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Sime Darby Plantation Sdn Bhd

Palm oil assessment
  • Latest update: November 2023
  • Next scheduled: November 2024

  • About this company:

    Established in 1910, Sime Darby Plantation's major business

  • Landbank (oil palm)
    668,980 hectares
  • Market cap:
    6,709,200,000 USD
  • Thomson Reuters ticker:
    SIPL.KL
  • Bloomberg ticker:
    SDPL MK Equity
  • LEI:
    No LEI
  • RSPO member?
    Yes
  • Website:
  • Media Monitor
    • ZSL's SPOTT team monitors international media for news on assessed companies, collecting articles about pertinent activities. They don't confirm the accuracy of the media coverage, but it can be leveraged by SPOTT users to gain insights into a company's operations and possible risks. To access this company's media reports, scroll down or click here.

Company assessment: Sime Darby Plantation Sdn Bhd – November 2017

Assessment date:

Total: 77.6% 97 / 125
  • Sustainability policy and leadership Sustainability policy and leadership
    6 / 6 100%
    • Y
      1 / 1

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

      Sime Darby Responsible Agriculture Charter.

    • Y
      1 / 1

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

      The Responsible Agriculture Charter covers all of its palm oil operations, both upstream and downstream but the Full Charter commitments will not be implemented for third party suppliers until 2018.

      The Responsible Sourcing Guidelines apply to all suppliers and is in force.

    • Y
      1 / 1

      3. High-level position of responsibility for sustainability?

      The Managing Director heads the Plantation Sustainability Committee and is a member of the Group Management Sustainability Committee which reviews overall sustainability direction.

    • Y
      1 / 1

      4. Sustainability report published within last two years?

    • Y
      1 / 1

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

      The company states that is member of the UN Global Compact and signatory to New York Declaration on Forests, they are also members of WBCSD, TFA 2020, HCV Resource Network and the Fire Free Alliance.

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

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

    • Y
      1 / 1

      7. Activities with government and/or NGOs to improve palm oil sustainability?

      The company states that it engages with all stakeholders, including government, regulators, NGOs, and communities, and gives examples of projects through Yayasan Sime Darby (YSD), its philanthropic arm, and on managing wildlife conflicts.

  • Landbank, maps and traceability Landbank, maps and traceability
    14.5 / 19 76.3%
    • Y
      1 / 1

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

      786695 - The company has a total landbank of 988,599 ha - includes other crops including rubber and cane plantations. The company reports a total land area for oil palm cultivation as 624,360.84 in its 2016 ACOP (which excludes its subsidiary NBPOL) and 162,334 is reported in NBPOL's 2016 ACOP = 786,694.84 ha.
      .

    • Y
      1 / 1

      9. Total oil palm planted area (ha)?

      609968 - Sime Darby Plantations reports a figure of 518,074 ha in its 2016 ACOP (which excludes its subsidiary NBPOL), and NBPOL reports a planted area of 91,894 ha. It also reports a total planted palm oil area of 603,254 ha in its 2016 Sustainability Report.

    • Y
      1 / 1

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

      92447 - The company also reports a figure of 45,000 ha in its 2016 sustainability report, however this is less than the amount the company states is RSPO certified under plasma (51,715 ha) in its 2016 ACOP. Also includes New Britain Palm Oil Ltd.'s associated smallholders, a subsidiary of Sime Darby, of 40,732 ha.

    • Y
      1 / 1

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

      10382 - Sime Dary reports 0 ha unplanted in its 2016 ACOP, and NBPOL reports 10,382 ha.

    • Y
      1 / 1

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

      52096.8 - This figure is the sum of Sime Darby Plantations and NBPOL's conservation area as stated in their 2016 ACOP's respectively. Sime Darby also reports a figure of 31,793 in its 2016 annual report, however this does not include NBPOL's operations.

    • N
      0 / 1

      13. Area for infrastructure (ha)?

    • Y
      1 / 1

      14. Number of company owned mills?

      71 - The company also reports in its 2016 ACOP that it has 59 mills and New Britain Palm Oil reports a figure of 11 mills.

    • Y
      1 / 1

      15. Maps or coordinates of company owned mills?

      All Malaysia, Indonesia, PNG, Solomon Islands and Liberia mills are available on OpenPalm traceability dashboard.

