Croda International Plc

Sustainable palm oil statement
Using natural resources brings a responsibility to ensure there are no associated negativesocial or environmental impacts, and an opportunity to advocate for, and contribute to, positivechange. This is only possible through intimate knowledge of our supply chains, collaboration
with all parties in them, and with complete transparency and traceability. This is the heart ofSDG 17, Partnership for Goals, with effective collaboration in the supply chain resulting ingreater positive impacts.
Croda is a founder member of the Action for Sustainable Derivatives (ASD) organisation, whooverlay environmental and social risk data and assessments to enable members to focus ourtransparency, risk management, and engagement efforts to improve and influence bestpractices. In 2022, we worked with ASD to publish our Grievance Policy in the palm derivatives
sector and supported the launch of the first ASD Impact Fund, Kaleka Mosaik Initiative,
aimed at driving positive impact in priority production landscapes in Central Kalimantan andIndonesia. We are also participating with ASD in a collaborative satellite monitoring pilot tocreate a methodology to identify and confirm deforestation-free mills, refineries andplantations.
Our palm sourcing policies fully support the RSPO Principles and Criteria 2018, and we haveachieved our goal of 100% certified palm purchasing on a mass balance or segregated basis
for our global operations. We are working with our joint venture partner in China to convert
palm purchasing to certified sources, and we aim to achieve this by the end of 2025. We arealso working to align our supply chains with the High Carbon Stock Approach (HCSA)
requirements and the Accountability Framework Initiative roadmap. We recommend the useof the HCSA framework to identify and conserve high carbon stock forests.
Requirements
Both Croda operations and our suppliers are required to comply with NPDE (no Deforestation,no Peat, no Exploitation) providing confirmation of compliance based on the following:
1. A public policy of no deforestation including a commitment to no-conversion production
or sourcing.
2. No fires and no plantation on peatlands regardless of depth.
3. No planting on High Conservation Value (HCV) areas and High Carbon Stock (HCS)
areas with management and monitoring plans that follow the HCV and HCSapproaches.
4. Respect for workers’ rights, of the legal and customary rights as well as the Free Priorand Informed Consent (FPIC) of Indigenous communities, no forced labour, no slave
labour, and no child labour. In the absence of a Decent Living Wage in a given country,
palm oil growers must engage with their workers to mutually agree terms.
5. Full compliance with the laws in the country where Croda and/or suppliers operate.
6. Support for smallholders and growers to develop outreach programmes to support
smallholders with sustainability and business skills.
7. Management and monitoring plans that include targeted reductions of GHG emissions.
8. Support of our transparency and traceability work either directly or through adesignated Croda third party.

Croda International Plc

To meet the requirements of the EUDR legislation from 1 July 2023, we shall ensure that ourspecific commodities and related products (palm and other regulated feedstocks) are:
• Produced free of deforestation/forest degradation, produced on land that was not
subject to deforestation after 31 December 2020. A retrospective assessment isrequired.
• Produced in compliance with the laws of the country of origin covering human rights;
labour laws; environmental and land use regulations; anti-corruption; and tax, tradeand customs legislation.
• Accompanied by a due diligence statement confirming the deforestation-free andlegality status.
Responsibilities
The President Operations owns this Policy, and the Exec Sustainability Committee Chair
working with the Sustainability Committee leads corporate governance oversight of the Policyand compliance.
The Global Head of Procurement ensures corporate Policy and implementation processes arein place, develops organisational competence, and reports compliance quarterly.
Regional Vice Presidents are responsible for implementing the Policy, organisation,procedures and assurance processes for all suppliers in scope within their region.

Michelle Marie
Global Head of Procurement and Sustainable Sourcing
We will continue to publish progress against our commitments through our annual
Sustainability Report, on our website and within the RSPO’s Annual Communication ofProgress.