SGS RSPO Doc. Number: GP 7003A

(Principles & Criteria: Independent Doc. Version date: 01 April 2013 Smallholder) Page: 1 of 67

RSPO PRINCIPLES & CRITERIA CERTIFICATION REPORT

Public Summary Information

Project Number: MY03723

RSPO Membership No.: 1-0138-13-000-00 Client Name: WAGS- Beluran Sabah Website: www.wildasia.org

Date of Issue: 10 Sept 2014 Certificate Number: SGS-RSPO/SC-MY14/01552 Date of Expiry: 05 Sept 2018

SGS Accreditation Code RSPO-ACC-010 Date of accreditation: 24 May 2014 Scope: Production of FFB

Type of Certificate Independent Smallholder Group Certification Holder: Supply Chain Module Mass Balance Total Certified Area Number of Smallholder: 198 smallholders+3 outgrower 1,227. 318 ha (Ha): Annual PK Produced (MT): 675.19 Annual CPO Produced 3,004.12 (MT): Annual PKO 303.84 Produced (MT): Address: Plantation Address Post Address: Head Office Upper Penthouse, Wisma RKT, No 2 Jalan Raja Street and number: Upper Penthouse, Wisma RKT, No 2 Abdullah, Kuala Lumpur, Federal Territory 50300 Malaysia Town/City Jalan Raja Abdullah, Kuala Lumpur, Federal Territory 50300 Malaysia State/Country Zip/Postal code Contact Person: Country Sheila Senathirajah Tel: +603 6201 2150Fax: +603 6201 2150.

Email: [email protected]

Country: Malaysia Total FFB Produced 13,979.17 (MT):

End of Public Summary

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TABLE OF CONTENTS SUMMARY ...... 3 BASIC EVALUATION INFORMATION ...... 4 List of Abbreviation ...... 5 1. Scope of certification assessment ...... 6 1.1 National Interpretation/Standard Used ...... 6 1.2 Certification Scope ...... 6 1.3 Location and Maps ...... 6 1.4 Description of Independent Smallholder as FFB producer ...... 15 1.5 Date of Planting and Cycle ...... 16 1.6 Other Certification Held ...... 17 1.7 Organizational Information and Contact Person ...... 17 1.8 Area of Plantation ...... 18 1.9 Date Certificate Issued and Scope of Certificate ...... 18 2. Assessment Process ...... 18 2.1 Certification Body ...... 18 2.2 Assessment Methodology, Programme, Site Visits ...... 18 2.3 Qualification of Lead Assessor and Assessment Team...... 21 2.4 Stakeholder Consultation and List of Stakeholders Contacted ...... 21 3. Assessment Findings ...... 22 3.1 Group Certification ...... 22 3.2 Principles & Criteria ...... 35 3.3 Corrective Action Request ...... 53 3.4 Noteworthy Positive & Negative Observation ...... 53 3.5 Status of Non-Conformities Previously Identified ...... 53 3.6 Issues Raised by Stakeholders and Findings ...... 53 4. Acknowledgement of Organization Internal Responsibility ...... 54 4.1 Date of Next Surveillance Visit ...... 54 4.2 Acknowledgement of Internal Responsibility and Formal Sign-off Assessment Findings ...... 54 APPENDIX A: CORRECTIVE ACTION REQUEST & OBSERVATION ...... 55 APPENDIX B: NON-CONFORMITIES PREVIOUSLY IDENTIFIED ...... 60 APPENDIX C: LIST OF STAKEHOLDERS CONTACTED...... 61 APPENDIX D: NAME LIST OF FARMERS FROM WAGS BELURAN GROUP ...... 62

LIST OF TABLES Table 1: WAGS Beluran Sabah Independent Small Producer Supply Base GPS Location ...... 6 Table 2: Total Smallholder/small grower and Planted Area Ha ...... 15 Table 3: Actual FFB production for FY 2014 and projection FFB for FY2015 ...... 15 Table 4: Actual FFB production, CPO, PK and PKO for FY 2014 ...... 15 Table 5: Estimated FFB production, CPO, PK and PKO for FY 2015 ...... 16 Table 6: Planting Age Profiles for all Supply Base Estates ...... 16 GP 7003A Page 3 of 67

Table 7: Smallholder Sampling Formula for Audit ...... 19 Table 8: Assessment Program ...... 19 Table 9: Auditors Profile ...... 21

LIST OF FIGURES Figure 1: Location Map for WAGS Beluran, Sandakan, Sabah, Malaysia ...... 7 Figure 2: Location Map for Mill, Collection Centers & Farmers ...... 8 Figure 3: Location Map for Beluran Project (Overall) ...... 9 Figure 4: Location Map for Beluran Project (Toniting) ...... 10 Figure 5: Location Map for Beluran Project (Kiabau) ...... 11 Figure 6: Location Map for Beluran Project (Reka Halus) ...... 12 Figure 7: Location Map for Beluran Project (Sapi) ...... 13 Figure 8: Location Map for Beluran Project (Terusan) ...... 14

SUMMARY SGS has conducted ASA02 assessment of WAGS Beluran operation comprising group of Independent Smallholders Members, Group Management/Manager and FFB supply chain. WAGS Beluran has been established to manage an independent group of smallholders numbering 198 (73 certified members and additional 125 new members and another 3 additional new outgrower), with total 1,227.318 ha planted to oil palm. WAGS Beluran is located in Sabah, Malaysia. Sapi Mill is assisting WAGS Beluran to implement the RSPO P&C, with the aim of achieving RSPO Certification and will then purchase the smallholders FFB for processing in one of the Sapi oil mills.

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BASIC EVALUATION INFORMATION MAIN EVALUATION Evaluation Dates: By other CB Team Leader/Team: Affiliate Project Manager: Date: Report approved by: Date: Certification approved by: Date: Database logged by: Date: SURVEILLANCE 1 Evaluation Dates: 30 July & 4-6 Aug 2014 Team Leader/Team: James Ong/Hoo Boon Han/Shazaley Affiliate Project Manager: Date:

Report reviewed & approved by: Haye Semail Date: 10 Sept 14 Certification approved by: Kenny Looi Date: 10 Sept 14 Database logged by: Shahziela Othman Date: 10 Sept 14 SURVEILLANCE 2 Evaluation Dates: 17 August & 24-28 August 2015 Team Leader/Team: James Ong/William Siow/Hoo Boon Han Affiliate Project Manager: Date:

Report reviewed & approved by: Aryo Gustomo Date: 31 Dec 15

Certification approved by: Kenny Looi Date: 31 Dec 15

Database logged by: Othman Shahziela Date: 31 Dec 15

SURVEILLANCE 3 Evaluation Dates: Team Leader/Team: Affiliate Project Manager: Date:

Report reviewed & approved by: Date:

Certification approved by: Date:

Database logged by: Date:

SURVEILLANCE 4 Evaluation Dates: Team Leader/Team: Affiliate Project Manager: Date:

Report reviewed & approved by: Date:

Certification approved by: Date:

Database logged by: Date: GP 7003A Page 5 of 67

LIST OF ABBREVIATION

Short Form Meanings CAR Corrective Action Request CHRA Chemical Health Risk Assessment CPO Crude Palm Oil DID Department of Drainage and Irrigation, Malaysia DOE Department of Environment, Malaysia EFB Empty Fruit Bunch EIA Environment Impact Assessment EMS Environmental Management System EQA Environmental Quality Act ERT Endangered, Rare and Threatened species ESA Environmentally Sensitive Area FFA Free Fatty Acids FFB Fresh Fruit Bunches FR Forest Reserve Ha Hectare HCV High Conservation Value HDPE High Density Polyethylene IPM Integrated Pest Management ISO International Organisation for Standardisation IUCN International Union for Conservation of Nature and Natural Resources JCC Joint Consultative Committee JUPEM Jabatan Ukur dan Pemetaan Malaysia (Department of Survey and Mapping Malaysia) K Potassium kW Kilowatt M Meter Mg Magnesium Mm Millimeter Mt Metric ton MYNI Malaysia National Interpretation N Nitrogen NGO Non Governmental Organisation OA Orang Asli (Indigenous People) OER Oil Extraction Rate OSH Occupational Safety & Health P Phosphate P & C Principles and Criteria PK Palm Kernel POME Palm Oil Mill Effluent PPE Personal Protective Equipment PT Pejabat Tanah (Coding for Pahang Land Office) SOP Standard Operating Procedures Sdn Bhd Sendirian Berhad (Private Limited) SEIA Social and Environment Impact Assessment Sg Sungai SGS Societe Generale de Surveillance SOP Standard Operating Procedures SPC Senior Plantation Controller USECHH Use and Standards of Exposure of Chemicals Hazardous to Health WHO World Health Organisation Yr Year

SGS services are rendered in accordance with the applicable SGS General Conditions of Service accessible at http://www.sgs.com/en/Terms-and-Conditions.aspx

SGS Malaysia (RSPO Program) Unit 10-1, 10th Floor, Bangunan Malaysian RE. No. 17, Lorong Dungun, Damansara Height 50490 Kuala Lumpur, MALAYSIA. Systems and Services Certification Division Contact Programme Manager at t. +6 (03)5121 2320 www.sgs.my

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1. SCOPE OF CERTIFICATION ASSESSMENT

1.1 National Interpretation/Standard Used The operations of the mill and their supply based of FFB were assessed against the of Final Documents of RSPO Principles & Criteria for Malaysia (MY-NI) Indicators and Guidance as approved NI dated 26 April 2008 including smallholders NI Approved by the RSPO Executive Board on November 2010; RSPO Standard for Group Certification: Final Approved July 2010.

1.2 Certification Scope The scope of certification covers Wild Asia Group Scheme (WAGS) Beluran Group with total 201 farmers, with total 1227.318 ha planted to oil palm, registered as group member and group manager who comply with the group rules, requirements of the RSPO Standard for Group Certification and Sustainable palm oil production.

1.3 Location and Maps The Wild Asia Group Scheme (WAGS), WAGS- Beluran Sabah is located in Telupid Sub-District, Beluran, Sandakan, Sabah, Malaysia. The location of the group members are very close to the RSPO certified Sapi Palm Oil Mill. Figure 1 shows location of the farmers group and the nearest mill which purchase majority of the FFB produced by the group members.

WAGS Beluran has been established to manage an independent group of smallholders numbering 198, with total 1227.318 ha planted to oil palm. Total 198 smallholders distributed into 5 different districts which are:

Table 1: WAGS Beluran Sabah Independent Small Producer Supply Base GPS Location

WAGS Beluran Sabah Latitude Longitude

Kampung Toniting 5.75 N 117.36 E

Terusan 5.88 N 117.37 E

Kiabau 5.76 N 117.25 E

Rekahalus 5.77 N 117.46 E

Sapi (small grower) 5.73 N 117.39 E

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Figure 1: Location Map for WAGS Beluran, Sandakan, Sabah, Malaysia

SGS services are rendered in accordance with the applicable SGS General Conditions of Service accessible at http://www.sgs.com/en/Terms-and-Conditions.aspx

SGS Malaysia (RSPO Program) Unit 10-1, 10th Floor, Bangunan Malaysian RE. No. 17, Lorong Dungun, Damansara Height 50490 Kuala Lumpur, MALAYSIA. Systems and Services Certification Division Contact Programme Manager at t. +6 (03)5121 2320 www.sgs.my

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Figure 2: Location Map for Mill, Collection Centers & Farmers

SGS services are rendered in accordance with the applicable SGS General Conditions of Service accessible at http://www.sgs.com/en/Terms-and-Conditions.aspx

SGS Malaysia (RSPO Program) Unit 10-1, 10th Floor, Bangunan Malaysian RE. No. 17, Lorong Dungun, Damansara Height 50490 Kuala Lumpur, MALAYSIA. Systems and Services Certification Division Contact Programme Manager at t. +6 (03)5121 2320 www.sgs.my

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Figure 3: Location Map for Beluran Project (Overall)

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Figure 4: Location Map for Beluran Project (Toniting)

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Figure 5: Location Map for Beluran Project (Kiabau)

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Figure 6: Location Map for Beluran Project (Reka Halus)

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Figure 7: Location Map for Beluran Project (Sapi)

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Figure 8: Location Map for Beluran Project (Terusan) GP 7003A Page 15 of 67

1.4 Description of Independent Smallholder as FFB producer The FFB is sourced from plantation which is directly managed by WAGS Beluran. The smallholder group are categorize based on the district. In total 5 groups of smallholder with total 198 members. For PG1, PG2, PG4 and PG5 are smallholder <40 ha, while PG3 is the small grower >40ha (less than 500 ha). The OER rate is 21.49%. The budgeted crop yields from each estate are listed in Table 2 below. The smallholder numbers and estimated FFB, CPO & PK production for 2014 and 2015 are listed as below too:

Table 2: Total Smallholder/small grower and Planted Area Ha

Group Name Total Member Total (ha) Certifie 42 PG1 TON d 323.565 New 14 Certifie 30+1 PG2 TER d 393.923 New 42 Certifie 0 PG3 Sap SGR d 143.12 New 3 KIABAU Certifie 0 PG4 d 200.258 (SAPI) New 42 Certifie 0 PG5 Rekahalus d 166.452 New 27

Table 3: Actual FFB production for FY 2014 and projection FFB for FY2015

Estimated Total Actual FFB Planting FFB Name Planted Area Production Year Production Ha 2014 (Ton) 2015 (Ton)

323.565 4,404.58 4,624.81 PG1 TON 1980-2015 393.923 2,020.99 2,122.04 PG2 TER 1980-2015 PG3 Sap SGR 1995-2011 143.12 4,006.58 4,206.91

200.258 1,378.44 1,447.36 PG4 KIABAU 1990-2015 (SAPI) PG5 Rekahalus 1980-2015 166.452 1,502.90 1,578.05

Table 4: Actual FFB production, CPO, PK and PKO for FY 2014

Source (Farmer 2014 (Actual 2014 (Actual 2014 (Actual 2014 (Actual Subgroup) FFB) CPO) PK) PKO)

PG1 TON 4,404.58 946.54 212.74 95.73 PG2 TER 2,020.99 434.31 97.61 43.92

SGS services are rendered in accordance with the applicable SGS General Conditions of Service accessible at http://www.sgs.com/en/Terms-and-Conditions.aspx

SGS Malaysia (RSPO Program) Unit 10-1, 10th Floor, Bangunan Malaysian RE. No. 17, Lorong Dungun, Damansara Height 50490 Kuala Lumpur, MALAYSIA. Systems and Services Certification Division Contact Programme Manager at t. +6 (03)5121 2320 www.sgs.my

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PG3 Sap SGR 4,006.58 861.01 193.52 87.08 PG4 KIABAU (SAPI) 1,378.44 296.23 66.58 29.96 PG5 Rekahalus 1,578.05 339.12 76.22 34.30

Total 13,388.64 2,877.21 646.67 290.99

Table 5: Estimated FFB production, CPO, PK and PKO for FY 2015

2015 2015 2015 2015 Source (Farmer (Projected (Projected (Projected (Projected Subgroup) FFB) CPO) PK) PKO)

PG1 TON 4,624.81 993.87 223.38 100.52

PG2 TER 2,122.04 456.03 102.49 46.12 4,206.91 PG3 Sap SGR 904.06 203.19 91.44 PG4 KIABAU (SAPI) 1,447.36 311.04 69.91 31.46 PG5 Rekahalus 1,578.05 339.12 76.22 34.30

Total 13,979.17 3,004.12 675.19 303.84

* The extraction rate of OER for CPO, KER for PK, KOER for PKO are to be based on MPOB statistic as: http://bepi.mpob.gov.my/index.php/statistics/oil-extraction-rate/140-oil-extraction-rate-2015.html

1.5 Date of Planting and Cycle The WAGS Beluran own estates were planted between 1980 and 2015. The palms were considered matured when approaching four years after planting and productive until the age of 25 years. The age profiles for all the estates are simplified in Table 6 below. Table 6: Planting Age Profiles for all Supply Base Estates

Area planted with OP (Ha) Total area Immature Young Mature Mature planted with

0-3 Years 4-7 Years >7 years Oil Palm PG1 79.218 18.73 225.617 323.565 TON PG2 48.357 23.249 322.317 393.923 TER PG3 Sap 0 30.00 113.12 143.120 SGR PG4 39.365 52.802 108.091 200.258 KIABAU PG5 64.815 21.311 80.326 166.452 REKA Total 231.755 146.092 849.471 1,227.318 GP 7003A Page 17 of 67

1.6 Other Certification Held No other certification held.

1.7 Organizational Information and Contact Person The company contact person and the group organization chart details are as follows:

Name: Sheila Senathirajah

Designation: Group Manager Upper Penthouse, Wisma RKT, No 2 Address: Jalan Raja Abdullah, Kuala Lumpur, Federal Territory 50300 Malaysia Contact No.: +603 6201 2150

Email address: [email protected]

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1.8 Area of Plantation The areas of supplying estates for this operating unit are listed in Table 6. Details of production area (mature/immature) are also listed.

