Royal Golden Eagle

"Responsible Practices in Our Work Places RGE Companies embrace their corporate responsibility to respect human rights. RGE Companies are committed to provide a safe, productive and conducive work environment throughout their supply chains where employees can contribute and advance, by ensuring specifically that: International Labour Organization's Declaration on Fundamental Principles and Rights at Work is respected Recruitment best practices are in place, meeting all legal requirements and cultural practices Freedom of association is respected Diversity within its workforce is respected Accommodation is safe and hygienic if provided as part of employment package The health and safety of workers is protected. RGE companies and their suppliers/sub-contractors shall equip workers to protect them from exposure to occupational health and safety hazards No tolerance is given for child labour, forced labour or bonded labour No tolerance is given for discrimination, harassment and abuse in any form"

"Of its 160,000 hectares of palm oil plantations, 60,000 are developed under the Plasma scheme, a national level project supporting smallholders. Asian Agri partners with more than 30,000 smallholder families as well as independent smallholders, bringing about positive impact on their quality of life and economic development."

Apical: "We are also committed to prevent employment and occupation-related discrimination based on gender. This applies within our operation and supply chain. Our commitment is to ensure that all workers are paid at least the minimum wage and this applies to all suppliers as well." [...] Asian Agri has a commitment to "gender equality an protection of women workers" this policy applies to their suppliers.

"Asian Agri respects the rights of communities to give or withhold their free, prior and informed consent (FPIC) for the use of their lands. We always conduct an environmental impact assessment (EIA) and actively engage the community. We have developed a system where complaints and concerns from the community can be addressed in a timely, transparent and responsible manner."[...]"Respect and recognize the rights of indigenous and local communities to give or withhold their free, prior and informed consent (FPIC) to the utilization of lands to which they hold legal, communal or customary"[...]"Respect of the rights of indigenous peoples and communities to give or withhold their Free, Prior and Informed Consent (FPIC) to operate on lands where they hold legal, communal or customary rights"

In 2020 Apical "maintained 100% traceability to palm oil mills [...] 99.28% traceability to plantation for three of our facilities" Originally Apical had aimed to achieve 100% TTP by 2020. Asian Agri also has a commitment to trace back to plantation level "we currently have full traceability for our plantations and smallholder partners, and continuously engage with third parties to provide assurance for our traceability system."

Apical is a "member of the Roundtable on Sustainable Palm Oil (RSPO) and the International Sustainability & Carbon Certification (ISCC), "

"Apical’s suppliers are required to comply with our Sustainability and Sourcing policies – we emphasise this within the terms and conditions of our commercial arrangement. Apical ensures the commitment to ethical conduct and prohibition of corruption is abided by their suppliers through the Code of Procurement Ethics (COPE)"[...]Asian Agri - "we will ensure that our suppliers comply with the above commitments, local laws and regulations."

Apical have "With a cut-off date of after December 2015, we proactively engage our suppliers to ensure they adopt similar commitments on no deforestation in their businesses. "

"The Group promotes the protection of high conservation value (HCV) and high carbon stock (HCS) areas, peatland and towards positive socio-economic development. Its sustainability partners include The Forest Trust, Proforest and Daemeter to ensure responsible sourcing, integration and continuous improvement to its supply chain transformation. Apical is committed to sustainable operations as the fundamental principle of its business to deliver high value products for today’s global market demands."

"In line with our Sustainability Policy, prior to any replanting, we conduct relevant assessments including HCV assessments, peatland mapping and Social and Environmental Impact Assessments. We also develop and implement conservation and management plans."[...]"As part of our Suppliers Self-Assessment (SFA), we ensure our suppliers conduct independent HCV assessment, in which the independent HCV assessments will be peer reviewed by the ALS licensed assessors who are technical members of the HCV Resource Network."

