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Sustainability Action Plan

No Area Activity Sub-activity 6 months 12 months 18 months Update January 2023 Update March 2023 Update February 2024
A GOVERNANCE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
A.1 Structure Review and strengthen organization structure (especially the sustainability team and GIS team) to allow clear role and collaboration between teams. A1.1.1 Review and finalization of organization structure Completed. Completed. Completed
A1.1.2 Establish role function, job description, and authority level   Completed. Under implementation, with Quarterly KPI stetting Completed Completed
A1.1.3 Resource audit and hiring of relevant people to fill in any gaps in the structure Completed. Completed. Completed
A1.1.4 Socialization and implementation of new organization structure On-going On-going Completed
A.1.1.5 Evaluation of organization structure On-going On-going Completed and being implemented on annual basis
A.2 Coordination and Oversight Establish regular meetings on sustainability issues A.2.1.1 Establish regular meeting on mill/plantation level and regional level On-going. On-going. On-going.
A.2.1.2 Establish sustainability steering committee and its regular meeting On-going. On-going. On-going.
Establish sustainability related Key Performance Indicators A.2.2.1 Establish clear KPIs for sustainability team Completed Completed Completed
A.2.2.2 Establish additional sustainability related KPIs for non-sustainability teams On-going On-going On-going
A.2.2.3 Evaluation of KPIs On-going On-going On-going and annual basis implementation
A.3 Talent and Culture Training / Capacity Building A.3.1.1 Conduct training needs assessment to create sustainability training plan for relevant people On-going On-going On-going
A.3.1.2 Implement and establish a training record On-going On-going On-going
A.4 Infrastructure and logistics Establish relevant policies and SOPs A.4.1.1 Establish SOP on stakeholder management Completed. Completed. Completed.
A.4.1.2 Establish SOP and system to track legal requirement Completed. Under implementation Completed. Under implementation Completed. Under implementation
A.4.1.3 Establish SOP for boundary demarcation and its maintenance Completed. To be trialed when on-going arrangements with Liberia Land Authority (LLA)  and other stakeholders are completed for boundary review. Completed. To be trialed in Tarjuowon in clan boundary remapping exercise Completed and being implemented. 
A.4.1.4 Review and update FPIC and PM SOP according to: Module 2 – Social requirements (version 2.0 May 2017) Module 3 – Integration of HCV HCS Forest and FPIC (version 2.0 May 2018) FPIC guide for RSPO members Completed and being implemented.  Completed and being implemented.  Completed and being implemented. 
A.4.1.5 Establish SOP for participatory mapping for disputed areas Draft completed. To be tested after resolution of Blogbo dispute. Second site visit by independent facilitator was carried in Mar 2021. Awaiting final facilitation report, and decision by RSPO. Completed. To be trialed in Tarjuowon in clan boundary remapping exercise Completed and being implemented. Include to solve disputed area between Numopoh & DWN which assistance by Liberia Land Authority.
A.4.1.6 Establish SOPs for mill operations in appropriate languages Completed; decision to do in English only, as the official language of Liberia Completed; decision to do in English only, as the official language of Liberia Completed; decision to do in English only, as the official language of Liberia
A.4.1.7 Establish SOP for monitoring of environmental management plan, implementation, and reporting Completed.  Completed.  Completed. 
A.4.1.8 Establish SOP for HCV HCS Peat management and monitoring Draft completed . Review of  EF assessment report submitted, and currently guiding the implementtation of the Draft SOP. Draft completed.  Being reviewed for approval Completed and on going on the implementation. Management & Monitoring plan of HCV HCS approved by GVL Top Management.
A.4.1.9 Establish SOP and system for grievance handling for both external and internal stakeholders. Also add mediation step before legal option. Completed. In use. Completed. In use. Completed and implemented. 
