SIPEF

SIPEF board of directors is ultimately responsible for the design and oversight of the Balanced Growth Strategy.

The implementation of the Balanced Growth Strategy is led by SIPEF's executive committee, which steers the global teams in Belgium, Singapore, and Luxembourg.

Delivery of the Balanced Growth Strategy is coordinated at a Group level by the global teams in Belgium, Singapore, and Luxembourg (finance, legal, marketing, IT, operational management, sustainability, and HR strategy). This includes monitoring and reporting on progress.

There are regional executive committees at SIPEF's operations in Indonesia, Papua New Guinea, and Côte d'Ivoire. These committees oversee the local teams and their operational activities and report directly to SIPEF's executive committee.

Regional teams at SIPEF's subsidiaries are responsible for operational activities. This includes HR matters (for employees and contractors), and the execution of the Balanced Growth Strategy for SIPEF's palm operations (in Indonesia and Papua New Guinea) and banana operations (in Côte d'Ivoire).

SIPEF BOARD OF DIRECTORS has REMUNERATION COMMITTEE, NOMINATION COMMITTEE, and AUDIT COMMITTEE.

Below the board is the SIPEF EXECUTIVE COMMITTEE.

Under the executive committee are three main regional operations:

• LUXEMBOURG (Jabelmalux SA) with regional executive committee
• BELGIUM (SIPEF Head Office) with regional executive committee
• SINGAPORE (SIPEF Singapore Pte Ltd) with regional executive committee

These oversee operations in:

• INDONESIA (PT Tolan Tiga Indonesia) with regional executive committee
• PAPUA NEW GUINEA (Hargy Oil Palms Ltd) with regional executive committee
• CÔTE D'IVOIRE (Plantations J. Eglin SA) with regional executive committee

Integration of sustainability-related performance in incentive schemes

Roles covered

The revised Remuneration Policy includes environmental, social and governance (ESG) based performance criteria for members of the executive committee, including the managing director.

Sustainability KPIs tied to remuneration

The variable remuneration for members of the executive committee (including the managing director) will be linked for 20% to ESG-based non-financial KPIs.

The ESG KPIs will be set annually by the board of directors upon the proposal of the remuneration committee. This approach ensures that ESG objectives remain dynamic, relevant, and aligned with the Company's evolving sustainability strategy, while maintaining oversight and accountability at the highest governance level.

Significant events, results of 2024, as well as sustainability KPIs, will be included in the annual remuneration considerations. The board of directors evaluates SIPEF's sustainability performance using rankings, ratings, certification progress, impact and risk assessments, and reports from the executive committee.

Weighting

• 80% of the short-term incentive (STI) remains linked to the financial objective of SIPEF's consolidated recurring result before tax (group share)
• 20% of the STI is linked to ESG-based non-financial KPIs

The 80% financial – 20% non-financial (ESG) parameter allocation aims to ensure an appropriate balance in the performance metrics applicable to the executive committee's variable remuneration. This structure provides sufficient weight to ESG KPIs, reinforcing SIPEF's commitment to sustainable and responsible business practices.

Performance period and target structure

The revised Remuneration Policy was approved by the board of directors upon the proposal of the remuneration committee and will be submitted for approval to the ordinary general meeting on 11 June 2025.

Subject to the approval of the ordinary general meeting on 11 June 2025, the revised Remuneration Policy will apply as of 1 January 2025 until 31 December 2028.

Link to STI or LTI

The ESG-based performance criteria are linked to short-term incentive (STI) remuneration.

Threshold/target/maximum performance definition

The principle that no variable remuneration will be paid to members of the executive committee if the Group incurs a loss in a given year will remain in place.

The directors receive a fixed remuneration that is not linked to the results. The non-executive directors do not receive any variable remuneration or options.

2024 remuneration paid against sustainability KPIs

The total variable remuneration paid to members of the executive committee in 2024 was EUR 1,377 thousand, representing 34.3% of total remuneration (excluding vested share options).

Executive Committee remuneration 2024

Note: The variable remuneration for 2024 was based on the 2023 recurring consolidated result and the management's performance during that year, as the revised Remuneration Policy explicitly introducing ESG KPIs was not yet in effect for 2024.

SIPEF's mission and strategy

Drawing on the experience developed throughout its more than 100-year history, SIPEF consistently produces high-quality and fully traceable palm products and bananas.

The Group is committed to generating economic value for its shareholders and other stakeholders while operating in an environmentally and socially responsible manner.

Sustainability is at the core of SIPEF's business model, and the Group works hard to make a positive contribution to the communities and economies where it operates.

Fundamental to achieving SIPEF's mission are the Group's Guiding Principles and Balanced Growth Strategy.

MISSION

SIPEF produces high-quality, sustainable, and traceable agricultural products, with the aim to diversify into targeted markets and foster a harmonious balance between nature, people and growth.

GUIDING PRINCIPLES

• Reliability and stability • Long-term planning and decision making • Continuous improvement • Sustainable economic growth • Conservation and restoration of the environment • Supporting employees and communities • Value creation for all stakeholders

BALANCED GROWTH STRATEGY

• Production efficiency • Operational excellence • High-quality, sustainable, traceable, certified products • Innovation and early adoption • Environmental stewardship • Respecting employees and communities • Responsible supply chain management • Good business conduct

SIPEF at a glance

SIPEF is a Belgian agribusiness group listed on Euronext Brussels, specialised in the production of sustainable palm products and bananas. In Indonesia and Papua New Guinea, the Group produces palm products including fresh fruit bunches (FFB), crude palm oil (CPO), palm kernels (PK), and crude palm kernel oil (CPKO). SIPEF's banana operations are located in Côte d'Ivoire. The Group is in the final stages of phasing out its operations in rubber, tea, and horticulture.

In 2024, SIPEF had 24 204 employees across five countries around the world. The majority are employed or contracted through the Group's subsidiaries in Indonesia, Papua New Guinea and Côte d'Ivoire.

SIPEF manages a total of 86 757 hectares of own production area. In 2024, its total revenue was KUSD 443 810.

Overview of SIPEF's activities

Palm Oil

SIPEF cultivates oil palms on more than 85 500 hectares of land in Indonesia and Papua New Guinea. Its estates are spread across several locations.

In Indonesia, the Group started cultivation in 1920 at the historical sites of Tolan Tiga in Northern Sumatra. Next, it acquired the sites of Agro Muko, located in Bengkulu province. The sites of Umbul Mas Wisesa group in North Sumatra, were first planted in 2007, with its oil palms reaching the end of their first planting cycle only in 2024.

SIPEF's latest oil palm development is a newer expansion in the province of South Sumatra, which is still mostly in a young mature phase.

To complement its own productions and meet market demand, the Group also sources from partner smallholder producers operating on 6 196 hectares near its own sites across Indonesia.

In Indonesia, SIPEF's commercial activities are managed by the Group's subsidiary PT Tolan Tiga Indonesia.

In Papua New Guinea, SIPEF started cultivating oil palms in 1978 in the province of West New Britain, a region known for its high yielding volcanic soils.

SIPEF's activities In Papua New Guinea are managed by its subsidiary Hargy Oil Palms Ltd.

Oil palm fresh fruit bunches (FFB) are grown and harvested across these areas before being processed into crude palm oil (CPO), palm kernels (PK) and crude palm kernel oil (CPKO). SIPEF owns ten processing mills: seven located at its sites in Indonesia, and three in Papua New Guinea.

CPO is SIPEF's main product, accounting for 98.2% of the Group's gross profit. 100% of the CPO produced in Papua New Guinea is exported to Europe. Of its Indonesian production, 7.6% is exported for sale to European customers, and the remaining 92.4% is sold to customers locally.

In 2024, the Group's palm oil related activities accounted for 89.3% of its total revenue.

Bananas

SIPEF started growing the Cavendish variety of bananas in Côte d'Ivoire in 1985.

By the end of 2024 these have become five connected estates, which cover an area of 1 257 hectares in the southern Lagunes Region of the country.

SIPEF's bananas are selected and packed for export at one of SIPEF's seven packing stations, located on its estates. Around 90.0% of the Group's banana production is exported for sale in the United Kingdom and on the European market, with the remainder being sold regionally, in West Africa.

SIPEF's activities in Côte d'Ivoire are managed by its subsidiary Plantations J. Eglin SA, which is one of three major players within the banana export sector in the country.

As the Group's second largest activity, banana cultivation accounted for 9.6% of its total revenue in 2024.

Rubber and tea

SIPEF started phasing out its operations in rubber and tea in 2021. Less than 1% of the Group's revenue in 2024 came from its residual production of these crops. The phase out will be completed in 2025.

Banned products

SIPEF does not produce any products that are banned in certain markets, nor is SIPEF active in fossil fuel sectors, chemicals production, controversial weapons, or the cultivation and production of tobacco.

Interests and views of stakeholders

Stakeholder mapping and engagement process

As part of SIPEF's double materiality assessment process, stakeholder mapping and engagement planning was conducted in Phase 1. SIPEF's key stakeholders were mapped, and existing engagement frameworks reviewed. Additionally, a plan was developed for any additional stakeholder and expert engagement that would be needed for the materiality process.

Stakeholder consultation approach

Stakeholder and expert consultation played a vital role in SIPEF's materiality process. The identification of IROs was informed by comprehensive desktop research, as well as materiality workshops conducted in 2022 and 2023 in the countries of operation. These workshops provided a platform for regional sustainability teams, employees, and internal experts from relevant departments to discuss key sustainability matters. Moreover, regional sustainability teams provided their scoring assessments of the IROs.

The desktop research was conducted using a list of key stakeholder organisations as a guide to review relevant online and offline materials. During its stakeholder mapping exercise, SIPEF evaluated that these organisations and their associated published materials would serve as appropriate proxies for affected stakeholders, particularly workers in the agricultural sector, local communities, consumers, and nature.

Relevant information from existing stakeholder engagement materials was also reviewed. This included social impact assessments conducted with communities surrounding SIPEF's operations, as well as criteria from previous customer and investor ESG questionnaires, and sustainability ratings and benchmarks.

SIPEF engaged with internal and external experts on very specific sustainability matters through interviews and, for climate and biodiversity-related topics, assessments of impacts, dependencies, risks, and opportunities.

Key stakeholder groups and engagement approaches

Affected stakeholders

Nature

• Relevance: Nature provides essential resources for cultivation, ecosystem services, and influences the health and productivity of plantations. Environmental impacts linked to SIPEF's activities could also affect the Company's reputation.
• Purpose: Assessing actual and potential impact on the natural environment; Improving environmental practices towards responsible production
• Engagement approach: Engagement with environmental experts/organisations, who serve as proxies for nature as a key stakeholder. Climate and biodiversity experts to conduct physical climate and biodiversity impact, dependencies, risks and opportunities assessments, and review SIPEF's climate-related targets. Technical consultants who carry out integrated HCV-HCSA assessments, Environmental Impact Assessments, and deforestation and fire monitoring. Science-based conservation organisations, such as the Zoological Society of London (ZSL) and SINTAS Indonesia, who have provided technical support and training on tiger monitoring under the SIPEF Biodiversity Indonesia programme (SBI). Environmental NGOs, to gather information on the latest sustainable agricultural practices, through participation in RSPO working groups, meetings at RSPO annual conferences, and desktop research.
• Response to engagement outcomes: Climate and biodiversity assessment results have informed SIPEF's double materiality analysis and the development of the Group's climate transition plan. Assessment and monitoring findings by technical consultants inform SIPEF's due diligence on its NDP commitment, as well as management plans for conservation areas. Training and support from ZSL and SINTAS have been utilised to improve tiger monitoring at SBI. Key publications and studies by NGOs help inform the materiality of sustainability matters.

Employees

• Relevance: With over 24,000 employees, SIPEF's workforce is the driving force behind its success and central to its operations and the successful implementation of its strategy.
• Purpose: Ensure compliance with human and labour rights policies; Address employee needs and grievances through structured mechanisms; Engage staff on workplace rights, well-being, and fair treatment; Provide essential services such as housing, healthcare, and education; Promote sustainability awareness and responsible workplace practices
• Engagement approach: Direct engagement with employees, or via trade unions and social experts/organisations, who serve as proxies. Risk assessments and training programmes, covering health and safety, sustainability, best management practices, and policy implementation to ensure compliance and continuous improvement. Trade unions, through annual, quarterly and ad-hoc meetings to discuss collective bargaining agreements, wages, and working conditions. Annual appraisals, to provide employees with performance evaluations, feedback, and development opportunities to support career growth. Social experts, for assistance in addressing grievances, evaluating gaps in labour practices, and improving relevant policies. Social NGOs and academic institutions, engaged to gather insights on leading frameworks and best practices through desktop research. SIPEF's grievance mechanism, which employees can engage directly through accessible channels to raise grievances or provide feedback.
• Response to engagement outcomes: Health and safety risk assessments inform management plans, as well as training content and frequency. Feedback from trade union meetings is reviewed by HR departments in each country of operation, with actions taken to align agreements and workplace conditions as needed. Grievances, and any corresponding recommendations from social experts, shape action plans. Past and ongoing grievances have also contributed to SIPEF's double materiality analysis. Desktop research findings help determine the materiality of sustainability matters.

Smallholder suppliers

• Relevance: Smallholders contribute significantly to SIPEF's FFB supply and global palm oil production. They ensure a stable supply chain and have the potential to enhance the overall sector.
• Purpose: Support smallholders to improve their production and livelihoods, and integrate sustainability practices with the aim to achieve RSPO certification; Engage smallholder suppliers in best management practices around optimising yields, soil health, correct pesticide use and biodiversity protection
• Engagement approach: Engagement with smallholders, primarily through SIPEF's smallholder departments and sustainability teams in Indonesia and Papua New Guinea. Smallholder programmes, through which SIPEF conducts training, shares best management practices, supplies [information incomplete in excerpt]. Monitoring and audits, carried out internally and by third parties, ensure compliance with supplier requirements, including no deforestation and RSPO certification. A Local Planning Committee (LPC), comprising of HOPL, a local government body, and research and smallholder representative organisations, coordinates R&D, agronomic services, training, and community development support for smallholders.
• Response to engagement outcomes: Assessment and monitoring findings support SIPEF's due diligence on Responsible Purchasing Policy implementation, including smallholder compliance with RSPO [information incomplete]. LPC meetings facilitate stakeholder engagement and collaboration between key stakeholders within the industry, leading to initiatives such as streamlining land title transfers, improving law and order, and implementing community-focused social programmes to support sustainable development and livelihoods.

Affected communities

• Relevance: Local communities can be directly impacted by operations through land use, environmental changes, employment opportunities, and social dynamics. Engagement strengthens social licence to operate, reduces conflicts, and enables targeted support.
• Purpose: Understand and address community grievances and concerns; Understand and support needs related to employment and community development
• Engagement approach: Direct engagement with communities through community engagement departments, or via social experts and organisations, who serve as proxies. Social experts and licenced assessors, engaged to guide SIPEF's FPIC processes with communities, ensuring transparent and inclusive decision-making prior to any new land development. Internal and external social experts, who carry out social impact assessments (SIAs) to evaluate and address the effects of operations on communities. Community programmes, supporting local development, well-being, and economic empowerment. Social NGOs and academic institutions, engaged to gather insights on leading frameworks and best practices through desktop research. SIPEF's grievance mechanism, which communities can engage directly through accessible channels to raise grievances or provide feedback.
• Response to engagement outcomes: Management plans are developed based on the results of SIAs. Integrated Conservation Land Use Plans are informed by FPIC results, and no new land is developed without the consent of affected communities. Confirmed grievances are followed up by action plans to address them. Past and ongoing grievances have also contributed to SIPEF's double materiality analysis. Desktop research findings help determine the materiality of sustainability matters.

Consumers

• Relevance: Consumers shape demand, particularly in SIPEF's key markets, the EU and UK, where quality and sustainability expectations are high.
• Purpose: Understand evolving market expectations on food safety, quality, and sustainability standards
• Engagement approach: Insights on consumer concerns are gathered through customers who act as proxies, as SIPEF operates upstream and does not produce consumer goods, or market directly to consumers.
• Response to engagement outcomes: Since 2022, SIPEF has increased its focus on quality, particularly food safety, as part of its broader business strategy. This shift addresses various industry priorities, including consumer health concerns about contaminants in palm oil.

