Sustainable palm and soy sourcing policy

Introduction

Avril's approach to sustainability is structured around a common Purpose: Serving the Earth¹. Through this Purpose, we have set six bold commitments which we commit to on a daily basis,  among which “taking action to protect natural resources and biodiversity”. Because we will continue to import agricultural raw materials that cannot be produced locally from countries at risk of deforestation or conversion of endangered ecosystems, we are committed to ensuring that by 2030,100% of our palm and soy supplies come from sustainable agriculture.

In particular, given the threats that particular ecosystems face due to the production of palm and soy-related materials, Avril decided to adopt a dedicated policy regarding its palm and soy supply. This policy is based on a shared ambition at Group level and specific action plans in the Group’s business units.


Ambition

With this policy, the Group strives to procure palm and soy-based products² from suppliers who can prove that their cultivation does not contribute to the destruction of forests and other natural  ecosystems (such as, but not limited to, peatlands, mangroves, savannahs), respects the human rights of workers, smallholders and local communities, and therefore the ‘No Deforestation, No Peat, No Exploitation’ (NDPE) principles. Through this ambition, the Group strives to uphold these principles and to have deforestation and conversion free palm and soy supply chains by 2030 in accordance with the definitions agreed within the Accountability Framework initiative (AFi).


Scope

This policy applies worldwide to every Avril subsidiary (EU and non-EU) using palm and soy-based products² in its supply chain.  This is a comprehensive approach which acknowledges and calls for compliance with local legislations, including (but not restricted to) the EU Deforestation Regulation³ .



Timeline
By 2025 at the latest, 100% of Avril palm and soy volumes will be traceable. When a deforestation risk exists⁴, the concerned volumes will be covered by sustainability schemes.
By 2030 at the latest, 100% of Avril palm and soy volumes will be deforestation and conversion free.



Avril expectations 

We expect Avril, its subsidiaries, and all of our suppliers to comply with the following requirements:

Environmental requirements and good agricultural practices
Avril defines deforestation and conversion free products as coming from plantations and plots which comply with the following criteria: 
o    Full compliance of the production, manufacturing and trading steps with local, national and 
international laws;
o    No deforestation according to the FAO guidelines5;
o    No conversion or degradation of High Conservation Value (HCV) areas, High Carbon Stock (HCS) forests6, and other forest-related natural ecosystems;
o    No burning, clearance, planting or exploitation of peatlands regardless of their depth.


Social requirements
o    Respect for workers, farmers and smallholders’ rights7, including freedom of association and collective bargaining, legal and decent working hours, safe and healthy workplaces, respect for minimum living wages, and the prevention of irresponsible and abusive working practices such as forced labor, child labor, discrimination, harassment and gender-based violence⁸;
o    Ensure the Free, Prior and Informed Consent (FPIC) of Indigenous Peoples and local communities prior to any activity that may affect these rights, and ensure adequate compensation, accommodation or remediation;
o    Protection of human, land and environmental rights defenders from violence, intimidation and criminalization;
o    Within the scope of sustainable sourcing field projects, provide support for local communities’ livelihoods, and smallholder farmers.



Grievance mechanism to address previous requirements
o    Operation of an open, transparent and consultative process to resolve complaints and conflicts, notably through the implementation of a group-level effective grievance management procedure⁹.

Suppliers are required to cascade the above-mentioned requirements within their supply chain and alert Avril in case of any violation via your point of contact at Avril, or on the dedicated reporting platform “Avril Ethics Line” (http://www.avrilethicsline.com).

Avril approaches for implementation

We believe that to meet this ambition and move towards greater sustainability, we need to follow a dual approach of i) risk assessment and management (traceability, satellite monitoring, etc.) and ii) working on enabling factors to address systemic issues (certification schemes, landscape projects, etc.). These items are described hereafter.

Traceability
Obtaining from our suppliers traceability data (see specific requirements in Appendix) to map all the supply chain back to the production areas.

Satellite monitoring
Identifying and monitoring high-risk forest areas and natural ecosystems located in Avril’s palm and soy supply chains, through the gradual implementation of a robust satellite monitoring system, which allows us to calculate our volumes of Verified Deforestation Free (VDF – see more details in  Appendix) palm and soy, and to strengthen our effective grievance management procedure.

Sustainability schemes
2025 commitment
100% of palm and soy volumes produced in high-risk forest areas and natural ecosystems must be covered by sustainability schemes by 2025. Avril acknowledges the following schemes:
Palm
o    RSPO Segregated or RSPO Mass Balance certificates; 
o    ISCC-EU or 2BSvs certificates to comply with European union regulations on biofuels;
o    Verified Deforestation Free by 3rd party satellite monitoring.
Soy
o    RTRS Segregated or RTRS Mass Balance certificates;
o    ISCC-EU or 2BSvs certificates to comply with European union regulations on biofuels;
o    Verified Deforestation Free by 3rd party satellite monitoring;
o    Schemes consistent with FEFAC guidelines10;
o    ZDC “Zéro Déforestation Conversion” attestation11.

In addition to the schemes above, credits, in order to reach the 100% coverage target by 2025
o    RSPO Credits e.g. Independent Smallholder Credits preferably or Book & Claim;
o    RTRS Credits.

A KPI measured our progress against this 100% target, it is audited by a tierce-party and will be published annually in our extra-financial report (“Déclaration de Performance Extra-Financière”).

