Policies

1. Purpose

This document details Stephenson’s requirements for the sourcing of palm oil in its supply chain.

2. Scope

Stephenson Group Ltd formulates, manufactures, and supplies high performance products designed to meet our customer’s specified requirements for use in the Personal Care, Industrial and Beverage markets that we serve.

Palm oil and other palm derived ingredients are used in the formulation and manufacture of our soaps and other personal care products.

These standards apply to all suppliers globally who supply Stephenson with products containing palm oil, palm kernel oil, palm fruit oil, palm shortening, palm derivatives and fractions.

3. Position on palm oil

Stephenson Group Ltd (SGL) is fully committed to minimising the impact on the environment and ensuring it does not negatively impact the people or communities associated with its activities or supply chain. We expect our business, and supply chains to remain compliant with all applicable legislation and strive to adhere to voluntary sustainability standards that support responsible practices to protect the natural world and the communities that we source from.

SGL are highly aware that there are a number of environmental and social challenges linked to the production of palm oil, such as deforestation, conversion of natural ecosystems and human rights violations. We have committed to purchasing RSPO certified palm oil and only trade with suppliers that source palm oil to these standards in order to ensure that the palm oil that we use in our products is sourced sustainably.

Rather than taking the decision to prohibit palm oil use, Stephenson have taken the position to source palm oil that is grown and managed in a sustainable way and certified by RSPO. Palm oil is a highly productive crop versus other vegetable oils, therefore deciding to use an alternative oil in our product may require more land, which could lead to further environmental issues.

4. Key Sourcing Principles for sustainable palm oil

We are committed to sourcing ingredients from suppliers who are aligned with our Key Sourcing Principles and the criteria set out by the RSPO. Our Key Sourcing Principles are as follows:

• No Deforestation: Protecting High Conservation Value (HCV) and High Carbon Stock areas.

• No Peat: No planting or development on peatland regardless of depth.

• No Exploitation of People and Local Communities: Protecting human rights, workers’ rights and the rights of local communities and indigenous peoples.

• Smallholder inclusion: Promoting the inclusion and fair treatment of smallholders into the supply chain.

5. Our commitment to sustainable palm oil

Stephenson have been members of the RSPO since July 2010. Our manufacturing facility based in Horsforth, West Yorkshire is audited by an RSPO Certification Body to meet the requirements of RSPO Supply Chain Certification Standard and is certified under both Mass Balance and Segregated supply chain models.

SGL already source 100% physically certified palm oil, however there are a number of our derivatives and fractions which we are actively transitioning to physically certified. While we work with relevant suppliers to transition to physically certified palm oil derivatives and fractions, we use other mechanisms to support a more sustainable and inclusive palm oil industry, such as purchasing RSPO Independent Smallholder credits (IS Credits) to support smallholder farmers.

Stephenson have been a member of Palm Oil Innovation Group (POIG) since 2015 and have committed to the POIG Retailer & Manufacturer Charter. Where possible and commercially viable, SGL source POIG-verified oil.

6. Supplier Requirements

Suppliers in scope of this policy must meet the requirements listed below:

• All products containing palm oil, palm kernel oil, palm fruit oil, palm shortening, palm derivatives and fractions, used in Stephenson’s products must be declared to Stephenson using our raw material approval process

• All suppliers must be members of RSPO and adhere to their vision and mission

• All manufacturing facilities handling palm oil must be certified by an RSPO Certification Body against the RSPO Supply Chain Certification Standard and be able to provide evidence of in-date certification status that meets our requirements.

• Distributors must be sufficiently licenced to trade RSPO certified material and have sufficient checks in place to ensure their manufacturing suppliers are certified against the RSPO Supply Chain Certification Standard.

• All suppliers must have a sustainable palm oil policy in place which aligns with our Key Sourcing Principles outlined in section 4 and the criteria set out by the RSPO.

Suppliers must communicate any challenges related to sustainable palm oil sourcing to their primary business contact. Where a supplier’s RSPO certificate is suspended due to a failed RSPO audit or otherwise, suppliers must inform Stephenson immediately.

7. Compliance and Grievances

Stephenson are committed to the responsible handling of reported grievances in our supply chain and complaints of breaches of our palm oil policy. As part of our grievance procedure, we engage with our suppliers if a grievance has been raised against them and support them to address any weaknesses in their policy or practices. Where there is a critical failure to comply with this policy, suppliers may be put on hold until the case has been resolved.

Grievances can be raised in confidence to Stephenson using our email address (Hello@StephensonGroup.co.uk) or via our contact page: https://www.stephensonpersonalcare.com/contact-us

8. Transitioning to physically certified palm oil

By the end of 2022, at least 85% of palm oil, palm oil ingredients and palm derivatives purchased from our suppliers must be physically certified to RSPO mass balance, segregated, or identity preserved supply chain models. As a step to transition to physically certified material, other mechanisms, such as purchasing RSPO Independent Smallholder credits (IS Credits) should be put in place.

