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Materiality
                                      Assessment    Appendix 1:    Appendix 2:   Appendix 3:
            Climate  Green   Inclusive   and Stakeholder   GRI Content   Assurance   Glossary of
            Action  Innovation  Progress  Engagement  Index  Statement  Terms













          In further recognition of certain vulnerable and    No  Activities
          marginalised groups  that may be at higher risk
                         3
          of being adversely impacted by our operations or   1.  Policy
          our supply chain, we adhere to the principles laid   • Launch of Apical Group Human Rights Policy
          out in the Convention on the Elimination of All
          Forms of Discrimination Against Women (CEDAW),    2.  Communication & Awareness
                                                        •  Internally to facilities
          United Nations Declaration on the Rights of   •  Externally  to  suppliers  (virtual  and  physical
          Indigenous Peoples (UNDRIP), Indigenous and     sessions)
          Tribal Peoples  Convention, United Nations
          Declaration on Human Rights Defenders and the   3.  Supplier Commitment
          United Nations Convention on the Rights of a Child   •  Supplier engagement letters with human rights
          (UNCRC).                                        commitments
          We shall adhere to all applicable national laws and   4.  Internal Policy and Standard Operating
          regulations throughout our operations. If there are   Procedure (SOP) review
          discrepancies between national and international   •  Identification  of  policies  and  SOP’s  for
          laws, Apical shall strive to adhere to the highest   review and development including Grievance
          applicable standards.                           Procedures
                                                    5.  Governance
          This Human Rights Policy is complementary to the   •  Developing a governance structure for human
          Apical Group Sustainability Policy, reinforcing our   rights implementation and monitoring
          commitment to ethical and responsible business
          practices across our entire operations, including   6.  Identify and Assess Risks and Impacts
          joint ventures, subsidiaries, and direct and indirect   •  Human Rights Impact Assessment (HRIA)
          suppliers within our palm oil supply chain.   •  Deployment of Palm Oil Collaboration Group
                                                          (POCG) HRDD checklist for refineries
              For more information on                   •  Action Plan development based on issues and
              Apical's Sustainability Policy,             risks determined
              please scan the QR code
                                                    7.  Disclosure and Reporting
                                                        •  Internal  and  External  reporting  on  human
                                                          rights
          Furthermore, to demonstrate our unwavering   8  Implementation & Monitoring
          commitment to this policy, we plan to strengthen our   •  Social Impact Assessments (SIA) for facilities
          existing sustainability framework by incorporating   •  Sedex  membership  and  SMETA  audits  for
          clear  targets,  milestones,  and  performance   facilities
          indicators specifically focused on human rights. We   •  Penilaian Resiko Bisnis Dan Ham (PRSIMA from
          have developed a comprehensive implementation   kemenkumham) verification for suppliers
          plan  for  fiscal  years  2024/2025,  outlining  specific   •  Monitoring  for  Indigenous  Peoples  &  Local
                                                          Communities’ risk using Badan Registrasi
          goals and timelines for achieving our human     Wilayah Adat (BRWA) maps for suppliers
          rights commitments. This plan will demonstrates   •  Implementation  of  Human  Rights  Action
          our  transparency  and  accountability  in  upholding   Plans  developed  and  monitoring  gaps  for
          human rights throughout our operations and      improvement
          supply chain.

          3  Includes (and not limited to) women, children, religious and ethnic minorities, indigenous peoples, environmental and human rights
           defenders and migrant workers

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