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 five years. The company also has published policies regarding the sustainability of palm oil independently.

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

Suppliers are required to commit to the company's Sustainable Palm Oil Policy and Code of Conduct.

3. High-level position of responsibility for sustainability?

The company has a Group Sustainability Committee, with the overall sustainability objectives, targets and priorities being the responsibility of the Executive Committee headed by the Chief Executive Director.

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?

0 (0%) - There are no female directors.

6. Percentage or number of women board members?

1 (9%) - The company's board of directors is made up of 10 males and one female.

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 has collaborated with Copenhagen Zoo since 2010, utilising their expertise to manage reserves and research biodiversity, and the social consulting service LINKS to establish FPIC procedures for plasma smallholdings.

9. Sustainability report published within last two years?

The company published a sustainability report in 2019, and can also be found integrated with its annual report.

10. Reports through standardised reporting systems?

The company answered the CDP Forests 2019 questionnaire.

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

58,866 - The company reports the total area managed for oil palm in its most recent RSPO ACOP.

14. Total oil palm planted area (ha)?

46,731 - The company discloses that the total area planted with oil palm in 2019 was 46,731 ha.

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

1,314 - The company reports the total area under scheme smallholders in its most recent RSPO ACOP.

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

450 - The company reports the total unplanted area managed for oil palm in its most recent RSPO ACOP.

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

7,939 - The company reports the total area managed for conservation in its most recent RSPO ACOP.

18. Maps of estates/management units?

The company uploaded a shapefile as part of its 2018 RSPO ACOP and declared that it counted for 100% of its concession sites.

19. Maps of scheme/plasma smallholders?

The company has published a map of scheme smallholders estates.

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

The company provides names and coordinates of supplier plantations, but no maps/shapefiles.

21. Number of company-owned mills?

5 - The company reports it owns five mills.

22. Names and locations of company-owned mills?

The company reports the names and coordinated of all five company-owned mills.

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

One (20%) company-owned mill sources from third parties.

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

4/5 mills source only from company-owned plantations, and the remaining mill sources 76% from company-owned plantations and the rest from third parties.

25. Number of third party supplying mills?

15 - The company reports 11 direct supplying mills supply CPO, and 4 direct supplying mills supply PK.

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

The company has 12 supplying mills, the locations of which are all disclosed.

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

All supplying mills source from their own plantations.

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

100% of third party mill supply comes from the third party mills' own operations.

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

7% of raw material sourced by the company's refinery comes from intermediary traders/refiners.

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

100% of CPO and CPKO is traceable to mill level.

31. 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.

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

Full certification and production of RSPO certified and segregated palm oil traceable to the mill and plantations is expected to be reached in 2022 for the company's Indonesian operations. The company's Malaysian operations are certified by the RSPO Identity Preserved model.

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

100% of the supply to company-owned mills is traceable to plantation level.

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

The company states that 58.79% of supply can be traced back to plantation. However, it is not clear how much of supply from third-party mills is traceable to plantation level.

35. Publishes traceability data at refinery level?

100% of CPO is traceable to plantation at refinery level, and 26.31% of CPKO supply can be traced to plantation level.

36. Publishes traceability data at crusher level?

This indicator is disabled as the company does not own palm kernel crushing facilities.

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

2004 - The company has been a member since 2004.

38. RSPO-certified within three years of joining the RSPO or by November 2010, for companies joining prior to finalisation of the RSPO certification systems in November 2007?

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

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

The company has submitted its 2019 ACOP.

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

The company operates in Malaysia (Perak, Selangor) and Indonesia (Central Kalimantan).

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

82.5% - 47,483 ha of land is certified making up 82.5% of the company's operations. This figure excludes scheme smallholders.

42. Percentage of mills RSPO-certified?

100% - All 5 company mills are RSPO certified.

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

2023 - The company commits to achieve this goal by 2023.

44. Year expected to achieve 100% RSPO certification of all palm product processing facilities?

2014 - The company's 2019 ACOP states that this was achieved in 2014.

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

0% - No scheme smallholders are currently certified.

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

2023 - The company commits to achieve this by 2023.

47. 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 FFB in 2019.

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

70% - The company reports 69.65% of its sourced palm oil was RSPO certified in 2019.

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

The company sources both RSPO Segregated and Identity Preserved.

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

[Externally verified] The company's only Indonesian mill is certified, but not all of its Indonesian landbank is ISPO certified.

51. Malaysia Sustainable Palm Oil (MSPO) certified?

All company mills and estates in Malaysia are MSPO certified.

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

53. Commitment to zero deforestation or zero conversion of natural ecosystems?

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 five years. The company also makes this commitment separately.

54. Commitment to zero deforestation or zero conversion of natural ecosystems applies to all suppliers?

The company's own policy applies to its suppliers also.

