SGS RSPO Doc. Number: GP 7003A

(Principles & Criteria) Doc. Version date: 01 April 2013 Page: 1 of 68

RSPO PRINCIPLES & CRITERIA CERTIFICATION REPORT

Public Summary Information

Certificate No.: SGS-RSPO/PM-MY10/00514 Project Number: MY01910 Validity Period: 27 Apr 2015 - 26 Apr 2020 RSPO Membership Report Ref. No.: MY01910 Re-Cert Assessment 2-0029-06-000-00 No.: Client Name: Carotino Sdn Bhd Website: www.carotino.com

Purchase of RSPO certified FFB, processing and sales of RSPO certified Crude (CPO) Scope: and (PK) by using IP Module D Supply Chain Option.

Type of Certificate INDIVIDUAL Holder: Number of Mill: 1 Number of Sites: 5 supply base estates CPO Production (MT) -Actual FY2013/2014: 27,464.57 - Estimated FY2014/2015: 33,521.39 Mill Capacity 30 MT/h PK Production (MT) -Actual FY2013/2014: 6,801.62 -Estimated 8,675.28 FY2014/2015: Address: Head Office Contact Person: Head office: Mr Seow Chee Chiang Street and number: Unit 30-08, Mail Box 238, Menara Estate Department/Sustainability Manager Landmark, No.12, Jalan Ngee Heng, Town/City Tel: +607-223 1633 80000, Johor Bahru, Johor State/Country Email: [email protected] Mill Address Zip/Postal code Carotino Palm Oil Mill Country PT 116, Lot No. 3840, Mukim Ulu Lepar Mill Contact Kuantan 26500 Mr. Kenny Alvin Ligunjang ( Mill Manager) Pahang , Tel: +609-4813105 Fax: +609-4813104

Country: Malaysia Plantation Unit Supply Base Name & Address Total Certified Area 10,243.45 ha Being Evaluated: Asia Oil Palm Estate 1 (Ha): Hwa Li Estate 1 FFB Production Hwa Li Estate 2 (MT)

Maran Estate -Actual 136,028.10 Pahang Oil Palm Estate 1 FY2013/2014:

- Estimated FY2014/2015: 163,259 End of Public Summary BASIC EVALUATION INFORMATION RECERTIFICATION- MAIN EVALUATION Evaluation Dates: 6-9 January 2015 Team Leader/Team: Lead: James Ong; Team member: Hoo Boon Han Affiliate Project Manager: Date: Report approved by: Haye Semail Date: 13 Jan 15 Certification approved by: Kenny Looi Date: 29 Jan 15 Database logged by: Othman Shahziela Date: 29 Jan 15 SURVEILLANCE 1 Evaluation Dates: Team Leader/Team: Report reviewed & pre-approved Date: by: Report reviewed & approved by: Date: Certification approved by: Date: Database logged by: Date: SURVEILLANCE 2 Evaluation Dates: Team Leader/Team: Affiliate Project Manager: Date:

Report reviewed & approved by: Date:

Certification approved by: Date:

Database logged by: Date:

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

Report reviewed & approved by: Date:

Certification approved by: Date:

Database logged by: Date:

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

Report reviewed & approved by: Date:

Certification approved by: Date:

Database logged by: Date:

SGS RSPO Doc. Number: GP 7003A

(Principles & Criteria) Doc. Version date: 01 April 2013 Page: 3 of 68

TABLE OF CONTENTS SUMMARY ...... 5 List of Abbreviation ...... 6 1. Scope of certification assessment ...... 7 1.1 National Interpretation Used ...... 7 1.2 Certification Scope ...... 7 1.3 Location and Maps ...... 7 1.4 Description of Supply Base and Mill Processing Capacity ...... 9 1.5 Date of Planting and Cycle ...... 10 1.6 Other Certification Held ...... 11 1.7 Organizational Information and Contact Person ...... 11 1.8 Time-bound Plan for Other Management Units ...... 11 1.9 Area of Plantation ...... 11 1.10 Date Certificate Issued and Scope of Certificate ...... 12 2. Assessment Process ...... 12 2.1 Certification Body ...... 12 2.2 Assessment Methodology, Programme, Site Visits ...... 12 2.3 Qualification of Lead Assessor and Assessment Team...... 14 2.4 Stakeholder Consultation and List of Stakeholders Contacted ...... 15 3. Assessment Findings ...... 16 3.1 Summary of Findings ...... 16 3.2 Corrective Action Request ...... 61 3.3 Noteworthy Positive & Negative Observation ...... 62 3.4 Status of Non-Conformities Previously Identified ...... 62 3.5 Issues Raised by Stakeholders and Findings ...... 62 4. Acknowledgement of Organization Internal Responsibility ...... 63 4.1 Date of Next Surveillance Visit ...... 63 4.2 Date of Closing Non-Conformities ...... 63 4.3 Acknowledgement of Internal Responsibility and Formal Sign-off Assessment Findings ...... 63 APPENDIX A: CORRECTIVE ACTION REQUEST & OBSERVATION ...... 64 APPENDIX B: NON-CONFORMITIES PREVIOUSLY IDENTIFIED ...... 65 APPENDIX C: TIMEBOUND PLAN ...... 66 APPENDIX D: LIST OF STAKEHOLDERS CONTACTED...... 67

LIST OF TABLES Table 1: Mill and Supply Base GPS Location ...... 7 Table 2: Hectareage and Production from Supply Base Estates (FY 2012/13) ...... 10 Table 3: Mill Processing Data (FY 2012/13) ...... 10

SGS RSPO, SGS (Malaysia) Sdn. Bhd., No. 26, Jalan Anggerik Vanilla, 31/93, Kota Kemuning, 40460 Shah Alam, Malaysia CONTACT PERSON: ABDUL HAYE SEMAIL Tel: +6 (03)5121 2320 - Fax: +6 (03)5122 5927 WWW.SGS.COM

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Table 4: Planting Age Profile of the Supply Base ...... 10 Table 5: Area Statement of the Supplying Estates ...... 12 Table 6: Assessment Program ...... 13 Table 7: Auditor Profile ...... 15

LIST OF FIGURES Figure 1: Location Map for Carotino Palm Oil Mill ...... 8 Figure 2: Supply Base Location ...... 9

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SUMMARY Carotino is a member of the vertically integrated J.C. Chang Group of companies with interests in plantations, palm oil mills and downstream processing activities that practices sustainable agriculture. In its downstream activities, Carotino is one of the major players in the oil palm industry producing oil palm- based products for the consumer in the food service and Industrial products, neutraceuticals, feed, oleochemicals and .

Information can be obtained from their website www.carotino.com The group owns and manages four oil palm mill-plantation units known as Production Units, namely: Asia, Carotino, Melewar and Takon Production Units which are under Carotino Sdn Bhd/ J C Chang Group. Presently, three of the Production Units, one of which located in the state of Pahang (Carotino) and two in the state of Sabah , Malaysia, namely Asia and Melewar have been RSPO-certified. This audit is the re-certification audit of Carotino Production Unit. The Carotino Production Unit comprises of 1 palm oil mill and 5 oil palm plantations sited in 2 locations in the State of Pahang, Peninsular Malaysia, covering a total land area of 10,243 hectares. They were recommended for certification against the RSPO P&C MYNI requirements in April 2010.

The Carotino Palm Oil Mill and its supply base estates consist of 5 estates (i.e. Hwa Li Estate 1, Hwa Li Estate 2, Maran Estate, Asia Oil Palm Estate 1, and Pahang Oil Palm Estate 1) with the following legal ownership:  Hwa Li Estate 1 – under 13 different PTs which are lands under the ownership of Syarikat Keratong Sdn Bhd, a wholly owned company under JC Chang Group.  Hwa Li Estate 2 – a single title PT 2389 HSD 2850 owned by Carotino Sdn Bhd, which is under JC Chang Group.  Maran Estate – under 6 titles belonging to Richley Corporation Sdn Bhd, which is under JC Chang Group.  Asia Oil Palm Estate 1 – less than 6 land titles owned by Asia Oil Palm Sdn Bhd, a company under JC Chang Group.  Pahang Oil Palm Estate 1 – land belongs to Pahang Enterprise Sdn Bhd, a wholly owned company under JC Chang Group.

The Carotino Production Unit is divided into two separate location blocks. The first block consists of the Asia Oil Palm Estate 1, Pahang Oil Palm Estate 1 and Maran estate located north of Sri Jaya town. The Carotino Oil Mill is located within this site. Other oil palm estates or natural areas such as a diminishing forest reserves or stateland forests surround this area. At present, iron ore mining companies are mining in the perimeter of the Unit nearby. Their operation of open cast mining, waste water reservoir and transport of the iron ore using trucks has affected the environment and road condition. The second block consists of the Hwa Li Estate 1 and Hwa Li Estate 2 that are located 100 km south of the first block. Hwa Li Estate 2 is located at the tri-state boundary (i.e. Negeri Sembilan, Johor and Pahang), while Hwa Li Estate 1 is further east and borders Hutan Simpan Lesong within Rompin District.

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LIST OF ABBREVIATION Short Form Meanings AOP1 Asia Oil Palm Estate 1 BOD Biological Oxygen Demand CAR Corrective Action Request CHRA Chemical Health Risk Assessment COD Chemical Oxygen Demand CPO Crude Palm Oil CPOM Carotino Palm Oil Mill DID Department of Drainage and Irrigation, Malaysia DOE Department of Environment, Malaysia EFB Empty Fruit Bunch EIA Environment Impact Assessment EMS Environmental Management System EQA Environmental Quality Act ERT Endangered, Rare and Threatened species ESA Environmentally Sensitive Area FFA Free Fatty Acids FFB Fresh Fruit Bunches FR Forest Reserve Ha Hectare HCV High Conservation Value HDPE High Density Polyethylene HL 1 Hwa Li 1 Estate HL 2 Hwa Li 2 Estate IPM Integrated Pest Management ISO International Organisation for Standardisation IUCN International Union for Conservation of Nature and Natural Resources JCC Joint Consultative Committee JUPEM Jabatan Ukur dan Pemetaan Malaysia (Department of Survey and Mapping Malaysia) K Potassium kW Kilowatt M Meter Mg Magnesium Mm Millimeter Mt Metric ton ME Maran Estate MYNI Malaysia National Interpretation N Nitrogen NGO Non Governmental Organisation OA Orang Asli (Indigenous People) OER Oil Extraction Rate OSH Occupational Safety & Health P Phosphate P & C Principles and Criteria PK Palm Kernel POME Palm Oil Mill Effluent POP 1 Pahang Oil Palm Estate 1 PPE Personal Protective Equipment PT Pejabat Tanah (Coding for Pahang Land Office) SOP Standard Operating Procedures Sdn Bhd Sendirian Berhad (Private Limited) SEIA Social and Environment Impact Assessment Sg Sungai SGS Societe Generale de Surveillance SOP Standard Operating Procedures SPC Senior Plantation Controller USECHH Use and Standards of Exposure of Chemicals Hazardous to Health WHO World Health Organisation yr Year GP 7003A Page 7 of 68

1. SCOPE OF CERTIFICATION ASSESSMENT

1.1 National Interpretation Used The operations of the mill and their supply based of FFB were assessed against the Roundtable on Sustainable Palm Oil (RSPO), Principles and Criteria (P&C) – Malaysia National Interpretation (MY-NIWG dated 26th April 2008). RSPO P&C 2013 also use to check against the compliance status.

1.2 Certification Scope The scope of certification includes the production of Carotino Palm Oil Mill and its supply base according to the standard of Roundtable on Sustainable Palm Oil (RSPO), Principles and Criteria (P&C) – Malaysia National Interpretation (MY-NIWG dated 26th April 2008) and RSPO Supply Chain Certification Standard dated 21 November 2014.

1.3 Location and Maps Carotino Palm Oil Mill is located in Sri Jaya, Pahang, Malaysia (Figure 1). More detailed information on the estates location and layouts is shown in Figure 2. The GPS locations of the mill and estates/supply base are shown in Table 1.

Table 1: Mill and Supply Base GPS Location

Mill/Supply Base Latitude Longitude

Carotino Palm Oil Mill N 3.82° E 102. 82°

Asia Oil Palm Estate 1 N 3.82° E 102.78°

Pahang Oil Palm Estate 1 N 3.82° E 102.80°

Maran Estate N 3.73° E 102.83°

Hwa Li Estate 1 N 2.45° E 103.00°

Hwa Li Estate 2 N 2.85° E 102.72°

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Figure 1: Location Map for Carotino Palm Oil Mill

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Figure 2: Supply Base Location

1.4 Description of Supply Base and Mill Processing Capacity The FFB is sourced from five estates which are directly managed by JC Chang Group/Carotino. The actual and projected crop yields from each estate are listed in Table 2 and Table 3 below.

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Table 2: Actual and Projected FFB from Supply Base

FFBs (Tonnage) Estates Actual (FY 13/14) Projected (FY 14/15)

Asia oil Palm Estate 1 41493.44 47242

Hwa Li Estate 1 9703.18 15000

Hwa Li Estate 2 27527.24 35500

Maran Estate 19206.71 22933

Pahang Oil Palm Estate 1 38097.48 42584

Total RSPO certified 136028.10 163259 supply base

Table 3: Actual and Projected Mill Processing Data

Mill Production Figures (MT) (Audited Estate)

Mill Actual (F/Y 13/14) Projected (F/Y 14/15)

CPOs PKs CPOs PKs

POM 27464.569 6801.621 33521.39 8675.28

OER:20.19 % KER:5.00 % OER: 20.53% KER:5.31 %

1.5 Date of Planting and Cycle The age profiles for all the estates are simplified in Table 5 below.

Table 5: Planting Age Profile of the Supply Base

Planting Age (Ha) Name of supplying estate Immature >2 - <5 years >5 - 10 years >10 - 15 years >15 - 24 years ( <2 y-o ) Asia Oil Palm Estate 1 0.00 137.50 378.06 1368.08 65.07

Pahang Oil Palm Estate 1 0.00 112.84 837.90 707.41 177.52

Maran Estate 187.15 954.69 530.45 0.00 112.02 GP 7003A Page 11 of 68

Hwa Li Estate 1 431.89 0.00 1,493.85 0.00 0.00

Hwa Li Estate 2 0.00 0.00 0.00 0.00 1515.95

Total 619.04 1 ,205.03 3 ,240.26 2, 075.49 1, 870.56

1.6 Other Certification Held Carotino Palm Oil Mill and estates are also ISCC-EU Certified

1.7 Organizational Information and Contact Person The company contact person details are as follows:

Name: Seow Chee Chiang

Designation: Estate Department/Sustainability Manager Address: Unit 30-01, Mail Box 300 Menara Landmark, No 12, Jalan Ngee Heng 80000 Johor Bahru, Johor Malaysia Contact No.: Tel: +607 2231633 Fax: +607 2241546 Email address: [email protected]

1.8 Time-bound Plan for Other Management Units Carotino / JC Chang Group is a member of RSPO and has been involved in the certification since 9/5/2006. The membership number with RSPO is 2-0029-06-000-00. Carotino / JC Chang Group owns and operates 4 mills and 17 oil palm estates which are divided and grouped into 4 Production Units covering a total of approximately 38,300 ha in Malaysia. Carotino / JC Chang Group has developed a time-bound plan (Appendix C) for the phased implementation of the RSPO P&C, commencing with Carotino Production Unit in 2009. Carotino / JC Chang Group will use the experience gained from achieving certification for the first two RSPO-certified Production Units to implement the RSPO P&C in parallel for the remainder of its operations. The SGS assessment team considers that Carotino / JC Chang Group is on the right track with its time-bound plan which is considered reasonable and challenging, given the widespread geographic locations of its properties, the resources required and the numbers of smallholders involved

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

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Table 6: Area Statement of the Supplying Estates

Conservation HCV Area Total Titled Name of Estates Mature Immature Others* Area (Ha) (Ha) Area (Ha)

Asia oil Palm 1948.71 0.00 74.94 0.00 117.17 2140.82 Estate 1

Hwa Li Estate 1 1493.85 435.89 45.24 0.00 186.87 2161.85

Hwa Li Estate 2 1515.95 0.00 0.00 0.00 143.26 1659.21

Maran Estate 1213.07 571.24 128.30 0.00 228.21 2140.82

Pahang Oil Palm 1835.67 0.00 62.33 0.00 242.75 2140.75 Estate 1

Total: 8007.25 1007.13 310.81 0.00 918.26 10243.45 Others : Transmission tower, Quarry, Roads, line site, rivers, water catchment area, office building etc.