A.4.1.10 Establish SOP to describe the process of information sharing and dissemination Completed. Completed. Completed
A.4.1.11 Review the recently announced Human Rights Defender Protection protocol by the RSPO and develop policy on human rights Completed Completed Completed
A.4.1.12 Review Greenbook SOP to be clearer on pest attack intensity and IPM Completed. Completed. Completed
A.4.1.13 Revise Greenbook SOP section 6.5.3 on empty pesticide package disposal Completed. Completed. Completed
A.4.1.14 Review recruitment policy to include a statement on no recruitment of workers under 18 years old Completed. Completed. Completed
A.4.1.15 Review recruitment policy to include non discrimination based on sexual orientation, union membership, and political affiliation Completed. Completed. Completed
A.4.1.16 Update policy of promotion to include non-discrimination promotion Completed. Completed. Completed
A.4.1.17 Establish policy to ensure no harrasment or abuse in the work place and reproductive rights are protected Completed. Completed. Completed
A.4.1.18 Establish policy on forced trafficked labor Completed. Completed. Completed
A.4.1.19 Establish SOP for waste management that cover all of the waste produced by operational including domestic waste. Completed. Completed. Completed
A.4.1.20 Establish policy to circumvent instigated violence to maintain peace and order Completed. Completed. Completed
A.4.1.21 Establish SOP for third party FFB sourcing Completed. Completed. Completed
A.4.1.22 Establish SOP for pollution and GHG emission mitigation or reduction Completed. Completed. Completed
Data and document management A.4.2.1 - Establish clear filing system for data and documents Completed. In operation. Completed. In operation. Completed and being implemented. 
- Ensure that documents and records are protected and retrieval (clarify the responsibilities and authorities for back up and the medium to be used)
- Establish systematic endorsement of documents shared with the communities (meeting minutes, maps, etc.)
A.4.2.2 Establish a clear hand over procedure and induction for new personnels on sustainability Completed. Completed. Completed
A.4.2.3 Strengthen the sustainability team in the documentation and filing system (hard and soft copy). Need to be enforced through KPIs Done. In operation. Done. In operation. Completed and being implemented. 
A.4.2.4 Strengthen the capacity of the sustainability team to ensure rigorous data record (meeting minute, evidences, endorsements, …) for every meeting with communities/ complaints.  Done. In operation. Done. In operation. Completed and being implemented. 
A.4.2.5 Evaluation of data and document management On-going. On-going. On-going.
Tracking of legal A.4.3.1 Establish a list of legal requirement and the copy of laws and regulations Completed. Completed. Completed
A.4.3.2 Establish a comprehensive system to track legal requirements, its update and its compliance analysis, including  personnel in charge, source of information, and frequency of update to track the regulation and legal law update. Draft completed. Under review Draft completed. Under review Draft completed. Under review to be implemented
A.4.3.3 Conduct an assessment of compliance (internal audit) to ensure that all legal requirements are fulfilled On-going. Quarterly updates. On-going. Quarterly updates. On-going bi-annual basis implementation
Establish baseline maps A.4.4.1 Establish clear and agreed baseline maps for: Done. In regular use Done. In regular use Completed and implemented. 
- soil fragility map
- slope map
- HCV and HCS maps
- Community map and participatory maps
- Land conflict map / encroachment area
- Area planted / developed
A.4.4.2 Establish clear guidance on map production, verification, approval and sharing. Ensure that RSPO needs are followed. Completed. In regular use Completed. In regular use Completed and implemented. 
Appropriate logistics A.4.5.1 Assess the logistic needs of the sustainability and GIS team and plan for their provision (transportation, computers, handheld GPS, etc.) Done. Done. Completed
A.4.5.2 Fulfilment of logistical needs On-going. Improved  in allocations under 2022 Annual Budget. Still affected by cost-cutting measures in response to global economic downturn. On-going. On-going.
B ENVIRONMENTAL MANAGEMENT
B.1 No development of and conservation of HCS areas Organize a training on the new HCS Approach especially on: oModule 2 – Social requirements (version 2.0 May 2017) oModule 3 – Integration of HCV HCS Forest and FPIC (version 2.0 May 2018) B.1.1.1 Explore opportunity for HCS training with HCSA Africa and attend training when available Exploring appropriate training opportunities in Africa. Secondment of GAR expert to do in-house training planned Secondment of GAR expert to do in-house training, planned within 2024
B.1.1.2 Obtain approval from HCSA on the reports and maps Reviewing pending grievance case developments To follow RSPO process, given GAR withdrawal from HCSA To follow RSPO process, given GAR withdrawal from HCSA
Review the previous HCS work (Grand Kru & Sinoe) in alignment with the new HCS Approach toolkit (integration of the community livelihoods programme (COPP perspective and alternative livelihoods) B.1.2.1 Review all HCS work (Grand Kru and Sinoe) and produce new updated HCS reports and maps to be submitted to HCSA Done.  Done.  Done. 
