INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

MSPO INITIAL CERTIFICATION SUMMARY REPORT

Standard: MS2530-3:2013 (Part 3) General Principles for Oil Palm Plantations and Organized Smallholders

Type of Certification: Group Certification

Organization: East West One Consortium Berhad [661215-V]

Main Office Address: Suite 1-9-E2, 9th Floor, CPS Tower, Centre Point , 88000, , Sabah

Phone/Fax No: Tel: +6088 268 889 Fax: +6088 310 009

Plantation Site Address: Rugading Estate, Kg Rugading, P.O Box 1168, 89307, , Sabah

Project No: BQAS/EWOC/015/11/19 November, 2019

Certification Body: BQAS Certification (M) Sdn Bhd (11179994-x) Sublot 6, 2nd Floor, Block A, Kings’ Center, Simpang Tiga, 93350, Kuching, Sarawak.

Accreditation No: [MSPO 06092019 CB 0015]

Tel: +6 082 572 043 Mobile: +6 017 814 1112 Email: [email protected] Website: www.bqas.com.my

Documented by: Wilfred S Landong Lead Auditor

Certifier: Maxwell S Landong Date: 25 November, 2019 Validity: Certificate issued on: Date: 1st December, 2019 From 01 12 2019 to 30 12 2024 Disclaimer: This Report (inclusive of enclosures & attachments) had been prepared for the exclusive use and benefits of the addressee(s) and solely for the purpose for which it was intended. Unless BQAS provide prior written consent, no part of this report should be reproduced, distributed or communicated to any third party. BQAS would not accept liability if this report is used for an alternative purpose from which it was intended, nor would we owe any duty of care to any third party in respect of this Report.

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

TABLE OF CONTENTS

NO DESCRIPTION PAGES

EXECUTIVE SUMMARY 3-5

1. INTRODUCTION

1.1 Information: Certification Assessment 6

1.2 Information: Certified Entity 6-7

2. THE AUDIT TEAM 8-9

3. AUDIT METHODOLOGY 9-10

4. AUDIT PLAN 10-12

5. AUDIT PROCESS 12-13

6. STAGE 1 AUDIT

6.0 Stage 1 Audit Report 14-31

6.1 Summary of Findings/Action Taken/Closure 32

7. STAGE 2 AUDIT – MAIN ASSESSMENT

7.1 Basic Information 32-33

7.2 Stage 2: Main Assessment Report 33-59

7.3 Summary of Findings 60-62

7.4 Lead Auditor Remarks 62

7.5 Corrective Action Reports [CAR] / Closures 63-69

8. AUDIT CONCLUSION & RECOMMENDATION 70

9. ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY & 70 CONFIRMATION OF AUDIT FINDINGS

10. CERTIFICATION RECOMMENDATIONS [CERTIFIER] 70

ST 11. DATE OF 1 YEAR SURVEILLANCE AUDIT 70

ATTACHMENTS:

MAPS: [GOOGLE MAP; LOCALITY; NATURAL VEGETATION; TOPOGRAPHY] 71

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

EXECUTIVE SUMMARY

This is an Initial Certification Audit & scope is Group Certification of East West One Consortium Berhad [EWOC] under the Standards MSPO MS2530-3:2013 for Oil Palm Plantations & Organized Smallholders

[EWOC] belong to East West One Group a conglomerate principally involved in the oil palm plantation industry. Business commenced in 2006 and the group continues to acquire and develop land suitable for oil palm cultivation in Sabah, .

East West One Group is known for being the first group in Malaysia to operate and manage two Companies Commission of Malaysia-approved Planter’s Schemes. Both Planters’ Schemes are approved under the Interest Schemes Act 2016 and are closely monitored by Companies Commission of Malaysia in particular the progress of the group’s plantation development and operation to safeguard investors’ interests.

[EWOC] headquarters office is located at Suite 1-9-E8, 9th Floor, CPS Tower Centre Point Sabah, 88000, Kota Kinabalu Sabah. The site management center for [EWOC] group of estates is located at Rugading Estate, Kg Rugading, Ranau, Sabah

East West One Consortium Berhad comprised of 10 Estates known as RANAU REGION. The areas are located in clusters [some contiguous] in the districts of Ranau, Pantai Barat Residency some 160km away from Kota Kinabalu. All the parcels of lands are linked and accessible through the Keningau/ Highway. Pertinent information as below:

No Name of Estate Certified Planted No of Palm Age Range FFB Production [MT] Area [HA] Area [HA] trees [average] Actual 2018 Estimate 2019 1. Rugading 376.87 273.7 33818 5.3 2497.54 4619 2. Kebu Baru 557.9 254.38 31938 3.5 476.58 1900 3. Matupang 359.3 147.71 17725 3.9 234.55 1438 4. Kituntul 589.3 190.9 22908 3.8 153.57 1901 5. Kodop 1208.7 469.28 56314 2.8 N/A N/A 6. Manikulau 1459.5 611.78 77404 5.5 4362.21 9814 7. Sumbilingon 186.3 153.13 18538 5.5 964.73 2407 8. Kawiyan 893.9 263.04 31563 4.6 771.64 3401 9. Paka 626.6 187.86 20622 3.7 85.22 1570 10. Nasakot 176.9 134.98 16197 2.4 N/A N/A 6435.27 2686.76 327027 9546.04 27050

For the Initial Certification, the following 3 estates were assessed and formed the sample frame:

Name of Estate Location: Geo – Coordinates

RUGADING  116°42'15.21"E 5°53'39.738"N

KEBU BARU  116°44'19.037"E 5°52'50.639"N KITUNTUL  116°43'4.005"E 5°55'14.556"N

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Topography & Soils

The estate land consists of about 20% of flat river alluvium beds, 50% of undulating hills and some 30% of quite hilly undulating hills. Vegetation are mainly bush (Belukar) on all the areas which will require little land clearing. The river alluvium beds are considered to be good oil palm planting soils. The hilly areas are derived from sandstone, shale and mudstone. The hilly soils consist of Dalit, Crocker and Bidu Bidu Associations. Dalit soils are usually of moderate hills and minor valleys floors and are considered fairly suitable for oil palm cultivation. The characteristic of Bidu Bidu, Dalit & Crocker Association in the landscape is the typically low rolling hills country. With adequate terracing, oil palm can be successfully established in this soil. The Labau associations are mostly narrow floodplains which also suitable for agricultural crops including oil palm.

Oil palm cultivation

Oil palm cultivation in this region in fact is already one of the major agriculture activities. A few well managed holdings had reported reasonable yields and oil palm fruits from are famed for the very high oil extraction rates at over 24% as compared to other parts of Malaysia.

Staff & Workers & Welfare

[EWOC] estate staff & management are majority local from the local communities; general workers mixed from local communities & Tenaga Kerja [TKI]. Local communities [with the appropriate skills & ability] are given preferential privilege to work in the estates. Workers & staffs are remunerated well above minimum wage; and living conditions in the Estate meet minimum requirements of health & safety regulations. Available amenities in both estates include treated water, domestic waste collection & disposal, electricity [diesel powered generator] and telecommunication services.

Assessments

The assessment method used follows principles of 3P (Paper, Practice & People).

This certification assessment is a sampling process where management systems effectiveness & efficiency are confirmed via an Audit Trail that the Auditor established to make an accurate conclusion. Information & data were systematically gathered & documented from interviews [with a cross section random sample of stakeholders], observations of process and activities, field audits & review of documentations and records.

Assessments were done at both the EWOC Site Management Center @Rugading Estate Office @ Ranau for documentation assessment; and Site assessments [facilities, amenities, harvesting activities, signages, markers, boundaries etc.] for all 5 estates were done in-situ during both Stage 1 & Stage 2 Audits.

2 Auditors were assigned to do the MSPO Certification Assessments. Stage 1 was done with 6 man-days & Stage 2 was done in 8 man-days; clocking a total of 14 Mandays to complete the Audits.

Stage 1 Audit was conducted from 18th to 20th July 2019 & Stage 2 on 23 to 26th September 2019 respectively.

There were 8 Findings in Stage 1 Audit classified as AWF (acceptable with findings noted); in areas of management system readiness, policy/policies documentation, legal register, procedures documentation, HIRARC, water management plan, non-renewable energy estimation, list of stakeholders & business management plan

The corrective action report (CAR) raised for these findings were closed out on 29 08 2019.

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

In Stage 2 Audit 5 OFI (opportunity for improvements) were recorded; in areas of Management Commitment & Responsibility, Social Responsibility, Health, Safety and Employment Conditions, Environment, Natural Resources, Biodiversity and Ecosystem Services & training and competency

The corrective action report (CAR) for these findings were closed out on 25 10 2019.

In both Audit Stages, dialogues and interviews were conducted with stakeholders [workers, local communities, landowners & other land users] to gauge understanding of MSPO principles, applications & its importance and relevance to sustainable growth and production of palm oil products.

Also assessed were their opinion & working relationship with EWOC Management and this was found to be mutually beneficial. Local communities were also allowed free access and use of roads within all the plantation

Land & Land use:

All EWOC estates operate on a Joint Venture Development agreement with local communities who owned the communal land. The local community in the joint venture is usually the Headman of the community and therefore validate the integrity of the agreement.

It is verified that all Agreements in respect of land use are legally binding and enforceable in law by both parties.

EWOC MSPO commitment & staffs

It is observed that EHPB is fully committed to obtain Certification under MSPO MS2530-3:2013. At corporate level 2 senior staffs are dedicated to manage the certification project; and the Sustainability Manager is a trained MSPO Auditor.

At estate management level, staffs are adequately trained and conversant with MSPO principles and requirements.

The Audit team has conducted a rigorous assessment of EHPB and it is evidenced that it has complied & conformed to MSPO2530-3:2013 Certification standards, conditions & requirements.

Conclusively, the Lead Auditor therefore, recommended that upon conclusion and closure of [OFI] of Stage 2 Audit East West Horizon Plantation Berhad be certified under MSPO Standards MS2530-3:2013.

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

1. INTRODUCTION

EAST West One Consortium Berhad [established in 2006] is a company based and headquartered in Kota Kinabalu, Sabah. EWOC comprised of 18 Estates known as RANAU REGION. The areas are located in clusters [some contiguous] in the districts of Ranau, Pantai Barat Residency some 140km away from Kota Kinabalu. All the parcels of lands are linked and accessible through the Keningau/Pensiangan Highway.

This report presents the assessments, findings & recommendations on certification evaluation of Syarikat Ilam which is seeking certification under MSPO MS2530-3:2013.

This is an Initial Certification Audit to assess the entity’s preparedness, compliance & conformance to MSPO Standards MS2530-3:2013 (Part 3: Requirements for Oil Palm Plantations & Organized Smallholders)

1.1. INFORMATION: CERTIFICATION ASSESSMENT

Type of Assessment: Initial Certification Audit

Scope of MSPO Certification: Palm Oil Plantation Certified Area:

MSPO Standard: MS2530-3:2013

1.2. INFORMATION: CERTIFIED ENTITY

The following are detailed information on EWOC estates assessed in the Initial Certification Audit. 1. RUGADING ESTATE Company Name: EAST WEST ONE CONSORTIUM BERHAD Registration No: 661215 - V Address: Suit 1-9-E2, 9th floor, CPS tower, Centre Point Sabah, 88000 Kota Kinabalu Sabah Site Name: Estate Rugading Address: Kg Rugading Ranau Sabah Management Contact details: Tel No: 088-268 899 / 016 810 5353 Fax: 088-310 009 Name Job Title Mobile Telephone Email Abdul Wahid ALi Estate Manager 011-1666 9979 Abdusaly B. Hassan Sr. Assistant Manager 011-2521 7706 No of Employees Local: 15 Foreign: 55 Total:70 MPOB License No: 586328002000 Expiry Date:30 Jun 2020 Scope of Activity: Oil Palm Plantation Date of Establishment: 2012 Geo-Coordinates: 116°42'15.21"E 5°53'39.738"N Certified Area: 376.87 Planted Area 273.70 FFB Production (actual) 2018 5,777.07 Mt FFB Production (estimate) 2019 4619 Sources of FFB: Estate Main FFB purchaser: Green Global Plantation Sdn Bhd No of Planting Blocks 13 No of Palm trees 33820 Palm Species DXP AAR, DXP FELDA, Age Range of Palm Trees 5-6 years Topography Hilly Area Soil Type: Bidu-bidu and Crocker association Land Status: Ownership ☐ Own Land ☐ Rented ☒ Joint Venture Other Sustainability Certification: Nil

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

2. KEBU BARU ESTATE Company Name: EAST WEST ONE CONSORTIUM BERHAD Registration No: 661215 - V Address: Suit 1-9-E2, 9th floor, CPS tower, Centre Point Sabah, 88000 Kota Kinabalu Sabah Site Name: Estate Kebu Baru Address: Kg Kebu Baru Ranau Sabah Management Contact details: Tel No: 088-268 899 / 016 810 5353 Fax: 088-310 009 Name Job Title Mobile Telephone Email Abdul Wahid Ali Estate Manager 011-1666 9979 Abdusaly B. Hassan Sr. Assistant Manager 011-2521 7706 No of Employees Local: 11 Foreign: 26 Total: 37 MPOB License No: 586328002000 Expiry Date:30 Jun 2020 Scope of Activity: Oil Palm Plantation Date of Establishment: 2013 Geo-Coordinates: 116°44'19.037"E 5°52'50.639"N Certified Area: 557.93 Planted Area 254.38 FFB Production (actual) 2018 476.58 Mt FFB Production (estimate) 2019 1900 Sources of FFB: own Estate Main FFB purchaser: Green Global Plantation Sdn Bhd No of Planting Blocks 12 No of Palm trees 31,939 Palm Species DXP AAR Age Range of Palm Trees 4-5 years Topography Hilly Area Soil Type: Bidu-bidu and Crocker association Land Status: Ownership ☐ Own Land ☐ Rented ☒ Joint Venture Other Sustainability Certification: Nil 3. KITUNTUL ESTATE Company Name: EAST WEST ONE CONSORTIUM BERHAD Registration No: 661215 - V Address: Suit 1-9-E2, 9th floor, CPS tower, Centre Point Sabah, 88000 Kota Kinabalu Sabah Site Name: Estate Kituntul Address: Kg Kituntul Ranau Sabah Management Contact details: Tel No: 088-268 899 / 016 810 5353 Fax: 088-310 009 Name Job Title Mobile Telephone Email Abdul Wahid Ali Estate Manager 011-1666 9979 Abdusaly B. Hassan Sr. Assistant Manager 011-2521 7706 No of Employees Local: Foreign: 39 Total: 39 MPOB License No: 586328002000 Expiry Date:30 Jun 2020 Scope of Activity: Oil Palm Plantation Other Sustainability Certification: Nil Date of Establishment 2014 Geo-Coordinates: 116°43'4.005"E 5°55'14.556"N Certified Area: 589.28 Planted Area 190.90 FFB Production (actual) 2018 153.57 FFB Production (estimate) 2019 1,901 Sources of FFB: own Estate Main FFB purchaser: Green Global Plantation Sdn Bhd No of Planting Blocks 11 No of Palm trees 18,154 Palm Species DXP FELDA, DXP IJM Age Range of Palm Trees 4-5 Years Topography Hilly Area Soil Type: Bidu-bidu & Mentapok Association Land Status: Ownership ☐ Own Land ☐ Rented ☒ Joint Venture

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

2. THE AUDIT TEAM

Audit Stage Name: Role

Stage 1 Wilfred S Landong Lead Auditor Robert Tella Auditor

Stage 2 Wilfred S Landong Lead Auditor Robert Tella Auditor

A. Wilfred S Landong Lead Auditor

Qualifications:

 Advanced Dip in Business & Management, UK  Degree in Marketing, UK  Masters in Marketing, UK  Successfully completed MSPO Lead Auditor Course (Pioneer Group) 0n 30th January, 2015

Working Career & Experience:

Year ended Employer Highest Job

1980 Cigarette Importers & Distributor Area Executive

1990 Sebor Sarawak Sdn Bhd Divisional Manager

1997 Gillette (M) Sdn Bhd Country Manager

1999 Zuelling (M) Sdn Bhd Sales & Marketing Director

2002 TimeDotCom. Bhd Vice President

2012 Sarawak Forestry Corporation Sdn Bhd General Manager

Present BQAS Certification (M) Sdn Bhd Managing Director

Relevant MSPO Related Credentials:

Sarawak Forestry Corporation SB  Pioneer GM of Sarawak Forestry Corporation SB (SFC), a wholly owned Company of Sarawak Government; responsible for formulating and implementing the Company’s organization structure, policies, regulations, procedures etc. Custodian of accreditation & certification related to management of Protected areas & Biodiversity conservation.  During tenure of office, Certification achieved included ISO9001 (2004), ISO14001(2004), OHSAS1800 (2007)  Intimate knowledge of sustainable forestry management and regulatory requirements enhanced a clear perspective & understanding of how palm oil industry should be managed sustainably.  Highly conversant & knowledgeable on Sarawak Forests Ordinances, Wildlife Protection Ordinance, Land Code, Native/NCR land laws; easily can relate and apply to governance and implementation of MSPO Principles & guidelines.

