Nisshin OilliO

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?

The company has a Management Sustainability Committee. However, it is unclear which high-level position has responsibility for sustainability.

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

The company has a 'Management Sustainability Committee', headed by the CEO who has ultimate responsibility for sustainability.

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

9.5% - The company reports the percentage of women in the senior management team as 9.5% in 2021.

6. Percentage or number of women board members?

2 (22.22%) - The company reports that it has 2 (22.22%) women board members 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] UNGC.

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

The company reports its partnership with Global Environment Centre (GEC) and Sahabat Hutan Bakau Kampung Dato' Hormat (SHBKDH) to plant mangrove trees in Sabak Bernam, Selangor. The company's subsidiary reports collaborating with one of its suppliers Hap Seng plantations on a smallholder project, as well as with another one of its suppliers, Johor Plantations Bhd to implement a Labour Transformation Programme (LTP) to support improving labour practices of selected plantation units.

9. Sustainability report published within last two years?

The company has published its Integrated Report 2022.

10. Reports through standardised reporting systems?

The company has submitted all three CDP questionnaires for 2022.

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 has published a climate-risk assessment, in line with TCFD guidelines.

13. Lists countries and operations?

The company provides a list of countries it operates in and the nature of these operations.

14. Lists countries sourcing from?

The company's main subsidiary, ISF, sources from Malaysia and Thailand. Sourcing data is not available for the company's entire 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 all scheme smallholders?

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

22. Maps 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?

1527 - The company has published a CPO supplier mill list.

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

The company has provided the names, addresses and coordinates 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?

The company's subsidiary ISF sources from 38 suppliers, 20 of which source FFB from their own plantations, and 18 from both their own and external plantations. Partial points have been awarded as it is not clear whether this covers all suppliers.

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's subsidiary ISF sources 61% of CPO volume from third-party supplying mills own plantations and 39% from external plantations. Partial points have been awarded as it is not clear whether this covers all suppliers.

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 its subsidiary, ISF, sources 82% of its supply directly from mills and 18% of supply from kernel crushing plants. It states that it does not source from traders. Partial points have been awarded as it is not clear whether this covers all suppliers.

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

The company's subsidiary, ISF, has achieved 100% traceability to mill level.

33. Percentage of supply traceable to mill level?

The company reports that 99% of the supply is traceable to the mill level. An additional point has been awarded as the company has RSPO SSC under SG supply chain certifications.

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

The company commits to achieve 100% traceability to plantation level for palm oil by the year 2024 and for palm kernel oil by 2030.

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 reports that 68.5% of its palm oil supply is traceable to the plantation level and 30.5% of its palm kernel oil supply is traceable to the plantation level.

37. Publishes traceability data at refinery 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] 2004 - The company has been a member of RSPO since 2004.

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?

2011 - The company was not certified within three years after joining or by November 2010.

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

The company has submitted its latest RSPO ACOP 2022.

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?

2030 - The company commits to achieve 100% RSPO certification of all palm product processing facilities by 2030. This is beyond 5 years.

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?

46.63% - The company reports 46.63% 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?

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

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

The company sells 44.29% RSPO-certified palm oil through segregated or identity-preserved supply chains.

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?

[Externally verified] The company's subsidiary has two Malaysian refineries which are MSPO SCCS certified. However, it is unclear whether these refineries represent all palm oil operations in Malaysia.

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

[Externally verified] The company's subsidiary is certified under 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 conversion of natural ecosystems applies to all suppliers?

57. Commitment to zero deforestation?

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

58. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to no deforestation and no development in High Conservation Value (HCV), High Carbon Stock (HCS) and peatland areas. This commitment has been in place since 2018.

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

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

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

The company commits all suppliers to no development in High Conservation Value (HCV), High Carbon Stock (HCS), and peatland areas. However, no cut-off date is specified.

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

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

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

63. 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.

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

The company records instances of deforestation in its grievance logs but a total figure for non-compliant deforestation in supplier operations is not reported and it is unclear if logs cover all supplying operations.

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

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

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

The company's subsidiary commits suppliers' to restore deforestation from a cut-off date of 31st December 2015 to re-renter back into the supply chain.

