Wilmar International Ltd

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

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

3. High-level position of responsibility for sustainability?

Chief Sustainability Officer.

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

The company has a board-level Risk Management Committee which supports the chairman and CEO with implementing its NDPE policy, as well as reviews sustainability reports and emerging issues on a quarterly basis.

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

22% - Figure covers the company's entire operations.

6. Percentage or number of women board members?

1 (8.3%)

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

[Externally verified] Tropical Forest Alliance 2020, UN Global Compact, Fire Free Alliance, HCS Approach Steering Group, NYDF, PONGO Alliance, Grow Asia.

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

The company states that it has engaged with around 200 NGOs, hosted several formal stakeholder dialogues and engages with NGOs through participation in multi-stakeholder initiatives or ad hoc discussions. It is part of the Sabah government's Sabah Jurisdictional Approach Steering Committee. It also details wildlife initiatives undertaken with government and NGOs.

9. Sustainability report published within last two years?

10. Reports through standardised reporting systems?

GRI, CDP.

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)?

327036 - Sum of total land area controlled/managed for oil palm cultivation by the company is 251,158.40 ha and by its subsidiary PPB Oil Palms is 75,878.27 ha. Data as of 2017.

14. Total oil palm planted area (ha)?

230409 - The company also has 46,000 ha in joint ventures in Uganda and West Africa.

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

35799 - The company also has another 149,000 hectares under smallholder and outgrower schemes through joint ventures and associates in Africa.

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

12364.2 - Total unplanted (11,015.29 ha for Wilmar International + 1,348.96 ha for PPB Oil Palms). Figures as of 2017.

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

30288

18. Area for infrastructure (ha)?

14000

19. Maps of estates/management units?

Concession boundaries have been made available to the RSPO, and the company declares this represents 100% of its concessions, but not all may be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO.

20. Maps of scheme/plasma smallholders?

Scheme smallholder boundaries have been made available to the RSPO as part of its estate maps according to the company, but not all may be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO. Maps of FFB suppliers, including small growers, are available for the company's nine mills in Malaysia.

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

The company details the locations of its FFB supply base of all its mills in Malaysia only.

22. Number of company-owned mills?

45 - This includes nine stand-alone mills that do not have a supply base of directly owned or managed plantations, or associated smallholders.

23. Names and coordinates of company-owned mills?

24. Number (or percentage) of company-owned mills that source from company-owned plantations and/or third-party plantations?

25. Total volumes (or percentages) sourced by company-owned mills that come from company-owned plantations and/or third-party plantations?

The company reports that its own mills source "42% of FFB from its own plantations, 5% from scheme smallholders and the remaining 53% from third-party sources".

26. Number of supplier mills?

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

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

The company states that there are over 850 supplier mills in Malaysia and Indonesia. A list of the supplying mills and their coordinates can be found through clicking the links in the company's Supply Chain resources.

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

29. Total volumes (or percentages) sourced from third-party supplier mills that come from their own plantations and/or third-party plantations?

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 percentage sourced that are either company owned mills, third party mills, company owned refineries or others (refiners/traders/bulkers).

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

The company made a commitment to be traceable to mill level for all palm oil physically handled by company refineries, but the commitment was not time-bound.

32. Percentage of supply traceable to mill level?

[Externally verified] 96% - As of December 2018, the company has achieved 96% traceability to mills. Specifically, 98.5% traceability to mills in Indonesia, and 99.4% traceability to mills in Malaysia.

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

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

[Externally verified] 100%

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

The company states that most FFB from supplying mills are currently 0% traceable to plantation level. It reports percentage traceability to plantation in its 2017 Q4 Progress Report for Indonesia and Malaysia refineries ranging from 0% to 35.7%, and states that approximately 15% of third-party supplying mills are traceable to plantation level.

36. Publishes traceability data at refinery level?

37. Publishes traceability data at crusher level?

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

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

40. Criteria for defining deforestation?

HCS, HCV, peat; cut-off date 2015.

41. Evidence of monitoring deforestation?

[Externally verified] The company states it uses the Spatial Monitoring, drones and Reporting Tool (SMART) to monitor HCV areas and identify threats, and is committed to contributing to TFT's efforts to use its newest technology "Starling", to add to company deforestation monitoring intelligence and expedite ground-truthing in critical landscapes.

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

The company states "Since our monitoring programme has been put in place, we have recorded no illegal and/or deforestation cases in our own operations as at end of 2018.".

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

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

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.

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

Cut-off date December 2015.

46. Implementing a landscape or jurisdictional level approach?

The company is a member of RSPO's Sabah Jurisdiction Approach Steering Committee and is implementing the Aggregator Refinery Transformation (ART) program as a landscape level approach aimed at transforming its supply chain.

47. Commitment to biodiversity conservation?

48. Commitment to biodiversity conservation applies to all suppliers?

The policy only applies to joint ventures and smallholders.

49. 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/volume.

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

[Externally verified] The company states it has a riparian rehabilitation project, has undertaken community outreach on restoration of degraded areas, and has organised a workshop on improving management of HCV areas, among others. Points for external verification have been awarded on the basis of the company's RSPO certified landbank/volume.

