SGS RSPO Doc

SGS RSPO Doc. Number: GP 7003A

(Associated Document) Doc. Version date: 01 January 2013 Page: 1 of 61

OIL PALM PLANTATION MANAGEMENT VERIFICATION REPORT

Report Nr: MY02410-Boustead Plantations

Client: Boustead Rimba Nilai Sdn Bhd (346457-W)

RSPO 1-0012-04-000-00 membership #: www.boustead.com.my Web Page:

Address: 28th Floor, Menara Boustead 69, Jalan Raja Chulan, 50200 Kuala Lumpur Malaysia

Telephone: 603-2145-2121

Country: Malaysia Certification Sg Jernih Business Unit Unit Evaluated: Total Plantation 7,029 hectares Area Company En Mohammad Tarmizi Taufek Contact Person: Head office: Mill: 11h Floor, Menara Boustead, Kilang Kelapa Sawit Sungai Jernih Address: 69 Jalan Raja Chulan, Wakil Pos Paloh Inai 50200 Kuala Lumpur, 26650 Pekan, Pahang Malaysia Malaysia Tel: 03-2145-2121 Fax 03-2141-1690 Email: [email protected] Evaluation dates: Pre-assessment 26 –28 April 2010 Main 21 – 25 March 2011 Assessment 1st Surveillance 07-10 August 2012

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TABLE OF CONTENTS

LIST OF TABLES ...... 3 LIST OF MAPS ...... 3 LIST OF FIGURES ...... ERROR! BOOKMARK NOT DEFINED. LIST OF PHOTOS ...... ERROR! BOOKMARK NOT DEFINED. LIST OF ABBREVIATIONS ...... 3 1. SCOPE OF VERIFICATION ...... 5 2. COMPANY BACKGROUND ...... 6 2.1 Ownership & History...... 6 2.2 Boustead Group Palm Oil Mill and Plantation Subjected to Certification ...... 7 2.2.1 Sg. Jernih Palm Oil Mill ...... 7 2.2.2 Oil Palm Estates ...... 8 3. OTHER BUSINESS UNITS OWNED BY BOUSTEAD GROUP AND PLAN FOR CERTIFICATION UNDER RSPO P&C ...... 11 4. PREPARATION FOR THE EVALUATION ...... 12 4.1 Schedule ...... 12 4.2 Team ...... 12 5. THE EVALUATION ...... 12 5.1 Stakeholders Notification & Consultation ...... 12 5.2 Field Assessment ...... 12 5.2.1 Opening meeting ...... 12 5.2.2 Document review ...... 12 5.2.3 Field assessments ...... 13 5.2.4 Summing up and closing meeting ...... 13 6. EVALUATION RESULTS ...... 14 6.1 Findings related to the general MYNI 2008 ...... 14 PRINCIPLE 1: Commitment to transparency...... Error! Bookmark not defined. PRINCIPLE 2: Compliance with applicable laws and regulation ...... Error! Bookmark not defined. PRINCIPLE 3: Commitment to long term economic and financial viability ...... Error! Bookmark not defined. PRINCIPLE 4: Use of appropriate best practices by growers and millers: ...... Error! Bookmark not defined. PRINCIPLE 5: Environmental responsibility and conservation of natural resources and biodiversityError! Bookmark not defined. PRINCIPLE 6: Responsible consideration of employees and of individuals and communities affected by growers and mills Error! Bookmark not defined. PRINCIPLE 7: Responsible development of new plantings ...... Error! Bookmark not defined. PRINCIPLE 8: Commitment to continuous improvement in key areas of activity ...... Error! Bookmark not defined. 7. CHAIN OF CUSTODY ...... ERROR! BOOKMARK NOT DEFINED. 8. ISSUANCE OF NON-COMPLIANCE ...... 54 9. ASSESSMENT DECISION ...... 54 ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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10. ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY AND FORMAL SIGN-OFF OF ASSESSMENT FINDINGS ...... 54 11. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS . ERROR! BOOKMARK NOT DEFINED. 12. RECORD OF CORRECTIVE ACTION REQUESTS (CARS) AND OBSERVATIONS ...... ERROR! BOOKMARK NOT DEFINED.

LIST OF TABLES

Table 1: FFB Input, CPO and PK output from Sg Jernih (Jan 2011-Nov 2012) ...... 5 Table 2: List of estates and FFB production (Jan 2012 – Nov 2012) ...... 5 Table 3: Land Statement and crop age profile of Sg. Jernih, LTT-T and Bebar Estate ...... 8 Table 4: Boustead Group’s Timeline for RSPO certification of oil palm plantations ...... 11 Table 5: Audit Team Resume ...... 12 Table 6: List of Stakeholders contacted...... Error! Bookmark not defined. Table 7: Audit Field Visits ...... 13 Table 8: Level of Non-Compliance based on RSPO requirement ...... 14 Table 9: Land Tenureship ...... Error! Bookmark not defined. LIST OF MAPS

Map 1: Sg. Jernih Estate...... 9 Map 2: Ladang Tabung Tentera ...... 10 Map 3: Bebar Estate ...... 10

LIST OF ABBREVIATIONS

CAR Corrective Action Request CPO Crude Palm Oil EFB Empty Fruit Bunch EIA Environment Impact Assessment EMS Environmental Management System ERT Endangered, Rare and Threatened species FFB Fresh Fruit Bunches Ha Hectare HCV High Conservation Value IPM Integrated Pest Management ILO International Labour Organisation ISO International Organisation for Standardisation IUCN International Union for Conservation of Nature and Natural Resources K Potassium kW Kilowatt LI Local Indicator LTT-T Ladang Tabung Tentera Terengganu Oil Palm Estate M Meter Mg Magnesium Mm Millimetre Mt Metric ton ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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N Nitrogen NGO Non Governmental Organisation OER Oil Extraction Rate OSH Occupational Safety & Health P Phosphate P & C Principles and Criteria PK Palm Kernel POM Palm Oil Mill POME Palm Oil Mill Effluent PPE Personal Protective Equipment RB Oryctes Rhinoceros Beetle SGS Societe Generale de Surveillance SOP Standard Operating Procedures UNDP United Nations Development Programme Yr Year

------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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INTRODUCTION

The purpose of the evaluation was to evaluate the operations of Boustead Rimba Nilai Sdn Bhd oil palm mill and plantations located in Pahang and Terengganu state, Malaysia, against the requirements of the QUALIPALM Programme, the SGS Group’s verification programme for compliance to RSPO P&C MYNI 2010 requirement.

1. SCOPE OF VERIFICATION The details of the Crude Palm Oil (CPO) mill and the oil palm plantations included in the scope of this assessment are presented in Table 1 and Table 2 below:

Table 1: FFB Input, CPO and PK output from Sg Jernih Palm Oil Mill (Jan 2011- Nov 2012)

MILL: SUNGAI JERNIH PALM OIL MILL

Mill location Capacity FFB input CPO output PK output Sungai Jernih, Pahang 2011 69,485.40 14,780.00 2,866.00

30 TPH 2012 ( Jan - 63,048.32 14,360.00 2,153.00 Nov 2012)

Table 2: List of estates and FFB production (Jan 2012 – Nov 2012)

NAME OF HOLDING LOCATION PLANTATION AREA ANNUAL FFB PRODUCED (Nearest town) Conservatio Planted areas (TONNES) n (ha) (ha)

Sungai Jernih Oil Palm Kuantan, Pahang 2,626.1 33.6 18,203.80 Estate Ladang Tabung Kemaman, 1,743.7 194.6 21,776.30 Tentera Terengganu Terengganu Oil Palm Estate Bebar Estate Bandar Muadzam, 2,263.8 5.0 23.068.22 Pahang Total 6,633.6 233.2 63,048.32

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2. COMPANY BACKGROUND

2.1 Ownership & History Boustead Holdings Berhad founded in 1828 is a diversified conglomerate in Malaysia. The Group has an active interest in six primary sectors of the Malaysian economy namely plantation, property, finance & investment, trading, manufacturing & services and heavy industries. The Group’s organisation chart is as shown in Figure 1 below:

Figure 1: Boustead Group’s Organisation chart

Source: www.boustead.com.my

It has more than 13,000 employees in over 100 subsidiaries and associates. The Group major shareholder is Lembaga Tabung Angkatan Tentera having a total assets in excess of RM9 billion and has been listed on Bursa Malaysia since 1961. Its market capitalisation was in excess of RM5 billion at the close of the financial year ( Annual Report 2010).

Boustead Plantations Berhad, one of the primary sectors is a major contributor to the Group’s earning. The Plantation Division is primarily involved in the cultivation and processing of oil palm. The Group's plantation operations are carried out on its own holding as well as on lease land. The Group's plantation operations are managed by Boustead Estates Agency Sdn Bhd (BEASB), a wholly owned subsidiary of Boustead Holdings Berhad. BEASB manages more than 82,807 hectares of agricultural land, of which 82,402 hectares are operated by the Group and the remaining on behalf of other investors. The group support local economy wherever it operates palm oil mill and established estates. The infrastructures it developed provide access for local communities living around its estates.

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BEASB is also a leading estate management agency in the region providing a complete range of management services and solutions, which includes engineering consultancy, design, construction and marketing for oil palm estates, mills and rubber factories. In the mill, the group implemented Good Milling Practices (GMP) guidelines to ensure the palm oil produced are of high quality while ensuring effective of management of water, effluents and mill by-products. Through its associate company Applied Agricultural Resources Sdn Bhd (AAR), BEASB provides research and advisory services to the plantation industry and stays ahead by utilising. advanced technologies. Additionally, AAR’s brand new and state-of-the-art oil palm tissue culture lab leads the way globally in the tissue culture clonal propagation of oil palm. The laboratory, situated in Ijok, Selangor, is the first and largest of its kind in the world and possibly boasts the largest area of clonal planting globally. The Molecular Laboratory known as the AAR-UNMC Biotechnology Research Centre (BRC) was opened on 29 September 2009. The BRC is located adjacent to the University of Nottingham Malaysia Campus, Semenyih. The overall and primary goal of the AAR biotechnology unit is to develop biotechnological tools that are rapid, sensitive and reliable to support and compliment our crop, improvement and agronomic research programme, which encompass oil palm breeding, tissue culture, pest and diseases and agronomy. The Group’s Plantation Division continues to move forward to enhance growth by tapping prospects locally and abroad. Toward this end, the Group has been actively investing in Sarawak through joint ventures with the Land Custody and Development Authority and Pelita Holdings Sdn. Bhd. of Sarawak. Other company in the Plantation Division includes Boustead REIT Managers Sdn. Bhd., a company responsible for the management and administration of Al-Hadharah Boustead REIT, an Islamic plantation-based real estate investment trust (REIT).

2.2 Boustead Group Palm Oil Mill and Plantation Subjected to Certification Sg Jernih palm oil mill and its supply base subjected to the evaluation are as tabulated in Table 1 and Table 2. Brief description of the POM and its estates are as follows:

2.2.1 Sg. Jernih Palm Oil Mill Sg Jernih Palm Oil mill was commissioned in 1992. As it is now, the mill has the capacity of 30 MT/hr processing and consuming about 80,000 metric tons of FFB per year. Photo 1 below shows the view of the mill with 4 CPO storage tanks (capacity 6,000 MT) . The mill has two boilers producing steam that use fibre and shell for power generation. There are eleven series of ponds for treating the POME (including three anaerobic) prior to releasing and applying it to plantation land within the Sg Jernih estate via channels and drains. The total land applications cover about 30 ha of the Sg Jernih estate. With the establishment of the composting plant ( which utilises the EFB and POME) , the balance of the EFB produced by the mill is applied directly to the estates. The electricity produced by the boiler is used for the mill operation, office as well as for the housing complex of the Sg Jernih mill and the Sg Jernih estates. Currently with 78 workers, and the average OER of about 21.27 %, in 2011 the mill generates about 14,780 MT of CPO and 2,866 mt of PK.