1.9 Date Certificate Issued and Scope of Certificate The certificate issue date is the date of RSPO approval of this assessment report. This certification scope is the independent group of smallholders numbering 198, with 3 independent outgrowers.

2. ASSESSMENT PROCESS 2.1 Certification Body SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 80,000 employees, SGS operates a network of over 1,650 offices and laboratories around the world. The RSPO Programme is the SGS Group’s RSPO Certification Programme internationally accredited by ASI to carry out oil palm plantation and supply chain certification/verification and accreditation for global RSPO certification.

2.2 Assessment Methodology, Programme, Site Visits The assessment was conducted in 17 August 2015 and 24-28 August 2015 for the central office and onsite audit involving 24 members of WAGS Beluran respectively. Additional 125 new members join the WAGS if compare to the surveillance 1 which has only 72 members. The audit covers documentation review, internal procedures, management system, field inspection as well as identification of any significant issues for both environment or social issues. A sample of stakeholders was consulted during the assessment to get their feedback on the management doing. The assessment was conducted based on sample in which regulated under RSPO Certification Requirement for Group Certification (2010). Under the requirement, size of samples was based on formula (0.8/y) x (z); where y is total number of independent group member and where z is the multiplier defined by the risk assessment. For the purpose of sampling audit, risk assessment of the group member and group manager was carried out prior to the certification assessment through the documentation. The risk assessment will based on factors i.e. geographically as well as socioeconomically, there are current replanting activities (very small scale due to the size of smallholder), there are new members, the group is well established. SGS audit team concluded that the risk is medium 1.2 (for existing certified) and 1.4 (for new members) as this is the surveillance assessment 2. During the site assessment, the sample size of WAGS shall be determined by the formula based on the risk 1.2 for certified smallholder and 1.4 for new smallholder. The assessment involved field visits to a sample of twenty-four (24) smallholders’ oil palm blocks (15 from newly joined members and 9 from existing members, no repetition from the previous audit sample) interviews of smallholders and WAGS’ staff and review of documents.

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Table 7: Smallholder Sampling Formula for Audit

Risk Factor: Minimum Smallholder Category Total 1.2 Moderate Audit sample 1.4 High Risk

Certified Smallholders 72+1 0.8 √ 73 x 1.2 9 (<40 ha)

New Smallholders 125 0.8 √ 125 x 1.4 13 (<40ha)

New Small Growers 3 0.8 √ 3 x 1.2 2 (<500ha)

Total 24

The methodology for objective evidence collection included physical site inspection, observation of tasks and processes, interview with workers, families and stakeholders, documentation review and monitoring data. The assessment program is included as shown in Table 5 below.

Table 8: Assessment Program

Day Auditor Morning Afternoon / pm

Monday James Ong 0830-1200: Opening 17th Aug meeting; Group manager William (ICS Audit) and related documents, ICS

Day 0 / Sunday James Ong rd Arrival to Sandakan 23 Aug William (KL-Sandakan) HBH

Day 1 / Monday James Ong th 9-11am: Opening 12.30 – 1.30 Drive to 24 Aug William meeting @ WAGS Kuala Sapi (Reka Halus) Beluran office HBH 1.30-5pm: Farm visit 11-12.30pm: Review member folders & key • 1. Joliu Paping New management documents (Reka Halus) • 2. Felix Ambari New (Reka Halus) GP 7003A Page 20 of 67

• 3. Leslie Laintie @ Into Samsudin New (Reka Halus)

Day 2 / Tuesday James Ong th 8 – 9 am Drive to Kiabau 2-5pm: Farm visit 25 Aug William (Kiabau) 9-12.30pm: Farm visit • 4. Wilson Jhary HBH (Kiabau) • 1. Hillary Vencent 2.30 – 3 pm Drive to Kolong New Sapi (Kiabau) • 2. Kanit Mediris New • 1. Asmaran Jiwa (Kiabau) (Sapi) • 3. Laban Idol New • 2. Samsudin Otoh (Kiabau) (Sapi) Day 3 / Wednesday James Ong th 8.30 – 9am Drive to 2 - 5pm: Farm visit 26 Aug William Terusan (Terusan) • 1. Kandoh Nor HBH 9-1 pm: Farm visit (Terusan) • 2. Maudi Jauri • 1. Maital Bangkit (Terusan) New (Terusan) • 3. Veronica Ajim • 2. Mansoon (Terusan) (Terusan) • 4. Malais Juroh • 3. Roslan Ahmad (Terusan) (Terusan) • 4. Anchi Tapal (Terusan) Day 4 / Thursday James Ong th 9-1 pm: Farm visit 2-5pm: Farm visit 27 Aug William (Small-grower) (Sapi) • 1. Elvis Sarigoh HBH (Sapi) • 1. Jimoi Ambong (Sapi) • 2. Linella Pallai (Sapi) • 2. Jera Hasil S/B lot 2 (Sapi) • 3. Sarigoh (Sapi) • 4. Lantina Ganai (Sapi) • 5. Rinah Pokah (Sapi) Day 5 / Friday James Ong 2.30-4.30pm: 9-12.30pm: 28th Aug William Documentation Review Travel Back to KL (Sapi-Sandakan) and wrap up; closing HBH meeting@ WAGS Beluran office

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2.3 Qualification of Lead Assessor and Assessment Team SGS Malaysia Sdn Bhd holds copies of educational qualifications, certificates and audit logs for each of the audit team members. SGS has evaluated the qualifications and experience of each audit team member and has registered the following designations for conducting RSPO Assessment. Summary of auditors’ educational background and experience are listed in Table 6 below. Table 9: Auditors Profile

Evaluation Team Notes

Team Leader – James S H Ong, a Bachelor of Agriculture Science holder and Agricultural best agronomist in SGS (M) Sdn Bhd. He has many years working practices experience in agriculture sector in Malaysia and has been working in estates as well in the agrochemical and fertilizer industry. He is well versed with agrochemical and fertilizer applications. Has undergone ISO 14001 and RSPO Lead Auditor training and involved in a number of audits on oil palm plantations. Auditor 1 – William Siow, a graduate in Bachelor of Science, is a Trainee Lead Plantation Auditor for Roundtable on Sustainable Palm Oil (RSPO). He has successfully completed RSPO Lead Auditor training, ISO 14001 Lead Auditor training, RSPO endorsed HCV training, Certified Mediator and etc. He had more than 6 years of experiences in plantation sustainability certification schemes. Experienced in auditing on environmental, social, GAP, GMP, OHSAS and Supply Chain implementation in palm oil industries. Auditor 2 – Hoo Boon Han is the SGS SEAP Program Coordinator, Bio Fuels Environment and Sustainability. He has successfully completed the RSPO Lead auditor Supply Chain training course for both P& C as well as the Supply Chain. He experienced in environmental monitoring & audit, carbon accounting & reduction, wastewater treatment, waste management and sustainable development experience across Southeast Asia.

2.4 Stakeholder Consultation and List of Stakeholders Contacted A wide range of stakeholders were contacted 4 weeks before the planned evaluation to inform them of the evaluation and ask for their views on relevant palm oil sustainability issues. These included environmental interest groups, local government agencies and forestry authorities, social groups and workers’ unions etc. Stakeholder consultation took place in the form of meetings and interviews. Meetings with village head, government agencies and NGOs were held in their respective premises within and near the WAGS Beluran smallholder estates. In all the interviews and meetings the purpose of the audit was clarified at the outset followed by an evaluation of the relationship between the stakeholder and the company before discussions proceeded in accordance with relevant RSPO principles, criteria and indicators. Issues discussed were related land ownership, environmental and social performance, legal and agricultural issues. No negative comments or complaints received as the size of independent smallholder is a very small. Further details please refer to 3.6. GP 7003A Page 22 of 67

3. ASSESSMENT FINDINGS 3.1 Group Certification

Requirement 1: Group requirements. Producers can form or join a group for group certification. The organization and its member shall demonstrate their ability to meet the RSPO Standard for Group Certification and the relevant RSPO Standard for Sustainable Palm Oil Production.

Criterion 1.1: Group Elements The group shall be managed by a central administration (i.e. The Group Manager), 1.1.1 which is responsible for ensuring the group’s compliance with the applicable standards and manages the Group Management Documentation. Findings In compliance: Yes: X No: Objective The Wild Asia Group Scheme (WAGS) intends to provide a platform for providing support to evidence: small independent oil palm producers. WAGS ICS is the management system which promotes traceability, encourages best practices and allows groups of producers to meet International Certification standards like RSPO. The WAGS_Beluran Group is managed by a central administration managed by the Group Manager, Sheila Senathirajah.

She is able to demonstrate its capacity for managing group certification and performance assessment against the RSPO Standard for Group Certification. The group manager job scope stated in the TOR WAGS GROUP Scheme Manager version 1 dated 30 July 2014.

Organization chart for the WAGS Beluran is made available during the central office audit . Ref: SAI Power point presentation pages 13 -19 . The committee include: a) Group Scheme Manager: Sheila Senathirajah. b) Asst Manager: Ms Lim Ying Ying c) Technical Officer : Kai Xiang d) Project Manager Sabah : Burhanuddin Ismail ( Dean ) e) , Project Coordinators: Danial f) Field Assistant Coordinators ( FAC ) g) WAGS Agronomist – Mohd Iqbal The group manager ensures that the group meet the requirements of RSPO standard for Group Certification.

1.1.2 The group shall consist of group members who have formally joined the group.

Findings In compliance: Yes: X No: Objective When a smallholder would like to join as group member they will need to undergo the following evidence: level of risk assessment. For example, a) Level 1 : ensure that they are an independent producer, b) Level 2 : for legal rights, no disputes on land etc. c) Level 3 : Production , Plantings compliance to WAGS requirement Guidelines on accepting a producer into the WAGS group scheme are available in Wild Asia Group Scheme Guidelines on WAGS Membership dated 22 July 2014. Baseline interviews and farm audits will need to be completed prior to membership sign up including application form, pre-inspection and checking on appropriate documents of farmers and internal approval.

Inspection one of the new contract (Document ISC 009 ref: PG4 Kiabau 35 ) of Hilary b Vencent Kolong dated 24 July 2015 has stated Registration of each member shall be agreed during panel committee of internal approval. Once accepted to join the group, the members sign an agreement with the group manager to

SGS services are rendered in accordance with the applicable SGS General Conditions of Service accessible at http://www.sgs.com/en/Terms-and-Conditions.aspx

SGS Malaysia (RSPO Program) Unit 10-1, 10th Floor, Bangunan Malaysian RE. No. 17, Lorong Dungun, Damansara Height 50490 Kuala Lumpur, MALAYSIA. Systems and Services Certification Division Contact Programme Manager at t. +6 (03)5121 2320 www.sgs.my

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follow the group rules/codes of conduct and meet the WAGS or RSPO requirement for group certification. In this audit WAGS_Beluran, intends to expand their producer group. Previously the farmers were from 2 producer group . PG No. of farmers PG1TON 42 PG3 TER 30

In this audit the following is the producer grouping. These are smallholder ( < 40 ha )

Group PG1 PG4 PG3 PG5 Number

PG Name TON (SAPI) KIABAU TERUSAN REKAHALUS (SAPI)

Established Sept 2012 Feb 2015 April 2014 Feb 2015

Receiving Mill Wilmar Sapi Wilmar Sapi Wilmar Wilmar Mill Mill Terusan Mill Rekahalus Mill

Members 56 42 73 27

Certified 42 0 30+1 0

New 14 42 42 27

In addition they have a producer group ( < 500 ha )

Group Number PG3

PG Name SAPI SGR

Established July 2014

Receiving Mill Wilmar Sapi/ Terusan Mill

Members 3

Certified 3

New 0

The Group Management Documentation shall include the documenting and monitoring of all the individual group members for membership status, production 1.1.3 process, and other relevant aspects to ensure compliance with the relevant RSPO Standard for Sustainable Oil Palm Production and the RSPO Group Certification Requirements.

Findings In compliance: Yes: X No: Objective The Internal Control System (ICS) dated 25 April 2014 has been developed for Producer Groups evidence: and its members.

Group manager established a system to check membership status, production process, and GP 7003A Page 24 of 67

RSPO requirements of principles and criteria for each farmer member. Checklist consists of Land information and status, planting year, palm seedling information, commitment to comply with RSPO requirements, and checklist of compliance with RSPO P&C. The Group manager has the document : Excel : WAGS-002 PG Farm and Buyer Registration _BEL_230714 to monitor their individual group members for membership status, production process, and other relevant aspects to ensure compliance with the relevant RSPO Standard for Sustainable Oil Palm Production and the RSPO Group Certification Requirements. WAGS Internal Control System Document WAGS Code of Conduct WAGS Organizational Chart WAGS Guidelines

The Group Manager shall specify in the Group Management Documentation the 1.1.4 maximum number of members that can be supported by the management system and the human resource and technical capacities of the Group Manager. Findings In compliance: Yes: X No: Objective In the Excel Document reference : WAGS Sabah Beluran Supply and Targets 30032015, the evidence: Group Manager specified in the Group Management Documentation that the maximum number of members that can be supported by the management system and the human resource and technical capacities of the Group Manager is about 863 farmers having an area of about 18,787 ha . Criterion 1.2: Compliance with standards All group members that are formal members of the group seeking RSPO 1.2.1 certification under group certification shall comply with the required relevant RSPO Standard for Sustainable Oil Palm Production. Findings In compliance: Yes: X No: Objective All group members that are formal members of the group seeking RSPO certification under group evidence: certification shall comply with the required relevant RSPO Standard for Sustainable Oil Palm Production. Under the Group scheme, every member will abide to the WAGS Code of Conduct which include elements relating to RSPO Standard for Sustainable Oil Palm Production. The elements are: a) Basic conditions : e.g. comply to legal regulation b) Commitment to Sustainable Agriculture c) Commitment to Good Management practices Formal members would have undergone training relating to RSPO Group Certification systems. They are also internally assessed annually and monitored so that the formal farmers maintain and comply with the required relevant RSPO Standard for Sustainable Oil Palm Production. Group managers may run a programme to support prospective members in achieving compliance with RSPO requirements. Where such a programme is in place, there must be robust mechanisms in place to ensure that neither the 1.2.2 prospective members nor the Group Manager makes any claim suggesting they are RSPO certified. Once the prospective member is in compliance with the RSPO standard they shall be formally included as a member of the certified group. Until RSPO compliance is achieved, the FFB production from prospective member sites will not count towards the total certified production of the group. Findings In compliance: Yes: X No: Objective Prospective members would go through a WAGS Producer Risk Assessment _v.1. evidence: This is to ensure that all WAGS members are able to meet the WAGS Code of Conduct prior to membership as well to identify producers that will require for further investigation. This programme will provide a) a degree of assurance that all WAGS members are pre-screened before eligibility and b) high risk producers are identified early in the process GP 7003A Page 25 of 67

Evaluation through initial internal assessment will be conducted by group manager before accepting into the group. Formal members of the Group shall sign an agreement with the Group Manager committing to achieving compliance with the relevant RSPO standard for 1.2.3 sustainable oil palm production. The Group Manager and each member shall keep copies of the agreement.