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

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

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

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

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

[Externally verified] There is public availability of the following HCV assessments:
Sumatra: PT Agrindo Indah Persada.
Kalimantan: PT Agronusa Investama - Sambas District, PT.
Nigeria: Biase Plantations - Ibiae Estate.

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

[Externally verified] There is public availability of the following HCV assessments:
Nigeria: Biase Plantations – Calaro Extension.

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

[Externally verified] There is public availability of the following HCV management and monitoring plans: Nigeria: Biase Plantations – Calaro Extension.

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

59. 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?

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

[Externally verified] An assessment for Benso Oil Palm Plantations Limited smallholder site in Ghana has a satisfactory review.

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

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

63. High Carbon Stock (HCS) assessments?

[Externally verified] HCS assessment published on High Carbon Stock website for PZ Wilmar – Nigeria, Calaro Extension.

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

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

66. Social and environmental impact assessments (SEIAs) undertaken, and associated management and monitoring plans?

[Externally verified] There is public availability of the following SEIA:
Sumatra: PT Agrindo Indah Persada – Jambi Province.
West Kalimantan: PT Agronusa Investama – Sambas District.
Nigeria: Biase Plantations – Ibiae Estate and extension.

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

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

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

Planted areas on peat have not increased between 2017 and 2018.

70. Landbank or planted area on peat?

22104 - The company reports peat planted area figures for its operations in Sabah, Sarawak, Kalimantan and Sumatra.

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

72. 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.

73. 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/volume.

74. Commitment to zero burning?

75. Commitment to zero burning applies to all suppliers?

76. Evidence of fire monitoring and management?

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

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

The company reports the number of fires within a 5 km radius of concessions.

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

The company has a target to reduce the overall GHG emissions intensity of its mills by 15% by 2023, but this does not cover all of its palm oil operations.

80. Methodology used to calculate GHG emissions?

RSPO PalmGHG calculator.

81. Progress towards commitment to reduce GHG emissions intensity?

The company reports carbon intensity (tCO2e/MT CPO) across its operations and reports an overall decrease from 2.88 to 2.77 between 2017 and 2018.

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

23 (51%) - The company states that two additional plants are expected to be completed in 2019.

83. GHG emissions intensity?

2.77 - MT CO2e/MT CPO.

84. GHG emissions from land use change?

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

The company states it has a target to reduce water consumption intensity to 1.2m3 per tonne of FFB processed for Indonesia and 1.3m3 per tonne of FFB processed for Malaysia and Ghana by 2023.

86. Progress towards commitment on water use intensity?

The company reports water use per tonne of FFB processed for 2017, 2017 and 2018. Water usage has increased slightly in some places and it is not clear if the company's overall water usage is improving.

87. Water use intensity?

1.34

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

The company commits to maintain BOD levels below local thresholds but the commitment does not cover COD.

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

The company reports BOD levels by region and discharge destination. These have increased across some operations but remain within legal limits as reported by the company. It does not report figures for COD.

90. Treatment of palm oil mill effluent (POME) and/or palm oil refinery effluent (PORE)?

The company states it treats POME, but does not mention PORE.

91. 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.

92. 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/volume.

93. 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.

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

95. Implementation of commitment to reduce chemical usage?

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

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

The company reports toxicity per hectare by region.

97. Commitment to no use of paraquat?

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

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

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

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

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

103. Integrated Pest Management (IPM) approach?

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

104. Commitment to human rights?

105. Commitment to human rights applies to all suppliers?

106. Progress on human rights commitment?

The company provides training on human rights to its employees and has put in place several means of checking supplier compliance, including supplier support and trainings, among others. Points for external verification have been awarded on the basis of the company's RSPO certified landbank/volume.

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

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

The company's supplier commitment does not cover legal land rights.

109. Details of process for addressing land conflicts available?

110. 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.

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

The company does not have a clear commitment for its suppliers to comply with the UNDRIP.

112. Examples of local stakeholder engagement to prevent conflicts?

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

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

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

115. 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.

116. Commitment to support the inclusion of women across palm oil operations, including addressing barriers faced?

117. Commitment to support the inclusion of women across palm oil operations, including addressing barriers faced, applies to all suppliers?

118. 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.

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

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

121. Commitment to provide essential community services and facilities?

122. 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/volume.

123. Commitment to respect all workers' rights?

124. Commitment to respect all workers' rights applies to all suppliers?

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

The company has been working with Verite to improve labour issues within its operations.

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

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

128. Commitment to eliminate gender-related discrimination with regards to employment and occupation?

129. Commitment to eliminate gender-related discrimination with regards to employment and occupation applies to all suppliers?

130. Percentage or number of temporary employees?

10.8%

131. Percentage or number of women employees?

15539 (33.1%)

132. Commitment to pay at least minimum wage?

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

134. Progress on commitment to pay minimum wage?

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

135. Reporting of salary by gender?

136. Commitment to address occupational health and safety?

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

138. Reduction of time lost due to work-based injuries?

The company reports an overall improvement in Lost Time Injury Frequency Rates (LTIFR) across its palm oil plantations and mills, but this does not cover all of the company's palm oil operations.

