IOI Corporation Bhd

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

Sustainable Palm Oil Policy.

2. Policy or commitment applies to direct and third-party suppliers?

3. High-level position of responsibility for sustainability?

Group Head of Sustainability, who reports to the CEO.

4. Sustainability report published within last two years?

5. Member of multiple industry schemes or other external initiatives to improve sustainability in relation to palm oil?

Member of Fire Free Alliance and HCS Approach Steering Committee.

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

This indicator is disabled as it is not applicable to this company.

7. Activities with government, NGOs or academic institutions to improve palm oil sustainability?

The company has formed a Sustainability Advisory Panel composed of NGOs, customers and other experts to advise on specific issues. It is also developing a landscape level approach in its Ketapang concession in Indonesia where it will collaborate with both the federal and provincial government agencies, local communities, NGOs and other plantation companies. In August 2018, it reported working with the University of Malaysia to promote a more sustainable palm oil industry.

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

206285 - The company states in its 2018 Annual Report that it has a total area of 217,329 ha including palm and rubber. Elsewhere in the same report it states planted area for both subsidiaries and associated companies, which together add up to 306,278 ha. If the unplanted and conservation area figures from the 2017 ACOP are added to this, that figure increases to 327,997.59 ha. The ACOP states a total of 206,285.38 ha managed for oil palm. These different figures mean it is unclear what the company's total land area managed for oil palm is.

9. Total oil palm planted area (ha)?

179063 - The company reports a figure of 179,063.56 ha in its 2017 ACOP, but a figure of 174,396 ha in its 2017 Annual Report. Its palm oil dashboard states an oil palm planted area of 184,266 ha, but this information is not dated.

10. Plasma/scheme smallholders planted area (ha)?

4250

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

7251

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

14468.5 - Sum of HCV areas and other conservation areas in 2017 ACOP.

13. Area for infrastructure (ha)?

33601 - The company states this area is for "Labour lines, building sites and others" but it is unclear exactly what this includes, and whether it includes commodities other than oil palm.

14. Number and names of company owned mills?

15 - The company reports it has 15 palm oil mills (POMs): Pamol Kluang POM, Gomali POM, Sukses Karya Sawit POM, Baturong POM, Unico Oil Mill, Unico-Desa Oil Mill, Morisem POM, Leepang POM, Syarimo POM, Mayvin POM, Ladang Sabah POM, Sakilan POM, Pamol Sabah POM, Bukit Leelau POM, and Pukin POM.

15. Maps or coordinates of company owned mills?

16. Number and names of supplier mills?

478

17. Maps of estates/management units?

Concession boundaries have been made available to the RSPO and the company declared in its 2015 ACOP this represents 100% of its concessions. The landbank appears to have increased since then, and although more shapefiles were submitted in the 2017 ACOP, these are not available and a new statement has not been made declaring 100% of concessions are still with the RSPO. Some maps are available on GeoRSPO. The company also provides a map of its estates on its dashboard, but this only shows point-locations, not estate boundaries.

18. Maps of scheme/plasma smallholders?

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

2018 - The company states that all volumes of palm oil and palm oil fractions will be 100% traceable to mills by the end of 2016 while palm kernel oil volumes will be traceable to crushers by end of 2016 and to the mills by end of 2018. It currently reports on its dashboard it has 100% traceability of palm oil, and 98% traceability of palm kernel oil, to mill.

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

2020 - The company commits to 100% traceability to plantation by the end of 2020.

21. Percentage of supply traceable to mill level (above 80%)?

98% - The company currently reports on its dashboard it has 100% traceability of palm oil, and 98% traceability of palm kernel oil, to mill.

22. Percentage of fresh fruit bunches (FFB) from own mills traceable to plantation level (above 75%)?

The company states that the volumes from company-owned mills are traceable to plantation level.