Findings In compliance: Yes: X No: Objective A copy of the agreement is kept at the group manager office, WAGS Beluran and a set of copy is evidence: distributed to each group members. Internal assessment is carried out to ensure that group members adhere to the internal requirement on group objective and policies. During onsite audit, agreement was made available for all the sampled group members. For example, agreement for member (Document ISC 009 ref: PG4 Kiabau 35 ) of Hilary b Vencent Kolong dated 24 July 2015 was verified. All the individual group members shall adhere to and show evidence that the 1.2.4 internal requirements, as set out in the systems, programmes or policies adopted by the Group Manager are met. Findings In compliance: Yes: X No: Objective Group Manager ensures that group members continuously committed to improve their compliance evidence: with relevant RSPO requirements by adhering to group rules and system All the individual group members shall adhere to and show evidence that the internal requirements, as set out in the systems, programmes or policies adopted by the Group Manager are met. When the farmer signs the agreement, it stipulates that the famer shall abide to the ‘Kod Amalan WAGS (Code of Conduct WAGS) as well as the ‘Peraturan Keahlian Kumpulan ‘ . They will also participate in WAGS annual internal assessment as well as the trainings planned by the Group Manager. Intensive training to all applicable and relevant procedures toward all RSPO principle and criteria requirements conducted regularly for all group members. Records of the training attended by the farmers are kept in the Farmer’s Record File. 1.2.5 The group manager shall comply with the requirements of the RSPO Standard for Group Certification. Findings In compliance: Yes: X No: Objective The Group Manager responsible for running the internal control system (ICS) and managing the evidence: WAGS Group will comply with the requirement s of RSPO Standard for Group Certification Criteria 1.3. In the Group Manager TOR ( Terms of Reference ) , it is also stated in 3.3.3 : the Group Manager shall be able to demonstrate knowledge of the requirement of Oil palm Production , the RSPO Standard for Sustainable Oil Palm Production , the RSPO Standard for Group Certification and internal WAGS group procedure and policies The Group manager , Ms Sheila has also the following qualifications: a) successfully completion of the RSPO lead auditor course b) has undergone ISO 18001 c) has conducted at least 5 palm oil sustainability related assessment d) able to converse in local language e) fully understands the WAGS Code of Conduct f) Internal auditor There shall be evidence to show that formal group members, individually and 1.2.6 collectively, continually strive to maintain their compliance with the relevant RSPO Standard for Sustainable Oil Palm Production. Findings In compliance: Yes: X No: Objective Please refer to : 1.2.1 evidence: GP 7003A Page 26 of 67

Annually, internal assessment is conducted. WAGS will refer to the document: G13 WAGS Guideline on Internal Audit. Internal audit assessment conducted with corrective action carried out clearly stated for verification purposes. Criterion 1.3: Group Manager The Group Manager of the Group shall demonstrate its capacity for managing group certification and performance assessment against the RSPO Standard for Group Certification.

1.3.1 The Group Manager shall be either a legal entity or an individual acting as a legal entity. Findings In compliance: Yes: X No: Objective The Group Manager, Ms Shiela Senathirajah is employed under Wild Asia, the legal entity which evidence: is a registered Malaysian company (Reg. No: 634446-W). The WAGS programme which Ms Sheila is the Group manager, is managed independently under Wild Asia. The WAGS programme has their own financial and resource planning under WildAsia. If the Group Manager is not an individual, there shall be a description of the general 1.3.2 structure of the Group Manager detailing the positions and responsibilities of all personnel clearly identified. Findings In compliance: Yes: X No: Objective See indicator 1.3.1 and also refer to the organizational chart. evidence: The Group Manager and/or their personnel shall be able to communicate in a 1.3.3 language understood by all group members (in both spoken and written form).

Findings In compliance: Yes: X No: Objective Please refer to 1.2.5. evidence: The group manager Sheila is a Malaysian which can communicate well in local language-Bahasa. Additionally , the Group Manager will ensure that the WAGS personnel appointed for the responsibility are a) Competent and are technically trained b) Able to communicate in a language understood by the group members /farmers c) Completed an RSPO –endorsed lead auditor Course The Field Programme Coordinator of the Beluran Group, Mr Burhanuddin Ismail was promoted to be the Project manager Sabah. He is a local Malaysian Sabahan who has an engineering and teaching career before he was employed by WildAsia to implement the WAGS group Scheme in Sabah. He is able to communicate well with his team members as well as at farm level with the farmers At present, the new Field Coordinator is Mr Danial Adha. He has a degree in Sociology and Anthropology. Besides the above, WAGS has also included in their team, Mr Chin Kai Xiang, as the Technical Programme Officer . He is responsible for the implementation of Group compliance. The Group Manager and/or their personnel shall be able to demonstrate knowledge 1.3.4 of the requirements of oil palm production, the RSPO Standard for Sustainable Oil Palm Production, the RSPO Standard for Group Certification, and internal group procedures and policies. Findings In compliance: Yes: X No: Objective The Group Manager and ICS personnel are able to demonstrate knowledge of the requirements evidence: of RSPO Standard for Sustainable Oil Palm Production, RSPO Standard for Group Certification, and internal group procedures and policies as stated in the sustainability manual. Please refer to 1.2.5 for details. All WAGS staff in HQ has undergone the RSPO accredited WildAsia Lead Auditor Course. GP 7003A Page 27 of 67

The Group Manager and/or their personnel shall not have any conflict of interest 1.3.5 likely to affect their capacity to meet the requirements for Group Managers and shall be able to provide evidence of this. Findings In compliance: Yes: X No: Objective The Group Manager, Ms Sheila, do not have any conflict of interest likely to affect their capacity to evidence: meet the requirements for Group Managers. Furthermore she does not have any personal relationship with any of the farmers in Beluran Group. In the TOR of the Group Manager, it is clearly spelt out in clause 3.4 that the Group Manager and/or their personnel shall not have any conflict of interest. The Group Manager shall demonstrate sufficient resources – i.e. human, financial, 1.3.6 physical and other relevant resources – to enable effective and impartial technical and administrative management of Group Certification. Findings In compliance: Yes: X No: Objective In the WMS 04 Planning Schedule & Resource Requirement, the Group Manager has planned the evidence: resource requirement for each project sites. The planning includes: a) Project sites b) Activities c) Baseline interviews d) No. of visits e) Personnel required ( Technical officers, Field Programme Coordinator, Assistant Field programme Coordinator and Field assistants) This Planning is projected for 2012 – 2017. For finance, they have the Budget – Income / Expenditure for each project site to track the financial activity for the project sites. They have also included the budget projection for the period 2013- 2015. They have included the new producer groups into the budget

The Group Manager shall have the capacity to control, monitor and evaluate all 1.3.7 members pertaining to their compliance to the RSPO requirements including communicating with them and visiting them at the required frequencies. Findings In compliance: Yes: X No: Objective It is also noted during the audit, with interaction and interview with Group Manager, audit team evidence: convinced the appointed group manager is mentally and physically capable. The WAGS field team is led by the WAGS Programme Manager Sabah , Field Programme Coordinator ( FPC) who has excellent administrative skills, local language and knowledge of project area. He would have undergone a WAGS induction programme at the WAGS HQ (conducted by the WAGS Technical Officers) and based on the site to ensure the producer always comply to the RSPO requirements. Key relevant document ( i.e contracts, farmers details etc ) will be scanned and a copy kept at the central server to be viewed by the GSM ( Group Scheme Manager ) The TOR WAGS FPC mentioned in 3.2.4 Monthly progress Report; it states that the FPC will update it on the 5th of the every month. All the records are made available during the ICS audit. The Group Manager shall have a documented system which sets out its mission 1.3.8 and objectives, policies and procedures for operational management and decision making in order to demonstrate ability to manage the group in a systematic and effective manner. Findings In compliance: Yes: X No: Objective In the WAGS ICS_v9_16042014, the Mission of WAGS is stated on Section 4.3 and the evidence: Objectives of WAGS is stated in Section 5.3. Policies and Procedures are also in the same document for operational management and decision making in order to demonstrate ability to manage the group in a systematic and effective manner.

1.3.9 There shall be clear policies and procedures for communication between the GP 7003A Page 28 of 67

Group Manager and group members.

Findings In compliance: Yes: X No: Objective The GSM will refer to the G08 WAGS Guideline on Public Documentation and CCG procedures. evidence: For communication to the Group members, WAGS has erected a ‘Producer Group Public Board ‘ at each project site . At each producer group site, there will be a Public Board erected at community halls. The information displayed includes; a. Producer Group Committee Organizational Chart; b. Minutes of meeting from last PGC meeting c. Grievance Procedure; d. Contact information of key persons; e. WAGS Code of Conduct; f. WAGS Sanctions Process; g. Producer Group status on membership; h. Producer Group progress statistics; i. News and updates such as training dates, farm visits, events etc; j. Simplified RSPO Principles & Criteria; k. Posters on Best Management Practices; l. Posters on training. m. List of relevant legal laws applicable n. Commonly used list of chemicals (banned and restricted to be highlighted The group manager shall ensure all formal and prospective members understand the relevant RSPO Standards. This may include the development of a strategic plan on how group certification shall be achieved for prospective members, and the 1.3.10 identification, definition and/or provision of training needs and/or communication strategies relevant to the implementation of the applicable RSPO Standard for Sustainable Oil Palm Production and the RSPO Standard for Group Certification. This can be provided directly by the Group Manager, an externally run training course or other means of provision of training or expertise. Findings In compliance: Yes: X No: Objective The Group Manager shall ensure all formal and prospective members understand the relevant evidence: RSPO Standards as they have a compulsory training known as ‘ T02 : Guidance for Farm Management of Sustainable Palm Oil that includes the following topics: • Code of Conduct (Review of the 12 requirements including legal compliance)-(T06) • WAGS Membership Requirement & Member responsibilities (T06) • Relevance of RSPO & Sustainable PO (T01) • Legal compliances • Importance of documentation (T03) • Soil fertility-Importance (T05) • Soil erosion-(steep , new, re-plantings)-Impacts & solutions (T05) • Water quality & availability-usage, Irrigation, impacts & solutions (T05) • Integrated Pest Management (IPM)- Types & functions (T05) They also have ‘WAGS ANNUAL PROGRAMME FOR PRODUCER GROUP’ that the GSM plans for the farmers. This are divided into 3 phases namely : a) Baseline & Scoping b) Training & audit Technical support Group Formation and Certification GP 7003A Page 29 of 67

The Group Manager shall ensure that if any group marketing system is developed and managed for the group, this is mutually fair and transparent to enable the securing of raw materials or trading of the group members‟ collective produce, or 1.3.11 setting-up of an equivalent arrangement. The group marketing system shall include; rules for purchasing and selling within the group, rules for claims of RSPO certified, dissemination of markets, and price information and related logistics (i.e. transportation to mill etc). Findings In compliance: Yes: X No: Objective WAGS_Beluran has a new guideline known as GXX_Traceability and Sales evidence: Guidelines_v.1_4042014 During the period Sept 2013 – Dec 2014, sales were done through Greenpalm . Since Jan 2014 , WAGS_Beluran has started the Mass Balance sales to Wilmar The Group Manager shall ensure that the total of all sales and claims of RSPO 1.3.12 certified FFB production from group members does not exceed the total certified FFB production of the group in its entirety. Findings In compliance: Yes: X No: Objective In the guideline G02 WAGS Guidelines for Farm Management _ver. 1, in Section 5 on Chain of evidence: Custody, it is mentioned that under 5.6, the GSM shall ensure that the total of all sales and claims of RSPO certified FFB production from group members does not exceed the total certified FFB production of the group in its entirety (recorded in WAGS 014). This will be done via a quarterly review of the PG documentation and is carried out by the GSM. The GSM will also ensure the FPC maintains regular updates and checks of the farmer information recorded (pertaining to the above information). The GSM will monitor the Production sheet WAGS 014 PG Farm Register and the Certificate Sales Tracking sheet , WFS_02_WAGS Master Income and Expenses Tracking _v.1 to ensure that the group members does not exceed the total certified FFB production of the group in its entirety.

Criterion 2.1: Group Management Documentation structure and content The Group Manager shall have its operational structure, policies and procedures, and basic information on individual group members documented. The system verifies whether operations within the group comply with the RSPO Standard for Group Certification Requirement and the relevant RSPO Standard for Sustainable Oil Palm Production. The Group Manager shall have an operating structure that defines group 2.1.1 management documentation (i.e. internal control systems), decision-making and responsibilities within the group. Findings In compliance: Yes: X No:

Objective The GSM has the WAGS ICS_v9_16042014 as well as the the WAGS Guidelines that will show evidence: an operating structure that defines group management documentation (i.e. internal control systems), decision-making and responsibilities within the group.

WAGS has the documented set of procedures and processes that a group implements to achieve its specified requirements. This also includes the Internal Control System (ICS). 2.1.2 All group records shall be retained for at least 5 years.

Findings In compliance: Yes: X No: Objective In the G02 WAGS Guidelines for Farm Management under 7.1.1 Documentation and Record evidence: Keeping it is mentioned that all group records will be kept for at least 5 years The Group Manager shall have documented membership requirements for the participation of individual members in the group. This shall include: 2.1.3 2.1.3.1 Requirements and procedures for joining the group. 2.1.3.2 Requirements and procedures for leaving the group. 2.1.3.3 Procedures for incorporating a remedial system for member non compliance. 2.1.3.4 Procedures for expulsion from the group. Findings In compliance: Yes: X No: GP 7003A Page 30 of 67

Objective With reference to the Guideline WAGS Guideline on WAGS membership_v1 it has topics on : evidence: a) Benefits of being a member b) Membership procedure for new members : c) WAGS contract d) Membership Sanction e) Dismissal Transition. There shall be a group-level operation manual that includes the following: 2.1.4.1 Internal assessment protocols. 2.1.4.2 Policies and procedures for accepting / removing members. 2.1.4.3 Policies and procedures for applying corrective action requests (CARs) to group members for non-compliance with the relevant RSPO standards. 2.1.4.4 Procedures for communicating corrective action requests (CARs). 2.1.4 2.1.4.5 Clear description of the process to fulfill any correction action requests (CARs) issued internally by the Group Manager or by the certification body including timelines and the implications if any of the CARs are not complied with. 2.1.4.6 Policies and procedures for handling complaints, appeals, corrective action requests (CARs), and group member performance assessment. 2.1.4.7 Policies and procedures for group monitoring, including carrying out and updating group risk assessment and annual surveillance of group members. Findings In compliance: Yes: X No:

Objective a) For Internal Assessment protocols the group will be guided by Guideline G13 : Guidelines evidence: for conducting internal audits of producer groups to ensure compliance to WAGS Code of Conduct b) For Policies and procedures for accepting / removing members the Group will refer to the Guideline WAGS Guideline on WAGS membership_v1 as in 2.1.3 c) For Policies and procedures for applying corrective action requests (CARs) to group members for non-compliance with the relevant RSPO standards , the Group will be guided by the Guideline G14 WAGS Guidelines on Corrective Action Request ( CAR) _v1 d) For Procedures for communicating corrective action requests (CARs), the Group will be guided by the Guideline G14 WAGS Guidelines on Corrective Action Request ( CAR) _v1 e) For Clear description of the process to fulfill any correction action requests (CARs) issued internally by the Group Manager or by the certification body including timelines and the implications if any of the CARs are not complied with, the the Group will be guided by the Guideline G14 WAGS Guidelines on Corrective Action Request ( CAR) _v1 f) For Policies and procedures for handling complaints, appeals, corrective action requests (CARs), and group member performance assessment, the Group will be guided by the guideline G08 WAGS Guidelines on Public Documentation and CCG ( communication, complaints and Grievance Procedure ) procedure For Policies and procedures for group monitoring, including carrying out and updating group risk assessment and annual surveillance of group members, the Group is guided by GXX Producer Risk Assessment _v1_21072014 and the G13 WAGS on Internal audit_v1: Guidelines for conducting internal audits of producer groups to ensure compliance to WAGS Code of Conduct. The Group Manager shall develop and maintain a database of group members included within the Group Scheme. This includes the information below as a minimum for each member: 2.1.5.1 A copy of each group member’s application form to the group with relevant information for each member that is updated regularly, i.e. name of producer, address, contact details, type of land ownership, size of plantation area, location, etc. 2.1.5 2.1.5.2 Total annual production and production per unit area (hectare) for previous years, from at least one year prior to joining the group, and the estimated production for the current year. 2.1.5.3 Results from the last internal and external assessments showing performance levels to the relevant RSPO Standard for Sustainable Oil Palm Production, including dates these were carried out, any plans for implemented improvement and corrective action requests (CARs) raised and closed out for each GP 7003A Page 31 of 67

group member. 2.1.5.4 The date of group membership acceptance and date of departure or expulsion from the group if relevant. 2.1.5.5 Maps of the plantation area for each group member. This can be in the form of individual maps or a collective map covering all group members. Findings In compliance: Yes: X No: Objective The Group Manager has developed and maintains a database of group members included within evidence: the Group Scheme. For the Beluran Group , the information can be extracted from the Excel database sheet document WAGS-002 PG Farm and Buyer registration _TON_06082015 as well as in WAGS-014 PG Farm Register_TON_07082015 It includes ; a) Name of producer, address, contact details, type of land ownership, size of plantation area, location, etc. b) Total annual production and p roduction per unit area (hectare) for previous years, from at least one year prior to joining the group, and the estimated production for the current year c) Results from the last internal and external assessments showing performance levels to the relevant RSPO Standard for Sustainable Oil Palm Production, including dates these were carried out, any plans for implemented improvement and corrective action requests (CARs) raised and closed out for each group member d) The date of group membership acceptance and date of departure or expulsion from the group if relevant. Maps of the collective map covering all group members are available in the file : P151 WAGS- Beluran PG maps Latest updated map for smallholders P151 Supply chain with supplier and sellers. All the smallholders are plotted in the map PG4 Kiabau smallholders. For the individual maps of the farm, this is available with the farmers. A summary of all the data on land use (in hectares) shall be kept and regularly updated covering the entire group that includes at least the following: 2.1.6.1 Total overall land area for each group member. 2.1.6.2 Total oil palm planted area for each group member. 2.1.6 2.1.6.3 Total RSPO certified production area for each group member. 2.1.6.4 Other crop production areas (i.e. non oil palm) for each group member if any. 2.1.6.5 Total undeveloped area or areas set aside for any particular reason (i.e. conservation, customary, identified HCV etc) for each group member, if any. 2.1.6.6 Total area with infrastructure for each group member, if any. Findings In compliance: Yes: X No: Objective WAGS has done an investigation and found that some of the land has hectarage mentioned in evidence: their land title, however the new additional joining 30 farmers have the document known as PT (Permohonan Tanah) with no known hectarage and only few of them have land title. These ‘PTs’ are provided by the land district office based in Kinabatangan, Sabah and they are legal. New farmers joining 125 smallholders and 3 small growers. Land title documents have been verified on site during audit from 24th to 28th August 2015. WAGS would also refer to the MPOB license as a reference to find out the hectarage of the farmer. For the Beluran Group , the information can be extracted from the Excel database sheet document WAGS-002 PG Farm and Buyer Registration _BEL_25072014 as well as in WAGS-014 PG Farm Register_BEL_250714

Summary sheet WAGS-002 PG Farm and Buyer Registration_TON_06082015, Elvis Sarigoh (MPOB license no: 28114210100) has been verified on site

It includes: a) Total overall land area for each group member. For Beluran due to the land hectarage issue , MPOB licence information is referred GP 7003A Page 32 of 67

b) Total oil palm planted area for each group member ( by interview with the farmer ) c) Total RSPO certified production area for each group member ( yet to be certified ) d) Other crop production areas (i.e. non oil palm) for each group member if any. ( Interview with farmers as well as field sighting ) e) Total undeveloped area or areas set aside for any particular reason (i.e. conservation, customary, identified HCV etc) for each group member, if any. Total area with infrastructure for each group member, if any. Criterion 2.2: Internal assessment system

Prospective members intending to join the group to be included under group certification shall only be allowed to become formal members of the group after an initial compliance assessment for entry by the Group Manager. This initial 2.2.1 assessment will determine that all group members who formally join the group with the intention of being included under group certification, are able fulfill the group membership requirements and are able to meet the relevant RSPO Standard for Sustainable Oil Palm Production.

Findings In compliance: Yes: X No: Objective Group manager has established procedure (Wild Asia Group Scheme Smallholder Internal Audit evidence: Guidelines dated 29 May 2013) for member registration. Prior to becoming a group member, all potential farmers in a producer group will be required to complete a Baseline Assessment comprising a Baseline Interview (WAGS-001) and a Farm Baseline Audit (WAGS-016) to check on his respective farm(s). This will ensure that the basic requirements of the group scheme are met and group members are able to fulfil the group membership requirements to meet the relevant standards as specified in WAGS Code of Conduct for Sustainable Oil Palm Production. Once farmer has been confirmed as a member, the Group Manager will implement a regular and on-going internal audit programme for all current group members. The internal audit is scheduled as listed in WMS-04_WAGS ANNUAL PROGRAMME FOR PRODUCER GROUPS. Latest assessment report of the Internal Audit Report (ref: WAGS03 dated 24th August 2015 under P151/P165 documents) was verified and the report recorded the check against production records, membership validity, training, farm checks and etc. The Group Manager shall implement a regular and ongoing internal assessment programme for all current group members that includes at least the following: 2.2.2.1 Internal assessments shall be documented and these documents maintained for 5 years. 2.2.2.2 Regular (at least annual) internal assessment visits to a sample of group members to confirm continued compliance with all the requirements of the relevant RSPO Standard for Sustainable Oil Palm Production and RSPO Standard for Group Certification. All members shall be monitored at least once during the period of validity of the group certificate (normally 5 years). 2.2.2.3 The Group Manager shall identify the relevant RSPO Standard for Sustainable Oil Palm Production that is appropriate for each group member. It is the performance against this standard that is assessed at each internal assessment. 2.2.2.4 The sample size for internal assessments shall be based on a risk assessment of the group members, where a higher risk requires a higher sample 2.2.2 size. 2.2.2.3 The Group Manager shall identify the relevant RSPO Standard for Sustainable Oil Palm Production that is appropriate for each group member. It is the performance against this standard that is assessed at each internal assessment. 2.2.2.4 The sample size for internal assessments shall be based on a risk assessment of the group members, where a higher risk requires a higher sample size. 2.2.2.5 The sample size shall be determined by the formula (0.8/y) x (z), where z is the multiplier defined by the risk assessment. Low risk = multiplier of 1, medium risk = multiplier of 1.2, high risk = multiplier of 1.4 (see Table 1). 2.2.2.6 The group shall use a minimum sample to be visited annually for internal assessment of (0.8/y), where y is the number of group members, and where selection of group members is based on random selection techniques. 2.2.2.7 The Group Manager shall ensure that different group members are visited in each annual internal assessment to those that have been selected for assessment by the certification body, unless there are circumstances which require GP 7003A Page 33 of 67

a revisit of the same members (e.g. pending corrective action requests (CARs), complaints received from stakeholders, risk factors etc). 2.2.2.8 Additional internal assessments shall be scheduled when potential problems arise or when the Group Manager receives information from stakeholders about alleged non-conformities of the relevant RSPO Standard for Sustainable Oil Palm Production by group members. Findings In compliance: Yes: X No: Objective According to Wild Asia Group Scheme Smallholder Internal Audit Guidelines dated 29 May 2013, evidence: clause 2.1 stated that 1 Internal assessment shall be documented and these documents maintained for 5 years. Program for regular internal assessment has been developed and first internal assessment as per program has been conducted. The internal assessment training/audit conducted from 12th to 15th August 2015. The assessment report was finalized and out on 24th August 2015. Verification by audit team has been conducted during the field assessment audit. Risk factor, sample size, methodology and result evaluation has been determined and recorded. This was confirmed in line with Group Certification Standard and internal procedure. The result of internal assessment recorded include some common issues on farmers understanding on proper storage facilities and etc. Corrective action against such findings also clearly stated in the internal assessment report. 2.2.3 Non-conformities identified by the Group Manager shall be resolved internally according to a documented system of applying corrective action requests (CARs). Findings In compliance: Yes: X No: Objective Corrective action list is available on the results of periodic internal audits and certification audit to evidence: identify non compliance and evidence of corrective action thereupon. Program for regular internal assessment has been developed and first internal assessment as per program has been conducted. See indicator 2.2.2. Minor non compliances raised close through action plan. Refer to the provided action taken and the plan.

Criterion 3: Chain of Custody (Supply Chain Module: Mass Balance) The Group Manager shall have a system in place to enable the trading of RSPO certified Fresh Fruit Bunches (FFB) produced from the group. The group manager shall document and implement a system for the tracking and 3.1 tracing of FFB produced by the group members, and intended to be sold as RSPO certified FFB. Findings In compliance: Yes: X No:

Objective WAGS document and implement a system for the tracking and tracing of FFB produced by the evidence: group members, and intended to be sold as RSPO certified FFB. The system managed by the GSM with assistance of FPC on the field. The whole procedures stated in the WAGS Internal Control System.

For each Producer Group the following information will be maintained and documented in WAGS- 014 Farm Register by the FPC(Field programme Coordinator): a) Total monthly FFB production (individual member); obtained from WAGS-012 Farmer Logbook b) Total monthly FFB sales summary: monitored via FFB sales summary obtained from mill or collection center.

The Group Manager and ICS staff monitors and register the sales of FFB from the group members to the palm oil mill. The group manager receives the FFB sales summary from the group member as well as from the palm oil mill with the member number indicated in the related documents such as: a) FFB sales slip or receipt (to all FFB buyers); containing info as listed in example below b) Information on FFB buyer. c) Volume sales d) WAGS id no

GP 7003A Page 34 of 67

Monthly FFB production monitoring summary also through WAGS 014 PG Farm register. This facilitates is traceable by the Group Manager and to ensure that the total sales volume and claimed are from the certified group members. The Chain of Custody of the Independent Smallholder Group members stops at the palm oil mill and collection point. The palm oil mill takes over the chain of custody from the Independent Smallholders. There shall be a collective group procedure for the sale of all certified FFB originating from the plantations of group members that is agreed by the group members and the Group Manager and is designed to ensure that non-certified FFB 3.2 are not sold as RSPO certified FFB. This shall be contained in any group marketing system that is developed for the group, and shall follow one of the supply chain models as per the RSPO Supply Chain Certification Systems, i.e. Identity Preserved, Segregation or Mass Balance. Findings In compliance: Yes: X No: Objective WAGS Beluran decide to sustain the module: mass balance as declared during the surveillance evidence: audit 1 as previously as they sell all certified RSPO product via Mass Balance for period of time from January to July 2015. Meanwhile, FFBs sold from September to December 2014 via Green Palm system. WAGS has a procedures: Traceability of FFB title A.2.6.1 to ensure that FFB from a WAGS producer can be traced from farm to first collection point. WAGS Identification is a unique number and individual cards cannot be duplicated. WAGS will keep track of each card issue number and in cases where a replacement card is required, the old card will be cancelled and a new card issued. WAGS is a group scheme, as such, the produce will be recognizable to the Group. Once a member is formally included in WAGS a membership card will be issued.

The group manager shall ensure that all invoices for sales of RSPO certified FFB 3.3 originating from the group are issued with the required information as per the adopted supply chain model requirements within Annex 6 of the RSPO Supply Chain Certification Systems document – November 2009. Findings In compliance: Yes: X No:

Objective During the surveillance audit, only sales via Green Palm system from September to December evidence: 2014 and via Mass Balance from January to July 2015. Sales invoice from Green Palm to WAGS indicated with buyer details and total certificates sold (ref: Payment Request Notification for Palm Kernek sold, No: PI00012765 dated 17 December 2014); In the document Disbursement of Green Palm Sales between the buyer (Cono Kaasmaker) with farmer and WAGS, recorded details such as WAGS ID, name of the group member, date and quantity. Mass Balance verified through Summary report from the mill (E.g Sapi CPO Mass Balance Report June 2015.) Contents include: Total FFB received from each of the individual farmers, (E.g. Lantina Ganai delivered FFB to mills on 8th June 2015, 3.09 mt, 9th June 2015, 3.78mt , 20th June, 2.81mt to Sapi Mill as per recorded). Through the summary report from the Sapi mill and field verification on weighbridge tickets, customer grouping report and payment advice. E.g. Luin Damsik delivered FFBs to Terusan Mill on May 2015: 13th May2mt, 14th 1.18mt, 26th : 1.53mt, 27th : 1.54mt. Verification of the related documents such as weighbridge tickets, FFB selling receipts and etc. had been conducted on site during audit assessment.

The physical transporting of RSPO certified FFB originating from the plantations of 3.4 group members shall be done either directly by the group (i.e. through own transportation), or via sub-contracted intermediaries. For intermediaries the requirements as outlined in 3.7 shall also apply. Findings In compliance: Yes: X No: Objective Smallholders Group is sending their FFB by own transportation (sub-contractor FFB transporter) evidence: to the mill or to the dealers directly. It is common for the independent smallholder that they do not have any written agreement between the transporter or the dealer. For transporter will base on the verbal agreement Every time payment made to transporters, payment voucher will be issued as evidence of monitoring. Meanwhile Wild Asia also keep track with the transporter involved in the documents named as WAGS 014 PG Farm register. GP 7003A Page 35 of 67

All sales of FFB originating from the plantations of group members shall be documented. This shall include: 3.5.1 Invoices and receipts (purchase and sale). 3.5 3.5.2 Information on transport. 3.5.3 The relevant group members‟ group identification number. 3.5.4 Description of the product sold (i.e. RSPO certified or not), product volume and destination. Findings In compliance: Yes: X No: Objective The invoices and receipts keep by the farmer on field. During onsite audit, one of the weighbridge evidence: advice tickets was verified (ticket no: 275097; date: 03-08-2014). All the details required details stated in the relevant weighbridge ticket. Verification on site on the weighbridge and others traceability records documents for Lantina and Luin were verified during the field visit. Documents WAGS PG14 Farm Register recorded all the details such as the WAGS ID, information on transport (third party, own or others transport). It also recorded the product sold, volume and destination. 3.6 The Group Manager shall maintain copies of all relevant documentation and records of group product transactions for a period of 5 years. Findings In compliance: Yes: X No: Objective WAGS Group Manager maintain copies of all relevant documentation and records of group evidence: product transactions of Green Palm System for a period of 5 years as stated in WAGS Internal Control System (ICS) version 9 dated 30 July 2014 with regards to Document Control. During onsite audit, one of the Group Certificate Sales Tracking dated 18 Jan 2014 was verified up to year 2014. (WFS02 WAGS Master Income and expenses tracking updated from time to time. During verification date on17th August 2015. Certificate sales: E.g Certicate no: SPO 598121: CPO volume 640 mt via Green Palms on 5th November 2013 Off market deal PKE volume 79 mt sold via Green Palm on 18th December 2014. If an intermediary exists in the supply chain from the group to the mill that wants to be included within the group certification control rather than obtain their own supply chain certification, the intermediary shall be identified by the Group Manager. The Group Manager shall have a contract with the intermediary to fulfill the RSPO Standard for Group Certification and agree to be assessed on an annual basis by the Group Manager as well as in certification assessments. It is the responsibility of 3.7 the Group Manager to ensure that the intermediary shall comply with the following Minor conditions: 3.7.1 There shall be a contract between the intermediary and the Group Manager. 3.7.2 The intermediary shall have complete purchasing and selling records. 3.7.3 The intermediary shall have RSPO supply chain systems in place to separate certified from non-certified materials through any of the RSPO supply chain options (i.e. Identity Preserved, Segregation or Mass Balance).

Findings In compliance: Yes: X No: Objective There is no intermediary exists as the WAGS- Beluran decided to switch their module to mass evidence: balance. All the farmers will send their FFB directly to the mill.

3.2 Principles & Criteria As outlined, objective evidence was obtained separately for each of the RSPO Indicators and criterion for the mills and estates. The results for each indicator from each of the operational areas were evaluated to provide an assessment of conformity. A statement is provided for each of the RSPO indicators in order to support the findings of the assessment team. There is 0 Major Non-conformities and 1 Minor Non-conformities identified during this assessment. Some areas identified with potential areas for improvement has leaded into 7 Observations raised. Details for each Non-conformities and observations are given in Appendix C. Major Non-conformities has been closed out within the period of 60 days after the assessment. Minor Non-compliances and GP 7003A Page 36 of 67

Observations will be followed up during the next Annual Surveillance Audit which is scheduled to be conducted within the period of twelve months after the RSPO approval of Main Assessment.

