SD Guthrie Bhd (previously assessed as Sime Darby Plantation Sdn Bhd)

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 (99.36%) and a further commitment to be 100% certified by 2022. The company also has a 'Responsible Agriculture Charter' and 'Human Rights Charter' in place which covers multiple dimensions of sustainability across the company's operations covering both social and environmental issues.

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

The company commits its suppliers to its 'Responsible Agriculture Charter' and 'Human Rights Charter'.

3. High-level position of responsibility for sustainability?

Head of Group Sustainability.

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

The company reports that the board of directors is ultimately accountable for the group's sustainability commitments and performance and is supported by the Sustainability Committee (SC). The SC comprises of TUNKU ALIZAKRI RAJA MUHAMMAD ALIAS- Non-Independent Non-Executive Director, DATO' HENRY SACKVILLE BARLOW- Independent Non-Executive Director and ZAINAL ABIDIN JAMAL- Non-Independent Non-Executive Director.

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

20 (21%) - Data as of 2019.

6. Percentage or number of women board members?

2 (22%) - Data as of 2019.

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

[Externally verified] Pongo Alliance, Decent Rural Living Initiative.

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

The company reports collaboration with Universiti Malaysia Sabah(UMS) in 2020, to conduct a research program on the 282.21ha secondary forest, results of which will be used to develop rehabilitation and restoration strategies to help turn the area into company's first HCV model forest. The company also reports to have partnered with Management and Ecology of Malaysian Elephants (MEME) to develop the world's first mechanism to minimise Human-Elephant Conflict. The company is also a part of 'The Decent Rural Living Initiative' which aims to identify and scale grower-driven solutions that enables the provision of employment in a safe, fair and decent manner in rural Indonesia.

9. Sustainability report published within last two years?

Sustainability Report 2019 is published by the company.

10. Reports through standardised reporting systems?

The company has prepared its sustainability report 2019 and annual report 2020 in accordance with the GRI standards. The company has also submitted the CDP questionnaires for forests, climate change and water security in 2021.

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

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

12. Climate risks assessment available?

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

718174 - The company reports that a total of 718,174 ha land is controlled for oil palm.

14. Total oil palm planted area (ha)?

583339 - The company reports the total planted area for oil palm as 583,339 ha. Data as of December 2020.

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

88333 - The company reports the scheme smallholders planted area in its RSPO ACOP 2020.

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

0 - The company reports that there is no unplanted area.

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

46502 - The company reports the total land designated and managed as HCV areas as 38179 ha and other conservation land set aside, excluding HCV areas as 8323 ha.

18. Maps of estates/management units?

The company reports to have submitted its updated concession maps to the RSPO in its RSPO ACOP 2020.

19. Maps of scheme/plasma smallholders?

The company provides maps of its smallholders in Papua New Guinea and the Solomon Islands, but only coordinates of its smallholders in Indonesia and Malaysia.

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

The company provides maps of its smallholders in Papua New Guinea and the Solomon Islands, but only coordinates of its suppliers in Indonesia and Malaysia.

21. Number of company-owned mills?

70 - The company reports in it's 2020 annual report to operate 70 palm oil mills, however the 2020 ACOP states 67 mills.

22. Names and locations of company-owned mills?

Names and locations of 77 company-owned mills are available in the GFW Universal Mill List. However, the total number of mills operated is unclear.

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

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

The company reports that 9,275,385 tonnes of FFB was sourced from its own operations and 1,743,419 tonnes of FFB was sourced from other suppliers in 2020.

25. Number of third party supplying mills?

The company has published the list of all third party supplying mills to its refineries and crushing plants. Data as of March 2021.

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

The names and coordinates of all third party supplying mills to company's refineries and crushing plants is published on the company website. Data as of March 2021.

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

The company reports that 101 third party suppliers source from their own plantations, 126 source from mixed sources, and the remaining 578 is unknown as of January to June 2021.

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

The company reports that 8.44% of third party supply comes from supplier mills which source from their own plantations, 12.05% comes from mixed sources, and the remaining 79.51% is unknown as of January to June 2021.

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

The company reports that 8.64% of supply is indirect, the remainder is direct supply or unknown.

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

The company reports to achieving 100% traceability to the mill, however this target is not time-bound. At present, the company reports to have attained 97% overall traceability to the mill.

31. Percentage of supply traceable to mill level?

The company reports that at present it has attained 97% overall traceability to the mill. Additional points are awarded for company's refineries and crushing plants RSPO SCC certified under SG.

