Case Study: Business Risks and Human Rights...While it hasn’t happened with Wilmar, there is a...

Case Study: Business Risksand Human RightsReputational Risks in Wilmar’s Palm Supply Chain

engagethechain.org

BUSINESS RISKS AND HUMAN RIGHTS

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An investigative report released in November 2016 by Amnesty International alleged significant humanrights abuses, including child labor and forced labor,on Wilmar’s own plantations as well as within its supplychain. Coverage of the report included widespreadmedia attention and articles by outlets such as Reuters,The Guardian, Mongabay, and Sustainable Brands. The coverage by advocacy media exposed Wilmar toreputational risk due to inadequate supplier policiesand deficient supplier monitoring and verification. The company responded by undertaking internalreviews and external collaborations for assessments of labor practices in upstream operations in 2017.

The historical insufficiency of land rights processes has resulted in claims of land grabs by civil society

organizations and other land issues. These claimsexposed Wilmar to a variety of business risks, includinglitigation and disruption to operations. Wilmar incurredlegal costs in its defense against complaints andexpenses for development and implementation of itsinternal preventative programs.

Due to its strategic position within the global palm oilsupply chain and its role as the world’s largest trader of palm oil, Wilmar has an important role to play inadvancing reforms on social issues in the wider palmoil industry by demonstrating compliance with humanrights norms committed by its NDPE (No Deforestation,No Peat, No Exploitation) policy within both its ownoperations and those of third-party suppliers.

Executive SummaryWilmar International (SGX:F34) is one of the largest listed palm plantation companies on theSingapore Exchange and its public stock is held by major U.S. institutional investors, includingmutual funds, pensions, endowments and foundations. Over the past several years, the companyhas been implicated in scandals involving violations of workers’ rights and land disputes in itsIndonesian palm oil business. Some of these claims include:

Forest PeoplesProgramm

releasesinvestigative

report onhuman rights

abuses andland conflicts

in WilmarGroup

plantation

Wilmarannounces

NDPE Policy

Thecommunity ofNagari Kapa

files acomplaint

against Wilmarfor mis-

appropriationof land

Wilmarlaunches

onlinedashboardfeaturing

CertificationProgress,

Traceabilityand SupplyChain, andGrievanceProcedure

Companydevelops andimplements

theAggregator

RefineryTransformation(ART) program

developedwith The

Forest Trust

AmnestyInternational

releases “The Great

Palm OilScandal”

investigativereport

RSPO declaresthat Wilmar

took over Kapalands without

consent inviolation of

RSPOstandards andIndonesian law

Wilmarannounces

collaborationwith Verité toimprove labor

practices

Wilmar’sappeal on

RSPO decisiongranted by the

ComplaintPanel

Wilmar joinscollaborationwith Business

for SocialResponsibility

(BSR) toimproveworking

conditions andlaunches Child

ProtectionPolicy

WORKINGCONDITIONS

LANDRIGHTS

NOVEMBER2011

DECEMBER2013

OCTOBER 2014

JANUARY 2015

AUGUST2015

NOVEMBER2016

FEBRUARY2017

APRIL2017

NOVEMBER2017

WILMAR INTERNATIONAL (SJX) SOCIAL ISSUES TIMELINE

Note: Timeline is not representative of all working conditions and land conflict issues, nor is it representative of all actions to remedy these issues taken by Wilmar.All the land rights cases involving Wilmar were acquired before the 2007 establishment of RSPO Principles and Criteria, which includes the FPIC methodology.


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Wilmar InternationalFounded in 1991, Wilmar International Limited is one of the largest publicly listed palm plantationsin the world, and the largest global processor and merchandiser of palm and lauric oils.1 Wilmar is a vertically integrated agribusiness, with business activities ranging from cultivation, to refining,to manufacturing of consumer products. While palm oil-related businesses account for a significantportion of Wilmar’s revenue, its businesses extend into oilseeds, grains, and sugar.

