Report number: 815150RSPOCUCRPT -2010-01-DO RSPO Assessment Report PUBLIC SUMMARY

SIME DARBY PLANTATION Sdn Bhd Labu POM POM Lavang POM Rajawali POM Derawan POM Pekaka POM

MALAYSIAN PENINSULAR/SARAWAK

This public summary has been prepared in accordance with RSPO requirements and the information included is the result of a full RSPO assessment of the Mills and supply base as included in the scope of the certificate.

Report prepared by: David Ogg FICFor. (Lead assessor). Certification decision made by: Gerben Stegeman.

Control Union (Indonesia) Control Union (Malaysia) S/B Jl. Kramat 3A, Persiaran Raja Muda Musa, CilandakTimur Off Jalan Sg Berith, Jakarta Selatan 12560 Teluk Gadong, 41100, Klang, Phone: 062-21-7884 2016 Selangor. Malaysia. Phone 03-3377 1600 / 1700 [email protected] [email protected]

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

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

www.controlunion.com

Contents

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 1 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO

CONTENTS

1. Scope of the Certification Assessment...... 3 1.1 National Interpretation used for the assessment...... 3 1.2 Assessment type. (mill, estate and mill, plantation only etc. etc) ...... 3 1.3 Location maps...... 3 – 4 1.4 Location addresses of the mill(s). Approximate tonnages CPO certified..... 5 1.5 Description of supply base...... 5 1.5.1 General description...... 5 1.5.2 Location of the supply base including: ...... 6  Control Union code for the certificate...... 6  Location address...... 6  GPS reference...... 6 1.5.3 Statistics of supply base including: ...... 7  Control Union code for the certificate...... 7  Area of oil palm...... 7  Mature area...... 7  Estimated annual FFB production in tonnes...... 7  Planting years...... 7  Cycle...... 7 1.5.4 Percentage of planted areas of different ages...... 8 1.6 Organisational information/contact person ...... 8 1.7 Audit against the rules for partial certification...... 9 1.7.1 Introduction ...... 9 1.7.2 Assessment agenda – Partial certificate audit in Indonesia...... 9 1.7.3 Audit team findings in relation to the rules to the rules for partial certification...... 10 - 12 1.8 Date certificate issued and scope of certificate ...... 13 - 14

2. Assessment Process ...... 14 2.1 Certification body ...... 14 2.2 Qualifications of the assessment team ...... 14 2.2.1 Qualifications of the lead auditor ...... 14 - 15 2.2.2 Qualifications of the audit team ...... 15 - 16 2.3 Audit methodology ...... 16 2.3.1 General overview ...... 16 2.3.2 Assessment agenda for main audit in Malaysia ...... 16 - 17 2.4 Stakeholder consultation ...... 18 2.4.1 Summary of how stakeholder consultation was organised ...... 18 2.4.2 List of National and International stakeholders consulted ...... 18 2.5 Date of next surveillance visit ...... 18

3. Assessment Findings ...... 19 3.1 Lead assessor’s summary and recommendation for certification ...... 19 3.2 Summary of the findings by criteria ...... 19 - 29 3.3 Non conformity registers ...... 30 - 32 3.4 Issues raised during stakeholder consultation and company responses ... 32 - 33 3.5 Formal sign-off of the assessment findings ...... 33 3.5.1 Acknowledgment of internal responsibility by the client ...... 33

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 2 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO

1. SCOPE OF THE CERTIFICATION ASSESSMENT.

1.1 National Interpretation used. The management of the Palm Oil Mill(s) and associated suppliers of FFB were assessed for compliance against the International RSPO criteria as interpreted and endorsed for Malaysia.

1.2 Assessment type. (Mill, Estate and Mill, Plantation only etc. etc). Palm Oil Mills and Estates owned by Sime Darby as included in the scope of the assessment.

1.3 Location maps – Peninsular Malaysia & Sarawak The individual estate maps for SOU 13 & 15 (Peninsular Malaysia) and SOU 31, 32, 33 & 34 (Sarawak) – Refer to Appendix A

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 3 of 33

LAVANG COMPL Report number: 815150RSPOCUCRPT -2010-01-DO

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 4 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO

1.4 Location of mills and approximate tonnages certified. (July 2008 - June 2009) (These figures exclude any output product from non-certified suppliers). Name of Mill Location address Annual output CPO (MT) Palm Kernel (MT) Labu POM Pusat Teknologi Kilang Sawit (POMTEC), 29,930.33 7,570.73 71900 Labu, . Rantau POM KKS Rantau, 71209 Rantau, Negeri Sembilan. 46,778.00 12,864.15 Lavang POM P.O. Box 1288, 97008 Bintulu, Sarawak 25,329.92 5,670.99 Rajawali POM P.O. Box 2324, 97011 Bintulu, Sarawak 56,486.40 11,384.85 Derawan POM P.O. Box 2324, 97011 Bintulu, Sarawak 32,493.67 6,308.37 Pekaka POM P.O. Box 1641, 97010 Bintulu, Sarawak 47,929.00 10,853.00

1.5 Description of supply base. 1.5.1 General description. The 6 SOUs and their associated supply bases are now under the single ownership of Sime Darby. Previous management was under Guthrie, Golden Hope and Sime Darby but there are now common management systems applicable to all estates. There are no dependent small holders and all projected mass balances of CPO for the mills is calculated on the delivery of FFB from the supply base included in 1.4.2 below.

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 5 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO 1.5.2 Location of the supply base. Name and CU Code Estate name and Location address. GPS reference number of Longitude Latitude business unit. SOU 13 PO1 Ladang Labu, 71900 Labu, Negeri Sembilan. N 4°12'90” E101°51' 45” Labu PO2 Ladang New Labu, 71800 , Negeri Sembilan. N 4°12'90” E101°48' 45” PO3 Ladang Bradwall, 71200 Rantau, Negeri Sembilan. N 2°35'090” E101°55' 66” SOU 15 PO4 Ladang Siliau, 71100 Siliau, Negeri Sembilan. N 2°32'059" E101°54'0" Rantau PO5 Ladang Sengkang, 71259 Pasir Panjang, Negeri N 2°26'095” E101°57' 72” Sembilan. PO6 Ladang Sungei Baru, 78300 Masjid Tanah, Melaka. N 2°26’18” E102°5’44” PO7 Ladang TampinLinggi, 71209 Rantau, Negeri Sembilan. N 2°30'56.71” E101°59' 47.11” PO8 Ladang Salak, 71100 Siliau, Negeri Sembilan. N 2° 34' 54" E 101° 53' 38" PO9 Ladang PD , Bt. 2½, Jalan , 71000 Port N 2°30’59.06” E 101°50’17.47” Dickson, Negeri Sembilan. SOU 31 PO10 Ladang Lavang, P.O. Box 1288, 97008 Bintulu, Sarawak. N 3°55.92” E 103°18.25’ Lavang PO11 Ladang Rasan, P.O. Box 1288, 97008 Bintulu, Sarawak. N 03°24.852” E 113°38.757” PO12 Ladang Kelida, P.O. Box 1288, 97008 Bintulu, Sarawak. N 3°22.50” E 113°37.46’ PO13 Ladang Belian, P.O. Box 1288, 97008 Bintulu, Sarawak. N 3°55.92” E 103°18.25’ SOU 32 PO14 Ladang Rajawali, P.O. Box 673, 97008 Bintulu, Sarawak. N 03024’ 19.7” E 113027’ 15.7” Rajawali PO15 Ladang Samudera, P.O.Box 2330, 97012 Bintulu, N 03°28.914’ E 113°23.857’ Sarawak. PO16 Ladang Semarak, P.O. Box 2070, 97011 Bintulu, N 03 22 536’ E 35.615’ Sarawak. PO17 Ladang Sahua, P.O. Box 1103, 97008 Bintulu, Sarawak. N 3031’41.45” E 113018’56.50” PO18 Ladang Damai, P.O. Box 1103, 97008 Bintulu, Sarawak. N5375800. E2407400. PO19 Ladang Bayu, P.O. Box 2596, 97012 Bintulu, Sarawak. N 2033.72” E 102033.73’ SOU 33 PO20 Ladang Derawan, P.O. Box 823, 97008 Bintulu, N 3023”59.23 E 113020”33.62 Derawan Sarawak. PO21 Ladang Takau, P.O. Box 823, 97008 Bintulu, Sarawak. N 3023”59.23 E 113020”33.62 SOU 34 PO22 Ladang Pekaka, P.O. Box 1048, 97008 Bintulu, N3°27’36.9” E 113°37’9.0” Pekaka Sarawak. PO23 Ladang Ruai, P.O. Box 1847, 97008 Bintulu, Sarawak. N 113.679 E 3.609 PO24 Ladang Dulang, P.O. Box 2054, 97011 Bintulu, Sarawak. N 3.44576 E 113.65109 PO25 Ladang Chartquest, P.O. Box 1724, 97010 Bintulu, N 3°27’ E 113°33’ Sarawak. PO26 Ladang Paroh, P.O. Box 2054, 97011 Bintulu, Sarawak. N 03°27.931’ E 113°43.509’