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Photo 1: Sg. Jernih Palm Oil Mill

2.2.2 Oil Palm Estates

The land statement and crop age profile of the three estates (Sg Jernih, LTT-T and Bebar) subjected to the current evaluation are as tabulated below:

Table 3: Land Statement and crop age profile of Sg. Jernih, LTT-T and Bebar Estate

Age category Sg Jernih (ha) LTT-T Bebar Total (year) (ha) (ha) (ha) < 3 (immature or less than 3 1,215.20 149.6 953.9 2,318.7 yrs)

3 – 6 (young mature) 612.9 155.9 1,101.0 1,869.8 7 – 15 yr (prime mature) 0 1,328.8 59.8 1,388.6

16 – 25 yr (prime mature) 798.0 109.4 149.1 1,056.5 Net area cultivated 2,626.1 1,743.7 2,263.8 6,633.6

Unplanted/Abandoned/ 42.1 186.8 20.6 249.5 Leasing/buffer zone area/swamps Mill, housing, office, roads, 34.2 2.4 36.3 72.9 amenities etc

TNB rentice 37.0 5.4 14.6 57.0 Nursery 7.0 0 8.7 15.7

Total not planted 120.3 194.6 80.2 395.1

Total 2,746.4 1,938.3 2,344.0 7,028.7

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Map 1: Sg. Jernih Estate

Sg Jernih Estate was previously own by LKPP (Lembaga Kemajuan Perusahaan Pertanian Pahang) Perwira Sdn Bhd. The estate was bought over by Boustead Group in 2004. Sg Jernih Estate is situated along the Tun Razak Highway (Federal Route 12) that connects Segamat in the state of Johore to Kuantan in the state of Pahang. It is situated between the Bukit Ibam Forest Reserve 2.11 km southwest and the South East Pahang Peat Swamp Forest in the 1.5 km east. The nearest town is Muadzam Shah, which is approximately 20 minutes journey from the estate.

Sg. Jernih Estate is surrounded by other plantations such as FELCRA Pahang Tenggara, IOI Plantation (Bukit Lee Lau Estate), SKS Plantation (Sri Jelutong, Motif Wawasan and Kurnia Setia Estate), NYT Plantation and LKPP Corporation (T1T2 Estate). Sg. Jernih Estate activities mainly on Oil Palm Cultivation, mature, young mature, replanting and nursery. Total planted area for Sg. Jernih Estate stand at 2,626.1 ha which derived from the latest GPS Map, surveyed by Applied Agriculture Research and currently use for daily operation and working purposes.

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Map 2: Ladang Tabung Tentera

Ladang Tabung Tentera Terengganu Estate ( LTT-T ) is located along the Jerangau – Jabor highway about 66 km from Kuantan and 38 km from Kemaman. The Estate is surrounded by other plantations such as Ladang Rakyat, Ketengah Perwira Estate, Felda Neram and Felda Sebarang Tayur Estate. The rivers Sg Dadong and Sg Paloh flow along the north and south boundary of the estate respectively. Sg Dadong drains into Sg Kemaman while Sg Paloh into Sg Cherul.

Refer to Table 2 for the FFB production data and Table 3 for the land statement.

Based on the soil map, soil survey and crop assessment report and agronomic reports, LTT-T has a number of soil types identified. Topographically LTT-T is more undulating and hilly. Nevertheless, LTT-T implemented appropriate agricultural practices like maintaining vegetative ground cover, proper frond stacking, planting of Guatemala grass on slopes and even gabion construction.

Map 3: Bebar Estate

Bebar Estate is located at about 65km on the left side of the Tun Razak Highway from Gambang to Bandar Muazzam Shah. The land is neighbouring the Lam Soon Estate in the north and northeast, Prosper Darabif

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in the south west, Felda Merchong in the south and State land forest Bukit Musuh in the mid west and Prosper Jawasa Estate in the east. Hutan Simpan Bukit Ibam is located on the northwestern border of the estate.

A drain has been constructed traversing the estate facilitating flow of surface water from North to South and eventually into Sg Bebar.

Refer to Table 2 for the FFB production data and Table 3 for the land statement.

3. OTHER BUSINESS UNIT OWNED BY BOUSTEAD GROUP AND PLAN FOR CERTIFICATION UNDER RSPO P&C

The current verification exercise is undertaken only for Sg Jernih Oil Mill and its supply base from the Group’s estates and sources in Pahang and Terengganu, Peninsular Malaysia. Boustead Group also owns and manages other palm oil mills and plantations located in Peninsular Malaysia, Sabah ,Sarawak. The company’s revised time bound plan for certification of other business units is as summarised in Table 4. Table 4: Boustead Group’s Revised Timeline for RSPO certification of the other business units ( oil mills and plantations)

Business Unit 2011 2013 2014 2015 2016 2017 2018 2019 2020 2021 1 2 3 4 5 6 7 8 9 10

Sg. Jernih Business Unit Nak Business Unit Loagan Business Unit Segamaha Business Unit Lapan Kabu Business Unit Telok Sengat Business Unit Segaria Business Unit Sugut Estates Business Unit TRP Business Unit Kanowit Business Unit

The company had revised the time bound plan for certification of the other business units because the management wanted to ensure that each unit is 100 % ready before being certified. All major and minor issue must be identified and if possible solved. The other issue is cost of certification as the company needs to allocate substantial amount of money to improve the estate condition as most of their estates have been established years before the adoption and the establishment of RSPO Principles and Criteria for Sustainable Palm Oil Production. Boustead Plantation Berhad advocated continuous improvement as seen in the certification of the Sg Jernih Business Unit. However, being a medium-sized plantation company, they do not have the economics of scale like other larger plantation companies and as a result, revision were made to the time-bound plan. Due to the consolidation of operation and management, Boustead Plantation Berhad has disposed off their interest in its estate operation in Indonesia, PT Dendy Marker, to concentrate its operations in Malaysia.

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SGS is of the opinion that the revised TBP by Boustead is in compliance to RSPO requirement where the revised timeline is more logical and in line with the available resources. There revised plan demonstrates the Group’s commitment towards the production of sustainable palm oil.

PREPARATION FOR THE EVALUATION

3.1 Schedule The Evaluation was preceded by a discussion on the logistic planning with Boustead personnel. This is important to ensure that sufficient time is allocated to allow coordination among team members.

3.2 Team The table below shows the team that conducted the pre-assessment. Table 5: Audit Team Resume

Audit Team Brief Resume Lead Auditor 1 James S H Ong, B.Agric Sc. was working as an agronomist in SGS (M) Sdn Bhd Agriculture Services Division. James has many years of experience in agriculture sector in Malaysia having worked in estates as well in the agrochemical and fertiliser industry. He is well versed with agrochemical and fertiliser applications. Has undergone ISO 14000 and RSPO Lead Auditor training for both P& C and Supply Chain and conducted many RSPO audits since 2010. Lead Auditor 2 Abdullah Din, is a forester by profession and a trained Lead Auditor with 6 years experience in forestry Chain of Custody (CoC) certification. He also has been involved in a number of Forest Management certification for the last 03 years. In addition, he is a Lead Auditor for RSPO, trained by RSPO for auditing against RSPO P&C and Supply Chain audits and involved in a number of plantation assessments and audit of palm oil mill. For the last 3 years he has also been involved in the ISCC certification.

4. THE EVALUATION The evaluation was conducted in the steps outlined below.

4.1 Stakeholders Notification & Consultation Only during main assessment

4.2 Field Assessment The steps for conducting the assessment are as outlined below.

4.2.1 Opening meeting An opening meeting was held at Sungai Jernih POM, Sungai Jernih Estate, Pahang, on 07 August 2012. The scope of the evaluation was explained and schedules were determined. A record was kept of all personnel who attended the meeting.

4.2.2 Document review

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A review of the documentation and management of both the oil mill and the estates was conducted to evaluate the adequacy of coverage of the RSPO P&C MYNI 2010 requirements. This includes the verification of available detail document of policies, management plans, systems, procedures, instructions and controls.

4.2.3 Field assessments Schedule for field visits were determined during the opening meeting after briefing given by the Boustead management. Focus of the visit was to sample the implementation of management practices and procedures. Field assessments aimed to determine how closely activities in the field complied with documented management systems and RSPO P&C MYNI 2010 requirements. Interviews with staff, operators and contractors were conducted to determine their familiarity with and their application of policies, procedures and practices that are relevant to their activities. A carefully selected sample of sites was visited to evaluate whether practices met the required performance levels. As a part of an effort to cover more areas, the verification team sometimes splits and works independently. The areas visited on daily basis were as tabulated in the below table: Table 6: Audit Field Visits Date Area visited Notes 07 Aug 2012 Opening Meeting at Sg Jernih POM Briefing on the estate and mill management given by the managers. Review of mill’s Audit at Sg Jernih POM ( Supply operational documents, verification of data, Chain and P & C requirements ) mill’s site visit, mill’s supply chain documents Audit at Sg. Jernih Estate and operations).

Sg Jernih Estate’s document review, visit to storage area, field operation (harvesting) , riparian , over-planted area.

08 Aug 2012 Audit at Bebar Estate Estate level document review, visit to line sites, storage and workshop, riparian, field operation ( manuring and P&D), land fill, over planted area , interview workers and biodiversity project).

09 Aug 2012 Audit at LTT-T Estate Document review, visit to overplanted area (encroached by smallholders) line sites, storage and workshop, riparian, field operation (manuring) , landfill, interview workers).

10 Aug 2012 Closing Meeting Closing Meeting at Sg Jernih POM End of audit

4.2.4 Summing up and closing meeting At the conclusion of the field evaluation, preliminary findings were presented to company management at a closing meeting held on 10th August 2012. Findings made highlighted compliance and non- conformance to the RSPO requirement.

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5. EVALUATION RESULTS

Results of the evaluation are tabulated below. The findings made under each criterion are discussed where non-compliances are raised against individual indicator of the MYNI 2010. Reference is also made to the RSPO Certification Systems document, May 2007 – Annex 3 Major Nonconformities against the RSPO Principles and Criteria - definition of compulsory indicators as a guidance for evaluation of compliance to the standard. Table 7: Level of Non-Compliance based on RSPO requirement Level of Non Compliance Minor CAR The management system applied complies with parts of the requirement or the system was inconsistently implemented. Improvements are required. . Minor non compliance to the stated requirement . Inconsistencies in documentation and implementation . Will not prohibit recommendation for certification

Major CAR The management system failed to comply with the requirement or the written policy, procedures etc were not implemented. . Major non conformance resulting in breakdown of the whole system . Major failure in documentation and implementation . Will prohibit recommendation for certification

5.1 Findings related to the MYNI 2010 Summary of the assessment findings under each criteria were presented to the company management at a closing meeting. Follows are detailed findings that described the compliance and non-compliances (raised as a CAR) under each criterion.

Principle 1: COMMITMENT TO TRANSPARENCY Criterion Oil palm growers and millers provide adequate information to other stakeholders on 1.1 environmental, social and legal issues relevant to RSPO Criteria, in appropriate language & forms to allow for effective participation in decision making. 1.1.1 Records of requests and responses must be maintained. Compliance Major S01 Findings: Records of requests and responses were maintained. Objective evidence: During the surveillance visit, it was observed that the estates and mill has maintain the following documents :  a list of local stakeholders that may be relevant to the company’s operation including local communities, local authorities and NGOs.  Consultation and Communication Procedure that define the responsibilities and actions required for receiving, recording and responding to enquiries and requests ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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from international and local stakeholders.  Minutes of meeting records with stakeholders ( internal and external) such as JCC Minutes of Meeting, JKKP Minutes of Meeting and Local Communities Minutes of Meeting For e.g. at LTT-T Estate, last JCC meeting was conducted on 07 Dec 2011.

The company is in compliance to this requirement: Y Criterion Management documents are publicly available, except where this is prevented by 1.2 commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes. 1.2.1 Land titles / user rights (C 2.2)

S01 Findings: Management documents are publicly available Objective evidence:  Boustead has maintained their website with management documents relating to the unit, it’s environmental, social and legal issues demonstrating commitment towards compliance to RSPO criteria.  The website link http://bea.boustead.com.my was last updated on 15 April 2011 The company is in compliance to this requirement: Y 1.2.2 Safety and health plan (C 4.7)

S01 Findings: Management documents are publicly available Objective evidence:  Available at the website link http://bea.boustead.com.my

The company is in compliance to this requirement: Y 1.2.4 Pollution prevention plan (C 5.6)

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S01 Findings: Management documents are publicly available Objective evidence:  Available at the website link http://bea.boustead.com.my The company is in compliance to this requirement: Y Principle 2: COMPLIANCE WITH APPLICABLE LAWS AND REGULATION Criterion There is compliance with all applicable local, national and ratified international laws and 2.1 regulations. 2.1.1 Evidence of compliance with legal requirements. Compliance Major S01 Findings: Evidence of compliance with legal requirements were available. Objective evidence: At the time of surveillance visit, it was observed that copies of legal documents were available with the compilation of a list of applicable laws and regulations at both mill and estate levels.  For. e.g. Sg. Jernih POM has maintain the list of applicable law in the “Legal Register & Requirements ( Ref #: SJOM 2010-PR2) updated Jan 2012.  LTT-T Estate has a valid MPOB license ( License no: 504807-102000 ) as evidence to comply with “Akta Lembaga Minyak Sawit Malaysia 1998” .  LTT-T also has maintain approval letter dated 18 May 2011 ( Approval no: PCF:9/2011) on staff housing plan as a record to comply with Peraturan - Peraturan Standard Minimum Perumahan dan Kemudahan Pekerja 1990 stated in the Workers Minimum Standards of Housing and Amenities Act 1990.

