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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 1 of 48 (SOU 16 Kok Foh: ASA-03)

Sime Darby Plantation Sdn Bhd RSPO Membership No: 1-0008-04-000-00 Plantation Management Unit SOU 16 Kok Foh (N. Sembilan) and (),

Assessment Report

"This report (including any enclosures and attachments) has been prepared for the exclusive use and benefit of the addressee(s) and solely for the purpose for which it is provided. Unless we provide express prior written consent, no part of this report should be reproduced, distributed or communicated to any third party. We do not accept any liability if this report is used for an alternative purpose from which it is intended, nor do we owe any duty of care to any third party in respect of this report."

Intertek RSPO Report: June 2014

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 2 of 48 (SOU 16 Kok Foh: ASA-03)

ANNUAL SURVEILLANCE ASSESSMENT (ASA-03)

ON RSPO CERTIFICATION

PUBLIC SUMMARY REPORT

SIME DARBY PLANTATION SDN BHD

RSPO Membership No: 1-0008-04-000-00

PLANTATION MANAGEMENT UNIT SOU 16 Kok Foh Bahau (N. Sembilan) and Gemas (Johor), Malaysia

Certificate No: RSPO 928188 Issued date: 7 July 2012 Expiry date: 6 July 2016 (Note: Original Cert. No: C819157CU-RSPO-01.2011 was issued by Control Union Certification on 7 July 2011 and valid until 6 July 2016)

Assessment Type Assessment Dates Initial Certification 18-19 May 2009 (by Control Union Certification) (Main Assessment) Annual Surveillance Assessment (ASA-01) 18-22 June 2012 (by Intertek Certification International) cum Transfer Annual Surveillance Assessment (ASA-02) 10-14 June 2013 Annual Surveillance Assessment (ASA-03) 20-23 May 2014 Annual Surveillance Assessment (ASA-04) Re-Certification

Intertek Certification International Sdn Bhd (formerly known as Moody International Certification (Malaysia) Sdn Bhd) 6-L12-01, Level 12, Tower 2, Menara PGRM No. 6 & 8 Jalan Pudu Ulu, Cheras, 56100 , Malaysia. Tel: +00 (603) 9283 9881 Fax: +00 (603) 9284 8187 Email: [email protected] Website: www.intertek.com

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TABLE OF CONTENTS

Section Content Page No 1.0 SCOPE OF SURVEILLANCE ASSESSMENT 1.1 Introduction 4 1.2 Location (address, GPS and map) mill, estates and hectarage 4 1.3 Description of supply base (fruit sources) 5 1.4 Year of plantings and cycle 6 1.5 Summary of Land Use, Conservation and HCV Areas 7 1.6 Other certifications held and Use of RSPO Trademarks 7 1.7 Organizational information/contact person 7 1.8 Tonnages Verified for Certification 8-9 1.9 Time Bound Plan 9 1.10 Abbreviations Used 10 2.0 ASSESSMENT PROCESS 2.1 Assessment Methodology, Plan & Site Visits 11 2.2 Date of next scheduled visit 11 2.3 Qualifications of the Lead Assessor and Assessment Team 11 2.4 Certification Body 11 2.5 Process of Stakeholder consultation 12 3.0 ASSESSMENT FINDINGS 3.1 Summary of findings 13-41 3.2 Status of Identified Noncompliance and Corrective Actions, Observations and 42-45 Identified Positive Elements 3.3 Feedback Received from Stakeholders and Findings 45 4.0 ASSESSMENT CONCLUSION AND RECOMMENDATION 4.1 Acknowledgement of Internal Responsibility and Confirmation of Assessment Findings 46

4.2 ICI RSPO Certification Details for SOU 16 Kok Foh 47

APPENDICES Appendix Page Appendix A Qualifications of the Lead Assessor and Assessment Team 1 Appendix B Assessment Plan 2-3 Appendix C Maps of location – Mill and Estates 4-13 Appendix D Photographs of Assessment findings at SOU 16 Kok Foh 14 Appendix E Time Bound Plan for Other Management units 15-16

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1.0 SCOPE OF SURVEILLANCE ASSESSMENT

1.1 Introduction This Annual Surveillance Assessment (ASA-03) was conducted on the Strategic Operating Unit (SOU) 16 Kok Foh of Sime Darby Plantation Sdn. Bhd. (SDPSB), from 20 to 23 May 2014, to assess the organization’s operations of the mill and its supply bases, for continued compliance against the RSPO Principles and Criteria (Apr 2013), Malaysian National Interpretation (MY- NI, Nov 2010) and RSPO Supply Chain Certification Standard (Nov 2011) for Palm Oil Mill. This assessment also includes a review of the changes made by the PMU to comply with the requirements of the ratified new RSPO Principles and Criteria (effective 25 April 2013). It was found that the PMU is aware of the new RSPO Principles and Criteria and the transition period for compliance but is in-progress of updating necessary changes required.

Note: Sime Darby’s, Strategic Operating Unit (SOU) or management unit is equivalent to a certification unit as defined in the RSPO Certification Systems document. Each SOU consists of one palm oil mill and its supply base which is mainly made up of estates owned by SDPSB and may include some outside crop producers (OCP).

1.2 Location (address, GPS and map) of palm oil mill and estates SOU 16 consists of one (1) palm oil mill, namely Kok Foh Palm Oil Mill and eight (8) own supplying estates as indicated in Table 1 below, which includes the addresses and GPS locations of the mill and estates. The location maps are provided in Appendix C. Table 1: Address of Palm Oil Mill, Estates and GPS Location

GPS Reference Name Address Latitude Longitude Kok Foh POM Kok Foh Palm Oil Mill, 72109 Bahau, 2°47.08’ N 102°30.25’ E (Capacity: 40 MT/hour) , Malaysia Kok Foh estate, 72109 Bahau, 1. Kok Foh estate 2°47.08’ N 102°30.25’ E Negeri Sembilan, Malaysia 2. Sg. Senarut estate Sg. Senarut estate, 85100 , 2°34.16’ N 102°45.20’ E Johor, Malaysia 3. River estate estate, Locked Bag No.503, 2°34.26’ N 102°45.08’ E 85009 Segamat, Johor, Malaysia 4. estate Pertang estate, 72300 , 2°57.25’ N 102°18.12’ E Negeri Sembilan, Malaysia 5. Sg. Gemas estate Sg. Gemas estate, 73400 Gemas, 2°34.73’ N 102°38.86’ E Johor, Malaysia 6. Bukit Pilah estate Bkt Pilah estate, 73500 Rompin, 2°33.73’ N 102°55.91’ E Negeri Sembilan, Malaysia. 7. St. Helier estate St. Helier estate, 72100 Bahau, 2°33.72’ N 102°33.73’ E Negeri Sembilan, Malaysia 8. Sg. Sabaling estate Sg. Sabaling estate, 72100 Bahau, 2°50.56’ N 102°29.03’ E Negeri Sembilan, Malaysia.

