June 1, 2015

Datuk Darrel Webber, Secretary General Roundtable on Sustainable Palm Oil C/O RSPO Secretariat Sdn Bdh Unit A-33A-2, Tower A, Level 33A Menara UOA Bangsar No. 5 Jln Bangsar Utama 1 59000 Kuala Lumpur, Malaysia

Dear Mr. Webber:

We, the undersigned companies and investors representing $5 trillion in assets under management, believe that sourcing palm oil that has been responsibly and sustainably produced is important to protect both consumer and producer companies’ operations, reputations, and market access. As an international certification scheme, the RSPO is uniquely positioned to support, promote, and enforce the widespread uptake of responsible and sustainable production practices across the palm oil industry. Given current shortcomings of RSPO certification, however, purchasing RSPO Certified Sustainable Palm Oil (CSPO) does not sufficiently address critical sustainability concerns in the palm oil supply chain. We are, therefore, writing to urge the RSPO to strengthen its standards and practices to reflect best practices widely recognized as necessary to ensure palm oil is produced in a manner that does not degrade the environment or result in violations of human rights.

Companies that purchase palm oil certified by the RSPO do so out of concern that conventional palm oil production is too often associated with adverse environmental and social impacts. Unfortunately, the RSPO currently does not include protections for some of the most critical externalities of palm oil production, such as conversion of High Carbon Stock forests and expansion on peatlands, nor provide sufficient assurance that its standards are being complied with. Consequently, many companies across the palm oil supply chain have voluntarily adopted their own sourcing standards that go beyond those set by the RSPO, to ensure responsible and sustainable palm oil production. The majority of palm oil flows through the supply chain of refiners and traders committed to standards that exceed those set by the RSPO.

Expectations for sustainable palm oil production have evolved rapidly with growing recognition of the sustainability challenges facing the industry. It would be inconsistent with the imperative of addressing deforestation, peatland conversion, and human rights violations swiftly and efficiently for the RSPO to wait until 2018—as the current timeline suggests—to finalize changes to the Principles & Criteria (P&C) to address these issues.

We recognize that the RSPO plays an important role in promoting sustainability in the palm oil sector. To ensure that the RSPO remains relevant as expectations for sustainable palm oil sourcing evolve, and that the platform better reflects the commitments of its membership, we call on the RSPO to take the following actions:

 Conduct an accelerated review of the P&C and related documents. The review should include recommendations leading to adoption and implementation in 2016 of the following requirements: o Conserve High Carbon Stock areas; o Protect peat, regardless of depth; o Report on greenhouse gas emissions and reduction targets; o Ensure palm oil originates from known sources; and  Strengthen transparency, auditing and enforcement among member companies: o Improve quality control measures for High Conservation Value and human rights assessments to ensure objective and rigorous auditing, verification, and grievance processes.

The undersigned investors and companies recognize that protecting forests and upholding human rights are essential for long-term business models and, consequently, investments that depend on a resilient, sustainable natural capital base. Palm oil production offers both challenges and opportunities to promote thriving, sustainable economic development. As such, we urge the RSPO to set and enforce standards for truly responsible and sustainable palm oil production.

Sincerely,

Mars, Inc Dunkin’ Brands

PepsiCo The Kellogg Company

The Procter & Gamble Company General Mills

Kao Corporation Walmart

Colgate-Palmolive Albertsons-Safeway

Johnson & Johnson Family of Consumer Coop Switzerland Companies Seventh Generation Starbucks Carrefour ConAgra

Thomas DiNapoli President Comptroller, State Green Century Capital Management, Inc. New York State Common Retirement Fund Naïm Abou-Laoude Chief Executive Officer Meryam Omi Candriam Investors Group Head of Sustainability Legal & General Investment Annie Bersagel Management Advisor, Responsible Investments GES Investment Services Kommunal Landspensjonskasse (KLP)

Allianz Global Investors Dennis van der Putten Head of ESG Research Y.K. Park ACTIAM Director, Sustainability & Governance Asia Per Lindren APG Asset Management, Asia Head of Manager Selection and Acting Steve Waygood Head of Governance Chief Responsible Investment Officer Skandia Aviva Investors Marieke de Leede Nataxis Asset Management Director of Responsible Investment Kempen Capital Management Peter van der Werf Engagement Specialist Carina Lundberg Markow Robeco Executive Officer, Corporate Governance Piet Klop Folksam Senior Advisor, Responsible Investment PGGM Investments Peter Lundkvist Head of Corporate Governance Kieran Quinn Third Swedish National Pension Fund Cllr (AP3) Local Authority Pension Fund Forum (LAPFF) Arne Lööw Head of Corporate Governance Scott Stringer Fourth Swedish National Pension Fund Comptroller, New York City (AP4) New York City Office of the Comptroller Ossian Ekdahl Therese Niklasson Head of ESG Global Head of ESG First Swedish National Pension Fund Investec Asset Management (AP1)

