RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

RSPO PRINCIPLES & CRITERIA PUBLIC SUMMARY REPORT ANNUAL SURVEILLANCE ASSESSMENT 3

Malaysia KEKAYAAN PALM OIL MILL -Kepong Berhad 2014

Report prepared by: Simon Selvaraj Subramaniam (Lead Assessor) Certification decision by: Nurhadi (Certifier) Certifying Office Control Union () Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100 , , Malaysia [email protected] Tel: +603-3377 1600 / 1700

Control Union Certifications Control Union Certifications is a member of the Control Union World Group - an international inspection and certification body. CUC performs assessments and certification in many agricultural based fields such as FSC, RSPO, and Organic production, Sustainable Textile Production, Organic Exchange, GLOBALGAP, HACCP, BRC, GMP and GTP.

CUC is accredited by the Dutch Council of Accreditation (RVA) on the European quality standard EN 45011 for the inspection and certification of CUC Organic program (according to the EU regulation 2092/91) and GLOBALGAP program. When requested a copy of the accreditation certificate can be obtained from CUC. RSPO Membership Number 8-0025-06-000-00 RSPO Approval Date 12/01/2006 Affiliate Membership http://www.rspo.org/en/member/339

RSPOPC-SUM-REPORT.F01 JULY2013 Page 1 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Table of Contents PART 1: SCOPE OF THE CERTIFICATION ASSESSMENT AUDIT ...... 4

1.1 COMPANY AND CONTACT DETAILS ...... 4 1.2 RSPO MEMBERSHIP & CERTIFICATION DETAILS ...... 4 1.3 ANNUAL SURVEILLANCE ASSESSMENT DETAILS ...... 4 1.4 ASSESSMENT TYPE ...... 4 1.5 LOCATION OF THE PALM OIL MILL ...... 4 1.6 PALM OIL MILL OUTPUT AND APPROXIMATE TONNAGES CERTIFIED ...... 4 1.7 GENERAL DESCRIPTION OF SUPPLY BASE ...... 5 1.7.1 Location of the Supply Base ...... Error! Bookmark not defined. 1.7.2 Statistics of the Supply Base and Estimated Tonnes of FFB produced per year ...... 5 1.7.3 Conservation and HCV Area (Ha) ...... 5 1.7.4 Percentage of Planted Oil Palm by different Age Ranges .. Error! Bookmark not defined. 1.7.5 Calculation of the Number of Production Units (N) to Sample for the Mill ...... 6 1.8 PROGRESS OF ASSOCIATED SMALLHOLDERS OR OUT-GROWERS, IF APPLICABLE TO THIS ASSESSMENT ...... 6 1.9 LOCATION MAP FOR THIS CERTIFICATION UNIT (SEE APPENDIX 1) ...... 7 PART 2: PARTIAL CERTIFICATION ...... 7

2.1 MANAGEMENT STRUCTURE ...... 7 2.2 NON-COMPLIANCE IDENTIFIED WITH 2.1 ABOVE ...... 7 2.3 SUMMARY OF THE TIME BOUND PLAN ...... ERROR! BOOKMARK NOT DEFINED. 2.4 UN-CERTIFIED UNITS OR HOLDINGS ...... ERROR! BOOKMARK NOT DEFINED. 2.5 SUMMARY OF THE FINDINGS FOR PARTIAL CERTIFICATION ...... 12 2.6 PARTIAL CERTIFICATION AUDIT AGENDA ...... 12 PART 3: AUDIT PROCESS ...... 12

3.1 ABOUT THE CERTIFICATION BODY ...... 12 3.2 AUDIT TEAM ...... 12 3.2.1 Qualifications of the Lead Auditor ...... 13 3.2.2 Qualifications of the Assessment Team ...... 13 3.3 AUDIT METHODOLOGY...... 15 3.3.1 General Overview ...... 15 3.3.2 Assessment agenda for this Audit ...... Error! Bookmark not defined. PART 4 ASSESSMENT FINDINGS ...... 17

4.1 LEAD ASSESSOR’S SUMMARY AND RECOMMENDATION FOR CERTIFICATION ...... 17 4.2 SUMMARY OF THE FINDINGS BY PRINCIPLES AND CRITERIA ...... 17 Principle 1: Commitment to Transparency ...... 17 Principle 2: Compliance with Applicable Laws and Regulations ...... 18 Principle 3: Commitment to Long-Term Economic and Financial Viability ...... 19 Principle 4: Use of Appropriate Best Practices by Growers and Millers ...... 19 Principle 5: Environmental Responsibility and Conservation of Natural Resources and Biodiversity ...... 23 Principle 6: Responsible Consideration of Employees and of Individuals and Communities by Growers and Millers ...... 24 Principle 7: Responsible Development of New Plantings ...... 27 Principle 8: Commitment to Continuous Improvement in Key Areas of Activity ...... 27 4.3 SAMPLE CRITERIA APPLIED DURING ANNUAL SURVEILLANCES ONLY & NOT APPLICABLE FOR THE MAIN ASSESSMENT ...... ERROR! BOOKMARK NOT DEFINED. 4.4 NON-CONFORMITY RAISED DURING THIS AUDIT AND ANY FROM THE PREVIOUS YEAR, IF APPLICABLE ...... 28 4.4.1 Non-Conformities Identified during this Audit ...... 28 Non-were raised during this audit. or...... Error! Bookmark not defined. 4.4.2 Non-Conformity Identified during the last ASA, not applicable for MA .. Error! Bookmark not defined. RSPOPC-SUM-REPORT.F01 JULY2013 Page 2 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Non-were raised during the last audit as this is the Main Assessment. or ...... Error! Bookmark not defined. THE FOLLOWING NC’S WERE RAISED DURING THE LAST AUDIT AND THE STATUS WAS REVIEWED AS INDICATED BELOW...... ERROR! BOOKMARK NOT DEFINED. 4.4.2 Observations Raised During this Audit ...... Error! Bookmark not defined. 4.5 ISSUES THAT WERE RAISED DURING THE STAKEHOLDER CONSULTATION, IF ANY ...... 33 PART 5: RSPO SUPPLY CHAIN CERTIFICATION ...... 34

5.1 POM INCLUDED IN THE SCOPE OF THE AUDIT ...... 34 5.2 CONFIRMATION OF THE COMPANY’S SUMMARY OF ANNUAL CERTIFIED VOLUME OF RSPO CERTIFIED PALM OIL AND PALM KERNEL OVER A SPECIFIED PERIOD ...... ERROR! BOOKMARK NOT DEFINED. 5.3 SUMMARY REPORT INCLUDING A BRIEF DESCRIPTION OF THE SCOPE OF CERTIFICATION ...... 34 5.4 MONTHLY RECORDS OF CERTIFIED AND UNCERTIFIED FFB RECEIVED SINCE THE LAST AUDIT ...... 34 5.5 MONTHLY RECORDS OF CERTIFIED CPO AND PK PRODUCED SINCE THE LAST AUDIT ...... 35 5.6 RECORDS OF CERTIFIED CPO & PK SOLD UNDER GREENPLAM TO BUYERS SINCE THE LAST AUDIT, IF ANY ...... 35 5.7 RECORDS OF CERTIFIED CPO & PK SOLD UNDER UTZ ETRACE TO BUYERS SINCE THE LAST AUDIT, IF ANY ERROR! BOOKMARK NOT DEFINED. 5.8 NON-CONFORMITIES IDENTIFIED DURING THIS AUDIT ...... 37 5.9 DESCRIPTION OF THE ORGANIZATIONAL MANAGEMENT SYSTEMS ...... 38 5.10 FINAL CERTIFICATION DECISION BY CONTROL UNION FOR THE RSPO SCCS AUDIT OF THE POM ...... 38 PART 6: CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY ...... 38

6.1 DATE OF NEXT ASA ...... 38 6.2 DATE FOR CLOSURE OF NON-CONFORMITIES ...... 38 6.3 SIGNING BY THE CLIENT ...... 33 6.4 SIGNING BY THE LEAD AUDITOR ...... 38 6.5 SIGNING BY THE CERTIFIER ...... 39 PART 7: APPENDICIES ...... 35

APPENDIX 1: LOCATION MAP FOR THIS CERTIFICATION UNIT ...... 35 FOR MALAYSIA ONLY. APPENDIX 2: LIST OF ABBREVIATIONS ...... 36

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

PART 1: SCOPE OF THE CERTIFICATION ASSESSMENT AUDIT

1.1 Company and Contact Details Company Name: Kuala Lumpur Kepong Sabah, Sdn. Bhd Business Address: 1, Jalan S.P. Seenivasagam, 30000 Ipoh, Perak. Contact Person: Mr. Sin Chuan Eng Office Telephone: +605 2417844 E-Mail: [email protected] Web Site: www.klk.com.my Other Certifications Held: ISCC

1.2 RSPO Membership & Certification Details RSPO Membership Number: 1-0014-04-000-00 Registered Client Name: Kuala Lumpur Kepong Berhad Certificate Number: CU-RSPO-816254 Start Date Of Certificate: 27 October 2011 End Date Of Certificate: 26 October 2016 Date Of Original Certification: 27 October 2011 Scope: Certification of the Palm Oil Mill and Supply Bases Type Of Certification: Single site Duration Of Certificate: 5 Years from date of certification

1.3 Annual Surveillance Assessment Details Dates Of This Audit: 26th – 30th May, 2014 Audit Number: ASA 3

1.4 Assessment Type This is a RSPO Principles &Criteria Compliance assessment of the palm oil mill and its respective supply bases as listed in this report below.

1.5 Location of the Palm Oil Mill Name Mill Location GPS Reference Palm Oil Mill Capacity (POM) MT/Hour Address Longitude Latitude

HS(D) 519, Block 5, Mukim Kekayaan POM 120 E 103º16’ N 2º 12’ Nyior, 86609 Paloh, Kluang, Johor.

1.6 Palm Oil Mill Output and Approximate Tonnages Certified Figures below are from:  Only from certified supply bases (Y/N). YES  Combining certified with uncertified supply bases (Y/N). NO  If the Mill is receiving FFB from uncertified supply bases outside the audit scope, such uncertified sources is highlighted under the following sections as seen applicable: a. PART 1, Section 1.7 – General Description of Supply Base, b. PART 2: Partial Certification, Section 2.4 – Uncertified Units or Holdings, c. PART 5: RSPO Supply Chain Certification of this report Projected Production from the Actual Production for this Audit Year Projected 12 Months (MT) last 12 Months (MT) 2013 (MT) Forecast Certified in this Report

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

FFB CPO PK FFB CPO PK FFB CPO PK 432,565 94,131 21,110 436,419 95,233 22,341 469,997 103,396 24,439

1.7 General Description of Supply Base The mill receives it supply 100% of FFB from its own estates. No changes introduced in the supply base since from previous assessment and this audit has carried out to ensure full compliance with RSPO requirement.

