Report - COP Prototype

2022 Communication on Progress

PT Austindo Nusantara Jaya Tbk

Published date

June 10, 2022

No. of questions

Supplemental files

ANJ Sustainability Policy-Final-311019-rev041119-for website.pdf ANJ Sustainability Policy Implementation Guidance-Final-311019-Revision 1-08092021.pdf ANJ_Code of Ethics_English_sC5Z0320170320083909.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

Please refer to our 2021 Sustainability Report and Annual Report which are available on our website.

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Please refer to: 1. Our 2021 Sustainability Report and Annual Report which are available on our website. https://www.anj-group.com/en/sustainability-report 2. Our Sustainability policy which are available on our website. https://www.anj-group.com/en/sustainability-approach-and-policies

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Please refer to our Code of Ethics on Business Conduct available in our website. Topics on environment and human rights are described in our Sustainability Policy Implementation Guidance (available on our website), and described further in our SOPs.

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Please refer to our 2021 Sustainability Report and Annual Report which are available on our website. The Sustainability Director reports to the President Director. The Human Resources and Change Management Director reports to the President Director. The Head of Internal Audit reports to the President Director.

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Please refer to our 2021 Sustainability Report and Annual Report which are available on our website. The sustainability topics mentioned above fall under the following committees, which are led by a Commissioner, respectively: 1. Sustainability Committee 2. Risk Management Committee 3. Audit Committee

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

The Risk Management Committee meeting is held on a monthly basis in which relevant directors and group heads present and discuss the risks and opportunities of specific topics to the commissioners. The management team will then follow up on the action plans and provide updates to the Committee.

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Our key suppliers (based on the value of transactions) are those providing fresh fruit bunches for our mill. We conduct environmental risk assessment of those suppliers.

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Our Sustainability Report is assured by an independent party, during which process we underwent a discussion and obtained recommendation from the assuror to improve our sustainability performance, particularly areas that are related to our material topics. In addition, we also conduct: 1. HCV assessment and social impact assessment which cover environmental risks and human rights risks. 2. RSPO internal and external audits for all operating palm oil mills and estates which cover environmental, labor right, and human rights risks 3. Financial audit by an independent, reputable accounting firm to assess our internal control.

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

We conduct due diligence process for our plasma and partnership suppliers.

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

Concerns and grievance can be raised through various channels, i.e. the whistleblowing system (Berani Bicara), the Value Champion system, grievance mechanism, LKS Bipartit and Gender Committee. Please refer to our Sustainability Report for more information.

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

“The company’s workforce can raise concerns through a confidential process (whistleblowing system) or other channels which are not confidential such as Value Champion, LKS Bipartit and gender committee.

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Optional comment

Please refer to our 2021 Sustainability Report which is available on our website.

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	13
Male (%)	85
Female (%)	15
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	15
Above 50 years old (%)	85
From minority or vulnerable groups (%)	0
Executive (%)	38
Independent (%)	23

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Our sustainability report is assured by TUV Rheinland

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
FPIC is articulated in our Sustainability Policy and its Implementation Guidance.
Access to water and sanitation

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Optional comment

Our Sustainability Policy is reviewed from time to time. In the process, we consulted with selected stakeholders and consultants who have expertise in social studies.

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

We have FPIC procedures in accordance with RSPO P&C for acquiring new land. The process involves engagement and collaboration with local stakeholders to ensure clarity to all parties at the start of any development. FPIC from affected local communities is strictly conditional for land acquisition and development activities to continue. In 2021, we carried out FPIC processes for our land acquisition process in our operations at GSB (South Sumatra). In other areas, we have ongoing dialogues with local stakeholders regarding land acquisition and other operational issues based on FPIC principles.

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

The training was provided to selected employees who are involved in the land acquisition process and also our security service providers.