Wilmar is one of the world’s biggest oil palm plantationowners, with a total planted area of 228,443 hectares(as of 30 Sep 2018), 66 percent of which is in Indonesiaand 25 percent in East Malaysia.2 It has over 500manufacturing plants, distributes to more than 50countries and employs about 90,000 people worldwide.3

The company has certifications from the four majorsustainable palm organizations: InternationalSustainability & Carbon Certification (ISSC), IndonesianSustainable Palm Oil (ISPO), Malaysian SustainablePalm Oil (MSPO) and the Roundtable for SustainablePalm Oil (RSPO). As of 2017, Wilmar reported 28 millsand more than 80 percent of planted area acrossMalaysia, Indonesia and Ghana being RSPO-certified.4

For fiscal year 2017, the company posted an 5.9 percentincrease in annual revenue to US$43.85 billion. Itstropical oils division, which comprises the company’sentire value chain of palm oil assets, generated over$18 billion in revenue in fiscal year 2017.5 Wilmar lists19 key subsidiaries, eight of which are palm oilcultivation, milling or refining operations in Indonesia.

Wilmar benefits from optimistic growth outlooks forthe global demand palm oil in both food and non-foodapplications. Wilmar’s stock would mostly be found in sector- and region-specific portfolios. Archer DanielsMidland (ADM) has been gradually increasing itsownership of Wilmar and is reported as having a 24.89 percent interest in the company as of March 13,2018.6 ADM views its ownership of Wilmar as a key partof its Asia strategy.7


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Social Issues in Palm OilCivil society actors have identified human rights violations and land disputes

within Wilmar’s extended palm supply chain.

1. Working ConditionsMany companies within the palm oilindustry have been implicated inviolations of workers’ rights for decades,as advocacy media and civil society actors

together have raised awareness on these issues.

In December 2016, Amnesty International publishedThe Great Palm Oil Scandal highlighting labor rightsviolations in Indonesia’s palm oil industry, based on itsinvestigation of Wilmar’s supply chain. AmnestyInternational conducted 120 interviews with workersat Wilmar’s PT Milano and PT Daya Labuhan Indahsubsidiaries and unaffiliated Wilmar suppliers for theextensive, more than 100 page report. A sample of thelabor rights violations uncovered include:

Exploitation via wages and production targets.Researchers found that companies had complexsystems to calculate workers’ wages based on timeworked and output per worker. Companies set outputtargets and, in at least one example, harvester salarieswould be reduced if production targets were not met.Production targets were static regardless of season,crop yield, and number of hours worked.

Forced labor. The large number of penalties (which canbe applied at the employer’s discretion) and the lack ofclarity and transparency on deductions from wages makeworkers vulnerable to pressure from their supervisors,who can extract work under the threat of loss of pay orloss of employment. The ILO Committee of Experts hassaid these kinds of practices amount to forced labor.

Child labor. The investigation uncovered instances ofchildren assisting parents on plantations to help meetproduction targets, sometimes by carrying heavy loadsof palm fruit or by transporting fruit via wheelbarrows.In some cases, children as young as eight dropped outof school to help their parents.

Health and safety issues. Amnesty Internationalresearchers found evidence that Wilmar suppliers wereusing a highly toxic, paraquat-based herbicide calledGramoxone. Workers who spray and prepare thechemicals and fertilizers were not provided sufficientprotective gear and have experienced regularinhalation and contact-based poisoning effects,including fingernails rotting out.

Gender discrimination. Researchers found that womenwere routinely denied permanent employment statusand benefits, including health insurance and pensions.Women were hired as casual day laborers while men were hired as harvesters with permanentemployment contracts.

As detailed in the Risk Mitigation section, Wilmar hastaken steps to address the abuses published in theAmnesty International report. Wilmar was also subjectto numerous additional special independent assessmentsin 2017 under the RSPO and ISCC certification schemesarising from the Amnesty International report. Theseassessments have found no non-compliance in relationto the RSPO Principles and Criteria, which many of theallegations refer to.8 However, NGO reports and recentindependent investigations into labor violations by theRSPO Complaints Panel have revealed widespread illegallabor abuses on RSPO-certified plantations, indicatingthat regular RSPO audits are not properly detecting orreporting on labor non-compliance.9

https://www.amnesty.org/en/documents/asa21/5184/2016/en/


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2. Land rights

SOCIAL ISSUES IN PALM OIL

Wilmar International has experienced land disputes with local communities over several of its sites, which have beendescribed as land grabs by activists.