1.7.1 Location of the Supply Base Oil Palm Area Summary Location GPS reference OPP Plantation (Ha) Name Address Longitude Latitude Total Mature Landak K/B 108, KM11, Jalan Paloh, 86609 OPP 1 E 103 17’ N 2 16’ 4,308 3,885 Estate Paloh, Johor. Kekayaan K/B 107, KM11, Jalan Paloh, 86609 OPP 2 E 103 28' N 2 18' 4,059 4,059 Estate Paloh, Johor. K/B 106, KM11, Jalan Paloh, 86609 OPP 3 Paloh Estate E 103 11.98’ N 2 12.09’ 1,943 1,752 Paloh, Johor. Voules K/B 506, KM1, Tenang Station, Jalan N 2 30' OPP 4 E 102 49' 1,266 1,224 Estate Segamat, 85009 Segamat, Johor. Fraser K/B 102, KM 7, Jalan Inas, 81000 OPP 5 E 103 36’ N 1 42’ 2,802 2,034 Estate Kulai, Johor. Ban Heng K/B 102, Batu 24, KM38, Jalan N 2 13’ OPP 6 E 102 49’ 621 577 Estate Pagoh, Labis, 84600 Pagoh, Johor. New Pogoh K/B 505, KM1, Tenang Station, Jalan N 2 30’ OPP 7 E 102 49’ 1,194 1,142 Estate Segamat, 85009 Segamat, Johor. Sg. Bekok KM2.5, Jalan Haji Eskanin, 86500 OPP 8 E 103 07’ N 2 18’ 631 631 Estate Bekok, Johor. See Sun K/B 108, KM4 Rengam, 86300 OPP 9 E 103 38' N 1 55' 577 545 Estate Rengam, Johor. Sg. Penggeli K/B 108, KM32 Kulai, 81440 Kulai, OPP 10 E 103 58' N 1 54' 965 965 Estate Johor. TOTAL 18,366 16,814

1.7.2 Statistics of the Supply Base and Estimated Tonnes of FFB produced per year Estimated FFB/Year (MT) OPP Oil Palm Plantation Planting Years Cycle (Years)

OPP 1 Landak Estate 112,516 1988-2009 25 OPP 2 Kekayaan Estate 123,180 1996-2008 25 OPP 3 Paloh Estate 47,213 1988-2011 25 OPP 4 Voules Estate 32,255 1996-2009 25 OPP 5 Fraser Estate 47,524 1988-2011 25 OPP 6 Ban Heng Estate 16,357 1988-2008 25 OPP 7 New Pogoh Estate 32,053 1992-2009 25 OPP 8 Sg. Bekok Estate 16,597 1992-2009 25 OPP 9 See Sun Estate 13,887 1988-2008 25 OPP 10 Sg. Penggeli Estate 21,398 1987-1989 25 TOTAL 462,980

1.7.3 Conservation and HCV Area (Ha)

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

* HCV part of OPP Oil Palm Plantation Conservation Area (Ha) HCV Area (Ha) Conservation OPP 1 Landak Estate - - - OPP 2 Kekayaan Estate - - - OPP 3 Paloh Estate - - - OPP 4 Voules Estate - - - OPP 5 Fraser Estate - - - OPP 6 Ban Heng Estate - - - OPP 7 New Pogoh Estate - - - OPP 8 Sg. Bekok Estate - - - OPP 9 See Sun Estate - - - OPP 10 Sg. Penggeli Estate - - - TOTAL - - * Indicate if HCV area is part of the Conservation Area. If the HCV area is part of the Conservation Area, then “YES” otherwise, “No”

1.7.4 Percentage of Planted Oil Palm by different Age Ranges Planting years by 5 year ranges ( % ) CU CODE Pre 1990 1996 -2000 2001 – 2006 – 2011 - 2015 Total (Ha) 1991-1995 2005 2010 OPP 1 3,885 0.35 0.12 38.47 47.07 13.99 - [23.11%] OPP 2 4,059 - - 34.83 54.70 10.47 - [24.14%] OPP 3 1,752 9.37 23.78 32.27 20.07 9.83 4.68 [10.42%] OPP 4 1,224 0.32 - 43.05 45.02 11.61 - [7.28%] OPP 5 2,034 34.55 20.45 11.96 14.88 11.17 6.99 [12.10%] OPP 6 577 6.00 13.00 20.00 32.00 29.00 - [3.43%] OPP 7 1,142 - 6.40 53.00 32.00 8.60 - [6.79%] OPP 8 631 - 29.32 31.22 25.36 14.10 - [3.75%] OPP 9 545 46.97 - 29.63 11.61 11.79 - [3.24%] OPP 10 965 100.00 - - - - - [5.74%] Total 16’814 [100%]

1.7.5 Calculation of the Number of Production Units (N) to Sample for the Mill N = 0.8√Y, where “Y” is the number of units, with the result always to be rounded “up” to the next whole integer. Where only a sample of the supply base is assessed, units not previously assessed, or assessed earlier in the certification program, are to be preferred over those more recently assessed For the Mill, how many units make up the production base? Owned estates (Y) N = 0.8√Y Smallholders (Z) N = 0.8√Z 10 4 0 0 Explanation as to the selection of estates sampled 4 out of the 10 estates; Kekayaan Estate, Sg Pengeli Estate, New Pogoh and Ban Heng Estate were assessed. 1.8 Progress of associated Smallholders or Out-growers, if applicable to this assessment

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Progress of associated Smallholders or Out-growers towards Compliance with relevant Standards - should be in accordance to the 3 year implementation plan, if applicable to this assessment Not Applicable

1.9 Location Map for this Certification Unit (See Appendix 1)

PART 2: PARTIAL CERTIFICATION The rules for partial certification allow organizations that have a majority holding in and / or management control of more than one autonomous company growing oil palm to certify individual management units and / or subsidiary companies subject to certain rules.

2.1 Management Structure Section Criteria Yes/No If “Yes” If “No” 2.1.1 Is the certified operation (POM and supply base as No Section 2 is Go to 2.1.2 detailed above) a stand-alone operation and there are N/A no other plantations or mills owned by the same company? 2.1.2 Is the certified operation part of a simple structure of Yes Go to 2.1.5 Go to 2.1.3 operations owned by one company? 2.1.3 Are there statements of the ultimate controlling - Go to 2.1.4 Go to 2.2.1 shareholders and directors in the managing agency company/companies: a. Explaining the legal relationship and the management arrangements with the subsidiary companies and / or with any operating groups? 2.1.4 b. A statement of commitment to complying with the - Go to 2.4 Go to 2.2.2 spirit of the RSPO for all companies and subsidiaries involved with the growing of oil palm and for the production of palm oil? 2.1.5 Is there a time bound plan in place for all subsidiaries, Yes Go to 2.3 2.2.3 estates and palm oil mills? 2.1.6 Is the parent company or one of its majority owned and / Yes or managed subsidiaries a member of RSPO.

2.2 Non-compliance Identified with 2.1 Above Section Non-compliance findings NC raised Category 2.2.1 There is no explanation as to the company’s structure and therefore it - Major Is not possible to conduct an effective audit against the rules for partial certification. 2.2.2 There is no statement of commitment to complying with the spirit of - Major the RSPO for all companies within the company structure. 2.2.3 There is no time bound plan in place for the certification for all - Major subsidiaries, estates and mills. 2.2.4 No applicable membership of the RSPO. - Major

2.3 Summary of the Time Bound Plan Section Requirement Findings and any action required Compliance 2.3.1 Does the plan New inclusion of supply base and mill has been updated in Yes include all below time bound plan. subsidiaries, estates and mills? 2.3.2 Is the time bound Existing time bound plan has been included with new supply Yes RSPOPC-SUM-REPORT.F01 JULY2013 Page 7 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

plan challenging? base and mill.  Age of plantations.  Location.  Mill development.  Infrastructure.  Compliance with applicable law. 2.3.3 Have there been The time bound plan reviewed by CUC and changes such as new Yes any changes since inclusion is updated and accepted. the last audit? Are they justified? 2.3.4 If there have been New inclusion of mill and supply base. No changes on the Yes changes, what targeted time line. circumstances have occurred? 2.3.5 Have there been  Recent stakeholder comment on acquired land in Papua Yes any stakeholder New Guinea on the credibility on land obtained has been comments? raised by OCEAN-Program Officer Collingwood Bay Community Representative, Mr. Adelbert Gangai has sent comments to KLK on a letter dated 5th December 2013 and kept RSPO & other parties in copy. Currently, KLK has leased a piece of a land to park all the machineries temporarily. As of 09 December 2013, this matter is being handled with RSPO and currently KLK is in progress to reply to RSPO. Wild Asia had been appointed since April 2013 to undertake SEIA assessment and subsequently 1st meeting at Wanigela district on 25th Nov 2013 and community and representative attended was recorded. Pending official assessment report.  On PT Menteng Jaya Sawit Perdana IUP for 7,400Ha approval no: 525.26/153/II/EKBANG/2007 dated on 13 February 2007 and Izin Lokasi(IL) is renewed and documented no: 188.45/359/HUK-BPN/2013 dated: 1st August 2013 which includes an approval clause 1a that this IL will remain in force until land swap process is finalised. 2.3.6 Have there been No new acquisition other than Papua New Guinea. Yes any newly acquired subsidiaries? 2.3.7 Have there been No lapses. Yes any isolated lapses in the implementation of the plan? 2.3.8 Has there been any No. Yes systematic failure to proceed with the implementation of the plan? 2.3.9 General statement The target to certify all the units within year 2015 remain same. Yes as to progress made since the last audit? RSPOPC-SUM-REPORT.F01 JULY2013 Page 8 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

2.4 Un-Certified Units or Holdings NOTE: Companies may demonstrate compliance by clear evidence of a self-audit (i.e. an internal audit for all subsidiaries, estates and Palm Oil Mills) Section Requirement Findings and any action required Compliance 2.4.1 Did the company The internal control points have included all the requirements to Yes conduct an internal validate the compliance against uncertified units or holdings as audit? If so, has a per partial requirements and assurance statement has been positive assurance generated by KLK has a list of subsidiaries inspected and dated statement been 30th Nov 2013. produced? 2.4.2 No replacement The company has conducted HCV assessment by Jump Yes after dates defined Consulting in January – February 2012 for all subsidiaries where in NIs Criterion 7.3 the assessment report confirms that there was no replacement of: of primary forest or containing HCV. The new mills and newly  Primary acquired land are still under consultant preliminary report. forest.  Any area identified as containing High Conservation Values (HCVs).  Any area required to maintain or enhance HCVs in accordance with RSPO criterion 7.3. 2.4.3 Any new plantings PT Anugerah Surya Mandiri has undergone NPP and published in Yes since January 1st RSPO website on 1st April 2013. 2010 must comply with the RSPO New Plantings Procedure. 2.4.4 Any Land conflicts For PT Karya Makmur Abadi, a total land of 4,745.13Ha has been Yes are being resolved compensated. PT Adei Plantation land conflicts around 2,544Ha through a mutually are still in progress of negotiation. agreed process, e.g. RSPO Grievance procedure or Dispute Settlement Facility, in accordance with RSPO criteria 6.4, 7.5 and 7.6. 2.4.5 Any Labor disputes None noted. No stakeholder comments or complaints received Yes are being resolved through a mutually agreed process, in accordance with RSPO criterion 6.3. 2.4.6 Any Legal non- None noted. No stakeholder comments or complaints received. Yes

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

compliance is being resolved in accordance with the legal requirements, with reference to RSPO criteria 2.1 and 2.2.