Users of annual report and other key stakeholders

Customers

• Relevance: Customers are critical to SIPEF's business as they purchase its products and set requirements for certification and purchasing policies.
• Purpose: Understand customer needs and expectations; Communicate developments in quality and sustainability across SIPEF's production practices and products; Collaborate on pilot projects to test innovative solutions to shared challenges
• Engagement approach: Direct engagement with customers through marketing department, fruits department, and sustainability teams. Customer meetings, to align on expectations, requirements, and sustainability commitments. ESG questionnaires, that assess SIPEF's compliance with customer policies. Knowledge exchange, through meetings with customers' sustainability teams, to share best practices and industry developments. Desktop research, including policy reviews, sustainability reports, and websites, to gather insights and benchmark customer priorities.
• Response to engagement outcomes: Customer requirements and priorities have contributed to SIPEF's strategy to focus on high quality, traceable, and sustainable certified palm oil. Engagement and feedback from customers prepares SIPEF for new and emerging market trends. Desktop research and benchmark results have informed the validation process of SIPEF's double materiality assessment.

Peers

• Relevance: Peers can indicate the benchmarks for sustainability already being set for the industry.
• Purpose: Benchmark sustainability performance to align with industry standards; Exchange knowledge and best practices to drive continuous improvement
• Engagement approach: Direct and indirect engagement through knowledge exchange, via meetings with customers' sustainability teams, to share best practices and industry developments. Desktop research, including policy reviews, sustainability reports, and websites, to gather insights and benchmark priorities.
• Response to engagement outcomes: Desktop research findings and benchmark results have supported the identification and prioritisation of the materiality of sustainability matters.

Shareholders and investors

• Relevance: Shareholder and investors Contribute to the financial foundation for SIPEF's business and set key requirements that shape its policies and strategic decisions.
• Purpose: Share updates on SIPEF's strategy, business, financial and sustainability performance; Build trust through open dialogue, disclosure and transparency; Understand expectations on financial and sustainability performance
• Engagement approach: Direct engagement with SIPEF's main shareholder, Ackermans & van Haaren (AvH) including regular meetings and workshops, organised by AvH and involving the sustainability team and their other participations, featuring ESG retrospective and forward-looking sessions, as well as ESG workshops. ESG questionnaire and annual ESG meeting, to review SIPEF's sustainability progress in relation to shareholder expectations and requirements. Board representation, providing SIPEF with strategic direction. Engagement with other shareholders and banks through financial and sustainability reporting, including interim reports, and the integrated annual report. ESG questionnaires, from banks to assess [information incomplete].
• Response to engagement outcomes: Requirements and feedback have influenced policy development, reporting, and strategic direction. Knowledge sharing and workshops have contributed to the development of SIPEF's double materiality methodology. Discussions and ESG questionnaires have informed the materiality assessment of sustainability matters.

Integration of stakeholder views into strategy and business model

SIPEF's first group-wide double materiality assessment in 2024, which has been informed by the engagement and views of various key stakeholders, has identified key impacts, risks, opportunities, and material sustainability matters for the Company. Following the assessment, SIPEF has refined its focus areas, priorities, and sustainability goals under the Balanced Growth Strategy to align with the results. The Company has also initiated a comprehensive review of its sustainability targets, KPIs, and policies, with the process set to continue in 2025 and 2026. This review exercise has the potential to modify the views of key stakeholders.

Governance of stakeholder engagement

SIPEF's executive committee and board of directors remain informed about stakeholder views on material sustainability matters through regular reporting and briefings. These include findings from risk assessments, certification audits, and sustainability ratings and benchmark results, which support strategic decision-making.

Additionally, the executive committee played a key role in the validation of SIPEF's double materiality assessment, while the board was responsible for its approval. The assessment incorporated stakeholder views and included benchmarking insights to support the validation process.

Through these reporting mechanisms and processes, SIPEF ensures that its management and supervisory bodies remain well-informed and responsive to stakeholder concerns, aligning sustainability priorities with the company's long-term direction.

Material impacts, risks and opportunities and their interaction with strategy and business model

Material IROs identified through double materiality assessment

SIPEF completed its first group-wide double materiality assessment in May 2024. The assessment identified nine topics and 45 sustainability matters as material at the group level. Circular economy was the only topic assessed as not material.

The assessment considered SIPEF's own operations and upstream and downstream value chain to identify material IROs, evaluating all sustainability matters required under ESRS 1 Appendix A. The analysis covered all of the Group's palm activities in Indonesia and Papua New Guinea, and banana production activities in Côte d'Ivoire.

Material sustainability matters by focus area

Environmental stewardship:

• E1: Climate Change (climate change mitigation, climate change adaptation, energy)
• E2: Pollution (pollution of air, pollution of water)
• E3: Water and marine resources (water consumption)
• E4: Biodiversity and ecosystems (land-use change, land degradation, species population size, species global extinction risk)

Respecting employees and communities:

• S1: Own workforce (secure employment, working conditions, equal treatment and opportunities for all, health and safety, work-life balance, training and skills development)
• S2: Workers in the value chain (working time, adequate wages)
• S3: Affected communities (economic, social and cultural rights of communities, land and resource rights of communities)
• S4: Consumers and end-users (consumer health and safety, consumer data protection)

Good business conduct:

• G1: Business conduct (corporate culture, incidents and breaches of laws and regulations, anti-corruption and anti-bribery)

Linkage between IROs and strategy/business model

Interaction with business model

SIPEF's Balanced Growth Strategy integrates sustainability and business priorities through four interconnected focus areas:

Business focus areas:

• Production efficiency
• Operational excellence
• High quality, sustainable, traceable, certified products
• Innovation and early adoption

Sustainability focus areas:

• Environmental stewardship
• Respecting employees and communities
• Good business conduct
• Responsible supply chain management

The material IROs identified inform SIPEF's sustainability goals under each focus area. For example:

Environmental stewardship goals:

• GHG emissions reduction and long-term climate resilience
• Minimise impacts on natural resources and the environment
• Sustainable land use and biodiversity conservation, including no deforestation and no new developments on peat

Respecting employees and communities goals:

• Zero fatalities and injuries
• Living wage and better working conditions for all employees
• Community well-being and development

Good business conduct goals:

• Zero incidents of corruption and bribery
• Zero human rights violations across the value chain

Responsible supply chain management goals:

• 100% traceable and sustainable supply chain
• Support smallholders on the path to certification

Value chain integration

For SIPEF's own operations, all goals apply universally across product groups and geographical areas. For SIPEF's value chain, key product groups (palm oil and bananas) and customer segments are specified, with sustainability matters assessed for upstream and downstream activities directly relevant to supplying SIPEF or producing, transporting, or selling SIPEF's products.

Key material risks and opportunities

Land-use change (deforestation)

Risk: Palm oil's potential and actual association with deforestation and biodiversity loss presents a material risk to SIPEF, as rising expectations for deforestation-free supply chains among regulators, buyers, and financial institutions may affect the Group.

Opportunity: With limited scope for new land developments, companies will need to increase productivity on existing plantations by adopting improved technologies. Advancements in F1 hybrid varieties, nutrition and soil management, and pest control will be key to achieving higher yields per hectare.

SIPEF's approach: SIPEF addresses deforestation risks by implementing its NDP commitment (effective since 31 December 2015), robust land use assessments, monitoring across its operations and supply chain, and targeted conservation practices. The Group addresses both the risk and opportunity by focusing on yield improvements on existing plantations through enhanced seed technology, soil management, and pest control.

GHG emissions and climate change

Impact: SIPEF's operations generate GHG emissions mainly from land use change including cultivation in organic soils, palm oil mill effluent (POME), and inputs such as fuel and fertilisers. Approximately 98% of SIPEF's GHG emissions come from cultivation and processing of oil palm products.

Risk: Climate physical risks identified include coastal flooding in Papua New Guinea (near-term), river flooding in Papua New Guinea and Côte d'Ivoire (medium-term), and heatwaves in Côte d'Ivoire (long-term). Transition risks include land use restrictions, carbon pricing, and growth constraints due to land availability.

Opportunity: Increased demand for palm oil, increased land valuation, and emerging carbon markets to support afforestation, forest restoration, and conservation represent significant potential financial gains.

Secure employment and living wage

Positive impact: SIPEF provides employment to over 24,000 employees in countries and areas with higher unemployment and poverty rates. Employees hired under permanent contracts (68% of workforce) have more stable and secure incomes, increasing their and their families' socio-economic well-being.

Challenge in value chain: Smallholders in SIPEF's palm oil supply chain often earn modest incomes while supporting multiple household members, creating financial challenges.

Resilience of strategy and business model

SIPEF's climate risk assessments confirm the resilience of agriculture despite potential climate challenges. The qualitative assessment identified no immediate material biodiversity-related physical, transition, or systemic risks to SIPEF's business. However, potential future risks and impacts require continuous monitoring, with relevant mitigation measures integrated into the Group's business plan.

The assessment highlighted long-term operational dependencies on ecosystem services such as pollination, water regulation, and soil fertility, which are essential to the resilience of SIPEF's operations. Addressing these dependencies aligns with SIPEF's ongoing implementation of sustainable land-use and best management practices.

Time horizons

SIPEF applies the following time horizon definitions for reporting purposes:

Standard definitions:

• Short-term: 1–3 years
• Medium-term: 4–10 years
• Long-term: 11–25 years

Climate change assessments: Given the 25-year lifecycle of an oil palm, alternative definitions were applied for climate-related IROs to provide a more accurate representation of long-term impacts.

Current and anticipated financial effects

In line with its double materiality assessment, SIPEF has assessed the likelihood of the identified impacts and risks occurring, together with their potential financial impacts. SIPEF has assessed that these impacts and risks are not expected to have a material financial impact on the Group, including its financial position, financial performance and cash flows. Nevertheless, the Group has implemented effective measures to mitigate these risks.

Amendments to strategy and business model

Following the 2024 double materiality assessment, SIPEF has refined its focus areas, priorities, and sustainability goals under the Balanced Growth Strategy to align with the results. The Company has also initiated a comprehensive review of its sustainability targets, KPIs, and policies, with the process set to continue in 2025 and 2026. This review exercise has the potential to modify the views of key stakeholders.

The executive committee and board of directors remain informed about stakeholder views on material sustainability matters through regular reporting and briefings, including findings from risk assessments, certification audits, and sustainability ratings and benchmark results.

Due diligence integration

SIPEF's due diligence framework is integral to how it identifies, assesses, and manages ESG impacts, risks, and opportunities. The framework ensures these are upheld, with leadership and management teams collaboratively managing risks and mitigating impacts. Regular reviews and reporting mechanisms further drive accountability and continuous improvement.

Key components:

1. Impacts and risks identification and assessment: The double materiality assessment is a foundational component, supported by inputs from teams in each country of operation and external risk assessments. At operational level, each subsidiary employs tailored mechanisms reflecting local contexts, unified by adherence to RSPO (palm operations) and Rainforest Alliance, Fairtrade, GLOBALG.A.P., and SMETA (banana operations).

2. Mitigation measures and continuous improvement: Training programmes, capacity-building initiatives, research development and innovation, and adoption of best practices foster continuous improvement.

3. Monitoring, evaluation, and reporting: Internal measures include on-the-ground surveys, audits, and grievance channels. External efforts involve impact assessments, stakeholder engagement, and third-party monitoring and certification. Increasingly, SIPEF develops digital tools including satellite surveillance for deforestation and fires, and the SIPEF Grievance Solutions platform.

4. Engaging with affected stakeholders: Stakeholder engagement is integral to all stages of identifying, addressing, and mitigating ESG risks and impacts. This includes a grievance mechanism with whistleblower protection and proactive community engagement.

5. Addressing actual adverse impacts: When actual adverse impacts are identified through monitoring or stakeholder feedback, SIPEF develops action plans to address non-conformities or ineffective actions.

Description of the process to identify and assess material impacts, risks and opportunities

Overview

In 2024, SIPEF completed its first Group-wide double materiality assessment, marking a significant milestone in its compliance journey with the CSRD. The materiality assessments from the last two reporting periods focused primarily on impact materiality and were guided by the requirements of the Global Reporting Initiative (GRI).

The 2024 assessment identified sustainability matters that are material from both impact and financial perspectives, evaluating the ESG impacts of the Group and its value chain, as well as ESG-related financial risks and opportunities. This comprehensive process was a collaborative effort involving SIPEF's sustainability teams, finance department, and an external consultant, and it was fully integrated into SIPEF's business impacts, risks, and opportunities assessment framework.

Scope of Assessment

In line with requirements of the ESRS, the assessment considered 10 topics and 93 sustainability matters. It was conducted in three main phases over the period from the third quarter of 2023 to the third quarter of 2024.

The analysis covered all of the Group's palm activities in Indonesia and Papua New Guinea, and banana production activities in Côte d'Ivoire, recognising that all of these activities in these locations carry some risk of adverse impacts. Tea and rubber activities were excluded, as these activities are being phased out, and their associated risks are considered limited.

Three-Phase Methodology

Phase 1: Mapping and Understanding (Q3 - Q4 2023)

1. Stakeholder mapping and engagement plan: SIPEF's key stakeholders were mapped, and existing engagement frameworks reviewed. Additionally, a plan was developed for any additional stakeholder and expert engagement that would be needed for the materiality process.

2. Value chain mapping: A high-level mapping of SIPEF's value chain was conducted and the various stakeholders at each step researched.

3. Relevance mapping: An initial relevance assessment was performed using the topics listed in Appendix A of ESRS 1, which included inputs from some of SIPEF's regional sustainability teams.

4. Benchmarking exercise: Material and reported topics of peers and customers were reviewed and compared in a benchmarking exercise, the results of which would inform SIPEF's process at a later phase.

Phase 2: Identification and Assessment of IROs (Q1 - Q2 2024)

Identification of IROs

• Long-list of impacts: Based on desktop research, findings from previous workshops and stakeholder consultations, and in-house expertise, two long-lists of actual, potential, positive, and negative impacts of SIPEF's operations were created—one for its palm operations and one for its banana operations. These lists were developed using the list of relevant ESRS sustainability matters identified in Phase 1. Additionally, each impact was categorised as short-, medium-, or long-term.

• Long-list of risks and opportunities: A long-list of risks and opportunities was developed for SIPEF's operations using the list of Business Risks approved by the SIPEF audit committee and board of directors, in conjunction with the list of relevant sustainability matters identified in Phase 1. In the case of biodiversity- and climate-related topics, the results of expert and internal impacts, dependencies, risks, and opportunities assessments were incorporated in the list. Links between the risks and opportunities and impacts and dependencies were reviewed and recorded during this exercise.

Impact materiality assessment

• Scoring mechanism: A consultant was engaged to support SIPEF on the overall methodology of the process, and in the development of specific elements, including the scoring mechanism for impact materiality. As per the ESRS requirements, the mechanism was developed to assess:
  • severity (scale, scope, and irremediability) of actual negative impacts
  • severity and likelihood of potential negative impacts
  • scale and scope of actual positive impacts
  • scale, scope, and likelihood of potential positive impacts

The scoring criteria used a scale from 1 to 5, with separate criteria for environmental impacts and for social and governance-related impacts.

• Impacts assessment process: The long-lists of impacts associated with SIPEF's operations, tailored separately for palm and banana operations, were incorporated into feedback and assessment templates, which integrated the aforementioned scoring mechanism. These templates were distributed to sustainability teams at the country level and to several internal experts, including the climate and biodiversity consultants, for their assessment. The internal expert teams evaluated and scored the impacts, and the results of climate and biodiversity assessments were integrated, with each internal team applying the same scoring methodology. Final scores were consolidated by the sustainability teams in coordination with external experts.

Financial materiality assessment

• Risks and opportunities assessment process: The results of the risks and opportunities assessment carried out separately by the finance team were incorporated in a consolidated template to capture both impact materiality and financial materiality results. This included:
  • a quantitative assessment of the magnitude of the financial effect
  • a qualitative assessment of the likelihood of the effect

The assessment was carried out by key internal departments (finance, sustainability, operations, legal and HR) through a collaborative process with an external consultant. The teams evaluated and scored the risks and opportunities, and the final results were integrated into a central template.

Value chain materiality assessment

Activities and actors from both upstream and downstream in SIPEF's value chains, segmented by crop (oil palm and banana), were assessed for IROs. The assessment began with a qualitative evaluation to identify the most significant impacts likely to occur, considering the nature and geographies of each key actor's business, and the associated risk of adverse impacts. The focus was on activities directly relevant to supplying SIPEF (upstream) or producing, transporting, or selling SIPEF's products (downstream), with all other activities deemed out of scope.