The company is in compliance to this requirement: Y 2.1.2 A documented system, which includes written information on legal requirements. Compliance Minor S01 Findings: A documented system, which includes written information on legal requirements were available in the offices of the estates and mill.

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Objective evidence:  Estates and mill has maintain a documented system that includes information on legal requirements . For e.g. LTT-T estate has maintain List of Law and details of Law The company is in compliance to this requirement: Y 2.1.3 A mechanism for ensuring that they are implemented. Compliance Minor S01 Findings: Evidence of compliance with implementation were available. Objective evidence:  Mechanism to track legal changes is available and the manager is responsible to disseminate changes to the estate/mill management.  For example in LTT-T Estate the Estate Manager, Mr Anthony Jones, is still the responsible personnel for the dissemination of the changes and its implementation. The company is in compliance to this requirement: Y 2.1.4 A system for tracking any changes in the law. Compliance Minor S01 Findings: A system for tracking any changes in the law is in place Objective evidence: At the mill the following were documented :  The Flow Chart entitled “Identification and Update on Legal & Other Requirement Flow Chart” and “Mechanism of Tracking Law Changes”  . The Mill Manager is responsible to update any new Legal & Other Requirements into Register.

The company is in compliance to this requirement: Y Criterion The right to use the land can be demonstrated, and is not legitimately contested by local 2.2 communities with demonstrable rights. 2.2.1 Evidence of legal ownership of the land including history of land tenure. Compliance Major S01 Findings: Evidence of legal ownership of the land including history of land tenure are available Objective evidence:  There are no changes in land ownership.

The company is in compliance to this requirement: Y 2.2.2 Growers must show that they comply with the terms of the land title. Compliance [This indicator is to be read with Guidance 2]. Major S01 Findings: Growers show that they comply with the terms of the land title Objective evidence:

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 Sg Jernih Business Unit maintain and comply with the terms of the land title The company is in compliance to this requirement: Y 2.2.3 Evidence that boundary stones along the perimeter adjacent to state land and Compliance other reserves are being located and visibly maintained. Minor S01 Findings: There are evidence that boundary stones along the perimeter adjacent to state land and other reserves are being located and visibly maintained. Objective evidence:  Sg Jernih Business Unit has as much as they can maintained the boundary stones .  Replaced damaged boundary stones  Remarking of boundary due to overplanting  Overplanted sites identified during the main assessment were left as it is. Sites in Bebar Estate and LTT-T were visited during the surveillance as evidence of the Unit’s commitment. The company is in compliance to this requirement: Y 2.2.4 Where there are, or have been, disputes, proof of resolution or progress towards Compliance resolution by conflict resolution processes acceptable to all parties are Minor implemented. CF 2.3.3, 6.4.1 and 6.4.2. S01 Findings: Disputes, proof of resolution or progress towards resolution by conflict resolution processes acceptable to all parties are implemented and recorded. Objective evidence:  There is no land dispute reported at the time of audit. Interviews with the villagers indicate the same.  However, in LTT-T , the management raised a serious concern on how compliance to RSPO Principle 2 requirement has caused an intrusion by illegal smallholder. The overplanted area was left unattended and as a result, illegal smallholders decided to build a bridge access to harvest the FFB crop in the reserve! According to LTT-T management , they have brought the issue to the local state authorities, Ketengah and apply for ‘TOL ( lease the land ) ‘ to manage the overplanted area to be managed by Boustead but no respond was received. The smallholders took advantage of Sg Jernih Business Unit transparency and managed to obtained permits from the local politician and land office in Kemaman to rear cattle in the said piece of land. Of course the smallholders will harvest FFB from the land. The presence of illegal smallholders pose a crop security risk to LTT-T  This has been communicated to RSPO through an email.  LTT-T would like RSPO to do is to communicate with the land office of Kemaman to protect its members, like Boustead , that there should not be any interference from outside until the application of TOL has been approved.

The company is in compliance to this requirement: Y

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Criterion Use of the land for oil palm does not diminish the legal rights, or customary rights, of other 2.3 users, without their free, prior and informed consent. 2.3.1 Where lands are encumbered by customary rights, participatory mapping should Compliance be conducted to construct maps that show the extent of these rights. Major S01 Findings: Evidence of mapping conducted to construct maps that show the extent of the customary rights. Objective evidence:

 As reported in the main assessment all plantations were established in the 1970s/80s without diminishing the legal rights, or customary rights, of other users in the vicinity at the time of planting.

The company is in compliance to this requirement: Y 2.3.2 Map of appropriate scale showing extent of claims under dispute. Compliance Major S01 Findings: Estate maps of appropriate scale available . Objective evidence:  No issues of claims or disputes raised since the last audit. The company is in compliance to this requirement: Y 2.3.3 Copies of negotiated agreements detailing process of consent. (C2.2, 7.5 and Compliance 7.6). Minor S01 Findings: A copy of negotiated agreements detailing process of consent is available. Objective evidence:  Record of process covering discussion and consultation with the affected parties for example with regard to the earmarking and protection of worshipping places is available. The company is in compliance to this requirement: Y

Principle 3: COMMITMENT TO LONG-TERM ECONOMIC AND FINANCIAL VIABILITY Criterion There is an implemented management plan that aims to achieve long-term economic and 3.1 financial viability. 3.1.1 Annual budget with a minimum 2 years of projection. Compliance Major S01 Findings: Annual budget with a minimum 2 years of projection is available. Objective evidence:  Annual budget is available and shown in “Forecast For Year 2013-2017.  Crop Yielding Areas, General Charges , upkeep, collection and depreciation of prime mature and young mature.  For year 2012 , total crop production is budgeted 32,300MT for prime and young mature.

The company is in compliance to this requirement: Y

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3.1.2 Annual replanting programme projected for a minimum of 5 years with yearly Compliance review. Minor S01 Findings: The 5 year replanting programme is avialable Objective evidence:  The annual replanting programme is documented in the replanting file. available for each estate. The company is in compliance to this requirement: Y

Principle 4: USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS: Criterion Operating procedures are appropriately documented and consistently implemented and 4.1 monitored. 4.1.1 Documented Standard Operating Procedures (SOP) for estates and mills. Compliance Major S01 Findings: Documented Standard Operating Procedures (SOP) for estates and mills are available and maintained. Objective evidence:  The Oil Palm Circular ( O.P.C) is the manual used for the operations in the estates is maintained and updated when a revision is conducted.  Similarly the Mill SOP is available in Mill Operation Manual (MOM) & QAM (Quality Assurance Manual) The company is in compliance to this requirement: Y 4.1.2 Records of monitoring and the actions taken are maintained and kept for a Compliance minimum of 12 months. Minor S01 Findings: Records of monitoring and the actions taken are maintained and kept for a minimum of 12 months Objective evidence:  The management reviewed the SOP on 2nd May 2012 and the records of monitoring and actions are now kept. Minor CAR 04 Closed . The company is in compliance to this requirement: Y Criterion Practices maintain soil fertility at, or where possible improve soil fertility to a level that 4.2 ensures optimal and sustained yield. 4.2.1 Monitoring of fertilizer inputs through annual fertilizer recommendations. Compliance Minor S01 Findings: Monitoring of fertilizer inputs through annual fertilizer recommendations is available.

Objective evidence:  Annual fertiliser recommendation is done annually

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 Ref: OP Manuring Recommendation 2012 Sg Jernih .Field PJ 08B was sampled  Ref: Work Programme Manuring 2012 of Sg Jerni Field PJ 08B was checked and the recommended amount of 1 kg of Ammonium Nitrate was applied  Similarly, In Bebar , a visit was done to PJ08D where application of fertiliser was being applied. Kieserite @ 1.75 kg . This was in accordance to the OP Manuring Recommendation 2012 Bebar Estate.  The company is in compliance to this requirement: Y 4.2.2 Evidence of periodic tissue and soil sampling to monitor changes in nutrient Compliance status. Minor S01 Findings: Evidence of periodic tissue and soil sampling available Objective evidence:  Ref: Sampling done by the AAR R&D in Feb – Mar 2011.

The company is in compliance to this requirement: Y 4.2.3 Monitor the area on which EFB, POME and zero-burn replanting is applied. Compliance Minor S01 Findings: Before the establishment of the composting plant , EFB and POME applied in the fields are recorded . Objective evidence:  In Sg Jernih estate : Records where EFB and POME are applied is documented in the EFB and POME utilization table/file .  In Block PR08/D Month Volume(m3) Ha Vol/ha May 3775 30 125.83 Jun 4327 30 144.23 Jul 4732 30 157.73  For Sg Jernih Estate, the Transporting EFB Report records the application of EFB. For example , as of July 2012, Field PJ 08E ( 49.20 ha ) received 2,536 MT to- date.

 In Bebar : No placement of EFB as the Unit has initiated a composting plant to utilise the EFB and the POME.  No EFB or POME applied in LTT-T as the estate is far from the Palm Oil Mill. The company is in compliance to this requirement: Y Criterion Practices minimise and control erosion and degradation of soils. 4.3 4.3.1 Documented evidence of practices minimizing soil erosion and degradation Compliance (including maps). Minor S01 Findings: Documented evidence of practices minimizing soil erosion and degradation (including

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maps) are available.

Objective evidence:  The unit has a ‘Polisi Perlindugan tanah curam’ or slope area policy in place  The O.P.C documents the SOP for practices to minimise and control erosion.  Topography maps are available to identify erosion –prone areas.  In Bebar: Evidence in the fields of young planting where the ground cover of cover crop is maintained to prevent erosion and minimise soil run-off  In LTT-T , gabions are constructed and Guatemala grass planted on affected areas eg PM04. The company is in compliance to this requirement: Y 4.3.2 Avoid or minimize bare or exposed soil within estates. Compliance Minor S01 Findings: Bare and exposed soil is minimised. Objective evidence:  The O.P.C documents the SOP for practices on soil conservation and weeding practices to avoid exposed soils.  In Bebar : As above. Maintenance of ground cover during replanting as well as control of spray only within the circles of the palms and paths  The company is in compliance to this requirement: Y 4.3.3 Presence of road maintenance programme. Compliance Minor S01 Findings: Presence of documented road maintenance programme is available

Objective evidence:  In Bebar Estate :In the Costing Book , Payment & Maps. In the Road maintenance programme for the year 2012 , budget is being allocated to: a) Grading b) Resurfacing c) Roadside & Cross Drain d) Slashing e) Pruining overhanging Fronds f) Making new roads g) Bullock Cart track upkeep  In Sg Jernih Estate, silt pits and side drains are also constructed to maintain the roads The company is in compliance to this requirement: Y 4.3.4 Subsidence of peat soils should be minimised through an effective and Compliance documented water management programme. Minor ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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S01 Findings: Soil map is available to identify the soil type.

Objective evidence:  Soil maps available in the estate verified that there is no peat in the 3 FFB supplying units  For example in Bebar Estate the low lying area is identified as swamp areas. The company is in compliance to this requirement: Y 4.3.5 Best management practices should be in place for other fragile and problem soils Compliance (e.g. sandy, low organic matter and acid sulphate soils). Minor S01 Findings: Soil map is available to identify the soil type.

Objective evidence:  There are no fragile or problem soils within the Unit.

The company is in compliance to this requirement: Y Criterion Practices maintain the quality and availability of surface and ground water. 4.4 4.4.1 Protection of water courses and wetlands, including maintaining and restoring Compliance appropriate riparian buffer zones at or before replanting along all natural Major waterways within the estate. S01 Findings: Although the Unit has documented evidence and policy for the protection of water courses and wetlands, including maintaining and restoring appropriate riparian buffer zones at or before replanting along all natural waterways within the estate , however some isolated areas were oversprayed.

Objective evidence:  Isolated oversprayed areas were found within the riparian buffer zone visited.  In Sg Jernih : A few palms on the riparian along river at 08E although marked were sprayed  Bebar estate : Some palms within the riparian along the main drain PR 10 & PR 11 were sprayed.