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

The company commits that Fresh Fruit Bunch (FFB) supplied to its own mills will be 100% traceable to the plantation by 2022. Commitment to achieve 100% traceability to plantation level for FFB sourced from third party suppliers is not reported by the company.

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

The company reports to have achieved 50% overall traceability to the plantation. Additional point has been awarded as many of the company mills have RSPO Identity Preserved certification.

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

The company reports overall traceability information for all its refineries and crushing plants, however, the percentage is not split as per own mills and third party mills. Additional points are awarded as many of the company's refineries have RSPO SCC under IP.

35. Publishes traceability data at refinery level?

The company reports traceability figures to plantation level for each of its refineries through Crosscheck and its own website. However, this information is not externally verified.

36. Publishes traceability data at crusher level?

The company reports traceability figures to plantation level for each of its KCPs through Crosscheck and its own website. However, this information is not externally verified.

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

[Externally verified] 2004 - The company is a member of the Roundtable on Sustainable Palm Oil (RSPO) since 7th September 2004.

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?

[Externally verified] 2008 - The company joined the RSPO in 2004 and received its first RSPO certification in 2008.

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

2020 RSPO ACOP is submitted.

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

Indonesia (Aceh, Central Kalimantan, Central Sulawesi, Jambi, Riau, South Kalimantan, South Sulawesi, West Kalimantan); Malaysia (Johor, Kedah, Malacca, Negeri Sembilan, Pahang, Perak, Sabah, Sarawak, Selangor), Papua New Guinea, Solomon Islands.

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

99.36% - The company reports the percentage of area RSPO certified in its RSPO ACOP 2020.

42. Percentage of mills RSPO-certified?

95.71% - The company owns total 70 mills out of which 67 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?

2020 - The company reported a target to achieve 100% RSPO certification of estates and mills in 2020 and have mentioned in the ACOP 2019 that all its mills have been certified within initial Time Bound Plan, the extension of timeline was due to new plantation acquired, latest in 2018 and a new mill established in 2020. Certification for remaining areas is in progress in line with the announcement by RSPO on Hak Guna Usaha (HGU) issues.

44. Time-bound plan for achieving 100% RSPO certification of all palm product processing facilities?

2019 - The company reports that all its refineries and kernel crushing plants have been certified since 2016 and two new facilities (Sime Darby Oils Indonesia and Sime Darby Research Sdn Bhd) were certified in 2019.

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

79.52% - The company reports the percentage of scheme smallholders RSPO-certified in its RSPO ACOP 2020.

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

2023 - The company reports to achieve 100% RSPO certification of scheme smallholders by 2023.

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

0% - From the 2020 ACOP this is calculated as 0%.

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

63.78% - The company reports its certified palm oil and palm oil products uptake as 63.78% in its RSPO ACOP 2020.

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

The company reports the total CSPO+CSPK sold as RSPO certified under SG is 16.70%.

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

The company reports that the percentage of CSPO and CSPK sourced as IP and SG is 47.20%.

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

[Externally verified] The company states that it has achieved 100% ISPO certification for its Indonesian mills. The company provides a zip file with all ISPO certificates.

52. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company's Malaysian estates and mills are 100% MSPO certified.

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

[Externally verified] ISCC Certification and Sustainable Agriculture Standard.

54. Commitment to zero conversion of natural ecosystems?

The company reports its commitment to zero conversion of natural ecosystems.

55. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to no deforestation.

56. Commitment to zero deforestation applies to all suppliers?

The company commits its suppliers to no deforestation.

57. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports to no development of HCS and peat areas with a cut-off date as 2020.

58. Evidence of monitoring deforestation?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to have co-financed Global Forest Watch's Radar for Detecting Deforestation (RADD) and in 2019, it introduced Crosscheck, an open access public domain tool that gives access to information about company's supply chain and helps provide transparency by tracking supply to its source, identifying where problems exist, and enabling action that is clearly outlined in its ?Working with Suppliers to Draw the Line on Deforestation' policy statement.

59. Evidence of monitoring deforestation in supplier operations?

The company has launched Crosscheck 2.0, with which it continues to make headway in its efforts to promote a deforestation-free supply chain through enhanced traceability functions. However, the information is not externally verified.

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

0 - The company reports that 0 heacters of illegal/non-compliant deforestation have occurred since 2015.

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

29673 - The company reports that 29,673 ha of potential forest and peatland clearing have occurred between 2015 and August 2021.

62. Commitment to restoration of non-compliant 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 (99.36%) and a further commitment to be 100% certified by 2022.