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1.3 Description of supply base (fruit sources) The main supply base i.e. FFB sources to the POM at SOU 16 Kok Foh PMU are from the abovementioned 8 estates which are owned by SDPSB. The POM also received FFB diverted from estates of other certified SOUs of SDPSB. SOU 16 Kok Foh also receive FFB from other independent suppliers/smallholders known as Outside Crop Producers (OCP). The supply of FFB from the OCP has been categorized as non-certified FFB. Note: Progress of the 3 year implementation plan towards compliance with the relevant RSPO standards for the OCP has been monitored by SDPSB. SDPSB confirmed that their OCP were not yet prepared for compliance.

Details of the planted hectarage for the FFB supply for SOU 16 are as shown in Table 2 below.

Table 2: Estate Area Summary - FY Jul 2013 / Jun 2014

Area Summary (ha) – FY Jul 2013 / Jun 2014 Estate Certified Area Planted Area - Oil Planted Area – Rubber (ha) Palm (ha) (ha) Kok Foh estate 2,307.85 2,166.00 0 (Assessed in ASA-01 & 03)

Sg. Senarut estate 1,988.77 557.69 1,213.68 (Assessed in ASA-02) Muar River estate 1,596.94 1,471.21 0 (Assessed in ASA-01 & 03) Pertang estate 1,070.52 749.14 234.18 (Assessed in ASA-02) Sg. Gemas estate 970.61 879.31 0 (Assessed in ASA-02) Bukit Pilah estate 3,667.31 795.03 2,762.96 (Assessed in ASA-01) St. Helier estate 1,992.65 955.95 956.15 (Assessed in ASA-02)

Sg. Sabaling estate 124.66 1,129.05 (Assessed in ASA-01 & 03) 1,321.35 Total: 14,916.00 7,698.99 6,296.02 Percentage: 100% 51.62% 42.21% *Note: A GPS re-survey exercise was done last year, 2013 and the Eestates have started using new GPS survey hectarages that have slight variance compared to previous year data.

Notes: 1. This surveillance assessment covered the overall land use for both oil palm and rubber plantation areas, and the identified Conservation areas including HCV areas marked out at the selected estates. 2. The estates sampled for this surveillance assessment have been selected based on their potential risks on social, environmental and biodiversity issues such as their proximity to forest reserves, hill sides, riparian zones and high conservation value areas. 3. Substantial portions of the certified areas at several estates such as at Bukit Pilah, St.Helier and Sg. Sabaling estates have been originally cultivated as rubber trees plantation areas since 1982 and remain as such with smaller areas cultivated with oil palms at later stages since 1988. Currently the oil palm plantation area is about 52% of the total certified area.

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1.4 Summary of plantings and cycle The 8 estates had been developed beginning from 1982 and are all currently in the 2 nd cycle of planting for the Oil Palms. The age profile is as shown in Table 3.

Table 3: Age Profile of Planted Oil Palm (FY Jul 2013 / Jun 2014)

Mature OP Immature OP Estate Name Year of Planting Cycle of Planting - Above 3 years - 3 years & below (ha) (ha) Kok Foh estate 1995-2002 2nd 2,166.00 - Sg. Senarut estate 2001-2006 2nd 557.69 - Muar River estate 2011-2014 2nd 1,186.52 284.69 Pertang estate 2013 2nd 681.84 67.30 Sg. Gemas estate 1996-2001 2nd 879.31 - Bukit Pilah estate 1989-2011 2nd 780.71 14.32 St. Helier estate 1984-2011 2nd 773.83 182.12 Sg. Sabaling estate 2004 2nd 124.66 -

Total 7,150.56 548.43 Note: There has been no New Planting in any of the 8 estates at the certified areas since Nov 2005.

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1.5 Summary of Conservation and HCV Areas The summary of Conservation and HCV Areas as identified in SOU 16 Kok Foh during this ASA-03 Assessment in 2014 is as shown in Table 4 below:

Table 4: Conservation and HCV Areas

# Statement of Land Use (Ha) FY 2012/2013 FY 2013/2014 (ASA-02) (ASA-03) Hectarage (ha) Hectarage (ha) 1 Planted Area (ha) – Oil Palm - Mature 7,200.12 7,150.56 - Immature 583.61 548.43 2 Conservation Area (ha) - comprising buffer zones along small streams, hilly 114.20 114.50 areas, swampy and unplantable areas 3 HCV Area (ha) - comprising buffer zones near forest reserves, 22.75 39.04 water catchments, burial & religious sites *Note: A GPS re-survey exercise was done last year, 2013 and the Estates have started using new GPS survey hectarages that have slight variance compared to previous year data.

1.6 Other certifications held and Use of RSPO Trademarks SOU 16 Kok Foh had received 5S certification from the Malaysian Productivity Centre (MPC) in March 2012.

1.6.1 The RSPO’s trademarks and logo are not being used by the PMU audited. Instructions for use were provided and acknowledged by the PMU through a signed Memorandum of commitment agreeing to adhere to the latest “RSPO Rules on Communications & Claims”.

1.7 Organizational information / Contact Person

At Head Office: Name: Sabarinah Marzuky Designation: Head In-charge, RSPO & Certifications Unit, PSQM Department Full Address: PSQM Level 3A, Plantation Tower, No. 2, Jalan PJU 1A/7, Ara Damansara, 47301 Petaling Jaya, Selangor Tel: 03-7848 4388

At SOU 16 Kok Foh: Mr. Ghazali bin Said SOU 16 Kok Foh Palm Oil Mill Manager Sime Darby Plantation Sdn Bhd SOU 16 Kok Foh 72109 Bahau, Negeri Sembilan. Tel: 606 457 7833 Fax: 606 457 7018 Email: [email protected]

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1.8 Tonnages Verified for Certification

The breakdown of all the suppliers and their tonnages of FFB supplied to the POM at SOU 16 Kok Foh based on the reporting period for FY July 2013- June 2014 are as follows:

# Estate /Supplier FFB Processed (MT) Main Receiving Mill Certified By A.1 Kok Foh Estate 56,899.65 Kok Foh POM Intertek A.2 Sg. Senarut Estate 14,558.17 Kok Foh POM Intertek A.3 Muar River Estate 26,152.22 Kok Foh POM Intertek A.4 Pertang Estate 16,920.64 Kok Foh POM Intertek A.5 Sg. Gemas Estate 24,770.81 Kok Foh POM Intertek A.6 Bukit Pilah Estate 12,713.05 Kok Foh POM Intertek A.7 St. Helier Estate 14,181.76 Kok Foh POM Intertek A.8 Sg. Sabaling Estate 3,483.80 Kok Foh POM Intertek

