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Palm oil assessments

Founded in 1986, UK based producer Noble manages global supply chains across a range of

  • Landbank (oil palm):
    70,705 hectares
  • Market cap:
    78,561,020 USD
  • Thomson Reuters ticker:
    NOBG.SI
  • Bloomberg ticker:
    NOBL SP
  • ISIN:
    BMG6542T1190
  • RSPO member?
    Yes
  • Website:

Company assessment: Noble Group Ltd – November 2018

SPOTT assesses companies against over 100 indicators across ten categories. Click on the icons or bars below to expand each category for further details, scoring and links to reports and sources.

Assessment date:

Total: 82.1% 87 / 106
  • Sustainability policy and leadership Sustainability policy and leadership 4.5 / 6 75%
    • Companies should publish sustainability policies or similar covering their entire supply chain — including third party suppliers — implemented and enforced through high-level leadership that engages with wider industry schemes.

    • Yes
      1 / 1
      Source

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

      The company details its commitments in its October 2017 Sustainability Information Document

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

      3. High-level position of responsibility for sustainability?

      The company states that sustainability is the responsibility of the General Manager and Manager for Compliance and Sustainability

    • Yes
      1 / 1
      Source

      4. Sustainability report published within last two years?

    • Partial
      0.5 / 1
      Source

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

      Signatory of UNGC and is a corporate member of WWF in Hong Kong, but not member of initiatives relating specifically to palm oil

    • n/a
      -
      No source

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

      This indicator has been disabled as the company is not a POIG member

    • No
      0 / 1
      No source

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

  • Landbank, maps and traceability Landbank, maps and traceability 13 / 13 100%
    • Companies should publicly report figures on their total landbank and details of different areas under their management. They should also disclose maps of their management areas and provide details on traceability of their products, both to mill and plantation level.

    • Yes
      1 / 1
      Source

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

      70,705

    • Yes
      1 / 1
      Source

      9. Total oil palm planted area (ha)?

      17,059.1 -

    • Yes
      1 / 1
      Source

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

      2,236

    • Yes
      1 / 1
      Source

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

      28,541.5

    • Yes
      1 / 1
      Source

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

      14,307.9 - Sum of HCV areas and other conservation areas

    • Yes
      1 / 1
      Source

      13. Area for infrastructure (ha)?

      1,384.5

    • Yes
      1 / 1
      Source

      14. Number and names of company owned mills?

      1

    • Yes
      1 / 1
      Source

      15. Maps or coordinates of company owned mills?

      Provide coordinates for only mill

    • n/a
      -
      No source

      16. Number and names of supplier mills?

      This indicator has been disabled as it is only relevant for processors/traders

    • Yes
      1 / 1
      Source

      17. Maps of estates/management units?

    • Yes
      1 / 1
      Source

      18. Maps of scheme/plasma smallholders?

      Scheme smallholder boundaries have been made available to the RSPO as part of its estate maps according to the company, but not all may be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO

    • n/a
      -
      No source

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

      This indicator has been disabled as it is only relevant for processors/traders

    • Yes
      1 / 1
      Source

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

      2,020

    • n/a
      -
      No source

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

      This indicator has been disabled as it is only relevant for processors/traders

    • Yes
      2 / 2
      Source

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

      100% - The company states that its only operational mill uses the Identity Preserved (IP) supply chain model. The mill uses fresh fruit bunches (FFBs) only from plantations that are owned by the company and will be certified by RSPO. All of (100%) FFBs are traceable to plantation level for all operations, including smallholdings which are managed as an integral part of the group operations

    • n/a
      -
      No source

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

      This indicator has been disabled as it is only relevant for processors/traders

  • Deforestation and biodiversity Deforestation and biodiversity 9 / 10 90%
    • Companies should commit to address deforestation and to set aside areas for conservation. They should report on any activities to manage or restore habitat in their conservation areas, or monitor deforestation in their supply chains. They should also provide evidence of species conservation and biodiversity protection.

