IOI Corporation Bhd

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 also has its own policy.

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

The company has sustainable palm oil policy and commitment which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company's day-to-day sustainability matters are led by its group Head of Sustainability who communicates and reports directly to the GMD.

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.

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

2 (12.5%) - The company has 2 out of 16 female senior management team members in 2021, however this has been calculated from staff profiles and is not directly reported by the company.

6. Percentage or number of women board members?

2 (29%) - The company reports that 2 out of 7 board members are female (29%) in 2021.

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 the HCS Approach Steering Committee.

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

The company collaborates with Earthworm Foundation to monitor the supply chain and adopt responsible practices. The company also collaborates with Aidenvironment Asia and Global Environment Centre for various sustainability initiatives, including the South Keptapang Landscape Initiatives which promote sustainable economic growth without negative consequences, RELeaf project which is a partnership with Nestle and NGOs for reforestation of the Kinabatangan River, Forest and Land Fire Prevention project with stakeholders within the district of Kendawangan in West Kalimantan, Indonesia.

9. Sustainability report published within last two years?

The latest sustainability report was published in 2021.

10. Reports through standardised reporting systems?

The company's sustainability report states it has been prepared 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?

The company reports climate-related risk and mitigation and adaptation strategies, which has been conducted in accordance with TCFD guidance.

13. Lists countries and operations?

The company publishes a map that includes the list of countries and operations within those countries.

14. Lists countries sourcing from?

The company reports that 52% is sourced from Peninsular Malaysia, 46% from Sabah Malaysia, and the remaining 2% from 'others'. The data is undated and it is not clear what locations 'others' includes. The company also reports a mill list which includes mills located in Malaysia, Cambodia, and Thailand. The countries sourcing from are not reported directly.

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

207482 - The company reports 206,987 ha as its total landbank. However, the RSPO ACOP reports that the company has 207481.5 ha of the land area managed/controlled for oil palm.

16. Total oil palm planted area (ha)?

176926 - The company reports that its total oil palm planted area is 176,926 ha. However, the RSPO ACOP 2021 reports 186767.84 ha of total oil palm planted including infrastructure area. Hence, considered the figure from the company's own reporting that is specific to total oil palm planted area.

17. Scheme smallholders planted area (ha)?

3995.05 - The RSPO ACOP reports that scheme smallholders planted area was 3995.05 ha in 2021.

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

6667.08 - The RSPO ACOP reports that the unplanted planted area was 6667.08 ha in 2021.

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

10051.6 - The company reports that the total HCV area is 3,608.47 ha and other conservation land set aside, excluding HCV areas, is 6,145.23 ha. However, the RSPO ACOP 2021 reports that the total land designated and managed as HCV areas was 3655.24 ha, and other conservation land set aside, excluding HCV areas was 6396.38 ha.

20. Maps of estates/management units?

Concession boundaries have been made available to the RSPO.

21. Maps of scheme smallholders?

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

23. Number of company-owned mills?

15 - The company reports it has 15 mills.

24. Names and locations of company-owned mills?

The company has published referenced maps for all its mills.

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

The company reports that as of 2021 "18% of supplying Mills source FFB entirely from Internal Plantations, The FFB for 9% of supplying Mills are from external sources, 59% of Mills source FFB from both internal plantations and external suppliers" and 14% of Mills are pending data Analysis. It is unclear if this data refers to own or third-party supplying mills.

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

The company reports that as of 2021 "49% of Oil volumes are derived from plantations owned by suppliers, 38% of Oil Volumes are derived from external sources, 13% of oil volumes ? pending data analysis." However it is unclear if this data refers to own or third-party supplying mills. Partial points have been awarded for 2018 data which states 96% of FFB processed by IOI's mills is supplied by its own estates. This data is over 2 years old.

27. Number of third party supplying mills?

412 - The company reports having 412 supplying mills as of 2021.

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

The company publishes a list of mills that state the mill name, parent company name, country, longitude, latitude, and source.

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

The company reports that as of 2021 "18% of supplying Mills source FFB entirely from Internal Plantations, The FFB for 9% of supplying Mills are from external sources, 59% of Mills source FFB from both internal plantations and external suppliers" and 14% of Mills are pending data analysis. However it is unclear if this data refers to own or third-party supplying mills.

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

The company reports that as of 2021 "9% of Oil volumes are derived from plantations owned by suppliers, 38% of Oil Volumes are derived from external sources, 13% of oil volumes ? pending data analysis." However it is unclear if this data refers to own or third-party supplying mills.