Ulrika Danielson Leslie Samuelrich

Head of Communications & Human Resources Mirova Second Swedish National Pension Fund (AP2) Megan Manzi Senior Investment Administrator Johan Strandberg Highclere ESG Investment Specialist SEB Investment Management Elizabeth Pearce Adrian Orr Vermont Pension Investment Committee CEO & Office of the Vermont State Treasurer New Zealand Superannuation Fund Julie Gorte Mark Mills Sr. Vice President for Sustainable Partner Investing Generation Investment Management Pax World Management, LLC

Tonya Wells Neville White VP Public Policy & Federal Advocacy Ecclesiastical Investment Management Trinity Health Aaron Ziulkowski Susan Vickers Senior ESG Analyst VP Corporate Responsibility Walden Asset Management Dignity Health Eric Hoterhues Annelie Enquist Head of SRI CEO Triodos Investment Management Skandia Fonder Mark Regier Luan Steinhilber Vice President, Stewardship Investing Director of Operations and Shareholder Everence and the Praxis Mutual Funds Advocacy Miller/Howard Investments, Inc. Jonas Kron Senior Vice President Marie Luchet Trillium Asset Management, LLC Head of SRI Ecofi Investissements Constantina Bichta Manager, ESG Research Bill Hartnett Boston Common Asset Management Head of Sustainability Local Government Super Blaine Townsend Partner, Senior Portfolio Management Robert Walker Nelson Capital Management, LLC Vice President, ESG Services & NEI Ethical Funds NEI Investments William Seddon

Chief Executive Officer Treasurer & CFO Central Finance Board of the Methodist Unitarian Universalist Association Church Ann Roberts Dominique Biedermann ESG Analyst CEO Dana Investment Advisors Ethos Foundation Seamus Finn Adam Kanzer Chief FCI Managing Director OIP Trust Domini Social Investments, LLC Seamus Finn Catherine Cartier Missionary Oblates of Mary Immaculate President Progressive Asset Management Danielle Ginach Impact Manager Tim Macready Sonen Capital Chief Investment Officer Christian Super Jeffery Perkins Executive Director Marcela Pinilla Friends Fiduciary Corporation Director, Shareholder Advocacy Susan Ernster John Keenan Treasurer American Federation of State, County Franciscan Sisters of Perpetual Adoration and Municipal Employees (AFSCME) Anselm Balk Steven Scheuth C-QUADRAT Asset Management President GmbH First Affirmative Financial Network Sally Ann Brickner Phil Vernon Coordinator of Justice, Peace, & Integrity Managing Director of Creation Australian Ethical Investment Congregation of Sisters of St. Agnes

Francis Sherman Nora Nash Associate Director Director Corporate Social Responsibility WIM-CRI Sisters of St. Francis of Philadelphia

Fr. Seamus Finn, OMI Kevin Jennings Chief of Faith Consistent Investing Executive Director OIP Investment Trust Arcus Foundation

Andrew Friedman Timothy Brennan President

AJF Financial Services, Inc. Lidija Marjanovic Sustainalytics Lisa Heinz Chief Financial Officer Mauro Meggiolaro Mennonite Education Agency Shareholder Engagement Fondazione Culturale Responsabilità Ken Jacobs Etica Owner, President Colorado Sustainable Asset Management William Provincial Missionary Oblates, USA Peter Krull President Alessandra Viscovi Krull & Company CEO Etica SGR Joy Peterson Sinsinawa Shareholder Committee Barbara King Sisters of the Presentation of the Blessed Ruth Geraets, PBVM Virgin Mary Treasurer Sisters of the Presentation Sister Colleen Dauerback SSJ Social Justice Coordinator Judy Byron, OP Sisters of St. Joseph of Chestnut Hill Director Northwest Coalition for Responsible Mary Beth Gallagher Investment Acting Director Tri-State Coalition for Responsible Maryann Mueller Investment JPIC Coordinator Leadership Team of the Felician Sisters Sisters of Providence of North America Leadership Team