United Plantations 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 (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates this in its own reporting.

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

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

3. High-level position of responsibility for sustainability?

The company has a Group Manager of Human Resources, Sustainability and Safety (HRSS).

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

The Chief Executive Director sits on the Group Sustainability Committee.

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

5 (0.1%) - The company reports that it has five female members on its senior management team.

6. Percentage or number of women board members?

2 (18.18%) - The company's board of directors is made up of 9 males and 2 females.

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 states that it has collaborated with Copenhagen Zoo since 2010 to build an in-house capacity, through it's Biodiversity team, to manage conservation and nurture more than 8,029 ha of jungle reserves. However, the details of this collaboration activities are unclear. The company also reports a collaboration with fair labour charity Verite, to address human rights risks in its supply chain, specifically risks related to forced labour and migrant workers.

9. Sustainability report published within last two years?

The company published a sustainability report in 2021, and can also be found integrated with its annual report.

10. Reports through standardised reporting systems?

The company's annual report has been prepared in accordance with GRI standard but does not specify GRI Core or Comprehensive standards. The company has submitted CDP Climate Change 2022 and Forests 2022 Responses.

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?

The company has a summary of a climate risk assessment and cites TCFD recommendation. The company does not report metrics, targets and processes used to assess or manage climate risks.

13. Lists countries and operations?

Malaysia (11 plantations, four mills, one biogas plant, and two refineries). Indonesia (one plantation, one mill, and one biogas plant).

14. Lists countries sourcing from?

The company reports that it sources from Indonesia and Malaysia only.

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

58298 - The company reports a total area of 62,980 ha which covers oil palm (including plasma smallholders) and coconut in 2021 annual and sustainability reports. A palm oil-specific figure of 58298 ha is reported in the company's 2021 ACOP.

16. Total oil palm planted area (ha)?

46521 - The company reports the total area planted with oil palm is 46,521 in its 2021 annual and sustainability report. The RSPO ACOP 2021 reports that the company has 48894 ha of Total land controlled or managed for oil palm planted cultivation including infrastructure area.

17. Scheme smallholders planted area (ha)?

1364 - The company reports the total area under scheme smallholders in its RSPO ACOP 2021 and on its website.

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

400 - The company reports the total unplanted area managed for oil palm in its 2021 RSPO ACOP.

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

7640 - The company reports that the total conservation area is 8,029 ha in its 2021 annual and sustainability report. However, the RSPO ACOP 2021 reports that the company has 7640 ha of the total conservation area.

20. Maps of estates/management units?

The company has submitted submit maps of its concessions through RSPO ACOP 2021.

21. Maps of scheme smallholders?

The company has published a map of its plasma scheme smallholders.

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

The company provides a georeferenced map of FFB suppliers to one of its subsidiaries only (PT SSS).

23. Number of company-owned mills?

5 - The company reports it owns 5 mills in its 2021 annual report.

24. Names and locations of company-owned mills?

The company reports the names and locations of company-owned mills.

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

The company reports that 1 out of 5 company-owned mills source from third parties.

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

The company reports that 4 of 5 mills source only from company-owned plantations, and the remaining mill sources 81.25% from company-owned plantations and the rest from third parties.

27. Number of third party supplying mills?

5 - The company reports five direct third-party supplying mills supplying CPO and PK.

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

The company reports the name and location of all direct and indirect supplying mills.

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

The company reports that all supplying mills source from their own plantations.

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

The company reports that 100% of third party mill supply comes from the third party mills' own operations.

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

The company reports that 5.65% of raw material sourced by the company's refinery comes from intermediary traders/refiners.

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

The company has already achieved 100% traceability to mill level.

33. Percentage of supply traceable to mill level?

The company states that 100% of supply can be traced back to mill level. Data is verified by RSPO Identity Preserved Certification.

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

The company commits to achieve 100% traceability to plantation level by the year 2027.

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

The company reports that 100% of the supply to company-owned mills is traceable to plantation level. Data is verified by RSPO Identity Preserved Certification.

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

The company states ""we source significant volumes of CPKO from external Kernel Crushing Plant (KCP) of which the main portion only can be traced back to the Palm Oil Mills (POMs)."" It is not clear how much of the supply from third-party mills is traceable to plantation level. Data is verified by RSPO Identity Preserved Certification.

