TSH Resources Bhd

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

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

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

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

3. High-level position of responsibility for sustainability?

The company reports that it has a head of ESG in a high-level position of responsibility for sustainability.

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

The company has established a sustainability steering committee chaired by the Group Managing Director, who is also a member of the board of directors.

5. Reports gender balance of senior management team?

18% - The company reports 18% of women in the management team. Data as of 2023.

6. Reports gender balance of board members?

11% - The company reports that it has 11% of women board members in 2023.

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

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

The company reports that in 2023, it conducted firefighting training in collaboration with the Indonesian Forest Fire Control Brigade. It also provides financial support, products, and training to scheme smallholders to help them develop businesses according to recognised sustainability standards.

9. Sustainability report published within last two years?

The company has a sustainability report in its Annual Report 2023.

10. Reports through standardised reporting systems?

The company's Annual Report 2023 has been prepared in accordance with GRI standards. However, it does not report the statement required by GRI.

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?

Malaysia - Sabah (Plantation, one mill), Indonesia - Kalimantan and Sumatera (Plantation, four mills).

14. Lists countries sourcing from?

The company states that it sources FFB from Malaysia and Indonesia. It does not report sourcing countries for its refineries.

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

80936.5 - The company reports its total land area managed for oil palm as 80,936.46 ha in its RSPO ACOP 2023.

16. Total oil palm planted area (ha)?

39068 - The company reports its total oil palm planted area as 39,068 ha in 2023.

17. Scheme smallholders planted area (ha)?

10478 - The company reports 10,478.05 ha of total land under scheme smallholders in its RSPO ACOP 2023.

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

20871.3 - The company reports 20,871.31 ha of unplanted area in its RSPO ACOP 2023.

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

10507.3 - The company reports 10,507.33 ha of total conservation set-aside area in its RSPO ACOP 2023.

20. Maps of estates/management units?

The company uploaded its estate location concession maps with its RSPO ACOP 2023 and declared that the map data submission represented 100% of its concession sites (both RSPO certified and uncertified).

21. Maps of all scheme smallholders?

22. Maps of all third-party supplying plantations?

23. Number of company-owned mills?

5 - The company reports that it has five palm oil mills.

24. Names and locations of company-owned mills?

The name and location of all company-owned mills are published on GFW.

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?

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

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

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

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

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

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

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

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

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

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

33. Percentage of supply traceable to mill level?

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

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

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

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

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

37. Publishes traceability data at refinery level?

38. Publishes traceability data at crusher level?

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

[Externally verified] 2014 - The company has been an RSPO member since 2014.

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?

[Externally verified] 2016 - The company joined the RSPO in 2014 and achieved its first certification in 2016.

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

The company submitted its most recent RSPO ACOP in 2023.

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

25.27% - The company reports that 25.27% of its area is RSPO-certified in its RSPO ACOP 2023.

43. Percentage of mills RSPO-certified?

60% - The company reports 60% of RSPO-certified mills in its RSPO ACOP 2023 and annual report 2023.

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

2025 - The company commits to achieve 100% RSPO certification of estates and mills by 2025. 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?

0% - The RSPO ACOP 2023 reports 0% land under scheme smallholders.

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

2026 - The company commits to achieve 100% RSPO certification of scheme/associated smallholders and outgrowers by 2026. 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 that 0% of FFB supply from independent smallholders, outgrowers and third-party FFB suppliers are 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?

The company sells 0% of 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 some of its operations are ISPO-certified. However, no ISPO certificates were available.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company has already achieved 100% MSPO certification for all of its Malaysian operations.

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

[Externally verified] The company has a valid ISCC certificate.

55. Commitment to zero conversion of natural ecosystems?

56. Commitment to zero conversion of natural ecosystems applies to all suppliers?

57. Commitment to zero deforestation?

The company commits to zero deforestation. However, this commitment was made after 1st Jan 2020.

58. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation. However, this commitment was made after 1st Jan 2020.

59. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

The company defines deforestation as removal of HCV and HCS areas and specifies any deforestation/conversion past 2020 will not be accepted.

