Sawit Sumbermas Sarana Tbk PT

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

The company meets this indicator through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own sustainability policy in place.

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

The company has published a sustainable palm oil policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has a Head of Sustainability.

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

The company reports that it has a head of sustainability within the board.

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

4 (17%) - The company reports that four out of 23 senior management members are women.

6. Percentage or number of women board members?

0 (0%) - The company reports no female members in the Board of Commissioners or Board of Directors. Data as of 2021.

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 routinely conducts surveillance for certification and implements RaCP as part of its fulfilment and responsibility for implementing RSPO provisions. Currently, there are 2 (two) of the 4 (four) existing RaCp running in the company, namely the Orangutan pre-release program on Pulau Salat through a partnership with the Borneo Orangutan Survival (BOS) Foundation and a partnership with Karya Masoraian in protecting the forest at Lake Masorian.

9. Sustainability report published within last two years?

The most recent Sustainability Report is published in 2022, covering the year 2021.

10. Reports through standardised reporting systems?

The 2021 Sustainability Report is 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?

Indonesia (plantations, palm oil mills and crushing facilities).

14. Lists countries sourcing from?

The company reports having 121 local suppliers (Indonesia) or 33.43% of the company's total suppliers in 2021. However, the country of origin for other suppliers is not reported.

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

57758 - The company reports contradictory figures in the same time period. The total land area managed/controlled for oil palm is reported as 115,649 ha in its 2021 Annual Report and 91,649.54 ha in its 2021 Sustainability Report. RSPO ACOP 2021 reports the same as 57,758 ha.

16. Total oil palm planted area (ha)?

45577 - The company reports contradictory figures in the same time period. The company specified the total area planted with oil palm, including mature, immature plantations and plasma areas as 92,684 ha in its 2021 Annual Report and 94188.23 ha in its 2021 Sustainability Report. RSPO ACOP 2021 reports the total land controlled or managed for oil palm cultivation - planted and infrastructure as 45,577 ha.

17. Scheme smallholders planted area (ha)?

5683 - The company reports contradictory figures in the same time period. The company reports the total plasma area planted with oil palm as 11,448 hectares in its 2021 Annual Report and 12,983.76 ha in its 2021 Sustainability Report. RSPO ACOP 2021 reports the total land under scheme smallholders planted with oil palm as 5,683 ha.

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

3149 - RSPO ACOP 2021 reports the unplanted area as 3149 ha.

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

3349 - RSPO ACOP 2021 reports the conservation set-aside area, including High Conservation Value (HCV) area (ha) as 3349 ha.

20. Maps of estates/management units?

Concession boundaries were made available to RSPO in 2021, and since then, the company declares that it has not acquired any new estates.

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 owning 8 mills.

24. Names and locations of company-owned mills?

The GFW universal mill list has the names and locations of only 2 company mills. RSPO certified growers database has names and coordinates for only six company mills. The names of all palm oil mills are available in the latest sustainability report of the company, however, the locations for all eight mills owned by the company are not reported.

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

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

27. Number of third party supplying mills?

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

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

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

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

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

The company commits to work towards a fully traceable palm oil supply chain, achieving full traceability to the supply base. However, this commitment is not time-bound.

33. Percentage of supply traceable to mill level?

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

The company commits to work towards a fully traceable palm oil supply chain, achieving full traceability to the supply base. However, this commitment is not time-bound.

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?

37. Publishes traceability data at refinery level?

38. Publishes traceability data at crusher level?

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

[Externally verified] 2007 - The company has been a member of RSPO since April 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?

2013 - The company achieved its first certification in 2013 (not within 3 years of joining RSPO).

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

The company has submitted its 2021 RSPO ACOP.

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

[Externally verified] 87.78% - The company reports that 87.79% of its area is certified under RSPO in its 2021 RSPO ACOP.

43. Percentage of mills RSPO-certified?

[Externally verified] 75% - 6 out of the total 8 company mills owned by the company are RSPO certified.

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

2024 - The company commits to achieving 100% RSPO certification of estates and mills by 2024. This is within 5 years.

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

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

The company reports that 0% of scheme smallholders are RSPO certified.