1.10 Date Certificate Issued and Scope of Certificate The certificate issue date is the date of RSPO approval of this assessment report. This certification scope is [scope of certification]

2. ASSESSMENT PROCESS

2.1 Certification Body Founded in 1878, the SGS Group is the world’s largest auditing, inspection, testing and verification organization. Truly global and benefiting from unique international network of more than 1180 offices, 321 laboratories and 50’000 full time staff, the SGS Group is able to provide its international clientele with a comprehensive range of services in more than 145 countries. SGS has no manufacturing, trading or financial interests which could compromise its independence. Its guarantee of independence, its reputation for professionalism, integrity and impartiality, as well as it remarkable international network, place the SGS Group in a unique position. The RSPO Programme is the SGS Group’s RSPO Certification Programme internationally accredited by the RSPO Executive Board to carry out oil palm plantation and supply chain certification/verification and accreditation for global RSPO certification.

2.2 Assessment Methodology, Programme, Site Visits The assessment was conducted in 6th – 9th January 2015 audit days and involving 2 estates and the Palm Oil Mill of Carotino Production Unit. However due to the uncertainty of the flood situation as well as the rise in the water level of the rivers in Pahang the audit selected the estates based on locality that is not flood-proned. The audit covers documentation review, internal procedures, management system, field inspection as well as identification of any GP 7003A Page 13 of 68

significant issues for both environment or social issues. A sample of stakeholders was consulted during the assessment to get their feedback on the management doing. The assessment was conducted based on random samples and therefore nonconformities may exist which have not been identified. The methodology for objective evidence collection included physical site inspection, observation of tasks and processes, interview with workers, families and stakeholders, documentation review and monitoring data. The assessment program is included as shown in Table 7 below.

Table 7: Assessment Program

Date Location Activities

Arrive and overnight at Muadzam Shah 5th January 2015 Muadzam Shah ( stayed at Muadzam Shah as this period Pahang was affected by flood )

Day 1 Travel to Hwa Li 2

Opening Meeting at Hwa Li 2 & Scheduling

Auditor 1- - external stakeholder ( Kg Pasal, Suburban Properites estate and Mill ) - Boundary stones Hwa Li Estate Div. - Riparian and waterway management - internal 6th January 2015 2 stakeholder interview ( harvesters ) , Field Operation ( workers ), Good Agricultural practices, - Landfill Interview with worker representatives, HA

Document Review

Presentation of Findings for HL 2

Day 2 travel to Hwa Li Estate 1

Auditor 1 - Interview with external stakeholder : Orang Asli community Riparian & Boundary

Field Operation & GAP– Hwa Li Estate Div. 7th January 2015 Interview workers – General Workers 1 IPM Riparian & Boundary Chemical 7 Fertiliser Store, Workshop – Oil Trap - Scheduled Waste Store - Linesite – amenities, drains , dust-bins , toilet, fire-extinguishers - HA clinic

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Auditor 2 – - Replanting - Riparian and buffer zone - Waste management – landfill

Documentation Review - management plans ( water, environmental , social ) , - monitoring documents , -budget, plantation profile, -continual improvement plans - workers profile file Social and environmental plans - Water management plans

Presentation of Findings for Hwa Li Estate 1

Documentation review

Auditor 2 – Carotino Palm Oil Mill Supply Chain Audit, Environment compliance,

Auditor 1 - Permits and Licence - OSH records , Meetings , - environment monitoring and analysis records, 8th January 2015 CPOM - update data for P&C ( fuel and water monitoring ), - worker’s personal file - water management plans - POME appiclation Effluent & Biogas project

Closing Meeting : Presentation of Finding summary and recommendation for Carotino Production Unit – Carotino / JC Chang

End of Audit

2.3 Qualification of Lead Assessor and Assessment Team SGS Malaysia Sdn Bhd holds copies of educational qualifications, certificates and audit logs for each of the audit team members. SGS has evaluated the qualifications and experience of each audit team member and has registered the following designations for conducting RSPO Assessment. Summary of auditors’ educational background and experience are listed in Table 8 below. GP 7003A Page 15 of 68

Table 8: Auditor Profile

Evaluation Team Notes

Team Leader – James S H Ong, B. Agr. Sc is an agronomist by training. He has years experience in the agriculture sector in Malaysia having worked as Assistant Plantation and Plantation Manager in a number of estates in Malaysia. He is well versed with Social agrochemical and fertiliser applications. Has undergone ISO 14000 ,RSPO Lead Auditor training and ISCC and has been involved in a number of audits on oil palm plantations Auditor 2 – Hoo Boon Han is the SGS SEAP Program Coordinator, Bio Fuels Legal, Sustainability. He has successfully completed the RSPO Lead auditor Environment and training course for both P&C as well as the Supply Chain. He Supply Chain experienced in environmental monitoring & audit, carbon accounting & reduction, wastewater treatment, waste management and sustainable development experience across Southeast Asia.

2.4 Stakeholder Consultation and List of Stakeholders Contacted In this re-certification main audit, informal stakeholder consultation took place in the form of meetings and interviews particularly with workers and worker representatives, villages representatives and estates who share the common border with Carotino Production Unit. In all the interviews and meetings the purpose of the audit was clarified at the outset followed by an evaluation of the relationship between the stakeholder and the company before discussions proceeded in accordance with relevant RSPO principles, criteria and indicators. See Appendix D for stakeholder’s details and comments.

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3. ASSESSMENT FINDINGS 3.1 Summary of Findings 3.1.1 Principles & Criteria As outlined, objective evidence was obtained separately for each of the RSPO Indicators and criterion for the mills and estates. The results for each indicator from each of the operational areas were evaluated to provide an assessment of conformity. A statement is provided for each of the RSPO indicators in order to support the findings of the assessment team. There were no Major Non-conformities and no Minor Non-conformities identified during this assessment as the Unit has been committed to compliance to the requirement of RSPO P&C. Some areas identified with potential areas for improvement has lead into 01 Observation raised. Details for each Non-conformities and observations are given in Appendix A and B. If raised, Major Non-conformities has to be closed out within the period of 60 days after the assessment. Minor Non-compliances and Observations will be followed up during the next Annual Audit which is scheduled to be conducted within the period of twelve months.

Principle 1: Commitment to Transparency Criterion 1.1: Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate language & forms to allow for effective participation in decision making. 1.1.1 Records of requests and responses must be maintained. Major

Findings In compliance: Yes: x No: Objective Records of requests and responses for both internal and external stakeholders are kept in the evidence: ‘Stakeholder Request Record’ book which was initiated in 2008. The last request was on 09 December 2014 regarding requested to have some money from workers fund to help their friend who will go back because of unit medical. In Hwa Li 1, the last request dated 25 December 2014 by Harvester- Abd Rasir, request buffalo money to solve his family problems. Response is also recorded in the stakeholder record book. At POM, the guideline on mechanism for information requests by stakeholders (doc ref: E/006- 04/20130 is available dated 07-02-2013 is available.

All requests already addressed and take action accordingly. Criterion 1.2: Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes 1.2.1 Land titles / user rights (C 2.2)

Findings In compliance: Yes: x No: Objective Copies of the land titles are publicly available to proof of ownership. evidence: Hwa Li 2 has 1 title (HSD 2850) with a hectarage of 1,659.21 ha. Hwa Li 1 has 13 land titles with a hectarage of 2161.85ha 1.2.2 Safety and health plan (C 4.7)

Findings In compliance: Yes: x No: Objective The Safety and Health (OSH) Plan Doc Ref No. RSPO Criterion 4.7- Ver.1; doc date: 1-10-2008. evidence: It includes the Safely and Health Policy, frequency of the Safety meetings, function of the committee, Risk Assessment of major operations in the estate, Awareness and Training Programme , appropriate use of PPE, Records of Safety meetings, Accident and emergency Procedures, workers trained in First aid and the availability of the kit at the worksite Similar safety and health plan is available (Doc ref no: P/036-01/2008; dated 1st October 2008) at GP 7003A Page 17 of 68

the mill. The plan includes: a. Safety and health policy b. Risk assessment of Major work operation in Mill c. Appropriate PPEs are used for each risk assessed operation d. Responsible person for safety and health plan e. Records of meetings between person responsible and workers f. Accident and emergency procedures g. Workers trained in first aid present in Mill operations. h. First Aid equipment available at worksite 1.2.3 Plans and impact assessment relating to environmental and social impacts

(C 5.1, 6.1, 7.1, 7.3)

Findings In compliance: Yes: x No: Objective Environmental and Social Improvement Plan evidence: - (Fourth review recorded, reviewed date 05/9/2014; doc ref: N/004-05/2014). It include: a) Aspect Identified b) Impact Identified c) Action Done and Reviewed d) Further action required after review The topic for the plans and impacts assessment covers as below: a. Soil erosion and water management i. Preservation of riparian reserve ii. Protection of steep areas iii. Reduction of potential flood levels. iv. Protection of water resources and quality b. Protection of HCV sensitive area i. Protection of HCV sensitive area ii. HCV Management c. Plantation operation Management i. Minimization of land area disturbance ii. Wastes management and recycling iii. Fire prevention and control iv. Pets and diseases management v. Chemical application and raw water pollution d. Socio-economic consideration i. Provision of employment opportunities to local communities ii. Labor shortage iii. Protection of workers safety and health iv. Employees training v. Provide better living and working condition 1.2.4 Pollution Prevention Plan (C 5.6)

Findings In compliance: Yes: x No: GP 7003A Page 18 of 68

Objective Environmental and Social Improvement Plan evidence: - (Fourth review recorded, reviewed date 05/9/2014; doc ref: N/004-05/2014). It include: a) Area and Place of Pollution ( diesel storage area, workshop , Housing sites , planting areas etc ) b) Action date and reviewed c) Further action after review At POM, guideline on pollution mitigation plans for estates and mill (doc ref: F/011-04/2013; dated: 15th September 2013) is available. The plan covers the mill area, pollutant, type of waste, way of pollutant, quantification, legal requirements/compliance and severity point. For example, the plan has included the mill area such as boiler, effluent ponds and land irrigation.. 1.2.5 Details of complaints and Grievances (C 6.3)

Findings In compliance: Yes: x No: Objective Details of complaints and Grievances is found in the Doc. Ref No: E/001-02/2013 evidence: It includes : a) Matters identified as Grievances b) Matters not identified as Grievances c) Possible Complainants d) Redress of Grievances e) Freedom form retaliation f) General requirement g) Consolidation of Grievances h) Initiating the Grievances Procedure for Employee ( Level 1-4 ) i) Closed meeting j) Time Limit for Grievances k) Records of Grievances l) Corrective Actions m) Administration n) Grievances procedure for Stakeholders and time Limit o) Mutual Agreement by Stakeholders

At POM, the SOP on mechanism for complaints and grievances (doc ref: E/001-04/2013 dated 07-0/2013) is made available during onsite audit.

The SOP defined the matters that could be considered as grievances such as: a. Mill’s or Estate’s administrative policies and procedures b. Inequality or dissatisfaction over wages or working hours c. Job classification and incentive systems d. Unfairness or favoritism e. Arbitrary rules by supervisors f. Layoffs or promotions or transfers g. Safety and health matters h. Discrimination on the basis of sex, race, religion, national origin, age or disability i. Discrimination or retaliation on the basis of the employee’s exercise of his or their personal rights. The training records for all employee year 2013 are available. GP 7003A Page 19 of 68

1.2.6 Negotiation procedures (C 6.4)

Findings In compliance: Yes: X No: Objective A negotiation procedure is found in the Doc Ref No: E/002-02/2012. SOP for identifying legal and evidence: customary rights and identifying people entitled to compensation. It includes: a) Identification of legal and customary rights b) Procedure for calculating and distributing fair compensation c) Documentation of Outcome of compensation 1.2.7 Continuous improvement plan (C 8.1)

Findings In compliance: Yes: X No: Objective The Continuous improvement plan for 2014/15 is available and filed in the Principle 8 : evidence: Continuous Improvement file It include: a) Minimize use of pesticide b) Environmental impact c) Maximizing recycling and minimize waste or by products generation d) Pollution prevention plans e) Social impact

The mill has established action plan for continual improvement shall be based on a consideration of the main social and environmental impact and opportunities for the company.

Such evidence is available in: a. Carotino POM Sustainability Improvement Plan (FY2014/2015) b. Environment Impact Plan (diesel genset with higher efficiency; new of skimmer for biogas incoming c. Social Impact plan (new public toilet; cooling water- Biogas; fencing for staff housing; domestic furniture for executive/staff.

Principle 2: Compliance with Applicable Laws and Regulation Criterion 2.1: There is compliance with all applicable local, national and ratified international laws and regulations. 2.1.1 Evidence of compliance with legal requirements Major

Findings In compliance: Yes: X No: Objective Current valid licenses and permits are framed and displayed in the mill and estate offices and evidence: there is no evidence of non compliance to legal requirement. At Hwa Li 2, the permits and licenses are also found in Hwa Li 2 a) MPOB Licence: 504216292999 ( 01/07/2017 – 30/06/2015) b) Land Title o Hwa Li 2 has 1 title (HSD 2850) with a hectarage of 1,659.21 ha. c) Permit Barang Kawalan Berjadual (Diesel, Petrol, Baja) d) Diesel- PPDNKK Bera 12/58 SK 01/52 P/D from 10-10-2014 to 09-10-2015. e) Lesen Perniagaan Tahun 2013/14; No: 0000062678 f) Lesen penggunaan sumber air 01-01-2015 to 31-12-2015

At CPOM, Evidence of compliance with legal requirements available and made sure is up-to-date

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Type of Licence Dept / Issuing Licence / No. Valid till MPOB 500356604000 31/10/15 for 144,000 MT FFB Carotino Sdn Bhd ( Registered No: 69046-T) DOE License 003216 30/06/15 Permit Barang Kawalan 25/5/15 Berjadual- License for Diesel Storage Trading License L202990136201 29/4/15 Weighbridge calibration 6/11/15, 9/4/15 Machinery Licences JKKP 2/12/2015 Boiler Air receiver Steam Receiver Steriliser Air compressor receiver Vacuum dryer etc Water Licence Pengarah sumber Air 31/12/14 ( submitted for renewal ) Bomba Licence - 10/7/17

Similar permits and licenses are also found in Hwa Li 2

2.1.2 A documented system, which includes written information on legal requirements Minor

Findings In compliance: Yes: X No: Objective A list and copies of legal documents and international treaties and agreements are available, with evidence: changes is tracked through www.lawnet.com.my. The person responsible for monitoring compliance to laws and regulations is formally identified in the guidelines. Hwa Li 2: List of local laws & List of Related International Standards are maintained. List of local laws has been divided into 03 categories as below: 1) Published Malaysia Government Laws & Regulations Governing Oil Palm Industries 2) List of Books on Malaysia Government Laws & Regulations Governing Oil Palm Industries 3) List of Other Related Reference Books

They have included the latest ‘New law on GST 2014. The Unit maintain copy of relevant laws and legislation pertaining to palm oil mill and the plantation operation as per listed in the standard. Observed that the list has been adequately reviewed with the latest revision was conducted on 15 September 2014.

2.1.3 A mechanism for ensuring that they are implemented Minor

Findings In compliance: Yes: X No: Objective A mechanism for ensuring that they are implemented is available. A list of all legal requirements evidence: with the renewal date and license number will be reviewed and updated annually to ensure the requirements are implemented. The unit will refer to the following “SOP on Mechanism to trace changes in legal requirements” (E/005-03/2011) dated 26 Jul 2011

GP 7003A Page 21 of 68

In each estate & Mill a personnel has been appointed to be in charge to track changes to any amendment of all relevant laws

The unit will refer to the following “SOP on Mechanism to trace changes in legal requirements” (E/005-04/2013) dated 07 Feb 2013. In Hwa Li 2, Mr Halimi has been appointed as personnel in charge to track changes to any amendment of all relevant laws.

2.1.4 A system for tracking any changes in the law Minor

Findings In compliance: Yes: x No: Objective evidence: A list and copies of legal documents and international treaties and agreements are available, with changes is tracked through www.lawnet.com.my. The person responsible for monitoring compliance to laws and regulations is formally identified in the guidelines (“SOP on Mechanism to trace changes in legal requirements” (E/005-04/2013) dated 07 Feb 2013). Changes on the laws will be checked through “NewsFlash” in the website http://www.lawnet.com.my In Hwa Li 2, the Trainee Assistant Manager Mr Halimi was appointed in maintaining his appointment to track changes in laws. System for tracking the changes in the law is reflected within the SOP on Mechanism to track changes in the legal requirement is found in Doc. Ref No: E/005-03/2013 ver.4. In addition, the company also has taken action to subscribe to the lawnet for an update of the latest laws and regulation in Malaysia. Evidence of subscription to the www.lawnet.com.my on latest publication / revision in laws. Latest update made by the lawnet to the company dated 15 September 2014 is available. Criterion 2.2: The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights. 2.2.1 Evidence of legal ownership of the land including history of land tenure Major

Findings In compliance: Yes: x No: Objective Copies of land titles are available to show evidence of ownership and tenure. evidence: Evidence of legal ownership of the land including history of land tenure is available.

