Olam International

"The Olam Supplier Code (‘Code’) provides a comprehensive set of conditions to support Olam’s goal to purchase raw materials, products, services and various supplies (‘supplies’) that are produced in a manner that is socially responsible, economically profitable and environmentally sustainable. [...] Complying with the International Labour Organization (ILO) [...] Not using forced, involuntary or slave labour [...] Creating an inclusive work environment that avoids any form of discrimination [...] Respecting employees’ rights to form and join unions or other associations, and to bargain collectively [...] prohibiting child labour"

"Supporting smallholders by partnering with the International Institute of Tropical Agriculture in Ibadan"

"Ensure no exploitation within their operations by [...] Encouraging gender equality, equal access and empowerment of women"

"Respect local com munities by; Respecting the rights of local communities and indigenous people and their cultural heritage, including Free, Prior and Informed Consent for new developments"

"Supplier Code Principles [...] Respect the natural environment by: i. Complying with all relevant applicable laws and regulations relating to the protection of the environment. ii. Prohibiting the conversion (i.e. destruction or deforestation) and the sourcing of raw materials resulting from the conversion of the following natural areas: – Legally Protected Areas designated for the protection of nature, and Internationally Recognized Areas for conservation [...] Olam reserves the right to conduct (or have its designee conduct) announced and unannounced inspections of the Supplier’s facilities and business practices to verify compliance with this Code. On the assumption that Olam become aware of non-compliance with any aspect of the Code, Olam reserves the right to demand corrective measures. Olam also reserves the right to terminate an agreement with any supplier that is not in compliance with the requirements set forth in this document."

Generic Grievance process - "Our Grievance Procedure applies to all our upstream operations and supply chain infrastructure (processing plants, warehouses and logistics hubs), and our third-party suppliers. It should be used to report and address breaches of relevant Olam Policies or Codes, resulting in illegality, exploitation of local communities or workers employed by Olam or a third-party supplier, or unacceptable practices in land use management as defined in the Olam Living Landscapes Policy and the Olam Supplier Code. [...] Raising a Grievance: The grievance may be made to: Address: Olam International - Grievance Manager New Zealand House, 80 Haymarket, London SW1Y 4TE. Tel: (+44) 20 7389 6464Email: crs@olamnet.com: Emails should be clearly titled ‘For Attention Of: Grievance Manager, Olam’ Grievances can also be addressed to the relevant Country Office as detailed on the location pages of this website. The grievance should include provision of the following information:• Your full name*• Name of your organization (if any)• Contact details (phone/fax/email/postal address)"

Relating to the supplier code of conduct which contains all labour rights "Olam reserves the right to conduct (or have its designee conduct) announced and unannounced inspections of the Supplier’s facilities and business practices to verify compliance with this Code. On the assumption that Olam become aware of non-compliance with any aspect of the Code, Olam reserves the right to demand corrective measures. Olam also reserves the right to terminate an agreement with any supplier that is not in compliance with the requirements set forth in this document." [...] relating to FPIC - "Auditing On an annual basis the CR&S Function shall facilitate an internal audit of each upstream operation using the Internal Audit Checklist accompanying this Code."

"The Olam Supplier Code (‘Code’) provides a comprehensive set of conditions to support Olam’s goal to purchase raw materials, products, services and various supplies (‘supplies’) that are produced in a manner that is socially responsible, economically profitable and environmentally sustainable. [...] Complying with the International Labour Organization (ILO) [...] Not using forced, involuntary or slave labour [...] Creating an inclusive work environment that avoids any form of discrimination [...] Respecting employees’ rights to form and join unions or other associations, and to bargain collectively [...] prohibiting child labour"

"Ensure no exploitation within their operations by [...] Encouraging gender equality, equal access and empowerment of women"

"If unacceptable practices are reported in our own operations or those of third party suppliers, we will assess the extent and nature of non-compliance and establish a time-bound plan with our suppliers to address the issue and where necessary remediate material negative impacts of non-compliance."