The company is in compliance to this requirement: N (Observation 01 ) 4.4.2 No construction of bunds/weirs/dams across the main rivers or waterways Compliance passing through an estate. Major S01 Findings: No construction of bunds/weirs/dams across the main rivers or waterways passing through an estate were found.

Objective evidence:

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 In Bebar no construction of bunds/weirs/dams across the main river or waterways passing through the estate The company is in compliance to this requirement: Y 4.4.3 Outgoing water into main natural waterways should be monitored at a frequency Compliance that reflects the estates and mills current activities which may have negative Major impacts (Cross reference to 5.1 and 8.1). S01 Findings: Outgoing water monitored and sampled.

Objective evidence:  In the Water Quality Monitoring file, sampling points identified in the estates maps  Water sampled yearly. The latest sample for Bebar Estate was done on 2/3/12  Result and comments on of the analysis kept in the file  In Bebar Estate, the result of the drinking water at the Intake Station and at the household were analysed by the ‘Pejabat Kesihatan Dearah Pekan’ 1 Ogos 2012 and the results reported that the water is fit for human consumption. The company is in compliance to this requirement: Y 4.4.4 Monitoring rainfall data for proper water management. Compliance Minor S01 Findings: Rainfall is recorded daily

Objective evidence:  Ref: Monitoring done in the estate rainfall data file  Example of the data ( Annula rainfall in mm ) Year Sg Jernih Estate Bebar Estate 2009 2509 2035 2010 2228 2029 2011 2605 2532 2012 1373 ( till July ) 1080 ( till July )

The company is in compliance to this requirement: Y 4.4.5 Monitoring of water usage in mills (tonnage water use/tonne FFB processed). Compliance Minor S01 Findings: Water usage in the palm oil mill is monitored

Objective evidence:  The water usage of Sg Jernih Palm Oil Mill was tabulated for monitoring .

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 2011 records Month Sept Oct Nov Dec FFB 8021.57 7432.27 6239.14 2448.18 Processed Boiler usage 4720 4472 3891 1691 m3 Processed 1162 1392 1222 367 usage m3 Water usage 0.88 0.93 0.99 0.96 (m3/MT FFB )

 Water usage in the estate is also monitored: Monitored monthly for domestic usage.  Example of water usage : Ladang Sg Jernih Year m3 2010 154,317 2011 96,888 2012 ( till June) 68,072

The company is in compliance to this requirement: Y 4.4.6 Water drainage into protected areas is avoided wherever possible. Appropriate Compliance mitigating measures will be implemented following consultation with relevant Minor stakeholders. S01 Findings: No water is drain into protected areas Objective evidence:  No water is drain into protected areas The company is in compliance to this requirement: Y 4.4.7 Evidence of water management plans. Compliance Minor S01 Findings: Evidence of water management plans were available in both the estates and mill. Objective evidence:  Documented Water Management Plan ( 2012) that include: 1) Riparian buffer zone 2) Areas where buffer zone not established 3) Water quality Monitoring 4) Drainage system in the field 5) Roadside Drain 6) Water treatment- Tanks are used for water storage at estate household. Daily records also taken in order to monitor water usage Although the Unit is committed to a Water Management Plan yet water wastage was

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evident at the linesite.  LTT-T Water leaking at linesite piping

The company is in compliance to this requirement: N (Observation 02 ) Criterion Pests, diseases, weeds and invasive introduced species are effectively managed using 4.5 appropriate Integrated Pest Management (IPM) techniques. 4.5.1 Documented IPM system. Compliance Minor S01 Findings: The IPM system is documented both in the SOP and circulars ( OPC ).

Objective evidence:  Within the OPC and the IPM Plan , the Unit has identified the following: a) IPM Coordinator b) Pesticide application c) Biological control d) Training e) General IPM Strategies f) Pest –Specific strategies : ants, leaf eating insects, rats, rhinoceros beetle, Ganoderma g) IPM Action plan flow chart The company is in compliance to this requirement: Y 4.5.2 Monitoring extent of IPM implementation for major pests. Compliance Minor S01 Findings: Monitoring extent of IPM implementation for major pests are recorded.

Objective evidence:  Monitoring Programme of the following are kept and monitored:  Planting & Upkeep of beneficial plant. Areas planted and future planting are are mapped out.  Barn Owl census and rat census For example in LTT-T : Monitoring programme: a) Barn Owl census ( quarterly ) . Barn owl occupancy : out of 80 boxes, only 27 boxes were occupied ( 25.2% ) in May 2012 b) Quarterly Black Bunch Census identifies forecast crop & rat attack. c) Rat baiting census , apply until acceptance is <5 % . This year the baiting started in April 2012.

 RB Census a) In Bebar Estate : Records of RB damage census and the summary for the different field are documented.

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b) In field 09G , chemical application of Cypermethrin was initiated as the pheromone trap record show that the pest level was above the threshold. c) Spraying was done with CKS.on the spear, leaf axil and drenchin o f the bore

The company is in compliance to this requirement: Y 4.5.3 Recording areas where pesticides have been used. Compliance Minor S01 Findings: Records of areas where pesticide are used is available

Objective evidence:  Ref: Stock Record Book  Herbicide Usage Form  In Bebar Estate the records are kept in :: a) Issuance Record from Pesticide Store and Upkeep program b) Chemical used in Field c) Monthly records of Pesticide Usage d) Reduction chemical usage records  In LTT-T Records are found in : a) Store issue form b) Costing Book c) Computerise Monthly Expenditure ledger The company is in compliance to this requirement: Y 4.5.4 Monitoring of pesticide usage units per hectare or per ton crop e.g. total quantity Compliance of active ingredient (a.i.) used/ tonne of oil. Minor S01 Findings: Monitoring of pesticide usage was available

Objective evidence:

 Ref: Monitoring of pesticide usage file  Monitored done on each pesticide.  An example obtained form the estate: LTT-T Chemical : Glyphosate 41% Usage( lits ) Ha cover Usage/Ha May 240 289.50 0.83 June 680 827.20 0.82

The company is in compliance to this requirement: Y

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Criterion Agrochemicals are used in a way that does not endanger health or the environment. There is 4.6 no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. Where agrochemicals are used that are categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented. 4.6.1 Written justification in Standard Operating Procedures (SOP) of all agrochemicals Compliance use. Major S01 Findings: Written justification of agrochemicals use is available. Objective evidence:  LTT-T has justification under the O.P.C for a) Weeds OPC No. 01.b b) Rats OPC No. 04b c) RB OPC No. 04f The company is in compliance to this requirement: Y 4.6.2 Pesticides selected for use are those officially registered under the Pesticides Act Compliance 1974 (Act 149) and the relevant provision (Section 53A); and in accordance with Major USECHH Regulations (2000). S01 Findings: Pesticides selected for use are those officially registered under the Pesticides Act 1974 (Act 149) and the relevant provision (Section 53A); and in accordance with USECHH Regulations (2000). Objective evidence:  All agrochemical used are registered in Malaysia The company is in compliance to this requirement: Y 4.6.3 Pesticides shall be stored in accordance to the Occupational Safety and Health Compliance Act 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act Major 149) and Regulations. S01 Findings: It was found that Pesticides were not stored in accordance to the Occupational Safety and Health Act 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations Objective evidence:  Although the following was found to be available : a) PPE b) Spill kit c) Hazard signs d) Operating Manual e) MSDS f) Ventilation g) Lighting h) Solid door and god roofing i) Labelling of products the following were found to be lacking::

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 Emergency phone numbers were not found posted at the chemical store in both Bebar Estate and LTT-T  An empty 20 litre drum of Supersate was found in the waste store in Ladang Sg Jernih  2 Bottles of herbicide Starane were found together with lubricating oil storage compartment of the P&D tractor in Bebar Estate and in LTT-T estate at least 2 old bottles of pesticide Nurelle ( the other 2 bottles do not have label ) were found in the garden ground of one of the estate staff. The company is in compliance to this requirement: N ( Observation 03 ) 4.6.4 All information regarding the chemicals and its usage, hazards, trade and generic Compliance names must be available in language understood by workers or explained Major carefully to them by a plantation management official at operating unit level. S01 Findings: Some of the information regarding the chemicals and its usage, hazards, trade and generic names were not available

Objective evidence:  Although in Bebar Estate, information on the chemicals are available in the local language however,  In Sg Jernih Estate MSDS for pesticide Kilsect and Nativo and for LTT-T MSDS for Garlon respectively were found to be missing

The company is in compliance to this requirement: N (Observation 04) 4.6.5 Annual medical surveillance as per CHRA for plantation pesticide operators. Compliance Major S01 Findings: Annual medical surveillance as per CHRA for plantation pesticide operators were found to be available. Objective evidence:  New workers undergo the FOMEMA medical assessment @ RM180 per male and RM190 for female workers.  The Spray workers : Hidayat, , Lukman,Pendika, Iskana, Jaelani and Mukri documentation were checked and found to be in place  For workers after 3 years with the company, the Unit will sent them to the annual Occupational safety and Health Act check up to certify fitness under the USECHH regulation

The company is in compliance to this requirement: Y 4.6.6 No work with pesticides for confirmed pregnant and breast-feeding women. Compliance Major S01 Findings: No female spray workers Objective evidence:  In LTT-T , no spraying are assigned to female workers The company is in compliance to this requirement: Y

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4.6.7 Documentary evidence that use of chemicals categorised as World Health Compliance Organisation Type 1A or 1B, or listed by the Stockholm or Rotterdam Minor Conventions and paraquat, is reduced and/or eliminated. Adoption of suitable economic alternative to paraquat as suggested by the EB pending outcome of the RSPO study on IWM. S01 Findings: Documentary evidence that use of chemicals categorised as World Health Organisation Type 1A or 1B, or listed by the Stockholm or Rotterdam Conventions and paraquat, is reduced and/or eliminated Objective evidence:  Usage of type 1B Monocrotophos ( Krotofos 60 ) by trunk injection was used to control bagworm in May 2011.  The Unit will monitor its bagworm count after application to decide cessation of the usage of the pesticide when the count is below the threshold level.  No incidence was detected in 2012  Paraquat is not used as a herbicide.

The company is in compliance to this requirement: Y 4.6.8 Documented justification of any aerial application of agrochemicals. No aerial Compliance spraying unless approved by relevant authorities. Major S01 Findings: No aerial spraying done Objective evidence:  No aerial spraying required The company is in compliance to this requirement: Y 4.6.9 Evidence of chemical residues in CPO testing, as requested and conducted by Compliance the buyers. Minor S01 Findings: Evidence of chemical residues in CPO testing, as requested and conducted by the buyers. Objective evidence:  No request made by buyers The company is in compliance to this requirement: Y 4.6.10 Records of pesticide use (including active ingredients used, area treated, amount Compliance applied per ha and number of applications) are maintained for either a minimum Minor of 5 years or starting November 2007. S01 Findings: The Unit has records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) are maintained Objective evidence:  The Unit has records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) since the main audit in 2011.  Records of pesticide usage is found in the ‘chemical file’ uder the title: a) Pengunaan Bahan Kimia dalam Ladang bagi Tahun 2012

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b) Reduction of chemical Usage The company is in compliance to this requirement: Y

Criterion An occupational health and safety plan is documented, effectively communicated and 4.7 implemented. 4.7.1 Evidence of documented Occupational Safety Health (OSH) plan which is in Compliance compliance with OSH Act 1994 and Factory and Machinery Act 1967(Act 139). Major S01 Findings: Incomplete evidence of documented Occupational Safety Health (OSH) plan which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967(Act 139).

Objective evidence:  The Unit has documented Occupational Safety Health (OSH) plan & policy in place and found on notice boards.  The safety and health policy is also communicated daily during the muster.  Training programme includes the safe handling of pesticide, correct usage of PPE , emergency response procedures, usage of fire-extinguisher etc.  PPE are distributed for the operations  Accident and emergency procedures notices are found at the stores  Mandores Mislan ( Bebar Estate ) , Decreeping Legume Mandore Ros and the Harvesting Mandore at LTT-T Estate all had their first aid kits. However the following was found to be lacking:  The first aid kit at the chemical store ( Bebar Estate ) and at the fertilizer store ( LTT-T Estate ) was not replenished as some of the items were missing or used up  During audit , the Store Staff ( LTT-Testate ) entered the chemical store were not wearing proper PPE ( slippers and without mask )

The company is in compliance to this requirement: N (Observation 05 ) 4.7.2 Records should be kept of all accidents and periodically reviewed at quarterly Compliance intervals. Major S01 Findings: Accident records are kept, periodically reviewed at quarterly intervals Objective evidence:  In Bebar Estate , records of accident are monthly updated in the Accident record file.  It is periodically reviewed in the JKKP meeting that is conducted quarterly.  In 2012 the March and June 2012 minutes have been documented and filed in the meeting file.