SOU 16 ESTATES TOTAL 169,680.10 Kempas POM SIRIM B.1 Kemuning (Diversion from SOU 17) 1,037.31 (SOU17) Sua Betong (SOU15) SGS B.2 Bradwall (Diversion from SOU 15) 174.92 POM Sua Betong (SOU15) SGS B.3 Sengkang (Diversion from SOU 15) 445.36 POM Sua Betong (SOU15) SGS B.4 (Diversion from SOU 15) 1,052.86 POM Other SDPSB SOU Estates Total 2,710.45 Sub-Total (SOU’s of SDPSB) 172,390.55 C.1 CHEONG WING CHAN 19,681.71 Subject to contractual agreements with C.2 SERN LEE 12,774.92 various POMs Subject to contractual ENG HUAT LATEX (DIVERSION FROM C.3 1706.16 agreements with SOU 17) various POMs Subject to contractual SRI MAJU BAJA (DIVERSION FROM C.4 817.57 agreements with SOU 17) various POMs Sub-total Other Suppliers - (OCP) 34,980.36 Grand total 207,370.91

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Total annual volumes / tonnages of FFB supplied from the supply base to SOU 16 POM during the previous assessment period, current surveillance assessment ASA-03 period and projected period are as follows:

FFB Processed in FFB Processed in FFB Processed for Previous Financial Year Current Financial Year Next Year Financial Year Estate / Supplier Jul 2012 / Jun 2013 Jul 2013 / Jun 2014 Jul 2014 / Jun 2015 - Projected MT % MT % MT % SOU 16 Estates 162,493.93 78.96 169,680.10 81.82 169,436.04 80.17 Other SDPSB Estates 14,211.52 6.91 2,710.45 1.31 18,920.20 8.95 Other Suppliers (OCP) 29,078.42 14.13 34,980.36 16.87 23,000 10.88 Total 205,783.87 100 207,370.91 100 211,356.24 100 * SCCS Model for POM MB MB MB

The certifiable tonnages of CPO and PK production by SOU 16 from the supply base/suppliers as assessed and verified during the current surveillance (based on 2013/14 data) and projected figures for 2014/15 are detailed as follows:

Previous Financial Year Current Financial Year Jul Next Year Financial Year Kok Foh POM Jul 2012 / Jun 2013 2013 / Jun 2014 Jul 2014 / Jun 2015 Actual - Actual + Projected (2 mths) - Projected Total FFB 176,705.45 172,390.55 188,356.24 Processed (MT) Total CPO 39,352.30 OER: 38,132.79 OER: 41,193.51 OER: Production (MT) 22.27% 22.12% 21.87% Total PK 9,400.73 KER: 9,533.20 KER: 10,303.09 KER: Production (MT) 5.32% 5.53% 5.47%

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

1.9 Time Bound Plan for Other Management Units

The Sime Darby Plantation Group has been a member of RSPO since 8 Sep 2004 and is committed to full compliance with the RSPO P&C and full certification in all aspects of its operations. Sime Darby Plantation Sdn Bhd (SDPSB) owns and operates 62 palm oil mills (Strategic Operating Unit – SOU) and 202 estates (as per update on 31 Mar 2012), throughout Malaysia and Indonesia which has completed its RSPO certification assessments in year 2011. For effective management and cost-efficiency, Sime Darby Plantation’s estates and mills operate within an organizational structure of strategic operation unit (SOU), zones and regions. (Source:http://www.simedarbyplantation.com/Sime_Darby_Plantation_in_Malaysia.aspx ).

Details of the time bound plan as submitted by SDPSB are covered under Appendix E.

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

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1.10 Abbreviations Used

AMESU All Malayan Estate Staff Union MAPA Malaysian Agriculture Producers Association CHRA Chemical Health & Risk Assessment ICI Intertek Certification International Sdn Bhd CPO Crude Palm Oil MSDS Material Safety Data Sheets CSDS Chemical Safety Data Sheets MTCS Malaysia Timber Certification Scheme CSPO Certified Sustainable Palm Oil NCR Non-Conformance Report CSPK Certified Sustainable Palm Kernel NGO Non-Government Organisation CUC Control Union Certification NUPW National Union Plantation Workers EFB Empty Fruit Bunch OER Oil Extraction Rate EHS Environmental Health & Safety OHS Occupational Health & Safety EIA Environmental Impact Assessment PEFC Programme for the Endorsement of Forest Certification ETP Effluent Treatment Plant PK Palm Kernel FFB Fresh Fruit Bunch PKO Palm Kernel Oil GAP Good Agriculture Practice POM Palm Oil Mill HCV High Conservation Values POME Palm Oil Mill Effluent IPM Integrated Pest Management PPE Personal Protective Equipment ISCC International Sustainability & Carbon SCCS Supply Chain Certification Standard Certification IUCN International Union for Conservation of Nature SDPSB Sime Darby Plantation Sdn Bhd JCC Joint Consultative Committee SOCSO Social Security Insurance KER Kernel Extraction Rate SOP Standard Operating Procedures KKS Kilang Kelapa Sawit SOU Strategic Operating Unit LTA Lost Time Accidents TQEM Total Quality Environment Management

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2.0 ASSESSMENT PROCESS

2.1 Assessment Methodology, Plan and Site Visits

Since 9 Apr 2014, ICI has initiated public communications and notifications and invited the relevant stakeholders before the assessment to provide feedback and comments on their concern (if any) on SOU 16 regarding the environmental, biodiversity, community development and other relevant issues.

From 20 to 23 May 2014, the Assessment team of ICI conducted the surveillance assessment in which 3 out of the 8 estates of SOU 16 Kok Foh grouping, namely Kok Foh estate, Muar River estate and Sg. Sabaling estate as well as the Kok Foh Palm Oil Mill were assessed for continued compliance against the RSPO requirements. The number of estates sampled was based on a minimum sample of 0.8 √y where y is the number of management sub- units and the selection was made based on their potential risks on social, environmental and biodiversity issues such as their proximity to forest reserves, hill sides, riparian zones and high conservation value areas.

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

SOU 16 POM was also assessed against the requirements for the Mass Balance Module as specified in RSPO Supply Chain Certification Standard for CPO mill. This part of the assessment covered the verification of implementation of documented procedures and availability of records to demonstrate compliance against all the elements for mass balance requirements. These include purchasing and goods in, record keeping, sales and goods out, monitoring and traceability of the CSPO and CSPK quantities, training for staff and claims.

After completion of the on-site field assessment, ICI also performed the evaluation of conformity against the RSPO Certification System requirements for CB. The surveillance assessment report, findings and associated documents were evaluated through an independent review and approval by the ICI Panel of Technical Reviewers prior to submission of the Public Summary Report to RSPO Secretariat.

The details of the Assessment Plan (actual on-site) are provided in Appendix B.

2.2 Date of next scheduled visit

The next scheduled visit will be the 4th Annual Surveillance Assessment (ASA-04) which will be carried out within a 12-month period of the due for annual surveillance during the certification cycle.