55. Criteria 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 five years. The company also makes this commitment separately.

56. Evidence of monitoring deforestation?

The company provides evidence of monitoring deforestation, however it is between two and five years old and not externally verified.

57. Evidence of monitoring deforestation in supplier operations?

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

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

60. Commitment to restoration of non-compliant deforestation/conversion?

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

62. Implementing a landscape or jurisdictional level approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports efforts of implementing a landscape approach in its annual report and on its website.

63. Commitment to biodiversity conservation?

The company publishes this commitment.

64. Commitment to biodiversity conservation applies to all suppliers?

The company's own policy applies to suppliers.

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

The company has identified species of concern using IUCN Red List classifications. Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company provides multiple examples of efforts to conserve habitats and species. Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company has published a commitment to no hunting.

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

The company extends its own policy to suppliers also.

69. 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 five years. The company also makes this commitment independently.

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

The company's own commitment extends to its suppliers.

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

An assessment and associated management and monitoring plan is available for PT Surya Sawit Sejati on the RSPO website.

72. 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.

73. 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.

74. 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 five years. The company also makes this commitment independently.

75. 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's own commitment is extended to suppliers.

76. 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.

77. 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 five years. The company also makes this commitment independently.

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

The company's own policy is extended to its suppliers.

79. High Carbon Stock (HCS) assessments available?

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

80. 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 five years.

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

The company's own commitment also applies to its suppliers.

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

SEIAs are included in the RSPO NPP for PT Surya Sawit Sejati.

83. 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 five years. The company also makes this commitment independently.

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

The company's own commitment is also applied to suppliers.

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

5,609 (12%) - The company reports the area planted on peat as 5,608.5 ha or 12% of its total planted landbank in its 2019 annual report. The company's landbank on peat has increased from last year due to new plantation acquisitions.

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

The company reports it has not planted on peat since 2010. It's landbank on peat has increased, however this is due to new plantation acquisitions. The company's landbank planted on peat has been verified by KPMG.

87. 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 five years. The company also makes this commitment independently.

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

The company's own commitment is extended to its suppliers.

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

The company provides evidence of implementing procedures such as monitoring drainage ditches, soil compaction and planting spacing. Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

90. 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 five years. The company also makes this commitment independently.

91. Commitment to zero burning applies to all suppliers?

The company's own policy also applies to suppliers.

92. Evidence of fire monitoring and management?

The company reports patrols and fire training. This information is not externally verified.

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

In 2019, 16.5 ha of its concession was burnt.

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

96.75 - The company reports 96.75 ha of the outer ring (?500 m adjacent to concession) of its concession was burnt.

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

The company commits to reduce the GHGs per MT of refined palm oil by 60% before 2025, compared to 2004 levels.

96. GHG emissions intensity?

GHG emissions (incl. iLuc & nature conservation) are 1.86 kg CO2-eq./kg neutralised, bleached and deodorized (NBD) oil in 2019. Additionally, in the company's most recent RSPO ACOP it reports GHG emissions at 0.29 tCO2e/ha.

97. GHG emissions from land use change?

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

98. Progress towards commitment to reduce GHG emissions intensity?

GHG emissions (incl. iLuc & nature conservation) have reduced from 3.25 kg CO2-eq./kg neutralised, bleached and deodorized (NBD) oil in 2004 to 1.86 kg CO2-eq./kg NBD oil in 2019. The company also has Life Cycle Assessment (LCA) study carried out by 2.0-LCA Consultants showing an improvement in GHG emission intensity.

99. 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 five years. The company also independently reports GHG emissions using ISO 14000 International Standards and PalmGHG.

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

All 5 company-owned mills have methane capture.

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

102. Water use intensity?

Water use intensity for company mills is reported as 1.7 MT water/MT FFB processed in Malaysia and 1.4 MT water/MT FFB processed in Indonesia.

103. Progress towards commitment on water use intensity?

[Externally verified] The company reports water use intensity for its mills over the last three years, however it is not improving. Figures do not cover the company's refining operations and are also not externally verified.

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

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

[Externally verified] BOD figures are verified as being within legal limits, but this does not cover all of the company's operations.

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

The company reports that it treats POME. Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

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

The company states that it treats PORE. This information is not externally verified.

108. 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 five years.

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

The company has published its standard operating procedure for riparian areas. Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

110. 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 five years. The company also makes this commitment independently.

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

112. 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 five years. The company also makes this commitment independently.

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

The company's own commitment also extends to suppliers.

114. 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 five years. The company also makes this commitment independently.

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

Suppliers are required to adhere to the company's own policy.

116. 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 five years. The company also makes this commitment independently.

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

Suppliers are required to adhere to the company's own policy.

