FELDA GLOBAL VENTURES PLANTATION SDN BHD (FELDA PLANTATIONS SDN BHD)

RSPO Membership No: 100130400000

PLANTATION MANAGEMENT UNIT KKS Kalabakan grouping , , Malaysia

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296W)

Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 2 of 50 KKS Kalabakan grouping - Main Assessment

MAIN ASSESSMENT REPORT ON RSPO CERTIFICATION

FELDA GLOBAL VENTURES PLANTATION MALAYSIA SDN BHD (FELDA PLANTATIONS SDN BHD)

RSPO Membership No: 100130400000

PLANTATION MANAGEMENT UNIT KKS Kalabakan grouping Tawau, Sabah, Malaysia

Certificate No: RSPO 928888 Issued date: 7 October 2014 Expiry date: 6 October 2014

Assessment Type Assessment Dates Initial Certification (Main Assessment) 9 – 13 June 2014 Annual Surveillance Assessment (ASA01) Annual Surveillance Assessment (ASA02) Annual Surveillance Assessment (ASA03) Annual Surveillance Assessment (ASA04) ReCertification

Intertek Certification International Sdn Bhd (formerly known as Moody International Certification (Malaysia) Sdn Bhd) 6L1201, Level 12, Tower 2, Menara PGRM No. 6 & 8 Jalan Pudu Ulu, Cheras, 56100 Kuala Lumpur, Malaysia. Tel: +00 (603) 9283 9881 Fax: +00 (603) 9284 8187 Email: [email protected] Website: www.intertek.com

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TABLE OF CONTENTS

Section Content Page No 1.0 SCOPE OF MAIN ASSESSMENT 4 1.1 Introduction 4 1.2 Location (address, GPS and map) mill, estates and hectarage 4 1.3 Description of supply base (fruit sources) 4 1.4 Year of plantings and cycle 5 1.5 Summary of Land Use – Conservation and HCV Areas 6 1.6 Other certifications held and Use of RSPO Trademarks 6 1.7 Organizational information/contact person 6 1.8 Tonnages Verified for Certification 7 1.9 Time Bound Plan 8 1.10 Abbreviations Used 9 2.0 ASSESSMENT PROCESS 10 2.1 Assessment Methodology, Plan & Site Visits 10 2.2 Date of next scheduled visit 10 2.3 Qualifications of the Lead Assessor and Assessment Team 10 2.4 Certification Body 10 2.5 Process of Stakeholder consultation 1112 3.0 ASSESSMENT FINDINGS 13 3.1 Summary of findings 13~43 3.2 Status of Identified Noncompliance and Corrective Actions, Observations and 4347 Identified Positive Elements 3.3 Summary of Feedback Received from Stakeholders and Findings 4748 4.0 ASSESSMENT CONCLUSION AND RECOMMENDATION 49 4.1 Acknowledgement of Internal Responsibility and Confirmation of Assessment Findings 49

4.2 Intertek RSPO Certification Details for Plantation Management Unit 50

APPENDICES Appendix Page Appendix A Qualifications of the Lead Assessor and Assessment Team 1 Appendix B Assessment Plan 23 Appendix C Maps of location – Mill, Estates, Conservation and HCV areas 47 Appendix D Photographs of Assessment findings at PMU 89 Appendix E Time Bound Plan for Other Plantation Management Units 10

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1.0 SCOPE OF MAIN ASSESSMENT

1.1 Introduction This Main Assessment was conducted on the Plantation Management Unit (PMU) KKS Kalabakan grouping of Felda Global Ventures Plantation Malaysia Sdn Bhd (hereafter abbreviated as FGVPM), from 9 – 13 June 2014, to assess if the organization’s operations of the mill and its supply bases were in compliance against the RSPO Principles and Criteria (April 2013), Malaysian National Interpretation (November 2010) and the RSPO Supply Chain Certification Standard (November 2011) for Palm Oil Mill. This assessment also includes a review of the changes made by the PMU to comply with the requirements of the ratified new RSPO Principles and Criteria (effective 25 April 2013). It was found that the PMU is aware of the new RSPO Principles and Criteria and the transition period for compliance but has not yet make the necessary changes required.

The plantation management unit (PMU) or management unit is equivalent to a certification unit as defined in the RSPO Certification Systems Document. Each PMU consists of one mill and its supply bases which are made up of estates owned by Felda Global Ventures Plantation Malaysia Sdn Bhd

1.2 Location (address, GPS and map) of palm oil mill and estates KKS Kalabakan grouping consists of one (1) palm oil mill, namely KKS Kalabakan and three (3) estates as indicated in Table 1 below, which includes the addresses and GPS locations of the mill and estates. The location maps are provided in Appendix C.

Table 1: Address of Palm Oil Mill, Estates and GPS Location

GPS Reference Name Address Latitude Longitude Kalabakan Mill POM Kilang Sawit Kalabakan, Peti Surat No. 62007, 4°24'36"N 117°29'21"E (Capacity:45 MT/hour) 91030 Tawau, Sabah FPSB Kalabakan Ladang Kalabakan Tengah, Peti Surat No. 61954, 4°23'25"N 117°27'35"E Tengah estate 91029 Tawau, Sabah FPSB Kalabakan Ladang Kalabakan Selatan, Peti Surat No. 61954, 4°16'50"N 117°31'11"E Selatan estate 91029 Tawau, Sabah FPSB Kalabakan Ladang Kalabakan Utara, Peti Surat No. 61954, 4°26'45"N 117°25'20"E Utara estate 91029 Tawau, Sabah

1.3 Description of supply base (fruit sources)

The supply base i.e. FFB sources to the POM at KKS Kalabakan grouping PMU are from the abovementioned three (3) estates which are owned by Felda Global Ventures Plantation Malaysia Sdn Bhd. Note: There is no Felda Settlers Scheme or organized smallholders under at the KKS Kalabakan PMU grouping. There was FFB supply from other external estates which are owned by independent smallholders and outgrowers, which had also supplied FFB to the POM. These other supply sources have also been considered in the overall assessment of KKS Kalabakan grouping PMU and have been verified to be part of the Time Bound Plan committed by FGVPM for certification.

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Details of the planted hectarage for the FFB supply for KKS Kalabakan grouping are as shown below:

Table 2: Estate Area Summary – 2013 / 2014

Area Summary (ha) – 2013 / 2014 Estate Certified Area Oil Palm Planted Area FPSB Kalabakan Tengah estate 3,236.01 2,520.45 FPSB Kalabakan Selatan estate 2,928.01 2,149.99 FPSB Kalabakan Utara estate 2,231.00 2,009.80 Total: 8,395.02 6,674.24 Percentage: 100% 79.5%

Notes: 1. This Assessment covered the overall land use for oil palm plantation areas which includes the identified Conservation areas including any HCV areas and other planted areas such as Teak, Mahogany and Durian trees (at Kalabakan Tengah and Kalabakan Selatan), as marked out at the respective estates. 2. The estates sampled for this Main Assessment have been selected based on their potential risks on social, environmental and biodiversity issues such as their proximity to forest reserves, hill sides, riparian zones and high conservation value areas.

1.4 Summary of plantings and cycle The 3 estates been developed beginning from 1984 and are currently in the 2 nd cycle of planting for the oil palms The age profile is as shown in Table 3.

Table 3: Age Profile of Planted Oil Palm 2013 / 2014

Cycle of Planting Mature OP (ha) Immature OP (ha) Estate Name Year of Planting - current – Above 3 years – 3 years & below st FGVPM / FPSB 1984 – 1987 (1 ) nd 2 1,044.44 1,476.01 Kalabakan Tengah estate 2010 – 2014 (2 nd ) st FGVPM / FPSB 1984 – 1987 (1 ) nd 2 1,865.70 284.29 Kalabakan Selatan estate 2009 – 2014 (2 nd ) st FGVPM / FPSB 1984 – 1987 (1 ) nd 2 1,740.69 269.11 Kalabakan Utara estate 2010 – 2014 (2 nd ) Total 4,650.83 2,029.41

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1.5 Summary of Conservation and HCV Areas The summary of Conservation and HCV Areas as identified in KKS Kalabakan grouping during this Main Assessment in 2014 is as shown in Table 4 below:

Table 4: Conservation and HCV Areas

# Statement of Land Use (Ha) Current 2014 (Main Assessment) Hectarage – Ha 1 Planted Area (ha) – Oil Palm • Mature 4,650.83 • Immature 2,029.41 2 Conservation Area (ha) comprising buffer zones along small streams, hilly areas, 1,200 swampy and unplantable areas 3 HCV Area (ha) comprising buffer zones near forest reserves, riparian near rivers, Nil water catchments, burial & religious sites

1.6 Other certifications held and Use of RSPO Trademarks Presently the Palm Oil Mill at KKS Kalabakan grouping holds the ISO 9001, ISO 14001 and OHSAS 18001 certifications. The RSPO’s trademarks and logo are not being used by the PMU audited. Instructions for use were provided and acknowledged by the PMU through a signed Memorandum of commitment agreeing to adhere to the latest “RSPO Rules on Communications & Claims”.

1.7 Organizational information / Contact Person

Name: Norazam Abdul Hameed Designation: Head of Department, Plantation Sustainability and Quality Management (PSQM) Department Full Address: Plantation Sustainability and Quality Management (PSQM) Department, Felda Global Ventures Plantations Malaysia Sdn Bhd, 3rd Floor, Balai Felda, Jalan Gurney Satu, 54000 Kuala Lumpur, Malaysia. Tel: 0326005348 ext 5348 or 0326005349 ext 5349 Fax: 0326987816 Email: [email protected]

Name: Anthonius Sani Designation: Sustainability Manager, Plantation Sustainability and Quality Management (PSQM) Department Full Address: Plantation Sustainability and Quality Management (PSQM) Department, Felda Global Ventures Plantations Malaysia Sdn Bhd, 3rd Floor, Balai Felda, Jalan Gurney Satu, 54000 Kuala Lumpur, Malaysia. Tel: 0326005348 ext 5348 or 0326005349 ext 5349 Fax: 0326987816 Email: [email protected]

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1.8 Tonnages Verified for Certification

The breakdown of all the suppliers and their tonnages of FFB supplied to the POM at KKS Kalabakan grouping based on the actual for January to May 2014 and projected for June to December 2014 are as follows:

Table 5: FFB Tonnages

# Estate /Supplier FFB Received (MT) Main Receiving Mill Certified By Covered under this 1 FPSB Kalabakan Tengah 19,715 KKS Kalabakan report Covered under this 2 FPSB Kalabakan Selatan 42,170 KKS Kalabakan report Covered under this 3 FPSB Kalabakan Utara 31,725 KKS Kalabakan report Sub-total for PMU estates 93,610 FELDA Settlers’ Scheme: 4 Nil 0 Sub-total from Settlers’ Scheme 0

Other Certified FELDA PMUs: 5 Nil 0 Sub-total other certified estates 0 Total Certifiable FFB 93,610

Other suppliers / external FFB 6 Various Traders/Dealers 11,260 KKS Kalabakan Not yet certified 7 Various Estates 103,558 KKS Kalabakan Not yet certified 8 Various Independent Smallholders 582 KKS Kalabakan Not yet certified Sub-total Non-certified sources 115,400

Grand total 209,010

Total annual volumes / tonnages of FFB supplied from the supply base to KKS Kalabakan grouping POM during the previous period, current Main Assessment period and projected period are as follows:

Table 6: FFB Processed (Certified & Non-certified) tonnages

FFB Processed in FFB Processed for FFB Processed for Estate / Supplier Jan – Dec 2013 Jan – Dec 2014 Jan – Dec 2015 - Actual - Actual + Projected - Projected MT % MT % MT % KKS Kalabakan PMU 85,216 40.22 93,610 44.78 90,470 43.95 grouping estates Other Suppliers (under 0 0 0 0 0 0 FGVPM Group) Other Suppliers / 126,679 59.78 115,400 55.22 115,400 56.05 External /Outside crop

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Total 211,895 100.00 209,010 100.00 205,870 100.00 SCCS Model for POM MB MB MB Total FFB Processed 211,895 209,010 205,870 (MT) Total CPO Production OER: OER: OER: 49,623 48,908 48,174 (MT) 23.42% 23.40% 23.40% Total PK Production KER: KER: KER: 9,011 8,987 8,852 (MT) 4.25% 4.30% 4.30%

The annual certifiable tonnages of CPO and PK production by KKS Kalabakan grouping from the supply base/suppliers as assessed and verified during the current Main Assessment are detailed as follows:

Table 7: Certifiable FFB tonnages

Jan – Dec 2013 Jan – Dec 2014 Jan – Dec 2015 KKS Kalabakan - Actual - Actual + Projected - Projected Total certifiable FFB 85,216 93,610 90,470 Processed (MT) Total certifiable CPO 19,956 21,905 21,170 Production (MT) Total certifiable PK 3,622 4,025 3,890 Production (MT) SCCS Model for POM MB MB MB

Note: Currently, the POM has established and maintained procedures for the book keeping and monitoring requirements for the CPO at the mill and was verified to be adopting the Mass Balance – MB’ model in accordance with the RSPO Supply Chain Certification Standard (SCCS) requirements. Verified activities and checked items for the SCCS of the POM are reported in section.3.1.1.

1.9 Time Bound Plan for Other Plantation Management Units

Felda Global Group operates 70 palm oil mills and 416 oil palm estates and schemes throughout Malaysia. The organization is a member of RSPO since 2004 and has been taking an active role in the RSPO certification.

Currently, a significant number of its Certification Units is undergoing the RSPO certifying process in accordance with its time bound plan to achieve RSPO certification for all its plantation certification units by 2016.

Based on the due diligence conducted on FGVPM there were no significant land conflicts, no replacement of primary forest or any area containing HCVs since November 2005, no labour disputes that are not being resolved through an agreed process, no evidence of noncompliance with law in any of the noncertified holdings.

Details of the status of the Time bound plan as submitted by FGVPM is referred to in Appendix E (Part 2 of Assessment report).

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1.10 Abbreviations Used

CB Certification Body KER Kernel Extraction Rate CHRA Chemical Health & Risk Assessment LTA Lost Time Accidents CPO Crude Palm Oil Intertek Intertek Certification International Sdn Bhd CSDS Chemical Safety Data Sheets MSDS Material Safety Data Sheets CSPO Certified Sustainable Palm Oil MTCS Malaysia Timber Certification Scheme CSPK Certified Sustainable Palm Kernel NCR NonConformance Report EFB Empty Fruit Bunch NGO NonGovernment Organization EHS Environmental Health & Safety OER Oil Extraction Rate EIA Environmental Impact Assessment OHS Occupational Health & Safety Programme for the Endorsement of Forest Effluent Treatment Plant ETP PEFC Certification Felda Global Ventures Plantation Malaysia Sdn Palm Kernel FGVPM Bhd PK FFB Fresh Fruit Bunch PMU Plantation Management Unit GAP Good Agriculture Practice POM Palm Oil Mill HCV High Conservation Values POME Palm Oil Mill Effluent IPM Integrated Pest Management PPE Personal Protective Equipment ISCC International Sustainability & Carbon Certification SCCS Supply Chain Certification Standard IUCN International Union for Conservation of Nature SOP Standard Operating Procedures

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2.0 ASSESSMENT PROCESS

2.1 Assessment Methodology, Plan and Site Visits

Since 2 May 2014, Intertek has initiated public communications and notifications and invited the relevant stakeholders before the assessment to provide feedback and comments on their concern (if any) on KKS Kalabakan grouping regarding the environmental, biodiversity, community development and other relevant issues.

