Noble Group Ltd

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

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

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

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.

4. Sustainability report published within last two years?

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

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

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.

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

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

70705

9. Total oil palm planted area (ha)?

17059.1

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

2236

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

28541.5

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

14307.9 - Sum of HCV areas and other conservation areas.

13. Area for infrastructure (ha)?

1384.5

14. Number and names of company owned mills?

1

15. Maps or coordinates of company owned mills?

Provide coordinates for only mill.

16. Number and names of supplier mills?

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

17. Maps of estates/management units?

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.

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

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

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

2020

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

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

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.

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.

24. Commitment to zero deforestation?

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

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

26. Criteria for defining deforestation?

Primary forest, HCV, HCS, peat
.

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.

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.

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

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

30. Commitment to biodiversity conservation?

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

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

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

33. Examples of species conservation activities?

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

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

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

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

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

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.

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.

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.

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

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.

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

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

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

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

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).

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

The company does not have operations on peat soil.

48. Landbank or planted area on peat?

0

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.

50. Commitment to zero burning?

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

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.

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

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

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

The company has 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)".

56. GHG emissions from land use change?

201738

57. Methodology used to calculate GHG emissions?

RSPO PalmGHG Calculator version 3.0.1 and GHG Protocol.

58. Progress towards commitment to reduce GHG emissions intensity?

The company reports intensity figures, but these are not improving.

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

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

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

62. Progress towards commitment on water use?

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

64. Protection of natural waterways through buffer zones?

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.".

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

67. No use of paraquat?

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.

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.

70. Integrated Pest Management (IPM) approach?

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.

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

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

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

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

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

77. FPIC commitment applies to independent suppliers?

This indicator is disabled as the company has no independent suppliers.

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

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.

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.

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.

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.

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."
.

84. Total number of employees?

3016

85. Percentage or number of temporary employees?

482 (16%)

86. Percentage or number of women employees?

943 (31%)

87. Commitment to pay minimum wage?

88. Commitment to address occupational health and safety?

89. Time lost due to work-based injuries?

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

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

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

91. Provision of personal protective equipment and pesticide training?

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

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

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

Indonesia (Papua and West Papua provinces).

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

2020

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

2020

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.

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?

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

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

0 (0%)

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

0 (0%)

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

0 (0%)

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.

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.

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

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.

106. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

108. Programme to support scheme smallholders?

Providing training on good agricultural practices and financial support.

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.

110. Programme to support independent smallholders?

This indicator is disabled as the company has no independent suppliers.

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

This indicator is disabled as the company has no independent suppliers.

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.

113. Suspension or exclusion criteria for suppliers?

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

115. Commitment to ethical conduct and prohibition of corruption?

116. Whistleblowing procedure?

117. Own grievance or complaints system?

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

119. Details of grievances disclosed?

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.