Wilmar International Ltd

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 has also published its sustainable palm oil policy.

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

The company has published a NDPE policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company reports it has a 'Sustainability Management Team (SMT)' which is led by the Chief Sustainability Officer and supported by the General Manager - Group Sustainability.

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

The company reports that its approach to sustainability is overseen by the Chairman and CEO, and the Board of Directors, with the support of the Board Sustainability Committee (BSC).

5. Reports gender balance of senior management team?

18% - The company reports that 18% of its senior management team in 2024 were female.

6. Reports gender balance of board members?

3 (23.1%) - The company reports it has 13 directors, of which three or 23.1% are female as of 2024.

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

Fire Free Alliance, POCG, and NYDF.

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

The company collaborates with research institutions, NGOs and governments on multiple projects, including preserving biodiversity, local community rights and labour rights. Some of the collaborations include collaboration with the University of Malaysia Sarawak (UNIMAS) since 2014 to study the diversity and abundance of flora and fauna in HCV areas within its plantation operations in Sarawak, collaboration with Proforest to deliver four BMPs training workshops for third-party suppliers in Malaysia, covering topics such as riparian management, biodiversity monitoring and HCV-HCS identification and management, and with the Sabah Wildlife Department (SWD) and local NGOs, to carry out engagement under Wildlife Awareness Outreach Programme (WAOP) with stakeholders across the districts of Sugut, Labuk and Segama to reduce risks and strengthen the management of HCV and conservation areas by inculcating positive attitudes to conservation and sustainable practices.

9. Sustainability report published within last two years?

The company published its latest sustainability report in 2025, covering the year 2024.

10. Reports through standardised reporting systems?

The company submitted CDP questionnaires for Forests, Climate Change, and Water Security in 2024. Additionally, the company's latest sustainability report is prepared in accordance with the GRI 1: Foundation 2021 requirements.

11. Climate risks assessment available?

The company has a process for identifying, assessing, and responding to climate-related risks and opportunities, which is disclosed in its 2023 CDP Climate Questionnaire and its latest sustainability report. However, the information reported is not externally verified.

12. Lists countries and operations?

Plantations and mills - Ghana, Indonesia, Malaysia, and Nigeria. The company also operates plantations through joint ventures in Ivory Coast, and Uganda. Refineries/Crushers - China, Indonesia, Malaysia, Nigeria, Netherlands, United States, Vietnam, South Africa, Sri Lanka, Mexico, Singapore, Bangladesh, Germany, India, Ivory Coast, Uganda, Ukraine, Zambia.

13. Lists countries sourcing from?

The company lists all countries that its mills and refineries source from through its mill lists and the location of mills and supply bases.

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

351181 - The company reports this figure in its 2024 RSPO ACOP.

15. Total oil palm planted area (ha)?

230951 - The company reports a planted area of 230,951 ha in 2024.

16. Scheme smallholders planted area (ha)?

43729.2 - The company reports the total scheme smallholders' planted area as 43729.21 ha. Data as of 2024.

17. Unplanted area (areas designated for future planting) (ha)?

20561.2 - The company reports a figure of 20561.20 in its 2024 RSPO ACOP.

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

41172.4 - The company reports a conservation area of 15963.07 ha, including an HCV area of 25209.30 ha in its 2024 RSPO ACOP.

19. Maps of estates/management units?

The company submitted its updated concession boundary maps to the RSPO in 2024.

20. Maps of all scheme smallholders?

The company states that every year, smallholder maps that are under the ownership or control of the company are submitted as part of the company's concession maps under the RSPO ACOP.

21. Maps of all third-party supplying plantations?

The company only states that it has prepared maps of all its own mills in Malaysia and Indonesia, showing all estate boundaries and the location of each smallholder and dealer. However, no maps could be found.

22. Number of company-owned mills?

44 - The company operates 44 palm oil mills. One is under a joint venture where the company does not have a majority shareholding.

23. Names and locations of company-owned mills?

The company has published the names and locations of all company-owned mills.

