Prevention of Deforestation Policy

1. POLICY STATEMENT
1.1. Forests play a critical role in climate change mitigation, provide an invaluable habitat for 
wildlife, and support the livelihoods of many people around the world. 
1.2. In line with our commitment to Net Zero 2040, we are committed to ensuring deforestation 
free products and supporting the prevention of illegal deforestation across our supply chains 
by 2040. However, due to the European Union Deforestation Regulations (EUDR), many of 
our products will be required to be deforestation free by 2026. We are committed to ensuring
products that will be exported to the EU are EUDR compliant (see appendix 1).
1.3. ‘Deforestation-free’ means:
(a) that the relevant products contain, have been fed with or have been made using raw 
materials, referred to as ‘in-scope materials’ (see appendix 1), that were produced on 
land that has not been subject to deforestation after December 31, 2020, and
(b) in case of relevant products that contain or have been made using wood, that the 
wood has been harvested from the forest without inducing forest degradation or 
negatively impacting biodiversity after December 31, 2020.
This applies also to products exported to the EU, but where we are committed to 
procuring deforestation free products by 2030, exports to the EU are required to be 
compliant by 2026.
1.4. This policy is closely linked to other policies that we already have in place, including:
• Environmental Policy Statement
• Palm Oil Policy
2. RESPONSIBILITY FOR THE POLICY
2.1. The board of directors has overall responsibility for ensuring this policy complies with our 
legal and ethical obligations, and that all those under our control comply with it.
2.2. The compliance manager for deforestation prevention is the Sustainability Manager who with 
support from the Operations Director, and the Managing Director, has primary and day-today responsibility for implementing this policy, monitoring its use and effectiveness, dealing 
with any queries about it, and auditing internal control systems and procedures to ensure 
they are effective in countering deforestation.
2.3. All employees must read, understand, and comply with this policy. Management at all levels 
are responsible for ensuring those reporting to them understand and comply with this policy. 
3. OUR COMMITMENTS
3.1. To enforce our commitment to procure deforestation-free products and prevent illegal 
deforestation across our supply chain, in line with our Net Zero by 2040 strategy, and EUDR 
legislation we:
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3.1.1. Commit to continue to do the following:
• Ensure there is board-level oversight of forest-related issues.
• Ensure this policy is made available company wide.
• Ensure this policy is made publicly available and commits to deforestation-free 
activities by 2030.
• Ensure that we procure deforestation free products for EU export by 2026, in line 
with EUDR legislation.
• Ensure this policy is fully integrated into the strategic Net Zero by 2040 plan.
• Where products contain in-scope raw materials, ensure that these come from 
certified sources (see Appendix 2). Certification plays a key role in helping 
producers change to more sustainable farming practices which help to support 
sustainable production and reduce deforestation.
• Proactively assist smallholder coffee suppliers in preserving biodiversity and 
encourage reforestation through specific programmes. For example, we have
previously supported reforestation projects in Bolivia with the Asocafé cooperative 
and Peru with the San Juan del Oro cooperative. Further information on these 
programmes can be accessed in our Sustainability Reports. We will use data from 
our annual producer surveys and work with our stakeholders to most effectively 
direct resources for future projects.
3.1.2.Commit to the following, as recommended by the Accountability Framework initiative1
:
• Conduct a comprehensive deforestation risk assessment with clear goals and 
outcomes.
• Ensure we can trace 100% of non-EU export supplier’s production/consumption 
back to at least municipality or equivalent.
• Ensure that we can trace 100% of EU export suppliers production/consumption 
back to the exact geolocation.
• Ensure 100% of in-scope materials certified in a no-deforestation compliant 
certification.
• Ensure we support and improve supplier capacity to comply with forest related 
policies, commitments, and other requirements through financial or technical 
assistance.
• Ensure we work beyond first tier suppliers to manage and mitigate deforestation 
risks through supply chain mapping or capacity building.
• Ensure we work with smallholders to support good agricultural practices and 
reduce deforestation or conversion of natural ecosystems through financial or 
technical assistance.
• Ensure we control, monitor, and verify compliance with no deforestation 
policies/commitments that covers all relevant operations and supply chains with 
100% of total volume in compliance.
• Ensure company or supplier compliance with forest regulations and/or mandatory 
standards is assessed if sourcing commodities from regions with a high 
deforestation risk.
• Ensure we are supporting or implementing ecosystem restoration and protection 
projects with timely monitoring and measured outcomes.
1 Accountability Framework (May 2022). “From Commitments to Action at Scale.” www.accountabilityframework.org/wp-content/uploads/2022/05/CDP_AFI_Forest_Report_2022_2022_05_23.pdf
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4. COMMUNICATION AND AWARENESS OF THE POLICY
4.1. All employees are made aware of this policy as part of their induction.
4.2. Adequate information and training on the prevention of deforestation is made available to all 
employees, with priority given to those with responsibility for procuring forest risk 
commodities.
4.3. Our approach to preventing deforestation in supply chains is communicated to all suppliers, 
contractors, and business partners at the outset of our business relationship with them and 
reinforced as appropriate thereafter.
5. BREACHES OF THIS POLICY
5.1. The prevention, detection and reporting of deforestation in our supply chains is the 
responsibility of all those working for us who engage with our suppliers and have 
responsibility for purchasing decisions. These employees are required to avoid any activity 
that might lead to, or suggest, a breach of this policy.
5.2. Employees are encouraged to raise concerns about deforestation in our supply chains (of 
any supplier tier) at the earliest possible stage. This includes when you suspect that an 
instance of deforestation has occurred or may occur in the future.
5.3. Should you suspect that a supplier has breached the standards set out in the policy, or that 
there may be a breach in future, you should report this to your line manager and the 
Compliance Manager for assistance in following-up with your concerns. We reserve the right 
to terminate our relationship with suppliers and organisations working on our behalf if they 
breach this policy.