2.3 Qualifications of the Lead Assessor and Assessment Team

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

2.4 Certification Body

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

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2.5 Process of stakeholder consultation

Stakeholder consultations began with notification of the upcoming assessment through the websites of RSPO, SDPSB and ICI. E-mails / facsimiles / letters of the same were sent to applicable stakeholders including government agencies, NGOs and local communities. Any stakeholder’s response and feedback received were followed up accordingly.

During the assessment, stakeholders who were able to be available, were interviewed and their feedbacks were recorded. Among the stakeholders who were approached were worker representatives, gender representatives; local community heads, government departments / agencies and NGOs representatives; external FFB, fertilizer suppliers and contractors.

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

Among the list of key stakeholders consulted was the following:

Government Agencies (by emails) 1. Department of Lands And Mines 11. Department of Environment (Johor) 2. Department of Environment 12. Department of Forestry (Johor) 3. Department of Forestry Peninsular Malaysia 13. Department of Immigration (Johor) 4. Department of Immigration 14. Department of Irrigation & Drainage (Johor) 5. Department of Irrigation & Drainage 15. Department of Labour (Johor) 6. Department of Labour 16. Department of Occupational Safety & Health (Johor) 7. Department of Occupational Safety & Health 17. Department of Orang Asli Affairs (Johor) 8. Department of Orang Asli Affairs 18. Department of Wildlife & National Parks (Johor) 9. Department of Wildlife & National Parks 19. Land and Mines Office (Johor) 10. Royal Malaysia Police 20. Police Department (Johor)

Statutory Bodies (by emails) 21. Pertubuhan Keselamatan Sosial (SOCSO) (Johor) 25. Malaysian Palm Oil Board (MPOB) - Southern Region 22. Pejabat Buruh (Johor) 26. Malaysia Palm Oil Association (MPOA) 23. Malaysian Palm Oil Board (MPOB) 27. Malaysia Palm Oil Association (MPOA) (Johor) 24. Malaysian Palm Oil Board (MPOB) - Central Region

NGOs (by emails) 28. Malaysian CropLife & Public Health Association (MCPA) 46. Malaysian Nature Society Johor 29. Pesticide Action Network Asia and the Pacific 47. National Council of Welfare & Social Development (PAN AP) Malaysia - NCWSDM 30. All Women’s Action Society (AWAM) 48. National Union of Plantation Workers (NUPW) 31. BCSDM - Business Council for Sustainable Development 49. Proforest - South East Asia Regional Office in Malaysia 32. Center for Orang Asli Concerns COAC 50. SUARAM - Suara Rakyat Malaysia 33. Centre for Environment, Technology and Development, 51. SUHAKAM - National Human Rights Society - Persatuan Malaysia - CETDEM Kebangsaan Hak Asasi Manusia 34. EcoKnights 52. Sustainable Development Network Malaysia (SUSDEN) 35. Environmental Management and Research Association of 53. Sustainable Development Network Malaysia (SUSDEN) Malaysia (ENSEARCH) 36. Environmental Protection Society Malaysia (EPSM) 54.Tenaganita Sdn Bhd 37. Friends of the Earth, Malaysia 55. The Malaysian Forum of Environmental Journalist (MFEJ) 38. Future in Our Hands Society, Malaysia 56. TRAFFIC - the wildlife trade monitoring network 39. Global Environment Centre 57. Transparency International - Malaysian Chapter 40. Institute of Foresters, Malaysia (IRIM) 58. Treat Every Environment Special Sdn Bhd. (TrEES) 41. JERIT - Jaringan Rakyat Tertindas - Coalition of the 59. United Nations Development Programme - UNDP Malaysia Oppressed People 42. JUST - International Movement for a Just World 60. Wetlands International (Malaysia) 43. Malaysian Environmental NGOs - MENGO 61. Wild Asia Sdn Bhd 44. Malaysian National Animal Welfare Foundation - MNAWF 62. World Wide Fund for Nature (WWF) Malaysia 45. Malaysian Nature Society (MNS) Kuala Lumpur 63. UNION - AMESU 46. Malaysian Nature Society Johor 64. UNION - NUPW

Local community (On-site interviews) 1. Worker representatives 3. Suppliers / Contractors 2. Gender representatives 4. Village Heads

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3.0 ASSESSMENT FINDINGS

3.1 Summary of findings

Principle 1: Commitment to transparency Criterion 1.1 Growers and millers provide adequate information to relevant stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages and forms to allow for effective participation in decision making. Indicators Findings and Objective Evidence Compliance 1.1.1 There shall be evidence that SOU 16 POM and the sampled estates have maintained Complied growers and millers provide adequate information upon request for information the records of requests via ‘Communication & Complaint on (environmental, social and/or legal) Log book’ for both external and internal parties. issues relevant to RSPO Criteria to Noted entries in above logbook were mostly made by relevant stakeholders for effective visitors comprising of local officials, inspectors, HQ participation in decision making. Management personnel and external Auditors. FY2013/2014 visits made by Minor Compliance DOSH/JKKP was without any adverse remarks. Generally comments of entries were congratulatory messages and positive remarks. Verified that no specific requests or complaints/grievances were found. 1.1.2 Records of requests for SOU16 PMU maintained an updated list of internal Complied information and responses shall be maintained. stakeholders and external stakeholders, i.e government departments, contractors, suppliers, transporters etc. Major Compliance Records of stakeholders’ engagements have been adequately maintained. Criterion 1.2 Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes. Indicators Findings and Objective Evidence Compliance 1.2.1 Management documents that are Management documents’ relating to environmental, social Complied made available to the public shall include, but are not necessarily limited and legal issues was verified to be available for the public to: (notices and websites) and updated by SDPSB, HQ. No • Land titles/user rights (Criterion 2.2); instances of any applicable documents being unavailable. Documents verified include: Major Compliance Copies of all the land titles were available and have been maintained at the estates. The respective land titles sighted for the estates under the PMU had indicated that the lands were for agricultural crops of economic value.

• Occupational health and safety plans Safety and Health Plan was available and reviewed for Complied (Criterion 4.7); FY2013/2014 by Mill Manager and respective Estate Managers. Major Compliance . Plans and impact assessments relating SEIA established by Sustainability team (HQ) have been Complied to environmental and social impacts (Criteria 5.1, 6.1, 7.1 and 7.8); annually reviewed with feedback by respective Estate managers in periodic meetings and was evident in the minutes of meetings with the improvement plans needed Major Compliance being adequately monitored.