60. Criteria and cut-off date for defining deforestation and/or ecosystem conversion in supplier operations?

The company defines deforestation for suppliers as removal of HCV and HCS areas and specifies any deforestation/conversion past 2020 will not be accepted in supplier operations.

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

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

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

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

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

65. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

66. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

67. Implementing a landscape or jurisdictional level approach?

68. Biodiversity policy?

The company has a general statement that commits to biodiversity protection with no detail given on its scope.

69. Biodiversity policy applies to all suppliers?

70. 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 reports that it has identified 68 species of flora and 110 species of fauna in accordance with the International Union for Conservation of Nature (IUCN).

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

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

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

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

73. 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.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also commits to conduct High Conservation Value (HCV) assessments in its own reporting.

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

The company commits all suppliers to conduct HCV assessments.

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

77. High Conservation Value (HCV) assessments for all estates planted/planned planting since January 2015?

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

78. High Conservation Value (HCV) or combined HCV/HCS management and monitoring plans for all estates planted/planned planting since January 2015?

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

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

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

80. 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?

81. 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.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also commits to apply the High Carbon Stock (HCS) Approach in its own reporting.

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

84. High Carbon Stock (HCS) assessments available?

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

85. 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 has not undertaken any new planting since January 2016.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also commits to conduct social and environmental impact assessments (SEIAs) in its own reporting.

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

The company commits all suppliers to conduct social and environmental impact assessments.

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

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also commits to no planting on peat of any depth in its own reporting.

90. 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.

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

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

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

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

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

95. 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.

96. Commitment to zero burning?

The company commits to zero burning.

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

98. 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 that it regularly conducts fire patrols to identify potential fire hazards and uses drones to detect fire hotspots. It also collaborates with the Indonesian Forest Fire Control Brigade to conduct fire fighting training.

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

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

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

102. GHG emissions intensity?

The company reports the GHG intensity as 1.15 tCO2 eq/MT CPO in 2023. However, figures do not clearly include at least scope 1 and scope 2 emissions.

103. GHG emissions from land use change in company's own operations (scope 1)?

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

104. GHG emissions from land use change in supplier operations (scope 3)?

105. Progress towards commitment to reduce GHG emissions intensity?

The company reports a decrease in GHG intensity from 2022 (1.20 tCO2 eq/MT CPO) to 2023 (1.15 tCO2 eq/MT CPO). However, figures do not clearly include at least scope 1 and scope 2 emissions.

106. Methodology used to calculate GHG emissions?

The company uses the RSPO Palm GHG calculator methodology to calculate GHG emissions.

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

The company reports that one out of five (20%) company-owned mills have methane capture.

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

The company only states a general commitment to improve its water use efficiency. However, no timebound commitment was found.

109. Water use intensity?

0.95 - The company reports its water use intensity as 0.95 m3 per MT of FFB processed in 2023.

110. Progress towards commitment on water use intensity?

The company reports a decrease in water use intensity from 2022 (1.12 m3 per MT of FFB) to 2023 (0.95 m3 per MT of FFB).

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

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

113. 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 POME is treated using an activated sludge system, which involves a multi-chamber reactor to enhance the quality of effluents before discharge.

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

115. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways through buffer zones.

116. 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.

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

The company commits to minimise the use of chemical fertilisers and pesticides.

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

The company commits all suppliers to minimise the use of chemical fertilisers and pesticides.

119. Commitment to no use of paraquat?

The company commits to not use paraquat.

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

The company commits all suppliers to not use paraquat.

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

The company commits to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

122. 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.

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

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

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

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

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

126. 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 also reports that palm oil waste such as empty fruit bunches is reused as organic mulch to reduce its dependence on inorganic chemical fertilisers.

127. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has implemented Integrated Pest Management (IPM) practices and provides evidence such as planting beneficial plants to attract predators of insect pests, use of baits, and natural predators of rodents like barn owls.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it collects and disposes of hazardous and scheduled waste at approved facilities through contractors licensed by the Malaysian DOE.

129. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

130. Commitment to human rights applies to all suppliers?

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

131. Progress on human rights commitment?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it conducts annual training on human rights for its employees. However, the information is two to five years old.