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

2025 - The company commits to achieving 100% RSPO certification of scheme/associated smallholders and outgrowers by 2025. This is within 5 years.

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

0% - The company reports the percentage of FFB supply (tonnes) from independent smallholders and outgrowers FFB suppliers that as 0% RSPO-certified.

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

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

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 only PT SMU and PT TSA are ISPO certified, also company has set a target to become fully ISPO certified by 2020. However, this target is not met.

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)?

The company and its subsidiaries are only ISO 14001 certified.

55. Commitment to zero conversion of natural ecosystems?

56. Commitment to zero deforestation?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have been therefore awarded on the basis of the company's RSPO-certified landbank (?75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to no deforestation of HCV and HCS areas.

57. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to no development in High Conservation Value (HCV) and High Carbon Stock (HCS) areas.

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

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own reporting mentions no deforestation of HCV and HCS areas, however, a cut-off date is not reported.

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

The company only reports to no deforestation of HCV and HCS areas by its suppliers. However, a cut-off date is not reported.

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.

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?

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 applying the RSPO Remediation and Compensation Procedure where there has been land clearing without prior HCV assessment since November 2005, or without prior HCV-HCSA assessment since November 2018, through the RSPO Principles and Criteria 2018. However, a commitment covering restoration of all non-compliant deforestation/conversion was not found. Partial points have therefore been awarded on the basis of the company's RSPO-certified landbank (?75%) and a further commitment to be 100% certified within 5 years.

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

The company reports to implement RSPO's Remediation and Compensation Procedure (RaCP) for all plantings without HCV assessments since November 2005, including current and future acquisitions. This applies to all suppliers of the company.

66. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company reports having formed a partnership with the Karya Masoraian Community in protecting the forest in the Ddanau Maosraian area to analyze and map peatland areas around the company's operational areas. The purpose of the peat mapping activity is to identify the distribution of peat areas and determine the depth, and maturity level, as well as monitor recommendations in the management of areas categorized as peat areas. However, the information reported is not externally verified.

67. Biodiversity policy?

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 periodically identifies protected flora and fauna both according to government regulations, the International Union for Conservation of Nature (IUCN) Red List, and based on CITES in all HCV areas.

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. The company also reports working together with the Borneo Orangutan Survival Foundation (BOSF) in the field of Orangutan Conservation on Pulau Salat. However, the information reported by the company is not externally verified.

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

The company commits to no hunting of all species in its operations.

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

The company commits all suppliers to no hunting of all species in their operations.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to conduct HCV assessments.

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

The company commits all suppliers to conduct HCV assessments.

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

[Externally verified] The company reports having conducted 5 HCV assessments in 2012 and 4 re-assessments in 2015. HCV assessments for two subsidiaries of the company are available on the RSPO database.

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

This indicator is disabled as the company has not undertaken any new planting since January 2015.

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

This indicator is disabled as the company has not undertaken any new planting since January 2015.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS).

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 commits all suppliers to only use licensed HCV assessors accredited by the HCV Resource Network's ALS.

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

This indicator is disabled as the company has not undertaken any new planting since January 2015.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to the High Carbon Stock (HCS) Approach.

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?

This indicator is disabled as the company has not undertaken any new planting since January 2016.

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

This indicator is disabled as the company is: only a processor/trader; or has had no new planting since April 2015, unless it has undertaken HCS assessments that are not for new planting; or all new planting is since November 2017 and has all been covered under combined HCV-HCS assessments.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own reporting only covers its commitment to Environmental Impact Analysis (AMDAL).

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?

[Externally verified] The social and environmental impact assessments (SEIAs), associated management and monitoring plans are available for PT Sawit Mandiri Lestari and PT Kalimantan Sawit Abadi.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to no planting on peat regardless of depth.

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)?

9.4% - The company reports that the soil composition of the plantations that the company operates is 90.6% high mineral soil, which is good for planting oil palms, and 9.4% peat soil. However, the information reported is from 2016 and is over five years old now.

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own reporting only covers commitment to best management practices for peat.

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

The company only reports commitment to best management practices for peat, which applies to all suppliers.

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. The company's own reporting only mentions one example of BMPs for soil stating that fronds are used for the soil when the oil palm tree is replanted as they serve as organic fertilizer and also maintains the soil moisture.