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

The company's ?Working with Suppliers to Draw the Line on Deforestation' policy statement commits its suppliers to develop a plan for remediating the damaged forest in the event of a violation of the company's NDPE standards. However, a cut-off date is not reported.

64. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company has collaborated with other stakeholders on a pilot jurisdictional project in the Malaysian states of Sabah to certify all palm oil output to the standards of the Roundtable of Sustainable Palm Oil (RSPO) by 2025. The has been externally verified by the TFA. As only one example could be found, partial points have been awarded.

65. Biodiversity policy?

66. Biodiversity policy applies to all suppliers?

67. 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.

68. 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 having a project on 'Restoration & Protection of Orangutan Habitats' which was completed in December 2018. The company reports collaboration with Yayasan Sime Darby, Management and Ecology of Malaysian Elephants (MEME), University of Nottingham Malaysia (UNM) to conduct a research and obtain information Human Elephant Conflict (HEC) found in its Malaysian operations from 2011 to 2018. The company also has an ongoing project on 'Conserving the Queen Alexandra's Birdwing Butterfly'. The company runs a Plant-A-Tree (SDP Plant-A-Tree) programme which seeks to enhance and restore the potential habitats within its estates and ensure the biodiversity richness of its forests.

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

The company prohibits hunting within its operations.

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

The company commits its suppliers to no illegal hunting but do not have a commitment to no hunting of all species.

71. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to conduct High Conservation Value (HCV) assessments.

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

The company commits its suppliers to conduct High Conservation Value (HCV) assessments.

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

[Externally verified] HCV assessments are available for the following : NBPOL Poliamba Limited - Lamawan, PNG, NBPOL Poliamba Limited - Lamendauen, PNG; New Britain Palm Oil Limited - Higaturu Oil Palm and Impu and Sagu Area of Interest, Markham District, Morobe Province, PNG, New Britain Palm Oil.

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

[Externally verified] HCV assessments are available for NBPOL ? WNB ? New Planting Procedure Report; HCV, NBPOL Tararan / Zifasing New Development, Indonesia; Integrated High Conservation Value / High Carbon Stock Approach Assessment Report Markham Valley ? Papua New Guinea New Britain Palm Oil Limited; Sime Darby Plantation Berhad - NBPOL (Poliamba Limited); New Britain Palm Oil (A Subsidiary of Sime Darby Plantation Bhd.) - Guadalcanal Plain Palm Oil Ltd.; New Britain Palm Oil Ltd - Higaturu Oil Palms; New Britain Palm Oil Ltd - Ramu Agri Industries Limited; Tivingau ILG Integrated HCV/HCSA assessment.

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

[Externally verified] HCV management and monitoring plans are available for NBPOL ? WNB ? New Planting Procedure Report; HCV, NBPOL Tararan / Zifasing New Development, Indonesia; Integrated High Conservation Value / High Carbon Stock Approach Assessment Report Markham Valley ? Papua New Guinea New Britain Palm Oil Limited; Sime Darby Plantation Berhad - NBPOL (Poliamba Limited); New Britain Palm Oil (A Subsidiary of Sime Darby Plantation Bhd.) - Guadalcanal Plain Palm Oil Ltd.; New Britain Palm Oil Ltd - Higaturu Oil Palms; New Britain Palm Oil Ltd - Ramu Agri Industries Limited; Tivingau ILG Integrated HCV/HCSA assessment.

76. 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 (99.36%) and a further commitment to be 100% certified by 2022.

77. 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 reports that it ""engages ALS Assessors for HCV Assessment or Integrated HCV ? HCS Assessment for all new planting activities under RSPO New Planting Procedure (NPP)"". This commitment is extended to all suppliers.

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

[Externally verified] Satisfactory review of: Integrated HCV-HCS Markham Valley ? Papua New Guinea New Britain Palm Oil Limited; HCV, NBPOL Tararan / Zifasing New Development, Indonesia, NBPOL ? WNB ? New Planting Procedure Report and Tivingau ILG Integrated HCV/HCSA assessment are available.

79. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to High Carbon Stock (HCS) Approach.

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

The company commits its suppliers to the High Carbon Stock (HCS) Approach.

81. High Carbon Stock (HCS) assessments available?

[Externally verified] Integrated HCV-HCS assessments of Ramu Agri Industries Ltd (Zifasing and Tararan); West New Britain, Papua New Guinea- NPP Areas and Tivingau ILG are publicly available on the HCSA database.

