Managing Grievances

Issue Under Review: Allegations of land conflict, labor rights, environmental non-compliance

Grievance Entity: Aceites y Derivados S.A.
July 2020 - Status: Monitoring Implementation

In July 2020, Cargill received a grievance submission on Aceydesa's operations, which include the following allegations:

• Deforestation in farms of Aceydesa's associates
• Unjustified increase of RSPO certified volume
• Land conflict
• Non-compliance of labor legislation of the country regarding management of farms' employees
• Lack of PPE
• Non-compliance of environmental legislation

Actions Cargill Has Taken to Date

• After receiving this allegation, Cargill commenced a desktop investigation which included several document reviews from submissions by the supplier, who fully collaborated during the process. Findings were imported into an action plan co-designed with the company. This action plan was complemented with a field evaluation in January 2021, conducted by a third-party, that had already been scheduled with the supplier prior to receipt of the grievance as part of Cargill's proactive supplier engagement program.
• Regarding the allegation on unjustified increase of RSPO certified volume, Cargill will take guidance from RSPO's due diligence process and findings given that a similar allegation is included in RSPO's grievance system. (March 2021)
• Cargill continues monthly follow ups with Aceydesa to ensure proper closure of issues found. Aceydesa has provided proof of implementation against milestones agreed upon. Cargill will continue monitoring Aceydesa's progress. (March 2022)

Issue Under Review: Human Rights

Grievance Entity: Agropalma SA
February 2022 - Status: Monitoring Implementation

While performing supply chain monitoring, Cargill identified an incident involving Agropalma and Quilombola communities located at the Acará River, near plantations managed by the said Company. This issue was also raised in other articles and included general allegations related to human rights and labor issues.

Since 2021, Cargill has engaged Earthworm to support Agropalma's transformation through the ART Program, an initiative to help palm oil mills in Cargill's supply chain achieve alignment with NDPE criteria.

Grievance Source: Media

Actions Cargill Has Taken to Date

• Cargill collected additional information to understand the validity of the allegations through an independent third party (LDR). (March 2022) 
• Cargill is reviewing the investigation report to identify next steps. The investigation report was focused on analyzing land rights conflicts from a legal perspective. (April 2022)
• Cargill also sent an external team to perform a follow up visit to the operations. (April 2022)
• In March 2022, Cargill conducted a verification visit together with our NGO partner Earthworm to jointly develop and agree on an action plan with Agropalma. To date, Agropalma continues to work on closing the gaps in our agreed action plan which includes specific actions for improvement in the areas of staff training in conflict management, grievance management and  community relations.
• In October 2022, Cargill was closely involved in an audit carried out by independent assurance expert DNV focused on labor conditions. During this audit, no labor issues were found.
• In February 2023, Agropalma’s RSPO certification was temporarily suspended due to unresolved land rights issues. Agropalma has shared with Cargill that they are appealing the suspension.
• Cargill worked with a third party to carry out an external assessment to investigate the alleged land rights issues.
• In the meantime, we continue to engage Agropalma to close the gaps in our agreed action plan. A key part of our engagement happens through the Aggregator Refinery Transformation (ART) Program that Cargill deploys in Brazil together with the Earthworm Foundation. (April 2023)
• At the end of June 2023, the implementation of the action plan was completed, and Agropalma was notified by IBD that the RSPO certification suspension had been lifted.
• Cargill continues to support Agropalma to ensure compliance with our sustainability policy through the Aggregator Refinery Transformation (ART) program. (July 2023)
• A training in Community Dialogues was conducted in the region. This activity was part of the ART program. (July 2023)
• A training in Facilitation of Community Meetings was conducted, with the participation of 21 people. During the event, technical assistance was provided for the collaborative construction of operational procedures. These procedures include policy review, definition of methodology for faithful dialogues with communities, support for compliance with RSPO Non-Conformities, and adaption of Tools for including field work. (October 2023)
• We understand that, on November 10th, there was an unauthorized occupation of a plantation owned by Agropalma. According to some sources, the group was identified as part of ARQVA – Association of Quilombola Remnants of Vale do Acará. However, this community did not claim responsibility for the invasion. A body was discovered in the same area following the incident. The Federal Police are investigating, with Agropalma providing full cooperation. The company reports that the occupiers have since voluntarily left the area. Agropalma has noted that during this invasion, their security team refrained from engaging in violence and avoided direct conflict, despite the unauthorized entry and occupation. (November 2023)
• Cargill is closely following the investigations by the competent authorities and awaiting developments and clarifications on the case. Cargill reiterates its strong commitment to human rights, condemning violence and intimidation.  All of our suppliers and partners are monitored in accordance with our Supplier Code of Conduct. (November 2023)
• Agropalma underwent a new audit in November 2023. During this audit, Agropalma received several non-conformities related to operational  and land issues. Following the audit report, Agropalma's certification has been suspended. Agropalma is currently implementing an action plan that includes corrective measures to regain RSPO certification. This action plan has already been shared with the certifying bodies. Cargill is closely monitoring the implementation of the action plan for the recovery of the certification and for addressing other outstanding issues (January 2024)

Issue Under Review: Alleged Land Conflict

Grievance Entity: PT Mamuang
April 2022 - Status: Monitoring Implementation

Grievance Source: Friends of the Earth, WALHI

Cargill received a report by Friends of the Earth (FoE) raising allegations related to Astra Agro Lestari's operations. In October 2022, we also received a summary report from our consultant titled: PT Astra Agro Lestari Grievance Case - Field Verification Executive Summary dated 19 August 2022. The issues related to PT Mamuang are summarized as follows:

• PT Mamuang and the local community are both claiming overlapping 50ha of land.
• Alleged criminalization of farmers linked to reports from employees of PT Mamuang.

Actions Cargill Has Taken to Date

• Cargill reached out to Astra Agro Lestari (AAL) for a response. AAL shared that they had provided a response to FoE on the report, but the response was not captured in the FoE Report. (July 2022)
• Cargill had a follow up discussion with AAL to review the Econusantara Summary report regarding the case with AAL. Cargill engaged AAL for a response and for an action plan to be developed together with Cargill.
• AAL has shared a response directly to Cargill regarding PT Mamuang, summarized as follows:
  • PT Mamuang obtained its Rights To Cultivate (Hak Guna Usaha or "HGU") land title certificate in 1997, after completing all the required processes to the satisfaction of the National Land Agency (Badan Pertanahan Negara or "BPN"). The HGU can only be issued if the land belongs to the state and verified by all parties involved, including community representatives. The land claim allegations against PT Mamuang were based on a document issued after the issuance of PT Mamuang's land title certificate.
  • Regarding the Certification of Ownership (SHM) issued on top of PT Mamuang's HGU, AAL has written to the BPN Donggala district and received an official letter stating that there was no certificate issued by the BPN Donggala District included in the coordinates of PT Mamuang's HGU. Cargill has asked for AAL to share further information with Cargill for verification. 
  • On the allegation of criminalization, the processes were held through court decisions in an open trial. The court decision can be perused through the following links here and here.
• AAL has also published their response to the allegations on their website. Cargill will continue to follow up with AAL to develop and implement an action plan. (October 2022)
• AAL announced at the end of March that they have commissioned an independent third party, EcoNusantara, to conduct an in-depth investigation of the grievances raised by FoE, including a land tenurial study to identify land ownership in relation to the three concessions and a community needs assessment. (March 2023)
• Cargill held a planned status meeting with AAL to discuss progress made against the agreed action plan. Key outcomes of the meeting are as follows:
  • AAL confirmed they have worked with independent partner Conflict Resolution Unit (CRU) to review and design a Human Rights Due Diligence (HRDD) strategy and that they will pilot their HRDD strategy at two sites over the next 15 months.
  • AAL shared with Cargill that they have hired advisory firm Robertsbridge to support Astra with stakeholder communication.
  • AAL agreed to grant Cargill access to documentation to help Cargill review their land-use certificates related to the three concessions highlighted by Friends of the Earth: PT Agro Nusa Abadi, PT Lestari Tani Teladan and PT Mamuang.
  • Cargill urged AAL to provide regular updates on their actions and share these on their public grievance log. (April 2023)
• AAL has committed to publish bi-weekly progress updates on their website. The first update from 12 May can be found here. (May 2023)
• AAL published a second work progress statement (26 May) on their kick-off meeting with the communities, which can be found here.
• AAL published a third work progress statement (9 June) on their verification activities with stakeholders who have came forward across 3 companies. Update can be found here.
• AAL published their fourth work progress statement (23 June) on their verification activities, still inviting stakeholders to come forward. Update can be found here.
• AAL published their fifth work progress statement (7 July), mentioning challenges on the ground. Update can be found here. (July 2023)
• AAL published their sixth work progress statement (21 July) on their continued verification activities. Update can be found here. (July 2023)
• AAL published their seventh work progress statement (4 August), mentioning their data collection phase is closer to a conclusion. Update can be found here.
• AAL published their eighth work progress statement (18 August), mentioning their completion of data collection phase and will move to data review stage, although there is a possibility to revisit some of the evidence. Update can be found here.
• AAL published their ninth work progress (1 September), starting their data consolidation process. Update can be found here. (September 2023)
• AAL published their tenth work progress (15 September), continuing their data consolidation progress. Update can be found here.
• AAL published their eleventh work progress (29 September), continuing their data consolidation and evidence review. Update can be found here.
• AAL published their twelfth work progress (13 October), starting their process of wrapping up the final report of their field assessment. Update can be found here.
• AAL published their thirteenth work progress (27 October), mentioning their finalized assessment that will be shared with key stakeholders the following week. Update can be found here. (November 2023)
• AAL published their fourteenth work progress (10 November) and their fifteenth work progress (24 November) mentioning their finalized investigation report and publication. The verification report can be accessed here. (November 2023)
• A few days after AAL officially published their investigation report, FoE made a statement rejecting the AAL/ENS verification report. FoE's statement can be seen here, and detailed feedback from FoE can be seen here. (November 2023)
• AAL/ENS published a response to stakeholders' comments or objections, which can be seen here. (November 2023)
• Walhi, FoE UK and a few members of the Sulawesi Community held a protest in London. AAL provided a response statement following the protest as can be seen here. AAL is aware that the report and next steps may not satisfy all stakeholders. However they still welcome feedback and continue to focus on the recommendation as developed during ENS' investigation. (May 2024)
• AAL and ENS published an action plan with communities as recommended by ENS on the verification report. The timebound action plan can be seen here. (June 2024)
• AAL announced its RSPO membership. (July 2024)
• AAL published its first action plan progress report as can be seen here. (September 2024)

Issue Under Review: Alleged Land Conflict

Grievance Entity: PT Lestari Tani Teladan
April 2022 - Status: Monitoring Implementation

Grievance Source: Friends of the Earth, WALHI

Cargill received a report by Friends of the Earth (FoE) raising allegations related to Astra Agro Lestari's operations. In October 2022, we also received a summary report from our consultant titled: PT Astra Agro Lestari Grievance Case - Field Verification Executive Summary dated 19 August 2022. The issues related to PT Lestari Tani Teladan (PT LTT) are summarized as follows:

• PT Lestari Tani Teladan has claimed approximately 100ha allegedly from farmers in the villages of Rio Mukti and Tawi.
• The company also allegedly implements an outsourcing system, allegedly mismatches working hours and fails to follow a wage system in accordance with Indonesian labor law, whereby the price of palm oil fruits produced by the farmers are allegedly determined by the company alone.

Actions Cargill Has Taken to Date

• Cargill reached out to Astra Agro Lestari (AAL) for a response. AAL shared that they had provided a response to FoE on the report, but the response was not captured in the FoE Report. (July 2022)
• Cargill had a follow up discussion with AAL to review the Econusantara Summary report regarding the case with AAL. Cargill engaged AAL for a response and for an action plan to be developed together with Cargill.
• AAL has shared a response to Cargill directly regarding PT LTT, summarized as follows:
  • The price for plasma holders was in accordance with regulations. PT LTT has not received complaints from its farmers or farmer group institutions regarding the pricing.
• AAL has also published their response to the allegations on their website. Cargill will continue to follow up with AAL to develop and implement an action plan. (October 2022)
• AAL announced at the end of March that they have commissioned an independent third party, EcoNusantara, to conduct an in-depth investigation of the grievances raised by FoE, including a land tenurial study to identify land ownership in relation to the three concessions and a community needs assessment. (March 2023)
• Cargill held a planned status meeting with AAL to discuss progress made against the agreed action plan. Key outcomes of the meeting are as follows:
  • AAL confirmed they have worked with independent partner Conflict Resolution Unit (CRU) to review and design a Human Rights Due Diligence (HRDD) strategy and that they will pilot their HRDD strategy at two sites over the next 15 months.
  • AAL shared with Cargill that they have hired advisory firm Robertsbridge to support Astra with stakeholder communication.
  • AAL agreed to grant Cargill access to documentation to help Cargill review their land-use certificates related to the three concessions highlighted by Friends of the Earth: PT Agro Nusa Abadi, PT Lestari Tani Teladan and PT Mamuang.
  • Cargill urged AAL to provide regular updates on their actions and share these on their public grievance log. (April 2023)
• AAL has committed to publish bi-weekly progress updates on their website. The first update from 12 May can be found here. (May 2023)
• AAL published a second work progress statement (26 May) on their kick-off meeting with the communities, which can be found here.
• AAL published a third work progress statement (9 June) on their verification activities with stakeholders who have came forward across 3 companies. Update can be found here.
• AAL published their fourth work progress statement (23 June) on their verification activities, still inviting stakeholders to come forward. Update can be found here.
• AAL published their fifth work progress statement (7 July), mentioning challenges on the ground. Update can be found here. (July 2023)
• AAL published their sixth work progress statement (21 July) on their continued verification activities. Update can be found here. (July 2023)
• AAL published their seventh work progress statement (4 August), mentioning their data collection phase is closer to a conclusion. Update can be found here.
• AAL published their eighth work progress statement (18 August), mentioning their completion of data collection phase and will move to data review stage, although there is a possibility to revisit some of the evidence. Update can be found here.
• AAL published their ninth work progress (1 September), starting their data consolidation process. Update can be found here. (September 2023)
• AAL published their tenth work progress (15 September), continuing their data consolidation progress. Update can be found here.
• AAL published their eleventh work progress (29 September), continuing their data consolidation and evidence review. Update can be found here.
• AAL published their twelfth work progress (13 October), starting their process of wrapping up the final report of their field assessment. Update can be found here.
• AAL published their thirteenth work progress (27 October), mentioning their finalized assessment that will be shared with key stakeholders the following week. Update can be found here. (November 2023)
• AAL published their fourteenth work progress (10 November) and their fifteenth work progress (24 November) mentioning their finalized investigation report and publication. The verification report can be accessed here. (November 2023)
• A few days after AAL officially published their investigation report, FoE made a statement rejecting the AAL/ENS verification report. FoE's statement can be seen here, and detailed feedback from FoE can be seen here. (November 2023)
• AAL/ENS published a response to stakeholders' comments or objections, which can be seen here. (November 2023)
• Walhi, FoE UK and a few members of the Sulawesi Community held a protest in London. AAL provided a response statement following the protest as can be seen here. AAL is aware that the report and next steps may not satisfy all stakeholders. However they still welcome feedback and continue to focus on the recommendation as developed during ENS' investigation. (May 2024)
• AAL and ENS published an action plan with communities as recommended by ENS on the verification report. The timebound action plan can be seen here. (June 2024)
• AAL announced its RSPO membership. (July 2024)
• AAL published its first action plan progress report as can be seen here. (September 2024)

Issue Under Review: Alleged Land Conflict

Grievance Entity: PT Agro Nusa Abadi
April 2022 - Status: Monitoring Implementation

Grievance Source: Friends of the Earth, WALHI

Cargill received a report by Friends of the Earth (FoE) raising allegations related to Astra Agro Lestari's operations. In October 2022, we also received a summary report from our consultant titled: PT Astra Agro Lestari Grievance Case - Field Verification Executive Summary dated 19 August 2022. The issues related to PT Agro Nusa Abadi (PT ANA) are summarized as follows:

• PT Agro Nusa Abadi has claimed 5,000ha of land allegedly belonging to farmers of Molino Village, Bungintimbe Village, Tompira Village and Butna Village, and is operating without a land use permit (HGU).
• The company is allegedly to have only location permits, thus being in violation of local laws concerning taxation and regional income.