Forest Peoples Programme (FPP) has been one of thepredominant critics of Wilmar for its land acquisitionpractices, including its investigative report on theJambi province of Indonesia in November 2011.10

In November 2012, FPP reported that a Wilmar subsidiary,PT Mustika Sembuluh, was slow in settling ongoing landdisputes in Central Kalimantan.11 In October 2013, FPPhighlighted conflict with local communities in SouthernMerauke, West Papua. FPP claimed that Wilmarsubsidiaries co-opted tribal leaders and convincedvillagers to sell their lands.12 According to a report issuedby Profundo, FPP claimed the subsidiary “did not getconsent to land conversion from some members of the community, and the community gave their consentto land conversion based on deceptive information andrestricted freedom of choice.”13 Wilmar has notproceeded with plantations in West Papua.

Another land dispute involves the Kapa community ofWest Sumatra, who filed a complaint with the RSPO inOctober 2014. The complaint alleges that Wilmar failedto obtain Free, Prior and Informed Consent (FPIC) withthe local community before establishing a plantationon Kapa land, in violation of both RSPO Indonesianstandards.14 After a two-year process leading up totheir ruling, the RSPO found that Wilmar Internationalhad taken over Kapa lands without their consent.15

In April 2017, the RSPO Complaints Panel agreed toreview the decision on the case,16 but the case waseventually settled later in the year with consensus toimplement processes determined by the Action Plan of the initial decision, including participatory mappingand stakeholder engagement.17 This complaint case hasbeen closed as of September 2018.18 As detailed later inthe Risk Mitigation section, land rights issues are nowrecorded in the company’s Grievance Procedure.19


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RisksWilmar International is exposed to several business risks arising from issues related to

land rights and labor conditions. The next section highlights some of these risks by drawing upon the framework established in Engage the Chain.

1. Operational riskLand conflict is an issue that affects allplantation companies and therefore canpresent material business risk. If productionis compromised when injunctions are

imposed, these issues can be considered operational risks.While it hasn’t happened with Wilmar, there is a possibilitythat local governments could put a halt to operations. As noted by Rights and Resources, an NGO based out of Washington, D.C., “Insecure [land] rights also threatencompanies’ bottom lines and long-term financial success.Disputes over land between companies and localcommunities frequently lead to conflict, work stoppages,and stalled investments.”20

The impact of land conflicts can be long-term in nature,as more than half of 288 land-related conflicts reportedafter 2001 in the Tenure and Investment in Southeast Asiareport between companies and communities were stillunresolved in 2017.21 This study also cites that theseconflicts are more difficult to resolve in Southeast Asiathan any other region in the world, partially due to unclearand/or unenforced property rights. The Indonesianpalm oil monitoring group SawitWatch has identified660 land disputes between palm oil companies andlocal communities in Indonesia — though the actualnumber many be higher than this.22

2. Litigation riskLitigation risk refers to the risk of legalsanctions stemming from a company’sfailure, or alleged failure, to comply withlaws, regulations, rules, related self-

regulatory organization standards, and codes ofconduct.23 Wilmar International not only incurred morethan three years’ worth of legal counsel costs in itsdefense against the Kapa community land disputes

(which was ruled in Wilmar’s favor at the IndonesianSupreme Court), but it also risks scrutiny from RSPOand other certification organizations if reputable andegregious claims against it continue to arise.Additionally, findings of forced labor in Wilmar’sextended supply chain could leave the company opento litigation if imported goods were proven to havebeen produced using forced labor.24

3. Reputational riskIssues related to working conditions andland conflict both pose reputational riskfor Wilmar when left unattended.Reputational risk is the risk that adverse

publicity regarding [a company’s] business practicesand associations, whether accurate or not, will cause a loss of confidence in the integrity of the institution.25

For the issues highlighted previously, the companyfaced significant reputational risk due to media andadvocacy group scrutiny on its supply chain. Dozens of articles by media and activist organizations focusingon Wilmar and abuses within its supply chain wereposted in the nine months following the release of the Amnesty International report in December 2017.The alleged human rights abuses were covered inarticles by leading advocacy media organizationsincluding Mongabay, One Green Planet, Eco-Business,and Sustainable Brands.