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• HCV documentation summary (Criteria HCV Management Plan was verified reviewed in Complied 5.2 and 7.3); FY2013/2014 by Mill Manager and respective Estate Managers. Major Compliance

• Pollution prevention and reduction Environmental and Pollution Prevention Management Plan Complied plans (Criterion 5.6); was verified reviewed in FY2013/2014 by Mill Manager and respective Estate Managers. Major Compliance • Details of complaints and grievances Complaints Register was maintained; noted some 12 Complied (C6.3) entries from Jan 2014 to current. Latest entry dated 21 Apr 2014 was on request for repairs to workers Major Compliance housing/quarters facilities (.e. lighting and water supply and broken utilities) which had been attended to accordingly. List of contractor repair work/items completed were reviewed by Mill & Estate Managers and signed off. • Negotiation procedures (C 6.4) Negotiation SOP and flowchart maintained since Jul 2009. Complied Currently, to date there was no incidence of any disputes. Major Compliance • Continuous improvement plan (C 8.1) The respective Annual Improvement Plan & Proposal was Complied available which had been reviewed by respective Estate Major Compliance Managers and Mill Manager for FY 2013/2014 .Kaizen has been extensively practiced throughout the mill and estates (see also findings on C 8.1) • Public summary of certification Public summary of earlier certification assessment reports Complied assessment report; of certifications achieved were available in the website. Major Compliance • Human Rights Policy (Criterion 6.13). The Human Rights Policy has not yet been documented New

and communicated to all levels of the workforce and requirement Major Compliance operations. of RSPO P&C (2013) - Follow up will be done at next Surveillance assessment Criteria 1.3 Growers and millers commit to ethical conduct in all business operations and transactions. Indicators Findings and Objective Evidence Compliance 1.3.1 There shall be a written policy Policy of Commitment to a Code of Ethical Conduct and New committing to a code of ethical conduct and integrity in all operations and Integrity has not yet been documented and communicated requirement transactions, which shall be to all levels of the workforce and operations. of RSPO P&C documented and communicated to all (2013) - levels of the workforce and operations. Follow up will be done at Minor Compliance next Surveillance assessment.

Intertek RSPO Report: June 2014

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 15 of 48 (SOU 16 Kok Foh: ASA-03)

Principle 2: Compliance with applicable laws and regulations Criterion 2.1 There is compliance with all applicable local, national and ratified international laws and regulations. Indicators Findings and Objective Evidence Compliance 2.1.1 Evidence of compliance with relevant Compliance with the applicable local, national and Complied legal requirements. international laws and regulations as identified in the “Legal Requirements Register” are evidenced with no cases of any violation or actions imposed Major compliance by relevant authorities. Evaluation of legal requirements was done by respective Estate Managers and Mill Manager between Feb and April 2014. Licenses and permits were renewed and verified to be valid for current year operations . 2.1.2 A documented system, which includes The system and process to comply with applicable Complied written information on legal requirements. laws and regulations - SOP on Maintenance of Legal requirements and “Legal Requirement Register” has been maintained. Minor compliance 2.1.3 A mechanism for ensuring that they Evaluation of legal requirements was done by Complied are implemented. respective Estate Managers and Mill Manager e.g. Statutory returns to relevant authorities found to be in compliance. Taxes such as quit rent (cukai Minor compliance tanah) for 2014 has been paid by the respective estates to the Land Offices of both Negeri Sembilan and Johor respectively. 2.1.4 A system for tracking any changes in Monitoring of changes to the applicable laws and Complied the law. regulations carried out through periodical review The systems used should be appropriate to in accordance with the documented SOP and the scale of the organization. communication from HQ Sustainability team. The monitoring is under the responsibility of both the Mill and Estate Managers who hold quarterly Minor compliance meetings to review the legal requirements and other performance measures. Changes are also communicated from the HQ to all PMUs via email and meetings held with the respective Regional General Managers. Criterion 2.2 The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights. Indicators Findings and Objective Evidence Compliance 2.2.1 Documents showing legal ownership or Copies of all land titles were sighted and observed Complied lease, history of land tenure (confirmation from community leaders based on history of customary that there were no changes to land ownership. land tenure, recognised Native Customary Right The original copies are maintained by the (NCR) land) and the actual legal use of the land corporate head office. The legal use of the land shall be available. was confirmed for the cultivation of oil palms and agricultural use. Major Compliance 2.2.2 There is evidence that physical markers are The stated use of the respective plots of land for Complied located and visibly maintained along the legal boundaries adjacent to state land, NCR land and agricultural / plantation purpose has been reserves. maintained as designated for cultivation of oil palms and agricultural use.

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 16 of 48 (SOU 16 Kok Foh: ASA-03)

Minor Compliance Locations of several boundary stones were visited and found to have pole markers for easy identification. On-site verification confirmed that there is no planting beyond the legal demarcated boundaries of the estates. 2.2.3 Where there are or have been disputes, There were no disputes with external parties over Complied additional proof of legal acquisition of title and evidence that fair compensation has been made to land ownership and no new land acquisition since previous owners and occupants shall be available, the last audit. and that these have been accepted with free, prior and informed consent (FPIC).

Minor Compliance 2.2.4 There shall be an absence of significant land There were no disputes with external parties over Complied conflict, unless requirements for acceptable conflict resolution processes (see Criteria 6.3 and land ownership and no new land acquisition since 6.4) are implemented and accepted by the parties the last audit. involved.

Major Compliance 2.2.5 For any conflict or dispute over the land, the There were no disputes with external parties over Complied extent of the disputed area shall be mapped out in a participatory way with involvement of affected land ownership and no new land acquisition since parties (including neighbouring communities and the last audit. relevant authorities where applicable).

Minor Compliance 2.2.6 To avoid escalation of conflict, there shall be There were no conflicts with external parties over Complied no evidence that oil palm operations have instigated violence in maintaining peace and order land ownership and no new land acquisition since in their current and planned operations. the last audit.

Major Compliance Criteria 2.3 Use of the land for oil palm does not diminish the legal, customary or user rights of other users without their free, prior and informed consent.

Indicators Findings and Objective Evidence Compliance 2.3.1 Maps of an appropriate scale showing the The lands at the PMU are legally owned by the Complied extent of recognised legal, customary or user rights (Criteria 2.2, 7.5 and 7.6) shall be SOU16 PMU. developed through participatory mapping involving affected parties (including neighbouring communities where applicable, and relevant authorities).

Major Compliance 2.3.2 Copies of negotiated agreements detailing There has been no existing disputed land. Complied the process of free, prior and informed consent (FPIC) (Criteria 2.2, 7.5 and 7.6) shall be available Presently, this is not applicable. and shall include: a)fected groups in the communities, and that information has been provided to all affected groups, including information on the steps that shall be taken to involve them in decision making; b) Evidence that the company has respected communities’ decisions to give or withhold their consent to the operation at the time that this decision was taken; c) Evidence that the legal, economic, environmental and social implications for permitting operations on their land have been

Intertek RSPO Report: June 2014

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 17 of 48 (SOU 16 Kok Foh: ASA-03) understood and accepted by affected communities, including the implications for the legal status of their land at the expiry of the company’s title, concession or lease on the land.