132. Commitment to respect Indigenous Peoples' and local communities' rights?

The company commits to the UN Declaration on the Rights of Indigenous Peoples.

133. Commitment to respect Indigenous Peoples' and local communities' rights applies to all suppliers?

The company commits suppliers to the UN Declaration on the Rights of Indigenous Peoples.

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

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

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

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

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

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

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

The company commits all suppliers to respect FPIC.

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

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

139. Examples of local stakeholder engagement to prevent conflicts?

The company states that it has conducted town hall meetings and community program meetings on issues, including land-related claims.

140. Details of process for addressing land conflicts available?

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has established a gender committee to promote gender equality and support women's rights in the workplace.

142. Commitment to mitigate impacts on food security?

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

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

144. Commitment to provide essential community services and facilities?

The company commits to provide essential community services and facilities.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it enhances the livelihood of its surrounding community through CSR activities, primarily focusing on donation drives to charitable hospitals, orphanages, and old folks' homes. It provides accessible education to local communities.

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

The company commits to provide work opportunities for local communities.

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

The company commits to the ILO's Declaration on Fundamental Principles and Rights at Work.

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

The company's policy applies to all suppliers but only commits to five Fundamental ILO Conventions.

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

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

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

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

151. 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.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it provides annual training to employees on equal opportunity and non-discrimination. However, the information is two to five years old.

153. Percentage or number of temporary employees?

4% - The company reported 4% of contractual employees in 2023.

154. Reports gender balance of employees?

1693 (22.51%) - The company reports that it has 1693 (22.51%) women employees in 2022.

155. Commitment to pay a living wage?

The company commits to pay a Living Wage to all workers.

156. Commitment to pay a living wage applies to all suppliers?

The company commits to pay only minimum wage applies to all suppliers.

157. Progress on commitment to pay a living wage?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has established a decent living wage committee in each estate to ensure compliance with fair compensation standards.

158. Reporting of salary by gender?

159. Commitment to address occupational health and safety?

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

160. 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.

161. Provision of personal protective equipment and related training?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it provides accessible healthcare, mandates the use of protective equipment, and ensures the availability of hazard management facilities.

162. Time lost due to work-based injuries?

3.86 - The company recorded a lost time incident frequency rate (LTIFR) of 3.86 in 2023. Calculated as 200,000 man-hours.

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

1 - The company reports one fatality in 2023.

164. Commitment to support smallholders?

The company states its objective to assist scheme smallholders through services provided under the 'Plasma Scheme'. However, it does not have a clear commitment to support independent smallholders.

165. Programme to support scheme smallholders?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that the 'Plasma Scheme' is designed to develop scheme smallholders within the local community in Indonesia. The scheme supports smallholders by providing seed stock, fertilisers, pesticides, training, and loans. It also assists these smallholders in obtaining RSPO certification and has set a target to certify smallholders under RSPO by 2027. However, the information is between two to five years old.

166. Percentage of scheme smallholders involved in programme?

14 - The company reports that it has assisted in establishing 14 smallholder cooperatives under the 'Plasma Scheme' in Indonesia. However, the information is between two to five years old.

167. Programme to support independent smallholders?

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

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

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

The company states that it conducts audits to ensure its suppliers comply with relevant local labor and environmental regulations.

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

171. Suspension or exclusion criteria for suppliers?

The company states that it will not establish or maintain business relationships with suppliers and contractors who do not align with its sustainable palm oil policy principles. However, it has not provided details on the steps that will be taken or the timeframes for action.

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

173. Proportion of supply from suppliers that is verified as deforestation- and/or conversion-free (DCF)?

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

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

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

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

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

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

180. Commitment to ethical conduct and prohibition of corruption?

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

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

The company's anti-bribery and corruption policy applies only to some suppliers.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that 100% of its workforce has received anti-corruption and anti-bribery training. It conducts annual corruption risk assessments and recorded zero incidents of corruption in 2023.

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

184. Whistleblowing procedure?

The company has a whistleblowing policy including, how whistleblowers can report unethical conduct and how they are protected.

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

The company reports that its grievance system is incorporated within its whistleblowing procedure and is open to all stakeholders.

186. Details of complaints and grievances disclosed?