Principle 1: Commitment to Transparency Criterion 1.1: Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate language & forms to allow for effective participation in decision making. Independent Group managers must provide documents showing compliance with Section 2.1 of Smallholder the RSPO Standard for Group Certification as well as a continuous improvement plan (8.1). Group managers must ensure that each participant smallholder is provided a copy of the agreements between them and group (criterion 1.2) and up- to-date records of sales and prices of their produce (6.10). Group managers should also provide all group members with simplified training materials in a language understood by the group members on:  IPM and safe use of agro-chemical use (4.6)  Health and safety plan (4.7).  Plans and impact assessments relating to environmental and social impacts (5.1, 6.1, 7.1, 7.3).  Pollution prevention plans (5.6).  Details of complaints and grievance procedures (6.3).  Procedures for pricing and grading members FFB (6.10) Official versions are kept centralized at group manager level for reference and all group members are made aware of this. Training shall be identified and provided where appropriate in relation to these documents (see 4.8).

Findings In compliance: Yes: X No: GP 7003A Page 37 of 67

Objective Wild Asia Group Smallholder (WAGS) did ensure that all 198 participants’ smallholders are evidence: provided with a copy of the agreement between them and the group. The agreement is maintain in WAGS009 folder. The contracts contain details as below: a. Details of the smallholder b. Commitment of WAGS c. Code of conduct Samples of the Perjanjian di antara Pengeluar dan WAGS; Doc. No.: WAGS-ICS-009-Ver. 2 (contract) reviewed are as below: No. Smallholder’s Name Member’s ID Area (Ha) Location Date Signed 1. Wilson Jhary KIA-420-SML 6.07 ha Kiabau 25 Jul 2015 TER-377- 2. Maital bin Bangkit 6.09 /1.781 ha Terusan 27 Feb 2015 SML REK-463- 6.12/ 1.356/ 3. Leslie Laintie Rekahalus 3 Aug 2015 SML 1.456 ha TON-361- 4. Samsudin Bin Otoh 3.48 ha Toniting 23 Jul 2015 SML SAP-260- 5. Jeral Hasil Sdn Bhd 26.22 ha Toniting 25 Apr 2015 SGR An up to date records of sales and prices of the FFB produced are maintained by all the smallholders in their individual folders. The records will be updated 3 monthly. Examples of FFB sold by the smallholders and the prices reviewed are as below: No. Smallholder’s Name Month Yield (MT) Price/MT (RM) 1. Wilson Jhary June 2015 14.12 423.22 2. Samsudin Bin Otoh June 2015 3.14 423.22

WAGS have provided the participating members with simplified training material in the language understood by the smallholders and available in the member’s personal folders. There are total 11 training modules which required during the certification period. Example of training material available are as below: a. WAGS Panduan Pengurusan Kebun Kelapa Sawit Mampan (Compulsory Training) b. WAGS Kesihatan dan Keselamatan Ketika Menggunakan Racun (Chemical Handling) c. Pengurusan Alam Sekitar untuk Pekebun Kecil (IPM) d. Kod Perlaksanaan dan Syarat Keahlian An annual training plan has been established and will be conducted to all participating members. The training materials were made available in WAGS office. Evidence of training conducted such as attendance sheet and training material for all members are as below: Training Titles Date Conducted Participants Introduction to Wild Asia & RSPO 20 February 2015 67 Best agricultural practices 04 May 2015 13 Documentation for WAGS 04 May 2015 13 In respective WAGS member file, it kept records of attended training with the stated date and training title. Criterion 1.2: Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes Independent Group managers must also have shared and explained the relevant RSPO Smallholder standard for Sustainable Oil Palm Production as set out in this document or in an approved national interpretation to group members. Group smallholders have agreements with the group managers.

Findings In compliance: Yes: X No: GP 7003A Page 38 of 67

Objective WAGS have conducted awareness training for all new members including to explain relevant evidence: RSPO standard for Sustainable Oil Palm Production and approved national interpretation (MY-NI). The awareness was delivered during compulsory training. The compulsory training including Pengenalan Kepada Wild Asia & RSPO. As below: Training Titles Date Conducted Participants Introduction to Wild Asia & RSPO 20 February 2015 67 In total 198 agreements between WAGS and the smallholders are well maintained at the site office and each famer has a copy with them. Besides, during the onsite visit also confirmed that notice board stated RSPO requirements stated in respective village’s hall. Principle 2: Compliance with Applicable Laws and Regulation Criterion 2.1: There is compliance with all applicable local, national and ratified international laws and regulations. Independent Group managers must hold an up-to-date list of applicable laws, which is known to Smallholder be available for reference by group members, through periodic assessments, group managers must ensure smallholders can show evidence of compliance with all relevant legal requirements including the acquisition or holding of lands. Group smallholders should be aware of and understand the intent of applicable laws and regulations. More detailed guidance must be given in the national interpretations.

Findings In compliance: Yes: X No: Objective WAGS did maintain an up to date list of applicable laws and made available for reference by the evidence: smallholder group members. List of applicable law is evident in Keperluan Perundangan Dalam Penanaman Kelapa Sawit which listed laws that need to comply by the smallholders. The list of law is made available at WAGS office and WAGS notice board at smallholders gathering place (i.e.: community hall). Assessment on every new member has been conducted by WAGS. The risk assessments are to ensure that the smallholders can show evidence of compliance with all relevant legal requirements including the acquisition or holding the land. The assessment will be segregated to 3 steps: a. Baseline Assessment/Scoping b. Baseline questionnaire/farm audit c. Risk Assessment d. Decision on the Compliance to WAGS Code of Conduct Evidence of assessment conducted by WAGS to one of the members smallholders are as below: a. Smallholder Name: Leslie Laintie b. Baseline Assessment: Producer Registration & Baseline Information Form & farm audit conducted on 2 July 2015 c. Risk Assessment: Gathering of legal documents (i.e.: land titles, MPOB license, etc.) d. Decision on participating WAGS program: Sign the contract (i.e.: Members ID-014; Date Signed 3 Aug 2015 Members of WAGS were made aware and understand the intent of applicable laws and regulations as they were always keep reminded during meeting and training session. This were confirm through interview conducted with the smallholders (i.e.: Mr. Joliu Paping; Mr. Wilson Jhary; Mr. Samsudin bin Otoh). Criterion 2.2: The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights. Independent Group Managers have maps or other documents showing the lands held by group Smallholder smallholders and can show these lands are not claimed or contested by third parties with legitimate claims. National interpretations must identify what kinds of documents are needed to show compliance. Documents that should be publicly available include, but are not necessarily limited to: - Land titles GP 7003A Page 39 of 67

- Land application - Land use right - Quit rent - Land agreement Findings In compliance: Yes: X No: Objective WAGS maintains copy of land map, land titles and land application (PT) documents showing the evidence: status of lands held by all smallholders and can show that those lands are not claimed of contested by third parties with legitimate claims. The list of all members and location is available in WAGS-014 PG Farm Register. Maps for all the four regions where the population of the smallholder are available. For each farmer, they hold the copy of the layout of their estate too. One of the members of WAGS- Felix Ambari holds certain documents to show the lands held such as: a. Land titles- Register of Native Title; No: 1147 b. Land Application (PT) c. Cess Payment receipt- No: 14311479 d. MPOB License- 322654-201000 2.3 Use of the land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent. Independent Group managers can show that lands acquired for group smallholders do not Smallholder diminish legal or customary rights of other users. Where others’ customary or legally owned lands have been taken-over there is documentary proof of transfer of rights (eg sale) and of payment or provision of agreed compensation. Findings In compliance: Yes: X No: Objective The land ownership status is based on the Native Title and Land Application records which show evidence: the progress of obtaining legal ownership on the land. Complete documentation for some lands which have been taken over is evidence in the Native Land Titles and signed by the Land Registrar. Farm layout for each member is well documented at their farm record book. Most of smallholder members were obtained a land use right from local government to cultivate those lands for oil palm planting since 1997; and now smallholder members are hold land title for those occupied land. Following smallholder and small grower which hold the land title or PT (Land application): Smallholder Land Title Types Number Leslie Laintie Native 084009334 Hilary Bin Vencent Kolong PT 2011080601 Maital Bangkit Native 083144101 There is no traditional land right neither land dispute within group members, this was confirmed during interview with head of villages

Principle 3: Commitment to Long-Term Economic and Financial Viability Criterion 3.1: There is an implemented management plan that aims to achieve long-term economic and financial viability Independent Group managers have a documented annual business plan which shows economic Smallholder benefits for the group (and set out expansion plans – see 7.1). This plan is shared with group members in an appropriate format.

Findings In compliance: Yes: X No: Objective Wild Asia has established a documented annual business plan which shows the expenses and evidence: estimated annual profit. The FFB yield production is recorded in the WAGS office. The business plan is available and evidence in WAGS-012 Annual Budget for Farmers. MPOB assist the farmers through provide seedlings and prepare the land during replanting activities. MPOB also provide fertilizer to help smallholder in increasing their yield.

GP 7003A Page 40 of 67

Principle 4: Use of Appropriate Best Practices by Growers and Millers Criterion 4.1: Operating procedures are appropriately documented and consistently implemented and monitored. Independent Group Managers can show how they document, monitor and manage the Smallholder implementation of best practices by group smallholders in accordance from the internal assessment of members from Group Managers, Group Managers should ensure that group smallholders can show evidence of compliance. More detailed guidance should be given in the national interpretations. Training should be provided under 4.8.

Findings In compliance: Yes: X No: Objective As these are smallholder farmers, WAGS instead of providing the farmers with procedural evidence: documentation they conducted training in the form of powerpoint presentation for ease of understanding. WAGS-Sabah, Beluran has maintained the SOP May 2013. In the farmers Record file the following operating procedure, management etc were presented annually for the farmers :

a) WAGS: Panduan Pengurusan Kebun Kelapa Sawit Mampan b) WAGS Documentasi c) WAGS- Penggunaan Bahan Kimia d) WAGS- Pengurusan Sisa Buangan e) WAGS Pematuhan Undang-undang f) WAGS- Pengurusan Perosak Berintegrasi g) WAGS- Penjagaan Tanah h) WAGS Penjagaan Sumber Air i) WAGS Kod perlaksanaan j) WAGS Proses Pengurusan k) WAGS Keperluan keahlian

In a separate awareness training WAGS will collaborate with Wilmar to organize session on WAGS – Penanaman Baru & penanaman Semula . The latest training was conducted on 5/12/14 attended by 93 smallholders as per attendance sheet.

In other separate sessions , training on l) WAGS Latihan Social conducted on Feb 2015

and on August 2015, a training was presented to smallholders/farmers/ members for their information on WAGS intention to switch from Green Palm to RSPO Mass Balance and the incentive scheme of RM5/ MT to WAGS-Sabah , Beluran members given by Wilmar POM for their commitment to RSPO compliance.

WAGS-Sabah , Beluran has conducted the compulsory training of the new members in the certified Producer Group as well as the members for the new Producer Groups Producer Group Date of training No. of attendees No. going for certification and attended training PG1 ( new members ) 12/2/15 – 15/7/15 - 18 PG2 2/2/15 – 9/8/15 43 PG3 11/3/15 3 3 PG4 Kiabau 7/5/15 77 42 PG5 Rekahalus 29/7/15 27 27

In the Farmers Record checklist known as ‘Senarai Semak Fail Dokumentasi Pekebun’ will include the following : a) Farm Layout sketch and title /Pelan Kebun GP 7003A Page 41 of 67

b) Land Grant / title / Receipt of payment for PT c) MPOB Licence / Salinan Lesen MPOB

Logbook information on : a) ‘Rekod Aktiviti Kebun ‘ b) Lain –lain rekod ( rekod penanaman Anak Sawit, rekod bantuan MPOB, Rekod bantuan isu berkaitan tanah ) Other information like :  Salinan Borang Keahlian  Salinan perjanjian kontrak WAGS  Borang keahlian latihan WAGS  Salinan Kontrak pekerja  Salinan dokumen memandu  Salinan dokumen kenderaan  Logbook monitoring sheet

d) Monthly Record of Farm Activity (Rekod aktiviti Kebun) that includes  Sales of FFB ( Rekod Penjualan BTS )  Expenditure records ( Record perbelanjaan )  Agrochemical Usage( Record penggunaan Racun )  Manuring Record ( Rekod Penggunaan Baja ) e) Palm Oil Mill Weighbridge Advice Ticket & Payment Advice f) Payment voucher for product purchase g) FFB Cash Sales h) Wages paid to workers ( 201x ) for Harvesting, Mulching, Loading, manuring, circle spraying , Pruning etc i) Training attended – Compulsory Training and Awareness Training m) Training material - WAGS: Panduan Pengurusan Kebun Kelapa Sawit Mampan j) Sample of hazard sign and empty container management k) Copy of Contract : Perjanjian di antara Pengeluar dan WAGS – Dokumen KOD WAGS ICS 009 l) Agronomi visit – WAGS Farm Maintenance for BMP m) Minutes of WAGS Member meeting

Files of the following farmers were viewed:

Day(s) Farmer visited Day 1 Felix Ambari, Leslie Laintie, Joliu Paping Day 2 Hilary Vencent , Wilson Jhary, Kanit Madiris , Laban Idol , Samsudin Otoh, Asmaran Jiwa/ Rahimah Grado Day 3 Maital Bangkit, Mansoon Bangkit,Roslan Ahmad, GP 7003A Page 42 of 67

Kandoh Nor,Maudi Jauri, Malais Juroh , Anchi Tapal & Veronica Ajim Day 4 Linella Pallai , Sarigoh Rantau, Elvis Sarigoh , Lantina Ganai, Rinah Pokah, Jera Hasil S/B, Jimoi Ambong/ Datuk Tan

Criterion 4.2: Practices maintain soil fertility at, or where possible improve soil fertility to a level that ensures optimal and sustained yield. Independent Group Managers can show how they carried out training with group smallholders to Minor Smallholder explain best practices to maintain soil fertility (see 4.8) and monitor and verify effective implementation.

Findings In compliance: Yes: x No: Objective WAGS have training material , WAGS Penjagaan Tanah (Soil Management ) that is presented evidence: to the farmers or smallholders to explain best practices to maintain soil fertility and the importance to ensure optimal or sustained yield . Annually, WAGS-Sabah Beluran will arrange agronomic visit for their members. After visit from the WildAsia agronomist, Mohd Iqbal , an agronomic report will be provided to address observations seen for more effective agronomic recommendation to the farmers. Below are the agronomic visit conducted :

Producer Group Date of visit No. farmer sampled PG1 21/3/15 2 CIR visit PG2 12/6/15 2 Agronomic visit PG3 26/5/15 2 facility inspection and monitoring PG4 13/6/15 3 Agronomic visit PG5 - - -

Records of application are being recorded as best possible based on farmer’s record of purchase sighted in Maital Bangkit and Mansoon Bangkit’s file. Records of some of the farmers’ ‘Monthly Record of Farm Activity (Rekod aktiviti Kebun) that has a section on Manuring Record (Rekod Penggunaan Baja). Records were kept like in Linella Pallai’s file . In her application she uses liquid fertilisers, chicken dung in fertiliser bags, EFB as well as the use of Compound blue 12;12:17:2. Similar records were found in the smallgrowers file of Jera Hasil and Jimoi Ambong . In Jimoi Ambong file , application of SOA, MOP, Kieserite, Borate and RP Nevertheless during this surveillance visit, it was found that most of the farmers have delayed or have not applied fertiliser 2014-2015 e.g. Wilson, Elvis Sarigoh and Sarigoh Rantau Some practices that requires monitoring to show its effect on sustainable yield are: a) Felix Ambari is using liquid fertiliser , Di-Grow with formula, 2.16%:2.03%:2.28%+TE and 2.01%:2.04%:3.02%+TE b) Roslan Ahmad use of urea only for the mature palms c) The use of MPOB fertiliser for their new replant for their mature palms

Best and alternative practices to maintain soil fertility during times of falling FFB prices and household commitment need to be communicated to the farmers.

