Bonsucro Benchmarking Protocol Version 1.0 May 2017

Bonsucro Benchmarking Protocol Version 1.0 May 2017 Bonsucro s vision is a sugarcane sector with thriving, sustainable producer communities and resilient, assured supply chains. Our mission is to ensure that responsible sugarcane production creates lasting value for the people, communities, businesses, economies and ecosystems in all cane-growing origins. Bonsucro is a company registered in England and Wales, company number 06798568. E&OE: information correct at time of publishing May 2017 Bonsucro, 2017 Bonsucro Benchmarking Protocol Version 1.0 2

Table of Contents 1. INTRODUCTION... 4 2. BENCHMARKING IN THE BENCHMARKING & ENDORSEMENT PROGRAMME... 6 3. BENCHMARKING IMPROVEMENT SCHEMES... 9 4. TRANSPARENCY OF ASSURANCE... 17 5. COMMUNICATION AND CLAIMS... 18 6. ANNEX... 20 Bonsucro Benchmarking Protocol Version 1.0 3

1. INTRODUCTION In the sugarcane industry, a growing body of improvement schemes are designed to improve the sustainability and performance of sugarcane farms and mills around the world. Bonsucro, as the global sugarcane platform, recognises the work of these initiatives to promote sustainable sugarcane production through our new Benchmarking & Endorsement Programme. This programme provides mechanisms for global recognition and alignment through the Benchmarking Protocol (outlined in this document) and the Endorsement of Local Improvement Programmes. Ultimately, the aim of the Benchmarking & Endorsement Programme is to encourage learning and exchange between schemes and to promote investment into initiatives that promote thriving, resilient and responsible producer communities. 1.1 Benchmarking Protocol The Benchmarking Protocol defines the process of evaluating the level of alignment between the Bonsucro Production Standard and schemes, tools and/or standards (collectively referred to as Improvement Schemes in this Protocol) that improve and validate the performance of sugarcane producers. It can be used to benchmark the core documents, such as a standard or reporting tool, of an Improvement Scheme to determine alignment with the Bonsucro Production Standard and where relevant, provide clarity on the type of assurance model used. 1.2 Output of the Benchmarking Protocol Benchmarking is available to Improvement Schemes that take a holistic approach to sustainable sugarcane production as well those that have an issue-specific focus, such as social issues like labour practices or environmental issues relating to water use. Conducted as a desktop exercise by an independent consultant, benchmarking results in one of three levels of alignment within the identified scope of assessment: basic, advanced, and comprehensive. Once benchmarked, the owner of a benchmarked improvement scheme can claim that their scheme demonstrates basic/advanced/comprehensive alignment with the Bonsucro Production Standard. Bonsucro publishes the names of all Benchmarked Schemes on our website, along with the Benchmark Assessment Report for transparency. However, it is important to note the benchmarking process does not reflect the ability of an Improvement Scheme to guide and/or assure actual producer performance (this is part of the Endorsement Programme). Therefore, any assessment of alignment made through the benchmarking process does not imply claims for the product or replace the need for a third-party audit for Bonsucro Certification by a Bonsucro-accredited certification body. Bonsucro Benchmarking Protocol Version 1.0 4

1.3 Endorsement Protocol The second element of the Benchmarking & Endorsement Programme is the Endorsement Protocol, which outlines how an improvement scheme or programme can be endorsed by Bonsucro as a credible mechanism for change in the sugarcane sector. This is separate to the Benchmarking Protocol. It is focused on the endorsement of an improvement programme which takes a defined (local) group of producers through a deliberate process of improvement, using a benchmarked tool or the Bonsucro Calculator as a reference. 1.4 Benchmarking Protocol Contents This document outlines the process of benchmarking Improvement Schemes. An Improvement Scheme can be benchmarked to the Bonsucro Production Standard following the steps in Section 3 of this protocol. The evaluation and alignment process is further described in Section 3 & 4, with assurance mechanisms covered in Section 4. Allowable claims and communication relating to Benchmarking and the Assessment Report are set out in Section 5. Bonsucro Benchmarking Protocol Version 1.0 5