We will maintain regular dialogue with our direct suppliers to achieve our roadmap objectives.

Glossary

Palm Oil: Edible vegetable oil that comes from the fruit of oil palm trees. Palm oil is used in a wide variety of products, such as cosmetics and consumer foods.

Palm Derivative: Chemical compound produced from palm oil or palm kernel oil, by fractionation, synthesis or successive mixtures. For example: fatty acids, fatty alcohols, fatty esters, surfactants or glycerine.

RSPO: “The Roundtable for Sustainable Palm Oil" is a multi-stakeholder association made up of 2,500 members - palm producers, processors and intermediaries, manufacturers of finished products and distributors, banks and investors as well as non-governmental organizations (NGOs) - supporting the sustainable production and use of palm oil and setting the standards to achieve it. The RSPO has defined a set of principles and criteria that member companies must respect to produce a certified sustainable palm oil, harming neither the environment nor the communities present in the areas of production.

RSPO Credit: An RSPO Credit is proof that one tonne of certified palm oil was produced by an RSPO certified company or independent producer and has entered the global palm oil supply chain. By purchasing credits, buyers encourage the production of certified sustainable palm oil. Purchasing RSPO credits rather than purchasing physically certified palm oil is referred to as the Book and Claim supply chain model.

RSPO Book and Claim: The Book and Claim supply chain model supports the production of RSPO certified sustainable oil palm (CSPO) products through the sale of RSPO Credits. It allows RSPO certified mills, crushers, independent out-growers, and independent smallholder groups to sell RSPO Credits to the supply chain actors at the end of the supply chain, while selling the physical oil palm products as non-certified/ conventional.

RSPO Mass Balance (MB): RSPO's Mass Balance model allows operators in the supply chain to mix oils from certified plantations and non-certified ones. The objective being to reduce the industrial costs associated with when the two are separated (as in the case of the segregated model). Although these operators, in particular the refineries, cannot market volumes of Mass Balance certified oil greater than the quantities of oil purchased and from certified plantations, the model does not guarantee the presence of oil from of certified plantations in products.

RSPO Segregated (SG): RSPO's segregated model ensures the physical separation of oil from certified plantations while along the supply chain. This traceability model is one of the most demanding of the RSPO. This model is particularly complex to implement in the case of palm derivatives, both for supply and economic reasons.

RSPO Identity Preserved or IP: This means that identity preserved (IP) supply chain assures that the RSPO palm oil is uniquely identifiable to a single RSPO certified mill and its certified supply base.

Physically Certified Palm Oil: For the purpose of this policy, physically certified palm oil refers to Mass Balance, Segregated, or Identity Preserved Supply Chain models rather than the purchasing of RSPO credits through a Book and Claim supply chain model.

NDPE: One of the most important commitments that has been made to date by the agricultural industry has been the ‘No Deforestation, No Peat and No Exploitation’ commitment, abbreviated to NDPE. The palm oil industry has pioneered the use of this type of commitment as part of its efforts to create transformational change in the supply chain.

POIG: founded in 2013, The Palm Oil Innovation Group (POIG) is a multi-stakeholder initiative that strives to achieve the adoption of responsible palm oil production practices by key players in the supply chain through developing and sharing a credible and verifiable benchmark that builds upon the Roundtable on Sustainable Palm Oil (RSPO), creating and promoting innovations.

Stephenson Group Ltd formulates, manufactures and supplies high performance products designed to meet our customer’s specified requirements for use in the Personal Care, Industrial and Beverage markets that we serve. We are committed to remaining compliant with all relevant legislation and other voluntary standards; and will never compromise on the safety or quality of our products and services.

We shall endeavor to continually monitor and improve all areas of the business to drive forward the company strategy of applying creative chemistry to develop specialty ingredients that add value to our customer’s products and brands.

The quality objectives of the Stephenson Group Quality Management System are set out to provide all interested parties with top quality products and customer experience in order to drive forward our position as a known manufacturer. These objectives will be achieved through internal and external audits, review meetings, employee engagement and continuous improvement. All the objectives set out in the quality policy will be reviewed by the senior management team continually throughout the year and changes made where required to improve the quality of Stephenson Group products and services.

Stephenson Group Ltd formulates, manufactures and supplies high performance products designed to meet our customer’s specified requirements for use in the Personal Care, Industrial and Beverage markets that we serve.

Stephenson Group Ltd is fully committed to reducing the impact on the environment caused by its activities as well as committed to remaining compliant with all applicable legislation and other voluntary standards which relate to our environmental aspects.

We maintain an environmental management system which considers the nature, scale and environmental impacts of our processes, and are committed to a process of continual improvement and prevention of pollution.

Environmental objectives and targets will be reviewed by the senior management team continually throughout the year these reviews are documented; objectives will be achieved through internal and external audits, review meetings, employee engagement and continuous improvement. . Information regarding these objectives and targets will be communicated on a regular basis.

