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UPDATED: MAY 11TH 2018

GRIEVANCE PROCEDURE

FUJI OIL HOLDINGS INC.

1. BACKGROUND Fuji Oil Holdings launched its Responsible Palm Oil Sourcing Policy in March 2016, recognising that sustainable development is integral to the long-term viability and success of its business. The Responsible Palm Oil Sourcing Policy has incorporated No deforestation, No peat land development and No exploitation requirements to meet the rising market demand for traceable, responsibly produced palm oil products. Fuji Oil Group recognises the important role that stakeholders play in the successful implementation of its Policy. The Fuji Oil Group Responsible Palm Oil Sourcing Policy includes a commitment to establish a Grievance mechanism to provide a platform for stakeholders to raise grievances regarding the implementation of the Fuji Oil Group Responsible Palm Oil Sourcing Policy across its supply chain. All grievances logged under the Grievance Procedure will be dealt with in a timely manner, and all investigations and findings will be reported transparently. To ensure the effective implementation of the grievance procedure, an annual review of the procedure will be conducted, taking into consideration input received from stakeholders. Fuji Oil Group acknowledges that the RSPO maintains a grievance process to which Fuji Oil Holdings has an existing commitment, while the scope of Fuji Oil Group Responsible Palm Oil Sourcing Policy will in some cases require a more dynamic approach to stakeholder engagement and transparency. In principle, however, all grievances raised through the RSPO grievance process will follow the RSPO process.

2. OBJECTIVES This procedure is to support and enhance the implementation of the Fuji Oil Group Responsible Sourcing Policy by addressing stakeholders’ grievances relating to Fuji Oil Group and its’ suppliers. It is intended to serve as a guide to review, manage, monitor and address the outcome of stakeholder grievances (from any external parties, including individuals, government organizations and non-governmental organizations) concerning the implementation of the policy across the Fuji Oil Group’ supply chain. Fuji Oil Group recognises that feedback and input from stakeholders is valuable to enhance transparency in our supply chain and provide a means to gauge progress on the implementation of the Policy.

3. SCOPE The Fuji Oil Group Responsible Palm Oil Sourcing Policy and this Grievance Procedure applies to Fuji Oil Group’s global business operations and their palm oil suppliers. This procedure covers activities related to the handling of stakeholders’ grievances regarding the implementation of the Policy. This includes the recording of grievances, taking action to verify claims, rectifying confirmed issues, reporting the verification results, responding to stakeholders, managing and monitoring any follow-up action.

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REFERENCES

a) Fuji Oil Group Responsible Palm Oil Sourcing Policy b) UN Guiding Principles on Business and Human Rights

4. DEFINITIONS

A grievance is a complaint, allegation, concern or problem which an individual or a group has raised to the Fuji Oil Group to address and identify a resolution to.

5. RESPONSIBILITIES - MANAGEMENT TEAMS

Tasks Responsible

Grievance Coordination

a) Receiving grievance CSR and Risk Management Group

b) Grievance registration Supply Chain Management Group

c) Grievance handling Supply Chain Management Group

d) Monitoring Supply Chain Management Group

e) Closing CSR and Risk Management Group

CSR and Risk Management Group ・The CSR and Risk Management group of Fuji Oil Holdings shall assign a grievance manager to coordinate all grievances. The grievance manager is in charge of grievance coordination across the CSR and Risk Management Group and the Supply Chain Management Group of Fuji Oil Holdings.

6. WORKFLOW PROCESS

a) Receiving a Grievance

Grievances raised through official channels Grievances can be raised to Fuji Oil Group via any of the following channels: Via email to : CSR-INQ@so.fujioil.co.jp By telephone to : +81-6-6459-0729 By fax to : +81-6-6459-0711 In writing to : Daibiru Honkan Building, 3-6-32 Nakanoshima, Kita-ku, Osaka-shi, Osaka 530-0005, Japan Attention to: Fuji Oil Holdings Inc. CSR and Risk Management Group

Grievances must include the following information: Full Name Name of Organization (if any) Address Phone No./Fax No./Email Address (at least one contact point) Description of the grievance in detail

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Evidences to support the grievance

Grievances raised through unofficial channels In addition to grievances submitted through the official channel above, issues raised through unofficial channels, such as the media and the internet, will be recorded as grievances if they allege a breach of policy by Fuji Oil Group, or one of its direct and indirect suppliers.

b) Grievance registration

Validation of grievances All reports received via the grievance communication channel or published in the media that allege a breach of Fuji Oil Group’s NDPE Policy will be evaluated by the Fuji Oil Holdings’ Supply Chain Management Group using a Grievance decision tree (See Appendix A). If necessary, the CSR and Risk Management Group will communicate with the grievance raiser to obtain further details and/or evidence of the grievance. The aim of the validation process is to confirm if the complaint falls into the category of a grievance. Possible outcomes include:

a. The grievance is validated; b. The grievance is unrelated to Fuji Oil Group’s NDPE policy and if relevant referred to the

relevant department; c. The grievance is not validated and the CSR and Risk Management Group shall provide

written confirmation to the complainant that the grievance was not accepted in case of grievances raised through an official channel.

