AAK AB

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

This indicator is disabled as the company is only a processor or trader.

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

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

3. High-level position of responsibility for sustainability?

The company has a Director of Sustainability.

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

The company's board of directors has the overall responsibility for the company's sustainability progress and performance.

5. Reports gender balance of senior management team?

36% - The company reports that 36% of its senior management team are women.

6. Reports gender balance of board members?

50% - The company reports that 50% of its board of directors were women in 2023.

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

[Externally verified] The company is a member of the UNGC and POCG.

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

The company collaborates with Forever Sabah for independent smallholder certification in Sabah, partners with the Musim Mas/Nestle program to address deforestation in Aceh, Indonesia, and works with Earthqualizer to monitor deforestation risks in Malaysia, Indonesia, and Papua New Guinea. It also collaborates with Solidaridad in Mexico to promote sustainable agricultural practices.

9. Sustainability report published within last two years?

The company published its latest sustainability report for 2023.

10. Reports through standardised reporting systems?

The company's sustainability report 2023 has been prepared in accordance with GRI 1: Foundation 2021 and it has also submitted the CDP questionnaire for 2023.

11. Verification report on compliance with POIG Charter, if a POIG member?

This indicator is disabled as the company is not a POIG member.

12. Climate risks assessment available?

The company reports a detailed climate-related risk assessment such as actual and potential impacts of climate change on the company, metrics, targets, and processes used to assess or manage climate risks.

13. Lists countries and operations?

The company lists the countries it's refineries are located in: Brazil, China, Colombia, Denmark, India, Japan, Malaysia, Mexico, Netherlands, Sweden, Turkey, UK, USA, Uruguay.

14. Lists countries sourcing from?

The company provides a full mill list, which discloses all the countries that the company is sourcing from.

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

This indicator is disabled as the company is only a processor or trader.

16. Total oil palm planted area (ha)?

This indicator is disabled as the company is only a processor or trader.

17. Scheme smallholders planted area (ha)?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

20. Maps of estates/management units?

This indicator is disabled as the company is only a processor or trader.

21. Maps of all scheme smallholders?

This indicator is disabled as the company is only a processor or trader.

22. Maps of all third-party supplying plantations?

23. Number of company-owned mills?

This indicator is disabled as the company does not own mills.

24. Names and locations of company-owned mills?

This indicator is disabled as the company does not own mills.

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

This indicator is disabled as the company does not own mills.

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

This indicator is disabled as the company does not own mills.

27. Number of third party supplying mills?

1382 - The company reports that it has 1,382 third-party supplying mills.

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

The company has disclosed a public mill list, with all the mill names and coordinates.

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

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

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

The company reports that 70% of supply comes from origin refineries rather than directly from mills.

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

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

33. Percentage of supply traceable to mill level?

The company already has achieved 100% traceability to mills in 2021. Some of the company's refineries have IP and SG certification.

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

The company commits to achieve 100% traceability to plantation level by the year 2025.

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

This indicator is disabled as the company does not own mills.

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

The company reports that 93% of supply from third-party mills is traceable to the plantation level. The company has some IP certificates.

37. Publishes traceability data at refinery level?

The company reports traceability to mill and plantation level for each refinery.

38. Publishes traceability data at crusher level?

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

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

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

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

[Externally verified] 2010 - The company became an RSPO member in 2004 and was first certified in October 2010.

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

The company has submitted its latest RSPO ACOP 2023.

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

This indicator is disabled as the company is only a processor or trader.

43. Percentage of mills RSPO-certified?

This indicator is disabled as the company does not own mills.

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

This indicator is disabled as the company is only a processor or trader.

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

2018 - The company has already achieved 100% RSPO certification of all palm product processing facilities.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

39.11% - The company reports that 39.11% of palm oil and palm oil products are certified and processed.

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

This indicator is disabled as the company is only a processor or trader.

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

The company reports 25.57% RSPO-certified palm oil through segregated or identity preserved supply chains in RSPO ACOP 2023.

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

This indicator is disabled as the company is only a processor or trader.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

This indicator is disabled as the company does not operate in Malaysia.

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

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

55. Commitment to zero conversion of natural ecosystems?

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to eliminate the conversion of other natural ecosystems. This commitment has been in place since 2015. However, the commitment does not cover all natural ecosystems.

57. Commitment to zero deforestation?

This indicator is disabled as the company is only a processor or trader.

58. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to no development in High Conservation Value (HCV), High Carbon Stock (HCS) and peatland areas. This commitment has been in place since 2015.

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

This indicator is disabled as the company is only a processor or trader.

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

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

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

This indicator is disabled as the company is only a processor or trader.

