Croda Policy on Grievances in the Palm Sector
Responsibly addressing the social and environmental issues associated with Palm Oil (PO) andPalm Kernel Oil (PKO) is a priority for Croda. In addition to sourcing palm raw materials fromRSPO certified supply chains, Croda is a founding member of the Action for Sustainable
Derivatives (ASD).
Action for Sustainable Derivatives (ASD) is an industry-led collaboration which seeks toachieve the responsible production and sourcing of palm oil derivatives. By promoting collective
transparency, risk management and engagement, the ASD ambition is to create a palm
derivatives supply chain that is free from deforestation, respects human rights, and supports
local livelihoods. ASD supports its Corporate Members to accelerate compliance of their
upstream supply chains with No Deforestation, No Peat, and No Exploitation (NDPE) policy
commitments.
Grievances in the Palm Sector
Croda defines a grievance related to palm oil as any complaint, allegation or concern we identify
that is inconsistent with the Croda Supplier Code of Conduct, our Responsible Palm Sourcing
Policy, or any relevant Croda corporate policies on governance and human rights. Grievances
may cover both environmental and social concerns.
In early 2021 the ASD organization outlined the ASD Collective Statement on Human Rights
which includes specific documentation regarding human rights grievances. Croda is aligned withASD and has signed off on this policy.
ASD Human Rights Approach
ASD is aware of the prevalence and complexity of issues driving human rights abuses in palm
production, whether in the form of forced labor, violence against women and at-risk groups,
child labor, or otherwise. ASD condemns human rights abuses in all forms and in accordance,with the UN Guiding Principles on Business and Human Rights, is committed to proactive
human rights due diligence in the palm derivatives supply chain. This includes working toprevent and mitigate impacts as well as the investigation and remedy of reported grievances.
ASD recognizes the unique position of corporate downstream users of palm derivatives toproactively safeguard human rights. While many share NDPE commitments, they also facesimilar barriers to progress presented by a supply chain characterized by fragmentation, highcomplexity, opacity, and the presence of numerous intermediaries. ASD works to bringalignment within the palm derivatives sector and identify opportunities for collective action bothwithin the ASD group and more widely with organizations active in the human rights andsustainable palm space.
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ASD Framework for Action
ASD has developed a framework for action tailored to the palm derivatives sector which outlines
levers of influence to address and uphold human rights in palm production. This framework
includes:•Collective Transparency: ASD provides annual supply chain mapping for its individual
corporate members and collectively for the palm derivatives sector to provide visibility ofsource to the refinery, crusher, and producer group. ASD identifies and informs members ofpotential linkages between their supply chains and reported human rights grievances.

•Risk Prioritization & Dynamic Monitoring: With an aggregated and anonymized collective
sourcing list, ASD has been able to leverage and overlay environmental and social risk dataand assessments. ASD identifies the priority geographies for members to focus engagement
efforts to improve practices.
Approaches are continuously updated in line with industry developments, e.g. the NDPE
Implementation Reporting Framework. The ASD is also investigating proactive monitoringalerts to NDPE non-compliance and where possible, identifying synergies with other industry
stakeholders.

Impact Strategy
Having established a common framework that identifies key sourcing areas and collective
supply chains, the ASD is further developing its impact strategy, focused on:•Collective Supply Chain Engagement: ASD aligns corporate member expectations tosupport transparency and sustainability in the palm derivatives supply chain.
ASD monitors and engages existing human rights and sustainable palm initiatives. For
example, ASD aligns with the Consumer Goods Forum’s (CGF) development of a common
Human Rights Due Diligence (HRDD) approach via the Human Rights Coalition: Working toEnd Forced Labour.
ASD has further developed its engagement strategy to address prioritized grievances via agrievance taskforce, and more broadly, collective mechanisms to engage with indirect
supply chain players (refineries, crushers, and producer mills) prioritized based on socialand environmental risk profile.

•Shared Strategy for Impact on the Ground: ASD also deploys collective support toexisting landscape projects through a collective funding model.

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ASD Grievance Prioritization Procedure

Croda Palm Grievance Procedure
The Croda Palm Grievance Procedure aligns with the United Nation’s Guiding Principles (UNGP’s)on Business and Human Rights, relevant RSPO policies, RSPO complaints procedure, and theRSPO principle of no tolerance for retaliation against grievance raisers and whistle-blowers.
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Grievances identified via ASD prioritization procedure will be dealt with by Croda according tothe following flow:
1.
Identificationof potential
noncompliance

Alert / Grievance identified throughcompany's grievance proactive monitoring(satellite or reports)

Alert / Grievance directly reported bycivil society, a worker or a victim
through a company's channel

Acknowledgement of the Alert / Grievance2. Analysis &Assessmentof Severity

Prioritization of theAcknowledged Alert /Alert / Grievance notprioritized

Decision to characterize the Alert /Grievance as Prioritized

Deeper investigation:* In-depth analysis of the case* Exchanges with relevant stakeholders(grievance raiser, targeted company,supplier, industry players, etc.)* Detailed individual supply chain reports

Characterization ofthe Alert / GrievanceNon-compliance notestablished3.
Implementation of Action
Plan /
Remediation

Non-compliance established not linked to company's
supply chain

Non-compliance establishedor need for further
investigation

Possible public statement related to theAlert / GrievanceEngagement with supplier

Design and implementation of a response:
action plan, remediation...

4. Monitoring,
Verification &Reporting

Monitoring of the Alert / Grievance evolution& Resolution

Non-resolved Alert /Grievance
Resolution of theAlert / Grievance

Communication with the Alert / Grievance
Raiser & Stakeholders

Non-compliance resolved

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We will publicly release the list of grievances in our supply chain and disclose how we have
responded to and addressed them.
Footnote: Launched in late 2019, Action for Sustainable Derivatives is a sector-wide initiativethat brings together companies in the cosmetics, home and personal care, healthcare, andoleochemicals industries to collective tackle supply chain issues around palm oil.
ASD facilitates the sharing of information, data, constraints, and solutions to accelerate
wholescale transformation of the palm derivatives sector. ASD also acts as an operational
platform, providing tools, methodologies, and concrete opportunities for its members to partneron specific topics. ASD’s activities are rooted in its impact vision, mission, and strategic
framework.
ASD operates in the pre-competitive space and complies with Anti-Trust Regulations.
ASD is co-managed and co-facilitated by BSR and Transitions, two organizations with extensive
experience and expertise in supply chain sustainability and business collaborations.

Croda Policy on Grievances in the Palm Sector October 20225