Actions Cargill Has Taken to Date

• Cargill reached out to Astra Agro Lestari (AAL) for a response. AAL shared that they had provided a response to FoE on the report, but the response was not captured in the FoE Report. (July 2022)
• Cargill had a follow up discussion with AAL to review the Econusantara Summary report regarding the case with AAL. Cargill engaged AAL for a response and for an action plan to be developed together with Cargill.
• AAL has shared a response to Cargill directly regarding PT ANA, summarized as follows:
  • PT ANA has not been able to compensate the remaining 1,140ha of land due to overlapping land ownership. Settlement of overlapping land ownership is done by the Team for Settlement of Plantation Land Disputes in North Morowali District formed by the Regent of North Morowali. PT ANA will fully align with the direction of the Team regarding who is the rightful owner of the concerned overlapping land.
• AAL has also published their response to the allegations on their website. Cargill will continue to follow up with AAL to develop and implement an action plan. (October 2022)
• AAL announced at the end of March that they have commissioned an independent third party, EcoNusantara, to conduct an in-depth investigation of the grievances raised by FoE, including a land tenurial study to identify land ownership in relation to the three concessions and a community needs assessment. (March 2023)
• Cargill held a planned status meeting with AAL to discuss progress made against the agreed action plan. Key outcomes of the meeting are as follows:
  • AAL confirmed they have worked with independent partner Conflict Resolution Unit (CRU) to review and design a Human Rights Due Diligence (HRDD) strategy and that they will pilot their HRDD strategy at two sites over the next 15 months.
  • AAL shared with Cargill that they have hired advisory firm Robertsbridge to support Astra with stakeholder communication.
  • AAL agreed to grant Cargill access to documentation to help Cargill review their land-use certificates related to the three concessions highlighted by Friends of the Earth: PT Agro Nusa Abadi, PT Lestari Tani Teladan and PT Mamuang.
  • Cargill urged AAL to provide regular updates on their actions and share these on their public grievance log. (April 2023)
• AAL has committed to publish bi-weekly progress updates on their website. The first update from 12 May can be found here. (May 2023)
• AAL published a second work progress statement (26 May) on their kick-off meeting with the communities, which can be found here.
• AAL published a third work progress statement (9 June) on their verification activities with stakeholders who have came forward across 3 companies. Update can be found here.
• AAL published their fourth work progress statement (23 June) on their verification activities, still inviting stakeholders to come forward. Update can be found here.
• AAL published their fifth work progress statement (7 July), mentioning challenges on the ground. Update can be found here. (July 2023)
• AAL published their sixth work progress statement (21 July) on their continued verification activities. Update can be found here. (July 2023)
• AAL published their seventh work progress statement (4 August), mentioning their data collection phase is closer to a conclusion. Update can be found here.
• AAL published their eighth work progress statement (18 August), mentioning their completion of data collection phase and will move to data review stage, although there is a possibility to revisit some of the evidence. Update can be found here.
• AAL published their ninth work progress (1 September), starting their data consolidation process. Update can be found here. (September 2023)
• AAL published their tenth work progress (15 September), continuing their data consolidation progress. Update can be found here.
• AAL published their eleventh work progress (29 September), continuing their data consolidation and evidence review. Update can be found here.
• AAL published their twelfth work progress (13 October), starting their process of wrapping up the final report of their field assessment. Update can be found here.
• AAL published their thirteenth work progress (27 October), mentioning their finalized assessment that will be shared with key stakeholders the following week. Update can be found here. (November 2023)
• AAL published their fourteenth work progress (10 November) and their fifteenth work progress (24 November) mentioning their finalized investigation report and publication. The verification report can be accessed here. (November 2023)
• A few days after AAL officially published their investigation report, FoE made a statement rejecting the AAL/ENS verification report. FoE's statement can be seen here, and detailed feedback from FoE can be seen here. (November 2023)
• AAL/ENS published a response to stakeholders' comments or objections, which can be seen here. (November 2023)
• Walhi, FoE UK and a few members of the Sulawesi Community held a protest in London. AAL provided a response statement following the protest as can be seen here. AAL is aware that the report and next steps may not satisfy all stakeholders. However they still welcome feedback and continue to focus on the recommendation as developed during ENS' investigation. (May 2024)
• AAL and ENS published an action plan with communities as recommended by ENS on the verification report. The timebound action plan can be seen here. (June 2024)
• AAL announced its RSPO membership. (July 2024)
• AAL published its first action plan progress report as can be seen here. (September 2024)

Issue Under Review: Labor and Human Rights Issues

Grievance Entity: Brasil Bio Fuels (formerly owned by Biopalma Amazonia)
June 2019 - Status: Suspended

While performing supply chain monitoring, Cargill found an article raising allegations about Biopalma, starting with an accident of a ferry that was allegedly transporting palm oil residues extracted from Biopalma plantations. Allegations raised were related to environmental topics, as well as human rights and labor issues.

Since 2014, Cargill has been engaging Biopalma to support its transformation through the ART Program. Apart from the information already available, the Company requested for additional documentation to assess the issues raised. After Biopalma was sold to Brasil Bio Fuels (BBF) in October 2020, Cargill received additional information related to previously described topics.

Grievance Source: Rio On Watch

Actions Cargill Has Taken to Date

• Cargill collected additional secondary and primary information to understand the validity of the allegations. (August 2019)
• Cargill analyzed the information and identified gaps regarding labor compliance and grievance management. (November 2019)
• Cargill informed Biopalma about the findings and requested for additional data. (January 2020)
• Cargill consulted external stakeholders on an action plan draft. (February 2020)
• Cargill shared the action plan with Biopalma. Both parties approved the proposed actions and local teams have been following up on the progress. (September 2020)
• Biopalma was sold to Brasil Bio Fuels in October 2020. Cargill engaged the new owner on the grievance and the compliance procedures in place. (November 2020)
• Cargill sent an external team to perform a verification visit to the region. (November 2021)
• Findings from the visit have been submitted to Cargill for review. (February 2022)
• Effective October 13, 2022, Cargill has decided to suspend Brasil BioFuels (BBF) from its palm supply chain in light of increasing tensions, including acts and allegations of violence surrounding BBF’s operations. Currently, Cargill is unable to ensure BBF is upholding its obligations as a Cargill supplier, as set out in our Policy on Sustainable Palm Oil, Supplier Code of Conduct and the specific sustainability action plan that is in place between Cargill and BBF.
• We are suspending our commercial relationship with BBF until information becomes available that allows us to confirm that BBF meets the requirements to be reinstated as a Cargill supplier. We will continue to engage with BBF to work with them on the execution of the action plan and improvement of their sustainability performance. A key part of our engagement happens through the Aggregator Refinery Transformation (ART) Program that Cargill deploys in Brazil together with Earthworm Foundation. (November 2022)

Issue Under Review: Allegations of land conflict

Grievance Entity: PT Poliplant Sejahtera (PSA)
May 8, 2019 - Status: Investigation

Cargill was informed of allegations made by LinkAR-Borneo that our subsidiary PT Poliplant Sejahtera (PSA) in West Kalimantan did not fully compensate Farmer “LK” for his plot inside the estate according to the agreed conditions of ownership transfer since 2009.

A separate but related allegation accuses PSA of causing the imprisonment of Farmer “LK”, who was caught at the end of 2018 for harvesting fresh fruit bunches in the plot he no longer owned. The case is being processed in the local district court.

Grievance Source: Link-Ar Borneo

Actions Cargill Has Taken to Date

• PSA has maintained documented evidence, including the notarized acceptance of transfer of land ownership by Farmer “LK”, that refute both allegations.
• Cargill requires all subsidiaries to comply with local laws of the countries we operate in, including Indonesia. This is in addition to U.S. laws concerning imports and exports, bribery and trade sanctions.
• As required by company policy and by law, PSA reported and handed the illegal harvesting case to local law authorities for their investigation and management.
• Cargill investigates all allegations fully and is committed to resolving the matter through constructive dialogue with Link-AR Borneo. (8 May 2019)
• Cargill and Link-Ar Borneo are planning a meeting to review the grievance. (July 5, 2019)

Issue Under Review: FPIC

Grievance Entity: PT Harapan Sawit Lestari
Oct. 9, 2018 - Status: Case Closed

Cargill was informed of allegations made by Link-Ar Borneo on behalf of the Asam Besar community that PT HSL had not sought proper consent from the community prior to commencing re-planting activities. 

Grievance Source: Link-Ar Borneo (RSPO Complaint)

Actions Cargill Has Taken to Date

• PT HSL has maintained documented evidence on the socialization process that was undertaken with the community prior to replanting activities in the disputed area, that refute allegations raised by the complainant.
• Nonetheless, Cargill is committed to resolving complaints raised through the RSPO process. We provided our clarifications to RSPO on October 30, 2018 and are awaiting feedback from RSPO on next steps. 
• The RSPO Complaints Panel has closed the complaint. PT HSL has reached a settlement agreement that is satisfactory to the Asam Besar village communities. Details of the CP’s decision can be found here. Cargill will continue supporting our engagement with local communities and ensuring FPIC is respected. (October 2020)
• Cargill understands that a report by Forest Peoples Programme has been published, which raises allegations regarding HSL's operations. Please find Cargill's full response to the allegations here. (June 2021)

Issue Under Review: Environmental Non-compliance

Grievance Entity: PT Harapan Sawit Lestari (HSL)
January 2021 - Status: Investigation

Grievance Source: Mighty Earth

Cargill was alerted to land clearing taking place within HSL’s concession boundary by Mighty Earth. At the point of enquiry, we were aware of ongoing clearing by community enclaves from past stakeholder engagements and knowledge by local teams on community activities. Cargill has a valid HCS assessment conducted in 2015 that was independently verified by Daemeter. In addition, the assessment was submitted to the High Carbon Stock (HCS) Secretariat following our membership to the HCS Steering Group. Peer review was not conducted as the assessment was carried out prior to the launch of the revised HCS toolkit which introduced the quality assurance process. All land clearing and planting was based on this assessment.

Actions Cargill Has Taken to Date

• Cargill communicated to Mighty Earth of the context in HSL and awareness that communities were clearing in HSL. Cargill requested for details of the alerts for investigation to commence. (January 2021)
• Once coordinates and shapefiles were shared, Cargill commenced investigation. Initial desktop review showed that land clearing was indeed by community enclaves. These communities had been socialized on HCS by Cargill and in the past made requests for Cargill to conduct land clearing on their behalf. Cargill had rejected the request on the basis of our No Deforestation policy following which the community pursued clearing on their own. These details were shared with Mighty Earth. (March 2021)
• In April, on the ground investigations were completed and outcomes reflected the desktop review. Engagements with the grievance raiser and HCS Secretariat are ongoing on topics related to HSL's HCS assessment. (April 2021)

Issue Under Review: Public accusation of: Deforestation of HCS forest in Asian Plantations Limited's Grand Performance concession.

Grievance Entity: Asian Plantations Limited (Grand Performance)
January 22, 2018 - Status: Implementation of action plan

Grievance Source: AidEnvironment

Actions Cargill Has Taken to Date

• Cargill reached out to FGV on the allegations. (January 22, 2018)
• FGV committed to a stop-work order in Grand Performance while an independent assessment to identify HCS area will be conducted. FGV will exclude any HCS area if identified. Please refer to FGV's official statement for further information. (February 1, 2018)
• FGV adopts the HCSA. This commitment was made as part of a wider set of updates to FGV's sustainability policy. Further details on this update is available here. (April 9, 2018)

Issue Under Review: Public accusation of: Development on peat in PT Temila Agro Abadi, Burning by surrounding communities

Grievance Entity: PT Temila Agro Abadi
April 18, 2017 - Status: Implementation of action plan

Grievance Source: AidEnvironment

Actions Cargill Has Taken to Date

• Cargill has reached out to FGV on allegations of HCV clearance in their Indonesian subsidiary, PT TAA. Felda is appointing a third-party assessor to verify the allegations. Read more here. (May 2, 2017)
• FGV committed to a stop-work order since April 22, 2017. Based on Cargill's last engagement with FGV on July 6, the stop-work order is still in place pending a board decision in August on FGV's Kalimantan operations.
• FGV has enhanced their Sustainability Policy to reflect "No Peat" development for all new planting regardless of depth and when land was acquired. FGV has also committed to rehabilitating the peat lands that were previously cleared in PT TAA. Read more here. Cargill will be meeting FGV in September to discuss these actions in further detail. (August 29, 2017)
• FGV is engaging various stakeholders as part of preparing its action plan to address these issues. FGV will share their action plan with Cargill following which time-bound milestones will be developed.
• Please refer to FGV's update on their "Kalimantan Peat Restoration Master Plan". Cargill will monitor FGV's implementation of the action plan to ensure timely execution. (January 12, 2018)
• Mighty Earth published Rapid Response Report 9, alleging that PT TAA had three fire incidents. Cargill investigated the allegations and reached out to FGV for more information. FGV clarified that the land clearing was conducted by a local community. FGV’s statement can be found here. FGV has been maintaining their moratorium since May 2017. (November 2018)
• Cargill met FGV senior management and sustainability team and enquired on current status of the moratorium and implementation plan. We understand FGV is mediating community pressure for development. The company has stepped up monitoring for community fires and encroachment. (March 5, 2019)
• FGV continues to implement its Kalimantan Peat Restoration Master Plan. The company is reporting its water table data to the relevant authorities monthly. (June 25, 2019)

Issue Under Review: Alerted by FGV that their Indonesian subsidiary PT Citra Niaga Perkasa, encountered HCV land clearing.

Grievance Entity:PT Citra Niaga Perkasa
April 17, 2016 - Status: Implementation of action plan

Grievance Source: Supplier self-reporting

Actions Cargill Has Taken to Date

• FGV engaged Aksenta, a certified HCV assessor, to reassess the area for any remediation/compensation process.
• Met FGV on July 22nd, 2016 to get clarification on the matter and was informed Aksenta’s ground investigation demonstrates clearance of area was carried out by contractors under local community pressure without knowledge of the plantation manager.
• Cargill is monitoring FGV's ongoing RSPO compensation procedure and mediation process with local community. Updates on FGV's progress can be found here.
• FGV commits to rehabilitating the peat lands that were previously cleared in PT CNP. Read more here. Cargill will be meeting FGV in September to discuss these actions in further detail. (August 29, 2017)
• FGV is engaging various stakeholders as part of preparing its action plan to address these issues. FGV will share their action plan with Cargill following which time-bound milestones will be developed.
• Please refer to FGV's update on their "Kalimantan Peat Restoration Master Plan". Cargill will monitor FGV's implementation of the action plan to ensure timely execution. (January 12, 2018)
• FGV continues to implement its Kalimantan Peat Restoration Master Plan. The company is reporting its water table data to the relevant authorities monthly. (June 25, 2019)

Issue Under Review: Public accusations of: Labor violations (Migrant labor) in Malaysian operations

Grievance Entity: Malaysian operations
December 14, 2015 - Status: Monitoring Implementation