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

BQAS Certification (M) SB  As MD of BQAS responsible for the formulation & implementation of Quality Manual, Policies & Procedures as required for Accreditation as Certified Body by Department of Standards Malaysia (DSM) under ISO/IEC 17021-1.  Top management accountability & responsibility to ensure BQAS conformance & compliance on operations, implementation & administration of MSPO MS2530:2013 as required by the owner of the Standard (MPOCC).

B. Robert Tella Gunjom Auditor

Qualifications

 Senior Cambridge Certificate  Completed Train the Trainer Course by HRDF in August 2018  Completed MSPO Auditor Course in September 2018

Working Career & Experience:

 Join Royal Malaysian Navy (RMN) in 1981  Retired from RMN in 2007 with the rank of Lieutenant Commander

Relevant MSPO Related Credentials:

Undergone training and practiced in the following  Total Quality Management (TQM)  Integrated Logistics Support (ILS)  Had clocked more than 40 man-days in MSPO Certification Audit

3. AUDIT METHODOLOGY

This certification assessment is a SAMPLING process where management systems effectiveness & efficiency are confirmed via an audit trail that the Auditor established to make an accurate conclusion.

Information gathering  Interviews Data collection  Observation of process & activities  Review of documentations & records  Site visits  Field inspections

Assessment method Paper  Assessing past implementations from records, reports of the management system Practice  Assessing current implementation from observing current practices People  Assessing future maintenance from interviewing personnel on understanding & assessing competencies

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Stage 1: Audit Findings Classification

Term Meaning / Description

Acceptable Fulfill requirement of audited standard

Acceptable with findings Demonstrate conformity. There are, however, improvement opportunity noted identified that will benefit the organization

Not acceptable Demonstrate absence or total breakdown of system to meet standard requirement

Stage 2: Audit Findings Classification

Term Meaning Description

YES Compliance Fulfill requirement of audited standard

OFI Opportunity for improvements Demonstrate conformity. There are, however, improvement opportunity identified that will benefit the organization

NO (minor NC) Minor non conformity Non-compliance to standard requirements or company’s SOP; or are issues that when combined, jeopardized the functioning of the system

NO (major NC) Major non conformity Demonstrate absence or total breakdown of system to meet standard requirement, or a number of minor NC against a clause of standard requirements / at a particular area. Of last assessment that are not effectively addressed will be classified as major NC.

4. AUDIT PLAN

AUDIT SITES:

For both Stage 1 & Stage 2 the Audit Team performed assessments at:  EHPB site management center @Jadi Estate [documentations]  Plantation sites office/Field Audits of all 5 sample estates

STAGE 1 AUDIT PROGRAM:

Date 18 – 20 07 2019 No of Auditors 2 No of Mandays 6

Day 1 Opening Meeting @EWOC site management center @ Rugading Estate Field / sites Audit at Rugading Estate & Kebu Baru Estate

Day 2 Documentation Audit @ EWOC site management center @ Rugading Estate

Day 3  Documentation Audit @ EWOC site management center @ Rugading Estate  Stakeholders Consultation & interviews  Closing Meeting & Stage 1 Audit Report presentation

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Audit Parameters:

 Basic information about the entity  Management system: scope & documentation  Evaluation of location/site specific conditions  Review understanding regarding requirements of the MSPO Standards (key performance, processes, objectives)  Related statutory & regulatory aspects & compliance  Land status/legality  MSPO policies, procedures  Management Manual  Management Plan  Resources management (water/non-renewable energy use)  Determine preparedness for Stage 2 Audit  Fertilizers/Chemical/Schedule waste stores  Estate Office & Workers Quarters, Signages  Boundary Markers, Geo-coordinates, Buffer Zone, Riparian Reserves  Stakeholders interviews

STAGE 2 AUDIT PROGRAM:

rd Date 23 – 26 September, 2019 No of Auditors 2 No of Mandays 8

Day 1  Opening Meeting @EWOC site management center @ Rugading Estate  Field / sites Audit at Rugading Estate

Day 2  Field / sites Audit at Kebu Baru Estate & Kituntul Estate

Day 3 Documentation Audit @EWOC site management center @Rugading Estate

Day 4  Documentation Audit @ EWOC site management center @ Rugading Estate  Stakeholders Consultation & interviews  Closing Meeting & Stage 2 Audit Report presentation

Audit Parameters:

 Evaluate implementation, including effectiveness of the management system  Information & evidence about conformity to all requirements  Performance monitoring, measuring, reporting  Reviewing against key performance objectives & targets  Performance as regards legal compliance  Operational control of the client’s process  Internal auditing & Management review  Management responsibilities for policies  Links between the normative requirements, policy  Competence of personnel  Customer specific requirements  Harvesting / collection of loose fruits / logistics & traceability of FFB  Use of PPE / Safety & Health training program  Revisit other points/areas of buffer zone, Riparian reserves, boundaries  Implementation of Policies & procedures at all stores (fertilizer, chemical, schedule waste store)  Improvements to workers quarters – health & safety  Infrastructure / roads & drainage / natural water management

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

 Continuous improvement plan & implementation  Implementation of Best practices  Implementation of environmental management plan  Stakeholders & workers interview

5. AUDIT PROCESS

The Audit Process for Stage 1 Assessments was programmed and implemented as follows: Process Description / Activities No

1 Public Notification Written notice to inform public on MSPO Audit is posted at Plantation Office 1 month before Audit dates. Public notice as follows:  Stage 1: 14 June, 2019 ↓

2 Audit Plan Auditee received 2 weeks before Audit dates ↓

3 Audit Day 1 Venue: Site Management Center @Rugading Estate Opening Meeting Participants: Audit Team & Auditee Management Agenda: Audit Plan, Objectives, Assessment Method

Field / sites Audit at Rugading & Kebu Baru Estate  Checks & verifications on Boundary, Buffer Zone, Riparian Zone, Waste/scheduled waste management, Water management, Water courses, Staff/workers housing & amenities, Harvesting, Use of PPE, Stores, Workshop

4 Audit Day 2 Documentation Review Management Systems, Policies, Procedures, MSPO Principles 1 to 6 documents etc.

↓ 5 Audit Day 3  Documentation Review Management Systems, Policies, Procedures, MSPO Principles 1 to 6 documents etc.  Stakeholders Consultation & interviews  Closing meeting Participants: Audit Team & Auditee Management Agenda: Report Presentation / Checklists: review, discuss & decide corrective & forward action to be taken with Auditee

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

The Audit Process for Stage 2 Assessments was programmed as follows:

Process Description / Activities No

1 Public Notification Written notice to inform public on MSPO Audit is posted at Plantation Office 1 month before Audit dates. Public notice as follows:  Stage 2: 17 August, 2019 ↓

2 Audit Plan Auditee received 2 weeks before Audit dates ↓

3 Audit Day 1 Venue: Site Management Center @Jadi Estate Opening Meeting Participants: Audit Team & Auditee Management & staffs Agenda: Audit Plan, Objectives, Assessment Method Field / sites Audit at Rugading Estate  Checks & verifications on Boundary, Buffer Zone, Riparian Zone, Waste/scheduled waste management, Water management, Water courses, Staff/workers housing & amenities, Harvesting, Use of PPE, Stores, Workshop ↓

4 Audit Day 2 Field / sites Audit at Kebu Baru & Kituntul Estate  Checks & verifications on Boundary, Buffer Zone, Riparian Zone, Waste/scheduled waste management, Water management, Water courses, Staff/workers housing & amenities, Harvesting, Use of PPE, Stores, Workshop

4 Audit Day 3 Documentation Review  Management Systems, Policies, Procedures, MSPO Principles 1 to 6 documents etc.

5 Audit Day 4  Documentation Review [continuation of Day 3] Management Systems, Policies, Procedures, MSPO Principles 1 to 6 documents etc.  Stakeholders Consultation & interviews  Closing meeting Participants: Audit Team & Auditee Management & staffs Agenda: Report / Checklists: review, discuss & decide corrective & forward action to be taken with Auditee

 Presentation of Stage 2 Audit report

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

6. STAGE 1 AUDIT MSPO MS2530-3:2013

MSPO STAGE 1 AUDIT REPORT Ref No.: EWHP/AU/ST1/07/19

CERTIFICATION BODY

Name BQAS Certification Sdn Bhd Audit Dates: From 15th July To 17th July 2019 Audit Duration: 6 man-days Audit Team: Name Role Wilfred S Landong Lead Auditor Robert Tella Auditor

Standard(s): MS 2530-1 MS 2530-2 MS 2530-3 MS 2530-4 Other Standards and/or NIL Edition:

1. INFORMATION ABOUT THIS ORGANISATION

Organization East West One Consortium Berhad 1 Site or Remote Location Site Group Management 2 Facility covered under this Audit or another CB? This Audit 3 Primary Function of the Site Plantation/Organized Smallholders 4 Multiple Site Certification Total of 10 Estates of EWOC

CERTIFIED ENTITY 1. GROUP [HQ] Company Name: East West Horizon Plantation Berhad Registration No 940673-T Address: Suite 1-9-E2, 9th Floor, CPS Tower, Centre Point Sabah, 88000, Kota Kinabalu, Sabah Management Contact details: Name Job Title Mobile Email Terence Mark Director of Human Resource & 019 881 3693 [email protected] Operation Plantation Support Jeffery Andrew Assistant Manager, Human Resource 016 897 6668 [email protected]

2. SITE MANAGEMENT

1. RUGADING ESTATE Company Name: EAST WEST ONE CONSORTIUM BERHAD Registration No: 661215 - V Address: Suit 1-9-E2, 9th floor, CPS tower, Centre Point Sabah, 88000 Kota Kinabalu Sabah Site Name: Estate Rugading Address: Kg Rugading Ranau Sabah

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Management Contact details: Tel No: 088-268 899 / 016 810 5353 Fax: 088-310 009 Name Job Title Mobile Telephone Email Abdul Wahid ALi Estate Manager 011-1666 9979 Abdusaly B. Hassan Sr. Assistant Manager 011-2521 7706 No of Employees Local: 15 Foreign: 55 Total:70 MPOB License No: 586328002000 Expiry Date:30 Jun 2020 Scope of Activity: Oil Palm Plantation Date of Establishment: 2012 Geo-Coordinates: 116°42'15.21"E 5°53'39.738"N Certified Area: 376.87 Planted Area 273.70 FFB Production (actual) 2018 5,777.07 Mt FFB Production (estimate) 2019 4619 Sources of FFB: Estate Main FFB purchaser: Green Global Plantation Sdn Bhd No of Planting Blocks 13 No of Palm trees 33820 Palm Species DXP AAR, DXP FELDA, Age Range of Palm Trees 5-6 years Topography Hilly Area Soil Type: Bidu-bidu and Crocker association Land Status: Ownership ☐ Own Land ☐ Rented ☒ Joint Venture Other Sustainability Certification: Nil

2. KEBU BARU ESTATE Company Name: EAST WEST ONE CONSORTIUM BERHAD Registration No: 661215 – V Address: Suit 1-9-E2, 9th floor, CPS tower, Centre Point Sabah, 88000 Kota Kinabalu Sabah Site Name: Estate Kebu Baru Address: Kg Kebu Baru Ranau Sabah Management Contact details: Tel No: 088-268 899 / 016 810 5353 Fax: 088-310 009 Name Job Title Mobile Telephone Email Abdul Wahid Ali Estate Manager 011-1666 9979 Abdusaly B. Hassan Sr. Assistant Manager 011-2521 7706 No of Employees Local: 11 Foreign: 26 Total: 37 MPOB License No: 586328002000 Expiry Date:30 Jun 2020 Scope of Activity: Oil Palm Plantation Date of Establishment: 2013 Geo-Coordinates: 116°44'19.037"E 5°52'50.639"N Certified Area: 557.93 Planted Area 254.38 FFB Production (actual) 2018 476.58 Mt FFB Production (estimate) 2019 1900 Sources of FFB: own Estate Main FFB purchaser: Green Global Plantation Sdn Bhd No of Planting Blocks 12 No of Palm trees 31,939 Palm Species DXP AAR Age Range of Palm Trees 4-5 years Topography Hilly Area Soil Type: Bidu-bidu and Crocker association Land Status: Ownership ☐ Own Land ☐ Rented ☒ Joint Venture Other Sustainability Certification: Nil

Page 15 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

2.0 MANAGEMENT SYSTEM READINESS (GENERAL)

Was the review of the client’s Acceptable status and understanding Acceptable with findings noted regarding requirements of the Unacceptable – recommend audit (Stage 2) to be delayed standard/ specification, in particular with respect to the Comments/Justification/Evidence: identification of key EWOCB assigned 2 Senior management staff dedicated as dedicated resources on performance or significant MSPO certification implementation and corporate support. At Plantation level the aspects, processes, certification preparation and implementation is headed by the Estate Manager. objectives and operation of Discussion, interaction with plantation staffs found evidences of adequate level of the management system was understanding on and knowledge on MSPO requirements. found to be adequate? Training on MSPO conducted by MBOP 20 06 19 on Harvesting & Grading MSPO Training conducted by Consultant on 19 04 19 [attended by all Estate staff]

The Top-Level Management Acceptable System Manual detailing Acceptable with findings noted justification for exclusions, Unacceptable – recommend audit (Stage 2) to be delayed inclusion of or reference to documented procedures for Comments/Justification/Evidence: the management system, Management System Manual not available for viewing and verification during Stage and providing a description 1 Audit of the interaction between processes? List any manual discrepancies: 1. No response to BQAS required 2. Changes will be reviewed during Stage 2 audit

The policy is defined and Acceptable appropriate to the purpose of Acceptable with findings noted the organization? Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: MSPO Policy viewed and verified. Policy statement. [EWOG are committed to comply and implement all requirements and principles of MSPO. All operating units under EWOG shall adhere to the key principles of MSPO to which the management of shall provide leadership & commitment]. Signed by Dato’ Dr. Jessie Tang, Group CEO [05 08 19] Policy well defined and appropriate for the purpose of the organization.

