Sampoerna Agro Tbk PT

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

The company has published a sustainable palm oil policy which covers all palm oil operations.

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 reports to have a sustainability head of division.

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

The company states its Research and Development Director is responsible for directing implementation of strategies and policies related to sustainability, amongst other issues.

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

The company reports a list of just 30 names of senior managers, gender is not reported, nor can it be deduced.

6. Percentage or number of women board members?

0 (0%) - The company reports that all six board members are male.

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 reports to work with local communities to establish the Kelompok Tani Peduli Api (KTPA) units to prevent and mange fire risk. It has also collaborated with the Faculty of Forestry of IPB on research related to changes in land cover and diversity of flora and fauna in oil palm plantation.

9. Sustainability report published within last two years?

Published as part of the company's 2021 annual report.

10. Reports through standardised reporting systems?

The company reports that its annual report has been prepared in accordance with the GRI Standards: Core option.

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

This indicator is disabled as the company is not a POIG member.

12. Climate risks assessment available?

13. Lists countries and operations?

The company reports that its estates and mills are located in Indonesia.

14. Lists countries sourcing from?

The company reports that all plasma supplying plantations are located in Indonesia. The company does not report the countries in which its independent suppliers are located in.

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

186036 - Total land area managed/controlled for oil palm is Total 186036 ha.

16. Total oil palm planted area (ha)?

134000 - Total oil palm planted area is 134,000 ha.

17. Scheme smallholders planted area (ha)?

49180 - The company reports a figure of 49,180 ha for scheme smallholders planted area.

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

21558 - Data as per RSPO ACOP 2021.

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

18643 - The company a HCV area of 18,643 ha.

20. Maps of estates/management units?

The company uploaded its estate location concession maps with its ACOP and declared that the map data submission represented 100% of its concession sites. The company also has four concessions mapped on GFW.

21. Maps of scheme smallholders?

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

23. Number of company-owned mills?

8 - The company reports to have 8 mills (5 in Sumatera and 3 in Kalimantan).

24. Names and locations of company-owned mills?

The names and locations of all 8 of the company's mills can be found on GFW.

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

The company states that 4 mills (50% of the total) whose FFB were supplied from the companies own plantation and scheme smallholders, while the remaining 4 mills (50% of the total) received FFB from the companies own plantation, scheme smallholders, and third parties.

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

The company states that FFB sources comprise of 62% from its own plantations, 29% from scheme smallholders, and 9% from third-parties.

27. Number of third party supplying mills?

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

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

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

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

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

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

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

31. 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.

32. 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.

33. Percentage of supply traceable to mill level?

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

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

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

36. 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.

37. Publishes traceability data at refinery level?

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

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] 2007 - The company has been a RSPO member since 2007.

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 became certified in 2011.

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

The company has submitted its 2021 ACOP.

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

[Externally verified] 27.87% - Data as of 2021.

43. Percentage of mills RSPO-certified?

[Externally verified] 75% - Six out of eight mills are certified.

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

2025 - The company plans to achieve 100% RSPO certification for all its estates and mills by 2025.

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

This indicator is disabled as the company is only a grower or miller.

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

[Externally verified] 64.63% - Land under scheme/plasma certified as reported in 2021 ACOP.

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

2027 - The company commits to achieve 100% RSPO certification of scheme/associated smallholders and outgrowers by 2027. This is within 5 years.

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

No FFB supply from independent smallholders/outgrowers/third-party FFB suppliers is RSPO-certified.

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

This indicator is disabled as the company is only a grower or miller.

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

The company's RSPO ACOP 2021 reports to sell zero tonnes of palm oil through Segregated or Identity Preserved supply chains.

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

This indicator is disabled as the company only reports a Grower ACOP.

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

The company reports that it has 8 ISPO-certified subsidiaries (30 working units), with a total certified area of 74,417 ha. This does not cover its entire landbank.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

[Externally verified] The company has one ISCC certificate. The company also self-reports certification under ISO 14001, PROPER and Sustainable Production Forest Management (PHPL).

55. Commitment to zero conversion of natural ecosystems?

56. Commitment to zero deforestation?

The company commits to zero deforestation.

57. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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

The company defines deforestation as the removal of HCV and HCS areas and specifies any deforestation/conversion past October 2019 will not be accepted.

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

The company defines deforestation for suppliers as the removal of HCV and HCS areas and specifies any deforestation/conversion past October 2019 will not be accepted in supplier operations.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to conduct monitoring of deforestation in its own reports, however no evidence is provided.