Grievance Source: Wall Street Journal

Actions Cargill Has Taken to Date

• Received allegations of labor abuses on palm plantations. (July 26, 2015)
• Initiated direct contact with FGV.  (July 27, 2015)
• Endorsed RSPO’s independent investigation conducted by Accreditation Services International. (September 14, 2015)
• Engaged with FGV senior management on the formation of a Sustainability Response Team and partnership with a third-party auditor. (November 2015)
• Informed by FGV on withdrawal of all upstream RSPO certification on May 3rd 2016.
• Met with FGV on June 9, 2016 to advance progress on outstanding issues.
• Met with FGV on July 22nd, 2016 to get updates on action plan progress. Implementation plans addressing grievances are underway. Updates on FGV's progress can be found here.
• Shared with FGV on Cargill’s experience developing and managing a grievance process (October 21st, 2016).
• Regular monthly meetings continue to take place to share updates and feedback.
• Cargill is working with FGV to develop a set of time-bound milestones that will address remaining issues (December 14, 2016).
• Participated in FGV's ‘Oil Palm Labor Workshop’ which aimed to develop recommendations on recruitment fees, passport retention and child labor. More details can be found here.
• Cargill is monitoring FGV's progress in the following areas:
  • Passport retention
  • Developing a grievance procedure
  • Developing a social management system. More details can be found here.
• FGV has developed a draft action plan covering their entire operations on five focus areas: forced/bonded labor, ethical recruitment, employment contract, wages (minimum wage), safety & health around institutional strengthening, policy commitment, due diligence and stakeholder engagement. FGV has also partnered with SUHAKAM, the Human Rights Commission of Malaysia, to implement, monitor and verify their action plan. Cargill will be reviewing FGV’s action plan once NGO consultations have been completed. (July 2017)
• FGV releases its progress update on its Social Compliance and Human Rights (SCHR) Initiatives. (October 2017)
• FGV provides a detailed update on its SCHR action plan with associated timelines. (April 9, 2018)
• Cargill met FGV senior management and sustainability team and enquired on current status of the RSPO action plan. FGV has committed to submitting the plan by 29 March 2019. In addition, FGV has committed to strengthening its policies and SOPs on human rights and labor management. Please see here for latest steps taken by FGV on the grievance. (March 5, 2019)
• Cargill reviewed FGV's 1st quarterly progress report with FGV's sustainability team. The company is taking steps to strengthen internal processes and training to ensure policies are cascaded to on ground implementation. In addition, priority will be given to ensuring FGV's third party contractors abide by its labor requirements. (April 30, 2019)
• Cargill reviewed FGV's 2nd quarterly progress report with FGV has published a revised group sustainability policy, supplier code of conduct and guidelines and procedures for responsible recruitment of foreign workers. The company has also commenced a socialization program with its third party contractors on their expectations. (June 28, 2019)
• RSPO Complaint Panel lifted the suspension on RSPO’s P&C certificate for FGV’s Serting complex based on satisfactory progress demonstrated by FGV on its action plan. Cargill will continue to evaluate FGV’s fulfillment of our supplier requirements and asses our relationship with FGV based on the delivery of their action plan. We urge FGV to ensure its entire operations and third-party contractors abide by Cargill’s Sustainability Policy. (August 5, 2019)
• FGV commits to third-party verification and engagement with independent organizations to strengthen its labor recruitment program. See here for details. (September 2019)
• FLA announces FGV’s participation in the FLA. FLA and FGV to work together on an action plan to address workers’ rights in FGV operations and supply chain. More information can be found here. (November 2019)
• Cargill is aware that the RSPO Complaints Panel has suspended RSPO’s P&C Certificate for Kilang Sawit Serting and all certification processes for uncertified FGV estates. Cargill has reached out to FGV and RSPO’s Complaint Panel Secretariat for more information. (13 January 2020)
• FGV announces it will write an official appeal letter to the Panel. (15 January 2020)
• FGV published a statement detailing its additional actions taken to implement the Complaints Panel’s Directives since the audit in October 2019 until January 2020. FGV also discloses the verification audit reports based on FGV operations in Peninsular Malaysia and Sabah. The audit shows that operations in Peninsular Malaysia are following the directives while those Sabah Malaysia has more room for improvement in fully implementing the directives. More information can be found here. (24 January 2020)
• Cargill spoke with FGV on 31 March 2020 to understand its progress with RSPO and FGV’s next steps. FGV shared the following –
  • FGV submitted its plans to the Complaints Panel on 13 February 2020 which details how it will follow the Complaints Panel’s new directives stated in January. FGV is waiting for the Complaints Panel’s feedback.
  • FGV has created an action plan together with Fair Labor Association aimed at ensuring FGV implements ethical labor practices. The deliverables of the action plan are also aligned with maintaining the implementation of the Complaints Panel’s Directives.
  • FGV also shared that a customer conducted its own verification audit in Sabah and found that FGV was implementing the Complaints Panel's Directives.
• FGV released the summary of its action plan with Fair Labor Association. FGV had consulted human rights organizations such as the Human Rights Commission of Malaysia (SUHAKAM) and Tenaganita when creating the action plan. The action plan covers responsible recruitment of migrant workers, strengthening grievance mechanisms, regularization of undocumented migrant workers, improving monitoring systems and remediation as well as enhancing FGV’s stakeholder engagement. FGV’s focus in 2020 will be on its operations before progressively implementing the action plan in its supply chain. FGV’s also listed its sustainability initiatives up till February 2020. Cargill will follow up with FGV once they have submitted their appeal to the Complaints Panel to lift the suspension. Cargill notes the comprehensiveness of FGV's action plan and stresses the importance of FGV being transparent and consistent in its implementation across all operations. (March 2020)
• FGV submitted their appeal letter to the RSPO Complaints Panel. (3 April 2020)
• FGV shared their action plan implementation progress with RSPO. (July 2020)
• FGV submitted an appeal to the Complaints Panel to extend the timeline for the regularization of workers in Sabah and new housing for workers due to movement restrictions during the COVID-19 pandemic. (July 2020)
• The United States Customs and Border Protection ordered the detention of all Malaysian palm oil and palm products made by FGV, its subsidiaries and joint ventures imported into the United States. CBP issued its Withhold Release Order based upon information which it states "reasonably indicates the use of forced labor" by FGV. We have taken immediate action to ensure compliance with CBP's Withhold Release Order against FGV. (30 September 2020)
• Cargill spoke with FGV regarding CBP's decision and FGV's progress in implementing its action plan. FGV shared that they have been implementing their action plan. FGV had also been in communication with CBP during its investigation and will continue engaging with CBP. Cargill will continue to follow up with FGV on the implementation of its action plan.
• FGV released a statement regarding updates on the Withhold Release Order. FGV shared that FGV and CBP held a conference call on 8 October 2020. The CBP could not reveal any information except that its research identified 11 International Labour Organization indicators of forced labor in FGV's practices. The CBP did not disclose any further information. FGV also announced in its statement that an external audit will be conducted and the findings shared with CBP to consider lifting the WRO. The full statement can be found here.
• FLA and FGV released FLA's Assessment Report on the implementation of FGV's action plan. Additional actions have also been included in FGV's action plan to be implemented at the end of 2020 or early 2021.
• Cargill remains committed to protecting human rights and will continue engaging suppliers to ensure better labor conditions are in place. (October 2020)
• FGV released a statement sharing its efforts to continue improving labor practices as part of addressing the Withhold Release Order issued by the CBP/ FGV also revised its Group Sustainability Policy in November 2020 to strengthen its labor commitments based on the FLA Workplace Code of Conduct. 
• FGV also published the FLA Assessment Report covering FGV's progress in implementing the FLA action plan across its operations. Activities implemented by FGV include:
  • Strengthening recruitment agencies' practices to comply with labor standards.
  • Improvement of FGV's communication pack developed for migrant workers' awareness during the recruitment process. Revisions included providing information on the employment contract duration, location and type of work, rules and regulations as well as workers' rights and compensation.
  • Employees' participation in a series of training sessions conducted by the FLA covering labor standards. The sessions covered content such as strengthening FGV's grievance mechanism, strengthening FGV's process of responsible recruitment of migrant workers and monitoring labor standards.
• The full report can be found on FGV's website. (April 2021)
• FGV released an update on its sustainability progress. FGV will continue with its second year of partnership with FLA, which includes a broader sampling in its Independent External Assessment. The RSPO verification audit has been completed and the audit report will be shared with the RSPO Complaints Panel. FGV is waiting for the RSPO Complaints Panel's decision on a review of its existing suspension.
• Regarding the US Withhold Release Order, FGV has called for proposals and aims to appoint an independent auditor in August.
• FGV's full update can be found on FGV's website. (July 2021)
• FGV continues to make progress in the implementation of their sustainability strategy, such as committing to Science-Based Targets through the Science Based Target initiative (SBTi) and spending RM350 million in workers’ housing upgrades from 2018 to 2022.
• On the US Withhold Release Order, FGV has appointed Crowell & Moring as the legal counsel since August 2021 to advise on the US CBP issue. FGV has had three meetings with the US CBP in in 2022, two of which were conducted in Washington DC.
• FGV appointed ELEVATE as the independent auditing firm to conduct an assessment of FGV’s operations against the 11 International Labour Organization (ILO) indicators of forced labor. The site assessments were conducted between April and September 2022 covering more than 25 of FGV’s operations, where the assessments were conducted at mills and estates based on the risk profiles established by Elevate. These visits were carried out unannounced. FGV will consolidate the findings reported by Elevate and develop a continuous remediation plan. This will be validated by Elevate, where the reports will then be submitted to the US CBP.
• Elevate is also supporting FGV to calculate the reimbursement of recruitment fees for workers. Elevate has indicated to FGV that reimbursement of recruitment fees would be mandatory.
• FGV continues to be a member of the FLA, strengthening aspects of FGV’s labor practices. FLA’s Independent External Assessment Report, which details relevant findings and FGV’s corrective action plan, was published in August 2022 on FGV’s website.
• On the RSPO Complaints Panel’s decision, the RSPO Complaints Panel has lifted suspension of FGV’s Serting complex effective July 2022. FGV has begun the process of recertifying the complex. However, the Complaints Panel has indicated that other uncertified FGV complexes' certification process will be deferred until a summary of Elevate's findings are shared to the US CBP and confirmation is received of no evidence of labor violations.
• In August 2022, FGV responded to the Complaints Panel to seek clarification on the Complaints Panel’s directive, stating that Elevate's assessments are not based on Complaints Panel’s directives and should fall outside of the RSPO Complaints system.
• In October 2022, the Complaints Panel responded to FGV stating that while they are not bound to findings from the Elevate report, the Complaints Panel has the authority to consider findings from the report to determine their decisions moving forward.
• FGV will continue to focus on their initiatives to enhance their labor practices and ensure they are free from labor violations. (January 2023)

Issue Under Review: Alleged Operational and Financial Ownership Connection to Other Palm Companies

Grievance Entity: First Resources
November 24, 2023 - Status: Investigation

Cargill was contacted by The Gecko Project regarding their latest findings on First Resources' connection to three palm-oil companies: FAP Agri, Ciliandra Anky Abadi (CAA) and Sulaidy Group. This is the third time such allegations have been made regarding First Resources, since initial allegations were raised in 2018 and 2021.

Grievance Source: The Gecko Project (2023), Greenpeace (2018, 2021)

Actions Cargill Has Taken to Date:

• Upon being contacted by The Gecko Project prior to the full publication of their article, Cargill immediately engaged with First Resources and asked for a response. An in-person meeting was conducted, followed by email exchanges. (November 2023)

• During the meeting, First Resources reaffirmed their position that they are not in anyway connected to the three companies referenced by The Gecko Project. They noted that a similar allegation been investigated previously by the RSPO Complaints Panel. (November 2023)

• First Resources published their first statement in response to the full article by The Gecko Project. (November 2023)

• Cargill engaged with First Resources to seek on clarifications on their statement, in particular on the operational control allegations that were not addressed in the public statement. Cargill also encouraged First Resources to provide more granular feedback to The Gecko Project in addition to their public statement. (January 2024)

• First Resources shared their action plan with Cargill. The action plan includes the following:

  • Engaging a consultant with expertise in sustainability and stakeholder engagement to help them communicate updates and reinforce their sustainability strategy.

  • Seeking engagement with The Gecko Project to understand the allegations and explore resolutions.

  • Actively supporting the RSPO Secretariat and Complaints Panel in expediting its investigation into the allegations. (January 2024)

• First Resources publicly stated that they have now appointed Robertsbridge as their independent consultant. Through that engagement, we also have been informed that RSPO has issued a new statement in their tracker, confirming that RSPO has accepted the new allegations as part of the ongoing investigation. (March 2024)

• Cargill engaged with Robertsbridge to understand their scope of work. We understood that Robertsbridge will help First Resources in reviewing the evidence provided by The Gecko Project and previous grievance raisers through mapping out and reaching out to all internal and external stakeholders. Cargill will be in close contact with Robertsbridge in monitoring the case. During the process, regular updates may be provided by First Resources through their public website. (March 2024)

Issue Under Review: RSPO Complaint Case: Concerns Regarding Legality of Operations; Bribery Court Case in 2018

Grievance Entity: Aditunggal Mahajaya, Agrokarya Primalestari, Agrolestari Sentosa, Buana Adhitama, Binasawit Abadi Pratama, Buana Artha Sejahtera, Mitrakarya Agroindo, Tapian Nadenggan
April, 2020 – Status: Investigation

Cargill is aware of the concerns raised about GAR’s operations in Central Kalimantan and that FPP has filed an RSPO Complaint against GAR.

Grievance Source: Forest Peoples Programme (RSPO Complaint)

Actions Cargill Has Taken to Date

• GAR releases a press statement refuting FPP’s allegations and announced that it will write an official appeal to RSPO. For more information, refer to GAR’s statement. (March 2020)
• We have reached out to GAR for more information and understand GAR is preparing their appeal to RSPO. (April 2020)
• GAR submitted their appeal letter to the RSPO Complaints Panel. (7 April 2020)

Issue Under Review: Public accusations of: Human rights violations, Environmental degradation

Grievance Entity: Reforestadora de Palmas del Peten, S.A. (REPSA)
Investigation by local government agencies into possible legal violations

December 14, 2015 - Status: Monitoring Implementation

Grievance Source: Rainforest Action Network, CONDEG, Friends of the Earth

Actions Cargill Has Taken to Date

• Changed the terms of our contract with the supplier with a contingency clause for improving standards. (December 15, 2015)
• Declared that continued sourcing will be dependent upon monitoring and implementation of an action plan. (May 11, 2016)
• Issued a full statement on REPSA here. (June 3, 2016)
• Regular monitoring of REPSA’s  implementation plans continue. REPSA’s first progress update can be found here.
• Convened 90-day milestone meeting with REPSA management to review progress on action plan (September 2016)
• Required REPSA to expedite improvements to drinking water purification system available to field workers to be complete by October 2016.
• Collaborated with stakeholders to get REPSA to agree to participate in a community dialogue and consensus-building process to mitigate social conflict with stakeholders.
• As part of policy review and community input process, collaborated with REPSA and third parties to add FPIC principles to REPSA’s policy.
• Helped REPSA identify resources to conduct a labor audit of operations, and refine terms of reference, to be commenced by end of 2016.
• Scheduled next milestone meeting with REPSA management set for December.
• Cargill is monitoring REPSA's progress across the following outcomes:
  • Engaging CONDEG (grievance raiser) to reach a mutually-agreed upon resolution to the 2015 kidnapping incident
  • Reach a credible, mutually-agreed upon resolution to the November 2016 allegations of intimidation
  • Develop a Year 2 Action Plan that incorporates stakeholder input and has active stakeholder buy-in and support
  • Develop a detailed participatory roadmap, in consultation with local stakeholders, for advancing a broad stakeholder engagement process.
• Update on REPSA (Friday, November 24, 2017)

Effective immediately, Cargill is suspending business with Guatemalan palm oil supplier Reforestadora de Palmas del Petén, S.A (REPSA). The suspension is a result of REPSA’s failure to meet requirements associated with Cargill’s sustainable palm oil policy.

In August 2017, Cargill called on REPSA to meet four critical milestones in response to environmental and social grievances raised by a coalition of international and Guatemalan NGOs. REPSA had to demonstrate meaningful progress in order to continue its sourcing relationship with Cargill. The deadline for REPSA to meet the milestones was October 31, 2017.

Although REPSA made encouraging progress with the parties that raised these grievances and was actively seeking to foster trust with local communities and activists, it fell short on several key expectations.

As a result, Cargill is suspending business with REPSA. We will not enter into any new purchase contracts until REPSA can meet the requirements of our sustainable palm oil policy.

Cargill has agreed to reassess our business relationship with REPSA if the supplier demonstrates a renewed commitment to achieving our required sustainability milestones.

• Cargill affirms our commitment to uphold the principles of our Statement on Human Rights across our supply chain and we hold our suppliers accountable to respect and protect people and human rights. We also expect all our suppliers to act in good faith while engaged in our grievance procedure. We will not tolerate any form of retaliation towards internal or external stakeholders such as employees, local communities and activists, including retaliation resulting from decisions undertaken by Cargill through our grievance procedure. Actions of such nature will lead to the termination of business relationship. (December 20, 2017)
• After suspending commercial relations in November 2017, CARGILL agreed with REPSA on a re-engagement plan which covered milestones that the company had yet to demonstrate sufficient progress in. This is in line with Cargill’s transformation approach and commitment to support suppliers that have been suspended to demonstrate compliance via our grievance procedure. While monitoring and supporting REPSA’s implementation of the said action plan, we continue to engage external stakeholders, including local stakeholders to provide independent feedback on REPSA’s progress. In addition, we conducted a field visit to REPSA’s operations in November 2018 to evaluate the implementation of REPSA´s sustainability plan 2017-2018.

After a year of implementation of the re-enlistment action plan, REPSA has demonstrated its commitment to meet our milestones and deliver on its own sustainability plan. Cargill will keep working closely with REPSA to keep following up on its progress. (March 15, 2019)

On 26 January 2021, Cargill resumed business with Guatemalan Palm supplier Reforestadora Palmas del Petén S.A. (REPSA). In line with our grievance policy, Cargill asked for corrective actions to resume business with REPSA, among them:

• Implementation of a sustainability action plan aligned to all gaps found during field evaluations
• Deployment of a credible grievance process with a public platform to receive and update issues
• Creation of a roadmap for stakeholder engagement with a time bound action plan

We recognize REPSA has made notable progress in the implementation of its sustainability strategy and meaningful efforts to strengthen stakeholder engagement with grievance raisers and other stakeholders interested in their operation. REPSA has met the expectations of the Cargill grievance process to date and that is why the Grievance Panel has decided to lift suspension on commercial relations with REPSA.

Cargill will continue to monitor REPSA’s sustainability implementation plan through bimonthly progress reports and engage the company on key topics for the palm sector in Guatemala. If additional non-compliances are found, we will reopen the grievance process in line with our protocol. (January 2021)

REPSA participated in a pilot where Cargill and other stakeholders tested work voice platforms as monitoring tools for human rights risks. Conclusions of the pilot were integrated into REPSA's sustainability action plan. (March 2022)

Based on Cargill's latest engagement, here are different strategies that are being implemented by REPSA to strengthen its human rights strategy (2022 - 2023):

• Staff Training on Human Rights: REPSA implemented comprehensive training on human and labor rights, ensuring their staff (from management to frontline staff) have an advanced knowledge and awareness of these fundamental principles. (2022-2023)
• Collaboration on Forced Labor Assessment: In collaboration with third-party evaluators, REPSA is finalizing a Forced Labor Risk Assessment to identify and mitigate potential vulnerabilities in their work practices. (2023)
• Comprehensive Due Diligence: Partnering with external human rights experts, REPSA is implementing a Human Rights Due Diligence process, holistically covering aspects from labor rights, health and safety, community relationships and environmental impacts. (2023)
• Gender Action in Agriculture: REPSA is developing gender action plans in their palm operations. Similar initiatives are now being rolled out in their banana farms and refinery industries, emphasizing gender equality at every step. Cargill is financing activities that are part of this gender strategy. (2023)
• "Good Treatment" Employee Program: Working with HR specialists, REPSA launched a program focused on ensuring dignified and positive working conditions, fostering a culture of respect and well-being. (2023)
• Grievance Mechanism with GREPALMA: As part of REPSA's commitment to transparency and improvement, REPSA is participating in an assessment by Earthworm Foundation on their grievance mechanism, within the framework of GREPALMA's Social Excellence Project. This initiative is funded by Cargill. (2022-2023)
• Engaging in Impact Studies: REPSA conducted Social and Environmental Impact Studies in all their palm operations. Moreover, Impact Mitigation Plans have been co-developed with local stakeholders to ensure a community-driven approach. (2022-2023)
• Sustained Community Dialogue: Engaging local community leaders and representatives, REPSA has set up a permanent plan to ensure proactive and direct communication and engagement with key stakeholders. (2022-2023) (November 2023)

Issue Under Review: NGO accusation of: Labor rights violation

Grievance Entity: Industrias Chiqibul
September 11, 2018 - Status: Suspended

Grievance Source: CONDEG

Actions Cargill Has Taken to Date

• Cargill received a grievance report by CONDEG on labor violations in Chiqibul’s operations.
• Cargill officially submitted a letter to Chiqibul requesting for clarifications on the allegations.
• Cargill received Chiquibul’s clarifications and have followed-up with request for evidence and verification (August 24, 2018)
• We are now working with Chiquibul to identify suitable third-parties to conduct the required verification procedures and develop an action plan. (September 9, 2018)
• Effective as of March 1, 2019 Cargill is suspending business with Guatemalan palm oil supplier Industria Chiquibul S.A.

