Palm Oil Procurement: A How-To Guide for the Retail and Services Sectors
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1 Palm Oil Procurement: A How-To Guide for the Retail and Services Sectors August 2012 i
2 CONTENTS Introduction..1 Why is it important to support sustainable palm oil? How can actively engaging with your supply chain make a difference? Given the negative impacts of palm oil production, shouldn t retailers try and cut palm oil entirely from their supply chains? What are the key ways in which you can make a difference?...3 Ask for certification Prioritise products containing CSPO Buy GreenPalm certificates Communicate! Who else is doing this?...4 Developing sustainable palm oil procurement standards: 7 easy steps 5 1. Develop a palm oil procurement policy that clearly outlines your organisation s commitments and timeframes 2. Carry out a review of all products potentially containing palm oil that are procured by the different departments within your organisation 3. Inform suppliers of your palm oil procurement policy 4. Review suppliers commitments to CSPO and ensure that they are in line with your policy requirements 5. Change suppliers 6. Formalise this process and develop a palm oil procurement procedure 7. Monitor, measure, and report on your success Flow diagram: a step-by-step guide to CSPO procurement..8 Appendix 1: ZSL s position statement on its work with the palm oil industry in Indonesia.. 9 Appendix 2: ZSL s sustainable palm oil policy...10 Appendix 3: ZSL s internal guide to uses of palm oil (case study example).11 Appendix 4: Common names for palm oil and palm oil derivatives 13 Appendix 5: ZSL s to suppliers (case study example)...15 Appendix 6: RSPO members with time-bound commitments to source 100% CSPO as of ii
3 Introduction ZSL believes a collaborative and participatory approach is fundamental in reducing and mitigating the negative pressures that palm oil plantations place upon the environment. To this end, we actively participate in the Roundtable on Sustainable Palm Oil (RSPO) and relevant working groups and taskforces in order to support progress towards better practices, stricter regulation, better spatial planning, and greater accountability and transparency. ZSL is currently working with the palm oil industry in Indonesia to reduce the negative impacts of palm oil production and is also looking at areas of high conservation value in Africa where palm oil production is likely to expand. For further information on ZSL s work, please see Appendix 1 (page 9). Why it is important to support sustainable palm oil? Palm oil production can have serious negative environmental and social impacts. Millions of hectares of tropical rainforest have been destroyed in recent years most notably in Malaysia and Indonesia to make way for oil palm plantations. This largescale deforestation has huge implications for climate change as well as for many native species, including tigers and orangutans, which are being pushed closer to extinction as their habitat is destroyed and they come into increasing conflict with humans. Palm oil production also causes social conflict when small farmers, local communities, and indigenous peoples lose the rights to their land. There have also been reports of workers rights being violated by plantation owners. The certification standards for sustainable palm oil developed by the RSPO are based on a set of principles and criteria that include the protection of primary forest and areas of high conservation value as well as the rights of local communities, plantation workers, and indigenous peoples. Best practices allow for positive development that offers real economic and social advantages for a country and its people and can consequently work towards safeguarding the environment. By purchasing certified sustainable palm oil (CSPO) you are supporting these efforts and driving the palm oil industry toward production of 100% certified sustainable palm oil. How can actively engaging with your supply chain make a difference? It is important for retailers to actively engage with supply chains as this will drive demand for sustainable palm oil. 1
4 As palm oil is used as an ingredient in a large number of consumer products, stakeholders at the retail/consumer end of the palm oil supply chain can play an important role in increasing demand for CSPO. This increased demand through the adoption of strict policies for the procurement of products containing CSPO places pressure upon growers to adopt best practices for sustainability. Establishing policies and procedures for procurement of sustainable palm oil is not as daunting a task as it might seem, and we provide here a simple step-by-step guide to help you through the process. Given the negative impacts of palm oil production, shouldn t retailers try and cut palm oil entirely from their supply chains? Palm oil is a highly versatile oil, and oil palm is by far the most productive commercial vegetable oil crop per hectare Since