Olam commit their suppliers to "Respecting the rights of local communities and indigenous people and their cultural heritage, including Free, Prior and Informed Consent for new developments

"We will assess risks associated with our Policy requirements in our supply chains, and use these risk assessments to define priorities to be addressed by our businesses with our suppliers, partners and third parties."

"Supplier Code Principles [...] Respect the natural environment by: i. Complying with all relevant applicable laws and regulations relating to the protection of the environment. ii. Prohibiting the conversion (i.e. destruction or deforestation) and the sourcing of raw materials resulting from the conversion of the following natural areas: – Legally Protected Areas designated for the protection of nature, and Internationally Recognized Areas for conservation [...] Olam reserves the right to conduct (or have its designee conduct) announced and unannounced inspections of the Supplier’s facilities and business practices to verify compliance with this Code. On the assumption that Olam become aware of non-compliance with any aspect of the Code, Olam reserves the right to demand corrective measures. Olam also reserves the right to terminate an agreement with any supplier that is not in compliance with the requirements set forth in this document."

Generic Grievance process - "Our Grievance Procedure applies to all our upstream operations and supply chain infrastructure (processing plants, warehouses and logistics hubs), and our third-party suppliers. It should be used to report and address breaches of relevant Olam Policies or Codes, resulting in illegality, exploitation of local communities or workers employed by Olam or a third-party supplier, or unacceptable practices in land use management as defined in the Olam Living Landscapes Policy and the Olam Supplier Code. [...] Raising a Grievance: The grievance may be made to: Address: Olam International - Grievance Manager New Zealand House, 80 Haymarket, London SW1Y 4TE. Tel: (+44) 20 7389 6464Email: crs@olamnet.com: Emails should be clearly titled ‘For Attention Of: Grievance Manager, Olam’ Grievances can also be addressed to the relevant Country Office as detailed on the location pages of this website. The grievance should include provision of the following information:• Your full name*• Name of your organization (if any)• Contact details (phone/fax/email/postal address)"

Relating to the supplier code of conduct which contains all labour rights "Olam reserves the right to conduct (or have its designee conduct) announced and unannounced inspections of the Supplier’s facilities and business practices to verify compliance with this Code. On the assumption that Olam become aware of non-compliance with any aspect of the Code, Olam reserves the right to demand corrective measures. Olam also reserves the right to terminate an agreement with any supplier that is not in compliance with the requirements set forth in this document."

"Our own operations must avoid or mitigate potential negative impacts, therefore all investment cases for any new developments must undergo environmental and social impact assessments and implement the relevant management plans. For our existing operations, we are guided by our Risk Appetite Framework, as well as a suite of Policies, Codes and Standards."

Limited maps of concessions and sawmill locations are given. 3 of total 5 sawmills have locations disclosed. Map is not complete, as does not include concessions in Republic of Congo, only Gabon and Cameroon. Implied that the only concessions with FSC certification are in Republic of Congo: "Olam maintains FSC certification for 100% of its natural forest concessions in the Republic of Congo"

"Where Olam controls operations, our Living Landscapes Policy requirements will be integrated in our own detailed framework for due diligence, planning, standard operating procedures, and reporting. For our own plantations and farms, this detailed framework will continue to be the Olam Plantations, Concessions and Farms Code (OPCF), which covers our requirements for social and environmental due diligence [...] Our businesses may choose to comply with credible international certification standards3 where available, and supplement certification requirements with additional elements of the Living Landscapes Policy. As the parent company of FSC®-certified operations, Olam abides by FSC® Codes4 , rules, and regulations, including the Policy for Association.[...] Where we control operations, our existing codes and policies already specify the elimination of unacceptable practices [...] We will analyse any gaps in the other codes and strategies applying to our own farms and plantations and integrate the new commitments and requirements of this Policy."