The decision to suspend is a result of Chiquibul’s failure to meet key milestones which had been agreed with the supplier via our grievance procedure. The milestones focused on closing gaps from a continuous improvement plan that was developed after Cargill conducted a proactive field assessment of the supplier back in June 2017. The assessment was aimed at verifying compliance of Cargill’s sustainable palm oil policy in Chiquibul´s operations.

The deadline for Chiquibul to demonstrate meaningful progress against the above action plan was January 2019. Among the prioritized actions pending in the plan was an independent labour audit; a milestone that was key to closing a specific grievance raised against the Company by CONDEG via Cargill’s grievance procedure relating to labor rights violations.

Throughout the process of engagement, Cargill closely monitored progress by Chiquibul on the agreed actions. Although the company made progress in policy and procedure definitions, it fell short on key expectations included in the plan, including carrying out the independent labor verification.

As a result, Cargill is suspending business with Chiquibul, which means the company will not enter into any new purchase contracts until Chiquibul can meet the requirements of our sustainable palm oil policy. Re-engagement discussions are dependent on Chiquibul first closing the major non-conformities from the December 2017 action plan, which has to be independently verified. (March 11, 2019)

Issue Under Review: RSPO Complaint Case: Community land conflict at IOI Pelita

Grievance Entity: IOI Pelita
July, 2016 - Status: Implementation of action plan

Grievance Source: RSPO Complaints

Actions Cargill Has Taken to Date

• IOI is engaged through the RSPO Complaints System and is committed to working through an implementation plan that is agreed with the community. The company is publicly providing updates on its grievance log. Additional updates can also be found on the RSPO complaints tracker.
• IOI received conditional endorsement from RSPO Complaints Panel on the resolution plan. A resolution plan socialization visit was conducted in July 2018 together with NGO and RSPO representatives. Please refer to IOI's statement for further details.
• The resolution plan has been accepted by all 9 communities. Cargill continues to monitor progress of the work plan through IOI's grievance updates and RSPO Complaints tracker. (July 19, 2019)

Issue Under Review: Social Non-Compliance

Grievance Entity: IOI Corporation Berhad
June 25, 2021 - Status: Investigation

Cargill is aware of the reporting that IOI is under investigation by the United States Customs and Border Protection (CBP) for allegations of forced labor in Malaysia. Cargill does not tolerate human trafficking, forced labor or child labor in our operations or supply chains.

Grievance Source: Andy Hall, Migrant Worker and Labor Rights Activist

Actions Cargill Has Taken to Date

• Cargill contacted IOI immediately to request for more information. IOI shared that they have not been contacted by CBP so far regarding an investigation. IOI’s full statement can also be found on their website. (June 2021)
• IOI have confirmed they have engaged the grievance raiser - Andy Hall, Migrant Worker and Labor Rights Activist - on the allegations. IOI shared with Cargill that they are taking corrective actions to address the issues raised. This information has been published on IOI’s grievance dashboard.
• Cargill will continue monitoring and engage with IOI on their progress. (July 2021)

Issue Under Review: Alleged Social Non-Compliance

Grievance Entity: PT Erasakti Wiraforestama 1, 2 and 3
February 2023 - Status: Case Closed

Grievance Source: Cash Investigations

Cargill received a report from customer raising allegations related to PT Erasakti Wiraforestama 1, 2 and 3 (PT EWF) on potential child labour practices in their plantation in Jambi. The allegation was made by Cash Investigations, a French investigative journalism TV programme that showed a footage of children working in plantations and handling chemicals (herbicides). The footage allegedly showed 13 and 15 years old girls using herbicides in plantations and 9 – 10 years old children working with their parents on plantations.

Actions Cargill Has Taken to Date

• Cargill has reached out to our direct supplier on this case.
• We received the following feedback and evidence through our direct supplier:
  • On November 7th, 2022, labour inspectors (from the National Labour Agency) went for a site visit to investigate the child labour allegations in PT Erasakti Wiraforestama plantations.
  • The inspectors verified that: PT EWF conducts routine inspections/patrols of their sites and has a regulation that prohibits children (below 18 years old) to be present on the working sites and also prohibits them from being employed by the company.
  • PT EWF has provided full safety equipment for pesticide spraying, which includes helm, goggles, masks, boots, gloves, and apron to all workers. Inspections of the equipment are always done by a supervisor before any spraying activities are conducted.
  • Worker’s recruitment process requires copy of national ID, which tells the applicant’s age. The minimum age accepted by the company is 18 years old according to PT EWF’s procedure and regulation (they have a specific regulation that prohibits child labour).
  • After showing the documenter video from Cash France 2 TV (20 Oct 2022) to the site workers, they did not recognize the location, people on the video, or the uniforms. The uniform and standard tools for spraying differ from those the workers use on the PT Erasakti Wiraforestama plantations.
  • Staff responsible for spraying activities consist of 6 people, with all above 40 years old.
• Following review from Jambi’s National Labour Agency (Dinas Tenaga Kerja dan Tansmigrasi), we deemed the case to be closed. (July 2023)

Issue Under Review: Deforestation

Grievance Entity: Ladang Bukit Bandi
September 2020 – Status: Monitoring Implementation

Grievance Source: Internal Monitoring

Actions Cargill Has Taken to Date

• Cargill visited Ladang Rakyat Trengganu’s concession on 14 September 2020 as part of our proactive supplier engagement, and identified land clearing in a HCV area. Cargill communicated the severity of the land clearing and required LRT to implement an immediate stop work order and develop a remediation plan as conditions for continued sourcing.
• Ladang Rakyat Trengganu issued a Stop Work Order effective 21 September 2020. Ladang Rakyat Trengganu shared with Cargill their timebound remediation plan for the 4.34ha cleared, which includes commitments to:
  • Uproot seedlings that were replanted
  • Planting white acacia trees and various species of forest trees
  • Setting the boundary between the HCV area and planted area to prevent any activities in HCV area
  • Developing an updated NDPE Policy
  • Conducting an NDPE briefing session for suppliers
  • Attending a program with Earthworm Foundation on supply chain monitoring and the Labor Transformation Program
  • Ensure there is an action plan to protect all HCV areas identified in other concession areas
• As part of the remediation plan, Ladang Rakyat Trengganu has uprooted all oil palm trees in the cleared HCV area and built a cement pole fence separating the HCV area from the planted area.
• Cargill will continue to monitor the implementation of LRT’s remediation plan. The next verification visit has been scheduled for mid-October 2020. (September 2020)
• Cargill continues to engage Ladang Rakyat Trengganu on their timebound remediation plan, including initiating the Labor Transformation Program and No-Deforestation Supply Chain Monitoring Program for LRT, supported by Earthworm Foundation.
• In January and July 2022, Cargill visited LRT to review LRT’s progress on their HCV management. The HCV areas that were previously cleared are in the process of rehabilitation, where LRT has demarcated and planted the area with various tree species. Together with Earthworm Foundation, a HCV training was also conducted for LRT’s management team as part of capacity building. The training covered the importance and types of HCV management and conservation.
• Cargill will continue monitoring LRT’s progress related to their HCV management and remediation plan. (October 2022)

Issue Under Review: Alleged Environmental Non-Compliance

Grievance Entity: Multipersada Gatramegah
December 2021 - Status: Case Closed

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill engaged Musim Mas on the alleged clearing of a HCS area. Musim Mas had conducted HCV and HCS assessments in 2018, where the findings showed that the area in question is neither HCV nor HCS area. The October 2020 integrated HCV/HCSA Assessment conducted only covered PT Multipersada Gatramegah's extension area as the existing area had already been assessed in 2018. Accurate maps of areas outside of the extension can be referred to in the HCS Report of PT Multipersada Gatramegah in 2018 (Figure 21 - Final HCS Map). EQ had also assessed the area alleged by Mighty Earth and came to the same conclusion. Further inspection by EQ showed that the area displayed qualities more consistent with scrub forest that is outside of the HCS threshold.
• Based on the evidence provided by Musim Mas, Cargill considers the case as closed. (January 2022)

Issue Under Review: Alleged Land Conflict

Grievance Entity: Naturaceites

January 2024 - Status: Monitoring Implementation

Cargill is aware of the allegations made against Naturaceites that have surfaced in various German media outlets. These concerns, notably highlighted in reports such as "In the shadow of the oil palm" by the Christian Initiative Romero (CIR), as well as grievances published by Foodwatch and the European Council for Constitutional and Human Rights (ECCHR), have prompted us to take immediate and transparent actions.

Grievance Source: Christian Initiative Romero, Foodwatch and European Council for Constitutional and Human Rights

Actions Cargill Has Taken to Date:

• Cargill has supported Naturaceites in collaborating with the Earthworm Foundation (EF) to enhance their grievance mechanism. This partnership aims to create a more transparent and responsive system to address concerns from NGOs and other stakeholders. The project was implemented during a period of 6 months from November 2023 to April 2024.
• The project has produced a comprehensive set of recommendations to develop a more transparent and responsive system to address any concerns raised by NGOs and other stakeholders effectively. (April 2024)
• Cargill is supporting the implementation of a robust action plan for Naturaceites beginning in Q3 2024, with the continued backing of the Earthworm Foundation. This initiative aims to address key concerns and ensure effective management of community conflicts, land issues, and environmental impacts. Additionally, the plan includes implementing recommendations to enhance Naturaceites' grievance mechanism. (May 2024)
• We are closely monitoring the development of the situation and maintain active engagement with Naturaceites to ensure compliance with our sustainability and human rights policies. (May 2024)
• During June and July 2024, Cargill has continued to work closely with Naturaceites and EF to further strengthen the action plan which is set to be implemented in Q3 2024 (August-September). This comprehensive action plan has three phases which will focus on gaining a deep understanding of the situation, establishing communication channels, and implementing actions to mitigate the risk of future conflicts related to land tenure, community conflicts, and environmental impacts. We have received valuable feedback from Naturaceites to reinforce some of the initiatives they are already implementing and incorporate them into the grievance action plan. (July 2024)

Issue Under Review: Environmental Non-Compliance

Grievance Entity: Palmeras del Llano S.A.

March 2021 - Status: Monitoring Implementation

Grievance Source: Internal Monitoring

During an evaluation visit that took place in 2019, Cargill identified environmental non-compliances in the mill’s operations. Following the visit, an action plan was developed alongside Palmeras del Llano to close gaps over a period of 2 years. Frequent follow ups were conducted with the sustainability team of the mill. In March 2021, after an evaluation of the mill’s progress, it was concluded that urgent environmental non compliances related to effluents of the mill are yet to be closed.

Actions Cargill Has Taken to Date:

• Cargill engaged with the mill and informed that the process had been moved to the grievance system, due to slow progress and that critical environmental non-compliances continued to be identified at the mill.
• The mill communicated that resources were now available to undertake the improvements required by Cargill. Dates of the action plan will be adjusted to the investment plan, according to priorities defined jointly. (April 2021)
• Cargill conducted a verification visit in November to confirm progress informed during action plan follow up sessions. Cargill verified that Palmeras Del Llano has made progress in resolving the environmental non-compliances, through actions agreed with the company. For instance, adjustments to the effluents system of the mill are in progress to be finalized. According to this, the follow up process will continue as planned. (March 2022)

Issue Under Review: Non-compliant sourcing from PT Kallista Alam

June 12, 2020 - Status: Monitoring Implementation

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Prior to RAN's report, Cargill and Permata had aligned on the need to prioritize engagement with Permata’s Aceh suppliers. Cargill traditionally does not source from Permata in Belawan, hence our exposure and engagement in Leuser has usually been with our other direct suppliers. Nonetheless, Permata is a supplier of Cargill and we are committed to ensuring Permata's entire supply chain is NDPE compliant.
• Cargill reached out to Permata to enquire about the allegations raised by RAN and reaffirmed our no-buy position on PT Kallista Alam. Permata has acknowledged the allegations and regrets that there has been a lapse in their mill disclosure process and ensuring that their no-buy list issued by sustainability is acted upon by procurement teams. Permata has committed to the following:
  • Immediately ceased all sourcing with PT Kallista Alam as of 10th June 2020
  • Commence investigation into standard operating procedures that resulted in the lapse, following which to update their public mill lists to reflect any new mills which were not declared
  • Share with Cargill Permata's no-buy list to ensure no suspended suppliers are missed out
  • Issue a public statement on Permata’s website.
• Cargill has been investing significant resources to support Permata Hijau Group's NDPE implementation, together with support from Proforest and Daemeter. This led to Permata publishing a sustainability dashboard in April 2020, which includes a mill list and a grievance log. Permata has also made progress in implementing NDPE practices within their supply chain, including the following:
  • Committed to an NDPE implementation plan for Permata’s supply chain which covers traceability, supplier engagement and monitoring and grievance management
  • Co-hosted an NDPE supplier workshop with Cargill in March 2020
  • Implementing a supplier code of conduct and currently rolling out supplier self-assessment questionnaire
  • Accelerate collection of traceability to plantation data
• Cargill will continue to follow-up with Permata to ensure that they follow through on their committed actions. Verification of mill lists are a critical component in transparency and we will accelerate efforts to ensure our suppliers are reporting accurate information. (June 2020)
• Cargill is aware that that RAN released a second report detailing that Permata was sourcing from PT Surya Panen Subur II.
• Prior to the release of RAN’s second report, Cargill had already been working closely with Permata to review their mill list, no-buy list, traceability process and acceleration of supplier engagement action plans. Following Permata’s public communication of their committed actions and no-buy position PT Kallista Alam, Permata immediately launched an internal investigation and found a number mills that were not included in their traceability records due to internal process gaps. This included PT Surya Panen Subur II, of which Permata immediately issued a suspension on 22nd June and communicated the suspension to PT SPS II and Cargill.
• Permata has been responsive and are making changes to their operations. Permata is in the process of updating their mill list based on their investigation findings and will reflect the new mill list on their website.
• We remain committed to working with Permata on their engagement with mills in the landscape as well as accelerating progress for their other refineries, beginning with traceability and supplier assessments for high risk mills. Cargill will continue to follow-up with Permata to ensure that they remain accountable to their committed actions.
• Cargill maintains our no-buy position on PT SPS II. Cargill continues to affirm the importance of ensuring compliant sourcing, especially from mills in proximity to critical areas such as the Leuser ecosystem. (July 2020)
• Cargill has been regularly following up with Permata on its supplier engagement and traceability. Permata shared with Cargill their updated mill list and no-buy list. Cargill will continue monitoring Permata’s sustainability implementation. (November 2020)

Issue Under Review: Media report: Deforestation by Bewani Oil Palms in PNG, alleged to be associated with Prosper Group (Malaysia)

Grievance Entity: Bewani Oil Palms
October, 2016 - Status: Case Closed

Grievance Source: Intel from implementation partner

Actions Cargill Has Taken to Date

• Cargill has on several occasions raised the concern of alleged association of Prosper to Bewani Oil Palms in PNG. Prosper denies any form of association, stating that Bewani is an investment by its minority shareholder with no commercial links to the Group. We have requested for written acknowledgment that Prosper is not commercially linked to Bewani and Prosper will not market any of Bewani's products.
• Following further evidence linking Prosper Group to Bewani Oil Palms through association by common shareholding, Cargill made the decision to suspend commercial relationship with Prosper Group. We acknowledge the divestment by its shareholder from Bewani Oil Palms, however due to the extensive deforestation which took place while the group remained associated to the company, we expect Prosper Group to demonstrate adequate remediation efforts.
• On 7 May 2021, Cargill resumed business with Malaysian palm supplier Prosper Palm Oil Mill Sdn Bhd (Prosper) as the company has committed to taking action to close the gaps needed to comply with Cargill’s Sustainable Palm Oil Policy. The main commitments made by Prosper include:
  • Adopting an NDPE sustainable Palm Oil Policy for its entire operations.
  • Initiating a recovery plan with a partnership with Global Environment Centre (GEC), to recover a portion of the North Selangor Peat Swamp Forest (NSPSF) in Selangor State, Malaysia.
  • Making a written commitment to a time-bound remediation plan that will compensate the full scope of approximately 10,000 hectares of NSPSF due to past deforestation at Bewani Oil Palms.
• Cargill recognizes that Prosper has made notable progress in the implementation of its sustainability strategy and recovery plan and has shown meaningful initiatives to strengthen engagement with stakeholders, including its suppliers on grievances and remediation. This is the reason why the Palm Grievance Panel has decided to lift the suspension on commercial relations with Prosper.
• Cargill will continue to follow up on Proper’s progress through quarterly sustainability progress reports and engage with them to maintain compliance with Cargill’s Sustainable Palm Oil Policy. If additional non-compliances are found, we will reopen the grievance process in line with our protocol. (May 2021)

Issue Under Review: Deforestation

Grievance Entity: Sabajau Estate
August 26, 2019 - Status: Investigation

Grievance Source: Customer enquiry

Actions Cargill Has Taken to Date

• Cargill was informed of potential clearing in SOP's Sabajau estate. We immediately investigated the matter with SOP. (August 26, 2019)
• SOP denied involvment in the clearing and provided document evidence demonstrating that the last clearing was in October 2016. SOP believes clearing was carried out by native community. Cargill has requested for further field verification on the matter. (September 6, 2019)

Issue Under Review: NGO report: Development on peat by Shin Yang Group (alleged to be a beneficial owner of SOP)

Grievance Entity: Shin Yang Group (Linau Mewah), Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD), Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum LD)
March 11, 2019 - Status: Investigation

Clearing by Shin Yang Group who is alleged to be linked to SOP.