    • N
      0 / 1

      16. Number and names of supplier mills?

      The company states that information on supplying oil palm mills is available in its Open Palm traceability dashboard, but this is only available to key clients.

    • Y
      1 / 1

      17. Maps of estates/management units?

      Concession boundaries have been made available to the RSPO and the company declares these represent 100% of their concession sites, but not all may not be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO.

    • N
      0 / 1

      18. Maps of scheme/plasma smallholders?

    • P
      0.5 / 1

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

      2020 - The company states it is working towards a fully segregated RSPO certified supply chain in its Responsible Agriculture Charter - the Charter will be implemented by 2020.

    • P
      0.5 / 1

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

      2020 - The company states it is working on "ensuring that FFB processed by our mills are traceable to our own estates and plasma smallholders" in its Responsible Agriculture Charter - the Charter will be implemented by 2020. However, the traceability to plantation commitment does not state 100% and does not include other suppliers that are not plasma smallholders.

    • Y
      2 / 2

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

      97.8% - The company states that CPO is 97.8% traceable and palm kernel is 100% traceable to the mill.

    • Y
      2 / 2

      22. Percentage of fresh fruit bunches (FFB) from own mills traceable to plantation level (is above 75%)?

      86.6%

    • P
      1.5 / 2

      23. Percentage of fresh fruit bunches (FFB) from supplier mills traceable to plantation level (is above 75%)?

      The company states that CPO is 65.1% traceable and palm kernel is 82.7% traceable up to plantation.

  • Deforestation and biodiversity Deforestation and biodiversity
    9.5 / 12 79.2%
    • Y
      0.5 / 0.5

      24. Commitment to address deforestation?

    • Y
      1 / 1

      25. Commitment to zero deforestation?

    • P
      0.5 / 1

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

      The company states that the full Charter commitments will be implemented by 2018 for all palm oil 3rd party suppliers.

    • Y
      1 / 1

      27. Criteria for defining deforestation?

      Intact forest landscapes, primary forest, HCV, HCS, Peat.

    • N
      0 / 1

      28. Evidence of monitoring deforestation?

    • Y
      1 / 1

      29. Commitment to set aside areas for conservation?

    • Y
      1 / 1

      30. Evidence of habitat management and/or habitat restoration?

      The company lists biodiversity conservation projects including its Plant-A-Tree Programme and restoration and protection of orangutan habitats.

    • Y
      1 / 1

      31. A landscape-level approach?

      The company commits to take into account landscape planning at a regional level for new developments and to adopt an enrichment landscape approach.

    • Y
      0.5 / 0.5

      32. Commitment to biodiversity conservation?

      The company states "We are committed to protect the environment and conserve biodiversity in all our areas of operation".

    • P
      0.5 / 1

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

      The company has a "Saving the Orangutan Policy" that includes protection and conservation of endangered and protected species, but it does not refer to a system of species classification.

    • Y
      1 / 1

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

      The company states that its efforts to reduce the biodiversity risk of its operations include no hunting within its operations.

    • P
      0.5 / 1

      35. Commitment not to operate within internationally and nationally designated protected areas?

      The company states its commitment to "Safeguarding the cultural and spiritual values of identified and/or protected areas" and its Sustainability Committee Terms of Reference states "respect legally designated protected areas", but it does not have a clear commitment to not operate in all types of protected areas.

    • Y
      1 / 1

      36. Evidence of species conservation activities?

      The company reports it is managing human-wildlife conflict. The company also states a number of conservation and biodiversity projects through Yayasan Sime Darby (YSD), the company's philanthropic arm.

  • HCV, HCS and impact assessments HCV, HCS and impact assessments
    6 / 7 85.7%
    • Y
      1 / 1

      37. Commitment to High Conservation Value (HCV) approach?

    • P
      0.5 / 1

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

      Sime Darby's Responsible Agriculture Charter currently applies to all its palm oil operations, including associated smallholders. It plans for Full Charter commitments to be implemented for 3rd party suppliers in 2018.

    • P
      0.5 / 1

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

      The company does not have an explicit commitment, but commits under RSPO NPP.

    • Y
      1 / 1

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

      There is public availability of the following HCV assessments:
      Liberia: Grand Cape Mount County, Bomi County and Gbarpolu County.

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

      This indicator is disabled as no new planting reported in 2015 or 2016 RSPO ACOP.

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

      This indicator is disabled as no new planting reported in 2015 or 2016 RSPO ACOP.