vegetable oils are largely interchangeable, ZSL believes that boycotting palm oil is not a practical solution as it will serve to drive demand for less productive oil crops such as sunflower, rapeseed, and soya bean, which may have a worse environmental impact in the long term. Given that the production of palm oil is also a significant source of employment and economic development in developing countries in the tropics, future increases in production seem inevitable. Therefore it is imperative that producers are engaged to use responsible practices and reduce their negative impacts. While the decision to boycott or not lies with individual retailers, you may find that it is simply not feasible, given that palm oil is present in one form or another in over 50% of the consumer goods sold in most supermarkets. We suggest that a procurement policy represents a reasonable compromise, as it enshrines a firm commitment to sourcing CSPO and drives demand in the market, which will ultimately compel producers to adopt best practices for sustainable production in oil palm plantations. 2
5 What are the keys ways in which you can make a difference? 1. Ask for certification The best option is to buy products that use RSPO Certified Sustainable Palm Oil (CSPO) rather than non-cspo. If CSPO is not available, you can ask whether GreenPalm certificates are available as an interim measure. These do not ensure that the palm oil you buy is sustainable, but they reward producers who are moving towards sustainable palm oil. Prioritise products containing CSPO Palm oil is one of the most widely used ingredients in the world, and its production is driven by consumer demand for a broad range of products, including foodstuffs, cosmetics, cleaning products, and fuel. By demanding that only CSPO be used in these products, retailers put pressure on manufacturers to source fully traceable sustainable palm oil, which in turn encourages oil palm growers and millers to adopt best practices for sustainability and increase their production of CSPO to meet this demand. Ask your suppliers if their products contain certified sustainable palm oil and look out for the RSPO logo. For more information on CSPO visit Buy GreenPalm certificates Securing sustainable palm oil through your supply chain takes time to implement; therefore you may want to consider purchasing GreenPalm certificates as an interim measure to cover the volume of palm oil purchased and provide an incentive to growers to produce more CSPO. Currently, most of the palm oil that is traded is sourced from multiple plantations and mills and is therefore unsegregated, making it impossible to know whether the palm oil you buy has come from a certified sustainable plantation or not. The GreenPalm certificate trading programme offers a solution to this problem in the absence of a fully traceable supply of CSPO. For every tonne of palm oil that an RSPO-certified grower produces, they can trade one GreenPalm certificate. The money they make from trading the certificates allows them to recover the costs of becoming certified and using sustainable practices. By purchasing GreenPalm certificates, manufacturers and retailers are actively supporting the sustainable production of palm oil. In turn, consumers can create demand for CSPO by purchasing products carrying the GreenPalm logo. For more information on GreenPalm visit 3
6 2. Communicate! By communicating a clear message to your staff, suppliers, and customers about your position on CSPO and why you are taking action to achieve a sustainable and ethical supply chain, you will raise awareness of the issues related to palm oil production and thereby strengthen the demand for CSPO. It is important to emphasise to customers that any additional costs incurred by sourcing CSPO will not be passed on to them. Who else is doing this? Many retailers have already made progress in sourcing CSPO. ASDA, Carrefour, Morrison s, Sainsbury s, and Tesco, among others, have committed to using only CSPO in their own-brand products by 2015, and many lesser known brands and smaller corporate responsibility-conscious companies are also playing their part. Any company that purchases palm oil, regardless of size, can easily take responsible measures to address its supply chain. Pressure also needs to be focused on third-party suppliers to take control of their supply chains and improve transparency and sustainability. On the manufacturing side, several global brand leaders, notably Unilever and Nestle (UK), have made significant progress towards using CSPO, as have United Biscuits, Royal FrieslandCampina, Burton s Foods, Cadbury, Premier Foods, and Remia. 4