"Where we source food, fibre and timber products from third parties, and therefore do not directly control operations, we work with our suppliers to ensure that they conform to our Policies, including the Living Landscapes Policy, through the application of the Olam Supplier Code, OSC, or through a product-specific Policy [...]  The requirement to eliminate unacceptable land use practices applies to all our suppliers from the date of publication of this Policy and our businesses may choose to adopt an earlier date according to the demands of their sector. [...] Implementation, monitoring and evaluation - Each Olam business will take a risk-based approach to address the ambition, objectives and commitments of this Policy, and establish strategies and plans appropriate to our role in growing, sourcing, processing and trading each crop and commodity. Our time-bound commitments for implementing this policy are detailed in section VI and in the accompanying document on eliminating unacceptable practices. [...] Building on the current roll-out of the Olam Supplier Code, we will continue to improve our engagement with third-party suppliers through a global, Olam-wide mechanism for supplier engagement and monitoring to be adopted and rolled out by all businesses" 

"If unacceptable practices are reported in our own operations or those of third party suppliers, we will assess the extent and nature of non-compliance and establish a time-bound plan with our suppliers to address the issue and where necessary remediate material negative impacts of non-compliance. • We will disengage from suppliers who are unable to demonstrate positive steps to eliminate unacceptable practices in a time-bound manner."

"The Olam Supplier Code (‘Code’) provides a comprehensive set of conditions to support Olam’s goal to purchase raw materials, products, services and various supplies (‘supplies’) that are produced in a manner that is socially responsible, economically profitable and environmentally sustainable. [...] Complying with the International Labour Organization (ILO) [...] Not using forced, involuntary or slave labour [...] Creating an inclusive work environment that avoids any form of discrimination [...] Respecting employees’ rights to form and join unions or other associations, and to bargain collectively [...] prohibiting child labour"

"There are 760,000 smallholders in Olam’s sustainability programmes - an uplift of 40% over the last two years, with farms covering 1.4 million hectares. Our approach to unlocking the economic potential of farmers through these programmes, was initially set in 2011 by the principles of the Olam Livelihood Charter which have now been absorbed into the framework of our sustainability insights platform AtSource, with its economic and social indicators. [...] The primary focus is to equip farmers with the knowledge and tools they need to achieve more crop from the same land, at a better quality and therefore higher income."

"Ensure no exploitation within their operations by [...] Encouraging gender equality, equal access and empowerment of women" [...] "Our 2020 goal set in 2015, was to support 100,000 women to have access to economic opportunities, including female farmers, processors, distributors, and workers supported or employed by Olam. We achieved: • More than 146,000 female farmers receiving sustainability support (19% of the total and a 6%-point increase on 2019, particularly due to the cotton programmes starting in Chad). • 10,350 women in our primary workforce. • 15,150 women in our secondary workforce."

"Olam has committed to meeting the FLA Workplace Code of Conduct for the Agriculture Sector and develop remediation plans for identified non-compliances." [...] "Corrective action for non-compliance after cut off date (Feb 2017) may include compensation/ conservation/ restoration of peatland or forest by working with expert stakeholders and communities where feasible. This applies to both their own plantations and their third party supplies."

" Community rights and access will be addressed through FPIC"

"In the event of a possible conflict over the land ownership and use rights of riparian communities, forestry operations that are the direct cause of the conflict may be delayed or suspended until the conflict is resolved."

"Commitment to ensuring our third party suppliers provide palm oil that complies with “No HCV, No HCS, No Peat and No Exploitation” [...] We have zero tolerance for forest burning, and we expect suppliers to take immediate action if burning is found in their supply chain."

"We will request our direct supplier(s) to suspend the producer/ mill, engagement could continue for corrective action. Corrective action for non-compliance after cut off date (Feb 2017) may include compensation/ conservation/ restoration of peatland or forest by working with expert stakeholders and communities where feasible. This applies to both their own plantations and their third party supplies."

"Working with Gabon’s National Park Agency and the Ministry of Forests, OPG implements a biodiversity management plan, with antipoaching policies, to protect iconic species including elephants, gorillas and chimpanzees. In 2019, the team partnered with WWF Gabon to roll out SMART (Spatial Monitoring and Reporting Tool) software to monitor wildlife that live in the protected areas within our concessions. The GPS-enabled tool allows the team to record observations within the 72,000 ha of High Conservation Value (HCV) areas."