From 9 – 13 June 2014, the Assessment team of Intertek conducted the Main Assessment in which 2 out of the 3 estates of KKS Kalabakan grouping namely FPSB Kalabakan Utara estate and FPSB Kalabakan Selatan estate as well as the palm oil mill were assessed for compliance against the RSPO requirements. The number of estates sampled was based on a minimum sample of 0.8√y where y is the number of management subunits and the selection was made based on their potential risks on social, environmental and biodiversity issues such as their proximity to forest reserves, hill sides, riparian zones and high conservation value areas.

During the onsite assessment, relevant documents and records, including Standard Operating Procedures (SOP), management plans, hectarage development, FFB, CPO and PK production, oil palm age profile, operational controls and measures, operational data and records, training records, etc. were reviewed and verified for compliance. The Assessment team using the process approach auditing technique covered the palm oil mill and estate operations, agricultural practices, pest management, pesticide and fertilizer application, occupational health and safety, social accountability, environment and other requirements. Stakeholders’ interviews were conducted during the assessment and feedback obtained as part of information and evidence gathering. (See section 2.5 Process of stakeholder consultation).

KKS Kalabakan grouping POM was also assessed against the requirements for the Segregation Model as specified in RSPO Supply Chain Certification Standard for CPO mill. This part of the assessment covered the verification of implementation of documented procedures and availability of records to demonstrate compliance against all the elements for Segregation requirements. These include documented procedure, purchasing and goods in, record keeping, sales and goods out, processing, monitoring and traceability of the CSPO and CSPK quantities, training for staff and claims.

After completion of the onsite field assessment, Intertek also performed the evaluation of conformity against the RSPO Certification System requirements for CB. The assessment report, findings and associated documents were evaluated through independent reviews conducted by the Intertek Internal Evaluation Panel and external Peer Review prior to Certification decision and approval of the report.

The details of the Assessment Plan (actual onsite) are provided in Appendix B.

2.2 Date of next scheduled visit

The next scheduled visit will be the Main Assessment which will be carried out within the 9 to 12 months period after the Certificate approval date of this report.

2.3 Qualifications of the Lead Assessor and Assessment Team

Competency details of the Lead Assessor and Assessment Team are given in Appendix A.

2.4 Certification Body

Intertek Certification International Sdn Bhd [formerly known as Moody International Certification (Malaysia) Sdn Bhd] is part of the Intertek Group, which is a worldwide technical services organization dedicated to reducing clients' risks by providing technical inspection services, management system certification in quality, environmental, occupational safety & health and product certification, RSPO SCC, ISCC, Marine Sustainability ChainofCustody, MTCS and PEFC Chainof Custody certification in applicable industry sectors including the agricultural and forestry sectors. Intertek operates globally providing clients with a wideranging technical inspection expertise and access to thousands of skilled specialists worldwide. Intertek Group’s certification business is ranked in the top 10 worldwide, and is available globally offering certification across a wide range of industries.

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2.5 Process of stakeholder consultation

Stakeholder consultations began with notification of the upcoming assessment through the websites of RSPO, FGVPM and Intertek. Emails, facsimiles and letters of the same were sent to applicable stakeholders including government agencies, NGOs and local communities. Telephone enquiries were made prior to the actual assessment and stakeholder’s response and feedback received were followed up accordingly.

During the assessment, stakeholders were interviewed and their feedbacks were recorded. Among the stakeholders consulted were workers, trade union leaders, women representatives; local community leaders, representatives of government departments / agencies and NGOs; external FFB suppliers, fertilizer suppliers and contractors.

Details on stakeholders’ feedback, PMU response and Intertek verification / comments are provided in section 3.3.

Among the list of key stakeholders consulted was the following:

Government Agencies (by emails) 1. Department of Lands And Mines, WP 10. Environment Protection Department Sabah 2. Department of Environment, WP 11. Department of Forestry, Sabah 3. Department of Forestry Peninsular Malaysia 12. Department of Immigration, Sabah 4. Department of Immigration, WP 13. Department of Irrigation & Drainage, Sabah 5. Department of Irrigation & Drainage, WP 14. Department of Labour, Sabah 6. Department of Labour, WP 15. Department of Occupational Safety & Health, Sabah 7. Department of Occupational Safety & Health. WP 16. Sabah Wildlife Department 8. Department of Orang Asli Affairs, WP 17. Land and Mines Office, Sabah 9. Department of Wildlife & National Parks, WP

Statutory Bodies (by emails) 18. Malaysian Palm Oil Board (MPOB) 23. Malaysian Palm Oil Board (MPOB) Sarawak Region 19. Malaysian Palm Oil Board (MPOB) Northern Region 24. Malaysian Palm Oil Board (MPOB) Sabah Region 20. Malaysian Palm Oil Board (MPOB) Central Region 25. Malaysia Palm Oil Association (MPOA) 21. Malaysian Palm Oil Board (MPOB) Southern Region 26. Malaysia Palm Oil Association Kuala Lumpur (MPOA) 22. Malaysian Palm Oil Board (MPOB) Eastern Region 27. Malaysia Palm Oil Association Sabah (MPOA)

NGOs (by emails) 28. All Women’s Action Society (AWAM) 57. Malaysian Nature Society Terengganu 29. BCSDM Business Council for Sustainable 58. Malaysian Plant Protection Society (MAPPS) Development in Malaysia 59. Mountaineering and Outdoor Pursuits Association of Negeri 30. Borneo Child Aid Society (Humana) Sembilan 60. National Council of Welfare & Social Development 31. Borneo Resources Institute Malaysia (BRIMAS) Malaysia NCWSDM 32. Borneo Rhino Alliance (BORA) 61. National Union of Plantation Workers (NUPW) 33. Center for Orang Asli Concerns COAC 62. Partners of Community Organisations (PACOS) 34. Centre for Environment, Technology and Development, 63. Penang Institute previously known as SocioEconomic & Malaysia CETDEM Environmental Research Institute (SERI) 35. Consumers Association Of Penang CAP 64. Proforest South East Asia Regional Office 65. R.E.A.C.H. Regional Environmental Awareness Cameron 36. EcoKnights Highlands 37. Environmental Management and Research Association 66. Sabah Wetlands Conservation Society (SWCS) of Malaysia (ENSEARCH) 38. Environmental Protection Society Malaysia (EPSM) 67. SEPA Sabah Environmental Protection Association 39. Friends of the Earth, Malaysia 68. SUARAM Suara Rakyat Malaysia 69. SUHAKAM National Human Rights Society Persatuan 40. Future in Our Hands Society, Malaysia Kebangsaan Hak Asasi Manusia 41. Global Environment Centre 70. Sustainable Development Network Malaysia (SUSDEN) 42. Institute of Foresters, Malaysia (IRIM) 71. Tenaganita Sdn Bhd 43. JUST International Movement for a Just World 72. The Malaysian Forum of Environmental Journalist (MFEJ) 73. TRAFFIC Southeast Asia Wildlife trade & trafficking 44. Malaysian Environmental NGOs MENGO monitoring programme 45. Malaysian National Animal Welfare Foundation 74. Transparency International Malaysian Chapter MNAWF 46. Malaysian Nature Society (MNS) Kuala Lumpur 75. Treat Every Environment Special Sdn Bhd. (TrEES) 47. Malaysian Nature Society Johor 76. United Nations Development Programme UNDP Malaysia 48. Malaysian Nature Society Kedah 77. Water Watch Penang (WWP) 49. Malaysian Nature Society Kelantan 78. Wetlands International (Malaysia) 50. Malaysian Nature Society Kuching 79. Wild Asia Sdn Bhd

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51. Malaysian Nature Society Melaka/Negeri Sembilan 80. World Wide Fund for Nature (WWF) Malaysia 52. Malaysian Nature Society Miri 81. World Wide Fund of Nature (WWF) Sabah 53. Malaysian Nature Society Pahang 82. UNION AMESU 54. Malaysian Nature Society Perak 83. Malaysian CropLife & Public Health Association (MCPA) 55. Malaysian Nature Society Pulau Pinang 84. Pesticide Action Network Asia and the Pacific (PAN AP) 56. Malaysian Nature Society Sabah

Local community (Onsite interviews) Gender representatives Suppliers & Contractors representatives Workers & Workers representatives

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3.0 ASSESSMENT FINDINGS

3.1 Summary of findings

Principle 1: Commitment to transparency

Criterion 1.1 Growers and millers provide adequate information to relevant stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages and forms to allow for effective participation in decision making. Indicators Findings and Objective Evidence Compliance 1.1.1 There shall be evidence that Documented procedure ML1A/L2PR30, Mar 2012 for Complied growers and millers provide adequate providing information, handling responses and requests from information on (environmental, social stakeholders was established and communicated at Felda and/or legal) issues relevant to Kalabakan PMU. The mill and estate management have RSPO Criteria to relevant recorded and responded constructively and promptly to any stakeholders for effective requests for information from the interested stakeholders. participation in decision making. Notice of public consultation was issued on 3 December 2013.

This was evident from records sighted among which were Major Compliance letters, minutes of meetings, attendance notes held together with local authorities (e.g. DOSH, DOE and BOMBA), security services, schools, clinics, smallholders, employee consultative committees and local community leaders. A stakeholders meeting was held on 17 December 2013 with stakeholders’ feedback recorded. Records of visits and inspections such as DOSH (JKKP) factory visits, DOE (JAS) sampling of effluent, BOMBA inspection records were verified onsite.

1.1.2 Records of requests for The PMU maintained an updated list of internal stakeholders, Complied information and responses shall be external stakeholders which included the government maintained. departments/agencies, consultants, contractors, suppliers and transporters. Major / Minor - TBF Request and responses were noted in the Record Log book maintained which indicated the actions taken and date from December 2013 to April 2014. These were verified to be adequately maintained. Other implementation documents & records were sighted from FFB supplying estates, which included land titles, training materials, health & safety plan, environmental & social impacts assessment, pollution prevention plan, complaint files, negotiation procedure, continual improvement plans.

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. Indicators Findings and Objective Evidence Compliance 1.2.1 Publicly available documents In line with the organization’s policies , Kalabakan PMU had Complied shall include, but are not necessarily established & documented information of land titles, health limited to: and safety plan, plans and impact assessments relating to environment and social impacts, pollution prevention plans, Major Compliance details of complaints & grievances, negotiation procedures and continuous improvement plan that are required to be made

available to the public & also for internal reference.

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• Land titles/user rights (Criterion Copies of all the land titles were available and have been 2.2); maintained. • Occupational health and safety Detailed documented plan of OSH established in ML1A/L4F2 Complied plans (Criterion 4.7); (0), updated & reviewed since December 2013. Programmes for protecting workers’ health & safety measures established & implemented. • Plans and impact assessments Environmental aspect and impact assessment, and its plan as Complied relating to environmental and social well as social impact assessment were documented. impacts The SEIA established by Sustainability team (HQ) was (Criteria 5.1, 6.1, 7.1 and 7.8); reviewed and updated on 7 Jan 2014 with feedback from the Mill, Estate managers and RSPO implementation team. See also related findings in C 5.1 and 6.1. • HCV documentation (Criteria 5.2 Based on the internal SEIA survey and evaluation, there was Complied and 7.3); no HCV area at Felda Kalabakan PMU. Management Action for Conservation areas need to be monitored and progressively implemented at the respective Estates. See also findings detailed under C5.2 and C7.3. • Pollution prevention and reduction Pollution prevention & reduction plans were documented in Complied plans (Criterion 5.6); FGVPM, 1/2013. It includes measures for pollution control (incl. pesticides, schedule wastes, domestic wastes etc). See also findings detailed under C5.6. • Details of complaints and Documented in ML1A/L2PR4 (0), dated Mar 2012. Complied grievances (Criterion 6.3); Complaints / queries and enquiries records for internal and external stakeholders were implemented but inadequately implemented and followed up. See also findings detailed under C6.3. • Negotiation procedures (Criterion Negotiation procedure was documented in ML1A/L2PR1 (0), Complied 6.4); updated & reviewed Mar 2012. There were no reported cases of any land conflict so far, at the Kalabakan PMU.

• Continual improvement plans Documented in ML1A/L2PR11 (0), dated Mar 2012. Complied (Criterion 8.1); See also findings under C8.1. • Public summary of certification Public summary of earlier certification assessment reports of Complied assessment report; FELDA certifications achieved were available in the website: www.felda.net.my The new integrated website under Felda Global Ventures for public summary of RSPO assessments is currently still being constructed. • Human Rights Policy (Criterion The Human Rights Policy has not yet been documented and New 6.13). communicated to all levels of the workforce and operations. requirement of RSPO P&C (2013) Follow up will be done at Surveillance assessment. Criterion 1.3 Growers and millers commit to ethical conduct in all business operations and transactions. Indicators Findings and Objective Evidence Compliance 1.3.1 There shall be a written policy Policy of Commitment to a Code of Ethical Conduct and New committing to a code of ethical Integrity has not yet been documented and communicated to requirement

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Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 15 of 50 KKS Kalabakan grouping - Main Assessment conduct and integrity in all operations all levels of the workforce and operations. of RSPO P&C and transactions, which shall be (2013) documented and communicated to all Follow up will levels of the workforce and be done at operations. Surveillance Major / Minor (TBF) assessment.

Principle 2: Compliance with applicable laws and regulations

Criterion 2.1 There is compliance with all applicable local, national and ratified international laws and regulations. Indicators Findings and Objective Evidence Compliance 2.1.1 Evidence of compliance with Felda KalabakanPMU has established a documented system Complied relevant legal requirements shall be explaining the mechanism for identifying, determining, available. reviewing and updating applicable legal and other requirements that the PMU has subscribed. Major Compliance Based on the site observations, interviews and records checking at the field and mill, there were evidences of compliance with the relevant laws, regulations, local and international laws at the POM and estates. There were no cases of any violation or actions imposed by relevant authorities. Palm oil mill possessed valid MPOB license which has been recently renewed which will expire on 31 March 2015. Certificates and records of qualified engineers, boilermen and electricians were noted to be maintained and were valid. Certificates of boilers and diesel generators are displayed, maintained and found to be valid. The permits and certificates are also annually checked by the DOSH officers. The Mill has also valid Quality, Environment and Safety & Health Management Systems which are annually checked and certified by SIRIM. Licenses and permits (License for Trading, License for Employment of Foreign Workers, Workers Wages Deduction Permit, Domestic and Consumer Permit for Keeping Diesel, Petrol & Fertilizer, DOSH Certificates, DOE Permit, etc) were renewed and evidenced to be valid.