    • Yes
      1 / 1
      Source

      24. Commitment to zero deforestation?

    • Yes
      1 / 1
      Source

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

      The commitment applies to its scheme smallholders. The company does not have independent suppliers

    • Yes
      1 / 1
      Source

      26. Criteria for defining deforestation?

      Primary forest, HCV, HCS, peat

    • Partial
      0.5 / 1
      Source

      27. Evidence of monitoring deforestation?

      The company states that it has a "Conservation Department responsible for establishing and monitoring conservation areas inside and outside of estate boundaries, to detect encroachment or disturbance by local people or by workers. The department is also responsible for informing local people that they are not allowed to grow crops, clear vegetation, erect buildings, hunt, or disturb conservation areas." "The GIS Department uses remote sensing high resolution images and drones to help monitor oil palm and conservation activities, and to produce maps." However, the extent of area being monitored and/or time-frame is unclear

    • Yes
      1 / 1
      Source

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

      The company manages 14,000 hectares of conservation areas where it conducts regular flora and fauna inventory counts; replanting in HCV areas; installing boundary markers and informative signs for conservation areas

    • Partial
      0.5 / 1
      Source

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

      Limited details available about scale of landscape approach, particularly beyond the company's own operations

    • Yes
      1 / 1
      Source

      30. Commitment to biodiversity conservation?

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

      Company states "No hunting or only sustainable hunting of species"

    • Yes
      1 / 1
      Source

      33. Examples of species conservation activities?

  • HCV, HCS and impact assessments HCV, HCS and impact assessments 7.5 / 8 93.8%
    • Companies should commit to the High Conservation Value (HCV) and High Carbon Stock (HCS) approaches, and to conduct social and environmental impact assessments (SEIA). They should develop and publish monitoring and management plans, and provide evidence through SEIA, HCV and HCS assessments, typically published in summary form due to the sensitive nature of certain sites.

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

      The following HCV assessments are publicly available: PT Pusaka Agro Lestari and PT Henrison Inti Persada

    • n/a
      -
      Source

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

      This indicator is disabled as the company has conducted HCV assessment for the whole of its concession area in 2010 and 2011

    • n/a
      -
      Source

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

      This indicator is disabled as the company has conducted HCV assessment for the whole of its concession area in 2010 and 2011

    • n/a
      -
      Source

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

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

    • Yes
      1 / 1
      Source

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

    • Partial
      0.5 / 1
      Source

      42. High Carbon Stock (HCS) assessments?

      The company states that "An independent carbon stock study, using a methodology approved by the RSPO (Carbon Assessment Tool for New Oil Palm Plantings?RSPO, December 2012), has been carried out" but the documents are not publicly available

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

      The following SEIA assessments are publicly available:
      PT Pusaka Agro Lestari; PT Henrison Inti Persada

  • Peat, fire and GHG emissions Peat, fire and GHG emissions 12.5 / 15 83.3%
    • Companies should commit to protect peatland and undertake best management practices for soils and peat. They should also have policies on zero burning and to reduce their greenhouse gas (GHG) emissions. Companies should report their GHG emissions, as well as any fires that occurred in or around their estates, along with plans for managing and monitoring fires.

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

      The commitment applies to all scheme smallholders (the company does not have independent FFB suppliers)

    • Yes
      1 / 1
      Source

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

      The company does not have operations on peat soil

    • Yes
      1 / 1
      Source

      48. Landbank or planted area on peat?

      0

    • Yes
      1 / 1
      Source

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

      The company refers to letter from the Government stating that there is no indication of peat soil and primary forest in the oil palm plantation area

    • Yes
      1 / 1
      Source

      50. Commitment to zero burning?

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

      52. Evidence of management and monitoring fires?

      The company states that it uses "an early warning system to detect the occurrence of fire (land, building and mill)." It describes training procedures, equipment and routine fire patrols with the community and Conservation Department

    • Yes
      1 / 1
      Source

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

    • No
      0 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

      The company has the following target for all of its operations: "10% reduction of CO2 emissions per product traded (MtCO2e /Mt) between 2013 (base year) and 2018 (target year)"

    • Yes
      1 / 1
      Source

      56. GHG emissions from land use change?

      201,738

    • Yes
      1 / 1
      Source

      57. Methodology used to calculate GHG emissions?

      RSPO PalmGHG Calculator version 3.0.1 and GHG Protocol

    • Partial
      0.5 / 1
      Source

      58. Progress towards commitment to reduce GHG emissions intensity?

      The company reports intensity figures, but these are not improving

    • No
      0 / 1
      No source

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

  • Water, chemical and pest management Water, chemical and pest management 12 / 12 100%
    • Companies should commit to managing water use and water quality, providing evidence through time-bound reduction plans, policies on toxic chemical use and treatment of palm oil mill effluent (POME).