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

Nine mills source exclusively from third-party suppliers, one mill sources exclusively from company-owned plantations, and the remaining 34 mills source from company-owned plantations and third-party suppliers. Data as of 2024.

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

The company's mills source 52% of FFB from its own plantations, 1.70% from scheme smallholders, and the remaining 46.3% from third-party sources. Data as of 2024.

26. Number of third party supplying mills?

The company states that there are over 850 supplier mills in Malaysia and Indonesia. A list of the names of the mills supplying to individual refineries of the company in all countries can be found through the company's Supply Chain Map.

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

The company states that there are over 850 supplier mills in Malaysia and Indonesia. A list of the names and locations of the mills supplying to individual refineries of the company in all countries can be found through the company's Supply Chain Map.

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

The company reports that 7.3% of third party mills source from their own plantations, 21.7% source from third party plantations, and 53.9% source from both. Data as of 2024. Data does not cover all third party supplying mills, percentages only make up 82.9% of third party mills.

29. 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 third party mills source 5.8% of volumes from their own plantations, 24.3% from third party plantations, and 63.9% from both. Data as of 2024. Data does not cover all third party supply, percentages only make up 94% of third party supply mills volumes.

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

The company reports for each of its refineries the total number of suppliers and the percentage sourced that are either from company-owned mills, third-party mills, company-owned refineries, or others (refiners/traders/bulkers). Data as of 2024.

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

The company commits to achieving 100% traceability to the mill level by the year 2025.

32. Percentage of supply traceable to mill level?

The company reports it achieved 98.5%traceability to the mill level in 2024. The data has undergone limited assurance by the Control Union. Additionally, many of the company's crushers and refineries also have RSPO SCC under SG.

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

The company commits to achieving 100% traceability to oil palm plantations by 2025.

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

The company has achieved 100% traceability to the plantation level for all company-owned palm oil mills. Also, many of the company mills have obtained RSPO Identity Preserved certification.

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

As of 2024, the company has achieved 91% traceability to plantations. The data has undergone limited assurance by the Control Union. Additionally, many of the company's refineries also have RSPO SCC under IP.

36. Publishes traceability data at refinery level?

[Externally verified] The company publishes traceability data to the plantation level for each of its refineries. This information is externally verified by Control Union.

37. Publishes traceability data at crusher level?

[Externally verified] The company owns one stand-alone crushing facility, PT Usaha Inti Padang, and all others are integrated with refineries and traceability data is reported for each refinery. This information is externally verified by Control Union.

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

2004 - The company has been a member of the Roundtable on Sustainable Palm Oil (RSPO) since 2004.

39. 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 achieved its first RSPO certification in 2008.

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

RSPO ACOP 2024 is submitted by the company.

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

82.12% - The company has 82.12 % of its land certified under RSPO, excluding scheme smallholders. Data as of 2024.

42. Percentage of mills RSPO-certified?

82.85% - 29 out of 35 mills of the company are RSPO certified. The calculation excludes nine stand-alone mills that do not have a supply base of directly owned or managed plantations or associated smallholders.

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

2026 - The company commits to achieving 100% RSPO certification of estates and mills by 2026. This is within 5 years.

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

2024 - The company has already achieved 100% RSPO-certification of all palm product processing facilities.

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

14.85% - The company reports that 14.85% of the land under the scheme smallholders is certified. Data as of 2024.

46. 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 achieving 100% RSPO certification of scheme/associated smallholders and out-growers by 2026. This is within 5 years.

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

0.4% - 14,952.24 tonnes were certified out of a total supply of 3,659,307.46 tonnes as per the 2024 RSPO ACOP.

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

10.87% - The company's certified palm oil, palm kernel oil, and related products uptake is 10.87% as per the 2024 RSPO ACOP.

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

The company reports a volume of 91,624.92 tonnes (11.78%) of CSPO and CSPK sold under the Identity Preserved system out of a total of 777,999.68 tonnes. Data as per 2024 RSPO ACOP.

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

The company reports 453,364.35 tonnes certified under RSPO SG and IP out of a total volume of 30,381,371.47 tonnes (1.49%). Data as of 2024.