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

      This indicator is disabled as no new planting reported in 2015 or 2016 RSPO ACOP.

    • Y
      1 / 1

      44. Commitment to the High Carbon Stock (HCS) approach?

      The company states that it will conduct robust assessment of High Carbon Stock (HCS) prior to new plantings and "For HCS methodologies we will combine the outputs from the HCS Science Study and the High Carbon Stock Approach".

    • 45. High Carbon Stock (HCS) assessments?

      Indicator disabled as no new planting as reported in 2016 RSPO ACOP. The company only states that it is undertaking trials of HCS+ Approach in its operations in Liberia.

    • Y
      1 / 1

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

      The company states that it undertakes Social & Environmental Impact Assessments (SEIA) as a standard operating procedure before any development begins.

    • Y
      1 / 1

      47. Social and environmental impact assessment (SEIAs) undertaken, and associated management and monitoring plans?

      There is public availability of the following SEIA assessments:
      Liberia: Grand Cape Mount County, Bomi County and Gbarpolu County.

  • Peat, fire and GHG emissions Peat, fire and GHG emissions
    12.5 / 17 73.5%
    • Y
      1 / 1

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

    • P
      0.5 / 1

      49. Peat commitment applies to scheme smallholders and independent suppliers?

      Sime Darby's Responsible Agriculture Charter currently applies to all its palm oil operations, including associated smallholders. It plans Full Charter commitments to be implemented for 3rd party suppliers in 2018.

    • Y
      1 / 1

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

    • N
      0 / 1

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

    • Y
      1 / 1

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

    • Y
      1 / 1

      53. Commitment to zero burning?

    • P
      0.5 / 1

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

      Sime Darby's Responsible Agriculture Charter currently applies to all its palm oil operations, including associated smallholders. It plans for Full Charter commitments to be implemented for 3rd party suppliers in 2018.

    • Y
      1 / 1

      55. Evidence of management and monitoring fires?

    • Y
      1 / 1

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

    • Y
      1 / 1

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

    • Y
      1 / 1

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

      2020 (40%) - The company states that it has a target to reduce emissions by 40% by 2020 against a 2009 baseline.

    • P
      0.5 / 1

      59. GHG commitment applies to scheme smallholders and independent suppliers?

      Sime Darby's Responsible Agriculture Charter currently applies to all its palm oil operations, including associated smallholders. It plans Full Charter commitments to be implemented for 3rd party suppliers in 2018.

    • Y
      1 / 1

      60. GHG emissions?

    • N
      0 / 1

      61. GHG emissions from land use change?

      The company states that its carbon emissions calculation currently do not include emissions from land use conversion and carbon sequestration from growth of oil palm trees. The methodology around this area is still under evaluation as it is regarded as highly controversial. However, once they are included, the total emissions of the Group may differ significantly and will require a restatement of the carbon baseline. Sime Darby plans to include the calculations in its public reporting once evaluations on the appropriate methodology to be adopted has been finalised.

    • Y
      1 / 1

      62. Methodology used to calculate GHG emissions?

      WRI GHG Protocol - (internalised using its Sustainability Management System (SMS)), PalmGHG Tool.

    • P
      0.5 / 1

      63. Progress towards commitment to reduce GHG emissions?

      The company states "The absolute carbon emissions increased by 21% from last year, mainly due to the inclusion of operating units in Liberia, Papua New Guinea and Solomon Islands. Excluding these operations, the absolute emissions recorded a slight decrease of 1.1%".

    • P
      0.5 / 1

      64. Percentage of mills with methane capture (is above 75%)?

      The company states it has at least 2 biogas plants operational, with 17 more due to be completed by 2015 and an additional 9 planned for 2016.

  • Water, chemical and pest management Water, chemical and pest management
    8.5 / 12 70.8%
    • Y
      1 / 1

      65. Time-bound commitment to improve water use?

      The company has a target to reduce its water usage by 25% from the baseline by 2020.

    • P
      0.5 / 1

      66. Time-bound commitment to improve water quality?

      The company only has a commitment to "Minimising the impact of all our polluting activities and monitoring and treating effluents from plantations, mills and refineries as part of our total water accountability programmes".

