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Wilmar Europe Trading BV

Wilmar’s business activities include oil palm cultivation, oilseed crushing, edible oils refining, sugar milling and refining, manufacturing of consumer products, specialty fats, oleochemicals, biodiesel and fertilisers as well as flour and rice milling.

Lobbying Activity

Meeting with Andrey Kovatchev (Member of the European Parliament, Shadow rapporteur for opinion)

22 Mar 2023 · Proposal for a for a regulation on prohibiting products made with forced labour on the Union market

Response to Sustainable corporate governance

20 May 2022

Central to Wilmar´s sustainability strategy is our No Deforestation, No Peat, No Exploitation (NPDE) policy, which extends across our global operations, including all third-party suppliers. Wilmar is a firm advocate of sustainable growth and is committed to transforming the palm oil industry towards more sustainable practices. Thus, Wilmar supports the objectives of the Directive. On the other hand, Wilmar sees that some aspects of the text proposal, must be improved. Notably: • Making companies responsible and liable for the upstream and downstream of the supply chain. Wilmar supports the idea that the companies must be held accountable and liable for the upstream part of the supply chain, as they exercise a leverage on the suppliers, traders and producers. Yet, Wilmar is against the idea of making companies also responsible and liable for the downstream part of the supply chain i.e., the costumers and what they do with the products. Making the company responsible for what the costumer does is also legally impossible. Once the customers have acquired a product or service from a company, these have the legal ownership of the product or service, and the company loses any legal rights: the Purchase act transfers the ownership, and the company loses any leverage. • The concept of “established business relationships”. Wilmar welcomed the introduction of the concept of “established business relationships” by the Commission to make the due diligence more manageable for companies. The new concept, which is not present in the international standards, such as those outlined by the UN or the OECD, must be clearly defined to achieve its primary goal. Wilmar highlights that the concept as defined in the current text is not clear and leaves room for unjust punishment. • Sectoral specific guidelines. The Commission may issue sector specific guidelines on how to comply with the due diligence obligations put in place by the Directive. It must do so after having analysed and assessed the resilience of each sector to comply with the due diligence requirements. • “Adverse human rights” and “environmental impact”. Wilmar considers that these two concepts should be part of the above-mentioned guidelines. In addition, these concepts should be defined in a narrower way. Whereas the proposed directive targets any human rights and environmental risks, the UN Guiding Principles require to look at ‘salient risk’, which implies that the company has influence on addressing these risks. • Clear definitions. Wilmar believes that the following, as well as others present in the text, are the definitions that need to be made clearer: “appropriate measures”, “value chain”, “severe adverse impact”, “adverse human rights and environmental impact”, etc. For businesses to operate with confidence, definitions should be sufficiently clear following a holistic, materiality-based and impact-oriented approach, which does not take away necessary flexibility for companies to adapt to their specificities. • Harmonized implementation across Member States. Given the fact that this is a directive and Member States will have to transpose it into national law, Wilmar supports the idea that the Directive itself should provide a high level of harmonization for the implementation of the rules including sanctions. Otherwise, the Directive will result in disturbing the EU internal market and causing trade flow distortions through changes in the placing of goods on the EU market. • Engagement with the companies. The Directive should put in place provisions that require the authorities to engage with the companies in different steps of the due diligence process. In addition, the companies should have the chance to have their say before being sanctioned and the complaints, to be taken into consideration, should be based on evidence and not hearsay, as a high number of complaints can be expected and the high chance that many of them may be unfounded must be taken into due account.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Europtimum Conseil

25 Oct 2021 · EU initiative on Deforestation and forest degradation – Wilmar’s position paper

Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

26 Jul 2021

Wilmar welcomes the opportunity to provide feedback More details in attachment Please find below our comments on: • Article 6 (b) • Chapter V: “Specific rules on compliance with the requirements on low ILUC-risk certification” • ANNEX VIII: “Minimum Requirements On The Process And Method For Certifying Low Indirect Land-Use Change (Iluc) Risk Biomass” GENERAL The draft: • Requires quite some agronomical expertise to determine and demonstrate if volumes comply with the regulation. This expertise is not commonly available to all kinds of growers. Furthermore, the level of complexity can serve as a deterrent for most growers to consider and evaluate compliance • Rewards lack of improvements and penalises productivity achieved in the past. As only productivity gains can be certified as low ILUC-risk, the system discriminates against efficient farms/plantations that have committed to sustainability standards in the past (including compliance with EU-RED) • Leads to more transport emissions and higher logistical costs since only additional yield volume can be certified, meaning that small volumes of certified crop will be fragmented over geographical regions BASELINE • A palm plantation is usually made up of trees with different age profiles, even within certain blocks. It is therefore impossible to compare yield improvements against a single baseline, since the yield improvement done in one block might be offset by lower yields due to the age profile in another block ADDITIONALITY MEASURE • A RED-certified farmer does not necessarily sell 100% of its crop to the EU biofuel market but serves a range of markets like food, feed, oleochemicals, and local biofuels under other sustainability certifications and initiatives, so it is hard to link any additionality measure to EU Biofuel alone. The unpredictable and uneven treatment of Palm Oil by the EU and its Member States in comparison to other 1G oil crops does not offer a supportive basis to stimulate farmer investments into more sustainable practices. • Attributing yield improvement to a specific measure or set of measures is very debatable, as many factors, including external factors (e.g. weather conditions, economic), can have an impact on the yield • Replanting is essentially ruled out as an additionality measure despite it being the most effective measure to increase yields FINANCIAL BARRIER • NPV calculation will most likely always fail: In general, any farmer benefits from additional yield as the price of the underlying commodity is interesting enough to produce more of it on the same hectare. We challenge if there are any reasonable additionality measures more expensive than the value of the increased yield • Fact is that some farmers have not been able to improve their yields because of economic & social factors, lack of market access and knowhow. The whole idea of the RED II is that these farmers will be incentivized to improve their yields to avoid new areas to be developed for plantations. We suggest other means to be investigated, which will likely require changes to the Delegated Act • The predictability of the cost for an additionality measure is not always straightforward NON-FINANCIAL BARRIER • This tool is rather subjective, but as long as the current Delegated Act remains in force the economic operators should have more possibilities to prove NON-financial barriers, especially because the NPV calculation will most likely always fail CONFIDENTIAL INFORMATION • Article 6.b “Where an audit identifies a list of non-conformities, voluntary schemes shall publish the respective action plan and timing for their correction ..”: NC & related information should not be made public; CB has the full information for sharing with the voluntary scheme. The action plan may contain confidential information, related to how system user manages operations internally. Only final summary audit report should be published
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Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

24 Mar 2021 · Sustainable Corporate Governance

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius)

1 Mar 2021 · Deforestation initiative and the impact on the palm oil countries producers

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

1 Mar 2021 · Deforestation and forest degradation