Transparency is identified to Acceptable ensure management of Acceptable with findings noted stakeholders’ is met with Unacceptable – recommend audit (Stage 2) to be delayed MSPO requirement. Comments/Justification/Evidence: Transparency is identified vide doc EWOG/MSPO/SP/20182004 dated 01 08 2018. Ref Item 4 [of the document] 4.1. Stakeholders requests and communication  Dealing with requests  Privacy & confidentiality  Public availability

Transparency is identified in Acceptable complying with traceability Acceptable with findings noted system. Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: Transparency is identified with FFB evacuation process [ref doc EWOG/MSPO/SP/20183001dated 01 08 2018. Verification documents : check-roll book, FFB delivery notes, receiving slip

Process for identification of Acceptable legal and other requirements. Acceptable with findings noted

Page 16 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: EWHP established legal register/Regulatory Requirements is identified vide Regulatory Requirements doc ref [EWOG/MSPO/SP/20183001 dated 01 08 19 approved by Group CEO on 01 08 18

Process for internal and Acceptable external communication. Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: Consultation & Communication Procedure not available during Audit time. Could not determine process for internal and external communication being documented

The outputs from Acceptable management reviews are Acceptable with findings noted consistent with the Unacceptable – recommend audit (Stage 2) to be delayed commitment to continual Not applicable due to not required for group management of independant improvement. smallholder (refer to 2.1d for detail) Special case with valid reason agreed by Lead Auditor Comments/Justification/Evidence: MSPO certification preparation viewed and verified as follows:  Management Review at HQ [corporate] chaired by Group CEO held monthly since late 2018  Management Review at Estate management held monthly [chaired by Estate Manager] since late 2018 In compliance with requirements Internal audits planned and Acceptable performed? Records are Acceptable with findings noted available? Unacceptable – recommend audit (Stage 2) to be delayed Not applicable due to not required for group management of independant smallholder (refer to 2.1d for detail)

Comments/Justification/Evidence: Internal Audit on [MSPO Principles 1 – 6] held on 02 04 19. Planned, performed and records are available vide doc ref MSPO/IA/02042019/01. Confirmed & verfied compliance

Is a translator required? Yes No

2.1 SUPLEMENT FOR MS 2530-2, MS 2530-3 & MS 2530-4 Review the information listed below to determine readiness of the organization for the stage 2 audit. 2.1 A POLICIES MSPO Policy Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Comments/Justification/Evidence: Policy available sighted and acceptable. Policies are communicated and implemented by Posting on notice board and meetings with internal staff and all stakeholders. Photos, Minutes and agendas of meeting sighted. Policy No. EWOG/MSPO-P/20181001 Policy signed by: Group Chief Executive Officer Dato’ Dr. Jessie Tang [05 08 18]

Page 17 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Safety and Health Acceptable Policy Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Policy Statement available, sighted and acceptable. All available Policies are communicated and implemented by posting it on notice board and meetings with internal staff and all stakeholders. Photos, Minutes and agendas of meeting sighted. Policy No. EWOG/MSPO-P/20181004 Policy signed by: Group Chief Executive Officer Dato’ Dr. Jessie Tang [05 08 18]

Sexual Harrassment Acceptable Policy Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Policy available, sighted and acceptable. Policies are communicated and implemented by posting it on notice board and meetings with internal staff and all stakeholders. Photos, Minutes and agendas of meeting sighted. Policy No. EWOG/MSPO-P/20181006 Policy signed by: Group Chief Executive Officer Dato’ Dr. Jessie Tang [05 08 18]

Good Social Practice Acceptable Policy Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Policy available, sighted and acceptable. Policies are communicated and implemented by posting it on notice board and meetings with internal staff and all stakeholders. Photos, Minutes and agendas of meeting sighted. Policy No. EWOG/MSPO-P/20180805 Policy signed by: Group Chief Executive Officer Dato’ Dr. Jessie Tang [05 08 18]

Environmental Policy Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Policy available, sighted and acceptable. Policies are communicated and implemented by posting it on notice board and meetings with internal staff and all stakeholders. Photos, Minutes and agendas of meeting sighted. Policy No. EWOG/MSPO-P/20181003 Policy signed by: Group Chief Executive Officer Dato’ Dr. Jessie Tang [05 08 19]

Page 18 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

2.1 B PROCEDURES

Training Procedure Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder) Comments/Justification/Evidence: Document not available at time of audit.

Internal Audit Acceptable Procedure Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Document available and marked: EWOG/MSPO-SP/20182028 dated 01st August 2018. last Internal Audit done and document sighted and marked MSPO-14-IA-02042019-01 dated 05/04/2019.

Complaint and Acceptable grievance Procedure Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Document and complaint book available and marked: EWOG/MSPO-SP/20182017 dated 01st August 2018.

Communication Acceptable Procedure Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Document not available at time of audit.

Emergency and Acceptable Incident procedure Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Procedure available and marked: Chemical Spillage (store) EWOCB-ERP-01 dated 01.01.2019. Chemical Spillage (Field) EWOCB-ERP-02 dated 01.01.2019. Fire outbreak EWOCB-ERP-03 dated 01.01.2019. Tractor/Lorry driver EWOCB-ERP-04 dated 01.01.2019. Physical injury EWOCB-ERP-05 dated 01.01.2019.

Traceability SOP Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Document sighted and verified. Ref: EWOG/MSPO-T/20183001 dated 01/08/2018

Page 19 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Site Management Acceptable SOP Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder) Not Applicable for MS 2530-4 (palm oil mill) Note: in case of single site certification

Comments/Justification/Evidence: SOP on site management developed and practiced. All documents are sighted; evidence of implementation are practiced and adhered to by all plantation staff and workers.

Mill Management SOP Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder) Not Applicable for MS 2530-3 (plantationl) Note: in case of single site certification

Comments/Justification/Evidence: Not applicable

Chemical Handling Acceptable SOP Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Document available. Titled and marked: Chemical and pesticide storage, usage and disposal.

EWOG/MSPO-SP/20182023 dated 01st August 2018.

Scheduled Waste Acceptable Handling SOP Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder) Comments/Justification/Evidence: Schedule waste handling procedure available. Documented vide doc ref: 1. EWOCB-SWP-02 dated 01.05.2019 2. EWOG/MSPO-SP/20182023 dated 01.08.2019 3. 2.1 C DOCUMENTS

List of Stakeholder Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder) Comments/Justification/Evidence: List of Stakeholders sighted and verified. However detail listings are incomplete. .

Page 20 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Land ownership Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: Legal Assessment verfied and noted as below [sample]:  Title Head: Negeri Sabah  Declaration of Kampung Kebu Baru Native Grazing Reserve District of Ranau under Schedule X1 [Cap 68]: Section 78 [1] [2] & [3]  Kampung Kebu Baru, Ranau  Native Title: Lot Ukur 06200744: Bil Pelan 06127971  385ha land size Customary Right Acceptable document Acceptable with findings noted Not applicable to the occupied land Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: Legal Assessment verfied and noted as below [sample]:  Title Head: Negeri Sabah  Declaration of Kampung Kebu Baru Native Grazing Reserve District of Ranau under Schedule X1 [Cap 68]: Section 78 [1] [2] & [3]  Kampung Kebu Baru, Ranau  Native Title: Lot Ukur 06200744: Bil Pelan 06127971  385ha land size

Boundary mapping of Acceptable the land Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: Boundary mapping of land available and verified with official map. Verified all documentations in order

HIRARC Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: A complete HIRARC assessment on all operation available and verified vide doc ref: HIRARC/MW/2019/01 dated 15/1/2019.

Training Programme Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Training program and training matrix developed and available. Evidence of training implementation in photos and attendance list available and sighted. Effectiveness of training as displayed by staff and workers during site inspection and documentation audit. Evidence of training and attendance list found in file marked “TRAINING RECORDS”

Page 21 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Environmental Policy Acceptable and Management Acceptable with findings noted Plan Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Environment Policy and Management plan available and verified. Doc ref:  Environmental Management Plan EWOG/MSPO-SP/20192036 dated 01.01.2019

Non-renewable Acceptable energy estimation Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Documentation of non-renewable energy estimation incomplete

Waste Identification Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: Documentation of waste identification incomplete

Business Management Acceptable Plan Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: BMP document not available for viewing and verification during Audit

Product Pricing Acceptable Mechanism Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Noted and verified product pricing mechanism doc ref EWOCB/P6/2019 dated 01 01 19

Contractor Acceptable Agreement Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Sample contractor agreement dated 01 05 19 Tansi Tanjeng [contractor] & East West One Plantation [Estate Manager] Contract No EWCOB/YA/2019/01. Agreement in dual language. Legally enforceable. Piece rates payment.

Page 22 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Soil and Topographic Acceptable Information Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Soil & topographic information comprehensively documented in the SEIA Report  Soil:Dominant prent materials of the soil in the Ranau Region estates comprise sandstone, mudstone; igneous rocks in Rugading; alluvial soil in Kawiyan & Paka Estate  Topography – hilly landform with slopes generally less than 25 degrees  Dominant soil types: Tanjong Lipat, Kumansi, , Kapilit, Luasong, Antulai

Social and Acceptable environmental impact Acceptable with findings noted assessment Unacceptable – recommend audit (Stage 2) to be delayed - Not Applicable for MS 2530-2 (Independant Smallholder) Environmental Impact Comments/Justification/Evidence: Assessment Noted and verified SEIA Report dated February 2019. Main components: - Social  Environmental Impact Assessment Impact  Social Impact Assessment & Mitigation Assessment  Environmental Monitoring Program - HCV Assessment

Legal Assessment of Acceptable Customary land Acceptable with findings noted Not Applicable Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Legal Assessment verfied and noted as below [sample]:  Title Head: Negeri Sabah  Declaration of Kampung Kebu Baru Native Grazing Reserve District of Ranau under Schedule X1 [Cap 68]: Section 78 [1] [2] & [3]  Kampung Kebu Baru, Ranau  Native Title: Lot Ukur 06200744: Bil Pelan 06127971  385ha land size

Compensation claim Acceptable of customary land Acceptable with findings noted Not Applicable Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Not applicable as all customary land for the estate use are on Joint venture arrangements

Job Description Acceptable Not Acceptable (Except for independant Comments/Justification/Evidence: smallholder) Viewed & verified all staffs had been given job description. Sampled JD of General Clerk with:  Job Functions  Principles Accountabilities  Job requirements/skills

Page 23 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Payslip Acceptable Not Acceptable (Except for independant Comments/Justification/Evidence: smallholder) Verified & noted the pay-slip of the following 1. Contractor 2. Assistant Manager Documentation in-order/above minimum wages.

Sales and Delivery Acceptable Not Acceptable record of FFB (for independant Comments/Justification/Evidence: smallholder only) Verified and noted sales & delivery records of 2 estates for 2018 & 2019. All records in order. Documents used Bunch Count Sheet, Des-patch Sheet, FFB delivery note, Receiving slip

Other records:

3.0 STAGE 1: AUDIT REVIEW

3.1 Competencies Further special technical competencies needed? Yes, please specify: No 3.2 Information Requirements List any further information necessary for planning the Stage 2 audit: Wildlife Inventory listings to be documented

3.3 Readiness for Stage 2 Based upon review of the above, please state the Auditee Ready for Stage 2 as scheduled readiness Ready for Stage 2 with concerns Not ready for Stage 2

3.4 Implementation Review Implementation review prior to Stage 2 audit (if applicable) Offsite Audit and Closure of CAR

4.0 AUDITOR DECLARATION

The stage 1 audit was based on collecting the necessary information regarding  the scope of the management system, processes and location(s)  reviewing the organization’s status and understanding regarding the requirements of the standard  the identification of objectives, processes and operations of the management The above stated recommendation regarding the organization’s readiness for registration or upgrade is limited to this information collected and was not based on a full audit of the management system. The information in this report should assist the organization in determining any action(s) needed prior to the stage 2 audit and whether to proceed with the stage 2 audit as currently scheduled.

5.0 LEAD AUDITOR: CONCLUSION STATEMENT

Overall, EWOC had made adequate preparation for MSPO Certification in respect of:  Top management committment [2 dedicated Senior Managers as corporate support] & 1 qualified as MSPO Auditor [20 02 2019]  personnel knowledge and understanding of MSPO  personnel training on requirements and appreciation of MSPO  Internal Audit & Management Review Plantation site Audit [Rugading & Kebu Baru Estate] was conducted on 18th July. Audit parameters & observations:  Fertilizer store: compliance

Page 24 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

 Workshop: compliance  Schedule Waste store: compliance  Chemical store: compliance  Boundary marker: compliance  Block markers: compliance but can improve on information  Diesel storage area: overflow drain / sump collection area concreted [fire hazard to chemical store [wooden walls] particularly during dry season.  New Staff Quarters: good continuous improvement plan. Observed naked [earth] wiring [fire hazard]  Designated riparian buffer: no signage  Observation: empty land between / vicinity of New staff quarters & workers housing; ideal to rehabilitate and restore as Riparian zone Conclusion: EWOC [with Rugading & Kebu Baru & Kituntul Estate as representative sample] is in preparedness for Stage 2 Audit which should be conducted/done upon appropriate action taken by EWOC & closure of Corrective Action Report [CAR] by Lead Auditor. Date: Name: 20 07 19 Wilfred S Landong Signature:

6.0 AUDITEE ACKNOWLEDGEMENT This acknowledges the BQAS audit team’s visits to this location and the organizations receipt of the report. Distribution of this report consists of the organization named above and parties names per contractual agreement. Additional distribution must be authorized by the organization. Date: Name: Job Title: Signature: 20 07 19 Abd. Wahid bin Ali Estate Manager

7.0 AUDIT RESULTS: FINDINGS: CORRECTIVE ACTION REPORTS [CAR]

Type of Findings No of Findings NA: Not Acceptable Nil AWF: Acceptable with findings noted 8 [eight]

1. CORRECTIVE ACTION REPORT Client: East West One Consortium Bhd Audit Stage: 1 Date: 20 07 19

STANDARDS MS 2530-3:2013 No 1 of 9 Ref No: EWOC/AU/ST1/07/19 1. FINDING To be completed by Auditor 2.0 MANAGEMENT SYSTEM READINESS (GENERAL)

The Top-Level Management System Manual Acceptable detailing justification for exclusions, inclusion of Acceptable with findings noted or reference to documented procedures for the Unacceptable – recommend audit (Stage 2) to be delayed management system, and providing a Comments/Justification/Evidence: description of the interaction between Management System Manual not available for viewing and processes? verification during Stage 1 Audit 2. CLASSIFICATION: NA ☐Not Acceptable AWF ☒Acceptable with Findings Type of follow up Document review (off-site audit and may be charged) On site audit (effort required will be charged) Page 25 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

Date 20 07 2019 Lead Auditor Wilfred S Landong

To be completed by Company Finding + classification is correct Yes No

Date 22.08.2019 Management Representative Abd. Wahid bin Ali

3. Correction(s), immediate measure To be completed by Company MSM has been extended to estate management for filing and record keeping

4. Root cause(s) To be completed by Company - Not aware of requirement

5. Corrective action taken (s) To be completed by Company MSM has been extended to estate management for filing and record keeping

6. Evidence To be completed by Lead Auditor Noted & Verified

7. Closure: Action for closing has been implemented & Plan for closing AWF/NC is suitable Yes No

Date: 29 08 19 Lead Auditor: Wilfred S Landong

Signature:

2. CORRECTIVE ACTION REPORT Client: East West One Consortium Bhd Audit Stage: 1 Date: 20 07 19

STANDARDS MS 2530-3:2013 No 2 of 9 Ref No: EWOC/AU/ST1/07/19 1. FINDING To be completed by Auditor Process for internal and external Acceptable communication. Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Comments/Justification/Evidence: Consultation & Communication Procedure not available during Audit time. Could not determine process for internal and external communication being documented 2. CLASSIFICATION: NA ☐Not Acceptable AWF ☒Acceptable with Findings Type of follow up Document review (off-site audit and may be charged) On site audit (effort required will be charged) Date 20 07 2019 Lead Auditor Wilfred S Landong

To be completed by Company Finding + classification is correct Yes No

Date 22.08.2019 Management Representative Jeffery Andrew

3. Correction(s), immediate measure To be completed by Company Consultation & communication Procedure is incorporated into External and internal communication SOP and has been extended to estate management for recording and filing.