95. Commitment to zero burning?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to zero burning.

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no 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. The company also reports its own information on fire monitoring and management in its latest sustainability report.

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

The company reports the number of hotspots annually for the last 3 years (2019-2021). Zero fire hotspots were recorded in 2021.

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

0 - The company reports in its 2017 Sustainability Report that it has not recorded any fire cases due to land clearing in surrounding communities. However, this information is over two years old.

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

101. GHG emissions intensity?

The company reports GHG emission intensity for five of its mills as 1.73 Kg CO2/Ton. However, this information does not cover all operations of the company. The company also reports the average GHG footprint for all certified management units by hectare as 46.18 (tCO2e/ha) and by units per tonne of crude palm oil as 5.58 (tCO2e/tCPO) in its RSPO ACOP 20201. However, this information only covers the certified operations of the company.

102. GHG emissions from land use change?

This indicator is disabled as the company has not undertaken any new planting since January 2015.

103. Progress towards commitment to reduce GHG emissions intensity?

The company states that its GHG emissions have increased by 15.55% from 207,011.06 Tons of CO2 in 2020 to 239,203.02 Tons of CO2 in 2021 for five mills out of the total eight mills owned by the company. The company also reports to operate one methane capture facility in in PT Mitra Mendawai Sejati and has one more facility in development progress at PT Natai Baru. However, this information does not cover all operations of the company.

104. Methodology used to calculate GHG emissions?

The RSPO requires companies to assess their GHG emissions through the Palm GHG calculator. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own reporting mentions to use the methods and standards from ISPO and RSPO to calculate the generated Greenhouse Gas (GHG) emissions.

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

The company has one operational methane capture faciltiy at PT Mitra Mendawai Sejati and has one more facility in development progress at PT Natai Baru. However, this information does not cover all operations of the company.

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

The company reports maintaining a water use ratio of 1.60 m3/ton FFB every year.

107. Water use intensity?

1.53 - The company reports the intensity of water consumption as 1.53 m3/ton in 2021.

108. Progress towards commitment on water use intensity?

The company reports water use intensity figures for the years 2019- 2021. The figures for all years (2019- 1.59 m3/ton, 2020- 1.54 m3/ton, 2021- 1.53 m3/ton) are below the annual target of 1.60 m3/ton FFB reported by the company. However, the information reported is not externally verified.

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

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

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's own reporting states that it converts the POME into electrical energy through a biogas plant since 2018.

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

113. Commitment to protect natural waterways through buffer zones?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

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 makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own reporting only generally mentions reducing dependence on chemicals and increasing the use of biological controls.

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 makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own reporting mentions that since 2016, it is committed to not using paraquats identified as limited pesticides.

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

The company commits to eliminate the use of paraquat by 2018 and extends this to all its suppliers, however it is unclear if this commitment has been met.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to no use of 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 commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

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

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

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. The company's own reporting mentions using empty palm bunches as compost and reused as organic fertilizer in the garden. It also uses palm oil liquid waste (POME) and jangkos as a substitute fertilizer to reduce the use of chemical fertilizers.

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 has a waste management system in place.

127. Commitment to human rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment 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. The company's own reporting mentions having a 'Human RightsCoordinator Team' in place, which is responsible to strengthen the practices of human rights respect with the tasks of drafting, implementing and supervising the implementation of human rights policies and procedures, aspects of human rights, as well as identifying the occurrence of human rights violations that may occur and have occurred in the company. The company also reports that 89% of its new employees have undergone 'Human Rights Dissemination'.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The commitment also reports its own commitment to the UN Declaration on the Rights of Indigenous Peoples, however, this commitment is reported in relation to FPIC.

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

The commitment reports its own commitment to the UN Declaration on the Rights of Indigenous Peoples which applies to all suppliers. However, this commitment is reported in relation to FPIC.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to respect legal and customary land tenure rights, however, the commitment is reported in relation to FPIC.

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

The company also reports its own commitment to respect legal and customary land tenure rights which applies to all suppliers. However, the commitment is reported in relation to FPIC.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to free, prior and informed consent (FPIC).

