Louis Dreyfus Company

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

This indicator is disabled as the company is only a processor or trader.

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?

Head of Sustainability.

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

The CEO sits on the Environmental Committee as well as the Human Rights Observance Committee. However, data over two years old.

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

6. Percentage or number of women board members?

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

[Externally verified] UNGC, WBCSD, TFA.

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

The company is working with SNV to provide training on sustainable palm production to 1,000 smallholder farmers in South Sumatra.

9. Sustainability report published within last two years?

2021 sustainability report.

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?

The company reports it operates refineries in Indonesia and India, as well as commercial trading operations in Singapore.

14. Lists countries sourcing from?

The company reports that its India refinery sources are from Indonesia and Malaysia, but data is not reported for its other operations.

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

This indicator is disabled as the company is only a processor or trader.

16. Total oil palm planted area (ha)?

This indicator is disabled as the company is only a processor or trader.

17. Scheme smallholders planted area (ha)?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

20. Maps of estates/management units?

This indicator is disabled as the company is only a processor or trader.

21. Maps of scheme smallholders?

This indicator is disabled as the company is only a processor or trader.

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

23. Number of company-owned mills?

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

24. Names and locations of company-owned mills?

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

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

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

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

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

27. Number of third party supplying mills?

55 - The company has published a list of its supplying mills as of H2 2021. However, mills supplying its India refinery are not provided.

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

The company has published a list including coordinates of its supplying mills as of H2 2021. However, mills supplying its India refinery are not provided.

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?

The company reports that 3% of volumes come from trading companies rather than mills for its Lampung and Balikpapan refineries in Indonesia. For its refinery in India its CPO is imported through trading partners.

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

The company commits to achieve 100% traceability to mill for direct and indirect sourcing by 2022.

33. Percentage of supply traceable to mill level?

The company states it has achieved 97% traceability to mill level, in 2021. However, data was not externally verified, hence no additional points were awarded.

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

The company has a target to achieve 100% traceability to 1st tier FFB for direct sourcing to refineries, but only 70% traceability to plantation for traded oil by 2022.

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

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

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

The company states that it has reached 90% traceability to plantation level for directly-sourced volumes, and 72% traceability to plantation for global volumes.

37. Publishes traceability data at refinery level?

The company reports traceability to plantation data for its two Indonesian refineries, but for its India refinery traceability data is only reported to mill level.

38. Publishes traceability data at crusher level?

This indicator is disabled as the company does not own palm kernel crushing facilities.

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

[Externally verified] 2017 - One of the company's subsidiaries joined the RSPO in 2012 and achieved certification in 2014, but this has since been included under the parent company which became an RSPO member in 2017.

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] 2014 - One of the company's subsidiaries joined the RSPO in 2012 and achieved certification in 2014, but this has since been included under the parent company which became an RSPO member in 2017.

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

2021 RSPO ACOP is submitted by the company.

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

This indicator is disabled as the company is only a processor or trader.

43. Percentage of mills RSPO-certified?

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

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

This indicator is disabled as the company is only a processor or trader.

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

2014 - The company has already achieved 100% RSPO-certification of all palm product processing facilities.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

[Externally verified] 7.1% - The company reports the percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that is RSPO-certified in its ACOP 2021.

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

This indicator is disabled as the company only reports a Processor and Trader ACOP.

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

The company reports that 0% of RSPO-certified palm oil is traded through Segregated and Identity Preserved supply chains in its ACOP 2021.

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

This indicator is disabled as the company is only a processor or trader.

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] ISCC.

55. Commitment to zero conversion of natural ecosystems?

This indicator is disabled as the company is only a processor or trader.

56. Commitment to zero deforestation?

This indicator is disabled as the company is only a processor or trader.

57. 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.

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

This indicator is disabled as the company is only a processor or trader.

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

The company defines no deforestation in HCV and HCS areas however it does not specify a cut-off date.

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

This indicator is disabled as the company is only a processor or trader.

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

The company states that monitoring for deforestation is carried out primarily through satellite tools. It currently works with Earth Equalizer / Aid Environment, Satelligence, and Global Forest Watch Pro. The company also reports that in 2020 it commissioned two satellite monitoring service providers to monitor sourcing for its refineries and trading book. The company reports to "receive bi-weekly monitoring reports from the providers". However, data is not externally verified.

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

This indicator is disabled as the company is only a processor or trader.

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

64. Commitment to restoration of deforestation/conversion?

This indicator is disabled as the company is only a processor or trader.

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

The company commits suppliers to restore ecosystems to their prior condition in cases of conversion within their own operations with a cut-off date of November 2016.

66. Implementing a landscape or jurisdictional level approach?

67. Biodiversity policy?

This indicator is disabled as the company is only a processor or trader.