Grievance records Upon validation as a grievance, the CSR and Risk Management Group shall record each grievance in the Grievance List (public case tracker). The CSR and Risk Management Group shall contact with the Grievance Raiser to confirm that the grievance has been registered (for grievances raised through an official channel).

Grievance scope The intended target of the grievance will be identified in the Grievance list: (i) Fuji Oil Group, (ii) direct supplier, and/or (iii) indirect supplier (in the Fuji Oil Group supply chain). Grievances raised through both official and unofficial channels will be categorised according to the following structure:

No. Category Scope

1. Grievances against Fuji Oil Group

Relates to Fuji Oil Group’s own business unit operations.

2. Grievances against a direct supplier

Relates to a direct supplier of Fuji Oil Group (palm oil mill or refinery).

3. Grievances against an indirect supplier

Relates to an indirect supplier to Fuji Oil Group via a direct supplier.

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c) Grievance handling

Grievances against Fuji Oil Group

a. The Supply Chain Management Group shall prepare a Grievance Report to address the grievance. This report shall include all available information regarding the grievance and necessary steps to close the grievance.

b. The Supply Chain Management Group shall contact the relevant business unit to verify the validity and details of the issues raised in the grievance. If it is determined that there is insufficient information available to verify the grievance, a site investigation shall be initiated. If a field visit is conducted, a verification report will be developed providing conclusions and recommended actions (see Appendix D).

c. The Supply Chain Management Group shall draft a Grievance Action Plan.

d. The CSR and Risk Management Group, in unison with the Supply Chain Management Group, shall then take steps to implement the grievance Action Plan.

e. The Supply Chain Management Group shall monitor the implementation of the action plan until the grievance is closed. Upon completion, the status of the grievance shall be updated on the Grievance List by CSR and Risk Management Group.

Grievances against a direct supplier

a. The Supply Chain Management Group shall prepare a Grievance Report to address the grievance.This report shall include all available information regarding the grievance and necessary steps to close the grievance.

b. The Supply Chain Management Group shall contact the supplier (via the relevant Fuji Oil

Group Procurement Department)and request an Action Plan to close the identified grievance.

In the event that the supplier is a Palm Oil Mill or Kernel crushing plant, Fuji Oil Group shall seek to directly engage the entity to verify the grievance prior to requesting the Action Plan from the supplier. If a field visit is conducted, a verification report will be developed providing conclusions and recommended actions for the supplier to include in their Action Plan (see Appendix D).

c. The Action Plan must be submitted to the Fuji Oil Holdings Supply Chain Management Group for review and confirmation. If the plan is not approved it shall be returned to the supplier with details on the required amendment to the plan. Upon approval, confirmation shall be provided to the supplier.

d. The Supply Chain Management Group shall then monitor the delivery of the action plan until the grievance has been closed. Upon completion, the status of the grievance shall be updated on the Grievance List.

Grievances against indirect supplier

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a. The Supply Chain Management Group shall prepare a Grievance Report to address the grievance. This report shall include all available information regarding the grievance and necessary steps to close the grievance.

b. The Supply Chain Management Group shall contact the intermediary (direct) supplier to Fuji Oil Group (via the relevant Fuji Oil Group Procurement Department) and request an Action Plan from the respective supplier that the grievance has been made against.

c. The Action Plan must be submitted to the Fuji Oil Holdings Supply Chain Management Group for review and confirmation. If the plan is not approved it shall be returned to the direct supplier with details on the required amendment to the plan. Upon approval, confirmation shall be provided to the supplier.

d. The Supply Chain Management Group shall then monitor the delivery of the action plan until

the grievance has been closed. Upon completion, the status of the grievance shall be updated on the Grievance List.

d) Monitoring The Supply Chain Management Group is responsible for overseeing and monitoring all grievances. In cases relating to grievances made against third-party (direct or indirect) suppliers, the Supply Chain Management Group shall coordinate with the respective Fuji Oil Group Procurement Departments to receive progress updates on the implementation of the grievance Action Plan. Progress updates on outstanding (open) grievances will be requested from suppliers on a quarterly basis. This information will be used to communicate with the grievance raiser (in cases where the grievance was raised through an official channel) until all parties are satisfied the grievance is closed. Grievances against direct/indirect suppliers that are not closed within the planned timeframe shall be referred to the Supply Chain Management Team by the CSR and Risk Management Group. A review of progress must be performed and depending on the nature of progress made, a new Grievance Handling Plan may be developed, or the supplier recommended for suspension until the grievance is closed. In either case, the Grievance Raiser shall be notified via written communication (for cases where the grievance was raised through an official channel). In cases where a legitimate grievance exists and the direct/indirect supplier does not comply with the Fuji Oil Group policy through the implementation of an agreed action plan, Fuji Oil Group shall suspend its relationship with the supplier.