Hwa Li 2 has 1 land title HSD 2850 as evidence of ownership.

2.2.2 Growers must show that they comply with the terms of the land title. [This indicator Major is to be read with Guidance 2]

Findings In compliance: Yes: x No: Objective evidence: Carotino Sdn Bhd show that they comply with the terms of the land title.

Hwa Li: Checked on H.S. (D) 33 (140 acre). The term stated land use category is for Agriculture specifically for palm oil plantation with 99 years tenure until 12 June 2077. Hwa Li 2: Checked on H.S. (D) 2850 with 1659.21 ha. The term stated land use category is for Agriculture specifically for palm oil plantation with 99 years tenure until 13 Mei 2086.

2.2.3 Evidence that boundary stones along the perimeter adjacent to state land and Minor other reserves are being located and visibly maintained

Findings In compliance: Yes: x No: Objective Boundary stones along the perimeter adjacent to state land , neighbouring estates and other evidence: reserves are maintained. In HL1, the boundary stone neighbouring the Orang Asli community was checked and was found to be correct with the records at the office . N 02° 44’ 06.3” , E 103° 02’ 58.4”. The boundary stone along the perimeter adjacent Forest Reserve Lesong was located and visibly GP 7003A Page 22 of 68

maintained N 02° 43’ 51.9” , E 103° 01’ 05.3”. In Hwa Li 2, Guatamala grass is planted along the boundary with the Kampung Pasal smallholders and stakes with red mark are also placed to indicate boundary lines. In HL1 , electric fence is build along the perimeter due to the persistent intrusion by elephants 2.2.4 Where there are, or have been, disputes, proof of resolution or progress towards Minor resolution by conflict resolution processes acceptable to all parties are implemented. (CF 2.3.3, 6.4.1 and 6.4.2)

Findings In compliance: Yes: x No: Objective The Carotino Production Unit does not have any land disputes. But a system to resolve land evidence: disputes is documented in ‘Complaints and Grievances’ procedure. SOP is available to resolve any land issues and as of today there are no land disputes with the neighbouring estates. All plantations were established in the 1960s and 1970s and they did not diminish the legal rights, or customary rights, of other users in the vicinity at the time of planting Clear physical boundary demarcation with legal land title was observed during site visits. Criterion 2.3: Use of the land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent. 2.3.1 Where lands are encumbered by customary rights, participatory mapping should Major be conducted to construct maps that show the extent of these rights.

Findings In compliance: Yes: x No: Objective All the estates within Melewar Production Unit are with proper legal title. The establishments of the evidence: plantations do not diminish legal or customary rights of any communities. As described earlier, the land is with clear and undisputed boundaries. Clear physical boundary demarcation with legally recognized plan is observed during site visits. In addition there are no dispute/claims by the neighbors on the estate’s land. 2.3.2 Map of appropriate scale showing extent of claims under dispute Major

Findings In compliance: Yes: x No: Objective Maps of appropriate scale available at the site notice board and in the office files. evidence: There are no lands under dispute. 2.3.3 Copies of negotiated agreements detailing process of consent (C 2.2, 7.5, 7.6) Major

Findings In compliance: Yes: x No: Objective SOP for negotiation procedures are available evidence: Currently, there are no claims on legal or customary rights exist for the estate.

Principle 3: Commitment to Long-Term Economic and Financial Viability Criterion 3.1: There is an implemented management plan that aims to achieve long-term economic and financial viability 3.1.1 Annual budget with a minimum of 2 years of projection Major

Findings In compliance: Yes: x No: Objective The estates , HL2 and HL 1 , has a document ‘ Carotino Sdn Bhd , HL Estate Div 2 Financial evidence: Estimate 2014/2015 Book 1 Budget Details ‘

It includes particulars concerning: 1) Manager’s comment 2) Summary & Details Area Statement 2014/14 3) Summary of Overall general charges, Nursery allocation and depreciation 2014/15. 4) Labour Statement , wages and labour Benefit 2014/15 5) Summary of Vehicle expenditure 6) Budget Detail – Capital Expenditure 2014/15 7) Budget detail – Nursery Expenditure 2014/15 GP 7003A Page 23 of 68

8) Budget detail – Mature expenditure activity detail by Division 2014/15 9) Budget detail – Mature expenditure activity detail by Budget Item 2014/15 10) etc In another file the ‘three year projection of FB , OER and Oil Yield 2014/15, 2015/16,and 2016/17 was sighted.

Based on the projection, the FFB Yield for HL2 for the FY 2014/15 is 41,130 MT.

Based on the projection, the FFB Yield for HL1 for the FY 2014/15 is 37,322 MT.

CPOM three year Product projection for FY2015/15 – 2017/18 is sighted in the ‘Commitment to Long-Term Economic and Financial Viability’ file . The projection is reported to be on the down trend due to the estates having high hectareages of young mature crop. The annual budget for CPOM is found documented in the ‘Final Estimate of Expenditure for FY2014/15 ( end 30th June 2015 ) It includes particulars such as : a) estate theoretical estimate extraction ratio table b) crop estimate and summary c) crop monthly estimate d) Mill throughput details e) Labour statement staff f) Proposed salary increment g) Staff payroll and overtime schedule h) Staff EPF and SOCSO contribution summary i) Labour statement workers j) Proposed salary increment for daily and monthly workers k) Workers salary, overtime , SOCSO, EPF, contribution summary l) Building Maintenance schedule m) CAPEX Summary and Details n) Budget details – General charges and overhead o) Machinery maintenance and repair budget summary and details p) Budget vehicle details q) Overall revenue expenditure estimates Based on the projected figure , the amount estimated to be processed for the FY2014/15 is : 2014/15 FFB 163,259 CPO 33,521.39 OER 20.53% PK 8,675.28 KER 5.31%

3.1.2 Annual replanting programme projected for a minimum 5 years with yearly review Minor

Findings In compliance: Yes: x No: Objective evidence: 2014/15 2015/16 2016/2017 2017/2018 2018/19 Asia Oil Palm 0.00 0.00 0.00 0.00 0.00 Estate 1 Pahang Oil 0.00 0.00 0.00 0.00 0.00 Palm Estate 1 Maran Estate 187.15 0.00 0.00 0.00 112.02 Hwa Li Estate 1 0.00 0.00 0.00 0.00 0.00 Hwa Li Estate 2 0.00 271 290 297 285 GP 7003A Page 24 of 68

Total 187.15 271 290 297 397.20

Principle 4: Use of Appropriate Best Practices by Growers and MIllers Criterion 4.1: Operating procedures are appropriately documented and consistently implemented and monitored. 4.1.1 Documented Standard Operating Procedures (SOP) for estates and mills Major

Findings In compliance: Yes: x No: Objective Documented SOPs for both estates and mill , guidelines and works instruction are maintained evidence: to guide implementation of best practices in the estates and the mill The list of SOP for estate and mills is available. In the Estate, the SOP covers the category section such as : A. Oil palm nursery and replanting B. Upkeep and cultivation C. Soil, water and biodiversity conservation & management D. FFB Harvesting and dispatch E. Legal employment, welfare, communication & consultation F. Waste and pollution management G. Vehicles and workshop management H. Store Management I. Building construction and maintenance J. Insurance K. Buffalo Management L. Pest and disease management M. OSH estate N. Estate/mill improvement plan O. Impact register and assessment For the mill the following SOPs are P. OSH Mill Q. SOP Mill 4.1.2 Records of monitoring and the actions taken are maintained and kept for a Minor minimum of 12 months

Findings In compliance: Yes: x No: Objective Records of SOP monitoring and the actions taken are recorded in the form known as ‘ evidence: Pemantauan Prosedur Bekerja dengan Selamat untuk ‘ for the operation such as : a) Penuai Buah b) Pemandu c) Penyembur Racun d) workshop e) Manuring At HL1 , records for the last 12 months was sighted in the files. The regular monitoring of ‘Geng PM98A (A) was sighted . They will check on : a) PPE use b) Appropriate equipment c) Appropriate pole d) Drinking water e) First Aid Kit f) Sickle cover GP 7003A Page 25 of 68

g) Focus h) Distance from palm during harvesting i) Storage of pole and sickle after use

At POM, the monitoring will be conducted on weekly basics using a checklist. . The monitoring area includes: a. Reception station b. Loading Ramp c. Grading Station d. Fruit handling station e. Threshing station f. Press station g. Oil room h. Depericapper station i. Kernel Plant Station j. EFB Pressing station k. Vertical Sterilizer Station Criterion 4.2: Practices maintain soil fertility at, or where possible improve soil fertility to a level that ensures optimal and sustained yield. 4.2.1 Monitoring of fertilizer inputs through annual fertilizer recommendations Minor

Findings In compliance: Yes: x No: Objective Ref: Manuring Programme file. evidence: a) Manuring Costing Book b) Monthly progress report c) Fertiliser Delivery Schedule and Receipt Book  Fertiliser Programme – HL2 for the first 2nd half 2014/15 Financial year ( Jan – June ) is sighted  This is done 6 monthly recommendation by Mr Tan Ah Aia, Agronomist – cum-Consultant for Carotino Production Unit  In the Jan – June 2015 programme the recommendation for HL2 is a) Jan – May 2015 : NK Mix ranges from 2.0 – 3.5 kg b) Mar – May 2015 : Borate ranges from 100-150g The area that has been identified as 2015 replanting e.g PM89A A6 or PM89A7, no application is recommended. HL 1 has similar site specific fertiliser recommendation provided by the agronomist. In HL1 fertiliser recommended for the 2nd half are NK Mix, Korn –Kali 14/8/19/3+0.4B, 10/6/25/4+0.5B, Borate Records of fertiliser input applied is also monitored in the Manuring costing File . for example in the fertiliser recommendation, in Dec 2014, for PR14A, was 1.5 kg of the formula 14/8/19/3+0.4B. In the costing file, showed that 1.5 kg was applied per palm during the Nov- Dec 2014.

4.2.2 Evidence of periodic tissue and soil sampling to monitor changes in nutrient status Minor

Findings In compliance: Yes: x No: Objective  Ref : Principle 4..2 file evidence:  Both soil and leaf sampling results are available and done yearly GP 7003A Page 26 of 68

 In HL2, the results for the latest foliar sampled in 9/10/14 was made available. The result was received on 22/11/14..  The soil sampled was also conducted on the same time . Soil sampling is only done on selected fields. In 2014 for HL2, fields 89A04, 90A04 and 91A05 were sampled.  In Hwa Li 1, foliar and soil samples were taken for analysis on the 11-15/10/14 .  Organic C is being monitored since 2008- 4.2.3 Monitor the area on which EFB, POME and zero-burn replanting is applied Minor

Findings In compliance: Yes: x No: Objective HL2 do not receive EFB or POME as the estate is about 190 km from the mill . evidence: HL1 occasionally receive EFB from their Carotino Mill. Records of delivery and application is found in the EFB file. the last application was done in Nov 2014 . From the record, to-date 37.65 MT/ha was applied in PM98A Blk 2 . EFB Distribution Map is also available POME application record is available at the Mill. POME is applied to fields close to the Mill in POP1 & AOP1 using a sprinkler system covering about 100 ha. Records of the discharge is also recorded at the mill The Boiler Ash is mixed with the EFB and delivered to the estates for mulching purposes Criterion 4.3: Practices minimize and control erosion and degradation of soils. 4.3.1 Documented evidence of practices minimizing soil erosion and degradation Minor (including maps)

Findings In compliance: Yes: X No: Objective Estate has standard operating procedures to minimise soil erosion and degradation. evidence: Documented procedure and guidelines of practices minimizing soil erosion and degradation (including maps) is found in the ‘ Guideline on Soil & Water Conservation Doc C/002-01/2008’ and in C/005-01/2008 Guidelines on Managing steep areas planted with oil palms Maps of individual blocks that shows areas of flat and steep are also available

Slope analysis , calculation and maps available and documented in the Principle 4 is ’ available where it is stated that >25 ° slopes will not be planted. In HL2 , the area >25° of an area of about 10 ha in PM90AB08 has been identified and was left in its natural state of vegetation with minimum maintenance. The slope analysis record show that HL1 do not have area > 25° Topography maps and slope table were sighted at the estate audited

SOP outlines measures on risk assessing existing steep areas, Operational risk, steps and measures to minimise environmental and operational risk and the long term plan for areas with slopes greater than 25 degrees. Documented evidence of minimizing soil erosion through terracing is also available Documents on techniques use are filed e.g. planting of cover-crop, roto-slashing, road maintenance, off-shoot, water diverter and ‘smiling terraces 4.3.2 Avoid or minimize bare or exposed soil within estates Minor

Findings In compliance: Yes: x No: Objective Guideline on Soil & Water Conservation Doc C/002-01/2008’ and in C/005-01/2008 Guidelines on evidence: Managing steep areas planted with oil palms will be referred to as reference to avoid or minimize bare or exposed soil within estates The estates practices selective spraying. Spraying is concentrated around the palm circles, and along the harvesting path especially along the terraces to ease crop evacuation. Bare soils are minimized to reduce erosion as well as for moisture conservation. GP 7003A Page 27 of 68

Evidences of soil erosion control through terracing, digging of silt traps and inter-row frond stacking were observed during the field inspections. It was also noted that palm circle spraying or strip spraying is the normal maintenance while the control of sporadic noxious woodys like Clidemia sp, Hedyotis sp. or even wild yam was mainly done through selective spraying or manual weeding/slashing. The palm area was generally well covered by soft grasses,broadleaves and Stenocleana sp. or Nephrolepis sp. ferns which help to avoid or minimize bare or exposed ground conditions within the estates inspected. 4.3.3 Presence of road maintenance programme Minor

Findings In compliance: Yes: x No: Objective Presence of road maintenance programme is found in the Principle 4 file under the ‘Road evidence: Maintenance’ section In HL2 , the following was recorded in the road maintenance programme:  Road Resurfacing ( till Nov 2014 RM 4,250 was already spent )  Road Grading ( till Nov 2014 RM 14,262 was already spent )  Pot hole filling ( till Nov 2014 RM 2,870 was already spent )  Compacting ( till Nov 2014 RM 0 was already spent )  Culverts – New/Replacement or Repair ( till Nov 2014 RM 433 was already spent )  Water diverter/Off-Shoots( till Nov 2014 RM 6,750 was already spent )  Making New roads ( till Nov 2014 RM 0 was spent )

In HL1 , the following was recorded in the road maintenance programme:  Road Resurfacing ( till Nov 2014 RM 9,860 was already spent )  Road Grading ( till Nov 2014 RM 14,782 was already spent )  Pot hole filling ( till Nov 2014 RM 123 was already spent )  Compacting ( till Nov 2014 RM 0 was already spent )  Culverts – New/Replacement or Repair ( till Nov 2014 RM 1,455 was already spent )  Water diverter/Off-Shoots( till Nov 2014 RM 10,200 was already spent )  Making New roads ( till Nov 2014 RM 0 was spent The road maintenance schedule and monthly expenditure table was also sighted. 4.3.4 Subsidence of peat soils should be minimized through an effective and Minor documented water management programme

Findings In compliance: Yes: X No: Objective As per the earlier certification report and based on the present soil map and estates visited , no evidence: peat are identified . Hwa Li 2 soils series identified are Tebok, Bungor/ Sekutuan Katong Melaka, Durian, Jempol, Sekutuan Katong Segamat , Lunas and Rengam HL1 soils identified are Beserah, Gong, Kerayong, Lanar setempat, Renggam, Tebok, Tai Tak and Tawar

4.3.5 Best management practices should be in place for other fragile and problem soils Minor (e.g. sandy, low organic matter and acid sulphate soils)

Findings In compliance: Yes: X No: Objective Soils are identified. No fragile or problem soils are recorded although sometimes the Rengam evidence: series can sometimes be quite sandy in nature, however it is not classified as a problem or fragile soil. GP 7003A Page 28 of 68

Hwa Li 2 soils series identified are Tebok, Bungor/ Sekutuan Katong Melaka, Durian, Jempol, Sekutuan Katong Segamat , Lunas and Rengam HL1 soils identified are Beserah, Gong, Kerayong, Lanar setempat, Renggam, Tebok, Tai Tak and Tawar POP1 soils series identified : Awang, Colluvium, Kawang, Penambang, Rengam, Tebok, Tok Yong

Criterion 4.4: Practices maintain the quality and availability of surface and ground water. 4.4.1 Protection of water courses and wetlands, including maintaining and restoring Major appropriate riparian buffer zones at or before replanting along all natural waterways within the estate.