Sustainability matters related to value chain actors were excluded from scope if:

• the sustainability matters were not deemed relevant
• risk of significant IROs was limited to none

SIPEF's smallholder suppliers are among the most important actors in SIPEF's palm value chain and were assessed as part of the main materiality process, specifically in relation to sustainability matters under ESRS S2, 'Workers in the Value Chain'. Environmental and business conduct impacts for smallholders were evaluated alongside the broader value chain.

Phase 3: Consolidation, Validation, and Next Steps (Q2 - Q3 2024)

1. Compiling and consolidating results: The final impact materiality assessment and financial materiality assessment results were brought together in a single overview. Sustainability matters exceeding the set thresholds for either impact or financial materiality were identified. A sustainability matter was deemed material if it surpassed the threshold for either impact or financial materiality.

2. Validation and approval of results: Validation and approval at the executive management level was carried out through workshops where members of the SIPEF executive committee, along with the GST, reviewed the final scores for each sustainability matter. The process considered benchmarking results, scoring inputs from the different teams and experts, and previously reported material topics. Final decisions and their rationales were clearly documented.

3. Identification of material information for disclosure: To identify the material information needed for disclosure and to assess SIPEF's maturity against the ESRS disclosure requirements, a gap analysis and mapping exercise was conducted. This exercise identified gaps, and the action plans needed to address them. Disclosure requirements linked to sustainability matters not deemed material through the double materiality assessment were also filtered out during this process.

4. Review and alignment of policies, actions, and targets: A mapping of policies, actions, targets, and KPIs has been carried out at Group level and at country level to ensure alignment with the results of the double materiality assessment.

Inputs to the Assessment

The assessment utilized multiple inputs:

• Sector benchmarks: Benchmarking exercise reviewing material and reported topics of peers and customers
• ESRS guidance: Topics listed in Appendix A of ESRS 1
• Internal experts: Regional sustainability teams, finance department, operations, legal and HR departments
• External consultants: Engaged to support overall methodology, scoring mechanisms, climate and biodiversity assessments
• Stakeholder consultation:
  • Desktop research using key stakeholder organisations to review relevant materials
  • Materiality workshops conducted in 2022 and 2023 in countries of operation with regional sustainability teams, employees, and internal experts
  • Participatory mapping conducted during consultations with affected communities as part of HCV-HCSA assessment process
  • Review of social impact assessments with communities surrounding operations
  • Customer and investor ESG questionnaires
  • Sustainability ratings and benchmarks
  • Expert interviews for specific sustainability matters

Stakeholder and Expert Consultation

Stakeholder and expert consultation played a vital role in SIPEF's materiality process. The identification of IROs was informed by comprehensive desktop research, as well as materiality workshops conducted in 2022 and 2023 in the countries of operation. These workshops provided a platform for regional sustainability teams, employees, and internal experts from relevant departments to discuss key sustainability matters. Moreover, regional sustainability teams provided their scoring assessments of the IROs.

The desktop research was conducted using a list of key stakeholder organisations as a guide to review relevant online and offline materials. During its stakeholder mapping exercise, SIPEF evaluated that these organisations and their associated published materials would serve as appropriate proxies for affected stakeholders, particularly workers in the agricultural sector, local communities, consumers, and nature.

Relevant information from existing stakeholder engagement materials was also reviewed. This included social impact assessments conducted with communities surrounding SIPEF's operations, as well as criteria from previous customer and investor ESG questionnaires, and sustainability ratings and benchmarks.

Lastly, SIPEF engaged with internal and external experts on very specific sustainability matters through interviews and, for climate and biodiversity-related topics, assessments of impacts, dependencies, risks, and opportunities.

Scoring Criteria

Impact Materiality

The scoring mechanism was developed to assess:

• Severity (scale, scope, and irremediability) of actual negative impacts
• Severity and likelihood of potential negative impacts
• Scale and scope of actual positive impacts
• Scale, scope, and likelihood of potential positive impacts

The scoring criteria used a scale from 1 to 5, with separate criteria for environmental impacts and for social and governance-related impacts.

Financial Materiality

• Quantitative assessment of the magnitude of the financial effect
• Qualitative assessment of the likelihood of the effect

Threshold for Materiality

Sustainability matters exceeding the set thresholds for either impact or financial materiality were identified. A sustainability matter was deemed material if it surpassed the threshold for either impact or financial materiality.

Results of Assessment

SIPEF's double materiality process identified nine topics, and 45 sustainability matters as material at the group level. Circular economy was the only topic assessed as not material, as SIPEF neither manufactures products nor engages in services relevant to this topic.

The results of the assessment were presented as part of SIPEF's business IROs assessment, which is reviewed annually by the board through the audit committee. The full scope of results was subsequently approved by the board.

An overview of the material IROs is provided in Section 5 on SIPEF's internal control and risk management systems in the Corporate Governance Statement. Detailed descriptions of specific material IROs, along with all information required under the ESRS 2 disclosure requirement SBM-3, are provided within the disclosures under the corresponding topical ESRS for each relevant sustainability matter.

Frequency and Review

The financial year 2024 marks the first year SIPEF has conducted a double materiality assessment. The business IROs assessment is reviewed annually by the board through the audit committee.

Use of Value Chain Mapping

A high-level mapping of SIPEF's value chain was conducted and the various stakeholders at each step researched during Phase 1.

Activities and actors from both upstream and downstream in SIPEF's value chains, segmented by crop (oil palm and banana), were assessed for IROs. The assessment began with a qualitative evaluation to identify the most significant impacts likely to occur, considering the nature and geographies of each key actor's business, and the associated risk of adverse impacts.

Transition plan for climate change mitigation

Overview

As an agriculture company, SIPEF has a goal to reduce its GHG emissions and build long-term climate resilience. This goal falls under the Group's environmental stewardship focus area, which is part of SIPEF's Balanced Growth Strategy. To achieve this goal, the Group will implement a comprehensive climate transition plan that integrates sustainable energy practices, circular economy principles, optimised land use, and water resource management, while protecting biodiversity. This approach contributes to fostering a sustainable, low-carbon future for the oil palm industry.

Scope of the plan

Organisational boundary: SIPEF reports its emissions and removals based on an organisational boundary that covers all its operations listed in the consolidated financial statements in the following locations: Belgium, Indonesia, Côte d'Ivoire, Papua New Guinea, and Singapore. The scope includes all activities in the processing and cultivation of palm oil and bananas. This comprises:

• Scope 1 and Scope 2: plantations, mills and packing stations that are owned and managed by SIPEF
• Scope 3: indirect upstream and downstream emissions associated with value chain activities relevant to SIPEF

The scope of the Company will be expanded or reviewed if there are additional processing activities reported under the consolidated assets.

Approximately 98% of SIPEF's GHG emissions come from the cultivation and processing of oil palm products. Banana production does not make a big contribution, accounting for just 2% of SIPEF's overall gross GHG emissions.

Targets

Emission reduction target:

• 28% reduction in net emissions intensity from 2021 baseline by 2030 (Scope 1 & Scope 2) for oil palm operations, which will be revised to align with ESRS requirements as a next step.

Note: The target was set prior to this reporting period and is not included in the scope of the CSRD limited assurance conducted for this Sustainability Statement. It will be revised in 2025 to align with the requirements of the ESRS.

In 2025, a process will begin to align this target with the ESRS on a gross emissions basis and with an updated baseline calculation using the ISO 14061-1 as a framework and aligning with the GHG Protocol methodology. This updated target will be used in the development of a climate change mitigation transition plan.

Paris alignment and scenario analysis

Climate transition scenarios:

Three climate transition scenarios were analysed for their potential effects on SIPEF's business in the short-term (0-3 years), medium-term (by 2030), and long-term (by 2050). These scenarios were implemented using the open-source Model of Agricultural Production and its Impact on the Environment (MAgPIE) (Dietrich et al., 2019) developed at the Potsdam Institute for Climate Change (PIK):

• Modest ambition: assumes greater global action and ambition but still inadequate, leading to warming of around 3°C by 2100, with the imposition of modest GHG emissions costs on palm oil producers
• Aggressive ambition: assumes the greatest global effort, limiting warming to 1.5°C by 2100, in line with the Paris Agreement. This includes strong government action in Indonesia, such as industry-wide NDPE restrictions, peatland reclamation, and aggressive costs on GHG emissions imposed

Key decarbonization levers

Operational targets:

• Methane capture: install methane capture at all mills by FY2030 (baseline: 5 mills; target: 10 mills in Indonesia and Papua New Guinea)
• Site-based monitoring: GHG emissions monitoring through direct measurements at all the organic soil estates by 2028 (baseline: 0; target: 3 estates in Indonesia)
• Rainwater harvesting: Installation of rainwater harvesting system at all palm oil mills by 2030 (baseline: 0; target: 10 mills in Indonesia and Papua New Guinea)

Land use and carbon stocks:

• Protection of coastal shorelines and prevention of flooding through buffer restoration of 41.5 hectares by 2027 in oil palm operations (6.5 hectares in Papua New Guinea; 35 hectares in Indonesia)
• Regenerative agriculture pilots with a model to scale up at five sites by 2026 in oil palm operations (Indonesia and Papua New Guinea)

Policy commitments:

SIPEF has committed to no deforestation or new plantings on peatland (NDPE) since 2015 in order to reduce emissions from land use change. All new oil palm projects are developed only after integrated HCV-HCSA assessments have been conducted, and areas identified for conservation are monitored and maintained in accordance with the management plan agreed with relevant stakeholders. Best management practices will continue to be implemented on existing cultivated areas and any new developments will be following SIPEF's NDPE policy.

Locked-in emissions and stranded assets

SIPEF acknowledges that GHG emissions associated with existing assets may present challenges in meeting its long-term emission reduction targets. However, by proactively addressing these potential risks by implementing its policy on no deforestation or new plantings on peatland NDPE and applying best practices of managing these areas identified within its operations, SIPEF is better positioned to manage transition risks and align with evolving regulatory and investor expectations.

Financial effects and resilience

SIPEF has considered climate-related risks in the preparation of its financial statements, and through the financial reporting process, no critical climate-related assumptions were identified. As a result, the climate scenarios used in the broader climate risk assessment are not directly connected to specific assumptions in the financial statements.

In line with its double materiality assessment, SIPEF has assessed the likelihood of the identified impacts and risks occurring, together with their potential financial impacts. SIPEF has assessed that these impacts and risks are not expected to have a material financial impact on the Group, including its financial position, financial performance and cash flows. Nevertheless, the Group has implemented effective measures to mitigate these risks.

Key medium- and long-term risks and opportunities for SIPEF include land use restrictions, growth constraints due to land availability, and carbon pricing set by external parties, which must be considered in future business planning for oil palm and banana operations. Principal opportunities identified include increased demand for palm oil, increased land valuation, and emerging carbon markets to support afforestation, forest restoration, and conservation, all of which would represent significant potential financial gains to SIPEF.

SIPEF's climate risk assessments confirm the resilience of agriculture rather than compromise its feasibility, despite the fact that certain climate challenges may occur. These findings highlight the importance of integrating climate considerations into SIPEF's operations. With proactive adaptation strategies in place, any challenges can effectively be managed while maintaining robust production. SIPEF's commitment to reducing GHG emissions and enhancing long-term climate resilience through research and development on climate mitigation and adaptation ensures the resilience of its strategy and business model.

Reporting limitations

Gross GHG emissions were reported for the first time in 2024. Prior to 2024, only net emissions were calculated, and the disclosed target was based on net values. Recalculation of historical data and development of gross-based targets are underway.

In the meantime, SIPEF actively monitors GHG emissions across its operations. By tracking key emission sources, the Group is able to assess progress, identify areas for improvement, and prepare for future target-setting in line with evolving regulatory requirements and stakeholder expectations. This demonstrates SIPEF's ongoing commitment to responsible management of climate-related risks and impacts.

Policies related to climate change mitigation and adaptation

SIPEF discloses two policies applicable to climate change mitigation and adaptation:

Responsible Plantations Policy (RPP)

• Scope: Applicable to plantation operations, including oil palm operations
• Key content: The policy outlines SIPEF's commitment to minimising environmental impact and includes measures for:
  • GHG emissions monitoring and reduction
  • Protection of coastal shorelines and prevention of flooding through buffer restoration
  • Implementation of regenerative agriculture
  • Water resource management (rainwater harvesting systems and water recycling)
  • Biodiversity protection

Responsible Purchasing Policy (RPuP)

• Scope: Applicable to purchasing activities
• Key content: Supports climate change mitigation objectives in the upstream value chain

Implementation and oversight

The policies are implemented through SIPEF's Balanced Growth Strategy, under the environmental stewardship focus area. The company monitors GHG emissions across its operations to assess progress and identify areas for improvement. SIPEF conducts regular consultations with affected communities and performs double materiality assessments to identify material sustainability matters, including climate change mitigation and adaptation.

The company is developing a comprehensive climate transition plan that integrates sustainable energy practices, circular economy principles, optimised land use, and water resource management. However, specific details on policy approval bodies, public availability, and linkages to international standards (UNGPs, OECD MNE Guidelines, ILO Conventions, UNGC) are not disclosed in the provided excerpts.

Targets related to climate change mitigation and adaptation

Climate Change Mitigation Targets

Climate Change Adaptation Targets

Other Related Targets

Progress and Key Updates (2024)

• Gross GHG emissions, including Scope 3, were reported for the first time in 2024
• Physical and transition climate risk assessments were carried out in support of the Group's climate transition planning
• The 28% net emissions reduction target was set prior to 2024 reporting period and is not included in the scope of the CSRD limited assurance. It will be revised in 2025 to align with the requirements of the ESRS
• SIPEF states it will begin a process in 2025 to align the GHG reduction target with ESRS on a gross emissions basis and with an updated baseline calculation using ISO 14061-1 as a framework and aligning with the GHG Protocol methodology

Notes

The disclosed 28% reduction target is based on net emissions intensity (Scope 1 & 2) and will be updated to gross emissions basis. Historical data recalculation and development of gross-based targets are underway.

Energy consumption and mix

Scope and methodology

SIPEF's energy consumption covers all activities in the processing and cultivation of palm oil and bananas across operations in Indonesia, Papua New Guinea, and Côte d'Ivoire. This includes Scope 1 and Scope 2 operations: plantations, mills and packing stations that are owned and managed by SIPEF.

Energy consumption includes energy from both non-renewable sources (such as fossil fuels and purchased electricity) and renewable sources (such as biomass). In palm oil mills, biomass combustion involves the use of by-product materials such as fibre, shell, and wood as fuel sources. Renewable energy is primarily generated from by-products of milling operations (fibres and shells) using steam turbines, and at one mill, methane capture from palm oil mill effluent (POME) is used with a biogas generator to produce electricity.

Energy intensity is calculated by dividing total energy consumption by net revenue (in thousand USD).

Energy consumption and mix (MWh)

SIPEF's energy consumption is mainly from non-renewable sources (78%), which reflects the fossil fuels used in plantation operations. Renewable energy, primarily from biomass combustion in palm oil processing, accounts for 22% of total energy use. SIPEF did not use nuclear energy in 2024.

Under Regulation (EC) No 1893/2006, agriculture is identified as a high climate impact sector. Accordingly, SIPEF reports its energy consumption intensity, which amounted to 0.33 MWh per thousand USD of revenue in 2024.

Gross Scopes 1, 2, 3 and Total GHG emissions

SIPEF reported gross GHG emissions for the first time in 2024, covering all three scopes in accordance with CSRD and ESRS requirements. The Group's emissions are calculated using the ISO 14064-1 standard and the GHG Protocol methodology.

Scope and methodology

The organisational boundary covers all operations in Belgium, Indonesia, Côte d'Ivoire, Papua New Guinea, and Singapore, including all plantations, mills, and packing stations owned and managed by SIPEF. Approximately 98% of total gross emissions come from oil palm operations in Indonesia and Papua New Guinea; banana operations in Côte d'Ivoire account for 2%.

Scope 1 and Scope 2 emissions are calculated using primary data. Scope 3 emissions use a combination of primary data and spend-based calculations as per the GHG Protocol; approximately 65% of total Scope 3 emissions are estimated using the spend-based approach.

Conversion and emission factors are based on peer-reviewed sources including IPCC, US EPA, and scientific studies. GHGs included: CO₂, CH₄, N₂O, HFCs, PFCs, SF₆, NF₃. Final emissions are converted to CO₂ equivalent using IPCC global warming potential coefficients.