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

In 2021 we commissioned an independent evaluation and engaged an independent consultant to review our labor policies and procedures raised as concerns in our West Papua palm oil operation. A detailed formal report and action plan has been completed. As a follow up, the Company distributed Internal Memo related to human rights and recently in March 2022 we conducted human rights training to employees, delivered by human rights experts to employees. We have also updated our SOP for security management which takes into account the voluntary principles on security and human rights.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
2021
Forced labour
2021
Child labour
2021
Non-discrimination in respect of employment and occupation
2021
Occupational safety and health
2021
Working conditions (wages, working hours)

Optional comment

Please see our Sustainability Policy and its Implementation Guidance

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Please see our Sustainability Policy and its Implementation Guidance

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	100

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	17.4

Optional comment

Collective bargaining and the channel for industrial relations are mainly through LKS Bipartit (Bipartite cooperation institutions in each location).

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	33
Non-executive board	13

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	91

Optional comment

In our 2021 Sustainability Report, we disclosed our employee segments and the ratio, as follows: 1. Non staff: 105% 2. Staff: 91% 3. General Manager and Manager: 85% 4. Director: 102% The majority of our employee is non staff employee (93% from the total workforce), but we are unable to fill in 105%. Therefore we put the percentage of staff employee only. We recommend that in the future you provide more options to disclose the ratio for each employee level.

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	5.7e-7

Optional comment

Our 2021 Sustainability Report (Table 32) presented data of injuries per million of working hour. The LTI Frequency Rate is 0.57 per million of working hour or 0.00000057 per hour.

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	0.00000181

Optional comment

The total recordable injury rate is 1.81 per million of working hour or 0.00000181 per hour (please refer to Table 32 of our 2021 Sustainability Report).

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

We commissioned an independent inquiry and engaged an independent consultant to review our labor policies and procedures following concerns raised about risks related to labor conditions in our Palm Oil concession in West Papua. A detailed formal report and action plan has been completed. In 2021 we conduct refreshment training regarding all five material aspects in the labor right principle to all employees. We also have monthly report to monitor the progress of our contractors' implementation relating to the five material aspects. All of our contractors are required to attend the labor right principle socialization program.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2021
Water
Oceans
As we operate on land (agriculture), our direct impact on oceans is non existent.
Forests / Biodiversity / Land Use
2021
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use
2021

Optional comment

Please see our Sustainability Policy and its Implementation Guidance.

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

1481293

Scope 2 Emissions

Full

None

Emissions (tCO2e)

2293

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

12098

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Optional comment

Please refer to our 2021 Sustainability Report.

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

53% comprised of revenue from Certified sustainable Crude Palm Oil (CSPO) and Certified Sustainable Palm Kernel (CSPK), revenue from renewable energy, and revenue from palm shells sales.

Unknown

Not applicable (Please provide additional information)

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	2157
Groundwater:
Surface water:	2157
Rainwater:
Wastewater:
Percentage of water withdrawn in regions with high or extremely high water stress (%)	0

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	479
Groundwater:
Surface water:	479
Rainwater:
Wastewater:
Percentage of water consumed in regions with high or extremely high water stress (%)	0

Optional comment

Please refer to our 2021 Sustainability Report. Our source of water is only from surface water including harvested rainwater. Our operations are not located in regions with high or extremely high water stress.

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

Unknown

Not applicable (Please provide additional information)

We do not operate in regions with high or extremely high water stress

Sector-specific: Forest, biodiversity, and land use

14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

	Number	Unknown	Not applicable (Please provide additional information)
Sites	4
Hectares	108366

Optional comment

Please refer to our 2021 Sustainability Report (Table 22). The relevant sites are: ANJAS, PMP, ANJ and ANJAP.