1.5.3 Statistics of the supply base. Financial year 2008/2009 (July 2008 – June 2009) 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 6 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO CU Name Area of oil palm (ha) EstTonnes Planting years Cycle Code Total area Mature FFB/yr (years) Oil Palm area. PO1 Ladang Labu 3,634.00 2,852.82 6,7989.28 1976 - 2006 25 PO2 Ladang New Labu 2,159.00 1,881.18 40,358.26 1985 - 2006 25 PO3 Ladang Bradwall 1,417.47 1,292.00 29,008.90 1984 - 2006 25 PO4 Ladang Siliau 1,647.85 1,463.00 35,162.27 1987 - 2008 25 PO5 Ladang Sengkang 2,741.00 2,268.00 60,394.00 1970 - 2009 25 PO6 Ladang Sungei Baru 1,444.17 267.15 4,926.05 1982 - 2006 25 PO7 Ladang 1,875.00 1,871.00 45,200.36 1985 - 2006 25 PO8 Ladang Salak 2,193.84 2,193.84 54,672.00 1985 - 2005 25 PO9 Ladang PD Lukut 1,421.00 1,415.00 33,538.28 1985 - 2007 25 PO10 Ladang Lavang 1,944.16 1,827.19 33,916.26 1997 25 PO11 Ladang Rasan 3,339.00 3,238.45 68,409.27 1997 - 2004 25 PO12 Ladang Kelida Estate 2,415.92 2,415.92 34,348.45 1996 25 PO13 Ladang Belian 2,885.84 2,697.82 51,508.26 1997 - 2004 25 PO14 Ladang Rajawali 3,681.00 3,542.00 71,555.53 1994 - 2004 25 PO15 Ladang Samudera 2,328.00 2,328.00 51,686.78 1998 - 2000 25 PO16 Ladang Semarak 2,360.50 2,360.50 47,837.62 1993 - 2004 25 PO17 Ladang Sahua 2,225.00 2,225.00 49,878.57 1994 - 2000 25 PO18 Ladang Damai Estate 2,488.00 2,488.00 46,892.05 1996 - 1998 25 PO19 Ladang Bayu 2,401.00 2,292.00 55,080.69 1998 - 2000 25 PO20 Ladang Derawan 2,163.52 2,163.52 50,168.06 1994 - 1996 25 PO21 Ladang Takau 2,140.00 2,140.00 52,915.30 1995 25 PO22 Ladang Pekaka 2,538.04 2,538.04 50,396.76 1989 - 1993 25 PO23 Ladang Ruai 2,455.00 2,455.00 44,836.74 1989 - 1993 25 PO24 Ladang Dulang 2,480.00 2,374.35 48,412.23 1991 - 1995 25 PO25 Ladang Chartquest 1,413.00 1,413.00 34,843.04 1997 25 PO26 Ladang Paroh Estate 2,469.31 2,469.31 41,501.94 1993 - 1995 25

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 7 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO

1.5.4 Percentage of planted areas of different ages. CU Code Name Before 1990 1991 – 1995 1996-2000 2001 – 2005 2006 – 2009 PO1 Ladang Labu 21.92% 5.77% 8.91% 42.88% 20.52% PO2 Ladang New Labu 29.95% 7.23% 27.62% 22.59% 12.61% PO3 Ladang Bradwall 36.37% 1.12% 19.25% 30.86% 12.40% PO4 Ladang Siliau 5.91% - 23.50% 45.57% 25.02% PO5 Ladang Sengkang 10.95% 3.97% 26.35% 39.59% 2.34% PO6 Ladang Sungei Baru 11.00% - - 39.00% 50.00% PO7 Ladang Tampin Linggi 9.21% 13.06% 60.94% 11.31% 5.48% PO8 Ladang Salak 23.07% 10.55% 33.62% 19.03% 13.73% PO9 Ladang PD Lukut 16.23% - 42.57% 32.18% 9.02% PO10 Ladang Lavang - - 100.00% - - PO11 Ladang Rasan - - 80.00% 20% - PO12 Ladang Kelida Estate - - 95.66% - 4.34% PO13 Ladang Belian - - 96.36% 3.64% - PO14 Ladang Rajawali - 29.59% 66.39% 4.02% - PO15 Ladang Samudera - - 100.00% - - PO16 Ladang Semarak - 80.09% 15.16% 4.75% - PO17 Ladang Sahua - 40.55% 59.45% - - PO18 Ladang Damai Estate - - 100.00% - - PO19 Ladang Bayu - - 98.64% - 1.36% PO20 Ladang Derawan - 83.00% 17.00% - - PO21 Ladang Takau - 100.00% - - - PO22 Ladang Pekaka 48.76% 51.24% - - - PO23 Ladang Ruai 5.49% 94.51% - - - PO24 Ladang Dulang - 100.00% - - - PO25 Ladang Chartquest - - 100% - - PO26 Ladang Paroh Estate - 100% - - -

1.6 Contact person. Principle Contact person: Zuhairi Bin Zubir Business address: Level 4, Wisma Guthrie, Jalan Gelenggeng, Bukit Damansara, KL. 50490 Office telephone: 0320932141 Mobile telephone: 0193672136 Fax: 0320932334 e-mail: [email protected] Web site: www.simedarby.com

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 8 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO 1.7 Audit against the rules for Partial Certification It was the conclusion of the audit team that Sime Darby were not in compliance with all of the rules for partial certification as laid out in paragraph 4.2.2 of the RSPO certification systems final document .

The two areas of non-compliance – as detailed in 1.6.3 below - were raised with both Sime Darby and with the RSPO. Sime Darby have now come to an agreement with the RSPO to off-set other land for conservation purposes and have also put an end to all the illegal gold mine activities. The RSPO have accepted both courses of action. 1.7.1 Introduction. It is noted that, for management purposes, the company has 65 individual “Strategic Operating Units” units (SOU’s) and each SOU comprises a number of individual estates. In Malaysia there are 39 SOU’s with 140 individual estates, extending to 229,470 ha. In Indonesia there are 26 SOU’s, (Known as companies) with 90 individual estates, extending to 295,156 ha.

It is noted that 21 SOU’s (In Malaysia) have either been certified or are currently in the process of being certified. It is the CU audit teams’ responsibility to be satisfied that the company conforms to the RSPO requirements for partial certification as laid out in the Final RSPO Certification Systems document, June 2007, section 4.2.4 for the un-certified SOU’s.

The audit team has to accept the audit findings and certification decisions of other Sime Darby SOU’s made by other certification bodies in Malaysia and, when considered with this audit, it is concluded that a sufficient sample of the Malaysian properties has been completed to accept compliance with 4.2.4. However, the audit team is unaware of any sampling conducted by the other CB’s as to the properties in Indonesia.

The audit team has reviewed the property portfolio and, by following the sampling principles of the Forest Stewardship Council for group certification, the square root of the number of SOU’s, rounded up to the nearest whole number is 6. Consequently 5 companies (SOU’s) in Kalimantan and 1 company in Sumatra were visited and audits conducted of the plantations that comprise these companies using a checklist covering the requirements for partial certification. In addition, the audit team reviewed all records relevant to the rules for partial certification, for all of the Sime Darby Kalimantan estates by visiting the Banjarmasin office.

The audit team arrived on site on Sunday 8th February, allowing the opening meeting to take place at 0800 on Monday 9th February. (For full agenda – see 1.7.2 below). The audit team was led by Bart van Assen with Mr. Dayu and Mr David Ogg.

1.7.2 Assessment agenda. Partial certification audit. Indonesia. Kalimantan and Sumatra. Date SOU Agenda 9/02/09 PT. Kridatama and 08.00 Opening meeting. Sukamandang. PT. Teguh Sempurna. Chaired by the audit team leader.  Introduction by team leader.  Briefing by TQSM  Briefing by BpBarma. The agenda was then discussed and finalised. Field visits and document review. Baras Danum and Batang Garing. Post November 2007 new planting. Sukamandang, Sapiri, Kuala Kuayan, Pemantang, Hatantiring and Kawan Batu estates. All pre November 2007. 10/02/09 PT. Indotruba Tengah Mill visit and document review. Field visits and document review. Sekunyir estate. 11/02/09 Banjarmasin Arrive 13.30. Review of all estate files. Drive to company 12/02/09 PT. Ladang Rumpun 08.00 Opening meeting. Angsana, Suburabadi. Chaired by the audit team leader. PT. Sajang Heulang.  Introduction by team leader.  Briefing by TQSM The agenda was then discussed and finalised. Field visits and document review. Angsana. Gunung Sari. Mustika. Pantai Bonati Closing meeting. 13/02/09 Depart. 16/02/09 PT Guthrie Peconina Field visits and document review. Ind. 5 Estates. 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 9 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO 1.7.3 Audit team findings in relation to the rules for partial certification. 1a. The organisation is a member of RSPO: Compliance found. Sime Darby has confirmed membership of the RSPO 1b. A time-bound plan for achieving certification of all relevant entities: Compliance found.