B.1.2.2 Ground check of HCS clearance claim and develop remediation action. Develop and implement the ICLUP (Integrated Conservation and Land Use Planning) Report completed and submitted to HCSA. Action plan developed for  mitigation, and under implementation. ProForest developing HCS remediation plan.   ProForest supporting HCS remediation plan. Mapping done and community agreement obtained for remediation plan. Official approval from relevant authorities delayed because of transition of presidential administraiton.
B.1.2.3 Define a prospective land acquisition plan for all the new development (Example: Barclayville, Juazon, etc.) Yet to commence. Subject to further consideration on the proposed  new areas. Expansion drive suspended indefinietly. Yet to commence. Subject to further consideration on the proposed  new areas. Expansion drive suspended indefinietly. Yet to commence. Subject to further consideration on the proposed  new areas. Expansion drive suspended indefinietly.
B.2 No development of and conservation of HCS areas Develop management and monitoring plan as well as implementation for protecting the HCV area. B.2.1.0.1 Conduct HCS assessments on all developed areas; construct land use change maps, establish cleared HCS and develop new baseline maps As in B.1.2.2 above. HCS assessments completed for existing MOU areas.  HCS/HCV management / monitoring SOP being reviewed HCS assessments completed for existing MOU areas.  Management & Monitoring plan of HCV HCS approved by GVL Top Management.
B.2.1.0.2 Conduct HCV/HCS Assessments for MoU areas for planned development As in B.1.2.2 above. As above As above
B.2.1.0.3 Update HCV/HCS maps As in B.1.2.2 above. As above As above
B.2.1.0.4 Get community agreement and incorporate into MOU As in B.1.2.2 above. As above As above
B.2.1.1 Development of management and monitoring plan according to established HCV maps.  As in B.1.2.2 above. As above As above
B.2.1.1.1 Development of forest restoration / remediation / conservation plan based on HCSA decision  As in B.1.2.2 above. As above As above
B.2.1.2 Conduct socialization to Operations, workers and community to increase awareness and protection of HCV and HCS areas On-going as part of routine community and employee engagement. On-going as part of routine community and employee engagement. On-going as part of routine community and employee engagement.
B.2.1.2.1 Demarcation of buffer zones and no-go areas On-going On-going On-going
B.2.1.3 Conduct field inspections conducted regularly to ensure implementation of mitigation plan Inspection on-going. To be reviewed and consolidateed subject to final report of HCV-HCS re-assessment, and submission of mitigation plan. Inspection on-going.  Filed inspections carried out according to the Management Plan regularly.
B.3 Yield improvement without intensification of use of chemical pesticides and fertilizers Establishment of integrated pest management B.3.1.1 Establishment of IPM Plan, which contain identification of potential pests and thresholds, technic use to control (cultural, biological, mechanical and physical methods) pest attacking, identify and plant native species used as part of biological control method refer to SOP and Concession Agreement. Completed. Completed. Completed
B.3.1.2 Having well documented IPM implementation records including records of training to IPM workers Completed. Completed. Completed
Proper usage of POME for fertilizers B.3.2.1 Conduct study of the optimum area for POME application for effluent mill with capacity 40 mt FFB/hour and for new pond capacity. Completed. Completed. Completed
B.3.2.2 Tarjuowon North (TNRE) estate/TRJM needs to record how much the total POME application, replace broken flowmeter Completed. Completed. Completed
B.3.2.3 Building of additional POME pond Completed. Completed. Completed
B.4 Greenhouse gas emissions Report and reduce greenhouse gas emissions B.4.1.1 Conduct assesment of pollution and GHG emission resource from the entire operational aspect . Completed. Completed. Completed
B.4.1.2 Establish action plan to mitigate or reduce the pollution and GHG emission. Completed. Completed. Completed
B.4.1.3 Calculate the operational GHG emission using RSPO GHG calculator ver.3.1 and report it to RSPO. Done. Iterative process. Done. Iterative process. Done. Iterative process.
B.5 Waste management Improve waste management B.5.1.1 Check BOD and other parameter in POME discharge to plantation refer to regulation. Done. Iterative process. Done. Iterative process. Done. Iterative process.
B.5.1.2 Engage the government about the license/permit for the hazardous warehouse base on the EMPL Regulation Section 64. Engagement done. Licencing process under periodic review. Engagement done. Licencing process under periodic review. Engagement done. Licencing process under periodic review.