"Asian Agri is committed to responding quickly and constructively to any grievance raised against any of our own operations or our suppliers, and to report them publicly. We develop a robust grievance procedure to resolve all verifiable complaints and conflicts with all related stakeholders such as land conflicts, social conflicts, human right issues, labor issues, etc." Asian Agri have a list of grievances."[...]"To ensure that the standards set out in our policies are being adhered to we have set up a robust grievance handling process for all stakeholders to raise concerns related to our business or suppliers. All grievances raised are dealt with in a transparent and accountable manner. The grievance process is managed and implemented by our Grievance Steering Committee (GSC), Grievance Secretariat, Stakeholder Engagement Team and Verification Team."

Apical report volumes in their 2020 Sustainability Report (these are volumes used) and Asian Agri report overall volume in their 2021 Sustainability Report - 131,951 MT CPKO

Asian-Agri: "To ensure the long-term protection of these conservation areas, aligned with our sustainability commitment, we have conducted required assessments such as HCV/HCS integrated assessment, Social and Environmental Impact Assessments (SEIAs) "[...]"To meet our conservation targets, we rely on results of our HCV/ HCS integrated assessment, peatland mapping and SEIAs"[...]"...our refineries are all located in designated industrial zones which have been subjected to an Environmental and Social Impact Assessment (ESIA)."

Apical provide a supply chain map with the mill name, company name, latitude and longitude and certification of their suppliers. "Apical does not own any upstream assets such as plantations and mills"

"The PSEP is designed to assess our high-risk suppliers prioritised through our Mill Prioritisation Process. The assessment criteria include suppliers' level of compliance with Apical Sustainability Policy as well as relevant industry standards"[...]"Apical conducts field visits for suppliers identified for PSEP...we provide detailed guidance on the development of Standard Operating Procedures and sustainability management systems. Conducted 45 PSEP visits since 2015 to improve compliance. After the PSEP visits proactively maintain working relationships to ensure recommended action plans are implemented".[...]"Apical uses GIS to monitor the movement of palm oil through our supply network...Apical uses Global Forest Watch Pro...which has several alert systems that identify new forest clearings in real time...our sustainability team receives alerts periodically".

Apical: "suppliers who are suspended are required to provide clear evidence of compliance with our NDPE commitments and grievance resolution for re-inclusion into our supply chain"

Both Apical and Asian Agri have a publicly available list of grievances.

"Responsible Practices in Our Work Places RGE Companies embrace their corporate responsibility to respect human rights. RGE Companies are committed to provide a safe, productive and conducive work environment throughout their supply chains where employees can contribute and advance, by ensuring specifically that: International Labour Organization's Declaration on Fundamental Principles and Rights at Work is respected Recruitment best practices are in place, meeting all legal requirements and cultural practices Freedom of association is respected Diversity within its workforce is respected Accommodation is safe and hygienic if provided as part of employment package The health and safety of workers is protected. RGE companies and their suppliers/sub-contractors shall equip workers to protect them from exposure to occupational health and safety hazards No tolerance is given for child labour, forced labour or bonded labour No tolerance is given for discrimination, harassment and abuse in any form"

"APRIL will continually seek opportunities to consult and align with the interests of communities and create shared value through: Inclusion of smallholders/Small Medium Enterprises (SME) into APRIL’s supply chains, where appropriate"

"ADVANCE EQUAL OPPORTUNITIES AND PARTICIPATION FOR WOMEN We will ensure women’s effective participation and equal opportunities for advancement."

"RGE Companies respect the rights of indigenous peoples and rural communities and are committed to the following: Respect of the rights of indigenous peoples and communities to give or withhold their Free, Prior and Informed Consent (FPIC) to operate on lands where they hold legal, communal or customary rights"

"All provisions in this Sustainability Framework apply without exception to:All Royal Golden Eagle (RGE) companies in the forestry, fibre, pulp and paper sectors worldwide (henceforth: RGE Companies), including current and future companies which RGE Companies own, manage or invest regardless of stake;All third-party fibre, wood and pulp suppliers to RGE Companies."