68. Biodiversity policy applies to all suppliers?

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to only allow sustainable hunting of species by local communities for subsistence purposes in their operations.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to conduct HCV assessments.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to only use licensed HCV assessors accredited by the HCV Resource Network's ALS.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

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

83. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company only commits to carrying out environmental and social impact assessments before commencing any project "ecologically and socially sensitive regions", this does not clearly apply to all new development.

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

The company only commits suppliers to carrying out environmental and social impact assessments before commencing any project "ecologically and socially sensitive regions", this does not clearly apply to all new development.

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

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits its suppliers to "leave all peat untouched, regardless of depth".

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits its suppliers to follow best management practices for peat, and good agricultural practices for soils.

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

This indicator is disabled as the company is only a processor or trader.

95. Commitment to zero burning?

This indicator is disabled as the company is only a processor or trader.

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

97. Evidence of fire monitoring and management?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits to reduce CO2 emissions 1% year on year from 2018-2022. However, this target is not based on GHG intensity, rather on overall emissions. New, science-based targets for its GHG emissions will be set in 2023.

101. GHG emissions intensity?

The company states that the global GHG emissions of its operations were 0.034 (tCO,/MT) in 2021.

102. GHG emissions from land use change?

This indicator is disabled as the company is only a processor or trader.

103. Progress towards commitment to reduce GHG emissions intensity?

The company states that the global GHG emissions of its operations were 0.043 (2018), 0.042 (2019), 0.034 (2020), and 0.034 (2021). However, information is not externally verified and not specific to palm oil operations.

104. Methodology used to calculate GHG emissions?

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

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

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

The company has a target to reduce water usage by 5% between 2018 to 2022. However, the target is not based on intensity and it includes palm operations only as part of an aggregate figure.

107. Water use intensity?

0.52 - The company reports a water use figure of 0.52 m3/MT. However, it covers palm operations as part of an aggregate figure only.

108. Progress towards commitment on water use intensity?

The company reports improving water use of 0.55 (2018), 0.49 (2019), 0.49 (2020), 0.52 (2021) (m3/MT) respectively. However, it covers palm operations as part of an aggregate figure only.

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

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

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

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

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

113. Commitment to protect natural waterways through buffer zones?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits suppliers to reduce the use of pesticides only.

117. Commitment to no use of paraquat?

This indicator is disabled as the company is only a processor or trader.

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?

This indicator is disabled as the company is only a processor or trader.

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?

This indicator is disabled as the company is only a processor or trader.

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?

This indicator is disabled as the company is only a processor or trader.

124. Implementation of commitment to minimise inorganic fertiliser use?

This indicator is disabled as the company is only a processor or trader.

125. Integrated Pest Management (IPM) approach?

This indicator is disabled as the company is only a processor or trader.

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

127. Commitment to human rights?

The company commits to the UN Guiding Principles on Business and Human rights.

128. Commitment to human rights applies to all suppliers?

The company commits suppliers to the UN Guiding Principles on Business and Human rights.

129. Progress on human rights commitment?

The company reports having a human rights committee in place. It also reports that in 2020, it began working with several stakeholders, including local governments, NGOs, and other palm oil companies in East Kalimantan, Indonesia, to draft guidelines for palm oil companies on Fair Employment of Casual and Temporary Workers and Mitigating the Risk of Child Labor in Palm Oil Plantations. The company also reports working with a service provider to develop a human rights assessment for NDPE implementation field verifications and has a target to take individual membership of the ILO's Child Labour Platform by 2022. However, the information is not externally verified.

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

This indicator is disabled as the company is only a refiner or trader.

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

The company commits its suppliers to uphold the rights of local communities and indigenous people, however, the commitment does not refer to the UN Declaration/ILO.

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

This indicator is disabled as the company is only a processor or trader.

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)?

This indicator is disabled as the company is only a refiner or trader.

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?

This indicator is disabled as the company is only a refiner or trader.

137. Examples of local stakeholder engagement to prevent conflicts?

This indicator is disabled as the company is only a refiner or trader.

138. Details of process for addressing land conflicts available?

This indicator is disabled as the company is only a refiner or trader.

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

This indicator is disabled as the company is only a processor or trader.

140. Commitment to mitigate impacts on food security?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

142. Commitment to provide essential community services and facilities?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is not a grower or miller.

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

The company commits to all Fundamental ILO Conventions.

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

The company commits all suppliers to all Fundamental ILO Conventions.

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

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

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

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

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

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

The company reports to have added Diversity and Inclusion (D&I) modules to leadership training programs delivered in 2020. It also reports that to create a global inclusive recruitment standard for the company, it is adopting a competency-based selection approach that supports a more consistent applicant experience. Its HR community has been trained in this new approach and is preparing for global implementation in 2021. However, the information is not externally verified.

151. Percentage or number of temporary employees?

2654 - The company reports seasonal workers in 2021 as 2,654 across all operations including palm oil operations.