"Since February 2011, when we first started development, we have fully complied with the RSPO New Plantings Procedure (inclusive of full ESIAs, HCV assessments and Free, Prior and Informed Consent activities), covering all our upstream activities [...] Since January 2015, all our High Conservation Value (HCV) assessments have been carried out in compliance with the HCV Resource Network’s quality control process, i.e. conducted by independent assessors and peer-reviewed as required per the HCV Assessor Licensing Scheme (ALS)"

"Supplier Code Principles [...] Respect the natural environment by: i. Complying with all relevant applicable laws and regulations relating to the protection of the environment. ii. Prohibiting the conversion (i.e. destruction or deforestation) and the sourcing of raw materials resulting from the conversion of the following natural areas: – Legally Protected Areas designated for the protection of nature, and Internationally Recognized Areas for conservation [...] Olam reserves the right to conduct (or have its designee conduct) announced and unannounced inspections of the Supplier’s facilities and business practices to verify compliance with this Code. On the assumption that Olam become aware of non-compliance with any aspect of the Code, Olam reserves the right to demand corrective measures. Olam also reserves the right to terminate an agreement with any supplier that is not in compliance with the requirements set forth in this document."

Palm Grievance ProcedureWe recognise that feedback and input from stakeholders is valuable because it helps drive best practices, evaluate compliance of our suppliers and increase transparency in our supply chains. [...] Our Grievance Procedure describes how we handle any grievance from any external parties, employees, individuals, communities and non-governmental organisations, concerning the implementation of our Policy.For our third-party sourcing, supplier selection and screening is an ongoing process, and suppliers may change over time, according to market dynamics. [... ] The Grievance Procedures are provided here and our Grievance log here. Grievances can be submitted through any of the following channels: By email to: palmsustainability@olamnet.com: By telephone to: +603 64116771: By fax to: +603 64416772: In writing to: Attention of: Palm SustainabilityC-4-2-10, Solaris Dutamas, No 1 Jalan Dutamas 1,   50480 Kuala Lumpur,Malaysia"

RSPO ACOP reports 82,152.05 tonnes of crude palm oil and palm kernel

30,000 tonnes come from RSPO Credits, which have been over-bought, giving >100% certification. In addition, they only mark their palm oil as certified when selling to Europe. In practice, 13,724 tonnes are mass-balance certified and sold as RSPO-certified.

Relating to the supplier code of conduct which contains all labour rights "Olam reserves the right to conduct (or have its designee conduct) announced and unannounced inspections of the Supplier’s facilities and business practices to verify compliance with this Code. On the assumption that Olam become aware of non-compliance with any aspect of the Code, Olam reserves the right to demand corrective measures. Olam also reserves the right to terminate an agreement with any supplier that is not in compliance with the requirements set forth in this document." [...] relating to FPIC - "Auditing On an annual basis the CR&S Function shall facilitate an internal audit of each upstream operation using the Internal Audit Checklist accompanying this Code."

"Environmental and Social Impact Assessments In order to provide a consistent approach across Olam, the Terms of Reference for the ESIA shall be carried out using the detailed guidance accompanying the Code. ESIAs shall also include High Carbon Value (HCV) assessments and Free Prior Informed Consent (FPIC) procedures where applicable, and consider measures to avoid or mitigate Greenhouse Gas (GHG) emissions. An ESIA aims to establish a project’s environmental and social baseline and propose mitigation measures through management and monitoring plans for the duration of the upstream operation. The ESIA, HCV and FPIC shall form part of the project review to receive final approval."