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

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

The company reports that all volumes of palm oil, palm oil fractions and palm kernel oil are 100% traceable to supplying mills.

33. Percentage of supply traceable to mill level?

The company reports that all volumes of palm oil, palm oil fractions, and palm kernel oil are 100% traceable to supplying mills.

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

The company has committed to achieving full traceability to plantations by the end of 2020. Also, the company reports having achieved 100% traceability to plantation level on its website. However, the information is undated.

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

The company reports on its Dashboard that supply to its mills is 100% traceable to the plantation level. However, this data is undated. The company's 2021 Sustainability Report states that palm oil is 83% traceable to plantation level and palm kernel oil is 69% traceable to plantation, however it is not clear if this data refers to own or third-party mills. and an additional point has been awarded due to company mills holding RSPO Identity Preserved certification.

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

The company's 2021 Sustainability Report states that palm oil is 83% traceable to plantation level and palm kernel oil is 69% traceable to plantation, however it is not clear if this data refers to third-party mills only. The additional point has been awarded due to company mills holding RSPO Identity Preserved certification.

37. Publishes traceability data at refinery level?

[Externally verified] The company reports that the traceability for the refiner (IOI Edible Oils Sandakan) to the plantation level is 93% for palm oil and 87% for palm kernel oil.

38. Publishes traceability data at crusher level?

[Externally verified] The company reports that the traceability for the refiner which is also the company's kernel crusher (IOI Edible Oils Sandakan), to the plantation level for palm oil is 93% and for palm kernel oil is 87%.

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

[Externally verified] 2004 - Note that the company was suspended from the RSPO for five months in 2016.

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.

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

The company has submitted its 2021 ACOP.

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

[Externally verified] 84.87% - The RSPO ACOP 2021 reports that 84.87% of the area is RSPO-certified.

43. Percentage of mills RSPO-certified?

[Externally verified] 93% - 14 out of 15 mills are RSPO-certified.

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

2023 - The company commits to achieve 100% RSPO certification of estates and mills by 2023. This is within 5 years.

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.

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

0% - The RSPO ACOP 2021 reports that 0% of the scheme smallholders area is RSPO-certified.

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

2023 - The company commits to achieve 100% RSPO certification of scheme/associated smallholders and outgrowers by 2023. This is within 5 years.

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

0% - The RSPO ACOP 2021 reports that 0% of the FFB supply from independent smallholders/outgrowers/third-party FFB suppliers is RSPO-certified.

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

[Externally verified] 37.32% - The RSPO ACOP 2021 reports that 37.32% of all palm oil and oil palm products handled/traded/processed are RSPO-certified.

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

[Externally verified] In the company's 2021 ACOP it is reported that it sells 87% of RSPO-certified palm oil through Segregated or Identity Preserved supply chains.

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

[Externally verified] In the company's 2021 ACOP it is reported that it process/trades 26.72% of RSPO certified palm oil through Segregated or Identity Preserved supply chains.

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

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company achieved 100% MSPO for estates and mills in Malaysia and data is externally verified.

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

[Externally verified] The company is certified under ISCC and data is externally verified.

55. Commitment to zero conversion of natural ecosystems?

56. 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 has also published this commitment independently.

57. Commitment to zero deforestation applies to all suppliers?

The company has a commitment to no deforestation which applies to all suppliers.

58. 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 also reports a moratorium for no deforestation since 2016.

59. 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. No clear criteria for defining deforestation is provided.

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

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

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

The company has partnered with Aidenvironment to establish a near real-time deforestation monitoring capacity where the company's suppliers are operating. However, the area covered by monitoring is not disclosed. Information is not externally verified.

62. 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 in 2016.

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

0 (0%) - The company reports that "there have been no new reported grievances related to deforestation and peat clearance on our suppliers" in FY2021, however the data appears only to be for the FY rather than since the commitment cut-off date.

64. Commitment to restoration of deforestation/conversion?

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 (?75%) and a further commitment to be 100% certified within 5 years.

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

66. Implementing a landscape or jurisdictional level approach?

The company has given information on different ways of implementing a landscape or jurisdictional level approach. However, data is not externally verified.

67. Biodiversity policy?

68. Biodiversity policy applies to all suppliers?

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. Also, the company has given examples of species and/or habitat conservation management.