Minor Compliance 2.3.3 Copies of negotiated agreements The lands were acquired in 1980’s from the Complied detailing process of consent (C2.2, 7.5 and respective Negeri Sembilan and Johor state 7.6). governments. Records are available to show such land acquisition comply with legal requirements and does not infringe on any legal Minor compliance rights that require free, prior and informed consent. 2.3.4 Evidence shall be available to show that No cases of land disputes were reported either by Complied communities are represented through institutions or representatives of their own choosing, including individuals or groups. Presently, this is not legal counsel. applicable.

Major Compliance

Principle 3: Commitment to long-term economic and financial viability Criteria 3.1 There is an implemented management plan that aims to achieve long-term economic and financial viability.

Indicators Findings and Objective Evidence Compliance 3.1.1 A business or management plan A 5 year management plan documented, with details of Complied (minimum three years) shall be documented that includes, where budget & cost of operation, both for oil mill & estates appropriate, a business case for Annual budget of Business Management Plan included scheme smallholders. the following:

Major Compliance (i) Planting materials (DXP seedling and cloned seedling); (ii) Crop projection = FFB yield/ha trends; (iii) Mill extraction rates = OER trends; (iv) Cost of Production = Cost/MT FFB trends; (v) Cost of Production = Cost/MT CPO trends; (vi) Forecast prices; (vii) Financial indicators = Cost of labor, cost of supervision, cost of manufacture, depreciation) 3.1.2 An annual replanting programme Replanting programme projected for each estate in this Complied projected for a minimum of five years (but longer where necessary to reflect PMU. Evidence of replanting programme planned, the management of fragile soils, see reviewed & on-going implementation carried out as Criterion 4.3), with yearly review, shall follow: be available. Replanting in ha.

Minor Compliance 2013/14 14/15 15/16 16/17 17/18 Muar Raver Est 39.04 45.88 ------Sg. Sabaling E ------Koh Foh E ------

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 18 of 48 (SOU 16 Kok Foh: ASA-03)

Principle 4: Use of appropriate best practices by growers and millers Criteria 4.1 Operating procedures are appropriately documented, consistently implemented and monitored. Indicators Findings and Objective Evidence Compliance 4.1.1 Standard Operating Procedures The mill and the estates had a copy each of the Complied (SOPs) for estates and mills shall be documented. Standard Operating Procedures and these had been verified to be in order. Major Compliance 4.1.2 A mechanism to check consistent The mechanism to check the implementation of SOPs Complied implementation of procedures shall be in place. was available. Records had been kept by the staff concerned for each operation to monitor the procedure Minor Compliance and progress of work, and these records would be checked by the Assistant Manager and the Manager regularly. These records had been verified to indicate satisfactory implementation during the visit. 4.1.3 Records of monitoring and any The records of monitoring and the actions taken had Complied actions taken shall be maintained and available, as appropriate. been maintained for more than 5 years on the mill and estates concerned. These records had been verified to Minor Compliance be satisfactory. 4.1.4 The mill shall record the origins of The mill maintained record on the origins of all third- Complied all third-party sourced Fresh Fruit Bunches (FFB). party sourced Fresh Fruit Bunches (FFB), and it had been verified to be satisfactory. Major Compliance Criteria 4.2 Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield. Indicators Findings and Objective Evidence Compliance 4.2.1 There shall be evidence that good GAP for minimization of soil erosion and maintenance of Complied agriculture practices, as contained in Standard Operating Procedures soil fertility is maintained via the frond stacking and (SOPs), are followed to manage soil fertilizer application as per the recommendation fertility to a level that ensures optimal provided from Sime Darby Research Centre. and sustained yield, where possible.

Minor Compliance 4.2.2 Records of fertiliser inputs shall be Records of fertilizer application had been verified to be Complied maintained. in order. Minor Compliance 4.2.3 There shall be evidence of Leaf analysis had been carried out annually to Complied periodic tissue and soil sampling to monitor changes in nutrient status. determine the nutrient levels for fertilizer recommendations that aimed to sustain the long term Minor Compliance soil fertility and nutrient efficiency. Soil sampling and analysis had been carried out at 5 year cycle. Records of the sampling and analysis had been verified to be satisfactory. 4.2.4 A nutrient recycling strategy shall EFB mulching had been carried out in mature area of Complied be in place, and may include use of Empty Fruit Bunches (EFB), Palm Oil Sabaling Estate only along the inter-row, and around Mill Effluent (POME), and palm residues the circle in the immature palms and for beneficial after replanting. plants on Muar River and Kok Foh Estates. Records had been verified to be satisfactory. Minor Compliance POME land irrigation had been carried out on Kok Foh estate over 840 ha by gravity feed. Criteria 4.3 Practices minimise and control erosion and degradation of soils.

Intertek RSPO Report: June 2014

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 19 of 48 (SOU 16 Kok Foh: ASA-03)

Indicators Findings and Objective Evidence Compliance 4.3.1 Maps of any fragile/marginal soils Based on the soil maps, there was no fragile soil on the Complied shall be available. estates. Major Compliance 4.3.2 A management strategy shall be in Based on SOP, water conservation terraces should be place for plantings on slopes between 9 and 25 degrees unless specified constructed for slope between 2° to 6° and planting terraces should be constructed on land with slope > 6°. otherwise by the company’s SOP.

Minor Compliance However, on Muar River Estate, a portion of field in F13A replant, where visual judgment of the slope Minor NC was >6°, but no planting terraces were constructed. # 1of 3 A Minor non-conformance was issued.

Also, in F14A replant, where slope was about 5°, no Minor NC water conservation terraces were constructed. # 2 of 3 A Minor non-conformance was issued. 4.3.3 A road maintenance programme Road maintenance programme had been found to be in shall be in place. order. Observation Minor Compliance Generally, estate roads were found to be in good and satisfactory condition.

However, on Muar River Estate, some gullies were found along the main roads and field roads, with silt deposits at the lower portions of the roads being sign of soil erosion, both in the mature and immature areas. A proper road grading is needed. An observation was raised. 4.3.4 Subsidence of peat soils shall be Based on the estate soil maps, there was no peat soil Complied minimised and monitored. A documented water and ground cover on the estates as confirmed by auditor’s on-site management programme shall be in assessment place.

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

Minor Compliance 4.3.6 A management strategy shall be in Based on the estate soil maps and visit to the estates, Complied place for other fragile and problem soils (e.g. podzols and acid sulphate soils). there were no other fragile and problematic soils on these estates. Minor Compliance Criteria 4.4 Practices maintain the quality and availability of surface and ground water. Indicators Findings and Objective Evidence Compliance 4.4.1 An implemented water Documented water management plan and relevant Complied management plan shall be in place. records had been verified to be in order. Minor Compliance 4.4.2 Protection of water courses and There was no construction of bunds/ weirs/dams across Complied wetlands, including maintaining and restoring appropriate riparian and other the main rivers or waterways passing through the buffer zones (refer to national best estates. practice and national guidelines) shall

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 20 of 48 (SOU 16 Kok Foh: ASA-03) be demonstrated.