Olam Palm Gabon plantation statistics [...] 202,000 ha Concession land area of which 112,455 ha are certified [...] 99,000 ha are protected as High Conservation Value areas"

Olam report their supplier and mill list, including boundaries and whether or not the supplier is RSPO certified

"Monitoring Each upstream operation shall implement KPIs and routinely report against them for each of their relevant ESMP requirements. Additionally, they shall report their status against the CR&S controls in Olam’s quarterly Control Management System. The results shall be reviewed by the CR&S Function with any significant issues escalated to the relevant product business management and the CR&S Executive Committee (CR&S ExCo).[...] Auditing On an annual basis the CR&S Function shall facilitate an internal audit of each upstream operation using the Internal Audit Checklist accompanying this Code"

"Supplier Code Principles: Respect the natural environment by: Prohibiting the conversion (i.e. destruction or deforestation) and the sourcing of raw materials resulting from the conversion of the following natural areas (etc) [...] Olam reserves the right to conduct (or have its designee conduct) announced and unannounced inspections of the Supplier’s facilities and business practices to verify compliance with this Code. On the assumption that Olam become aware of non-compliance with any aspect of the Code, Olam reserves the right to demand corrective measures. Olam also reserves the right to terminate an agreement with any supplier that is not in compliance with the requirements set forth in this document"

"Suspend non-complying suppliers and engage for corrective actions"

" 3 suppliers suspended in 2020 (and 2 re-enter according to the re-entry protocol)"

"The Olam Supplier Code (‘Code’) provides a comprehensive set of conditions to support Olam’s goal to purchase raw materials, products, services and various supplies (‘supplies’) that are produced in a manner that is socially responsible, economically profitable and environmentally sustainable. [...] Complying with the International Labour Organization (ILO) [...] Not using forced, involuntary or slave labour [...] Creating an inclusive work environment that avoids any form of discrimination [...] Respecting employees’ rights to form and join unions or other associations, and to bargain collectively [...] prohibiting child labour"

"Ensure no exploitation within their operations by [...] Encouraging gender equality, equal access and empowerment of women"

"If unacceptable practices are reported in our own operations or those of third party suppliers, we will assess the extent and nature of non-compliance and establish a time-bound plan with our suppliers to address the issue and where necessary remediate material negative impacts of non-compliance."

Olam commit their suppliers to "Respecting the rights of local communities and indigenous people and their cultural heritage, including Free, Prior and Informed Consent for new developments

"Supplier Code Principles [...] Respect the natural environment by: i. Complying with all relevant applicable laws and regulations relating to the protection of the environment. ii. Prohibiting the conversion (i.e. destruction or deforestation) and the sourcing of raw materials resulting from the conversion of the following natural areas: – Legally Protected Areas designated for the protection of nature, and Internationally Recognized Areas for conservation [...] Olam reserves the right to conduct (or have its designee conduct) announced and unannounced inspections of the Supplier’s facilities and business practices to verify compliance with this Code. On the assumption that Olam become aware of non-compliance with any aspect of the Code, Olam reserves the right to demand corrective measures. Olam also reserves the right to terminate an agreement with any supplier that is not in compliance with the requirements set forth in this document."

Generic Grievance process - "Our Grievance Procedure applies to all our upstream operations and supply chain infrastructure (processing plants, warehouses and logistics hubs), and our third-party suppliers. It should be used to report and address breaches of relevant Olam Policies or Codes, resulting in illegality, exploitation of local communities or workers employed by Olam or a third-party supplier, or unacceptable practices in land use management as defined in the Olam Living Landscapes Policy and the Olam Supplier Code. [...] Raising a Grievance: The grievance may be made to: Address: Olam International - Grievance Manager New Zealand House, 80 Haymarket, London SW1Y 4TE. Tel: (+44) 20 7389 6464Email: crs@olamnet.com: Emails should be clearly titled ‘For Attention Of: Grievance Manager, Olam’ Grievances can also be addressed to the relevant Country Office as detailed on the location pages of this website. The grievance should include provision of the following information:• Your full name*• Name of your organization (if any)• Contact details (phone/fax/email/postal address)"

Relating to the supplier code of conduct which contains all labour rights "Olam reserves the right to conduct (or have its designee conduct) announced and unannounced inspections of the Supplier’s facilities and business practices to verify compliance with this Code. On the assumption that Olam become aware of non-compliance with any aspect of the Code, Olam reserves the right to demand corrective measures. Olam also reserves the right to terminate an agreement with any supplier that is not in compliance with the requirements set forth in this document."