TIME BOUNDP PLAN FORECAST FOR RSPO CERTIFICATION OF ALL PALM OIL MILLS & SUPPLY BASES

Supply Bases (estates, Targeted RSPO Current Certification Palm Oil Mill Country plantations, associations) Certification Year Status as per this Audit Pelam Estate Serdang, Batu Lintang Estate Batu Lintang Kedah, 2013 Certified Subur Estate Malaysia Buntar Estate Landak Estate Kekayaan Estate Voules Estate Sg Penggeli Estate Paloh, Johor, New Pogoh Estate Kekayaan Oct 2011 Certified Malaysia Fraser Estate Paloh Estate Sg Bekok Estate Ban Heng Estate See Sun Estate Paloh, Johor, Supply base consisting of Paloh 2015 Pending Malaysia smallholders Ayer Hitam Estate Batang Jelai Estate Jeram Padang Estate Bahau, Negeri Kombok Estate Jeram Padang Sembilan, Ulu Pedas Estate Sept 2012 Certified Malaysia Sg Pertanian Estate Sg Kawang Estate Renjok Estate Tuan Estate Tanjung Changkat Asa Estate Tanjung Malim Malim, Perak, Kerling Estate 2013 Certified Malaysia Sg Gapi Estate Sungai Buloh, Tuan Mee Selangor, Tuan Mee Estate 2013 Certified Malaysia Kerilla Estate Kuala Krai, Pasir Gajah Estate Kuala Pertang Kelantan, By 2013 Pending Sg Sokor Estate Malaysia

100% independent Tawau, smallholders, not to be Mill 1 Sabah, N/A N/A included in the scope of Malaysia the certification Tawau, Pang Burong Estate Mill 2 Sabah, Sri Kunak Estate March 2009 Certified Malaysia Tundong Estate RSPOPC-SUM-REPORT.F01 JULY2013 Page 10 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Ringlet Estate Jatika Estate Tawau, Sigalong Estate Pinang Sabah, March 2009 Certified Pangeran Estate Malaysia Pinang Estate Lahad Datu, Tungku Estate Lungmanis Sabah, Bukit Tabin Estate July 2010 Certified Malaysia Lungmanis Estate Lahad Datu, Rimmer Estate Rimmer Sabah, July 2010 Certified Sg. Sibalukan Malaysia Kinabatangan, Bornion Estate Bornion Sabah, July 2010 Certified Segar Usaha Estate Malaysia Lekir Estate Changkat Chermin Estate Manjung. Raja Hitam Estate Changkat Perak, Glenealy Estate 2013 Certified Chermin Malaysia Serapoh Estate Kuala Kangsar Estate Allagar Estate Kebun Malindomas Berau, Kaltim, Perkebunan, Kebun Hutan Berau 1 By 2014 Pending Indonesia Hijau Mas, Kebun Jabontara Ekakarsa Steelindo Belitung, Kebun Steelindo Wahana Audited on 30/9- Wahana By 2013 Indonesia Perkasa 04/10/2013. Pending. Perkasa Kebun Parit Sembada Belitung, Parit Sembada Kebun Alam Karya By 2014 Pending Indonesia Sejahtera Riau, Mandau Sumatera, Kebun Mandau Oct 2012 Certified Indonesia Riau, Approved by RSPO, Nilo 1 Sumatera, Kebun Nilo Timur By 2013 pending certificate Indonesia issuance. Riau, Approved by RSPO, NIlo 2 Sumatera, Kebun Nilo Barat By 2013 pending certificate Indonesia issuance. Riau, Kebun Sekarbumi Tapung Kanan Sumatera, By 2013 Certified. Alamlestari Indonesia Langkat, Kebun Basilam Sumatera Kebun Gohor Lama Gohor Lama By 2014 Pending Utara, Kebun Tanjung Beringin Indonesia (New inclusion) Kebun Padang Brahrang Kebun Bukit Lawang Sumatera Padang Kebun Tanjung Keliling Utara, By 2014 Pending Brahrang Kebun Bekiun Indonesia Kebun Maryke (New Inclusion) MAP March Kalimantan Kebun Karya Makmur By 2015 Pending RSPOPC-SUM-REPORT.F01 JULY2013 Page 11 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

2013 tengah, Abadi Indonesia Kebun MAP Kebun Menteng Jaya Sawit Perdana With reference to time bound plan, the following issues were reviewed openly with the Control Union audit team during the assessment and which may be in conflict with the rules for partial certification, if applicable Name of Mill or Plantation *Area of concern (See examples below) N/A N/A Include any known concerns, media reports and major issues both present and from the past covering, for example:  Replacement of primary forest or any area containing HCV’s since November 2005.  Evidence of non-compliance with the law  Legal issues  Compensation payments  Social relations  Burning  Labor disputes

2.5 Summary of the findings for Partial Certification The audit team assessed compliance with the above requirements during this audit. Failure to address any non- compliance identified may lead to certification suspension. Overall findings are satisfactory and a minor non-compliance raised has been closed with an assurance statement. The 6 estates which have been excluded from time bound plan previously is included now with a target date. Out of the two mill in Kalimantan Timur, a new palm oil mill named Berau 2 POM is yet to commission. Stabat POM in Medan & KMA POM in Sampit has not commissioned and will be included in the time bound plan once ready.

The company has also made decision to include Paloh Mill into certification by year 2015. Mill 1 which consists of 100% of independent smallholders will be shut down within 3 years from 2012.

For final conclusion, please refer to table 3.1.

2.6 Partial Certification Audit Agenda Date Location Agenda 26.5.2014 Kekayaan POM Documentation review

PART 3: AUDIT PROCESS

3.1 About the Certification Body Control Union Certifications is a member of the Control Union World Group – an international inspection and certification body. CUC performs Audits and certification in many agricultural based fields such as FSC, RSPO, and Organic production, Sustainable Textile Production, Organic Exchange, GLOBALGAP, HACCP, BRC, GMP and GTP.

CUC is accredited by the Dutch Council of Accreditation (RVA) on the European quality standard EN 45011 for the inspection and certification of CUC Organic program (according to the EU regulation 2092/91) and EUREPGAP program. When requested a copy of the accreditation certificate can be obtained from CUC.

3.2 Audit Team Lead auditor: Simon Selvaraj Subramaniam Team member 1: Selvanathan Grapragasem Team member 2: Muhd. Jamalul Arif RSPOPC-SUM-REPORT.F01 JULY2013 Page 12 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Team member 3: Mahaswaran Maliyapan Team member 4: Jaruwat Boonrod

3.2.1 Qualifications of the Lead Auditor Requirement Qualifications A minimum of post high school (post-secondary Post graduate qualification in agriculture with more than school) training in either agriculture/forestry, 5 years working experience in plantation. environmental science or social sciences; At least 5 years professional experience in area of More than 5 years working experience in plantation. work relevant to the assessment (e.g., palm oil Involved in RSPO auditing since November 2010. Fully management; agriculture/forestry; ecology; social trained in similar agriculture certification programs such science); as RSPO SCCS, Global Gap, ISCC and GMP. Training in the practical application of the RSPO Involved in RSPO assessment since November 2010. criteria, and RSPO certification systems; Member of CUC RSPO audit team. Involved in audits conducted in Malaysia and Indonesia. Successfully completion of an ISO 9000:19011 lead Completed ISO 9001:2008 lead auditor course in July auditors course; 2011. Successfully completed RSPO Lead Auditor Course Training in the practical application of RSPO Post graduate qualification in agriculture with more than certification systems. 5 years working experience in plantation. A supervised period of training in practical auditing Involved in RSPO assessment since November 2010. against the RSPO criteria or similar sustainability Member of CUC RSPO audit team. Involved in audits standards, with a minimum of 15 days audit conducted in Malaysia and Indonesia. experience and at least 3 audits at different organizations. RSPO endorsed lead auditors course. Completed RSPO Lead Auditor training in 2011 Signed code of conduct. Signed with CUC General knowledge of:  RSPO P&C standards. Sound knowledge of the P&Cs, Nis and Local Interpretations.  CUC organizational structure. Sound understanding and has prepared training documents for others.  CUC quality systems. Sound understanding and has prepared training documents for others.  Lead auditor role. ISO 9001. Prepared an ISO 19011 training course and conducts internal training on auditing techniques.  Report writing. Extensive experience in report writing.  Stakeholder consultation. The process and need for this is fully understood.  Certification decision process. Full understanding.  RSPO SCCS program manual. Full understanding.  CUC filing systems. Full understanding.  Correct use of RSPO trademarks. Full understanding.  History and objectives of RSPO. Full understanding.  CV available. Upon request. Completion of CUC RSPO lead auditor training. Completed & Passed RSPO Lead Auditor training in 2011

3.2.2 Qualifications of the Assessment Team RSPO Requirement Team Member Name Qualifications

Fluent in main local Selvanathan Grapragasem Fluent in both English and Bahasa Malaysia languages and English. Muhd. Jamalul Arif Fluent in both English and Bahasa Malaysia Jaruwat Boonrod Fluent in English. Has understanding of Bahasa Malaysia Mahaswaran Maliyapan Fluent in both English and Bahasa Malaysia

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Field working Selvanathan Grapragasem SA 8000 advanced auditor, QMS, EMS & OHSAS experience in the palm Lead Auditor, Working experience in oil palm oil sector, or a plantation. demonstrable Muhd. Jamalul Arif Involved in RSPO auditing since November 2010. equivalent. Auditing experience in GMP and Globalgap. Jaruwat Boonrod Working in Quality laboratory for produce minimal process vegetable and fresh fruit for control fruits shelf life. Mahaswaran Maliyapan Certified ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007 Lead Auditor. More than 15 years of working experience in various industries.

Good agricultural Selvanathan Grapragasem SA 8000 advanced auditor, QMS, EMS & OHSAS practices (GAP), Lead Auditor, Working experience in oil palm integrated pest plantation. management (IPM), Muhd. Jamalul Arif Involved in RSPO auditing since November 2010. pesticide and fertilizer Auditing experience in GMP and Globalgap. use. Jaruwat Boonrod Performed audit observation of GMP+FSA, USDA-NOP and EU organic, Global-GAP standard. Mahaswaran Maliyapan Fully trained in similar agriculture certification programmes such as RSPO, SCCS and RFS2.

Health and Safety Selvanathan Grapragasem SA 8000 advanced auditor, QMS, EMS & OHSAS auditing on the farm Lead Auditor, Working experience in oil palm and in processing plantation. facilities. (For example Muhd. Jamalul Arif Involved in RSPO auditing since November 2010. OHSAS 18001 or Auditing experience in GMP and Globalgap. occupational. Health Jaruwat Boonrod and safety assurance Certified Lead Auditor for ISO 9001 and ISO system). 14001. Mahaswaran Maliyapan Certified ISO 14001:2004 and OHSAS 18001:2007 Lead Auditor.

Workers welfare issues Selvanathan Grapragasem SA 8000 advanced auditor, QMS, EMS & OHSAS and social auditing Lead Auditor, Working experience in oil palm experience. (For plantation. example with SA8000 or Muhd. Jamalul Arif Involved in RSPO auditing since November 2010. related social or ethical Auditing experience in GMP and Globalgap. accountability codes). Jaruwat Boonrod Nil Mahaswaran Maliyapan Involved in RSPO assessment since 2012. Member of CUC RSPO audit team. Involved in audits conducted in Malaysia and Indonesia.

Environmental and Selvanathan Grapragasem SA 8000 advanced auditor, QMS, EMS & OHSAS ecological auditing. (For Lead Auditor, Working experience in oil palm example experience plantation. with organic agriculture, Muhd. Jamalul Arif Involved in RSPO auditing since November 2010. ISO 14001 or Auditing experience in GMP and Globalgap.

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

environmental Jaruwat Boonrod Certified Lead Auditor for ISO 9001 and ISO management systems). 14001. Mahaswaran Maliyapan Certified ISO 14001:2004 and OHSAS 18001:2007 Lead Auditor.

Economic issues. Mahaswaran Involved in RSPO assessment since 2012. Member of CUC RSPO audit team. Involved in audits conducted in Malaysia and Indonesia. Selvanathan SA 8000 advanced auditor, QMS, EMS & OHSAS Lead Auditor, Working experience in oil palm plantation.

3.3 Audit Methodology 3.3.1 General Overview The Audit was carried out in conformity with the procedures as laid down in the CUC Procedure Manual and the RSPO Program Manual for the auditors and Certifier. During the Audit the qualified CUC auditors used the RSPO standard as endorsed for the country in which the audit took place and recorded their findings.

Workers and local communities were interviewed and evidence sought to confirm ongoing compliance to include:  Chemical stores. Storage, MSDS leaflets, Herbicide mixing areas, PPE, Ventilation, Security.  Field inspections. Herbicide application programs. Harvesting sites and efficiency. Fertilizing operations. SOP’s. Soil maps. Land preparation. Ground cover. IPM. First aiders and boxes. Ground cover. Soil erosion. Field observations of all operations.  Worker interviews. OSH. Sexual, religious, racial harassment. Pay and contracts. Child labor. First aid. Awareness.  Re-planting sites. Zero burn.  HCV’s. Identification. Management plans. Environmental Impact Assessments. Implementation.  Riparian zones. Width. Current and future management. Non maintenance regimes.  Water management. Water courses. Water monitoring.  Road maintenance. Run off.  Social amenities. Social Impact Audits.  Local communities. Contributions made. Employment opportunities. Social impacts. Complaints procedures.  Workshops. Oil traps. Safe working environment. PPE. Diesel tanks. Environmental waste management.  Line sites. Interviews with householders. Inspection of water discharge points. Water improvement plans. Waste disposal.  Documentation review.