Major Compliance 4.4.3 Appropriate treatment of mill In palm oil mill, water samples had been taken at Complied effluent to required levels and regular monitoring of discharge quality, shall be monthly interval at the discharge point of effluent pond. in compliance with national regulations BOD levels had been in the range of 117 ppm in July, (Criteria 2.1 and 5.6). 2013 and 377 ppm in Jan, 2014 with an average of 313 ppm for the past 12 months. The upper limit specified by Minor Compliance D.O.E. Negeri Sembilan. was complied with . 4.4.4 Mill water use per tonne of Fresh Water usage in the mill averaged at 1.22 m 3/tonne FFB. Complied Fruit Bunches (FFB) (see Criterion 5.6) shall be monitored. The level of water usage was within the industrial norm.

Minor Compliance Criteria 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management techniques. Indicators Findings and Objective Evidence Compliance 4.5.1 Implementation of Integrated Pest Records on planting of beneficial plants had been Complied Management (IPM) plans shall be verified on the estates. monitored. Trapping of Rhinoceros beetle with pheromone had Major Compliance been carried out in the immature areas of the estates. There was attack of bag worm on Kok Foh Estate and Muar River Estate, and was brought under control by trunk injection of Methamidophos. Programme for planting of beneficial plants such as Turnera subulata, Cassia cobanensis, and Antigonon leptopus , and records on areas planted had been verified together with the respective maps to be satisfactory 4.5.2 Training of those involved in IPM Training records for personnel on IPM implementation Complied implementation shall be demonstrated. were available and was verified on-site to be Minor Compliance satisfactory during field assessment. Criteria 4.6 Pesticides are used in ways that do not endanger health or the environment. Indicators Findings and Objective Evidence Compliance 4.6.1 Justification of all pesticides used Written justification in Standard Operating Procedures Complied shall be demonstrated. The use of selective products that are specific to of all agrochemicals use had been reviewed and found the target pest, weed or disease and acceptable. which have minimal effect on non-target species shall be used where available.

Major Compliance 4.6.2 Records of pesticides use Records of pesticides and their active ingredients used, Complied (including active ingredients used and their LD50, area treated, amount of LD50, area treated, amount of a.i. applied per ha, and active ingredients applied per ha and number of applications had been maintained and kept number of applications) shall be for a minimum of 5 years. It had been verified that provided. records of monitoring were satisfactorily.

Major Compliance

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

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 21 of 48 (SOU 16 Kok Foh: ASA-03)

Major Compliance 4.6.4 Pesticides that are categorised as It is the policy of the Sime Darby Group not to use Complied World Health Organisation Class 1A or Paraquat. 1B, or that are listed by the Stockholm or Rotterdam Conventions, and paraquat, are not used, except in specific situations identified in industry’s Best Practice. The use of such pesticides shall be minimised and eliminated as part of a plan, and shall only be used in exceptional circumstances. Pesticides selected for use are those officially registered under the Pesticides Act 1974 (Act 149) and the relevant provision (Section 53A); and in accordance with USECHH Regulations (2000).

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

Major Compliance 4.6.6 Storage of all pesticides shall be Storage of pesticides found to be in accordance with the Complied according to recognised best practices. All pesticide containers shall be properly Occupational Safety and Health Laws and Regulations disposed of and not used for other and local laws on pesticides control. purposes (see Criterion 5.3). Pesticides Used chemical containers were disposed of by DOE shall be stored in accordance to the approved / registered Hazardous waste contractor. Occupational Safety and Health Act 1994 (Act 514) and Regulations and Orders, Pesticides Act 1974 (Act 149) and Regulations. Major Compliance 4.6.7 Application of pesticides shall be Pesticides had been applied using the proven methods Complied by proven methods that minimise risk and impacts. (Best Management Practices) that minimize risk and impacts. Minor Compliance 4.6.8 Pesticides shall be applied aerially It’s not the policy of the company to carry out aerial Complied only where there is documented justification. Communities shall be application of pesticides. This policy has been adhered. informed of impending aerial pesticide applications with all relevant information within reasonable time prior to application.

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

Minor Compliance 4.6.10 Proper disposal of waste Scheduled waste had been disposed of through Complied material, according to procedures that

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 22 of 48 (SOU 16 Kok Foh: ASA-03) are fully understood by workers and licensed contractor approved by DOE: managers shall be demonstrated (see • Criterion 5.3). Muar River Estate- G.Planter Sdn Bhd. • Sg. Sabaling Estate- MIDO Recycle Sdn. Bhd. Minor Compliance • Sime Darby Industrial Sdn. Bhd. • Kok Foh Estate- Hiap Huat Chemicals Sdn. Bhd. Records of scheduled waste involved had been verified to be satisfactory. 4.6.11 Specific annual medical Annual medical surveillance for pesticide operators had Complied surveillance for pesticide operators, and documented action to treat related been implemented as follows: health conditions, shall be Kok Foh POM had sent 6 workers for medical demonstrated. surveillance on 23-12-2013

Major Compliance Muar River estate had sent 30 of its workers for medical surveillance on 5-5-2014. Sg Sabaling estate had sent 9 and 1 of its workers for medical surveillance on 3-4-2014 and 15-4-2014 respectively. Kok Foh estate had sent 7 of its workers for medical surveillance on 7-11-2013. 4.6.12 No work with pesticides shall be Verified from records, field inspections and interviews Complied undertaken by pregnant or breast- feeding women. that no pregnant or breast-feeding woman had been offered work as pesticide operator. Major Compliance Criteria 4.7 An occupational health and safety plan is documented, effectively communicated and implemented. Indicators Findings and Objective Evidence Compliance The occupational health and safety plan Occupational Safety and Health (OSH) plan in Complied shall cover the following: compliance with OSH Act and Factory Machinery Act 4.7.1 An occupational health and safety was documented and implemented. policy shall be in place. An occupational OSH policy was clearly displayed at POM and in estates health and safety plan covering all office. Workers had demonstrated awareness towards activities shall be documented and occupational safety and health policy. implemented, and its effectiveness monitored. Risk assessment carried out on all operations where health and safety is an issue (e.g. noise exposure, Major Compliance pesticides/chemicals exposure, accident, fire). Yearly reporting of JKKP 8 regulations was submitted to JKKP on time i.e. in December. POM & its estates established their accident reporting KPI, and incident monitoring implemented. Procedures and actions documented and implemented on the issues concerned. Awareness and training programmes planned for year 2014 was consistently implemented. Evidence of training on safe working practices for workers involved in pesticides spray, use of fire extinguishers, awareness & understanding of MSDS/CSDS, First Aid boxes were sighted at both POM & estates. Precautions attached to products properly observed and applied to workers in all estates Appropriate PPE (safety boots, safety helmets, rubber boots, cartridge masks, safety goggles, gloves) verified to be provided. Ear protective device put on by worker working at engine room POM (>95 db limit). There were

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 23 of 48 (SOU 16 Kok Foh: ASA-03)

records maintained for the yearly audiometric test conducted for the listed mill workers. Companies had provided the appropriate PPE at the place of work to cover all potentially hazardous operations such as pesticides application, and harvesting. The Safety & Health officer was responsible for overall in change of safety and health planning, operation & coordination. Adequate fire extinguisher and hose reels found to be located at strategic locations, operational and maintained in good conditions. Training for estate workers in First Aid was carried out and records maintained. A total of 13 fire extinguishers were utilized at fire drills. First Aid equipment was available at POM, estates and at worksite. Samples of First Aid boxes were checked and contents found to be complete and in usable order i.e. at Sg. Sabaling estate when spraying activities was in progress during field visit. 4.7.2 All operations where health and All operations had been risk assessed, documented and Complied safety is an issue shall be risk assessed, and procedures and actions implemented. shall be documented and implemented All precautions attached to the products had been to address the identified issues. All observed and applied to the workers through MSDS. precautions attached to products shall be properly observed and applied to the workers.

