Committed To Sustainability

This non-Governmental organization¹ and other non-business third-parties engagement policy (the "Policy") of the Corporation defines how the Corporation and its employees, officers, directors and contractors (herein collectively referred to as "Representatives") respond to approaches from, and make proactive approaches to, non-Governmental organizations and other non-business third-parties (herein collectively referred to as "NGOs"). The Policy is neither a contract nor a comprehensive manual that covers every situation that might be encountered. The Policy will form part of the Corporation's Stakeholder Engagement and Community Development Plans which are currently under development.

For the basis of this Policy, an 'approach' by or to an NGO is defined as a request for assistance or collaboration that places demands on the resources of the Corporation, including but not limited to; the use of facilities, labor, management assistance and financial support. The focus of this Policy is to define:

• how the Corporation will respond to an approach by, or proactively approach an NGO;
• how potential NGO collaborations will be considered by the management of the Corporation; and
• the Corporation's oversight and monitoring arrangements.

Sustainable development is best pursued through partnership

The Corporation is aware that while it can achieve much within its own business, it believes that sustainable development is best pursued through partnership. The Corporation is also committed to transparency and "fairness of process", and it firmly believes that collaborative efforts are desired on the part of both the Corporation and NGOs. In most cases, NGOs have vital skills and resources that can benefit the Corporation and, more importantly, the communities in which the Corporation operates.

According to the International Finance Corporation (IFC):

"Non-governmental organizations (NGOs) and community-based organizations (CBOs), particularly those who represent communities directly affected by a project [business operations], can be important stakeholders for companies to identify and engage on a proactive basis. NGOs may have expertise valuable to effective stakeholder engagement. For example, they can be sources of local knowledge, sounding boards for project design and mitigation, conduits for consulting with sensitive groups, and partners in planning, implementing and monitoring various project-related programs."

The following is an example of how Feronia engages with NGOs and the reasoning behind such a collaboration:

When Feronia acquired its palm oil business from Unilever, it inherited a vast social infrastructure built over a period of several decades. The infrastructure had suffered from a lack of investment and much of it, despite the efforts of management and the communities, was in a state of widespread disrepair. Whilst the Company put in place an extensive and ongoing maintenance and repair program, it identified a significant requirement for the improvement of access to safe drinking water across its plantations and in neighboring communities. Feronia approached Water for Africa, a UK charity focused on the provision of sustainable water sources in Africa, and is now partnering with the charity to train a team of local people in the installation, maintenance and upgrade of over 50 boreholes. The Company's decision to partner with Water for Africa was driven by a number of reasons including:

• Water for Africa is expert in the design and implementation of sustainable water projects and has a track record in Africa.
• Partnering with Water for Africa to develop a long term borehole drilling programme will creates a number of skilled and semi-skilled jobs in the communities in which the Corporation operates.
• Training local people to maintain the boreholes and pumps has been shown to prolong the life of water supplies, making the project sustainable in the long term.
• Partnering with Water for Africa to provide safe drinking water is a more cost effective approach than using an external drilling contractor which ultimately means that more boreholes can be installed.

How will the Corporation respond?

All NGO approaches, whether formal or informal, by or to a Representative, are recorded in a 'Report on contact with NGO or other non-business third party' (see Exhibit A). This report is completed by the Representative who was first contacted by, or made first contact with, the NGO and issued to the Corporation's Compliance Officer. The Compliance Officer is then responsible for informing the Corporations senior management, typically the CEO and COO, and coordinating the management's response to the NGO.

The Corporation is committed to responding in writing (including email) to all approaches by NGOs within 28 days. If the management consider that the potential exists for collaboration, as defined by the evaluation criteria (described below), a proposal for next steps will be included in the response along with (in some instances) a request for references. If the management consider that the NGO approach does not meet the criteria for collaboration then reasons for not continuing the engagement will be explained in writing.

How will NGO collaboration be considered by the management?

As stated above, the Corporation believes that sustainable development is best pursued through partnership and collaborative efforts are desired on the part of both the Corporation and NGOs. However, it is not possible to collaborate with all NGOs that approach or are approached by the Corporation and therefore, in order to ensure transparency and fairness of process, criteria have been established against which NGO approaches are evaluated.

Every NGO approach is reviewed by senior management of the Corporation, typically the CEO and the COO, and approaches for collaboration are reviewed against the following criteria:

• Alignment of Values and Objectives: Are the NGOs objectives and/or mandate aligned with the Environmental and Social (E&S) values and objectives of the Corporation as defined by the Corporation's E&S Policies?
• Track Record: Does the NGO have a track record of successfully achieving its objectives? Will the NGO deliver on the commitments made to the Corporation?
• Resources: What resources would be required for any potential collaboration? Would this be technically and financially feasible for the Corporation?
• Timing: Does the Corporation have the resources available at this time to facilitate a potential collaboration? Will a potential collaboration be more effective at another time?
• Religious and Political Impartiality: NGOs objectives should not include the furtherment of political or religious creeds.
• Sustainability: Potential collaborations which provide benefits which can be sustained in the long term will generally be viewed more favorably than those whose benefits are short-term in nature.
• Dependency: The objectives of a potential collaboration should not create a dependency which cannot be sustained/supported by the Corporation in the long-term
• Community Development: Collaborations which use local resources, capacities and provide employment and/or training/furtherment opportunities for local people, especially underrepresented groups, will generally be viewed more favorably.
• Compatibility: Any collaboration should be compatible with existing environment, social and governance policies and/or strategies and the Corporation's wider Code of Business Conduct. All policies are available at http://feronia.com/Responsibility.aspx