2. BENCHMARKING IN THE BENCHMARKING & ENDORSEMENT PROGRAMME 2.1 Purpose The Benchmarking Protocol is the cornerstone of Bonsucro s Benchmarking & Endorsement Programme (B&E Programme). The B&E Programme works with external stakeholders that are also driving adoption of sustainable production practices in the sugarcane sector to create a platform of learning and collaboration, instead of competition. The Benchmarking Protocol widens the scope of and application of the Bonsucro Production Standard from a standard for certification to a guide for Improvement Schemes to align with globally recognised best performance in sugarcane sustainability. This Protocol defines a process to evaluate the alignment of a core document (standard or reporting tool) of an Improvement Scheme to the Bonsucro Production Standard, and provide transparency in the assurance mechanism available for implementation. Bonsucro's Benchmarking & Endorsement Programme The Benchmarking & Endorsement Programme is one of Bonsucro s four new global programmes, with a focus on benchmarking and endorsement of local improvement programmes to the Bonsucro Production Standard. The programme provides a learning platform for local partners allied with Bonsucro s vision of a sugarcane sector with thriving, sustainable producer communities and resilient, assured supply chains. The B&E Programme recognises the vast variability in programmes designed to support sustainable sugarcane production. The FAO estimates that 26,522,734 hectares are used to produce sugarcane globally, making it one of the most significant global crops, and an important part of global sustainable agricultural production. Bonsucro, as the Global Sugarcane Platform, seeks to effectively engage with others promoting sustainability objectives in the sector by leveraging the Bonsucro Production Standard to be the common ground and reference points for improvement schemes. 2.1.1 About the Bonsucro Production Standard The Bonsucro Production Standard, used as the framework to conduct a benchmark, was initially developed in 2008 and later refined through a standard revision process involving public consultations, pilots, and engagement with industry experts. The Standard was designed to be technology agnostic and contains several indicators that can be achieved using locally adapted solutions. It has been proven for Bonsucro Benchmarking Protocol Version 1.0 6

application globally, with certification achieved in seven countries across three continents as of May 2017. 2.2 Development of the Benchmarking & Endorsement Programme The development of the Benchmarking Protocol occurred in several phases. The concept was launched in a working group at Bonsucro Week in 2015. In phase one, several Improvement Schemes were identified for benchmarking, followed by the execution of three pilots through 2016. Learnings from the pilots informed the initial draft of this protocol (phase two). Phase three consisted of public consultation on the draft Benchmarking Protocol during February and March of 2017, where 59 individual comments were received and addressed. The protocol was taken for a second, shorter round of consultation and published in May of 2017. 2.3 Referenced Publications The Bonsucro Production Standard (Including Bonsucro EU Production Standard) v4.2 Bonsucro Calculator v4.1.1 Bonsucro Claims and Labelling Policy 2.4 Definitions Assurance: Demonstrable evidence that specified requirements relating to a product, process, system, person or body are fulfilled (ISEAL Assurance Code as adapted from ISO 17000). Bonsucro Production Standard: The Bonsucro Production Standard is the standard developed and used to achieve Bonsucro Certification. It is comprised of principles, criteria, and indicators, which define metric requirements for sustainable sugarcane production. Core Document: Improvement Scheme s standard or reporting tool which includes requirements and/or recommendations for sustainable sugarcane production. Improvement Scheme: The combined offering of a standard, reporting tool, and/or assurance mechanism that provides recommendations/requirements as well as a progress capture mechanisms to define and standardise an approach to sustainable sugarcane. These are external Bonsucro. Improvement Scheme Owner: The entity that owns and/or manages the intellectual property of the Improvement Scheme. Local Improvement Programme: A programme that take a defined group of farmers and/or mills through a deliberate process of continuous improvement, using a benchmarked tool or the Bonsucro Calculator, based on a commitment to address critical issues, sharing progress and learning on the Bonsucro Platform. Producers: Users of schemes, tools and/or standards designed to improve and validate performance of sugarcane farmers and/or millers. Bonsucro Benchmarking Protocol Version 1.0 7