Gross GHG emissions by scope (2024)

Biogenic emissions: Biogenic emissions of CO₂ from combustion or biodegradation of biomass: 529,807 tCO₂e (reported separately from Scope 1).

Scope 1 breakdown

The main sources of Scope 1 emissions in palm oil operations are palm oil mill effluent (POME) and land use change, including cultivation on organic soils.

Scope 2 approach

SIPEF currently reports Scope 2 using the location-based method and uses this as a proxy to estimate market-based emissions. Steps will be taken to implement the market-based approach as data quality and availability improve.

Scope 3 categories excluded

The following Scope 3 categories are excluded based on materiality, data availability, operational control, or business relevance:

• Excluded due to immateriality: Category 5 (Waste generated in operations), Category 7 (Employee commuting), Category 15 (Investments).
• Excluded due to lack of visibility and control over product use (downstream): Category 10 (Processing of sold products), Category 11 (Use of sold products), Category 12 (End-of-life treatment of sold products).
• Excluded due to non-relevance to SIPEF's business: Category 8 (Upstream leased assets), Category 13 (Downstream leased assets), Category 14 (Franchises).

SIPEF notes it has no operational control or influence over downstream processing of intermediate products sold. The Company will periodically revisit the relevance of these categories and assess opportunities to enhance data availability and estimation methodologies in future reporting cycles.

GHG emissions intensity

GHG emissions intensity by crop

GHG removals

SIPEF actively manages 35,336 hectares of conservation and reserve areas. Carbon sequestration from biological growth of plants within conservation land management units (owned or managed by SIPEF) totalled 324,019 tCO₂e in 2024. This calculation is in line with ISO 14064-1 and has been externally audited. GHG emissions associated with carbon removal activities (e.g. fuel for transportation) are included in Scope 1. There were no reversals in 2024, and removal activity was not converted into carbon credits nor sold to other parties on the voluntary market.

Notes

SIPEF previously set a target to reduce Scope 1 and Scope 2 net GHG emissions by 28% by 2030 compared to base year 2021. In 2025, the Group will align this target with ESRS on a gross emissions basis and update the baseline calculation using ISO 14064-1 as a framework and aligning with GHG Protocol methodology.

Policies related to pollution

SIPEF addresses pollution through two main policies that set the framework for managing air and water pollution impacts.

Responsible Plantations Policy (RPP)

Key content and principles:

• Minimising pollutants to the environment
• Maintaining riparian buffer zones to protect waterways
• Meeting relevant environmental legal requirements
• 100% RSPO certification and traceability of products
• No deforestation, no new developments on peat, and no exploitation (NDPE)
• Free, Prior, and Informed Consent (FPIC) prior to any new development
• GHG emissions reduction
• Continuous improvement, emphasising the prompt adoption of best management practices for optimising land use, while minimising adverse impacts

Scope:

• All SIPEF-managed plantations
• Smallholders supplying products to SIPEF mills and integrated kernel crushing plants

History:

• First established in 2014

Governance and oversight:

• Implementation overseen by the group head of sustainability, supported by the heads of each regional sustainability team, and other relevant departments at the Group's operations

Public availability:

• Available to all stakeholders on SIPEF's website

Links to standards:

• Drives commitment to achieving 100% Roundtable on Sustainable Palm Oil (RSPO) certified supply base for palm oil production
• Commits to 100% certification of banana operations to the Rainforest Alliance Sustainable Agriculture Standard, GLOBALG.A.P., and Fairtrade standards

Monitoring:

• Best practices in agrochemical management align with requirements of both RSPO and Rainforest Alliance certification programmes
• Third-party sustainability certification audits carried out annually
• Palm oil mills consistently monitored by environmental agencies including Indonesia's Public Disclosure Programme for Environmental Compliance (PROPER) and the Environmental Code of Practice in Papua New Guinea

Note on stakeholder consultation:

• Stakeholder input and socialisation during and following the Policy's initial development in 2015 were not documented; these aspects will be reviewed and documented as part of SIPEF's upcoming group-wide policy revision

Environmental Policy

Key content and principles:

• Minimising pollutants to the environment
• Maintaining riparian buffer zones to protect waterways
• Meeting relevant environmental legal requirements
• Preventing pollution and improving environmental performance by using resources efficiently, including water
• Emphasises compliance with relevant environmental regulations
• Continuous improvement of environmental practices
• Improving water management and reducing water usage intensity across operations
• Sustainable land preparation and management
• Minimising the use of agrochemicals
• Reducing waste and pollution

Scope:

• All companies under SIPEF's management

History:

• Initially developed in 2015

Governance and oversight:

• Implementation overseen by the group head of sustainability, supported by the heads of each regional sustainability team, and other relevant departments at the Group's operations

Public availability:

• Available to all stakeholders on SIPEF's website

Monitoring:

• Resources allocated for environmental management
• Group identifies environmental impacts related to its operations and ensures effective mitigation is implemented for normal, abnormal, and emergency situations

Note on stakeholder consultation:

• Stakeholder input and socialisation during and following the Policy's initial development in 2015 were not documented; these aspects will be reviewed and documented as part of SIPEF's upcoming group-wide policy revision

Targets related to pollution

SIPEF has set a GHG emission reduction target of 28% by 2030. This target is mentioned in the context of pollution management and climate change mitigation.

Target details:

Additional context:

• SIPEF has committed to no deforestation or new plantings on peatland (NDPE) since 2015 to reduce emissions from land use change
• The company invests in GHG emissions reduction programmes through circular economy initiatives
• 100% of palm oil operations are RSPO compliant
• The document references the GHG target in the context of pollution management (page 264) but detailed quantitative breakdowns are not provided in these excerpts

Note: While the 28% GHG reduction target is stated, key information such as baseline year, baseline value, scope details, and whether the target is absolute or intensity-based is not disclosed in the provided excerpts.

Pollution of air, water and soil

Air Emissions

Palm Oil Mills - Smoke Density Monitoring (2024)

SIPEF monitors smoke opacity at palm oil mills to control air pollution from biomass combustion. Engineering controls including cyclones are installed in smokestacks to separate solid particles and reduce particulate emissions.

Indonesia: Smoke opacity measured using monitors assessing light absorption/reflection/scattering. Legal limit: <30% opacity during normal operations. External testing conducted twice yearly.

Papua New Guinea: Smoke density measured using Ringelmann Index comparing smoke to standardised grey shades. Environmental Code of Practice requires smoke density to remain below Ringelmann 2 (40%) for no more than 20% of operating time.

Target: Zero non-conformance against local regulations and industry regulations on smoke density in palm oil mills.

2024 Result: All mills in Indonesia and Papua New Guinea met the required limits during 2024.

Water Discharges

Wastewater Quality Monitoring

SIPEF monitors wastewater discharge quality from palm oil mills and banana packing stations using biological oxygen demand (BOD), chemical oxygen demand (COD), and total suspended solids (TSS), measured in mg/L.

Target: Zero non-conformance against local regulations and industry regulations on effluent limits in palm oil mills and packing stations.

Monitoring frequency: Palm oil mills - monthly sampling; Banana packing stations - twice yearly. Testing conducted by external laboratories.

2024 Results:

Summary of exceedances (2024):

Papua New Guinea: Six TSS limit exceedances mainly due to high rainfall washing volcanic ash (from November 2023 eruption) into wastewater ponds. Corrective actions included desilting ponds and implementing regular desilting programmes.

Côte d'Ivoire: BOD exceeded limits in 3 cases, COD in 2 cases, TSS in 1 case. Caused by temporary maintenance issue with water purification system. Corrective actions implemented to improve maintenance schedule.

Soil Pollution

No quantified emissions to soil disclosed.

Regulatory Framework

SIPEF operations are located outside the EU. Regulation (EC) No 166/2006 establishing the European Pollutant Release and Transfer Register (E-PRTR) does not apply.

Anticipated financial effects from pollution-related impacts, risks and opportunities

No material pollution-related risks and opportunities identified, and no material incidents and deposits expected to have negative financial effects.

Phase-in exemption

Phase-in for E2-6: 40c, 39a, 39b, 39c, 41.

Policies related to water and marine resources

SIPEF has identified water consumption, water withdrawals, and water discharges as material sustainability matters. The company discloses two applicable policies related to water:

Responsible Plantations Policy (RPP)

• Scope: The policy applies to SIPEF's plantations and operations. While the document excerpts focus primarily on biodiversity aspects of the RPP (including no deforestation and no new development on peat commitments implemented Group-wide since 2015), the policy is explicitly listed as applicable to water-related sustainability matters.

Environmental Policy

• Scope: The Environmental Policy is listed as one of the applicable policies for managing water consumption, withdrawals, and discharges across SIPEF's operations.

Note on marine resources: Marine resources are not applicable to SIPEF's operations and were not identified as material. The company's water-related policies therefore focus exclusively on freshwater management in agricultural contexts.

Implementation approach: SIPEF recognizes the vital importance of responsible water management and is committed to minimizing its impact on local ecosystems and communities. The company monitors water usage intensity across its operations, setting site-specific targets for water efficiency in palm oil mills and banana production. Water is primarily used in palm oil milling processes (with withdrawals from groundwater and rivers) and in banana cultivation irrigation.

SIPEF's operations are not located in areas that WWF's Water Risk Filter identifies as high risk, though water consumption has been identified as material through the company's double materiality assessment.

Targets related to water

SIPEF has set water usage intensity targets for its palm oil mills based on the predominant soil type at each site. The targets are voluntary in nature and not required by any existing legislation. Water usage intensity targets will be set for banana operations once an accurate baseline has been assessed.

Water Usage Intensity Targets - Palm Oil Mills

Additional Water-Related Targets

• Installation of rainwater harvesting systems at all palm oil mills
• Implementation of a water recycling basin at one packing station

Performance Notes

Indonesia (2024): The Agro Muara Rupit mill recorded 1.24 m³ per tonne of FFB, exceeding its target of ≤1.0 m³ per tonne, primarily due to the mill commencing operations in June 2024 and requiring further calibration. All other mills in Indonesia remained within target.

Papua New Guinea (2024): All mills operated within their respective water intensity targets, with values ranging from 1.00 to 1.23 m³ per tonne of FFB processed. The Navo mill showed notable improvement, reducing water intensity from 1.56 to 1.23 m³ per tonne.

Côte d'Ivoire (2024): Water usage intensity for banana production increased by around 19% in 2024, reaching 212.85 m³ per tonne compared to 178.12 m³ per tonne in 2023, attributed to reduced rainfall, drier weather conditions, and continuation of the new planting programme at the Akoudié site.

Water consumption

Total water consumption

In 2024, the SIPEF Group's total water consumption reached 11,237,154 m³ across its palm oil mills, banana plantations, and packing stations, equivalent to 27,341 m³ per million EUR of net revenue.

Of this total:

• Approximately 92% was attributed to banana cultivation and processing activities
• The remaining 8% was related to palm oil processing

Calculation methodology: Total water consumption was calculated by subtracting the volume of water discharged from palm oil mills and packing stations from the total water withdrawn across palm oil mills, banana plantations, and packing stations.

Water management breakdown by operation type

Water recycling and reuse

Palm oil processing:

• A total of 504,545 m³ of water was recycled and reused through the land application of treated POME (Palm Oil Mill Effluent)
• Based on direct measurement using flowmeters at palm oil mills
• Additionally, 566,972 m³ of water was stored, based on the annual capacity of on-site water storage facilities

Banana operations:

• A total of 46,524 m³ of water was recycled and reused across the packing stations and for irrigation within the plantations
• The recycled volume used in the packing stations was estimated based on the capacity of the recycling tanks and the number of operational days
• The volume redirected for irrigation corresponds to 100% of the treated discharge from the relevant packing stations
• No on-site water storage is required for these activities

Water withdrawal by source

Palm oil mills: Water is sourced from rivers, water bores, or other on-site water storage facilities.

Banana operations in Côte d'Ivoire:

• Irrigation water is sourced from a combination of:
  • Rainwater
  • Treated discharge from banana packing stations stored in on-site dams
  • Adjacent rivers
• For packing stations, water is extracted from wells in accordance with food safety regulations
• After use, 100% of water from the packing process is either:
  • Recycled through decantation tanks and redirected to dams for future irrigation, or
  • Safely discharged into rivers

Note on banana plantations: Accurately quantifying water uptake by banana plants is challenging as discharge of excess irrigation water is not measurable; therefore, it is assumed that 100% of the water withdrawn for irrigation is fully consumed within the plantations, resulting in no discharge from these areas.

Water discharge

Palm oil mills: Some mills recycle treated POME for land application within the plantations, while others discharge the treated effluent into rivers or other water bodies in compliance with regulatory standards.

Banana packing stations: 100% of water from the packing process is either recycled for irrigation or safely discharged into rivers.

Water usage intensity by crop

Palm oil mills - Water usage intensity (m³/tonne FFB processed)

Performance notes:

Indonesia:

• The Agro Muara Rupit mill recorded a water usage intensity of 1.24 m³ per tonne of FFB, exceeding its target of ≤1.0 m³ per tonne. This was primarily due to the mill commencing operations in June 2024, and further calibration is needed before its water usage stabilises within the target range
• All other mills in Indonesia remained within target, demonstrating either improved or consistent efficiency

Papua New Guinea:

• All mills operated within their respective water intensity targets, with values ranging from 1.00 to 1.23 m³ per tonne of FFB processed
• Most showed slight improvements compared to 2023, notably the Navo mill, which reduced its water intensity from 1.56 to 1.23 m³ per tonne

Côte d'Ivoire (bananas):

• Water usage intensity for banana production increased by around 19% in 2024, reaching 212.85 m³ per tonne compared to 178.12 m³ per tonne in 2023
• This increase is primarily attributed to:
  • Reduced rainfall
  • Drier weather conditions leading to higher evaporation
  • The continuation of the new planting programme underway at the Akoudié site

Target methodology: Water usage intensity targets are measured per tonne of FFB processed at each mill. These targets are designed to ensure that water efficiency is continuously monitored and maintained. To reflect varying environmental conditions and operational contexts, SIPEF has set water usage intensity targets for its palm oil mills based on the predominant soil type at each site.

Water consumption in areas of water stress

SIPEF's operations are not located in areas that WWF's Water Risk Filter identifies as high risk.

Measurement methodology

All reported volumes were directly measured using flowmeters installed at the respective operational sites, with the exception of irrigation water uptake in banana plantations as noted above.

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

SIPEF applies the phase-in exemption for E3-5 disclosure requirements 33a, 33b, and 33c.

No quantified anticipated financial effects from water and marine resources-related impacts, risks and opportunities are disclosed in the reporting period.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Integration of biodiversity in corporate strategy and business model

SIPEF has integrated biodiversity and ecosystem considerations into its business strategy through a comprehensive Group-wide analysis conducted in 2024. The company engaged an external expert to consolidate the results of its HCV-HCSA assessments into a comprehensive Group-wide analysis.

A core component of this was the threat and dependency analysis, which mapped potential impacts of land use on ecosystem services, evaluating both direct effects of SIPEF's operations and pressures from surrounding land uses and industries.

The analysis considered how key ecosystem services, such as water supply, soil health, pollination, and cultural values, are affected, and how these changes may impact local communities who depend on them.

The results of the Group-wide assessment, including identified dependencies, risks, and opportunities, provide the context for assessing the resilience of SIPEF's business. While no immediate material transition, physical, or systemic risks were identified, the assessment highlighted long-term operational dependencies on ecosystem services such as pollination, water regulation, and soil fertility. These ecosystem services are essential to the resilience of SIPEF's operations, as well as the broader agricultural sector.

Use of frameworks

The assessment referenced frameworks such as the Taskforce on Nature-related Financial Disclosures (TNFD):

• Transition risks assessed include policy and legal changes, market developments, technology shifts, and reputational risks.
• Physical risks assessed include drought, pest and disease outbreaks, fires, and land and soil degradation.

Geographic and value-chain scope

The assessment was conducted at each estate, with HCV-HCSA assessments carried out by a third party following internationally recognised, peer-reviewed methodologies.

The assessment was based on a set of forward-looking assumptions, including the potential introduction of additional tariffs or environmental levies, a shift in customer preferences towards more sustainable and traceable supply chains, and the continued market demand for deforestation-free commodities. These were considered across SIPEF's strategic business planning horizon (ten years) as well as a full oil palm crop cycle (20 years).