2030 commitment
100% of palm and soy volumes produced in high-risk forest areas and natural ecosystems must be covered by the above-mentioned sustainability schemes, excluding Mass Balance certifications and credits, by 2030.

Landscape projects
Alongside other players in the sector, we financially support field projects in areas connected to our palm supply chain. These projects focus on helping local farmers with integrated land use, socializing and training smallholders on No Deforestation, no Peat, no Exploitation (NDPE), contributing to natural ecosystems conservation and restoration, and supporting local communities in transitioning towards sustainable livelihoods. Field projects in soy supply chains could be considered in the future.

Supporting the French soybean sector
We support the development of the French soybean sector to avoid imported deforestation or conversion as much as possible. For example, we invest in soybean crushing units in France¹². using French soybeans to provide the animal feed sector with local and deforestation-free soy.
 
Engaging with our suppliers
Our subsidiaries using palm and soy-related materials commit to the following actions:
o    Establishing and maintaining a regular dialogue with their direct suppliers and asking them to do likewise with upstream operators in the supply chain;
o    Informing new suppliers about Avril’s sustainable sourcing policy;
o    Ensuring the alignment of their suppliers’ sustainability and/or deforestation and conversion free initiatives with Avril’s policy;
o    Obtaining, on a regular basis, all the necessary information from suppliers to map the supply chain back to the production area.


Non-compliance

Avril reserves the right to monitor its suppliers’ sustainability performance and compliance, itself or by a 3rd party, and in case of violations, to remind them of Avril’s requirements. The suppliers whose practices are not aligned with Avril’s ambition will be encouraged to become compliant. In accordance with our internal procedure for managing non-conformities, any supplier who does not cooperate or display any intention to change may be subject to the suspension of its commercial relationship with Avril.


 











Appendix – Definitions

Traceability
Palm-based products
o    Mandatory requirement: traceability to the mill
o    Preferred requirement: traceability to the plantation (concession map)
Soy-based products
o    Mandatory requirement: traceability to the cultivation area (i.e. country, and if Brazil, municipality)
o    Preferred requirement: traceability to farm level

On top of that, any palm and soy imported in the EU will need to be compliant with the EU Deforestation Regulation requirements on traceability.

Risk of deforestation and conversion
Palm-based products: all palm oil producing countries are considered to be at risk of deforestation or conversion. Therefore, all palm-based products must be covered by sustainability schemes or be attested as Verified Deforestation Free by 3rd party satellite monitoring
Soy-based products: the following origins are considered at risk of deforestation or conversion for soy :
o    Municipality at risk in Brazil (including Cerrado)13 
o    Gran Chaco in Argentina
o    Other South America countries
o    Unknown origin
Therefore, all soy-based products sourced from these origins or of unknown origin must be covered by sustainability schemes or be attested as Verified Deforestation Free by 3rd party satellite monitoring.

This list is subject to change, to align with the list of risky origins the European Commission will published as part of the Regulation (EU) n°2023/1115 on deforestation.

Cut-off dates
A cut-off date determines the permissibility of deforestation or conversion based on the timing of such events on the ground. Clearance of natural forests and forest-related natural ecosystems after a determined cut-off date implies non-compliance of the affected area or production unit with zero deforestation or no natural ecosystem conversion commitments.

We are aligned with the EU Deforestation Regulation cut-off date of December 31st 2020. Previous cut-off dates may be applied to answer specific client requests.


Palm-based products
o    Mandatory requirement: 31/12/2020 (EU Deforestation Regulation)
o    Preferred requirement: November 2018 (RSPO)
Soy-based products
o    Mandatory requirement: 31/12/2020 (EU Deforestation Regulation)
o    Preferred requirement: June 2016 (RTRS)

Verified Deforestation Free palm and soy
The Satelligence14   Verified Deforestation Free (VDF) module combines satellite-based deforestation insights and Avril’s own supply chain data, to analyze the proportion of Avril’s supply chain that is meeting Avril commitment on zero deforestation-conversion. Satelligence tool is based on FAO definition for forest5 and on EUDR cut-off date of 31/12/2020 at least (users can choose earlier cut-off dates). 




[1] Find more details on our Purpose here : From purpose to reason for action - Avril
[2] Palm-based products covers palm oil and palm kernel oil, their fractions (including olein and stearin) and their derivatives (alcohols, fatty acids, glycerin, esters (PME) - including FAME, palm kernel meal). Soy-based products covers any form of soy: meal, oil, seed, esters (including FAME).
[3] Regulation (EU) n°2023/1115
[4] See definition of traceability and risk in Appendix p.4
[5] FAO definition for forest : Article 2 (4) p.15 of EU Deforestation Regulation
[6] Following definitions of the High Carbon Stock Approach (HCSA).
[7] In line with the Universal Declaration of Human Rights (UDHR), the United Nations’ Guiding Principles on Business and Human Rights (UNGPs) and the International Labor Organization (ILO) fundamental Conventions.
[8] See Avril Code of Conduct
[9] In line with the United Nations’ Guiding Principles on Business and Human Rights (UNGP).
[10] List of all schemes compliant with FEFAC guidelines available here: StandardsMap
[11] The ZDC methodology is a deforestation and conversion risk assessment protocol applied in the soy supply chain.
[12] For more details check our Declarations of extra-financial performance
[13] List of municipalities at risk of deforestation and conversion set up by and updated annually by Earthworm Foundation for ZDC methodology implementation. To do so, Earthworm backs on Trase data.
[14] To know more on Satelligence, click here