4. Market riskWilmar’s social issues present market riskson two levels. First, with each majorallegation of human rights abuses or illegalland acquisition, relationships with major

buyers may be adversely affected. As the AmnestyInternational report pointed out, major brands are clients

https://engagethechain.org/drivers-financial-risk


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of Wilmar — including Colgate-Palmolive, Kellogg, Nestlé,Unilever, and Procter & Gamble. A number of other majorbrands also source from Wilmar including PepsiCo, Mars,Mondelez, General Mills, and Johnson & Johnson.26 Aseach of these brands has their own sustainable supplychain policies and are members of sustainable palmorganizations, they run their own reputational risk ifWilmar as supplier violates their standards. The resultingmarket risk is that these brands could terminate, reduceor suspend supply contracts with Wilmar. Importantly,land rights and labor conditions are not the only sourceof business risk shared with their customers. The parallel

issue of deforestation cases, including the current Leuserecosystem situation, exposes Wilmar to market risk.27

Second, as Wilmar continues to peg its financing to sustainability metrics, the most favorable interestrate may not be achieved if the company fails toachieve certain targets. These sustainable financingcommitments include facilities with ING, DBS, andOCBC Bank, and the announcement for each of thesegarnered coverage by the broad financial press, suchas Nikkei Asian Review, The Business Times, and GlobalTrade Review.

Risk MitigationWilmar has made advances in addressing social issues within its supply chain. Over the past severalyears, the company has sought to address working conditions and land conflict issues with internal

reviews and external collaborations with several consultants and NGOs, including TFT, BSR andVerité. (Details can be found in Wilmar’s two-year progress report on labor practices).

Engagement with stakeholders and implementation ofnew processes mitigated imminent reputational risk. InJanuary 2015, Wilmar launched an online transparencytool which was hailed as an important step towardstransparency at its time by civil society organizations.The Dashboard featured include information onCertification Progress, Traceability & Supply Chain, as well as the Grievance Procedure.

In its 2015 annual report, Wilmar described its GrievanceProcedure as part of risk management. The grievanceprocedure “provides stakeholders with an avenue to report suspected sustainability-related breachesand concerns pertaining to its own operations and its suppliers.”28 While most grievances are relatedenvironmental issues such as deforestation and peatlandclearance, the interactive dashboard enables stakeholdersto view a list of grievance cases and their developments.

In addition to the dashboard, Wilmar implemented theAggregator Refinery Transformation (ART) program,which seeks to strengthen all actors’ practices in theirsupply chain.29 The program, developed with The Forest

Trust (TFT), is a combination of site evaluation andeducation for suppliers. The mills are prioritized for an audit based on spatial and non-spatial data. Spatialfactors using GIS include legally protected areas, keybiodiversity areas, and peat; non-spatial factors includemills that have their own NDPE policy, RSPO certification,volumes, public information, and TFT assessment.

At year-end 2017, Wilmar conducted 62 assessments in Indonesia and Malaysia.30 The assessments werethen compiled into anonymized reports which weresummarized and discussed at regional workshops. Thetopics of regional workshops also included “guidance onland-use planning, and respecting the rights of workersand indigenous and local communities.”31 The ability ofthe ART program to zoom into supplier practices basedon regional characteristics demonstrates that Wilmarrecognizes how land issues impact operational costs and revenues. However, NGO and advocacy groups suchas Rainforest Action Network (RAN) called into questionthe utility of the tool, identifying a lack of overalltransparency and strong human rights approach.32

https://www.wilmar-international.com/docs/default-source/default-document-library/sustainability/wilmar-2-year-progress-update-in-strengthening-labour-practices---final-final-final.pdf?sfvrsn=a56b5de8_0https://www.wilmar-international.com/sustainability/traceabilityhttps://www.wilmar-international.com/sustainability/traceability


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Improving Disclosure

Although the company was an early adopter of a NDPEpolicy and has invested in several sustainability pilotsand programs, Wilmar’s public documentation can beimproved to allow for more efficient evaluation byengaged investors. For example, Wilmar’s disclosure of risk can be tied more closely to sustainability issueslike the framework established in Engage the Chainand should align with Ceres’ Reporting Guidance forResponsible Palm Oil. In its 2017 filings, the company’sdisclosure structure separated its business riskdiscussion from its sustainability discussion. Wilmar

disclosed key performance indicators pertaining to theenvironment as well as health and safety but did notexplicitly frame them within business risk categories.

As a publicly traded company and dominant actor inthe global palm supply chain, Wilmar is in a uniqueposition to lead social practices in palm oil production.Continued engagement with stakeholders andenhancements in disclosures can be expected to helpWilmar maintain and improve its value propositionamong sustainable investors.