4. Root cause(s) To be completed by Company Communication procedures was previously incorporated in Transparency & Communication Procedures.

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INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

5. Corrective action taken (s) To be completed by Company Documents are in filing

6. Evidence To be completed by Lead Auditor As per attached. Noted and verified.

7. Closure: Action for closing has been implemented & Plan for closing AWF/NC is suitable Yes No

Date: 29 08 29 Lead Auditor: Wilfred S Landong

Signature:

3. CORRECTIVE ACTION REPORT Client: East West One Consortium Bhd Audit Stage: 1 Date: 20 07 19

STANDARDS MS 2530-3:2013 No 4 of 9 Ref No: EWOC/AU/ST1/07/19 1. FINDING To be completed by Auditor 2.1 B PROCEDURES

Training Procedure Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder) Comments/Justification/Evidence: Document not available at time of audit. 2. CLASSIFICATION: NA ☐Not Acceptable AWF ☒Acceptable with Findings Type of follow up Document review (off-site audit and may be charged) On site audit (effort required will be charged) Date 20 07 2019 Lead Auditor Wilfred S Landong

To be completed by Company Finding + classification is correct Yes No

Date 22.08.2019 Management Representative Jeffery Andrew

3. Correction(s), immediate measure To be completed by Company Internal Training SOP has been extended to estate management for filing and recording

4. Root cause(s) To be completed by Company -not aware of requirement

5. Corrective action taken (s) To be completed by Company In filling in the MSPO Folder at Rugading Estate Office

6. Evidence To be completed by Lead Auditor As per attached. Noted and verified

7. Closure: Action for closing has been implemented & Plan for closing AWF/NC is suitable Yes No

Date: 29 08 19 Lead Auditor: Wilfred S Landong

Signature:

Page 27 of 71 BQAS Certification (M) Sdn Bhd All aspects of the Audit are Confidential November, 2019

INITIAL CERTIFICATION AUDIT REPORT EAST WEST ONE CONSORTIUM BHD MSPO MS 2530-3:2013 REF NO: BQAS/EWOC/015/11/19 November, 2019

4. CORRECTIVE ACTION REPORT Client: East West One Consortium Bhd Audit Stage: 1 Date: 20 07 19

STANDARDS MS 2530-3:2013 No 5 of 9 Ref No: EWOC/AU/ST1/07/19 1. FINDING To be completed by Auditor 2.1 B PROCEDURES

Communication Procedure Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Document not available at time of audit. 2. CLASSIFICATION: NA ☐Not Acceptable AWF ☒Acceptable with Findings Type of follow up Document review (off-site audit and may be charged) On site audit (effort required will be charged) Date 20 07 2019 Lead Auditor Wilfred S Landong

To be completed by Company Finding + classification is correct Yes No

Date 22.08.2019 Management Representative Jeffery Andrew

3. Correction(s), immediate measure To be completed by Company Communication Procedures is documented in Internal and External Communication SOP

4. Root cause(s) To be completed by Company Oversight

5. Corrective action taken (s) To be completed by Company Internal and External Communication SOP has been extended to estate management, filed into MSPO Folder

6. Evidence To be completed by Lead Auditor As per attached. Noted and verified

7. Closure: Action for closing has been implemented & Plan for closing AWF/NC is suitable Yes No

Date: Lead Auditor: Wilfred S Landong 29 08 19 Signature:

5. CORRECTIVE ACTION REPORT Client: East West One Consortium Bhd Audit Stage: 1 Date: 20 07 19

STANDARDS MS 2530-3:2013 No 6 of 9 Ref No: EWOC/AU/ST1/07/19 1. FINDING To be completed by Auditor 2.1 C DOCUMENTS

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List of Stakeholder Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder) Comments/Justification/Evidence: List of Stakeholders sighted and verified. However detail listings are incomplete. 2. CLASSIFICATION: NA ☐Not Acceptable AWF ☒Acceptable with Findings Type of follow up Document review (off-site audit and may be charged) On site audit (effort required will be charged) Date 20 07 2019 Lead Auditor Wilfred S Landong

To be completed by Company Finding + classification is correct Yes No

Date 22.08.2019 Management Representative Jeffery Andrew

3. Correction(s), immediate measure To be completed by Company Updated with list of individuals stakeholders

4. Root cause(s) To be completed by Company Previously list was only with Ketua Peserta

5. Corrective action taken (s) To be completed by Company Updated list has already been filed in MSPO Folder.

6. Evidence To be completed by Lead Auditor As per attached. Noted & verified

7. Closure: Action for closing has been implemented & Plan for closing AWF/NC is suitable Yes No

Date: 29 08 19 Lead Auditor: Wilfred S Landong

Signature:

6. CORRECTIVE ACTION REPORT Client: East West One Consortium Bhd Audit Stage: 1 Date: 20 07 19

STANDARDS MS 2530-3:2013 No 7 of 9 Ref No: EWOC/AU/ST1/07/19 1. FINDING To be completed by Auditor 2.1 C DOCUMENTS

Non-renewable energy estimation Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Not Applicable for MS 2530-2 (Independant Smallholder)

Comments/Justification/Evidence: Documentation of non-renewable energy estimation incomplete

2. CLASSIFICATION: NA ☐Not Acceptable AWF ☒Acceptable with Findings Type of follow up Document review (off-site audit and may be charged)

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On site audit (effort required will be charged) Date 20 07 2019 Lead Auditor Wilfred S Landong

To be completed by Company Finding + classification is correct Yes No

Date 22.08.2019 Management Representative Jeffery Andrew

3. Correction(s), immediate measure To be completed by Company Details budgeted and actual are printed out from system to support the main document.

4. Root cause(s) To be completed by Company Not aware of requirement

5. Corrective action taken (s) To be completed by Company Attached and filed into master documents of the MSPO Folder

6. Evidence To be completed by Lead Auditor Noted and evidence verified

7. Closure: Action for closing has been implemented & Plan for closing AWF/NC is suitable Yes No

Date: Lead Auditor: Wilfred S Landong 29 08 19 Signature:

7. CORRECTIVE ACTION REPORT Client: East West One Consortium Bhd Audit Stage: 1 Date: 20 07 19

STANDARDS MS 2530-3:2013 No 8 of 9 Ref No: EWOC/AU/ST1/07/19 1. FINDING To be completed by Auditor 2.1 C DOCUMENTS

Waste Identification Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed

Comments/Justification/Evidence: Documentation of waste identification incomplete 2. CLASSIFICATION: NA ☐Not Acceptable AWF ☒Acceptable with Findings Type of follow up Document review (off-site audit and may be charged) On site audit (effort required will be charged) Date 20 07 2019 Lead Auditor Wilfred S Landong

To be completed by Company Finding + classification is correct Yes No

Date 22.08.2019 Management Representative Jeffery Andrew

3. Correction(s), immediate measure To be completed by Company Schedule waste identification list has been filed in MSPO Folder

4. Root cause(s) To be completed by Company

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Waste list has been mixed together with domestic waste documentation

5. Corrective action taken (s) To be completed by Company List has been filed accordingly to types of waste

6. Evidence To be completed by Lead Auditor As per attached. Noted & verified

7. Closure: Action for closing has been implemented & Plan for closing AWF/NC is suitable Yes No

Date: Lead Auditor: Wilfred S Landong 29 08 19 Signature:

8. CORRECTIVE ACTION REPORT Client: East West One Consortium Bhd Audit Stage: 1 Date: 20 07 19

STANDARDS MS 2530-3:2013 No 9 of 9 Ref No: EWOC/AU/ST1/07/19 1. FINDING To be completed by Auditor 2.1 C DOCUMENTS Business Management Plan Acceptable Acceptable with findings noted Unacceptable – recommend audit (Stage 2) to be delayed Comments/Justification/Evidence: BMP document not available for viewing and verification during Audit 2. CLASSIFICATION: NA ☐Not Acceptable AWF ☒Acceptable with Findings Type of follow up Document review (off-site audit and may be charged) On site audit (effort required will be charged) Date 20 07 2019 Lead Auditor Wilfred S Landong

To be completed by Company Finding + classification is correct Yes No

Date 22.08.2019 Management Representative Jeffery

3. Correction(s), immediate measure To be completed by Company Business Management Plan has been extended to Estate Management

4. Root cause(s) To be completed by Company Not aware of requirement

5. Corrective action taken (s) To be completed by Company BMP filed into MSPO Folder

6. Evidence To be completed by Lead Auditor Noted & verified

7. Closure: Action for closing has been implemented & Plan for closing AWF/NC is suitable Yes No

Date: Lead Auditor: Wilfred S Landong

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ALL CORRECTIVE ACTION REPORTS FOR STAGE 1 WERE CLOSED OUT ON 29 08 2019

6.1 REPORT SUMMARY: FINDINGS/ACTION TAKEN / CLOSURE

6.1.1 SUMMARY OF FINDINGS There were 8 Findings in Stage 1 Audit classified as AWF (acceptable with findings noted). Corrective action reports [CAR] were raised on these findings and presented to Auditee for action [at end of Stage 1 Audit] with timeline of 2 months from 20 07 2019 to respond.

6.1.2 ACTION TAKEN BY AUDITEE

Auditee responded with documentations & photo evidence [where appropriate] on corrective action taken; last submission of response by Auditee received on 22 08 2019.

6.1.3 CLOSURE OF CAR BY LEAD AUDITOR

The corrective action report (CAR) for these findings were closed out by Lead Auditor on 29 08 2019; upon satisfactory confirmation and verification that all corrective actions taken were in line with MSPO requirements & MS2530-3:2013 Standards

7.0. STAGE 2 AUDIT [ASSESSMENT] MSPO MS2530-3:2013

7.1 BASIC INFORMATION

A. CERTIFICATION BODY Name BQAS Certification [M] Sdn Bhd Audit Dates: From: 19th to 22nd September 2019 Audit Duration: 8 man-days Audit Team: Name Role Wilfred S Landong Lead Auditor Robert Tella Auditor

B. CERTIFIED ENTITY KITUNTUL ESTATE Company Name: EAST WEST ONE CONSORTIUM BERHAD Registration No: 661215 - V Address: Suit 1-9-E2, 9th floor, CPS tower, Centre Point Sabah, 88000 Kota Kinabalu Sabah Site Name: Estate Kituntul Address: Kg Kituntul Ranau Sabah Management Contact details: Tel No: 088-268 899 / 016 810 5353 Fax: 088-310 009 Name Job Title Mobile Telephone Email Abdul Wahid Ali Estate Manager 011-1666 9979 Abdusaly B. Hassan Sr. Assistant Manager 011-2521 7706

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No of Employees Local: Foreign: 39 Total: 39 MPOB License No: 586328002000 Expiry Date:30 Jun 2020 Scope of Activity: Oil Palm Plantation Other Sustainability Certification: Nil Date of Establishment 2014 Geo-Coordinates: 116°43'4.005"E 5°55'14.556"N Certified Area: 589.28 Planted Area 190.90 FFB Production (actual) 2018 153.57 FFB Production (estimate) 2019 1,901 Sources of FFB: own Estate Main FFB purchaser: Green Global Plantation Sdn Bhd No of Planting Blocks 11 No of Palm trees 18,154 Palm Species DXP FELDA, DXP IJM Age Range of Palm Trees 4-5 Years Topography Hilly Area Soil Type: Bidu-bidu & Mentapok Association Land Status: Ownership ☐ Own Land ☐ Rented ☒ Joint Venture

PRINCIPLE 1 MANAGEMENT COMMITMENT & RESPONSIBILITY

Criterion 4.1.1: Malaysian Sustainable Palm Oil (MSPO) Policy

Indicator Requirement Compliance Findings

4.1.1.1 A policy for the ☒ Yes MSPO Policy established, documented, approved and signed implementation of by Dato’ Dr. Jessie Tang, Group Chief Executive Officer on 05 MSPO shall be ☐ No 08 2019. Policy No: EWOG/MSPO-P/20181001 [EN] established. ☐ OFI Quote: Policy statement

[East West One Group is committed to comply and implement all requirements and principles of MSPO. All operating units under EWOG shall adhere to the key principles of MSPO to which the management shall provide leadership and commitment.]

Verified in compliance with requirements.

4.1.1.2 The policy shall also ☒ Yes Noted and written in the Policy statement: emphasize [Our objectives are to: commitment to ☐ No continual Strive to commit our employees, contractors, suppliers, trading improvement. ☐ OFI partners and stakeholders to adhere to our company policies and cooperate with them in an ambition to find continual improvement.]

Verified in compliance with requirements

Criterion 4.1.2: Internal audit

Indicator Requirement Compliance Findings

4.1.2.1 Internal audit shall be ☒ Yes Jeffery Andrew appointed as MSPO Internal Auditor for EWOG planned and on 22 06 2018. conducted regularly ☐ No to determine the

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strong and weak ☐ OFI Ref [EWOG/MSPO-LM/201804002] points and potential area for further Noted and verified in Internal Audit Procedure [5.1] Audit improvement. planning – each element of MSPO will be audited at least once a calendar year]

4.1.2.2 The internal audit ☐ Yes 1. East West One Consortium Bhd [EWOC] Internal Audit procedures and audit Procedure documented & approved by CEO dated 01 results shall be ☐ No 08 2019 [EWOG MSPO – SP20182028] documented and 2. Internal Audit for EWHPB [no 1 of 2019] conducted on evaluated, followed ☒ OFI 03 04 2019. Result summary: 74 conformities; 4 non by the identification of conformities; 44 opportunities for improvement [OFI]. strengths and root Internal Audit report was comprehensively documented and causes of subsequent actions recorded in a progress GANTT Chart. nonconformities, in order to implement However, CAR [corrective action reports] on 4 NC raised but not the necessary signed both Auditee & Auditor; also not closed out by Internal corrective action. Auditor.

4.1.2.3 Report shall be made ☒ Yes Noted and verified Internal Audit Report [dated 03 04 2019] available to the presented to management for review on same date as report. management for their ☐ No review. Management Review/Meeting was held on 28 05 2019 with ☐ OFI principal agenda to discuss Internal Audit Report findings and action to be taken arising.

Criterion 4.1.3: Management review

4.1.3.1 The management shall ☐ Yes 2 Internal Audit had been conducted since; July 2018 & April periodically review the 2019. continuous suitability, ☐ No adequacy and 2 formal Management Reviews had also been conducted ☐ effectiveness of the OFI since. Noted and verified in the minutes of Management requirements for Review as follows: effective  Reviews were chaired by Mr Jeffery Andrew, Assistant implementation of Manager HR/Lead Facilitator [management MSPO and decide on involvement] any changes,  Review agenda include documentations, compliance, improvement and continuous improvement plans & its implementation & modification. progress; facilities improvements were also discussed in details & forward action plan documented.  MSPO watsapp group comprising management & staff members Compliance is observed.