Specific biodiversity targets and commitments

Deforestation-free commitment

Land-use change (deforestation) - Risk and Opportunity

SIPEF's approach:

SIPEF addresses deforestation risks by implementing its NDP commitment, robust land use assessments, monitoring across its operations and supply chain, and targeted conservation practices. The Group addresses both the risk and opportunity by focusing on yield improvements on existing plantations through enhanced seed technology, soil management, and pest control. This strategy supports sustainable production without expanding into new land.

Investment commitments

The transition will require increased investment, including continued development of seed technology, but offers long-term gains in efficiency and output.

Linkage to nature-related risk assessment

The following risks and opportunities were identified by the broader business risks and opportunities assessment, and under the financial materiality lens of the 2024 double materiality assessment.

In line with its double materiality assessment, SIPEF has assessed the likelihood of the identified material financial impact on the Group, including its financial position, financial performance, and [text cuts off in excerpt].

Policies related to biodiversity and ecosystems

SIPEF addresses biodiversity and ecosystems through broader policies that include commitments relevant to this topic, rather than through a standalone biodiversity policy.

Responsible Planting Policy (RPP)

Key content and principles:

• Commitment to implementing sustainable land-use management
• Maintaining conservation areas
• Advancing biodiversity projects
• No deforestation policy: FFB from deforested areas cannot be sold to NDP-committed companies
• Supporting communities and promoting smallholder inclusion
• Protecting the rights of local and indigenous communities

Scope:

• Applies to SIPEF's plantations and operations
• Extends to smallholder suppliers (through FFB sourcing restrictions)

Link to international standards:

• RSPO certification commitment, which includes requirements for smallholder inclusion, community development support, respect for land tenure rights, and participatory engagement processes

Additional information:

• The RPP includes broader commitments beyond biodiversity, addressing community engagement and social dimensions
• Targets set under this framework are internally defined and focus on sustainable land-use management, conservation areas, and biodiversity projects
• Targets are not currently informed by or aligned with the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2030, or national biodiversity policies
• Biodiversity offsets have not been used in the target setting process

Responsible Purchasing Policy (RPuP)

Key content and principles:

• Supports the commitments outlined in the RPP
• Includes RSPO Principles & Criteria requirements

Governance and oversight:

• For development, governance, and communication of both RPP and RPuP, the report refers to a 'General information' section (not included in provided excerpts)

Public availability:

• The report states "To view more information on the development, governance, and communication of the RPP and RPuP, please see 'General information'" but specific URLs or documents are not provided in the excerpts

Actions and resources related to biodiversity

Overview

SIPEF takes a proactive approach to managing biodiversity and ecosystem-related impacts, adopting a range of measures to address deforestation and promote biodiversity and habitat conservation. The Company implements a strict no deforestation and no new developments on peat (NDP) policy across all operations, supported by integrated HCV-HCSA assessments to guide responsible land-use planning. It also applies best management practices, including sustainable land preparation, soil conservation measures, and integrated pest management (IPM) to reduce chemical inputs.

Resources allocated: These actions have not required significant Capex or Opex during the financial year.

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Action 1: Sustainable land use

Scope: Own operations

Description: Prior to any new land development, SIPEF conducts integrated HCV-HCSA assessments, supported by social and environmental impact assessments (SEIAs). These are performed by independent, licensed experts using internationally recognised methodologies that combine spatial analysis with field verification to identify areas of high biodiversity, ecosystem service value, cultural significance, and high carbon stock. As part of this process, the Company also upholds customary land rights and applies FPIC to ensure inclusive and sustainable development.

In previously developed organic soil areas, SIPEF applies best management practices in line with RSPO peatland management guidance and local regulations. This includes RSPO-compliant drainability assessments to evaluate long-term land use suitability and prevent further degradation.

Resources: Non-financial - partnerships with independent licensed experts

Mitigation hierarchy level: Avoidance

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Action 2: Fire prevention and monitoring

Scope: Own operations and supplier areas

Description: SIPEF implements fire prevention measures and monitoring systems across its operations and supplier areas. In 2024, favorable climatic conditions contributed to a sharp reduction in fire incidents. The total affected area dropped from 160.5 hectares in 2023 to just 10.71 hectares in 2024. Most 2024 hotspots were recorded in South Sumatra (10.7 hectares), with a minor incident in Papua New Guinea (0.01 hectares). In Indonesia, the majority of fire events were triggered by fires originating on adjacent community lands.

In supplier areas, the number of verified fire incidents fell from 18 in 2023 to 2 in 2024, though the total area affected increased from 2.2 to 11 hectares. The affected areas are in the process of rehabilitation.

The action includes awareness campaigns and capacity-building initiatives, reinforcing best practices in fire prevention and responsible land management.

Target: Zero incidents of fire in own concessions under the Company's management control and supplier areas (annual target)

2024 status: Not achieved (see fire incidents above)

Mitigation hierarchy level: Avoidance

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Action 3: Integrated land-use planning in Papua New Guinea

Scope: Own operations

Time horizon: By 2030

Description: SIPEF is committed to promoting regenerative landscapes that combine conservation, restoration, and sustainable land use, guided by respect for land and community rights and strengthened through stakeholder collaboration. In Papua New Guinea, SIPEF is advancing integrated land-use planning to balance conservation and responsible development. Based on a detailed HCV-HCSA assessment completed in 2023, the Group has identified areas for long-term conservation and others suitable for sustainable development near existing smallholder plantations.

Target: Establish at least one landscape-level example of nature-positive oil palm cultivation and community engagement in Papua New Guinea by 2030

Mitigation hierarchy level: Avoidance, Restoration, and Rehabilitation

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Action 4: SIPEF Biodiversity Indonesia (SBI) programme

Scope: Own operations

Time horizon: 2033 (restoration target)

Description: The SBI programme is a 12,672-hectare ecosystem restoration initiative located next to Kerinci Seblat National Park. It focuses on biodiversity protection and monitoring, including the presence of critically endangered species such as the Sumatran tiger. The project also supports active reforestation and agroforestry.

Resources allocated:

• Type (c) Opex related to the biodiversity programme: USD 180,000 (2024)
• Non-financial: Partnerships with Zoological Society of London (ZSL) and SINTAS (local NGO in Indonesia)

2024 performance:

Long-term target: Restore a cumulative 1,123 hectares of degraded land within SBI by 2033

Mitigation hierarchy level: Avoidance, Restoration, and Rehabilitation

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Action 5: Zero deforestation monitoring

Scope: Own operations and supplier areas

Description: An external partner is engaged to monitor the implementation of SIPEF's NDP policy across its own concessions and supplier areas, providing quarterly updates. Impacted areas are identified through alert systems and are verified by local teams through on-the-ground investigations.

Target: Zero incidents of deforestation in own concessions under the Company's management control and supplier areas (annual target)

2024 status: Achieved - No incidents recorded of deforestation

Resources: Non-financial - external monitoring partner

Mitigation hierarchy level: Avoidance

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Planned action: Biogas plants (type (c) Capex)

Scope: Own operations (Indonesia and Papua New Guinea)

Description: As part of SIPEF's transition strategy, planned improvements intended to meet EU Taxonomy criteria include investments in biogas plants for climate mitigation.

Resources allocated:

• Type (c) Capex for construction of biogas plants: USD 2,513,000 (2024)
• Revenue from sale of electricity from biogas plants: USD 86,000 (2024)

Link to EU Taxonomy: Activity D35.11 (climate mitigation) and A2 (biodiversity conservation)

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Application of ecological thresholds

SIPEF has not yet applied ecological thresholds or allocated environmental impacts in setting its conservation and biodiversity targets. Current goals are internally defined and focus on implementing sustainable land-use management, maintaining conservation areas, and advancing biodiversity projects. These targets are not currently informed by or aligned with the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2030, or national biodiversity policies. Biodiversity offsets have also not been used in the target setting process.

As relevant methodologies and frameworks continue to evolve, SIPEF will consider aligning with them where appropriate to support the further development of its approach to sustainable land use, landscape management, and biodiversity conservation.

Targets related to biodiversity and ecosystems

SIPEF acknowledges targets related to biodiversity and ecosystems but does not fully disclose quantified targets with baseline and target values in the provided excerpts.

Disclosure approach

• Ecological thresholds: SIPEF has not yet applied ecological thresholds or allocated environmental impacts in setting its conservation and biodiversity targets
• Framework alignment: Current goals are internally defined and are not currently informed by or aligned with the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2030, or national biodiversity policies
• Biodiversity offsets: Not used in the target setting process
• Science-based approach: Not science-based or externally validated; targets are internally defined

Target areas mentioned

• Zero tree cover loss: Mitigation hierarchy level - Avoidance
• Zero fire incidents: Mitigation hierarchy level - Avoidance
• SBI (Sustainability Benchmark Index) targets: Mitigation hierarchy level - Avoidance, Restoration, and Rehabilitation
• Landscape approach: Mitigation hierarchy level - Avoidance, Restoration, and Rehabilitation

Reference to detailed information

The excerpts indicate that detailed targets and progress are disclosed in Annex 1 (pages 409-410), but quantified values, baseline years, and target years are not reproduced in the provided excerpts.

Partial omission noted

SIPEF states: "SIPEF does not apply ecological thresholds as per ESRS E4-4 definitions. Therefore 32a (i,ii,iii) and 32b are omitted."

Impact metrics related to biodiversity and ecosystems change

Land use and conservation areas

Total land area managed by SIPEF:

• Oil palm cultivation: over 85,500 hectares across Indonesia and Papua New Guinea
• Banana operations: 1,257 hectares in Côte d'Ivoire (FY2024)
• Smallholder sourcing: 6,196 hectares near SIPEF sites across Indonesia

Conservation areas within SIPEF concessions (hectares):

Note: These areas encompass identified HCV and HCS areas within the Group's concessions, excluding the area managed under the SIPEF Biodiversity Indonesia (SBI) programme. The net reduction of 259 hectares in Indonesia was primarily due to boundary realignments of land titles.

Operations in or near protected areas and KBAs

Following an internal GIS-led assessment in 2024, SIPEF confirmed it has not identified any owned, leased, or managed sites within its operations in Papua New Guinea, Indonesia, and Côte d'Ivoire that are located in or near biodiversity-sensitive areas, such as protected areas or key biodiversity areas (KBAs). 'Near' is defined as within a 500-meter radius.

Land use change metrics

Deforestation monitoring coverage (2024):

• Total areas monitored: 157,791 hectares
  • SIPEF own concessions: 133,305 hectares (84%)
  • Suppliers' areas: 24,486 hectares (16%)

Deforestation incidents (2024):

• Zero incidents of deforestation or peatland conversion recorded within SIPEF's own estates or among its smallholders.
• Historical assessment identified 24 hectares of historical deforestation in Papua New Guinea (period: 31 December 2015 to 31 December 2023). SIPEF is engaging in remediation for this area.

Fire incidents:

Note: In 2024, fire incidents within SIPEF's own concessions declined significantly. Most 2024 hotspots were recorded in South Sumatra (10.7 hectares), with a minor incident in Papua New Guinea (0.01 hectares). The majority of fire events in Indonesia were triggered by fires originating on adjacent community lands.

Biodiversity restoration

SIPEF Biodiversity Indonesia (SBI) programme:

• Total area: 12,672 hectares (ecosystem restoration initiative next to Kerinci Seblat National Park)
• Degraded area restored: 286.44 hectares (2024); 224 hectares (2023)
• Cumulative restoration target: 1,123 hectares by 2033
• Number of agroforestry growers engaged: 376 (2024 and 2023)

Coastal buffer restoration:

• Papua New Guinea: 796 mangrove seedlings planted in 2024 (target: 6.5 hectares by 2027)
• Indonesia: 581 seedlings planted within coastal buffer zone in 2024 (target: 35 hectares by 2027)

Species impact metrics

SIPEF's operations focus on critically endangered species monitoring, particularly the Sumatran tiger within the SBI programme area. The 12,672-hectare SBI initiative includes biodiversity protection and monitoring. No quantified species population metrics or Red List species counts are disclosed in numerical form.

Methodology notes

• HCV-HCSA assessments are performed by independent, licensed experts using internationally recognised methodologies combining spatial analysis with field verification.
• Conservation areas are monitored by dedicated teams implementing HCV-HCS management plans.
• Deforestation monitoring integrates historical and near real-time satellite imagery, with quarterly reports from third-party specialists.

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

SIPEF applies the phase-in exemption for E4-6 disclosure requirements 45a, 45b, and 45c as indicated in the cross-reference table.

Waste

Not disclosed.

SIPEF does not provide quantitative waste data (total waste generated, hazardous vs. non-hazardous split, waste diverted from disposal, waste directed to disposal) in its 2024 CSRD sustainability statement.

Circular Economy Materiality Assessment: The company's double materiality assessment (pages 91-93) identified Circular Economy (ESRS E5) as not material. The assessment states: "Circular economy was the only topic assessed as not material, as SIPEF neither manufactures products nor engages in services relevant to this topic." Consequently, SIPEF has omitted all ESRS E5 disclosure requirements, including waste-related metrics.

Operational By-Product Management: While comprehensive waste data is not reported under E5-5, the sustainability statement describes operational practices for managing agricultural by-products and biomass:

• Palm oil operations: Empty fruit bunches (EFB) and treated palm oil mill effluent (POME) are applied to plantations as organic fertilizer. Mill waste and by-products (fibers, shells) are used to generate renewable energy through biomass combustion and biogas capture. In 2024, 504,545 m³ of water was recycled and reused through land application of treated POME (page 139).

• Banana operations: Organic field waste and biomass (banana stems, empty bunches, cocoa husks from local suppliers) are applied as organic fertilizer. Packing materials are re-used or recycled; some operations use reusable IFCO crates instead of cardboard boxes (page 45).

These practices align with circular economy principles but are reported under climate change mitigation (E1), pollution prevention (E2), and operational excellence commitments rather than as formal waste management disclosures under E5.

Policies related to own workforce

SIPEF has established multiple policies governing its own workforce, as outlined in its CSRD sustainability statement. These policies apply to all companies under SIPEF's management across its operations in Indonesia, Papua New Guinea, Côte d'Ivoire, Belgium, Luxembourg, and Singapore.

Responsible Plantations Policy (RPP)

Policy name: Responsible Plantations Policy

Scope: All SIPEF-managed plantations and smallholders supplying products to SIPEF mills and integrated kernel crushing plants

Key content/principles:

• 100% certification and traceability of products
• No deforestation, no new developments on peat, and no exploitation (NDPE)
• Free, Prior, and Informed Consent (FPIC) prior to any new development
• GHG emissions reduction
• Continuous improvement and adoption of best management practices
• 100% RSPO certification for palm oil production
• 100% certification of banana operations to Rainforest Alliance Sustainable Agriculture Standard, GLOBALG.A.P., and Fairtrade standards

Links to international standards:

• Commitment to implementing the Free and Fair Labour in Palm Oil Production: Principles and Implementation Guidance
• RSPO certification requirements
• Rainforest Alliance, GLOBALG.A.P., and Fairtrade standards

Public availability: First established in 2014; accessible on SIPEF's website

Monitoring: Implementation overseen by human resources heads in each country or regional sustainability team leads who report to the executive committee in each country of operation. Effectiveness tracked through annual external audits including RSPO certification audits for palm oil operations and Rainforest Alliance, Fairtrade, and SMETA audits for banana operations.

Human Rights Policy

Policy name: Human Rights Policy

Scope: All companies under SIPEF's management

Key content/principles:

• Compliance with applicable national regulations
• Adherence to ILO Core Conventions
• Alignment with International Bill of Human Rights

Links to international standards:

• ILO Core Conventions
• International Bill of Human Rights
• United Nations Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work

Public availability: Accessible on SIPEF's website as group-level policy. Locally adapted versions displayed on notice boards at operational sites and communicated during training sessions.

Governance: Implementation overseen by human resources heads in each country or regional sustainability team leads who report to the executive committee in each country of operation.

Monitoring: Policy will be reviewed as part of SIPEF's upcoming group-wide policy revision in 2025-2026, which will incorporate stakeholder feedback.

Child Labour Policy

Policy name: Child Labour Policy

Scope: All companies under SIPEF's management

Key content/principles:

• No individual under 18 employed
• Mandatory age verification during hiring
• Immediate corrective actions if violations identified
• Disciplinary measures against policy breaches

Links to international standards:

• ILO Convention No. 182 on the Worst Forms of Child Labour (1999)
• National laws
• RSPO standards (prohibition of child labour)

Public availability: Group-level policies publicly accessible on SIPEF's website; locally adapted versions displayed on notice boards at operational sites

Governance: Implementation overseen by human resources heads in each country or regional sustainability team leads

Monitoring: Zero-incidence approach with strict monitoring and enforcement. Effectiveness tracked by annual external audits and grievance mechanism. Corrective action protocols include immediate contract termination and disciplinary action.