B.5.1.3 Stored and disposed used chemicals and their containers responsibly according to GVL Procedure, EMPL and best practices. Done. Iterrative process. Done. Iterrative process. Done. Iterrative process.
B.5.1.4 Have well documented waste management and disposal plan to avoid or reduce pollution. Completed. Completed. Completed
B.5.1.5 Arrange logbook for hazardous warehouse. Some of the amount must refer to the logbook of general warehouse. For example amount of ex-pesticide bin in to the hazardous warehouse must be consider to the amount of pesticide bin put from chemical warehouse. On-going. Iterative. On-going. Iterative. On-going. Iterative.
B.5.1.6 Develop the implementation of 3R (Reduse, Reuse, Recycle) and separation of domestic waste into organic and inorganic waste to simplify the management. Completed. Completed. Completed
B.6 Energy efficiency  Improve energy efficiency  B.6.1.1 Improve efficiency of the use of fossil fuel and optimization of renewable energy. On-going On-going On-going
B.6.1.2 GVL should calculate how much renewable energy use per ton CPO or palm product, estimated fuel use by on-site contract workers and transport and machinery operations and electricity use in operations.  Draft completed. Review on-going. Draft completed. Review on-going. Draft completed. Review on-going.
C SOCIAL AND COMMUNITY ENGAGEMENT
C.1 FPIC Process Review all FPIC process to fulfill any process and documentation gaps C.1.1.1 Review and update the FPIC documentation process in alignment with the SOP that will be updated. This include improvement of scoping process and identification of community's self chosen representatives Completed. Completed. Completed
C.1.1.2 Conduct the boundary demarcation based on FPIC procedure with clear markers and maintain them regularly. In collaboration with Liberia Lands Authority (LLA). Implementation target deferred until further notice, due to review of funding mechanism. In collaboration with Liberia Lands Authority (LLA). Implementation target deferred until further notice, due to review of funding mechanism. In collaboration with Liberia Lands Authority (LLA), to be done as part of the ongoing MOU review process with all communities. National Bureau of Concessions to assist communities
C.1.1.3 Improve ESIA report by conducting participatory SIA assessment . Develop plans for avoidance or mitigation of negative impacts and promotion of the positive and monitoring of impacts. Entire environmental and social requirements subject to on-going discussions with RSPO. Entire environmental and social requirements subject to on-going discussions with RSPO As above
C.1.1.4 Develop a monitoring system with regular reporting to outline the plan on mitigation, implementation and monitoring according to the SIA report. Entire environmental and social requirements subject to on-going discussions with RSPO Entire environmental and social requirements subject to on-going discussions with RSPO As above
Review all MOUs to fulfill any process, documentation gaps and the implementation level of each MOUs signed C.1.2.1 Converting provisional MOUs to permanent MOUs, whether to include maintenance and refurbishment schedules (for specified period) in updated Social Agreements. Proposed permanent MOUs sent to all communities for review in November 2022 . Target completion depends on agreement of independent facilitator appointed by RSPO for community with recorded grievances, and / or the response of communities in securing legal advise and making their input for others.  Proposed permanent MOUs sent to all communities for review in November 2022 . Target completion depends on agreement of independent facilitator appointed by RSPO for community with recorded grievances, and / or the response of communities in securing legal advise and making their input for others.  GVL continues consultation on MoU finalization / conversion with each Community through their representatives (CRCs). Communities will review the draft of MoUs with NBC assistance. Timeline and process to be determined by communities as per FPIC guidance.
  C.1.2.1.1 Butaw Already Permanent. Review process on-going. Already Permanent. Review process on-going. Already Permanent. Review process on-going.
  C.1.2.1.2 Tarjuowon Already Permanent. Review process on-going. Already Permanent. Review process on-going. Already Permanent. Review process on-going.
  C.1.2.1.3 Others Already Permanent. Review process on-going. Already Permanent. Review process on-going. Already Permanent. Review process on-going.
C.1.2.2 Define a company standard (quality, type, budget, …) for each type of infrastructure to be constructed or rehabilitated Done. Done. Done.
C.1.2.3 Prepare the budget needed to fill the implementation gaps as per the agreed timeframe of each MOUs signed. Done. Done. Done.