Reporting Tool: The mechanism used to capture data and/or information from a producer participating in Improvement Scheme. Stakeholder: Individual or group that has an interest in any decision or activity of an organisation (from ISO 26000). Bonsucro Benchmarking Protocol Version 1.0 8

3. BENCHMARKING IMPROVEMENT SCHEMES 3.1 What can be considered an Improvement Scheme? An Improvement Scheme is the combined offering of a standard, reporting tool, and/or assurance mechanism that provides recommendations or requirements and a progress capture mechanisms to define and standardise an approach to sustainable sugarcane. The Improvement Scheme owner is a partner external to Bonsucro that has developed at least one of these components, as shown in Figure 1. There are no restrictions on location of use or number of participants in the Improvement Scheme. An example of the application of these components is described in the text box below. Benchmark Assessment Pilot - Valore Figure 1: Components of an Improvement Scheme Bayer Crop Science (the Scheme Owner) developed an Improvement Scheme to support sustainability in the sugarcane sector, Valore. The Valore programme consists of two protocols - one for general agriculture practices and a second for sugarcane-specific practices. Producers are ranked in a star system depending on performance to requirements in the standard. The programme is currently active in Brazil, and has been succesfully implemented in several farms. Trained consultants use the input data sheet in the Bonsucro Calculator to collect data from farmers (reporting tool). Verification is provided by a third-party. The Valore Protocols have been benchmarked for comprehensive alignment with the Bonsucro Production Standard, and the claims are transparent in communicating the level of assurance. 3.2 What is the Improvement Scheme benchmarked against? The Improvement Scheme s core document is evaluated for alignment against the Bonsucro Production Standard. The Bonsucro Production Standard is comprised of principles, criteria, and indicators, which define metric requirements for sustainable sugarcane production. Sustainability requirements cover environmental, social, and economic indicators, and the standard applies globally. Bonsucro Benchmarking Protocol Version 1.0 9

The indicators in the Bonsucro Production Standard are further defined in two ways: (1) core/non-core and (2) relevant to farm and/or mill. Core indicators provide basic requirements and address the most important and foundational sustainability matters in the sugarcane sector. Non-core indicators represent a second tier of indicators, they have still been identified as important requirements. The second way the indicators are further defined is which process they are relevant to (farm and/or mill). The Improvement Scheme s core document, which includes the requirements/ recommendations to guide sustainable production, is benchmarked and graded for alignment to the Bonsucro Production Standard. To demonstrate and check the performance to metric requirements in the standard, Bonsucro has developed the Bonsucro Calculator- a reporting tool available for members of Bonsucro. If the improvement scheme provides a reporting tool in addition to a core documents, then this can be benchmarked to the Bonsucro Calculator. 3.3 Process of Assessing Alignment The steps to evaluating the Improvement Scheme s level of alignment with the Bonsucro Production Standard are summarised in Table 1. The following sections of this protocol provide the detailed process behind each step in the process for assessing alignment. Step 1 Initiation of Engagement 2 Agreement of terms with an MOU 3 4 Benchmark the Improvement Scheme's core document to in the indicators in the Bonsucro Production Standard - If applicable, evaluate the reporting tool of the Improvement Scheme against the Bonsucro Calculator Grade alignment of each indicator as full/partial/none within the given scope (Completed by third-party to Bonsucro and the Improvement Scheme owner) 5 Assess overall alignment of the Improvement Scheme s core document as comprehensive/advanced/basic 6 Review assurance system document(s) and determine type 7 Draft Benchmark Assessment Report is submitted for review to Scheme Owner. Feedback is reviewed and integrated where needed to finalise report. 8 Publish accurate claims and communication Table 1: Summary of Steps to Benchmark an Improvement Scheme Bonsucro Benchmarking Protocol Version 1.0 10