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

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

0 - The company states that throughout 2021, there were "no incidents of policy violations related to deforestation and inappropriate land conversion activities". However, this is not reported since the cut-off date of October 2019.

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

64. Commitment to restoration of deforestation/conversion?

The company commits to rehabilitate and restore damaged areas within HCV area only. This does not clearly cover all non compliance.

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

66. Implementing a landscape or jurisdictional level approach?

67. Biodiversity policy?

The company commits to "maintaining and improving its efforts related to nature conservation, especially the preservation of ecosystems and protected flora and fauna species". This does not clearly cover both within and beyond HCV/HCS/set-asides and no time-bond target is provided.

68. Biodiversity policy applies to all suppliers?

69. 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 also reports species of concern using the IUCN Red List of Threatened Species in its own reporting.

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

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

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

The company commits to no hunting of species across all operations, however it also states that hunting is permitted if there is a need to reduce a specific animal species' population due to overpopulation, but no further details on this are given.

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

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

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

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

The company commits only scheme smallholders (plasma) to conduct HCV assessments.

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

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

[Externally verified] HCV summaries are publicly available for eight estates. The company has also submitted a further two Integrated HCV-HCSA Assessments to HCVN for review but the reports are not yet publicly available.

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

[Externally verified] Management and monitoring plans are publicly available for eight estates. The company has also submitted a further two Integrated HCV-HCSA Assessments to HCVRN for review but the reports, including management and monitoring plans are not yet publicly available.

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

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

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

The company's commitment only applies to scheme smallholders (plasma) and reports that HCV assessments had been carried out for nucleus and plasma estates under the ALS scheme from the HCVN.

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

[Externally verified] Eight out of ten HCV assessments have received a satisfactory review, two are yet to receive a review but are reported to be "on-track".

81. 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. The company also makes this commitment in its own reporting.

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

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

83. High Carbon Stock (HCS) assessments available?

[Externally verified] The company has submitted two integrated HCV-HCSA assessments and five HCS assessments submitted to HCSA, but none of which are publicly available.

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

None of the company's HCS assessments have been peer reviewed.

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

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

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

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

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

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

89. 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.

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

68 - The company states it has 68 ha of peat within its conservation area, but does not disclose the total planted landbank on peat.

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

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

The company commits to best management practices for soils and peat.

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

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

94. 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.

95. Commitment to zero burning?

The company commits to no burning.

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

97. Evidence of fire monitoring and management?

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

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

The company reported that there were no fires in its estate in 2021.

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

0 - The company reported that there were no fires in its plasma estate in 2021.

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

The company reports a target to reduce its GHG emissions intensity from 3.73 tCO2e/tCPO in 2015 to 1.22 by 2035.

101. GHG emissions intensity?

The company reports a figure of 5.05 tCO2e/ha and 3.27 tCO2e/tCPO in its 2019 ACOP, however this only covers certified units.

102. GHG emissions from land use change?

103. Progress towards commitment to reduce GHG emissions intensity?

104. Methodology used to calculate GHG emissions?

The company uses both the RSPO and ISCC methodology to calculate GHG emissions.

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

Two out of the company's eight mills have methane capture.

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

The company only has a general commitment to reduce water use.

107. Water use intensity?

0.66 - The company reports its water use intensity as 0.66 m3 per tonne of FFB processed.

108. Progress towards commitment on water use intensity?

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

The company commits to maintain BOD and COD levels within legal limits.

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

The company reports BOD and COD levels which are consistently below legal limits.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also communicates this in its own reporting.

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

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

113. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways through buffer zones.

114. 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.

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

The company commits to reduce chemical use. It is unclear if the commitment requires the company to minimise chemical fertiliser and pesticide use.

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

117. Commitment to no use of paraquat?

The company commits to not use paraquat.

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

119. Commitment to 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 pesticides.

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

The company's commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to only company's scheme (nucleus) smallholders.

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

The company commits to not use Stockholm and Rotterdam Convention chemicals.

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

The company's commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to only company's scheme (nucleus) smallholders.

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

The company reports the total use of inorganic pesticides in its as operational areas in 2021 as 1.46 kg/ha. The company does not report a figure for chemical fertilisers.

124. Implementation of commitment to minimise inorganic fertiliser use?

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

125. Integrated Pest Management (IPM) approach?

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

126. 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. The company also reports examples of waste management under the principle of the 3Rs (Reduce, Reuse, Recycle) including reusing solid and liquid waste from mills as fertiliser.

127. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

The company commits suppliers to the Universal Declaration of Human Rights.

129. Progress on human rights commitment?

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

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

The company states it protects the rights of local communities, but indigenous people are not mentioned and it does not reference the UN Declaration on the Rights of Indigenous Peoples or ILO.

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

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

The company commits to respect legal and customary land tenure rights.

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

The company commits suppliers to respect legal and customary land tenure rights.

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

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

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

The company makes this commitment for its plasma smallholders only.

136. 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.

137. Examples of local stakeholder engagement to prevent conflicts?

The company states that stakeholder meetings are held every two years, in which one of the objectives is to review the social management plan stipulated in the SIA report, however limited details are given.

138. Details of process for addressing land conflicts available?

The company reports a conflict resolution mechanism stipulated in the "Procedure for Handling Claims and Land Disputes".

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

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

140. Commitment to mitigate impacts on food security?

The company reports have CSR programmes to improve food security but no clear commitment is provided and there is no details of how this is achieved.

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

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

142. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

143. 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. The company also reports to have constructed places of worship, education facilities, roads, and installed an audio system at a local police station.

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

The company reports a commitment to "developing local businesses within the surrounding communities" and states that it "strives to involve qualified local talents to take up senior managerial roles". No specific commitment to provide business/work opportunities is reported.

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

The company commits to all Fundamental ILO Conventions and Free and Fair Labour Principles.

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

The company commits all suppliers to all Fundamental ILO Conventions and Free and Fair Labour Principles.

147. 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.

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

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

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that there were no cases of gender based discrimination in 2021 but does not report how this is monitored.

151. Percentage or number of temporary employees?

95 (1.11%) - The company reports 95 temporary employees out of 8,586.

152. Percentage or number of women employees?

1222 (14.23%) - The company reports 1,222 woman employees out of 8,586.

153. Commitment to pay a Decent Living wage?

The company commits to pay minimum wage only.

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

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

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

156. Reporting of salary by gender?

The company reports that the ratio of salaries for male and female employees is 1:1 but does not is not split by employee category and significant locations of operation.

157. Commitment to address occupational health and safety?

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

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

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

159. Provision of personal protective equipment and related training?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also communicates this in its own reporting.

160. Time lost due to work-based injuries?

58.17 - The company reports Total Working Hours Lost due to Occupational Accidents as 58.170 hours, based on a 40-hour workweek.

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

1 - The company reports one fatality due to Occupational Accidents.

162. Commitment to support smallholders?

The company commits to support plasma smallholders and provides a general commit to improve the quality of life of smallholders. No commitment to support independent smallholders is reported.

163. Programme to support scheme smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to provide technical assistance through ""various programmes"" to all plasma (scheme) smallholders.

164. Percentage of scheme smallholders involved in programme?

35277 (100%) - The company reports to have collaborated with 35,277 plasma (scheme) smallholders in 2021 and that all plasma smallholders "receive technical assistance in various programs".

165. Programme to support independent smallholders?

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

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

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

The company reports that it evaluates each supplier annually based on its environmental, occupational health and safety, and human rights performance and requires legal documents from suppliers. The company also reports that suppliers must fill out a self-assessment form on compliance with the company's Standard Operating Procedure for the purchase of FFB.

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

169. Suspension or exclusion criteria for suppliers?

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

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

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

This indicator is disabled as the company does not source from mills.

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

This indicator is disabled as the company does not source from mills.

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

This indicator is disabled as the company does not source from mills.

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

This indicator is disabled as the company is only a grower or miller.

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

This indicator is disabled as the company is only a grower or miller.

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

This indicator is disabled as the company is only a grower or miller.

178. Commitment to ethical conduct and prohibition of corruption?

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

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that to support complying with company's regulations and enforcing its ethical standards, the company established the "Corporate Compliance Committee" (CCC) to supervise level of compliance. The company also conducts training on ethical conduct and prohibition of corruption.

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

The company reports to have a taxation policy, but details of the policy are not provided.

182. Whistleblowing procedure?

The company reports a whistleblowing system including information on the whistleblowing procedure/how to report unethical conduct, a clear description of steps taken, and how whistleblowers are protected.

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

The company states that grievances can be submitted through the whistleblowing system which is accessible to both internal and external parties.

184. Details of complaints and grievances disclosed?