The company is in compliance to this requirement: Y 4.7.3 Workers should be covered by accident insurance. Compliance Major

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S01 Findings: Workers are covered by accident insurance. Objective evidence:  All workers are insured under the AXA Workmen Compensation Scheme  The Unit uses contract system where monitoring of payment, PPE, Housing is done by the Unit.  The Unit uses contract workers for some of their operations like harvesting. Passport & Insurance of the contract workers are paid by the contractor.  Copies of the AXA Workmen Compensation Scheme are available at the estate. For example , in Bebar Estate the policy No: LWX/03032688/27/12/SC for the period 1/1/12 – 31/12/12 was viewed.  No. of workers 149 workers. The estate makes sure all workers provided by the contractor are insured.  For the Harvesting operation in Sg Jernih Estate, the contractor Sukandar Munthe Enterprise provide the workers .

The company is in compliance to this requirement: Y Criterion All staff, workers, smallholders and contractors are appropriately trained. 4.8 4.8.1 A training programme (appropriate to the scale of the organization) that includes Compliance regular assessment of training needs and documentation, including records of Major training for employees are kept. S01 Findings: A training programme (appropriate to the scale of the organization) that includes regular assessment of training needs and documentation, including records of training for employees are kept

Objective evidence:  A training programme and plan for 2012 , including records of training for employees are kept in the training file at each estate and mill.  For example in the records, Harvesting Mandore Mislan ( Bebar Estate ) has been trained as a first aider on 4-5 Feb 2011.  So has the contractor Mr Kanda of Sukandar Munthe Enterprise.  In Bebar Estate: Employee training and Development records are available The company is in compliance to this requirement: Y

Principle 5 : ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY Criterion Aspects of plantation and mill management, including replanting, that have environmental 5.1 impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement. 5.1.1 Documented aspects and impacts risk assessment that is periodically reviewed Compliance and updated. Major

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S01 Findings: Documented aspects and impacts risk assessment are periodically reviewed and updated. Objective evidence:  LTT –T Ref : BEA/5.1/EAI , ‘Borang Pengenalpastian Aspek & Impak Alam Sekitar’ for the various acitvitity within the estate is documented.with the latest 1/12/2011.  Some of the stations identified were: a) Persekitaran b) Kawalan Mahkluk Perosak c) Penghataran BTB d) Petrol / diesoline e) Stor Bahan Buangan Terjadual f) Menuai & Memungut hasil g) Jalan h) Meracun & Merumput i) Klinik j) Pintu masuk Utama  Similar documents are also available in Bebar Estate  a) EAI Identification Form (EQMS)  b) EIE Form (Evaluation Criteria)

The company is in compliance to this requirement: Y 5.1.2 Environmental improvement plan to mitigate the negative impacts and promote Compliance the positive ones, is developed, implemented and monitored. Minor S01 Findings: Environmental improvement plan to mitigate the negative impacts and promote the positive ones, is developed, implemented and monitored Objective evidence:  Ref: Environmental Management Plan file. It consist of the Environmental managemet Programme that identifies the Objectives, Target, Action plan, proposed and completion date, Proposed budget, person –in-charge as well as the status/verification.  The objectives identified were: a) Water source contamination b) Conservation soil Erosion c) Agricultural land contamination d) Degradation of Agricultural land e) Chemical reduction  A checklist for the operation is also available The company is in compliance to this requirement: Y Criterion The status of rare, threatened or endangered species (ERTs) and highly conservation value 5.2 habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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plans and operations. 5.2.1 Identification and assessment of HCV habitats and protected areas within land Compliance holdings; and attempt assessments of HCV habitats and protected areas Major surrounding landholdings. S01 Findings: Identification and assessment of HCV habitats and protected areas within land holdings Objective evidence:  This was done prior the main assessment  Ref: A Rapid conservation Assessment of Sg Jernih Business Unit ( Identification of HCV) prepared by WildAsia Aug 2010.  It identifies the HCV landscapes and biodiversity of Sg Jernih Business Unit for the 3 estates.  Estates has the ‘Biodiversity Point map’, Wetland point Map  In Bebar, Wildlife Conservation Area is identified both in the field as well as in the map

The company is in compliance to this requirement: Y 5.2.2 Management plan for HCV habitats (including ERTs) and their conservation. Compliance Major S01 Findings: Management plan for HCV habitats (including ERTs) and their conservation is avialable Objective evidence:  The parent company Boustead Plantaitns Berhad has establish a policy on commitment to environment and biodiversity ,’ Polisi Alam Sekitar dan Biodiversiti;  HCV habitats identified were maintained with the signs ‘Biodiversity Lung’ found in the estates.

 LTT-T has issued an internal policy ( 1 March 2011 ) : ‘Polisi Activiti Pemburuan Hidupan Liar Akta 1972(76) to discourage hunting in the estate. The company is in compliance to this requirement: Y 5.2.3 Evidence of a commitment to discourage any illegal or inappropriate hunting, Compliance fishing or collecting activities, and developing responsible measures to resolve Minor human-wildlife conflicts. S01 Findings: Evidence of a commitment to discourage any illegal or inappropriate hunting, fishing or collecting activities, and developing responsible measures to resolve human-wildlife conflicts.

Objective evidence:  Boustead has a management policy: ‘Polisi Alam Sekitar & Biodiversiti’ issued on 11 January 2011 to protect and support biodiversity.  ‘No Hunting’ signages were found at designated identified areas and was found to be sufficient.

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The company is in compliance to this requirement: Y

Criterion Waste is reduced, recycled, re-used and disposed of in an environmentally and socially 5.3 responsible manner. 5.3.1 Documented identification of all waste products and sources of pollution. Compliance Major S01 Findings: Documented identification of all waste products and sources of pollution available Objective evidence:  LTT-T has started to compile ‘ Senarai Bahan kimia/bahan yang boleh di kitar semula. The company is in compliance to this requirement: Y 5.3.2 Having identified wastes and pollutants, an operational plan should be developed Compliance and implemented, to avoid or reduce pollution. Minor S01 Findings: Although the Unit has identified wastes and pollutants, an operational plan developed to avoid or reduce pollution implementation seemed lacking.

Objective evidence:  LTT-T estate has segregated the recyclable materials like plastic, tins etc, however it is accumulating and piling up at the linesite as they report that there are no interested collector.  A chemical supplier Indah Agro Sdn Bhd collects the chemical containers for Mido Resources ( CA 017619-W) an approved chemical container collector . It was informed that Mido Resources will deliver the containers to an approved disposal company in Johor.  On the 7th August a collection was made for 18 x 20 lit and 150 kg of plastic containers from LTT-T estate.  For Scheduled Waste, a collection was done by Hiap Huat chemical Sdn Bhd for SW305 for the quantity 28 x 20 lit ( for LTT-T estate) .  For Sg Jernih estate , an approved waste oil collector : QLD Trading Sdn Bhd collected 600 m3 on 29/6/12 to be disposed off at Kualiti Kitar Alam Sdn Bhd. In spite of the above , the following were found to be wanting :  complete and correct use of spill kit is lacking at : a) workshop ( Sg Jernih estate ) b) chemical store ( LTT-T estate ) c) contaminated or used sawdust need to be disposed off in proper manner ( LTT –T estate)  In all estate , reuse of chemical container for a) storage of lubricant oil ( LTT-T & Bebar estate) b) petrol ( LTT –T staff quarter ) , c) FFB loader Rudin was using a loose fruit scraper made from chemical container ( Sg Jernih estate) d) contractor store ( Bebar )

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 In Sg Jernih, a container of used oil was found disposed at the scrap iron site.

The company is in compliance to this requirement: N (Minor 08) 5.3.3 Evidence that crop residues / biomass are recycled (Cross ref. C4.2). Compliance Minor S01 Findings: There are evidence that crop residues / biomass are recycled

Objective evidence:  Please refer to Indicator 4.2.3 for evidence of mill by-product and waste like EFB and POME are recycled back to the estate.  LTT is about 150km from the mill so do not get the EFB as it is dangerous to transport EFB for long distance due to spillage on the road.  Within the estate, pruned fronds are place along the palm inter-rows as a practice of recycling of crop residue. The company is in compliance to this requirement: Y Criterion Efficiency of energy use and use of renewable energy is maximized. 5.4 5.4.1 Monitoring of renewable energy use per tonne of CPO or palm product in the mill. Compliance Minor S01 Findings: Monitoring of renewable energy use per tonne of CPO or palm product in the mill is tabulated.

Objective evidence:  Burning of palm fibre and shell in the boiler is used as sources for the production renewable energy

 Documents at the mill show that renewable energy use per tonne of FFB is recorded and monitored monthly .  Sample of the records: Renewable energy ( kWh) generated for 2012 Month May Jun Jul FFB processed 4539.15 4969.18 6049.90 kWh 165,110 151,740 182,320 kWh/FFB 36.37 30.54 30.14

The company is in compliance to this requirement: Y 5.4.2 Monitoring of direct fossil fuel use per tonne of CPO or kW per tonne palm Compliance product in the mill (or FFB where the grower has no mill). Minor

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S01 Findings: Monitoring of direct fossil fuel use per tonne of CPO or kW per tonne palm product in the mill is recorded.

Objective evidence:  In the mill , usage of diesel is recorded in the ‘ Pengunaan Diesel’ file  The estates lile Bebar Estate also monitors fossil fuel usage in the ‘Record Of Fossil Used Per MT FFB (Diesel & Petrol Record). ‘

The company is in compliance to this requirement: Y Criterion Use of fire for waste disposal and for preparing land for replanting is avoided except in 5.5 specific situations, as identified in the ASEAN Guidance or other regional best practice. 5.5.1 No evidence of open burning. Where controlled burning occurs, it is as prescribed Compliance by the Environmental Quality (Declared Activities) (Open Burning) Order 2003. Major S01 Findings: No evidence of open burning Objective evidence:  Boustead do not practice open burning during replanting The company is in compliance to this requirement: Y 5.5.2 Previous crop should be felled/mowed down, chipped/shredded, windrowed or Compliance pulverized/ ploughed and mulched. Minor S01 Findings: Previous crop should be felled/mowed down, chipped/shredded, windrowed or pulverized/ ploughed and mulched.

Objective evidence:  Yes, during replanting the previous crop is felled , chipped/shredded, windrowed and placed between the planting points  The company is in compliance to this requirement: Y 5.5.3 No evidence of burning waste (including domestic waste). Compliance Minor S01 Findings: Although Sg Jernih Production Unit do not allow burning of waste (including domestic waste , this was found to be flouted at one site.

Objective evidence:

 At one of the worker’s home in LTT-T estate linesite , there was evidence that burning of of domestic waste like used safety boots and plastics material was done.

The company is in compliance to this requirement: N (Minor 09) Criterion Plans to reduce pollution and emissions, including greenhouse gases, are developed, 5.6 implemented and monitored. ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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5.6.1 Documented plans to mitigate all polluting activities (Cross ref to C5.1). Compliance Major S01 Findings: Documented plans to mitigate all polluting activities is found in the Environmental Management Plan.

Objective evidence:  Documented plans to mitigate all polluting activities is found in the Environmental Management Plan.  Pollution activities are identified in 5.1 and documented plans to mitigate all polluting activities was available. Documents and records viewed:  Environmental Management Plan.  Criteria for Evaluation of Environmental Aspects and Impact  Register of environmental aspect and impact  Environment impact evaluation form

The company is in compliance to this requirement: Y 5.6.2 Plans are reviewed annually Compliance Minor S01 Findings: Plans are reviewed annually

Objective evidence:  At LTT- T and Sg Jernih Palm oil mill it was found that the plans are reviewed annually  In the estates the annual reviewed plans are found in the Annual Quality / Safety / Environment Management Programs.

The company is in compliance to this requirement: Y 5.6.3 Monitor and reduce peat subsidence rate through water table management. Compliance (Within ranges specified in C 4.3). Minor S01 Findings: Not applicable as the Unit do not have peat areas.