The Palm Oil Mill audit verification included the following activities:  Mill and workshop inspections. Documentation review & worker interviews.  Mill. SOP’s. Safe working environment. Gen sets. Walk ways. Signs. EFB. POME treatment. Emissions. Mass balance. Diesel tanks. PPE. Fire extinguishers. First aiders and boxes. Fuel and water usage.  OSH. Training. Management structure. First aiders.  Full document review. Completion of the checklist. Review and documentation of evidence. All aspects of RSPO P&C’s applicable.  Worker interviews. OSH. Sexual, religious, racial harassment. Pay and contracts.  Compliance against the RSPO SCCS certification scheme.

Verification: Verification of implementation was done through field observations, workshop and chemical store inspections, worker and community interviews and mill inspections as summarized above.

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

3.3.2 Assessment agenda for this Audit Date Location Auditors Main activities 08.30 Opening meeting Chaired by the audit team leader Kekayaan  Introduction by team leader Training Simon  Presentation by respective managers Centre  Presentation of Palm Oil Mill source of FFB by respective managers 26/05/2014 Mill inspection [Mon] Selva  Workshops Jamal  Stores Jaruwat  Kekayaan Nur Atiqah POM application POM  Document review

Mahas Supply Chain Certification Assessment of the POM (RSPO SCCS) Field operations.  Worker interviews  Chemical stores Selva  Workshops 27/05/2014 Kekayaan Jamal Jaruwat  Housing [Tue] Estate Nur Atiqah  Medical Mahas  Schools  Local communities  Environmental Field operations. Mahas New Pogoh  Worker interviews Jaruwat  Chemical stores Estate Nur Atiqah  Workshops

28/05/2014  Housing [Wed]  Medical Ban Heng Selva  Schools Estate Jamal  Local communities  Environmental KLKEO Simon RSPO SCC

Field operations.  Worker interviews Selva  Chemical stores Jamal 29/05/2014 Sg Pengeli Jaruwat  Workshops [Thu] Estate Nur Atiqah  Housing Mahas  Medical  Schools  Local communities  Environmental

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Preparation for closing meeting Additional field visits and meetings with managers as necessary Closing meeting Kekayaan Chaired by the audit team leader 30/05/2014 All Training  Welcome and introduction by the team leader [Fri] auditors Centre  Presentation of findings by the audit team  Questions and answers  Final summary by team leader End of assessment

PART 4 ASSESSMENT FINDINGS

4.1 Lead Assessor’s Summary and Recommendation for Certification The mill and supply bases visited (as per the above Tables 1.5 and 1.7.1) and were assessed at field, office, facilities, stores and a document review was carried out in accordance to the RSPO principles and criteria. The subscribed RSPO management system’s documentations seen with minor changes that due to internal external influenced factors that in relation to scope of certification. Specific evidence was recorded for estates and mill. Interviews with Estate Managers, Mill Manager, members of workers union and committee took place in both formal and informal environments and worker interviews were conducted at the supply base and the mill. The management is highly committed in maintaining the RSPO system by adopting to continuous improvement programs.

There was no complaint or feedback received during the audit or during the field assessment when interviewing with the external stakeholders. Under partial certification rules, there is a time-bound plan established. For further clarification on Partial Certification, see PART 2 above.

The management continually monitoring the established KPI / objectives that significantly rules the achievement of company’s corporate policy on RSPO. The mill is fully verified for RSPO SCCS system verification and it is found to be in full compliance. See PART 5 below. It is therefore the recommendation of the lead assessor that:

 A certificate of compliance is maintained.

Signed:

Name: Simon Selvaraj Subramaniam Date: 30/05/2014

4.2 Summary of the findings by Principles and Criteria  Over the 5 year period of the life of the certificate, there will be 4 annual surveillance audits  Identified Non-Conformities and noteworthy Positive and Negative Observations.  The RSPO require that this report contain findings by each principle and some example criteria. Please see table below.

Principle 1: Commitment to Transparency Criterion by Requests made by stakeholder were responded to and all these are well Audit documented. Relevant documents are made publicly available. Adequate Summary information in the requests and responses logbook and the other with regards to some confidential information being listed as publicly available. ASA3 1.1 The mill and estates all have a Request and Responses logbook that records all requests made and the corresponding action that was taken. Records are

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

maintained and it details the date of request, person who made the request and what was the nature of the request. Record of action that has been taken to fulfill the request and acknowledgement by the person who made the request and an estate or mill executive is also recorded in the logbook. Stakeholder logbook is open for any stakeholders are in place. Request & Response used through Stakeholder Engagement form. Retention for 10 years sighted recorded in Master list of Documents issued 1.6.2012 ASA3 1.2 The following documents were made publicly available in the mill and estate offices:  Land titles / user rights  Safety and health plan  Plans and impact assessments relating to environmental and social impacts  Pollution prevention plans  Details of complaints and grievances  Negotiation procedures  Continuous improvement plan All these documents were sighted in the mill and estate offices. All requests for documents through the estate or mill offices will have to go through the mill or estate managers. They will make the decision as to whether the information can be shared to or viewed by the person requesting the information or document. The RSPO Master List of Documents stipulates the documents that can be made publicly available and documents that should be kept confidential. Principle 2: Compliance with Applicable Laws and Regulations Criterion by The mill and estates have demonstrated compliance to all applicable local, Audit national and international laws. Legal ownership of land and its land use is Summary clearly demonstrated through the respective land titles. Boundaries have been clearly demarcated. There have been no land disputes or claims involving the mill and estates. ASA3 2.1 The mill and estates have a register of all applicable laws and regulations and this includes among others:  OSHA and regulations 1994 (Act 514)  Factories and Machinery Act with regulations (Act 139)  Pesticides Act and Regulations (Act 149)  Poison Act and Regulations 1952 (Act 366)  Malaysia Palm Oil Board (MPOB) Regulations  Employees Provident Fund Act 1991  Employment Act 1955

All applicable permits and licenses for the mill and estates are clearly displayed in the respective offices. Records of expiry of these permits and licenses are kept in the office and monitored through Licenses Renewal Monitoring Record to ensure that they are renewed well before the expiry dates to ensure no lapses in the compliance to Malaysian government laws and regulations. The person responsible for monitoring the compliance to applicable laws and regulations are the respective estate and mill managers. They are also responsible for the tracking of the changes in the laws and regulations. All operating units will also receive an official letter from the Personnel and Administration Department informing them regarding any changes or amendments in laws and regulations from time to time. Among the changes in the law is the implementation of the new minimum wage for RSPOPC-SUM-REPORT.F01 JULY2013 Page 18 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

plantations workers and it was determined through document review and interviews that these changes have been fully implemented in all estates and mills. ASA3 2.2 The mill and estates have demonstrated legal ownership of their land by having legal land titles to the land. All land titles demonstrate the right to use the land and clearly mentions the fact that the land is to be used for palm oil cultivation only. The land titles are kept in the estate office and were sighted during the audit. Evidence of annual payment of land tax to the state government is available in the form of receipts. The estate boundary is well demarcated with boundary stones surrounding the land. The boundary stone clearly states the GPS coordinate of that particular point. Maps clearly showing the estate boundary were also sighted in the estate office. ASA3 2.3 There is no customary land in or surrounding all the estates. There are also no land disputes or claims involving these estates. Principle 3: Commitment to Long-Term Economic and Financial Viability Criterion by The annual budget and 2 years projections for the mill and estate that details Audit Summary revenue and costs are available. Replanting programme for the estates for the next five years is also available for estate with replanting activities. ASA3 3.1 Annual financial plan 2013/2014 & Estimate POM is available.

Year OER % FFB [mt] KER [mt]

2014 22.50 471,134 24,498

2015 22.50 446,368 23,212

There are 10 supply bases. Annual financial plan 2013/2014 & Estimate is available. For POM and its entire supply base. Sampled as:

Kekayaan New Pogoh Year Est [FFB] Est [FFB] 2014 119894 30479

2015 121332 31759

Principle 4: Use of Appropriate Best Practices by Growers and Millers Criterion by The mills and estates have a complete set of SOPs which is being strictly Audit adhered to and continuously monitored. Soil fertility is being maintained in the fields and erosion prevention is continuously carried out. IPM is being implemented in all the estates and the use of chemicals are in accordance Summary with the regulations. There is a comprehensive OSH policy and is being implemented throughout the estate and mill. Improvement sighted in the identification and assessment with HIRARC. Trainings are being carried out as per the Annual Training Plan. However recording of IPM activities lacking and Safety & Health plan is not updated effectively. ASA3 4.1 The mill has all its SOPs in place and these SOP covers all mill operations from FFB reception right until mill effluent treatment. These SOPs details the procedures to run each mill operation in an efficient and safe manner. The implementation of these SOPs is done through maintenance and record keeping of forms and data for, FFB incoming records, boiler smoke density records, sterilizer temperature and time records, steam flow record, water usage records, chemical test records, process control and production report and CPO stock inventory, spare parts inventory records and so on.

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The estates have the ‘Good Agricultural Practices’ which is their guide in ensuring efficient and optimal field operations. These SOPs cover all estate operations from nursery until delivery of FFB to the mill and includes among others land clearing, land conservation, distance of planting, field maintenance, pest control, fertilizer application and harvesting. All SOPs are reviewed periodically or when there is a new technique of operation being introduced, records and data are kept for a period of 10 years. ASA3 4.2 Soil surveys and foliar sampling were carried out by Applied Agriculture Resources Sdn Bhd. Latest recommendations for 2014 available. Records of these were sighted in the estate offices. Through these surveys and analysis, the optimum fertilizer to be used is recommended to cover the nutrient deficiencies that may exist for the palms. Application of EFB is also recommended to reduce the usage of inorganic fertilizers. Annual Fertilizer recommendation AA Resources: for Ban Heng Estate to apply 2.25 kg/palm of German kieserite to palms showing Mg deficiency symptoms. For 2013/2014 fertilizer programme, recommendation of higher fertilizer rates for palms planted on hilly terrains and hilltop. i.e 1PM2000A2 & 1PM2007A. Checks on the records of fertilizer application indicate the fertilizer application is done based on the recommendation of AAR. Soil maps such as the general soil map, slope classes map and elevation map are also available and were sighted. These maps are used to provide general recommendations for soil and water management practices and to identify solutions to overcome soil limitations including regeneration of ground covers and soft grasses. Stacking of cut fronds by spreading in and L shape configuration or placing across the slopes in hilly terrain will minimize surface run-off. Total Nitrogen is satisfactory. ASA3 4.3 Soil erosion is prevented through the following methods:  The planting of cover crops such as Mucuna bracteata and Pueraria javanica. The areas being planted with these cover crops are recorded in the monthly record books and marked on maps.  The presence of road maintenance programme. These road maintenance programme detail the type of road maintenance works to be carried out in each estate block and the cost involved in doing so. Budgets and actual expenditure for road maintenance works were sighted.  The application of EFB and frond stacking on slopes. This not only minimizes erosion but also enhances soil fertility. Control of soil erosion is in accordance with the guidance stipulated in SOP 8 – Erosion Control. Soil maps and topography maps that clearly state the elevation and types of soil are also available in the estate offices. No peat area identified in all the estates. ASA3 4.4 The estates have maintained the riparian buffer zones along rivers in accordance with the national and local regulations. - Ban Heng Estate has a water catchment for nursery use. Appropriate buffer zone was established according to the KLK’s SOP - No river crosses in all the estate. There are no bunds, weirs nor dams that have been constructed in the estates. Field visits to the estates confirmed this fact. Water management plan 2014 including subject, person responsible, detail, Target. Subjected to formulate environment policy , identification of water

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source, construction of water reservoir, protection of water courses and wetlands, monitoring of water quality and usage, piped water supply, emergency response plan. Monitoring of water quality and usage were carried out. Incoming and outgoing water quality be monitored on every 6 months and water is checked for microbial count annually. Water sampling points from 4 areas [ water pump, bulking tank-treated water, Line site wastewater & outlet drain Rainfall monitoring done on monthly basis. Documented water management plan updated January 2014. Each area of management (e.g. river banks, domestic waste water) has specific water management plan. Verified Department of Health visit report and has no comments were made.