Findings In compliance: Yes: X No: Objective Estate is guided by the SOP : Doc No: C/001-02/2009 - Guidelines on Establishment of Riparian evidence: Buffer Zone Estates plants Guatamala grass along the river to prevent soil erosion Sign Boards ‘Zon Penampan’, PVC poles and ‘yellow-marked ‘palms were also evidence on commitment to maintain the buffer zone.

4.4.2 No construction of bunds/weirs/dams across the main rivers or waterways passing Major through an estate

Findings In compliance: Yes: X No: Objective No construction of bunds/weirs/dams across the main rivers or waterways passing through an evidence: estate.

4.4.3 Outgoing water into main natural waterways should be monitored at a frequency Major that reflects the estates and mills current activities which may have negative impacts (Cross reference to 5.1 and 8.1)

Findings In compliance: Yes: X No: Objective  The estates are guided by : Guideline on River Water sampling procedures evidence:  The estate will analyse the result yearly  In HL2 , there are no rivers that flow through the estate. However the estate will sample the river water of Sungai Palong which flows along the boundary for monitoring purposes .  In HL1 , sampling is done on 3 points along the river Sungai Jekatih that flows through the estate. The result was sighted it was reported to be satisfactory complying to WQI Class II  Hwa Li 2 sources their domestic water from a tube well close to 89A. In 2012, they started to pay the State authorities for the extraction.  In the Mill the following are monitored  The final effluent waste water is 100% for land Irrigation / Atas Tanah . The POME is channelled to the neighbouring estates field for land irrigation (sprinkler system) . As such ,there are no outgoing water to waterways for CPOM .  Sampling is done at the final discharge sampling poing ( marked’X’) at the outlet prior to the discharge through the sprinkler system (settling pond outlet) for land irrigation . Analysis is done at the accreditated lab, Makmal Analisa Bukit Goh ( FPISB )  Ref: Effluent Test Certificate file , DOE Quarterly Returns and the BOD,COD & Effluent files  Records the weekly analysis BOD, and meter reading of the outgoing waste water are sighted .  Records of the BOD f or the following quarters are checked. GP 7003A Page 29 of 68

BOD Jul, Aug Sept ‘14 5,5,5 Apr,May, Jun ‘14 3,8,4 Jan, Feb, Mar ‘14 5,4,9 Oct, Nov, Dec ’13 9,6,5

 The effluent discharge is also monitored and records are found in the ‘ETP Influent & Final discharge Meter Reading’ record book and for the month of Dec 2014 the amount discharge is 9,188 m3  The weekly analysis is recorded in the ‘Effluent Testing Certificates: Felda and result for the BOD test in year 2014 is within the range of 500 mgl  Submission of the Quarterly A.S.04 to DOE was also sighted . The mill complies to the quarterly submission required by DOE. 4.4.4 Monitoring rainfall data for proper water management Minor

Findings In compliance: Yes: X No: Objective Rainfall data is available at each individual estate. They are kept in the ‘ Estate Rainfall Record evidence: Book’ .

Division 2012 2013 2014 (till Nov) Asia Oil Palm 2170mm 2636mm 1778.15mm Estate 1 (169days) (165days) (126days)

Pahang Oil 2418mm 2834mm 1801mm Palm Estate 1 (161 Days) (160 Days) (131 Days)

Maran Estate 2544mm 2545mm 1977mm (176 days) (147 days) (113 days) Hwa Li Estate 1 1443mm 2223mm 1150mm (124 days) (143 days) (102 days) 1670mm 1587.30mm 1636mm Hwa Li Estate 2 (133days) (120days) (96days)

4.4.5 Monitoring of water usage in mills (tonnage water use/tone FFB processed) Minor

Findings In compliance: Yes: X No: Objective The domestic water is sourced from the Sg Belayar, treated at the mill and pumped to the estate evidence: for distribution. The monthly water analysis of the raw water used is filed . The Sample A ( upstream ) , sample B ( intake ) and Sample c ( downstream ) results are sighted ad found to be within the limits

The monitoring of daily and monthly water usage is mill is available as below:  For example, for 2014 records Month Jun Jul Aug Sept Oct Nov FFB Processed 10,936.4 13,321.6 11,058.42 11,751.89 11,653.63 14,367.38 5 Boiler usage m3 6461 7335 7418 7669 8899 8021 Processed 11058 12691 13052 13561 14387 15660 usage m3 Water usage 1.16 1.14 1.15 1.31 1.06 1.05 (m3/MT FFB ) GP 7003A Page 30 of 68

In the estates, monitoring of usage and analysis are also conducted. For Hwa Li 2 , in December 2014, the domestic water usage is 327.61 lits / person /day 4.4.6 Water drainage into protected areas is avoided wherever possible. Appropriate Minor mitigating measures will be implemented following consultation with relevant stakeholders.

Findings In compliance: Yes: X No: Objective Effluent water from the mill is for land irrigation and not drained into protected area. evidence:

4.4.7 Evidence of water management plans Minor

Findings In compliance: Yes: X No: Objective Ref: Guidelines on Water Management Plan-West Malaysia doc. Ref No: C/003-01/2008 evidence: a) Riparian Buffer Zone b) Demarcation of Wetland areas c) Soil & Water conservation d) No construction of bunds weir across rivers e) Monitoring of water into main river f) Monitoring water for Household consumption g) Monitoring water for Milling and Household consumption In HL2 , records of water usage monitoring is available . Presently the water is pumped from a tube-well filtered before distributing . In Dec 2014, the usage per month for each worker was 304 lit. CPOM will refer to the above guideline as well as their water management plan is documented in COM-WMP-V2-CPOM (15/3/14 ) . In the mill’s improvement plans, the following were listed : a) Install water flow meters b) Water pond project / water catchment c) New sterilizer system d) Monitoring of water usage e) Change old pipes f) Reduce underground pipe lines

Criterion 4.5: Pests, disease, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques. 4.5.1 Documented IPM system Minor

Findings In compliance: Yes: X No: Objective Ref: Doc L/001-05/2014 (revised 7/8/14): Guidelines on Integrated pest & disease management of evidence: Oil Palm. The SOP / Guidelines include : a) Definition , concept b) Surveillance , Monitoring and Census c) Calibration of chemical application d) Biological control e) IPM for leaf eating caterpillars, rhinoceros beetle, rats, Ganoderma

GP 7003A Page 31 of 68

4.5.2 Monitoring extent of IPM implementation for major pests Minor

Findings In compliance: Yes: X No: Objective As above, IPM implementation involves early detection through regular surveillance and evidence: monitoring of pest population followed by census. Census will provide data to indicate sites or field s where treatment is required and the time of treatment . Biological control use is also monitored e.g. population of barn owl and beneficial plants . For the beneficial plants, areas where it is planted or maintained are found . Records of beneficial plants Turnera sp., Antigonon sp. and Cassia cobanensis were sighted  Recorded in the Pest Damage Census Form  Maps of planting of beneficial plants  Records of maintenance of beneficial plant – weeding Similarly , records of the monitoring of implementation of barn owl are available. The record shows:  Maps of barn owl nest location  Records of occupancy ( HL2 ) a) Date census: 20/12/14 b) Field : PM89A c) No. of boxes : 63 d) Total adult: 54 e) Chicks: 41 f) Eggs : 42 Census is done every 6 months In Hwa Li 2, during harvesting every fortnight, report will be received from the mandore where leaf eating occurrences are sighted . This will be relayed to the management and IPM census will be conducted . Due to the persistent presence of the bagworm, Metisa plana, a ‘bagworm census file ‘ is established. Records of the census from PM89 A09, A10,A11 is sighted . Based on the census done on 17/12/14, record show that the population reached beyond the threshold. On Dec 22, , the estate applied the biological control product ‘ Lipel a.i ‘bt kurstaki’ ’ using tractor mounted high volume power sprayer .for the control instead of using the trunk injection method of control. Census is conducted after the spray to monitor the population and to decide on the next course of action. During this recent application, the application on 22 Dec 2014 was sufficient to bring the population below the threshold. . 4.5.3 Recording areas where pesticides have been used Minor

Findings In compliance: Yes: X No: Objective Recording areas where pesticides have been used are available. evidence: Areas where pesticides are used are recorded in the ‘Stores Issue Chit /Note’ whenever an agrochemical is issued by the store clerk e.g Store Issue chit . When the pesticide/weedicide is used in the operation, the field staff would record the pesticide used in the Estate Costing Book and the Weeding Progress Report file if the chemicals used are herbicides.

In HL2 , the bagworm spraying is recorded in the ‘Bagworm spraying –PM89B’  Recorded in the Costing File and the P&D Census file GP 7003A Page 32 of 68

 E.g. on record on 22 December 2014 ,  Block A9 ,  Pest : metisa plana  Bait used: Lipel  material cost RM 379.00  labour cost RM105.00 ,  total per ha RM 60.54 Similar records were sighted at HL1. The circle spray costing file was checked.  E.g. on record on 31 December 2014 ,  PM02A ,  Pest : weeds aroung the palm circle  Method: Micropur CDA ( ULV )  Chemical Used : Roundup Glyphosate + Amine + Miracle  material cost RM 1690.00  labour cost RM 984.00  total per ha RM 14.00

4.5.4 Monitoring of pesticide usage units per hectare or per ton crop e.g. total quantity of Minor active ingredients (a.i) used/tone of oil

Findings In compliance: Yes: X No: Objective Monitoring of pesticide usage a.i per FFB , per ha and per CPO is recorded . evidence: In the estates, pesticide usage and type of chemical is monitored in the Chemcial Usage file. Monitoring of pesticide usage units per hectare for HL2 is found in the ‘Pesticide usage for the year 2012/13 – 2014/15’ . HL2 monitors individual as well as total pesticide usage per ha. The following is the total a.i / ha monitoring record: Total a.i kg / ha FY2011/12 0.09 FY2012/13 0.81 FY2013/14 ( till Dec 2013 ) 0.40

Similar pesticide usage are monitored in HL 1 Lit a.i per ha FY2011/12 0.96 FY2012/13 0.94 FY2013/14 1 ( increase is due to replanting chemical use )

In the Chemical Usage File, a tabulated table : Monitoring of pesticide usage units per ha & per ton of crop will include the following data: a) Period of monitoring b) Field GP 7003A Page 33 of 68

c) Total treated Area d) Total no. of Rounds e) Total FFB f) Av OER g) Total Oil Yield h) Total Chemical Used, % a.i, Total a.i used/litre a.i used per MT FFB and Oil

Criterion 4.6: Agrochemicals are used in a way that does not endanger health or the environment. There is no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. Where agrochemicals are used that are categorized as World Health Organization Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented. 4.6.1 Written justification in Standard Operating Procedures (SOP) of all agrochemical Major use

Findings In compliance: Yes: X No: Objective Written justification in Standard Operating Procedures (SOP) of all agrochemicals use available is evidence: found in the ‘Princ. 4’ file. The following documents are sighted:  Doc. Ref: B/008-11/2014 Justification for pesticide usage under IPM management ( revised 05/06/2014)  Doc. Ref : B/009-09/2013 “Justification for Weedicides Usage” ( dated 03 Jan 2013 4.6.2 Pesticides selected for use are those officially registered under the Pesticides Act Major 1974 (Act 149) and the relevant provision (Section 53); and in accordance with ESECHH Regulations (2000)

Findings In compliance: Yes: X No: Objective  All pesticide selected for use are those officially registered evidence:  Chemicals and Herbicides used according to local requirements – “Senarai Racun Makhluk Perosak” available in Department of Agriculture website.  Examples of products used are : a) Ally b) Transorb c) Amine 48 & 60 d) Icon e) Nufarm and Roundup Glyphosate f) Ken-Triclopyr g) Hextar 5.5EC h) Lipel 4.6.3 Pesticides shall be stored in accordance to the Occupational Safety and Health Act Major 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations

Findings In compliance: Yes: X No: Objective In HL 1 and HL 2 , pesticides are found to be stored with the necessary requirements in evidence: accordance to the Occupational Safety and Health Act 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations which required the presence and existence of the followings: a) Good lightings b) Adequate natural and fan-ventilation GP 7003A Page 34 of 68

c) Spill kit ( mesocarp fibre ) , dust pan and broom d) Systematic shelving and chemicals segregated based on Class - typed of chemicals e) Lock and key f) MSDS of all products g) Warning /Hazard signs were posted on the doors h) Spill tray i) Weighing scale or calibrated cups j) Available of suitable PPE like mask, gloves, apron k) First aid kit and emergency eyewash l) Emergency shower and a source of water close-by m) Emergency response procedure in case of flood, spillage , accident etc were posted on the notice board. n) At the agrochemical mixing area , equipment like measuring container, funnel etc are present

4.6.4 All information regarding the chemicals and its usage, hazards, trade and generic Major names must be available in language understood by workers or explained carefully to them by a plantation management official at operating unit level

Findings In compliance: Yes: X No: Objective All chemicals information regarding the chemical, usage , MSDS are available at the storage site. evidence: The MSDS is available in local understood languages like English and Bahasa Malaysia In HL2 the following were found to be in place: - CSDS – Chemical Safety Data Sheet translated to Malay language is available at the Chemical Store and understood by the store clerk ,mandore and the pre-mixer Khairul Azhar who is in-charge of chemical handling and mixing. - E.g. “Data Keselamatan Kimia” for Ally 20DF.

4.6.5 Annual medical surveillance as per CHRA for plantation pesticide operators Major

Findings In compliance: Yes: X No: Objective Annual medical surveillance of pesticide operators were viewed and were made available during evidence: onsite audit. In HL2 , the following male spray operators were interviewed and the annual surveillance viewed : a) Akmaludin ( PnD Sprayer ) b) Mangal Mandal Kewat ( Circle Sprayer ) c) Parvez Khan ( PnD Sprayer ) d) Manoj Gurung ( Circle sprayer ) e) Sanjeev Kumar ( Circle sprayer ) According to the assessment by Dr Ling Kay Kwong ,Chemical Health Risk Assessor, Klinik Segamat . They were checked on 26/6/14 and were passed and deemed to be fit. Reference : Pemantauan Perubatan untuk Peracuk racun mahluk Perosak Based on the CHRA, Sprayers, Workshop, Manuring, Genset operators are now involved in the annual surveillance New pesticide operators are only tested after a year of operation. Similarly the pre-mixer , Khairul Azhar who was recently appointed , will be tested after 1 year. In Hwa Li 2 and HL 1 , there are no female sprayers.

For the mill , the last Chemical Health Risk Assessment ( CHRA ) for CPOM was conducted on the 14/1/13 GP 7003A Page 35 of 68

4.6.6 No work with pesticides for confirmed pregnant and breast feeding women Major

Findings In compliance: Yes: X No: Objective In Hwa Li 2and HL 1 , there are no female operators involved in pesticide operation . evidence: For the other estates , if there are female sprayers , they will be tested by the estate HA monthly for pregnancy and they are allowed to work once the test result is negative. Reference : Ladies sprayer and Pregnancy Test’ 4.6.7 Documentary evidence that use of chemical categorized as World Health Minor Organization Type 1A or 1B, or listed by the Stockholm or Rotterdam Conventions and paraquat, is reduced and/or eliminated. Adoption of suitable economic alternative to paraquat as suggested by the EB pending outcome of the RSPO study on IWM

Findings In compliance: Yes: X No: Objective Documentary evidence e.g chemical records and stock card show that WHO Type 1A or 1B class evidence: chemicals are not used. Paraquat has been eliminated from used since 2011 4.6.8 Documented justification of any aerial application of agrochemicals. No aerial Major spraying unless approved by relevant authorities

Findings In compliance: Yes: X No: Objective No aerial spraying unless approved by relevant authorities evidence: 4.6.9 Evidence of chemical residues in CPO testing, as requested and conducted by the Minor buyers

Findings In compliance: Yes: X No: Objective No request by buyers to analyse CPO for chemical residues evidence:

4.6.10 Records of pesticides use (including active ingredients used, area treated, amount Minor applied per hectare and number of applications) are maintained for either minimum of 5 years or starting November 2007

Findings In compliance: Yes: X No: Objective As in 4.5.4, records of pesticide used is available and maintained since the previous certification evidence: 2011. Monitoring of pesticide usage a.i per FFB , per ha and per CPO is recorded . In the estates, pesticide usage and type of chemical is monitored in the Chemcial Usage file. Monitoring of pesticide usage units per hectare for HL2 is found in the ‘Pesticide usage for the year 2012/13 – 2014/15’ .