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill immediately engaged SOP and enquired on the ownership structure between the company and Shin Yang Plantations. SOP maintains independent management and decision-making between the two entities. We are reviewing the evidence presented by the company.
• While this process is ongoing, SOP has commenced discussion with Shin Yang on the allegations of peat soil in Belaga area as preliminary studies identify the area as mineral soil, with no peat in the region. (March 26, 2019)
• Cargill is engaging SOP on other alleged land clearings in Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD) and Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum LD) as reported by Mighty Earth (May 2020)

Issue Under Review: Forced Labor and Child Labor

Grievance Entity: Sime Darby Plantations (Malaysia)

July 2020 - Status: Case Closed

Grievance Source: Liberty Shared

Actions Cargill Has Taken to Date

• Cargill is aware of the petition summary released by Liberty Shared against Sime Darby Plantation Berhad regarding allegations of forced labor and child labor in Sime Darby’s operations. The petition was also submitted to the United State Customs and Border Protection (CBP). (July 2020)
• Sime Darby released a statement responding to the petition by Liberty Shared for the US CBP. Sime Darby will reach out to Liberty Shared for clarification on the allegations and commence investigation. (8 July 2020)
• Sime Darby released a second statement on the petition and allegations raised by Liberty Shared. Sime Darby has reached out to Liberty Shared for more information on the allegations. Sime Darby also issued details on its response to the statements made by Liberty Shared based on Sime Darby’s current practices. The full statement can be found here. (10 July 2020)
• Sime Darby released a third statement in response to the petition and the latest statement by Liberty Shared. Sime Darby has not received full details on the allegations raised by Liberty Shared. Sime Darby reiterated its commitment to respecting human rights and zero tolerance for bribery and corruption. The full statement can be found here. (7 August 2020)
• Sime Darby has appointed PricewaterhouseCoopers (PwC) to support Sime Darby in strengthening the implementation of their Human Rights commitment in Sime Darby’s Malaysia operations. Sime Darby will continue taking action as necessary to ensure labor rights, especially migrant workers’ rights, are respected. The full statement can be found here. (10 November 2020)
• Cargill is aware that The Associated Press (AP) released an article reporting allegations of abuse of women in Sime Darby’s plantations. (18 November 2020)
• Sime Darby released a statement in response to AP’s article. Sime Darby will investigate the allegations raised by AP and share its progress in the investigations. Sime Darby reiterates zero tolerance to any forms of sexual or human rights violations, exploitation or other criminal offences and will continue to ensure the safety and well-being of its workforce. Sime Darby also encourages employees or stakeholders to report grievances to Sime Darby via its Whistleblowing channels. (19 November 2020)
• Sime Darby concluded its investigations regarding the allegations raised by AP. Sime Darby is taking the necessary steps to strengthen its processes. Refer to Sime Darby’s full statement for more information. (3 December 2020)
• The United States Customs and Border Protection (CBP) issued its Withhold Release Order to detain all imports into the United States that consist of Malaysian palm oil and palm products produced by Sime Darby, its subsidiaries and joint ventures. The CBP stated it has “information that reasonably indicates the presence of all 11 of the International Labour Organization’s forced labor indicators” in Sime Darby’s operations. We have taken immediate action to ensure compliance with CBP’s Withhold Release Order against Sime Darby. (30 December 2020)
• Sime Darby released a statement regarding the US CBP’s Withhold Release Order. Sime Darby seeks to meaningfully address the allegations and looks forward to receiving pertinent information and working with CBP to resolve the issue. Sime Darby will also continue engagement with Liberty Shared and other organizations to gather information on the allegation. Sime Darby reiterates its commitment to protecting workers’ rights and combatting forced labor. (31 December 2020)
• Cargill does not tolerate human trafficking, forced labor or child labor in our operations or supply chains. We support the UN Sustainable Development Goals’ ambitions to promote decent work for all around the world and across the supply chains in which we operate. We are working to further assess this issue globally in compliance with our policies. Cargill’s import of palm oil and palm products into the U.S. will not be directly sourced from Sime Darby Malaysia. While we continue our assessment of the allegations against Sime Darby for our global supply chain, we have taken immediate action to ensure compliance with the CBP’s December 30 order. (4 January 2021)
• Cargill has spoken to Sime Darby regarding their investigation of the allegations raised. Sime Darby shared that their independent auditor, Impactt, had been conducting remote interviews but on-site assessments were delayed because of movement restriction orders related to the COVID-19 pandemic. Impactt will complete its independent report for publication in March 2022. Cargill continues to monitor progress by Sime Darby. (January 2022)
• Sime Darby has informed Cargill that the US CBP's has converted the Withhold Release Order into a "Finding". Sime Darby has released a statement in response to the notice and they will engage with the US CBP accordingly. Refer to Sime Darby's full statement here. (January 2022)
• On February 15, 2022, Sime Darby Plantation Berhad (SDP)  issued a press release in which it announced what it calls “sweeping changes in governance and operations” intended to address the gaps Impactt has identified. We consulted SDP on these measures and, once again, urged them to share as much information as possible with us so that we can assess if the issues the CBP identified have been addressed and are being remediated. While we believe the actions described by SDP are very constructive and potentially transformative, we need additional information to be able to verify if the actions SDP is taking meet the requirements set out in Cargill’s Policy on Sustainable Palm Oil. As we currently do not have this information, Cargill decided to suspend all new sourcing of palm oil and derivative products from SDP operations in Malaysia. Crude palm oil futures contracts traded on Bursa Malaysia Derivatives are not impacted.  Cargill will review this decision when the independent report by Impactt is published, which is expected to happen at the end of March 2022. In the meantime, we also continue to ensure compliance with the CBP requirements. (March 2022)
• On February 13, 2023, Cargill’s Palm Grievance Panel has made a decision to resume business with Sime Darby Plantation Berhad (SDP) with immediate effect, following the decision by the United States Customs and Border Protection (CBP) to allow SDP palm oil and derivative products into the U.S. and confirming that SDP had addressed its forced labor concerns. Cargill concludes that satisfactory evidence has been presented to the CBP demonstrating that SDP does not use forced labor to produce palm oil and derivative products. Cargill follows the CBP decision by lifting the suspension, as this means SDP meets Cargill’s requirements as set out in our Policy on Sustainable Palm Oil. According to the CBP, the agency does not modify its decisions until the agency has evidence demonstrating that “the subject merchandise is no longer produced, manufactured, or mined using forced labor”. (February 2023)

Issue Under Review: Labor Rights

Grievance Entity: Agro Kati Lama

October 5, 2020 - Status: Investigation

Grievance Source: Customer

Actions Cargill Has Taken to Date

• Cargill reached out to SIPEF for clarification on the allegations raised in Transnational Palm Oil Labour Solidarity’s article (TPOLS). SIPEF stated that the allegations were originally raised in 2017 by 11.11.11 and Sawit Watch. SIPEF had been engaging with both parties to address the gaps. SIPEF was then contacted by TPOLS in February 2020 and had been communicating with TPOLS before TPOLS published its article. Refer to SIPEF’s Grievance Dashboard for more details on their actions and engagement.
• SIPEF released a statement detailing the actions taken regarding labor standards in Indonesia. SIPEF will engage a third party to investigate the allegations by TPOLS and provide recommended actions for SIPEF. Cargill will continue monitoring for updates. (November 2020)

Issue Under Review: Deforestation

Grievance Entity: Agro Muara Rupit

January 2021 - Status: Verification

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill is aware of the allegations raised against Agro Muara Rupit that an integrated HCV-HCS Assessment was not conducted prior to the company's land development.
• Upon investigation, Cargill understands that Agro Muara Rupit has completed its HCS Assessments and peer review is ongoing. Agro Muara Rupit also completed its HCV Assessment in 2014. Cargill has reviewed SIPEF's statement and will follow up with SIPEF accordingly. Details can be found on SIPEF's Grievance Dashboard and the HCSA website. (February 2021)
• Cargill spoke with SIPEF to understand more about the allegations. SIPEF shared that the HCSA Peer Review has been completed for PT AMR 1 & 2. The report findings show that the area cleared was predominantly rubber. Details can be found on HCSA's website. Cargill will continue monitoring and engagement with SIPEF. (March 2021)

Issue Under Review: RSPO Complaint Case: Community land conflict in PT Permata Hijau Pasaman

Grievance Entity: PT Permata Hijau Pasaman 
February 8, 2017 - Status: Case Closed

Grievance Source: RSPO Complaints

Actions Cargill Has Taken to Date

• Cargill engaged Wilmar on the progress of the RSPO case and the agreed action plan. Due to the agreed MoU between parties, external communication can only be made by RSPO and facilitator. As such, please refer to the RSPO complaints tracker for details. Wilmar has provided Cargill with the status of activities and is committed to complying with decisions made through the RSPO complaints system.
• The RSPO Complaints Panel has closed the grievance. As such Cargill considers the case as closed. (September 2018)

Issue Under Review: Public accusation of Labor rights exploitation in Wilmar subsidiaries 

Grievances Entity: PT Perkebunan Milano and PT Daya Labuhan Indah
November, 2016 - Case Closed

Grievance Source: Amnesty International
Read more here.

Actions Cargill Has Taken to Date

• Cargill engaged Wilmar on the reports and requested for Wilmar to share detailed action plans relating to the allegations. Cargill acknowledges Wilmar's detailed response through its grievance log and collaboration with BSR to assess the linked concessions. Wilmar has committed to transparently report all findings and action plans in relation to the allegations. Cargill will hold Wilmar accountable to its commitments.
• Wilmar has partnered with Verite to help develop and implement a comprehensive labour programme
• Wilmar's action plan can be found here.
• Verité conducted a verification audit in February 2020 to verify the progress made by Wilmar. Verité shared their findings to Wilmar and identified further opportunities for improvement. Verite’s review of Wilmar's action plan progress can also be found here.
• Given Wilmar's significant progress in implementing their 3-year action plan, Cargill considers the case as closed. (December 2020)

Issue Under Review: Deforestation

Grievance Entity: Mentiga Corporation Bhd (Area A & B); Amanah Saham Pahang Berabong Estate 
August 2020 – Status: Investigation

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date:

• Plantations belonging to Amanah Saham Pahang are alleged to have deforestation, and that mills in our supply chain are allegedly sourcing FFB from Amanah Saham Pahang. We are investigating either directly or indirectly with our suppliers on these allegations. (August 2020)
• Amanah Saham Pahang has an NDPE Policy. Amanah Saham Pahang has also committed to a moratorium on new planting. Amanah Saham Pahang met with Global Environment Center in September 2020 to discuss a potential recovery plan. Details can be found here. (October 2020)

Direct Trading Partner: Wilmar, Musim Mas

Issue Under Review: Deforestation

Grievance Entity: Kahayan Agro Plantation
November, 2017 - Status: Implementing action plan

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill initiated engagement with our direct suppliers upon receipt of Mighty Earth's Rapid Response Report 1. We continued to get updates on the engagements and was informed that AEP committed to a moratorium pending assessments at PT Kahayan Agro Plantation (KAP).
• PT Meganesia Tirta Foresta has been appointed to conduct a HCS study at PT KAP. More details can be found here.(May 2018)
• Cargill understands the assessment report will be ready in September 2018.
• Cargill learnt of potential new clearing and are engaging our direct suppliers for clarification. We understand AEP has submitted their PT KAP HCS report to the HCS Secretariat for review. (25 March 2019)
• Cargill received updates from our direct suppliers as follows:
  • Land clearing of about 0.3ha in HCV area was due to a GPS error on the ground.
  • Land clearing of about 0.5ha around riparian zone due to gold mining activities by local communities.
• AEP has committed to rehabilitating these areas and will take steps to prevent future incidents. (15 April 2019)
• AEP issued a stop work order beginning May 27, 2019 pending HCSA peer review.
  AEP has officially published their NDPE policy. (July 19, 2019)
• On 9 December 2019, the HCSA peer review process of PT KAP was completed and published on HCSA’s website as an official notification of the completion of the peer review. Since AEP addressed the concerns received during the peer review process, the results were accepted and the stop work order that the company had put in place since 2018 was lifted allowing the development of plasma smallholder area.
• In January, land clearing was reported by Mighty Earth. AEP was notified that a second peer review was conducted due to an interpretation error during the 1st review. The clearing identified by Mighty Earth was reclassified to be conserved during the second review. This clearing is in an area allocated for plasma smallholder development.
• On 27 February 2020, AEP conducted a re-negotiation with the plasma smallholders and local government regarding the recommendation by HCSA to relocate the plasma area. Local stakeholders expressed strong disappointment with the HCSA process and stated that they will not accept any further stop work orders and/or relocation of their development area.
• GAR, our direct supplier linking us to AEP and who is also a HCSA member, has been attempting to broker discussion between AEP, HCS and Mighty Earth. We have been engaging with GAR for updates on the grievance where possible.
• PT KAP has agreed to the HCSA Secretariat recommendation for a moratorium covering the disputed area. PT KAP has also completed its ground truthing process and will discuss the findings with the HCSA Secretariat. (May 2020)

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: Sumur Pandanwangi 
March 2019 - Status: Suspended

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill was previously impacted by other direct suppliers in the last quarter all of whom have suspended the company. In our Q4 2018 mill list, we identified we were now impacted through our sourcing with PHG and are engaging them on the grievance. (March 25, 2019)
• Supplier is no longer in our supply chain. Cargill adopts a no buy position on the company.

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity:  PT Permata Putera Mandiri and PT Permata Mununggal Perkasa
September 9, 2016 - Status: Case Closed

Grievance Source: Multiple Sources

Actions Cargill Has Taken to Date

• Cargill reached out to KLK and was notified of KLK’s suspension of ANJ in October 2016. This effectively removed ANJ from Cargill’s supply chain.
• KLK continues engagement with ANJ to strengthen sustainability with ANJ’s senior management. Cargill continues to receive updates from KLK on the engagements and supports KLK’s request for ANJ to commit to a sustainability implementation plan. (March 2017)
• Cargill adopted a "no-buy" position to ANJ in October 2016. However in the last quarter, traceability data indicated ANJ's presence in our supply chain via our direct supplier PHS. PHS is only sourcing from ANJ's RSPO certified operations. We immediately engaged PHS and are in discussions with them to remove ANJ from our supply chain. (May 2018)
• PHG has removed ANJ from Cargill's supply chain. Cargill is supporting our direct supplier's engagement with ANJ on re-engagement milestones.
• Cargill has been engaging with ANJ directly since the suspension. ANJ has shared information and updated us on several measures taken for remediation, including the following actions:
  • Committing to a group wide moratorium on new clearing.
  • Developing an NDPE Implementation Standard Operating Procedure.
  • Concession map monitoring through the RSPO (Roundtable on Sustainable Palm Oil).
  • Demonstration of progress through publishing reports, including ANJ's Second Progress Report on their Group Recovery Site.
• In light of the notable progress made by ANJ, Cargill’s Palm Grievance Panel has decided to lift the suspension of ANJ effective 14 February 2022. As part of the reinstatement criteria, ANJ will undergo Cargill’s due diligence process to determine ANJ’s alignment with Cargill’s Policy on Sustainable Palm Oil. If additional non-compliances are found, we will reopen the grievance process in line with our protocol. (April 2022)

Direct Trading Partner: GAR, Fuji

Issue Under Review: Community Conflict

Grievance Entity: PT Dua Perkasa Lestari
August 2020 – Status: Investigation

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Cargill is indirectly connected to Beurata Subur Persada. Cargill has contacted our direct supplier for more information on the allegations. Our direct supplier released a statement on their engagement with PT DPL. GAR has commenced investigations on the community grievance. GAR has been engaging with Beurata Subur Persada and PT DPL on no-deforestation since 2017. PT DPL issued a moratorium in February 2020 and GAR has not detected land clearing by PT DPL. (August 2020)

Direct Trading Partner: Apical

Issue Under Review: Deforestation

Grievance Entity: PT Laot Bangko
July 2019 - Status: Suspended

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Cargill was alerted to deforestation allegations through RAN's Leuser Watch platform of PT Laot Bangko. We do not source from the concession but are impacted indirectly through Apical's sourcing from PT MJSL which is part of the same group. Following a series of unsatisfactory engagement with PT MJSL and the parent group Bima Golden Powerindo, Apical confirmed the decision to cease sourcing on September 19. (September 2019)

Trading Partner: Musim Mas, Wilmar, Yanzhou Guoji, Shanghai Hefeng, Olam, Zhejiang Sibang, Fuji, AAK, ADM

Issue Under Review: Alleged Environmental Non-Compliance

Grievance Entity: Bumi Sawindo Permai
August 2021 - Status: Investigation

Grievance Entity: Mighty Earth

Actions Cargill Has Taken to Date:

• Cargill has reached out to our direct supplier for more information. Our direct supplier has engaged Bumi Sawindo Permai and is investigating the allegation raised. (September 2021)

Direct Trading Partner: Golden Agri-Resources, Wilmar, Musim Mas, LDC, Marvesa Oil & Fats, Vandemoortele, JSC "NMGK"

Issue Under Review: Land Conflict

Grievance Entity: PT Artha Prigel
April 23, 2020 - Status: Developing Action Plan
Grievance Source: Customer