C.1.2.4 Improve joint monitoring (GVL and communities) of MoU implementation and release an annual report. Completed.  Completed.  Completed
C.1.2.5 Clarify to the communities the following concept:    areas developed/planted,    areas developed non planted (infrastructure, conservation, etc.)     areas non developed non planted (conservation areas) and the implication on communities benefits (CDF, employment, taxes, etc.) On-going. Iterative. On-going. Iterative. On-going. Iterative.
C.1.2.6 Review development maps (from the base maps including the version shared with local communities) and conduct the reconciliation process. Part of the on-going MOU Review. Some communities seeking third party support for verification of boundaries and acreages.  Part of the on-going MOU Review. Some communities seeking third party support for verification of boundaries and acreages.  Part of the on-going MOU Review. Some communities seeking third party support for verification of boundaries and acreages. 
C.2 Responsible handling of conflict and grievances, and resolution of conflict Improve the system to ensure that complaints or grievances including land claims are addressed or resolved in an effective, timely and appropriate manner (internal and external) C.2.1.1 Socialize SOP on grievance and conflict handling and have a proper documentation and resolution process. Deeper training for social team including use of complaint management table and assign a team member per estate to be in charge of the complaint management table On-going.  On-going.  On-going. 
C.2.1.2 Establish internal grievance committee including Operation & Sustainability. Done. On-going. Done. On-going. Done. On-going.
C.2.1.3 Ensure that all documents related to grievance resolution are properly stored and access to the document. Done. On-going. Done. On-going. Done. On-going.
C.2.1.4 Conduct monthly review and summary of grievances and complaint in each Estate and feed the Top Management dashboard to support decision making in term of improvement (stakeholder engagement, etc.) On-going.  On-going.  On-going. 
C.2.1.5 Create awareness to communities on GVL grievance management system. On-going (iterative). On-going (iterative). On-going (iterative).
C.3 Open and constructive engagement with local, national and international stakeholders Stakeholder management system C.3.1.1 Conduct stakeholders mapping and categorization (local communities and their respective diaspora, government, CSO, development organization, workers, etc. ) at:    County level    National level and    International level Etc. Done. Done. Done.
C.3.1.2 Develop logbook of information requests and responses. On-going. Iterative. On-going. Iterative. On-going. Iterative.
C.3.1.3 Develop and maintain list of publicly available document and the stakeholders related to those information Done.  Done.  Done. 
C.3.1.4 Set up the stakeholders platform per County of operation To be rationalised. Discussions with NBC on-going. Ministry of Internal Affairs (MIA) is also setting up a similar platform to contonue/complement that of NBC. HCSA Remediation Plan also requires setting up of Multi-Stakeholder Platform, and is currently under development. Discussions with NBC on-going. Ministry of Internal Affairs (MIA) is also setting up a similar platform to contonue/complement that of NBC.  Discussions with NBC on-going. Ministry of Internal Affairs (MIA) is also setting up a similar platform to continue/complement that of NBC. Plans may change because of new government administration
C4 Community development programmes Implementation of CDF C.4.1.1 Continue the channeling of funds as agreed to the community On-going On-going On-going
C.4.1.2 Establish detailed information on its progress on CDF, strategy and timeline to fulfill this commitment in its progress report. In addition, the company shall also inform the communities whether any program is postponed On-going. On-going. On-going.
C.4.1.3 Continue the brainstorming with IDH and keys stakeholder on the COPP Process temporarily suspended pending further consultation with government, and  review of alternative  suitable model and financing mechanisms. GVL also exploring other options outside this on-going consultation. GVL also exploring other options as part of Tarjuowon facilitated discussions. GVL also exploring other options outside and this is on going consultation.
C5 Land tenure rights Develop  appropriate  land  tenure  study  guidelines to provide guidance on conducting land tenure study in order to understand the traditional land ownership system in a community and rules and mechanism in ownership transfer C.5.1.1 Improve Land Tenure Study according to RSPO guideline 2015 Yet to commence. The feasibility of implementation to be reviewed. Part of MOU discussions Part of the MOU discussions
C.5.1.2 Improiving Participatory Mapping according to RSPO guideline 2015 On-going. Iterative. On-going. Iterative. On-going. Iterative.
C.5.1.3 Raise awareness to the sustainability staff on the new land Act and the potential implication on the outreach Done. Done. Done.
D LABOUR ENGAGEMENT
D.1 Responsible Employment Documented and transparent recruitment D.1.1.1 Ensure the recruitment process prioritizing local community base on signed MoU. On-going. Routine process.  On-going. Routine process.  On-going. Routine process. 