    • N
      0 / 1

      67. Progress towards commitment on water use?

    • N
      0 / 1

      68. Progress towards commitment on water quality?

    • Y
      1 / 1

      69. Protection of natural waterways through buffer zones?

    • Y
      1 / 1

      70. Evidence of treating palm oil mill effluent (POME)?

    • Y
      1 / 1

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

    • Y
      1 / 1

      72. No use of paraquat?

    • Y
      1 / 1

      73. No use of World Health Organisation (WHO) Class 1A and 1B pesticides?

    • Y
      1 / 1

      74. No use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

    • Y
      1 / 1

      75. Integrated Pest Management (IPM) approach?

    • N
      0 / 1

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

  • Community, land and labour rights Community, land and labour rights
    15.5 / 18 86.1%
    • Y
      1 / 1

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

    • Y
      1 / 1

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

    • Y
      1 / 1

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

      The company states it protects and respects the rights of communities living within and around our operations, and refers to the UN Declaration of Rights of indigenous People in relation to FPIC.

    • Y
      1 / 1

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

    • N
      0 / 1

      81. FPIC commitment applies to independent suppliers?

      The company states that the full Charter commitments will be implemented by 2018 for all palm oil 3rd party suppliers.

    • Y
      1 / 1

      82. Free, prior and informed consent (FPIC) process?

    • P
      0.5 / 1

      83. Process for addressing land conflicts?

      The company only states that the company respects right to land through establishing effective conflict resolution frameworks, which are communicated to all relevant stakeholders, including effective access to advocates and to remedy with a resolution and that it has "established clear guidelines on resolving boundary disputes" but no further details are given.

    • Y
      1 / 1

      84. Commitment to ensure food security for local communities?

      The company states that it is committed to developing land in a manner which enhances rather than jeopardises local food security in relation to empowering local communities.

    • Y
      1 / 1

      85. Commitment to respect all workers' rights?

      The company states that it protects labour standards and implements them for both employees and contractors.

    • Y
      1 / 1

      86. Reference to Fundamental ILO Conventions or Free and Fair Labour Principles?

      The company states that it seeks to implement International Labour Organization (ILO) core labour standards and conventions, as well as the Fair and Free Labour Principles For Oil Palm.

    • Y
      1 / 1

      87. Total number of employees?

      102551

    • N
      0 / 1

      88. Percentage or number of temporary employees?

    • Y
      1 / 1

      89. Percentage or number of women employees?

      The company provides the number of male and female workers by country and by employee category.

    • Y
      1 / 1

      90. Minimum wage that the company pays?

    • Y
      1 / 1

      91. Commitment to address occupational health and safety?

    • Y
      1 / 1

      92. Lost time accident rate?

      9.3 incidents per million man-hours worked.

    • Y
      1 / 1

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

      13 - The company reports 13 fatalities in the last financial year and a fatal accident rate of 2.0 for every 100 million hours worked.

    • Y
      1 / 1

      94. Provision of personal protective equipment and pesticide training?

      The company states that safety and health of its workers is ensured with the provision of protective equipment, preventive training and the inculcation of safety culture among all its employees, and it conduct safe chemical handlings trainings.

  • Certification standards Certification standards
    13.5 / 18 75%
    • Y
      1 / 1

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

      2004 - Sime Darby has been a member since 2004. Subsidiaries Sime Darby Unimills has been an RSPO member since 2007 and New Britain Palm Oil Ltd (NBPOL) has been an RSPO member since 2004.

    • Y
      0.5 / 0.5

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

    • N
      0 / 0.5

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

      Sime Darby states its operations in Indonesia, Malaysia and Liberia, and states all relevant regions in which it operates in these countries. The company does not state its operations through New Britain Palm Oil Ltd (NBPOL) in Papua New Guinea and the Solomon Islands.

    • Y
      0.5 / 0.5

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

      2017 - An original target for 100% certification of estates of 2011 was extended to 2014, and then to 2015, 2016 and 2017.

    • Y
      0.5 / 0.5

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

      2020 - An original target of 2015 was extended to 2020, and then brought forward to 2019, then extended to 2020 again.

    • Y
      0.5 / 0.5

      100. Time-bound plan for achieving 100% RSPO certification of all supply chains?

      2025 - For Sime Darby Unimills.

    • Y
      0.5 / 0.5

      101. 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?

      2008

    • Y
      2 / 2

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

      68 (95.8%) - Sime Darby Plantations reports a number of 57 certified mills in in its 2016 ACOP (one less than it reports in its 2015 ACOP) and NBPOL reports a figure of 11 in its 2016 ACOP.