Criterion 4.1.4: Continual improvement

4.1.4.1 The action plan for ☒ Yes Viewed EWOC Continuous Improvement Plan [CIP] [Doc: continual EWOC/MSPO [CI]/2019/03]. Stated & noted: improvement shall be ☐ No based on  CIP review done monthly consideration of the ☐ OFI  Social and environmental impact and opportunities of main social and the company is well covered under the plan and implementation is being monitored monthly and

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environmental impact reported quarterly by the Senior Estate Manager to Top and opportunities of Management. the company. Compliance to requirements is verified.

4.1.4.2 The company shall ☒ Yes EWOC had introduced a system documented in Best Practices establish a system to part of the Management Plan. Among new techniques & improve practices in ☐ No technology already implemented are: line with new information and ☐ OFI  Weevil pollination techniques [to improve yield and techniques or new fruit quality] industry standards and  Solar energy to be installed in all estates technology, where  Use of drone for aerial surveillance of plantation applicable, that are  Use of [ArcGIS] software for mapping available and feasible  Use of soil detector for soil survey etc. and PH reading for adoption. Verified in compliance

4.1.4.3 An action plan to ☒ Yes Training Plan EWOCB/TMATRIX 2019-001 dated 02 01 2019. provide the necessary Documented and established. Training conducted on: resources including ☐ No training, to implement  Use of drone for aerial surveillance of plantation the new techniques or ☐ OFI [February 2019] new industry standard  Use of [ArcGIS] software for mapping [May 2019] or technology (where  Use of soil detector for soil survey etc. and PH reading applicable) shall be [August 2019] established.

PRINCIPLE 2 TRANSPARENCY

Criterion 4.2.1: Transparency of information and documents relevant to MSPO requirements

Indicator Requirement Compliance Findings

4.2.1.1 The management shall ☒ Yes MSPO Policies & documents & public notices are publicly communicate the displayed at Estate Offices, workers & staff quarters in information requested by ☐ No both English and Bahasa. Also made available upon the relevant stakeholders in request from the public. the appropriate languages ☐ OFI and forms, except those This is noted during site visits and plantation sites limited by commercial inspection; in both Rugading Estate & Kebu Baru Estate confidentiality or disclosure

that could result in negative environmental or social outcomes.

4.2.1.2 Management documents ☐ Yes 26 management documents are made available shall be publicly available, [already displayed or given upon request]. These except where this is ☐ No documents include: prevented by commercial  Standard operating procedures

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confidentiality or where ☐ OFI  Policies disclosure of information  Emergency response plan would result in negative  Working hours environmental or social  Copies of land titles outcomes.  Complaint and grievance form  Licenses  Wildlife posters etc. Verified compliance to requirements

Criterion 4.2.2: Transparency method of communication and consultation

4.2.2.1 Procedures shall be ☐ Yes 2 Procedures established established for consultation and communication with ☐ No 1. Transparency & Communication ref doc the relevant stakeholders. EWOG/MSPO/SP/20182019 ☐ OFI 2. External & Internal Communications. Doc ref EWOG/MSPO SP/20182062 Evidenced that this was regularly communicated with relevant stakeholders, landowners & authorities. Up to date 2019, 3 stakeholders meeting had been conducted in Jan, March & August.

Verified compliance

4.2.2.2 A management official ☐ Yes Estate Manager of EWOC, Mr Abd. Wahid bin Ali had should be nominated to be been appointed as Transparency Officer [senior responsible for issues ☐ No management official]. Vide CEO letter Ref doc related to Indicator 1 at EWOG/MSPO LM/20194047 dated 15 05 2019; he ☐ each operating unit. OFI oversees 4 Assistant Managers.

4.2.2.3 List of stakeholders, records ☒ Yes EWOC has listed 122 stakeholders. of all consultation and Regular meetings are conducted with stakeholders as communication and ☐ No records of action taken in and when required. For 2019, 3 stakeholders meeting response to input from ☐ OFI had been conducted. Viewed and verified meeting stakeholders should be minutes and action taken. [documentation in Bahasa] properly maintained.

Criterion 4.2.3: Traceability

4.2.3.1 The management shall ☒ Yes Noted Traceability Procedure established. Ref doc establish, implement and EWOG/MSPO/T/20183001 dated 01 08 2019 approved by maintain a standard ☐ No CEO. operating procedure to comply with the ☐ OFI Noted also evidence the procedure had been requirements for implemented. Procedures clearly include the chain of traceability of the relevant custody of FFB tracked to original source [block] product(s).

4.2.3.2 The management shall ☒ Yes EWOG established a traceability monitoring system conduct regular [Pemeriksaan BTS Tuai-Kilang] as inspection mechanism inspections on compliance ☐ No on Traceability. Form EWOC FRM P2-001dated 1stJan with the established 2019 used to monitor. Traceability of FFB is monitored on

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traceability system. ☐ OFI a weekly basis by Assistant Managers & Field Conductors.

Evidence of on-site inspection is noted during Audit.

[inspection done @Rugading Estate Block 6]

4.2.3.3 The management should ☒ Yes Mr Abdusaly B Hassan had been appointed as identify and assign suitable Traceability Officer to implement and maintain the employees to implement ☐ No system for EWOC. and maintain the traceability system. ☐ OFI Ref doc EWOC/MSPO LM/20184032 dated 13 07 2018.

4.2.3.4 Records of sales, delivery or ☐ Yes Verified, confirmed & viewed based on Traceability transportation of FFB shall flowchart proper record of sales & delivery are be maintained. ☐ No maintained. Documentation include:

☐ OFI  Bunch count chit  FFB dispatch/delivery note  Collection center/mill net weight report  FIS-FFB register  FFB yield statistics Evidence viewed FFB delivery note from Kebu Estate to Green Global SB [collection center] dated 19 02 2019

PRINCIPLE 3 COMPLIANCE TO LEGAL REQUIREMENTS

Criterion 4.3.1: Regulatory requirements

Indicator Requirement Compliance Findings

4.3.1.1 All operations are in ☒ Yes All operation are in compliance with to legal compliance with the requirement and applicable laws and regulation with applicable local, state, the indication of ongoing effort to comply. ☐ No national and ratified international laws and MPOB LICENCE No.: 586328002000 ☐ OFI regulations. Trading Licence: DBKK 552442

Document sighted and verified

4.3.1.2 The management shall list ☒ Yes List of all relevant and applicable laws are available. all laws applicable to their operations in a legal Document sighted, verified and in compliance ☐ No requirement register.

☐ OFI

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4.3.1.3 The legal requirements ☒ Yes All legal requirements are up to date; mechanisms for register shall be updated as updating are available. and when there are any ☐ No new amendments or any Document sighted and verified. new regulations coming ☐ OFI Ref: EWOG/MSPO-SP/20182018 dated 01th Aug 2018. into force.

4.3.1.4 The management should ☒ Yes Evidence of appointment of such person are available. assign a person responsible Refer appointment letter Mr. Abd. Wahid bin Ali to monitor compliance and EWOG/MSPO-LM/201840346 dated 15.05.2019 ☐ No to track and update the changes in regulatory Appointment letter sighted and verified. ☐ OFI requirements.

Criterion 4.3.2: Land use rights

4.3.2.1 The management shall ☒ Yes Land use right documents: ensure that their oil palm cultivation activities do not Terms and condition ref: ☐ No diminish the land use rights A. EWOG/MSPO-SP/20182029 dated 01st Aug 2018. of other users. ☐ OFI B. Ketua peserta / land owner confirm land rights have not been abused. The following people were interviewed:

1. IRIN @JAMIRIN BIB KULANGAS

IC. No. : 650716-12-5111/H0700641

Ketua kaum KG. Rugading. Bangsa Dusun

2. SAHAJIMAN B. BARANTING

IC. N0: 690704-12-5807

Kpg. Rugading Bangsa Dusun

3. MOHD ZULZAIDI B YASIN

IC No.: 870724 49 5811 - DUSUN

Kg. Kinapulidan.

Workers and partner.

Document sighted and verified.

4.3.2.2 The management shall ☒ Yes Legal document on land ownership available ref: provide documents showing legal ownership or 1. RUGADING LOT UKUR BIL. 06200254 dan Pelan ☐ No lease, history of land tenure 06123904 and the actual use of the ☐ OFI 2. KEBU LOT UKUR Bil pelan 06200744 dan Bil Pelan land. 06127971.

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4.3.2.3 Legal perimeter boundary ☒ Yes Boundary markers are visibly maintained [red/white peg] markers should be clearly and GPS coordinate are found to be correct. demarcated and visibly ☐ No maintained on the ground Document sighted and verified. where practicable. ☐ OFI Ref: EWOG/MSPO-SP/20182068

dated 01.08.2018

4.3.2.4 Where there are, or have ☒ Yes No records of dispute found. Interviews made with the been, disputes, following local stakeholders: documented proof of legal ☐ No acquisition of land title and A. IRIN @JAMIRIN BIB KULANGAS fair compensation that ☐ OFI IC. No. : 650716-12-5111/H0700641 have been or are being made to previous owners KG. Rugading. Bangsa Dusun. and occupants; shall be made available and that B. SAHAJIMAN B. BARANTING these should have been accepted with free prior IC. N0: 690704-12-5807 informed consent (FPIC). Kpg. Rugading Bangsa Dusun

C. MOHD ZULZAIDI B YASIN

IC No.: 870724 49 5811 - Dusun

Kg. Kinapulidan.

Workers and partner.

Criterion 4.3.3: Customary rights

4.3.3.1 Where lands are ☒ Yes Customary rights are not threatened or reduce by both encumbered by customary parties as demonstrated in their Join Venture agreement rights, the company shall the “PERJANJIAN USAHASAMA” ☐ No demonstrate that these rights are understood and ref: ☐ OFI are not being threatened 1. RUGADING LOT UKUR BIL. 06200254 dan Pelan or reduced. 06123904

2. KEBU LOT UKUR Bil pelan 06200744 dan Bil. Pelan 06127971.

Documents sighted and verified.

4.3.3.2 Maps of an appropriate ☒ Yes Maps and documents recognizing customary rights are scale showing extent of available. Document sighted and verified. recognized customary ☐ No rights shall be made Ref: EWOCB/P3MAP/2019 available. ☐ OFI

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4.3.3.3 Negotiation and FPIC shall ☒ Yes FPIC negotiation to protect and maintain customary be recorded and copies of rights are made and recorded in the “PERJANJIAN negotiated agreements USAHASAMA” dated 06th Sept 2011 prepared by: ☐ No should be made available. Tetuan RM Jarin & Co. ☐ OFI Advocates and solicitors,

Suite 1-7-E2, CPS Tower,

Center Point Sabah, 88000.

Malaysia.

Document available and verified

PRINCIPLE 4 SOCIAL RESPONSIBILITY, HEALTH, SAFETY & EMPLOYMENT CONDITIONS

Criterion 4.4.1: Social impact assessment (SIA)

Indicator Requirement Compliance Findings

4.4.1.1 Social impacts should ☒ Yes Social Impact Assessment done and report available. be identified and plans are Mitigation plan developed and implemented. ☐ No implemented to Ref: EWOCB/SMP/01 dated 01st June 2019 mitigate the negative ☐ OFI impacts and promote Document sighted and verified. the positive ones.

Criterion 4.4.2: Complaints and grievances

4.4.2.1 A system for dealing ☒ Yes Written/flow chart procedures/system for dealing with with complaints and complaint and grievance for employees and affected grievances shall be stakeholders. ☐ No established and documented. Ref: EWOG/MSPO-SP/20182017 ☐ OFI dated 01.08.2019

Document sighted and verified

4.4.2.2 The system shall be ☒ Yes All complaint and grievances have been resolve as per able to resolve established procedures within the timeline. Complaint disputes in an books and forms are available, sighted and verified. ☐ No effective, timely and appropriate manner ☐ OFI that is accepted by all parties.

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4.4.2.3 A complaint form ☒ Yes Complaint books are available at all times and accessible should be made at all times by employees and affected stakeholders. available at the ☐ No premises, where Document sighted and verified. employees and ☐ OFI Ref complain form/book: EWOCB/BA2019-001 affected stakeholders can make a complaint.

4.4.2.4 Employees and the ☒ Yes Employees and surrounding communities are made aware surrounding through meeting with employees and surrounding communities should communities. ☐ No be made aware that complaints or Minute of meeting sighted and verified. ☐ OFI suggestions can be Refer minute dated 21st January 2019. made any time.

4.4.2.5 Complaints and ☒ Yes All complaint for the last 24 month have been entertained resolutions for the last and resolved. 24 months shall be ☐ No documented and Complaint and grievances book sighted and verified. made available to ☐ OFI Ref: complain form/book: EWOCB/BA2019-001 affected stakeholders upon request.

Criterion 4.4.3: Commitment to contribute to local sustainable development

4.4.3.1 Growers should ☒ Yes CSR such as road repair, contribution of community relation contribute to local works and community development needs to the development in surrounding communities are made and well documented ☐ No consultation with the in minutes of meetings. Photos of activities are available. local communities. ☐ OFI

Criterion 4.4.4: Employees safety and health

4.4.4.1 An occupational ☒ Yes OSH developed and signed by the current top safety and health management in accordance to OSH Act (Act 514). Ref: policy and plan shall ☐ No be documented, 1. OSH Policy EWOG/MSPO-P/2018100 (EN) effectively ☐ OFI Dated 05th Aug. 2018. communicated and implemented. 2. Records of OSH committee minute meeting available EWOCB/MSPO MEETING JULAI-01 dated 05th.July 2019.

3. Appointment of OSH committee Ref: MSPO/APPOINTMENT/20190048 dated 15.05.2019

4. Procedures concerning safety and health safe working procedures available.

All documents sighted and verified.

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4.4.4.2 The occupational ☐ Yes safety and health plan shall cover the ☐ No following:

☐ OFI

A. A safety and health ☒ Yes OSH policy available and displayed. Communicated with policy, which is employees meeting and training and implemented. communicated and ☐ No implemented. Ref: EWOG/MSPO-P/2018100 (EN)

☐ OFI Dated 05th Aug. 2018.

Document sighted and verified

B. b) The risks of all ☒ Yes HIRARC covering all activities and operation carried out and operations shall be available. assessed and ☐ No documented Ref: HIRARC folder

☐ OFI Document sighted and verified

C. An awareness and ☐ Yes training programme which includes the ☐ No following requirements for employees ☐ OFI exposed to pesticides:

C.1 All employees ☒ Yes Training program and training matrix developed and involved shall be available. Evidence of training implementation in photos adequately trained on and attendance list available and sighted. Effectiveness of ☐ No safe working training as displayed by staff and workers during site practices; and inspection and documentation audit. ☐ OFI Refer: • Training program - EWOCB/TMATRIX/2019-001 dated 02.01.2019. •

Document sighted and verified

C.2 All precautions ☒ Yes All safety data sheets are available for all products and attached to products communicated to relevant employees via training and shall be properly briefings to ensure proper application. ☐ No observed and applied. Warning signage posted at strategic places to create ☐ OFI awareness in the field.

Document sighted and verified.

D. The management shall ☒ Yes Adequate and appropriate PPE are provided free of charge provide the to all employees as recommended. List of issued PPE to all appropriate personal staff and workers available. ☐ No protective equipment

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(PPE) at the place of ☐ OFI work to cover all potentially hazardous Health and Safety policy Ref: EWOG/MSPO-SP/20182007 operations as dated 01.08.2018 identified in the risk Document sighted and verified. assessment and control such as Hazard

Identification, Risk Assessment and Risk Control (HIRARC).