D.1.1.2 Calculate the worker quota of every county can be recruited base on manpower requirement and potential MoU released. On-going. Routine process.  On-going. Routine process.  On-going. Routine process. 
D.1.1.3 Develop, disclose and implement a transparent recruitment procedure for skilled/specialized position and non skilled position. On-going.  On-going.  On-going. 
D.1.1.4 Ensure full alignment with the Operation and Social team on areas planted prior to any communication to the communities for employment. On-going. On-going. On-going.
D.1.1.5 Review and revise the recruitment mechanism in HR Manual and HR Recruitment Policy ensure there are the clauses set the recruitment or job training  process proposely hired from the local community without any payment and transparent. also about job vacancy information to the town and city leader if required. On-going. Under routine improvement. On-going. Under routine improvement. On-going. Under routine improvement.
D.1.1.6 Set up the publication of the community recruitment to external stakeholders. Done. Done. Done.
D.1.1.7 GVL support the local worker to have the ID. Completed. Completed. Completed
Acquaint the employee to the company D.1.2.1 Establish a policy or procedure for new employee/worker include socialization of regulacy, CBA, job description, contract, recruitment related to MoU, working hours, etc On-going. Under review, as part of company restructuring. On-going. On-going.
D.1.2.2 New Employee orientation:  socialization of regulacy, CBA, job description, contract, recruitment related to MoU, working hours, etc On-going (iterative). On-going (iterative). On-going (iterative).
Ensure provision of proper contract D.1.3.1 Identify the worker who have not signed a contract Completed for existing employees.  Completed for existing employees.  Completed for existing employees. 
D.1.3.2 Make sure the worker keep the copy of the contract Done.  Done.  Done. 
D.1.3.3 Consider the workers who do not speak english, and arrange the contract with their language Done.  Done.  Done. 
D.1.3.4 Revise the contract format, and add on the other relevant information i.e. working hours, union membership and the membership fee Revision done. Ammendments incorporated into completed CBA review; will be concluded when organizational restructuring is finalized. Revision done. Ammendments incorporated into completed CBA review Revision done. Ammendments incorporated into completed CBA review
Ensure proper salary administration and on time payment D.1.4.1 The deduction of salary should have an agreement from the relevant workers. So, for current workers who have had a contract so company needs to arrange the power of attorney to company to deduct their salary for NASSCORP, union, etc  On-going. Iterative. On-going. Iterative. On-going. Iterative.
D.1.4.2 Consider to implement the regulation that stated in the HR manual to review the basic salary annually On-going. Iterative. On-going. Iterative. On-going. Iterative.
D.1.4.3 Propose to initiate a living wage study for the workers Yet to commence. Awaiting national DLW benchmarking, possibly with inputs/support from RSPO DLW initiative Yet to commence. Awaiting national DLW benchmarking, possibly with inputs/support from RSPO DLW initiative Yet to commence. Awaiting national DLW benchmarking, possibly with inputs/support from RSPO DLW initiative
Ensure compliance of working time D.1.5.1 Conduct the SOP of finger printing Completed. On-going. Completed. On-going. Completed. On-going.
D.1.5.2 Conduct the procedure/policy of break time of worker that need to stand by i.e, security, machine operator in mill, etc  On-going. Part of completed CBA review and company restructuring. On-going On-going
D.1.5.3 Working hour procedure in CBA needs to adjust to the regulation stated in HR and Employement refference Manual On-going. Part of completed CBA review and company restructuring. On-going On-going
D.1.5.4 Procedure to conduct the over time working (overtime agreement letter, detail payment). On-going. Part of completed CBA review and company restructuring. On-going On-going
D.1.5.5 Manage the working and overtime hour for FFB driver at the certain condition. i.e ffb truck driver stuck due to bad road condition. On-going. Part of completed CBA review and company restructuring. On-going On-going
Implementation of Child Labor and forced labour policy D.1.6.1 Ensure proper working permit for all expat staff On-going. Updated for all relevant staff. On-going On-going
D.1.6.2 Increase the socialization on No Child Labor and no forced labour through poster or directly in the morning muster. On-going (iterative). On-going (iterative). On-going (iterative).
D.1.6.3 Socialization to the community about No child labor. On-going (iterative). On-going (iterative). On-going (iterative).