ASA3 4.5 IPM plan is documented as per the Good Agricultural Practices which includes beneficial planting and the use of biological control as opposed to chemical control of pests. Planning and realization of IPM programmes were monitored by mapping the beneficial plant to be planted with types of plant. The plans are monitored by daily completion of planting, expressed in meter of plants planted. Trainings are given to all staff on IPM. There is no IPM plan available as the estate not infected with any pest but with very little / rare rat attacks. They used barn owls for control rat. The locations where barn owl cages are built are also mapped in each field and monitoring carried out by census where the it records the division, area size, block no, month erected, box no, type of owl(egg, immature, mature), box condition, condition around the box. The establishment of beneficial plants and barn owl breeding as measures to assist in the control of leaf pest and rat populations. Trainings are given to all staff on IPM. Pesticide toxicity units monitored by each active ingredient and it are calculated based on LD 50(Mg/Kg), chemical usage, total ai. Used, Ha planted, FFB produced, pesticide usage (L/Ha), L/ton and finally result shown in Pesticide toxicity units monitored (Kg/LD 50/FFB) by monthly and to date.. However, records for census for barn owl for Sg Pengeli Estate were not available. A minor non conformance was raised for this matter. An observation was issued in previous Assessment 2013. ASA3 4.6 The mill and estates maintain a chemical register detailing the chemicals use, its purpose and classification as per the classification, packaging and labeling requirements as per the Register of Chemicals Hazardous to Health stipulated in the USECHH 2000 regulations (regulation 5). All pesticides used are in accordance with the Pesticides Act 1974 (Act 149) and the relevant provision (Section 53A) and in accordance with USECHH Regulations (2000). Estate maintains the Standard operation procedure (SOP 2) for justification of agrichemicals used. Highly toxic agrochemicals (class 1) will be replaced by less toxic ones (class II, III & IV) such as Paraquat is replaced Glufosinate Ammonium and Glyphosate (class III). Rat bait 2nd generation (e.g Brodifacoum) as alternate for warfarin. Parquet usage has been stopped since 2008. The estates still use class 2, 3 and 4 chemicals namely Monocrotophos and Warfarin for trunk injection to counter bagworm attack and to counter rat attack respectively. These chemicals will only be used in the event that the threshold of infestation in a

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block exceeds 5%. These chemicals are stored separately in the chemical store. The chemical stores were found to be in good condition with the appropriate spillage traps filled with charcoal and empty bunch. First aid kits as well as shower and washing facilities are available. Annual medical surveillance as per CHRA dated 03-08-2012, Dr. Yasriza Bin Yahaya, JKKP HIE 127/171-(08), assessment date 29-1-12 was done for all the sprayers, manuring gang, storekeepers and mill laboratory workers. Medical surveillance records were sighted in the mill and estate offices. There are no pregnant workers who were handling pesticides in the estates. CHRA for the mill and estates were conducted and all recommendations of the CHRA were adhered to. The quantity of active ingredient of pesticides and herbicides used are recorded and are kept for at least 5 years. ASA3 4.7 Latest HIRADC is available dated on 12.4.2014. OSH plan for year 2014 established with 2 programs. Register of 30 Chemical Hazardous for Health available in DOSH given format. Annual machinery Inspection list attached with quarterly OSH inspection records. Verified DOSH visit log book for 2013. Licence renewal monitoring for machineries verified satisfactory. Contractors were given prior safety information on site. OSH policy has no changes since previous audit. Health and safety policy dated 10.1.2005. General safety practices are satisfactory. The HIRADC established based on process. Mitigation plans are associated in the HIRADC and training records sighted. First aid kit check list available with monthly monitoring records. The interval for OSH meeting is at minimum of once in 3 months. Latest meeting held on 4.2.2014 for New Pogoh Estate. Minute’s agenda are in accordance to DOSH requirements.

Since Jan 2013, there is neither incident nor accident recorded. The insurance coverage is done as group coverage, based on number of employees and not based on staff name or ID. There is “Workmen Compensation” headed letter available indicating the entire KLK workers being insured [Ban Heng Estate - Group insurance policy no. LWX/03320206/37/09/HHT by AXA Insurance for all workers under KLK Kekayaan Region. The insurance will renewable every year.] All local workers are covered with SOCSO insurance and proof of payment and claims in the event of an accident was sighted in the mill and estate office. The foreign workers are covered with Foreign Workers Compensation Scheme (FWCS) which is underwritten by AXA Insurance. The policy for the year 2014 was sighted and coverage was for all workers working in the mill and estates. However, Health and Safety plan for year 2014 not updated since ASA 2 for Kekayaan Estate, hence its effectiveness not monitored. A major non conformance was raised for this matter. ASA3 4.8 2014 training matrix are available. Training programme for 2014 is available including safety training of spraying, safety training on harvesting, driver safety training, safety training on manuring, CPR training, fire extinguisher, fire drill and emergency and accident procedures/first aid. Training record for year 2013; which mostly for OHS were completed and verified training records evidence for 2013 and 2014 which as below:

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

• Chemical Handling • 1st Aid training • PPE usage training Verification of training records against with employee list of 2013. Principle 5: Environmental Responsibility and Conservation of Natural Resources and Biodiversity Criterion by Environmental Impact Assessment has been carried out by the mill and Audit estates. A comprehensive identification of all waste has been recorded and disposal of scheduled waste has been carried out by an approved and registered collector. Monitoring and analysis of waste is carried out regularly. Summary Landfills were filled with biodegradable wastes. Assessment of all polluting activities is not covered all source of pollution. Still lacking schedule waste SW409 & SW410 in mill source of pollution document. Plan to reduce or minimize pollution not effectively carried out, a major non conformance were raised. ASA3 5.1 The mill and estates have conducted their Environmental Impacts Assessment (EIA) for 2014. Has established SOP-10.0 dated on 01/10/2013 with rev 01. Sighted the latest EIA dated on 24/04/14. EIA last reviewed by Manager`s. The EIA is sighted for “Medium” rating level of risk ranging from 5 - 20. The EIA details the environmental impacts of operations and new activities as well as plans to mitigate any negative impacts should there be any. The impacts from mill & estate operations, which covers land preparation and clearing (if any) right up till the delivery FFB to the mill and all mill operation is assessed through stakeholder consultation. The impacts from mill operations from reception of FFB in the mill right up till effluent treatment is also assessed in the similar way. ASA3 5.2 The HCV areas in the estate are indicated on the maps. The management and monitoring of HCV areas are done by the estate management. Signages for no hunting and trespassing are available at all HCV areas. In Kekayaan Estate has conserved 5.0 Ha of jungle area in the estate. ERT identification assessment based on IUCN Red List of Threatened Species identified ERT present in the estate area such as Butterflies (Amathusia phidippus, Appias libythea, Elymnias panther, Bird – Collared, kingfisher, Greater coucal & spotted dove, Mammals – Long tailed macaque, Malaysian field rat, Wild boar, lesser mouse deer, Malayan porcupine, plantain squirrel & musang pulut. Measures to maintain the ERT done by management with restricted of hunting in the identified area. Appropriate signages were sighted during site visit. ASA3 5.3 Waste and pollution mapping identifies domestic house hold wastes, agrochemical containers, used oil, battery, spoiled light, filter, clinical waste and so on. Office waste and factory waste is separated in glass, paper and plastic. Different waste bins are in place. All waste [general, laboratory and engineering] is identified, documented and waste is disposed of in the prescribed way. Verified the Jadual 2[notification to DOE], 5[inventory of schedule waste] & 6 [consignment note] with proper records maintained. All crop residues are being recycled by estates. The estates collect all the residues for fertilizer purposes. The scheduled wastes handling and storage is handled in accordance to the Scheduled Wastes regulations 2005. There are sufficient wastes collecting bins mill wide that enable employees to dispose the waste according to the label [glass, paper, plastic]. A logbook is used to record all wastes generated. Shell and fibers are recycled RSPOPC-SUM-REPORT.F01 JULY2013 Page 23 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

in the mill. Domestic waste goes to landfill. EFB is being sent to the estates for mulching. Decanter solids and POME are also being applied in the field. The recycle programme term into 3R where used PPE, waste paper and plastics being incorporated into mitigation plan. List of waste available and updated on April 2014. ASA3 5.4 Monitoring of energy usage per tonne of FFB processed was monitored by SOP 12.0 Waste Management & Energy Use issue/revision 2/0 dated on 01/03/2013. Data sighted for period Oct 2013 – March 2014 Month Diesel FFB Litre/MT usage processed Jan 31,755 37975.080 0.84 Feb 45,063 30831.030 1.46 Mar 66,467 32471.640 2.05 Mill has a documented plan to reduce the usage of the fossil fuel by Biogas Plant (Methane Capture) in next 2013/2014 budget. Plan is to replace the genset that consume more than 70% of diesel used in palm oil mill. ASA3 5.5 Kuala Lumpur Kepong Berhad has zero burning policy which explicitly prohibits open burning for land clearing or any other purpose whatsoever within plantation limits. There was no evidence that open burning takes place in the mill and estates, including in areas where replanting is taking place, and this was verified during the field visits. ASA3 5.6 Mill emissions source is identified at each operating station and the type and quantity of pollutants generated such as fibre, shell, scrap iron, EFB, effluent, schedule waste, waste oil from diesel tank, and emission from generator set, boiler ash and dust from the soot blower are well documented. Stack emissions analysis are done twice a year as per the Environmental Quality Act 1974 requirements and records of this were sighted in the mill. The effluent (POME) quantity is monitored on a daily and monthly basis and a summary is available and was sighted. However, assessment of all polluting activities is not covered all source of pollution. Still lacking schedule waste SW409 & SW410 in mill source of pollution document. Plan to reduce or minimize pollution not effectively carried out, a major non conformance were raised. Principle 6: Responsible Consideration of Employees and of Individuals and Communities by Growers and Millers Criterion by The mill and estates have conducted the social impact assessment in a Audit participative manner. A documented social impact assessment given was not presented. Assessment done with affected parties not evident. A timetable with responsibilities for mitigation and monitoring reviewed and updated as necessary not evident There was no evidence that participatory methods were used to conduct the SIA. A major non- conformance raised for this issue. The relevant policies are in place and are fully implemented across the board. Communication and consultation as well complaints and grievances Summary procedure are well communicated and adhered to. There are no evidence of workers been discriminated against in any way and all are being paid their fair wages. The workers quarters at estate were up to living standards. The gender committee lacking in addressing issues specific to women’s needs. A specific grievance mechanism is established. However; the main issue of sexual harassment, violent, breastfeeding and pregnant lady advises were not evident in women gender committee activities. No risk assessment carried out for works that will affect the pregnant lady. An observation was

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

issued on these 2 issues. Workers right and welfare evidently taken care. There is transparency in contract documents and CSR is well conducted. ASA3 6.1 The mill and estates have conducted their Social Impacts Assessment for 2013/14. However, a documented social impact assessment given was not presented. Assessment done with affected parties not evident. A timetable with responsibilities for mitigation and monitoring reviewed and updated as necessary not evident There was no evidence that participatory methods were used to conduct the SIA. A major non- conformance raised for this issue. ASA3 6.2 The mill and estates have a communication and consultation procedure in place and this was sighted in their respective offices. The procedure for communication and consultation is as follows:  Receipt of communication from the stakeholder by the nominated plantation management official.  Communication will be recorded and will be attended to and resolved within 30 days.  If the matter cannot be resolved within 30 days, all the related document will be send to the company secretary for further action.  The matter will be forwarded to the Grievances Executive Committee who will decide on the action to be taken.  Action that has been decided by the Executive Committee will be carried out and outcome of the resolution will be documented and stakeholder will be informed accordingly.  Should the outcome be not resolved to the mutual satisfaction of the stakeholder and the company, it will then be dealt with under the relevant provisions of the law. The nominated management official whom is responsible for handling matter pertaining to communication and consultation with stakeholders particularly external stakeholders are the estate and mill manager. A complete list of stakeholders covering mill and estate employees, contractors and suppliers, education and medical facilities and government agencies are available and was sighted in the mill and estate offices. ASA3 6.3 The mill and the estates have a complaints and grievances procedure that serves as the SOP for handling of complaints and grievances from both internal and external stakeholders. This procedure has been displayed in the offices and also on notice boards around the mill and estates. A complaint and grievances logbook is kept in every mill and estate and it contains the details of the complaints made, the complainant or aggrieved party, the action taken to resolved the complaint or grievance and the date the action was taken. All complaints and grievances were promptly attended to and records of this were sighted in the mill and estate offices. Workers who were interviewed confirmed that they are aware of the complaints and grievances procedure and how to channel their grievances. Complaint and Grievances record in Stakeholder Logbook was maintained. All complain were adhered and action was taken by responsible person and acknowledged to the complainer back. No grievance registered as per this audit period ASA3 6.4 There is no customary land surrounding the estates and there are no land disputes. No negotiations concerning compensation for loss of legal or customary rights are as per this assessment period [this land where the Mill & Estate stand s belongs to KL-Kepong ]. ASA3 6.5 Mill and estates workers are being paid wages in accordance with the Kadar