Actions Cargill Has Taken to Date

• Cargill has reached out to our direct suppliers to better understand the various chronology of events. Our direct supplier also released a statement on their ongoing investigations.
• From our direct suppliers, we understand that PT AP has attempted remediation, including looking into the provision of compensation for the victims' families. We also understand that there were indications of aggression from the village community. A police report was lodged by PT AP and the suspect has been detained as part of the investigation. PT AP has temporarily stopped activities in the disputed area until legal authorities have a resolution.
• Our direct supplier's site visit to PT AP has also been delayed due to the lockdown by the Indonesian government in light of COVID-19. Cargill affirms the necessity of on-ground verification to investigate whether the incident was symptomatic of historic land conflict between PT AP and the village community which only resurfaced recently.
• Due to differences in narratives amongst our direct suppliers and from media reports, Cargill believes it is best to rely on the authorities' independent investigations while ensuring that our direct suppliers remain transparent in their processes. While authorities and court are investigating the case, Cargill will request for our direct suppliers to ensure that BBIP does not create further situations that may allow for intimidation or harassment. BBIP should also remain transparent and cooperate with legal authorities to abide to the law.
• Cargill has specific commitments pertaining to zero toleration of intimidation and violence These commitments also apply to our suppliers. Read our NDPE Policy for more information. (May 2020)
• Due to the need for further investigation, our direct supplier commissioned a 3rd-party assessment related to the allegations.
• Upon completion of the field assessment, findings showed that PT AP fulfilled legal requirements pertaining to the land use. Regarding the fatality, the court ruled that the security officer of PT AP had acted in self-defense inside the palm plantation area and has been sentenced for his resulting actions that led to the fatality. PT AP had committed to support the victims' families. PT AP had also conducted mediation sessions.
• Our direct supplier continues to engage PT AP on NDPE and has proposed actions PT AP can take to prevent similar situations from occurring in its operations. PT AP will also continue the suspension of activities in the disputed area until a resolution is found.
• Cargill will continue to monitor our direct supplier's engagement with PT AP. For more information refer to our supplier's grievance dashboard. (June 2021)

Trading Partner: GAR, Mewah, Musim Mas, Wilmar, Fuji, AAK, AAA

Issue Under Review: Deforestation

Grievance Entity: PT Sejahtera Sawit Lestari, PT Guntajaya Harapan Lestari and PT Lestari Gemilang Intisawit
September 2018 - Status: Implementing Action Plan

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• Cargill engaged our direct suppliers on the various allegations raised. Bumitama's statement can be found here. The company acknowledges there were gaps in implementing its sustainability policy however immediate actions have been taken to address all non-compliances. Where there are liabilities, Bumitama is managing it through the RSPO Remediation and Compensation Procedure. Cargill is monitoring the progress of Bumitama's RaCP. (November 2018)
• Land clearing was detected in PT Lestari Gemilang Intisawit. Our direct suppliers engaged Bumitama and an update was made by Bumitama which can be accessed here. (March 2019)
   

Issue Under Review: Deforestation

Grievance Entity: Value Greenwood Sdn Bhd

January 2021 - Status: Investigation

Grievance Source: Mighty Earth

Actions Cargill Has Taken To Date:

• Cargill reached out to our direct suppliers for more information. Our direct supplier shared that Bunga Group has implemented a moratorium and adopted an NDPE Policy from 25 January 2021. Investigation regarding the alleged land clearing is ongoing. (February 2021)

Direct Trading Partner: Wilmar

Issue Under Review: Deforestation

Grievance Entity: PT Medcopapua Hijau Selaras
May 12, 2020 - Status: Developing Action Plan

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Though Capitol Group is not in our latest mill list, Cargill has reached out to our previous direct supplier, to understand progress on their grievance engagement. (May 2020)
• The direct supplier is investigating the legitimacy of the case.
• Cargill has been informed that the supplier has a HCV/HCS study and field verification was needed. Due to delays from COVID-19 movement restrictions, a field visit could only be conducted last week. We are awaiting the outcomes of the visit. (June 2020)
• Verification findings showed that the land clearing was due to the local community's pressure to develop in the area. Further investigation was conducted in September to identify the locations of the land clearing. Medcopapua Hijau Selaras also imposed a moratorium effective September 2020.
• Medcopapua Hijau Selaras has agreed to rehabilitation for the areas cleared. Our direct supplier will continue engagement with Medcopapua Hijau Selaras to develop a remediation plan. Refer to our direct supplier's grievance dashboard for details. (June 2021)

Direct Trading Partner: Wilmar, Musim Mas, AAK

Issue Under Review: Deforestation

Grievance Entity: PT Hardaya Inti Plantation
February, 2018 - Status: Developing action plan/Moratorium in place

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• Cargill initiated engagement with our direct supplier in February 2018 on allegations of deforestation facing PT Hardaya Inti Plantations. Following investigations and dialogue, the supplier has committed to a moratorium and compliance of NDPE. (May 2018)

Direct Trading Partner: Wilmar, KPN

Issue Under Review: Alleged Environmental and Social Non-Compliance

Grievance Entity: Mitra Abadimas Sejahtera
December 2021 - Status: Case Closed

Grievance Source: Lembaga Bentang Alam Hijau (LemBAH)

Actions Cargill Has Taken to Date

• When the grievance was first raised, Mitra Abadimas Sejahtera (PT MAS) was not in Cargill's latest mill list. However Cargill was later exposed to PT MAS via our direct suppliers.
• Our direct supplier has investigated with PT MAS on the allegations raised and is engaging the grievance raiser on PT MAS' response to the allegations. Cargill will monitor our direct supplier's progress. (December 2021)
• Our direct supplier carried out a field visit to PT MAS to investigate in June 2022. The grievance team conducted document review and interviewed PT MAS and the surrounding communities. Findings are as follows:
  • PT MAS is operating legally, having obtained all legal permits (location permit, IUP and HGU).
  • PT MAS has utilized their plasma obligations and provided for land acquisition to the previous land owners.
  • There are no community settlements, buildings, graves and community houses within the boundaries of PT MAS' IUP and HGU.
  • Majority of the workers are from local communities of Subah sub-district and appeared to have a good relationship with PT MAS (workers welfare is protected and insurance coverage has been provided).
• Based on the above findings, the fact that the grievance raiser did not provide further comments upon receiving the findings and that no RSPO complaint has materialized, we deem this case to be closed. (September 2023)

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: PT Agreendo Green Lestari and PT Citra Agro Abadi
February 2018 - Status: Suspended

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• CAA has implemented a moratorium on  PT AGL and PT CAA as of 31 August 2018 and has committed to carry out HCS/HCV assessments. They have also committed to publish an NDPE policy in 2019.

Direct Trading Partner: Wilmar, Fuji, AAK

Issue Under Review: Deforestation

Grievance Entity: PT Gemilang Sawit Kencana
February, 2018 - Status: Developing action plan/Moratorium in place

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• Cargill initiated engagement with our direct supplier in February 2018 on allegations of land clearing. The company agrees to commit to NDPE. A moratorium is in place at PT Gemilang Sawit Kencana pending completion of required assessments by the supplier. (May 2018)

Direct Trading Partner: NIL

Issue Under Review: Deforestation, Land conflict

Grievance Entity: Radiant Lagoon
March 2019 - Status: Suspended

Grievance Source: Media Reports

Actions Cargill Has Taken to Date

• Cargill raised the matter with our direct suppliers based on local media reports and NGO report. Our direct suppliers have met with the company and are verifying details of the allegation. While the process is ongoing, a moratorium has been put in place. (March 26, 2019)
• Our direct supplier has suspended Double Dynasty. The company is no longer in our supply chain. (7 May 2019)

Direct Trading Partner: Apical

Issue Under Review: Deforestation 

Grievance Entity: PT Lahan Agro Inti Ketapang and PT Permata Lestari Jaya
February 2019 - Status: Suspended

Grievance Source: Greenpeace and internal monitoring

Actions Cargill Has Taken to Date

• Cargill initiated engagement with our direct supplier in February 2018 on allegations of land clearing by PT Lahan Agro Inti Ketapang. We are aware that land clearing has ceased and the company is carrying out the required assessments prior to any development, including HCS. (May 2018)
• Cargill identified a new supply chain connection to DTK Opportunity via our supplier Apical and engaged them on the continued sourcing relationship with DTK. We were informed that DTK no longer owns PT LAIK. However, Cargill's internal monitoring also identified potential clearing in DTK's PT Permata Lestari Jaya. We have been informed that as of 2nd week of September, DTK has implemented a moratorium on new land clearing. While we continue engagement with Apical on the case, we have communicated our expectation that repeat verified deforestation in a supplier group will result in commercial consequences. (September 2019)

Direct Trading Partner: GAR, Wilmar, AAA, Fuji, AAK, ADM, LIPSA

Issue Under Review: Deforestation

Grievance Entity: PT Arrtu Energie Resources
September 30, 2016 - Status: Closed for monitoring

Grievance Source: Greenpeace 

Actions Cargill Has Taken to Date

• EHP provided evidence that the deforestation was a result of community encroachment. Through engagement with our direct supplier, EHP was to carry out a land tenure study to reach agreement with the community.
• PT AER is involved in an orangutan conservation project to protect HCV corridors and where viable to restore critical sites. Details of the efforts can be found here. (July 2019)

Direct Trading Partner: GAR, Wilmar, AAA, Fuji, AAK, ADM, LIPSA

Issue Under Review: Labor Disputes

Grievance Entity: PT Tandan Sawita Papua
December 2016 - Status: Case Closed

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• A verification visit was conducted by our direct supplier on the issues of labor dispute and use of security forces on employees and communities. An action plan was developed to close structural gaps identified. (March 2017)
• Cargill considers the case closed. (November 2020)

Direct Trading Partner: GAR, Wilmar, AAA, Fuji, AAK, ADM, LIPSA

Issue Under Review: Deforestation

Grievance Entity: PT Tandan Sawita Papua
June 2021 - Status: Monitoring Implementation

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• The mill is not in our supply chain, however Cargill is connected to other operations of Eagle High Plantations through our direct suppliers.
• Our direct suppliers have engaged Tandan Sawita Papua. Tandan Sawita Papua conducted site verification and shared that the land clearing was conducted by the local community who was not aware that the area was controlled by Tandan Sawita Papua. The full verification report can be found on our direct supplier's grievance dashboard.
• Tandan Sawita Papua has since engaged the local community's village leadership. The local community has agreed to stop land clearing. Tandan Sawita Papua has engaged local government authorities to ensure there is clarity between the community and Tandan Sawita Papua about Tandan Sawita Papua's boundaries. The company will also install signboards notifying that the area belongs to Tandan Sawita Papua. Our direct supplier is monitoring the supplier's progress. (August 2021)

Direct Trading Partner: Mewah

Issue Under Review: Environmental and Social Non-Compliance

Grievance Entity: East New Britain Resources
July 2021 - Status: Suspended

Grievance Source: Global Witness

Actions Cargill Has Taken to Date

• Cargill has reached out to our direct suppliers for more information on the allegations raised and supply chain connections. Cargill understands that our direct suppliers are also linked to East New Britain Resources through Mewah.
• Pending verification regarding the allegations, our direct supplier Mewah has ceased sourcing from East New Britain Resources. Mewah has also engaged East New Britain Resources on the grievance allegations. Cargill will continue to follow up with our direct supplier on their investigation progress. (August 2021)
• Effective March 31, 2022, Cargill has decided to suspend East New Britain Resources based on allegations in Papua New Guinea brought to us through a public report by NGO Global Witness in October 2021. This is following the engagement and suspension by our direct supplier on the case.

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: PT Kapuasindo Palm Industry and PT Buana Tunas Sejahtera
March 2019 - Status: Suspended

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Company had been suspended by our direct suppliers at the point of engagement. Cargill adopts a no buy position on the company.

Direct Trading Partner: Wilmar, Musim Mas

Issue Under Review: Deforestation 

Grievance Entity: PT Ketapang Hijau Lestari
March 2019 - Status: Investigation

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill has engaged our direct supplier on the allegations and was informed no clearing was identified on HCS areas. FAP’s PT Ketapang Hijau Lestari has a credible HCS assessment. A verification visit is currently being planned by our direct supplier.

Direct Trading Partner: AAA, AAK, Fuji, Shanghai Kaiye, Zhejiang Wuchan

Issue Under Review: Deforestation

Grievance Entity: PT Kumai Sentosa
June 2020 – Status: Verification

Grievance Source: Customer

Actions Cargill Has Taken to Date

• Our direct supplier, Fuji, sources from Gagah Putra Satria Holdings through GAR. GAR was engaging with PT KS since May 2019 when allegations were raised that PT KS was developing on peat. In May 2020, GAR suspended Gagah Putra Satria due to unsatisfactory grievance engagement and new information on clearing of peat. For more information, refer to GAR’s grievance dashboard. (June 2020)
• Cargill identified that we are connected through another direct supplier. Cargill reached out to the direct supplier to understand the status of the grievance.
• Our direct supplier shared that PT Kumai Sentosa conducted a soil survey from Pusat Penelitian Kelapa Sawit in 2014, which includes measuring the depth of peat. The concession is outside of the peat hydrology area and the peat within the HGU was also removed. Following the assessment report, the government revised Kumai Sentosa’s map in 2015 to reflect that there is no peat area in the concession. Gagah Putra Satria sent the report to our direct supplier as evidence. Our direct supplier continues engaging Gagah Putra Satria to conduct a HCV/HCS Assessment. (August 2021)

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: Multiple
July, 2018 - Status: Case Closed

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• We would like to stress that there is no legal entity of “Gama Group”, instead this is a situation of unstructured family-owned companies without any formal overarching management. Based on Greenpeace’s list of alleged companies associated to Ganda and Martua families and a list from a representative of the families in its response to Greenpeace, we can confirm that Cargill currently does not source directly from any of the above mentioned companies associated with Gama. We were indirectly impacted through our direct sourcing from Wilmar and other traders also source from Wilmar. However, with Wilmar’s decision to cease all sourcing from these companies since 20th June 2018, our supply chain is no longer linked. We will continue to review all traceability data to ensure that these companies are not in our supply chain until we have further confidence of compliance with our sustainability policy.
• We understand the family is in the process of further restructuring and consolidating its companies into a group with a credible third-party to ensure all its subsidiaries are accounted for and are committed to adopting NDPE policies regardless of shareholding. Cargill is also supportive of Wilmar’s commitment to set up an NDPE Action Committee chaired by Wilmar’s CEO to review its supplier relationship with the companies.  We will continue to follow these developments closely and define expectations with our direct suppliers.
• The issue of indirect links between NDPE and non-NDPE companies is an ongoing area of concern for Cargill. Because there is no established approach on the issue, we believe a more thorough review is warranted. Our grievance panel is in the process of defining the approach our grievance procedure will take when determining the application of group association in respect of individuals in positions of influence.
• On 16 June 2021, Cargill lifted the suspension on sourcing Indonesian palm supplier KPN Group (formerly GAMA Group) as the company has demonstrated commitment to taking action to close the gaps needed to comply with Cargill's Sustainable Palm Oil Policy.
• The main commitments made by KPN include:
  • Establishing an NDPE Policy covering all operations under KPN Plantation.
  • The implementation of a sustainability action plan with precise activities and specific tasks for each activity, timeline, priorities, people responsible, and outcomes.
  • Conduct a responsibility study with an independent consultant to determine the area that was cleared.
  • Demonstrate action on the ground through regular reporting of KPN's progress regarding its sustainability action plan and remediation plan.
• Cargill recognizes that KPN has made notable progress in the implementation of its sustainability strategy and recovery plan and has shown meaningful initiatives to strengthen engagement with local stakeholders on NDPE practices. This is the reason why the Palm Grievance Panel has decided to lift suspension on commercial relations with KPN.
• Cargill will continue to follow up on KPN's progress through bi-annual sustainability progress reports and engage with them to maintain compliance with Cargill's Sustainable Palm Oil Policy. If additional non-compliances are found, we will reopen the grievance process in line with our protocol. (June 2021)

Direct Trading Partner: GAR, Musim Mas, Mewah, IOI, Wilmar, AAK, Fuji

Issue Under Review: Deforestation

Grievance Entity: PT Citra Sawit Cemerlang
April 2019 - Status: Implementing action plan

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill has reached out to our direct suppliers for investigation. Our direct suppliers are reviewing PT Citra Sawit Cemerlang’s HCS assessment report. In the meantime we have requested for a moratorium to be put in place. (April 2019)
• Cargill engaged our direct suppliers and was informed that the land clearing took place outside HCS areas as assessed by consultant, AidEnvironment. PT CSC will submit the assessment for peer review, pending which a stop work order is in place as of 1st May 2019.
• Genting also clarified that PT Permata Sawit Mandiri does not belong to the group. Divestment took place in march 2017 to Sepanjang Group. (June 2019)

Trading partner: Wilmar, AAK

Issue Under Review: Deforestation, Exploitation

Grievance Entity: PT  Nabire Baru
September 30, 2016 - Status: Closed for monitoring

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• Cargill has communicated to our direct suppliers our expectation for Goodhope to reassess their HCS and HCV landscape. (April 2017)
• Goodhope has published a sustainability policy and implementation plan. The supplier is also sharing progress of its implementation plan.
• Cargill requires Goodhope to commit to its implementation plan and follow through the RSPO DSF process. (May 2017)
• Cargill reviewed Goodhope's implementation plans and acknowledge the progress achieved on several fronts including resolution of RSPO complaints, HCS and HCV assessments as well as ensuring credible FPIC processes. (July 2019)

Issue Under Review: Land Conflict

Grievance Entity: Grupo Agroindustrial Hacienda La Gloria
February 2018 – Status: Suspended

While performing supply chain monitoring, Cargill found that the Constitutional Court of Colombia had ordered in 2017 that Grupo Agroindustrial Hacienda La Gloria return 1,200 hectares of their estates planted in palm to Colombian Authorities. These hectares were declared as state lands and afterwards allocated to a group of peasants who were violently displaced by previous owners from the land purchased by La Gloria some years after the incident.

Therefore, Cargill initiated an investigation to understand the level of implementation of the Constitutional Court ruling and risk that the case represented for compliance of the Company´s Palm Policy. Cargill’s last purchase from La Gloria was in 2017 and we decided to put any new business on hold until findings from the investigation were clear.