"Effective immediately, RGE Companies will enforce a moratorium on any further natural forest clearance pending the outcome of High Carbon Stock (HCS) and High Conservation Value (HCV) assessments. This moratorium will also apply to all thirdparty Indonesian wood suppliers to RGE Companies."[...]"RGE Companies and their third-party Indonesian wood suppliers are committed to protecting forests of HCS and HCV, by ensuring specifically that they:Only develop areas that are not forested, as identified through independent HCS and HCV assessments"

Royal Golden Eagle states that "RGE Companies will establish a Grievance Procedure to allow stakeholders to register any issues or complaints, and for RGE Companies to transparently respond and report on progress" [...] "APRIL has established a grievance mechanism with resolution procedures that is accessible and open to all stakeholders, internal and external, who may be adversely impacted by APRIL. The grievance mechanism allows stakeholders to raise any concerns, complaints or issues related to APRIL operations and those of our suppliers. Independent evaluators and investigators will be involved if needed. Local communities and stakeholders are kept informed of the channels open to raise concerns and disputes. Potential concerns may be related to forestry practices, businessrelated human rights, community impacts, and manufacturing processes. [...] There were no incoming grievances registered in 2021. Our historical records of the grievances received including grievance tracking are publicly available on APRIL’s sustainability dashboard and it can be accessed here."

In April Asia's 2021 Sustainability Report - "In 2021, we produced a total of 2,868,525 tonnes of pulp and 1,103,362 tonnes of paper. 91% of the production of pulp and paper involved the use of renewable materials for year 2021"[...]"Asia Symbol is a leading producer of pulp and paper established in China in 2005. Using renewable fibre that is sourced responsibly, Asia Symbol has an annual production of 2 million tons of pulp, 1 million tons of fine paper and 530,000 tons of paper board at its plants in Shandong (Rizhao) and Guangdong (Xinhui) provinces in China."[...]"Sateri is the world’s largest producer of viscose fibre, a natural biodegradable raw material found in everyday items like textiles, wet wipes and personal hygiene products. Its six mills in China collectively produce about 1.8 million tonnes of viscose fibre yearly."

"RGE Companies will plan and implement regular monitoring and reporting of progress in a transparent manner. Where appropriate, RGE Companies will invite relevant stakeholders to participate in a verification process." [...]April Asia's compliance policy: "in 2021, APRIL received a total wood supply of 14,546,184 M3 covered by timber legality certification – IFCC-PEFC, Pengelolaan Hutan Produksi Lestari (PHPL), or Sistem Verifikasi Legalitas Kayu (SVLK). Compliance to these thirdparty verification and certification systems and Indonesia’s legality system is part of our commitment to only source from responsible sources. [...] APRIL is committed to protecting our plantation forests from fire or any other risk of loss of timber or damage. Our landscape planning work supports our commitments to manage the land responsibly. Various measures are in place to protect forest areas, including production, conservation and restoration areas, from illegal activities. They include land cover change monitoring, security patrols, community engagement and boundary demarcation. Patrols are conducted to identify any illegal activity. Activities that infringe the law or our policies are recorded by our patrol team along with the details of the entity that conducted the misdeeds and the location coordinates of the activity. Breaches of law or regulations are reported to the relevant authorities."

"RGE Companies will plan and implement regular monitoring and reporting of progress in a transparent manner. Where appropriate, RGE Companies will invite relevant stakeholders to participate in a verification process."

"RGE Companies will cease to do business with any suppliers whom our independent advisors or other stakeholders find are in serious violation of this Framework, and do not take immediate remedial action to correct those violations. Regardless of remedial action, we will not do business with serious repeat violators of the Framework."

"RGE Companies embrace their corporate responsibility to respect human rights. RGE Companies are committed to provide a safe, productive and conducive work environment throughout their supply chains where employees can contribute and advance, by ensuring specifically that:International Labour Organization's Declaration on Fundamental Principles and Rights at Work is respected...Freedom of association is respectedDiversity within its workforce is respected...No tolerance is given for child labour, forced labour or bonded labourNo tolerance is given for discrimination, harassment and abuse in any form."