2.1.2 A documented system, which The documented system Doc No. ML1A/L2PR2 (0) (March Complied includes written information on legal 2012) for identifying, determining, reviewing and updating requirements, shall be maintained. applicable legal and other requirements has been maintained. List of legal requirements (both international & national) filed & Minor Compliance maintained in oil mill & estate levels. Review was done in January 2014 and related legal and regulatory changes had been updated. 2.1.3 A mechanism for ensuring Monitoring mechanism was done through a 6monthly Complied compliance shall be implemented. evaluation checked against the items in the Legal Register. Minor Compliance 2.1.4 A system for tracking any A system for tracking changes in the law established and NC 5 of 8 - changes in the law shall be documented at the POM and estates. Minor implemented. However, at the estates of Ladang Tengah and Selatan, Minor Compliance the tracking and updating did not sufficiently include other relevant legal requirements for Sabah state, e.g. requirement for EIA / PMM during replanting and approval by JPAS. Thus a NC was issued.

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Criterion 2.2 The right to use the land is demonstrated, and is not legitimately contested by local people who can demonstrate that they have legal, customary or user rights. Indicators Findings and Objective Evidence Compliance 2.2.1 Documents showing legal The lands in the Kalabakan PMU are legally leased by Felda Complied ownership or lease, history of land from the Sabah State Government since 1983 as evidenced tenure and the actual legal use of the by the copies of land tiles produced and verified onsite. land shall be available. The original copies are maintained by the corporate head Major Compliance office at KL. The legal use of the land was confirmed for the cultivation of oil palms and agricultural use. Copies of the land titles of all the PMU estates were maintained and found to be in proper order.

2.2.2 Legal boundaries shall be It was verified that there has been no change to the stated Complied clearly demarcated and visibly land titles and designated use for cultivation of oil palms and maintained. agricultural use. Boundary pole markers and trenches were sighted and Major Compliance maintained along the perimeters of estate lands. No boundary stones could be found at the estates. Pole markers placed were verified to be within the boundary parameters of the estates audited. Demarcation via dug up trenches and drains which were adjacent to neighbouring villager / outgrower estates were also evidenced.

2.2.3 Where there are or have been There has been no recent dispute on the land rights within the Complied disputes, additional proof of legal Kalabakan PMU. acquisition of title and evidence that fair compensation has been made to As such, the process of fair compensation and FPIC is previous owners and occupants shall currently not applied. be available, and that these have been accepted with free, prior and informed consent (FPIC). Major / Minor (TBF) 2.2.4 There shall be an absence of Due diligence was exercised through the implementation of Complied significant land conflict, unless documented procedure for handling and response to land requirements for acceptable conflict disputes, customary rights in ML1A/L2PR12(0), Mar 2012; resolution processes (see Criteria 6.3 documented procedure for handling negotiation in ML1A/L2 and 6.4) are implemented and accepted by the parties involved. PR1(0), Mar 2012; as well as documented procedure for calculation & distribution of compensation in ML1A/L2 Major / Minor (TBF) PR13(0), Mar 2012. There has been no dispute on the land rights within the Kalabakan PMU (see C2.2.3 above) 2.2.5 For any conflict or dispute over As per the procedure and mechanism documented, whenever Complied the land, the extent of the disputed there were incidences of land conflict, the disputed areas area shall be mapped out in a would be mapped out in participatory way with involvement of participatory way with involvement of affected parties. Internal investigation would be carried out, affected parties (including neighbouring communities where and appropriate follow up actions taken to resolve land conflict applicable). issues. This was evidenced at the PMU estates as follows: Major / Minor (TBF) At Kalabakan Tengah, Native Customary Rights – NCR land of 281.79 ha, belonging to the indigenous Murut community has been mapped out and proper contract of agreement had been made to manage the land by FELDA (Agreement dated 10 February 1983 was evidenced for the 99 year lease between Sabah State Government and FELDA – on behalf of the Murut Community).

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At Kalabakan Selatan, it was noted the Native Customary Rights – NCR land of 198.29 ha, belonging to the indigenous local community has been mapped out and released back to the community for their own use since 2009. 2.2.6 To avoid escalation of conflict, As per the procedure and mechanism documented, Complied there shall be no evidence that palm precautionary measures would be exercised on any disputed oil operations have instigated area during the investigation period. Avoidance of violence violence in maintaining peace and would be exercised to maintain peace and order in their order in their current and planned operations. current and planned operations at the estates. Major / Minor (TBF) Criterion 2.3 Use of the land for oil palm does not diminish the legal, customary or user rights of other users without their free, prior and informed consent. Indicators Findings and Objective Evidence Compliance 2.3.1 Maps of an appropriate scale The lands in the Kalabakan region are legally leased by Felda Complied showing the extent of recognised from the Sabah State Government since 1983 as evidenced legal, customary or user rights by the copies of land tiles and maps produced which were (Criteria 2.2, 7.5 and 7.6) shall be verified onsite. developed through participatory mapping involving affected parties (including neighbouring communities where applicable, and relevant authorities). Major Compliance 2.3.2 Copies of negotiated Records are available to show that the land lease comply with Complied agreements detailing the process of legal requirements and does not infringe on any legal rights free, prior and informed consent that require free, prior and informed consent (FPIC). (FPIC) (Criteria 2.2, 7.5 and 7.6) This was evidenced at Kalabakan Tengah, Native Customary shall be available and shall include: Rights – NCR land of 281.79 ha, belonging to the indigenous a) Evidence that a plan has been Murut community has been mapped out and proper contract of developed through consultation and discussion with all affected groups in agreement had been made to manage the land by FELDA the communities, and that information (Agreement dated 10 February 1983 was evidenced for the 99 has been provided to all affected year lease between Sabah State Government and FELDA – groups, including information on the on behalf of the Murut Community). steps that shall be taken to involve them in decision making; b) Evidence that the company has respected communities’ decisions to give or withhold their consent to the operation at the time that this decision was taken; c) Evidence that the legal, economic, environmental and social implications for permitting operations on their land have been understood and accepted by affected communities, including the implications for the legal status of their land at the expiry of the company’s title, concession or lease on the land. Minor Compliance 2.3.3 All relevant information shall be All the relevant and information and pertinent documents were Complied available in appropriate forms and also available in the local language i.e. Bahasa Malaysia languages, including assessments of which can be understood by the stakeholders. impacts, proposed benefit sharing, and legal arrangements. Major / Minor (TBF)

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2.3.4 Evidence shall be available to As there were no recent cases of land disputes reported in the Complied show that communities are PMU, the evidence for this did not apply. represented through institutions or representatives of their own choosing, including legal counsel. Major / Minor (TBF)

Principle 3: Commitment to long-term Economic & Financial Viability

Criterion 3.1 There is an implemented management plan that aims to achieve longterm economic and financial viability. Indicators Findings and Objective Evidence Compliance 3.1.1 A business or management plan The 3year management plan from 2014 2017 had been Complied (minimum three years) shall be documented, with details of budget & cost of operation, both documented that includes, where for oil mill & estates. appropriate, a business case for scheme smallholders. Annual budget of Business Management Plan included the following: (i) Planting materials (DXP seedling and cloned seedling); Major Compliance (ii) Crop projection = FFB yield/ha trends; (iii) Mill extraction rates = OER trends; (iv) Cost of Production = Cost/MT FFB trends; (v) Cost of Production = Cost/MT CPO trends; (vi) Forecast prices; (vii) Financial indicators = Cost labour, supervision, production and machinery depreciation).

The PMU i.e. POM and its 3 estates are managed under FGVPM i.e. not Felda Settler Schemes.

Estate Managers monitor the monthly, quarterly and annual performances which includes cost and quality. Reports are submitted to the GM of Zone/Wilayah. Performances are discussed in the monthly meetings held at the PMU i.e. POM & Estate Managers being present. Issues and actions needed are minuted for follow up in next monthly meeting. The records of these meetings were available and verified during audit.

3.1.2 An annual replanting programme The Annual replanting programme projected for the next 5 Complied projected for a minimum of five years years for each estate in this PMU is available. Evidence of (but longer where necessary to reflect replanting programme planned, reviewed and ongoing the management of fragile soils, see implementation being carried out was observed during the Criterion 4.3), with yearly review, shall be available. onsite assessment and field inspection. Minor Compliance

Principle 4: Use of appropriate best practices by growers and millers Criteria 4.1 Operating procedures are appropriately documented, consistently implemented and monitored. Indicators Findings and Objective Evidence Compliance 4.1.1 Standard Operating Procedures The mill and the estates had a copy each of the Standard Complied (SOPs) for estates and mills shall be documented. Operating Procedures and these had been verified to be in order. Major Compliance The list of SOPs available includes Safe working practices

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and application of pesticides, Riparian zone management, Safe working practices in the mill etc. Control measures for Safe working practices at the POM and estates included issuance of Permit to Work, use of PPE and related Training which is documented in the HIRARDC Analysis table. Records of implementation were verified. 4.1.2 A mechanism to check consistent The mechanism to check the implementation of SOPs was Complied implementation of procedures shall be in place. available. Records had been kept by the staff concerned for each operation to monitor the procedure and progress of Minor Compliance work, and these records would be checked by the Assistant Manager and the Manager regularly. These records had been verified to indicate satisfactory implementation during the visit.

4.1.3 Records of monitoring and any The records of monitoring and the actions taken had been actions taken shall be maintained and available, as appropriate. maintained for more than 12 months on the mill and estates concerned. These records had been verified to be

Minor Compliance satisfactory. However at the palm oil mill, some of the readings on NCR 1 of 8 – POME flow meter records were erroneously written. A Minor minor non-compliance had been issued. 4.1.4 The mill shall record the origins of The mill maintained record on the origins of all thirdparty Complied all thirdparty sourced Fresh Fruit Bunches (FFB). sourced Fresh Fruit Bunches (FFB), and it had been verified to be satisfactory. Major Compliance Criteria 4.2 Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield. Indicators Findings and Objective Evidence Compliance 4.2.1 There shall be evidence that good GAP for minimization of soil erosion and maintenance of soil Complied agriculture practices, as contained in Standard Operating Procedures fertility is maintained via the frond stacking and fertilizer (SOPs), are followed to manage soil application as per the recommendation provided from fertility to a level that ensures optimal FELDA Research Centre. and sustained yield, where possible.

Minor Compliance 4.2.2 Records of fertiliser inputs shall be Records of fertilizer application had been verified to be in Complied maintained. order. Minor Compliance 4.2.3 There shall be evidence of Leaf and soil sampling and analysis had been carried out Complied periodic tissue and soil sampling to monitor changes in nutrient status. annually to determine the nutrient levels for fertilizer recommendations that aimed to sustain the long term soil Minor Compliance fertility and nutrient efficiency. Records of the sampling and analysis had been verified to be satisfactory. 4.2.4 A nutrient recycling strategy shall On Kalabakan Tengah Estate, EFB mulching had been Complied be in place, and may include use of Empty Fruit Bunches (EFB), Palm Oil carried out in the interrow of mature area while compost Mill Effluent (POME), and palm residues had been used for mulching in the immature palms. after replanting. On Kalabakan Selatan estate EFB mulching had been carried out in the mature and immature areas while compost Minor Compliance had been applied in the mature area only. Records had been verified to be satisfactory.

POME land irrigation had been carried out in Kalabakan

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Tengah estate over 150 ha by gravity feed. Criteria 4.3 Practices minimise and control erosion and degradation of soils. Indicators Findings and Objective Evidence Compliance 4.3.1 Maps of any fragile/marginal soils Based on the soil maps, there was no fragile/marginal soil Complied shall be available. on the group Estates Major Compliance 4.3.2 A management strategy shall be in Planting terraces had been constructed on land with slope place for plantings on slopes between 6 and 25 degrees unless specified 6° to 25°. Records and maps on terraces constructed had been verified on the estates. otherwise by the company’s SOP. However, on Kalabakan Tengah and Kalabakan Selatan Minor Compliance Estates, on some of the land with slope >6°, some NCR 2 of 8 - palms were not planted on terraces. Minor A minor non-compliance had been issued. (MYNI 4.3.1) 4.3.3 A road maintenance programme Generally estate roads were found to be in good and shall be in place. satisfactory condition. Road maintenance programme had been found to be in order. Minor Compliance However, it was noted on Kalabakan Tengah Estate, in Field PM 11H Block 12, the road had been partially NCR 3 of 8 - eroded due to rain, there was no signage to give Minor warning to the passerby on the potential hazard of falling into the ravine. A minor non-compliance had been issued. 4.3.4 Subsidence of peat soils shall be Based on the estate soil maps, there was no peat soil on the Complied minimised and monitored. A documented water and ground cover estates as confirmed by auditor’s onsite assessment management programme shall be in place.

Major Compliance 4.3.5 Drainability assessments where Based on the estate soil maps, there was no peat soil on the Complied necessary will be conducted prior to replanting on peat to determine the estates as confirmed by auditor’s onsite assessment longterm viability of the necessary drainage for oil palm growing.

Minor Compliance 4.3.6 A management strategy shall be in Based on the estate soil maps and visit to the estates, there Complied place for other fragile and problem soils (e.g. podzols and acid sulphate soils). were no other fragile and problematic soils on these estates.

Minor Compliance Criteria 4.4 Practices maintain the quality and availability of surface and ground water. Indicators Findings and Objective Evidence Compliance 4.4.1 An implemented water Documented water management plan and relevant records Complied management plan shall be in place. had been verified to be in order for the palm oil mill, Minor Compliance Kalabakan Tengah and Kalabakan Selatan Estates. 4.4.2 Protection of water courses and 1. In Field PM 09F Block 5, there was no marking of NCR 4 of 8 – wetlands, including maintaining and buffer zone on both sides of the stream, the palms Major restoring appropriate riparian and other had been planted too close to the stream, and there buffer zones (refer to national best was sign of chemical spraying on grasses within (MYNI 4.4.1) practice and national guidelines) shall be demonstrated. the palm circles next to the river. 2. In Field PR 13P Blocks 8 & 9 new replants, there Major Compliance was no marking of buffer zone on both sides of the river, and the palms had been planted too close to the river. A major non-compliance had been issued for the above-

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mentioned items. There was no construction of bunds/ weirs/dams across the main rivers or waterways passing through the estates. 4.4.3 Appropriate treatment of mill In palm oil mill, water samples had been taken at monthly effluent to required levels and regular monitoring of discharge quality, shall be interval at the discharge point of effluent pond. Noted that samples are for all the 7 key parameters i.e. BOD, COD, in compliance with national regulations (Criteria 2.1 and 5.6). TSS, Ammonical nitrogen, Oil & Grease, Nitrogen content & Discharge temperatures and results verified to be within the Minor Compliance DOE limits. TSS levels are noted to be within permissible limits i.e. less than 200 ppm.