Financial Year SOU Main Status Surveillance Status Assessment Assessment PLANTATION MALAYSIA 2010 / 2011 SOU 26 Jun-08 Certified in Oct-08 Sep-10 Re-certification approved SOU 28, 29, May-08 Certified in Jan-09 Nov-10 *2nd Surveillance Report 30 & 30b submitted to RSPO by SIRIM SOU 14 & 17 Sep-08 Certified in May-10 Mar-11 Assessed, 1st Surveillance Report pending finalization by BSi SOU 8, 9 & 9a Jan-08 Certified in May-10 Mar-11 **1st Surveillance Report submitted by BSi to RSPO SOU 21 Feb-09 Certified in May-10 Feb-11 Assessed and 1st Surveillance report pending finalization (CB: Moody Intl Cert, Malaysia) SOU 25 & 30a Apr-09 Certified in May-10 Apr-11 ***1st Surveillance Report submitted by BSi to RSPO SOU 1 Jul-09 Certified in Aug-10 Jun-11 Planned SOU 19a Jun-09 Certified in Oct-10 Jul-11 Planned SOU 20 Jun-09 Certified in Nov-10 Jul-11 Planned SOU 19 Jun-09 Certified in Jan-11 Jul-11 Planned SOU 27 May-10 Certified in Jan-11 Oct-11 Planned SOU 24 Dec-08 Certified in Mar-11 Nov-11 Planned SOU 5 & 6 Jan-09 Certified in Mar-11 Nov-11 Planned SOU 23 Jan-09 Certified in Apr-11 Nov-11 Planned SOU 7 Jul-09 Certified in Apr-11 Jan-12 Planned SOU 2, 4, 5a, Feb-09 Assessed, report 18 & 22 pending finalization with CUC SOU 10, 11, Jun-09 Public Summary 12 & 16 Report submitted by CUC to RSPO SOU 13, 15, Jun-09 Assessed, report 16, 31, 32, 33 pending finalization & 34 with CUC SOU 3 Mar-11 Public Summary Report submitted by BSi to RSPO Financial Year SOU Main Status Surveillance Status Assessment Assessment PLANTATIONS - INDONESIA 2010 / 2011 SOU 13 Nov-08 Certified in Aug-10 Jun-11 Planned SOU 1, 14 May-09 Certified in Nov-10 Sep-11 Planned SOU 2, 3, 4, & Oct-10 Assessed, report 5 pending finalization with Mutu Agung SOU 14, 15, Nov-10 Assessed, report 19 & 20 pending finalization with Mutu Agung SOU 18 Dec-10 Assessed, report pending finalization with Mutu Agung SOU 6, 7, 8, 9 Jun-11 Planned & 10 SOU 11, 12, Jun-11 Planned 20 & 21

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 10 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO

*Due to realignment of processing strategy, the SOU 30b mill has been designated as a third party mill w.e.f September 2010 and currently is processing 100% crop procured from outside suppliers (non RSPO certified). Crop from SOU 30b estate is currently being processed by SOU 29 mill. Therefore, the Annual Surveillance Assessments were conducted only for SOU 28, 29 & 30. The RSPO certificate for SOU 30b has subsequently been withdrawn.

**Similarly, SOU 9a mill was designated as a third party mill w.e.f July 2010 and crop from SOU 9a estate is currently being processed by SOU 8 mill. The RSPO certificate for SOU 9a has since been withdrawn.

***Annual Surveillance Assessment was conducted only for SOU 25 as SOU 30a mill has ceased operation w.e.f August 2009. Subsequently SOU 30a was dissolved and the estate has been realigned under SOU 28. The RSPO certificate for SOU 30a has also been withdrawn.

Evidence: The current area of oil palm owned by the company extends to some 524,626 ha and is located in both Malaysia and Indonesia. It is the declared intention of the company to certify the whole of the oil palm area by the 31st December 2009. This is considered to be both challenging and realistic. See also 1.6.1 above. 1c. i. There are no significant land conflicts. Non - Compliance found. Evidence: Batang Gura Estate. There is an illegal gold mine covering 300ha within the HGU boundary. Mustika Estate. There is an illegal gold mine covering 70ha within the HGU boundary. Angsana Estate. There is an illegal gold mine covering 40ha within the HGU boundary.

The alleged, and likely use of mercury within these mines is both illegal and leads to environmental pollution. ------Other evidence: The company maintains detailed records on ongoing and resolved claims. Land claims occur(ed) in almost all estates. Various claims are documented on the internet, but little verifiable evidence is given in these documents (mainly newspaper clippings). Sime Darby took over the company in February 2007, and the majority of the above claims pre-date this take-over date.

The auditors interviewed 2 community representatives: Mr Ignatius Soriado (Dusun Pemantang) and Mr Arwinto (DusunTajur Beras). Dusun Pemantang was 100% community claim, while DusunTajur Beras was over 50% claimed by local communities. So far, the company has resolved all claims in good order and none are outstanding at the moment. Both agreed that the company actively addresses issues brought forward by the local communities, and resolved informally though the estate managers.

The auditors reviewed one case, where local communities from Sebamban Baru block aded the access road to SOU Angsana. This case from January 2005 appears to be a protest related to a land dispute concerning almost 6000 ha. The company maintains detailed records for land claims. The case in question was documented in the Land Committee Meetings and closed at the meeting held on 22 September 2006.

In SOUs Angsana, Pemantang, and Sukamandang, land clearing and new planting is ongoing. The SOUs maintain details on compensations paid for community lands. In SOUs Angsana and Pemantang, Illegal mining have encroached upon some estates, although these now appear stable. To what extent this can be considered a land dispute remains unclear… 1c. ii. No replacement of primary forest or any area containing HCVs since Non - Compliance November 2005. found.

Planting year range Total area No of estates HCV assessments? Nov 2005 to Nov 2007 10,317 ha 28 No Post Nov 2007 1,215 4 No

As no HCV assessments were conducted, the company cannot demonstrate compliance with this rule. 1c. iii. No labour disputes that are not being resolved through an agreed Compliance found. process. None noted and conformed by interview with managers and workers. Workers contracts (Kontrak perjanjian kerja) are approved by the sub district head of department of man power. (Kepala Dinas Ketenagakerjaan dan Transmigrasi Kotawaringin Timur). 1c. iv. No evidence of non-compliance with law in any of the non-certified Compliance found. holdings. Land records were inspected in the Banjamarsin office for all of the properties in Kalimantan and a sample of documents noted to demonstrate compliance with the law: Document review for PT. Kridatama Lancar (SOU Sukamandang): . Ijin prinsip No. HK.350/E5.679/10.94 dated 19th October 1994 for 11,000ha in Kabupaten Kotawaringin Timur. . Ijinusaha perkebunan (IUP) No. 445/Menhutbun-VII/2000 dated 25th March 2000 for 14,780ha. . IjinLokasi No. 2056/460/BPN/XII/1993 dated 16th December 1993, for 17,500ha . HGU No. 58/HGU/BPN/99 dated 22nd June 1999; expiry date 9th August 2034 for 14,779ha. . AMDAL/UK/UPL by Department of Agriculture No.35/ANDAL/RKL-RPL/BA/X/1998 dated 9th October 1998. . Cadastral map. Document review for PT. Teguh Sempurna (SOU Pemantang): . Ijinprinsip issued by DirjenBun No. HK.350/E5.678/10.94 dated 19th October 1994 for 11,000ha. 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 11 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO . Ijinusahaperkebunan (IUP) olehDirjenBun No. 444/Menhutbun-VII/2000 dated 25th March 2000. . IjinLokasi issued by BPN tk.II No 2057/40/BPN/XII/1993 dated 16th December 1993. . HGU No. 63/HGU/BPN/99 dated 2nd July 1999; expiry date 9th August 2034 for 16,602ha . Persetujuandokumen AMDAL/UKL/UPL by Department of Agriculture No.35/ANDAL/RKL-RPL/BA/X/1998 dated 9th October 1998. . Cadastralmap No. D.1.302 for 11,995ha and 4,660ha. Batang GaringEstate (SOU Pemantang). Document: . Invitation letter to local authorities to inspect the compensation process No. BGE – UM/VII/2007/042/S. . Beritaacara at June 28th, 2007, PT. Teguh Sempurna met the land owner and compensation agreed. . Record of compensation paid to Aspar at January 31st 2009, 20ha. Paid Rp. 8.800.000 by PT. TeguhSempurna (SOU Batang Garing). . Form (formulir-03) Contract for worker stated the rights and obligations of the worker. Including payments, medical assessment, work hour. . Company rules (Peraturanperusahaan) PT. Teguh Sempurna approved by head of man power and transmigration office in KotawaringinTimur district (KepalaDinasTenagaKerjadanTransmigrasiKabupatenKotawaringinTimur) No. 560.565/897/KEP/HI – KESJA/2008 and 32/PP/X/2008 based on UU no. 13 tahun 2003 about Man power, UU no. 2 tahun 2004 about Industrial dispute resolution, UU no 21 tahun 2000 about labor union, UU no 51 tahun 1951 about Labor monitoring consisting work hours, payment, housing, worker social insurance (jamsostek), safety working condition, working tools.

PT. Indotruba Tengah (SOU Sekunyir) Mill: . HGU No. 152/HGU/BPN/97 dated 26th December 1997 for 7,734.6ha . AMDAL document: ANDAL No. 020/RKL-RPL/BA/X/1994 dated 18th October 1994. RKL No. 020/RKL-RPL/BA/X/1994 dated 18th October 1994. RPL No. 020/RKL-RPL/BA/X/1994 dated 18th October 1994. IjinPembuangan Air Limbah No. 660/23/Bpdl/XII/2003 stated the mill effluent volume 25m3/day. . Report on waste water test (Laporanhasiluji air limbah) from BalaiRisetdanStandardisasiIndustriBanjarbaru No.0180-PU/CU/BPPI/BRSBB/02/2007 dated February 6th, 2007, Analysis No. P148(3), Test date January 22nd, 2007, sample taken from Pond no.3. Result: pH: 7,51, COD: 4,771.2, BOD: 2,271.4mg/l, TSS: 2,730mg/l. Sample taken from Buaya river, result: COD: 48.3mg/l, BOD: 22.5mg/l, TSS: 117mg/l. Sample taken from control/monitoring well at mill, result: COD: 57.3mg/l, BOD: 26.0mg/l, TSS: 189mg/l. . Report of Analysis for River water by Sucofindo, Ref no. LAB.AKL.0280.2008 Certificate no. 00444/EEEBAB dated February 6th, 2008. Result: Ammonia: 0.28mg/l, pH: 6.12, Sulfate(SO4): 20.17mg/l. Analysis of air emission dated June 8th, 2007. sample from 1 boiler chimney, measurement dated August 6th, 2007;result: Ammonia: 1.25mg/m3, klorin gas: 6.85mg/m3, total reduced sulphur: 5.42mg/m3, Opacity: 25-30%

Sekunyir Estate: . Ijinprinsip No. 525/432/UT/1990 dated 27th February 1990 for 50,000ha. . Ijin Usaha Perkebunan (IUP) No.70/Menhutbun-VII/2000 dated 21st June 2000. . IjinLokasi No. 526.26/20/BPN dated 10th June 1993. . Persetujuan AMDAL No. Rc.220/95/B/I/94 dated 18th January 1994. . HGU (Sekunyir on Kotawaringin Barat district) No. 152/HGU/BPN/97 dated December 26th, 1997 for 3,260ha and No. 11/HGU/BPN/98 dated April 2nd,1998 for 829.2ha. . HGU (Sekunyir on Seruyan district) No. 10/HGU/BPN/98 dated April 2nd 1998 for 740.4ha and No. 13/HGU/BPN/98 dated April 6th,1998 for 2,905ha. . Cadastral map.