7 Developing sustainable palm oil procurement standards: 7 easy steps The guidelines presented here are based on ZSL s first-hand experience of developing a procurement strategy for its operations at London Zoo and Whipsnade Zoo as part of its ISO14001 Environmental Management System (EMS). This strategy covers a range of departments within ZSL, including internal catering, external catering, retail, animal department, and estates. This guide is designed to flexibly apply to any company, regardless of differences in structure or operations, and if your organisation already has an EMS in place, this procedure should fit easily within that system. 1. Develop a palm oil procurement policy that clearly outlines your organisation s commitments and timeframes. This should include a communication strategy for encouraging others to become more ethical consumers of palm oil and to highlight your company s commendable efforts in this regard. If possible, have it signed off by someone senior in your organisation as a sign of your commitment to sustainable palm oil. As an example, see ZSL s Sustainable Palm Oil Policy (page 10). 2. Carry out a review of all products potentially containing palm oil that are procured by the different departments within your organisation. Check whether suppliers have a sustainable palm oil policy. Be aware that many products contain hidden palm oil in the form of palm oil by-products or palm oil that has been simply labelled as vegetable oil in the ingredients list. For more information on what to look out for, refer to ZSL s guide on uses of palm oil in food and non-food products (page 11). This document is related to products used by ZSL and is provided as a case study example. You may wish to develop something similar for your own organisation. As part of its UNLESS project to engage and inform consumers on the environmental issues associated with palm oil production, Philadelphia Zoo has produced a more detailed list of common names for palm oil and palm oil derivatives (page 13), which can be very useful when checking product ingredients for palm oil. Given the large number of products that contain palm oil, you may decide to take a step-by-step approach, initially committing to a review of the food items you procure, leaving cleaning products and other groups to a later stage. 5
8 The product review is a simple process of gathering information on the use of palm oil by all of your suppliers. It is suggested that the following information be recorded: The name of the supplier The individual companies whose products they supply The types of products supplied Do these products contain palm oil? (as of date ) Does the supplier have a policy on sustainable palm oil? (as of date ) What are the supplier s key commitments in relation to sustainable palm oil? (as of date ) Is this in line with your organisation s policy? (as of date ) The name, position, and /telephone number of a key contact Date of last contact All of this information can be stored in a simple tabular framework such as an Excel spreadsheet. To help you manage your supply chain for sustainability, you may wish to consider joining an organisation such as Sedex, which provides a platform for information-sharing on labour standards, health & safety, the environment, and business ethics. 3. Inform suppliers of your palm oil procurement policy. Once information has been gathered on the uses of palm oil by your suppliers and their commitments regarding CSPO, you will want to inform them of your own CSPO procurement policy. Ideally you should discuss the policy with them and identify the changes in your requirements of them as suppliers. For large-scale suppliers we suggest that you may wish to involve them in the development of your strategy, and in turn motivate them to generate one of their own. For all suppliers this is an opportunity to encourage them to publicly commit to sourcing CSPO within a stated timeframe, if they have not already done so. It is important to ensure that your supplier is aware that sourcing from RSPO members and/or purchasing GreenPalm certificates does not equate to purchasing CSPO. Suppliers will need to provide certification from the RSPO as proof that they are sourcing and using sustainable palm oil in their products. Simple membership of the RSPO does not imply certification but that a company has made a time-bound commitment to becoming more sustainable. 6
9 For an example of how suppliers can be approached, see ZSL s sample for contacting suppliers (page 15). 4. Review suppliers commitments to CSPO and ensure that they are in line with your policy requirements. Records of all your suppliers and manufacturers policies and commitments relating to palm oil should be collated and maintained, updating them as and when new companies are brought into your procurement. Include this information in the same simple table used for step 2. We suggest you use the list of RSPO members with time-bound commitments on CSPO (page 16) as a starting point, and if in doubt contact your suppliers directly. 