152. Percentage or number of women employees?

27% - The company reports that 27% of its employees globally are female as of 2021.

153. Commitment to pay a Decent Living wage?

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

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

156. Reporting of salary by gender?

157. Commitment to address occupational health and safety?

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

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

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

159. Provision of personal protective equipment and related training?

The company states it provides personal protective equipment (PPE) and related training. However, the information is undated.

160. Time lost due to work-based injuries?

0.19 - The company reports a gravity index of 0.19 for 2021 which shows the number of workplace injuries serious enough to result in time away from work, in relation to hours worked.

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

0 - The company reports zero work-related fatalities recorded across the company in 2021.

162. Commitment to support smallholders?

The company has published a commitment to support smallholders.

163. Programme to support scheme smallholders?

The company reports that Côte d'Ivoire in collaboration with the Louis Dreyfus Foundation has launched a new project in South Comoé, to train smallholder oil palm producers on sustainable farming practices, regenerative agriculture, agricultural diversification, and business entrepreneurship, with a particular focus on younger generations and female farmers. The company also reports to have trained 2030 smallholders on good agricultural practices, however the type of smallholders is unclear.

164. Percentage of scheme smallholders involved in programme?

700 - The company reports a three-year project expected to establish a rural farm business incubator that serves as a center of knowledge exchange, learning, and best practice testing. It aims to train 400 young adults (minimum 30% women) and have 300 farmers apply regenerative practices and cultivation improvements at the farm level. The company also reports to have trained 2030 smallholders on good agricultural practices, however the type of smallholders is unclear.

165. Programme to support independent smallholders?

The company reports that in 2019, it started a project with Dutch non-profit organization SNV and the Louis Dreyfus Foundation in South Sumatra, Indonesia, to include smallholder farmers in sustainable supply chains. In 2020, the project managed to train over 1,000 independent smallholders. The company also reports to have trained 2030 smallholders on good agricultural practices, however the type of smallholders is unclear. The information is not externally verified.

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

1000 - The company states that in 2020, the project managed to train over 1,000 independent smallholders. However, the information is not externally verified.

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

The company states it conducts field visits, screens all new suppliers, and carries out risk assessments, workshops and training.

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

The company reports that in 2020, 40% of mills supplying its refineries participated in engagement workshops on how to use its self-declaration tool to show compliance with its policy. The company also reports that in 2021 80% of suppliers had completed an NDPE self-assessment.

169. Suspension or exclusion criteria for suppliers?

The company states that it has a grievance process to investigate policy breaches and that "We try to work with the supplier to change their approach, but where efforts fail the ultimate sanction is to remove them from our approved supplier list and stop trading all commodities with them, resuming only when the supplier proves they are addressing the issues. " However, no clear criteria, steps taken, or timeframes are reported.

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

The company has a number of 'palm sustainability objectives' with a target for 2022 stating '100% of direct & indirect sourcing volumes has a commitment to NDPE / agreement to LDC sustainability policy/certified volume'.

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

The company reports that in 2020, approximately 90% of the palm it sources is covered by contractual supplier commitments to NDPE. However, separate figures are not provided for direct and indirect supply.

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

The company commits to engage with all high risk mills by the year 2024. This is within 3 years.

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

The company states in 2020 "Where possible, we engaged higher-risk supplier groups to ensure understanding of our grievance protocol and process." and that it "carried out a three-day training course on Best Management Practice on Peat and Fire Prevention System, in cooperation with Earthworm Foundation and the Indonesian Ministry of Environment and Forestry, attended by almost 90% of our Lampung mill suppliers.".

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

The company reports annually on engaging with mills, this includes high-risk mills. in 2021 the company engaged with 25% of high risk mills. However, the information is not externally verified.

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

The company reports it assesses mill risk based on supplier NDPE Policy, Self Assessment Questionnaire result and certification profile, Traceability to Plantation Profile Assessment, and Grievances raised.

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

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

The company reports risk levels as low, medium, and high for all direct and indirect third-party suppliers. However, the information is not externally verified.

178. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and the prohibition of corruption.

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

The company commits all suppliers to ethical conduct and the prohibition of corruption.

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

The company reports running a compliance and ethics program which covers areas of Regulatory Compliance, Trade Compliance, and Compliance Monitoring. However, the information is not externally verified.

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

The company has disclosed its tax strategy, however, it only covers the UK subsidiaries of the company.

182. Whistleblowing procedure?

The Code of Conduct includes information on how to report non-compliant conduct, however no details are given on the steps taken. The company's grievance secure servers, EthicsPoint also has an FAQs document which explains how whistleblowers are protected.

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

The company has a palm grievance protocol, open to all stakeholders.

184. Details of complaints and grievances disclosed?

The company has provided a grievance list which contains a details of complaints.