E. The management shall ☒ Yes Standard Operating Procedures to ensure proper and safe establish Standard storage and handling of chemicals in accordance to OSH Operating Procedure developed and available. ☐ No for handling of chemicals to ensure Ref: EWOG/MSPO-SP/20182024 dated 01.08.2018. ☐ OFI proper and safe

handling and storage in accordance to Occupational Safety Health (Classification Packaging and Labelling) Regulation 1997 and Occupational Safety Health (Use and Standard of Exposure of Chemical Hazardous to Health) Regulation 2000.

F. The management shall ☒ Yes Appropriate and qualified safety officer appointed for appoint responsible workers safety and health at site. person(s) for workers' ☐ No safety and health. The Refer appointment letter for MR. ABD. WAHID BIN ALI. appointed person(s) of ☐ OFI MSPO/APPOINTMENT/20190048 dated 15th May 2019. trust must have knowledge and

access to latest national regulations and collective agreements.

G. The management shall ☒ Yes OSH committee meeting conducted as required by conduct regular two- regulation. All categories of operation are represented. way communication ☐ No with their employees Ref: EWOCB/MSPO MEETING/JUN-01 where issues affecting ☐ OFI Dated 18th June 2019. their business such as employee's health, Document sighted and verified. safety and welfare are discussed openly. Records from such meetings are kept and

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the concerns of the employees and any remedial actions taken are recorded

H. Accident and ☒ Yes Accident and emergency procedures available and emergency communicated to employees. procedures shall exist ☐ No and instructions shall Ref: EWOG/MSPO-SP/20182021 be clearly understood ☐ OFI dated 01.08.2019 by all employees.

I. Employees trained in ☒ Yes Qualified personnel available and present on site. Training First Aid should be conducted and first aid kit available. Appointment of Izzat present at all field Muzakkir Bin Mursidi as First Aid Trainer. ☐ No operations. A First Aid Kit equipped with Ref: MSPO/APPOINMENT2018 dated 29th July 2018. ☐ OFI approved contents Record of training sighted and verified should be available at each worksite.

J. Records shall be kept ☒ Yes The company have Zero accident recorded. OSH of all accidents and committee meeting done quarterly to improve existing be reviewed control. Refer: ☐ No periodically at quarterly intervals. EWOCB/MSPO MEETING/JUN-01 ☐ OFI dated 18.06.2019

Criterion 4.4.5: Employment conditions

4.4.5.1 The management shall ☒ Yes Policy is available, sighted and verified. establish policy on good social practices Policies are communicated and implemented by posting it ☐ No regarding human on notice board and meetings with internal staff and all rights in respect of stakeholders. ☐ OFI industrial harmony. The Photos, Minutes and agendas of meeting sighted. policy shall be signed by the top Ref: management and effectively EWOG/MSPO-P/20180814 dated 14 08 2018 communicated to the employees. Policy signed by:

Group Chief Executive Officer Dato’ Dr. Jessie Tang

4.4.5.2 The management shall ☒ Yes Policy is available, sighted and verified. not engage in or support discriminatory Policies are communicated and implemented. ☐ No practices and shall A. Foreign Workers Recruitment Policy Ref: provide equal ☐ OFI opportunity and EWOG/MSPO-P/20181024 dated 05 08 2018 treatment regardless

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of race, colour, sex, B. Polisi Hak Asasi Manusia Ref: religion, political opinion, nationality, EWOG/MSPO-P/20181018 dated 05 08 2018 social origin or any Policy signed by: other distinguishing characteristics. Group Chief Executive Officer Dato’ Dr. Jessie Tang

4.4.5.3 Management shall ☒ Yes Minimum wage applied to all local and foreign workers. ensure that Evidence shown in payslip and interviews of local and employees’ pay and foreign employees. ☐ No conditions meet legal or industry minimum ☐ OFI standards and as per Polisi Hak Asasi Manusia Ref: agreed Collective Agreements. The living EWOG/MSPO-P/20181018 dated 05 08 2018 wage should be sufficient to meet Policy signed by: basic needs and provide some Group Chief Executive Officer Dato’ Dr. Jessie Tang. discretionary income based on minimum Document sighted and verified wage.

4.4.5.4 Management should ☒ Yes All contractors are bound by their agreement to apply by ensure employees of the CONTRACTOR CONTRACT AGREEMENT upon engaging contractors are paid as independent contractors. ☐ No based on legal or industry minimum Ref: EWCOB/2019/002 dated 01st Jan. 2019 ☐ OFI standards according Document sighted and verified. to the employment contract agreed

between the contractor and his employee.

4.4.5.5 The management shall ☒ Yes Summary of all employees including seasonal, contract and establish records that subcontract workers are available. provide an accurate ☐ No account of all List of workers for the period ending Aug 2019 available. employees (including ☐ OFI Document sighted and verified. seasonal workers and subcontracted

workers on the premises). The records should contain full names, gender, date of birth, date of entry, a job description, wage and the period of employment.

4.4.5.6 All employees shall be ☒ Yes All employees and contract workers are provided with provided with fair employment contract sign by both parties’ employer and

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contracts that have ☐ No employees. been signed by both employee and ☐ OFI employer. A copy of Document sighted and verified. employment contract is available for each and every employee indicated in the employment records.

4.4.5.7 The management shall ☒ Yes Permanent employee time recording are by means of establish a time check roll, all time in and time out are clearly recorded. recording system that ☐ No makes working hours Contract workers are as required by their contractor. and overtime ☐ OFI Document sighted and verified. transparent for both employees and employer.

4.4.5.8 The working hours and ☒ Yes Working hours and breaks of each individual worker are as breaks of each indicated in check roll and comply with legal regulation. individual employee ☐ No as indicated in the No overtime as payment are made base on rate per time records shall tonnage for harvesting and rate per hectare for manuring, ☐ OFI comply with legal maintenance or clearing. regulations and Check-roll sighted and verified. collective agreements. Overtime shall be mutually agreed and shall always be compensated at the rate applicable and shall meet the applicable legal requirement.

4.4.5.9 Wages and overtime ☒ Yes All wages and working on public holidays and overtime payment payment records are acceptable and legal requirement. documented on the ☐ No pay slips shall be in line Check-roll and payslip sighted and verified. with legal regulations ☐ OFI and collective agreements.

4.4.5.10 Other forms of social ☒ Yes Social benefit provided by the company: benefits should be offered by the 1. Medical and health care. ☐ No employer to 2. Housing amenities. employees, their ☐ OFI families or the 3. Motorcycle allowance - 300/per month all. community such as incentives for good 4. Telephones benefit - staff only

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work performance, 5. FFB incentives 1 % - staff only bonus payment, professional development, Receipts and other medical bills sighted and verified. medical care and health provisions.

4.4.5.11 In cases where on-site ☒ Yes Onsite workers housing and amenities meet the minimum living quarters are standard of housing and amenities. 5years housing provided, these improvement plan available, implemented and in progress. ☐ No quarters shall be habitable and have Housing visited. ☐ OFI basic amenities and 5years plan sighted and verified. facilities in compliance with the Workers' Minimum Standards Housing and Amenities Act 1990 (Act 446) or any other applicable legislation.

4.4.5.12 The management shall ☒ Yes Policy is available, communicated and implemented by establish a policy and posting it on notice board and meetings with internal staff provide guidelines to and all stakeholders. ☐ No prevent all forms of sexual harassment Photos, Minutes and agendas of meeting sighted. ☐ OFI and violence at the Policy No. EWOG/MSPO-P/20181006 dated 05.08.18 workplace.

Policy signed by:

Group Chief Executive Officer Dato’ Dr. Jessie Tang

4.4.5.13 The management shall ☒ Yes Good social practices policy on freedom of association and respect the right of all the effective recognition of the rights of collective employees to form or bargaining is noted. Policy communicated and ☐ No join trade union and implemented by posting it on notice board and meetings allow workers own with internal staff and all stakeholders. ☐ OFI representative(s) to facilitate collective Policy No. Ref: EWOG/MSPO-P/20180814 bargaining in Dated 14.08.2019. accordance with applicable laws and

regulations. Employees shall be given the Policy sighted and verified. freedom to join a trade union relevant Policy signed by: to the industry or to organize themselves Group Chief Executive Officer Dato’ Dr. Jessie Tang for collective bargaining. Employees

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shall have the right to organize and negotiate their work conditions. Employees exercising this right should not be discriminated against or suffer repercussions.

4.4.5.14 Children and young ☒ Yes Good social practices policy on prohibition of child labour persons shall not be available. Policy communicated and implemented by employed or posting it on notice board and meetings with internal staff ☐ No exploited. The and all stakeholders. minimum age shall ☐ OFI comply with local, Policy No. Ref: EWOG/MSPO-P/20180814 state and national dated 14.08.2019. legislation. Work by children and young Policy sighted and verified. persons is acceptable on family farms, under Policy signed by: adult supervision, and when not interfering Group Chief Executive Officer Dato’ Dr. Jessie Tang with their education. They shall not be exposed to hazardous working conditions.

Criterion 4.4.6: Training and competency

4.4.6.1 All employees, ☒ Yes Training programme for 2019 available and conducted. contractors and relevant smallholders Record of training in the forms of attendance, photos and ☐ No are appropriately training material sighted and verified. trained. A training ☐ OFI Ref: EWOCB/TMATRIX/2019-001 dated 02.01.2019 programme (appropriate to the

scale of the organization) that includes regular assessment of training needs and documentation, including records of training shall be kept.

4.4.6.2 Training needs of ☐ Yes Insufficient Training Need Analysis on individual worker and individual employees staff. shall be identified prior ☐ No to the planning and No Training Need Analysis made prior to planning and implementation of the implementation of training programme on specific skill and ☒ OFI training program in competency. order to provide the specific skill and

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competency required to all employees based on their job description.

4.4.6.3 A continuous training ☒ Yes Continuous training programme for 2019 planned and programme should be implemented. planned and ☐ No implemented to Record of training in the forms of attendance, photos and ensure that all training material sighted and verified. ☐ OFI employees are well Ref: EWOCB/TMATRIX/2019-001 dated 02.01.2019 trained in their job function and

responsibility, in accordance to the documented training procedure.

PRINCIPLE 5 ENVIRONMENT, NATURAL RESOURCES, BIODIVERSITY & ECOSYSTEM SERVICES

Criterion 4.5.1: Environmental management plan

Indicator Requirement Compliance Findings

4.5.1.1 An environmental policy ☒ Yes Environmental management Plan available concerning and management plan in environmental management. compliance with the ☐ No relevant country and state environmental laws shall be ☐ OFI EWOG/MSPO-SP/20192036 dated 01.01.2019 developed, effectively communicated and Document sighted and verified. implemented.

4.5.1.2. The environmental ☒ Yes Refer Environmental management plan. EWOG/MSPO- management plan shall SP20192036 dated 01.01.2019. cover the following: ☐ No Document sighted and verified.

☐ OFI

A. An environmental policy ☒ Yes Environmental policy and management plan to maintain and objectives high standard on environmental care and minimize impact through continuous improvement plan. Document ☐ No sighted and verified.

☐ OFI

B. The aspects and impacts ☒ Yes Environmental plan covers: analysis of all operations.

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☐ No A. Policy.

B. The aspect and impact of all operations. ☐ OFI Document sighted and verified.

4.5.1.3 An environmental ☒ Yes Environmental improvement plan to mitigate negative improvement plan to impact and promote positive impact developed, mitigate the negative effectively implemented and monitored. ☐ No impacts and to promote the positive ones, shall be Document sighted and verified. ☐ OFI developed, effectively

implemented and monitored.

4.5.1.4 A programme to promote ☒ Yes Programme available. the positive impacts should be included in the Ref: EWOG/MSPO-SP/20182026/002 ☐ No continual improvement dated 01.01.2019 plan. ☐ OFI Document sighted and verified.

4.5.1.5 An awareness and training ☐ Yes Environmental management plan available, however, programme shall be Awareness training programme on environmental established and management and improvement plans as part of ☐ No implemented to ensure implementation and communication policy are on-going that all employees however training are yet to be conduct. ☒ OFI understand the policy and objectives of the Ref: EWOG/MSPO-SP/20192036 environmental Dated 01.01.2019. management and improvement plans and

are working towards achieving the objectives.

4.5.1.6 Management shall ☒ Yes Meeting conducted with employee representatives to organize regular meetings discuss their concern on quality of environment. Last with employees where their meeting done on 29th May 2019.9.23. Minute and agenda ☐ No concerns about of meeting sighted and verified. environmental quality are ☐ OFI discussed.

Criterion 4.5.2: Efficiency of energy use and use of renewable energy

4.5.2.1 Consumption of non- ☒ Yes Available trend /record of diesel usage as follows: renewable energy shall be optimized and closely ☐ No monitored by establishing 2016 249,534 liters baseline values and trends ☐ OFI shall be observed within an 2017 320,534 liters appropriate time frame. There should be a plan to 2018 407,134 liters assess the usage of non-

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renewable energy 2019 MTD 502,199 liters including fossil fuel, electricity and energy efficiency in the operations over the base period.

Document sighted and verified. Consumption increases due to increase in number of plantation vehicles.

4.5.2.2 The oil palm premises shall ☒ Yes Budgeted direct usage (annual) of non-renewable energy estimate the direct usage as follows: of non-renewable ☐ No 2019 502,199.42 liters. Energy for their operations, including fossil fuel, and ☐ OFI Note: electricity to determine energy efficiency of their 1. 2019 budget include diesel fuel projection for major operations. This shall infrastructure and estate road construction. include fuel use by contractors, including all 2. Plantation is expected to be fully using 24hrs electricity transport and machinery supply from Sabah Electricity Sdn. Bhd by year end. operations.

4.5.2.3 The use of renewable ☒ Yes No renewable energy use for the time being, however energy should be applied street lighting using solar energy have been written up in where possible. continuous improvement plan. ☐ No

☐ OFI

Criterion 4.5.3: Waste management and disposal

4.5.3.1 Waste products and ☒ Yes List of types and source of waste and pollution by sources of pollution shall be plantation: identified and ☐ No documented. 1. Domestics waste

☐ OFI A. workers quarters

2. Schedule waste.

A. Workshop - used lubricant and spillage.

B. Chemicals - pesticide gallons and fertilisers bag.

Document sighted and verified

4.5.3.2 A waste management plan to avoid or reduce pollution shall be

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developed and implemented. The waste management plan should include measures for:

A Identifying and monitoring ☒ Yes Waste management plan: sources of waste and pollution A. Domestic waste ref; ☐ No i. EWOG/MSPO-SP/20182017 dated 01.08.2018. ☐ OFI B. Schedule waste procedure refer:

i. EWOCB-SWP-01 dated 01.05.2019

ii. EWOCB-SWP-02 dated 01.05.2019

iii. EWOCB-SWP-03 dated 01.05.2019

Document sighted and verified.

B. Improving the efficiency of ☐ Yes POME and EFB utilized as nutrient and value added by resource utilization and product however no record available other than undated recycling of potential and unmarked photos. ☐ No wastes as nutrients or converting them into value- ☒ OFI added by-products.

4.5.3.3 The management shall ☒ Yes SOP established and implemented in accordance with establish Standard regulation. Refer EWOG/MSPO-SP/20182024 dated Operating Procedure for 01.08.2019. ☐ No handling of used chemicals that are classified under Evidence refer to CHRA training: EWOCB/TMARIX/2019-001 ☐ OFI Environment Quality dated 02.01.2019 Regulations (Scheduled Document sighted and verified. Waste) 2005, Environmental Quality Act, 1974 to ensure proper and safe handling, storage and disposal.