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

The company has one assessment on the HCSA website, Bomi & Gbarpolu, Blocks K, D and F, it is not peer reviewed.

83. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to conduct social and environmental impact assessments (SEIAs).

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

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

[Externally verified] Social and environmental impact assessment of New Britain Palm Oil Ltd - Higaturu Oil Palms is publicly available on the RSPO NPP database.

86. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to no planting on peat, regardless of depth.

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

The company commits its suppliers to no planting on peat, regardless of depth.

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

32797 - The company reports its existing landbank on peat as 32,797 ha. Data as of December 2020.

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

The company reports the figures for its landbank on peat in 2019 as 32,797.28 ha and in December 2020 as 32,797 ha. There is no increase in the company's landbank on peat, however, the information reported is not externally verified.

90. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to best management practices for soils and peat.

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

The company only commits its suppliers to best management practices for peat.

92. 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 reports to employ best management practices (BMPs) to maximise the utilisation of peatlands without causing any environmental problems. This includes monitoring of water level, fire incidents and maintaining existing vegetations in and adjacent to its oil palm plantations. The company also engages with local communities to educate them on sustainable management of peat areas in an effort to prevent slash and burn activities.

93. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to zero burning.

94. Commitment to zero burning applies to all suppliers?

The company commits its suppliers to zero use of fire for land preparation.

95. 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 reports using satellite data to monitor hotspots, as part of its surveillance of fire occurrences in its estates as well as neighbouring areas. The company also reports to have firefighting teams at all estates. For the management of fires, the company reports to conduct corrective action awareness and education programs with surrounding villages as well as company employees and dependents. Some areas where re-occurrences of fires are sighted, signages are also erected to inform people of the high risk of fire. In Ramu Agri Industries (where 57% of the fires occurred in 2020), monitoring towers were erected in the sugar cane fields and security personnel posted at the towers.

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

The company states that 2,445 potential fires were detected of which 255 (10.43%) fires were within the company concession areas.

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

2190 - The company reports the total number of fires outside its concession areas as 2190(89.57%).

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

The company reports that it has committed to a 2030 target for reducing its carbon emissions intensity by 40% against a 2009 baseline.

99. GHG emissions intensity?

The company reports its carbon emission intensity in 2020 as 1.01 tCO2-e/mt of CPO produced.

100. GHG emissions from land use change?

The company reports its 'Total Land Use Change Carbon Emissions (tCO2e)' as 637,483.68 in 2020.

101. Progress towards commitment to reduce GHG emissions intensity?

The company reports that its carbon emission intensity has reduced 4.7% to 1.01 tCO2 -e/mt of CPO produced in 2020 as compared to 1.06 tCO2-e/mt of CPO produced in 2009, which is its baseline year. However, the information reported is not externally verified.

102. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company's own reporting mentions that its uses the Roundtable on Sustainable Palm Oil (RSPO)PalmGHG calculator version 3 and the Greenhouse Gas (GHG) Protocol accounting standard to calculate GHG emissions.

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

The company reports that as of 2020, 11 of its mills have been installed with biogas plants to capture methane.

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

The company has a target to reduce its water usage to 1.0 m3 per tonne of FFB produced by 2023.

105. Water use intensity?

1.4 - The company reports water use intensity in 2019 as 1.40 m3 per tonne of FFB.

106. Progress towards commitment on water use intensity?

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

The company has limited the use of BOD according to the legal limits of Malaysian region. However, time bound commitment to improve water quality is not reported.

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

The company's reporting reflects that some regions of its Malaysian operations comply with legal limits of BOD of water discharge and land application. However, this information does not cover all operations of the company.

109. 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 reports that it has introduced new technologies for the efficient treatment of industrial wastewater in 2019 and 2020. Patent applications have been filed in Malaysia, Indonesia and Thailand on the process for treating palm oil mill effluent using electro oxidation means and in Malaysia on the process for treating vegetable oil refinery effluent using electro-oxidation means.

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

111. 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 99.36%) and a further commitment to be 100% certified by 2022. The company also reports to maintain riparian zones following the requirements by Roundtable on Sustainable Palm Oil (RSPO) and the HCV Resource Network for all HCV assessments of its land concessions.

112. 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. The company reports to have planted 69,911 trees as a part of its riparian and coastal reforestation in Papua New Guinea.

113. 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 99.36%) and a further commitment to be 100% certified by 2022. The company also makes this commitment independently.

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

The company commits to the reduction of the use of pesticide and fertilisers. This applies to suppliers.

115. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to no use of paraquat, unless in exceptional circumstances, as validated by a due diligence process, or when authorised by government authorities for pest outbreaks.

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

The company commits its suppliers to no use of paraquat, unless in exceptional circumstances, as validated by a due diligence process, or when authorised by government authorities for pest outbreaks.

117. 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 99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits its suppliers to no use of World Health Organisation (WHO) Class 1A and 1B pesticides.

119. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention.

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

The company commits its suppliers to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention.

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

The company provides a list of chemicals used and KG A.I./HA/YR. This information is undated so cannot be scored.

122. 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 reports composting empty fruit bunches (EFB), palm oil mill effluent (POME) as well as boiler ash, and use the end product to fertilise the fields as part of its efforts to reduce mineral fertiliser usage.

123. Integrated Pest Management (IPM) approach?

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

124. 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 reports practicing composting as a part of its mill waste management since 2004 and also has a waste management system in place.

125. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports to adhere to the Universal Declaration for Human Rights and the United Nations Guiding Principles on Business and Human Rights.

126. Commitment to human rights applies to all suppliers?

The company commits its suppliers to respect, support and uphold fundamental human rights as expressed, amongst others, in the Universal Declaration for Human Rights and the United Nations Guiding Principles on Business and Human Rights.

127. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to have a 'Human Rights Charter', administered by the group's 'Human Rights Task Force' which is accountable to the 'Sustainability Committee'. It outlines company's commitment to the management and governance of actions to uphold human rights across its operations and continues to form an essential part of its employees training materials. The company also has a 'Human Rights Due Diligence programme', under which mills and estates undergo an independent audit process to ensure compliance with human rights considerations and certifications to mitigate forced labour vulnerabilities. In March 2021, the company appointed Impact Ltd (Impact), an ethical trade consultancy with specific expertise in detecting and remediating force labour issues in company supply chains, to undertake a human rights assessment of its operations and verify its internal findings.

128. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to respect the legal, customary or user rights of local communities and indigenous peoples, including their right to land-use and right to self-determination.

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

The company commits its suppliers to respect the legal, customary or user rights of local communities and indigenous peoples, including their right to land-use and right to self-determination.

130. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to respect the legal, customary or user rights of local communities and indigenous peoples, including their right to land-use and right to self-determination.

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

The company commits its suppliers to respect the legal, customary or user rights of local communities and indigenous peoples, including their right to land-use and right to self-determination.

132. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to undertake robust free, prior and informed consent (FPIC) processes prior to any new development.

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

The company commits its suppliers to undertake robust free, prior and informed consent (FPIC) processes prior to any new development.

134. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company has also published its own FPIC process on its website.

135. Examples of local stakeholder engagement to prevent conflicts?

136. 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 (99.36%) and a further commitment to be 100% certified by 2022.

137. 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. The company reports to have 'Female Manager Development Programme', with the aim of accelerating opportunities for women to lead and manage estates and mills in the company.

138. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to developing land in a manner which promotes food security and the enhancement of livelihoods to address the needs of the community.

139. 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.

140. 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 99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to provide essential community services and facilities.

141. 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 its progress on commitment to provide essential community services and facilities.

142. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company reports that it aims to support the livelihoods of local communities through job opportunities, economic growth and alternative livelihood training.

143. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to all Fundamental ILO Conventions.

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

The company commits its suppliers to all Fundamental ILO Conventions.

145. 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.

146. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to eliminate gender related discrimination with regards to employment.

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

The company commits its suppliers to eliminate gender related discrimination with regards to employment.

148. 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 reports to have collaborated with Women's Aid Organisation (WAO) which develops an improved Women's Safety Framework and contains key components targeted at inculcating a diverse and inclusive workplace culture through gender audits, gender sensitivity training for managers and trainings for Gender Representatives. The company also has a gender committee in place and in 2019, it has published a revised sexual harassment policy which sets out robust reporting procedures and prescribed courses of action to remediate issues pertaining to sexual and physical violence.

149. Percentage or number of temporary employees?

5% - The company reports 5% temporary employees as of December 2020.

150. Percentage or number of women employees?

20% - The company reports that as of December 2020, an average of 20% of its workforce are female.

151. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to providing decent and fair wages.

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

The company commits its suppliers to providing decent and fair wages.

153. 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.

154. Reporting of salary by gender?

155. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to providing a safe and healthy working environment.

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

The company commits its suppliers to providing a safe and healthy working environment.

157. 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.