HL2 monitors individual as well as total pesticide usage per ha. The following is the total a.i / ha monitoring record: Total kg a.i / ha FY2011/12 0.09 FY2012/13 0.81 FY2013/14 ( till Dec 2013 ) 0.40

Similar pesticide usage are monitored in HL 1 lit kg a.i / ha FY2011/12 0.96 GP 7003A Page 36 of 68

FY2012/13 0.94 FY2013/14 1 ( increase is due to replanting chemical use )

In the Chemical Usage File, a tabulated table : Monitoring of pesticide usage units per ha & per ton of crop will include the following data: a) Period of monitoring b) Field c) Total treated Area d) Total no. of Rounds e) Total FFB f) Av OER g) Total Oil Yield h) Total Chemical Used, % a.i, Total a.i used/litre a.i used per MT FFB and Oil

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

Findings In compliance: Yes: x No: Objective Documented of OSH plan is available. Doc. Ref No: P/036-01/2008 Safety and Health Plan. evidence: The plan includes: a) Safety and Health Policy b) Risk assessment of major work c) Appropriate PPE are used for each risk Assessed Operation d) Responsible person for Safety and health Plan e) Records of meetings between responsible person and workers f) Accident and Emergency Procedure g) Workers trained in first Aid present h) First aid equipment available at worksite

A Safety and Health policy is communicated and implemented, ‘ Safety and Health Policy ‘ revised 1st July 2014 All operations have been risk assessed and documented. : Ref : HIRARC file Documented in the Hazard Identification , Risk Assessment and Control ( HIRARC) on Oil Palm Estate daily operation. The latest assessmentfor the mill , CPOM was conducted on the 1/08/14 and the next review will be done in 1/08/2015. According to the ‘Garis Panduan bagi Pengenalpastian HIRARC 2008’ every 3 years ( sekurang2 nya ) Visitors like auditors, prior to a visit are briefed on safety, assembly area in case of evacuation and informed of the Carotino Production Unit’s ‘Standard RSPO Principles for Visitors’ in the office

i) In the training file : Awareness and training programme which includes the following to ensure all workers involved have been adequately trained in a safe working practices ( See also C 4.8)

ii) all precautions attached to products should be properly observed and applied to the workers. iii) The appropriate personal protective equipment (PPE) is used for each risk assessed GP 7003A Page 37 of 68

operation. As in above, HIRARC, the document show also the PPE to be used for the operation e.g. for manuring the PPE to be issued are safety helmet, gloves, PVC apron, dust respirator, safety goggles, long rubber boots. For the CPOM , at the reception , leather glove, safety shoe and Industrial safety helmet are the PPE requirement. The PPE requirement is based on the hazard and risk rating identified . iv) Appointment of person responsible for emergency is also sighted v) The responsible person (s) identified. For HL1 : Mr Lei Wei Tak, Jr Asst Manager appointed 1/1/13 as the OSH Officer. In Hwa Li 2 the OSH officer is Mr Mohd Halimi Zahari , Trainee Assistant., appointed 1/9/14. CPOM has appointed the Mill Manager , Kenny Alvin Ligunjang as the personnel responsible for OSH matters . vi) Organization chart of the OSH committee for each site are available . vii) There are records of regular meetings between the responsible person(s) and workers where concerns of workers about health and safety are discussed. The OSH meetings are conducted 4 times a year. The following are the documented evidence of the meetings:

Estate Date Attendees

26/3/14. 22 attendees

HL 1 25/6/14. 22 attendees

24 /9/14 19 attendees

22/12/14 21 attendees

12/11/14 ( 29th meeting ) 21 attendees

Hwa Li 2 24/9/14 ( 28th meeting 18 attendees

14/5/14 ( 27th meeting 19 attendees

12/2/14 ( 26th meeting 17 attendees

16/12/14 15 attendees

CPOM 9/9/14 15 attendees

2/7/14 9 attendees

13/3/14 12 attendees

viii) Accident and emergency procedures exist at the storage area and instructions are in languages clearly understood by workers. ix) .Workers trained in First Aid are present in both field and mill operations. – Harvesting mandore, Mohd Saizal at HL 2 and En Satrudin , GW mandore was interviewed were found to have first aid kit x) First Aid equipment are also available at worksites e.g. field operatoion , Chemical storage site, Workshop and Office xi) The annual report of occupational accident /dangerous occurrence for the year 2014 will be submitted to the ‘Jabatan Keselamatan & Kesihatan Pekerjaan / JKKP 8 by 31 Jan 2015. Records of submission for 2014 is filed. This was sighted at the estates as well as mill xii) The JKKP 6 was submitted whenever there is an accident and as of 2014 in HL 2 , there was no accident recorded / reported . However in HL 1 , an accident was recorded and the JKKP 6 was submitted on the 14/4/14 for the worker En Abdul Basir, Harvester. xiii) Records of accidents is recorded in the file ‘Statistik Kemalangan pekerja ‘ monitored by the Hospital Assistant, Cik Noorhafini for HL 2 and Cik GP 7003A Page 38 of 68

Syahiedah for HL 1. For CPOM, the records of injuries or accidents is monitored and recorded by the HA,Vijayakumar a/l Kunjiraman based in Asia Oil Palm Estate Div 1. For the mill monthly summary for the clinical medical report records the type of sickness/injury/accident and the number of workers who are inspected. In November 2014 , there were 96 patients .

xiv) The HA will also decide the sick leave for the workers and records at HL1 was sighted xv) For the Mill , CPOM , the audiometry testing report done on 11 March 2014 by ‘Procoma Environmental (M) Sdn Bhd was sighted . Scale of hearing No. of employees Normal 19 Impairment – Mild ( 25 – 40db ) 7 Impairment – Moderate ( 41 – 55db ) 1 Impairment – Moderate Severe( 56 – 70db ) 1 Impairment – Severe( 71 – 90db ) 1 Impairment – Profound (>91+db ) 1 30

In compliance to Regulation 12 of the Factories and machinery ( Noise Exposure ) Regulation 1989, CPOM has conducted an additional Noise exposure Monitoring report on 14/08/14 to prevent employee hearing against the Noise-induced hearing Loss. A layout is available to identify the area with all the different Noise db category 4.7.2 Records should be kept of all accidents and periodically reviewed at quarterly Major intervals

Findings In compliance: Yes: X No: Objective Records of all accidents are recorded in the accident Investigation file and periodically reviewed evidence: at quarterly intervals during the OSH Meeting. The following are the OSH meetings held: Estate Date Attendees 26/3/14. 22 attendees HL 1 25/6/14. 22 attendees 24 /9/14 19 attendees 22/12/14 21 attendees 12/11/14 ( 29th meeting ) 21 attendees Hwa Li 2 24/9/14 ( 28th meeting 18 attendees 14/5/14 ( 27th meeting 19 attendees 12/2/14 ( 26th meeting 17 attendees 16/12/14 15 attendees CPOM 9/9/14 15 attendees 2/7/14 9 attendees 13/3/14 12 attendees

4.7.3 Workers should be covered by accident insurance Major

Findings In compliance: Yes: x No: Objective All workers are covered by accident insurance. GP 7003A Page 39 of 68

evidence: HL2 : - Local employees being covered by SOCSO.

- Foreign workers covered by “Foreign Worker Compensation Scheme”. All the workers have Work Permit and can only be renewed if the workers have the accident insurance. The estate has the files ‘workers Addition and workers Deletion’ to monitor the workers who join and the workers who leave as well as the workers who are renewing their work permit.

In Hwa Li 2and HL 1 , document ‘ Slip Pengesahan Skim Pampasan Pekerja Asing ( SPPA ) shows records of all the foreign workers are covered by the’ Foreign Worker Compensation Scheme’

HL1 HL2 CPOM Total employees 160 135 89 Indonesia 108 112 - Nepal 39 11 47 Pakistan 2 2 - Myammar - - 4 Local 11 10 38

The list workers and the insurance policy for each worker was sighted at HL2 . For example , Abdul Haris is insured under the Insurance policy J14WF01000191JHR-48 Similar records are also sighted in HL1 . For example , Basran and Hasmiati Jumaddin( wife ) are insured under the Insurance policy J14BX22024320JHR issued on 28/10/14

In the Oil Mill , foreign workers are covered by Skim Perlindungan Insurans Kesihatan Pekerja Asing (SPIKPA) by LONPAC Insurance Berhad. In mill, the record of total 51 foreign workers are all covered under insurance was sighted in the document ‘ Details of Foreign workers at 30/12/14)

Criterion 4.8: All staffs, workers, smallholders and contractors are appropriately trained. 4.8.1 A training programme (appropriate to the scale of the organization) that included Major regular assessment of training needs and documentation, including records of trading for employees are kept

Findings In compliance: Yes: x No: Objective The training programme is found to be sufficient as it cover most of the operations and safety evidence: issues . The following are some of the training found in the training programme for each estate : HL 2 Training attendees 11/3/14 First Aid ( Trainer HA ) 19

25/4/14 New workers Training 4

3/6/14 IPM 5 5/6/14 Store and HA on chemical 3 Hazard 14/7/14 Harvesting 60 16/7/14 Selective & circle spraying 3,2 20/9/14 Buffer Zone Awareness 6 The training programme for Hwa Li 2 is on track GP 7003A Page 40 of 68

At CPOM, the training plan on July14 to June 2015 is available. The training plan available for all target groups such as workshop, storage station, weighbridge, oil room and etc. Similarly, training programme for the station such as management, receiving, processing, monitoring, CCP is also sighted. The training includes: a. First aid training b. PPE Training c. SSOP – Manuring d. Chemical Handling e. OSHA training

Training Date of Training Boiler 20/10/14 Oil room 30/11/14 Kernel plant 8/12/14

The employee profile of Ghalan Dawa Sing , Production Operator and Norhayati Yusof , Lab employee training records were sighted .

Principle 5: Environmental Responsibility and Conservation of Natural Resources and Biodiversity Criterion 5.1: Aspects of plantation and mill management, including replanting, that have environmental impacts are identified and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement. 5.1.1 Documented aspects and impacts risk assessment that is periodically reviewed Major and updated

Findings In compliance: Yes: X No: Objective Carotino Production Unit has documented their aspect and impact in the Environmental and evidence: Social Improvement Plan (Fourth review recorded, reviewed date 05/9/2014; doc ref: N/004- 05/2014). The plan is reviewed annually. The topic for the plans and impacts assessment covers as below: a. Soil erosion and water management i. Preservation of riparian reserve ii. Protection of steep areas iii. Reduction of potential flood levels. iv. Protection of water resources and quality b. Protection of HCV sensitive area i. Protection of HCV sensitive area ii. HCV Management c. Plantation operation Management i. Minimization of land area disturbance ii. Wastes management and recycling iii. Fire prevention and control iv. Pets and diseases management v. Chemical application and raw water pollution d. Socio-economic consideration i. Provision of employment opportunities to local communities ii. Labor shortage GP 7003A Page 41 of 68

iii. Protection of workers safety and health iv. Employees training v. Provide better living and working condition. 5.1.2 Environmental improvement plan to mitigate the negative impacts and promote the Minor positive ones, is developed, implemented and monitored

Findings In compliance: Yes: X No: Objective Environmental improvement plan to mitigate the negative impacts and promote the positive ones, evidence: is developed, implemented and monitored. In Hwa Li 2, action done such as river riparian zone is well established and sign of movement for biodiversities observed during site visit. Demarcation and awareness signage for riparian zone’s conservation is visible maintained; the management has carried out selective weeding to maintain and encourage the proliferation of soft grasses and desirable low herbaceous broadleaves on palm. Criterion 5.2: The status of rare, threatened or endangered species (ERTs) and highly conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations. 5.2.1 Identification and assessment of HCV habitats and protected areas within land Major holdings and attempt assessments of HCV habitats and protected areas surrounding landholdings

Findings In compliance: Yes: x No: Objective A final ‘A conservation assessment of Carotino’s Peninsular Malaysian Estates – Conservation evidence: values and recommendations’ dated 22 January 2008 by WildAsia is made available. The report identifies habitat areas of significance within the estates and makes recommendations for their conservation. This includes a timetable for implementation of riverine buffers and suggests support for the conservation of lowland forest and karsts areas surrounding the estates. The report also includes estate level map identifying HCVs within each estate is available. HCV improvement plans for each estate exist and actions that were taken by Carotino to manage and enhance the HCVs (e.g. physical boundary for estate are proper marked and identified. Estate activities are not encroached into state and forest reserve) are documented. However, no HCV available were identified in Hwa Li 1 and Hwa Li 2. 5.2.2 Management plan for HCV habitats (including ERTs) and their conservation Major

Findings In compliance: Yes: X No: Objective Based on the above-mentioned HCV assessment conducted, Carotino has established the evidence: management plan of the HCV habitat identified as well as its conservation. The management plan dated 05 September 2014 highlighted the values identified, the management plan and implementation status of plan. Values identified highlighted within the management plan are as follows:  In Hwa Li 1, Hutang Lesong forest reserve adjacent to estates boundaries which are rich in natural species and habitats provide most of the biodiversities and major rivers Jekatih within or adjacent to estates provide the floodplains, riverine forests and flood retention control to the estates;  Electric fencing was set up at the boundaries adjacent the forest reserve to prevent the instruction of the elephant. Elephant intrusion record is available.  Rivers and streams flowing through the estate provide flood retention controls and water resources to the estates and also provide living ground for natural species and habitats; 5.2.3 Evidence of a commitment to discourage any illegal or inappropriate hunting, Minor fishing or collecting activities and developing responsible measures to resolve human-wildlife conflicts

Findings In compliance: Yes: x No: Objective The management of the individual estates has taken action to discourage any illegal or evidence: inappropriate hunting fishing or collecting activities. This is done through placing signage in appropriate locations e.g at the boundary, riparian / buffer zone and the guard house and briefing GP 7003A Page 42 of 68

workers. Interviewed with the workers and they are aware that hunting is prohibited within the estate. Criterion 5.3: Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner. 5.3.1 Documented identification of all waste products and sources of pollution Major

Findings In compliance: Yes: x No: Objective At estate, wastes and waste products identification and disposal plan (F/007-03/2014) for estates evidence: and mills covered all the area and major waste identified, include the handling methods and disposal plan/mode. The area such as office, dispensary, store, workshop etc. Waste such as used lubricants oil, used filter and chemical drum are well record in the store book. All the schedule waste sends to licensed contractor- Urban Environmental Industries, for example one of the consignment record CN No: 30394 dated 25 December 2014 for the empty drum is made available during onsite audit. At POM, wastes and waste products identification and disposal plan for estates and mills (doc ref: F/007-02/2012; dated 28-04-2012) is available. The records of actual wastes in the mill and estates are documented properly. 5.3.2 Having identified wastes and pollutants, an operational plan should be developed Minor and implemented to avoid or reduce pollution

Findings In compliance: Yes: x No: Objective The guidelines on garbage disposal; (doc ref no: F/006-04/2013; dated 15-08-2013) is available. evidence: The guidelines stated the method of garbage disposal (landfill), collection and disposal of waste materials and handling of waste material. Inspection of Mill confirmed scheduled Waste are stored and disposed in accordance DOE regulatory requirements. Notification of Scheduled Wastes to DOE Pahang dated 09 Dec 2014 is available. The list of raw material/chemicals and quantities used per month and schedule wastes generated per month.

