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4.1  The company has senior leadership responsibility and accountability to stand behind its commitments, including at CEO and/or board-level.

4.2  Commitments are embedded into decision-making processes, systems, and performance metrics of core business units (eg, procurement), agents, affiliates, and subsidiaries at all applicable levels of the company. This includes dedication of relevant personnel as well as efforts to raise awareness and build capacity through company policies, incentives, manuals, and training initiatives.

4.3  The company has effective systems to avoid financing site acquisition, land clearance, land development, or infrastructure that contribute to deforestation, conversion, or human rights violations.

4.4  The company operates an effective operational-level grievance mechanism(s), following the Effectiveness Criteria of the UN Guiding Principles on Business and Human Rights, for rightsholders and other stakeholders to raise complaints and access remedy in cases where environmental or social harms have occurred. The company assesses existing state and non-state grievance mechanisms and supports efforts to strengthen and facilitate access to these as necessary to help identify and resolve grievances within their operations and supply chains.

4.5  The company implements stakeholder engagement processes to provide relevant information to stakeholders and afford opportunities for input and engagement related to fulfilment of the company’s supply chain commitments.

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