Objective evidence:  No peat The company is in compliance to this requirement: Y

PRINCIPLE 6: RESPONSIBLE CONSIDERATION OF EMPLOYEES AND OF INDIVIDUALS AND COMMUNITIES BY GROWERS AND MILLERS

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Criterion Aspects of plantation and mill management, including replanting, that have social impacts 6.1 are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement. 6.1.1 A documented social impact assessment including records of meetings. Compliance Major S01 Findings: Documented social impact assessment including records of meetings is avilable. . Objective evidence:

 Observed during the surveillance visit that all the three estates and the mill have maintained the documented SIA , ‘ Addressing the Social Dimension of Oil Palm Developments in Boustead Plantation’ conducted by external consultant in 2010.

 All estates and mill also maintains records of meetings with stakeholders ( internal and external).

 For example in LTT-T, several meetings with stakeholders had been conducted. For example, the last meeting with stakeholders was conducted dated 20th Dec 2011 with stakeholders ( local communities ) . Minute of meeting was made available during the audit and kept in file.

The company is in compliance to this requirement: Y

6.1.2 Evidence that the assessment has been done with the participation of affected Compliance parties. Minor S01 Findings: Evidence that the assessment has been done with the participation of affected parties is available

Objective evidence:

 The SEIA report available at estates and mill showed that the assessment is carried out through consultation with stakeholders/affected parties to identify potential impacts and plans for mitigation measures to be taken to control negative impacts.

 For e.g. at Bebar Estate the report showed that involvement of surrounding local communities that affected (i.e. Kampung Dungun, Kampung Simpai, Kota Perdana) and workers.

The company is in compliance to this requirement: Y 6.1.3 A timetable with responsibilities for mitigation and monitoring is reviewed and Compliance updated as necessary. Minor S01 Findings: A timetable with responsibilities for mitigation and monitoring is reviewed and updated as necessary was not practised in all the sites.

Objective evidence:

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 Although it was found that the mill has maintain a time table for monitoring based on stake holder meeting output and SEIA report.,however, in LTTT, the estate has not establish a timetable with responsibilities for mitigation and monitoring social impacts that are identified during assessment.

The company is in compliance to this requirement: N (Observation 06)

Criterion There are open and transparent methods for communication and consultation between 6.2 growers and/or millers, local communities and other affected or interested parties. 6.2.1 Documented consultation and communication procedures. Compliance Major S01 Findings: Documented consultation and communication procedures was available Objective evidence:  All estates and mill has maintain Communication Procedure and Complaint Flow Chart to deal with complaints from external and internal stakeholders.  In all estates, they have established complaint panel committee to handle all stakeholders’ issues and complaints. The committee is chaired by estate’s manager.  The company maintains records of complaints made by stakeholders (particularly workers) and there were also evidence of communication with the surrounding villagers.

 This was viewed at Bebar Estate . It was shown that the estate maintains the communication procedure. The company is in compliance to this requirement: Y

6.2.2 A nominated plantation management official at the operating unit responsible for Compliance these issues. Minor S01 Findings: A nominated plantation management official at the operating unit responsible for these issues.

Objective evidence:  In all estates, they have established complaint panel committee to handle all stakeholders’ issues and complaints. The committee is chaired by estate’s manager.

 For e.g. at Bebar Estate a total 9 personnel been appointed as Complaint Panel to involved in communication with stakeholders.  At LTT-T , the Complaint Flow Chart showed that the complaint from stakeholders shall be reported to Assistant Managers or Estate Manager.

The company is in compliance to this requirement: Y

6.2.3 Maintenance of a list of stakeholders, records of all communication and records Compliance of actions taken in response to input from stakeholders. Minor

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S01 Findings: Maintenance of a list of stakeholders, records of all communication and records of actions taken in response to input from stakeholders

Objective evidence:  List of stakeholders , records of all communication and records of actions taken in response to input from stakeholders are maintain at estates and mill.  In LTT-T Estate, it was observed that complaints received from local communities have been discussed during stakeholders meeting ( for e.g. meeting conducted on 20 Dec 2011) . The minute of meeting available showed that both management and stake holders has agreed with the actions to be taken to solve the complaints..  Internally, complaints from workers has been discussed during the JKKP or JCC Meeting with the output of the meeting will be informed to all personnel attended the meeting.  At Bebar Estate the last JCC and JKKP meeting has been conducted on 05 July 2012 and 21 Mar 2012 respectively.  At Bebar estate , a meeting with native community was conducted on the 29th Feb 2012 The company is in compliance to this requirement: Y

Criterion There is a mutually agreed and documented system for dealing with complaints and 6.3 grievances, which is implemented and accepted by all parties. 6.3.1 Documentation of the process by which a dispute was resolved and the outcome. Compliance Major S01 Findings: Documentation of the process by which a dispute was resolved and the outcome is avialable Objective evidence:

 All estates sampled and mill maintains a complaints and grievance procedure for external and internal stakeholders that is specified in its SOP documentation.

 The document entitled “ Communication Procedure” and Grievance Flow Chart is available at all estates and mill. The company is in compliance to this requirement: Y

6.3.2 The system resolves disputes in an effective, timely and appropriate manner. Compliance Minor S01 Findings: Disputes are resolved in an effective, timely and appropriate manner.

Objective evidence:  Observed at LTT-T estate that all the complaint and grievances received had been in an effective, timely and appropriate manner. All action taken had been informed and accepted by complainer.

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The company is in compliance to this requirement: Y

6.3.3 The system is open to any affected parties. Compliance Minor S01 Findings: The system is open to any affected parties Objective evidence:  Observed during the audit that the system implemented is open to any affected parties, both internal and external.  Boustead has a website http://bea.boustead.com.my that is publicly available The company is in compliance to this requirement: Y

Criterion Any negotiations concerning compensation for loss of legal or customary rights are dealt 6.4 with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions. 6.4.1 Establishment of a procedure for identifying legal and customary rights and a Compliance procedure for identifying people entitled to compensation. Major S01 Findings: Establishment of a procedure for identifying legal and customary rights and a procedure for identifying people entitled to compensation Objective evidence:  Bebar Estate has established the procedure for identifying legal and customary right and procedure for identifying entitled to compensation The company is in compliance to this requirement: Y

6.4.2 A procedure for calculating and distributing fair compensation (monetary or Compliance otherwise) is established and implemented. This takes into account gender Minor differences in the power to claim rights, ownership and access to land; and long- established communities; differences in ethnic groups’ proof of legal versus communal ownership of land. S01 Findings: A procedure for calculating and distributing fair compensation (monetary or otherwise) is not established and implemented Objective evidence:  Although Bebar Estate has establish procedure for identifying legal and customary righ it has not established procedure for calculating and distributing fair compensation. The company is in compliance to this requirement: N ( Minor CAR 10) 6.4.3 The process and outcome of any compensation claims is documented and made Compliance publicly available. Minor S01 Findings: The process and outcome of any compensation claims is documented and made publicly available. Objective evidence:  No compensation claims received by Bebar Estate, Sg Jernih Estate or LTT-T

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The company is in compliance to this requirement: Y

Criterion Pay and conditions for employees and for employees of contractors always meet at least 6.5 legal or industry minimum standards and are sufficient to provide decent living wages. 6.5.1 Documentation of pay and conditions. Compliance Major S01 Findings: Documentation of pay and conditions is available Objective evidence:  The mill and estates maintains the pay slips of all employees.  Copies will be provided for the employees and staff

 The mill has a pay slip for each workers detailing the income (basic wages, price bonus, insurance subsidy, shift allowance, overtime etc.  Based on the pay slip, the income is above industry minimum. On interview with workers, the salary is paid on time.  Similar details are also found in the estate employee payslips  For local employees, the payslip will detail : the employee reference, basic wages, public Holiday pay, deduction for EPF, SOCSO and checkroll advance.

The company is in compliance to this requirement: Y

6.5.2 Labour laws, union agreements or direct contracts of employment detailing Compliance payments and conditions of employment (e.g. working hours, deductions, Minor overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc) are available in the language understood by the workers or explained carefully to them by a plantation management official in the operating unit. S01 Findings: The contracts of employment detailing payments and conditions of employment are available in the local language which understood by the workers. Objective evidence:

 There are proper terms and conditions for the employment of workers that are documented in the Offer Letter . Auditor had checked sample of Offer Letter at Sg. Jernih Mill and Bebar Estate and found that the Offer Letter clearly stated on detailing payments and condition of employment ( e.g. basic salary, overtime rate , annual leave , reason for dismissal, sickness etc.)

 E.g. of offer letter checked:  Mohd Nazir B. Nayan - Mill Operator 06 Jan 2012  Faizul Sham B. Utu - Mill Operator 17 Oct 2011  Mohd Zulkefli B. Abd Jalil - Mill Operator 19 Sept 2011  Bebar Estate maintains the offer letter: - Muhammad Zahiruddin Jamian 22 02 2012 - General Workers

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The company is in compliance to this requirement: Y

6.5.3 Growers and millers provide adequate housing, water supplies, medical, Compliance educational and welfare amenities in accordance with Workers’ Minimum Minor Standard of Housing and Amenities Act 1990 (Act 446) or above, where no such public facilities are available or accessible (not applicable to smallholders). S01 Findings: Growers and millers provide adequate housing, water supplies, medical, educational and welfare amenities Objective evidence:  Boustead has provided adequate amenities to all staff and workers  For e.g. the amenities available includes surau,staff housing equipped with piped treated water and electricity, sundry shop, canteen, clinic, worker’s hall, children playground, transportation to nearby school, ‘smart road system, waste disposal, recycled bins, landscaped surroundings, crèche, football field, gas cylinder storage area, ‘green-book project’, muster hall, bus stops, The company is in compliance to this requirement: Y

Criterion The employer respects the right of all personnel to form and join trade unions of their choice 6.6 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. 6.6.1 Documented minutes of meetings with main trade unions or workers Compliance representatives. Major S01 Findings: Documented minutes of meetings with main trade unions or workers representatives are available Objective evidence:  Minutes Of Meeting With Union Representatives  Bebar Estate maintains minutes of meeting ( 05 July 2012 and JKKK 21 Mar 2012. The company is in compliance to this requirement: Y

6.6.2 A published statement in local languages recognizing freedom of association. Compliance Minor S01 Findings: A published statement in local languages recognizing freedom of association is available.

Objective evidence:  Displayed Policy (Dual Language)  A valid freedom of association policy is available in all local languages. The company is in compliance to this requirement: Y

Criterion Children are not employed or exploited. Work by children is acceptable on family farms, 6.7 under adult supervision, and when not interfering with education programmes. Children are

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not exposed to hazardous working conditions. 6.7.1 Documented evidence that minimum age requirement is met. Compliance Major S01 Findings: There is documented evidence that the minimum age requirement is met. Objective evidence:  No evidence of child labour or under age workers in mill and estate operations. The company has a clearly defined minimum working age policy of 18 years and above.  For the mill, based on record ( Employee Master List), the youngest employee was born in year 1993 ( Mohd Azlan b. Mohd Hassan) The company is in compliance to this requirement: Y

Criterion Any form of discrimination based on race, caste, national origin, religion, disability, gender, 6.8 sexual orientation, union membership, political affiliation, or age, is prohibited. 6.8.1 A publicly available equal opportunities policy. Compliance Major S01 Findings: A publicly available equal opportunities policy is available. Objective evidence:  There is a publicly available equal opportunities policy all estates and mill which states that Boustead is an equal opportunity employer, whereby the company does not practice discrimination based on race, caste, national, origin, disability, gender, sexual orientation, union membership, political affiliation, or age. The company is in compliance to this requirement: Y

6.8.2 Evidence that employees and groups including migrant workers have not been Compliance discriminated against. Minor S01 Findings: There is evidence that employees and groups including migrant workers have not been discriminated against. Objective evidence:  Based on the interview conducted with some workers, there are no evidence of migrant workers been discriminated against.  All workers had been equally treated.

The company is in compliance to this requirement: Y

Criterion A policy to prevent sexual harassment and all other forms of violence against women and to 6.9 protect their reproductive rights is developed and applied. 6.9.1 A policy on sexual harassment and violence and records of implementation. Compliance Major S01 Findings: A policy on sexual harassment and violence and records of implementation is available.