PT. LagunaMandiri (LMI) . Ijinprinsip No. HK.350/E4.72/01.90 dated 31st January 1990. . Ijin Usaha Perkebunan (IUP) No.462/Menhutbun-VII/200 dated 25th April 2000. . IjinLokasi No. SK.06/PL.84/1989/BPN.43 dated 31st May 1989. . Persetujuan AMDAL No. 008/ANDAL/BA/II/95 dated 27th February 1995 consist of ANDAL 050/RKL-RPL/BA/III/95. . HGU No. 138/HGU/BPN/97 dated 31st October 1997 for 14,500ha.

PT. ParipurnaSwakarsa (PSA) . Ijinprinsip No. HK.350/E4.70/01.90 dated 31st January 1990. . Ijin Usaha Perkebunan (IUP) No.460/Menhutbun-VII/200 dated 25th April 2000. . IjinLokasi No. SK.08/PL.84/1989/BPN.43 dated 31st May 1989 for 22,800ha. . Persetujuan AMDAL No. 480/AMDAL/VIII/93 consist of ANDAL 047/RPL-RKL/BA/III/95. . HGU No. 137/HGU/BPN/97 for 14,892ha.

PT. BersamaSejahteraSakti (BSS) . Ijinprinsip No. KB.110/EC.509 dated 25th May 1985. . Ijin Usaha Perkebunan (IUP) 193/I/IX/BUT-4/1999 dated 1st March 1999. . IjinLokasi No. SK.114/PL.460/1997/KP-KTB. . Persetujuan AMDAL No. 1337/AMDAL/II/94 dated 23rd February 1994 consist of RKL-RPL 010/RKL-RPL/BA/IV/1997 dated 21st April 1997. . HGU No. 22/HGU/BPN/92 for 8,222ha and No. 9/HGU/BPN/2002 for 3,318ha.

PT. Langgeng Muara Makmur (LMR) . Ijinprinsip No. HK.350/E4.1/01.90 dated 31st January 1990 for 18,000ha and HK.720/ED.103/03.90 dated 7th March 1990 for 13,000ha. . Ijin Usaha Perkebunan (IUP) 61/Menhutbun-VII/2000 dated 25th April 2000. . IjinLokasi No. SK.07/PL.84/1989/BPN-43 dated 31st May 1989 for 21,480ha. . Persetujuan AMDAL No. 008/ANDAL/BA/II/95 dated 27th February 1995 consist of RKL-RPL 048/RKL-RPL/BA/III/95 dated 30th March 1995. . HGU No. 133/HGU/BPN/97 for 15,533ha.

PT. Ladang Rumpun Suburabadi (LSI) . Ijinprinsip No. 525/717/UT-1 dated 4th August 1997 for 5,000ha. . Ijin Usaha Perkebunan (IUP) no.458/Menhutbun-VII/2000 dated 25th April 2000. . IjinLokasi No. SK.05/PL.84/1990/BPN-03. . Persetujuan AMDAL No.154/Menhut-II/2000 dated 22nd September 1999. . HGU No. 44/HGU/BPN/99 dated 11th May 1999 for 5,909ha and 02-540.2-43-2003 dated 20th November 2003 for 168ha.

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 12 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO

1.8 Date certificate issued and scope of certificate Name of Client: Sime Darby Client number: CU815150 Certificate number: CUC 815150 Certification Decision Date: Issued by Control Union Certifications Group scheme: Yes Address Meeuwenlaan 4-6, 8025 BS Zwolle, Netherlands. Telephone 0031 (0) 38 426 0100 Fax 0031 (0) 38 423 7040 Email [email protected] Website www.controlunion.com/certification

Scope Name of Mill: Labu POM Scope (Summary of suppliers of FFB):  PO1  PO2  PO3 Projected mass balance CPO and PK: 29,930.33 tonnes and 7,570.73 tonnes Certificate registration code: CU- 815150D01 Type of certification: Single site: Yes Group scheme: Yes

Name of Mill: Rantau POM Scope (Summary of suppliers of FFB):  PO4  PO5  PO6  PO7  PO8  PO9 Projected mass balance CPO and PK: 46,778.00 tonnes and 12,864.15 tonnes Certificate registration code: CU- 815150D02 Type of certification: Single site: Yes Group scheme: Yes

Name of Mill: Lavang POM Scope (Summary of suppliers of FFB):  PO10  PO11  PO12  PO13 Projected mass balance CPO and PK: 25,329.92 tonnes and 5,670.99 tonnes Certificate registration code: CU- 815150D03 Type of certification: Single site: Yes Group scheme: Yes

Name of Mill: Rajawali POM Scope (Summary of suppliers of FFB):  PO14  PO15  PO16  PO17  PO18  PO19 Projected mass balance CPO and PK: 56,486.40 tonnes 11,384.85 tonnes Certificate registration code: CU- 815150D04 Type of certification: Single site: Yes Group scheme: Yes

Name of Mill: Derawan POM Scope (Summary of suppliers of FFB):  PO20  PO21 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 13 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO Projected mass balance CPO and PK: 32,493.67 tonnes and 6,308.37 tonnes Certificate registration code: CU- 815150D05 Type of certification: Single site: Yes Group scheme: Yes

Name of Mill: Pekaka POM Scope (Summary of suppliers of FFB):  PO22  PO23  PO24  PO25  PO26 Projected mass balance CPO and PK: 47,929.00 tonnes and 10,853.00 tonnes Certificate registration code: CU- 815150D06 Type of certification: Single site: Yes Group scheme: Yes

Certifier (contact person) Gerben Stegeman. Signature

2. ASSESSMENT PROCESS.

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

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

2.2 Qualifications of the audit team. 2.2.1 Qualifications of the lead auditor. David Ogg FICFor. REQUIREMENT QUALIFICATIONS Compliance A minimum of post high school (post OND (credit) Forestry. Newton Rigg College of Yes secondary school) training in either Agriculture and Forestry. Penrith, Cumbria. U.K. agriculture/forestry, environmental 1978 to 1981 science or social sciences; At least 5 years professional Professional forester since 1981. Yes experience in area of work relevant to 1987. Passed the examinations necessary to be the assessment (e.g., palm oil accepted as a Member of the Institute of Chartered management; agriculture/forestry; Foresters. ecology; social science); 2004 Promotion to a Fellow of the ICF. Training in the practical application of Instrumental in the preparation of the CUC Yes the RSPO criteria, and RSPO certification systems. Fully trained in similar certification systems; certification programmes such as FSC, PEFC, GOTS, Organic Exchange. Successfully completion of an ISO BATALAS ISO 900:2000 lead assessors course. Yes. 9000:19011 lead assessors course; September 2007. A supervised period of training in Extensive experience in the Palm Oil industry by Yes. practical assessmenting against the conducting pilot projects with 4 different companies RSPO criteria or similar sustainability throughout Malaysia and Indonesia from August

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 14 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO standards, with a minimum of 15 days 2006 to August 2007. Developed the CUC assessment experience and at least 3 assessment checklist and system plans and assessments at different training new assessors as team members. organisations. Conducted a significant number of assessments since 1998. (In excess of 3,000). Smart Wood. Soil Association. Indfor: 700 group members including PEFC and FSC FM and COC; Control Union: GOTS, GGL, FSC COC, CRAMER, OE, Recycle standard. RSPO to date: 6 x pre-assessments. 6 x main assessments. (Malaysia, Indonesia and Colombia).

2.2.2 Qualifications of audit team. RSPO REQUIREMENT ASSESSOR QUALIFICATIONS Compliance Fluent in main local languages Manivannan Malaysian citizen. Yes and English. Sahathevan Malaysian citizen. Yes Senniah Malaysian citizen. Yes Field working experience in David Ogg Professional forester since 1981. Yes the palm oil sector, or a See also above. demonstrable equivalent. Manivannan 2 years of plantation management Yes and 7 years with corporate agriculture financing. Senniah Working experience in Plantation Yes for more than 10 years.

Sahathevan Working experience in Plantation Yes for more than 10 years.

Good agricultural practices David Ogg Professional forester since 1981. Yes (GAP), integrated pest See also above. management (IPM), pesticide Manivannan Global Gap and GMP B2, 7 years Yes and fertilizer use. assessment experience GAP and IPM Senniah As above. Yes

Sahathevan As above. Yes Health and Safety David Ogg Professional forester since 1981. Yes assessmenting on the farm See also above. and in processing facilities. (For example OHSAS 18001 Manivannan Global Gap and GMP B2, 7 years Yes or occupational. Health and assessment experience GAP and safety assurance system). IPM Senniah As above Yes Workers welfare issues and David Ogg Professional forester since 1981. Yes social assessment experience. See also above. (For example with SA8000 or Manivannan As above Yes related social or ethical Senniah As above Yes accountability codes). Environmental and ecological David Ogg Biodiversity and environmental Yes assessmenting. (For example forest management. experience with organic agriculture, ISO 14001 or Manivannan Global Gap Standard Yes environmental management systems). Economic issues. David Ogg Managing Director of forest Yes management company for 18 years. 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 15 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO Manivannan 7 years with corporate agriculture Yes financing.