37. Publishes traceability data at refinery level?

The company states that 100% of CPO is traceable to plantation at refinery level, and 25.39% of CPKO supply can be traced to plantation level. The information is externally verified.

38. Publishes traceability data at crusher level?

[Externally verified] The company states ""All Crude Palm Kernel Oil (CPKO) derived from UP's own production of Palm Kernel(PK) can be traced back to the plantations"". The information is externally verified.

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

[Externally verified] 2004 - The company has been a member since 2004.

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] 2008 - The company's first certification was achieved in 2008.

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

The company has submitted its 2021 ACOP.

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

[Externally verified] 84.34% - The RSPO ACOP 2021 reports that the company has 84.34% RSPO-certified area excluding scheme smallholders.

43. Percentage of mills RSPO-certified?

[Externally verified] 100% - All 5 company mills are RSPO certified.

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

2023 - The company commits to achieve 100% RSPO certification of estates and mills by 2023. This is within 5 years.

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

2008 - The company has already achieved 100% RSPO-certification of all palm product processing facilities.

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

0% - No scheme smallholders are currently certified.

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

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

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

0% - No FFB from independent smallholders/outgrowers/third-party is RSPO-certified in 2021.

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

[Externally verified] 75.11% - The company reports that 75.11% of its sourced palm oil was RSPO certified in 2021.

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

[Externally verified] The company reports a total volume of 275760 tonnes of CSPO and CSPK sold under the Segregated and Identity Preserved systems.

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

[Externally verified] The company reports a total volume of 318876.00 tonnes of RSPO-certified palm oil and oil palm products sourced under the Segregated and Identity Preserved systems in 2021.

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

[Externally verified] The company states "We are pleased to announce that we have successfully obtained the ISPO initial certificate for the entire HGU* area of 6717.62ha in August 2019 and subsequent Annual Surveillance Audits are ongoing." An ISPO certificate for PT Surya Sawit Sejati is available on the company's website. However, the company is not 100% certified. Hence, only partial points.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] All company mills and estates in Malaysia are MSPO certified.

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

55. Commitment to zero conversion of natural ecosystems?

The company commits to zero conversion of natural ecosystems.

56. Commitment to zero deforestation?

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

57. Commitment to zero deforestation applies to all suppliers?

The company's environment and biodiversity policy also applies to its suppliers.

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

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates the criteria and cut-off date as 2010 in its own reporting.

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

The company has specified the criteria of forests that are not to be deforested by suppliers, including no new development on high conservation value (HCV) areas, and has also specified a cut-off date as 2010 beyond which deforestation or conversion would not be accepted in supplier operations.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that BioD Team has set up a comprehensive GIS database for monitoring deforestation, however this information is undated.

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

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

0 - The company reports 0 non-compliant deforestation across its operations since 2010. This information was last updated in December 2021.

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

0 - The company reports zero deforestation in supplier operations since the 2010 cut-off date.

64. Commitment to restoration of deforestation/conversion?

The company commits to restore ecosystems to their prior condition in cases of conversion within its own operations as of 2010.

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

The company commits suppliers to restore ecosystems to their prior condition in cases of conversion within their own operations as of 2010.

66. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company provides examples of activities it has carried out within the landscape which was updated in December 2021.

67. Biodiversity policy?

The company has a biodiversity and environment policy. It reports targets to increase the number of species in concessions but it is unclear how this will be achieved.

68. Biodiversity policy applies to all suppliers?

The company has published a biodiversity policy which applies to all suppliers, covers multiple dimensions of biodiversity protection and extends beyond HCV/HCS/set-asides.

69. Identified species of conservation concern, referencing international or national system of species classification?

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports mangrove and riparian forest restoration projects.

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

The company commits to only allow sustainable hunting of species by local communities for subsistence purposes in its operations.

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

The company commits all suppliers to only allow sustainable hunting of species by local communities for subsistence purposes in their operations.

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

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

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

The company commits all suppliers to conduct HCV assessments.

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

[Externally verified] An assessment and associated management and monitoring plans is available for PT Surya Sawit Sejati on the RSPO website.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

83. High Carbon Stock (HCS) assessments available?

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

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

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

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

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

86. 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.