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

[Externally verified] The company reports that 25 of its total 34 mills in Indonesia are ISPO-certified as of 2024. Evidence is externally verified by the Control Union.

52. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] 100% of the company mills and estates are MSPO certified as of 2024. Evidence is externally verified by the Control Union. The certificates are also publicly available on the MSPO database.

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

[Externally verified] The company has multiple ISCC certificates.

54. Commitment to zero conversion of natural ecosystems?

The company commits "no conversion of areas of biodiversity conservation importance" which is defined as "all natural ecosystems identified as HCV and HCS areas, as well as IUCN categories- I-IV protected areas, World Heritage Areas, protected areas that are gazetted under national or state laws, and all areas designated under regional agreements and international conventions". It does not clearly cover all natural ecosystems.

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

The company commits "no conversion of areas of biodiversity conservation importance" which is defined as "all natural ecosystems identified as HCV and HCS areas, as well as IUCN categories- I-IV protected areas, World Heritage Areas, protected areas that are gazetted under national or state laws, and all areas designated under regional agreements and international conventions". The commitment applies to all suppliers but does not cover all 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 reports its commitment to no deforestation.

57. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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

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's reporting defines deforestation as the development of HCV and HCS areas and specifies that any deforestation/conversion past 31st December 2015 will not be accepted.

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

The company defines deforestation for suppliers as the development of HCV and HCS areas and specifies any deforestation/conversion past 31st December 2015 will not be accepted in supplier operations.

60. Cross-commodity zero deforestation commitment?

61. Cross-commodity zero deforestation commitment applies to all suppliers?

62. Target date to achieve zero deforestation?

63. Target date to achieve zero deforestation in supplier operations?

64. 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 reports it monitors 31,842 ha of set-aside conservation areas and its supplier operations through satellite monitoring. Since 2020, the company has been collaborating with Satelligence to monitor deforestation and peatland development in its own operations and those of its suppliers. This collaboration involves providing notifications and conducting historical and current deforestation risk analyses.

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

[Externally verified] The company monitors deforestation in supplier operations using a platform from Earthqualizer and Satelligence, which provides deforestation alerts. As of 2024, the company monitors more than 23.1 million ha of land cover across its global operations and supply base. Evidence is externally verified by the Control Union.

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

0 - The company states that its monitoring programme has been in place since 2004, and it has recorded no illegal and/or deforestation cases in its operations as of the end of 2024.

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

2600000 - The company reports that 2.6 million ha of oil palm plantations have been removed from its supply chain due to suspension from non-compliance with its NDPE policy since its cut-off date of 2015. A figure for deforestation and/or ecosystem conversion area since the company's cut-off date for no deforestation is not reported.

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

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

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

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

70. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company is a member of RSPO's Sabah Jurisdiction Approach Steering Committee and is also a contributor to a jurisdictional approach initiative convened by the Tropical Forest Alliance (TFA) and Conservation International.

71. Biodiversity policy?

The company has a commitment to biodiversity conservation both within conservation areas and the wider landscape. The company has also published targets to restore, rehabilitate, and maintain 1,000 ha of riparian zones by 2050, to increase the siamang (Symphalangus syndactylus) population in PT Kencana Sawit Indonesia (KSI) to 30 by 2050, and to maintain proboscis monkey (Nasalis larvatus) population in Sabahmas Plantation in Malaysia, by 2050.

72. 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.

73. 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 has also published a list of wildlife from the International Union for Conservation of Nature (IUCN) Red List of Threatened Species, potentially found in its conservation areas.

74. 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.

75. 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.

76. 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.

77. 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 reports its commitment to conduct High Conservation Value (HCV) assessments.

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

The company commits all suppliers to conduct HCV assessments.

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

[Externally verified] HCV assessments and associated management and monitoring plans are publicly available for PT Agrindo Indah Persada, PT Agro Nusa Investama, and Biase Plantations Limited.