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Upah Pekerja Ladang (Wage Rates for Plantation Workers). Contract of service and salary slips for both local and foreign workers were checked and workers were paid the same amount of minimum wages which is currently RM 900/month. All wage rates, benefits and working conditions are stipulated in the contract of service of the workers. Salary slips clearly shows the calculations of gross salary, all deductions and net salary of a worker. Workers interviewed confirmed that they are being paid more than the stipulated minimum wage and that they understand all the deductions being made. All workers were also provided with adequate housing that exceeds the requirements of the Workers minimum Standards of Housing and Amenities Act 1990. Salary slips clearly shows the calculations of gross salary, all deductions and net salary of a worker. Workers interviewed confirmed that they are being paid more than the stipulated minimum wage and that they understand all the deductions being made. During the visit to line-site, all workers were also provided with adequate housing. Each unit of quarters will be occupied by a maximum of 2 workers per room; a 3 room quarters will house a maximum of 6 workers. All quarters are provided with electricity and treated water supply. Repairs to any damage in the quarters are done without any cost to the workers. Interview with workers have confirmed that they are indeed satisfied and comfortable with the quarters provided. Housekeeping, rubbish collector, mosque for the majority Muslim workers, kindergarten, crèche and basic maintenance. Medical facility is available. ASA3 6.6 The mill and estates adhere to the Kuala Lumpur Kepong Berhad Policy on The Freedom of Collective Association of Employees that recognizes and allows the freedom of association and collective bargaining of its employees. This policy is displayed in the mill and estates and has been communicated to all workers and staff. Mill and estate workers are free to bargain collectively by forming groupings on their own to collectively bargain with the management of the mill or estates. ASA3 6.7 Kuala Lumpur Kepong Berhad has a Child Employment Policy that prohibits under-aged children from working in the company. All mill and estate adhere to this policy. There are no children below ages of 18 working in the mill or estates and this was proven through the checking the list of employees as well as their bio-data and through field visits. ASA3 6.8 Kuala Lumpur Kepong Berhad has an Equal Opportunity policy dated 1 January 2008 and signed by the regional Director that is clearly displayed in the office and on the notice boards around the estates and mill. Both local and foreign workers enjoy the same scale of pay and provided with equal housing and work facilities. This was confirmed though interview with workers from both the mill and estates and also through verification of contracts of service and pay slips of workers. No evidence of discrimination based on race, skin color, religion, gender, national origin, ancestry, disability, marital status, and sexual orientation was found in both the mill and estates. ASA3 6.9 The Policy on Sexual Harassment, Violence and Reproductive Rights dated has been displayed at all estates and mill. This policy has also been communicated to all staff and workers and this was evident through the training records. Gender committees have been established in the mill and both the estates. A specific grievance mechanism for workers to voice their grievances with regards harassment of a sexual or violent nature has been established. RSPOPC-SUM-REPORT.F01 JULY2013 Page 26 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Under this mechanism, the aggrieved worker will lodge a complaint or grievance directly to the Chairperson of the Gender Committee and the chairperson will then bring this matter up with management of the estate or mill and this matter will be deliberated within closed doors in a meeting. Workers interviewed were aware of the policy against Sexual Harassment and Violence, the establishment of the gender committee at every operating unit and the specific grievance mechanism. However, The gender committee lacking in addressing issues specific to women’s needs. A specific grievance mechanism is established. However; the main issue of sexual harassment, violent, breastfeeding and pregnant lady advises were not evident in women gender committee activities. No risk assessment carried out for works that will affect the pregnant lady. An observation was issued on these 2 issues ASA3 6.10 Kekayaan mill only receives FFB from its own estates. As such there is no specific contract for the estates due to the fact that the estates will deliver 100% of its FFB to the mill. The prices of FFB paid to the estates is in accordance with the prices set by the Malaysian Palm Oil Board (MPOB) and the records of past and present prices of FFB, CPO and PK are kept by the Marketing Department. ASA3 6.11 The mill and estates are committed and have contributed to local development. The Response and Requests logbook and letters of contributions detailing the type, purpose and amount of contributions were sighted in all operating units. Amenities and Welfare column in the Indirect Cost Expenditure captures the expenses and Detailed Expenditure Estimates for Financial Year 2013/2014 estimates the CSR programmes in coming year Principle 7: Responsible Development of New Plantings Criterion by There were no new plantings carried out. Summary Audit ASA3 Summary There were no new plantings involving forest land. ASA3 7.1 Sighted the EIA and SIA covering the socio economy; culture and health of surrounding people who may be affected by plantation activities by company either from negative or positive impact. ASA3 7.2 There is no new land surveyed for the growing of oil palm. However there are sufficient SOPs available for the soil and land type that being implemented at all operating units. A general soil map, slope classes map and elevation map, to provide a general recommendation for soil and water management practices to overcome soil limitations are available. ASA3 7.3 Maps are available to show that land clearing avoided identified HCVs. There was no forest areas converted since November 2005. ASA3 7.4 The company has prepared soil maps. SOPs are in place to protect fragile and marginal soils. Terracing implemented above 15° as per the topographic map. Field inspection confirmed on the implementations. ASA3 7.5 SIAs and EIAs developed with participation form affected parties and include an analysis of both positive and negative impacts. ASA3 7.6 The company has a procedure to identify the people who may be entitled to receive compensation. Principle 8: Commitment to Continuous Improvement in Key Areas of Activity Criterion by All the operating units are regularly monitoring and review their activities and Audit develop and implement action plans that allow demonstrable continual Summary improvement in key operations such as in minimizing use of certain pesticides, environmental impacts, maximizing recycling and minimizing waste or by-products generation, pollution prevention plans. RSPOPC-SUM-REPORT.F01 JULY2013 Page 27 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

ASA3 8.1 The mill and estates have programmes in place to continually reduce their pesticide and herbicide usage, wastes generated and pollution. Wastes are also being converted into fertilizers such as EFB for EFB mulching in the field, old tires being used for land and garden beautification projects. Environmental and social impact assessments are conducted to ensure that negative environmental and social impacts are being reduced and mitigated.

4.3 Non-conformity Raised During this Audit and Any from the Previous Year, if applicable This section gives an over view of new or revised non-conformities raised during this audit and of action taken to close out non-conformities raised during the previous audits, if applicable  If a minor-non-conformity raised at the last audit, is not closed out, then this will be raised to Major status and the company given 60 days to close this out.  The NC number is comprised of 2 parts to include the year in which the NC was raised as well as a sequential number.

4.3.1 Non-Conformities Identified during this Audit 4 Non-Conformities Identified during this audit

NON CONFORMITY REPORT for NC identified during this ASA. NC number: 01/2014 Client name: KLK – Ladang Sg Pengeli Date raised: 29.5.2014 Major or Minor: Minor Raised by: Simon Aspect of standard : Indicators: 4.5.1 An IPM plan is recommended and current Evidence of non-conformity: No barn owl record.

Auditors signature:

Date: 29.5.2014 Proposed corrective action / improvement action by company.

Timeline for conformance: Before next surveillance Review of corrective /improvement action: Will be verified in next surveillance audit.

Assessors signature:

Date: 30.5.2014

NON CONFORMITY REPORT for NC identified during this ASA. NC number: 02/2014 Client name: Kekayaan Estate Date raised: 29.5.2014 Major or Minor: Major Raised by: Simon

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Aspect of standard: 4.7.1 A health and safety policy shall be in place. A health and safety plan covering all activities shall be documented and implemented, and its effectiveness monitored Evidence of non-conformity: Health and safety plan for year 2014 not updated since ASA 2 audit, hence its effectiveness not monitored.

Auditors signature:

Date: 29.5.2014 Proposed corrective action / improvement action by company.

Timeline for conformance: Before 30.8.2014 Review of corrective /improvement action: Will be verified in next surveillance audit.

Assessors signature:

Date: 30.5.2014

NON CONFORMITY REPORT for NC identified during this ASA. NC number: 03/2014 Client name: KLK Kekayaan POM Date raised: 29.5.2014 Major or Minor: Major Raised by: Simon Aspect of standard: 5.6.1 An assessment of all polluting activities shall be conducted, including gaseous emissions, Particulate/soot emissions and effluent (see Criterion 4.4). Evidence of non-conformity: Assessment of all polluting activities is not covered all source of pollution. Sighted still lacking schedule waste SW409 & SW410 in mill source of pollution document. Furthermore, and no plan to reduce or minimise.

Auditors signature:

Date: 29.5.2014 Proposed corrective action / improvement action by company.

Timeline for conformance: Before 30.8.2014 Review of corrective /improvement action: Will be verified in next surveillance audit.

Assessors signature:

Date: 30.5.2014

NON CONFORMITY REPORT for NC identified during this ASA. NC number: 04/2014 Client name: KLK Kekayaan Complex Date raised: 29.5.2014

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Major or Minor: Major Raised by: Simon Aspect of standard: 6.1 Aspects of plantation and miller management 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. Evidence of non-conformity: A documented social impact assessment given was not conducted as per the procedure SOP 13 as stated above. Assessment done with affected parties not evident. A timetable with responsibilities for mitigation and monitoring reviewed and updated as necessary not evident

Auditors signature:

Date: 29.5.2014 Proposed corrective action / improvement action by company.

Timeline for conformance: Before 30.8.2014 Review of corrective /improvement action: Will be verified in next surveillance audit.

Assessors signature:

Date: 30.5.2014

4.3.2 Non-Conformity Identified during the last ASA, not applicable for MA 5 Non-conformities identified for previous audit.

NON CONFORMITY REPORT NC number: 01 Client name: Kuala Lumpur Kepong Berhad Date raised: 5 July 2013 Major or Minor: Minor Raised by: Viknesvaran Paramasivan Aspect of standard: 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. This concerns management documents relating to environmental, social and legal issues that are relevant to compliance with RSPO Criteria. Documents that must be publicly available include, but are not necessarily limited to:- 1.2.1 Land titles / user rights (C 2.2) 1.2.2 Safety and health plan (C 4.7) 1.2.3 Plans and impact assessments relating to environmental and social impacts (C 5.1, 6.1, 7.1, 7.3) 1.2.4 Pollution prevention plans (C 5.6) 1.2.5 Details of complaints and grievances (C 6.3) 1.2.6 Negotiation procedures (C 6.4) 1.2.7 Continuous improvement plan (C 8.1) Evidence of non-conformity: Documents that needed to be publicly available were listed as confidential in the Master List of Documents. Auditors signature:

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Date: 05/07/2013 Proposed corrective action / improvement action by company. Review and revise the documents according to the commercial availability

Timeline for conformance: Before next surveillance Review of corrective /improvement action: Verified that the documents were listed either as confidential or publically available.