5. Change suppliers. Once suppliers been informed of your new policy on CSPO procurement, if a company does not, or is unable to, adhere to your procurement policy, contractual obligations must be fulfilled and an alternative supplier found. However, always try and encourage suppliers to commit to sustainable palm oil in the first instance, and where possible offer assistance to facilitate this change. Be aware that it may take them some time to understand the issues surrounding the palm oil supply chain and to make the transition to CSPO. 6. Formalise this process and develop a palm oil procurement procedure. Once this process has been tested, outline all the necessary steps to ensure that your organisation complies with its palm oil policy and the standards it wants to maintain in the long term. Develop this into a procedure and issue to all relevant staff. 7. Monitor, measure, and report on your success It is important to set achievable targets and key performance indicators (KPIs) by which to measure your own success and identify where improvements are necessary. KPIs within your policy could include the percentage of your suppliers who are committed to CSPO or the percentage of products that contain CSPO. Reviews must be carried out periodically to ensure that suppliers have not changed their commitments. Corrective action must be taken to address any failures identified, and your corrective action process should be outlined in your procedure. 7
10 MONITOR & REPORT DEVELOP PROCUREMENT PROCEDURE REVIEW SUPPLIERS SET POLICY A STEP-BY-STEP GUIDE TO CSPO PROCUREMENT Develop a palm oil procurement policy that clearly outlines your organisation s commitments and timeframes Carry out a review of all products potentially containing palm oil Inform suppliers of your palm oil procurement policy Record company commitments Does the company use palm oil in its products? Yes No Is it using RSPO CSPO and/or does it have a policy or time-bound action plan in place to source only RSPO CSPO by 2015? Request a policy on the use of palm oil that adheres to your own procurement policy in order to cover potential future use Yes No Go ahead with the purchase Go ahead with the purchase Find alternative supplier Monitor progress via KPIs Perform corrective actions as necessary at any of the above stages 8 Report outcomes
11 Appendix 1: ZSL s position statement on its work with the palm oil industry in Indonesia Background: The Zoological Society of London (ZSL) is an international scientific, conservation and educational charity whose mission is to promote and achieve the conservation of animals and their habitats. Our mission is realised through ground breaking and internationally acclaimed science which we apply and develop in active conservation projects in more than fifty countries. ZSL recognises the economic value that palm oil has for developing countries to help them achieve their development goals. However, current practices used in the production palm oil have been found to have long-lasting negative effects on biodiversity, habitats, and ecosystem services. ZSL believes it is essential to use a collaborative and participatory approach to reduce and eradicate the negative pressures that palm oil plantations place upon the environment. The Roundtable on Sustainable Palm Oil (RSPO) is a certification scheme, as well as a stakeholder platform, committed to achieving this goal. ZSL therefore actively participates within the RSPO and its working groups and taskforces in order to steer the direction of progress towards better practices, stricter regulation, better spatial planning, and greater accountability and transparency. ZSL has been researching the effects of palm oil production on biodiversity since 2001 and is now one of the leading environmental NGOs working to provide knowledge-based, practical solutions, tools and mechanisms to address these problems. To refine the biodiversity monitoring methods we are proposing, we are undertaking research on two plantation sites run by RSPO certified companies that actively participate in the RSPO s Biodiversity and High Conservation Value (HCV) working group. Through these relationships, we aim to refine our methods; developing practical and standardised tools and techniques that can be used in the palm oil plantations to increase a company s capacity to minimise impacts on the environment and manage the biodiversity found in the remaining HCV areas on palm oil concessions. Go back 9
12 Appendix 2: ZSL s sustainable palm oil policy The Zoological Society of London s (ZSL) mission is: to promote and achieve the worldwide conservation of animals and their habitats. ZSL is committed to sourcing products which contain certified sustainable palm oil (CSPO), especially those used within the Catering and Retail Departments. ZSL recognises that good environmental management is a critical element of achieving its mission and that sourcing CSPO is an important aspect of this. ZSL recognises that palm oil production has serious negative environmental and social impacts. However ZSL also recognises that the palm oil industry plays an important role in employment, economic development and is currently the most productive commercial vegetable oil crop per hectare. Due to