2.3 Audit methodology. 2.3.1 General overview. The assessment was carried out in conformity with the procedures as laid down in the CUC RSPO Procedure Manual and the program manual for the assessor and certifier. During the assessment the qualified CUC assessors used the RSPO standard as endorsed for the country in which the assessment took place and recorded their findings.

Due to the location and proximity of the estates comprising each SOU, combined with the common management systems and information derived during the audit, it was possible to carry out both field and office assessments of all the estates within the time frame without compromising the integrity of the assessments in anyway.

All the estates and mills as detailed in 1.8 above were visited and the assessment team carried out field and office assessments of compliance for all the RSPO principles and criteria. Common systems were identified and specific evidence was recorded for individual estates. Interviews with managers took place in both formal and informal environments and worker interviews were conducted on all estates and mills.

2.3.2 Assessment agenda. Main audit in Malaysia. Date SOU Main activities Wednesday SOU 13 08.30 Opening meeting. Ladang Labu 24th June Labu Chaired by the audit team leader. 2009  Introduction by team leader.  Presentation by respective managers.  Presentation of Oil Mills source of FFB by respective managers. Field operations. Ladang Labu. Ladang New Labu. Ladang Bradwall.  Worker interviews.  Chemical stores.  Workshops.  Housing  Medical.  Schools.  Local communities.  Environmental.

Labu POM Mill inspection.  Workshops.  Stores.  POME application.  Document review. Thursday SOU 15 Open stakeholder meeting. Ladang Siliau. 25thJune Rantau 2009 Field operations(as above) Ladang Siliau Ladang Sengkang Ladang Sungei Baru Ladang Tampin Linggi

Rantau POM (as above) Friday SOU 15 Field operations(as above) 26th June Rantau Ladang Salak 2009 Ladang PD Lukut

Interim Closing Meeting – Chaired by the Audit team leader  Welcome and introduction by the team leader.  Presentation of findings by the audit team.  Questions and answers.  Final summary by team leader

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 16 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO Monday SOU 31 08.30 Opening meeting. Ladang Lavang 29thJune Lavang 2009 Field operations Ladang Lavang Ladang Kelida Ladang Rasan Ladang Belian  Worker interviews.  Chemical stores.  Workshops.  Housing  Medical.  Schools.  Local communities.  Environmental.

Lavang POM Mill inspection.  Workshops.  Stores.  POME application.  Document review. Tuesday SOU 32 Open stakeholder meeting. Ladang Rajawali 30th June Rajawali 2009 Field operations(as above) Ladang Rajawali Ladang Samudera

Rajawali POM (Mill inspection as above) Wednesday SOU 32 Field operations (as above) 1st July 2009 Rajawali Ladang Semarak Ladang Damai Ladang Sahua Ladang Bayu Thursday SOU 33 Field operations (as above) 2nd July 2009 Derawan Ladang Derawan Ladang Takau

Derawan POM (Mill inspection as above) SOU 34 Field operations (as above) Pekaka Ladang Pekaka Ladang Ruai Ladang Dulang

Pekaka POM (Mill inspection as above) Friday SOU 34 Field operations (as above) 3rd July 2009 Pekaka Ladang Chartquest Ladang Paroh

Preparation for closing meeting. Additional field visits and meetings with managers as necessary. Closing meeting. Chaired by the audit team leader.  Welcome and introduction by the team leader.  Presentation of findings by the audit team.  Questions and answers.  Final summary by team leader.

End of assessment. Number of assessors participating: 4 Number of days spent for the assessment on site: 8 Total number of person days used for the assessment on site: 32

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 17 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO 2.4 Stakeholder consultation 2.4.1 Summary of how the stakeholder consultation was organised. Number of stakeholders included in the companies application form to CUC and who were included in the 271 stakeholder consultation process: Number of additional National and International stakeholders identified by the company and by CUC and who 6 were also included in the stakeholder consultation process: Number of responses received: 0 Notification of the planned assessment was also posted on the CUC and RSPO web sites in accordance with the RSPO requirements. All stakeholders were sent a letter which included full details of the company to be assessed, the names and addresses of all the mills and supply base, the dates of the assessment and the date time and place of an open stakeholder meeting. They were invited to make any comments and given the following bullet points to assist them.  Environmental protection.  Biodiversity conservation.  Opportunities for employment.  Provision of housing, sanitation, amenities and educational support.  Company approach to community development.  Participation in decision making.  Any other issue, both positive and negative that you consider may be of relevance to the assessment.  Issues relating to other plantations owned by the company not included in this assessment. 3 separate stakeholder meetings were held. Number of persons who attended the open stakeholder meeting(s): 34 Subsequently to the stakeholder meeting, the audit team discussed the issues raised with management representatives of the company and follow up visits to specific sites were conducted. (See 3.4 below)

2.4.2 List of the National and International stakeholders contacted. Donker Curtiusstraat 7-523, 1051 AID Environment Eric Wakker [email protected] JL Amsterdam, The Netherlands 1c Fosseway Business Centre, Tel. : +44(0) 1608 652 893 Forest Peoples Programme Stratford Road, Moreton-in-Marsh, [email protected] Fax : +44(0) 1608 652 878 GL56 9NQ, England. PACOS Trust (Partners of Sabah Mr. Adrian Lasimbang [email protected] Community Organisations) [email protected] Sawit Watch Indonesia Mr. Norman [email protected] [email protected] Suite A-06-04, Plaza Mont Kiara, 2, [email protected] / RSPO Secretariat Mr. Ali Baizuri Razali JalanKiara, 50480 Kuala Lumpur. [email protected] 49, Jalan SS23/15, 47400 Petaling [email protected]/cont WWF Malaysia Mr. Darrel Webber Jaya, Selangor DarulEhsan. [email protected] Ms.IntanShafinaz Mohd. Wild Asia Sdn. Bhd. Kuala Lumpur, Malaysia. Suhaimi [email protected] Mob. : 012-3910 123 Mr. Sam Mannan Sabah Forestry Department Sabah Mob. : 019-8538 126 [email protected] Off. : 089-671 306

2.5 Date of next surveillance visit: The first full annual surveillance audit will be conducted 12 months from the date of certification.

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 18 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO

3. ASSESSMENT FINDINGS.

3.1 Lead auditor’s recommendation for certification: A full and complete audit of the estates and mills included in the scope of the certificate was conducted and conformance to the RSPO principles and criteria, as interpreted for Malaysia, was sought.

The audit team commends Sime Darby for their commitment to management in accordance with the RSPO principles and criteria.

It is the recommendation of the lead auditor that certification be awarded to the Company and supply base included in the scope of this audit.

The delay in making this recommendation is due to the findings of the audit for partial certification and the resulting action taken by the RSPO to resolve the issues found.

Signed:

Name: David Ogg FICFor. Date: February 2011.

3.2 Summary of the findings by criteria: 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 languages and forms to allow for effective participation decision making. Findings: Comments: Compliance  Records of all requests for information  All mills: Communication book records showing Yes are maintained. Date; Time; Issue; Person in charge; Remarks; Signature of visitor. The Auxiliary Police also record the vehicle number and date. A safety briefing book also records the name of the person.  All estates: Communication book records (Corporate Social Responsibility) shows Date; Time; Issues; Person In charge; Remarks; signature of visitors. The name and style of the book may vary from one estate to another but they all keep a clear record. 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. Findings: Comments: Compliance  Public documents are available and  No restriction as to the documents that are made Yes include legal, social and environmental publicly available with the exception of confidential documents and current and past FFB commercial information. prices.  Commercially sensitive documents are not available as verified by the audit team. Principle 2: Compliance with applicable laws and regulations Criterion 2.1: There is compliance with all applicable local, national and ratified international laws and regulations Findings: Comments: Compliance  Clear compliance with the law in all  “Legal requirement register” listing all the laws Yes areas sampled. applicable and copies of laws are in the office. Any  Good systems in place to track and changes in the law are advised to the managers. implement changes in the law. Applicable laws were verified against

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 19 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO  The laws affecting the oil palm industry implementation and found to be in compliance. are listed and available to all managers.  Document checks on licences and permits, statutory returns and other laws confirmed implementation.  Qualifications of relevant staff were checked and verified such as electrician and boiler men.  Total Quality Environment Management dept in KL circulates all relevant changes in the law. If the mill finds relevant changes, then the mill will inform the TQE dept.  Boilers are checked for smoke density detector and found to be equipped with. Criterion 2.2: The right to use the land can be demonstrated and is not legitimately contested by local communities with demonstrable rights Findings: Comments: Compliance  Land titles / country leases for all  Land titles inspected for all estates and the mills Yes properties in accordance with the law of and the number of land titles varies from 14 to over the land. 30.  No need for boundary stones.  No restrictions noted in terms of the land titles  The company has mechanism for the noted as being abused. resolution of conflicts and where there  No land disputes noted. have been disputes; there is proof of progress in an acceptable manner to all parties.  Land acquisition has been with free prior and informed consent. Criterion 2.3: Use of land for oil palm does not diminish the legal or customary rights of other users without their free, prior and informed consent. Findings: Comments: Compliance  No customary rights.  No customary rights noted. Yes 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.  Annual budget with a minimum 2 year  The audited estates and mills are part of Sime Yes projection. Darby Plantations Sdn Bhd called Strategic  Annual planting programme projected Operating Units (SOUs). for a minimum of 5 years with yearly  Overall financial management and responsibility is review. located at the corporate Head Quarters of the Group.  However, expenditure budgets and productivity targets for the current financial year and subsequent 3 years are available for all operating units. The budget includes all relevant data such as FFB yield/Ha, OER, CPO yield/Ha and the whole expenditures.  The financial year runs from 1 July to 30 June the following year. Sime Darby is majority state owned, and the second largest oil palm plantation in Malaysia and given the importance of oil palm for the Malaysian economy, long term financial support is assured.  Group replanting schedule available until 2018/2019. Principle 4: Use of appropriate best practices by growers and mills Criterion 4.1 Operating procedures are appropriately documented and consistently implemented and monitored. Findings: Comments: Compliance  The company has generic SOP’s, which  All plantations have SOP from land clearing to Yes are up to date and which cover all harvesting, which mainly emphasize on safe plantation and mill activities from working practices on all high risk areas.