Forced or Trafficked Labour Policy

Policy name: Forced or Trafficked Labour Policy

Scope: All companies under SIPEF's management

Key content/principles:

• Prohibition of all forms of slavery, forced, or compulsory labour
• Disciplinary actions including dismissal and legal consequences for violations
• Business partners must comply; non-compliance leads to contract termination and possible legal action

Public availability: Group-level policies publicly accessible on SIPEF's website; locally adapted versions displayed on notice boards

Governance: Implementation overseen by human resources heads in each country or regional sustainability team leads

Monitoring: Zero-incidence approach. Monitored through annual external audits and grievance mechanism.

Freedom of Association Policy

Policy name: Freedom of Association Policy

Scope: All companies under SIPEF's management

Key content/principles:

• Protection of workers' rights to unionize, bargain collectively, and engage in social dialogue
• Non-interference in trade union activities
• Adequate resources and protections for worker representatives

Links to international standards:

• ILO Core Conventions
• International Bill of Human Rights
• RSPO standards
• Rainforest Alliance and Fairtrade standards

Public availability: Accessible on SIPEF's website

Governance: Implementation overseen by human resources heads and regional sustainability team leads

Monitoring: SIPEF plans to review and update this policy to explicitly address collective bargaining. As of 2024, 51% of employees covered by collective bargaining agreements (100% in Côte d'Ivoire, 83% in Belgium, 57% in Indonesia, 0% in Singapore and Papua New Guinea).

Occupational Health and Safety Policy

Policy name: Occupational Health and Safety (OHS) Policy

Scope: All SIPEF employees, contractors, and their employees

Key content/principles:

• Ensures workers are made aware of and understand their individual OHS rights and obligations
• Alignment with local laws, international agreements, and industry standards
• Safe and compliant working conditions

Links to international standards:

• Local laws
• International agreements
• Industry standards
• RSPO requirements

Governance: At Group level, executive committee responsible for oversight. Legal counsel provides support for updates and communication.

Monitoring: Regular internal and external audits, third-party certification audits verify compliance.

Equal Employment Opportunity Policy

Policy name: Equal Employment Opportunity Policy

Scope: All companies under SIPEF's management

Key content/principles:

• Anti-discrimination and equal opportunity
• Zero tolerance for discrimination based on gender, race, ethnicity, religion, or other protected characteristics
• Breaches result in disciplinary action up to termination and legal consequences

Public availability: Group-level policies publicly accessible on SIPEF's website; locally adapted versions displayed on notice boards

Governance: Implementation supported by gender committees and equivalents established across operating units and head offices in each country

Monitoring: Gender and social issues committees meet regularly. Awareness-raising, employee training, and grievance mechanisms in place to prevent, identify, and address discrimination.

Protection of Reproductive Rights Policy

Policy name: Protection of Reproductive Rights Policy

Scope: All companies under SIPEF's management

Key content/principles: Specific content not detailed in excerpts, but addressed by gender committees

Governance: Gender and social issues committees address reproductive rights concerns

Monitoring: Monitored through gender committee activities

Sexual Harassment Policy

Policy name: Sexual Harassment Policy

Scope: All SIPEF-managed entities; applies to all genders

Key content/principles:

• Defines sexual harassment as unwanted, unwelcome, and offensive conduct
• Prohibition of sexual harassment, abuse, and gender-based violence
• Confidential reporting channels
• Protection against retaliation
• Country-level policies in Indonesia, Papua New Guinea, and Côte d'Ivoire
• In Papua New Guinea, complemented by Family Violence Policy for employees in company housing

Links to international standards:

• RSPO standards (mandates policies on harassment and violence, protection of reproductive rights)
• Rainforest Alliance and Fairtrade standards

Public availability: Group-level policies publicly accessible on SIPEF's website; locally adapted versions displayed on notice boards

Governance: Gender and social issues committees play key role in raising awareness and responding to concerns

Monitoring: Monitored through gender and social issues committees, HR department, and grievance mechanism. In 2024, no workplace harassment cases reported through grievance mechanism. Targeted training and awareness programmes conducted.

Code of Conduct

Policy name: Code of Conduct

Scope: All SIPEF executives, employees, consultants, and contractors

Key content/principles:

• Minimum norms and standards for conduct
• Zero-tolerance stance on bribery and corruption
• Whistleblowing and grievance handling
• Prohibition of using Group facilities or working hours for personal business
• Guidelines for maintaining respectful workplace
• Professional, transparent relationships with clients and suppliers
• Prohibition of conflicts of interest, insider trading
• Corporate social responsibility including environmental protection, anti-discrimination, safeguarding human rights
• Data protection and confidential information

Public availability: Publicly available on SIPEF's Company website since 2020. Comprehensive review planned for first half of 2025.

Governance: At Group level, executive committee responsible for oversight of implementation. Group's legal counsel provides support for updates and communication. At subsidiary level, legal departments and internal audit departments ensure alignment and dissemination.

Monitoring: Annual review by board of directors. Grievance mechanism captures reported breaches. No training conducted in 2024 as comprehensive review planned for 2025-2026.

Policy Development Process

SIPEF developed these policies with consideration for:

• Compliance with local regulations in Indonesia, Papua New Guinea, and Côte d'Ivoire
• RSPO standards for palm oil operations
• Rainforest Alliance, SMETA, and Fairtrade standards for banana operations

While stakeholder input during initial development in 2015 was not documented, policies will be reviewed as part of SIPEF's upcoming group-wide policy revision (2025-2026), which will incorporate stakeholder feedback.

Overall Approach

SIPEF's policies are transposed into country-level policies to ensure compliance with local regulations and operational contexts. The Group commits to 100% certification across operations, which reinforces adherence to labour standards embedded in these policies. Implementation is monitored through internal and external audits, grievance mechanisms, and gender/social issues committees.

Taking action on material impacts on own workforce

Overview

SIPEF implements various actions across multiple workforce topics to address material impacts, risks, and opportunities. Actions are disclosed throughout the S1 section covering training, diversity, working conditions, health and safety, and grievance mechanisms.

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Training and Skills Development

Structured training initiatives

• Scope: Own operations across Indonesia, Papua New Guinea, Côte d'Ivoire, Belgium
• Description: Various structured training programmes to strengthen workforce skills, enhance career development, reduce workplace risks, and ensure compliance with company policies and regulatory/certification requirements (RSPO, Rainforest Alliance, Fairtrade)
• Content: Occupational health and safety, working conditions, human rights, standard operating procedures, agronomic practices, certification, and regulatory requirements
• Delivery: Training materials developed in local languages; delivered in-person and online
• Resources allocated: Total of 59,511 hours of training delivered in 2024 (excluding Singapore)
  • Female employees: 13,734 hours (average 2.24 hours per employee)
  • Male employees: 45,777 hours (average 2.54 hours per employee)
• Monitoring: Training participation rates tracked; employee feedback collected; training impact assessments inform future programme development; one-on-one coaching between supervisors and team members

Cadet programmes

• Scope: Indonesia and Papua New Guinea
• Description: Train college graduates for middle-management roles in palm oil operations
• Time horizon: Medium-term career development
• Status 2024: No new cadets recruited in Indonesia as programme is being revamped following hire of new training manager; female participation actively encouraged

Apprentice programmes

• Scope: Papua New Guinea (HOPL)
• Description: Well-established programme focused on technical fields such as construction and workshop operations
• Expected outcomes: Practical skills development; building more inclusive technical workforce

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Gender Equality and Diversity

Female harvesters and ablation workers programme

• Scope: Indonesia (North Sumatra, Bengkulu, South Sumatra)
• Description: Empowering women to take on plantation roles traditionally held by men (harvesting, ablation) in higher-paid labour functions
• Resources: Over 50 full-time female employees trained and employed in North Sumatra and Bengkulu
• Time horizon: Ongoing rollout to new sites in South Sumatra
• Expected outcomes: Equal employment opportunities; greater gender equality in palm oil industry

Upskilling for women in technical roles

• Scope: Own operations
• Description: Targeted training programmes in gender-inclusive skills development and technical fields
• Roles covered: Harvesting, ablation, tractor driving, machinery operation, technical trades
• Expected outcomes: Greater participation by female employees in roles traditionally held by men

Gender and social issues committees

Indonesia (PT Tolan Tiga Indonesia):

• Description: Assesses and addresses gender-related issues, advises board on decision-making, provides training on female employees' rights
• Scope: Each operating unit supported by gender committee contact group
• Focus areas: Equal opportunity, reproductive rights, sexual harassment

Papua New Guinea (HOPL):

• Description: Social issues committees identify and address employee and local community concerns
• Structure: Female representatives from every department; term of reference and annual workplan

Côte d'Ivoire (Plantations J. Eglin):

• Description: Gender committees address broad range of gender-related concerns
• Focus areas: Equal opportunities, women's health and safety, workplace harassment, women's advancement
• 2024 workplan achievements:
  • Awareness-raising on workplace harassment
  • Training staff representatives on handling harassment grievances
  • Pink October campaign (breast and cervical cancer)
  • Initiatives to encourage women to apply for positions of responsibility
• Expected outcomes: Internal promotions for women
• 2024 results: First female station manager appointed; promotions to assistant station manager, assistant agronomist, four supervisory roles; first female tractor driver

Monitoring: Committee feedback tracked; no specific target set; focus on policy implementation and training delivery

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Employee Engagement

Daily musters

• Scope: Operational sites (plantations and mills)
• Description: Daily briefings on safety protocols, operational updates, company policies; space for employees to voice concerns or provide feedback
• Responsibility: Managing director (overall); head of HR per country (operational); site managers and supervisors (facilitation)

Union engagement

• Description: Structured engagement with union representatives through scheduled meetings
• Scope: Local level

Policy development input

• Description: Employee input actively sought during policy development and revisions
• Expected outcomes: Alignment with regulatory requirements and workforce priorities

Annual appraisals

• Description: Performance reviews supporting workforce development

Monitoring: Effectiveness assessed through direct communication and ongoing monitoring via grievance mechanism; gender and social issues committees provide dedicated platform

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Grievances and Remediation

SIPEF Grievance Solution system

• Scope: All stakeholders including own workforce
• Description: Transparent and confidential platform to raise concerns or report incidents related to material impacts
• Channels: In-person at nearest office, email, online grievance form; anonymous reporting allowed
• Key features: Confidentiality guaranteed; retaliation prohibited; investigation team assigned per case; all cases tracked through digital system
• Time horizon: Revised policy and mechanism launched in 2024
• Promotion: Employee training sessions, policy publications, website updates, notice boards, morning musters
• Planned monitoring: Periodic surveys, engagement sessions, feedback initiatives to assess employee awareness and trust

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Anti-Corruption and Anti-Bribery Training

ACAB Policy training programme

• Scope: All subsidiaries
• Time horizon: 2024 implementation (third and fourth quarter)
• Content: Policy definitions, detection and reporting of corruption, whistleblowing procedures, transparency in political engagements, anti-competitive behaviour, case exercises
• Target group: All employees in 'functions-at-risk' (employees whose roles expose them to corruption/bribery risks); executive committee members
• Delivery: Primarily in-person; online where possible; adapted for each country reflecting local risks and applicable penalties
• Resources: 478 employees in at-risk functions trained (100% completion); 68 other workers trained; average 2.5 hours duration
• Frequency: Annual training required
• 2024 results: 100% of at-risk employees trained
• Coordination: Legal counsel ESG; collaboration with internal audit and legal departments

Grievance manager training

• Time horizon: Third and fourth quarter 2024
• Participants: Internal audit and HR staff, RSPO officers, safety officers, legal counsel
• Description: Specialized training on grievance handling procedures

Target: Annual training for all employees in functions-at-risk within own operations

• Baseline: Zero at beginning of each financial year (recurring target)
• Monitoring: Participation rates and attendance records

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Code of Conduct Revision

Group-wide policies review

• Time horizon: 2025-2026
• Timeline:
  • Q3 2024: Policies review workstream established
  • H1 2025: Group Code of Conduct revision
  • Post H1 2025: Country-level Codes of Conduct alignment
  • H2 2025: Communication, dissemination, socialisation, and training
• Scope: SIPEF Group and subsidiaries in Indonesia, Papua New Guinea, Côte d'Ivoire
• Expected outcomes: Enhanced alignment across policies with Group's ESG priorities, values, and latest EU and national legislative requirements; country-level codes aligned with Group minimum standards while complying with national legal frameworks

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General Mitigation and Monitoring Approach

Continuous improvement measures

• Training programmes
• Capacity-building initiatives
• Research development and innovation
• Adoption of best practices

Monitoring and evaluation

• On-the-ground surveys
• Audits
• Grievance channels
• Impact assessments
• Stakeholder engagement
• Third-party monitoring and certification
• Digital tools: satellite surveillance for deforestation and fires; SIPEF Grievance Solutions platform
• Internal reporting mechanisms from country-level to Group-level
• Structured data collection processes
• Transparent publication in Integrated Annual Report and Grievance Dashboard

Action plan development

• When actual adverse impacts identified through monitoring/evaluation or stakeholder feedback, SIPEF develops action plans to address non-conformities or ineffective actions

Targets related to own workforce

The document references S1-5 targets multiple times in the index (pages 157, 164, 167, 171, 174, 178, 181-182, 185, 190, 192, 411) and indicates these are disclosed in "Sustainability Statement - S1: Own workforce; Annex 1".

However, the provided excerpts do not contain the actual target details for own workforce (S1-5). The excerpts only include:

• References to biodiversity and conservation targets (which relate to environmental topics, not own workforce)
• EU Taxonomy disclosure content (unrelated to S1-5)
• An index table showing where S1-5 information can be found in the full report

The specific quantified targets related to own workforce management (such as health and safety targets, training targets, diversity targets, adequate wage targets, etc.) are referenced as being on the cited pages but are not included in the provided excerpts.

Without access to the actual content from pages 157, 164, 167, 171, 174, 178, 181-182, 185, 190, 192, and 411, the specific S1-5 targets cannot be extracted.

In 2024, SIPEF had 24 204 employees across five countries around the world. The majority are employed or contracted through the Group's subsidiaries in Indonesia, Papua New Guinea and Côte d'Ivoire.

Gender breakdown:

• Male: 18 066
• Female: 6 138

More than 2 000 employees carry out the cultivation, harvesting, and transportation of bananas across SIPEF's five estates in Côte d'Ivoire. An additional 400 employees work across the seven packing stations.

More than 24 000 employees work in SIPEF's plantations and mills in Indonesia and Papua New Guinea. They are responsible for the cultivation, harvesting, transportation, and processing of CPO, PK and CPKO.

Characteristics of non-employees in the undertaking's own workforce

Disclosure statement

SIPEF has omitted the disclosure of S1-7 (Characteristics of non-employees in the undertaking's own workforce) for the financial year 2024.

Phase-in applied: S1-7: 55a, 55b (i,ii), 55c, 57

As stated in the ESRS disclosure index (page 459):

S1-7 Characteristics of non-employees in the undertaking's Own workforce: Omitted - Phase-in for S1-7: AR 55a, 55b (I,ii), 55c, 57

Scope clarification

While the Sustainability Statement addresses the own workforce comprehensively under section S1, the scope explicitly excludes non-employees. As stated on page 159:

"This section covers all employees in SIPEF's own workforce who can be materially impacted by the Company and its operations. It does not cover non-employees.

Employees include those on permanent and temporary contracts.

• Permanent: Hired on a contract for an indefinite period
• Temporary: Employed on a fixed-term contract that ends upon completion of a specified duration, task, or event

Non-employees, including contractors, are referenced where applicable in policies or monitoring procedures but are not included in the scope of the data."

References to contractors

While quantitative metrics for non-employees are not disclosed, contractors are mentioned in various policy contexts throughout the report:

• Governance and management structure references "HR matters (for employees and contractors)" (page 34)
• Good business conduct goals include fostering "a culture of ethical conduct amongst management, staff, and contractors" (page 93)
• Freedom of association rights extend to "all workers and contractors across SIPEF's operations" (page 173)
• Health and safety commitments cover "all its employees, its contractors, and their employees" (page 217)
• Code of Conduct applies to "all SIPEF executives, employees, consultants, and contractors" (page 265)

No headcount, FTE, or breakdown data for non-employee workers is provided for 2024.