these factors ZSL recognises that palm oil production will persist and increase in the future, therefore producers must be engaged to strongly reduce their negative impacts. Since vegetable oils are largely interchangeable, ZSL believes that boycotting palm oil is not a practical solution as it will serve to drive demand elsewhere. Specifically ZSL is committed to: Review all products purchased to identify their palm oil content. By 2012, only purchasing products that are either manufactured using only palm oil that has been certified as sustainable by the Roundtable on Sustainable Palm Oil or are from suppliers who have committed to sourcing only RSPO CSPO by 2015 at the latest. Ensuring external caterers and agents adhere to the sustainable palm oil policy Communicating our sustainable palm oil policy and guidance to suppliers to improve corporate social responsibility through the supply chain. Working with the RSPO through our Biodiversity and Oil Palm Project in Indonesia and participation in the RSPO Biodiversity and High Conservation Value Working Group in order to strengthen its Principles & Criteria Increasing public awareness of the importance of sustainable palm oil CSPO is defined as that compliant with the requirements of the RSPO certification scheme. This policy currently only applies to products purchased for human consumption; however, other key areas under review with regards to use of CSPO include cleaning products and animal feed. ZSL is aware that at present palmderived oleochemical usage in cleaning products is unknown and further research is needed. ZSL will ensure that its staff and external agents and contractors are kept aware of this policy and their individual responsibilities by issuing a procedure on sustainable palm oil procurement, incorporating it into its wider Environmental Management System. Go back 10
13 Appendix 3: ZSL s internal guide to uses of palm oil (case study example) Use of palm oil within the food sector Palm oil is predominantly used in confectionary, breads, pastries, margarines, and spreads and is principally listed as vegetable oil in the ingredients. Retail and catering staff and their suppliers should be aware of the various guises in which palm oil and its fractionates are listed, mainly: Vegetable oil Palm oil kernel Palmitate Saturated fat content 50% or > then good chance it s palm oil Margarine highly likely to be derived from palm oil Cocoa butter equivalent (CBE) Cocoa butter substitute (CBS) Palm Olein Palm Stearine Although E471 (Emulsifier) and other food additives can be derived from palm oil, it is unlikely that certified sustainable oleochemical derivatives will be widely available in the near future, therefore we will focus initially on tackling the use of palm oil as a vegetable oil until such time as the situation changes. This should be done by requesting either certification evidence of current use of CSPO or a signed policy or time-bound action plan outlining a company-wide commitment to sourcing only CSPO by If a company does not use palm oil, you should still request a position statement from them which adheres to your procurement policy in order to cover potential future use. Use of palm oil within the non-food sector Cleaning products: Cleaning products contain oil-based chemical derivates in the form of oleochemicals; however, because oleochemicals are rarely differentiated based on the original feedstock, traceability is currently a major challenge. Some key industry players have begun working with their manufacturers and suppliers to identify the sources and encourage sustainable and responsible production and procurement practices. 11
14 We recommend prioritising the purchase of products from those suppliers who source CSPO. Animal feed: Palm oil and palm kernel meal is a component of animal feed used for commercial livestock (such as cattle, sheep and pigs), pet food, as well as domestic and commercial fish food. Currently there is little awareness of sustainability of palm oil in the feed industry, though there is evidence that this is starting to change. Palm Kernel Meal is often described as a by-product, and some have argued that for this reason sustainability concerns are not an issue. However, there are indications that this is changing, for example, in November 2010, GreenPalm introduced tradeable certificates for Palm Kernel Meal (PKM). When procuring animal feed which contains palm-derived ingredients, make your suppliers aware that certification is now available for the sector and encourage them to cover their usage of palm kernel meal with GreenPalm certificates. Go back 12