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

The company reports chemical usage per tonne of palm oil produced, as well as reduction of overall herbicide usage (kg a.i./ha/year).

119. Implementation of commitment to minimise inorganic fertiliser use?

The company utilises oil palm residues as fertiliser on its plantations.

120. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company provides multiple examples of implementing IPM such as introducing barn owls for pest control and planting flowers to encourage beneficial insects.

121. 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 provides examples of waste management.

122. 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 five years. The company also commits to the ILO Convention and the UDHR.

123. Commitment to human rights applies to all suppliers?

The company's own Human Rights Policy extends to suppliers.

124. Progress on human rights commitment?

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

125. 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 five years.

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

The company applies its own Human Rights Policy, which references the UN Declaration on the Rights of Indigenous Peoples, to suppliers.

127. 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 five years. The company also makes this commitment independently.

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

The company's own commitment also applies to suppliers.

129. 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 five years.

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

The company's own commitment also applies to suppliers.

131. 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 five years. The company has also published its FPIC process on its website.

132. Examples of local stakeholder engagement to prevent conflicts?

The company collaborates with social justice charity LINKS on social research, mapping, information dissemination, conflict mediation and training of FPIC related issues for local communities and company employees.

133. 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 five years. The company has also published its Standard Operating Procedure for land conflicts.

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

The company has published a Gender Policy which works to address the barriers faced by women in regards to employment, however, the company does not commit to include women across all palm oil operations. Information has not been externally verified.

135. 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 five years.

136. Commitment to mitigate impacts on food security applies to all suppliers?

The company requires suppliers to consider food security as part of FPIC and SIA processes.

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

The company provides one example of planting fruit trees for employees and local residents.

138. 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 five years.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports progress in its annual report.

140. 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 five years.

141. 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 five years. The company also makes this commitment independently.

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

The company's own commitment is extended to suppliers.

143. 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. The company also provides examples independently.

144. 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 five years.

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

The company's own policy extends to suppliers.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also provides examples of progress independently.

147. Percentage or number of temporary employees?

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

148. Percentage or number of women employees?

862 (12.6%) - The company reports 12.6% of its workforce (862 workers) across the whole group is female.

149. Commitment to pay at least minimum 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 five years.

150. Commitment to pay at least minimum wage applies to all suppliers?

The company's own commitment also applies to suppliers.

151. Progress on commitment to pay at least minimum wage?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports all workers across its operations were paid above the minimum wage in 2019.

152. Reporting of salary by gender?

153. 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 five years. The company also makes this commitment independently.

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

The company's own commitment also applies to suppliers.

155. 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.

156. Time lost due to work-based injuries?

8.27 - The company reports a Lost Time Injury Frequency Rate (LTIFR) of 8.27 accidents per million man hours. However, this is for its Malaysian operations only.

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

3 - The company reports three fatal accidents in 2019. However, this is for its Malaysian operations only.

158. 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 five years. The company also makes this commitment independently.

159. Programme to support scheme/plasma smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company publishes details of its programme, such as providing training on preparation of soils and cultivation of oil palm, in its 2019 annual report.

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

815 (100%) - The company states it has 815 smallholders that are managed by the company and participating in the Plasma scheme.

161. Programme to support independent smallholders/outgrowers?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also hosts field days for smallholders to experience good agricultural practices such as IPM and proper use of PPE.

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

134 (89%) - 134 out of 150 smallholders attended the company's smallholder field day in 2019.

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

Supplier compliance is assessed using a self-assessment questionnaire and then suppliers are placed into low, medium or high risk categories.

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

100% - All upstream and downstream suppliers were assessed in 2019.

165. 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.

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

167. 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 that are sent to all suppliers annually, however it is not clear if indirect suppliers are also assessed.

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

The company currently has no high risk suppliers.

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

The company provides examples of training sessions for high risk suppliers, and this has been verified by KPMG.

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

The company currently has no high risk mills, but provides examples of past engagement 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.

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

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

Supplying mills are assessed annually, and this has been externally verified by KPMG.

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

No supplying mills were high risk in 2018, as determined through a self-assessment questionnaire. This has been verified by KPMG.

174. 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 five years. The company also makes this commitment independently.

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

The company's own policy also applies to suppliers.

176. 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. Additionally, the company has appointed an Internal Audit Officer who is responsible for anti-corruption compliance, anti-bribery training is conducted in all operating units, and a risk assessment was conducted which resulted in the introduction of procedures to minimise corruption.

177. 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.

178. 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 five years.

179. 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 five years. The company has published its procedures for dealing with grievances from external and internal stakeholders.

180. Details of complaints and grievances disclosed?

The company provides a summary of land dispute cases from 2017-2019, and provides one detailed summary of a single case. However, the single case is over five years old and cannot be considered for points.