Provide education access for all children D.1.7.1 Conduct the education need assessment to analyse the infrastructure requierement for education implementation in the farm. This is to ensure the which public government school that available and which public company's spnsored school needs to set up (Please see CBA page 12) Phase III of the GVL Education Support (GES) Program is on-going for 2022-2023 acadminc year. Assessment of prospective bebeficiary schools for Phase IV commenced. To be completed before 20203-2024 acadmic year begins. Phase III of the GVL Education Support (GES) Program is on-going for 2022-2023 acadminc year. Assessment of prospective bebeficiary schools for Phase IV ongoing. Phase IV of the GVL Education Support (GES) Program is on-going for 2023-2024 academic year. In this phase the GES program will be converted into School Fee which is given to the employee's dependants.
D.1.7.2 Engange CRC and relevant parties to arrange the planning for education facilities as promised in the CA Process improved under the implementation of the current Phase III for the 2022-2023 academic year. Beneficiary schools increased to 60, up  from 38 schools in Phase II and 22 public schools in Phase I. Process improved under the implementation of the current Phase III for the 2022-2023 academic year. Beneficiary schools increased to 60, up  from 38 schools in Phase II and 22 public schools in Phase I. Total beneficiary schools of the GES program Phase 1-3 is 109 and 29 schools from total had been renovated.
D.1.7.3 Engage the government (MOE) to set up "Free and Compulsory Early Childhood Education" base on national Liberia program 2017 in the farm for all of the children in the farm and the community within age 3 to 5 (Please see CBA page 12). On-going . MOU arrangement made with MoE  under the Education Support Program.   On-going . MOU arrangement made with MoE  under the Education Support Program.   On-going . MOU arrangement made with MoE  under the Education Support Program.  
D.1.7.4 Propose sufficient transportation to reach the school for worker children as weel as community near the site. On-going. To be upgraded as part of the Education Support Program.   On-going. To be upgraded as part of the Education Support Program. On-going. As part of the school fee in the GVL Education Support Program.
D.1.7.5 Propose to build the company sponsored school base on the assesment. On-going On-going On-going
D.1.7.6 Communicate to the national and internal stakeholder on education plan and progress in GVL. On-going On-going On-going
D.1.7.7 GVL can propose the spesific class for palm oil lesson to enhance the education of local people about palm oil so later the community might be join to GVL as employee. Yet to commence. Under review as part of company's overall investment review. Yet to commence.  Yet to commence. 
D.1.7.8 Involve the GVL staff as the teacher in the school and LCC can set up the curiculum for that. Yet to commence. Under review as part of company's overall investment review. Yet to commence. Yet to commence.
Develop the capacity building for all of the worker D.1.8.1 Conduct HIV AIDS, Ebola, and Malaria awareness training as requested in the CBA On-going.  On-going.  On-going. 
D.1.8.2 Develop learning center commiittee  (LCC) to handle the training Done. Team training on-going. Done. Team training on-going. Done. Team training on-going.
Establish system to prevent and handle sexual harrasment D.1.9.1 Arrange the procedure to handle the sexual harrasment and persecution cases Done.  Continuos awareness and training on-going. Done.  Continuos awareness and training on-going. Done.  Continuos awareness and training on-going.
D.1.9.2 Form a gender commiittee Commenced. Target completion defered to Q1 2023 as part of major HR reforms. Commenced.  Commenced. 
D.1.9.3 Socialization on sexual harrasment persecution and the way to report the case based on SOP made before Commenced. Target completion defered to Q4 2022 as part of major HR reforms. Commenced. Commenced.
D.2 Respect the right of association and collective bargaining  Ensure proper engagement with union D.2.1.1 Evaluate about the membership of union. It suppose to be valuntary however the current situation indicate that all new workers automaticly become members. Completed. Part of CBA review and on-going company restructuring. Completed. Completed
D.2.1.2 Engage the union to arrange the financial report of membership fee and report to the member. On-going. On-going. On-going.
D.2.1.3 Arrange the program of capacity building for union organizers On-going.  On-going.  On-going. 
D.2.1.4 Set up in collaboration with worker’s union a social clause which prioritize consultation and brainstorming with the management around issues. Done, as part of  CBA review in Dec 2020. Done Done
D.2.1.5 Raise awareness/socialize workers and union on the corporate mindset and culture. Done, as part of  CBA review in Dec 2020. Done Done
D.3 Health and Safety Conduct risk analysis of safety and health and implementing action plan D.3.1.1 Conduct hazard identification and risk assessment of all part of workplace in the mill and estate. Arrange the action plant to determine the control of the risk base on the risk management hierachy Done. Done. Done.