    • Y
      2 / 2

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

      780649 (99.2%) - According to the company's 2016 ACOPs, they have a total certified area of 780,649 ha (total area RSPO-certified reported for Sime Darby and NBPOL = 624,854 + 155,795 ha).
      .

    • Y
      2 / 2

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

      70645 (76.4%) - Land certified under scheme/associated smallholders (29,913 ha for Sime Darby + 40,732 ha for NBPOL) divided by total land under scheme/associated smallholders.

    • N
      0 / 2

      105. Percentage of FFB supply (tonnes) from independent FFB suppliers that is RSPO-certified (is above 75%)?

    • P
      1 / 2

      106. Percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that are RSPO-certified (is above 75%)?

      The company only provides data only for Sime Darby Unimills . It is unclear what the total amount handled/processed/traded by Sime Darby is. All the palm oil and oil palm products handled/traded/processed by Sime Darby Unimills are RSPO-certified.

    • Y
      1 / 1

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

      Book & Claim, Mass Balance, Segregated, Identity Preserved.

    • P
      0.5 / 1

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

      The company states that 12 of its SOUs in Indonesia have been ISPO certified, and the remaining 13 are undergoing different stages of verification.

    • P
      0.5 / 1

      109. Malaysia Sustainable Palm Oil (MSPO) certified (100%)?

      The company states Labu SOU has obtained MSPO certification.

    • Y
      1 / 1

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

      The company states that it has ISCC Certification.

  • Smallholders and suppliers Smallholders and suppliers
    6 / 9 66.7%
    • Y
      1 / 1

      111. Programme to support scheme smallholders?

    • Y
      1 / 1

      112. Details of support programme for scheme smallholders?

      The company states that is supports smallholders in achieving certification, increasing yields, improving agro-management practices and achieving sustainable practices.

    • P
      0.5 / 1

      113. Number or percentage of scheme smallholders involved in programme?

      The company states that the Kredit Koperasi Primer Anggota (KKPA) and Plasma schemes have impacted more than 25,000 families.

    • Y
      1 / 1

      114. Programme to support independent smallholders?

    • Y
      1 / 1

      115. Details of support programme for independent smallholders?

      The company is collaborating with Wild Asia to help smallholders achieve RSPO certification; as well as working on traceability, zero deforestation and zero burning commitments and committing to purchasing FFBs.

    • P
      0.5 / 1

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

      1,000 small producers have been identified in the area of the programme of whom 400 have so far been identified, but unclear how many supported to date.

    • Y
      1 / 1

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

      The company states it has developed Responsible Sourcing Guidelines and will implement these in three phases: identification of key suppliers and effective communication; identification of pre-qualified suppliers through desktop assessment; and verification and continuous engagement towards compliance.

    • N
      0 / 1

      118. Suspension or exclusion criteria for suppliers?

      The company states it will not engage third-party suppliers that do not comply with the mandatory requirements in its Responsible Sourcing Guidelines, but does not make the guidelines publicly available.

    • N
      0 / 1

      119. Number or percentage of suppliers assessed and/or engaged?

  • Governance and grievances Governance and grievances
    5 / 7 71.4%
    • Y
      1 / 1

      120. Commitment to ethical conduct and prohibition of corruption?

    • Y
      1 / 1

      121. Whistleblowing procedure?

    • Y
      1 / 1

      122. Own grievance or complaints system?

    • Y
      1 / 1

      123. Grievance system accessible to internal stakeholders (i.e. employees)?

    • Y
      1 / 1

      124. Grievance system accessible to external stakeholders?

      The company states "We aim to address any grievance or complaints by an employee or a third party" and also that they have implemented community grievances mechanisms.

    • N
      0 / 2

      125. Details of grievances disclosed?

Media monitor: Sime Darby Plantation Sdn Bhd

SPOTT monitors global media sources for coverage of assessed companies. The media monitor gathers reports about specific activities related to the assessment indicator categories. ZSL does not assess or score the validity of media coverage, but users can explore the media monitor to provide context on implementation, and infer risks associated with reported operations on the ground. The media monitor undergoes a full update at the time of publishing an assessment round, with ad-hoc updates throughout the year. This is not an exhaustive list of all media reports relevant to the company.

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