15 Appendix 4: Common names for palm oil and palm oil derivatives These ingredients are definitely palm oil or derived from palm oil: Cetyl Palmitate Elaeis Guineensis Epoxidized Palm Oil (UV cured coatings) Ethylhexyl Palmitate Hydrated Palm Glycerides Octyl Palmitate Palm Oil Palm Fruit Oil Palm Kernel Palm Kernel Oil Palm Stearine Palmate Palmitate Palmitic Acid Palmityl Alcohol Palmitoyl Oxostearamide Palmitoyl Tetrapeptide-3 Palmolein Saponified Elaeis Guineensis Sodium Kernelate Sodium Palm Kernelate Sodium Palmate These ingredients are either derived from palm oil or coconut oil: Cetyl Alcohol Fatty alcohol sulphates Isopropyl or Isopropyl Palmitate Sodium Dodecyl Sulphate (SDS or NaDS) Sodium Isostearoyl Lactylaye Sodium Laureth Sulfate (in almost everything that foams) Sodium Lauryl Sulfate Sodium Lauryl Sulfoacetate These ingredients are often derived from palm oil, but could be derived from other vegetable oils: Other vegetable oils (palm oil may be included under this term) Cocoa Butter Equivalent (CBE) Cocoa Butter Substitute (CBE) Emulsifiers (some can be palm oil derived) Glyceryl Stearate Sodium Lauryl Lactylate 13
16 Steareth -2 Steareth -20 Steareth-21 Stearic Acid Go back 14
17 Appendix 5: ZSL s to suppliers (case study example) The text below is a sample for contacting suppliers regarding their use of palm oil. It can be used for guidance and amended according to your specific policy on palm oil procurement: Dear X, Following a review of its supply chains as part of its sustainable procurement strategy, Company name has developed a policy on palm oil which it is outlining to all its suppliers. As from 2012, Company name will only purchase products that contain RSPO-certified sustainable palm oil (CSPO) or from suppliers that have made a public commitment to source only RSPO-certified sustainable palm oil (CSPO) by 2015 at the latest. This will require either a signed policy document and/or time-bound action plan from suppliers, even if their products do not contain palm oil. By committing to sourcing products which contain certified sustainable palm oil (CSPO), Company name is committed to its mission (example from ZSL) to promote and achieve the worldwide conservation of animals and their habitats and is encouraging companies to join them. Thank you for your help in advance. Kind regards, Go back 15
18 Appendix 6: RSPO members with time-bound commitments to source 100% CSPO as of 2011 Organisation Country Time-Bound Pledge to Use/Supply 100% Certified CSPO (as of 2011) Aachener Printen- und Schkoladenfabrik Germany 2012 Henry Lambertz GmbH & Co KG Allied Bakeries United Kingdom 2014 Boots UK Limited United Kingdom 2014 Burton s Foods Ltd United Kingdom 2011 B.V. Remia Handelmaatschappij The Netherlands 2014 Cadbury PLC United Kingdom 2010 Carotino/JC Chang Group Malaysia 2015 Carrefour France 2015 Cloetta Sverige AB Sweden 2011 Coles Supermarkets Pty Ltd Australia 2015 ConAgra Foods, Inc USA 2015 Coop, Switzerland Switzerland 2011 CSM NV The Netherlands 2015 Dairy Crest Group plc United Kingdom 2015 Dragsbaek A/S Denmark 2014 DSM Nutritional Products AG Switzerland 2013 Federation of Migros Cooperatives Switzerland 2015 Ferrero Trading Lux S.A. Luxembourg 2015 Findus Group/Young's Seafood Ltd United Kingdom 2015 Fonterra Co-operative Group Ltd New Zealand 2015 Goodman Fielder Ltd Australia 2015 Gőteborgs Kex AB Sweden 2011 H J Heinz Company Ltd United Kingdom 2013 Haribo GmbH & Co KG Germany 2011 Henkel AG & Co. KGaA Germany 2015 J Sainsbury PLC United Kingdom 2014 Johnson & Johnson USA 2015 Juchem Food Ingredients GmbH Germany 2015 Kamani Oil Industries Pvt. Ltd India 2015 Kao Corporation Japan 2015 Kerry Group United Kingdom 2015 Lantmännen ek för Sweden 2011 Lindt & Sprungli (International) AG Switzerland 2011 Lion Corporation Japan 2015 L Oreal France 2010 Marks & Spencer PLC United Kingdom 2015 Morning Foods Ltd United Kingdom 2010 Nataïs France 2011 Natra SA Spain 2011 Neste Oil Corporation Finland 2015 Nestle S.A. Switzerland 2015 Nutriswiss AG Switzerland 2015 Nutrition et Santé France
19 Oy Karl Fazer AB (VAT F ) Finland 2012 P&G USA 2015 Palsgaard A/S Denmark 2015 Peeters Produkten BV The Netherlands 2013 PEPSICO USA 2015 Premier Foods Group Limited United Kingdom 2015 PT Intibenua Perkasatama Indonesia 2020 Remia C.V. The Netherlands 2014 Royal Ahold NV The Netherlands 2015 Royale Lacroix Belgium 2015 sa Aigremont nv Belgium 2015 Saraya Co Ltd Japan 2015 SAS Devineau France 2011 SC Johnson & Son, Inc USA 2015 Seventh Generation, Inc USA 2015 Sime Darby Unimills BV The Netherlands 2012 Sun Products Corporation USA 2015 Taiyo Yushi Corp Japan 2015 Tesco Stores Ltd United Kingdom 2012 The Body Shop International United Kingdom 2011 The Co-operative Group United Kingdom 2011 The Jordans & Ryvita Company Ltd United Kingdom 2010 Unilever NV (VAT: NL B77) The Netherlands 2015 United Biscuits (UK) Ltd United Kingdom 2011 Vitacuire SAS France 2015 Waitrose Ltd United Kingdom 2012 Wal-Mart Stores, Inc USA 2015 Walter Rau Neusser Öl und Fett AG Germany 2015 Warburtons Ltd United Kingdom 2015 WhiteWave Foods USA 2015 Wilmar International Ltd Singapore 2015 WM Morrison Supermarkets PLC United Kingdom 2015 Woolworths (Proprietary) Limited South Africa 2015 Woolworths Limited Australia 2015 Yves Rocher France 2010 Go back 17
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