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

The company commits to no hunting of animals.

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

73. 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 has also published this commitment independently.

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

The company hasa commitment to conduct High Conservation Value (HCV) assessments which applies to all suppliers.

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

[Externally verified] The company has published a summary of HCV assessment for PT. Bumi Sawit Sejahtera on the RSPO website.

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

[Externally verified] The company has submitted the HCV public summary report and RSPO NPP report of its subsidiary.

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

[Externally verified] The company has submitted the HCV public summary report and RSPO NPP report of its subsidiary.

78. 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.

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?

80. 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 approved by the HCV ALS Quality Panel.

81. 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. Also, the company has its own commitment to the High Carbon Stock (HCS) Approach.

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

The company has a commitment to the High Carbon Stock (HCS) Approach which applies to all suppliers.

83. High Carbon Stock (HCS) assessments available?

[Externally verified] The company has published an HCSA Peer Review Report on the HCSA website and completed the peer review process.

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

[Externally verified] The company has published an HCSA Peer Review Report on the HCSA website and completed the peer review process.

85. 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 has also published this commitment independently.

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

The company has a commitment to conduct social and environmental impact assessments (SEIAs) which applies to all suppliers.

87. 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.

88. 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 has also published this commitment independently.

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)?

3767 - The company reports that in 2021, 3,767 ha of land has been planted on peat in accordance with the RSPO Manual on Best Management Practices and IOI's internal Peatland Protection & Management Guideline.

91. 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.

92. 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.

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

The company commits suppliers to BMPs for peat soils and 'marginal soils' (those of poor agricultural value). As this does not cover all soil types full points cannot be awarded.

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

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

95. 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 makes this commitment independently.

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

97. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports examples such as utilisation of drones and SMART for monitoring.

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

In 2021, the company reports there was 1 fire incident within company concessions in Sarawak, and none in Sabah, Peninsular Malaysia or Indonesia.

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

5 - In 2021, the company reports there were 4 fire incidents within company concessions in Peninsular Malaysia, 1 in Indonesia, and none in Sarawak or Sabah.

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

The company has a target to reduce GHG emissions intensity by 41.7% or 48.7% (dependent on two scenarios) by the year 2025.

101. GHG emissions intensity?

The company reports GHG Emission Intensity by company division as 1.56 (plantation - mills & estates), 0.34 (oleochemical) and 0.03 (refinery) tCO2-e/MT Product in 2021.

102. GHG emissions from land use change?

The company only states ""About 51% of the total GHG emissions were from historical land use change during plantation development."".

103. Progress towards commitment to reduce GHG emissions intensity?

The company reports a reduction in GHG emission intensity for plantations and mills, and refineries in 2021 compared to 2020 and both have reduced from the 2015 baselines. For its oleochemical division, GHG emissions intensity increased in 2021 compared with 2020 and exceeded the 2015 baseline.

104. 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 reports that refinery calculations are based on ISCC methodology and plantations (Mills & Estates) based on RSPO PalmGHG calculator.

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

The company reports that 10 mills have methane capture facilities.

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

107. Water use intensity?

5.9 - The company reports a water consumption figure for the processing of FFB as 5.90 (m3 water/MT FFB) in 2021.

108. Progress towards commitment on water use intensity?

The company reports the water use intensity (m3 water/MT product) for each division. Water use intensity has improved from FY2021 to FY2022 for plantations (mill operations) and the company's refinery, but water use intensity for oleochemicals has not improved.

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

The company commits to maintain BOD and COD levels within legal limits.

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

The company reports that it keeps BOD levels range between 20mg/l to 100 mg/l, depending on the licence issued to the respective mill by the Department of Environment ("DOE"). it is unclear what the legal limits are compared to the company's BOD levels.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. Also, the company states it treats POME before discharge.

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

The company states it treats PORE before discharge.

113. 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 makes this commitment independently.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports having a buffer zone rehabilitation programme.

115. 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 publishes this commitment independently.

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 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 publishes this commitment independently.

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

The company commits all suppliers to not use paraquat.

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

The company 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 publishes this commitment independently.

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

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

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

The company 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 publishes this commitment independently.

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

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

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

The company lists the names of pesticides and fertilisers. However, per hectare usage figures were not reported.

124. Implementation of commitment to minimise inorganic fertiliser use?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company gives examples of reusing oil palm discards as organic fertiliser and researching precision pesticide application.

125. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company gives examples of using biological controls to reduce pests.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also provides multiple examples of waste management throughout its operations.

127. 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. Also, the company states it respects and upholds the rights of all workers and protects human rights in accordance with the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

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

129. Progress on human rights commitment?

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

130. 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. Also, the company has a commitment to respect the rights of indigenous local communities in accordance with the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP").

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

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

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

The company 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. Also, the company has a commitment 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 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 has also published this commitment independently.

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

The company commits all suppliers to respect FPIC.

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

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior, and informed consent (FPIC). 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 process.

137. 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.

138. 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.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. Also, the company launched a Women's Empowerment Committee to help combat barriers faced.

140. 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.

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

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

142. 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.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company gives examples of providing support for education, medical, and community initiatives.

144. 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.

145. 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 publishes this commitment independently.

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

The company has published this commitment.

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

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

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

The company 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. Also, the company has a commitment to providing fair and equal employment opportunities for all employees, regardless of race, nationality, religion, or gender.

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company has established a Women and Empowerment Committee providing a platform for women employees to discuss any issues that may affect them, such as sexual harassment, violence towards women, discrimination, women's welfare and workplace related issues as well as to undertake and explore opportunities in empowering women at the workplace.

151. Percentage or number of temporary employees?

152. Percentage or number of women employees?

6764 (27.9%) - The company has 6,764 women employees in total.

153. Commitment to pay a Decent 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 has a commitment to paying the minimum wage.

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

The company commits suppliers to pay the minimum wage.

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

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

156. Reporting of salary by gender?

157. 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. Also, the company has an occupational health and safety policy.

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

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

159. Provision of personal protective equipment and related training?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. Also, the company reports it provides personal protective equipment and related training.

160. Time lost due to work-based injuries?

36.99 - The company reports that the lost time injury frequency rate (Number/Million Hours) for its Plantation and Refinery divisions was 33.89 and 3.10 respectively.

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

5 - The company reports the number of fatalities was 5.00 (Plantation) and 0.00 (Refinery).

162. 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 has also published this commitment independently.

163. Programme to support scheme smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports it helps smallholders and outgrowers to increase their yield and assists them in preparing for mandatory sustainability certifications like Malaysian Sustainable Palm Oil ("MSPO") and Indonesian Sustainable Palm Oil ("ISPO").

164. Percentage of scheme smallholders involved in programme?

3000 - The company reports that 3,000 scheme smallholders are involved in a support programme. It is unclear what the percentage of all scheme smallholders this represents.

165. Programme to support independent smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it provides training to smallholders and outgrowers so that they could improve the quality of FFB.

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

The company reports that 30 smallholders and 19 out growers were involved in Smallholders Engagement Programmes in Lahad Datu. It is not clear what smallholders this is referring to and it is unclear what the percentage of all independent smallholders this represents.

167. 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.

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

90% - The company reports that in 2021 over 90% of supplying mills have participated in a self-assessment against NDPE requirements.

169. 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.

170. 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 was reported and data does not cover all sourcing.

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

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

The company has identified high-priority suppliers within its supply chain, however, no time frame was given, and it is unclear if it covers both own and third-party mills. Hence, awarded no points.

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

The company states that in 2020, it engaged with 77% of suppliers through direct engagement methods such as workshops and on-site engagement. However, unclear if covers both own and third-party mills.

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

The company only states that it engaged with suppliers through direct engagement methods such as workshops and on-site engagement. However, it is not clear if it engages on an annual basis or if this covers both own and third-party mills.

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

The company states that it has identified high priority, medium priority, and low priority suppliers within its supply chain through a desktop analysis using GFW Pro platform, however no further details on the procedure are given, and it is not clear if the information covers both own and third-party mills.

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

The company reports that mills are assessed every two years.

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

The company reports the risk level for some suppliers. However, it is unclear if the data covers both own and third-party mills and the data not externally verified.

178. 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 has also published this commitment independently.

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

The company has a commitment to ethical conduct and prohibition of corruption which applies to all suppliers.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports examples of training on its revised Business Ethics, Compliance, Anti-corruption and Anti-Money Laundering Policy.

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

182. 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 has a whistleblowing policy which states the scope of the policy and ensures the protection to whistleblower.

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

The company adheres to this 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 has also published details of its grievance procedure.

184. Details of complaints and grievances disclosed?

The company discloses details about individual grievances from stakeholders regarding suppliers and its own operations.