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Objective evidence:  Sg. Jernih POM, Bebar Estate and LTT-T Estate has maintained a policy on sexual harassment, ‘ Polisi Gangguan Seksual’  A mechanism for recording grievances for official review is also available. The company is in compliance to this requirement: Y

6.9.2 A specific grievance mechanism is established. Compliance Major S01 Findings: A specific grievance mechanism is established Objective evidence:  All estates has established Grievance Procedure and Flow Chart to deal with woman’s issues and sexual harassment.  Agreed Grievances Procedure By Women Committee  At Bebar Estate, it was observed that the agreement letter signed by each employee on the method of complaint related to woman issues and sexual harassment dated 09 January 2012 is available. The company is in compliance to this requirement: Y

Criterion Growers and mills deal fairly and transparently with smallholders and other local 6.10 businesses. 6.10.1 Pricing mechanisms for FFB and inputs/services shall be documented. Compliance Major S01 Findings: Not applicable as the mill only sourced form their own supply bas estates Objective evidence:

 The POM only processes FFB sourced from its own plantations, so the company does not deal with smallholders and all operations within the estates are carried out by the company.

The company is in compliance to this requirement: Y

6.10.2 Current and past prices paid for FFB shall be publicly available. Compliance Minor S01 Findings:

Objective evidence:  The Sg. Jernih POM only processes FFB sourced from their own supplying estates The company is in compliance to this requirement: Y

6.10.3 Evidence that all parties understand the contractual agreements they enter into, Compliance and that contracts are fair, legal and transparent. Minor

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S01 Findings: Objective evidence:  The Sg. Jernih POM only processes FFB sourced from their own supplying estates The company is in compliance to this requirement: Y 6.10.4 Agreed payments shall be made in a timely manner. Compliance Minor S01 Findings: Objective evidence:  The Sg. Jernih POM only processes FFB sourced from their own supplying estates  Harvesters and contractors are paid in a timely manner The company is in compliance to this requirement: Y

Criterion Growers and millers contribute to local sustainable development wherever appropriate. 6.11 6.11.1 Demonstrable contributions to local development that are based on the results of Compliance consultation with local communities. Minor S01 Findings: Demonstrable contributions to local development that are based on the results of consultation with local communities. Objective evidence:  Proof Of Contribution (Letter/Receipt/Photos)  Some of the evidence documented are : - Family day - Gotong royong / clean-up of line site - Worker’s party - Children Day - Open air projection live telecast of the Euro Cup 2012 final - Donation to the local natives or ‘orang asli’ in terms of food and household items - Muslim festive season meat donation - Donation to the local police station

The company is in compliance to this requirement: Y

P7: RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS This whole Principle is not applicable to this assessment as there are no new plantings. The company is only involved in re-planting programme after felling of old palms and there is no plan for expansion.

P8: COMMITMENT TO CONTINOUS IMPROVEMENT IN KEY AREAS OF ACTIVITY Criterion Growers and millers regularly monitor and review their activities and develop and implement 8.1 action plans that allow demonstrable continuous improvement in key operations. ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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8.1.1 Minimise use of certain pesticides (C4.6). Compliance Major S01 Findings: Growers regularly monitor and review the use of certain pesticides

Objective evidence:  The Estate management regularly monitors and review the use of pesticides that is used .

 Chemical is monitored individually and tabulated in the ‘Annual Chemical Usage per ha ‘eg for the pesticide rat bait, glyphosate, amine, and Ally  In addition, the estates monitor the usage of chemical in terms of records and in graph The company is in compliance to this requirement: Y 8.1.2 Environmental impacts (C5.1). Compliance Major S01 Findings: Growers and millers regularly monitor and review the environmental impacts Objective evidence:  Ref: Environmental Management Plan file. It consist of the Environmental management Programme that identifies the Objectives, environmental aspects and impact, Pollution prevention plan, Target, Action plan, proposed and completion date, Proposed budget, person –in-charge as well as the status/verification  Monitoring is done on regular basis. Environmenta Aspect Impact and Evaluation forms are submitted regularly to the management to monitor the maintenance of the different operations.  Some of the upgrade done in the estates to minimise the environment impacts are : a) Construction of oil traps b) Concrete floor and wall for diesel tank c) Schedule waste store In the mill the following are some of the improvement they have introduced: a) Composting plant to utilise the EFB and POME b) Boiler smoke monitoring – to connect CEMS to the Dept of Environment and the installation of lightning arrestor.

The company is in compliance to this requirement: Y 8.1.3 Maximizing recycling and minimizing waste or by-products generation. Compliance Major S01 Findings: Growers and millers regularly monitor and review the recycling and minimizing waste or by- products generation. Objective evidence: ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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 List Of Recycle Item  Estate Recycle Program  Estate Recycle Records  Training Refer C4.2/C4.3/C4.4/C4.5  Monitoring of weekly domestic waste started in 2012 The company is in compliance to this requirement: Y 8.1.4 Pollution prevention plans (C5.6). Compliance Major S01 Findings: Growers and millers regularly monitor and review the pollution prevention plans Objective evidence:  Ref: Environmental Management Plan file. It consist of the Environmental management Programme that identifies the Objectives, environmental aspects and impact, Pollution prevention plan, Target, Action plan, proposed and completion date, Proposed budget, person –in-charge as well as the status/verification  In LTT-T , the triple rinsing practice and procedure has been emphasised and training conducted to reduce chemical pollution  For the mill – refer to 8.1.2 The company is in compliance to this requirement: Y 8.1.5 Social impacts (C6.1). Compliance Major S01 Findings: Growers and millers regularly monitor and review the social impacts Objective evidence:  The management is committed and regularly meet with the stakeholders, staff and workers to discuss social matters.

Some of the upgrades done for the convenience of the workers are : a) Shelter in the field especially in fields that are a distance b) Housing repainting c) Upgrade of clinic The company is in compliance to this requirement: Y 8.1.6 A mechanism to capture the performance and expenditure in social and Compliance environmental aspects. Minor S01 Findings: The estates and mill has a mechanism to capture the performance and expenditure in social and environmental aspects. Objective evidence:  One of the mechanism used to capture the performance and expenditure in social and environmental aspects is through the yearly financial budget meeting and planning. ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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 Each estate will prepare their estimates based on the staff and workers’ representatives. This will then be presented to the management for approval.  LTT-T In the Financial Budget 2012 under the Welfare code 12 the social allocation is reported to be : RM87,341

The company is in compliance to this requirement: Y

6. MODULE D – CPO MILLS: SEGREGATION

As described in the earlier sections of this report, Fresh Fruit Bunches (FFB) produced by the plantation are transported to and processed at Sg. Jernih mill which is located within the Sg. Jernih Estate in Pahang. The mill with a capacity of 30 metric tonne FFB per hour receives and processes only raw materials from the supply base estates, Sg. Jernih, Bebar and Ladang Tabung Tentera. Below is the summary of the

Palm Oil Product Categories Approximate Annual Purchases

FFB ( 2011 ) 69,485.40 MT Purchased

CPO ( 2011 ) 14,780.00 MT

Sale / Processed Palm Kernel ( 2011 ) 2,866.00 MT

Sale as RSPO Certified CPO ( 2011 ) 0

Palm Kernel ( 2011 ) 0

Module D: Segregation

Module D.1: Documented Procedures Criterion D.1.1: The facility shall have written procedures and/or work instructions to ensure the implementation of all the elements specified in these requirements. D.1.1.1 Complete and up to date procedures covering the implementation of all the elements in these requirements

Findings In Yes: X No: compliance: Objective The Mill has the Standard Operation Procedures (SOP) - Mill Operation Manual evidence: document that identify the critical control points (CCPs) and described the method used in identifying, segregating and recording at each point identified. - Introduction - Machinery Layout - Schematic Flow Diagram - Quality Plan - Reception Station - Fruit Handling

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- Sterilization Station - Threshing Station - Pressing Station - Depricarping Station - Nut Cracking and Kernel Station - Clarification Station - Boiler House - Engine Room

D.1.1.2 The name of the person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements

Verifiers and guidance: This person shall be able to demonstrate awareness of the facilities procedures for the implementation of this standard. Findings In Yes: No: X compliance: Objective There is no evidence of appointment of person having overall responsibilities and evidence: authorities in implementation of the Supply Chain requirements (Non- Conformance 01). Criterion D.1.2: The facility shall have documented procedures for receiving and processing certified and non-certified FFBs. Findings In Yes: No: compliance: Objective Sg. Jernih POM only received and process FFB from own estates which all are RSPO evidence: certified. Procedure for receiving and processing certified FFB has been described in the following procedures: - Reception Station - Fruit Handling - Sterilization Station - Threshing Station - Pressing Station - Depricarping Station - Nut Cracking and Kernel Station - Clarification Station

Module D.2: Purchasing and Goods In Criterion D.2.1: The facility shall verify and document the volumes of certified and non-certified FFBs received. Findings In Yes: X No: compliance: Objective The mill only received certified FFB from its own estates. ------SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

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evidence: The volumes of certified FFB received are recorded in “Daily Production Figure” record. Criterion D.2.2: The facility shall inform the CB immediately if there is a projected overproduction. Findings In Yes: X No: compliance: Objective As described in the SOP, the Mill shall inform SGS if there is a projected over evidence: production.

Module D.3: Record Keeping Criterion D.3.1: The facility shall maintain accurate, complete, up-to-date and accessible records and reports covering all aspects of these requirements. Findings In Yes: X No: compliance: Objective Sg. Jernih POM maintains accurate, complete, up-to-date and accessible records and evidence: reports covering all aspects of RSPO SC requirements Observed during the audit that the Mill maintains the followings records: - Daily Production Figure Weighbridge Ticket ( FFB and Palm Oil) Criterion D.3.2: Retention times for all records and reports shall be at least five (5) years. Findings In Yes: No: X compliance: Objective The SC procedure established by the Mill did not stated the retention times for all evidence: records and reports shall be at least five (5) years. ( Non-Conformance 02) Criterion D.3.3: The facility shall record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO, PKO and palm kernel meal on a three-monthly basis. Findings In Yes: X No: compliance: Objective The Mill received all certified palm oil from its own estate. All certified palm oils evidence: received are recorded in “Daily Production Figure” updated on daily basis. Criterion D.3.4: The following trade names should be used and specified in relevant documents (e.g. purchase and sales contracts, *product name*/SG or Segregated). The supply chain model used should be clearly indicated. Findings In Yes: X No: compliance: Objective No sales of certified RSPO SC products yet. evidence:

Module D.4: Sales and Good Out Criterion D.4.1: The facility shall ensure that all sales invoices issued for RSPO certified products delivered include the following information: a) The name and address of the buyer b) The date on which the invoice was issued c) A description of the product, including the applicable supply chain model (Segregated) d) The quantity of the products delivered

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e) Reference to related transport documentation Findings In Yes: No: X compliance: Objective The delivery procedure did not indicate list of information (e.g. RSPO certificate no. evidence: and supply chain model) to be stated in the RSPO products delivery document (invoices) as required by the standard. ( Non-Conformance 03)

Module D.5: Processing Criterion D.5.1: The facility shall assure and verify through clear procedures and record keeping that the RSPO certified palm oil is kept segregated from non-certified material including during transport and storage and be able to demonstrate that is has taken all reasonable measures to ensure that contamination is avoided. The objective is for 100% segregated material to be reached. The systems should guarantee the minimum standard of 95% segregated physical material; up to 5% contamination is allowed. Findings In Yes: No: X compliance: Objective To date, the Mill received all certified palm oil from its own estate. evidence: However, there is no procedure to ensure that the RSPO certified palm oil will be kept segregated from non certified material including during transport, storage and processing to ensure that contamination is avoided. (Non-Conformance 04) Criterion D.5.2: The facility shall provide documented proof that the RSPO certified palm oil can be traced back to only certified segregated material. Findings In Yes: X No: compliance: Objective RSPO certified palm oil can be trace back to only certified segregated material by evidence: using “Daily Production Figure” record and WB ticket issued by the estates for FFB delivered to the Mill. Criterion D.5.3: In cases where a mill outsource activities to an independent palm kernel crush, the crush still falls under the responsibility of the mill and does not need to separately certified. The mill has to ensure that: a) The crush operator conforms to these requirements for segregation b) The crush is covered through a signed and enforceable agreement Findings In Yes: X No: compliance: Objective The Mill does not outsource any activities to the subcontractor. evidence:

Module D.6: Training Criterion D.6.1: The facility shall provide the training for all the staff as required to implement the requirements of the Supply Chain Certification System. Findings In Yes: No: X compliance: Objective No training was provided to the related staff with regards to SC requirements ( Non- evidence: Conformance 05)

Module D.7: Claims

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Criterion D.7.1: The facility shall only make claims regarding the use of or support of RSPO certified palm oil that are in compliance with the RSPO Rules for Communication and Claims. Findings In Yes: X No: compliance: Objective No usage of RSPO trademark license yet. evidence: The procedure on usage of RSPO trademark is avaialbe. The Mill manager has been appointed as the personnel responsible to manage and control the use of trademark license.