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

[Externally verified] The company reports that it uses satellite monitoring through Earthqualizer and Satelligence to monitor 100% of its supply chain, which provides biweekly reports, identifying potential deforestation that is then investigated with its direct suppliers. This information is externally verified by Satelligence and Earthqualizer.

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

This indicator is disabled as the company is only a processor or trader.

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

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

This indicator is disabled as the company is only a processor or trader.

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

67. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company supports the 'Forever Sabah' initiative to help independent smallholders achieve RSPO certification. It also reports collaborating with Nestle and Musim Mas on a landscape project in Sumatra and supports the Solidaridad project in Mexico, which promotes good and sustainable agricultural practices.

68. Biodiversity policy?

This indicator is disabled as the company is only a processor or trader.

69. Biodiversity policy applies to all suppliers?

The company reports a general commitment to the protection and restoration of biodiversity. However, the scope of this commitment is not provided.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to conduct HCV assessments.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits to only use licensed HCV assessors accredited by the HCV Resource Network's ALS. However, it does not apply to all suppliers.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

83. 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.

84. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

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

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

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

This indicator is disabled as the company is only a processor or trader.

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

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

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company only commits to the best management practices to protect soil quality.

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

This indicator is disabled as the company is only a processor or trader.

96. Commitment to zero burning?

This indicator is disabled as the company is only a processor or trader.

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

98. Evidence of fire monitoring and management?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits to reduce its absolute scope 1 and 2 GHG emissions by 50% by the year 2030 from a base year of 2019. However, the target is not intensity-based.

102. GHG emissions intensity?

The company reports its GHG emission intensity including scope 1 and scope 2 as 130 kg CO2e/t raw material in 2022. However, it is unclear if it is specific to whole palm oil operations.

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

This indicator is disabled as the company is only a processor or trader.

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

The company reports its scope 3 emissions as FLAG (forest, land & agriculture) emissions, which include agriculture, land use change, and land management. However, figures specific to land use and specific to whole palm oil operations are unclear.

105. Progress towards commitment to reduce GHG emissions intensity?

The company reports that its absolute scope 1 and 2 GHG emissions reduced by 8.4% in 2023 compared to 2022, an overall improvement of 12% compared to the base year 2019. However, reports progress but not as intensity figures.

106. Methodology used to calculate GHG emissions?

The company uses the IPCC, GHG Protocol, and DEFRA methodology to calculate GHG emissions.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits to reduce its freshwater consumption by 50% compared to the 2019 base year by 2030. However, it does not refer to water use intensity.

109. Water use intensity?

0.35 - The company reports its water consumption intensity as 0.35 m3 per tonne of processed material in 2022. However, it is not clear if the figure is specific to whole palm oil operations.

110. Progress towards commitment on water use intensity?

The company reports an increase in the water consumption intensity from 0.34 m3 per tonne of processed material (2021) to 0.35 m3 per tonne of processed material (2022). However, it reports figures on water use intensity over time but intensity was not improving.

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

The company reports a general commitment to water quality that does not refer to BOD or COD, it is not timebound or measurable.

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

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

This indicator is disabled as the company does not own mills.

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

The company has a wastewater treatment plant in Ghana. However, it does not explicitly mention PORE.

115. Commitment to protect natural waterways through buffer zones?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits suppliers to the correct use and application of agrochemicals that eliminates or minimises any potential harm to the environment or human health. This is not a clear commitment to minimise the use of chemicals, and pesticides and chemical fertilisers are not explicitly mentioned.

119. Commitment to no use of paraquat?

This indicator is disabled as the company is only a processor or trader.

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

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

This indicator is disabled as the company is only a processor or trader.

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

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

This indicator is disabled as the company is only a processor or trader.

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

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

This indicator is disabled as the company is only a processor or trader.

126. Implementation of commitment to minimise inorganic fertiliser use?

This indicator is disabled as the company is only a processor or trader.

127. Integrated Pest Management (IPM) approach?

This indicator is disabled as the company is only a processor or trader.

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

The company reports limited details of its waste management system such as the segregation of waste into hazardous and non-hazardous categories. It also focuses on reducing hazardous waste and finding sustainable alternatives for materials like bleaching earth.

129. Commitment to human rights?

The company commits to the UN Guiding Principles on Business and Human rights.

130. Commitment to human rights applies to all suppliers?

The company commits suppliers to the UN Guiding Principles on Business and Human rights.

131. Progress on human rights commitment?

The company reports that it conducts human rights risk assessments across its palm oil supply chain and has initiated efforts to strengthen governance and accountability structures for human rights. This includes training and awareness initiatives about the prohibition of forced labor. It also conducted an e-learning program for the group code of conduct.

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

This indicator is disabled as the company is only a processor or trader.

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

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

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

This indicator is disabled as the company is only a processor or trader.