PALM OIL MATERIALITY MATRIX

●●

●

● ●

●

● ●

●

●

●

●

●

●

Small holder inclusiveness

Greenhouse gas emissions

Jurisdictional approaches/certifications

Supplier/supply chain monitoring

Transparency and accountability

Child protection

Labor conditions

Investment in communityinfrastructure

Wildlife conservation,fire and haze

Deforestation/High Carbon Stock (HCS) forests,High Conservation Value(HCV) area, supply chaintransformation

Community relations and conflict resolution

Pesticides and chemical usage, health and safety

Corporate governance/ethicsand anti-corruption

Sustainability certification,water impacts, peatdevelopment

Moderate Significant Priority

IMPORTANCE TO WILMAR’S BUSINESS

IMPORTANCE TO WILMAR’S EXTERNAL STAKEHOLDERS

Source: Wilmar International Limited (2018). Sustainability Report 2017. Singapore: Wilmar International Limited.

https://engagethechain.org/https://www.ceres.org/resources/reports/reporting-guidance-responsible-palmhttps://www.ceres.org/resources/reports/reporting-guidance-responsible-palm

ENDNOTES


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1 Wilmar International Limited. (2018). 2017 Annual Report. Singapore: Wilmar International Limited.






7 Archer Daniels Midland. (n.d.). ADM Worldwide Asia and Pacific Rim. Retrieved from Archer Daniels Midland:https://www.adm.com/adm-worldwide/asia

8 Wilmar No Deforestation, No Peat, No Exploitation update: Q1 2017 Update, page 6, https://www.wilmar-international.com/sustainability/wp-content/uploads/2018/05/Wilmar-Sustainability-Report-2017.pdf

9 The Human Cost of Conflict Palm Oil Revisited: How PepsiCo, Banks, and the Roundtable on Sustainable Palm OilPerpetuate Indofood’s Worker Exploitation, November 2017, https://www.ran.org/wp-content/uploads/2018/06/Human_Cost_Revisited_vWEB.pdf

RSPO Complaints Decision on FELDA GLOBAL VENTURES HOLDING BERHAD (FELDA), November 2018,https://askrspo.force.com/Complaint/s/casetracker

RSPO Complaints Decision on PT. PP London Sumatra Indonesia Tbk (Indofood), November 2018,https://askrspo.force.com/Complaint/s/casetracker

10 Forest Peoples Programme. Human rights abuses and land conflicts in the PT Asiatic Persada concession inJambi. November 2011. https://www.forestpeoples.org/sites/default/files/publication/2011/11/final-report-pt-ap-nov-2011-low-res-1.pdf

11 Forest Peoples Programme. Press Release — New oil palm land grabs exposed: Asian palm oil companies runinto trouble in Africa. 1 November 2012. https://www.forestpeoples.org/en/topics/palm-oil-rspo/news/2012/11/press-release-new-oil-palm-land-grabs-exposed-asian-palm-oil-compa

12 Rights and Resources. New report by FPP, Pusaka and Sawit Watch launched on World Food Day. 23 October2013. https://rightsandresources.org/en/blog/new-report-by-fpp-pusaka-and-sawit-watch-launched-on-world-food-day/#sthash.4vMlCIVL.dpbs

13 Profundo. (2018, January 21). External Concerns on the RSPO and ISPO Certification Schemes. Retrieved fromFriends of the Earth Europe: https://www.foeeurope.org/sites/default/files/eu-us_trade_deal/2018/report_profundo_rspo_ispo_external_concerns_feb2018.pdf

14 Diaz-Bastin, R. (2017, February 16). Wilmar grabbed indigenous lands in Sumatra, RSPO finds. Retrieved fromMongobay: https://news.mongabay.com/2017/02/wilmar-grabbed-indigenous-lands-in-sumatra-rspo-finds/

15 Forest Peoples Programme. (2017, February 2). PRESS: Wilmar has violated the rights of the Kapa indigenouscommunity of West Sumatra, concludes RSPO. Retrieved from www.forestpeoples.org:https://www.forestpeoples.org/en/palm-oil-rspo/press-release/2017/press-wilmar-has-violated-rights-kapa-indigenous-community-west

16 Wilmar International Limited. (2017 April 26). Update: Wilmar’s appeal on land conflict in West Sumatra granted by theRSPO Complaints Panel. http://www.wilmar-international.com/sustainability/wp-content/uploads/2017/04/Update-on-Wilmars-Appeal-to-the-RSPO-Complaints-Panel-26-April-2017-Final.pdf