ISSUANCE OF NON-COMPLIANCE During the 01 surveillance, 3 Minor CARs and 6 observations were issued as a result of the assessment. The non-conformances are as tabulated under section 12 of this report. For the RSPO Supply Chain, 05 ‘Majors’ or non-conformities were issued. Corrective Actions were submitted within the stipulated time frame to SGS and reviewed. The 5 Major nonconformities were subsequently closed. Boustead Rimba Nilai Sdn Bhd has prepared some Corrective Action Plan for closing of some of the Minor CAR and observations. SGS has reviewed and have noted them in the Report as ‘closed out evidences..

7. ASSESSMENT DECISION With no outstanding Major CAR, the Boustead Plantation Bhd’s management of Sg Jernih Palm Oil Mill and its supply base estates in Pahang and Terengganu, Peninsular Malaysia, is recommended for the continued certification against the RSPO P&C MYNI 2010. The issues highlighted as Minor CARs must be adequately addressed and the adequacy of the actions taken will be verified during the second surveillance visit to be conducted within 12 months from the date of assessment.

8. ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY AND FORMAL SIGN-OFF OF ASSESSMENT FINDINGS It is acknowledged that the assessments cited in this report have been carried out as stipulated and we confirm the acceptance of the assessment report contents including assessment findings.

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APPENDIX A: CORRECTIVE ACTION REQUEST & OBSERVATION

PRINCIPLES & CRITERIA

08 5.3.2 Date 08/08/12 Due 2nd surveillance Date Recorded> Date Closed Non-Conformance: Although the Unit has identified wastes and pollutants, an operational plan developed to avoid or reduce pollution implementation seemed lacking.

Objective Evidence:  LTT-T estate has segregated the recyclable materials like plastic , tins etc , however it is accumulating and piling up at the linesite as they report that there are no interested collector.  A chemical supplier Indah Agro Sdn Bhd collects the chemical containers for Mido Resources ( CA 017619-W) an approved chemical container collector . It was informed that Mido Resources will deliver the containers to an approved disposal company in Johor.  On the 7th August a collection was made for 18 x 20 lit and 150 kg of plastic containers from LTT-T estate.  For Scheduled Waste, a collection was done by Hiap Huat chemical Sdn Bhd for SW305 for the quantity 28 x 20 lit ( for LTT-T estate) .  For Sg Jernih estate , an approved waste oil collector : QLD Trading Sdn Bhd collected 600 m3 on 29/6/12 to be disposed off at Kualiti Kitar Alam Sdn Bhd. In spite of the above , the following were found to be wanting :  complete and correct use of spill kit is lacking at : a) workshop ( Sg Jernih estate ) b) chemical store ( LTT-T estate ) c) contaminated or used sawdust need to be disposed off in proper manner ( LTT –T estate)  In all estate , reuse of chemical container for a) storage of lubricant oil ( LTT-T & Bebar estate) b) petrol ( LTT –T staff quarter ) , c) FFB loader Rudin was using a loose fruit scraper made from chemical container ( Sg Jernih estate) d) contractor store ( Bebar )  In Sg Jernih, a container of used oil was found disposed at the scrap iron site.  Minor 08 Raised Close-out evidence: On 16/10/12 , Bebar Estate submitted evidence that they have replaced Chemical container used as petrol /diesel by both workers and contractor with appropriate containers. Instruction has also been given to contractors not to use unmarked chemical containers for their fuel or lubricants.

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09 5.5.3 Date Recorded 09/08/12 Due 2nd surveillance Date Date Closed Non-Conformance: Although Sg Jernih Production Unit do not allow burning of waste (including domestic waste , this was found to be flouted at one site. Objective Evidence: At one of the worker’s home in LTT-T estate linesite , there was evidence that burning of of domestic waste like used safety boots and plastics material waste Minor 09 Raised Close-out evidence:

10 6.4.2 Date Recorded 09/08/12 Due 2nd surveillance Date Date Closed Non-Conformance: A procedure for calculating and distributing fair compensation (monetary or otherwise) is not established and implemented

Objective Evidence: . Objective evidence:  Although Bebar Estate has establish procedure for identifying legal and customary righ it has not established procedure for calculating and distributing fair compensation. Minor 10 Raised Close-out evidence:

MODULE D: CPO MILLS: SEGREGATION

CAR Indicator CAR Detail # M001 D1.1 Date 07 Aug Due dd mm yy Date Closed> 07 Oct 2012 Recorded> 2012 Date> Non-Conformance: No evidence of appointment of a person having overall responsibility and authority over the implementation of SC requirements.

Objective Evidence: Appointment letter of the personnel to having overall responsibility and authority over the implementation of SC requirements is not available. Close-out evidence: The Mill Manager has been appointed as the personnel having overall responsibilities in implementing the SC system. An appointment letter dated 28 Sept 2012 was send to SGS (M) on 01 Oct 2013.

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CAR Indicator CAR Detail # M002 D3.2 Date 07 Aug Due dd mm yy Date Closed> 07 Oct 2012 Recorded> 2012 Date> Non-Conformance: The SC procedure established by the Mill did not stated the retention times for all records and reports shall be at least five (5) years. Objective Evidence: The SC procedure Close-out evidence: The Mill has revised its SOP document (Quality Management System) on Sept 2012 to include the procedure on 05 years retention times on record keeping. The procedure was send to SGS (M) on 01 Oct 2013. M003 D4.1 Date 07 Aug Due dd mm yy Date Closed> 07 Oct 2012 Recorded> 2012 Date> Non-Conformance: The delivery procedure did not describe list of information (e.g. RSPO certificate no. and supply chain model) to be stated in the RSPO products delivery document (invoices) as required by the standard. Objective Evidence: The delivery procedure in the SOP document Close-out evidence: The Mill has indicated the information of its RSPO certificate no. and supply chain model in the template of invoice. The template of invoice was send to SGS on 01 Oct 2013. M004 D5.1 Date 07 Aug Due dd mm yy Date Closed> 07 Oct 2012 Recorded> 2012 Date> Non-Conformance: There is no procedure to ensure that the RSPO certified palm oil will be kept segregated from non certified material including during transport, storage and processing to ensure that contamination is avoided

Objective Evidence: The SOP document Close-out evidence: The Mill has revised its procedure to include the records to be maintained in ensuring the RSPO certified palm oil being kept segregated from non certified material during receiving, transportation and processing. List of records are as below: 1) Mass Balancing Record of Oil Mill 2) List of Certified Suppliers The above record has been submitted to SGS on 01 Oct 2013.

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CAR Indicator CAR Detail # M005 D6.1 Date 07 Aug Due dd mm yy Date Closed> 07 Oct 2012 Recorded> 2012 Date> Non-Conformance: No training was provided to the related staff with regards to SC requirements

Objective Evidence: Training records Close-out evidence: Training has been conducted to the key personnel at the mill involved in implementing the SC system. Training procedure and records has been submitted to SGS on 01 Oct 2012.

OBSERVATION

OBS # Indicat Observations Detail or 01 4.4.1 Date Recorded 09/08/12 Due Date - Date Closed> Non-Conformance: There was no protection of water courses and wetlands, including maintaining and restoring appropriate riparian buffer zones at or before replanting along all natural waterways within the estate.

Objective Evidence:  Isolated oversprayed areas were found within the riparian buffer zone visited.  In Sg Jernih : A few palms on the riparian along river at 08E although marked were sprayed  Bebar estate : Some palms within the riparian along the main drain PR 10 & PR 11 were sprayed. Observation 01 Close-out evidence: On 16/10/12, Bebar Estate submitted evidence to show that ‘ No spraying and fertilizing ‘ signboard at the buffer zone and placed wooden pole along riparian along the main drain PR 10 and PR 11 to mark and inform workers to avoid spraying and fertilizing along the watercourse.

02 4.4.7 Date Recorded 09/08/12 Due Date Date Closed Non-Conformance: Water management plan not implemented Objective Evidence:

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Although the Unit is committed to a Water Management Plan yet water wastage was evident at the linesite.  LTT-T Water leaking at linesite piping Observation 02 Close-out evidence: Oil traps at workshops in all the estates were visited and were found to be adequate as oil is not evident in the last section of the traps 03 4.6.3 Date Recorded 09/08/12 Due Date Date Closed Non-Conformance: It was found that Pesticides were not stored in accordance to the Occupational Safety and Health Act 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations

Objective Evidence:  Emergency phone numbers were not found posted at the chemical store in both Bebar Estate and LTT-T  An empty 20 litre drum of Supersate was found in the waste store in Ladang Sg Jernih  2 Bottles of herbicide Starane were found together with lubricating oil storage compartment of the P&D tractor in Bebar Estate and in LTT-T estate at least 2 old bottles of pesticide Nurelle ( the other 2 bottles do not have label ) were found in the garden ground of one of the estate staff. Observation 03 Close-out evidence: On 16/10/2012, Bebar Estate submitted pictorial evidence to show emergency numbers posted on the Chemical store Secondly , they have informed all spraying mandore and tractor driver to store all unused chemicals back in the chemical store and not place on the tractor.

OBS # Indicat Observations Detail or 04 4.6.4 Date Recorded 09/08/12 Due Date - Date Closed> Non-Conformance: Some of the information regarding the chemicals and its usage, hazards, trade and generic names were not available

Objective Evidence:  Although in Bebar Estate, information on the chemicals are available in the local language however,  In Sg Jernih Estate MSDS for pesticide Kilsect and Nativo and for LTT-T MSDS for Garlon respectively were found to be missing Observation 04 Close-out evidence:

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05 4.6.3 Date Recorded 09/08/12 Due Date Date Closed Non-Conformance: Incomplete evidence of documented Occupational Safety Health (OSH) plan which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967(Act 139).

Objective Evidence:  Mandores Mislan ( Bebar Estate ) , Decreeping Legume Mandore Ros and the Harvesting Mandore at LTT-T Estate all had their first aid kits. However the following was found to be lacking:  The first aid kit at the chemical store ( Bebar Estate ) and at the fertilizer store ( LTT-T Estate ) was not replenished  During audit , the Store Staff ( LTT-Testate ) entered the chemical store were not wearing proper PPE ( slippers and without mask )

Observation 05 Close-out evidence: On the 16/10/12, evidence was submitted by Bebar Estate to show the first aid kit replenished as well as emergency contact number has been posted on the store.

06 6.1.3 Date Recorded 09/08/12 Due Date Date Closed Non-Conformance: A timetable with responsibilities for mitigation and monitoring is reviewed and updated as necessary was not practised in all the sites.

Objective Evidence:  Although it was found that the mill has maintain a time table for monitoring based on stake holder meeting output and SEIA report.,however, in LTT-T, the estate has not establish a timetable with responsibilities for mitigation and monitoring social impacts that are identified during assessment. Observation 06 Close-out evidence:

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APPENDIX B: NON-CONFORMITIES PREVIOUSLY IDENTIFIED

CAR Indicator CAR Detail # 04 4.1.2 Date 24/03/2011 Due 1st surveillance Date 07/08/2012 Recorded Date Closed Non-Conformance: There was no system and records on monitoring of effectiveness of SOPs at the mill and estates. Objective Evidence: No system for monitoring and improvement on SOPs. Close-out evidence: Estates and mill has reviewed its management SOP on 02 May 2012.

05 4.6.3 Date 24/03/2011 Due 1st surveillance Date 07/08/2012 Recorded Date Closed Non-Conformance: Inconsistent inventory and implementation of triple rinsing and perforation of chemical containers prior to disposal. Objective Evidence: Storage for scheduled waste are available but require improvement in documentation (inventory) and triple rinsing procedures are not consistently implemented.

Close-out evidence: a) The Unit has documented the implementation of triple rinsing procedure : Prosedur 3 kali pembilasan bekas simpanan ( triple rinsing ) b) They have kept records of the chemical containers as well as records of disposal by the approved collector, Mido Resources 07 5.3.2 Date 24/03/2011 Due 1st surveillance Date 07/08/2012 Recorded Date Closed Non-Conformance: Domestic waste are disposed at land fills but not properly segregated Objective Evidence: Organic and inorganic waste from the line sites, office and garden refused are dumped together in the land fill despite availability of programme and facilities for segregation and recycling. Close-out evidence: Recyclable waste now segregated from organic waste both at linesite as well as at the landfill. At LTT-T linesite , recyclable material like plastic, PET bottles , tins etc are now stored at the recyclable site awaiting approved collector

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