23. Percentage of fresh fruit bunches (FFB) from supplier mills traceable to plantation level (above 75%)?

The company reports traceability to plantation of 36% for palm oil and 26% for palm kernel oil. It is unclear if these figures include traceability to the company's own mills as well as supplier mills.

24. Commitment to zero deforestation?

25. Deforestation commitment applies to scheme smallholders and independent suppliers?

26. Criteria for defining deforestation?

HCV, HCS, peat.

27. Evidence of monitoring deforestation?

The company reports a project with Satelligence to monitor forest clearance, and mentions that patrols are organised to monitor for illegal logging, hunting and fires (once a week in dry season, twice a month in the wet season).

28. Examples of habitat management and/or habitat restoration?

The company has engaged the Global Environment Centre on peat restoration and protection measures in peat and HCV areas, and is continuing to rehabilitate peatland. It is undertaking rehabilitation and enrichment of degraded HCV areas, using signage for restriction of restricted areas and monitoring the condition of conservation and buffer areas.

29. Implementing a landscape-level approach to biodiversity conservation?

The company has developed and begun implementing its "Ketapang Landscape Level Approach" in West Kalimantan, which "has been adapted to foster integrated peatland management and rehabilitation, orangutan habitat protection, and fire prevention".

30. Commitment to biodiversity conservation?

31. Commitment to not endanger species of conservation concern, referencing international or national system of species classification?

The company states "We are focused on protecting nationally protected flora and fauna and those endemic to the areas in which we operate. We do match these species to the IUCN Red List status.".

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

The company mentions patrols to monitor hunting, but does not make a commitment regarding hunting.

33. Examples of species conservation activities?

The company has conducted wildlife management training, has honorary wildlife and forest managers, and is contributing to several conservation efforts, such as the Malua Wildlife Conservation Initiative. It also mentions identification of rare, threatened and endangered species, and patrols for illegal poaching.

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

35. HCV commitment applies to scheme smallholders and independent suppliers?

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

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

The following HCV assessment is publicly available:
PT. Bumi Sawit Sejahtera (summary report).

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

PT. KPAM, a subsidiary of the company, has a summary assessment available on the HCVRN website and RSPO New Planting Procedures for an area of 11,000 ha in 2018.

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

PT. KPAM, a subsidiary of the company, has a summary management and monitoring plan available on the HCVRN website and RSPO New Planting Procedures for an area of 11,000 ha in 2018.

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

PT. KPAM, a subsidiary of the company, has a summary assessment available on the HCVRN website. This has been deemed satisfactory after a third review, and seems to cover an area of 11,001 ha (although elsewhere the report states 1,100.1 ha). However, RSPO NPP were submitted in April 2018 for PT. KPAM, and it is not clear if this assessment covers all the same area (the NPP state 11,000 ha, whereas the assessment alternately states 1,100.1 ha and 11,001 ha).

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

42. High Carbon Stock (HCS) assessments?

PT. KPAM, a subsidiary of the company, has an assessment available on the HCS Approach website, which is marked as complete.

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

44. Social and environmental impact assessments (SEIAs) undertaken, and associated management and monitoring plans?

The following SEIA assessment is publicly available: PT. Bumi Sawit Sejahtera.

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

46. Peat commitment applies to scheme smallholders and independent suppliers?

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

48. Landbank or planted area on peat?

8396

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

50. Commitment to zero burning?

The company has a zero burning policy, though states within it that "Where burning is necessary, IOI will follow the rules in EQA 1974".

51. Zero burning commitment applies to scheme smallholders and independent suppliers?

52. Evidence of management and monitoring fires?

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

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

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

The company has a commitment to "Reduce GHG at all IOI mills through the installation of Biogas capturing systems by 2020 (subject to new technologies)" but this commitment does not have a target reduction figure and is not framed in terms of intensity. Other than this, it only states it is committed to implement programs to progressively reduce GHG emissions and it has drafted a GHG reduction plan, but has no target-based, time-bound, commitment.