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

[Externally verified] HCV assessments of Biase Plantations Limited (Calaro extension), Benso Oil Palm Plantation (BOPP), PT Rimba Harapan Sakti (PT RHS), PT Bumi Sawit Kencana (Koperasi Produksi Permadat Sejahtera), BOPP Adum Banso (Nana Kwandoh Brempong III Estate), and HCV assessment of proposed SH Oil Palm Dev't for BPL are publicly available.

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

[Externally verified] HCV assessments of Biase Plantations Limited (Calaro extension), Benso Oil Palm Plantation (BOPP), PT Rimba Harapan Sakti (PT RHS), PT Bumi Sawit Kencana (Koperasi Produksi Permadat Sejahtera), BOPP Adum Banso (Nana Kwandoh Brempong III Estate), and HCV assessment of proposed SH Oil Palm Dev't for BPL are publicly available.

82. 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 reports its commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS).

83. 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.

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

[Externally verified] All High Conservation Value (HCV) assessments undertaken since January 2015 are deemed satisfactory by the HCV ALS Quality Panel.

85. 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 reports its commitment to the High Carbon Stock (HCS) Approach.

86. 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.

87. High Carbon Stock (HCS) assessments available?

[Externally verified] HCS assessment of Calaro Extension is publicly available.

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

[Externally verified] Peer review of the HCS assessment of Calaro Extension is available.

89. 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 reports its commitment to conducting social and environmental impact assessments (SEIAs).

90. 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.

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

[Externally verified] SEIA and associated management and monitoring plans for Biase plantations are publicly available.

92. 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 reports its commitment to no planting on peat of any depth.

93. 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.

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

1701 (0.74%) - The company reported a total peat planted area of 1,701 ha, which is about 0.74% of its total planted area. Data as of 2024.

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

[Externally verified] The company reported a total peat-planted area of 1,701 ha in 2024, which is a decrease from the peat-planted area of 1,702 ha reported in 2023. Control Union have performed limited assurance procedures on this data.

96. 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 reports its commitment to best management practices for soils and peat.

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

Only the company's commitment to BMPs for peat applies to all of its suppliers.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's reporting for BMPs for peat mentions maintaining water tables at optimal levels to minimise peat subsidence and the release of carbon dioxide. For BMPs for soil, the company only mentions allowing woody debris to remain in situ to decompose and enhance soil fertility.

99. 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 reports its commitment to no burning.

100. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

101. 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's reporting states having a 24/7 fire monitoring system and using satellite imagery to monitor and identify fires within and up to five kilometres outside its boundaries. Additionally, all of the company's concessions are staffed with on-site response teams who are immediately dispatched once fires are confirmed.

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

The company reports 35 hotspots and 18 actual fires in 2024 for Indonesia and states that no fires were detected in the company's operations in Malaysia, Nigeria, and Ghana in 2023.

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

182 - The company reports 1,656 hotspots and 178 actual fires in 2024 within a five-kilometre radius of its concession boundaries in Indonesia. The company also states that there were four fires detected near its operations in Nigeria and no fires detected near its concessions in Ghana or Malaysia in 2023.

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

The company reports commitment to reducing absolute Scope 1 and 2 GHG emissions by 50.4% and Scope 3 emissions by 30% by 2032 from a 2022 base year for its energy and industry sector. The company also reports to reduce absolute Scope 1 and 3 FLAG GHG emissions by 36.4% by 2032 from a 2022 base year.

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

The company reports a target to reduce Scope 1 and 2 emissions by 50.4% and Scope 3 emissions by 30.0% respectively, by 2032 from a 2022 baseline, as well as to reduce FLAG Scope 1 and 3 emissions by 36.4% within the same timeframe.

106. Absolute GHG emissions?

1809000 - The company reports absolute Scope 1 emissions as 0.7 million tCO2e for oil palm plantations and 1.1 million tCO2e for palm oil mills. It also reports Scope 2 emissions as 6,300 tCO2e for oil palm plantations and 2,700 tCO2e for palm oil mills. It does not report figures for crushers, refineries, and physical trading of product.

107. GHG emissions intensity?

126 - The company reports its GHG emission intensity (Scope 1 and 2) for 2024 as 126 kgCO2e per MT of product.