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 20 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO seedling to the despatch of CPO and  All mills: Mill Quality Management System. 16 PK or PKO. sections and numerous sub sections covering all  The company has comprehensive aspects of mill management. SOP contains the safe annual monitoring records. working methods as well. This is noted through the sign boards on safety awareness.  Smoke Emissions. BOD. Water usage. Water analysis. FFA. Kernel moisture. Oil loss. Kernel loss etc. Records inspected.  All estates: 3 files:

1. Estate Quality Management System for all estates. Comprehensive file covering all management system associated with oil palm growing. 2. Agricultural Reference manual gives justification and policy in support of the EQMS. 3. Sustainable Plantation Management System – RSPO manual.

 Comprehensive range of monitoring and record keeping inspected and maintained for a minimum of 12 months. Criterion 4.2: Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield Findings: Comments: Compliance  The company has records of regular  Annual foliar analysis carried out by Sime Darby Yes soil, leaf and visual analysis. Leaf Research. Recommendations are given to the analysis is conducted on an annual individual estate and these maybe updated during basis to determine fertiliser regimes. the year. The records for all estates were inspected  All fertiliser regimes are well planned; and it was found that the actual fertiliser, EFB and implemented and recorded. POME applications were in accordance with the  Legume cover is used. recommendations.  EFB application to areas determined by  Zero burn policy. Clearly evident. the foliar analysis.  EFB application monitored by ha and Mt.  POME is used for land irrigation.  POME used for land application.  Good monitoring of fertiliser inputs.  Application records inspected.  Criterion 4.3: Practices minimise and control erosion and degradation of soils. Findings: Comments: Compliance  Documented evidence of practices to  SOP section B6. Soil and Water conservation in Oil No minimise soil erosion. Palm Field. Covers slopes. Highly erodible soils.  Weeding programmes minimise bare or Poor canopies. Planting platforms. Mulching. Water exposed soils. conservation. Moisture pits and fond placement.  Comprehensive road maintenance Avoidance of bare soils. programme.  Soil maps for some estates.  No peat or fragile soils noted.  Terrace planting and cover crops, mulching is in practice to prevent soil erosion on hilly areas.  The weeding programmes were discussed with all managers. Spraying regime is spot spraying and harvester routes, plus noxious weeds. Site inspections show good to excellent retention of ground cover.  A road maintenance schedule is in place for all estates. General format: By month and field number: The following operations are included: Grading / Cambering. Filling potholes / Crusher run. Re-surfacing / Laterite.  Soils are not considered to be fragile or problematic. Soils maps available for most estates. They are not considered to be fragile. There is no 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 21 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO peat of any significant depth.  SOP section B4, only mentions weeding and spraying in the plantation and makes no reference to roadside. Unnecessary spraying of a 2m wide band alongside roads on some estates is resulting in bare ground and erosion. Criterion 4.4: Practices maintain the quality and availability of surface and ground water. Findings: Comments: Compliance  Water courses (and wetlands) are  SOP B6 covers soil and water conservation. There Yes identified on maps and management is a slope protection and river buffer zone policy plans are in place for restoring riparian detailing buffer zones to be maintained in relation to buffer zones. river width and for Peninsular Malaysia, Sarawak  No construction of bunds/weirs/dams and Sabah. across the main waterways.  All estates have identified watercourses and the  Water management includes the appropriate width of buffer zone is established (in monitoring of all water courses as they accordance to guidelines by the Drainage and enter and leave the estate(s). Irrigation Department) and the non-maintenance  Rainfall monitored. programme is then implemented i.e. no fertiliser  Good levels of water usage per tonne of applications and spraying of agrochemicals within FFB processed. riparian zones.  No drainage into protected areas.  No evidence of any bunds/weirs or dams on any  Water management plans in place. estate.  Monitoring of water points identified on all estates. Water samples are taken and sent for analysis to detect BOD level. Drinking water analysis is carried out to detect coli form and e-coli and results showed that there is none detected.  Rainfall monitored and results used by management.  Between 0.6 and 1 tonne of water used for every 1 tonne FFB processed.  No protected areas noted.  Water management plans inspected in all mills and estates. Criterion 4.5: Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate integrated Pest Management (IPM) techniques Findings: Comments: Compliance  Documented and implemented IPM  Integrated pest management and pest and disease Yes system. control. Chipping and pulverizing of felled palm  Monitoring of IPM used, which includes trees. Use of biological, pesticide and manual the training of staff and workers. control.  Planting of beneficial plants.  Census. Identification. Treatment. Evaluation and  Record of pesticide use per ha. record keeping.  Monitoring of pesticide toxicity units.  Throughout all estates the use of beneficial plants such as Tunerasubulata, Cassia cobanensis, Antigonon spp. are very evident. Replant sites are restructured to allow enough light for these plants. Leguminous cover crops are also well-established to suppress growth of noxious weeds. Barn owl boxes, with a high percentage of occupancy. The barn owls are effective in rat the control of rats. Criterion 4.6: Agrochemicals are used in such a way that does not endanger health or the environment. There is no prophylactic use, and where agrochemicals are used that are categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented. Findings: Comments: Compliance  Written justification for all  SOP B4 covers the use of agrochemicals. The Yes agrochemicals used. Agricultural Reference Manual (An integral part of  All pesticides are officially registered. the SOP’s) section 1.1.1 and 1.1.2.  Well ventilated and secure chemical  Register of chemicals used by the operating units. 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 22 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO stores with MSDS leaflets and first aid.  MPOA Circular on approved list of pesticides  Annual medical checkups. registered for Oil Palm (ref April 2007). All a.i used  No work with pesticides for confirmed or is included in the list. breast feeding woman.  Glyphosate is used as substitute.  The use of WHO type 1a or 1b  The chemical stores inspected all conform to the chemicals, such as paraquat has requirements. Locked and ventilated. MSDS ceased. leaflets. First aid kits. Warning notices. Separate  No aerial spraying. chemical mixing areas so pre-mixed herbicides and  CPO testing for residues. pesticides are taken into the field. Remaining  Records of use of pesticides. balance of pesticide are kept locked and the store keeper is responsible for accounting and access.  Chemical traps. Showers and eye wash. Washing facilities and storage of PPE. PPEs are supplied by competent suppliers and this was checked during the audit. PPEs issuance is recorded and monitored.  One person is in charge of each store and has the access key. This person may be able to speak English but MSDS leaflets are either in English or Malay as appropriate. Training of all workers includes explanations of the chemicals being used and this was confirmed by worker interviews. There is no class 1a pesticides used, and records of other class pesticides used are maintained.  Medical records for all workers. No problems noted related chemical use. Only heat exhaustion! First aid kit is given to the mandore at field and available on all sites. Those first aid kits will be checked by the HA on regular basis and inventory is kept to counter check.  Annual checkups are adhered to for all, especially sprayers. Records inspected. Women sprayers interviewed confirmed that they are medically examined (eyes, lungs, blood test, etc) annually. Medical reports are signed by the doctor and the workers are verified if they are fit for work. It is also confirmed that there is no occupational disease or any other disease due to the pesticide spraying work and this was confirmed by the interview of workers and HA. All medical records including audiograms and check up records are maintained.  Women sprayers interviewed are aware of the” no work for confirmed pregnant and breast feeding woman” policy and of the risks of spraying while pregnant and breastfeeding. They are also aware of the process in informing Management of their pregnancy. Management confirms the pregnancy via medical check-up. This is covered in the SOP. Alternative jobs (lighter work) are given to pregnant and lactating women. This was also confirmed during worker interviews.  Spraying areas are alerted with sign boards of hazards. Criterion 4.7: An occupational health and safety plan is documented, effectively communicated and implemented Findings: Comments: Compliance  OSH plan in place.  The OSH plans and documents are well thought Yes  Accident records kept and reviewed. out and are also displayed in the work places.  Accident insurance in place. There is a fire drill team which is formed among the staffs and training has been provided. POM:

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Report number: 815150RSPOCUCRPT -2010-01-DO  The policy is reviewed after each financial year.  25 employees, including managers and workers form the OSH committee. A meeting every month. All aspects are discussed. Every morning a safety briefing is given,  Risk assessment criteria laid out in a file covering all operations. Used during training. All workers are trained prior to starting work and the weekly assembly is used for additional training and for emphasising the importance of wearing PPE etc. Hazard Identification, Risk assessment and risk control (HIRARC) file includes risk assessments for all mill activities. Included in the training of all staff.  Daily toolbox briefing. General issues and re- iteration of OSH requirements.  PPE is supplied and worn.  The noise level of 90dB is complied with and this is being observed and monitored continuously. Workers in high noise area workers were interviewed for further investigation, but there was no issues found. All estates:  Dated April 2008. Policy is displayed in offices and at muster grounds. It is explained to workers at all musters on a daily basis. Training. OSH meetings. See also OSH manual.  HIRARC file contains risk assessments for all operations and all workers have copies of the relevant risk assessments in local language.  All workers are trained.  PPE provided free of charge. Site observations confirmed correct use. Records on file of PPE distribution and records of checks of use of PPE.