3.3.1 Initiation of Engagement in the Benchmarking & Endorsement Programme Bonsucro views the benchmarking process as an assessment done in partnership with the Improvement Scheme Owner, rather than a task done independently of the Improvement Scheme owner. Bonsucro will sign a memorandum of understanding (MOU) with the Improvement Scheme owner to outline the benchmarking process, timelines, and on communications development. The benchmark process will involve a third-party to provide the grading. This adds transparency and credibility to the process. To participate as an Improvement Scheme, the Scheme owner must be a member of Bonsucro and, in this case, Bonsucro will fund the work of third-party consultant. Alternatively, the Improvement Scheme owner can fund the work of thirdparty consultant at-cost. In both cases if they are not a member of Bonsucro. In this case, Bonsucro will manage the recruitment and oversight of the consultant and this will be agreed in the MOU. The MOU outlines the following: Defined Improvement Scheme Owner and membership status (or terms for engagement of third-party consultant). Agreement on project timeline and roles including designated contact point for Independent Expert & Bonsucro. Note: Scheme Owner is responsible for completing the benchmark assessment template (Annex 6.1). Agreement on scope of assessment (subject to be defined later if issuespecific). Agreement on terms and conditions of logo use, claims period and communication of claims including terms of use, period of validity, communications relating to assessment results (e.g. public announcements), and communications of updates when there have been changes in either party s system. Throughout the duration of the programme, agree to submit a report to Bonsucro on the use of the system annually at the request of Bonsucro (e.g. countries where the system is used, uptake by producers, etc.) and update Bonsucro with any substantial changes prior to implementation of those changes by the owner of the Improvement Scheme. Bonsucro will send the annual report template one month in advance. 3.3.2 Defining the Scope of Assessment The Bonsucro Production Standard is comprised of principles, criteria, and indicators, which define metric requirements for sustainable sugarcane production, which is used as the framework for benchmarking. The Improvement Scheme s core document is assessed against each indicator in the Bonsucro Production Standard. There are 53 indicators in the Standard that apply to the mill, farm, or both the mill and farm. The selection of applicable indicators from the Bonsucro Production Bonsucro Benchmarking Protocol Version 1.0 11

Standard depends on the scope of the Improvement Scheme being benchmarked: farm, mill, both the farm and mill or issue-specific as defined in Table 2. Scope of Improvement Scheme Scope to Assess Alignment to the Bonsucro Production Standard Farm If the Improvement Scheme is focused on agricultural operations, alignment will be assessed against 41 indicators out of the 53 indicators in the Bonsucro Production Standard. Mill Farm and Mill Issue-Specific (e.g. human rights, water management ) If the Improvement Scheme is focused on mill operations, alignment will be assessed against 43 indicators out of the 53 indicators in the Bonsucro Production Standard. If the Improvement Scheme is focused on both agricultural and mill operations, alignment will be assessed against all indicators in the Bonsucro Production Standard. In this case, the issue-specific Improvement Scheme and Bonsucro will evaluate the scope of topics addressed and applicable for assessment. It can be done at topic-level for example, an improvement scheme that is only focused on human and labour rights will be evaluated against the all applicable social and labour rights indicators in the Bonsucro Production Standard. Alternatively, the core indicators can be the defined scope. This will be defined in collaboration with the improvement scheme owner and be included in any communications on the results of the benchmarking. Table 2: Scope of evaluation for alignment with the Bonsucro Production Standard 3.3.3 Alignment on Indicator Level Once the scope of alignment is determined, the relevant indicators in the Bonsucro Production Standard are noted as applicable (or not) in the benchmarking template in Annex 6.1. Bonsucro aims at gaining consensus around the level of alignment by asking feedback from the Scheme Owner to ensure the alignment was determined effectively. The relevant recommendations/requirements within the Improvement Scheme s Core Document are mapped to the Bonsucro Production Standard, also using the relevant template in Annex 6.1. The level of alignment to each indicator within the identified scope is then graded using the criteria in Table 3. Bonsucro Benchmarking Protocol Version 1.0 12

