R.E.A. Holdings plc

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

The company has a number of sustainability policies, including its Environment and Biodiversity Conservation, Human Rights, Health and Safety and Responsible Development Policies.

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

The company states that all contracts with suppliers include a clause that requires the supplier to comply with all company policies.

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 company states that the President Director of the Indonesian subsidiary (REA Kaltim) and at the PLC level the Managing Director and audit committee of REA Group are responsible for sustainability.

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

13

6. Percentage or number of women board members?

2

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

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

The company states that it works closely with NGOs, universities, and local governments on various species and habitat conservation and rehabilitation projects including monitoring and management activities.

9. Sustainability report published within last two years?

The company published a 2019 Annual Report with a significant sustainability section focused on palm oil.

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?

The company has a summary of climate risks in its 2019 annual report.

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

89,064

14. Total oil palm planted area (ha)?

36,154 - The figure includes smallholder areas.

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

6,072

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

24,516

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

18,012

18. Maps of estates/management units?

Concession boundaries have been made available to the RSPO in 2018 and the company declares no new concession acquisition or changes in the ownership of existing concessions were undertaken in its ACOP 2019.

19. Maps of scheme/plasma smallholders?

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

21. Number of company-owned mills?

3

22. Names and locations of company-owned mills?

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

The company states that all three mills source from both own plantations and third-party plantations.

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

The company states it sources 800,666 tonnes of FFB from its own estates and 198,737 tonnes from third-party suppliers.

25. Number of third party supplying mills?

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not source from third-party supplying mills.

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

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

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

This indicator is disabled as the company does not source from third-party supplying mills.

31. Percentage of supply traceable to mill level?

This indicator is disabled as the company does not source from third-party supplying mills.

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

The company states it has achieved 100% traceability to plantation level.

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

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

This indicator is disabled as the company does not source from third-party supplying mills.

35. Publishes traceability data at refinery level?

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

36. Publishes traceability data at crusher level?

The company reports its two crushing facilities only source from company-owned mills. Data to plantation level is not available and data is not externally verified.

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

2007

38. 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

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

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

The company states all the countries and regions in which the company operates: Indonesia (East Kalimantan).

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

42. Percentage of mills RSPO-certified?

66.6% - Two of the company's three mills are RSPO certified.

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

2022

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

2022 - Crushing facilities are integrated into company mills.

45. Percentage of scheme/plasma smallholders (ha) RSPO-certified?

0% - The company states that plasma smallholders are currently preparing for RSPO certification.

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

2023

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

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

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

Mass Balance only.

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

The company claims that all of its estates and mills were ISPO certified and passed yearly audits. However, the information is not externally verified.

51. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

53. Commitment to zero deforestation or zero conversion of natural ecosystems?

The company has a "No Deforestation, No Peat and No Exploitation" policy.

54. Commitment to zero deforestation or zero conversion of natural ecosystems applies to all suppliers?

The policy applies to all independent smallholders and third party contractors.

55. Criteria for defining deforestation?

The company specifies HCV, HCS, and peat areas, however, no cut-off date is specified.

56. Evidence of monitoring deforestation?

The company reports monitoring deforestation and encroachment through patrols and satellite mapping which helps to detect logging or land clearing within the conservation reserves areas. However, the information is not externally verified.

57. Evidence of monitoring deforestation in supplier operations?

The company monitors deforestation using a mapping and monitoring system which assesses land cover. However, the extent of the area being monitored and time-frames are not clear.

58. Amount of illegal/non-compliant deforestation recorded in own operations?

28.47 - The figure represents non-compliant deforestation recorded in two estates by squatters. Damai Estate: 21.02 ha and in Perdana Estate: 7.45 ha.