5.3.3 Evidence that crop residues/biomass are recycled (Cross reference C 4.2) Minor

Findings In compliance: Yes: x No: Objective Mesocarp fiber and kernel shell fully utilized to fire the boilers for the generation of renewable evidence: energy. Empty fruit bunches ( EFB) are sent back to the field and used as mulch placed around the palm circles of young palms or along the frond stack in the mature palms fields Criterion 5.4: Efficiency of energy use and use of renewable energy is maximized. 5.4.1 Monitoring of renewable energy use per ton of CPO or palm product in the mill Minor

Findings In compliance: Yes: x No: Objective Renewable energy use are monitored and reported monthly. The monitoring will be used for future evidence: renewable energy management plans. The information has been used to optimized the operation of the mill boiler for electricity generation. The sample of renewable energy use per ton of CPO as below: Fibre usage Shell usage (MT Month CPO ( MT ) RE MT/CPO (MT) ) JUN’14 2,269.59 0.53 0.32 2.51

JUL’14 2,381.95 0.54 0.32 3.08 AUG’14 2,393.62 0.53 0.32 3.10 SEPT ‘14 2,289.31 0.52 0.31 3.35 OCT ‘14 2,724.37 0.53 0.32 3.27 NOV ‘14 2,990.55 0.52 0.32 2.68 GP 7003A Page 43 of 68

The sample of renewable energy use per ton of CPO as below: Dec 2014: per MT of CPO using 1.17 MT EFB; 0.65 MT Nut; 0.32 MT Kernel; 0.34 MT shell and 0.57 MT Fibre. 5.4.2 Monitoring of direct fossil fuel use per ton of CPO or kW per ton palm product in Minor the mill (of FFB where the growers has no mill)

Findings In compliance: Yes: x No: Objective Usage of non-renewable energy recorded monthly is available: evidence: Diesel used per Month CPO Diesel ton JUN’14 2269.59 17359 7.65

JUL’14 2381.95 22,053 9.26 AUG’14 2393.62 23,104 9.65 SEPT ‘14 2289.31 24,247 10.59 OCT ‘14 2724.37 25,371 9.31 NOV ‘14 2990.55 16,722 5.59

Criterion 5.5: Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN Guidance or other regional best practice. 5.5.1 No evidence of open burning. Where controlled burning occurs, it is as prescribed Major by the Environmental Quality (Declared Activities) (Open Burning) Order 2003

Findings In compliance: Yes: x No: Objective No evidence of open burning during onsite audit. evidence: 5.5.2 Previous crop should be felled/mowed down, chipped/shredded, windrowed or Minor pulverized/ploughed and mulched

Findings In compliance: Yes: x No: Objective Felled palms are chipped and placed between the planting rows. evidence: 5.5.3 No evidence of burning waste (including domestic waste) Minor

Findings In compliance: Yes: x No: Objective Inspection of the mill and housing, workshop and estates confirmed no fire has been used for evidence: burning of waste. Criterion 5.6: Plans to reduce pollution and emissions, including greenhouse gases are developed, implemented and monitored. 5.6.1 Documented plans to mitigate all polluting activities (Cross reference C 5.1) Major

Findings In compliance: Yes: x No: Objective Guidelines on pollution mitigation plans for estates and mill (Doc ref: F/011-02/2010; dated 11th evidence: July 2010) is available. Environmental and social improvement plan (doc ref: N/004-04/2014; dated 05/09/2014) has documented all the impact identified, action done and further action requires.

5.6.2 Plans are reviewed annually Minor

Findings In compliance: Yes: x No: Objective The environmental and social improvement plan is reviewed annually up to date 25/7/2014. evidence: Greenhouse gas emissions assessment (April 2013- June 2014) is available which include the activities such as FFB transportation, emission from POME, and chemical usage. The GHG Value for 2013/2014 is 1124 kg CO2EQ/MT FFB.

GP 7003A Page 44 of 68

Monthly POME test report submission of the report for the month of October 2014 to DOE (ref: AS31152/233 dated 01/01/2014-31/03/2014 was verified.

Notification of Scheduled Wastes to DOE Pahang dated 09 Dec 2014 (ref: AS:C31/152/000/042) is available. The list of raw material/chemicals and quantities used per month and schedule wastes generated per month.

No burning observed within the mill area. 5.6.3 Monitor and reduce peat subsidence rate through water table management (Within Minor ranges specified in C 4.3)

Findings In compliance: Yes: X No: Objective No peat soil evidence:

Principle 6: Responsible Consideration of Employees and of Individuals and Communities by Growers and Millers Criterion 6.1: Aspects of plantation and mill management, including replanting, that have social impacts are identified in a participatory way and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored to demonstrate continuous improvement. 6.1.1 A documented social impact assessment including records of meetings Major

Findings In compliance: Yes: X No: Objective Documented Social and Environmental Impact Assessment (SEIA) dated 14 January 2009 is evidence: available stating a comprehensive documentation that includes impact identified following to the assessment, the mitigation measure and action to be taken to mitigate the impact as well as the maps and identification of communities of and stakeholders surrounding each estates. In addition, the assessment also includes maps identifying all the stakeholders. The impacts that has been highlighted are as follows:  Occupational safety;  Workers health;  Workers working condition;  Safety and health of women workers;  Workers wages;  Term of employment;  Workers living condition;  Labour contract; and  Other issues. Annually, each estate and mill does a revised Environmental and Social Improvement Plan to monitor the issues raised in the Social and Environmental Impact Assessment (SEIA) dated 14 January 2009. This was sighted at both CPOM, HL1 & HL2

6.1.2 Evidence that the assessment has been done with the participation of affected Minor parties

Findings In compliance: Yes: X No: Objective All records of meetings, consultation takes place during the SEIA is incorporated in the evidence: assessment document. List of the stakeholders consulted are also available The Unit takes the effort to visit the external stakeholders. In 2014 the following stakeholders were met : a) Kg Pasal Community 31/12/14 GP 7003A Page 45 of 68

b) Prosper Estate / Bukit Kerisek 31/12/14 c) Lading Pertanian 31/12/14 For HL 1 the following stakeholders were met : a) Suburban Properties Sdn Bhd ( neighbouring estate ) : 5-6 January 2015 b) Lum Trading ( neighbouring estate ) : 5-6 January 2015) c) Kuantan Trading ( neighbouring estate ) : 5-6 January 2015) d) Kimah a/l Alai ( representative Orang Asli settlement beside F99B ) e) HL 1 estate shopkeeper and canteen operator

6.1.3 A timetable with the responsibilities for mitigation and monitoring is reviewed and Minor updated as necessary

Findings In compliance: Yes: X No: Objective The annual and revised Environmental and Social Improvement Plan ( N/004-05/2014 ) dated 05 evidence: September 2014 specifies issues and strategies to be implemented on a yearly basis in relation to the social impact assessment. The action plan is found to be reviewed on a yearly basis. The Action Plan the aspect identified, Impact identified, action done and reviewed, further action require after review specifies the responsible person to implement and the timeframe for the action plan to be conducted for each of the following identified aspects:  Provisions of employment opportunities to local communities;  Labour shortage;  Protection of workers safety and health;  Employees training; and  Provide better living and working condition  Implementation of Minimum wages Order  Anti-corruption The Administrative Officers of the individual estate is responsible for the timetable with the responsibilities for mitigation and monitoring. In HL1 , Ms Abhirami is responsible for the monitoring. For CPOM, the AO, Ms Norzilawati , has been appointed for its mitigation and monitoring is reviewed and updated as necessary Criterion 6.2: There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties. 6.2.1 Documented consultation and communication procedures Major

Findings In compliance: Yes: X No: Objective There is a Standard Operating Procedures (SOP) on Mechanisms for Communication and evidence: Consultation established for the purpose of conducting the consultation with employees and other stakeholders. The document E/004-05/2014 dated 03 September 2014 specifies the following identified mechanism for communication and consultation:  Joint Consultative Committee (JCC) be established covering the following items: o Objectives of the committee; o Membership of the JCC Meeting; o Selection of Committee Representatives from Workers; o Frequency of the Meeting i.e. once every three months; o Agenda of the Meeting; and o Actions to be taken on matters discussed.  Complaints and Grievance Procedures: GP 7003A Page 46 of 68

o The document E/001-04/2013 dated 07 February 2013 has been established as a means to channel communication and consultation for the workers; other internal as well as external stakeholders to resolve any issues raised  Suggestion box: o To be used as another means for communicating and consulting with workers as well as other external stakeholders; o The Manager has been appointed as the designated person to open the box once every week to ensure the confidentiality of the correspondence. The correspondence received shall be filed separately from other correspondences.  Nominating the officer for handling the communication and consultation: o Manager is designated as the main contact person responsible for any issues pertaining to communication and consultation. In addition, the above document also specifies the mechanism for Gender Group Consultation covering the following elements:  Membership of the committee:  Selection of committee members and representatives from female workers: o The company gives full liberty to the workers to elect their own representatives. All appointed committee members are found to have been officially appointed through evidence of appointment letters.  Frequency of the meeting i.e. at least two times a year;  Agenda of the meeting; and  Actions to be taken following matters discussed

6.2.2 A nominated plantation management official at the operating unit responsible for Minor these issues

Findings In compliance: Yes: X No: Objective As stated in the above document, the Manager and the Assistant ( 1/9/14 ) have been appointed evidence: as the designated person responsible for any issues pertaining to communication and consultation. For HL2 , the Assistant is also appointed on the 1/9/14 for this role besides the manager and in HL1 the AO is the person responsible besides the manager. CPOM has nominated the AO, Ms Norzilawati , for communication with the stakeholders e.g FFB suppliers, etc. With regard to receiving of complaints, the Assistant Manager of each of the estates has been designated as a responsible person to receive all complaints and grievances raised by any stakeholders. In practice, Mr. Seow Chee Chiang (Estate Department Manager (Admin. / Sustainability)) handles all social issues for Carotino Production Unit when manager fails to solve the issues within timeframe given. There is also the Joint Consultative Committee (JCC) that are participated among others by Workers representatives, one each from harvesting, spraying, manuring, LF collection, general workers and female representative. 6.2.3 Maintenance of a list of stakeholders, records of all communication and records of Minor actions taken in response to input from stakeholders

Findings In compliance: Yes: x No: Objective List of stakeholders at estate and mill level as well as records of communication is available in the evidence: external communication record book. In HL1, the list has been updated on the 9/12/14 and CPOM updated the list on 31/10/14 With regard to the list of stakeholders, Carotino Production Unit maintained the stakeholders list that includes GP 7003A Page 47 of 68

a) Supplier of material and services b) Statutory bodies c) Local communities d) Neighbouring Estates and Mills e) Contractors f) NGO

The stakeholder meetings for 2014 for CPOM was conducted on 21/1/14 and attended by the managers of the estates, Mining company, Timber company, quarry operator. Issues discussed are; a) Mudflow issue b) Dead ‘Tualang ‘ tree on the road c) Road maintenance d) Clogging of drains due to sedimentation e) Washing bay for Mining company trucks On 11/3/14 , CPOM has meeting with their FFB supply estates to discuss: a) Mill performance b) Harvesting Interval c) Labour Matters d) Rainfall record e) Rates for road resurfacing f) Machinery sharing g) Alternative road h) Transfer of Estate asset i) Slide presentation on Palm Mounting j) Demo on the use of motorized cutter ‘Smart Cut ‘

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

Findings In compliance: Yes: X No: Objective There is a Standard Operating Procedures (SOP) on Mechanisms for Communication and evidence: Consultation established for the purpose of conducting the consultation with employees and other stakeholders. The document E/004-06/2014 dated 31 December 2014 specifies the following identified mechanism for communication and consultation:  Joint Consultative Committee (JCC) be established covering the following elements; o Objectives of the committee; o Membership of the JCC Meeting; o Selection of Committee Representatives from Workers; o Frequency of the Meeting i.e. once every three months; o Agenda of the Meeting; and o Action to be taken on matters discussed.  Complaints and Grievance Procedures: In addition, the company also has established the SOP on Mechanism for Complaints and Grievances. SOP on Mechanism for Complaints and Grievances (Ref No. E/001-04/2013) dated GP 7003A Page 48 of 68

07 February 2013 has been established as a means to channel communication and consultation for the workers; other internal as well as external stakeholders to resolve any issues raised. Observed that the mechanism has been explained to all stakeholders and had been agreed by everyone The document describes the following procedures:  Matters that could be considered as Grievances:  Matters that could not be considered as grievances:  Possible complainants of grievances:  Redress of grievances:  Freedom of retaliation:  General requirements:  Consolidation of grievance:  Initiating the grievance procedure for employees:  Closed meeting:  Time limit for grievances:  Records of grievances:  Corrective actions:  Administration JCC Meeting is conducted on a quarterly basis. Evidence of meeting conducted is available in the form of Minutes of Meeting. Based on records, since last Annual Surveillance Audit, Carotino has held the JCC meetings as follows: Estates Date Hwa Li 1  26/3/14.  25/6/14.  24 /9/14  22/12/14. Hwa Li 2  12/11/14  24/9/14  14/5/14  12/02/14 CPOM  16/12/14  29/8/14  15/5/14  10/02/14

6.3.2 The system resolves disputes in an effective, timely and appropriate manner Minor

Findings In compliance: Yes: X No: Objective The established grievances procedures specify the estimated time required to be taken for each evidence: of the process, to be addressed before proceed to the subsequent process. As stated in the documented procedures, all grievances need to be addressed within 10 working days. As above , JCC Meeting were conducted on a quarterly basis. Evidence of meeting conducted is available in the form of Minutes of Meeting. The minutes of the Meetings mentioned above is maintained and made available to the auditing team during the surveillance audit. 6.3.3 The system is open to any affected parties Minor

Findings In compliance: Yes: X No: Objective Communication to the affected parties is evidenced. For instance, any internal social issues is evidence: communicated through either Gender Committee (for women issues) or during briefing during daily Muster Call or during the Safety and Health Briefing. GP 7003A Page 49 of 68

With regard to the external issues, the issues are communicated during the meeting with external stakeholders conducted between the estates/mill and the relevant stakeholders. Criterion 6.4: Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions. 6.4.1 Establishment of a procedure for identifying legal and customary rights and a Major procedure for identifying people entitled to compensation

Findings In compliance: Yes: X No: Objective The SOP for Identifying Legal and Customary Rights and Identifying People Entitled to evidence: Compensation (E/002-02/2012) dated 11 September 2012 is maintained and made available to the auditor during the audit. The SOP included the following elements:  Procedure for Identifying Legal and Customary Rights:  Procedure for Calculating and Distributing Fair Compensation: and  Documentation on outcome of compensation. Nevertheless, this procedure is not applicable to Carotino Production Unit as the estates do not have any issues on customary rights with their immediate neighbouring communities or villagers.

6.4.2 A procedure for calculating and distributing fair compensation (monetary or Minor otherwise) is established and implemented. This takes into account gender differences in the power to claim rights, ownership and access to land; and long- established communities; differences in ethnic groups’ proof of legal versus communal ownership of land. Findings In compliance: Yes: X No: Objective The SOP document (E/002-02/2012) specifies the procedures that need to be followed for evidence: calculating and distributing land claims covering the ownership, claim rights and access to land as well as period of settlement of local communities on the claimed areas. Section 3.0 of the above-mentioned SOP document specifies the procedures that need to be employed for calculating and distributing land claims covering the ownership, claim rights and access to land as well as period of settlement of local communities on the claimed areas. In addition, the procedure also describes the means in resolving the grievance that covering the usage of arbitrator and legal means if the issues cannot be resolved by direct negotiations. As stated in 6.4.1 above, this procedure is irrelevant for Carotino Production Unit as the estates do not face any issues on this particular matter.