e) Closing grievance Upon closure of the grievance, written confirmation will be provided to notify the Grievance Raiser (in cases wherethe grievance was raised through official channel) that the grievance has been closed and seek input . Subsequently, the CSR and Risk Management Group shall update the status of the case on the Grievance List. Any party that is unsatisfied with a written response received from the CSR and Risk Management Group can reply in writing. All subsequent complaints will be reviewed by the CSR and Risk Management Group. Where appropriate, additional follow up action can be initiated including a direct explanation of the case, a joint field visit, inclusion of external observers or discussion of outstanding actions to be taken to resolve the remaining grievance.

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f) Timelines The grievance resolution process often involves numerous stakeholders and the length of time required to process cases may vary depending on the complexity of the case. The following timelines are provided for the key stages of this procedure and if the expected or actual timeline needs to be adjusted, the CSR and Risk Management Group shall confirm in writing with the Grievance raiser in cases where the grievance was raised throughan official channel. The timelines below refer to all grievance types, as received through the official channel or via unofficial channels:

Category Timeline

All cases Within 2 weeks (14 days) the grievance shall be validated and recorded. (since the time the grievance was received)

All cases Within 3 weeks (21 days) the Supply Chain Management Group will prepare a Grievance Report. (since the time the grievance was received)

All cases Within a month (30 days) a written response will be provided to the Grievance raiser (for cases raised through an official channel) since the grievance was received by the CSR and Risk Management Group received the complaint.

For cases relating to Fuji Oil Holdings’ own operations

Within a month and a half (45 days) the Grievance Action Plan will be implemented after approval by the Supply Chain Management Group. (since the time the grievance was received)

For cases relating to Fuji Oil Group’s third-party suppliers (direct and indirect):

Within three weeks (21 days) the Supply Chain Management Group shall request a Grievance Action Plan from the respective supplier. (since the time the grievance was received)

Within one month (30 days) the Supply Chain Management Group shall receive the Grievance Action Plan from the respective supplier and return it within a turnaround time of no more than 10 days. (since the time the grievance was received)

Grievance List The Grievance List is to be published on the FUJI OIL Group website and updated (at a minimum) on a quarterly basis.

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Attachments Appendix A: Grievance Decision Tree Appendix B: Grievance Report Template Appendix C: Grievance Action Plan Template Appendix D: Verification Report Template Appendix E: Grievance Log (List) Appendix F: Grievance Process Flow Diagram

Appendix A: Grievance Decision Tree

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Appendix B

Grievance Report Template 1. BACKGROUND Relevant background information 2. OBJECTIVE Clearly describe the objective of grievances and rationale of allegation 3. EXPECTED OUTCOMES List the expected outcomes and proposed resolution to the grievance 4. FIELD INVESTIGATION Identify if onsite investigation / verification of the grievance is necessary by Fuji Oil Identify issues requiring verification / investigation If field investigation is proposed, identify the proposed methodology Include a timeline by which field investigation is to be completed 5. REPORTING Investigation result and proposed actions Identify next steps for FUJI OIL

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Appendix C

Grievance Action Plan Template

No. Target Action Deliverable PIC Due Date Status

… Issue / complaint as reported in grievance

Detailed description of activity

Agreed outcome that must be met for grievance to be considered closed

Person in Charge, Company name and position.

Date for activity to be completed

Ongoing / closed

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Appendix D

Investigation Report Template 1. BACKGROUND Background information relevant to the Grievance and the Investigation Findings. 2. INVESTIGATION PROCESS Verification methodology, details of the steps taken during the investigation, and information collected. Include locations and dates of all site visits. 3. CONCLUSIONS Provide a conclusion to each of the issues identified for verification in the Grievance Report. Include relevant information used to reach the conclusion made. 4. RECOMMENDATIONS Where issues raised through the grievance have been verified to be legitimate, a concrete time bound action plan should be developed to address each of the issues. Methods/processes and Person In charge for monitoring implementation for the action plan should also be recorded here.

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Appendix E: Grievance List Template

Ref. No. Means of Delivery

Date Received

Subject Raised by Progress Status

… Email, letter, or Public Report

DD/MM/YYYY Short description of grievance

Stakeholder name

Short description of progress to date

Ongoing, complete

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2

1

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Appendix F: Grievance Procedure Process Flow Diagram

Grievance Procedure Process Flow Diagram

Grievance Registration

NoNon-Grievance confirmation

Prepare Grievance Report and

request Action Plan

No

Yes

Grievance closed

Approve Grievance

Action Plan

Implement Grievance Action Plan (according to the category of the grievance)

Grievance Submission

Notify grievance raiser of closure & seek input.

Verification

Monitor implementation of

Action Plan

Supply Chain Management Group

CSR and Risk Management Group