Grievance Source: RSPO Grievance System

Actions Cargill Has Taken to Date

• Cargill collected secondary and primary information to understand the full context and background on the case. (March 2018)
• Cargill engaged the supplier to gather information on the latest developments of the case and the actions conducted by La Gloria to execute the ruling. (2018)
• Cargill collected information on the pending actions by Colombian Authorities to implement the ruling effectively. (2019)
• Cargill legal department found that there are pending actions from both sides and some additional legal actions had been installed. This context will delay a quick resolution of the land conflict. (2019)
• Cargill decided to postpone any new businesses with this supplier until the case is resolved. (April 2020)

Direct Trading Partner: Mewah, AAK, IOI

Issue Under Review: Deforestation

Grievance Entity: PT Prima Bahagia Permai
February, 2018 - Status: Implementing action plan

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• We engaged our direct supplier in February 2018 and are aware that PT Prima Bahagia Permai has committed to a moratorium pending required assessments. The company has also been offered support for a HCSA assessment by a direct supplier. (May 2018)
• The HCS-HCV assessment has been completed. (August 2018)
• PT PBP continues to maintain its moratorium. (July 2019)

Direct Trading Partner: Musim Mas, Wilmar, Fuji, AAK

Issue Under Review: Deforestation

Grievance Entity: PT Sumatera Jaya Agro Lestari
January 2019 - Status: Closed for Monitoring

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill engaged our direct suppliers and is aware a moratorium is in place. Our direct supplier Musim Mas is also in active engagement on a 90 day workplan with the supplier beginning February 2019. We will follow-up on the progress of the action plan. (March 1, 2019)
• Incasi Raya has ceased all clearing since March 2019 and the cleared area has been planted with cover crop. No palm planting will be carried out for the said area. (September 2019)

Direct Trading Partner: Wilmar, GAR, Musim Mas, ADM

Issue Under Review: Labor rights violation, RSPO complaint

Grievance Entity: Indofood
September 30, 2016 - Status: No longer in supply chain

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Cargill has communicated our expectations to our direct suppliers for Indofood to publish a time-bound implementation plan of its sustainability policy. (April 2017)
• Cargill met RSPO on July 13, 2017 to communicate our concern on the progress of the RSPO complaint. We understand RSPO is looking into an independent investigation.
• GAR conducted a site visit at PT Salim Ivomas Pratama, another Indofood mill in August with a focus on labor. No major non-compliance was observed. PT SIP is implementing a time-bound action plan to close up other observations.
• RSPO is carrying out an independent investigation into the complaints. Cargill has requested for RSPO to update the RSPO complaints page to assist members in our own grievance engagements. Indofood remains committed to the RSPO complaints process. (November 2017)
• Indofood is no longer in our supply chain. (May 2018)

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: PT Internusa Jaya Sejahtera
February, 2018 - Status: Suspended

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• The supplier is no longer in our supply chain as engagement via our direct supplier was unsatisfactory.

Direct Trading Partner: AAK, Musim Mas, Sime Darby, GAR

Issue Under Review: Land rights

Grievance Entity: PT Mitra Austral Sejatera
July 2019 - Status: Investigation

Grievance Source: Customer

Actions Cargill Has Taken to Date

• Cargill is aware PT MAS has been part of the RSPO complaints system. Sime Darby divested from PT MAS in February 2019. Cargill is engaging our direct suppliers on the process of resolution by the new owners of PT MAS. (July 2019)

Issue Under Review: Deforestation

Grievance Entity: Aspirasi Kristal (M) Sdn Bhd
August 2020 – Status: Investigation

Actions Cargill Has Taken to Date:

• Aspirasi Kristal's plantations are alleged to have deforestation, and that mills in our supply chain are allegedly sourcing FFB from Aspirasi Kristal. We are investigating with our suppliers on these allegations. (August 2020)

Direct Trading Partner: Mewah, Fuji, Keck Seng, IOI, Bunge, ISF

Issue Under Review: Environmental Non-Compliance

Grievance Entity: Jernih Kemboja Sdn Bhd 
March 2022 - Status: Suspended

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Effective March 31, 2022, Cargill has decided to suspend Jernih Kemboja Sdn. Bhd from its supply chain following evidence of deforestation in Malaysia obtained via satellite imagery. Cargill remains open to engage with Jernih Kemboja Sdn. Bhd and support re-engagement efforts that meet our supplier standards.

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: Batulicin Agro Sentosa
October 2018 - Status: Suspended

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Due to unsatisfactory progress in existing grievance engagements and NDPE implementation, Cargill has stopped indirect sourcing from Jhonlin group. Should Jhonlin Group demonstrate significant progress in their NDPE implementation and addressing existing grievance allegations, Cargill may consider re-engagement. (June 2020)

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: Tunas Sawa Erma
July 26, 2016 - Status: Suspended

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Company has been suspended by our direct suppliers. Cargill adopts a no buy position on the company.

Issue Under Review: Deforestation, Mills are at risk of sourcing from concessions clearing peat

November 7, 2016 - Status: Monitoring landscape and ongoing engagement with direct suppliers

Actions Cargill Has Taken to Date

• Cargill has requested for our direct suppliers to share their action plan for Leuser monitoring. Our direct suppliers are approaching the risks in Leuser at a landscape level through various multi-stakeholder initiatives such as the "Areal Prioritas Transformasi". They are also carrying out sustainability workshops to raise awareness on the issues in Leuser. Read more in their respective grievance lists.
• Cargill is also proactively monitoring the Leuser landscape for mill assessment opportunities. We are also supporting other landscape-level deforestation monitoring & response system which can strengthen work in Leuser. (April 2017)

Issue Under Review: Deforestation

Grievance Entity: PKPP Plantation Sdn Bhd
August 2020 – Status: Verification

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• We are engaging our direct suppliers for more information. (August 2020)
• A joint meeting was held between LKPP, Prosper, Far East Holdings, Bunge and Cargill to discuss the land clearing and socialize NDPE. LKPP is to establish a comprehensive NDPE policy and identify potential remediation plan to the conversion. A follow-up meeting has been scheduled for the end of September. (September 2020)
• Through follow-up engagements by Bunge, Prosper and Far East Holdings, the group has agreed to implement a group-wide policy from 1 January 2021. PKPP/LKPP will also identify programs and activities which align with their NDPE commitment. PKPP also shared that no further land clearing and development will take place.
• Discussions are ongoing to obtain a written commitment from PKPP on a recovery plan through their remaining land bank. (December 2020)

Direct Trading Partner: NIL

Issue Under Review: Development on peat

Grievance Entity: PT Persada Era Agro Kencana
March 2019 - Status: Suspended

Grievance Source: Mighty Earth 

Actions Cargill Has Taken to Date

• Company had been suspended by our direct suppliers at the point of engagement. Cargill adopts a no buy position on the company.

Direct Trading Partner: AAA, Mewah, IOI, AAK

Issue Under Review: Deforestation of peat 

Grievance Entity: PT Sumber Alam Selaras
February, 2018 - Status: Implementing action plan

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• Cargill initiated engagement with our direct supplier in February 2018. Moratorium is in place and monitoring is ongoing to ensure it is complied with. Assessments relating to NDPE compliance were completed for PT Sumber Alam Selaras in April 2018 and the report is being prepared. (May 2018)
• NPC's HCS-HCV report is undergoing peer-review. (May 2019)

Direct Trading Partner: AAA

Issue Under Review: Deforestation

Grievance Entity: PT Global Primatama Mandiri
March 2019 - Status: Suspended

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill has raised the matter with our direct supplier. AAA has reached out to Palma Serasih and are expecting a response by end of March. We will closely follow the matter and expect a moratorium to be put in place. (March 26, 2019)
• Palma Serasih is reviewing options to carry out a HCS assessment for the area referenced. Cargill has communicated our expectations to AAA that no new land clearing should take place pending these discussions. (8 May 2019)
• New contracts have been placed on hold pending agreement to requirements on HCS.  (July 2019)

Direct Trading Partner: GAR, Musim Mas

Issue Under Review: Deforestation

Grievance Entity: Blang Tualang
May 2019 - Status: Developing Action Plan

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• As part of Cargill's monitoring of the Leuser Ecosystem, we were alerted to allegations of ongoing clearing in several concessions operating in the landscape, including PTPN 1. We engaged our direct suppliers and are aware that authorities are also investigating the matter. Engagement is ongoing.
• The alleged deforested area is an existing plantation area with HGU permit. PTPN 1 explained that they were conducting replanting activities in the area.  The palm plantation was in operation between 1990-1999, however operations were abruptly ceased in 1999 due to the insurgency in Aceh and Military Operations Area (Daerah Operasi Militer) being enforced. PTPN 1 could only resume the maintenance of the plantation area in 2014 and began replanting unproductive and overgrown oil palm areas. The last replanting activity was in 2019 and allegations in 2020 were caused by community encroachment.
• As the area was abandoned for a long duration, young undergrowth developed around the unmanaged palm trees and the area started to look like a regenerating forest populated by wood weed and thick bushes with dense population.
• Given the unique situation, we are advocating for our direct suppliers to also engage HCSA to determine appropriate next steps, and potentially take guidance from other landscapes who have faced similar civil conflict situations. Since the area was left unmanaged, regenerating vegetation may have reached the HCS Young Regeneration Forest threshold and should be reviewed.
• Our direct supplier shared that PTPN 1 has agreed to stop land clearing in the area identified as a potential forest to do an integrated assessment. Cargill is in dialogue with our direct suppliers to develop the appropriate action plan to account for the regenerating vegetation, which will include remediation if found necessary.
• PTPN 1 also has a Sustainable Palm Oil Policy and is willing to share it with interested stakeholders. (August 2020)

Direct Trading Partner: Wilmar, GAR, Musim Mas

Issue Under Review: Labor exploitation

November 1, 2016 - Status: Monitoring Implementation of Action Plan

Actions Cargill Has Taken to Date

• Field visits have been conducted by direct suppliers and follow-up action plans have been put in place to close necessary gaps. (December 2016)

Direct Trading Partner: Wilmar

Issue Under Review: PT Koperasi Prima Jasa is alleged to be sourcing from PT ABN where deforestation is occurring

February 6, 2017 - Status: Suspended

Actions Cargill Has Taken to Date

• Cargill sought clarification from Wilmar and we understand that PT KPJ is no longer sourcing from PT ABN. (February 2017)
• Wilmar also confirms that its other suppliers are not sourcing from PT ABN. (May 2017)

Direct Trading Partner: GAR, Wilmar, AAK

Issue Under Review: Burning, Community intimidation

Grievance Entity: PT Andika Permata Sawit Lestari
August 5, 2016 - Status: Closed

Grievance source: Internal monitoring

Actions Cargill Has Taken to Date

• The issue has been brought to the courts and Cargill is monitoring the development through our direct suppliers. (August 2016)
• PT APSL clarified that the fires occurred outside of its concession in area belonging to independent farmers, and denied the company instigated the incident. Our direct supplier verified that the case has been closed and a suspect has been arrested for arson. (April 2018)

Direct Trading Partner: Musim Mas, Permata

Issue Under Review: Sourcing from deforested area

Grievance Entity: CV Buana Indah 
December 2019 - Status: Monitoring Implementation

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Cargill has commenced engagement with our direct suppliers who are presently preparing for field verification with the mills. Cargill will work with our direct suppliers to ensure the mill has a time-bound NDPE action plan, including traceability to plantation. (December 2019)
• Musim Mas completed verification and found that PT BDA was sourcing from PT Laot Bangko in 2019, however stopped sourcing from the concession since September 2019 following engagement by Musim Mas on high risk areas in the region.
• PT BDA provided Musim Mas an acknowledgment letter in December 2019 that it commits to stop sourcing from all protected areas. Musim Mas is currently supporting PT BDA in creating a time-bound NDPE action plan.
• Cargill will continue engagement with Musim Mas to ensure PT BDA plans and implements an action plan. We consider Leuser as a high priority landscape, and will continue to monitor our suppliers’ programs to address concerns in the Rawa Singkil Wildlife Reserve and the wider Aceh landscape. (January 2020)
• PT BDA has been engaged by Musim Mas and is implementing their action plan. PT BDA has completed the following action plan items:
  • Developed an SOP for Traceability to Plantation (TTP).
  • Training to socialize FFB suppliers about high-risk areas and PT BDA's TTP requirements.
  • In the process of ensuring FFB suppliers agree with PT BDA's TTP requirements.
• Refer to Musim Mas' grievance log for more details on PT BDA's action plan implementation progress. (November 2020)

Direct Trading Partner: Wilmar, Permata Hijau Group

Issue Under Review: Social Non-Compliance

Grievance Entity: PT Dewa Rencana Perangin Angin
March 2022 - Status: Suspended

Grievance Source: Mongabay

Actions Cargill Has Taken to Date

• Effective March 31, 2022, Cargill has suspended PT. Dewa Rencana Perangin Angin from its supply chain due to forced labor allegations in Indonesia. Based on investigations done by our direct suppliers, Cargill has concluded that PT. Dewa Rencana Perangin Angin is in violation of Cargill’s Policy on Sustainable Palm Oil. Cargill does not use or tolerate the use of human trafficking, forced labor or child labor.

Direct Trading Partner: GAR, Fuji

Issue Under Review: Community Conflict

Grievance Entity: PT Dua Perkasa Lestari
August 2020 – Status: Suspended

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Cargill has contacted our direct supplier for more information on the allegations. Our direct supplier is not sourcing directly from PT DPL but their third-party mill, PT Beurata Subur Persada is sourcing FFB from PT DPL. PT BSP has begun engagement with PT DPL on the allegations and actions taken. Our direct supplier released a statement on their engagement with PT DPL. GAR has commenced investigations on the community grievance. GAR has been engaging with PT DPL on no-deforestation since 2017. PT DPL issued a moratorium in February 2020 and GAR has not detected land clearing by PT DPL. Refer to GAR’s grievance dashboard for more information on their past engagement with PT DPL. (August 2020)
• Due to unsatisfactory engagement with PT DPL, GAR has suspended PT DPL from its supply chain. GAR has also notified PT BSP on the suspension of BSP. (October 2020)

Direct Trading Partner: lmar, GAR, Fuji, AAK, Musim Mas

Issue Under Review: Sourcing from deforested area

Grievance Entity: PT Agra Bumi Niaga
July 21, 2017 - Status: Closed for monitoring

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Cargill reached out to all direct suppliers for further information. PT ES stated in a public response that they unwarily sourced from PT ABN due a name change by the company and will take steps to strengthen traceability efforts. (July 24, 2017)
• PT Ensem Sawita has ceased sourcing from PT ABN and is committed to maintaining the decision until PT ABN demonstrates compliance and is assessed by a credible third-party.
• Musim Mas is engaging PT Ensem Sawita in the development of an internal sustainability policy in line with their NDPE policy and an action plan with timelines that will include traceability initiatives. Wilmar is awaiting an assessment report and will follow-up based on the outcome. (August 14, 2017)
• Our direct suppliers have been supporting Ensem Sawita on achieving full TTP. As of January 2019 the mill has successfully achieved the target and is expected to maintain the data. (February 2019)

Direct Trading Partner: AAA

Issue Under Review: Sourcing from deforested area

Grievance Entity: CV Buana Indah; PT Laot Bangko
October 2019 - Status: Monitoring Implementation

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Cargill has commenced engagement with our direct suppliers who are presently preparing for field verification with the mills. Cargill will work with our direct suppliers to ensure the mill has a time-bound NDPE action plan, including traceability to plantation. (October 2019)
• Musim Mas and GAR completed their field verification which included site visits, interviews and document reviews. Both Musim Mas and GAR found documented evidence that PT GSS sourced from CV Buana Indah, PT Laot Bangko and PT ASDAL in 2019. Records also verified PT GSS’ statement that they stopped sourcing FFB from CV BI after RAN’s report.
• PT GSS is to implement its time-bound action plans to prevent future risks of sourcing FFB from areas under conservation. The action plan includes traceability to plantation and for all FFB suppliers of PT GSS to commit to sourcing only from outside of the protected areas. PT GSS has commenced actions which include hiring a sustainability officer to manage the TTP process.
• Cargill will continue engagement with our direct suppliers to ensure PT GSS is successfully implementing its action plan. We consider Leuser as a high priority landscape, and will continue to monitor our suppliers’ programs to address concerns in the Rawa Singkil Wildlife Reserve and the wider Aceh landscape. (January 2020)
• Cargill understands allegations have been raised that Global Sawit Semesta is sourcing from non-compliant supplier, PT Laot Bangko. PT Laot Bangko is a suspended supplier of Cargill due to deforestation in the Leuser Ecosystem.
• Cargill engaged our direct supplier for more information. Our direct supplier has been engaging PT GSS upon identifying that the mill sourced FFB from Laot Bangko basis its traceability declarations. PT GSS is expected to fulfill all action plan items as required by our direct supplier, which includes implementing a traceability SOP and monitoring of suppliers to ensure no illegal FFB enters its supply chain again.
• Separately PT GSS has also engaged PT Laot Bangko to stop land clearing. PT Laot Bangko has ceased land clearing from June 2021, developed a sustainability policy and is in the process of hiring a consultant to conduct a HCV/HCS Assessment. Details can be found on our direct supplier’s grievance dashboard.
• Our direct supplier has ceased sourcing from both companies until the grievance is resolved. Cargill will continue to monitor the grievance progress. (August 2021)
• PT GSS has committed to a sustainability policy and implementation of an action plan to improve their traceability procedures. Our direct supplier continues to monitor PT GSS' progress.
• PT Laot Bangko has also published a sustainability policy and is working with a consultant on the HCV/HCS Assessment. (December 2021)

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: PT Henrison Inti Persada and PT Pusaka Agro Lestari
January 2017 - Status: Suspended

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• Company has been suspended by our direct suppliers. Cargill adopts a no buy position on the company.