Collective bargaining coverage and social dialogue

Policy and governance

SIPEF has a Freedom of Association Policy and a Human Rights Policy, which commit the Group to compliance with applicable national regulations, the ILO Core Conventions, and the International Bill of Human Rights.

Under the Responsible Planting Policy (RPP), SIPEF commits to 100% certification across its operations, ensuring compliance with RSPO, Rainforest Alliance and Fairtrade standards. All four certification standards protect workers' rights to unionise, bargain collectively, and engage in social dialogue, requiring certificate holders to respect these rights and actively engage with worker representatives.

The RPP outlines SIPEF's commitment to implementing the Free and Fair Labour in Palm Oil Production: Principles and Implementation Guidance, which explicitly protects freedom of association and collective bargaining.

All workers and contractors across SIPEF's operations, permanent or temporary, have the right to join unions and organise themselves following the respective legislation of the country of operation.

Collective bargaining coverage

As of 31 December 2024, 51% of SIPEF's employees are covered by collective bargaining agreements, with full coverage in Côte d'Ivoire, 83% in Belgium, 57% in Indonesia, and 0% in Singapore and Papua New Guinea. Employees not covered by collective bargaining agreements are instead covered by contractual agreements.

Collective Bargaining Agreement Coverage 2024

Note: Others that are not covered by collective bargaining agreements are covered by contractual agreements.

Social dialogue mechanisms

In locations where unions are present, SIPEF engages with union representatives through structured meetings and open communication channels to support social dialogue and address workplace concerns. While not all engagements result in formal collective bargaining agreements, they provide a platform for discussing working conditions, employee rights, and labour policies.

SIPEF works to identify barriers to union participation and, where possible, address them. In Papua New Guinea, for example, while a union is available to employees, participation remains low due to the perceived limited advantages of joining.

Plantations J. Eglin SA contributed to advancing social dialogue in the Ivorian banana sector by supporting a major industry event in Abidjan focused on living wage and shared responsibility.

Actions and targets

SIPEF is exploring ways to incorporate sustainability issues in collective bargaining discussions and increase resources for worker representatives and social dialogue mechanisms.

SIPEF has not set specific targets for freedom of association or collective bargaining, as participation in these arrangements is voluntary for employees. Instead, the Group monitors its performance by tracking the percentage of employees who have joined unions and are covered by collective bargaining agreements. SIPEF also plans to review and update its Freedom of Association Policy to explicitly address collective bargaining and ensure alignment with best practices.

Methodology

Collective bargaining coverage includes employees whom SIPEF is required to cover under local regulations. Through their unions, employees negotiate with the Company on matters such as pay, benefits, working hours, leave, and safety. The coverage percentage is calculated as the number of employees covered as of 31 December 2024, divided by the total number of employees at that time.

Diversity metrics

Gender diversity at top management

Board and executive committee representation by country (2024)

• Belgium: 36% women at board level, 25% women at executive committee level
• Singapore: 33% women at board level
• Papua New Guinea: 33% women at board level, 13% women at executive committee level
• Indonesia: 14% women at board level, 13% women at executive committee level
• Côte d'Ivoire: 0% women at board level, 0% women at executive committee level

SIPEF's Managing Director is a woman.

Total workforce gender distribution

Total employees: 24,204 (2024)

• Male: 18,066 (75%)
• Female: 6,138 (25%)

Women in oil palm and banana operations: 24% (Indonesia), 31% (Papua New Guinea)

Age band distribution of total workforce (2024)

Detailed age distribution by country (2024)

Multi-year comparison

No multi-year data on gender diversity or age distribution is provided in the excerpts. This is SIPEF's first year of reporting on gender pay gap, annual remuneration ratio, and employee turnover metrics (2024).

Adequate wages

Benchmark used

SIPEF meets all local regulations for minimum wages and complies with RSPO, Rainforest Alliance, and Fairtrade standards on living wage requirements and calculations. These standards follow the Global Living Wage Coalition (GLWC) definition and use salary matrices to identify gaps where no approved benchmark exists.

The Responsible Plantations Policy (RPP) outlines SIPEF's commitment to implementing the Free and Fair Labour in Palm Oil Production: Principles and Implementation Guidance (developed by Humanity United), which require that a living wage be paid to all workers based on living costs, commodity prices, and worker consultations.

The RSPO has established a Living Wage Task Force to develop decent living wage benchmarks for palm oil-producing countries, particularly in regions where no existing benchmarks are available from the Global Living Wage Coalition (GLWC).

Coverage and compliance

SIPEF states that it "meets all local regulations for minimum wages and complies with RSPO, Rainforest Alliance, and Fairtrade standards on living wage requirements and calculations" across its operations.

The company confirms: "SIPEF has not set a specific target for adequate wages, as it already meets its established benchmarks, including minimum wage requirements in all operating locations, as well as compliance with certification and industry standards on providing a decent living wage."

No percentage coverage is explicitly disclosed for the proportion of workforce assessed against living wage benchmarks.

Geographic scope

The living wage approach applies to operations in Indonesia, Papua New Guinea, Côte d'Ivoire, Belgium, Singapore, and Luxembourg.

Targets and commitments

SIPEF has not set a specific target for adequate wages. However, the company has set a broader target to achieve 100% RSPO certification for its own oil palm estates by the financial year 2030, while its banana operations are already fully certified. RSPO certification includes living wage requirements.

Methodology and monitoring

• Salary grading system: SIPEF utilizes a documented salary grading system, which is reviewed annually as part of internal control processes
• Third-party audits: Annual third-party audits are conducted to verify compliance with RSPO standard for palm oil operations and Rainforest Alliance and Fairtrade standards for banana business
• Supplier audits: SIPEF audits third party labour suppliers to assess compliance with minimum wage laws and relevant regulations
• Living wage definition: Aligned with GLWC's definition, which includes decent living conditions, housing, clean water, education, and healthcare

Supporting infrastructure

SIPEF provides extensive in-kind benefits to support adequate living standards:

• 12,135 housing units for employees
• 47 clinics providing medical care
• 50 schools for employees' children
• 43 day care facilities (free childcare offered since 2017 in Indonesia)
• Clean water access

These facilities are accessible to both employees and local communities.

Value chain workers (smallholders)

For smallholders in the palm oil value chain, SIPEF's Responsible Purchasing Policy (RPuP) requires that "pay and employment conditions for workers or contract workers meet at least legal or industry minimum standards."

Under RSPO Principles & Criteria, SIPEF must ensure that smallholders receive:

• Fair pricing
• Transparent payment terms
• Financial support mechanisms

In Papua New Guinea, HOPL purchases fresh fruit bunches (FFB) at world market prices in accordance with a government formula and shares an annual premium from each shipment with smallholders.

In Indonesia, SIPEF applies local FFB pricing formulas that align with market conditions and provides advanced monthly payments during the immature phase of plantation development.

Disclosure quality note

SIPEF omitted the following disclosure: "Partially omitted: All employees are paid adequate wage, in line with applicable benchmarks" (page 459). The company states compliance with living wage benchmarks (GLWC via RSPO, Rainforest Alliance, and Fairtrade) but does not provide specific percentage coverage or wage gap data.

Social protection

Disclosure approach

S1-11 (Social protection) is omitted under the phase-in provisions. According to the reporting table, SIPEF has applied phase-in for disclosure requirements S1-11: 74a, 74b, 74c, 74d, 74e, 75, 76.

Qualitative information disclosed

While quantitative metrics are not provided, SIPEF's sustainability statement includes descriptive information about social protection coverage in specific operations:

Côte d'Ivoire (Plantations J. Eglin):

• Permanent employees receive comprehensive benefits including medical coverage
• Company-funded private health insurance covering 80% of healthcare costs
• Social security through the national social security system, "Caisse Nationale de Prévoyance Sociale" (CNPS)
• CNPS provides benefits such as:
  • Family allowances
  • Retirement pensions
  • Maternity and paternity leave
  • Coverage for work-related accidents and disability

Indonesia:

• Employees entitled to:
  • 12 days annual leave
  • 12 weeks maternity leave
  • Sick leave
  • Public holidays

Papua New Guinea:

• Employees entitled to:
  • Annual leave
  • 12 weeks maternity leave (with option for 6 weeks as pregnancy leave)
  • Duty leave
• Annual leave entitlements vary based on employee grade and level

No percentage coverage data, breakdown by scheme type (public vs. private), or systematic country-by-country coverage metrics are disclosed for the 2024 reporting period.

Training and skills development metrics

Average training hours per employee

Overall average training hours (2024):

• Male employees: 2.54 hours
• Female employees: 2.24 hours
• Total workforce average: Not explicitly stated

Average training hours by gender and country

*Training hours for Singapore office and Cibuni Tea Estate are not available for 2024.

Total training hours delivered

In 2024, a total of 59,511 hours of training were delivered across the Group, excluding Singapore, where training hours were not available.

Training by employee category

Average training hours by employee category (executive/management/non-management) is not disclosed.

Performance and career development reviews

Percentage of employees who received a performance and career development review (overall and by gender) is not disclosed.

Total investment in training

Total investment in training (€) is not disclosed.

Methodology note

Total training hours are recorded and used to calculate the average training hours by gender, based on the total number of male and female employees with active status as of 31 December 2024. On average, men received more training hours than women, largely because the highest number of training hours are linked to technical field roles, which are predominantly held by men.

Health and safety metrics

Coverage by health and safety management system

All employees at operational locations are covered by a health and safety management system aligned with legal requirements and internationally recognised standards. Each operating unit in Indonesia, Papua New Guinea, and Côte d'Ivoire has a dedicated OHS and environment committee, made up of worker and management representatives.

Fatalities

No work-related fatalities or deaths due to work-related ill health occurred across the Group in 2024.

Lost Time Injury Frequency Rate (LTIFR)

LTIFR per million hours worked

*LTIFR is not tracked for Singapore and Belgium, as these locations consist only of administrative offices.

Additional LTIFR detail for 2024:

Lost work days

Lost work days from an LTI are counted starting from the next working day after the incident occurred during working hours.

Methodology notes

• Lost Time Injury (LTI): A work-related accident or injury that prevents an employee from doing their regular job, confirmed by a medical certificate.
• LTIFR calculation: (Total number of LTIs / Total hours worked) × 1,000,000
• Hours worked: Estimated total number of hours employees worked during the reporting period, including paid leave like annual leave and public holidays, based on legal working hours in each country.
• Scope covers own employees only; non-employees including contractors are not included in the metrics.

Compensation metrics

2024 marked SIPEF's first year of reporting on gender pay gap and annual remuneration ratio, strengthening transparency on workforce data.

Pay gap

The gender pay gap varies significantly across SIPEF's operations:

These figures reflect broader differences in workforce composition, role distribution, and seniority levels across countries.

Remuneration ratio

The annual total remuneration ratio of the highest paid individual to the median annual total remuneration of all employees in each country for financial year 2024:

Methodology

Gender pay gap: The percentage of gender pay gap is calculated using the formula: (Average gross pay of male employees – Average gross pay of female employees) / Average gross pay level male employees x 100. The data has been calculated without adjustments for job grades or specific roles and does not distinguish between administrative and field functions.

Remuneration ratio: The highest paid individual in each country has been excluded from each median calculation. The data has been calculated without adjustments for job grades or specific roles and does not distinguish between administrative and field functions. Total pay includes salary, bonuses, and regular financial benefits.

Incidents, complaints and severe human rights impacts

Summary of grievances related to own workforce in 2024

In 2024, 20 grievances were filed by SIPEF's own workforce through its grievance channels across the Group. None of these grievances met the definitions prescribed by ESRS for severe human rights incidents, discrimination cases, or severe human rights violations under the UN Guiding Principles and OECD Guidelines.

No fines, penalties, or damages (zero USD) were issued in connection to severe human rights violations, discrimination, harassment, or workforce-related incidents. Additionally, no material fines, penalties, or compensations were imposed for violations related to social and human rights factors.

*Only Belgium has an OECD NCP. Singapore, Indonesia, Papua New Guinea, and Côte d'Ivoire do not participate in this initiative, as they are not OECD country members.

Additional metrics from Annex 2

Incidents of discrimination including harassment (2024):

Incidents of severe human rights (2024):

Grievance mechanism

SIPEF's grievance mechanism offers all stakeholders, including its workforce, a transparent and confidential platform to raise concerns or report incidents related to material impacts. The mechanism ensures accountability and appropriate remediation where necessary.

Grievances can be submitted in person at the nearest SIPEF office, via email, or using an online grievance form. The system allows for anonymous reporting and guarantees confidentiality. SIPEF's Grievance Policy clearly prohibits retaliation against individuals who raise concerns. An investigation team with relevant expertise is assigned to address and resolve each grievance. All cases are tracked through the SIPEF Grievance Solution system to ensure timely and transparent resolution.

As part of annual certification audits under schemes such as RSPO, ISPO, Rainforest Alliance, and Fairtrade, SIPEF is assessed on its grievance mechanism to ensure it is accessible, effectively implemented, and capable of providing fair and timely resolution in line with human rights and social standards.

Methodology note

All grievances received are documented through SIPEF's Grievance Solution system. Each case is reviewed and categorised based on its nature and severity, including incidents related to: discrimination, harassment and severe human rights violations, if any are identified. No cases were identified in the 2024 reporting period.

Policies related to value chain workers

SIPEF has established policies to manage impacts on workers in its value chain, particularly focusing on smallholder suppliers and their employees. The company references adherence to leading sustainability standards and international frameworks.

Responsible Purchasing Policy (RPuP)

Scope:

• All Fresh Fruit Bunch (FFB) suppliers, who are exclusively smallholders
• Serves as SIPEF's supplier code of conduct

Key content:

• Core commitment to achieving 100% RSPO certification
• Compliance requirements for smallholder suppliers

Linkage to international standards:

• Aligns with RSPO standards
• Referenced alongside UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, and OECD Guidelines for Multinational Enterprises

Responsible Plantations Policy (RPP)

Scope:

• Smallholder suppliers must adhere to this policy

Key content:

• Core commitment to achieving 100% RSPO certification
• Explicitly references international labour and human rights standards

Linkage to international standards:

• Universal Declaration of Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work

Grievance Policy

Scope:

• All stakeholders including smallholders, their families, their employees, and workers from SIPEF's shipping and logistics partners

Key content:

• Allows raising concerns or reporting incidents related to any identified material impacts
• Enables anonymous reporting
• Ensures confidentiality of all grievances
• Explicitly stipulates protection against retaliation for individuals using these channels
• Ensures fairness, transparency, accountability, and appropriate resolution

Accessibility:

• Multiple channels available
• Smallholders can submit grievances via voice note, through grievance managers at nearby offices, and in Indonesia by calling a dedicated hotline
• Smallholders are informed about the mechanism during training sessions

Monitoring:

• Issues are tracked
• Effectiveness of the mechanism is monitored
• Overview of grievance procedures available in 'G1: Business conduct'

Overall Policy Framework

Linkage to international standards: SIPEF's commitment to upholding human rights in its supply chain aligns with:

• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises
• RSPO standards
• Rainforest Alliance standards

Key principles incorporated:

• Social risk assessment
• Fair labour practices
• Prohibition of forced, trafficked, and child labour
• Establishment of grievance mechanisms ensuring transparency, accessibility, and equitable resolution

Monitoring implementation:

• Monitoring activities conducted by SIPEF's smallholder teams (smallholder department in Indonesia and SHAAS team in Papua New Guinea)
• Progress tracking of smallholder compliance with RSPO and SIPEF's policies
• Smallholder managers report directly to regional executive committees in Indonesia and Papua New Guinea
• Regular technical assistance, training, and comprehensive compliance support provided
• Feedback from smallholders during training sessions used to refine programmes

Note on logistics partners: SIPEF is assessing how best to develop its approach for logistics partners. Engagement on sustainability-related matters with this category remained limited in 2024.

Policies related to affected communities

The company references policies related to affected communities on pages 230, 232, and 235 of the Sustainability Statement - S3: Affected communities section.

The disclosure index indicates that the company addresses sustainability matters including:

• Free, prior, and informed consent (FPIC)
• Security-related impacts
• Adequate food

However, the excerpts provided do not contain the actual policy content from the referenced pages. The index cross-references S3-1 and S3.MDR-P (Policies to manage material impacts, risks and opportunities related to affected communities) to the same page numbers (230, 232, 235), suggesting that policies exist and are disclosed in those sections of the full report, but the specific policy names, content, scope, governance structures, and other details are not included in the excerpts provided.