Estates and Mills:  Estate or mill manager has overall responsibility as chairman of the OSH committee.  Records are maintained on file.  Accident and emergency procedures are in place and understood by all staff and workers interviewed.  Trained first aiders noted on all sites.  First aid kits noted and inspected. Regularly inspected by management and replenished as soon as any item is used.  Interviews with workers confirmed knowledge of the plans and procedures and first aid training records were inspected and also confirmed by interview.  Safe working environments observed in mills and places of work. Criterion 4.8: All staff, workers, smallholders and contractors are appropriately trained Findings: Comments: Compliance  Training plans and records are in place  Training matrix and training records in place. Yes as appropriate for all staff and workers. Target dates for all workers including actual dates  Contractors are trained in accordance and the names of the trainers. with company procedures.  The training modules identify all risk areas and its related trainings as well as for pesticide and agrochemical hazards to all relevant workers. All contractors are included in the training where it is relevant. 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 24 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO  The training programmes were assessed against the relevant needs and found to be appropriate.  All estates: Training matrix showing training needs and plan file: Details of training requirements for all levels of management and workers. Training programme file: Detailed training records for all workers. Principle 5: Environmental responsibility and conservation of natural resources and biodiversity Criterion 5.1: Aspects of plantation and mill management 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 Findings: Comments: Compliance  Documented and implemented impact  Identification of impacts which are rated according Yes assessments in accordance with RSPO to their potential impact on the environment. For all and legal requirements. risks rated over a certain level results in an  Environmental improvement plans in environmental improvement plan. place. Criterion 5.2: The status of rare, threatened or endangered species and high conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations Findings: Comments: Compliance  HCV assessments completed.  For each estate biodiversity areas are identified. Yes  Management plans in place. River buffer zones. Agro forestry. Graveyards.  Inappropriate hunting, fishing and Worship areas. Bordering forests. Action to be collecting activities are discouraged. taken is listed and records on file are in both photographic and map format.  Site inspections confirmed that action is being implemented. Criterion 5.3: Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner. Findings: Comments: Compliance  Waste products have been identified  Scheduled Waste management file identifying all Yes and documented. waste. Including Lead acid batteries. Spent  Plans to avoid pollution are in place. Hydraulic Oil. Oily residue form workshops. Clinical  Biomass is recycled. waste. Tag, plastic, paper etc, Waste from production, formulation, pesticide/herbicide or biocides. i.e. contaminated containers. Waste management action plan 2008/2009.  Stores inspected at all sites and disposal by scheduled company confirmed.  EFB recycled in the fields. POME is used for land application form all mills.  Sample of effluent discharge is sent for analysis of the BOD level and report is shown. The parameters set by authority is well adhered to and results are within the limit.  Boilers are monitored through boiler register where maintenance details are available. Dust and emission factors are also monitored and it is within the limit.  Operational plans to avoid and reduce pollution are incomplete and there is no clear evidence of implementation. Criterion 5.4: Efficiency of energy use and use of renewable energy is maximised Findings: Comments: Compliance  All energy used in the mills is  Monthly record showing fibre and shell produced Yes monitored. and boiler usage.  Fossil fuel records are maintained and  Diesel consumption usage recorded. trends shown.

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Report number: 815150RSPOCUCRPT -2010-01-DO 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 guidelines or other regional best practice Findings: Comments: Compliance  The use of fire is not allowed for any  SOP’s and evidence on ground. Yes land preparation or for replanting.  No evidence of burning anywhere on any estate.  No evidence of burning waste.  Previous crops chipped and shredded.  Domestic waste is removed by contractors to government land fill sites. Criterion 5.6: Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and monitored. Findings: Comments: Compliance  Documented plans to mitigate all  Management of Waste Generated by Estates. 5.6.1 Yes polluting activities. – reviewed annually. Scheduled waste. Oil palm biomass i.e. Pruned 5.6.2 No  No peat land. fronds, Felled palms, and empty fruit bunches are 5.6.3 Yes  Non conformity raised relating to 5.6.2. returned to the field.  Pollution prevention plans in place for mills.  5.6.2: On a number of estates, diesel tank bunds were noted to be in-adequate. Bunds too small. Cracked. No valves on drain pipes. Valves left on – no locks to ensure they remain off until drainage. Principle 6: Responsible consideration of employees and of individuals and communities affected by growers and mills. Criterion 6.1: Aspects of plantation and mill management that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement Findings: Comments: Compliance  Documented and implemented social  One SIA each for SOU 13, 15, 31,32, 33, &34. Yes impact assessments prepared in  For each estate: participation with affected parties, for District. plantations and mills. Nearest town. Villages adjacent. Total estate population. Total workers. Religions. Houses. Gender and type of work.

 This is a comprehensive report including FPIC principles of consultation. For each estate there is a list of issues that may affect local communities with management proposals.  For each RSPO Principle and criteria, there is compliance requirement, action required and remarks.  A documented procedure is included and identifies the need to interview members of the local community.  The social impact assessments do not include clear responsibilities for mitigation and monitoring and it is not clear when they are reviewed and updated. 6.2 There are open and transparent methods for communication and consultation between growers and/or mills, local communities and other affected or interested parties

Findings: Comments: Compliance  Clear and transparent systems of  Estate Quality Management System Sub section Yes consultation and communication with 5.5. Procedure for external communication which local stakeholders. includes a flow diagram of the process. An assistant  Identified lines of communication. manager is responsible at each estate for consultation and communication. Individual interviews with managers confirmed that the procedure is being followed.

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Report number: 815150RSPOCUCRPT -2010-01-DO  The contractor management file includes a list of all stakeholders. (These lists were used by CU for stakeholder consultation one month prior to this RSPO audit). 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 Findings: Comments: Compliance  There is a complaints and dispute  Plantation Quality Management System. Appendix 6.3.1 Yes resolution procedures which is 5. Procedures for handling social disputes. Flow 6.3.2 No demonstrably accepted by potentially chart included. (Procedures for other disputes also 6.3.3 Yes affected parties. included).  Procedure is fully available to all.  No grievances / serious disputes noted  The requests for improvements were inspected at all estates and it was found that they were instigated in a very timely manner. 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 stake holders to express their views through their own representative institutions Findings: Comments: Compliance  Procedure in place for identifying legal  No customary rights noted. Yes and customary rights and a procedure for identifying people entitled to compensation. Criterion 6.5: Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages. Findings: Comments: Compliance  Documented pay and conditions.  Pay and conditions and contracts were inspected in Yes  Labour laws, union agreements and all offices and discussed during worker interviews. contracts of employment are in place They are understood by all workers. Pay slip were and in the appropriate languages. verified. It is noted that the deductions are made in  Adequate housing, water supplies, accordance with law and deduction permits are medical, educational and welfare available. The locals protected by SOCSO and amenities are provided. foreign workers by the Group Insurance. Foreign workers have valid work permits. The NUPW/ MAPA agreements are also available and sighted.  Line-sites were inspected and it is noted that water supplies and electricity comes directly from the main government supplies. Worker interviews: Satisfaction with the housing, which was inspected at all estates. Workers housing facilities complies with housing act and requirements. Total Employees for each SOU with the supply base and their housing units are as follows:  SOU 13- Employees=1,065 and Housing Units=460  SOU 15- Employees=2,671 and Housing Units=961  SOU 31- Employees=3,034 and Housing Units=421  SOU 32- Employees=2,273 and Housing Units=518  SOU 33- Employees=2,382 and Housing Units=374  SOU 34- Employees=2,326 and Housing Units=550  Clinics at all estates. . Medicine stocks are kept up to date and stored in racks and are locked up. There is female nurse for assistance. Mosques. Churches. Places of worship. Sports facilities. Creche are taken care by baby sitters, and 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 27 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO there are toys for children. The HA and VMO visits the creche on regular basis. 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 Findings: Comments: Compliance  Published statement recognizing  Minutes of meeting with worker reps are recorded. Yes freedom of association. Meeting with worker reps is through the various  Minutes of meetings with trade unions committees (eg: OSH Committee, and Sexual and worker representatives. Harassment Committee). 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. Findings: Comments: Compliance  There is a documented and published  Interviews and inspection of records and labour Yes company policy on worker ages in registration cards confirmed no employment of accordance with national laws. children below the age of 18. 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. Findings: Comments: Compliance  There is a publicly available equal  Policy displayed in office and muster grounds. Yes opportunities policy. Wage records inspected and rates confirmed as  No evidence of discrimination. Workers being the same for male and female workers and are treated equally with regard to migrant workers. working opportunities. 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. Findings: Comments: Compliance  Well displayed and clear policy on  Policy publicly displayed in office and at line-site. Yes sexual harassment and violence.  Worker interviews confirmed that no sexual  The company has set up a specific harassment takes place. gender committee to facilitate the grievance mechanism. Criterion 6.10: Growers and mills deal fairly and transparently with smallholders and other local businesses. Findings: Comments: Compliance  The pricing mechanism for FFB and  Interviews with suppliers of services confirmed that Yes other services provided to both the they are fairly treated and paid promptly. mill(s) and the estates is documented.  The pricing mechanism for FFB is understood and  Current and past prices for FFB are accepted. publicly available. Criterion 6.11: Growers and mills contribute to local sustainable development wherever appropriate. Findings: Comments: Compliance  The company makes contributions for  Structure and responsibility file gives details of Yes local development and records are contributions to local communities. maintained.  Observation raised. Principle 7: Responsible development of new plantings. Criterion 7.1: A comprehensive and participatory social and environmental impact assessment is undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management and operations Findings: Comments: Compliance No new planting planned on any estate  Not applicable. n/a included in the scope of this assessment. Criterion 7.2: Soil surveys and topographic information are used for site planning in the establishment of new plantings, and the results are incorporated into plans and operations Findings: Comments: Compliance No new planting.  Not applicable. n/a Criterion 7.3: New plantings since November 2005 have not replaced primary forest or any area containing one or more high Conservation Values 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 28 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO Findings: Comments: Compliance No new planting.  Not applicable. n/a Criterion 7.4: Extensive plantings on steep terrain, and/or on marginal and fragile soils, are avoided. Findings: Comments: Compliance No new planting.  Not applicable. n/a Criterion 7.5: No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their own representative institutions Findings: Comments: Compliance No new planting.  Not applicable. n/a 7.6 Local people are compensated for any agreed land acquisitions and relinquishment of rights, subject to their free, prior and informed consent and negotiated agreements. Findings: Comments: Compliance No new planting.  Not applicable. n/a Criterion 7.7: Use of fire in the preparation of new plantings is avoided other than in specific situations as identified in the ASEAN guidelines or other regional best practices Findings: Comments: Compliance No new planting.  Not applicable. n/a Principle 8: Commitment to continual 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 continual improvement in key operations Findings: Comments: Compliance  Clear evidence of continual Continuous improvement programme for 2009 for all Yes improvement in key areas. estates.  Planting of beneficial plants. Training on calibration of sprayers. Cattle project. Planting beneficial plants. Barn owl boxes 1/10ha. Census of barn owl is recorded.  Maximising recycling and minimise waste.  Scrap iron, Disposal of lubricants, Spent batteries, Empty chemical containers are kept separately at the schedule waste storage area. Empty fertiliser bag, used oil.  Using of recycle trash bin inside the line site, divide between glass, paper and plastic.  Pollution prevention plan available in the Environment Management programme 2008/2009. Ex: Zero spillage in POME application, Management planned to have pipe and valve maintenance to be done in 20th June 2009.  Pollution prevention plan inside the environment impact management plan. Ex: avoid discharge of waste water and septic tank into sensitive areas identified to reduce water quality due to grey water from line site area.  Using spill kit to treat chemical leakage. Using tray on the workshop to treat oil leak.  Plan to upgrade existing playground. Plans to have stakeholder meeting once every 4 months. Social impact assessment done through discussion during stakeholder meeting. Upgrading of line sites.