GP 7003A Page 43 of 67

OBSERVATION 01 Criterion 4.3: Practices minimize and control erosion and degradation of soils. Independent Group Managers can show that they have carried out trainings with group Smallholder smallholders to explain best practices to minimise and control the erosion and degradation (see 4.8) and monitor and verify effective implementation.

Findings In compliance: Yes: X No: Objective WAGS have training material , WAGS Penjagaan Tanah (Soil Management ) that is presented evidence: to the farmers or smallholders to explain best practices to minimise and control the erosion and degradation (see 4.8) and monitor and verify effective implementation. They have also stacked the pruned fronds . In Rinah Pokah’s farm, where the farm was on a undulating terrain , although no terrace were constructed, the frond were stacked against the slope. Most of the farmers have do not overspray their farms. Most of the farmers seem to be using Glyphosate-based herbicide like Sentry or Farmphosate for their spraying. Farmers like Leslie , Kandoh , and Asmaran Jiwa seemed to be in favour of using grass-cutting to manage their weeding regime however we found that in Leslie and Kandoh’s farm, the weeding is overdue resulting in weedy situation . The over-reliance of Glyphosate-based has resulted in resurgence of broadleaves weeds and woodies in farms e.g. Roslan Ahmad. In Samsudin Otoh and in Mansoon Bangkit’s farm there were some overspraying done . OBSERVATION 02 Criterion 4.4: Practices maintain the quality and availability of surface and ground water. Independent Group Managers shall ensure that group members are maintaining riparian buffer Smallholder zones and not contributing to water quality degradation. This is monitored and overseen by the Group Manager.

Findings In compliance: Yes: X No: Objective WAGS have training material , WAGS Penjagaan Sumber air ( Water Source Management ) evidence: that is presented to the farmers or smallholders to ensure that group members are maintaining riparian buffer zones and not contributing to water quality degradation . In Roslan Ahmad’s farm the erosion of the banks has caused ‘movement’ of the buffer zone of his farm. In Maudi Jauri’s farm, some spraying were done at the embankment as there were sighting of snakes resulting in the farmer doing some spraying along the river Sg Sualok OBSERVATION 03 Criterion 4.5: Pests, disease, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques. Independent Pests, diseases, weeds and invasive introduced species are effectively managed Smallholder using appropriate Integrated Pest Management (IPM) techniques.

Findings In compliance: Yes: X No: Objective WAGS have training material , WAGS Pengurusan Perosak Berintegrasi ( IPM ) that particularly evidence: pests ( like rats, leaf eating insects and Oryctes beetle ) , diseases, weeds and invasive introduced species can be effectively managed using appropriate Integrated Pest Management (IPM) techniques. in October 2014, Wilmar contributed and distributed beneficial plants for the smallholders to plant in their farms . According to Wilmar Mr Yeap about 300-400 plants were distributed and according to Mr Danial Adha, WAGS – FPC each farmer was given 2-3 plants. In Leslie’s farm, due to the delay in the excavator to chipped his old palms during replanting, Mr Leslie engaged the use of chainsaw to fell his palms however as he was not able to chip his palms he had a bad attack of Oryctes beetle during replanting. According to him, he need to show proof of the felled palms so that he is entitled to participate in the MPOB incentive replanting of seedling and fertiliser. GP 7003A Page 44 of 67

The training has given him insight on how to avoid such attack in the near future. In Kandoh’s farm , rat attacked were evidence in the bunches harvested and from attending the IPM training ,Mr Kandoh is aware of the need to monitor rat damage. In Jimoi Ambong farm, the supervisor Mr Boon Fatt, sighted some leaf eating insect incidence. He planned to use manual spray using the chemical alpha-cypermethrin and a long lance. The owner, Datuk Tan and Mr Boon Fatt were not aware of the importance of beneficial plants like Cassia sp, Turnera sp or Antigonon sp, census and the proper use of spray equipment or trunk injection for the control of these leaf- eating insect. OBSERVATION 04 Criterion 4.6: Agrochemicals are used in a way that does not endanger health or the environment. There is no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. Where agrochemicals are used that are categorized as World Health Organization Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented. Independent Group managers records will also show: Smallholder  List of all agrochemicals used by group members documentary evidence that use of chemicals categorised as World Health Organisation Type 1A or 1B, or listed by the Stockholm or Rotterdam Conventions, and paraquat is reduced and/or eliminated and alternatives identified where possible by the group manager in accordance with the dangers identified of these chemicals.  Note: Records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) are maintained for either a minimum of 5 years or starting November 2007.

Findings In compliance: Yes: X No:

Objective WAGS-Sabah, Beluran has information of the list of agrochemical used by the group members evidence: posted on the notice board of the ‘Dewan’ / Training Stations where meetings conducted.

The training stations are located :

a) Kg Toniting

b) Kg Kiabau

c) Kg Kuala Sapi

d) Kg Sualok

e) Kg Gana Jati

The notice board include information like:

a) List of chemical used

b) Monitoring of chemical usage ( monthly ) and summarised yearly

c) Memos and events like audits

d) Code of conducts

e) Membership requirement

f) Contact numbers

g) List of active members

h) Trainings and upcoming events

i) etc

Paraquat is still used and WAGS-Sabah Beluran is recording the individual usage in their Excel GP 7003A Page 45 of 67

sheet: ‘Summary of record of farmer logbook’

Most farmer have storage area for their chemicals.

List of chemical used is posted at the WAG-Sabah, Beluran notice-board at Kg Toniting. WAGS plan to have it on the notice- boards of suitable place for the new producer groups. They have included products that were left out last year like Basta and Blocus.

Most of the chemical storage site of farmers were visited where available. They were in different state and condition depending on the ‘ability’ of the farmer.

a) Maital Bangkit is building a new storage

b) Linella Pallai’s store was quite unique with its sliding door.

Most of the store had lock and key , raised shed, away from children etc.

Hazard signs were also posted on the wall and instruction on how to triple rinse and dispose of the empty containers.

Most of the other farmers will only purchase minimum quantity of agrochemical for the operation like weeding .

Some farmers keep their chemical in a makeshift store nearby to the worker’s quarters e.g Felix, others will bring it back and keep it at a separate store beside their home , e.g. Sarigoh Rantau.

In the Farmer Record file, the list of agrochemical used are available. In the recording form ( Rekod Aktiviti Kebun ) , the following are recorded under the chemical used ( Rekod Penggunaan Racun ) section : a) Date of operation (Tarikh meracun) b) Name of agrochemical Used (Nama Racun) c) Quantity Used (Kuantiti) d) Area treated ( Keluasan di racun ) e) No. of palms f) Cost of application ( jumlah kos )

WAGS-Sabah Beluran is still monitoring the records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications). Even the information PG1 Toniting is only updated till mid-2014.

One farmer , Wilson has not build to store his chemical and spray as they were kept below a palm in his farm and exposed to the elements/weather e.g. rain One of the farmer’s store build did not have sufficient ventilation e.g Linella Pallai.

OBSERVATION 05 Criterion 4.7: An occupational health and safety plan is documented, effectively communicated and implemented Independent Independent smallholders need not have a formal health and safety plan but Smallholder should ensure working practices for all workers are safe.

Findings In compliance: Yes: X No: Objective WAGS have training material, WAGS – Kesihatan & Keselamatan ketika menggunakan racun that evidence: is presented to the farmers as part of their annual awareness training. The training for health and safety plan for the new farmers/members is now incorporated in their compulsory training under the topic : WAGS- Penggunaan Bahan Kimia and WAGS- Pengurusan Sisa Buangan GP 7003A Page 46 of 67

Producer Group date of training No. of attendees No. going for certification and attended training PG1 ( new members ) 12/2/15 – 15/7/15 - 18 PG2 2/2/15 – 9/8/15 43 PG3 11/3/15 3 3 PG4 Kiabau 7/5/15 77 42 PG5 Rekahalus 29/7/15 27 27

The training topics include: a) Kepentingan Dokumentasi b) Penyimpanan Bahan Kimia c) Penyelenggaran & Penggunaan Bahan Kimia d) Bahan Kimia Yang Biasa dipakai & Status e) Purchase , delivery and storage f) Spillage g) Dispensing h) Personal Protective Equipment i) Washing after activity j) Method of spraying and calibration k) Triple rinsing and the disposal of containers The WAGS-Sabah, Beluran will also ensure that casual workers that come to work in the smallholder farm for example for spraying and harvesting abide with some safe working practices . MPOB has provided some basic PPE like mask, helmet, boots , gloves and apron to inculcate safety values into their work operation However the use of PPE still require continue reminder as: a) Maudi Jauri said he uses a towel to wrap his nose and mouth during spraying instead of mask. b) Lantina Ganai worker , Ismail Ali has already buried his damaged PPE and awaiting his replacement c) etc OBSERVATION 06 Criterion 4.8: All staffs, workers, smallholders and contractors are appropriately trained. Independent Group managers should raise awareness on relevant issues and identify training Smallholder needs and provided to smallholders where needed. Areas for assessment of training include:  The functioning of groups and the responsibilities of group members  The relevance of the RSPO standard  Legal compliance (see 2.1)  Operating procedures (see 4.1)  Soil and water management (see 4.2, 4.3 & 4.4)  Integrated Pest Management (see 4.5)  Agrochemical use (see 4.6)  Occupational Health and Safety (see 4.7)  Use of fire and relevant regulations (see 5.5)

Findings In compliance: Yes: X No: GP 7003A Page 47 of 67

Objective In the WAGS Sabah Team office , all training and meeting documents with the farmers are kept in evidence: the Minutes of Group Training and Meeting file

As these are smallholder farmers , WAGS instead of providing the farmers with procedural documentation, they conducted training in the form of powerpoint presentation for ease of understanding. WAGS-Sabah, Beluran has maintained the SOP May 2013. In the farmers Record file the following operating procedure, management etc were presented annually for the farmers :

a) WAGS: Panduan Pengurusan Kebun Kelapa Sawit Mampan b) WAGS Documentasi c) WAGS- Penggunaan Bahan Kimia d) WAGS- Pengurusan Sisa Buangan e) WAGS Pematuhan Undang-undang f) WAGS- Pengurusan Perosak Berintegrasi g) WAGS- Penjagaan Tanah h) WAGS Penjagaan Sumber Air i) WAGS Kod perlaksanaan j) WAGS Proses Pengurusan k) WAGS Keperluan keahlian

In a separate awareness training WAGS will collaborate with Wilmar to organize session on WAGS – Penanaman Baru & penanaman Semula . The latest training was conducted on 5/12/14 attended by 93 smallholders as per attendance sheet.

In other separate sessions , training on l) WAGS Latihan Social conducted on Feb 2015

and on August 2015, a training was presented to smallholders/farmers/ members for their information on WAGS intention to switch from Green Palm to RSPO Mass Balance and the incentive scheme of RM5/ MT to WAGS-Sabah , Beluran members given by Wilmar POM for their commitment to RSPO compliance.

According to Mr Dean, annually the farmer have to attend the compulsory training a) WAGS- (Panduan Pengurusan Kebun Kelapa Sawit Mampan ) and 2 awareness training (b) – (l)

Some training for consideration

Malais Juroh – Re-establishing the oil palm after years of neglect Rinah Pokah – use of EFB and Decanter cake as a fertilizer replacement

Principle 5: Environmental Responsibility and Conservation of Natural Resources and Biodiversity Criterion 5.1: Aspects of plantation and mill management, including replanting, that have environmental impacts are identified and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement. Independent Group managers must undertake and document an impact assessment, developed Major Smallholder with the participation of smallholders and local communities, that includes all the group smallholdings and sets out appropriate actions to address each impact identified when:  Replanting or expanding smallholdings.  Clearing remaining natural vegetation and the need to avoid the use of fire (see 5.5). Findings In compliance: Yes: X No: Objective WAGS has sets out appropriate actions to address each impact of replanting/new planting and evidence: use of fire during land clearing by: a. Providing training to all the smallholder:  Training title: T08- New Planting and replanting training b. Send the circular to all the smallholder  Circular: 15 Sep 2014- Using of fire in New planting and replanting

Verified onsite of the one of the smallholder, GP 7003A Page 48 of 67

Criterion 5.2: The status of rare, threatened or endangered species (ERTs) and highly conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations. Independent Information on protected species and habitat with high conservation values may be Smallholder obtained from smallholders organisation and relevant government institution and competent NGOs.

Findings In compliance: Yes: X No: Objective WAGS Baseline Assessment for SPOC Telupid dated 13 May 2013 stated the majority of the evidence: HCV potential within the smallholdings is bordering forest reserves such as those located on the Sapi Estate and Toniting kampong. No HCV or RTE species were identified within or adjacent to the forest reserve. Visited one of the farmer’s estate (Mansoon Bangkit) which bordering the Bidu Bidu forest reserve and observed that signboards are erected to create awareness prohibiting illegal hunting. Interviewed with the farmers confirmed that the patrolling activities conducted by the Forest Department twice a year. Criterion 5.3: Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner. Independent Group Managers shall ensure that group members have identified all waste and Major Smallholder are disposing these in a responsible manner. This is monitored and overseen by the Group Manager. There should be appropriate disposal of hazardous chemicals and their containers. Surplus chemical containers should be disposed of such that there is no risk of contamination of water sources or to human health. The disposal instructions on manufacturer’s labels should be adhered to.

Findings In compliance: Yes: x No: Objective Group manager has established mechanisms for waste management which include hazardous evidence: agrochemical waste such as Management of agrochemical used containers by sending to the waste store belong to partnering mill- Wilmar Sapi Mill. The empty agrochemical container is triple rinsed and punched at bottom before disposal. The remains of the agrochemical and contaminated water from the washing of used container are re- using for the next pre-mixing compound. Generally all the farmers will keep the chemical container for premixing purpose which use for the spraying activities. The containers will be marked with “X” and “poison” to indicate the used of the containers. Besides, most of the famers have built their own chemical store at their house to keep the sprayer, chemical container, PPE and tools. It was observed in small holder as well as the small grower such as Lim Chee Tien estate. Criterion 5.4: Efficiency of energy use and use of renewable energy is maximized. Independent Not applicable to independent smallholders. Smallholder This criterion is not applicable to group smallholders.

Findings In compliance: Yes: x No: Objective NOT APPLICABLE. evidence: Criterion 5.5: Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN Guidance or other regional best practice. Independent Independent smallholders should not practice open burning during replanting Major Smallholder unless with permission from Department of Environment (DOE)

Findings In compliance: Yes: x No: Objective Replanted area inspected during the field visit. No any sign of burning activities in the field. evidence: Interview with stakeholders’ i.e. government officers, village head- Mr Maital Bangkit and neighboring farmers confirmed that fire is not used. Zero burning techniques have been explained to group members by WAGS through internal training.

Criterion 5.6: Plans to reduce pollution and emissions, including greenhouse gases are developed, GP 7003A Page 49 of 67

implemented and monitored. Independent This criterion is not applicable to group smallholders. Smallholder

Findings In compliance: Yes: x No: Objective NOT APPLICABLE. evidence:

Principle 6: Responsible Consideration of Employees and of Individuals and Communities by Growers and Millers Criterion 6.1: Aspects of plantation and mill management, including replanting, that have social impacts are identified in a participatory way and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored to demonstrate continuous improvement. Independent Group managers must be able to demonstrate that group smallholders participated Smallholder in the development of a simplified impact assessment for their group holdings. Group managers must provide: - A documented simplified social impact assessment on these factors: - Right to land use and access - Income (e.g. daily workers) and working condition - Livelihood activities - Cultural and religious values - Evidence that the assessment has been done with the participation of group smallholders, local communities and stakeholders.

A timetable with responsibilities for mitigation and monitoring, reviewed and updated as necessary, in those cases where the assessment has concluded that changes should be made to current practices.