BOD levels had been in the range of 80 ppm in Jan to 101 ppm in Oct during 2013 with an average of 92 ppm. The new upper limit specified by DOE Tawau was 20 ppm by end 2014. The mill is taking the necessary steps to reduce the BOD levels. The mill had applied and obtained permission for a 6- Observation month extension period since April 2014 from the DOE CFK-01 to complete and commission a Bio-Polishing plant in order to further reduce the BOD level to the DOE specified limits of 20ppm. Thus an Observation was issued. 4.4.4 Mill water use per tonne of Fresh Water usage in the mill ranged from 0.90 m3 to 0.93 Complied Fruit Bunches (FFB) (see Criterion 5.6) shall be monitored. m3/tonne FFB in 2013 with an average of 0.92 m3/tonne FFB. Minor Compliance The level of water usage was within the industrial norm. Criteria 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management techniques. Indicators Findings and Objective Evidence Compliance 4.5.1 Implementation of Integrated Pest Records on planting of beneficial plants had been verified Complied Management (IPM) plans shall be monitored. on the estates. Trapping of Rhinoceros beetle with pheromone had been Major Compliance carried out in the replants. Pest infestation was minimal on the estates. Programme for planting of beneficial plants such as Turnera subulata, Cassia cobanensis, and Antigonon leptopus , and records on areas planted had been verified together with the respective maps to be satisfactory 2 campaigns of rat baiting had been carried out around April and August of each year on the Estates. 4.5.2 Training of those involved in IPM Training records for personnel on IPM implementation were Complied implementation shall be demonstrated. available and was verified onsite to be satisfactory during Minor Compliance field assessment. Criteria 4.6 Pesticides are used in ways that do not endanger health or the environment. Indicators Findings and Objective Evidence Compliance 4.6.1 Justification of all pesticides used Written justification in Standard Operating Procedures of all Complied shall be demonstrated. The use of selective products that are specific to agrochemicals use had been reviewed and found the target pest, weed or disease and acceptable. which have minimal effect on nontarget species shall be used where available.

Major Compliance 4.6.2 Records of pesticides use Records of pesticides and their active ingredients used, Complied

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(including active ingredients used and LD50, area treated, amount of a.i. applied per ha, and their LD50, area treated, amount of number of applications had been maintained and kept for a active ingredients applied per ha and minimum of 5 years. Verified that records of monitoring were number of applications) shall be satisfactorily. provided.

Major Compliance 4.6.3 Any use of pesticides shall be It had been the policy of the estates to minimize the use of Complied minimised as part of a plan, and in accordance with Integrated Pest pesticides in accordance with integrated pest management. Management (IPM) plans. There shall No prophylactic use of pesticides had been carried out at be no prophylactic use of pesticides, the estates for the period concerned. except in specific situations identified in industry’s Best Practice.

Major Compliance 4.6.4 Pesticides that are categorised as It is the policy of the group to reduce the use of Paraquat Complied World Health Organisation Class 1A or 1B, or that are listed by the Stockholm gradually and achieve zero usage eventually. or Rotterdam Conventions, and The pesticide reduction program is monitored on usage per paraquat, are not used, except in hectare basis. On overall, it has shown a decline on a year specific situations identified in industry’s to year basis. Noted that the usage was mainly limited to the Best Practice. The use of such immature palm areas. pesticides shall be minimised and The requirements for use of Highly Toxic Pesticides (HTP) eliminated as part of a plan, and shall only be used in exceptional such as paraquat were checked and verified for compliance circumstances. Pesticides selected for under the Pesticides Act 149 and USECHH 2000 use are those officially registered under regulations i.e. they are kept under lock and key; records of the Pesticides Act 1974 (Act 149) and Form II for the paraquat used were available; First Aid Kits the relevant provision (Section 53A); was issued to all Mandores & Supervisors; Portable and in accordance with USECHH Signage boards were available and noted to be displayed at Regulations (2000). areas of spraying activity during field inspection and visit.

Minor Compliance 4.6.5 Pesticides shall only be handled, All pesticide operators had been given training on the Complied used or applied by persons who have completed the necessary training and handling and application of the pesticides. Appropriate shall always be applied in accordance safety and application equipment had been provided and with the product label. Appropriate used by the operators. safety and application equipment shall All precautions attached to the products had been observed, be provided and used. All precautions applied, and understood by the workers. attached to the products shall be properly observed, applied, and Programme and training records had been verified to be understood by workers (see Criterion satisfactory. 4.7).

Major Compliance 4.6.6 Storage of all pesticides shall be Storage of pesticides found to be in accordance with the Complied according to recognised best practices. Occupational Safety and Health Laws and Regulations and All pesticide containers shall be properly local laws on pesticides control. Permit for the hazardous disposed of and not used for other waste storage was available and maintained at Estate purposes (see Criterion 5.3). Pesticides shall be stored in accordance to the offices. Records verified. Occupational Safety and Empty chemical containers had been used for mixing Health Act 1994 (Act 514) and chemicals for spraying pesticides in the field. Extra unused Regulations and Orders, Pesticides Act empty chemical containers were triple rinsed and punctured 1974 (Act 149) and Regulations. before disposal by external contractors. Practise was Major Compliance verified onsite. 4.6.7 Application of pesticides shall be Pesticides had been applied using the proven methods Complied by proven methods that minimise risk and impacts. (Best Management Practices) that minimize risk and impacts. Minor Compliance 4.6.8 Pesticides shall be applied aerially It’s not the policy of the company to carry out aerial Complied only where there is documented justification. Communities shall be application of pesticides. This policy has been adhered. informed of impending aerial pesticide

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Major Compliance 4.6.9 Evidence of continual training to Periodic training on pesticide handling had been carried out. Complied enhance knowledge and skills of employees and associated smallholders Information on the pesticides displayed on the notice board on pesticide handling shall be and next to the pesticides in the store. demonstrated or made available. (see Criterion 4.8).

Minor Compliance 4.6.10 Proper disposal of waste Empty pesticide containers had been used for mixing Complied material, according to procedures that are fully understood by workers and chemical for spraying in the fields. Scheduled waste of palm managers shall be demonstrated (see oil mill had been disposed of through licensed contractor Criterion 5.3). approved by DOE. Records of scheduled waste involved at Minor Compliance the mill had been verified to be satisfactory. 4.6.11 Specific annual medical Annual medical surveillance for pesticide operators had Complied surveillance for pesticide operators, and documented action to treat related been implemented as follows: health conditions, shall be Kalabakan POM has sent 3 workers for medical surveillance demonstrated. on 1522014.

Major Compliance Kalabakan Tengah estate had sent 15 of its workers for medical surveillance on 1892013. Kalabakan Selatan estate has sent 20 of its workers for medical surveillance on 1892013. Medical surveillance reports of individual sprayers were available and details checked. Comments of abnormalities are stated by the Medical doctor. Those found unsuitable for handling pesticides or other health reasons are recommended by the Medical doctor to be assigned for other work. Estate managers do reassign those found unfit for spraying work. Besides the annual medical surveillance, clinical records are checked as maintained by at the clinics available. Interviews with the clinic nurses confirm that the workers with medical disorders or symptoms are checked thoroughly to determine if they are still suitable for field work. Workers interviewed at field visit were healthy and fit for work.

4.6.12 No work with pesticides shall be Verified from records, field inspections and interviews that Complied undertaken by pregnant or breast feeding women. no pregnant or breastfeeding woman had been offered work as pesticide operator. Major Compliance Kalabakan Selatan used only male workers for spraying operations. Criteria 4.7 An occupational health and safety plan is documented, effectively communicated and implemented. Indicators Findings and Objective Evidence Compliance The occupational health and safety plan Occupational Safety and Health (OSH) plan in compliance Complied shall cover the following: with OSH Act and Factory Machinery Act was documented 4.7.1 An occupational health and safety and implemented. policy shall be in place. An occupational OSH policy was clearly displayed at POM and in estates health and safety plan covering all office. Workers had demonstrated awareness towards activities shall be documented and occupational safety and health policy. implemented, and its effectiveness monitored. Risk assessment carried out on all operations where health and safety is an issue (e.g. noise exposure, pesticides / Major Compliance chemicals exposure, accident, fire).

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POM & its estates established their accident reporting KPI, and incident monitoring implemented. Procedures and actions documented and implemented on the issues concerned. Awareness and training programmes planned for year 2013 /2014 was consistently implemented. Evidence of training on safe working practices for workers involved in pesticides spray, use of fire extinguishers, awareness & understanding of MSDS/CSDS, First Aid boxes were sighted at both POM & estates. Precautions attached to products properly observed and applied to workers in the mill and estates. Appropriate PPE (safety boots, safety helmets, rubber boots, cartridge masks, safety goggles, ear plugs and mufflers, hand gloves, body aprons) verified to be provided in accordance to the area of work which has adequately covered all potentially hazardous operations such as high noise areas (above 90dB at POM) , welding/repair works (POM), pesticides application and harvesting (estate fields) The Safety & Health officer was responsible for overall in charge of safety and health planning, operation & coordination. Adequate fire extinguishers found to be located at strategic locations, operational and maintained in working condition. Training for estate workers in First Aid was carried out in the Group Estates and records maintained. First Aid equipment was available at POM, estates and at worksite. 4.7.2 All operations where health and All operations had been risk assessed, documented and Complied safety is an issue shall be risk assessed, and procedures and actions implemented. shall be documented and implemented All precautions attached to the products had been observed to address the identified issues. All and applied to the workers through MSDS. precautions attached to products shall be properly observed and applied to the workers.

Major Compliance 4.7 .3 All workers involved in the Awareness and training programme had been carried out. Complied operation shall be adequately trained in safe working practices (see Criterion All workers involved had been adequately trained in safe 4.8). Adequate and appropriate working practices. protective equipment shall be available Appropriate PPE had been provided to all workers at the to all workers at the place of work to cover all potentially hazardous place of work to cover all potentially hazardous operations. operations, such as pesticide application, machine operations, and land preparation, harvesting and, if it is used, burning.

Major Compliance 4.7.4 The responsible person/persons The responsible person (usually the Mandore or Headman) Complied shall be identified. There shall be records of regular meetings between the had been identified. responsible person/s and workers. Records of regular meetings between the responsible person Concerns of all parties about health, and workers to discuss about health and safety had been safety and welfare shall be discussed at verified to be satisfactory. these meetings, and any issues raised shall be recorded.

Major Compliance 4.7.5 Accident and emergency Accident and emergency procedures had been written and Complied procedures shall exist and instructions

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Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 25 of 50 KKS Kalabakan grouping - Main Assessment shall be clearly understood by all briefed to staff, workers, contractors and visitors. workers. Accident procedures shall be available in the appropriate language of Workers trained in First Aid were present in the mill and field the workforce. Assigned operatives operations. trained in First Aid should be present in First Aid Kits were available at worksites. Samples of First both field and other operations, and first Aid boxes were checked and contents found to be complete aid equipment shall be available at and in usable order i.e. at Field PM 07 D Block 1 of worksites. Records of all accidents shall Kalabakan Tengah estate when harvesting activities were in be kept and periodically reviewed. progress, and at Field PM 0F Block 13 of Kalabakan Selatan Minor Compliance Estate when spraying operation was in progress, during field visit. Records on all accidents had been verified to be maintained satisfactorily. Quarterly review on accident cases had been carried out during quarterly meeting of Environment, Safety, & Health (ESH) 4.7.6 All workers shall be provided with Medical care had been provided to all the workers. Local Complied medical care, and covered by accident insurance. workers are covered by SOCSO, whereas foreign workers of the Group Estates are covered by Foreign Workers Minor Compliance Compensation Scheme with ETIQA Takaful Bhd. insurance company. 4.7.7 Occupational injuries shall be Records on Lost Time Accident (LTA) metrics had been Complied recorded using Lost Time Accident (LTA) metrics. verified to be satisfactory.

Minor Compliance Criteria 4.8 All staff, workers, smallholders and contract workers are appropriately trained. Indicators Findings and Objective Evidence Compliance 4.8.1 A formal training programme shall A formal training programme on all aspects of RSPO Complied be in place that covers all aspects of the RSPO Principles and Criteria, and that Principles and Criteria has been established and includes regular assessments of training implemented. needs and documentation of the Training for various categories of operators, including all field programme. and office staff, with regards to their duties and training needs had been reviewed and found acceptable. Major Compliance 4.8.2 Records of training for each Records of training were available. However at Kalabakan Observation employee shall be maintained. Selatan estate, some records for new employees taken in CFK-02 Minor Compliance over the past 3 months were not updated yet. Thus an Observation was issued.

Principle 5: Environmental responsibility and conservation of natural resources and biodiversity Criterion 5.1 Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continual improvement. Indicators Findings and Objective Evidence Compliance 5.1.1 An environmental impact Documented Environmental Aspect and Impact Complied assessment (EIA) shall be documented. Assessment, Plans were documented for the POM and respective estates of Kalabakan PMU by the Plantation Sustainability and Quality Management (PSQM) Department Major Compliance of FELDA Group based in Kuala Lumpur in 2013. The assessment documents had included the identification of aspects from field activities that includes fertilizing, spraying, transportation of FFB, garbage disposal and road maintenance. The report includes action plans and

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recommendations in order to mitigate negative effects and promote positive ones such as sewage, landfills and conservation activities applicable to the PMU. 5.1.2 Where the identification of impacts The Management plan for mitigation of environmental requires changes in current practices, in impacts, timeframe for action and responsible persons order to mitigate negative effects, a were not adequately followed up by the Estate timetable for change shall be developed managers at the PMU. and implemented within a For instance at Ladang Tengah and Ladang Selatan the NC 6 of 8 - comprehensive management plan. The management of the landfill areas were not adequately management plan shall identify the Minor developed. responsible person/persons. EIA /PMM (Pelan Pengurusan Mitigasi) documentation Major / Minor -TBF review by Environment Protection Department i.e. Jabatan Perlindungan Alam Sekitar (JPAS) not available for Kalabakan PMU, and thus plans and recommendations on mitigating impacts which on replanting activities were also not available. Thus NCR was issued.

5.1.3 This plan shall incorporate a Implementation and monitoring of the documented Complied monitoring protocol, adaptive to environmental improvement plans were planned and operational changes, which shall be reviewed on an annual basis scheduled at the 1 st quarter of implemented to monitor the each year. effectiveness of the mitigation measures. The plan shall be reviewed The review had considered the mitigation of negative as a minimum every two years to reflect impacts and promotion of positive ones such as the proper the results of monitoring and where demarcation of buffer zone, clearing of overgrown natural there are operational changes that may vegetation and debris along the streams, disposal of have positive and negative scheduled and domestic wastes at the PMU. environmental impacts. Major / Minor -TBF The monitoring of the documented environmental improvement plans is currently ongoing. See above NCR under C5.1.2 on the inadequate implementation. Criterion 5.2 The status of rare, threatened or endangered species and other High Conservation Value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and operations managed to best ensure that they are maintained and/or enhanced. Indicators Findings and Objective Evidence Compliance 5.2.1 Information shall be collated in a Information has been collated in a HCV assessment and Complied High Conservation Value (HCV) being conducted by a consultancy company, Aksenta dated assessment that includes both the 29 March 2014 for the Kalabakan PMU. The exercise has planted area itself and relevant wider taken into consideration all aspect of environmentally landscapelevel considerations (such as wildlife corridors). sensitive areas such as ponds, streams and forest reserve boundaries.