4.5.3.4 Empty pesticide containers ☒ Yes All empty herbicide containers are recycle and used as shall be punctured and ready use container for herbicide premix used for spraying disposed in an weeds. ☐ No environmentally and socially responsible way, Evidence in photos and site visit. ☐ OFI such that there is no risk of contamination of water sources or to human health. The disposal instructions on manufacturer’s labels should be adhered to. Reference should be made to the national programme on recycling of used HDPE

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pesticide containers.

4.5.3.5 Domestic waste should be ☒ Yes All domestic waste are segregated and dispose in disposed as such to accordance with their classification. minimize the risk of ☐ No contamination of the All bio-degradable domestic waste are disposed off as environment and landfill at location more than 50meters away from housing ☐ OFI watercourses. and water course.

Map sighted and site visited.

Criterion 4.5.4: Reduction of pollution and emission

4.5.4.1 An assessment of all ☐ Yes No available & proper records of assessment polluting activities shall be done/conducted on polluting activities including conducted, including greenhouse gas emissions, scheduled wastes, solid wastes ☐ No greenhouse gas emissions, and effluent. scheduled wastes, solid ☒ OFI wastes and effluent.

4.5.4.2 An action plan to reduce ☒ Yes Action plan to reduced identified significant pollutants identified significant and emission established and implemented. Refer: pollutants and emissions ☐ No shall be established and EWOG/MSPO-SP/20192036 dated 01.01.2019 implemented. ☐ OFI

Criterion 4.5.5: Natural water resources

4.5.5.1. The management shall ☒ Yes Water management plan available. Refer: EWOG/MSPO- establish a water SP20192067 dated 01.02.2019 management plan to ☐ No maintain the quality and availability of natural water ☐ OFI Document sighted and verified. resources (surface and ground water). The water management plan may include:

A Assessment of water usage ☐ Yes No proper record of water usage and assessment. and sources of supply. Plantation uses gravity feed from 900meters away water source. ☐ No

Alternative source of water are rainwater harvesting. ☒ OFI

B Monitoring of outgoing ☐ Yes No monitoring of outgoing water done. No retention pond water which may have built, used water fed to the ground; may cause negative impacts into the contamination. ☐ No natural waterways at a frequency that reflects the However construction of retention pond is noted in the ☒ OFI estate’s current activities. continuous improvement plan.

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C Ways to optimize water ☒ Yes No records of implementation optimize water and and nutrient usage to nutrients usage and to reduce wastage. Plantation uses reduce wastage (e.g. gravity feed and rainwater harvesting. ☐ No having in place systems for re-use, night application, ☐ OFI maintenance of equipment to reduce leakage, collection of rainwater, etc.).

D Protection of water courses ☒ Yes Appropriate riparian buffer zone kept on the bank of Tikou and wetlands, including stream to protect the natural waterways within the maintaining and restoring plantation. ☐ No appropriate riparian buffer zones at or before planting Site visit done and verified. ☐ OFI or replanting, along all natural waterways within the estate.

E Where natural vegetation ☒ Yes Riparian zone allocated and signage posted along in riparian areas has been waterways. removed, a plan with a ☐ No timetable for restoration Site visit done and verified. shall be established and ☐ OFI implemented.

F Where bore well is being ☒ Yes No bore well use. Plantation uses gravity feed and use for water supply, the rainwater harvesting. level of the ground water ☐ No table should be measured at least annually. ☐ OFI

4.5.5.2 No construction of bunds, ☒ Yes No construction of bunds, weirs or dams over main weirs and dams across waterways. main rivers or waterways ☐ No passing through an estate. Site visit done and verified.

☐ OFI

4.5.5.3 Water harvesting practices ☒ Yes Rain water harvesting and gravity feed system used as should be implemented main source of water supply. (e.g. water from road-side ☐ No drains can be directed and stored in conservation ☐ OFI terraces and various natural receptacles).

Criterion 4.5.6: Status of rare, threatened, or endangered species and high biodiversity value area

4.5.6.1. Information shall be

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collated that includes both the planted area itself and relevant wider landscape- level considerations (such as wildlife corridors). This information should cover:

A Identification of high ☒ Yes The 2 estates audited under this certification audit are biodiversity value habitats, situated mostly on hill terrain. Random assessment of such as rare and ☐ No ecosystem indicated there are spots of non-contiguous threatened ecosystems, occurrence of high biodiversity value habitats [caves, that could be significantly ☐ OFI hardwood timber species etc.]. These spots are set aside, affected by the grower(s) conserved and left undisturbed. activities.

B Conservation status (e.g. ☒ Yes To monitor wildlife population EWHPB established record The International Union on keeping [Wildlife Inventory log book]. Observed in the log Conservation of Nature ☐ No book there has been sightings of the following wildlife and Natural Resources since April 2019: (IUCN) status on legal ☐ OFI protection, population  Civet cats status and habitat  Porcupines requirements of rare,  Wild deer threatened, or  Mousedeer endangered species), that  Wild cats could be significantly  Various species of birds affected by the grower(s)  Wild pheasants activities.  Wild boars Compliance is verified.

4.5.6.2. If rare, threatened or endangered species, or high biodiversity value, are present, appropriate measures for management planning and operations should include:

A Ensuring that any legal ☒ Yes EWOC maintain in the legal register the Sabah Protection requirements relating to the of Wildlife Act 1972; this is used to ensure consistent protection of the species ☐ No monitoring of regulations pertaining to endangered are met. species ☐ OFI

B Discouraging any illegal or ☒ Yes Signages [No hunting, No fishing] were installed at various inappropriate hunting, appropriate locations in the estates. Verified and noted fishing or collecting ☐ No during both stages of field audits. activities and developing responsible measures to Wildlife signage [protected species] is placed at estate

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resolve human-wildlife ☐ OFI entrance gates and other strategic location in the estates. conflicts.

4.5.6.3 A management plan to ☒ Yes Wildlife management plan is established under Chapter comply with Indicator 1 3.4 [fauna & flora] of the SEIA [Social environmental shall be established and ☐ No impact assessment report/plan] February 2019. effectively implemented, if required. ☐ OFI Verified compliance.

Criterion 4.5.7: Zero burning practices

4.5.7.1 Use of fire for waste ☐ Yes Currently there is no replanting activities and land disposal and for preparing preparation for oil palm cultivation. land for oil palm cultivation ☐ No or replanting shall be No occurrence of use of fire for waste disposal found ☐ avoided except in specific OFI during facilities & site audits. situations, as identified in

regional best practice.

4.5.7.2 A special approval from ☒ Yes No history of crops affected by disease in all EWOC the relevant authorities shall Estates. be sought in areas where ☐ No the previous crop is highly Not applicable as no controlled burning is practiced. diseased and where there ☐ OFI is a significant risk of disease spread or continuation into the next crop.

4.5.7.3 Where controlled burning is ☐ Yes Not applicable as no controlled burning is practiced. allowed, it shall be carried out as prescribed by the ☐ No Environmental Quality (Declared Activities) (Open ☐ OFI Burning) Order 2003 or other applicable laws.

4.5.7.4 Previous crops should be ☒ Yes No activities related to previous crops felled or mowed down, chipped and shredded, ☐ No windrowed or pulverized or ploughed and mulched. ☐ OFI

PRINCIPLE 6 BEST PRACTICES

Criterion 4.6.1: Site management

Indicator Requirement Compliance Findings

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4.6.1.1 Standard operating ☒ Yes 15 [SOP] procedures established on Best Practices procedures shall be  Oil palm nursery culling appropriately documented ☐ No and consistently  Block design implemented and ☐ OFI  Palm pruning monitored.  Manuring  Weeding management  Harvesting  Integrated pest management-beneficial pant  Rat baiting and control  Ganoderma  Leaf eating caterpillar  Rhinoceros beetle  Tirathaba bunch moth  Soil sampling  Foliar sampling for fertilizers

4.6.1.2 Where oil palm is grown ☒ Yes Noted and verified during site audit following conservation within permitted levels on measures taken: sloping land, appropriate ☐ No soil conservation measures  Planting of mucuna plant & vertiver grass as cover shall be implemented to ☐ OFI crop prevent both soil erosion as  Planting of bamboo well as siltation of drains  Use of palm fronds and waterways. Measures  Appropriate terracing – 14 feet width shall be put in place to PH reading [soil] in the Rugading estate is ranging from 5.5 prevent contamination of to 6.0 [slightly acidic] surface and groundwater PH reading is done quarterly [2 months after manuring] through runoff of either soil, nutrients or chemicals.

4.6.1.3 A visual identification or ☒ Yes Verified and noted during site audit block markers installed reference system shall be on the ground [pole] with following indicators: established for each field. ☐ No  Block no ☐ OFI  Year of planting  Species  No of palm trees Criterion 4.6.2: Economic and financial viability plan

4.6.2.1 A documented business or ☒ Yes Viewed and verified Business management Plan. The plan management plan shall be covers a strategic period from 2018 to 2024 and established to demonstrate ☐ No demonstrated attention to include the following attention to economic and economic and financial viability factors: financial viability through ☐ OFI long-term management  Yield projections planning.  Profit and loss projection  Field development program  Project costing

4.6.2.2 Where applicable, an ☒ Yes No replanting program for all EWHPB estates; all fully annual replanting planted with age range from 4 to 5 years. programme shall be established. Long term

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replanting programme ☐ No should be established and review annually, where ☐ OFI applicable every 3-5 years.

4.6.2.3 The business or ☐ Yes management plan may contain: ☐ No

☐ OFI

A Attention to quality of ☒ Yes Following species are planted in all EWOC estates: planting materials and FFB.  Calix [Sime darby] 600 ☐ No  DXP [dura pisifera] Guthrie ☐ OFI  DXP AAR  DXP FELDA  BSSB [borneo samudra]  DXP AVCROSS  DXP IJM

B Crop projection: site yield ☒ Yes Business Management Plan [BMP] contained crop potential, age profile, FFB projection [page 35 to 37] factors [yield potential, age yield trends. ☐ No profile, FFB yield trends. FFB projections as follows:

☐ OFI 2019 to date [August] 7088MT

2018 11,462MT

2019 52,788

2020 61,902

2021 70,336

2022 75,964

C Cost of production: cost ☒ Yes Projected for cost of production 2019 per ton of FFB.  Cost per ton of FFB: RM275/- ☐ No  Cost per hectare: RM6034/- ☐ OFI

D Price forecast ☐ Yes Noted in the BMP price per MT projected @RM500/- for period 2018 to 2024 ☐ No

☐ OFI

E Financial indicators: cost ☒ Yes All financial indicators are documented in the BMP: benefit, discounted cash Profit/loss before tax [PBIT] projected as follows: flow, return on investment. ☐ No Year RM ☐ OFI 2018 1,736,422 actual

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2019 11,817,303

2020 13,867,861

2021 15,765,661

4.6.2.4 The management plan ☐ Yes At both Top Management & Estate level the management shall be effectively plan is reviewed and action plan discussed and implemented and the ☐ No implemented on a monthly basis. Monthly meeting held at achievement of the goals estate level are documented. Viewed & verified Estate ☐ and objectives shall be OFI meeting minutes. regularly monitored, periodically reviewed and documented.

Criterion 4.6.3: Transparent and fair price dealing

4.6.3.1 Pricing mechanisms for the ☒ Yes Pricing mechanism documented and revised annually. products and other services Piece rate/daily rated/productivity based mechanism shall be documented and ☐ No used to remunerate workers & contractors and itemized effectively implemented. pricing done for each specific activities like harvesting, ☐ OFI weeding, manuring, spraying, de-creeping, slashing.

Ref doc: EWOCB/P6/2019 effective 01 January 2019.

Evidence of implementation viewed.

4.6.3.2 All contracts shall be fair, ☒ Yes Noted and viewed sample of contract agreement legal and transparent and [contract no: EWCOB/2019/002] dated 01 01 2019 agreed payments shall be ☐ No between EWOC and AMIRUDDIN BIN TAHER [Mandore] made in timely manner. ☐ OFI Contract legally enforceable. Verified through documentary evidence [contract payment document], contract is executed fairly to both parties.

Criterion 4.6.4: Contractor

4.6.4.1 Where contractors are ☒ Yes MSPO briefing to contractors/stakeholders had been engaged, they shall conducted thrice in 2019.[Jan, April & May 2019] understand the MSPO ☐ No requirements and shall Verified through Contractor interviewed on 25 09 19 provide the required ☐ OFI [MOHD ZULZAIDI B YASIN] of Kpg Kinapulidan that basic documentation and knowledge of MSPO had been acquired; and in practice information. MSPO related documentation is used.

4.6.4.2 The management shall ☒ Yes Contract agreement was made available during Audit provide evidence of time. agreed contracts with the ☐ No contractor. Viewed Contract Agreement doc Ref: ☐ OFI EWOCB/FBB/2019/02 KITUNTUL dated 01 09 2019 between Joel Sumaliling [contractor] & Abd Wahid Ali [EWOC Estate

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Manager] on construction of new labor quarters.

Each contractor is also given copies of Contract agreement. Verified that all contract agreement viewed are legal and proper.

4.6.4.3 The management shall ☐ Yes MSPO Auditors were allowed to access Contractors file accept MSPO approved and interview Contractors during Stage 1 & 2 Audit. 2 auditors to verify ☐ No Contractors were interviewed. assessments through a ☐ physical inspection if OFI required.

4.6.4.4 The management shall be ☐ Yes Verified and noted Contractors performance & work responsible for the activities are supervised by Field Conductors and observance of the control ☐ No approved by Assistant Estate Manager. points applicable to the ☐ tasks performed by the OFI Field Inspection Report form is used to monitor Contractor contractor, by checking performance. [viewed report dated 08 08 19 on and signing the assessment Contractor [AMIRRUDIN] of the contractor for each

task and season contracted.

PRINCIPLE 7 DEVELOPMENT OF NEW PLANTING

Principle 7 is not applicable as there is no development of new planting in all EWHPB Estates

7.3 SUMMARY OF FINDINGS

PRINCIPLE 1 MANAGEMENT COMMITMENT & RESPONSIBILITY

Criterion 4.1.2: Internal audit

Indicator Requirement Compliance Findings

4.1.2.2 The internal audit procedures and audit ☐ Yes 3. East West One Consortium Bhd results shall be documented and [EWOC] Internal Audit Procedure evaluated, followed by the identification ☐ No documented & approved by CEO of strengths and root causes of dated 01 08 2019 [EWOG MSPO – nonconformities, in order to implement ☒ OFI SP20182028] the necessary corrective action. 4. Internal Audit for EWHPB [no 1 of 2019] conducted on 03 04 2019. Result summary: 74 conformities; 4 non conformities; 44 opportunities for improvement [OFI]. Internal Audit report was comprehensively documented and subsequent actions

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recorded in a progress GANTT Chart.

However, CAR [corrective action reports] on 4 NC raised but not signed both Auditee & Auditor; also not closed out by Internal Auditor.

PRINCIPLE 4 SOCIAL RESPONSIBILITY, HEALTH, SAFETY & EMPLOYMENT CONDITIONS

Indicator Requirement Compliance Findings

Criterion 4.4.6: Training and competency

4.4.6.2 Training needs of individual employees ☐ Yes Insufficient Training Need Analysis on individual shall be identified prior to the planning worker and staff. and implementation of the training ☐ No program in order to provide the specific No Training Need Analysis made prior to skill and competency required to all planning and implementation of training ☒ OFI employees based on their job programme on specific skill and competency. description.