Findings In compliance: Yes: X No: Objective Wild Asia has conducted baseline Social Impact Assessment (SIA) which has been participated evidence: by 85 small farmers from 15 villages within Telupid, Beluran, Sabah. The assessment report was available in WAGS Baseline Assessment for SPOC Telupid Identification of Potential Producer Groups, Farmer Profiles and Key Risk Areas dated 13 May 2013. The SIA report did includes: a. Section 4.1.1 - Rights to land b. Section 4.2 - FFB Production (including yields, supply chain, grading and pricing and transportation) c. Section 3.3 - Socio-Cultural Context (including demographics, economic activities and land rights and tenure ships) d. Section 4.4 - Social Risk e. Section 5 - Profile of farmers

The report has identified some big gaps which have been categorized as follow: a. Agricultural Practices b. Waste Management c. Health and Safety d. Documentation e. Social Accountability f. Environment WAGS have identified some necessary action that need to be taken on monitoring and updates of the identified gaps. Training and regular field assessment is example of action taken in order to minimize the gaps. GP 7003A Page 50 of 67

Re-assessment on Social impacts, livelihood, dispute and grievances investigation and etc. conducted from 13th to 18th August 2015. The assessment conducted with participation of certified members and new members. Assessment team consists of Chris (Team Leader), Nadiah (Social), Ming Yee (Environment), Cherlyn (HCV). SEIA report includes the social impacts and mitigation plan is available during the audit. Criterion 6.2: There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties. Independent Group managers must have documentary evidence that they have clear, Smallholder implemented procedures for regular communications with, and assessments of, group smallholders in line with the requirements of the RSPO Standard for Group Certification and liaise with local communities.

Findings In compliance: Yes: X No: Objective WAGS has documented evidence of implementation of regular communications and assessment evidence: of group smallholders (i.e.: invitation for meeting; training memo; WAGS notice boards) in line with the requirements of RSPO. Some evidence reviewed for the communication with members during the audit are as below: a. Management meeting/training (T02 SPO Management for outgrower) for outgrower conducted on 11th March 2015. Discussion on Social, economy and environment aspect. b. WAGS PG TON Meeting with members regarding certification update, upcoming assessment, internal and external audit. c. Agronomic Visit by Mr. Iqbal, Danial Adha, Jenner Jasper to smallholders farms (Including farmers: Rohani Pauluos, Umah Sarigoh, Rajain Osman, Rahimah Grado, Abta Bakar, Dahlan Ali) conducted on 21st March 2015 and minuted. External Audit Notification: Makluman Audit Luar RSPO oleh Juruaudit Luar untuk Tahun 2015 in a memo dated 17th August 2015. Criterion 6.3: There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties. Independent Independent smallholders should be able to respond to complaints that are raised Smallholder by neighbours or stakeholders.

Findings In compliance: Yes: X No: Objective WAGS have established a Tatacara Aduan (complaints procedure) for all smallholders in evidence: responding to any complaints raised by neighbours and stakeholders. The procedure also indicates the period to respond for any complaints or grievance for each step (which totals to maximum 26 days). The complaints procedure was made publicly available at WAGS office and WAGS notice board at smallholders gathering place (i.e.: community hall). As to the date of audit, all smallholders have not received any complaints from their neighbours or stakeholders. The complaints procedures are applicable to all stakeholders. Criterion 6.4: Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions. Independent Independent smallholders can demonstrate that they have paid compensation to Smallholder prior legal or customary rights-holders through a system that enables stakeholders to express their views through their own representative institutions.

Findings In compliance: Yes: X No: Objective As to the date of audit, there is no compensation has been paid by the smallholders. There is no evidence: case of customary and land claims within the WAGS members. Criterion 6.5: Pay and conditions for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages. Independent Independent smallholders with formal employees must comply with national or Smallholder ratified international legislation protecting workers’ rights, pay and condition. For temporary workers (except casual workers) work conditions should be in accordance with mutual verbal agreement made transparently and freely. GP 7003A Page 51 of 67

Findings In compliance: Yes: X No: Objective During audit verification, audit team found that only one of the independent outgrower estate evidence: (Jimoi Ambong) out of 24 samplings audited have employed permanent workers. However, there is a risk of the respective workers for not achieving minimum wages due to low productivity and absenteeism. Hence, management has to always ensure that all the workers employed are able to earn at least or more than RM800 per month. OBSERVATION 07 Criterion 6.6: The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel. Independent This criterion is not applicable to group smallholders. Smallholder

Findings In compliance: Yes: x No: Objective NOT APPLICABLE evidence: Criterion 6.7: Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programmes. Children are not exposed to hazardous working conditions. Independent Group managers will train group smallholders in the national and ratified Smallholder international legal requirements for avoiding the use of child labour. Work by children on family smallholdings is only acceptable under adult supervision and when not interfering with education programmes and if permitted by national and ratified international laws.

Findings In compliance: Yes: X No: Objective WAGS have conducted social training to all members to train them in the legal requirements for evidence: avoiding the use of child labour. Interview with the smallholders and WAGS representatives (i.e.: Mr. Tungud Saudin; Mr. Burhanuddin Ismail) confirms that there is no children involved in the farms activities. All children will be sent to school and education is the priority. Criterion 6.8: Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation union membership, political affiliation or age is prohibited. Independent Group managers must provide training to group members about the need to avoid Smallholder discrimination in the recruitment and employment of workers employed by, or to assist, smallholders.

Findings In compliance: Yes: X No: Objective WAGS have developed an annual training program which includes Social Training. The training evidence: includes the awareness on no discrimination policy. WAGS have developed Code of Conduct which includes that all workers must be treated equally. All members must comply with WAGS code of conduct as part of the contract agreement. Refer to the criterion 6.7. All members are committed to WAGS code of conduct where no discrimination and respect to the human rights Criterion 6.9: A policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied. Independent Group managers must provide training to group members about the need to Smallholder prevent sexual harassment and the abuse of women among both smallholders and any workers employed by them.

Findings In compliance: Yes: X No: Objective WAGS have developed an annual training program which includes Social Training to give evidence: awareness on sexual harassment or abuse of women. Complaints Procedure was made available for members to report any cases of sexual harassment and abuse of women among smallholders and workers employed. As to the date of audit, there is no case of sexual harassment reported in the smallholders. Criterion 6.10: Growers and mills deal fairly and transparently with smallholders and other local businesses. GP 7003A Page 52 of 67

Independent Group managers must ensure that: Smallholder  Current and past prices paid for FFB are freely available to group members and other parties.

 Fair and transparent mechanisms must be established to pay members and other parties for their FFB

 Agreed payments are made in a timely manner.

Findings In compliance: Yes: X No: Objective WAGS member are sending their FFB to palm oil mill (i.e.: Sapi POM, Terusan mill, Reka halus evidence: mill) and collecting centre (i.e.: PL Sawit Sdn Bhd; Kiabau collecting centre, Multi Bloom Sdn Bhd). All members are holding valid MPOB license (MPOB L1) for selling FFB. a. The FFB pricing is depend on the collecting centre pricing. b. The price was made publicly available at the collecting centre and transparent documentation. c. Agreed payments were made through Final FFB Payment Voucher, Payment Advice at the end of month or after the delivery. The payment documents were signed by the SH and collecting centre. Sample of payment advice is evident below: i. PL Sawit Sdn Bhd (Ticket No.: 034697 dated 15 Jan 2014) pay RM360.50 for 1.03MT FFB to Mr. Melson Appla ii. Multi Bloom Sdn Bhd (Ticket No.: 009044 dated 24 Jun 2014) pay RM 622.30 for 1.27MT FFB to Mr. Wveliah Mukail

 Pricing mechanism training by Wilmar conducted 12th June 2015.

 Fluctuating pricing change every month and communicated to all smallholders by multiple channels, including display at notice board in the mill, stated in the payment slip, training and etc.

Members are encouraged and allow to request for the pricing info from the mill. Criterion 6.11: Growers and millers contribute to local sustainable development wherever appropriate. Independent This criterion is not applicable to group smallholders. Smallholder

Findings In compliance: Yes: x No: Objective NOT APPLICABLE evidence:

Principle 7: Responsible Development of New Plantings This whole Principle is not applicable to this assessment as there are no new plantings. The WAGS Beluran group is only involved in re-planting program after felling of old palms. Objective Before the smallholder can join as WAGS member, they will be assessed through: evidence: a. Baseline Assessment/Scoping b. Baseline questionnaire/farm audit c. Risk Assessment In their baseline assessment, new planting after 2005 is one of their key criteria (ICS Code No: WAGS-002; ver. 3a). Those smallholders planted after 2005, WAGS will crosscheck their farm location whether overlay with any HCV area using GPS coordinates. Smallholder who cannot comply with the requirement will be excluded from joining as members.

GP 7003A Page 53 of 67

Principle 8: Commitment to Continuous Improvement in Key Areas of Activity Criterion 8.1: Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations. Independent Group managers must develop an action plan for continual improvement, Smallholder developed in a participatory manner with group smallholders, based on a consideration of the main social and environmental impacts and opportunities of the smallholdings, and should include a range of indicators covered by these principles and criteria.

Findings In compliance: Yes: No: x Objective WAGS Beluran have develop for the following plan: evidence: WAGS-018 Producer Group Management (PGMP) Toniting 26072014. WAGS-018 Producer Group Management (PGMP) Terusan 27072014. The continuous plan covered the continuous plan for best management plan and legal compliance. Group manager is also increase the number of group member in order to improve their capability to produced more certified FFB and sale into the market either GreenPalm system or physical trading. However, List of temporary, permanent, or casual workers who work for the farmers was not identified and list down for monitoring purposes on their wages paid, legality, job competency, safety and etc. Minor01

3.3 Corrective Action Request There are total of 0 Major, 1 Minor and 7 observations were raised. Please refer to the Appendix A for the details findings and relevant correction actions have been taken.

3.4 Noteworthy Positive & Negative Observation d. Group Manager is capable and has very strong knowledge for managing the independent smallholders. e. The smallholders demonstrate their high commitment towards the certification and organized documentation for keeping all the relevant records. f. Field Coordinator and team have demonstrated their knowledge and competency in managing the smallholder scheme.

3.5 Status of Non-Conformities Previously Identified This is the annual surveillance 2 assessment. All Non-Conformities Previously Identified were closed accordingly and has been verified by the audit team during the audit.

3.6 Issues Raised by Stakeholders and Findings A list of stakeholders contacted is included as Appendix C. No comments receive during the public notification. Stakeholders did not provide any feedback in writing regarding the WAGS Beluran environmental and social performance. During onsite audit, all interviewed stakeholders had positive comments about WAGS Beluran. There were no legal or land disputes issues highlighted. GP 7003A Page 54 of 67

Interview with the Group Manager and smallholders indicated that they are in the good relationship of cooperation in achieving the RSPO certification. Sapi Mill also provides consultation and advice to help the smallholder during the process of certification. The MPOB officer explained to the audit team regarding the how the smallholder applies for the MPOB license and the subsidy for the fertilizer and chemical. JKKK described the background of the shifting cultivation of the village and how the mechanism for Permohonan Tanah (PT/ Land Application). Appendix C contains list of stakeholder and topic contacted such as supplier, villager, workers etc.

4. ACKNOWLEDGEMENT OF ORGANIZATION INTERNAL RESPONSIBILITY 4.1 Date of Next Surveillance Visit The next surveillance audit is planned before on July 2015. Time Bound Plan is not applicable.

4.2 Acknowledgement of Internal Responsibility and Formal Sign-off Assessment Findings SGS Malaysia acknowledges and confirms acceptance of the Report contents and including the assessment findings. SGS Malaysia accepts the responsibility for addressing the opportunities of improvement detailed in this report.

Signed on behalf of Sheila Senathirajah Signed on behalf of SGS Malaysia Sdn Bhd

GP 7003A Page 55 of 67

APPENDIX A: CORRECTIVE ACTION REQUEST & OBSERVATION

CAR # Indicator CAR Detail Date Due Date 27/8/15 26/8/16 Recorded> Date> Closed> Non-Conformance:

Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations.

Group managers must develop an action plan for continual improvement, developed in a m 01 8.1 participatory manner with group smallholders, based on a consideration of the main social and environmental impacts and opportunities of the smallholdings, and should include a range of indicators covered by these principles and criteria. Objective Evidence: List of temporary, permanent, or casual workers who work for the farmers was not identified and list down for monitoring purposes on their wages paid, legality, job competency, safety and etc. Close-out evidence:

Observations

Date Due Date 24-27/8/15 N.A Recorded> Date> Closed> Non-Conformance: OBS 4.6 01 Although Group Managers can show how they carried out training with group smallholders to explain best practices to maintain soil fertility (see 4.8) however monitoring and implementation was not practiced effectively Objective Evidence: GP 7003A Page 56 of 67

Records of application are being recorded as best possible based on farmer’s record of purchase sighted in Maital Bangkit and Mansoon Bangkit’s file. Records of some of the farmers’ ‘Monthly Record of Farm Activity (Rekod aktiviti Kebun) that has a section on Manuring Record (Rekod Penggunaan Baja). Records were kept like in Linella Pallai’s file . In her application she uses liquid fertilisers, chicken dung in fertiliser bags, EFB as well as the use of Compound blue 12;12:17:2. Similar records were found in the smallgrowers file of Jera Hasil and Jimoi Ambong . In Jimoi Ambong file , application of SOA, MOP, Kieserite, Borate and RP Nevertheless during this surveillance visit, it was found that most of the farmers have delayed or have not applied fertiliser 2014-2015 e.g. Wilson Jhary, Elvis Sarigoh and Sarigoh Rantau Some practices that requires monitoring to show its effect on sustainable yield are: a) Felix Ambari is using liquid fertiliser , Di-Grow with formula, 2.16%:2.03%:2.28%+TE and 2.01%:2.04%:3.02%+TE b) Roslan Ahmad use of urea only for the mature palms c) The use of MPOB fertiliser allocated for their new replant is used instead for their mature palms Best and alternative practices to maintain soil fertility during times of falling FFB prices and household commitment need to be communicated to the farmers. Close-out evidence:

Date Due Date 24-27/8/15 N.A Recorded> Date> Closed> Non-Conformance:

Although Group Managers can show that they have carried out trainings with group smallholders to explain best practices to minimise and control the erosion and degradation (see 4.8) however monitoring and implementation was not practiced effectively Objective Evidence: WAGS have training material , WAGS Penjagaan Tanah (Soil Management ) that is presented to the farmers or smallholders to explain best practices to minimise and control the erosion and degradation (see 4.8) and monitor and verify effective implementation. They have also stacked the pruned fronds . In Rinah Pokah’s farm, where the farm was on a OBS undulating terrain, although no terrace were constructed, the frond were stacked against the 4.3 02 slope. Most of the farmers have do not overspray their farms. Most of the farmers seemed to be using Glyphosate-based herbicide like Sentry or Farmphosate for their spraying. Farmers like Leslie , Kandoh , and Asmaran Jiwa seemed to be in favour of using grass-cutting to manage their weeding regime however we found that in Leslie and Kandoh’s farm, the weeding is overdue resulting in weedy situation . The over-reliance of Glyphosate-based has resulted in resurgence of broadleaves weeds and woodies in farms e.g Roslan Ahmad. In Samsudin Otoh and in Mansoon Bangkit’s farm there were some overspraying done. Close-out evidence:

Date Due Date 24-27/8/15 N.A Recorded> Date> Closed> OBS Non-Conformance: 4.4 03 Although Group Managers shall ensure that group members are maintaining riparian buffer zones and not contributing to water quality degradation. This is monitored and overseen by the Group Manager, however monitoring and implementation was not practiced effectively GP 7003A Page 57 of 67

Objective Evidence: WAGS have training material , WAGS Penjagaan Sumber air ( Water Source Management ) that is presented to the farmers or smallholders to ensure that group members are maintaining riparian buffer zones and not contributing to water quality degradation . In Roslan Ahmad’s farm the erosion of the banks has caused ‘movement’ of the buffer zone of his farm. In Maudi Jauri farm, some spraying were done at the embankment as there were sighting of snakes resulting in the farmer doing some spraying along the Sg Sualok Close-out evidence:

Date Due Date 24-27/8/15 N.A Recorded> Date> Closed> Non-Conformance:

Pests, diseases, weeds and invasive introduced species are not effectively managed using appropriate Integrated Pest Management (IPM) techniques. Objective Evidence: WAGS have training material , WAGS Pengurusan Perosak Berintegrasi ( IPM ) that particularly pests ( like rats, leaf eating insects and Oryctes beetle ) , diseases, weeds and invasive introduced species can be effectively managed using appropriate Integrated Pest Management (IPM) techniques. in October 2014, Wilmar contributed and distributed beneficial plants for the smallholders to plant in their farms . According to Wilmar Mr Yeap about 300-400 plants were distributed and according to Mr Danial Adha, WAGS – FPC each farmer was given 2-3 plants. In Leslie’s farm, due to the delay in the excavator to chipped his old palms during replanting, Mr OBS 4.5 Leslie engaged the use of chainsaw to fell his palms however as he was not able to chip his 04 palms he had a bad attack of Oryctes beetle during replanting. According to him, he need to show proof of the felled palms so that he is entitled to participate in the MPOB incentive replanting of seedling and fertiliser. The training has given him insight on how to avoid such attack in the near future. In Kandoh’s farm , rat attacked were evidence in the bunches harvested and from attending the IPM training ,Mr Kandoh is aware of the need to monitor rat damage. In Jimoi Ambong farm, the supervisor Mr Boon Fatt, sighted some leaf eating insect incidence. He planned to use manual spray using the chemical alpha-cypermethrin and a long lance. The owner, Datuk Tan and Mr Boon Fatt were not aware of the importance of beneficial plants like Cassia sp, Turnera sp or Antigonon sp, census and the proper use of spray equipment or trunk injection for the control of these leaf- eating insect.