59. Amount of illegal/non-compliant deforestation recorded in supplier operations?

60. Commitment to restoration of non-compliant deforestation/conversion?

61. Commitment to restoration of non-compliant deforestation/conversion applies to all suppliers?

62. Implementing a landscape or jurisdictional level approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

63. Commitment to biodiversity conservation?

64. Commitment to biodiversity conservation applies to all suppliers?

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company has also identified species of conservation concern referring to the IUCN Red List.

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

The company engages with local communities, schools, and workers' emplacements to encourage participation in forest conservations. Also includes camera trapping point surveys, restoration, and enrichment activities. Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

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

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

The company has its own commitment and also commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

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

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

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

[Externally verified] The company has an HCV summary report publicly available for PT Kartanegara Kumalasakti estate and the HCV assessment for PT Prasetia Utama estate is under review.

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

[Externally verified] The company has an HCV summary report publicly available for PT Kartanegara Kumalasakti estate and the HCV assessment for PT Prasetia Utama estate is under review.

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

The company has its own commitment and also commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

75. 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?

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

[Externally verified] The company has an HCV summary report for new plantings done after Jan 2015, namely PT Prasetia Utama which is under review and PT Kartanegara Kumalasakti which have been quality reviewed and deemed satisfactory.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

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

79. High Carbon Stock (HCS) assessments available?

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

The company has its own commitment and also commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

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

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

There is public availability of the following SEIAs: East Kalimantan: PT Cipta Davia Mandiri; PT Persada Bangun Jaya; PT. Kutai Mitra Sejahtera.

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

The company has its own commitment and also commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

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

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

1,067 - The company reports that 1,067 ha of its planted area is on peat at certified estates and states that there has not been or will be new developments on peatland covering all operations.

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

The company reports that 1,067 ha of peatlands are in certified units (Sentekan and Tepian Estate), and there has been and will not be any other planting on peatlands. The information is not externally verified.

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

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

The company commits to best management practices for soils and peat, however it is unclear if the policy applies to all suppliers.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

90. Commitment to zero burning?

91. Commitment to zero burning applies to all suppliers?

92. Evidence of fire monitoring and management?

The company reports that it carries out routine fire training for the prevention and identification of hazards. However, the information found is not externally verified.

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

The company reports that "In 2019 there were 36 incidents (fire hotspots) recorded within the company concessions that were reported to the RSPO.".

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

0 - The company reports that in 2018 no forest fires were recorded within surrounding areas. Data between one and two years old.

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

The company had a target to reduce the intensity of GHG emissions per planted hectare by 2017 but did not state by how much. A new target could not be found within the company's 2018 and 2019 reporting.

96. GHG emissions intensity?

The company reports 1.5 tonnes as net emissions per tonne of CPO production and 5.3 tonnes of net emissions per planted hectare.

97. GHG emissions from land use change?

The company reports that GHG emissions from land use change for the whole scope of operations in 2018 were: 138,496.49 tonnes of CO2eq (own operations) and 36,806.01 (group).

98. Progress towards commitment to reduce GHG emissions intensity?

The company reports GHG emission per planted hectare in 2017, 2018 and 2019 as 4.95, 5.6 and 6.6 respectively, which shows that the intensity figures are not improving.

99. Methodology used to calculate GHG emissions?

RSPO PalmGHG calculator v. 3.0.1.

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

Two of the company's three mills have methane capture.

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

The company had a time-bound commitment for water use intensity to reach a maximum of 2.5 m3/tonnes FFB in 2017 and in 2018.

102. Water use intensity?

The company reports water use intensity figures for all its operations in 2019: POM: 1.58 m3/tonnes FFB; COM: 1.11 m3/tonnes FFB; SOM: 2.43 m3/tonnes FFB.

103. Progress towards commitment on water use intensity?

The company reports water use intensity and states that set targets have been met at all operations. However, the information is not externally verified.

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

The company reports that BOD and COD levels are kept within legal limits (5,000mg/litre and 10,000mg/litre, respectively) and this is checked on a monthly basis.