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

      62. Progress towards commitment on water use?

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

      64. Protection of natural waterways through buffer zones?

    • Yes
      1 / 1
      Source

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

      The company states "Palm Oil Mill Effluent (POME) is treated in aerobic and anaerobic ponds, to ensure that Biological Oxygen Demand (BOD) levels are safe before being discharged to the water body. The quality of river water is monitored by taking samples for analysis each month, from both downstream and upstream of the discharge point. The quality of palm oil mill effluent is monitored by taking samples from a trap pit each month. The Company monitors the quality of effluent waste in every pond."

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

      67. No use of paraquat?

    • Yes
      1 / 1
      Source

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

      The company commits to not use World Health Organisation (WHO) Class 1A and 1B pesticide by 2018 and says it has stopped use

    • Yes
      1 / 1
      Source

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

      The company commits to not use Stockholm Convention and Rotterdam Convention chemicals by 2018 and says it has stopped use

    • Yes
      1 / 1
      Source

      70. Integrated Pest Management (IPM) approach?

    • Yes
      1 / 1
      Source

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

      The company provides a list of pesticides and fertilisers it used between January and June 2017

  • Community, land and labour rights Community, land and labour rights 18 / 18.5 97.3%
    • Companies should commit to respect human rights, including those of indigenous peoples and local communities, consulted with free, prior and informed consent (FPIC). Companies should respect the rights of workers, report relevant workforce data, and comply with health and safety legislation.

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

    • n/a
      -
      No source

      77. FPIC commitment applies to independent suppliers?

      This indicator is disabled as the company has no independent suppliers

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

      79. Details of process for addressing land conflicts available?

      The company provides a Resolution of Social Conflicts and Land Disputes SOP in its 2015 ACOP

    • Partial
      0.5 / 1
      Source

      80. Commitment to mitigate impacts on food security?

      The company states that it "endeavours to contribute...to promote the fulfilment of human rights through improving economic (including to ensure food security for local communities), environmental and social conditions" but offers no details on how it operationalizes this commitment in respect to local communities

    • Yes
      1 / 1
      Source

      81. Commitment to provide essential community services and facilities?

      Provides heavy equipment and materials for road maintenance in Indonesia near palm oil operations; globally has invested over $636,000 in community projects, including in Jamaica and Indonesia

    • Yes
      1 / 1
      Source

      82. Commitment to respect all workers' rights?

      The company respects rights of all employees though does not specify if includes both permanent and temporary employees

    • Yes
      1 / 1
      Source

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

      Company says it is "moving towards application of the Fundamental ILO Conventions or Free and Fair Labour Principles through engagement and collaboration where necessary."

    • Yes
      0.5 / 0.5
      Source

      84. Total number of employees?

      3,016

    • Yes
      1 / 1
      Source

      85. Percentage or number of temporary employees?

      482 (16%)

    • Yes
      1 / 1
      Source

      86. Percentage or number of women employees?

      943 (31%)

    • Yes
      1 / 1
      Source

      87. Commitment to pay minimum wage?

    • Yes
      1 / 1
      Source

      88. Commitment to address occupational health and safety?

    • Yes
      1 / 1
      Source

      89. Time lost due to work-based injuries?

      8.74 - Frequency rate (Total accidents x 1,000,000)/work hours)

    • Yes
      1 / 1
      Source

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

      0 - Zero fatalities for both palm oil and overall Group operations

    • Yes
      1 / 1
      Source

      91. Provision of personal protective equipment and pesticide training?

  • Certification standards Certification standards 3.5 / 12.5 28%
    • Companies should become members of credible certification standards and report in accordance with all appropriate categories of membership. The Roundtable on Sustainable Palm Oil (RSPO) requires members registered as growers to submit data relating to certification targets for their estates, scheme smallholders and independent fresh fruit bunch (FFB) suppliers, via an annual communications of progress (ACOP) report.