Taking action on material impacts on affected communities

1. Free, Prior, and Informed Consent (FPIC) Process

What it does: SIPEF conducts FPIC processes with communities before any new land development, ensuring transparent and inclusive decision-making. This includes:

• Engagement of social experts and licensed assessors to guide FPIC processes
• Participatory social and environmental impact assessments (SIAs)
• Collaborative land-use planning with local communities

Scope: Own operations (Indonesia and Papua New Guinea)

Expected outcomes:

• Integrated Conservation Land Use Plans are informed by FPIC results
• No new land is developed without the consent of affected communities
• Management plans are developed based on SIA results

Link to policy: Aligns with Responsible Plantations Policy (RPP) and RSPO requirements

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2. Third-party Verification of Social Impact Assessments

What it does: Third-party verification of SIAs conducted in 2023 began in 2024 to support preparations for new developments and ensure robust assessment processes.

Scope: Own operations (Papua New Guinea)

Time horizon: Ongoing (started 2024)

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3. Community Engagement Department (Papua New Guinea)

What it does: A dedicated community engagement department was established by HOPL in March 2024 to address local concerns and strengthen stakeholder relations.

Scope: Own operations (Papua New Guinea)

Resources allocated (non-financial):

• Dedicated community engagement department staff
• Reporting structure: oversight from group head of sustainability, who reports to executive committee

Time horizon: Ongoing (established March 2024)

Expected outcomes:

• Systematic, context-sensitive engagement that informs decision-making at the highest level
• Improved responsiveness to community-related issues

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4. Youth Empowerment Initiatives (Papua New Guinea)

What it does: HOPL's youth engagement programme aims to mobilize and empower local youth through:

• Service activities (roadside and cemetery clean-ups)
• Training in financial literacy and practical topics (e.g., herbicide handling)
• Legal support for association registration to enable business accounts and contract work eligibility

Scope: Affected communities in Papua New Guinea

Time horizon: Ongoing

Resources allocated (non-financial):

• Led by community engagement department
• Support from sustainability and smallholder teams
• Regular field assessments

Expected outcomes:

• Build life skills and improve employability
• Two youth groups formally registered in Kabaya (achieved)
• Three additional groups in development
• Track participation, training outcomes, and employment connections

Link to policy/target: Supports FPIC process and addresses root causes of security-related risks

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5. Participatory Land-Use Planning and Smallholder Development

What it does: HOPL's integrated HCV-HCSA and SIA assessments conducted in 2023 included participatory mapping to identify areas suitable for future smallholder development. Results are currently undergoing verification.

Scope: Own operations and smallholders (Papua New Guinea)

Time horizon: Medium-term (assessments conducted 2023, verification ongoing 2024)

Expected outcomes:

• Identify inclusive land-use opportunities
• Support community development projects
• Address underlying land-related pressures by promoting inclusive development and livelihood initiatives

Link to policy: Aligns with RPP and NDP commitment

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6. Food Access and Affordability Initiatives

What it does: SIPEF engages in food provision and access initiatives for employees and their families (many of whom are also community members):

• Food provision programmes
• Provision of land for food gardening at accommodation compounds

Scope: Own operations (Indonesia and Papua New Guinea)

Time horizon: Ongoing

Expected outcomes:

• Ensure reliable access to food (basic need and human right)
• Reduce financial burden on households, particularly where food prices and inflation are high
• Support household food access through food gardening

Link to policy: Aligns with RPP and RSPO requirements on local food and water security as integral components of FPIC process

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7. Grievance Mechanism

What it does: Accessible grievance mechanism allowing stakeholders (including local and indigenous community members) to report incidents of misconduct or violation of community rights, including land disputes and compensation issues.

Channels:

• Direct submission at any SIPEF office
• Official online form
• Email
• Through representative institutions (customary councils, local NGOs, traditional chiefs, committees)

Scope: All operations

Time horizon: Ongoing

Resources allocated (non-financial):

• Anonymous reporting capability
• Confidentiality protections
• Explicit protection against retaliation

Expected outcomes:

• All community members can voice concerns effectively regardless of location or literacy level
• Confirmed grievances are followed up by action plans to address them
• Past and ongoing grievances have contributed to SIPEF's double materiality analysis

Link to policy: Grievance Policy; aligns with RSPO requirements

2024 performance: No severe human rights issues or incidents connected to affected communities were reported

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8. Community Programmes Supporting Local Development

What it does: Community programmes supporting local development, well-being, and economic empowerment.

Scope: Affected communities in operating areas

Time horizon: Ongoing

Resources allocated (non-financial):

• Engagement with social NGOs and academic institutions to gather insights on leading frameworks and best practices through desktop research

Expected outcomes:

• Desktop research findings help determine the materiality of sustainability matters
• Support community well-being and economic opportunities

Targets related to affected communities

No targets have been set.

According to the disclosure index, SIPEF has omitted S3-5 (Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities) with the explanation that "targets have not yet been set for material impacts related to affected communities."

High-quality, sustainable, traceable, certified products

SIPEF is committed to producing high-quality, sustainable, traceable, and certified palm oil and bananas. This contributes to the Group's mission to foster a harmonious balance between nature, people, and growth, while also differentiating the Group from other players on the market and providing a competitive advantage.

Goals for this focus area are:

• Implementing the highest food safety and quality standards.
• Maintaining 100% traceability for all products.
• Full compliance with leading sustainability standards and certifications.

High-quality, low contaminant products

SIPEF's commitment to high-quality starts from the initial stages of production and extends throughout its supply chain. This is an important commitment that differentiates SIPEF from its competitors while meeting growing demand for high-end, premium products.

For its palm oil operations, the Group has established comprehensive quality assurance protocols and conducts regular inspections and tests to ensure that its palm oil meets the strictest industry standards for food safety.

SIPEF aims to significantly minimise contaminants, such as Mineral Oil Saturated Hydrocarbons (MOSH), Mineral Oil Aromatic Hydrocarbons (MOAH), and Chloride (the precursor that can lead to a higher formation of 3-monochloropropane-1,2-diol (3-MCPD) and Glycidyl Esters (GE) in the refining process). These contaminants can lead to health concerns if consumed in large quantities.

Taking a leading role in significantly minimising these contaminants positions SIPEF well to respond to growing concerns in consumer countries over additives and specific contaminants in vegetable oils, alongside the requirements of European food safety regulations.

During the course of 2023 – 2024 a series of targeted programmes were successfully implemented, aimed at producing low contaminant crude palm oil (CPO), and thereby unlocking new supply chain opportunities in premium markets.

Stringent safety controls across SIPEF's banana value chain

Effective procedures and controls are in place to uphold the quality and food safety of the Group's banana production. Strict maximum residue levels (MRL) regulations apply for the United Kingdom and the European Union (EU), SIPEF's destination markets.

To ensure consistent compliance with these regulations, and maintain high GLOBALG.A.P. certification standards, year-round assessments across all of the farms of Plantations J. Eglin SA (Plantations J. Eglin) are conducted. These tests assure the readiness and effectiveness of SIPEF's traceability protocols and process, in the unlikely event of a food safety incident.

Should a risk or incident be identified or reported, SIPEF's traceability system enables full tracking of the affected banana, back to its field of origin including harvest details, applied treatments, personnel involved, and processes at packing stations and during transportation.

Control and reduction of MOSH and MOAH

MOSH and MOAH can enter palm oil at different stages of food production including cultivation, processing, storage or transportation.

A Group wide strategy was launched in 2023 underpinned by significant investments in resource capacities, machinery and equipment. Under 'Engineering 2.0' the transition to H1 food grade lubricants was realised for all mills in 2023. Over the course of 2024, the Group progressed to refurbish, upgrade, do maintenance on, or replace all machinery and presses across its mills. New engineering controls and procedures were developed, and the necessary change management and cultural shifts were implemented. As such, across SIPEF's entire operations, state of the art processes, machinery and facilities now significantly reduce the risk of lubrication leaks.

During 2024, all CPO mills and PKO crushers were using only H1 food grade lubricants. Regular and strict sampling was carried out by SIPEF as well as by customers themselves, confirming a clear and consistent reduction in MOSH and MOAH, significantly lower than the European Food Safety Authority, or current customer requirements.

With the success of this programme, SIPEF has firmly placed itself on the market as the provider of low contaminant, high-quality premium CPO.

Prevention of 3-MCPD formation through CPO washing

CPO washing is an effective way to eliminate chloride and ensure a premium product.

In 2024, a pilot CPO washing plant was installed at one of SIPEF's mills in Indonesia. Standard operating procedures were implemented, and in-house testing capabilities and protocols were developed. The first batch of washed CPO was delivered with promising results, placing SIPEF in a leading position to produce CPO with significantly lower chloride levels than those recommended by European food safety standards.

In 2025, SIPEF will continue to invest in developing its state-of-the-art CPO washing capacities in response to customer demands for CPO with significantly lower chloride levels that what is currently available on the market.

As such SIPEF is able, ahead of its peers, to respond to the requests of its customers and are taking the lead in raising the bar and setting new standards with regards to producing premium CPO.

Full traceability for palm oil and bananas

SIPEF is a market leader in traceability, with all its products being fully traceable to their production location, either an estate managed by SIPEF or a supplier smallholder plot.

Traceability goes hand in hand with sustainability, and all the sustainability certification schemes SIPEF complies with require full traceability on sourcing to claim full sustainability of a product. This is important because it enables customers and consumers to ascertain that the products they buy are indeed sourced from certified estates and smallholders, and therefore contribute to environmental, social and economic sustainability.

Traceability is also crucial for ensuring food safety, meeting consumer demands for transparency, complying with regulations, and improving supply chain management and efficiency. SIPEF's traceability capabilities prepare the Group for compliance with the European Union Deforestation Regulation (EUDR), which mandates stringent traceability requirements to ensure that commodities placed on the EU market do not come from deforested land.

SIPEF uses an advanced interactive mapping application called GeoSIPEF to give its palm customers traceability insights and provide comprehensive tracking and verification of product origins. The application makes it possible to view all locations of cultivation and processing, either a block within an estate managed by SIPEF or a smallholder supplier block.

In 2024, SIPEF maintained 100% traceability for its palm oil products and bananas.

Good business conduct

SIPEF maintains the highest regard for ethical business practices, understanding their critical role in mitigating financial, reputational, and legal risks.

SIPEF's good business conduct goals are to:

• Foster a culture of ethical conduct amongst management, staff, and contractors
• Implementing systems and processes to ensure the practice of ethical conduct
• Maintain robust policies, procedures, and measures to address any risks, including those associated with bribery or corruption

GUIDING PRINCIPLES

SIPEF's management and employees, as well as all contracting parties, are governed by a set of Guiding Principles, which shape the conduct and culture of the Group:

1. Reliability and stability - To be a reliable and stable partner for all its stakeholders.

2. Long-term planning and decision making - To always plan for, and make decisions, based on its long-term vision.

3. Continuous improvement - To continuously improve all aspects of its business, focusing on quality, productivity and best environmental, social and governance practices.

4. Sustainable economic growth - To generate economic value for its shareholders and other stakeholders, while striving for a controlled level of debt.

5. Conservation and restoration of the environment - To conserve and, where possible, restore the natural environment within its operations by engaging in sustainable agricultural practices and actively managing conservation areas.

6. Supporting employees and communities - To treat all employees and local communities with respect for their rights, while supporting opportunities to improve their well-being and development.

7. Value creation for all stakeholders - To create value for all its stakeholders, fairly and responsibly.

Responsible supply chain management

SIPEF believes that creating value in a responsible way includes supporting its suppliers to become part of its sustainable supply chain. All of the Group's suppliers are oil palm smallholders, whose locations are known and mapped.

SIPEF's responsible supply chain management goals are to:

• Support smallholders in their journey towards improved, sustainable, and certified production
• Support smallholders to earn higher incomes and have better access to international markets
• Screen and monitor suppliers to ensure compliance with SIPEF policies

Smallholder operations

To complement its own productions and meet market demand, the Group also sources from partner smallholder producers operating on 6 196 hectares near its own sites across Indonesia.

5 540 smallholder suppliers whose production areas are in close proximity to the Group's plantations.

Indonesia smallholder sourcing:

Papua New Guinea smallholder operations:

In Papua New Guinea, SIPEF works with 3 646 certified smallholders across 13 745 hectares of mature areas and 1 180 hectares of immature areas. These smallholders produced 201 965 tonnes of FFB in 2024, compared to 232 414 tonnes in 2023.

SIPEF provides raw materials, best management practices and certification support to enable access to global high-value markets for smallholder suppliers in its supply chain in Indonesia and Papua New Guinea.

SIPEF published its revised Group-level policies on grievances, and on anti-corruption and anti-bribery, in addition to the revisions to its Responsible Plantations and Responsible Purchasing Policies.

SIPEF maintains robust policies, procedures, and measures to address any risks, including those associated with bribery or corruption as part of its good business conduct goals.

Incidents of corruption or bribery

Confirmed incidents and convictions

In 2024, SIPEF recorded zero convictions and zero USD in fines or financial penalties for violations of anti-corruption or anti-bribery laws across its operations in Belgium, Singapore, Papua New Guinea, Côte d'Ivoire, and Indonesia. The Company remains committed to preventing, detecting, and addressing corruption risks through strict compliance measures and ongoing monitoring.

Disciplinary actions and contract terminations

No incidents of corruption or bribery requiring disciplinary action or contract termination were reported in 2024. The Company has established procedures whereby breaches of SIPEF's ACAB Policy may result in contract termination.

Investigation and speak-up procedures

SIPEF has established comprehensive procedures to prevent, detect, and address corruption and bribery, including:

• Mandatory anti-corruption and anti-bribery training for all employees in functions-at-risk (100% completion achieved in 2024, totaling 478 individuals)
• Internal monitoring mechanisms such as regular compliance audits and whistleblowing channels
• Clear reporting pathways through the SIPEF Grievance Solution system for employees and external stakeholders to report concerns confidentially

All grievances received are documented through SIPEF's Grievance Solution system. Each case is reviewed and categorised based on its nature and severity. When a suspected violation is identified, an internal investigation is conducted in accordance with company policies and applicable legal frameworks. In cases of breaches, the severity of the violation may result in contract termination, in line with SIPEF's ACAB Policy.

SIPEF guarantees the confidentiality and protection of whistleblowers from all forms of threats, victimisation, reprisals, intimidation, discrimination, or harassment. Any form of retaliation against whistleblowers is prohibited.

Summary table (2024)

Political influence and lobbying activities

Declaration

Political influence and lobbying activities was assessed as not applicable and not material for SIPEF.

Political engagement approach

While SIPEF does not classify political influence and lobbying as material, the company does engage with policymakers on regulatory matters affecting its operations:

• EU Deforestation Regulation (EUDR): SIPEF actively engages with EU policymakers, industry associations, and certification bodies to advocate for an approach that recognises RSPO certified palm oil as meeting EU sustainability criteria.

• Market access protection: SIPEF engages with stakeholders to maintain compliance and secure market access, particularly for its operations in Papua New Guinea, which relies heavily on European demand.

• Industry dialogue: As part of its reputation management strategy, SIPEF actively engages with industry associations, policymakers, and sustainability initiatives to advocate for responsible palm oil production.

Ethical standards and guidelines

SIPEF's Code of Conduct prohibits:

• Conflicts of interest
• Insider trading
• Bribery
• Improper use of corporate funds

The Code of Conduct ensures transparency in relationships with clients and requires employees to act with integrity and conduct business responsibly in compliance with applicable laws.

Trade association memberships

SIPEF participates in various industry and sustainability associations, including:

• Roundtable on Sustainable Palm Oil (RSPO) – Sustainability certification body
• Oil Palm Growers Association (OPIC) – Supports smallholders and out-growers
• Oil Palm Research Association (OPRA) – Provides extension services and R&D support to smallholders

No specific membership fees or contributions are disclosed.

Focus areas

SIPEF's stakeholder engagement on regulatory matters focuses on:

1. RSPO certification recognition: Advocating for RSPO certified palm oil to be recognized under EU sustainability criteria
2. EUDR compliance: Ensuring alignment between RSPO requirements and EU legislation
3. Sustainable palm oil advocacy: Promoting responsible palm oil production standards
4. Market access: Safeguarding market position in the EU and other jurisdictions

Political contributions and lobbying expenditure

No political contributions or lobbying expenditure are disclosed.

SIPEF's Code of Conduct prohibits the improper use of corporate funds, which would include political contributions not aligned with company policy.