56. GHG emissions from land use change?

57. Methodology used to calculate GHG emissions?

The company stated in its 2016 RSPO ACOP it was using the RSPO Palm GHG Calculator and ISCC GHG Emission Calculation Methodology. It did not make a statement on this in the 2017 ACOP.

58. Progress towards commitment to reduce GHG emissions intensity?

The company reports GHG intensity figures for some of its operations, but not all, and only Scope 1 and 2. It reports an overall figure of 12,465 MT CO2e for its plantation operations in its 2017 Annual Report, but this is not a measure of intensity. The company also does not have a target-based, time-bound commitment to reduce GHG emission intensity.

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

2 (13.3%) - As of June 2018, the company reports it has two biogas plants completed, three under construction and expected to begin operation in Q318, and a further four mills planned by 2019.

60. Time-bound commitment to improve water use per tonne of FFB Processed?

The company states it had a target to reduce water usage by 5% by the year 2016, which it met, but this target was not framed in intensity (by tonne of FFB processed). It now states "A review of operations is currently underway, and reduction targets will be set during our 2018 reporting cycle for the next five years.".

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

62. Progress towards commitment on water use?

The company reports figures on water consumption per MT of FFB from 2013 to 2016. This improved between 2015 and 2016 by more than 5%, in line with the company's general target, but water consumption increased again in 2017. Furthermore, although water usage is reported per tonne, the company's target was not framed around intensity.

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

The company reports that "The BOD level of our POME is within the acceptable limit as required by the Department of Environment. The lowest BOD level recorded is 23 PPM in 2015" but it is not clear if this figure is improving. The company does not have a commitment to reduce levels of BOD and COD. It does not report levels for COD.

64. Protection of natural waterways through buffer zones?

65. Evidence of treating palm oil mill effluent (POME)?

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

The company only states that "Best agronomic practices and efficient land utilisation led to higher productivity, hence reducing usage of chemical fertiliser and pesticide" and mentions minimising pesticide use as part of IPM, but does not have a clear commitment. It released a new Agrochemical Management Policy in July 2018, but this does not contain a commitment to reduce chemical use.

67. No use of paraquat?

68. No use of World Health Organisation (WHO) Class 1A and 1B pesticides?

69. No use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

70. Integrated Pest Management (IPM) approach?

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

The company reports the total amount used of pesticides and fertilisers in its 2017 Sustainability Report, and lists names of pesticides and fertilisers used in its 2018 Sustainability Report. It is not clear if this list is exhaustive.

72. Commitment to human rights, referencing the UN Declaration of Human Rights or UN Guiding Principles on Business and Human Rights?

73. Commitment to human rights applies to scheme smallholders and independent suppliers?

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

The company states "At the core of IOI's community development and social impact approach is a respect for local communities to hold legal, communal or customary rights on any project that might affect their way of life or occurs in their territories".

75. Commitment to respect indigenous and local communities' rights, referencing the UN Declaration on the Rights of Indigenous Peoples or ILO 169?

The company commits to respect rights according to the UNDRIP, but only in reference to land tenure rights and FPIC.

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

77. FPIC commitment applies to independent suppliers?

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

79. Details of process for addressing land conflicts available?

The company has a "boundary disputes handling" document.

80. Commitment to mitigate impacts on food security?

81. Commitment to provide essential community services and facilities?

The company commits to "strive to drive positive socio-economic impact and enhance the wellbeing of the communities in which it operates" and gives examples of services and facilities it has provided the community with, including school scholarships and the construction of roads and bridges.

82. Commitment to respect all workers' rights?

The company commits to "Respect and uphold the rights of all workers, including contract, temporary, and migrant workers".

83. Reference to Fundamental ILO Conventions or Free and Fair Labour Principles?

84. Total number of employees?

23000 - This is the total number of employees under the Group, as reported in the 2017 Sustainability Report.

85. Percentage or number of temporary employees?

9685 (42.1%) - Sum of temporary and contract employees.

