KPN Plantation (previously GAMA Plantation)

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

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

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

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

3. High-level position of responsibility for sustainability?

The company reports its sustainability management team is led by the "Compliance and Sustainability Certification Division Head". However, the information reported is from 2021 and is now over two years old.

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

This indicator has been disabled as the company is not publicly listed and does not have a board.

5. Reports gender balance of senior management team?

6. Reports gender balance of board members?

This indicator has been disabled as the company is not publicly listed and does not have a board.

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with palm oil production?

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

The company reports its has been part of the Collaborative Research Center (CRC) 900: Ecological and Socioeconomic Functions of Tropical Lowland Rainforest Transformation System (EfforTS) Indonesia which conducts studies on the ecological and socioeconomic effects of sustainable plantation management for smallholders based on research carried out at Bukit Duabelas and Hutan Harapan in Jambi. The company also reports collaboration with PT Restorasi Ekosistem Indonesia (REKI) to manage degraded conservation areas surrounding its concessions. However, the information reported is from 2021 and is over two years old now.

9. Sustainability report published within last two years?

The company published its first Sustainability Report in 2022, covering the years 2018-2021. However, this information is over two years old now.

10. Reports through standardised reporting systems?

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

This indicator is disabled as the company is not a POIG member.

12. Climate risks assessment available?

13. Lists countries and operations?

Indonesia (plantations, mills, and crushing facilities).

14. Lists countries sourcing from?

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

248000 - The company reports controlling a total area of over 248,000 ha in Indonesia. However, approximate figures are reported and information is from 2021.

16. Total oil palm planted area (ha)?

200668 - The company reports a total planted area of 200,668 ha as of 2021. However, the information reported is over two years old now.

17. Scheme smallholders planted area (ha)?

37166 - The company reports a total of 37,166 ha of planted area under scheme smallholders as of December 2021. However, the information reported is over two years old now.

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

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

25594 - The company reports a total of 25,594 ha of conservation set-aside area, as of December 2021. However, the information reported is over two years old now.

20. Maps of estates/management units?

21. Maps of all scheme smallholders?

22. Maps of all third-party supplying plantations?

23. Number of company-owned mills?

26 - The company reports it operates 26 mills as of August 2023.

24. Names and locations of company-owned mills?

The company only discloses the names of the palm oil mills it operates.

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

The company reports that nine company-owned mills source from their own operations and twelve mills source from both company-owned operations and third parties. However, the information reported is from 2021 and is over two years old now.

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

The company reports that of the total volumes (3,104,173 MT) sourced in 2021, 79.4% originated from its own plantations, including plasma smallholders. The remaining 20.6% were sourced directly from external suppliers, third-party plantations, and independent smallholders or indirectly through traders. However, the information reported is from 2021 and is over two years old now.

27. Number of third party supplying mills?

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

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

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

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

This indicator is disabled as the company does not own refineries.

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

33. Percentage of supply traceable to mill level?

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

The company has already achieved 100% traceability to the plantation level. However, this information is from 2020 and no updated information or target is reported as of 2024.

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

The company reports that 100% of the supply to own mills is traceable to the plantation level as of 2020. However, this information is over two years old now.

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

37. Publishes traceability data at refinery level?

This indicator is disabled as the company does not own refineries.

38. Publishes traceability data at crusher level?

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

40. RSPO-certified within three years of joining the RSPO or by November 2010, for companies joining prior to finalisation of the RSPO certification systems in November 2007?

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

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

43. Percentage of mills RSPO-certified?

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

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

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

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

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

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

50. Sells 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?

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

As of 2021, 34 estates and 13 mills of the company have achieved ISPO certification. However, the certificates are not publicly available.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

[Externally verified] The company reports that 7 mills and 1 crushing facility have ISCC EU/PLUS certification. Certificates of a few mills are publicly available on the ISCC database.

55. Commitment to zero conversion of natural ecosystems?

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

57. Commitment to zero deforestation?

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

58. Commitment to zero deforestation applies to all suppliers?

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

59. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

The company defines deforestation as the removal of HCV and HCS areas and specifies any deforestation/conversion past July 2018 will not be accepted.

60. Criteria and cut-off date for defining deforestation and/or ecosystem conversion in supplier operations?

The company defines deforestation for suppliers as the removal of HCV and HCS areas and specifies any deforestation past July 2018 will not be accepted in supplier operations.