17 RSPO. Case Tracker PT Permata Hijau Pasaman 1 (Wilmar International Ltd).https://www.rspo.org/members/complaints/status-of-complaints/view/76

https://www.adm.com/adm-worldwide/asiahttps://www.wilmar-international.com/sustainability/wp-content/uploads/2018/05/Wilmar-Sustainability-Report-2017.pdfhttps://www.wilmar-international.com/sustainability/wp-content/uploads/2018/05/Wilmar-Sustainability-Report-2017.pdfhttps://www.ran.org/wp-content/uploads/2018/06/Human_Cost_Revisited_vWEB.pdfhttps://www.ran.org/wp-content/uploads/2018/06/Human_Cost_Revisited_vWEB.pdfhttps://askrspo.force.com/Complaint/s/casetrackerhttps://askrspo.force.com/Complaint/s/casetrackerhttps://www.forestpeoples.org/sites/default/files/publication/2011/11/final-report-pt-ap-nov-2011-low-res-1.pdfhttps://www.forestpeoples.org/sites/default/files/publication/2011/11/final-report-pt-ap-nov-2011-low-res-1.pdfhttps://www.forestpeoples.org/en/topics/palm-oil-rspo/news/2012/11/press-release-new-oil-palm-land-grabs-exposed-asian-palm-oil-compahttps://www.forestpeoples.org/en/topics/palm-oil-rspo/news/2012/11/press-release-new-oil-palm-land-grabs-exposed-asian-palm-oil-compahttps://rightsandresources.org/en/blog/new-report-by-fpp-pusaka-and-sawit-watch-launched-on-world-food-day/#sthash.4vMlCIVL.dpbshttps://rightsandresources.org/en/blog/new-report-by-fpp-pusaka-and-sawit-watch-launched-on-world-food-day/#sthash.4vMlCIVL.dpbshttps://www.foeeurope.org/sites/default/files/eu-us_trade_deal/2018/report_profundo_rspo_ispo_external_concerns_feb2018.pdfhttps://www.foeeurope.org/sites/default/files/eu-us_trade_deal/2018/report_profundo_rspo_ispo_external_concerns_feb2018.pdfhttps://news.mongabay.com/2017/02/wilmar-grabbed-indigenous-lands-in-sumatra-rspo-finds/https://www.forestpeoples.org/en/palm-oil-rspo/press-release/2017/press-wilmar-has-violated-rights-kapa-indigenous-community-westhttps://www.forestpeoples.org/en/palm-oil-rspo/press-release/2017/press-wilmar-has-violated-rights-kapa-indigenous-community-westhttp://www.wilmar-international.com/sustainability/wp-content/uploads/2017/04/Update-on-Wilmars-Appeal-to-the-RSPO-Complaints-Panel-26-April-2017-Final.pdfhttp://www.wilmar-international.com/sustainability/wp-content/uploads/2017/04/Update-on-Wilmars-Appeal-to-the-RSPO-Complaints-Panel-26-April-2017-Final.pdfhttps://www.rspo.org/members/complaints/status-of-complaints/view/76


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18 RSPO. Case Tracker PT Permata Hijau Pasaman 1 (Wilmar International Ltd).https://askrspo.force.com/Complaint/s/case/50090000028Erz4AAC/detail

19 Direct communication from RAN — Wilmar made a commitment in November of 2018 to align theirgrievance procedure with the effectiveness criteria for non-judicial grievance mechanisms outlined by theUnited Nation Guiding Principles on Business and Human Rights.

20 Ogden, B. (2018, May 31). To End Deforestation, We Must Protect Community Land Rights. Big Ideas. In Brief. bythe. Retrieved from https://rightsandresources.org/en/to-end-deforestation-we-must-protect-community-land-rights/

21 (2017). Tenure and Investment in Southeast Asia. United Kingdom: The Munden Project Ltd. trading as TMP Systems.