86. Percentage or number of women employees?

6812 (29%)

87. Commitment to pay minimum wage?

The company states that minimum wage is paid to all employees, but evidence of this is only provided in relation to employees on plantations in Malaysia.

88. Commitment to address occupational health and safety?

89. Time lost due to work-based injuries?

56.38 - This is the injury rate per million hours in IOI Plantation, across 2016-17. The company also reports for Loders Croklaan (which it no longer has management control of) and IOI Oleochemical.

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

3 - The company reports fatalities of 1 female and 2 male workers across 2016-17, for IOI Plantation. It reports 0 fatalities for the same period across Loders Croklaan (which it no longer has management control of) and IOI Oleochemical.

91. Provision of personal protective equipment and pesticide training?

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

2004

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

94. Listed all countries and regions in which operates in most recent RSPO Annual Communication of Progress (ACOP)?

The company states all the countries and regions in which the company seems to operate, when cross-referenced with its plantation maps: Indonesia (West Kalimantan); Malaysia (Johor; Malacca; Negeri Sembilan; Pahang; Sabah; Sarawak).

95. Time-bound plan for achieving 100% RSPO certification of estates within 5 years or achieved 100% RSPO-certification of estates?

2020 - This target was extended from 2013 to 2017, and then to 2018 and then to 2020.

96. Time-bound plan for achieving 100% RSPO certification of scheme/associated smallholders within 5 years or achieved 100% RSPO-certification of scheme/associated smallholders?

2020 - This target was extended from 2017.

97. Year expected to achieve 100% RSPO certification of all palm product processing facilities?

2020 - This target was extended from 2018.

98. 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?

2009

99. Percentage of mills RSPO-certified (above 75%)?

12 (80%)

100. Percentage of area (ha) RSPO-certified (above 75%)?

155596 (75.4%)

101. Percentage of scheme/associated smallholders (ha) RSPO-certified (above 75%)?

The company reports 0 ha and 0 tonnes certified from scheme/plasma smallholders, but does report that the 2391.51 tonnes sourced from associated smallholders is certified.

102. Percentage of FFB supply (tonnes) from independent FFB suppliers that is RSPO-certified (above 75%)?

103. Percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that are RSPO-certified (above 75%)?

569541 (20%) - Total volume handled/processed/traded in year RSPO certified divided by total volume of all palm oil and oil palm products handled/traded/processed in the year.

104. Sells or processes/trades RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

Book and Claim, Mass Balance, Segregated, Identity Preserved.

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

106. Malaysia Sustainable Palm Oil (MSPO) certified?

The company reported that it has a total of six 'groupings' MSPO-certified in June 2018. The MSPO list of certifications shows the company has multiple estates certified, but only three complete certifications of both estate and mill.

107. Certified under voluntary sustainability certification scheme (e.g. ISCC, SAN, RSB, etc.)?

Plantations and mills in Peninsula Malaysia and Sabah have been ISCC-certified and the company is certified to the ISO 4001 standard. The company has RSPO-Next certification for 1 mill as of June 2018, and has audits for others coming up.

108. Programme to support scheme smallholders?

109. Number or percentage of scheme smallholders involved in programme?

110. Programme to support independent smallholders?

111. Number or percentage of independent smallholders involved in programme?

112. 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.

113. Suspension or exclusion criteria for suppliers?

The company states for both direct and indirect supplier mills, that it requires compliance within 12 months and "Where groups are suspected of serious or ongoing environmental, social and labour violations, IOI Group shall consider suspending purchases from the group until investigations are concluded and any policy violations resolved".

114. Percentage of suppliers assessed and/or engaged on compliance with company requirements?

The company states in its 2017 report that "A total of 21 mill verification assessments were completed during the reporting period, representing 1.5% of our suppliers".

115. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct, but does not explicitly commit to an anti-corruption policy.

116. Whistleblowing procedure?

117. Own grievance or complaints system?

118. Grievance or complaints system is accessible to internal and external stakeholders?

119. Details of grievances disclosed?