Major Compliance Conservation areas such as neighbouring forest reserves, swamp lands and river tributaries adjacent to the PMU were indicated. Based on the review, there were no HCV areas apart from the identified conservation areas for hilly terrain, steep gorges and buffer zones needed for streams passing within the PMU estates. 5.2.2 Where rare, threatened or Regular patrols within the POM and PMU were being carried Complied endangered (RTE) species, or HCVs, out and findings recorded by the respective Estate are present or are affected by plantation executives to monitor the Conservation / buffer zone areas. or mill operations, appropriate measures that are expected to maintain The occasional sightings of various types of wildlife and/or enhance them shall be encountered such as eagles, herons and crocodiles were implemented through a management found to have been recorded. plan. Monitoring and control of any illegal hunting, fishing or collecting activities was also implemented. Some signages Major Compliance that prohibit hunting, fishing and water polluting activities

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were verified onsite and found to have been satisfactorily maintained. 5.2.3 There shall be a programme to The program to regularly educate the workforce and Complied regularly educate the workforce about community about the status of these RTE species are also the status of these RTE species, and established with ongoing consultation with the relevant appropriate disciplinary measures shall authorities such as the Sabah Wildlife Department (Jabatan be instigated in accordance with company rules and national law if any Kehidupan Liar, Sabah) at the Kalabakan PMU. individual working for the company is There is evidence of commitment to discourage any illegal found to capture, harm, collect or kill or inappropriate hunting, fishing or collecting activities via these species. the signages erected which prohibit such activities. Major Compliance 5.2.4 Where a management plan has Management plans were established and monitoring Complied been created there shall be ongoing outcomes were reviewed by the Estate managers. There are monitoring: no HCV or reported RTE. which has been verified during on • The status of HCV and RTE species site assessment to be satisfactory. that are affected by plantation or mill operations shall be documented and Ongoing monitoring of the overall management plan on the reported; status of any HCV and / or RTE species at the Kalabakan • Outcomes of monitoring shall be fed estate areas is collated and reviewed by the HQ back into the management plan. Sustainability team for the PMUs in the region. Major / Minor -TBF 5.2.5 Where HCV setasides with It is verified that there has been no instance of HCV set Complied existing rights of local communities aside that conflicts with the rights of local communities at the have been identified, there shall be PMU estates assessed. Thus negotiated agreement of such evidence of a negotiated agreement nature is not applicable. that optimally safeguards both the HCVs and these rights. Major / Minor -TBF Criterion 5.3 Waste is reduced, recycled, reused and disposed of in an environmentally and socially responsible manner. Indicators Findings and Objective Evidence Compliance 5.3.1 All waste products and sources of Visits made to POM and PMU estates showed that all waste Complied pollution shall be identified and products and sources of pollution were identified and documented. documented. The documentation and identification of all the waste Major Compliance products such as scheduled waste, domestic waste , clinical waste and recyclable waste such as metal, plastic, mill waste and polluting materials e g. EFB, POME, Stack emissions and Boiler ashes were maintained and monitored at the PMU. Segregation of wastes i.e. scheduled wastes and general wastes were verified to be satisfactory. The mill and estates also have a proper Scheduled Waste Store for storing scheduled waste until time of disposal by DOE authorized waste disposal contractors e.g. Petrojadi Sdn Bhd. Scheduled Waste identified included spent hydraulic oil (SW 305), spent lubricant oil (SW 306), used chemical containers/drums (SW 409), used filters (SW 410), clinical waste (SW 404) and used batteries (SW 102). Appropriate secondary containment for the diesel skid tanks, chemical and scheduled waste storage areas was verified to be maintained. Proper storage areas were available for the storage of the recyclable wastes at the POM and estates.

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5.3.2 All chemicals and their containers At the POM, the disposal of used chemicals and containers shall be disposed of responsibly. were done accordingly to their schedule on waste management as planned. Scheduled waste stores inspected

Major / Minor -TBF at audited sites and disposal was done by scheduled waste disposal company authorized and licensed by Department of Environment (Jabatan Alam Sekitar) i.e. Petrojadi Sdn Bhd. The last record of disposal done was in January 2014. However at the PMU estates, chemical containers were NC 7 of 8 - not disposed in a responsible manner. For instance at Minor Kalabakan Tengah and Kalabakan Selatan, the disposal plan for chemical containers which are under Scheduled waste code SW 409 were not adequately documented and implemented. At Ladang Selatan, there was improper re-use of some empty chemical containers at the line site and field. Thus a NC was issued. 5.3.3 A waste management and The waste management and disposal plan were in place at Complied disposal plan to avoid or reduce both the POM and PMU. It has been documented and pollution shall be documented and implemented as required and is being carried out implemented. responsibly.

Waste disposal was done an appointed contractor that is Major / Minor -TBF licensed by the Department of Environment. The solid waste management and disposal plan using landfills was available at the mill and estates. The designated landfill areas at Kalabakan Tengah and Selatan estates were verified to be at least more than 50m away from any streams / water sources, thus minimizing the risk of contamination of contamination of water sources. Recycling of crop residues / biomass i.e. EFB and POME had been implemented. Management EFB application plans and progress reports were verified to be satisfactory. Recycling bins of three different colour codes for specific recycle waste were available in the POM and estates and were used for solid waste segregation and recycling. Criterion 5.4 Efficiency of fossil fuel use and the use of renewable energy is optimised. Indicators Findings and Objective Evidence Compliance 5.4.1 A plan for improving efficiency of The use of energy in palm oil mill and line site was Complied the use of fossil fuels and to optimise monitored monthly to compare the energy usage against the renewable energy shall be in place and production of CPO. Electricity generation was through steam monitored. turbine and boiler where Palm fiber and PK shells were used as renewable energy/fuel on a 70:30 ratio basis. Minor Compliance Monthly records of energy consumption of nonrenewable and renewable fuel per metric tonne of palm product at the POM were available. At POM, average energy usage for 2013 is at 0.23 kWh/mt FFB processed and current average for 2014 is at 0.21 kWh/mt FFB processed. At the estates, diesel consumption per metric ton FFB was also monitored on a monthly basis. It is verified that energy usage are being monitored at the PMU for better control and comparison of trends. Criterion 5.5 Use of fire for preparing land or replanting is avoided, except in specific situations as identified in the ASEAN

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Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 29 of 50 KKS Kalabakan grouping - Main Assessment guidelines or other regional best practice. Indicators Findings and Objective Evidence Compliance 5.5.1 There shall be no land preparation The Group policy of ‘Zero open burning’ is enforced since Complied by burning, other than in specific July 2011. Both the POM (Kalabakan) and PMUs had situations as identified in the ‘Guidelines observed the policy of ‘Zero open burning’ for any replanting for the Implementation of the ASEAN at the estates. Policy on Zero Burning’ 2003, or comparable guidelines in other regions. Field inspections made at Kalabakan Tengah and Selatan, where replanting has been carried out showed no evidence Major Compliance of open burning. 5.5.2 Where fire has been used for The PMU has adhered to the ‘zero burning ‘policy for Complied preparing land for replanting, there shall replanting at the estates. Replanted areas visited showed no be evidence of prior approval of the evidence of fire being used for land preparation. controlled burning as specified in ‘Guidelines for the Implementation of There was also no evidence of any burning of domestic the ASEAN Policy on Zero Burning’ waste at the housing line sites and at the sanitary landfills of 2003, or comparable guidelines in other the estates during on site field assessment. regions. Minor Compliance Criterion 5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and monitored. Indicators Findings and Objective Evidence Compliance 5.6.1 An assessment of all polluting The PMU had reviewed the environmental impact activities shall be conducted, including assessment on potential pollution to water, gaseous gaseous emissions; particulate/soot emissions to air and contamination on land. emissions and effluent (see Criterion Monitoring of POM air emissions has been recently 4.4). commissioned since April 2014 online using the Continuous Emissions Monitoring System (CEMS) and emissions were Major Compliance verified to be within the permissible limits of DOE. Noted that Ringlemann Smoke charts were still maintained as a backup for the CEMS monitoring by DOE.

POME treatment, monitoring and land application is monitored and maintained. Correspondence with DOE/EPD Sabah had indicated that the POM is instructed to lower their BOD limits from the existing 50ppm to 20ppm in the Kalabakan region, by the end of 2014. An extension letter for upgrading of POM effluent treatment to EPD, Sabah dated 24 April 2014 was evidenced. The POM had constructed a new Bio polishing plant, which is due for commission in July 2014.

It was noted that BOD levels prior final discharge was Refer to averaging at 45ppm and being progressively reduced in Observation order to meet the latest DOE / EPD regulations of 20 CFK-01 ppm. Refer to Observation CFK-01, issued under indicator 4.4.3 for follow up in the next assessment. 5.6.2 Significant pollutants and Identification of significant pollutants and greenhouse gas greenhouse gas (GHG) emissions shall (GHG) emissions was implemented e.g. POME, diesel / fuel be identified, and plans to reduce or and fertilizer. Their usage have been recorded and minimise them implemented. documented at the PMU.

However the plans to further reduce or minimise GHG Major / Minor -TBF Observation emissions are still yet to be established and AL-01 implemented. Thus an observation is issued for further monitoring plans for reduction of GHG emissions at the PMU. This will be followed up during the next

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surveillance – See Observation raised, AL-01

5.6.3 A monitoring system shall be in Monitoring and reporting of the significant pollutants to Complied place, with regular reporting on water, gaseous emissions to air and contamination on land progress for these significant pollutants are in place. and emissions from estate and mill operations, using appropriate tools. Tools and systems used include the DOE/EPD online CEMS monitoring for air emissions, water quality analysis at the discharge points and SW disposal in accordance with Sabah Major / Minor -TBF DOE requirements. POME is being treated using a series of 14 ponds including aerobic and anaerobic ponds before discharge. Water samples were regularly taken every six months and tested by mill environment officer in charge and analyzed to ensure compliance to DOE requirements at final discharge points. The water samples were sent to Felda Agricultural Services analytical laboratory for analysis. The discharged water is 100% used for land application into Kalabakan Tengah estate of the PMU as per approval issued by the Sabah DOE. Records and regular reporting to DOE were noted to be maintained and verified onsite.

Principle 6: Responsible consideration of employees, and of individuals and communities affected by growers and mills Criteria 6.1 Aspects of plantation and mill management that have social impacts, including replanting, 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 continual improvement. Indicators Findings and Objective Evidence Compliance 6.1.1 A social impact assessment (SIA) The Social Impact Assessment (SIA) based on interim Complied including records of meetings shall be documented. report prepared by Aksenta, a consultancy company, sighted and verified. The assessment was between 23 and Major Compliance 29 March 2014 which covered both Felda Kalabakan and Felda Umas PMUs. Full report is expected to be completed by July 2014. In addition, a stakeholder consultation was also conducted at regional level on 17 Dec. 2013 involving all Felda plantations and POMs in Sabah, internal and external stakeholders. However the issues raised during the regional stakeholder consultation do not cover specific issues at the Felda Kalabakan PMUs. Specifically in Felda Kalabakan Selatan a social survey was conducted by the management in Mar. 2014 in addition to the assessments made above. The survey is conducted using form to available in Manual Lestari 1A [ML1A/L4 FF30(0), Mar. 2012. 6.1.2 There shall be evidence that the The participation of both internal and external stakeholders Complied assessment has been done with the participation of affected parties. (including local from Governmental organizations) was evident in the list of interviewees stated in Aksenta interim Major Compliance social impact assessment report. Around 105 interviewees listed in the report including villagers living at the vicinity of the PMU, outside crop suppliers, shops owners, sub contractors, government agencies, etc. 6.1.3 Plans for avoidance or mitigation Mitigation plan dated 26 May 2014 sighted at the PMUs is Complied

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Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 31 of 50 KKS Kalabakan grouping - Main Assessment of negative impacts and promotion of based on stakeholder consultation conducted on 17 Dec. the positive ones, and monitoring of 2013. This is a generic mitigation plan which did not include impacts identified, shall be developed specific issues at the Felda Kalabakan PMU. A more PMU in consultation with the affected parties, specific mitigation was only available at Felda Kalabakan documented and timetabled, including responsibilities for implementation. Selatan prepared dated 13 Mar. 2014 and prepared by Muhammad Nasuha Bin Abd.Manan. Other estate Major / Minor - TBF managements prepare their own specific plan based on final social impact assessment prepared by Aksenta. However, Aksenta interim social impact assessment has already listed the negative impacts and promotion of the positive ones such as the continued support for the surrounding local communities, schools (both primary and secondary) for migrant as well as local workers children. 6.1.4 The plans shall be reviewed as a There is no revision plan being developed for verification Complied minimum once every two years and updated as necessary, in those cases during the audit. This is due to the fact that the first where the review has concluded that mitigation plan for Felda Kalabakan PMU specific should be changes should be made to current based on final SIA report which has not been published by practices. There shall be evidence that Aksenta yet. the review includes the participation of A generic mitigation plan based on stakeholder consultation affected parties. on 17 Dec. 2013 conducted in Felda Sahabat,

Minor Compliance is sighted and verified. 6.1.5 Particular attention shall be Positive impacts such as increased work opportunities, Complied paid to the impacts of smallholder schemes (where the plantation increased income and improved living standards are includes such a scheme). identified. Two OCPs supplying to the PMUs, i.e. Persatuan Peladang Kawasan [PPK] and Usahawan Borneo, reported Minor Compliance an increase in quantity of FFB supplied the POM. Criteria 6.2 There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties. Indicators Findings and Objective Evidence Compliance 6.2.1 Consultation and communication Documented policies and procedures are available for Complied procedures shall be documented. internal and external communication and consultation. Major Compliance Policy on industrial relations is available, i.e, “Polisi Liasion Perhubungan Sosial”, for internal communication and consultation. Complaint procedure is also available through complaint and handling methods, i.e. reference document is ML1A/L2PR3(0). Estate managers and other nominated persons are responsible for communication with the stakeholders. The organization has a list of stakeholders including local authorities, government departments, suppliers and contractors. Among available channels of communications between the management and affected or interested parties are, the Joint Consultative Committee [JCC] and workers representatives at the management meetings. All of these meetings are conducted frequently. Other than meetings and gatherings, affected parties also have access to workplace inspections, suggestion boxes, housing maintenance request forms and morning roll calls to raise their concerns. 6.2.2 A management official Appointment records sighted show evidence the existence Complied responsible for these issues shall be nominated. of a management official for these issues. Interviews with mill and estate managers verified the understanding of their Minor Compliance roles and responsibilities. For example, appointment letters for Mr. Sabri, Assistant Manager at the POM and Mr. Kadir

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Mausal, Penyelia Ladang Kalabakan Tengah 01 dated 5 June 2014 were sighted and verified. 6.2.3 A list of stakeholders, records List of stakeholders are sighted in “P6 Tanggungjawab Complied of all communication, including confirmation of receipt and that Terhadap Pekerja dan Komuniti” file at the POM and in in efforts are made to ensure “Impak and Sosial Mitigasi 6.1.1” file in Felda Kalabakan understanding by affected parties, Selatan. and records of actions taken in Noted that there are open and transparent methods for response to input from communication and consultation which has taken into stakeholders, shall be maintained. consideration the local conditions including migrant workers

Minor Compliance and job opportunities for local people. Verified that consultations with various stakeholders had been held during the preparation of SIA report by Aksenta in Mar. 2014 and during stakeholder consultation held on 17 Dec. 2013 in Felda Sahabat, Lahad Datu. Criteri a 6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all affected parties. Indicators Findings and Objective Evidence Compliance 6.3.1 The system, open to all affected The PMU has an established and documented system for parties, shall resolve disputes in an effective, timely and appropriate dealing with complaints and grievances and it was well implemented. Reference document Manual Lestari 1A [ML manner, ensuring anonymity of complainants and whistleblowers, 1A/L2PR4(0)] sighted and verified. where requested. So far there were no cases reported in 2014. Respect of anonymity and protection of complainants is provided Major Compliance through “Polisi Pemberian Maklumat”, dated 18 Jan. 2013 signed by Dato’ Sabri Ahmad, Group President. So far the record shows the ‘Complaints and Grievances Book’ in all estates are still active in recording complaints/requests made by employees and actions taken. However, complaints and grievances are mostly on maintenance of the housing quarters and followup not appropriately recorded thus determination whether the complaints and grievances are handled in timely manner cannot be made. For example in Felda Kalabakan Selatan requests for house maintenance received with no dates indicated and proof of followup actions taken are only

based on work orders issued and payments made to the contractors. Date if actual job completions are not indicated to determine the requests are handled in timely manner. E.g. S12L34, Safuan Amat made a report of piping problem in bathroom, payment made to Mewah Jaya Trading received on 17 Feb. 2014 Interviews with staff and workers and their representatives revealed knowledge and understanding of the complaints, dispute and resolution mechanism. The mechanism provides for open and consensual agreements with relevant

affected parties.