22 Sawit Watch. What’s Happen[ing] in the Indonesia Palm Oil Industry? September 20, 2011.http://sawitwatch.or.id/2011/09/what%E2%80%99s-happen-in-the-indonesian-palm-oil-industry-2/

23 Modified from CEA definition. (2007). Solvency II Glossary. Brussels: CEA and Groupe Consultatif.

24 https://www.cbp.gov/trade/programs-administration/forced-labor

25 Modified from CEA definition. (2007). Solvency II Glossary. Brussels: CEA and Groupe Consultatif.

26 Mars: https://www.mars.com/global/about-us/policies-and-practices/palm-oil-policy

PepsiCo: https://www.pepsico.com/sustainability/palm-oil

Nestle: https://www.nestle.com/csv/raw-materials/palm-oil

Mondelez:https://www.mondelezinternational.com/~/media/mondelezcorporate/uploads/downloads/supplier_list.pdf

General Mills: https://www.generalmills.com/~/media/Files/Issues/PalmOil%20MasterList%20318.pdf?la=en

Johnson & Johnson: https://www.jnj.com/_document?id=00000164-ed97-d1a7-a9e7-ff9f7d0f0001

27 Gore-Langton, Louise. (2017, March 26) Nestlé “very concerned” over deforestation links to palm oil. FoodNavigator.com. https://www.foodnavigator.com/Article/2017/03/27/Nestle-very-concerned-over-deforestation-links-to-Wilmar-palm-oil

28 Wilmar International Limited. (2016, March). Annual Report 2015. Retrieved from Wilmar CorporateInformation: https://wilmar-iframe.todayir.com/attachment/20180820150703324005316_en.pdf

29 Wilmar International Limited. (2018). Sustainability Report 2017. Singapore: Wilmar International Limited.



32 Direct communication from RAN, December 10, 2018

ENDNOTES

https://askrspo.force.com/Complaint/s/case/50090000028Erz4AAC/detailhttps://www.unglobalcompact.org/library/2https://rightsandresources.org/en/to-end-deforestation-we-must-protect-community-land-rights/https://rightsandresources.org/en/to-end-deforestation-we-must-protect-community-land-rights/http://sawitwatch.or.id/2011/09/what%E2%80%99s-happen-in-the-indonesian-palm-oil-industry-2/ https://www.cbp.gohttps://www.mars.com/global/about-us/policies-and-practices/palm-oil-policyhttps://www.pepsico.com/sustainability/palm-oilhttps://www.nestle.com/csv/raw-materials/palm-oilhttps://www.mondelezinternational.com/~/media/mondelezcorporate/uploads/downloads/supplier_list.pdfhttps://www.generalmills.com/~/media/Files/Issues/PalmOil%20MasterList%20318.pdf?la=enhttps://www.jnj.com/_document?id=00000164-ed97-d1a7-a9e7-ff9f7d0f0001https://www.jnj.com/_document?id=00000164-ed97-d1a7-a9e7-ff9f7d0f0001https://www.foodnavigator.com/Article/2017/03/27/Nestle-very-concerned-over-deforestation-links-to-Wilmar-palm-oilhttps://www.foodnavigator.com/Article/2017/03/27/Nestle-very-concerned-over-deforestation-links-to-Wilmar-palm-oilhttps://wilmar-iframe.todayir.com/attachment/20180820150703324005316_en.pdf


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ABOUT CERES | WWW.CERES.ORG

Ceres is a sustainability nonprofit organization working with the most influential investors and companiesto build leadership and drive solutions throughout the economy. Through powerful networks andadvocacy, Ceres tackles the world’s biggest sustainability challenges, including climate change, waterscarcity and pollution, deforestation, and human rights abuses.

Support for this series was provided by the Gordon and Betty Moore Foundation as part of a conservationand financial markets collaboration among Ceres, World Wildlife Fund (WWF) and World Business Councilfor Sustainable Development (WBCSD).

REPORT AUTHOR

Bridget Bearden, Strooga Consulting

Ceres would like to thank those employees who provided extensive support with this project, includingJulie Nash, Christie Merino, and Siobhan Collins.

We would also like to acknowledge the following individuals and organizations who shared their time and expertise to review and provide feedback on this white paper including Michael Guindon andAnnabelle Dodson of ZSL SPOTT, Sharon Smith, and Robin Averbeck of Rainforest Action Network (RAN).

DISCLAIMER

Ceres reports are offered to Engage the Chain subscribers and our Investor Network on Climate andSustainability (INCRS). Ceres is not an investment adviser and makes no recommendations regarding the advisability of investing in any particular company, investment fund or other vehicle. The informationused to compile this report has been collected from a number of sources believed to be accurate whichare available in the public domain.

CONTACT FOR MORE INFORMATION

Siobhan Collins, [email protected] Manager of Food & Capital Markets
http://www.ceres.org

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