139. Time lost due to work-based injuries?

The company provides Lost Time Injury Frequency Rate (LTIFR) per 200,000 Working Hours for its plantations and mills only.

140. Zero fatalities as a result of work-based accidents?

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

6 - In 2018.

142. 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/volume.

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

[Externally verified] 2005 - The company has been a member since 2005. Its joint ventures and associates Adani Wilmar, Olenex, Goodman Fielder, Delta Wilmar and Volac are also RSPO members.

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

[Externally verified] PPB Oil Palms certified its first estate in 2008 and Wilmar International in 2010.

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

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

The company states the countries in which the it operates and has over 50% shareholdings: Indonesia (Bengkulu, West Kalimantan, Central Kalimantan, Riau, West Sumatera, South Sumatra, North Sumatra), Malaysia (Sabah, Sarawak), Ghana and Nigeria. The company also has operations, through joint ventures in Uganda and West Africa. However, with less than 50% shareholdings, these are not under the company's management control.

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

2023 - An original target of 2013 was extended to 2016, then to 2018, then to 2022, and now 2023.

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

[Externally verified] 76% - The company states in its 2018 sustainability report that it has 76% of its planted area certified. The company does not report this data in its 2018 ACOP.

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

[Externally verified] 5525.86 (14.4%) - Data as of 2017.

150. Percentage of mills RSPO-certified?

[Externally verified] 28 (77%) - The calculation excludes nine stand-alone mills that do not have a supply base of directly owned or managed plantations, or associated smallholders.

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

2023 - An original target of 2019 was extended to 2022 and then to 2023.

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

[Externally verified] 51534.9 (1.3%) - Calculation: FFB volume supplied that is certified for independent smallholders, outgrowers and other third party suppliers for Wilmar and PPB Oil Palms divided by total FFB volume that is supplied for Wilmar and PPB Oil Palms. Data as of 2017.

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

2020 - The company states "Only for subsidiary manufacturing plants" in the company's 2017 ACOP.

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

[Externally verified] 5%

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

[Externally verified] In the company's 2017 ACOP it reports it sells through Mass Balance and Book & Claim only, but processes Segregated as well. Its subsidiary PPB Oils reported it sold through Identity Preserved and Mass Balance. This data was not reported in the company's 2018 ACOP.

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

[Externally verified] The company states eight mills and their supply bases have been certified.

157. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company has certified nine mills and their supply bases to date.

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

[Externally verified] ISCC.

159. Commitment to support smallholders?

160. Programme to support scheme/plasma smallholders?

[Externally verified] Scheme smallholders are supported through initial financing for development and land preparation, provision of planting materials such as seedlings, fertilisers and pest control, technical assistance and training.Points for external verification have been awarded on the basis of the company's RSPO certified landbank/volume.

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

The company states a total of 15,883 scheme smallholders were supported but it is unclear what the proportion of smallholders supported overall is.

162. Programme to support independent smallholders/outgrowers?

[Externally verified] The company supports independent smallholders by providing training and facilitation to obtain ISPO certification in collaboration with Wild Asia’s group smallholder programme.

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

The company states a total of 13,669 independent smallholders are covered by support programmes but it is unclear what the proportion of smallholders supported overall is.

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

The company states that mills are selected for assessment using the Mill Prioritisation Process (MPP), developed together with TFT, in a process that combines spatial and non-spatial information relating to environmental and social components.

165. Percentage of suppliers assessed and/or engaged on compliance with company requirements?

[Externally verified] The company states that 429 mills have participated in the Supplier Reporting Tool (SRT).

166. Time-bound plan to engage with all high-risk mills within three years?

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

[Externally verified] The company states that for cases under the “Suspend then Engage” approach, it will publish a ReEngagement Protocol specifying the time-bound process to engage suppliers that have been suspended, including the terms and conditions to resume sourcing.

168. Regularly engages with a subset of high-risk mills?

The company enagages with suppliers through the Supplier Reporting Tool, which is done annually.

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

The company has internal compliance teams to conduct annual internal audits of its own mills, and conducts risk screening of supplying mills through ART.

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

The Supplier Reporting Tool requires suppliers to report on their compliance on an annual basis.

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

172. Suspension or exclusion criteria for suppliers?

The company states "with effect from 1 January 2019, Wilmar requires all suppliers at group level to provide written confirmation of their commitment to adhere to our NDPE policy (to be provided by Q1 2019), unless they already have an acceptable public NDPE policy". It also states "new grievances with verified proof of deforestation and/or peatland development will result in an immediate halt of purchases from the supplier at group-level. We will continue working with the suspended supplier to assist them in moving towards compliance via time-bound action plans. Suspended suppliers must meet minimum re-entry criteria before we are able to resume sourcing".

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

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

175. Commitment to ethical conduct and prohibition of corruption?

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

The company's Anti Fraud Policy applies to all suppliers.

177. 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/volume.

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

179. Whistleblowing procedure?

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

181. Details of complaints and grievances disclosed?

The company provides details on grievances logged through its own grievance procedure and the RSPO Complaints System. It states that it had a total of 30 grievances in 2016.