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Report number: 815150RSPOCUCRPT -2010-01-DO

3.3 Non conformity register. This section gives an over view of new or revised non-conformities raised during this assessment and of action taken to close out non-conformities raised during the previous assessments. Major non-conformities raised during a main assessment will prevent CU from making a positive certification decision for the concerned units/products. The NC number is comprised of 2 parts to include the year in which the NC is raised as well as a sequential number.

Date: 25/02/2009 Number settled. Number outstanding. 5

NON CONFORMITY REPORT NC number: 07/2009 Client name: Sime Darby Date raised: 19/05/2009 Major or Minor: Minor Raised by: David Ogg Aspect of standard: 4.3.1. Documented evidence of practices minimizing soil erosion and degradation (including maps). Evidence of non-conformity: Not all estates have soil maps.

Assessors signature:

Date: 19th May 2009. Proposed corrective action / improvement action by company.

Timeline for conformance: Time of next annual surveillance.

NON CONFORMITY REPORT NC number: 08/2009 Client name: Sime Darby Date raised: 19/05/2009 Major or Minor: Minor Raised by: David Ogg Aspect of standard: 4.3.2. Avoid or minimize bare or exposed soil within estates. Evidence of non-conformity: SOP section B4, only mentions weeding and spraying in the plantation and makes no reference to roadside. Unnecessary spraying of a 2m wide band alongside roads on some estates is resulting in bare ground and erosion.

Assessors signature:

Date: 19th May 2009. Proposed corrective action / improvement action by company.

Timeline for conformance: Time of next annual surveillance. 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 30 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO

NON CONFORMITY REPORT NC number: 09/2009 Client name: Sime Darby Date raised: 19/05/2009 Major or Minor: Minor Raised by: David Ogg Aspect of standard: 5.3.2. Having identified wastes and pollutants, an operational plan should be developed and implemented, to avoid or reduce pollution. Evidence of non-conformity: Operational plans to avoid and reduce pollution are incomplete and there is no clear evidence of implementation.

Assessors signature:

Date: 19th May 2009. Proposed corrective action / improvement action by company.

Timeline for conformance: Time of next annual surveillance.

NON CONFORMITY REPORT NC number: 10/2009 Client name: Sime Darby Date raised: 19/05/2009 Major or Minor: Minor Raised by: David Ogg Aspect of standard: 5.6.2 (Relating to the reduction of pollution) Plans are reviewed annually. Pollutants and emissions are identified and plans to reduce them are developed in conformance to national regulations and guidance. Evidence of non-conformity: On a number of estates, diesel tank bunds were noted to be in-adequate. Bunds too small. Cracked. No valves on drain pipes. Valves left on – no locks to ensure they remain off until drainage. Assessors signature:

Date: 19th May 2009. Proposed corrective action / improvement action by company.

Timeline for conformance: Time of next annual surveillance.

NON CONFORMITY REPORT NC number: 11/2009 Client name: Sime Darby Date raised: 19/05/2009 Major or Minor: Minor Raised by: David Ogg Aspect of standard: Reference to Social Impact Assessments. 6.1.3 A timetable with responsibilities for mitigation and monitoring reviewed and updated as necessary. 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 31 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO Evidence of non-conformity: The social impact assessments do not include clear responsibilities for mitigation and monitoring and it is not clear when they are reviewed and updated.

Date: 19th May 2009. Proposed corrective action / improvement action by company.

Timeline for conformance:Time of next annual surveillance.

Observations. Client name: Sime Darby. Date raised: 19/05/2009 Raised by: David Ogg There is still a general miss-understanding of the HCV concept with some riparian zones being classified as HCV 4 when it is quite clearly inappropriate to do so. Whilst there are biodiversity plans for all estates, which identify HCV and give a management plan, it is an observation at this time that local knowledge is poor.

Training of local managers would be of benefit and the audit team will expect to see a more pro-active approach by estate managers at the annual surveillance.

19/05/2009

3.4 Issues raised during stakeholder consultation and company responses.

Thursday 25th June 2009: Ladang Siliau: 20 attendees. Wednesday 8th July 2009: Ladang Rajawali: 14 attendees. Subject raised Company response and proposed Assessment team findings action to be taken. Local native stakeholder in Rajawali The locals are very selective and not No action required. requested that more job opportunities able to accept the job opportunity and transport contracts to be given to offered by the management. them.

FFB Transport contractor in Rajawali There is a plan to review the present No action required. highlighted that their contract is contract system. Will be discussed with renewed on monthly basis. Requested individual contractors on estate basis. possibility to renew annually.

Contractors in Rajawali said that The contract is given to them and they Discussion with the managers reveals payment is prompt and no difficulty in can go through the details. that the contract is given and the meeting management but sometimes contractor is able to keep it. when contract is signed they are not given enough time to read the No action required. contract.

Suppliers in Siliau gave positive No action required. Positive comment. comment. Their payments are prompt. Documents assessment confirmed that payments are made promptly. 1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 32 of 33

Report number: 815150RSPOCUCRPT -2010-01-DO Contractors in Rajawali find it difficult It is against the company policy and No action required. to get workers/qualified drivers. local immigration law. Recruitment seems very difficult. Asked whether the company can allocate some AP (Application Principle) to recruit worker.

Grass near the houses not cut or Site inspection shows that the problem No action required. controlled. Snakes. Complaints raised. is over-exaggerated. The grass cutting programme is in place and being carried out accordingly. Pruning contractors are asking to The different rate is already in practise No action required. revise the rate for tall palms. and paid based on overall average. Pruning contractors are not clear The management agrees to inspect No action required. about the standard required. If immediately after work is done. possible they requested for immediate inspection after their work is completed.

Estate School at Ldg. PD Lukut Already cut and removed all the huge To be reviewed at annual surveillance. (Sendayan Div) – building is old. The trees around, for fencing and school requested for painting, fencing, RM 20,000 spent on this operation guard house and electricity subsidy. already. The fencing and other issues The manager agreed to assist but will be attended by the management on have not complied fully. next phase.

Request for salary increment every Term and contract is as per No action required. year. NUPW/MAPA collective agreement. Stakeholder asks the role of Company agrees to carry out more To be reviewed at annual surveillance. stakeholders in RSPO assessment. briefings to stakeholders on their role in RSPO assessment.

3.5 Formal sign off of assessment findings. 3.5.1 Acknowledgement of internal responsibility by the client.

I the undersigned, being the legal representative of the inspected company, agree with the contents of this report and accept the liability in execution of the instructions given in the report. SOU 13, 15, 31, 32, 33 and 34. Name: Zuhairi Zubir Position: Assistant Vice President 1 Signature:

Date: 20th February 2011.

1.8 Public summary. RSPO. Sime Darby 2010. Malaysia.Page 33 of 33