Direct Trading Partner: Fuji, Musim Mas, GAR

Issue Under Review: Sourcing from deforested area

Grievance Entity: CV Buana Indah 
October 2019 - Status: Developing Action Plan

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Cargill has commenced engagement with our direct suppliers who are presently preparing for field verification with the mills. Cargill will work with our direct suppliers to ensure the mill has a time-bound NDPE action plan, including traceability to plantation. (October 2019)
   
• Musim Mas and GAR completed their field verification which included site visits, interviews and document reviews. Both Musim Mas and GAR did not find documented evidence that PT SSN was sourcing from CV Buana Indah. As there still is a risk of undocumented sourcing from CV Buana Indah, Musim Mas and GAR are supporting PT SSN to implement a time-bound NDPE action plan to prevent future risks of sourcing FFB from areas under conservation. The action plan includes traceability to plantation and for all FFB suppliers of PT SSN to commit to sourcing only from outside of the protected areas. PT SSN is working on TTP through collaboration with Koltiva.
  
  Cargill will continue engagement with our direct suppliers to ensure PT SSN is successfully implementing its action plan. We consider Leuser as a high priority landscape, and will continue to monitor our suppliers’ programs to address concerns in the Rawa Singkil Wildlife Reserve and the wider Aceh landscape. (January 2020)

Direct Trading Partner: Permata Hijau Group, Sumber Tani Agung, Musim Mas, Wilmar, AAK, Fuji, Trans-Global Tradelinks, Celena Alimentos, Sea Terminal Taman

Issue Under Review: Alleged Environmental Non-Compliance

Grievance Entity: PT Sawit Sukses Sejati
May 2022 - Status: Case Closed

Grievance Source: Mighty Earth, Environmental Investigation Agency

Cargill received a report by Rapid Response No 39 raising allegations related to PT Sawit Sukses Sejati (former PT Anugerah Langkat Makmur/ALAM). This company is identified as one of the top 2022 deforesters, which has cleared around 660 hectares of forest in 2022. Later, in December 2022, Environmental Investigation Agency (EIA) also published a report which alleged that PT SSS has supplied to an RSPO MB mill, Sikarakara (owned by PT Rimba Mujur Mahkota, part of the Pasifik Agro Sentosa Group) since at least 2020.

Actions Cargill Has Taken to Date

• Cargill has reached out to Sumber Tani Agung for their connection to PT SSS for the Rapid Response No 39 case. Sumber Tani Agung confirmed that they have not sourced from PT SSS since May 2022 and have mentioned this in their 2022 Sustainability Report (page 67).
• Regarding EIA’s report on the alleged new connection to Sikarakara mill via PT Rimba Mujur Mahkota, Cargill has reached out to direct suppliers. Feedback and evidence is as follows:
  • On PT Rimba Mujur Mahkota (Sikarakara mill) last sourced from PT SSS in October 2022, before PT SSS's connection to this mill was mentioned by EIA.
  • After our supplier engagement and sharing of information about the case, the mill has banned sourcing from PT SSS effective immediately  (May 2023) using a letter from the corporate sustainability of their parent group (PT Pasifik Agro Sentosa).
• Based on the above feedback, we deemed the case to be closed. (May 2023)

Direct Trading Partner: NIL

Issue Under Review: Community land conflict

Grievance Entity: PT Sintang Raya
August 2, 2016 - Status: Not in supply chain

Grievance Source: Internal Monitoring

Actions Cargill Has Taken to Date

• The issue has been brought to the courts and Cargill is monitoring the development through our direct suppliers. (August 2016)
• Supplier is no longer in our supply chain. (July 2019)

Direct Trading Partner: NIL

Issue Under Review: Deforestation, Development on peat

Grievance Entity: PT Pinang Witmas Abadi
February 2019 - Status: Suspended

Grievance Source: MIghty Earth 

Actions Cargill Has Taken to Date

• Company had been suspended by our direct suppliers at the point of engagement. Cargill adopts a no buy position on the company.

Direct Trading Partner: ISF, Dreyfus, Marvesa, Vandemoortele, AAA, JSC “NMGK”

Issue Under Review: Deforestation

Grievance Entity: Pipit Mutiara Indah
June 2020 – Status: Implementing Action Plan

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill reached out to our direct suppliers for more details on their grievance engagement with QL Resources. Our direct supplier shared that QL Resources has agreed to commit to the following:
  • Implementing an immediate group wide moratorium on land clearing and peatland development
  • Acknowledging the total area of non-compliant development of forest or peatland areas post 31 December 2015 within all of the group’s concessions
  • Resolve the non-compliant development through the creation and implementation of a comprehensive recovery plan.
• Our direct supplier will continue engagement with QL Resources on the implementation of their commitments. (June 2020)
• Refer to our direct supplier's grievance dashboard for more information on QL Resources' commitments. Cargill will continue to follow up with our direct supplier to ensure QL Resources is implementing their commitments. (July 2020)

Direct Trading Partner: Wilmar, Mewah, LDC, KLK, IFFCO, IOI, Marvesa, Vandemoortele, Unitata, GAR, ISF, Apical, AAK, Bunge, Olenex

Issue Under Review: Deforestation

Grievance Entity: Gilford Ltd
October 2018 - Status: Developing action plan/Moratorium in place

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• Supplier is maintaining a moratorium as of 20 September 2018. They have shared concession maps and committed to NDPE through Wilmar.

Direct Trading Partner: Wilmar, Mewah, LDC, KLK, IFFCO, IOI, Marvesa, Vandemoortele, Unitata, GAR, ISF, Apical, AAK, Bunge, Olenex

Issue Under Review: Environmental and Social Non-Compliance

Grievance Entity: Rimbunan Hijau (Papua New Guinea) Group
July 2021 - Status: Monitoring Implementation

Grievance Source: Global Witness

Actions Cargill Has Taken to Date

• Cargill has reached out to our direct suppliers for more information on the allegations raised.
• Pending verification regarding the allegations, our direct supplier Mewah has suspended Rimbunan Hijau until the grievance allegations are fully investigated. As such Cargill is not linked to Rimbunan Hijau in Papua New Guinea but are indirectly linked to Rimbunan Hijau at a group level through Rimbunan Hijau’s operations in Malaysia. Cargill will continue to follow up with our direct suppliers sourcing from Rimbunan Hijau at a group level regarding their investigations. (August 2021)
• Our direct supplier has engaged Rimbunan Hijau on the allegations raised. Rimbunan Hijau has provided clarifications and supporting documents on the allegations raised, which has been reviewed by our direct supplier. Regarding the issue of PPE, they are engaging Rimbunan Hijau to ensure their PPE policy and implementation is aligned with NDPE practices. Cargill will continue monitoring the progress. Refer to our direct supplier's grievance dashboard for details. (October 2021)

Direct Trading Partner: Sime Darby Berhad, Intercontinental Specialty Fats Sdn Bhd

Issue Under Review: Deforestation 

Grievance Entity: Myanmar Stark Prestige Plantation
February 8, 2017 - Status: Suspended

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• Cargill sought clarification from Wilmar and understands the supplier is reassessing its environmental assessments. (May 2017)
• Samling has issued a moratorium on land clearings in their Indonesia, Myanmar and Malaysia operations. The supplier is aware that credible assessments are required as pre-conditions for any new development. Samling has divested from its PNG operations. (May 2018)
• Cargill is aware of allegations of deforestation against Samling's other forestry operations. Our direct suppliers have verified that palm trees are not being planted in the concession. Cargill's palm grievance procedure is only limited to palm oil. Our suppliers would be considered non-compliant if the deforested land is subsequently developed for palm production. (July 2019)
• Our direct suppliers have ceased sourcing from Samling Group due to the unsatisfactory engagement which has prevented monitoring of Samling’s palm oil operations. Cargill will not source from Samling directly nor indirectly through our direct suppliers unless sufficient evidence is presented to manage deforestation risks and verify NDPE compliance. (February 2020)
• Prior to February 2020, our only connection to Samling group was through Wilmar, who then suspended Samling from their supply chain. Following an update of our mill list, we are now connected to Samling through Sime Darby and Intercontinental Specialty Fats. Cargill is engaging both direct suppliers on their ongoing sourcing from Samling. We are requesting for information from our direct suppliers on their grievance engagement status with Samling and will evaluate our position on the supplier.
• We have spoken with our direct supplier on the status of their grievance engagement with Samling. Cargill’s grievance panel is now reviewing the information shared by our direct supplier. (April 2020)
• Cargill has officially suspended Samling Group from our supply chains. All our direct suppliers are being notified of our position (May 2020)

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: PT Saraswanti Agro Estate
February 2019 - Status: Suspended

Grievance Source: Foresthints

Actions Cargill Has Taken to Date

• Company had been suspended by our direct suppliers at the point of engagement. Cargill adopts a no buy position on the company. (February 2019)

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: PT Surya Panen Subur II
November 2016 - Status: Suspended

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Surya Panen Subur II is no longer in Cargill's supply chain. We will be discussing with our direct suppliers on milestones required for SPS II to demonstrate compliance with our policy next month. (October 31, 2018)
• Expected milestones can be found on our direct supplier's log

Direct Trading Partner: Fuji, Apical

Issue Under Review: Deforestation

Grievance Entity: PT Tualang Raya
September 2020 – Status: Developing Action Plan

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Cargill has reached out to our direct supplier for investigation. Cargill considers PT Tualang Raya a non-compliant plantation and expects all mills in our supply chain to not source from the entity. (September 2020)
• Syaukath Sejahtera has ceased sourcing from PT Tualang Raya. Our direct supplier shared that Syaukath Sejahtera has committed to an action plan that includes:
  • Creating an NDPE Policy
  • Submitting traceability information
  • Conducting risk assessments to detect if their suppliers are clearing land in the Leuser Ecosystem or operating illegally
• Refer to our direct supplier's grievance dashboard for more information. Cargill will continue to follow up with our direct supplier to ensure Syaukath Sejahtera is implementing their action plan. (September 2020)

Direct Trading Partner: AAA, GAR, Musim Mas, Permata Hijau, AAK, Bunge

Issue Under Review: Sourcing from Tesso Nilo national park

Grievance Entity: PT Citra Riau Sarana, PT Makmur Andalan Sawit, PT Fortius Wajo Perkebunan, PT Sawit Mas Nusantara, PT Persada Alam Jaya and PT Inti Indosawit Subur
July 2018 - Status: Implementing action plan

Grievance Source: Eyes on the Forest

Actions Cargill Has Taken to Date

Cargill does not directly source from the Tesso Nilo landscape. Through our engagements with our direct suppliers, we were informed of the following details:

• Wilmar  suspended sourcing from PT Citra Riau Sarana in June 2018 due to alleged association with Ganda and Martua families. As such, the supplier is no longer in our supply chain.
• PT Makmur Andalan Sawit, PT Fortius Wajo Perkebunan, PT Sawit Mas Nusantara and PT Persada Alam Jaya have denied allegations by EoF. There were insufficient evidence that could proof the allegations, and in some situations the trucks did deliver to the mill however the source of FFB was not supplied by concessions indicated by EoF.
• PT Inti Indosawit Subur acknowledge receiving FFB through a dealer coming from illegal sourcing areas. Due to the negligence of the supply agent, he was suspended.
• All mills committed to either blacklisting or strengthening monitoring against trucks and dealers in the report. They have commitments and SOPs against sourcing from illegal concessions in the landscape and will socialize them again with suppliers.
• In line with our expectations of engaging in high priority landscapes, we advocate for our direct suppliers to collect traceability to plantation data in these areas. (July 2018)

Direct Trading Partner: GAR, Wilmar

Issue Under Review: Deforestation

Grievance Entity: PT Indo Alam
August 2020 – Status: Monitoring Implementation

Grievance Source: Rainforest Action Network

Actions Cargill Has Taken to Date

• Upon reviewing our latest mill list, Cargill found indirect supply chain connections to PT Teupin Lada. Cargill has reached out to our direct suppliers for investigation. Cargill considers PT Indo Alam a non-compliant plantation and expects all mills in our supply chain to not source from the entity. (August 2020)
• PT Teupin Lada has ceased sourcing from PT Indo Alam. Our direct supplier is engaging PT Teupin Lada to complete 100% traceability to plantation by the end of 2020. (August 2020)
• Our direct supplier updated that PT Teupin Lada achieved 100% traceability to plantation in September 2020. Refer to our direct supplier's grievance dashboard for details. (October 2020)

Direct Trading Partner: Wilmar, Mewah, Sime Darby, AAK, IOI

Issue Under Review: Deforestation

Grievance Entity: PT Persada Kencana Prima
September 2016 - Status: Developing action plan/Moratorium in place

Grievance Source: Greenpeace

Actions Cargill Has Taken to Date

• Cargill is engaging our direct suppliers in the allegations raised.
• THP has agreed to stop further land-clearing while a review of the area is in progress. Wilmar will be conducting a joint site visit to PT Persada Kencana Prima in July 2017. Please refer to Wimar's grievance list for further details. (June 2017)
• THP is maintaining its moratorium on land clearing. Wilmar has conducted the site visit and an action plan is in place to support THP's sustainability practices. (December 2017)
• Cargill has reached out to Wilmar on the allegations of clearing despite THP's commitment to a moratorium. (July 2018)
• THP has clarified that the clearing detected was due to stacking activities of land that was cleared several years ago. Please refer to Wilmar's dashboard for detailed clarifications.
• PT PKP continues to maintain its moratorium on new land clearing.

Direct Trading Partner: NIL

Issue Under Review: Deforestation

Grievance Entity: PT Kruing Lestari Jaya, PT Harapan Rimba Jaya and PT Rimba Karya Rayatama
November 2018 - Status: Suspended

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Company had been suspended by our direct suppliers at the point of engagement. Cargill adopts a no buy position on the company.

Direct Trading Partner: NIL

Issue Under Review: Development on peat

Grievance Entity: PT Solusi Jaya Perkasa and PT Samora Usaha Jaya
January 2017 - Status: Suspended

Grievance Source; Greenpeace

Actions Cargill Has Taken to Date

• Cargill is engaging our direct suppliers in the allegations raised. TBL has a moratorium in place while verifications are ongoing.
• Please refer to the grievance lists of our direct suppliers for further details. (June 2017)
• GAR and Wilmar is no longer sourcing from TBL. We have communicated our expectations to Musim Mas which include requesting that TBL must commit to no development on peat, and will follow-up closely.
• TBL is no longer in our supply chain.

Direct Trading Partner: GAR, AAK

Issue Under Review: Deforestation

Grievance Entity: PT Mulia Inti Perkasa
August 2018 - Status: Implementing Action Plan

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• Cargill engaged our direct suppliers on the clearing and was informed that a stop work order as of 20th August 2018 is in place for PT MIP. HCS and HCV assessments have also been completed in August by registered assessors.
• PT MIP submitted the assessment reports for peer review.(May 2019)
• Cargill enquired further on reports of additional clearing. Our direct suppliers informed that PT MIP was facing pressure to develop plasma area as part of commitments to the local communities. As such PT MIP agreed that the development of plasma area will be outside of HCS-HCV areas identified in earlier assessments. Our direct suppliers have confirmed that the land clearing identified was outside the HCS-HCV areas. (June 2019)
• PT MIP has committed to a peer review of the HCS/HCV study. PT MIP will ensure that their land preparation will take place outside of the HCS/HCV areas as categorized in the study. PT MIP will also ensure that there is compensation for any differences that may arise from the peer review.
• Our direct supplier, GAR, will continue to engage PT MIP and the HCV assessor on the peer review.
• We are investigating latest information on PT MIP as per Mighty Earth's Rapid Response Report #25. (May 2020)
• Mighty Earth released Rapid Response Report 29 stating that PT MIP allegedly cleared land. Our direct supplier has engaged PT MIP on both allegations in Report 25 and 29. Based on HCV-HCS assessments and shapefiles shared by PT MIP, the land clearing is in accordance to the HCV-HCS assessments. Refer to our direct supplier’s grievance dashboard for more information. (July 2020)

Issue Under Review: Deforestation

Grievance Entity: YP Plantation Sdn Bhd
August 2020 – Status: Developing Action Plan

Grievance Source: Mighty Earth

Actions Cargill Has Taken to Date

• YP Plantation is alleged to have peat development and land prepared for clearing, and that mills in our supply chain are allegedly sourcing FFB from Yayasan Pahang. We are investigating either directly or indirectly with our suppliers on these allegations. (August 2020)
• YP Plantation has issued a stop work order as of 17 August 2020. We will continue engaging our direct supplier to understand YP Plantation's next steps. (August 2020)
• YP Plantation has an NDPE policy. Discussions are ongoing regarding potential recovery plans. (September 2020)
• YP Plantation commenced partnership with NGO, Global Environment Centre, to work on a recover project. The project will conserve and rehabilitate 4800ha of forested and degraded peatland in the Pekan Forest Reserve and buffer zone. YP Plantation and GEC have agreed on objectives for the first 3 years of the project. The full statement can be found on YP Plantation's website. (June 2021)

Issue Under Review: Deforestation

Grievance Entity: YPJ Plantations Sdn Bhd (Ladang SSI Sg Ara)

January 2021 - Status: Investigation

Grievance Entity: Mighty Earth

Actions Cargill Has Taken To Date:

• Cargill reached out to our direct suppliers for more information. Our direct supplier is investigating the alleged land clearing. (February 2021)