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

The company reports GHG emissions from land use change as 0.5 million tCO2e in 2024.

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

110. Progress towards commitment to reduce absolute GHG emissions?

The company reports a reduction in absolute GHG emissions as follows: for oil palm plantations, Scope 1 reduced from 0.9 million tCO2e in 2023 to 0.7 million tCO2e in 2024, and Scope 2 decreased from 6,800 tCO2e to 6,300 tCO2e over the same period. For palm oil mills, Scope 1 reduced from 1.3 million tCO2e to 1.1 million tCO2e, while Scope 2 decreased from 2,900 tCO2e to 2,700 tCO2e. The company does not report figures for crushers, refineries, or physical trading; totals are therefore partial.

111. Progress towards commitment to reduce GHG emissions intensity?

The company reports its GHG emissions intensity (Scope 1 and 2) as 126 kgCO2e per MT of product in 2024 and 128 kgCO2e per MT of product in 2023. Intensity has improved in 2024 as compared to 2023; however, the information is not externally verified.

112. 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. The company's reporting states that it uses the GHG Protocol to calculate GHG emissions.

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

As of 2024, 25 mills have methane capture facilities across the company's operations in Indonesia and Malaysia.

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

The company states that it has met its previous targets of reducing the water usage intensity for its palm oil mills to 1.20 m³/MT FFB processed for Indonesia and 1.30 m³/MT FFB processed for Malaysia, Ghana and Nigeria. As these targets are met, the company has set a new target to achieve a 3% reduction in water use intensity of palm oil mills by 2028, from a 2022 baseline. However, the target only covers oil palm milling operations of the company.

115. Water use intensity?

The company separately reports the water usage intensity of all its oil palm milling operations. However, water use information for the company's refineries and crushing facilities is not reported.

116. Progress towards commitment on water use intensity?

[Externally verified] Only five regions out of the total seven regions of oil palm mills show a reduction in water usage intensity in 2024 as compared to the water usage intensity reported in 2023. The information is externally verified by Ernst & Young LLP (EY) for both years; however, the information for the company's refineries and crushing facilities is not reported.

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

The company's BOD levels are within the legal limits as of 2024.

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

[Externally verified] The company reports that the BOD level for all its mills was compliant with relevant local thresholds in 2024. Evidence is externally verified by Ernst & Young LLP (EY).

119. 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's reporting states that POME from mills undergoes treatment, including anaerobic and aerobic biological digestion, before reuse.

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

[Externally verified] The company mentions that 'Palm oil refinery effluent (PORE)', from the refining of crude palm oil (CPO), is treated using chemical processes to remove oil, grease and inorganic substances, followed by aerobic biological digestion. Evidence is externally verified by Ernst & Young LLP (EY).

121. 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 reports its commitment to protecting natural waterways through buffer zones.

122. 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.

123. 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 reports its commitment to minimise the use of chemicals, including pesticides and chemical fertilisers.

124. 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.

125. 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 reports its commitment to no use of paraquat.

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

The company commits all suppliers to not use paraquat.

127. 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 reports its commitment to only use World Health Organisation (WHO) Class 1A and 1B pesticides in exceptional circumstances.

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

The company commits all suppliers to only use World Health Organisation (WHO) Class 1A and 1B pesticides in exceptional circumstances.

129. 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 reports its commitment to only use Stockholm and Rotterdam Convention chemicals in exceptional circumstances.

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

The company commits suppliers to only use Stockholm and Rotterdam Convention chemicals in exceptional circumstances.

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

The company reports chemical usage in oil palm plantations (kg of active ingredients per ha) in all regions for 2024.

132. 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's reporting states that waste generated by its upstream operations, which includes biomass materials such as EFB, mesocarp fibre and PKS from palm oil production, is recovered and reused as fuel or fertiliser wherever possible.

133. 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 having an integrated pest management (IPM) approach, which includes breeding and releasing barn owls, which are natural predators of rats.