However, the channels for external stakeholders to submit complaints and grievances are not well NCR 8 of 8 – explained and made accessible. Thus an NCR was Major issued. 6.3.2 Documentation of both the Complaints and grievances are handled by respective Complied process by which a dispute was resolved and the outcome shall be nominated persons or through various occasions as available. mentioned in 6.2.1. A record book is used to forward a complaint or make a request for maintenance. Major Compliance Mechanisms are appropriately established and implemented but not well explained and made accessible

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especially for external stakeholder. Records of meeting and any resolutions or outcomes, especially request for house maintenance, are maintained through issuance of work orders [surat perintah kerja] for each individual case. But these work orders did not specify the dates of job completion. Criteria 6.4 Any negotiations concerning compensation for loss of legal, customary or user rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions. Indicators Findings and Objective Evidence Compliance 6.4.1 A procedure for identifying legal, There are borders adjacent to villages and native land in the Complied customary or user rights, and a PMU. However, no cases require any negotiation or procedure for identifying people entitled compensation pertaining to these criteria. This because The to compensation, shall be in place. Felda PMU operations in Sabah are based on approval

Major Compliance from state government through “Warta Kerajaan Negeri Sabah”, No. 148 and 223 in 1979. Futhermore, the PMU is also managing some parts of the Kaum Murut NCR lands under the state government and Felda agreement dated 10 Feb. 1983. Based on this agreement the NCR land will be under Felda management for 99 years with an annual dividend payable to the Kaum Murut involved. There have been no changes in this status as at the period of verification on site, therefore, no cases requiring any negotiation or compensation pertaining to these criteria. 6.4.2 A procedure for calculating and There are borders adjacent to villages and native land in the Complied distributing fair compensation PMU. However, no cases require any negotiation or (monetary or otherwise) shall be compensation pertaining to these criteria. This because The established and implemented, Felda PMU operations in Sabah are based on approval monitored and evaluated in a participatory way, and corrective from state government through “Warta Kerajaan Negeri actions taken as a result of this Sabah”, No. 148 and 223 in 1979. Futhermore, the PMU is evaluation. This procedure shall take also managing some parts of the Kaum Murut NCR lands into account: gender differences in the under the state government and Felda agreement dated 10 power to claim rights, ownership and Feb. 1983. Based on this agreement the NCR land will be access to land; differences of under Felda management for 99 years with an annual transmigrants and longestablished dividend payable to the Kaum Murut involved. communities; and differences in ethnic groups’ proof of legal versus communal There have been no changes in this status as at the period ownership of land. of verification on site, therefore, no cases requiring any negotiation or compensation pertaining to these criteria. Minor Compliance 6.4.3 The process and outcome of any There are borders adjacent to villages and native land in the Complied negotiated agreements and PMU. However, no cases require any negotiation or compensation claims shall be compensation pertaining to these criteria. This because The documented, with evidence of the Felda PMU operations in Sabah are based on approval participation of affected parties, and made publicly available. from state government through “Warta Kerajaan Negeri Sabah”, No. 148 and 223 in 1979. Futhermore, the PMU is Major Compliance also managing some parts of the Kaum Murut NCR lands under the state government and Felda agreement dated 10 Feb. 1983. Based on this agreement the NCR land will be under Felda management for 99 years with an annual dividend payable to the Kaum Murut involved. Annual dividend payments made to 215 Kaum Murut involved are sighted and verified. There have been no changes in this status as at the period of verification on site, therefore, no cases requiring any negotiation or compensation pertaining to these criteria. Criteria 6.5 Pay and conditions for employees and for contract workers always meet at least legal or industry minimum

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Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 34 of 50 KKS Kalabakan grouping - Main Assessment standards and are sufficient to provide decent living wages. Indicators Findings and Objective Evidence Compliance 6.5.1 Documentation of pay and Documentation and conditions of pay are available for both Complied conditions shall be available. local and migrant workers. Employment agreement for Major Compliance Indonesian foreign workers in “Surat Perjanjian Pekerjaan diantara Felda Global Ventures Plantations (M) Sdn. Bhd. (974143 – H) dengan Pekerja Asing Indonesia”.stated all statutory fringe benefits and eligible incentives, e.g. working hours, overtime, leave and medical benefits, maternity leave for women, insurance coverage, deductions, resignation notice period, company rules. The payment slips sighted are easy to understand and this fact was further verified with migrant workers. Payments are made latest by 7 th of each month and consistent with Minimum Wage Order 2012 for all employees in the PMU. Holidays entitlements as required by the laws are satisfactorily fulfilled, e.g. annual leaves, public holidays, and maternity leave. Payments for unused annual leaves in December 2013 were sighted in all PMUs. The PMU also provides free housing and piped water supply, free electricity, medical benefits, insurance cover, mosques, church and welfare amenities that in overall constitutes a decent living for the employees. 6.5.2 Labour laws, union agreements Documented employment contract verified for migrant Complied or direct contracts of employment detailing payments and conditions of workers had covered all issue such as working hours, employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, deductions, overtime, sickness, holiday maternity leave, and reasons for dismissal, period of notice entitlement, maternity leave, reasons made available in Bahasa Malaysia which is understood by for dismissal, period of notice, etc.) the workers (local and foreign workers). This contract is shall be available in the languages known as “Surat Perjanjian Pekerjaan diantara Felda Global understood by the workers or explained Ventures Plantations (M) Sdn. Bhd. (974143 – H) dengan carefully to them by a management Pekerja Asing Indonesia. official. The same issues covered in contract document for local Major Compliance workers, i.e. “Pengakuan Penerimaan Syaratsyarat Perkhidmatan Petugas Syarikat Kumpulan Felda & Kod Etiksa dan Tatalaku Petugas Syarikat Kumpulan Felda yang berkuatkuasa Mulai 1 Januari 2010” 6.5.3 Growers and millers shall provide The estate management was noted to have complied with Complied adequate housing, water supplies, medical, educational and welfare Workers’ Minimum Standard of Housing and Amenities Act 1990 (Act 446). amenities to national standards or above, in accordance with Workers’ Site visits to workers’ homes and interviews with their Minimum Standard of Housing and dependents revealed their general satisfaction with their Amenities Act 1990 (Act 446) or above, housing conditions and amenities. where no such public facilities are available or accessible (not applicable Housing, electricity and water supply to smallholders). Workers are given a small patch of land to grow vegetables/fruit trees and keep poultry around their houses Minor Compliance in order to reduce the cost of living. The workers staying in

the estate are provided with free electricity and treated pond water 24 hours daily. There are still wooden quarters being used however the PMU is in the process of replacing them with brick terrace houses. Schools The migrant workers’ children had received free education in a NGOmanaged school, i.e. Yayasan Pelita located in Felda Kalabakan Tengah 01. Maintenance of the school building, furniture, electric and water supplied are is under

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the purview of the estate management. Furthermore, three foreign teachers originally from Indonesia are paid by the estate management as well. There is another NGO

managed school There are government managed primary, secondary, kindergarten and religious schools in the vicinity of the PMUs for local workers children. School children of local and foreign workers are ferried to and from the school on the estates own school buses. Sundry shops Sundry shops available outside the PMU but still accessible to the workers. Only Felda Kalabakan Selatan have sundry shops within the estate. The availability of sundry shops helped the staff and workers get their sundries nearby. From interviews with the workers in PMU it was found that most household sundries, including frozen foodstuffs were available on sale. Fresh food, such as fish, chicken, vegetable and meat are also brought in by fresh food suppliers into the estates in food trucks at least twice a week. Crèche ( Rumah Asuhan Kanakkanak) There is no crèche within PMU. Children are either stay at home under the care of other relatives or sent to the kindergarten. Medical clinics Felda Kalabakan PMU panel clinic is located in Kalabakan village very near and easily accessible. All medical related issues minor or major will be referred to the panel clinic. Each workers local and foreign, with or without family, are entitled for medical allowance of RM200/year. Fogging activities for controlling of mosquitoes by the local Dept. of Health are frequently at the workers quarters. Other amenities available are playing field and courts, community hall, playing grounds as well as mosque. 6.5.4 Growers and millers shall make Food for the workers provided through sundry shops within Complied demonstrable efforts to monitor and where able, improve workers’ access to the Felda Kalabakan Selatan estate and surrounding area. adequate, sufficient and affordable The PMU also allows access to the food trucks supplying food. fresh food to the workers quarters at least twice a week.

Minor Compliance Criteria 6.6 The employer respects the rights of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel. Indicators Findings and Objective Evidence Compliance 6.6.1 A published statement in local The published statements of policy “Kebebasan Complied languages recognising freedom of association shall be available. Menganggotai Kesatuan /Khidmat Sukarela”, dated 28 Jun. 2011 signed by Dato’ Dzulkifli Abd. Wahab, Pengarah Major Compliance Besar Felda, recognises the employee’s freedom of association, was found to be available and widely displayed in all notice boards of the PMUs. This policy is available in Bahasa Malaysia which can be understood by majority of the workers. 6.6.2 Minutes of meetings with main Under the policy mentioned above two workers unions are Complied trade unions or workers representatives shall be documented. formed, i.e. “Kesatuan PekerjaPekerja FPISB (Sabah)” for local mill workers and “Kesatuan PekerjaPekerja Felda Global Plantation” for the local plantation workers. No

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Minor Compliance association available for migrant workers as it is prohibited by the law. Meetings of both of these unions are minuted and properly, FPISB last meeting was 2 Apr. 2014 and meeting for the Kesatuan PekerjaPekerja FPISB (Sabah) was on 28 Dec. 2013. In 2013 the workers’ union main achievement was to acquire monthly minimum wages of RM900 which is equal to minimum wages in Peninsular Malaysia instead of RM800 for Sabah and Sarawak. Back payment was made starting January to August in 2013. Criteria 6.7 Children are not employed or exploited. Indicators Findings and Objective Evidence Compliance 6.7.1 There shall be documentary The PMU has a policy of not employing child labour i.e. Complied evidence that minimum age requirements are met. persons below 17 years old in accordance with Employment Act 265 as evidenced in “Polisi Pekerja KanakKanak”, Major Compliance dated 20 Dec. 2010 signed by Dato’ Dzulkifli Abd. Wahab, Pengarah Besar Felda This policy is displayed at strategic public places. Employees and workers profile were sighted during the audit. No underage workers or children were noted to be working at the estates. This fact was further verified through interviews with staff and workers in the PMU estates. Criteria 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited. Indicators Findings and Objective Evidence Compliance 6.8.1 A publicly available equal The PMU has a publicly displayed documented policy on Complied opportunities policy including identification of relevant/affected equal opportunities, i.e. “Polisi Kesetaraan Peluang”, dated groups in the local environment shall 20 Dis. 2010, signed by Dato’ Dzulkifli Abd. Wahab, be documented. Pengarah Besar Felda. The policy stressed on non discrimination based on race, caste, nationality, religion, Major Compliance gender, sexual orientation, disability/handicap, and union/political affiliations. However, positive discrimination for the benefit of certain society groups may be allowed after consultation. The POM does not employ any foreign workers. Foreign Indonesian workers were hired at the estates. 6.8.2 Evidence shall be provided that There is a documented policy on foreign workers “Polisi Complied employees and groups including local communities, women, and Pengambilan Pekerja Asing” dated 28 June 2011, signed by migrant workers have not been Dato’ Dzulkifli Abd. Wahab, Pengarah Besar Felda. It is discriminated against. publicly displayed along with other policies at strategic places. Major Compliance Compliance to relevant regulatory requirements such as Sabah Labour Ordinance 1950, Minimum Wages Order 2012, Immigration Act 1959/63 and Workmen’s Compensation Act 1952 are observed when recruiting workers from Indonesia. The employment of foreign workers was implemented without affecting the opportunities for local communities. Local workers are covered under SOCSO scheme and the migrant workers are covered under Foreign Workers Compensation scheme (FWCS) underwritten by Etiqa Takaful with latest coverage valid until 31 Jan. 2015 in Felda Kalabakan Selatan. There were cases of accidents approved

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by the local Labour Department for compensation. Compensations were paid to the respective workers and all necessary documents were sighted and verified. Interviews with migrant workers’ dependents revealed their satisfaction with the PMU for job opportunities and they enjoy all common welfare amenities like free housing, free water and electricity supplies, medical care, and transportation of school children. They are aware of the “aduan” mechanism by which they can make any complain or request to the management. 6.8.3 It shall be demonstrated that Depending on the nature of work positions, The PMU Complied recruitment selection, hiring and promotion where relevant are based on management takes into considerations the needs for skills, capabilities, qualities, and technical qualifications/experience and related skills in medical fitness necessary for the jobs recruitment selection, hiring and promotion exercises. available. It was verified that the promotions to higher position at the estates and POM were based on evaluations which Minor Compliance considered the skill, capabilities, qualities and medical fitness of the employees. Criteria 6.9 There is no harassment or abuse in the work place, and reproductive rights are protected. Indicators Findings and Objective Evidence Compliance 6.9.1 A policy to prevent sexual and all A documented policy to prevent sexual harassment and Complied other forms of harassment and violence shall be implemented and violence is available and publicly displayed, i.e. “Polisi communicated to all levels of the Gangguan Seksual Dan Keganasan”, dated 28 Jun. 2011 workforce. signed by Dato’ Dzulkifli Abd. Wahab, Pengarah Besar Felda. Major Compliance However, through letters of appointment sighted, Gender Committees in the PMUs were only formed a few days prior to site visit, e.g. appointment of Asurah bte Baitan, Supervisor in Felda Kalabakan Tengah 1 dated 5 June 2014 by the Estate Manager, Muhammad Dari Sari. For that reason, the Gender Committees in the PMU have very limited time available to prepare as a fully functional committee during the site visit. 6.9.2 A policy to protect the The PMU’s commitment to protect the reproductive rights Complied reproductive rights of all, especially of women, shall be implemented and and rights to have a family of the workers especially women communicated to all levels of the is evidently stated in the policy to prevent sexual harassment workforce. and violence “Polisi Gangguan Seksual Dan Keganasan”, dated 28 Jun. 2011 signed by Dato’ Dzulkifli Abd. Wahab, Major Compliance Pengarah Besar Felda. Local female staff is fully aware that they are entitled for two months paid maternity leave. Staff on maternity leave is paid according to the regulation, e.g. twomonth pay awarded to Filisnah Bte Saminggul who gave birth in April 2014 was sighted and verified. Through interviews made in Felda Kalabakan Selatan, a foreign women worker willingly to temporary discontinue her service to the estate due to her pregnancy. She will continue her service after giving birth. 6.9.3 A specific grievance mechanism Complaint and grievance procedures “Prosedur Menangani Complied which respects anonymity and protects complainants where requested shall be Aduan dan Rungutan dan Polisi Pemberian Maklumat / established, implemented, and whistleblowing” are available to manage grievances and communicated to all levels of the complaints from internal and external stakeholders. workforce. Onsite audits verified that the complaint and grievance procedure and whistle blowing procedure are displayed Minor Compliance outside staff offices, muster call stations and at the public

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areas. Interviews with Management personnel confirmed that there has been no report of sexual harassment in the PMU so far. Criteria 6.10 Growers and millers deal fairly and transparently with smallholders and other local businesses. Indicators Findings and Objective Evidence Compliance 6.10.1 Current and past prices paid for Onsite audit verified that the current and past prices paid for Complied Fresh Fruit Bunches (FFB) shall be publicly available. FFB pricing were displayed at the Mill and Estate offices.