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

[Externally verified] SEIAs are included in the RSPO NPP for PT Surya Sawit Sejati.

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

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

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

The company commits all suppliers to no planting on peat of any depth.

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

4913.93 (10.56%) - The company reports the area planted on peat as 4913.93 ha or 10.56% of its total planted landbank in its 2021 annual report.

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

[Externally verified] The company reports total plantation on peat was approximately 5,411.24 ha in 2020 and 4,913.93 ha in 2021, which means the total landbank on peat area has decreased from last year. However, the information is externally verified by KPMG.

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

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

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

The company commits all suppliers to good agricultural practices for soils and peat.

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

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

95. Commitment to zero burning?

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

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

97. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to conduct. In addition to this, the company has four fire watch towers constructed at strategic points and has purchased additional six units of GPS devices to monitor fires.

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

The company reports that in 2021, 0.05 ha of its planted areas were burnt.

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

0.004 - The company reports that 0.004 ha of the outer ring ( ?500 m adjacent to concession) of grassland was burnt.

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

The company commits to reduce GHG emissions intensity by 66% by the year 2030.

101. GHG emissions intensity?

The company reports a figure of 1.47 kg CO2 -eq emissions per kg. NBD oil in 2021.

102. GHG emissions from land use change?

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

103. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports that GHG emissions have reduced from 1.53 kg CO2-eq./kg NBD oil in 2020 to 1.47 kg CO2-eq./kg NBD oil in 2021. Information on GHG emissions intensity is externally verified by Jannick Schmidt and Michele De Rosa, the LCA assessment uses a different methodology to the annual report which is the reason for the different figures.

104. Methodology used to calculate GHG emissions?

The RSPO requires companies to assess their GHG emissions through the Palm GHG calculator. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

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

The company reports that all five company-owned mills have methane capturing facilities.

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

The company commits to reduce its mill water consumption by 10% frThank you, full points have now been awarded. om the average of 1.6 MT water/MT FFB processed by 2025.

107. Water use intensity?

The company reports the water use intensity for Malaysian operation as 1.5MT water/MT FFB processed and for Indonesian operation as is1.2MT water/MT FFB processed in 2021.

108. Progress towards commitment on water use intensity?

[Externally verified] The company reports water use intensity for its mills over the last three years however, which is improving. The information is externally verified by KPMG.

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

The company commits to reduce BOD and COD by 10% by the year 2025.

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

The company states that BOD and COD are far below the permissible level set by the Department of Environment of Malaysia and Indonesia. Annual figures are improving.

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

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

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

The company states that it treats PORE.

113. Commitment to protect natural waterways through buffer zones?

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

114. Implementation of commitment to protect natural waterways through buffer zones?

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

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

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

116. 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.

117. Commitment to no use of paraquat?

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

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

The company commits all suppliers to not use paraquat.

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

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

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

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

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

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

122. 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.

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

The company reports chemical usage of per tonne of palm oil produced for each fertiliser nutrient as well as an over figure of 0.76 kg pesticides/herbicides used per tonne of oil palm produced. The company also reports a reduction of overall herbicide usage (kg a.i./ha/year).

124. Implementation of commitment to minimise inorganic fertiliser use?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also states that it utilises oil palm residues as fertiliser in its plantations.

125. 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 communicates this in its own reporting.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also self-reports regular waste collection, recycling, and safe disposal of waste.

127. Commitment to human rights?

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

128. Commitment to human rights applies to all suppliers?

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

129. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports a partnership with Verité, a human and social rights NGO, to address and improve human rights and safety gaps within its supply chain.

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

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

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

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

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

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

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

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

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

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

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

The company commits all suppliers to respect FPIC.

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

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company has also published its FPIC process on its website.

137. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company has only mentioned the engagement of stakeholders to prevent conflicts but the evidence of how they prevent conflicts was not reported. The company has multiple RSPO audit reports with examples of stakeholder meetings with local communities but do not explain how they prevent conflicts.

138. Details of process for addressing land conflicts available?

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

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

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

140. Commitment to mitigate impacts on food security?

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it ensures all of its estates' sundry shops provide an adequate supply of healthy food to the workers at a reasonable price. Night markets were held in the estate on a monthly basis where the workers have access to more varieties of sundry goods. In addition, rice and cooking oil were offered to the workers at a subsidised rate. All workers were also provided with some land at the back of their houses to plant vegetables and a dedicated area within the housing complex to be planted with fruit trees.