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

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

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits all suppliers to respect FPIC.

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

This indicator is disabled as the company is only a processor or trader.

139. Examples of local stakeholder engagement to prevent conflicts?

This indicator is disabled as the company is only a processor or trader.

140. Details of process for addressing land conflicts available?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

142. Commitment to mitigate impacts on food security?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

144. Commitment to provide essential community services and facilities?

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

This indicator is disabled as the company is only a processor or trader.

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

The company commits to all Fundamental ILO Conventions.

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

The company commits all suppliers to all Fundamental ILO Conventions.

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

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

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

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

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

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

The company reports that it has initiated ethical behaviour training, including programs on discrimination, diversity and inclusion, and unconscious bias. This information does not specifically address gender-related discrimination and data is between two to five years old. The company also reports that it set up a Diversity and inclusion team in 2022 and rolled out a training programme. it does not specifically reference gender related discrimination.

153. Percentage or number of temporary employees?

4% - The company reported that 4% of its staff were temporary employees in 2020, this information is between two and five years old. In 2023, the company only reports temporary employee figures in a graph, however, it is not possible to clearly read a figure from the graph.

154. Reports gender balance of employees?

23% - The company reports only 23% of female permanent employees. Further, it also reports information for various employment categories including management level, region level, and leadership level. This is for all operations, including palm oil.

155. Commitment to pay a living wage?

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

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

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

157. Progress on commitment to pay a living wage?

158. Reporting of salary by gender?

159. Commitment to address occupational health and safety?

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

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

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

161. Provision of personal protective equipment and related training?

The company commits to have adequate health and safety procedures and use relevant protective equipment. However, no further details were provided for training.

162. Time lost due to work-based injuries?

0.46 - The company recorded a lost time injury frequency rate (LTIFR) of 0.46 in 2023. Calculated as recordable injuries x 2,000,000/total working hours.

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

0 - The company reports zero fatalities in 2022.

164. Commitment to support smallholders?

The company has published a commitment to support smallholders.

165. Programme to support scheme smallholders?

The company states that it supports smallholders by investing in training programs and promoting good agricultural practices. However, the type of smallholders involved was unclear.

166. Percentage of scheme smallholders involved in programme?

4100 - The company reports that 4,100 smallholders were engaged in various initiatives conducted in 2023. However, the type and percentage of smallholders were unclear.

167. Programme to support independent smallholders?

The company supports the Forever Sabah NGO initiative, which aims to provide RSPO certification to independent smallholders. It also has a Solidaridad project in Mexico that promotes good and sustainable agricultural practices to increase fruit and oil productivity for smallholders both within and outside its supply chain.

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

342 - The company reports that 342 independent smallholders were certified under RSPO in 2023.

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

The company states suppliers in Mexico and Colombia have completed self-assessments. Further, it also reports that Proforest has supported training programs and individual audits of suppliers.

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

100% - The company reports that 100% of palm suppliers signed the new and updated 'Group Policy' and 'Code of Conduct for Responsible Sourcing of Plant-Based Oils'.

171. Suspension or exclusion criteria for suppliers?

The company states that it will terminate commercial relations with the supplier if found any violation or breach against the 'Code of Conduct for Suppliers of Raw Materials'. Further, it agreed upon timeframes for action that should be within one working week, depending on the severity and complexity of the case.

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

The company published a time-bound action plan for all its suppliers to be compliant. However, no information on KPIs could be found.

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

The company reports that 83% of its palm oil supply chain was verified as deforestation-free. The assessment includes third-party verification.

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

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

The company reports that it works with Proforest to identify priority suppliers and to improve environmental management. It also conducts training and workshops. Further, detailed assessments were done for audited mills to identify compliance gaps.

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

The company worked with Proforest to develop an online mill engagement platform for self-assessment of commitments and progress. It is unclear how frequently this engagement takes place.

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

The company states that it has a procedure to conduct site assessments on mills. It also reports that it uses satellite monitoring methods in its diligence process, covering 100% of the mills in its palm oil supply chain. However, no details of the procedure can be found.

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

The company states that it is working with Proforest and conducts site assessments on an annual basis to ensure environmental improvements are made in the mills.

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

180. Commitment to ethical conduct and prohibition of corruption?

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

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

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

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

The company reports that it offers e-learning courses for employee training, conducts annual anti-corruption risk assessments of its operations, and reported zero confirmed incidents of corruption in 2023.

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

184. Whistleblowing procedure?

The company has a whistleblowing procedure including a flowchart that reports unethical conduct and how they are protected.

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

The company has a grievance management procedure open to all stakeholders.

186. Details of complaints and grievances disclosed?

[Externally verified] The company has a grievance tracker which includes the date, issue, status, alleged issue, and progress of grievances.