Assessors signature:

Date: 29.05.2014

NON CONFORMITY REPORT NC number: 02 Client name: Kuala Lumpur Kepong Berhad Date raised: 5 July 2013 Major or Minor: Minor Raised by: Viknesvaran Paramasivan Aspect of standard: Criterion: 4.6.10 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. Evidence of non-conformity: Calculations of active ingredient used/hectare were not done for pesticides used in Sungai Bekok estate. Auditors signature:

Date: 05/07/2013 Proposed corrective action / improvement action by company. To include calculations of active ingredient used/hectare in the pesticide records.

Timeline for conformance: Before next surveillance Review of corrective /improvement action: Verified that the calculations of active ingredient used/hectare were stated in the pesticide records.

Assessors signature:

Date: 29.05.2014

NON CONFORMITY REPORT NC number: 03 Client name: Kuala Lumpur Kepong Berhad Date raised: 5 July 2013 Major or Minor: Minor Raised by: Viknesvaran Paramasivan Aspect of standard: Criterion: 4.7.1[h] Workers trained in First Aid should be present in both field and mill operations. Evidence of non-conformity: There were no workers or staff trained in First Aid in the entire Sungai Bekok estate. Auditors signature:

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Date: 05/07/2013 Proposed corrective action / improvement action by company. To train workers or staff in First Aid

Timeline for conformance: Before next surveillance Review of corrective /improvement action: Sighted training records for First aid for Sungai Bekok Estate and in all the audited estate..

Assessors signature:

Date: 29.05.2014

NON CONFORMITY REPORT NC number: 04 Client name: Kuala Lumpur Kepong Berhad Date raised: 5 July 2013 Major or Minor: Minor Raised by: Viknesvaran Paramasivan Aspect of standard: Criterion: 5.3.2 Having identified wastes and pollutants, an operational plan should be developed and implemented, to avoid or reduce pollution. Evidence of non-conformity: In Sungai Bekok estate: 1) Used chemical containers were found in the landfill 2) Used chemical containers were stored in open ground. Many of it was not triple rinsed and punctured. 3) Scheduled waste labeling was incomplete. Scrap iron was also stored in the Scheduled Wastes store.

Auditors signature:

Date: 05/07/2013 Proposed corrective action / improvement action by company. Used chemical containers to be collected and send to registered Schedule Waste Collector, with triple rinsed and punctured. Scheduled waste labeling to complete. Scrap iron to be stored away.

Timeline for conformance: Before next surveillance Review of corrective /improvement action: Used chemical containers were collected and send to registered Schedule Waste Collector, with triple rinsed and punctured. Scheduled waste labeling sighted and Scrap iron was stored away. Assessors signature:

Date: 29.05.2014

NON CONFORMITY REPORT NC number: 05 Client name: Kuala Lumpur Kepong Berhad Date raised: 5 July 2013 Major or Minor: Minor Raised by: Viknesvaran Paramasivan Aspect of standard: Criterion: 6.1.2 RSPOPC-SUM-REPORT.F01 JULY2013 Page 32 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Evidence that the assessment has been done with the participation of affected parties. Evidence of non-conformity: A documented social impact assessment was not supported with adequate evidence of the process of conducting the assessment. Auditors signature:

Date: 05/07/2013 Proposed corrective action / improvement action by company. To document social impact assessment Timeline for conformance: Before next surveillance Review of corrective /improvement action: Sighted and verified SIA were lacking methodology of impact assessment. A major non-conformance was raised for this issue. Refer NC number 04/2014.

Assessors signature:

Date: 29.05.2014

4.3.3 Observations Identified during this audit

Observation OB -1 Client name: Kekayaan Complex Date raised: 29.5.2014 Raised by: Mr. Simon Aspect of standard: Indicator 6.9.1 A policy on sexual harassment and violence in the workplace and records of implementation.

No risk assessment carried out for works that will affect the pregnant lady

Assessors Signature Date 29.5.2014

Observation OB -2 Client name: Kekayaan Complex Date raised: 29.5.2014 Raised by: Mr. Simon Aspect of standard: Indicator 6.9.2 A specific grievance mechanism is established.

A specific grievance mechanism is established. However; the main issue of sexual harassment, violent, breastfeeding and pregnant lady advises were not evident in women gender committee activities

Assessors Signature Date 29.5.2014

4.4 Issues that were raised during the Stakeholder Consultation, if any Stakeholders were either informed by the client or by Control Union via the RSPO website.  For Main Assessments, a 30 day Stakeholder consultation announcement is published on the RSPO website prior to the audit. The same announcement is circulated by the client prior to the audit  For subsequent Annual Assessments, it is based on stakeholders reading the approved public summary

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

reports available on the RSPO website, the client’s procedures in receiving on-going feedback or if feedback was sent directly to Control Union prior to an audit or thorough RSPO complaints procedures. During each assessment, the audit team will review the company’s implemented procedures in receiving feedback and will execute field visits and interviews. Not limited to the following questions, any feedback received is reviewed and summarized in this summary report for either Part 2 – Partial Certification or Part 4 – Assessment Findings above or noted below, if applicable: 1. Do you have any remarks on the RSPO standard? 2. What is your relation with the applicant? 3. Are there any plantation or mill management practices that affect you? 4. Do you consider any management is in conflict with the RSPO principles and criteria? 5. Do you have any suggestions for management? 6. Are you aware of any HCV in the plantations or in adjacent land? 7. Are you aware of any endangered or rare species? 8. Are there any adverse (or positive) effects on local communities? 9. Additional comments? 11. Do you have any comments about the assessment team and would you like to meet with them? 12. Do you have any comments for the client’s management of any other plantations? Subject raised Company response and Audit team findings proposed action to be taken refer to PART 2 and PART 4 refer to PART 2 and PART 4 refer to PART 2 and PART 4

PART 5: RSPO SUPPLY CHAIN CERTIFICATION The palm mill mentioned in the scope of the audit was audited against the requirements of the following: RSPO Supply Chain Certification Systems. November 2011 RSPO Supply Chain Certification Standard. November 2011

5.1 POM Included In The Scope Of The Audit Name Mill Location Supply Chain Model Palm Oil Mill Capacity (POM) MT/Hour Address (IP or SG or MB) HS (D) 519 Block 5, Mukim Nyior, Kekayaan POM 120 IP 86609 Paloh, Kluang, Johor.

5.2 Projection Of The Company’s Summary Of Annual Certified Volume Of RSPO Certified Palm Oil And Palm Kernel Over A Specified Period Product CPO (MT) PK (MT) Specified 12 month period CU Code Forecasted volumes between May 2014 to April 2015. POM 1 103,396 24,439 See also 1.6 above.

5.3 Summary Report Including A Brief Description Of The Scope Of Certification A full RSPO SCCS certification audit was used during this annual assessment and the findings support the certification based on supply chain model listed above.

5.4 Monthly Records of Certified and Uncertified FFB Received Since the Last Audit If this is the 1st Main Assessment, the figures used are from the last 12 months. If this is an Annual Surveillance Assessment, the figures used are since the last audit. No MONTH-YEAR Certified Supply Bases (MT) Uncertified Supply Bases (MT), if Total (MT) any 1 May 2013 27033.090 - 27033.090 2 June 2013 30166.530 - 30166.530 RSPOPC-SUM-REPORT.F01 JULY2013 Page 34 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

3 July 2013 34866.560 - 34866.560 4 Aug. 2013 34701.040 - 34701.040 5 Sept. 2013 43673.990 - 43673.990 6 Oct. 2013 45612.310 - 45612.310 7 Nov. 2013 42276.080 - 42276.080 8 Dec. 2013 43554.470 - 43554.470 9 Jan. 2014 37975.080 - 37975.080 10 Feb. 2014 30831.030 - 30831.030 11 March 2014 32471.640 - 32471.640 12 April 2014 33257.150 - 33257.150 TOTAL 436418.970 - 436418.970

5.5 Monthly Records of Certified CPO and PK Produced Since the Last Audit If this is the 1st Main Assessment, the figures used are from the last 12 months. If this is an Annual Surveillance Assessment, the figures used are since the last audit. No MONTH-YEAR Certified CPO (MT) Certified PK Total (MT) 1 May 2013 5852.969 1301.868 7154.837 2 June 2013 6528.283 1521.582 8049.865 3 July 2013 7587.326 1703.962 9291.288 4 Aug. 2013 7415.285 1888.409 9303.694 5 Sept. 2013 9199.754 2227.774 11427.528 6 Oct. 2013 9942.941 2304.041 12246.982 7 Nov. 2013 9334.564 2209.206 11543.770 8 Dec. 2013 9291.401 2210.431 11501.832 9 Jan. 2014 8486.007 2039.050 10525.057 10 Feb. 2014 7169.211 1635.116 8804.327 11 March 2014 7105.137 1634.118 8739.255 12 April 2014 7319.799 1665.804 8985.603 TOTAL 95232.677 22341.361 117574.038

5.6 Records of Certified CPO & PK Sold under Green Palm to Buyers since the Last Audit, if Any If this is the 1st Main Assessment, the figures used are from the last 12 months. If this is an Annual Surveillance Assessment, the figures used are since the last audit. The transactions were sighted form the clients registered Green Palm Account. Certified CPO Certified PK No Buyers Name Green Palm Trading No (MT) Sold (MT) Sold 1 Nil

5.7 Records of Certified CPO & PK Sold under UTZ eTrace to Buyers since the Last Audit, if Any If this is the 1st Main Assessment, the figures used are from the last 12 months. If this is an Annual Surveillance Assessment, the figures used are since the last audit. The transactions were sighted form the clients registered UTZ eTrace Account. Certified CPO Certified PK No Buyers Name UTZ eTrace Trading No (MT) Sold (MT) Sold 1 Palmaju Edible Oil Sdn Bhd TR-a116d84d-7c8b 288.79 - 2 PGEO Edible Oils SDN BHD TR-505ac324-0645 61.58 - 3 Palmaju Edible Oil Sdn Bhd TR-25f5e740-7cde 99.34 - 4 Intercontinental Specialty Fats Sdn Bhd TR-ac140771-c52e 499.57 5 Intercontinental Specialty Fats Sdn Bhd TR-5690da01-d429 1503.39 6 Intercontinental Specialty Fats Sdn Bhd TR-94d11de6-44ee 998.61 7 Intercontinental Specialty Fats Sdn Bhd TR-43bb6a68-e680 999.77 8 PGEO Edible Oils SDN BHD TR-24393c7a-729e 400.00