The Bonsucro Production Standard is metric-based, therefore to achieve full alignment with the indicator, an equivalent requirement/recommendation in the Improvement Scheme s core document must include a measurement methodology and metric threshold that is aligned with the Bonsucro Production Standard if applicable. For example, where the indicator in the Bonsucro Production Standard is Overtime is paid at a premium rate or equally compensated (at least 25% premium rate), then a requirement in the Improvement Scheme indicating overtime be paid at a premium is considered aligned with this indicator in the Bonsucro Production Standard. For full alignment, the requirement must include a premium of at least 25%. If the indicator requires that a premium is paid, but does not specify at least 25%, the indicator is given partial alignment. For non-metric indicators, the assessment allows for some flexibility in the language and terms used to describe the indicator, as long as it achieves the objective of the indicator and includes. Non-metric indicators include, for example, legal compliance, management plans, and social sustainability indicators. Level of Alignment Full Partial None Description of Alignment Criteria to Indicators Evidence of full alignment where the objective of the indicator has been achieved. In the case where the Bonsucro Indicator has a metric requirement, there is an indication of measurement and metric threshold that meets or exceeds the threshold set. Evidence of partial alignment, where the indicator is not fully captured, and if metrics are applicable: there is evidence of measurement, but no metric threshold and/or the threshold is lower than Bonsucro requirement. No evidence of alignment in the standard. Table 3: Grading of Indicator Alignment with the Bonsucro Production Standard 3.3.4 Evaluating Scheme Alignment There are three levels of alignment that can be achieved by Improvement Schemes within the identified scope of assessment: basic, advanced, and comprehensive. An indicator is considered for the overall alignment only if it has full alignment with the indicator as defined in Table 3. Each level can be achieved if the minimum percentage of full alignment is met for both core indicators and overall indicators (core + non-core). The Bonsucro Bonsucro Benchmarking Protocol Version 1.0 13

Production Standard contains sixteen core indicators, these are the critical requirements that all producers must meet for Bonsucro Certification. The core indicators are a fundamental baseline for achieving sustainable production of sugarcane and are of the highest priority. For Bonsucro certification, the producer must be compliant with all core indicators, and 80% of indicators overall (core + noncore) to receive a certificate. The indicators are also defined as applicable for the mill, farm, or both as appropriate. The calculation to determine the overall percentage of alignment: Number of indicators with full alignment Total number of indicators in scope Level of Scheme alignment with all indicators [%] The calculation to determine the percentage of alignment with core indicators: Number of core indicators with full alignment Total number of core indicators in scope Level of Scheme alignment with core indicators [%] Once the percentage is determined based on the number of indicators where the Improvement Scheme s core document has achieved full alignment, the level of alignment can be assessed using Table 4. The percentage is given to core indicators and overall (core plus non-core). For example, if the Improvement Scheme is fully aligned with 15 out of 16 core indicators, the percentage of alignment is 93.7%. And if 30 out of 53 indicators are aligned with, the Improvement Scheme has achieved 56% of indicators overall. This would imply advanced alignment for the Improvement Scheme. To reach a level, the improvement scheme must meet the minimum percentage for both core and all farm/mill indicators. Level of Improvement Scheme Alignment Core Indicators All farm/mill indicators Improvement Scheme s Standard Alignment Basic >50% >50% Advanced >80% >50% Comprehensive 100% >80% X% core X% overall Table 4: Interpretation of Improvement Scheme Alignment Bonsucro Benchmarking Protocol Version 1.0 14