15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

Conversion of natural resources (hectares)

Unknown

Not applicable (Please provide additional information)

16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
97.3 hectares in five sites (ANJA, SMM, ANJAS, KAL and PPM)
Natural regeneration
Agroforestry
Set-aside land
60,985.27 hectares set aside for conservation areas
Biodiversity offsetting
Other (please specify in text box)

Optional comment

Reforestation are within our concessions and also outside our concession areas

Sector-specific: Air pollution

17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

	Emissions (tCO2e)	Unknown	Not applicable (Please provide additional information)
NOx	247
SOx	80
Volatile Organic Compounds (VOC)
Hazardous air pollutants (HAP)
Particulate matter (PM10)	117
Persistent organic pollutants (POP)
Other (please specify in text box)

Optional comment

Other pollutants are not regulated by the Indonesian Government. Unit of measurement for NOx, SOx and PM10 are in tons.

Sector-specific: Waste

18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

Waste Generated (t)

511842

Unknown

Not applicable (Please provide additional information)

Optional comment

Please refer to our 2021 Sustainability Report (Table 18).

19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

Hazardous Waste Ratio (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

Hazardous waste is 0.02%.

20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

Single-use plastics (tonnes)

Unknown

Not applicable (Please provide additional information)

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

In 2021, we fully integrated ESG aspects into our business strategy, placing a greater emphasis on our ESG ambitions and targets. Several targets related to the environment and tackling climate change have been set during this process, including: • Achieving net-zero emissions by 2030 • Reduce the GHG emissions intensity of our palm oil unit by 30%, compared to the 2015 baseline, by the year 2030. • Increase our renewable energy portfolio to above 60% and reduce our fossil fuel dependence by 20% by 2025 • Reduce water consumption by 5% per annum • Achieve water intensity of 1 ton of water for each ton of fresh fruit bunch (FFB) processed by 2027. Many of our climate change initiatives have been ongoing since 2014, and the targets will enable us to better measure and quantify our impact and progress. We also remain committed to protecting forests, peatland, and biodiversity. In 2021, we completed a Land Use Risk Identification (LURI) study prior to developing a new area in our operations which identified low-risk areas to be developed and high-risk areas to be set aside for conservation. To manage wildfires, we have built the first phase of our integrated fire management infrastructure in KAL, which was completed in January 2022. We also continue to implement our citizen science biodiversity monitoring program called “Pendaki”. In 2021, more than 40,000 “Pendaki” observation records made so far have been verified by external experts to validate their accuracy. We have also launched a website and encyclopedia of wildlife identified in our operations at SMM. More about our environmental initiatives can be found in our Sustainability Report pages 40-75.

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2021

Optional comment

The programs include the following: 1. Integrity Pact that should be signed by employees and products and services providers. 2. Value Champion system. 3. Whistleblowing system (Berani Bicara).

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

Please refer to our Code of Ethics on Business Conduct

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

All employees are required to attend ANJ Value Workshop as part of their onboarding program. A refresher workshop is also organized from time to time. The same workshop is also provided to contractors and direct suppliers of the Company.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Internal audit conduct routine audit and investigation for cases reported through whistleblower system ANJ Values Champion system

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years
Confirmed during the current year, and related to this year	3
The incidents include data manipulation and embezzlement, by staff and non-staff level.

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

External: as a signatory of the UN Global Compact. Internal: Integrity Pact with employees, contractors, suppliers.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

We place a high priority on ensuring that all employees uphold the corporate value of integrity by conducting training on corporate values for new employees and refresher training for existing employees. In 2021, we have appointed 32 Value Champions, which are carefully selected to become role models, communicate the corporate values to their colleagues, and monitor the daily implementation of these values. Value Champions report significant practices that are not aligned with the corporate values in their business units to the Value Guardians, who are commissioners of the company. Reports are followed up and, if required, will be further investigated resulting in sanctions for the persons concerned. We have a whistle-blowing system (WBS), called Berani Bicara as a channel to report misconduct anonymously and safely to the Internal Audit Unit, including fraud, corruption, breaches of the Code of Ethics, or the corporate values by any member or associate of the company. The system is designed to contribute to the prevention and early detection of misconduct. In 2021, our BOD and Internal Audit Unit found and acted on 11 cases related to fraud and manipulation.