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

Both BOD and COD limits consistently stayed below legal limits in 2018 and 2019. Data is not externally verified.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

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

108. Commitment to protect natural waterways through buffer zones?

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

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

112. Commitment to no use of paraquat?

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

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

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

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

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

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

The company reports figures for tonnes of inorganic fertilisers applied per hectare and a list of herbicides used in 2018.

119. Implementation of commitment to minimise inorganic fertiliser use?

The company states "application of EFB for mulching provides the palms with organic matter that helps to retain ground moisture which is important during dry weather periods and also helps to minimise the quantities of inorganic fertiliser required.".

120. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

122. Commitment to human rights?

123. Commitment to human rights applies to all suppliers?

124. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

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

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

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

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

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

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

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). Points have therefore been awarded on the basis of the company's commitments under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

132. Examples of local stakeholder engagement to prevent conflicts?

The company states in its 2018 ACOP that it carried out extensive participative mapping activities with local communities.

133. Details of process for addressing land conflicts available?

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

The company is committed to promote diversity and equality and maintain gender balance within its workforce. However, the information found is not externally verified.

135. Commitment to mitigate impacts on food security?

136. Commitment to mitigate impacts on food security applies to all suppliers?

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

The company provides multiple examples of how it supports local communities on mitigating impacts on food security including crop diversification, training, and access to markets.

138. Commitment to provide essential community services and facilities?

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

147. Percentage or number of temporary employees?

135

148. Percentage or number of women employees?

1,827

149. Commitment to pay at least minimum wage?

The company states "The minimum wage for both casual and permanent employees of REA is in line with the regulations applicable to the location of employment.".

150. Commitment to pay at least minimum wage applies to all suppliers?

151. Progress on commitment to pay at least minimum wage?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

152. Reporting of salary by gender?

153. Commitment to address occupational health and safety?

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

155. Provision of personal protective equipment and related training?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

156. Time lost due to work-based injuries?

1,651 - The figure represents the lost days rate in 2018. The unit of measurement is not specified.

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

4 - The company reported four fatalities out of which two fatalities are not directly work-related as it occurred outside working hours.

158. Commitment to support smallholders?

159. Programme to support scheme/plasma smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

160. Percentage of scheme/plasma smallholders involved in programme?

100% - The company reports that all plasma smallholders are involved in support programmes. However, the information is not externally verified.

161. Programme to support independent smallholders/outgrowers?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

1,000 - The company reports that all PPMD smallholders and 1,000 out of 1,927 independent smallholders are involved in support programmes.

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

The company has procedures/mechanisms to identify the "compliance level" of suppliers with government regulations, policies, SOPs, standards that the company has set (e.g. setting purchase prices, grading criteria, etc.). Further, the company has a program to support suppliers to comply with existing standards so that FFB is produced from sustainable sources. For controlling the acceptance of FFB suppliers, the company has implemented a computerised system to identify the identity of FFB receipts. Further, policies and contracts are explained to contractors (including suppliers) during meetings.

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

The company reports the number of contractors involved with the company however it is unclear if these are suppliers or other contractors and if these are all the suppliers/contractors engaged/assessed by the company.

165. Suspension or exclusion criteria for suppliers?

The company states it only accepts FFB from farmers who participate in a traceability mapping exercise but does not have clear criteria for suspending or excluding suppliers that breach its policies. The company also states that if a supplier does not fulfill the criteria the first step taken is the socialisation of the requirements.

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

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

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

This indicator is disabled as the company's crushing facilities are integrated with its mills.

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

This indicator is disabled as the company's crushing facilities are integrated with its mills.

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

This indicator is disabled as the company's crushing facilities are integrated with its mills.

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

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

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

174. Commitment to ethical conduct and prohibition of corruption?

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

178. Whistleblowing procedure?

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

The company only has an internal complaint handling mechanism, which is not open to external stakeholders.

180. Details of complaints and grievances disclosed?