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9 PGEO Edible Oils SDN BHD TR-21b48dfa-e665 198.73 10 Palmaju Edible Oil Sdn Bhd TR-177e67c7-9533 304.14 11 Palmaju Edible Oil Sdn Bhd TR-d9f24440-719c 294.40 12 Intercontinental Specialty Fats Sdn Bhd TR-8a80b398-79b1 507.61 13 Intercontinental Specialty Fats Sdn Bhd TR-677fcc5f-0a67 497.60 14 Intercontinental Specialty Fats Sdn Bhd TR-4277cb61-84e8 999.77 15 PGEO Edible Oils SDN BHD TR-6177b052-b9e9 150.100 16 Palmaju Edible Oil Sdn Bhd TR-38458b99-3991 170.130 17 Intercontinental Specialty Fats Sdn Bhd TR-090c2bc8-b8dd 987.560 18 Intercontinental Specialty Fats Sdn Bhd TR-138aa19d-bd08 994.580 19 Palmaju Edible Oil Sdn Bhd TR-73fab68f-e552 297.690 20 Intercontinental Specialty Fats Sdn Bhd TR-2df7c83f-01cc 500.00 21 Intercontinental Specialty Fats Sdn Bhd TR-5a5361f7-58ba 505.48 22 KL-Kepong Edible Oils Sdn. Bhd. TR-2edef7cb-932b 210.00 23 Intercontinental Specialty Fats Sdn Bhd TR-4b6819ee-f31e 996.170 24 Palmaju Edible Oil Sdn Bhd TR-a999eb70-b128 350.00 25 Palmaju Edible Oil Sdn Bhd TR-139f4cc8-9797 303.280 26 KL-Kepong Edible Oils Sdn. Bhd. TR-9c079afb-5613 423.930 27 PGEO Edible Oils SDN BHD TR-8960fa94-9dad 300.00 28 Intercontinental Specialty Fats Sdn Bhd TR-0ef2c780-93c0 1000.250 29 Intercontinental Specialty Fats Sdn Bhd TR-f941cf9a-e4b7 1017.400 30 Intercontinental Specialty Fats Sdn Bhd TR-68c5bc19-4df7 993.230 31 PGEO Edible Oils SDN BHD TR-dfa1b792-0a04 35.00 32 Intercontinental Specialty Fats Sdn Bhd TR-c01d69df-d4b2 993.710 33 Intercontinental Specialty Fats Sdn Bhd TR-8d253a2a-6664 988.950 34 PGEO Edible Oils SDN BHD TRd7834299-1de2 50.00 35 Palmaju Edible Oil Sdn Bhd TR5a7d7ebe-f5a3 100.00 36 PGEO Edible Oils SDN BHD TR-0ad993de-fe63 35.00 37 PGEO Edible Oils SDN BHD TR-767c3866-19a0 30.45 38 KL-Kepong Edible Oils Sdn. Bhd. TR-e2732bf5-cb59 506.65 39 PGEO Edible Oils SDN BHD TR-922ebc43-e03a 150.00 40 Intercontinental Specialty Fats Sdn Bhd TRf4a90072-00cf 986.72 41 Intercontinental Specialty Fats Sdn Bhd TR-5397020f-03fb 1016.56 42 PGEO Edible Oils SDN BHD TR-159a6d27-3187 207.75 43 Intercontinental Specialty Fats Sdn Bhd TRf95c0b9e-df84 1502.5902 44 Intercontinental Specialty Fats Sdn Bhd TRc09959e7-c837 984.990 45 KL-Kepong Edible Oils Sdn. Bhd. TR-352e003a-4a2f 499.950 46 PGEO Edible Oils SDN BHD TR-0b8fba2f-49a2 200.00 47 PGEO Edible Oils SDN BHD TR-10314ca6-fcc1 40.00 48 Intercontinental Specialty Fats Sdn Bhd TRea3d4a7c-534d 998.60 49 Intercontinental Specialty Fats Sdn Bhd TR-3b0cc3f7-4d67 1002.02 50 PGEO Edible Oils SDN BHD TR-68b4eb1c-e927 42.00 51 Intercontinental Specialty Fats Sdn Bhd TR-363f0388-c113 1013.97 52 Intercontinental Specialty Fats Sdn Bhd TRfc1d43ae-13d2 999.05 53 PGEO Edible Oils SDN BHD TR-1f56a2c5-4da8 100.290 54 IFFCO Sdn. Bhd. TR-4d7e755a-5053 508.87 55 PGEO Edible Oils SDN BHD TR-83e9b98c-9844 200.00 56 PGEO Edible Oils SDN BHD TR-199c6cac-6b30 200.00 57 Intercontinental Specialty Fats Sdn Bhd TRef7663fd-379e 1010.84 58 IFFCO Sdn. Bhd. TRc50be731-4cda 608.97 59 Intercontinental Specialty Fats Sdn Bhd TR-013c3dfb-9572 1018.26 60 Intercontinental Specialty Fats Sdn Bhd TR-2905f510-37df 986.10 61 Intercontinental Specialty Fats Sdn Bhd TR-1497de7f-5a16 1009.68 RSPOPC-SUM-REPORT.F01 JULY2013 Page 36 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

62 Intercontinental Specialty Fats Sdn Bhd TR-4588c67a-2b43 993.59 63 Palmaju Edible Oil Sdn Bhd TR-d05f39cf-69a2 300.00 64 Palmaju Edible Oil Sdn Bhd TR-e28c3482-7268 297.58 65 IFFCO Sdn. Bhd. TR-2e0019b8-7a08 1493.39 66 PGEO Edible Oils SDN BHD TR-5c0ff771-6858 26.17 67 PGEO Edible Oils SDN BHD TR-0da0f810-ff79 300.00 68 PGEO Edible Oils SDN BHD TR-56ebe72e-8e87 255.82 69 Palmaju Edible Oil Sdn Bhd TR-055b0912-03d6 199.54 70 IFFCO Sdn. Bhd. TR-b95363be-d669 1005.16 71 IOI Loders Croklaan Procurement TRe7628a38-12aa 1500.00 72 Intercontinental Specialty Fats Sdn Bhd TR-999b57ee-e0d4 994.66 73 IOI Loders Croklaan Procurement TRf3f1e083-1ae8 496.70 74 KL-Kepong Edible Oils Sdn. Bhd. TR-3f743046-0788 498.99 75 PGEO Edible Oils SDN BHD TR-3445ba13-7ee0 120.07 76 IFFCO Sdn. Bhd. TRc5f724d7-77f0 1001.92 77 Palmaju Edible Oil Sdn Bhd TR-64068fb0-35c9 600.00 78 Palmaju Edible Oil Sdn Bhd TR-4304263a-fe96 101.90 79 IOI Loders Croklaan Procurement TR-28f76321-05af 1000.00 80 IOI Loders Croklaan Procurement TR-6fee995b-6211 500.00 81 IOI Loders Croklaan Procurement TRada7da0f-0a27 494.30 82 Intercontinental Specialty Fats Sdn Bhd TR-874132ac-f3dc 993.58 83 PGEO Edible Oils SDN BHD TRf9af7591-ae3c 117.19 84 IOI Loders Croklaan Procurement TR-2f8b5734-beae 500.00 85 IOI Loders Croklaan Procurement TR-755c4bbf-4500 500.00 86 IOI Loders Croklaan Procurement TR-9c637b7a-297e 500.00 87 IOI Loders Croklaan Procurement TR-4ebbc310-e751 500.00 89 IOI Loders Croklaan Procurement TRaa3ad0c6-a8c9 500.00 90 IOI Loders Croklaan Procurement TR-161ad7d2-6578 500.00 91 IOI Loders Croklaan Procurement TR-4baac546-a916 299.09 92 Intercontinental Specialty Fats Sdn Bhd TR-13bf1cb0-22bc 990.37 93 Palmaju Edible Oil Sdn Bhd TRdd0f27cd-a251 299.67

5.8 Non-Conformities Identified during this Audit Timeline for compliance: 1. All non-conformances observed during an audit shall be classified as ‘major’ since all requirements for Supply Chain certification have to be met before granting certification. 2. For Main Assessments, all non-conformances shall be addressed satisfactorily by the operation before certification may be granted by the certification body. If non-conformances are not addressed within three (3) months of the audit, a full re-audit shall be required. The certification body shall assess the effectiveness of the corrective and/or preventive actions taken before closing out the non-conformances. 3. For Annual Surveillance Assessments, non-conformances raised after the certification are serious (i.e. must be considered as a major) and the integrity of the RSPO Supply Chain Certification is at risk. A maximum of one month is to be given to the certified client to satisfactorily address the non-conformance. The certification body shall assess the effectiveness of the corrective and/or or preventive actions taken. Should the nonconformance not be addressed within the one-month maximum timeframe, a suspension or withdrawal of the certificate and a full re-audit may be necessary. 4. If no non-conformances are observed at an audit or when the corrective action plan has satisfactorily addressed raised non-conformance(s), the client shall be recommended for (re-) certification. Non-were raised during this audit.

NC Number: NA

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Date: Reference to standard: Standard requirement: Evidence of non-compliance:

5.9 Description of the Organizational Management Systems Including organizations, management and operational systems to ensure compliance with the RSPO Supply Chain Certification Systems and Standards as detailed above Lungmanis palm oil mill and its supply bases were audited against RSPO SCCS. The mill processing capacity is 45 ton FFB per hour. The mill is capable of handling SG supply chain model. However, downgrading to a lesser supply chain model is done by internal system where linking of both FFB purchasing and weigh bridge were carried out automatically. 5.10 Final Certification decision by Control Union for the RSPO SCCS Audit of the POM Recommendations made: Yes Summary of non- None Found compliances: Certification status of client: The POM included in the scope of this audit demonstrated full compliance with the RSPO SCCS.

With effect from the certification date given in the RSPOPC certificate, this POM mentioned in the scope of this report is considered to be certified in accordance with the RSPO SCCS.

PART 6: CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY

6.1 Date of next ASA The provisional date for the next ASA is: May 2015

6.2 Date for Closure of Non-Conformities See sections above for details of NC’s, if any  All major NCs to be closed by: 60 days from the issuance date  All minor NCs to be closed by: Before next surveillance audit

6.3 Signing by the Client I the undersigned, being the most senior relevant management representative of the operation seeking or holding certification, agree with the contents and audit findings as presented in this document .

I also confirm:  Acceptance of liability in execution of the instructions given.  That this company was made aware that the findings of the audit team are tentative; pending review and decision making by the duly designated representatives of Control Union Certifications.  That during the closing meeting all agenda items was covered by the Lead Auditor.

Acknowledged by: Name: Sin Chuan Eng Position: Head of Sustainability Date: 30/05/2014 Signature

6.4 Signing by the Lead Auditor I the undersigned, being the Lead Auditor, confirm that this report is an accurate record of the findings and of the closing meeting. I further confirm that the summary of the findings as presented in this report are a true representation of the actual findings of the audit team.

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Acknowledged by: Name: Simon Selvaraj Subramaniam Position: Lead Auditor

Date: 30/05/2014 Signature

6.5 Signing by the Certifier I the undersigned, being the Certifier, confirm that the information and conclusions included in this report have been prepared in good faith and that the certification decision has been based upon this information. Acknowledged by: Name: Nurhadi Position: Ceritifer

Date: 22/07/2014 Signature

PART 7: APPENDICIES

Appendix 1: Location Map for this Certification Unit From 1.9, the location map(s)

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RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

Appendix 2: List of Abbreviations BRC British Retail Consortium BOD Biochemical oxygen demand CHRA Chemical Health Risk Assessment CoC Chain of Custody RSPOPC-SUM-REPORT.F01 JULY2013 Page 40 of 41 Control Union (Malaysia) Sdn. Bhd. 150-A, 1st Floor, Persiaran Raja Muda Musa, Off Jalan Sg Bertih, Teluk Gadong, 41100, Klang, Selangor. Malaysia. Tel: +603-3377 1600 / 1700

RSPO Principles & Criteria Annual Surveillance Assessment Report Report Number CU821295

COD Chemical oxygen demand CPO Crude Palm Oil CSR Corporate Social Responsibility CU Control Union CUC Control Union Certifications DOE Department of Environment DOSH Department of Safety and Health EFB Empty Fruit Bunch EIA Environment Impact Assessment ERT Endangered Rare or Threatened species EU European Union FFB Fresh Fruit Bunch FSC Forest Stewardship Council FSC COC Forest Stewardship Council Chain of Custody FSC FM Forest Stewardship Council Forest Management GGL Green Gold Label GMP Good Manufacturing Practice GOTS Global Organic Textile Standard GTP Good Trading Practice GPS Global Positioning System HACCP Hazard Analysis and Critical Control Point HIRARC Hazard Identification, Risk Assessment and Risk Control HCV High Conservation Value HCVF High Conservation Value Forest IPM Integrated Pest Management JAS Japanese Agricultural Standard LTI Lost Time Injury MDC MDC Publishers Sdn Bhd ( Company Name) MSDS Material Safety Data Sheet NC Non Conformity OE Organic Exchange OSH Occupational Safety and Health OSHAS Occupational Safety and Health Assessment Scheme P&C Principle and Criteria PEFC Programme for the Endorsement of Forest Certification PK Palm Kernel POME Palm Oil Mill Effluent PPE Personal Protective Equipment RSPO Roundtable on Sustainable Palm Oil RSPO NI Roundtable on Sustainable Palm Oil National Interpretation SA8000 Social Accountability 8000 Sdn Bhd Sendirian Berhad SIA Social Impact Assessment SOCSO Social Security Organization SOP Standard Operating Procedure USDA/NOP United States Department of Agriculture – National Organic Program MT Metric Tones WHO World Health Organization

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