134. 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 reports having a waste management system in place for all operations where hazardous waste, including non-reusable chemicals, is carefully collected and disposed of by licensed contractors, who handle the waste in full compliance with local regulations. Similarly, non-hazardous waste is managed internally where possible, while materials such as metals and glass are handled by licensed third-party contractors, ensuring adherence to regulatory requirements.

135. 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 reports its commitment to the UN Declaration on Human Rights.

136. Commitment to human rights applies to all suppliers?

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

137. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports it regularly carries out due diligence as part of its Human Rights Due Diligence (HRDD) approach and also has the Human Rights Risk Analysis and Gap Identification (HuRRAGI) programme in place since February 2023. Additionally, the company provides regular human rights training to its employees and suppliers.

138. Commitment to respect Indigenous Peoples' 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 reports its commitment to the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP).

139. 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.

140. 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 reports its commitment to the UN Food and Agriculture Organisation's Voluntary Guidelines on the Responsible Governance of Tenure, Fisheries and Forests in the Context of National Food Security.

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

The company commits suppliers to the FAO Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security.

142. 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 reports its commitment to free, prior and informed consent (FPIC).

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

The company commits all suppliers to respect FPIC.

144. 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.

145. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company conducts participatory mapping in land-related planning, involving affected communities, stakeholders, independent experts, and supporting NGOs. In case of conflicts, it commits to timely and transparent remediation of any adverse human rights impacts, following its Grievance Procedure. Progress reports on the Pasaman Barat Community, West Sumatra, indicate collaboration with community leaders and the Earthworm Foundation for conflict prevention and grievance development. However, the external verification report is from May 2022, over two years old now.

146. 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's reporting includes the land conflicts process as a part of its grievance process.

147. 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.

148. 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 reports its commitment to mitigate impacts on food security.

149. 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's reporting states that it supports food security in local communities by helping farmers grow other crops and establish food production businesses. In Ghana, the company allocates areas of land for workers to grow vegetables, improving their access to fresh food and reducing their dependency on external sources. In addition, the company provides guidance on responsible farming practices, such as the safe use of agrochemicals, to protect both health and the environment.

150. 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 reports its commitment to providing essential community services and facilities.

151. 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 multiple pieces of evidence for progress on its commitment to providing essential community services and facilities in the field of education and healthcare.

152. 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 reports that it is committed to hiring employees from the local talent pool, subject to suitability.

153. 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 reports its commitment to the ILO's Declaration on Fundamental Principles and Rights at Work.

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

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

155. 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's reporting states partnering with Dignity in Work for All (formerly Verité Southeast Asia) since 2017, a technical partner and labour rights expert, to identify potential root causes of issues such as child labour, the links between work and pay practices and emerging labour challenges.

156. 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 reports its commitment to eliminating gender-related discrimination with regard to employment.

157. 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.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that since 2007, it has formed women's committees across its oil palm plantations, and by 2020, WoW or Gender Committees were operational across plantations in Indonesia, Malaysia, Nigeria and Ghana, serving as critical channels for implementing and communicating its social policies. In 2019, the Women's Committee Steering Group (WCSG) was formed to align efforts with the five focus areas of the company's Women's Charter. Additionally, all new hires are required to read and acknowledge the Workplace Behaviour Policy as part of their induction. In 2024, there were zero reported incidents of harassment and discrimination.

159. Percentage or number of temporary employees?

17.9% - The company reports 17.9% temporary employees as a part of its workforce in 2024.

160. Reports gender balance of employees?

23.8% - The company reports that 23.8% of its total global employee headcount was female in 2024.

161. Commitment to pay a 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 also reports its commitment to pay a living wage to all its workers.

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

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

163. Progress on commitment to pay a living wage?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company's reporting only states that in 2024, it assessed 100% of its employees and contractors to ensure they are paid a living wage. However, clear figures/ratios for the wages paid are not reported by the company.

164. Reporting of salary by gender?

The company reports the female-to-male ratio of weighted average annual basic salary and remuneration by employee category, however, the data is not split by significant locations of operations.

165. 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 reports its commitment to addressing occupational health and safety at work.

166. 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.

