T Progress Update Year - No.1
-
March 2014
NPP - PT. Bumi Sawit Sejahtera
-
November 2017
HCV PT Kalimantan Prima Agro Mandiri
-
April 2018
IOI Group - PT. Kalimantan Prima Agro Mandiri
-
No date
Assessment Reports - HCSA - WEBPAGE
-
2020
Sustainability Report 2020
-
2021
Sustainability Report 2021
-
May 2018
Zero Burning Policy
-
2018
IOI's efforts (as one of the Fire-Free Alliance (FFA) members) in resolving Indonesia's persistent fire and haze issues
-
2019
Sustainability Report
-
No date
Establish System and Process - IOI - WEBPAGE
-
No date
STAKEHOLDER ENGAGE
-
March 2022
Occupational Safety, Health and Hygiene Policy
-
No date
SUPPLIER ASSESSMENT FORM CODE OF CONDUCT
-
2020
IOI SUPPLY BASE NDPE PROGRESS UPDATE No. - 2020
-
April 2023
Supplier Engagement in Q1 2023 for NDPE Compliance
-
March 2022
BUSINESS ETHICS, COMPLIANCE, ANTI-CORRUPTION AND ANTI-MONEY LAUNDERING POLICY
-
No date
Whistleblowing Channel - IOI - WEBPAGE
-
November 2022
WHISTLEBLOWING POLICY
-
January 2020
Grievance Procedure
-
No date
Grievance Update - Environmental, Social and Governance
-
No date
Grievances - IOI - WEBPAGE
Media monitor: IOI Corporation Bhd
SPOTT monitors global media sources for coverage of assessed companies. The media monitor gathers reports about specific activities related to the assessment indicator categories. ZSL does not assess or score the validity of media coverage, but users can explore the media monitor to provide context on implementation, and infer risks associated with reported operations on the ground. The media monitor undergoes a full update at the time of publishing an assessment round, with ad-hoc updates throughout the year. This is not an exhaustive list of all media reports relevant to the company.
March 2023
Conservationists decry palm oil giants’ exit from HCSA forest protection group
September 2022
RSPO Complaint: IOI Plantation Mekassar Estate (a subsidiary of IOI Corporation Berhad)
June 2021
Statement In Response To Circulation Of A Letter From US Customs and Border Protection About IOI Corporation
April 2021
The Chain: Selangor State Agricultural Development Corporation Peat Clearing Risks Access to FMCG and Trader/Refiner Supply Chains
September 2020
Kebakaran di konsesi IOI ketika jerebu dikaitkan dengan perladangan baru (Fires at IOI concessions during haze are associated with new plantations)
September 2020
IOI Response to Malaysiakini Articles Published 17 September 2020
September 2020
IOI says fire at its Kalimantan concession due to 'negligent' locals
September 2020
The Chain: Sarawak State Government to Purchase TH Plantations' Sarawak Concessions, but NDPE Supply Chain Not Guaranteed
July 2020
The Chain: Aspirasi Kristal's Forest Clearance for Oil Palm in Sabah Raises Questions for IOI
September 2019
Companies linked to haze may be penalised when entering Malaysia, says Guan Eng
September 2019
Greenpeace claims Malaysia's Genting among palm oil groups with most burnt land in Indonesia but firm disputes findings
February 2019
The Chain: NDPE Uptake Impacts List of Top 10 Deforesters in SE Asia
September 2018
The Final Countdown: Now or never to reform the palm oil industry
19
8
11
50
14
4
35
19
17
14
Media monitor: IOI Corporation Bhd
SPOTT monitors global media sources for coverage of assessed companies. The media monitor gathers reports about specific activities related to the assessment indicator categories. ZSL does not assess or score the validity of media coverage, but users can explore the media monitor to provide context on implementation, and infer risks associated with reported operations on the ground.
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