Minor Compliance 6.10.2 Evidence shall be available that FFB prices were displayed at POM office’s Notice Board and Complied growers/millers have explained FFB pricing, and pricing mechanisms for available at mill office records. The POM was found to have FFB and inputs/services shall be treated outgrowers and other local business fairly. documented (where these are under Pricing mechanism for FFB is fair and transparent. Price of the control of the mill or plantation). FFB was set based on MPOB approved price. FFB was also graded by licensed graders based on MPOB specification. Major Compliance Training attended and results of the test taken by the licensed grader, Rosli Idris passed MPOB “Peperiksaan Kemahiran Menggred Buah Kelapa” on 20 Apr. 2005 at the POM was verified. 6.10.3 Evidence shall be available that Stakeholder interviews conducted during this assessment Complied all parties understand the contractual agreements they enter into, and that with suppliers, contractors, and relevant parties including contracts are fair, legal and local and foreign workers confirmed that understand the transparent. contractual agreements (such as terms and payment) they enter into with the PMU. They also consider the business

Minor Compliance transactions as fair and transparent. 6.10.4 Agreed payments shall be made Agreed payments are made and almost all made promptly Complied in a timely manner. within 30 day of the following month. Only one specific OCP Minor Compliance supplier, i.e. Persatuan Peladang Kawasan [PPK], had experienced for a number of times delayed payments from the POM in 2014. However in general through interviews made, there is no evidence to suggest of any unfair business practices with the local businesses. Criteria 6.11 Growers and millers contribute to local sustainable development where appropriate. Indicators Findings and Objective Evidence Compliance 6.11.1 Contributions to local The PMU’s contribution towards local communities had been Complied development that are based on the results of consultation with local evidenced in several social areas and verified during on site communities shall be demonstrated. visit as follows: • Providing free water, electricity, transports for school Minor Compliance children as well as paying the wages of teachers at Yayasan Peduli, i.e. school for foreign workers children school in Felda Kalabakan Selatan. • Providing maintenance of public amenities at Kaum Murut village, e.g. bridges, road, water works. • Organising blood donation campaign conducted on 2 Mar. 2014 for • Continuous plan to replace old wooden quarters with new brick quarters for all workers. • Plan to build a proper mosque at Felda Kalabakan Selatan quarters for the use of Moslem workers. • Major road repair has been approved on road leading to the POM for comfort of the vehicles using the road.

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6.11.2 Where there are scheme It was verified that there were no smallholder scheme N.A. smallholders, there shall be evidence that efforts and/or resources have been programs at the Felda Kalabakan PMU estates. allocated to improve smallholder productivity.

Minor Compliance Criteria 6.12 No forms of forced or trafficked labour are used. Indicators Findings and Objective Evidence Compliance 6.12.1 There shall be evidence that no Audit of employment records such as work permits in an Complied forms of forced or trafficked labour are used. estate office confirmed that all Indonesian migrant workers were recruited through legal means and according to the Major Compliance regulatory requirements. Unit Tenaga Kerja, FELDA Global Ventures [FGV] located in Felda Sahabat, Lahad Datu, is the main unit organising recruitment of new migrant workers in collaboration with private recruitment agencies. PMUs responsibilities are only to allocate each migrant worker with suitable accommodation and offer them enough jobs in a month. There are migrants workers found to have their family members staying at the linesites, but these are those workers who have entered Sabah long before the immigration rules being enforced. These workers have valid travelling documents and working permit. The PMUs even arrange staying permit for their family members through annual deduction and payment to the Immigration Department. Interviews with migrant workers and their dependents in the housing are confirmed that there were no forced or trafficked labours. 6.12.2 Where applicable, it shall be There was no evidence of contract substitution and this was Complied demonstrated that no contract substitution has occurred. confirmed from interviews with workers and relevant stakeholders. Minor Compliance 6.12.3 Where temporary or foreign The special policy on recruitment of foreign workers “Polisi Complied workers are employed, a special labour policy and procedures shall be Pengambilan Pekerja Asing” and equal opportunities “Polisi established and implemented. Kesetaraan Peluang” are established and the implementations are verified to be satisfactory. Review on Major Compliance employment contracts of foreign workers also confirmed that the policies, including minimum wages have also been duly implemented. Criteria 6.13 Growers and millers respect human rights. Indicators Findings and Objective Evidence Compliance 6.13.1 A policy to respect human rights The Human Rights Policy has not yet been documented and New shall be documented and communicated to all levels of the communicated to all levels of the workforce and operations. requirement workforce and operations (see Criteria of RSPO 1.2 and 2.1). P&C (2013) Follow up Major Compliance action at next ASA. 6.13.2 As long as children of plantation For children of migrant workers, the PMUs in collaboration Complied workers of Sabah and Sarawak are not secured a right to go to government with an NGO, i.e. Yayasan Peduli Pendidikan Anak school, the plantation companies Indonesia (YPPAI), managed a school located in Felda should engage in a process to secure Kalabakan Tengah 01. This school is for migrant workers the children of the plantation workers who came into the country before immigration rules have

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Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 40 of 50 KKS Kalabakan grouping - Main Assessment access to education as a moral been enforced. New intakes of foreign workers do not bring obligation. their family together with them from their home country. Transport is provided free for children of the workers daily. Minor Compliance An annual contribution of RM100 for each primary school and RM150 for each secondary school children are allocated every year in January by the PMU. See also details under C6.5.3.

Principle 7: Responsible development of new plantings KKS Kalabakan PMU has documented procedures for this development but to date has not carried any new plantings after November 2005. Therefore, the requirements of Principle 7 are not applicable during this assessment.

Principle 8: Commitment to continuous improvement in key areas of activity Criteria 8.1 Growers and millers regularly monitor and review their activities, and develop and implement action plans that allow demonstrable continual improvement in key operations. Indicators Findings and Objective Evidence Compliance 8.1.1 The action plan for continual KKS Kalabakan Grouping had planned & progressively Complied improvement shall be implemented, based on a consideration of the main implemented the continual improvement activities, both in oil social and environmental impacts and mill & estates. opportunities of the grower/mill, and Estate: Planned activities to reduce use of pesticides: shall include a range of Indicators covered by these Principles and Increase planting of beneficial plants ( Turnera subulata, Criteria. Cassia cobanensis and Antigonon leptopus ); Estate: Planned activities for waste reduction: As a minimum, these shall include, but are not necessarily be limited to: Reuse fertilizer bags; Reuse pesticide containers for mixing • Reduction in use of chemicals for spraying in the fields. pesticides(Criterion 4.6); Estate: Planned activities for preventing pollution: • Environmental impacts (Criteria 4.3, 5.1 and 5.2); Kalabakan Selatan Estate planned to increase the area of • Waste reduction (Criterion 5.3); subsoil fertiliser application from 550 ha to 600 ha to • Pollution and greenhouse gas (GHG) reduce surface runoff of the fertiliser. emissions (Criteria 5.6 and 7.8); The estate also planned to increase the use of compost • Social impacts (Criterion 6.1); from 3200 tonnes to 3700 tonnes in 2015 in place of the • Encourage optimising the yield of the supply base. inorganic fertilisers. Oil mill: Planned activities Major Compliance The mill had started a composting plant and the compost was being used by the Group Estates. Estate/oil mill: Planned activities for social: Repair/refurbish sport facilities & quarters; Free tuition class for school students. Social • Continuous plan to replace old wooden quarters with new brick quarters for all workers. Expected completion for Felda Kalabakan Selatan within 2016. • Plan to build a proper mosque at Felda Kalabakan Selatan quarters for the use of Moslem workers. Major road repair has been approved on road leading to the POM for comfort of the vehicles using the road.

3.1.1 Supply Chain Certification Standards Findings - on CPO Mill

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The Supply Chain model applied at KKS Kalabakan Grouping POM during this Main Assessment is Module E – CPO Mills: Mass Balance (MB).

Details of findings are as follows:

E.1 Documented procedures Indicators Findings and Objective Evidence Compliance E.1.1 A documented Supply Chain Procedure Doc No. FGVPM Complied The facility shall have written procedures RSPO SCCS Issue 1.0 Rev 2.0 (Effective 1 Dec 2012) and/or work instructions to ensure the SOP for Mill RSPO Supply Chain Certification System has implementation of all the elements been established and implemented for Module E: Mass specified in these requirements. This Balance (MB) system. shall include at minimum the following: a) Complete and up to date procedures All the requirements for controlling the FFB receipt, Complied covering the implementation of all the processing, sale and CPO dispatch, training and claims for elements in these requirements Mass Balance (MB) Module for the Palm Oil Mill has been addressed in the SOP. Implementation complied with all the requirements. b) The name of the person having overall POM’s Mill Manager, Mr. Mohd Shakri Abd Samad has Complied responsibility for and authority over the been appointed as the person responsible for the Supply implementation of these requirements Chain aspects of FFB receipts, processing and shipping of and compliance with all applicable CPO, PK and palm products. Interview of the Mill Manager requirements. This person shall be able and other relevant staff confirmed their knowledge of the to demonstrate awareness of the facilities RSPO Supply Chain Certification requirements for the procedures for the implementation of this respective areas of operations. Organization Chart and job standard. descriptions documented.

E.1.2 The SOP covers the receiving of FFB supply from the PMU Complied The facility shall have documented estate and also from external crop suppliers. All supplies procedures for receiving and processing of FFB were subjected to verification of documents certified and noncertified FFBs. (delivery notes) and quality checks by weighbridge personnel. All Storage tanks at the POM are designated as Mass Balance (MB) CPO.

E.2 Purchasing and goods in Indicators Findings and Objective Evidence Compliance E.2.1 The Mill verifies and records tonnages and supply source Complied The facility shall verify and document the of FFB received at the weighbridge in the delivery notes volumes of certified and noncertified and weighbridge tickets and all FFB data are entered by FFBs received. the weighing clerk into the Felda computer system or reporting spreadsheet every day. Daily and monthly reports are submitted to the Sabah Zone Office and Kuala Lumpur Head Office through the Mill Performance Report (MPR) system. Production Reports for Jan – Dec 2013 and Jan – May 2014 is verified to be Mass Balance palm products.

Satisfactory performance of deliveries of FFB made by transport contractors, Felda Transport Services.

E.2.2 The POM has an internal monitoring and reporting Complied The facility shall inform the CB mechanism for advising the CB of production variations. So immediately if there is a projected far, there is no projected overproduction. overproduction.

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E.3 Record keeping Indicators Findings and Objective Evidence Compliance E.3.1 Inspection of records at the Mill confirmed these were Complied The facility shall maintain accurate, updated daily. complete, uptodate and accessible records and reports covering all aspects of these requirements. E.3.2 As per the SOP, the records are archived and to be stored Complied Retention times for all records and for a minimum of 10 years. reports shall be at least five (5) years.

E.3.3 Transaction documents and bookkeeping of CPO and PK Complied The facility shall record and balance all are done daily and monthly summary report of FFB receipt, receipts of RSPO certified FFB and FFB processed, CPO production, PK production and deliveries of RSPO certified CPO, PKO balance stocks submitted to the Sabah Zone Office and and palm kernel meal on a threemonthly Kuala Lumpur Head Office. basis. The two weighbridges at the Mill are duly calibrated and calibration certificates found to be in order.

There is no PKO and Palm Kernel mill at the said POM facility. PK sold and delivered to Kilang Isi Sawit Sahabat at Wilayah Sahabat.

Deduction and conversion ratios for the volumes of CPO delivered from the Palm Oil Mill have been appropriately done and recorded.

All deliveries of the MB sales are from positive stock.

E.3.4 POM has prepared an appropriate stamp for the use of Complied The following trade names should be identification of RSPO certified CPO and PK. Documents used and specified in relevant to be stamped ‘RSPO – MASS BALANCE appropriately for documents, e.g. purchase and sales CPO and PK products. contracts, e.g. *product name*/SG or Segregated. The supply chain model Traceability was verified for the production reports for Jan used should be clearly indicated. Dec 2013 and Jan to May 2014, which was verified from the related records (FFB Delivery Note, Weigh Ticket, FFB & Truck Daily Summary, Production Report, CPO Storage Report, and CPO Delivery Orders.

E.3.5 There is no such outsourcing activity done at this POM. Complied In cases where a mill outsources activities to an independent palm kernel crush, the crush still falls under the responsibility of the mill and does not need to be separately certified. The mill has to ensure that the crush is covered through a signed and enforceable agreement. E.4 Sales and good out Indicators Findings and Objective Evidence Compliance E.4.1 Items (a) to (e) are included in the company’s invoices, Complied The facility shall ensure that all sales delivery note and other relevant documents to all CPO invoices issued for RSPO certified buyers as stipulated in the SOP for RSPO/MB module. products delivered include the following information: Deliveries of CPO and PK made with Delivery Notes. Data

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Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 43 of 50 KKS Kalabakan grouping - Main Assessment a) The name and address of the buyer; entry into computer system or reporting spreadsheet. b) The date on which the invoice was Delivery of CPO and PK checked to ensure that the issued; authorized quantities are not exceeded, c) A description of the product, including the applicable supply chain model Satisfactory performance of deliveries made by contractor, (Segregated); Felda Transport Services. d) The quantity of the products delivered; e) Reference to related transport documentation. E.5 Training Indicators Findings and Objective Evidence Compliance E.5.1 The PMU has maintained records of training on the Supply Complied The facility shall provide the training for Chain Certification System for Mass Balance (MB) Module. all staff as required to implement the Interview with mill personnel confirmed their awareness of requirements of the Supply Chain how the MB module is being implemented and maintained. Certification Systems. E.6 Claims Indicators Findings and Objective Evidence Compliance E.6.1 The PMU has not made any claims outside of the RSPO Complied The facility shall only make claims Rules for Communications and Claims. regarding the use of or support of RSPO certified palm oil that are in compliance with the RSPO Rules for Communication and Claims.