167. 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 reports that all of its employees and workers who may be exposed to risks to their health or safety while at work are provided with PPE and guidance or training on its proper use.

168. Time lost due to work-based injuries?

0.48 - The company reports the Lost Time Injury Rate (LTIR) per 200,000 hours worked for employees and contractors in 2024 as 0.48.

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

9 - The company reports nine work-related fatalities among its employees and contractors in 2024.

170. 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 reports its commitment to supporting smallholders.

171. Programme to support scheme smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it implements a range of scheme smallholder programmes across its key operations to empower farmers with the training and resources needed to adopt sustainable practices, enhance yield per hectare and work towards relevant industry certifications.

172. Percentage of scheme smallholders involved in programme?

100% - The company reports that in 2024, it provided support to 100% of its scheme smallholders. However, the information reported is not externally verified.

173. Programme to support independent smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that its independent smallholder programmes are tailored to the specific needs of farmers in each country. Support includes capacity building, facilitating better access to high-yield seedlings and high-quality fertilisers, training on sustainable agricultural practices, support to attain ISPO, MSPO and RSPO certifications and so on.

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

[Externally verified] 4785 (41.1%) - The company reports that 41.1% of its independent smallholders were supported by the company's capacity-building programmes in 2024. Information on the number of independent smallholders involved in the programme (4,785) is externally verified by Ernst & Young LLP (EY).

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

The company that it has developed and launched the Supplier Reporting Tool (SRT) in 2017 to enable better assessment of its suppliers' progress and their implementation of the NDPE policy. The SRT is an online self-reporting tool that is hosted on the OnConnect system to allow suppliers to report their current compliance to environmental and social risk-related issues within the company's supply chain.

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

[Externally verified] 917 (100%) - As of 2024, 100% of the company's suppliers were engaged on compliance with the company's policy. Evidence is externally verified by the Control Union.

177. Suspension or exclusion criteria for suppliers?

The company operates a 'suspend first' approach where suppliers involved in verified cases of deforestation and/or new development on peatland face immediate suspension at the group level. Through corrective measures and action, suspended suppliers can re-enter the company's supply chain. Minimum requirements for re-entry into the company's supply chain are also published.

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

The company has published time-bound action plans to ensure NDPE implementation throughout its supply chain.

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

[Externally verified] 95.9% - The company reports that as of December 2024, 95.9% across its global supply chain have achieved "Delivering" status for both No Deforestation and No Peat requirements using the NDPE IRF. Evidence is externally verified by the Control Union.

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

The company engages with all high-risk mills on an annual basis.

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

[Externally verified] The company conducts site visits with high-risk supplying mills and provides them with time-bound action plans to bring them into compliance.

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

[Externally verified] The company's Supplier Reporting Tool (SRT) is used to assess its own and supplier mills for risk annually, and high-risk mills undergo site assessments or direct engagement. Evidence is externally verified by Control Union.

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

The company's Supplier Reporting Tool (SRT) is used to assess its own and supplier mills for risk annually, in conjunction with mills' certification status, SRT responses, grievances, NDPE commitment, TTP, SCGP, grievances raised against them and GFW commodity risk geospatial analysis.

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

[Externally verified] The company assesses mill risk annually. This information is externally verified by Control Union.

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

[Externally verified] The company reports the number of suppliers assessed as high-priority mills as 11 or 1.2% and as low-priority mills as 906 or 98.8% in 2023. Evidence is externally verified by Control Union.

186. 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 reports its commitment to ethical conduct and the prohibition of corruption.

187. 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.

188. 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's reporting only states that all employees, including part-timers and contractors, receive training and specific guidance on its corporate policies, including anti-bribery and corruption, as part of the onboarding process.

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

The company has published its tax policy and states that its Group Tax department oversees and monitors the tax risks of all companies within the group and the tax department is supported by the tax and finance teams in the respective jurisdictions.

190. 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 policy in place.

191. 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 also has a grievance procedure in place, which is open to all stakeholders.

192. Details of complaints and grievances disclosed?

86 grievances have been logged since June 2014. Details of all grievances are published on the company website.