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

The company reports monitoring its concession boundaries for non-compliant land clearing in partnership with Earthqualizer to screen its concessions for NDPE compliance. The system generates bi-weekly reports that allow the company to identify potential deforestation and peat clearance within company operations and recovery areas surrounding its operations. However, the information reported is from 2021 and is over two years old now.

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

The company reports that in 2019 and 2020, it partnered with a third-party expert to develop a risk assessment tool using spatial and non-spatial tools for all FFB suppliers. The Subsidiary Priority Scale Report (Skala Prioritisasi Anak Perusahaan (SPAP)) system helps detect environmental risks at company sites across its areas of operation, including deforestation biodiversity loss, peat conversion, and social risks at own operations and in the supply chain within a 50-kilometer radius of company operations. However, this only covers a limited area around company operations, and the time frame is also not reported.

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

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

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

The company commits to restore ecosystems to their prior condition in cases of conversion within its own operations.

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

The company commits suppliers to restore ecosystems to their prior condition in cases of conversion within their own operations.

67. Implementing a landscape or jurisdictional level approach?

The company reports its has been part of the Collaborative Research Center (CRC) 900: Ecological and Socioeconomic Functions of Tropical Lowland Rainforest Transformation System (EfforTS) Indonesia which conducts studies on the ecological and socioeconomic effects of sustainable plantation management for smallholders based on research carried out at Bukit Duabelas and Hutan Harapan in Jambi. The company also reports collaboration with PT Restorasi Ekosistem Indonesia (REKI) to manage degraded conservation areas surrounding its concessions. However, the information reported is from 2021 and is over two years old now.

68. Biodiversity policy?

69. Biodiversity policy applies to all suppliers?

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

The company has identified the species of conservation concern, referencing the IUCN Red List. However, the information reported is not externally verified.

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

The company reports working with the Natural Resource Conservation Agency (BKSDA) and its partners to protect the natural habitats of Borneo orangutans. However, the information reported is from 2021 and is over two years old now.

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

The company reports that hunting is prohibited, however, this information is reported in concern of the conservation areas of the company.

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

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

The company commits to conduct HCV assessments.

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

The company commits all suppliers to conduct HCV assessments.

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

The company states that since 2013, it has conducted HCV assessments at 15 concessions across West Kalimantan, Papua, and Sumatra, and in September 2018, it conducted additional HCVHCSA scoping studies at 12 concessions to reevaluate previous HCV assessments and identify other potential areas for conservation. However, no documents or summaries are publicly available.

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

The company states that since 2013, it has conducted HCV assessments at 15 concessions across West Kalimantan, Papua, and Sumatra, and in September 2018, it conducted additional HCVHCSA scoping studies at 12 concessions to reevaluate previous HCV assessments and identify other potential areas for conservation. However, no documents or summaries are publicly available.

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

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

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?

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

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

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

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

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

84. High Carbon Stock (HCS) assessments available?

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

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

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

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

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

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

90. Commitment to no planting on peat of any depth applies to all suppliers?

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

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

122643 - The company reports that as of December 2021, it has a total of 122,643 ha of peat land. However, the information reported is over two years old now.

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

The company reports it ceased all planting on peat at its operations in July 2018. However, the company does not directly report landbank on peat over time and the information reported is from 2021 and over two years old now.

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

The company only reports commitment to best management practices for peat.

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

The company only commits suppliers to best management practices for peat.

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

The company reports several examples of best management practices for peat, including maintaining the groundwater table at 40cm below surface level, based on the decision of KLHK, and keeping peat subsidence below 7cm a year, cumulatively less than 35cm every five years. However, no examples are reported for best management practices for soil.

96. Commitment to zero burning?

The company commits to no burning.

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

98. Evidence of fire monitoring and management?

The company reports various examples of fire monitoring and management which includes having a hotspot monitoring system that incorporates satellite imagery from three agencies (SIPONGI, NASA and LAPAN) to identify potential fires on a continuous basis. These monitoring activities extend to a two-kilometre radius beyond the company's concessions. The company also has an early warning system (EWS) and rapid response team as part of its prevention and preparedness strategy. However, all information reported is from 2021 and is over two years old now.

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

The company reports that in 2021, 12 hotspots were detected within and outside of the company concessions. However, the information reported is over two years old now.

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

12 - The company reports that in 2021, 12 hotspots were detected within and outside of the company concessions. However, it is unclear whether these hotspots occurred within smallholder estates or surrounding areas.