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

The company commits all suppliers to respect FPIC.

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). Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

137. Examples of local stakeholder engagement to prevent conflicts?

The company only reports one example of local stakeholder engagement to prevent conflicts. It states that to prevent conflicts with communities around HCV areas, the company regularly disseminates the existence of HCV areas and explains the functions of the areas designated as HCVs to the surrounding community. This outreach is carried out annually in villages around the HCV areas.

138. Details of process for addressing land conflicts available?

The RSPO Principles and Criteria 2018 contain requirements for addressing land conflicts. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

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 makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

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 makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to providing 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 information on the progress of its commitment to provide essential community services and facilities in its latest sustainability report.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports to providing job opportunities to local communities where it operates.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to International Labor Organization's core conventions.

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.

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 makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to providing fair and equal employment for all employees regardless of race, nationality, religion, or 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.

151. Percentage or number of temporary employees?

11373 (60%) - The company reports a total of 11,373 contractual employees as of December 2021.

152. Percentage or number of women employees?

5106 (26.94%) - The company reports 5,106 or (26.94%) female employees in 2021.

153. Commitment to pay a Decent Living wage?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company's own reporting only covers the commitment to pay minimum wage.

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?

157. Commitment to address occupational health and safety?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to addressing occupational health and safety.

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 reports its own information on the provision of personal protective equipment and related training.

160. Time lost due to work-based injuries?

19 - The company reports a 'Total Recordable Injury Rate (TRIFR)' as 19 and a Lost Time Injury Frequency Rate (LTIFR) as 6 in the year 2021.

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

0 - The company reports that throughout 2020 it recorded zero accidents or even fatal accidents in the operational area.

162. Commitment to support smallholders?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to actively engaging smallholders and developing training as well as assistance programs to support farmer compliance with its sustainability policy and commitments.

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 reports having plasma partnership programs in place, which are facilitated by the company to build community plantations with a loan system. With this system, the farmer is able to get free coaching and training from the company which will help them in managing their plantations independently which can increase the income of smallholders by improving the quality and production of Fresh Fruit Bunches (FFB).

164. Percentage of scheme smallholders involved in programme?

5148 - The company reports having a total plasma area of 12,983.76 ha with 9,102 plasma farmers. Out of this,144 plasma groups or 5,148 plasma smallholders are involved in the company's plasma partnership programs as of 2021. However, the information reported is not externally verified.

165. Programme to support independent smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to empower independent farmers through its 'Independent Smallholders (ISH)' program.

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

409 - The company reports that the RSPO smallholder certification of independent smallholders included 994.81 ha and 409 farmers in 2021. However, it is unclear if this covers all independent smallholders supported by the company.

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

The company has a supplier policy for suppliers of goods and services, approved by the President Director. The performance of existing suppliers is assessed periodically every 6 (six) months, while new suppliers are selected according to the applicable internal procedures. The company strictly selects suppliers to ensure that the company's needs can be fulfilled with quality products and services, be available when needed, be delivered on time and at adequate prices, as well as comply with the company's sustainability policies (quality, availability, delivery, price, and compliance). Supplier selection is carried out in accordance with one of the commitments in the company's sustainability policy, namely "Committed to actively involving suppliers and helping them increase their capacity to ensure compliance with our policies and commitments".

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?

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

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

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

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

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

178. Commitment to ethical conduct and prohibition of corruption?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports its own commitment to ethical conduct and 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 also reports that to strengthen its commitment to anti-corruption, the company has a Whistleblowing System (WBS) as a medium for reporting indications of violations related to corruption. In 2021, the company socialized it ethical standards to provide the understanding and raise awareness of all the company's employees to always uphold the company's ethical standards. Throughout 2021, socialization was carried out twice a year.

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

182. Whistleblowing procedure?

The RSPO Principles and Criteria 2018 contain guidance and requirements on whistleblowing procedures. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also reports information on its whistleblowing system.

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

The company adheres to this criteria through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own grievance procedure open to all stakeholders.

184. Details of complaints and grievances disclosed?

The company reports that in 2021, it did not receive any complaints through the complaint service center, direct complaints or the WBS system. However, there is no platform where the details of complaints from earlier years are reported.