PRINCIPLE 5 ENVIRONMENT, NATURAL RESOURCES, BIODIVERSITY & ECOSYSTEM SERVICES

Criterion 4.5.1: Environmental management plan

Indicator Requirement Compliance Findings

4.5.1.5 An awareness and training programme ☐ Yes Environmental management plan available, shall be established and implemented to however, Awareness training programme on ensure that all employees understand environmental management and improvement ☐ No the policy and objectives of the plans as part of implementation and environmental management and communication policy are on-going however ☒ OFI improvement plans and are working training are yet to be conduct. towards achieving the objectives. Ref: EWOG/MSPO-SP/20192036

Dated 01.01.2019.

Criterion 4.5.4: Reduction of pollution and emission

4.5.4.1 An assessment of all polluting activities ☐ Yes No available & proper records of assessment shall be conducted, including done/conducted on polluting activities greenhouse gas emissions, scheduled including greenhouse gas emissions, ☐ No wastes, solid wastes and effluent. scheduled wastes, solid wastes and effluent.

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☒ OFI

Criterion 4.5.5: Natural water resources

4.5.5.1. The management shall establish a water ☐ Yes Water management plan available. Refer: management plan to maintain the EWOG/MSPO-SP20192067 dated 01.02.2019 quality and availability of natural water ☐ No resources (surface and ground water). The water management plan may ☐ OFI Document sighted and verified. include:

A Assessment of water usage and sources ☐ Yes No proper record of water usage and of supply. assessment. Plantation uses gravity feed from 900meters away water source. ☐ No

Alternative source of water are rainwater ☒ OFI harvesting.

B Monitoring of outgoing water which may ☐ Yes No monitoring of outgoing water done. No have negative impacts into the natural retention pond built, used water fed to the waterways at a frequency that reflects ground; may cause contamination. ☐ No the estate’s current activities. However construction of retention pond is ☒ OFI noted in the continuous improvement plan.

7.4 CONCLUSION BY LEAD AUDITOR [26 09 2019] [end day of Stage 2 Assessment]

No of “NO”: Non-Conformance Nil No of “OFI”: Opportunity for Improvement 5 [five] criteria REPORT SUMMARY & RECOMMENDATIONS

East West One Consortium Bhd {EWOCB] group is a well-structured & organized corporate organization; with 10 Oil Palm Plantation under the group. MSPO Certification is a corporate driven initiative with the full support and commitment of the BOD/top management. 2 senior officers of EWHPB [Mr Terrence Mark & Mr Jeffery Andrew] are assigned and dedicated to ensure comprehensive preparation of MSPO certification both at corporate and in-situ implementation. Mr Jeffery Andrew is a trained MSPO Auditor. It is observed during both Audit stages that plantation managers & staffs are conversant with good understanding of MSPO principles, requirements. All level of staffs & workers are continuously trained on applications and knowledge of MSPO. Since 2018, 21 training sessions had been conducted at Estate level. During both Audit stages, interviews with landowners/participants/joint venture partners of EWOC indicate satisfaction on the business partnership/joint venture agreement implementation. Relationship is cordial between estate management & landowners, many of whom are contractors to EWOC. Overall, EWOC had committed investments & demonstrated high level of in-situ efforts to achieve compliance to all MSPO Principles & criteria. After conclusion of both Audits the Audit team would conclude that EWOC had generally satisfied the requirement of certification under the MSPO 2530- 3:2013 Standards.

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It is therefore the Lead Auditor recommendation that subject to closure of all OFI and approval of the Final Audit Report, East West One Consortium Bhd be certified under MSPO MS2530-3:2013.

Lead Auditor: Acknowledged by Auditee Estate Manager Wilfred S Landong East West One Consortium Bhd Abdul Wahid bin Ali Signature/Date: Signature/Date:

26 09 2019 26 09 2019

7.5 CORRECTIVE ACTION REPORTS [CAR]

The following Corrective Action Reports were raised on 26 09 19

1. CORRECTIVE ACTION REPORT (NC/OFI) No. 1 of 5 Date: 26 09 19 1 FINDINGS To be completed by Lead Auditor Standards MSPO MS2530-3:2013 Reference EWOC/AU/ST2/09/19

Criterion 4.1.2: Internal audit

Indicator Requirement Compliance Findings

4.1.2.2 The internal audit procedures and audit ☐ Yes 1. East West One Consortium Bhd [EWOC] results shall be documented and Internal Audit Procedure documented evaluated, followed by the identification ☐ No & approved by CEO dated 01 08 2019 of strengths and root causes of [EWOG MSPO – SP20182028] nonconformities, in order to implement ☒ OFI 2. Internal Audit for EWHPB [no 1 of 2019] the necessary corrective action. conducted on 03 04 2019. Result summary: 74 conformities; 4 non conformities; 44 opportunities for improvement [OFI]. Internal Audit report was comprehensively documented and subsequent actions recorded in a progress GANTT Chart.

However, CAR [corrective action reports] on 4 NC raised but not signed both Auditee & Auditor; also not closed out by Internal Auditor.

2 CLASSIFICATION To be completed by Lead Auditor

Major Non-conformity Minor-nonconformity Opportunity for Improvement (OFI) ☒

Type of follow up Document review (off-site audit and may be charged)

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On site audit (effort required will be charged)

Date 26 09 19 Remarks: (if any)

3 CONFIRMATION To be completed by Company

Finding + classification is correct Yes No

Comments: (if any)

4 ROOT CAUSE(S) of NC / OFI To be completed by Company Remarks: CAR was not signed because the closed of work done was made in CIP Gantt Chart. Estate management already respond and IA has closed the IA CAR.

5 CORRECTIVE ACTIONS TAKEN To be completed by Company Remarks: Action Taken

Date 20 10 2019 Name/Job of Management Rep Jeffery Andrew Signature: Assistant Manager HR 6 CLOSURE of NC / OFI To be completed by Lead Auditor Remarks / Evidence:

As per attached. Noted & verified

Corrective Actions taken to close this NC or OFI has been implemented and found acceptable

Yes No

Confirmed by: Wilfred S Landong Lead Auditor Date:

2. CORRECTIVE ACTION REPORT (NC/OFI) No. 2 of 5 Date: 26 09 19 1 FINDINGS To be completed by Lead Auditor Standards MSPO MS2530-3:2013 Reference EWOC/AU/ST2/09/19

Indicator Requirement Compliance Findings

Criterion 4.4.6: Training and competency

4.4.6.2 Training needs of individual employees ☐ Yes Insufficient Training Need Analysis on individual shall be identified prior to the planning worker and staff. and implementation of the training ☐ No program in order to provide the specific No Training Need Analysis made prior to skill and competency required to all planning and implementation of training ☒ OFI employees based on their job programme on specific skill and competency. description.

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2 CLASSIFICATION To be completed by Lead Auditor

Major Non-conformity Minor-nonconformity Opportunity for Improvement (OFI) ☒

Type of follow up Document review (off-site audit and may be charged)

On site audit (effort required will be charged)

Date 26 09 19 Remarks: (if any)

3 CONFIRMATION To be completed by Company

Finding + classification is correct Yes No

Comments: (if any)

4 ROOT CAUSE(S) of NC / OFI To be completed by Company Remarks:

TNA was prepared HR in HQ. A copy of TNA has been extended to estate management

5 CORRECTIVE ACTIONS TAKEN To be completed by Company Remarks:

Action Taken as per enclosed in the CAR

Date 20 10 2019 Name/Job of Management Rep Jeffery Andrew Signature: Assistant Manager HR 6 CLOSURE of NC / OFI To be completed by Lead Auditor Remarks / Evidence:

Corrective Actions taken to close this NC or OFI has been implemented and found acceptable

Yes No

Confirmed by: Wilfred S Landong Lead Auditor Date: 26 10 19

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3. CORRECTIVE ACTION REPORT (NC/OFI) No. 3 of 5 Date: 26 09 19 1 FINDINGS To be completed by Lead Auditor Standards MSPO MS2530-3:2013 Reference EWOC/AU/ST2/09/19

Criterion 4.5.1: Environmental management plan

Indicator Requirement Compliance Findings

4.5.1.5 An awareness and training programme ☐ Yes Environmental management plan available, shall be established and implemented to however, Awareness training programme on ensure that all employees understand environmental management and improvement ☐ No the policy and objectives of the plans as part of implementation and environmental management and communication policy are on-going however ☒ OFI improvement plans and are working training are yet to be conduct. towards achieving the objectives. Ref: EWOG/MSPO-SP/20192036

Dated 01.01.2019.

2 CLASSIFICATION To be completed by Lead Auditor

Major Non-conformity Minor-nonconformity Opportunity for Improvement (OFI) ☒

Type of follow up Document review (off-site audit and may be charged)

On site audit (effort required will be charged)

Date 26 09 19 Remarks: (if any)

3 CONFIRMATION To be completed by Company

Finding + classification is correct Yes No

Comments: (if any)

4 ROOT CAUSE(S) of NC / OFI To be completed by Company Remarks: Due to tight training schedule, Awareness training was scheduled after the 2nd stage audit as per in the CIP Gantt Chart 5 CORRECTIVE ACTIONS TAKEN To be completed by Company Remarks:

Training and Awareness Meeting was held at Rugading Office on the 15.10.2019

Date 20 10 2019 Name/Job of Management Rep Jeffery Andrew Signature: Assistant Manager HR 6 CLOSURE of NC / OFI To be completed by Lead Auditor Remarks / Evidence:

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Corrective Actions taken to close this NC or OFI has been implemented and found acceptable

Yes No

Confirmed by: Wilfred S Landong Lead Auditor Date: 26 10 19

4. CORRECTIVE ACTION REPORT (NC/OFI) No. 4 of 5 Date: 26 09 19 1 FINDINGS To be completed by Lead Auditor Standards MSPO MS2530-3:2013 Reference EWOC/AU/ST2/09/19

Criterion 4.5.4: Reduction of pollution and emission

4.5.4.1 An assessment of all polluting activities ☐ Yes No available & proper records of assessment shall be conducted, including done/conducted on polluting activities greenhouse gas emissions, scheduled including greenhouse gas emissions, scheduled

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wastes, solid wastes and effluent. ☐ No wastes, solid wastes and effluent.

☒ OFI

2 CLASSIFICATION To be completed by Lead Auditor

Major Non-conformity Minor-nonconformity Opportunity for Improvement (OFI) ☒

Type of follow up Document review (off-site audit and may be charged)

On site audit (effort required will be charged)

Date 26 09 19 Remarks: (if any)

3 CONFIRMATION To be completed by Company

Finding + classification is correct Yes No

Comments: (if any)

4 ROOT CAUSE(S) of NC / OFI To be completed by Company Remarks:

Assessment were made based on SEIA report. All activities has been incorporate into the Environmental Management Plan and monitored through the CIP Gantt Chart

5 CORRECTIVE ACTIONS TAKEN To be completed by Company Remarks: Action taken

Date 20 10 2019 Name/Job of Management Rep Jeffery Andrew Signature: Assistant Manager HR 6 CLOSURE of NC / OFI To be completed by Lead Auditor Remarks / Evidence:

As evidence in the EMP EWOCB-EMP-01. Noted & verified

Corrective Actions taken to close this NC or OFI has been implemented and found acceptable

Yes No

Confirmed by: Wilfred S Landong Lead Auditor Date: 5. CORRECTIVE ACTION REPORT (NC/OFI) No. 5 of 5 Date: 26 09 19 1 FINDINGS To be completed by Lead Auditor Standards MSPO MS2530-3:2013 Reference EWOC/AU/ST2/09/19

Criterion 4.5.5: Natural water resources

4.5.5.1. The management shall establish a water ☐ Yes Water management plan available. Refer: management plan to maintain the

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quality and availability of natural water ☐ No EWOG/MSPO-SP20192067 dated 01.02.2019 resources (surface and ground water). The water management plan may ☐ OFI include: Document sighted and verified.

A Assessment of water usage and sources ☐ Yes No proper record of water usage and of supply. assessment. Plantation uses gravity feed from 900meters away water source. ☐ No

Alternative source of water are rainwater ☒ OFI harvesting.

B Monitoring of outgoing water which may ☐ Yes No monitoring of outgoing water done. No have negative impacts into the natural retention pond built, used water fed to the waterways at a frequency that reflects ground; may cause contamination. ☐ No the estate’s current activities. However construction of retention pond is ☒ OFI noted in the continuous improvement plan.

2 CLASSIFICATION To be completed by Lead Auditor

Major Non-conformity Minor-nonconformity Opportunity for Improvement (OFI) ☒

Type of follow up Document review (off-site audit and may be charged)

On site audit (effort required will be charged)

Date 26 09 19 Remarks: (if any)

3 CONFIRMATION To be completed by Company

Finding + classification is correct Yes No

Comments: (if any)

4 ROOT CAUSE(S) of NC / OFI To be completed by Company Remarks: Work earlier done not documented

5 CORRECTIVE ACTIONS TAKEN To be completed by Company Remarks: Water assessment and monitoring has been compiled into Sustainable Water Management Plan and to be implemented by stages. Implementation is in progress during the audit period. All implementation are monitored via CIP Gantt Chart.

Date 20 10 2019 Name/Job of Management Rep Jeffery Andrew Signature: Assistant Manager HR 6 CLOSURE of NC / OFI To be completed by Lead Auditor Remarks / Evidence: As per the Sustainable Water Management Plan. Noted & Verified

Corrective Actions taken to close this NC or OFI has been implemented and found acceptable

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Yes No

Confirmed by: Wilfred S Landong Lead Auditor Date:26 10 19

NOTE ALL CORRECTIVE ACTION REPORTS WERE CLOSED OUT ON 26 10 2019

8.0 LEAD AUDITOR CONCLUSION & RECOMMENDATION

Based on the Findings/Action taken by Auditee/Closures above, East West One Consortium Bhd [through the sample frame of 3 estates namely Rugading, Kebu Baru & Kituntul Estates] had been able to demonstrate its compliance with the MSPO MS2530-3:2013 Standard for Oil Palm Plantations & Organized Smallholders Therefore, it is recommended that the Initial Certification of East West One Consortium Bhd group of Estates be approved.

Signed for & On Behalf of BQAS CERTIFICATION SDN BHD WILFRED S LANDONG LEAD AUDITOR Dated: 27 10 2019

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9.0 ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY & CONFIRMATION OF AUDIT FINDINGS

This is to acknowledge and confirm the Audit Visits/Assessments described in this Report and the Acceptance of the Contents and Findings in the said Audit Report. Signed for & On Behalf of Auditee, Dated 01 11 2019

JEFFERY ANDREW ASST MANAGER

10.0 CERTIFICATION RECOMMENDATION / DECISION [CERTIFIER]

I/the undersigned, being the Certifier, confirm that I have examined thoroughly all contents of the Report in its’ entirety, including the incorporation of Peer Review comments/report and other related reports [where applicable and relevant]. I confirm that, to the best of knowledge the information and conclusions included in this report have been prepared in compliance with the Standards requirements; and done in good faith and that the certification decision had been based upon this information. I, hereby confirm that, East West One Consortium Bhd be certified and awarded the Certificate under the Standard MSPO2530-3:2013 [Part 3: Standard for Oil Palm Plantations & Organized Smallholders] CERTIFIER: Maxwell S Landong Dated: 25 11 2019

11.0 DATE OF 1ST YEAR SURVEILLANCE AUDIT OCTOBER, 2019

RUGADING KITUNTUL KEBUH MASTER.pdf 3 Rugading Estate 5 Kebuh Estate MASTER.pdf MASTER.pdf maps & legends.docxmaps & legends.docx

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