6.4.3 The process and outcome of any compensation claims is documented and made Minor publicly available

Findings In compliance: Yes: X No: Objective There is no reported case of dispute with any parties which have resulted in payment of evidence: compensation ever occurred. The individual estates recognised management by customary users and provide material support for the maintenance and places of worship (Muslims ( surau ) , Chinese ( tokong ) and Hindu) located within the estate’s land. Carotino Production Unit do not have such compensation issues Criterion 6.5: Pay and conditions for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages. 6.5.1 Documented of pay and conditions Major

Findings In compliance: Yes: X No: Objective Guidelines on Terms and Conditions of Employment for Estate Workers are available. The evidence: guidelines (E/007-03/2013) dated 08 February 2013 include the following elements:  contract agreement and minimum wages policy  wages and other employment benefits, GP 7003A Page 50 of 68

 workers’ repatriation, and  workers’ passport. In addition, the Employment Agreement and related conditions is available. Furthermore, the company also has established a terms of reference or signed contracts between employers and employees stipulating among others the following items:  workers reference no.;  name of the workers;  IC no.;  Date of birth;  Permanent address;  position of the workers,  working hours,  Position/occupation,  Date of commencing employment;  Rate of wages,  Overtime and other allowances,  holidays,  rest days,  annual leave,  fringe benefits, and  dismissal. As for the foreign workers, personnel information is kept in appropriate file with details on the rate of payment and benefits. For foreign workers, employment contract kept contain details of the following information:  workers reference no.;  name of the worker;  passport no.:( foreign workers ) , IC no. (local workers);  date of birth;  nationality;  date of commencing employment  Position/occupation,  bayaran cuti umum / payment during public holidays  elaun kehadira;/ attendance allowance  faedah sementara;  vacation leave pay;  deduction i.e. advance request, KWSP and SOCSO (local workers);  minimum basic wages,  shift allowance;  dismissal;  average overtime per month,  yearly medical check-up,  leave benefits; and  Insurance. GP 7003A Page 51 of 68

Clear and transparent remuneration system is in place. Workers were issued with pay slips every time salary payment is made where wage and deduction made is clearly printed. In the estates, the wage rates of different categories of harvesting activities are available. The wage rates may differ slightly between estates depending on the terrains and difficulty of task. In practice, the payslips states the following: Several payslips for harvester and sprayer workers are inspected. Estate worker Work type Month Salary (RM) Hwa Li 2 Ramesh Harvester Nov 1,894.02 Hwa Li 2 Supriyanto Harvester Nov 2,350.70 HL 1 Sahdi Harvester Dec 2014 1,599.97+982.52 HL 1 Rajbanshi Sarat General Worker Dec 2014 1,041.93+490 Lal HL 1 Anita Ibak General worker Dec 2014 910+490 CPOM Ghalan Dawa D07/P36 Nov 2014 1,968.75 Sing Production Operator

6.5.2 Labour laws, union agreements or direct contracts of employment detailing Minor payments and conditions of employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc) are available in the language understood by the workers or explained carefully to them by a plantation management official in the operating unit Findings In compliance: Yes: No: Objective The employment documents are established and made available in Malay language. With regard evidence: to the foreign workers, the documents are articulated to them via the mediator which is their senior who is able to speak in Malay. The employment documents known as ‘Kontrak Pekerjaan ‘ that are verified are as follows: a) Date of contract b) Estate Name c) Name of worker d) Passport Number e) Definitions / Terjemahan f) Appointment g) Work/ Pekerjaan h) Waktu Kerja / working Hours i) Rates and allowance j) Overtime k) Housing l) Medical and Fomema m) Insurance n) Govt Levy o) Transport p) In case of Death q) Public Holiday ( 5 compulsory + 8 days ) , emergency leave , annual leave r) Training s) Probation ( Tempoh Penyesuaian) t) Contract Period u) Prohibition (Larangan –Larangan) GP 7003A Page 52 of 68

v) Termination of contract w) Compensation x) Long service leave y) Signature of Management , worker and witness

 Employment Agreement;  Terms of reference;  Signed contracts between employers and employees;

In the employee file , the following documents were sighted : a) Daftar Pekerjaan b) Kontrak Plekerjaan & Syarat Pekerjaan c) Persetujuan passport di simpan oleh Majikan d) Salinan Passport e) Matrix Latihan f) Others (Lain-lain ( surat amaran, Latihan Bulanan dll ) ) The Public holiday for 2015 is already posted at the a) Office notice board b) Provision shop c) Line-site The 5 compulsory public holiday is recorded in their ‘Kontrak Pekerjaan ‘ e.g. CPOM has an official list of the paid public holiday for the workers. The public holiday for the Hindus, Muslim and Chinese are differentiated. However , it was noted that in the document ‘ Butir-butir peribadi( personal particular ) of each worker the differentiation was not done in accordance to their religion/races. OBSERVATION 01 6.5.3 Growers and millers provide adequate housing, water supplies, medical, Minor educational and welfare amenities in accordance with Workers’ Minimum Standard of Housing and Amenities Act 1990 (Act 446) or above, where no such public facilities are available or accessible (not applicable to smallholders) Findings In compliance: Yes: X No: Objective All estate workers and employees are provided adequate housing ( 2-4 workers per house ) , evidence: medical, educational and welfare amenities and waste disposal facilities in accordance with Workers’ Minimum Standard of Housing and Amenities Act. In HL1 and Hwa Li 2 , the water and electricity is provided free to the workers. Since the estate electricity is run on genset, the workers are aware of the times when electricity is available. Disposal of domestic solid wastes at the linesite is conducted at least twice a week. In addition, the company also encouraged and promotes on the segregation and recycling of domestic wastes at the line sites and work places. During interview with some workers , the toilets in their houses are not clogged . The drainage system is maintained and the drain water is freeflowing. The Hospital Assistant is also appointed to do routine helath and sanitation check to make sure the workers and employee are maintaining adequate standard of hygiene and cleanliness around the houses provided by the company. CPOM also provide adequate housing for their employees. They are also provided with 24 hour of treated piped water, overhead water tank , 24-hour electricity . The mill supervisor will arrange domestic waste disposal twice in a week to the landfill in AOPE 1. GP 7003A Page 53 of 68

Criterion 6.6: The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel. 6.6.1 Documented minutes of meetings with main trade unions or workers Major representatives

Findings In compliance: Yes: X No: Objective Joint Consultative Committee has been established where the Manager of the estate has been evidence: appointed as the chairman of the committee. All matters discussed concerning the workers rights i.e. safety, health, minimum wages, child labour and anti-discrimination during the meeting is channelled via the committee.

With regard to the workers representative, the auditor observed that workers representatives (each representing the workers groups of the workers i.e. workers’ nationality such as Indonesian, Myanmar, Nepal and local as well as their working field) are a member of the committee that has been elected in a democracy manner through voting process by their colleague workers.

Based on interview made with the workers representative, it is found that they have set up their own committee among themselves to discuss issues concerning their rights i.e. workers welfare, benefits, wages etc. All of the issues arise is subsequently being brought up to the JCC Meeting to be discussed with the management.

In addition, the interview conducted also confirmed that currently, all matters concerning their rights are channelled via the committee through their respective representative who is the member of the committee. The auditor also observed that their representatives are elected through a voting process among the workers that is conducted in democracy manner. Based on record, for 2014, the Carotino Production Unit has conducted the following JCC meetings: Estates Date HL1  26/3/14.  25/6/14.  24 /9/14  22/12/14.. Hwa Li 2  12/11/14  24/9/14  14/5/14  12/02/14 CPOM  16/12/14  29/8/14  15/5/14  10/02/14 Each estate and mill will appoint worker representatives , elected by the workers to attend the meetings. In the mill , the following were appointed : Name Nationality Phyo Wai Myammar Hari Narayanan Nepal Nor Hasni Local Mr R Munain ( supervisor ) Local and mill workers

For HL 1 the following are the representatives: Name Nationality Satrudin, Mahyudin, Rustam Indonesian GP 7003A Page 54 of 68

Dik Bir Rai Nepal

6.6.2 A published statement in local languages recognizing freedom of association Minor

Findings In compliance: Yes: X No: Objective In all estates and mill, a published statement in local language recognising freedom of association evidence: was placed on the notice board of the management office. The statement reads “Pekerja-pekerja bebas untuk mengikut atau menyertai mana-mana agensi berdaftar di bawah undang-undang Malaysia. Kenyataan ini adalah sebagai tambahan kepada kontrak pekerja yang sedia ada. Daripada Pihak Pengurusan” , ” which means “ workers are free to follow or participate in any agencies registered under the Malaysian laws. This statement is an addition to the existing workers’ contract from the Management”.

Criterion 6.7: Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programmes. Children are not exposed to hazardous working conditions. 6.7.1 Documented evidence that minimum age requirement is met Major

Findings In compliance: Yes: X No: Objective No evidence of underage workers. The company maintained a complete list of workers with the evidence: qualification age information. Carotino has a policy that does not employ persons under 18 years old. Verification within the employment and personal information of workers records evidenced that all workers employed within the mill and estates are above 16 years old hence confirming that there is no evidence of use of child labour within the company’s mill and estate operation.

In HL1, based on the records the youngest in HL1 is 20 years old. He is Fathur Rahman Criterion 6.8: Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation union membership, political affiliation or age is prohibited. 6.8.1 A publicly available equal opportunities policy Major

Findings In compliance: Yes: X No: Objective No cases of discrimination are reported. Interview with the different nationalities in the estates evidence: show that the company treats all workers equally. Equal Opportunities Policy is documented and is translated into the Malay language (Polisi Kesamaan Peluang) 1/7/12 and placed on the notice boards of the management offices. Observations indicated that the policy is put into practice

6.8.2 Evidence that employees and groups including migrant workers have not been Minor discriminated against

Findings In compliance: Yes: X No: Objective There is no evidence which confirmed the discrimination against foreign workers. Based on evidence: records, the auditing team observed that equal opportunities are demonstrated through the following issues:  similar daily wages for foreign workers and local workers ( e.g. RM35 per manday )  working hours where similar treatment is given between both the foreign and local workers.  On basic amenities whereby both foreign and local workers received similar facilities.  Well representation of JCC Meeting between both foreign and local workers  Well representation of Gender Committee meeting between foreign and local workers Criterion 6.9: A policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied. 6.9.1 A policy on sexual harassment and violence and records of implementation Major GP 7003A Page 55 of 68

Findings In compliance: Yes: X No: Objective Sexual Harassment Policy is in place and displayed. The policy was also written in both the Malay evidence: and English language and displayed on the notice boards outside the office. No evidence or practices that contradict this policy were observed. Discussion and interview with female staff, Ms Anita Ibak of HL 1 shows that the company provide fair and just treatment to women. In HL1 the Chairwoman is Ms Periyah , Checkroll Clerk . The organization chart is sighted , with the manager being the advisor. The committee comprises of 8 members. The minutes of the meetings were checked and it was reported that no sexual harassment were reported for 2014. In Hwa Li 2,Ms Loga Nayagi , Acting Account Clerk is the Chairwoman and the committee members comprise of all the 14 female workers . Meetings are held twice per year. Meetings were sighted and no sexual harassment were reported. In CPOM ,Mdm S.Chandra, Account Clerk ( appointed 15/7/14 ) is the Chairwoman and the committee members comprise of all the 7 female workers . Meetings are held twice per year. Meetings were sighted and no sexual harassment were reported. In addition there is a gender committee and a nominated gender representative established at the mill. Based on records, the last meeting was conducted on 8/7/2014 and the attendance record is available. No reports of harassment was reported .

In the Hwa Li 1 , meeting on the 23/12/14 the following were discussed: a) Minutes of previous meeting b) Report of any sexual harassment c) Sanitation d) AOB Estates Date HL 1  26/6/14  23/12/14. Hwa Li 2  14 May 2014  12 Dec 2014 CPOM  8/7/14

However in 2014, CPOM have not conducted the second meeting for the 2014 year as required by the management. The guideline doc. Ref. No: E/004-05/2014’ SOP on mechanism for Communication and consultation. Section (B) Mechanism for Gender Group Consultation ‘ 1.3 was referred OBSERVATION 02 6.9.2 A specific grievance mechanism is established Minor

Findings In compliance: Yes: x No: Objective A SOP on “Mechanism for the Prevention and Eradication of Sexual Harassment and Violence in evidence: the Work Place” is also in place. The SOP E/003-01/2008 dated 01 October 2008 includes the following mechanisms and procedures:  preventing sexual harassment in workplace,  rationale,  Definition of sexual harassment,  forms of sexual harassment,  Strategies to prevent sexual harassment, o adopt a clear sexual harassment policy, GP 7003A Page 56 of 68

o monitoring the work place on a regular basis, o Take all complaints seriously o Guidelines for handling complaints on sexual harassment.

Criterion 6.10: Growers and mills deal fairly and transparently with smallholders and other local businesses. 6.10.1 Pricing mechanisms for FFB and inputs/services shall be documented Major

Findings In compliance: Yes: X No: Objective Carotino Palm Oil mill only processes FFB sourced from own plantation as such the company evidence: does not deal with smallholders and the company carries out all operations within the estates. 6.10.2 Current and past prices paid for FFB shall be publicly available Minor

Findings In compliance: Yes: X No: Objective The mill only receives FFB from their own Group / Unit supply base so there is no need of FFB evidence: prices to be made publicly available 6.10.3 Evidence that all parties understand the contractual agreements they enter into Minor and that contracts are fair, legal and transparent

Findings In compliance: Yes: x No: Objective Supply base are from the same Group. evidence: 6.10.4 Agreed payments shall be made in a timely manner Minor

Findings In compliance: Yes: x No: Objective Supply base are from the same Group. evidence: Criterion 6.11: Growers and millers contribute to local sustainable development wherever appropriate. 6.11.1 Demonstrable contributions to local development that are based on the results of Minor consultation with local communities

Findings In compliance: Yes: x No: Objective The individual estates and the mill have a very basic form of corporate social responsibility (CSR), evidence: which usually involves stakeholders, especially the local communities and workers. In general, the following events and contributions has been rendered by the company:  religious celebrations ( Hari Raya Haji ) e.g poultry is provided to the workers during the festive season & ‘kenduri’  Opportunities for employment for local communities ,  estate school children education aid , transport reimbursement & transport to school going children  sports day & maintenance of a badminton court  Road Maintenance  Purchase of forest tress from the Orang Asli Nursery  Dispensary for workers and villagers nearby  Provide water for the Orang Asli when required e.g during the drought  Maintenence of place of worship – surau,temple , ‘datuk’  In Hwa Li 2 , a shelter was build at the wakaf / graveyard for the Kg Pasal Orang Asli community.  All activities and contribution rendered are recorded for each of the financial year

GP 7003A Page 57 of 68

Principle 7: Responsible Development of New Plantings This whole Principle is not applicable to this assessment as there are no new plantings. The company is only involved in re-planting programme after felling of old palms and there is no plan for expansion.

Principle 8: Commitment to Continuous Improvement in Key Areas of Activity Criterion 8.1: Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations. 8.1.1 Minimize use of certain pesticides (C 4.6) Major

Findings In compliance: Yes: x No: Objective In minimizing use of certain pesticides, improvement plan as below: evidence: a. Provided for only 2.5 rounds of circle spraying and only 1 round of selective spraying mainly to reduce & control of the usage of pesticides. b. To extend predator host plant plantings to all matured area as biological control for all leaf eating caterpillas, hence reduce the requirements of pesticides spraying.

8.1.2 Environmental impacts (C 5.1) Major

Findings In compliance: Yes: x No: Objective In Hwa Li 2, budget for sustainable improvement plan 2014/2015 is available as below: evidence: Provision allocated for the Riparian upkeep, maintenance & planting of trees in the riparian and field drains maintenance. Provision allocated to continuously improve main access road and filed roads by grading compacting, filling pot holes, road surfacing, cutting off shoots, construction water diverters and culvert maintenance & repair. Provision allocated for waste collection and segregation. Total budget for the program above allocated RM146, 668. In Hwa Li 1, continue planting of local species, Ara Tree, for barren spot along Jekatih River. Budget mainly for supplying purpose. The mill has established action plan for continual improvement shall be based on a consideration of the main social and environmental impact and opportunities for the company.

Such evidence is available in: a. Carotino POM Sustainability Improvement Plan (FY2014/2015) b. Environment Impact Plan (diesel genset with higher efficiency; new of skimmer for biogas incoming c. Social Impact plan (new public toilet; cooling water- Biogas; fencing for staff housing; domestic furniture for executive/staff. 8.1.3 Maximizing recycling and minimizing waste or by-products generation Major

Findings In compliance: Yes: x No: Objective For the estate, sustainability improvement plan FY2014/2015: evidence: a. Disposals the schedule waste to the licensed collector for recycle, mainly for used filter; budgeted cost:RM1000 b. Training provided to the garbage collector on waste segregation c. Continue to improve on waste segregation and recycling. Budgeted: RM7757 d. Disposed off the plastic herbicide containers through licensed collector for recycle 8.1.4 Pollution prevention plans (C 5.6) Major

Findings In compliance: Yes: x No: Objective For the estate, sustainability improvement plan FY2014/2015: evidence: a. Replacement if 2 units very old and poor conditioned tractors and new addition for more GP 7003A Page 58 of 68

efficient internal crop evacuation. Budgeted: RM230000 b. Maintenance of oil/chemical trap is carried out as per requirements, c. Tray placed under the parked vehicle to minimize the risk of oil production. Provide more training to drivers to instill their awareness on the effect of oil spill

8.1.5 Social impacts (C 6.1) Major

Findings In compliance: Yes: x No: Objective Social impacts improvement plan with the budget: evidence: - Budget was provided mainly for the routine repairs & maintenance of all staff & labour quarters and upkeep sundry buildings. - Repainting program: Staff Bungalow; Labour quarters - Safety Signage - Safety Awareness Campaign - Personal Protective Equipment - Provide school education aid for the staff - Transport School children - Long services award - Annual Sport - Estate Kenduri - Staff Annual Event - Contribution to Local Community - Stakeholder Meeting Expenses 8.1.6 A mechanism to capture the performance and expenditure in social and Minor environmental aspects

Findings In compliance: Yes: x No: Objective The mechanism to capture the performance and expenditure in social and environmental evidence: aspects are in the budget. Hwa Li 2 The Unit has implemented an accounting Software System, Lintramax, for tracking of all expenditure in social and environmental aspects. The following is the amount allocated for the following : Allocation Budgeted 2014/15 ( RM) Minimize use of certain pesticides 344,304 Environmental impacts 156,668 Maximizing recycling and minimizing waste or by- 0 products generation Pollution prevention plans 0 Social impacts 1,170,370

GP 7003A Page 59 of 68

3.1.2 Supply Chain For supply chain, the Carotino Palm Oil Mill has maintained the use Module D in this assessment. The findings and objective evidence find during the assessment are outlined in the table below. The results for each indicator from each of the operational areas were evaluated to provide an assessment of conformity. A statement is provided for each of the RSPO indicators in order to support the findings of the assessment team.