    • Yes
      1 / 1
      Source

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

    • Yes
      0.5 / 0.5
      Source

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

    • Yes
      0.5 / 0.5
      Source

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

      Indonesia (Papua and West Papua provinces)

    • Yes
      0.5 / 0.5
      Source

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

      2,020

    • Yes
      0.5 / 0.5
      Source

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

      2,020

    • n/a
      -
      No source

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

      This indicator has been disabled as it is only relevant for processors/traders

    • No
      0 / 0.5
      Source

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

      2,019 - The company joined the RSPO in 2011 (after commencing plantation operations in 2010) but year of first certification planned for 2019

    • No
      0 / 2
      Source

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

      0 (0%)

    • No
      0 / 2
      Source

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

      0 (0%)

    • No
      0 / 2
      Source

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

      0 (0%)

    • n/a
      -
      Source

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

      This indicator is disabled as the company has no independent suppliers

    • n/a
      -
      No source

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

      This indicator has been disabled as it is only relevant for processors/traders

    • No
      0 / 1
      No source

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

    • Partial
      0.5 / 1
      Source

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

      The company states it has received an ISPO certificate for PT HIP, but is not fully ISPO certified

    • n/a
      -
      No source

      106. Malaysia Sustainable Palm Oil (MSPO) certified?

      This indicator has been disabled as the company does not operate in Malaysia

    • No
      0 / 1
      No source

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

  • Smallholders and suppliers Smallholders and suppliers 3 / 5 60%
    • Companies should report details of any programmes or schemes to support both schemed and independent smallholders, as well as criteria to assess suppliers on compliance with company policies, and in what cases suppliers should be suspended or excluded due to non-compliance.

    • Yes
      1 / 1
      Source

      108. Programme to support scheme smallholders?

      Providing training on good agricultural practices and financial support

    • Yes
      1 / 1
      Source

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

      100% - The company details the number of smallholders and states it involves them all in its programmes

    • n/a
      -
      Source

      110. Programme to support independent smallholders?

      This indicator is disabled as the company has no independent suppliers

    • n/a
      -
      Source

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

      This indicator is disabled as the company has no independent suppliers

    • Yes
      1 / 1
      Source

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

      The company states it has a Contractor Management System to ensure compliance with its safety policy, quality and social aspects before selecting a supplier

    • No
      0 / 1
      No source

      113. Suspension or exclusion criteria for suppliers?

    • No
      0 / 1
      No source

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

  • Governance and grievances Governance and grievances 4 / 6 66.7%
    • Companies should operate in an ethical manner at all levels, providing accessible channels and clear procedures for both employees and external stakeholders to raise any grievance or complaint with the company, as well as allowing for whistleblowing.

    • Yes
      1 / 1
      Source

      115. Commitment to ethical conduct and prohibition of corruption?

    • Yes
      1 / 1
      Source

      116. Whistleblowing procedure?

    • Yes
      1 / 1
      Source

      117. Own grievance or complaints system?

    • Yes
      1 / 1
      Source

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

    • No
      0 / 2
      Source

      119. Details of grievances disclosed?

      The company only reports that it received no formal complaints on any violation of the rights of indigenous people and no credible complaints on discrimination in any locations in 2017

Media monitor: Noble Group Ltd

SPOTT monitors global media sources for coverage of assessed companies. The media monitor gathers reports about specific activities related to the assessment indicator categories. ZSL does not assess the validity of media coverage, but users can explore the media monitor to provide context on implementation, and infer risks associated with reported operations on the ground.

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Research protocols: Noble Group Ltd

Research protocols guide how ZSL conducts SPOTT assessments and allocates scores to ensure a fair and consistent approach, setting the expectations for companies on how they should publish ESG data. The full palm oil indicator framework contains 119 indicators across 10 categories, aligned with corporate reporting initiatives.

SPOTT is a ZSL initiative.
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