D.3.1.2 Socialization the HIRADC to the workers On-going.  On-going.  On-going. 
D.3.1.3 Put the first aid kit in the certain location base on identification (mill) Done. Done. Completed and implemented. 
D.3.1.4 Select the PIC for emergency coordination and train them for the accident emergency action (mill) Done Done Done
D.3.1.5 Arrange JSHC in every site that consist of management and worker/union Done Done Done
D.3.1.6 Install more signboard and poster related to OSH implementation On-going. On-going. On-going.
D.3.1.7 Select the PIC for emergency condition and train them for the accident emergency action (mill) Completed. Completed. Completed
D.3.1.8 Socialize to the emergency handling to the high risk workeplace workers Done. Periodic review on-going Done. Periodic review on-going Done. Periodic review on-going
D.3.1.9 Review annually the HIRADC base on the operational evaluation or accident happen during a year Done. Periodic review on-going Done. Periodic review on-going Done. Periodic review on-going
D.3.1.10 Emergency socialization for all workers Done. Periodic review on-going Done. Periodic review on-going Done. Periodic review on-going
OHS Training Programme D.3.2.1 Arrange OSH training identification and training program On-going. On-going. On-going.
D.3.2.2 Arrange the timebound plan for training, socialization, simulation related to OSH On-going. On-going. On-going.
D.3.2.3 Training ISO 45001 or training from Ministry of Manpower to ensure the competency base on government qualification for OSH/Sust Dept Yet to commence. Re-adjusted target  agaain to Q1 2023 to account for company restructuring and mobility constraints. Yet to commence.  Yet to commence. 
Provision of PPE and protection from chemical exposure D.3.3.1 Provide safety equipment to handle emergency on the workplace related to chemical i.e emergency shower and eye washer in chemical warehouse, etc On-going.  On-going.  On-going. 
D.3.3.2 Provide the sufficient PPEs for the sprayer On-going. On-going. Completed and implemented. 
D.3.3.3 Provide the PPEs storage for the sprayer to avoid contamination in their house On-going. On-going. On-going.
D.3.3.4 Socialization on the chemical (pestiside and fertilizer) direct body contact to the worker as well as the community (suggest the community not to take and comsume the palm fruit taken from the farm) On-going. On-going. On-going.
D.3.3.5 Socialization not to use the waste bin for water storage On-going.  On-going.  On-going. 
D.3.3.5 Evaluate PPEs quality and consider other treatment to minimise risk On-going. On-going. Completed and implemented. PPE evaluation carry out annually.
D.3.3.6 Conduct the specific annual medical surveillance for workers On-going. On-going. On-going.
D.3.3.7 Conduct the rotation of chemical sprayers to reduce chemical contamination of their body On-going On-going On-going
D.3.3.8 Provide sufficient warehouse to store the hazardous waste Done.  Done.  Done. 
D.3.3.9 Engage with the licensed user to take out the hazardous waste  Completed. Completed. Completed
Provision of accident insurance for all workers D.3.4.1 Update the percentation of payment in the HR and Employment Manual with regards to NASSCORP membership Done. Done. Done.
D.3.4.2 Make sure the deduction have a power of attorney from the worker On-going. On-going. On-going.
D.3.4.3 Engage the NASSCORP for the claiming process since there was a case that the claim payment for the worker who got the accident in 2015 On-going. On-going. On-going.
Provision of adequate housing and health facility for the workers and family D.3.5.1 Educate the worker on the housing maintenance since commonly the community house is different to the house provided by company. It is include to the proper usage of toilet. On-going. On-going. On-going.
D.3.5.2 GVL to provide dedicated doctor in each of the central clinic and make schedule to visit other clinic in other site. Process re-organized  in consultation with MOH to operate a VMO in Sinoe and GK, and refer serious cases to nearby Hospitals.  Process re-organized in consultation with MOH to operate a VMO in Sinoe and GK, and refer serious cases to nearby Hospitals.  Completed the process re-organized with MOH to operate a VMO in Sinoe and GK. VMOs have been assigned by MOH for GVL Clinics and refer serious cases to nearby Hospitals. 

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