Endorsed: Nick Snow – Managing Director
Date: 10/01/2025
Endorsed: Neil Freckingham – Operations Director
Date: 10/01/2025
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Appendix 1: European Union Deforestation Regulations and Affected Materials2
Commodity Products
Cattle Live cattle, meat of cattle (fresh, chilled and frozen), edible offal, livers, 
other prepared or preserved meat, meat offal, blood of cattle, raw hides 
and skin, tanned or crust hides and skins of cattle and leather.
Cocoa Whole cocoa beans, cocoa husk, skins and other waste, cocoa paste, 
cocoa butter, cocoa powder and chocolate and other food containing 
cocoa.
Coffee Green coffee, roasted coffee, coffee husks and skins, and coffee 
substitutes containing coffee in any proportion.
Oil Palm Palm nuts and kernels, palm oil and its fractions, palm kernel and 
babassu oil and their fractions, oilcake and other solid residues of or 
palm nuts or kernels, palmitic acid, saturated acyclic monocarboxylic 
acids and derivatives, steric acid, oleic acid, industrial monocarboxylic 
fatty acids and industrial fatty alcohols.
Rubber Natural rubber, balata, gutta-percha, guayule, chicle and similar natural 
gum, compounded rubber, unvulcanised rubber, vulcanised rubber, 
conveyer or transmission belts or belting, pneumatic tyres, inner tubes, 
articles of apparel or clothing accessories, and hard rubber.
Soya Soya beans, soya bean flour and meal, soya bean oil and its fractions, 
oilcake and other solid residues.
Wood Fuel wood in any form, wood charcoal, wood in the rough, hoopwood, 
wood wool and flour, wood sawn or chipped, sheets for veneering, 
particle board, fibreboard, plywood, densified wood, wooden frames, 
packing cases (not including those used exclusively for packing 
material), tools, joinery and carpentry wood, table and kitchenware, 
printed books and newspapers, and seats.
N.B. As per Annex I of the EUDR legislation, under ‘Wood’ states ‘not including packing material used 
exclusively as packing material to support, protect or carry another product placed on the market’.
Appendix 2: Raw ‘In Scope’ Materials for Non-EU Exports
Commodity Primary In-Scope Materials Secondary In-Scope Materials
Coffee Coffee beans Coffee as an ingredient
Cocoa Cocoa butter; Cocoa powder; 
Cocoa liquor
Cocoa as an ingredient
Palm Oil Crude palm oil (CPO); Palm 
Kernel Oil (PKO); PFAD; fatty 
alcohols
Palm oil as an ingredient
Pulp and Paper Wood-fibre-derived paper and 
board packaging
Labels; tea bags
Soy Soybean oil; soy protein Soybean products that are not 
derived from soybean oil (e.g. 
lecithin); Embedded soy (soy in 
animal feeds)
Tea Leaf tea for leaf tea applications None
Timber Wood prepared for use Timber used for factory equipment 
such as pallets 
Sugar Cane sugar Sugar as an ingredient
Metals Steel, copper, lithium, tin, silver, 
gold, nickel, and aluminium etc.
Metals used in coffee machines, 
electronics, and factory equipment
Natural Rubber Natural rubber Rubber used in coffee machines 
and factory equipment
Cattle Leather None
2 EUDR Legislation: http://data.europa.eu/eli/reg/2023/1115/oj
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Appendix 3: Certification Regulations for Deforestation
Certification In-Scope Material Link to standard Benefit
Fairtrade Coffee, Cocoa Fairtrade Standard 
for Small-scale 
Producer 
Organisations
See requirements 
3.2.31 and 3.2.32.
“Fairtrade actively promotes 
both the protection of forests 
and the planting of trees. 
Fairtrade Standards prohibit the 
felling of forests with high 
conservation value and 
require farmer co-operatives to 
map risk areas, raise their 
members’ climate awareness 
and promote climate-friendly 
production methods.” 3
Rainforest Alliance Coffee, Cocoa Sustainable 
Agriculture Standard 
Farm Requirements
See requirements 
6.1, 6.2 and 6.4.
“…focused on natural climate 
solutions—which includes forest 
conservation, restoration, and 
improved land management 
practices—to increase carbon 
storage, avoid greenhouse gas 
emissions, and build resilience 
to changing weather patterns.” 4
Round Table on 
Sustainable Palm Oil 
(RSPO)
Palm Oil RSPO Principles and 
Criteria
See criteria 7.12.
“The RSPO Principles & Criteria 
consists of seven core 
principles, one of which is to 
“operate legally and respect 
rights.” Legality is a requirement 
for RSPO certified production, 
making RSPO Certification a 
viable tool for due diligence 
related to illegal deforestation” 5
Forest Stewardship 
Council (FSC)
Pulp and Paper The FSC National 
Forest Stewardship 
Standard of the UK
See Indicators 6.9.1, 
6.9.2 and 6.9.3.
“FSC does not allow for 
deforestation to take place in its 
certified concessions. It has 
several strict requirements in 
place that ensure that certifiedforest managers maintain their 
forest cover, and maintain or 
enhance their forest’s structure, 
function, biodiversity and 
productivity.” 6
Round Table on 
Responsible Soy 
(RTRS)
Soy RTRS Standard for 
Responsible Soy 
Production
See guidance 
principles 4.4 and 
4.5.
“RTRS offers a soy certification 
standard with zero deforestation 
and zero conversion explicitly 
stated in its criteria. This means 
that no conversion of any 
natural land, steep slopes and 
areas designated by law to 
serve the purpose of native 
conservation and/or cultural and 
social protection is allowed.” 7