142. Commitment to provide essential community services and facilities?

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports to provide education, infrastructure investment and support, and hospitals for local communities.

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

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

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

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

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

The company commits all suppliers to all Fundamental ILO Conventions.

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

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

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

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

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

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

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

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

151. Percentage or number of temporary employees?

This indicator is disabled as the company has no temporary employees.

152. Percentage or number of women employees?

13.53% - The company reports that 13.53% of its workforce across the whole group is female.

153. Commitment to pay a Decent Living wage?

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

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has proactively worked with several large growers in the industry to engage Monash University for a fair and decent wage assessment.

156. Reporting of salary by gender?

157. Commitment to address occupational health and safety?

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

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

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

159. Provision of personal protective equipment and related training?

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

160. Time lost due to work-based injuries?

The company reports a Lost Time Injury Frequency Rate (LTIFR) of 5.02 and 87.41 accidents per million man hours for its Malaysian and Indonesian operations respectively.

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

1 - The company reports no occupational-related fatal accidents within its Malaysian operations. However, Indonesian operations experienced one fatal accident.

162. Commitment to support smallholders?

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

163. Programme to support scheme smallholders?

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

164. Percentage of scheme smallholders involved in programme?

[Externally verified] 845 - The company states it has 815 smallholders that are managed by the company and participating in the plasma scheme. The information is externally verified by KPMG.

165. Programme to support independent smallholders?

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

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

[Externally verified] 134 - The company reports that 134 smallholders attended a Smallholders Field Day in 2019, where they were provided training sessions on various management practices including safe handling of pesticides with appropriate Personal Protective Equipment (PPE), effective use of pre-emergent herbicides for less chemical usage, integrated pest management (IPM) and mechanised harvesting in order to assist. However, the information is externally verified by KPMG.

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

The company reports that supplier compliance is assessed using a self-assessment questionnaire (SAQ) to every oil palm product supplier on annual basis.

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

[Externally verified] 100% - The company reports that all the company's suppliers were assessed in 2021. The information is externally verified by KPMG.

169. Suspension or exclusion criteria for suppliers?

The company requests for suppliers to implement corrective measures using a 60-day time-bound action plan. If the supplier is still unable/unwilling to conform to the company's policy then the relationship is terminated.

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

The company states that if any suppliers violate or breach the policies or supplier code of conduct, they shall immediately be requested for implementing corrective measures with a 60 days time-bound action plan, however, if a supplier is unable or unwilling to take the necessary actions to conform to the expectations outlined in the company's own policy, the last resort would be to terminate the commercial relationship with the supplier. However, compliance is determined based on self-assessment by suppliers only.

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

[Externally verified] The company verifies compliance through self-assessment questionnaires only, that are sent to all suppliers annually. It is also not clear if indirect suppliers are also assessed. Through this process, the company states that 100% of suppliers are categorised as 'low risk'. Based on this, the company takes no further action to verify compliance. The information is externally verified by KPMG. However, compliance is determined based on self-assessment by suppliers only.

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

The company currently has no high-risk suppliers.

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

[Externally verified] The company provides examples of training sessions for high-risk suppliers. This information is externally verified by KPMG.

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

[Externally verified] The company currently has no high-risk mills, however, provides examples of engagement in past with non-compliance to its sustainable palm oil policy for mills, and has a procedure for engaging high risk mills when they are identified through the self-assessment questionnaire. This information is externally verified by KPMG.

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

The company uses self-assessment questionnaires to evaluate whether its suppliers are high, medium, or low risk.

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

[Externally verified] The company reports that all supplying mills are regularly assessed on annual basis. This is externally verified by KPMG.

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

[Externally verified] The company reports the risk level of all mills on annual basis. This is externally verified by KPMG.

178. Commitment to ethical conduct and prohibition of corruption?

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

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports to have conducted a corruption and bribery risk assessment and conducts related training for employees.

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

The company has published a comprehensive tax risk management policy detailing how risks are calculated and who is responsible.

182. Whistleblowing procedure?

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

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

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

184. Details of complaints and grievances disclosed?

The company only provides a summary table on the number and type of grievances.