Close-out evidence:

Date Due Date 26/8/15 N.A Recorded> Date> Closed> Non-Conformance: Group managers records will also show:  List of all agrochemicals used by group members documentary evidence that use of OBS chemicals categorised as World Health Organisation Type 1A or 1B, or listed by the 4.6 05 Stockholm or Rotterdam Conventions, and paraquat is reduced and/or eliminated and alternatives identified where possible by the group manager in accordance with the dangers identified of these chemicals. Note: Records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) are maintained for either a minimum of 5 years or starting November 2007. Objective Evidence: GP 7003A Page 58 of 67

Most of the chemical storage site of farmers were visited where available. They were in different state and condition depending on the ‘ability’ of the farmer.

c) Maital Bangkit is building a new storage

d) Linella Pallai’s store was quite unique with its sliding door.

Most of the store had lock and key , raised shed, away from children etc.

Hazard signs were also posted on the wall and instruction on how to triple rinse and dispose of the empty containers.

Most of the other farmers will only purchase minimum quantity of agrochemical for the operation like weeding .

Some farmers keep their chemical in a makeshift store nearby to the worker’s quarters e.g Felix, others will bring it back and keep it at a separate store beside their home , e.g. Sarigoh Rantau.

In the Farmer Record file, the list of agrochemical used are available. In the recording form ( Rekod Aktiviti Kebun ) , the following are recorded under the chemical used ( Rekod Penggunaan Racun ) section : g) Date of operation (Tarikh meracun) h) Name of agrochemical Used (Nama Racun) i) Quantity Used (Kuantiti) j) Area treated ( Keluasan di racun ) k) No. of palms l) Cost of application ( jumlah kos )

WAGS-Sabah Beluran is still monitoring the records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications). Even the information PG1 Toniting is only updated till mid-2014.

One farmer , Wilson has not build to store his chemical and spray as they were kept below a palm in his farm and exposed to the elements/weather e.g. rain Some of the store build did not have sufficient ventilation e.g Linella Pallai. Close-out evidence:

Date Due Date 27/8/15 N.A Recorded> Date> Closed> OBS Non-Conformance: 4.7 06 Although Independent smallholders need not have a formal health and safety plan but assurance that working practices for all workers are safe were not effectively implemented Objective Evidence: GP 7003A Page 59 of 67

The WAGS-Sabah, Beluran will also ensure that casual workers that come to work in the smallholder farm for example for spraying and harvesting abide with some safe working practices . MPOB has provided some basic PPE like mask, helmet, boots , gloves and apron to inculcate safety values into their work operation However the use of PPE still require continue reminder as: a) Maudi Jauri said he uses a towel to wrap his nose and mouth during spraying instead of mask. Lantina Ganai worker , Ismail Ali has already buried his damaged PPE and awaiting his replacement and etc. Close-out evidence:

Date Due Date 27/8/15 N.A Recorded> Date> Closed> Non-Conformance:

Documentation of pay and conditions shall be available. Management has to improve the workers productivity and earning to ensure their workers are always achieves the minimum wages requirement. OBS Objective Evidence: 6.5.1 07 During audit verification, audit team found that only one of the independent outgrower estate (Jimoi Ambong) out of 24 samplings audited have employed permanent workers. However, there is a risk of the respective workers for not achieving minimum wages due to low productivity and absenteeism. Hence, management has to always ensure that all the workers employed are able to earn at least or more than RM800 per month. Close-out evidence:

GP 7003A Page 60 of 67

APPENDIX B: NON-CONFORMITIES PREVIOUSLY IDENTIFIED

Non conformities raised has been closed accordingly and verified during the ASA02 audit assessment and verified by the audit team.

Time Bound Plan Time Bound Plan is not applicable in WAGS program.

GP 7003A Page 61 of 67

APPENDIX C: LIST OF STAKEHOLDERS CONTACTED

Stakeholder Issues Discuss

Smallholder Group Member ICS Documentation & group a. Group Manager- Sheila Senathirajah management system

Sampled WAGS Smallholder group member a. Joliu Paping – Reka Halus b. Felix Ambari- Reka Halus Physical inspection of blocks and interview with group member. c. Leslie Laintie- Reka Halus d. Wilson Jhary - Kiabau Best Field Practices/ OSH/Agrochemical e. Asmaran Jiwa- New (Sapi) handling/HCV/ f. Samsudin Otoh- New (Sapi) Environment/stakeholder g. Kandoh Nor- Terusan interview/ workers interview/Social Issues. h. Maudi Jauri- Terusan i. Veronica Ajim –Terusan j. Malais Juroh – Terusan k. Rinah Poka – New (Sapi) l. Jimoi Ambong – New Sapi (Outgrower) m. Jera Hasil – New Sapi (Outgrower) a. Sapi Palm Oil Mill- Mr Yeap Quality of the crop, pricing and payment. b. MPOB officer Boundary and Land Dispute Land Title and PT (Pemohonan Tanah) MPOB License

GP 7003A Page 62 of 67

APPENDIX D: NAME LIST OF FARMERS FROM WAGS BELURAN GROUP

Producer Group 1

Total Hectares No Producer Name Planted with OP

1 Annith bt. Serigu @ Sarigoh 4.870

2 Gustian Bin Kumbong 5.150

3 Kerendi Bin Engok 7.540

4 Linella Pallai 5.100

5 Sarigoh Bin Rantau 5.260

6 Teresa Japri / Welldext Lawrence 4.850

7 Trisar Binti Saligo @ Sarigoh 5.800

8 Umah Binti Sarigoh 5.670

9 Elizabeth Japari 5.510

10 Risma Binti Asang 5.600

11 Titi Bonsilon 4.925

12 Malai Bin Pallie 4.760

13 Tungud Bin Saudin 5.260

14 Madais Bin Dulumbai 9.300

15 Golfred Bin Japari 4.690

16 Mimah Binti Kilian 5.910

17 Ajain Bin Samayong 4.610

18 Sempineh Bin Ingok - (Ingok Bin Dali) 7.360

19 Rohani Binti Paulous 5.938

20 Johdan Bin Pokah - (Rinah Pokah) 2.020

21 Irok Bin Ingok 6.800

22 Juwitah Saiti 7.700

23 Adun Bin Sunsulak 5.260

24 Elvis Saligoh @ Sarigoh 4.390

25 Ridelly Japri @ Japari 4.980

26 Welfred Bin Sarigoh 2.830

27 Ronielo Rolando 3.360

28 Verronica Saiti 3.240

29 Connika Binti Tangkian 6.281

30 Charless Jaikal 5.500

31 Jaikal @ Gabok Bin Sunsulak 21.190

32 Rickleas B Madais 5.670

33 Rickline B Madais 5.670 GP 7003A Page 63 of 67

34 Jimmy Bin Kuting 4.650

35 Asmah Nasir - (Terance @ Tata Rantau) 6.470

36 Jaafar Bin Nanau 5.460

37 Asmah Nasir - (Jerry Bin Terance) 5.260

38 Lantina Binti Ganai 10.320

39 Helen Binti Rantau 10.530

40 Mathew Paping 15.140

41 Fatimah Ab Jalal 1.170

42 Lawrence Samuah 13.179

43 Abta Bin Bakar 3.153

44 Dahlan Bin Ali 2.500

45 Jumat Bin Amirunsin 1.820

46 Jumatia Binti Darmansah 1.750

47 Masnah Binti Moktar 3.359

48 Samsudin Bin Otoh - (Masnah Binti Moktar) 2.575

49 Rahimah Grado Abdullah 4.295

50 Asmaran Jiwa Bin Yusop - (Rahimah Grado Bin Abdullah) 3.700

51 Rajain Bin Osman 4.709

52 Sapan Bin Kanua 10.160

53 Farah Binti Sapan 4.117

54 Anna Binti Sapan 5.840

55 Milton Sapan 5.820

56 Abdul Ghani Bin Osman 4.594

Producer Group 2

Total Hectares No Producer Name Planted with OP

1 Aveline Binti Randi 4.047

2 Ekim Binti Pasikin 6.070

3 Jami bin Sinai 5.662

4 Jaulim Ajak 1.618

5 Jaunny Kandong 7.082

6 Jiklin Binti Amos 3.838

7 Jimah Binti Antak 2.400

8 Jimi Pasilcin @ Pasikin 4.047

9 Kamria @ Yongor Binti Tulayu 4.594

10 Kandoh Bin Nor 4.047 GP 7003A Page 64 of 67

11 Lawernce Bin Robin 1.619

12 Luin Bin Damsik 5.460

13 Malais Bin Juroh 6.070

14 Marin Bin Matin 3.034

15 Martin Bin Robin 4.037

16 Masliah Binti Titi 2.833

17 Maudi Jauri Umar 3.230

18 Mekron Bintang 12.287

19 Melson Bin Appla 7.284

20 Michael Bin Onteh 10.920

21 Mukail Bin Guang 2.020

22 Nikrun Bintang 16.960

23 Palimin Bin Aping @ Kulimin Aping 5.200

24 Petrus Bin Tadon @ Petrus Bin Antadon 5.868

25 Raji Bin Sinai 4.856

26 Rasnah Binti Satu 2.020

27 Rosma Binti Kanoong @ Rosma Binti Kandong 1.620

28 Sabinah Binti Bintang 4.856

29 Veronica Ajim 6.070

30 Janis Bin Harun (d.) - (Veronica Ajim) 6.070

31 Wveliah Mukail 1.780

32 Binjal Bin Bangkit 5.635

33 Gabriel Lionel Luis 9.827

34 Jespan Bin Pariman 6.237

35 Laiman Bin Dasir 3.067

36 Limsoon Bin Bangkih @ Bangkit 5.868

37 Lislie Bin Masuil 9.489

38 Maital Bin Bangkit 7.669

39 Mansoon Bangkit 5.940

40 Patrick Bangkit 6.070

41 Roland Bin Piriman 9.875

42 Wilfred Bin Louis @ lionel Luis 4.047

43 Abdul Rahman Bin Bajau @ Isah 4.978

44 Anchi AK Tapal 4.450

45 Jeffri Pariman 4.450

46 Mariamah Binti Kanua (Buani Binti Pariman @Ella 4.044

47 Peter Kanua 5.668 GP 7003A Page 65 of 67

48 Jamadil Bin Bakar 2.024

49 Roslan Bin Ahmad 2.833

50 Rusman Bin sulaiman 2.294

51 Saidal bin Nasir 1.619

52 Uting Bin Bati 5.028

53 Indang Bin Salleh 4.411

54 Maumah Binti Harun 5.868

55 Norita Binti Ahim 2.290

56 Romadia Angguh @ Angoh 5.868

57 Pasikin Bin Tingkal (Ambran Pasikin) 6.070

58 Philip Bin Awok 14.592

59 Zaimah Binti Antak 2.365

60 Clarence S Sigual 1.618

61 Jaimin Bin Abah 10.139

62 Jalumin Randi 3.238

63 Jikor Bin Marusid 18.413

64 Kambiriah Onteh 1.619

65 Mairin @ Rose Binti Kanua 5.666

66 Thia Eng 4.651

67 Qwek Tsy Yeong 4.050

68 Aini Binti Tuloh 5.868

69 Aminah Binti Ismail 6.070

70 Noraisah Binti Ganduali 6.070

71 Omar Bin Kasim 6.070

72 Sabdiah binti Ganduaali 6.070

73 Wahwa @ Azman Bin Gandawali 4.306

Producer Group 3

Total Hectares No Producer Name Planted with OP

1 Jimoi Ambong 82.100

2 Jera Hasil Sdn Bhd 25.920

3 Sumber Bahagia Lestari Sdn Bhd 35.100

Producer Group 4

Total Hectares No Producer Name Planted with OP GP 7003A Page 66 of 67

1 Pianus Bin Laniu 8.290

2 Zohainah Binti Otot 4.860

3 Johnius Bin Gunting 7.628

4 Tinah Binti Kandayoh 3.640

5 Solubia Bin Tindi@ Kindi (d.) - (Gerald Solubia) 11.129

6 Rainah Binti Junali 3.800 7 Frankie Bin Solubia 1.619

8 Solubia Bin Tindi @ Kinti (d.) - (Frankie Solubia) 2.428

9 Peter Walter Anun (d.) - (Moilin Jimbun) 4.808 10 Jasper Bin Anggalong 4.706

11 Jenner Jasper 3.238

12 Juita @ Adriana Binti Indang 4.718

13 Donny Jhary 2.830

14 Erah Leimor 1.618

15 Anita Sangti Pain 0.809

16 Lurinah Binti Mediris 3.919

17 Dennis Bin Undalis 5.828

18 George Guang Bin Dansol 6.910

19 Talis Bin Bulu 14.840

20 Bulu Bin Kudumpor (d.) - (Talis Bin Bulu) 3.234

21 Sangti Pain Bin Puramau 5.709

22 Jaarah @ Margaret Binti Kupi 3.011

23 Kanit Bin Madiris 2.020

24 Wilson Jhary 4.800

25 Jauyah Puramau 2.020

26 Jeisee Mediris 2.829

27 Maini Bin Minsin 1.214

28 Leo Bin Onong 4.524

29 Dennis Musali Bin Angki 4.856

30 Taino Nora Binti Gusti 4.856

31 Minah Binti Sarikura @ Kurah 2.833

32 Laban Bin Idol 2.833

33 Lina Binti Gusti 2.023

34 Rita Binti Bulok 4.571

35 Emin Binti Dongkong 4.040

36 Hilary Bin Vencent Kolong 11.141

37 Felicity Undalis 11.141 GP 7003A Page 67 of 67

38 Jalil @ Joseph Bin Worong 4.047

39 Rapidah Binti Albert Pain 4.040

40 Bistinus Undalis 11.379

41 Roland Tony 4.305

42 Patrick Albert @ Patrick Sangti Pain 1.214

Producer Group 5

Total Hectares No Producer Name Planted with OP

1 Dickson Juin 2.711

2 Noklin Binti Bulun 4.191

3 Peter Thomas @ Peter Thomas Rining 1.619

4 Eleong Nasir 8.264 5 Saping Bin Majid 2.870

6 Julius Antok 5.378

7 Noriah Titing 3.720

8 Nasir Bin Minor 5.416

9 Mustin Bin Apung 9.583

10 Marjinah @ Celestina Kaling 7.985

11 Talsing Binti Lambou 9.160

12 Baxter Bin Bian 5.590

13 Istimawah Binti Kisong 6.916

14 Jackrow Bin Tamah 10.020

15 Felix Ambari 11.776

16 Roddy Timas 6.649

17 Saidi Bin Taiu 5.698

18 Juin Bin Kundasar 10.030

19 Langsi Bin Miting 3.359

20 Noriah Binti Alan 5.239

21 Anjumin Bin Kisong 4.493

22 Tianah Binti Siol 5.261

23 Eduin Bin Boon Liong 4.626

24 Zanariah Binti Titing 5.260

25 Leslie Laintie @ Into Samsudin 8.602

26 Mark Rammus 7.460

27 Joliu Paping 4.576