67. Implementing a landscape or jurisdictional level approach?

The company's subsidiary ISF, has taken part in a multi-stakeholder initiative to improve local labour practices.

68. Biodiversity policy?

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

69. Biodiversity policy applies to all suppliers?

70. 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.

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

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

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

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

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

The company's subsidiary commitment to no hunting of all species applies to its suppliers. However, the commitment does not apply to all other groups' supplies.

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

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

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

The company's subsidiary, ISF, commits its suppliers to conduct HCV assessments.

76. 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.

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

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

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

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)?

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

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?

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

81. 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.

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

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

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

The company's subsidiary, ISF, commits all suppliers to apply the HCS Approach.

84. High Carbon Stock (HCS) assessments available?

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

85. 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.

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

The company's subsidiary commits to conduct social and environmental impact assessments. However, this commitment does not cover all operations.

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?

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

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)?

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

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

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

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

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

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

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

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

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

96. Commitment to zero burning?

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

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

98. Evidence of fire monitoring and management?

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

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

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

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

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

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

The company commits to reduce GHG emissions by 31% by the year 2030. However, the figure is not reported as intensity.

102. GHG emissions intensity?

The company reports its GHG emissions intensity as 0.119 (t-CO2/t) processed oil in 2021.

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

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

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

The company's subsidiary, ISF, reports its overall emissions from LUC in supplier operations as 718,846.27 MT CO2e. This does not cover the company's entire operations.

105. Progress towards commitment to reduce GHG emissions intensity?

The company reports a reduction in its GHG emission intensity from 0.128 (t-CO2/t) processed oil in 2020 to 0.119 (t-CO2/t) processed oil in 2021.

106. Methodology used to calculate GHG emissions?

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

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

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

The company commits to reduce its water use per unit of production by 16% (from FY2016) by 2030, but the target was not reported as intensity. The company's subsidiary, ISF, has a commitment to reduce its water consumption intensity by 10% against the 2019 baseline.

109. Water use intensity?

1.06 - The company reports its water use intensity as 1.06 m3/t in 2021.

110. Progress towards commitment on water use intensity?

The company reports that in 2021 the water use intensity decreased to 1.06 m3 /t as compared to the intensity of 1.12 m3 /t in 2020, and 1.13 m3 /t in 2019.

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

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

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

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

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

The company's subsidiary, ISF, states that it has wastewater treatment systems in place to treat effluents.

115. Commitment to protect natural waterways through buffer zones?

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

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

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

117. 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.

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

119. Commitment to no use of paraquat?

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

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

The company's subsidiary commits to no use of paraquat which applies to all its suppliers. However, the commitment does not apply to all other groups' suppliers.

121. 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.

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

The company's subsidiary commits to no use of World Health Organisation (WHO) Class 1A and 1B pesticides which apply to its suppliers. However, the commitment does not apply to all other groups' supplies.

123. 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.

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

The company's subsidiary commitment to no use of chemicals listed under the Stockholm Convention and the Rotterdam Convention applies to its suppliers. However, the commitment does not apply to all other groups' supplies.

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

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

126. Implementation of commitment to minimise inorganic fertiliser use?

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

127. Integrated Pest Management (IPM) approach?

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

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

The company's subsidiary reports that it has a waste management system in place to manage scheduled and non-scheduled waste. All waste classified as hazardous or scheduled waste requires special storage, packaging and labelling, and then the containers are managed and disposed of at a licensed waste recovery facility. However, this does not cover all company's operations.

129. Commitment to human rights?

The company commits to human rights principles as a member of the UN Global Compact.

130. Commitment to human rights applies to all suppliers?

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

131. Progress on human rights commitment?

The company reports that in 2021, it hold an online lecture on the theme of 'Business and Human Rights' where it discussed the background of the growing importance of respect for human rights in supply chains, policies and rules to protect human rights. The company also states that it will implement human rights due diligence to identify any negative impact of its business on human rights.

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

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

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

The company's commitment to indigenous and local communities' rights applies to all of its suppliers. However, it does not refer to the UN Declaration/ILO conventions.