Module D- Identity Preserved (IP) D.1: Definition D.1.1 A mill is deemed to be Identity Preserved (IP) if the FFB used by the mill are sourced from its own supply base certified to the RSPO Principles and Criteria (RSPO P&C). Certification for CPO mills is necessary to verify the volumes and sources of certified FFB entering the mill, the implementation of any processing controls (for example, if physical separation is used), and volume sales of RSPO certified products. A mill may be taking delivery of FFB from uncertified growers, in addition to those from its own certified land base. If a mill processes certified and uncertified FFB without physically separating the material then only Module E is applicable. D.2: Explanation

D.2.1 The estimated tonnage of CPO and PK products that could potentially be produced MAJOR by the certified mill must be recorded by the certification body (CB) in the public summary of the P&C certification report. This figure represents the total volume of certified palm oil product (CPO and PK) that the certified mill is allowed to deliver in a year. The actual tonnage produced shall then be recorded in each subsequent annual surveillance report. Findings In compliance: Yes: X No: Objective The quarterly summary for the FFB, CPO and PK is available and well documented at the mill evidence: level.

D.2.2 The mill must also meet all registration and reporting requirements for the MAJOR appropriate supply chain through the RSPO supply chain managing organization (RSPO IT platform or book and claim).

Findings In compliance: Yes: X No: Objective The mill has registered at the etrace and their RSPO member ID: RSPO_PO1000000034. The evidence: monthly summary of the etrace transaction is available. D.3: Documented Procedures

D.3.1 The site shall have written procedures and/or work instructions to ensure the MAJOR implementation of all the elements specified in these requirements. This shall include at minimum the following: a) Complete and up to date procedures covering the implementation of all the elements in these requirements; b) The role of the person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements. This person shall be able to demonstrate awareness of the site’s procedures for the implementation of this standard.

Findings In compliance: Yes: X No: Objective The procedures is available name: General Traceability System, the procedures cover: evidence: a. Management system and documentation b. Receiving c. Processing d. Monitoring e. Appointed person

Miss Norzilawati has been appointed on 07 July 2014 as the sustainability operation admin officer GP 7003A Page 60 of 68

to implement all supply chain requirements. She has demonstrated awareness of the supply chain implementation.

D.3.2 The site shall have documented procedures for receiving and processing certified MAJOR and non-certified FFBs.

Findings In compliance: Yes: X No: Objective The mill only receives FFBs from their own supply base. evidence: However, the mechanism for handling non-conforming FFB (MEC-02/2014-CPOM; dated 14th December 2014) is available. D.4: Purchasing and goods in

D.4.1 The site shall verify and document the tonnage and sources of certified and the MAJOR tonnage of non-certified FFBs received.

Findings In compliance: Yes: X No: Objective Up to date, the mill only receives the certified FFBs from its own supply based. evidence:

D.4.2 The site shall inform the CB immediately if there is a projected overproduction of MAJOR certified tonnage.

Findings In compliance: Yes: X No: Objective Up to date, there is no overproduction. evidence: D.5: Record keeping

D.5.1 The site shall record and balance all receipts of RSPO certified FFB and deliveries MAJOR of RSPO certified CPO and PK on a three-monthly basis.

Findings In compliance: Yes: X No: Objective The quarterly summary for the FFB, CPO and PK is available and well documented at the mill evidence: level. D.6: Processing

D.6.1 The site shall assure and verify through documented procedures and record MAJOR keeping that the RSPO certified oil palm product is kept segregated from non- certified material including during transport and storage.

Findings In compliance: Yes: X No: Objective All summary record for the RSPO certified oil is available. Following documents were verified evidence: during onsite audit: a. Dispatch Slip; ticket no: CPO14000647W b. Dispatch Note; ticket no: CPO14000246W c. Purchase weighing slip; ticket no: P020185 d. Quarterly sustainability products report for FFB, CPO and PK e. Shipping announcement

D.6.2 The objective is for 100 % segregated material to be reached. MAJOR

Findings In compliance: Yes: X No: Objective Up to date, the mill only receives the certified FFBs from its own supply based. evidence:

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3.2 Demonstration on compliance to the new RSPO P&C 2013 at Carotino Production Unit.

Summary: RSPO P&C 2013 and draft RSPO MYNI for Public Consultation – March 2014 obtained by the Group and have studied and reviewed by the Group’s Estate Department Manager (Admin. / Sustainability). Internal audit and implementation checklist was developed based on the requirement of RSPO. Training on RSPO P&C 2013 was conducted based on draft RSPO MYNI for Public Consultation – March 2014. No CAR will be raised for the new clause below as this audit during transition period of existing MYNI and new MYNI. 1.3.1 There shall be a written policy committing to a code of ethical conduct and integrity in all operations and transactions, which shall be documented and communicated to all levels of the workforce and operations Compliance Policy on ethical conduct developed and has gone through the process of internal status: stakeholder consultation and currently, it was pending for approval from Board of Director. 2.2.3 Where there are or have been disputes, additional proof of legal acquisition of title and evidence that fair compensation has been made to previous owners and occupants shall be available, and that these have been accepted with free, prior and informed consent (FPIC).

Compliance Policy on ethical conduct developed and has gone through the process of internal status: stakeholder consultation and currently, it was pending for approval from Board of Director. 3.1.1 A business or management plan (minimum three years) shall be documented that includes, where appropriate, a business case for scheme smallholders. 3.1.2 An annual replanting programme projected for a minimum of five years (but longer where necessary to reflect the management of fragile soils, see Criterion 4.3), with yearly review, shall be available. Specific Guidance: For 3.1.1: The business or management plan should contain: • Attention to quality of planting materials; • Crop projection = Fresh Fruit Bunches (FFB) yield trends; • Mill extraction rates = Oil Extraction Rate (OER) trends; • Cost of Production = cost per tonne of Crude Palm Oil (CPO) trends; • Forecast prices; • Financial indicators. Suggested calculation: trends in 3-year running mean over the last decade (FFB trends may need to allow for low yield during major replanting programmes). Compliance Policy on ethical conduct developed and has gone through the process of internal status stakeholder consultation and currently, it was pending for approval from Board of Director. 4.1.2 A mechanism to check consistent implementation of procedures shall be in place. 4.1.4 The mill shall record the origins of all third-party sourced Fresh Fruit Bunches (FFB). 4.2.4 A nutrient recycling strategy shall be in place, and may include use of Empty Fruit Bunches (EFB), Palm Oil Mill Effluent (POME), and palm residues after replanting. 4.4.3 Appropriate treatment of mill effluent to required levels and regular monitoring of discharge quality, especially Biochemical Oxygen Demand (BOD), shall be in compliance with national regulations (Criteria 2.1 and 5.6). 4.6.2 Records of pesticides use (including active ingredients used and their LD50, area treated, amount of active ingredients applied per ha and number of applications) shall be provided. 4.6.5 Pesticides shall only be handled, used or applied by persons who have completed the necessary training and shall always be applied in accordance with the product label. Appropriate safety and application equipment shall be provided and used. All precautions attached to the products shall be properly observed, applied, and understood by workers (see Criterion 4.7). 4.8.2 Records of training for each employee shall be maintained. 5.3.2 All chemicals and their containers shall be disposed of responsibly Compliance The new requirement under 4.1.2, 4.1.4, 4.2.4, 4.4.3, 4.6.2, 4.6.5, 4.8.2 and 5.3.2. have status been studied and documented evident developed accordingly. 5.6.3 A monitoring system shall be in place, with regular reporting on progress for these significant pollutants and emissions from estate and mill operations, using appropriate tools. GP 7003A Page 62 of 68

Compliance GHG monitoring system and tools of monitoring system have been developed based on status IFEU GHG calculator and its formula requirements. 6.12.1 There shall be evidence that no forms of forced or trafficked labour are used.

6.12.2 Where applicable, it shall be demonstrated that no contract substitution has occurred. Compliance The new requirement under 6.12.1 and 6.12.2 have been studied and documented status evidence developed accordingly. 6.13.1 A policy to respect human rights shall be documented and communicated to all levels of the workforce and operations (see Criteria 1.2 and 2.1). Compliance Human Right Policy was confirmed and signed by Director on 22/12/2014. It is now status displayed on operating unit’s main notice board. Training on the content of Human Right policy was conducted by individual operating unit. 7.3.1 There shall be evidence that no new plantings have replaced primary forest, or any area required to maintain or enhance one or more High Conservation Values (HCVs), since November 2005. New plantings shall be planned and managed to best ensure the HCVs identified are maintained and/or enhanced (see Criterion 5.2). Compliance The Group doesn’t have any new plantings as such requirements under new planting will status not be studied.

3.3 Corrective Action Request There are total of 0 Major and 0 Minor were raised. Please refer to the Appendix A for the details findings and relevant correction actions have been taken. 3.4 Noteworthy Positive & Negative Observation Two observations were raised. 3.5 Status of Non-Conformities Previously Identified Please refer to Appendix B for the previous audit.

3.6 Issues Raised by Stakeholders and Findings A list of stakeholders contacted is included as Appendix D. after a 30 day announcement on the RSPO website both SGS (Malaysia ) Sdn Bhd and Carotino Produciton Unit did not receive any correspondence concerning against the re-certification of Carotino Production Unit. Stakeholders did not provide any comments in writing regarding Carotino Production Unit in relation to environmental and social performance. All interviewed stakeholders had positive comments about Carotino Production Unit.

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4. ACKNOWLEDGEMENT OF ORGANIZATION INTERNAL RESPONSIBILITY 4.1 Date of Next Surveillance Visit The next audit will be held within a year after the approval of the Carotino Production Unit report

4.2 Date of Closing Non-Conformities Not applicable as this is re-certification.

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

Signed on behalf of Carotino / JC Signed on behalf of SGS Malaysia Sdn Bhd Chang Group – Carotino Production Unit

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APPENDIX A: CORRECTIVE ACTION REQUEST & OBSERVATION

There were no Non-Conformities raised during the audit.

OBSERVATIONS

OBS # Indicator Observation Detail 01 6.5.2 Date Due Date 8/1/15 Recorded> Date> Closed> Non-Conformance: The requirement is that the labour laws, union agreements or direct contracts of employment detailing payments and conditions of employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc) are available in the language understood by the workers or explained carefully to them by a plantation management official in the operating unit Objective Evidence: CPOM has an official list of the paid public holiday for the workers. The public holiday for the Hindus, Muslim and Chinese are differentiated. However , it was noted that in the document ‘ Butir-butir peribadi( personal particular ) of each worker the differentiation was not done in accordance to their religion/races. Observation 01 – Raised

Close-out evidence:

OBS # Indicator Observation Detail 02 6.9.1 Date Due Date 8/1/15 Recorded> Date> Closed> Non-Conformance: A policy on sexual harassment and violence and records of implementation Objective Evidence: However in 2014, CPOM have not conducted the second meeting for the 2014 year as required by the management . The guideline doc. Ref. No: E/004-05/2014’ SOP on mechanism for Communication and consultation . Section (B) Mechanism for Gender Group Consultation ‘ 1.3 was referred

Observation 02 – Raised

Close-out evidence:

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APPENDIX B: NON-CONFORMITIES PREVIOUSLY IDENTIFIED

Not applicable

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APPENDIX C: TIMEBOUND PLAN

The Takon Production Unit is the last Unit to be certified under Carotino/ JC Chang Group.

The Takon Palm Oil Mill and its FFB supplying plantations under the JC Chang group will be seeking for RSPO certification in April 2016. The Takon Production Unit comprises of 1 palm oil mill and 4 oil palm plantations located in the State of Sabah, Malaysia.

Reasons / Justification for deferring RSPO certification plan for Takon Production Unit.

1. The original proposed plan to certify our Takon Production Unit in Sabah was somewhat over ambitious as it was based on the achievement of our other Production Units where some basic preparatory works were started 2 to 3 years ahead of its pre and main assessments. The CB commented that our plan was challenging connotes that we were somewhat over-zealous on the plan proposed.

2. The overly long delay of more than a year by CB and RSPO Board to vet and re-vet our Production Units’ certification report and limited premium paid / uptake on certified products had created disappointment and a sense of uncertainty on the RSPO certification process and direction which somehow had affected our zest and drive to pursue vigorously on the preparatory works for our Takon Production Unit in Sabah.

3. As our Takon Production Units in Sabah have out-grower supply base, their reluctance and unpreparedness to embrace RSPO certification voluntarily has somewhat setback our pace to initiate the certification process as previously planned. More than 50% of FFB received are from outsider farm.

4. The pace of development for RSPO certification in our Takon Production Unit was generally slowed by lack of personnel with the right knowledge, exposure and experience in the operating unit to stimulate RSPO enthusiasm and to spur the necessary trainings and other preparatory works.

5. By the process, plantation groups which have become member of RSPO should plan for certification soonest so as to demonstrate their sincerity for being a member and not to hitch a ride on the RSPO name. Hitherto, many large Malaysia plantation groups which have become member have yet to get any of their production units certified. As such, in all fairness and in the spirit of RSPO, it is pertinent to ponder whether this is more inappropriate and un-abiding that the deferment of our stated plans to certify our Takon Production Unit in Sabah. GP 7003A Page 67 of 68

APPENDIX D: LIST OF STAKEHOLDERS CONTACTED

Issues Date Location Stakeholders 6th Jan a) The Batin, En Kamisan b Wahab was 2015 a) Batin’ or ‘Ketua’ of Kg. Pasal interviewed at his homein the b) Harvesters interview morning. He confirmed :

 that the ‘pondok wakaf’ was constructed at the cemetery plot  that work was offered by Carotino  that road maintenance is done  no issue of boundaries disputes or security issues from Carotino workers  repair of bus-stop

a) b) Harvesters Mohd Faizal, Suparman, Kamaludin, Sohibu, Surip and Ramis were interviewed. All were satisfied with the management, pay is on time , normally before 7th , PPE are provided by the company, management has provided facilities to clean up after work before going back . House repair get responded, water and electricity is free. General worker aishah been working for the company for 21 years.. c) Gender Chairman - No issues, and no reports of sexual harassment or violence against women and women are represented.

th 7 Jan a) Gate Security Guard at Hwa Li 1 a) The security guard was interviewed and 2015 cleanliness of the security guard hut b) Neighbouring Estate : Ladang Suburban and the surrounding of his house was Properties checked . b) Appointment was made to meet and c) Estates workers.- Mandore & General interview the Mill manager of the workers neighbouring estate, Mr Chan as well d) Neighbouring Orang Asli Settlement ( about as the estate Manager Mr Chan Fei. 50 acs) No Land disputes with HL 1 and, HL1 has invited Suburban Properties e) Line-site visit during their stakeholder meeting, No f) Hospital Assistant issue of workers from HL 1 intruding into their land or quarrelling with their g) Worker representatives workers, no issue with river quality or boundary. Estate co-oporate for road maintenance. Mill Manager is satisfied with the crop from HL1. He hoped for more crops from HL 1. c) Workers interviewed, Mandor Satrudin, and workers Seper, Deb Naraj, Octapelatin, Mahara Ram, Winado No issue of payment, payslip, housing, workers are satisfied with the management. d) Interviewed GiEng. No issue with boundary with HL1. HL1 purchases forest seedling raised by them for planting along conservation or riparian. HL 1 has offered clinic assistance to the ‘orang asli’ e) At line site, interviewed the line-site GP 7003A Page 68 of 68

sweeper, Ms Anita who has worked for 5 years. Satisfied with management, pay on time. No issue with sexual harassment issues. f) Hospital assistant is satisfied with the quantity of medical supplies provided. Facilities is sufficient and availability of transport to nearby hospital during emergency g) Worker representatives Satrudin (Indonesian) and Dik Bir Rai (Nepal) attends JCC meetings and they are satisfied with the non-discriminatory policy of Carotino.

Government stakeholders Due to the Flood situation in Pahang, the DOSH, Forestry as well as DOE were not available for interview as they were instructed to assist in volunteering in the flood evacuation programme as the situation which was serious this time.