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

The company reports maintaining GHG emission intensity at its two ISCC-certified sites below 1 tonne of carbon dioxide equivalent per dry tonne of CPO processed (MT CO2e/MT CPO). However, the commitment does not cover all operations of the company or at least includes scope 1 and scope 2 emissions and is also not time-bound.

102. GHG emissions intensity?

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

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

105. Progress towards commitment to reduce GHG emissions intensity?

106. Methodology used to calculate GHG emissions?

The company reports that in 2022, it started tracking GHG emissions at all its sites using the ISCC methodology and will report GHG emissions in future reports.

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

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

The company reported an ongoing target of maintaining average water use intensity below 1.29 m3/MT FFB annually across all its sites, which was achieved in 2020 and 2021 where the average water use intensity was 1.24 m3/MT FFB However, no updated information is reported after 2021.

109. Water use intensity?

1.24 - The company reports its average water use intensity as 1.24 m3/MT FFB (cubic meters per metric tonne FFB) in 2021. However, the information reported is over two years old now.

110. Progress towards commitment on water use intensity?

The company reports its target of maintaining an average water use intensity below 1.29 m3/MT FFB annually across all its sites, which was achieved in 2020 and 2021 where the average water use intensity was 1.24 m3/MT FFB. However, this information is over two years old now and no updated information is reported after 2021.

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

The company reports a commitment to keep BOD levels below regulatory thresholds, however, the commitment reported is not time-bound.

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

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

The company reports that its facilities are equipped with anaerobic systems that treat all palm oil mill effluent (POME) before it is discharged to waterways or recycled for land application. However, the information reported is not externally verified.

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

This indicator is disabled as the company does not own refineries.

115. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways through buffer zones.

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

The company reports that it adheres to local regulations and maintains 50-meter riparian buffer zones for narrow rivers and 100-meter buffers for wide ones. As a part of its Recovery Plan at its three sites, the company identified and is restoring degraded and cleared areas, including buffer zones, riparian areas, peatlands, and forests cleared for roads and canals through replanting activities. As of 2021, the company has rehabilitated 671 ha of land. However, the information reported is from 2021 and is over two years old now.

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

The company commits to minimise the use of chemical pesticides only.

118. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers, applies to all suppliers?

The company commits suppliers to minimise the use of chemical pesticides only.

119. Commitment to no use of paraquat?

The company commits to not use paraquat.

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

The company commits all suppliers to stop the use of paraquat by 2020, however, it is unclear if this commitment has been met.

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

The company only reports that it is exploring ways to phase out and reduce the use of pesticides listed on the World Health Organization's Class 1A (extremely hazardous) and Class 1B (highly hazardous) pesticide lists. However, this reporting is not time-bound.

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

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

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

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

The company reports chemical usage per planted ha in 2021. However, the information reported is over two years old now.

126. Implementation of commitment to minimise inorganic fertiliser use?

The company reports chemical usage per planted ha for all its operations. However, the usage figures in 2021 show an increase in the use of chemicals as compared to previous years (2018-2020). The company also mentions using palm kernel shells (PKS), empty fruit bunches (EFB), and mesocarp fibre recovered as organic fertiliser.

127. Integrated Pest Management (IPM) approach?

The company reports it employs an integrated pest management (IPM) approach to reduce its reliance on chemicals. The company uses biological controls to manage pests at its plantations, including barn owls (Tyto alba) to control the rat population at estates and flowering plants (e.g., Turnera Antigonon and Cassia) to control nettle caterpillars. However, the information reported is from 2021 and is over two years old now.

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

The company reports waste at its operations is sorted into organic and inorganic waste. Organic waste is composted and reused as fertiliser and inorganic waste is collected and temporarily stored before it is sent to waste disposal sites. However, the information reported is from 2021 and is over two years old now.

129. Commitment to human rights?

The company reports a commitment to human rights, however, the commitment does not reference the UN Declaration of Human Rights or its equivalent.

130. Commitment to human rights applies to all suppliers?

131. Progress on human rights commitment?

132. Commitment to respect Indigenous Peoples' and local communities' rights?

The company commits to uphold the rights of local communities, particularly indigenous communities, however, the commitment does not reference the UN Declaration or ILO Convention.

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

The company commits suppliers to no exploitation of Indigenous people and other communities but does not reference the UN Declaration or ILO Convention.