158. Time lost due to work-based injuries?

8.4 - The company reports that it has reported a Loss Time Injury Frequency Rate (LTIFR) of 8.4 for FY2020, indicating that 8.4 loss time injuries occurred within the company's workplaces for every million hours worked. This marks a 26% reduction compared to the previous year.

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

6 - The company reports six (6) occupational fatalities (Class 1 Accidents) and a fatality rate (FAR) of 2.9 for FY2020, which indicates a total of 2.9 fatality cases for every 100 million hours worked. This represents a 4% increase in FAR from FY2019 despite the same number of recorded fatality cases.

160. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to support smallholders.

161. Programme to support scheme/plasma smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to provide support on financial insecurity, resource scarcities, and infrastructure gaps that prevent the smallholders from gaining access to markets or producing enough quality product to earn sufficient income.

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

61719 - The company reports to have a total of 61,719 smallholders in its entire supply chain across Papua New Guinea, Indonesia and Malaysia, as of 2020. However, it is unclear whether these figures refer to scheme smallholders only, or include independent smallholders as well.

163. Programme to support independent smallholders?

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

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

61719 - The company reports to have a total of 61,719 smallholders in its entire supply chain across Papua New Guinea, Indonesia and Malaysia, as of 2020. However, it is unclear whether these figures refer to independent smallholders or includes scheme smallholders as well.

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

The company provides the details on the process used to prioritise, assess and engage suppliers on compliance with company's policy.

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

The company states that 100% of its supplying mills are assessed for compliance to NDPE requirements via the NDPE Implementation Reporting Framework.

167. Suspension or exclusion criteria for suppliers?

The company states that in the event of the violation of NDPE standards, it will stop work immediately on the affected land, develop a plan for remediating the damaged forest, and develop a program to improve its ongoing operational practices to meet NDPE standards. If the supplier concerned is unwilling to make these commitments, it is the policy to suspend them. Once a supplier has been suspended, purchases will not resume until respective conditions are met.

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

The company only reports that re-engagement of suppliers will include development within 2 months of time-bound plans for the recovery of High Carbon Stock (HCS) and High Conservation Value (HCV) forests and/or peatland cleared, plus agreement not to use the area cleared for commercial production, development within 2 months of NDPE policies and time-bound implementation plans for operational improvement to meet those standards, covering their group-wide operations. However, KPIs are not reported by the company.

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

The company's global NDPE IRF profile reports that 71% of mills are 'delivering' on deforestation progress and 87% are 'delivering' on peat progress.

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

The company does not has a clear commitment on this, but reports in its 2019 sustainability report that 61 high-risk mills had been identified as of December 2019, and that all of these have been or are being engaged with (or have been removed from the supply chain).

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

The company states that in the event of supplier suspension, it will resolve the issues through constructive engagement, and it outlines steps a non-compliant company must take, but it is not clear exactly how the company supports these suppliers on working on these steps towards compliance. The company stated an intention to "deliver the supplier improvement programme starting in January 2020", which includes "Designing the steps required to progress towards meeting NDPE standards" in collaboration with Conservation International and Aidenvironment, but detail on what this support programme involves was not found.

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

The company states that 61 high-risk mills were identified and engaged as of December 2019 and that they engage with key/high-risk suppliers on a monthly basis to ensure compliance and investigate non-conformances.

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

The company uses its Crosscheck platform which maps its own and third-party mills, classifying them as high, medium or low risk using monthly reports from Aidenvironment on potential occurrences of deforestation and peat clearing.

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

The company receives monthly reports from Aidenvironment on potential occurrences of deforestation and peat clearing, which are used to classify risk-level of own and supplying mills.

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

The company receives monthly reports from Aidenvironment on potential occurrences of deforestation and peat clearing, which are used to classify risk-level of own and supplying mills and which are displayed on Crosscheck. The company states that it has identified 61 high-risk mills.

176. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also reports its own commitment to ethical conduct and prohibition of corruption.

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

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

178. 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 has an 'Anti-Corruption Management System' in place which is a manifestation of its zero-tolerance policy against all forms of bribery and corruption.

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

180. 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 (99.36%) and a further commitment to be 100% certified by 2022. The company also has a whistleblowing policy in place.

181. 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 99.36%) and a further commitment to be 100% certified by 2022. The company also has its own grievance mechanism open to all stakeholders.

182. Details of complaints and grievances disclosed?

The company has published a detailed supplier grievance register which is inclusive of date, issue, complainant category, actions taken, and status.