3.3.5 Reporting Tool Following the evaluation of the alignment with the production standard, if an Improvement Scheme is using an additional reporting tool for data collection, this can also be assessed for alignment with the Bonsucro Calculator. This will support future linkages of the tool to share and analyse aggregated data with Bonsucro. This can be an informative process for the improvement scheme owner, and is not considered part of the final grade of alignment. The Bonsucro Certification System s reporting tool for producer performance is the Bonsucro Calculator. This is how producers actively measure and report their level of conformity with the Bonsucro Production Standard. In addition to an assessment of the topics covered in an Improvement Scheme, which represents the intent of the system, this Protocol can also include the assessment of the tool used for the reporting against the improvement scheme. The assessment of the Improvement Scheme s reporting tool follows the same scope of the Bonsucro Production Standard that was applied to the Improvement Scheme s standard (for example, if the scope is only on social indicators, then only the data inputs in the calculator would be considered within the scope and inputs for greenhouse gas emissions calculations would not be assessed). The Bonsucro Calculator contains 256 data entry points, and this list is included in one of the worksheets in Annex 6.1. 3.3.6 Additionality Improvement Schemes have been designed independently of the Bonsucro Production Standard, and therefore are likely to bring additionality in the topics covered. This additionality is identified by gathering requirements in the Improvement Scheme that have no alignment with the Bonsucro Production Standard. The additionality is summarised in two categories: I. Prescriptive implementation of management system indicators these are requirements or indicators that are assessed and verified in practice during an audit for Bonsucro Certification but not explicitly referenced in the Bonsucro Production Standard. II. Issues/indicators that are Out of scope of the Bonsucro Production Standard and therefore not assessed during an audit for Bonsucro Certification. For example, indicator 1.1.1 in the Bonsucro Production Standard requires legal compliance with national laws but does not explicitly list all the laws that must be complied with because these vary by country/region of operation. However, where an Improvement Scheme s standard specifies these laws, this would be considered a prescriptive implementation requirement of indicator 1.1.1 and referenced under additionality category I. As another example, some Improvement Schemes include Bonsucro Benchmarking Protocol Version 1.0 15

food safety requirements within their standard, which would be referenced under category II as this is not included in the Bonsucro Production Standard. Additionality is not considered in the percentage of alignment because these represent additional scope compared to the Bonsucro Production Standard and the purpose of the benchmark is to assess alignment. They are, however, summarised in the Benchmark Assessment Report. Bonsucro Benchmarking Protocol Version 1.0 16

4. TRANSPARENCY OF ASSURANCE 4.1 Process for Defining Assurance Models Assurance systems provide a mechanism to test if requirements and/or recommendations are being followed in the field and are used to ensure integrity of claims. An assurance system is meant to provide demonstrable evidence that specified requirements relating to a product, process, system, person or body are fulfilled (ISEAL Assurance Code as adapted from ISO 17000). The Benchmarking Protocol provides transparency to the assurance system that is used by the Improvement Scheme, but does not carry out an assessment or judgement if the assurance model is credible or not. To be described in the in the allowable claim by Bonsucro, the assurance system needs to be documented by the Improvement Scheme Owner and relevant documents shared with Bonsucro. This section of the Protocol outlines how the Improvement Scheme s assurance system is evaluated, if applicable, and allowable claims from the assessment are written in section five of this Protocol.If an Improvement Scheme does not have an assurance model, it can still be benchmarked but the lack of assurance model will be mentioned in any communication on the programme. 4.2 Types of Assurance Models To ensure consistency in communication on assurance systems, the Improvement Scheme must provide a documented assurance process that outlines the type of assurance system used. Table 5 provides the types of assurance models recognised by Bonsucro and the interpretation of those assurance models for the purpose of this Benchmarking Protocol. Assurance Model Self-declared Self-assessed Peer reviewed Second-party verified Third-party certification Description Meet the standard, but do not provide evidence to support. Assesses their own performance and submits information to Improvement Scheme in support of claim. A similar entity (another producer) reviews compliance. Assessment carried out by a third party that is related to the producer or the Improvement Scheme Owner. Assessment carried out by a party that is independent, unrelated to the producer or the standard-setter being assessed. Company accredited for ISO 17065. Table 5: Type of Assurance Models Bonsucro Benchmarking Protocol Version 1.0 17