Statement:

Stephenson Group Ltd will provide and maintain a safe place of work and strive to prevent accidents and cases of work related ill-health by managing the risks in the workplace.

We will provide and maintain a safe and healthy working environment; safe plant, equipment and machinery; and ensure the safe use of substances at all times on our site.

We will provide adequate information, instruction, training and supervision to enable employees to carry out their work safely and competently.

We are committed to remaining compliant with all relevant health and safety legislation, and we will consult with employees on matters relating to their health and safety.

Arrangements:

All employees and contractors will be inducted to the Stephenson Group site prior to starting work.

Employees will be provided with the necessary personal protective equipment to enable them to do their job safely.

Toilets, drinking water and washing facilities will be provided to all personnel working at the Stephenson group site.

Risk assessments will be carried out and improvements implemented where necessary. Standard operating procedures and instructions will be provided throughout site, and training will be carried out by competent persons. Supervision will be provided by staff at all levels of the business.

Inspection, testing and maintenance of equipment will take place to ensure that it remains safe, in good working order and without defects.

Employees will be consulted on health and safety matters as issues arise, and are also encouraged to raise any issues about which they have concerns.

Responsibilities:

Chief Operating Officer - Responsible for the provision of a safe working place and safe plant and equipment.

Health, Safety, Environment and Training Manager - Responsibility for the day to day management of health and safety on site. Responsibility for the provision of training for employees.

Department Managers - Responsibility for day to day management and supervision.

All employees - Responsible for working safely and in accordance with the instructions and training provided.

Stephenson Group Ltd contract manufactures and supplies performance products designed to meet customers’ specified requirements for use in the carbonated beverage industry for the brand Sustain.

SGL is committed to providing products that are safe and fit their intended purpose as a processing aid/foam control agent/emulsifier by maintaining a robust hazard analysis and critical control point system, under the guidance of the FSSC 22000 scheme and the Food Safety Management System used on site for this product range. SGL will also maintain and monitor the Quality Management System, this will help the business continually improve in all areas in order to ensure continued customer satisfaction. This contract manufacturing is a key objective for the business.

A business communication plan is in place to cover internal and external communication when required. A Food Safety Management Team is in place to ensure the system is continually beaning monitored and continual improvement is taking place to improve the business. Everyone involved in the Food Safety Management Team and the production of the sustain product range have the relevant competencies for their role within the business.

The company is aware that full commitment to a food safety management system is vital to obtaining this objective. We are committed to remaining compliant with all relevant legislation and other voluntary standards where applicable.

This privacy policy has been compiled to better serve those who are concerned with how their personal information is being used online. Personal information can be used to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website and newsletter signups. We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons, so we recommend reviewing it occasionally.

What personal information do we collect from users that visit our website?

When you visit the website, we automatically collect certain information about the way you browse our website and your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. We also automatically collect information about how you browse the website, which pages you visit and generally how you interact with our website. Additionally, as you browse the website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the website, and information about how you interact with our website. We refer to this automatically-collected information as “Device Information.”

When do we collect information?

We collect information from you when you browse our website, subscribe to a newsletter, fill out a form, use Live Chat or enter information on the forms of our website. We refer to this information as “Enquiry Information”. We collect enquiry information from you such as your name, email address, phone number, website and country of origin.

How do we use your information?

We use information from sign-ups for our newsletter, survey responses or marketing communication, website surfing, or use certain other website features in the following ways:

• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.

• To improve our website in order to better serve you.

• To allow us to better service you in responding to your customer service requests.

• To send periodic emails regarding your order or other products and services.

• To follow up with you after correspondence (live chat, email or phone inquiries)

About cookies on our website

Cookies are small files that a website or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enables the website's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us report and improve our products, and improve user experience on the website. They are also used to help us understand your preferences based on previous or current website activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about website traffic and website interaction so that we can offer better website experiences and tools in the future.

We also use trusted third-party services that track this information on our behalf (Hubspot and Google Analytics).

Turning off cookies
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.

We track website on Google Analytics (through cookies described above), however if you visit our page for the first time, you can accept or ignore cookies to run on the site via the pop up enabled on our website. If you turn cookies off, it will not affect the user's experience.

How do we protect your information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our website as safe as possible.

We use regular Malware Scanning
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.


Third-party disclosure & Information Sharing
As a business to business provider, we will often share your data an affiliate distributor in order to fulfil customer requests, such as to purchasing products. This is the only instance where we will share customer data. Otherwise, we do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our website policies, or protect ours or others' rights, property or safety.

Email Communications

We collect your email address in order to:

Send information, respond to inquiries, and/or other requests or answer to questions

• Process orders and to send information and updates pertaining to orders.

• Send you additional information related to your product and/or service

• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

If at any time you would like to unsubscribe from receiving future emails, follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

Also if you want to change your personal information at any time, you can do so by:

• By emailing us

• By chatting with us

• Filling the forms
  

Contacting Us

If there are any questions regarding this Privacy Policy, you may contact us using the information on our contact page.