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

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

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

The company commits to respect FPIC.

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

The company commits all suppliers to respect FPIC.

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

139. Examples of local stakeholder engagement to prevent conflicts?

The company mentions only one example of local stakeholder engagement activities that it has undertaken participatory mapping and land tenure studies in multiple locations.

140. Details of process for addressing land conflicts available?

The company reports that it has a process for dealing with land conflicts, but provides limited details about the nature of this procedure.

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

142. Commitment to mitigate impacts on food security?

The company only reports limited information on food security as a part of its corporate social responsibility (CSR) program.

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

144. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

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

The company reports several examples of providing essential community services and facilities which include housing, health care services, etc. However, the information reported is not externally verified.

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

The company reports supporting enhancing community livelihoods, which includes engagement in village-level programs in Kubu Raya in West Kalimantan to create income-generating opportunities for residents. However, a clear commitment is not reported.

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

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

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

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

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

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

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

153. Percentage or number of temporary employees?

154. Reports gender balance of employees?

7880 (27%) - The company reports the total number of female employees as 7880 in 2021. However, the information reported is over two years old now.

155. Commitment to pay a living wage?

The company only commits to paying the minimum wage.

156. Commitment to pay a living wage applies to all suppliers?

The company only commits suppliers to pay the minimum wage.

157. Progress on commitment to pay a living wage?

158. Reporting of salary by gender?

159. Commitment to address occupational health and safety?

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

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

161. Provision of personal protective equipment and related training?

The company reports the provision of personal protective equipment and related training. However, the information reported is from 2021 and is over two years old now.

162. Time lost due to work-based injuries?

The company only reports Lost time injuries and Total days lost due to injuries as 226 and 408, respectively in 2021. However, the information does not report the rate of injuries and is over two years old now.

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

0 - The company reports that there were zero work-based fatalities in 2021. However, the information reported is over two years old now.

164. Commitment to support smallholders?

The company has published a commitment to support smallholders.

165. Programme to support scheme smallholders?

The company reports it supports scheme smallholders through two initiatives; one is through two plasma schemes programs in Sumatra which were established before the 2007 regulations, and span a total of 11,988 ha. The second is through the Kredit Koperasi Primer Anggota (KKPA) scheme for cooperatives established after the regulation, where the company now operates 21 programs across Sumatra, Kalimantan, Merauke and Sulawesi totalling 25,178 ha. However, the information reported is from 2021 and is over two years old now.

166. Percentage of scheme smallholders involved in programme?

The company only reports the number of programs and areas planted under scheme smallholders. The information on the number or percentage of scheme smallholders supported by the company is not reported.

167. Programme to support independent smallholders?

The company reports having established a program called the Embrace Independent Farmers Program to support independent smallholders. However, the information reported is from 2021 and is over two years old now.

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

418 - As of December 2021, the company's program to support independent smallholders comprises 418 farmers who collectively manage 1,591 ha of land. However, the information reported is over two years old now.

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

The company reports that in 2019 and 2020, it partnered with a third-party expert to develop a risk assessment tool using spatial and non-spatial tools for all FFB suppliers. The Subsidiary Priority Scale Report (Skala Prioritisasi Anak Perusahaan (SPAP)) system helps detect environmental risks at company sites across its areas of operation, including deforestation, biodiversity loss, peat conversion, and social risks at company operations and in its supply chain within a 50-kilometer radius of its operations.

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

171. Suspension or exclusion criteria for suppliers?

The company reports that its purchase agreements meet and exceed all legal requirements and include its NDPE commitments, which are communicated to all suppliers in their contracts. Should suppliers breach these commitments, the company stops sourcing FFB from them until they comply with the terms of their contracts. However, the steps that would be taken or the timeframes for action are not reported.

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

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

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

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

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

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

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

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

180. Commitment to ethical conduct and prohibition of corruption?

The company only reports commitment to bribery and corruption.

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

The company only commits its suppliers to bribery and corruption.

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

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

184. Whistleblowing procedure?

The company reports having a whistleblowing hotline and commits to protecting the security of whistle-blowers, to ensure their anonymity when requested. However, the details of the process are not reported.

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

The company has a grievance system that is open to all stakeholders.

186. Details of complaints and grievances disclosed?

The company has published the details of complaints and grievances from 2020. However, this includes only four complaints for the year 2020-2021.