1. What is an Exclusion List?

An exclusion list, in general, is defined as a collection of entities that are intentionally excluded from standard procedures because they do not meet common categories or criteria.
In the context of sustainable finance, an exclusion list is not used to exempt companies from regulatory compliance. Rather, it plays an important role in identifying companies that are actively engaged in activities that contradict Environmental, Social, and Governance (ESG) principles, and are therefore deemed ineligible to receive capital support from financial institutions.

2. What is the purpose of creating an Exclusion List?

• To restrict funding or investment by financial institutions to corporations that pose potential negative impacts on ESG aspects.

• To encourage high-risk companies (e.g., those contributing to deforestation) to raise their ESG standards so they can meet investment criteria and gain access to funding.

• To ensure that the portfolios of financial institutions are aligned with sustainability values and principles.

• To protect the reputation of financial institutions from potential associations with illegal or harmful entities or activities.

3. Who are the users of the Exclusion List?

• Civil society, including government agencies.

4. How is the Exclusion List assessed?

Assessment uses a matrix developed based on methodologies derived from the TKBI guidelines for the AFOLU sector and the Indonesian Standard Industrial Classification (KBLI).

5. Must all criteria in the Exclusion List be met, and how is the assessment carried out?

Yes. All ESG aspects in the Exclusion List assessment must be met to qualify for the “green” classification as defined in the guideline.
If even one ESG aspect is not fully met, the company will be automatically categorized as “red.”

6. How is the Exclusion List assessed in terms of environmental, social, and governance (ESG) aspects?

Each ESG aspect has detailed, sector-specific criteria that must be fulfilled. See questions 9–12 below for specific criteria per aspect.

7. What reference is used for the criteria in the Exclusion List assessment?

The assessment methodology refers to the TKBI guideline for the AFOLU sector and the KBLI (Indonesian Business Field Classification).

8. Is the Exclusion List assessment conducted regularly?

Yes, the Exclusion List is reviewed periodically. If updated data becomes available, a “send report” field is provided to submit revised company information.

9. When is the Exclusion List assessment conducted?

The data and documents used in the exclusion list will be updated on a regular basis.

10. Where is the Exclusion List assessment carried out?

The assessment is conducted by internal evaluators using the assessment matrix to calculate the greenwash score of each company based on each indicator.

11. Is there a contact point for reporting complaints or updates?

Yes. You may get in touch with a contact person using the Contact Us form if you have any questions, complaints, and/or reports regarding specifics of the Exclusion List assessment.

Assessment Guidelines Using the Exclusion List Matrix for the Palm Oil Plantation Sector

12. What is meant by the criteria for compliance with basic prerequisites?

• Valid location permit

• Valid environmental permit

• Forest release permit

• Valid plantation business permit (IUP)

• Valid land use rights (HGU)

• Indonesian Sustainable Palm Oil (ISPO) certification

13. What is meant by the criteria for environmental, natural resources, and biodiversity management?

• Number of forest and land fires within the plantation area

• Existence of conservation zones within the plantation area

• New plantation development does not involve clearing natural forests or peatlands

• Plantation is not located within forest areas

• Waste (solid, liquid, and air) is properly managed

• Integrated Pest Management (IPM) or pest control guidelines are in place and implemented

14. What is meant by the criteria for social aspects?

• At least 20% of the plantation area under IUP is allocated to community-owned plantations

• Land disputes within the company’s area have been resolved by mutual agreement (if any exist)

• Occupational Health and Safety (OHS) documentation includes policies, procedures, and resources for emergency, disaster, and accident response

• A standard operating procedure (SOP) prohibiting child labor exists

• Minimum wage laws are applied

• Gender-sensitive and responsive policies are implemented

• Reports are available for Corporate Social and Environmental Responsibility (CSR) programs

15. What is meant by the criteria for sustainable plantation governance?

• HGU matches with official spatial and regional planning maps

• Physical maps and plantation size align with HGU documentation

• Plantation Business Assessment (PUP) results exist for either development or operational phases

• Policies and SOPs exist to ensure traceability of Fresh Fruit Bunches (FFB) sourced from outside the plantation (outgrowers)

• Supplier data is available for FFB supplied to the palm oil mill (PKS)

• The mill periodically informs FFB suppliers of current pricin