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

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

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

The company commits all suppliers to respect legal and customary land rights in relation to FPIC only.

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

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

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?

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

139. Examples of local stakeholder engagement to prevent conflicts?

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

140. Details of process for addressing land conflicts available?

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

141. 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.

142. Commitment to mitigate impacts on food security?

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

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

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

144. Commitment to provide essential community services and facilities?

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

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

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

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

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

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

The company commits to the ILO's Declaration on Fundamental Principles and Rights at Work.

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

The company states that it will make efforts so that suppliers also understand this policy. This does not constitute a clear commitment.

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

The company's subsidiary, ISF, has collaborated with Sedex to improve labour conditions and ensure that workers rights are upheld and communicated.

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?

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

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

The company reports that it has established a Women's Advancement Promotion Action Plan, with various targets to encourage women in the workplace. The company is also working on gender balance by increasing the number of female employees at managerial levels.

153. Percentage or number of temporary employees?

150 (11.99%) - The company reports that 150 employees out of 1251 were temporary employees.

154. Percentage or number of women employees?

714 (23.9%) - The company reports that it has 714 (23.90%) women employees in 2021. However, data only includes permanent employees.

155. Commitment to pay a Living Wage?

The company's subsidiary commits to paying a minimum wage to all workers. However, it does not cover all operations.

156. Commitment to pay a Living Wage applies to all suppliers?

The company's subsidiary commitment to pay a minimum wage applies to its suppliers. However, the commitment does not apply to all other groups' supplies.

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?

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

161. Provision of personal protective equipment and related training?

The company reports the number of participants enrolled in safety training for its factories but does not specify the type of training or equipment supplied.

162. Time lost due to work-based injuries?

7.04 - The company's subsidiary reports a lost time accident rate (LTAR) of 7.04 for 2021. Calculated as number of accidents x 1,000,000/total working hours. However, it does not cover all palm oil operations.

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

0 - The company's subsidiary reported zero fatalities in 2021. However, it does not cover all palm oil operations.

164. Commitment to support smallholders?

The company commits to support smallholders. However, it is unclear if it covers all types of smallholders.

165. Programme to support scheme smallholders?

166. Percentage of scheme smallholders involved in programme?

167. Programme to support independent smallholders?

The company's subsidiary ISF has a programme to help independent smallholders obtain certification.

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

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

The company's subsidiary, ISF, describes processes used to assess and engage suppliers' on compliance.

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

33 - One of the company's subsidiaries reports that it engaged with 33 suppliers against food safety criteria and confirmed that 29 suppliers use food-grade lubricants in the processes. However, it does not cover the whole scope of operation.

171. Suspension or exclusion criteria for suppliers?

The company reports that when a complaint is raised against a supplier then it engages with the named supplier to discuss the issues raised in accordance with the objective of resolving the issue. If the supplier does not engage effectively in the process towards resolution and compliance with the policy, the company will review its relationship with that supplier and may cease the relationship as a last resort.

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)?

The company's subsidiary reports that 61.2% of its FFB supply from supplying mills is verified as deforestation- and/or conversion-free (DCF). However, data does not cover all operations and it is based on self-assessment by suppliers only.

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?

The company implements risk assessments based on the supplier mill list. However, no further details on the procedure could be found.

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 commits to ethical conduct and the prohibition of corruption.

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

The company commits all suppliers only to prohibit corruption.

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

The company reports that it regularly monitors the risk of anti-corruption. Further, the company states that every October month is designated as 'Corporate Ethics Month' in which lectures are provided on corporate ethics-related themes. In addition to this, the company has also established a 'Corporate Ethics Hotline' which enables employees to directly provide management with important information regarding corporate ethics violations or legal violations.

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

184. Whistleblowing procedure?

The company states that it protects the privacy of whistleblowers and responds with strict actions on a corporate level against any unfavourable treatment or retribution against them. However, no flowchart or clear description is available. One of the company's subsidiaries has a clear whistleblowing policy.

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

The company has its own grievance or complaints system which is open to all stakeholders.

186. Details of complaints and grievances disclosed?

[Externally verified] The company has disclosed details of complaints and grievances in comprehensive detail.