3.1.2 Status on Supply Chain on POM: Based on the documents and records presented during the onsite verifications made, it is concluded that the Felda KKS Kalabakan POM has been able to comply with the requirements of the RSPO SCCS under the ‘MB’ module and is thus eligible for ‘MB’ trading for its palm products for year 2014/2015.

3.2 Status of Identified Noncompliance and Corrective Actions, Observations and Positive Elements. The status of the Noncompliances (NCR) and Observations (OBS) identified against the MYNI Compliance Indicators is as per the details below: Assessment Type Year Noncom pliance (NCR) Observations (OBS) Main Assessment 2014 8 (2Major & 6Minor) 3

Year 2014: Main Assessment (7 NCRs)

NCR # MYNI Details of NCR Indicator 1 of 8 4.1.2 Date issued: 12 June 2014 Date closed: 11 July 2014 Date of verification: ASA01 - Minor Nonconformance: In Palm Oil Mill, some of the readings on POME flow meter records were erroneously written. Thus the records are not properly and accurately maintained.

Root Cause and Corrective Action: Mill personnel taking readings was not properly trained. Briefing was done for Mill personnel how to perform and record the readings of the POME flow meter and checking of monthly data.

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Verification (for effective closure): During ASA01

NCR # MYNI Details of NCR Indicator 2 of 8 4.3.1 Date issued: 12 June 2014 Date closed: 11 July 2014 Date of verification: ASA01 - Minor Nonconformance: At the PMU estates sample audited and inspected i.e. Kalabakan Tengah and Selatan estates, the palms were planted on the slope >6° without having planting terraces. For instance at Kalabakan Tengah Estate, Field PM 10G Block 17. This is contrary to the Company’s policy.

Root Cause and Corrective Action: 1) Type of soil there is ‘Musang Coral’ and thus not suitable for terracing. 2) High rainfall experienced led to more frequent erosion. At affected areas, ‘platforms’ will be constructed and more frequent monitoring done.

Verification (for effective closure): During ASA01

NCR # MYNI Details of NCR Indicator 3 of 8 4.3.3 Date issued: 12 June 2014 Date closed: 11 July 2014 Date of verification: ASA01 - Minor Nonconformance: On Kalabakan Tengah Estate, in Field PM 11H Block 12, the road had been partially eroded due to rain, there was no signage to give warning to the passerby on the potential hazard of falling into the ravine.

Root Cause and Corrective Action: Estate Manager had overlooked the safety issue at that area. New warning signage will be made and placed at the strategic position to warn users of the potentially hazardous area on the road.

Verification (for effective closure): During ASA01

NCR # MYNI Details of NCR Indicator 4 of 8 4.4.1 / Date issued: 12 June 2014 Date closed: 9 August 2014 Date of verification: ASA01 - Major P&C Nonconformance: 2013, 4.4.2 At the PMU estates sample audited and inspected i.e. Kalabakan Tengah and Selatan estates, the buffer zone signages and markings were not adequately maintained.

For example at Kalabakan Tengah Estate:

3. In Field PM 09F Block 5, there was no marking of buffer zone on both sides of the stream, the palms had been planted too close to the stream, and there was sign of chemical spraying on grasses within the palm circles next to the river. 4. In Field PR 13P Blocks 8 & 9 new replants, there was no marking of buffer zone on both sides of the river, and the palms had been planted too close to the river.

These are contrary to the Company’s policy.

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Root Cause and Corrective Action: There was limited buffer zone signage due to budget constraints. Signages for the ‘Buffer zone’ and ‘No Spraying of Chemicals’ will be prepared to ensure no chemical applications at the ‘Buffer zone’ areas. Communication notices, briefing and warning will be given to the workers and contractors. Photographs for the completed signages and documentation will be submitted.

Closure of Major NCR: On site verification was followed up and conducted on 4 August 2014 by HQPSQM. Buffer zones and signages were confirmed to have been erected and records of briefings done were available and photographs were taken on site and submitted to CB auditor. The evidences submitted were reviewed and accepted for the closure of NC. (Refer to attachments in Part 2 of report) Verification (for effective closure): During ASA01

NCR # MYNI Details of NCR Indicator 5 of 8 2.1.4 Date issued: 12 June 2014 Date closed: 11 July 2014 Date of verification: ASA01 - Minor Nonconformance: A system for tracking changes in the law established and documented at the POM and estates. However, at the estates of Ladang Tengah and Selatan, the tracking and updating did not sufficiently include other relevant legal requirements for Sabah state, e.g. requirement for EIA / PMM during replanting and approval by JPAS.

Root Cause and Corrective Action: The updating had been overlooked by the estate managers. Tracking of legal requirements is being done and PMU has written to JPAS for latest approval. Records will be updated once received approval from JPAS.

Verification (for effective closure): During ASA01

NCR # MYNI Details of NCR Indicator 6 of 8 5.1.2 Date issued: 12 June 2014 Date closed: 11 July 2014 Date of verification: ASA01 - Minor Nonconformance: The Management plan for mitigation of environmental impacts, timeframe for action and responsible persons were not adequately followed up by the Estate managers at the PMU. For instance at Ladang Tengah and Ladang Selatan the management of the landfill areas were not adequately developed.

EIA /PMM (Pelan Pengurusan Mitigasi) documentation review by Environment Protection Department i.e. Jabatan Perlindungan Alam Sekitar (JPAS) not available for Kalabakan PMU, and thus plans and recommendations on mitigating impacts which on replanting activities were also not available.

Root Cause and Corrective Action: The EIA / PMM (Pelan Pengurusan Mitigasi) were not properly followed up by the Estate Managers. All Management plan items indicated will be immediately followed up, actions taken, reviewed and supported with photographic evidences.

Verification (for effective closure): During ASA01

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INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296W)

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NCR # MYNI Details of NCR Indicator 7 of 8 5.3.2 Date issued: 12 June 2014 Date closed: 11 July 2014 Date of verification: ASA01 - Minor Nonconformance: Chemical containers were not disposed in a responsible manner at the PMU estates. For instance at Ladang Tengah and Ladang Selatan, the disposal plan for chemical containers which are under Scheduled waste code SW 409 were not adequately documented and implemented. At Ladang Selatan, there was improper reuse of some empty chemical containers at the line site and field.

Root Cause and Corrective Action: The matter was overlooked and no proper storage area was available. Proper area for storage and disposal of the chemical containers will be done. Briefing will be done for all workers about proper reuse and disposal of the containers

Verification (for effective closure): During ASA01

NCR # MYNI Details of NCR Indicator 8 of 8 6.3.1 Date issued: 12 June 2014 Date closed: 9 August 2014 Date of verification: ASA01 - Major Nonconformance: 1. Complaints and grievances received are not appropriately recorded thus determination whether the complaints and grievances are handled in timely manner cannot be made. However, grievances from staff are recorded appropriately.

2. The channels for external stakeholders to submit complaints and grievances are not well explained and made accessible to them.

Root Cause and Corrective Action: The proper recording has been overlooked by the Estate Managers. 1. Complaints and grievance register has been established with columns for dates of complaints and follow up done. Recording will commence for any complaints received. 2. Briefing for external stakeholders will be done and channels made available.

Closure of Major NCR: On site verification was followed up and conducted on 4 August 2014 by HQPSQM. The complaints and grievance register established was available and complaints received will be reviewed by respective Estate Managers and signed off upon completion. Briefing for external stakeholders done on 11July 2014 as per guidelines of FGV Stakeholder consultations booklet for Kompleks Sabah, issued in December 2013. Records of consultations done are maintained. The evidences submitted to CB auditor were reviewed and accepted for the closure of NC. (Refer to attachments in Part 2 of report) Verification (for effective closure): During ASA01

Year 2014: Main Assessment (3 Observations)

Status RSPO Op ened Closed Remark, Ref No: MYNI Location Details of Observation date date if any Indicator

AL01 5.6.2 – PMU POM It is noted that the PMU has not 12 June To follow up

INTERTEK RSPO Report: 26 August 2014 Final R1

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296W)

Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 47 of 50 KKS Kalabakan grouping - Main Assessment

New & Estates compiled the GHG emissions and 2014 during ASA01 requirem the plans to further reduce or ent minimise GHG emissions are yet to be established and implemented. Thus an Observation was issued for the follow up during next assessment.

CFK01 4.4.3 POM The mill had applied and obtained 12 June To follow up permission for a 6 month extension 2014 during ASA01 period since April 2014 from the DOE to complete and commission a BioPolishing plant in order to further reduce the BOD level to the DOE new specified limits of 20ppm by end 2014. Thus an Observation was issued for the follow up during next assessment.

CFK02 4.8.2 Estates Records of training were available. 12 June To follow up However at Kalabakan Selatan 2014 during ASA01 estate, some records for new employees taken in over the past 3 months were not updated yet. Thus an Observation was issued for the follow up during next assessment.

3.2.2 Identified Positive Elements 1) KKS Kalabakan PMU has been provided proper infrastructure such as road access and basic social amenities such as grocery stores, clinics and schooling to the local communities at the Sahabat Grouping estates. 2) The PMU has made financial contributions during local festivities and assisted in the significant events such as marriages, burial and medical assistance when needed.

3.3 Feedback Raised by Stakeholders and Findings

Prior to and during the Assessment, written and verbal feedback communicated from the stakeholders on the environmental and social performance of KKS Kalabakan Grouping PMU operations were sourced. All pertinent feedback issues were reviewed and followed up for verification and these had been accordingly incorporated into the report findings. See table below:

Stakeholders’ Feedback PMU Response Intertek verification / Follow up (if any) comments Government Agencies Comunication done via email There has been no Verified during onsite on 27 March 2014. See list feedback / enquiries assessment that there has under para 2.5. received from any been no issues from any government Agencies Government Agencies

No feedback received. concerning the operations concerning the PMU’s of KKS Kalabakan operations. Grouping PMU.

Non -Governmental

Organizations Comunication done via email There has been no Verified during onsite on 27 March 2014. See list feedback / enquiries assessment that there has under para 2.5. received from any NGOs been no issues from any

INTERTEK RSPO Report: 26 August 2014 Final R1

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296W)

Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 48 of 50 KKS Kalabakan grouping - Main Assessment

No feedback received. concerning the operations NGOs concerning the of KKS Kalabakan PMU’s operations. Grouping PMU.

Local Communities A total of 18 stakeholders comprising of Village heads, Contractors, Native Murut and Local community,Government agencies and Employees / workers was interviewed during the onsite assessment. Concerns and suggestions The programs for Verified during onsite To be followed up raised include: improvement of road assessment that the PMU during Surveillance • Improve on road building & maintenance has a mid and long term assessment (ASA01) maintenance and waste and waste management management plan for the management activities. will be monitored. imporvement of infrastructure, social and Native Murut community Concerns of the Murut environmental needs of the under FGV / Felda at community is being local community including Kalabakan Tengah estate progressive resolved the Native Murut issues: through on going community under FGV / • Deductions & costing to be consultation with them. Felda. more transparent Request for assistance in See report details under • Request for housing housing & transportation P&C 4, 5, 6 & 8) assistance has been considered and • Request for transportation provided whenever assistance for sending their possible. children to school

Other Interested parties Nil

INTERTEK RSPO Report: 26 August 2014 Final R1

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296W)

Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 49 of 50 KKS Kalabakan grouping - Main Assessment

4.0 ASSESSMENT CONCLUSION AND RECOMMENDATION

Based on the findings above, FELDA KKS Kalabakan Grouping had been able to demonstrate its compliance with the RSPO Principles and Criteria (April 2013), Malaysian National Interpretation (MYNI November 2010) and the RSPO Supply Chain Certification Standard (November 2011) for Palm Oil Mill.

Therefore, it is recommended that the certification of FELDA KKS Kalabakan Grouping be approved.

Signed for and on behalf of Intertek Certification International Sdn Bhd

Augustine Loh Lead Assessor

Date: 26 August 2014

4.1 Acknowledgement of Internal Responsibility and Confirmation of Assessment Findings

This is to acknowledge and confirm the assessment visits described in this report and the acceptance of the contents and findings in this assessment report.

Signed for and on behalf of Felda Global Ventures Plantations (M) Sdn Bhd

Mr. Norazam Abdul Hameed Head, Plantation Sustainability & Quality Management

Date: 26 August 2014

INTERTEK RSPO Report: 26 August 2014 Final R1

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296W)

Report No.: R9288/14-1 Felda Global Ventures Plantation Malaysia Sdn Bhd Page 50 of 50 KKS Kalabakan grouping - Main Assessment

4.2 Intertek RSPO Certificate details for KKS Kalabakan grouping

Certificate No: RSPO 928888 Issue date: 7 October 2014 Expiry date: 6 October 2019 Organization Felda Global Ventures Plantations (Malaysia) Sdn Bhd Address of Head Office: Felda Global Ventures Plantations (Malaysia) Sdn Bhd, PSQM Department, SPO Unit, 8th Floor Balai Felda, Jalan Gurney Satu, 54000 Kuala Lumpur RSPO Membership No: 100130400000

Plantation Management Unit: KKS Kalabakan Grouping Address of POM: KKS Felda Kalabakan Grouping, Peti Surat No. 62007, 91030 Tawau, Sabah Standards: RSPO Principles and Criteria (April 2013); Malaysian National Interpretation (November 2010); RSPO Supply Chain Certification Standards (November 2011) for the Palm Oil Mill. Certification scope: Production of Crude Palm Oil and Palm Kernels Supply Chain model for Mass Balance (MB) CPO & PK:

Details of the Mill and Supply bases covered by this certificate and the tonnage approved are: GPS Reference Name Address Latitude Longitude Kalabakan Mill POM Kilang Sawit Kalabakan, Peti Surat No. 4°24'36"N 117°29'21"E (Capacity:45 MT/hour) 62007, 91030 Tawau, Sabah FPSB Kalabakan Tengah Ladang Kalabakan Tengah, Peti Surat 4°23'25"N 117°27'35"E estate No. 61954, 91029 Tawau, Sabah FPSB Kalabakan Selatan Ladang Kalabakan Selatan, Peti Surat 4°16'50"N 117°31'11"E estate No. 61954, 91029 Tawau, Sabah FPSB Kalabakan Utara Ladang Kalabakan Utara, Peti Surat No. 4°26'45"N 117°25'20"E estate 61954, 91029 Tawau, Sabah

The annual certifiable tonnages of CPO and PK production at the PMU from the supply base/suppliers as assessed and verified during the current Assessment and projected year are detailed as follows:

Jan – Dec 2014 Jan – Dec 2015 KKS Kalabakan Grouping - Actual & Projected - Projected Total certifiable FFB Processed (MT) 93,610 90,470 Total certifiable CPO Production (MT) 21,905 21,170 Total certifiable PK Production (MT) 4,025 3,890 SCC Model for POM MB MB

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