5. COMMUNICATION AND CLAIMS 5.1 Communications The outcome of benchmarking work described in Sections Three and Four of this protocol is summarised into a Benchmark Assessment Report. After approval by the Scheme Owner, the Benchmarking Assessment Report will be published on the Bonsucro Global Programmes Page of the Bonsucro website for the Bonsucro Benchmarking & Endorsement Programme. This will include the logo of the Improvement Scheme, and a link to the website of the Improvement Scheme. The Benchmark Assessment Report contains the following content: Benchmark Evaluation - Summary of assessment - Description of the specific gap from indicators that remain with no/partial alignment - Summary of additionality for both category I and II - Final level of alignment - Period of validity of the claim (all claims are valid for a period of three years unless there have been changes to either system) - List of documents and records reviewed - Annex of the detailed assessment at indicator level including which points in the improvement Scheme s standard provide additionality to Bonsucro - Name of assessor Description of Improvement Scheme - Scope of coverage (mill, mill and farm, specific topic) - Main purpose/objective of Improvement Scheme - Type of reporting tool/calculation method used - Type of assurance mechanism used (self, first, second, third party etc.) - Additionality to the Bonsucro Production Standard (clarity if category I or II) 5.2 Allowable Claims Bonsucro has established a set of allowable claims that can be used to communicate the outcome of the benchmark. As per the MOU signed at the initiation of the engagement in the Benchmarking & Endorsement Programme, Bonsucro works with the scheme to ensure accurate communication around these claims. The claim can follow the examples below or be re-phased with approved variations. Bonsucro must approve any public claim. Any further communication that is not already described in the MOU must be approved by both parties prior to release (Bonsucro and the Improvement Scheme Owner). Once an outcome has been reached on the evaluation and is defined in a Benchmark Assessment Report, where an agreed level of alignment has been Bonsucro Benchmarking Protocol Version 1.0 18

defined for the Improvement Scheme according to Table 1 (Scope of Assessment), Table 3 (Level of Alignment, and Table 4 (interpretation on assurance mechanism), then the following claims can be completed and used publicly. There are two types of allowable high-level claims that can be used to develop further communication: I. Benchmarked Tool or Standard The [Improvement Scheme] has been benchmarked by Bonsucro, the global sugarcane platform, and demonstrates [level of] alignment with the global Bonsucro Production Standard. II. Transparent Assurance [Improvement Scheme] operates a [self/peer/second/third party] assurance mechanism. The claim is focused on the standard, tool, scheme, or assurance system and is for off-product use only. The claim is not allowable on-pack or specifically on the product that has been produced in compliance with the Improvement Scheme. The claim shall include a further description which ensure there is no misinterpretation that this means equivalence to the Bonsucro Production Standard and/ Bonsucro Certification. 5.2 Claim Management Any claims or logo usage must adhere to the Bonsucro Claims and Labelling Policy. Use of the Bonsucro logo must follow the Bonsucro Claims and Labelling Policy, which can be downloaded from www.bonsucro.com. 5.3 Communication The Benchmarking Assessment Report will be published on the Bonsucro Global Programmes Page of the Bonsucro website for the Bonsucro Benchmarking & Endorsement Programme. This will include the logo of the Improvement Scheme, approved claim, and a link to the website of the improvement scheme. Any further communication that is not already listed in the MOU should be approved by both parties prior to release (Bonsucro and the Improvement Scheme Owner). The Improvement Scheme Owner can link to this page in the website and use the Bonsucro logo along with the reference. 5.4 Stakeholder Input and Escalation Policy The Benchmarking Protocol defines a process meant to maximize learning between the schemes, while ensuring credibility of the results. External stakeholders are welcome to input on the process or results. If stakeholders would like to input on the process of benchmarking, please contact info@bonsucro.com. Results of the benchmark will be published on the website, including contact information for both parties and can be used in case of any request for clarification on the benchmarking process. If a stakeholder would like to challenge the results of Bonsucro Benchmarking Protocol Version 1.0 19

the benchmark, a formal written and substantiated disagreement can be raised to Bonsucro, which the Bonsucro Secretariat will address. If the Bonsucro Secretariat is unable to resolve, the issue will be raised with the Technical Advisory Board and any decision shall be shared with the stakeholder. 6. ANNEX 6.1 Benchmarking Template Available in excel format for download here. - The Bonsucro Production Standard farm indicators can be found in the first sheet of the workbook. - The Bonsucro Production Standard mill indicators can be found in the third sheet of the workbook. - The Bonsucro Calculator Input Data Sheet can be found in the second sheet of the workbook. Bonsucro Benchmarking Protocol Version 1.0 20

Bonsucro Ltd. The Wenlock, 50-52 Wharf Road, London N1 7EU, UK t +44 (0)20 3735 8515 e info@bonsucro.com w bonsucro.com Company Number: 06798568