Major Compliance 4.7.3 All workers involved in the Awareness and training programme had been carried Complied operation shall be adequately trained in safe working practices (see Criterion out. All workers involved had been adequately trained in 4.8). Adequate and appropriate safe working practices.Appropriate PPE had been protective equipment shall be available provided to all workers at the place of work to cover all to all workers at the place of work to potentially hazardous operations. cover all potentially hazardous operations, such as pesticide application, machine operations, and land preparation, harvesting and, if it is used, burning.

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

Major Compliance 4.7.5 Accident and emergency Accident and emergency procedures had been written Complied procedures shall exist and instructions shall be clearly understood by all and briefed to staff, workers, contractors and visitors. workers. Accident procedures shall be Workers trained in First Aid were present in the mill and available in the appropriate language of field operations. the workforce. Assigned operatives trained in First Aid should be present in First Aid Kits were available at worksites. both field and other operations, and first Records on all accidents had been verified to be aid equipment shall be available at maintained satisfactorily. worksites. Records of all accidents shall be kept and periodically reviewed. Quarterly review on accident cases had been carried

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 24 of 48 (SOU 16 Kok Foh: ASA-03)

out during quarterly meeting of Environment, Safety, & Minor Compliance Health (ESH) 4.7.6 All workers shall be provided with Medical care had been provided to all the workers. Complied medical care, and covered by accident insurance. Local workers were covered by SOCSO, whereas foreign workers were covered by Foreign Workers Minor Compliance Compensation Scheme with RHB Insurance Bhd.

4.7.7 Occupational injuries shall be Records on Lost Time Accident (LTA) metrics had been Complied recorded using Lost Time Accident (LTA) metrics. verified to be satisfactory.

Minor Compliance Criteria 4.8 All staff, workers, smallholders and contract workers are appropriately trained. Indicators Findings and Objective Evidence Compliance 4.8.1 A formal training programme shall A formal training programme on all aspects of RSPO Complied be in place that covers all aspects of the Principles and Criteria has been established and RSPO Principles and Criteria, and that includes regular assessments of training implemented. needs and documentation of the Training for various categories of operators, including all programme. field and office staff, with regards to their duties and training needs had been reviewed and found Major Compliance acceptable. 4.8.2 Records of training for each Records of training for employees verified to be Complied employee shall be maintained. satisfactory in the POM, Minor Compliance

Principle 5: Environmental responsibility and conservation of natural resources and biodiversity Criterion 5.1 Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continual improvement. Indicators Findings and Objective Evidence Compliance 5.1.1 An environmental impact Environment Aspect and Impact Identification as well as Complied assessment (EIA) shall be Environmental Impacts Evaluation initially conducted in documented. 2009 were reviewed annually. Review for FY 2013/2014 has been conducted adequately for the SOU. Major Compliance Dates for latest EAI assessment for sampled estates are as follow : Kok Foh POM - 12/05 /14 Kok Foh Estate - 02/08/13 Sg. Sabaling Estate - 10/04/13 Muar River Estate - 02/03/14 5.1.2 Where the identification of Environmental improvement plan implemented and Complied impacts requires changes in monitored every quarter taking into consideration the current practices, in order to results of the environmental aspects and risk assessment mitigate negative effects, a conducted. Environmental improvement plans for SOU16 timetable for change shall be developed and implemented within (FY2013/2014) included : a comprehensive management To recollect water used at chemical mixing area to be plan. The management plan shall recycled during chemical mixing activities. identify the responsible To construct containment sum at chemical mixing area to

Intertek RSPO Report: June 2014

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 25 of 48 (SOU 16 Kok Foh: ASA-03) person/persons. contain any leakages / spillages. To place all chemical containers on metal trays Minor compliance 5.1.3 This plan shall incorporate a For FY2013/2014, an environmental improvement plan was Complied monitoring protocol, adaptive to implemented to monitor the effectiveness of the mitigation operational changes, which shall measures. This plan incorporated a monitoring protocol, be implemented to monitor the which is adaptive to operational changes and is reviewed effectiveness of the mitigation measures. The plan shall be every year to reflect the results of monitoring operational reviewed as a minimum every two changes that may have positive and negative years to reflect the results of environmental impacts. monitoring and where there are operational changes that may have positive and negative environmental impacts.

Minor compliance Criterion 5.2 The status of rare, threatened or endangered species and other High Conservation Value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and operations managed to best ensure that they are maintained and/or enhanced. Indicators Findings and Objective Evidence Compliance 5.2.1 Information shall be collated HCV(s) identification and assessment maintained as per Observation in a High Conservation Value Biodiversity Baseline Assessment Report. Previous (HCV) assessment that includes Biodiversity Baseline Assessment was done in May 2009. both the planted area itself and Next Biodiversity Baseline Assessment is ongoing at time relevant wider landscape-level considerations (such as wildlife of this surveillance audit and expected to be completed by corridors). end 2014. However, HCV documentation and details need to be updated including hectarage in a timelier manner. An observation was raised. Major Compliance HCV Baseline assessment done in 2009 was reviewed on for FY2013/2014 was done as follows: Kok Foh POM - 12 / 05 /14 Kok Foh Estate - 03/01/14 Sg. Sabaling Estate - 10/04/14 Muar River Estate - 02 / 03/ 14 The HCV hectarage are as shown in Table 4 . 5.2.2 Where rare, threatened or Management plans for HCV habitats and their conservation Complied endangered (RTE) species, or were currently monitored, tracked and updated annually HCVs, are present or are affected within the estates / mill. However, latest review of HCV by by plantation or mill operations, SDPSB Sustainability Department indicates no RTE or appropriate measures that are expected to maintain and/or HCV within SOU16.The PMU was focused on enhancing enhance them shall be the signages for conservation areas and permitting the implemented through a growth of natural vegetation in the conservation areas and management plan. buffer zones areas identified were identified and maintained. Major Compliance 5.2.3 There shall be a programme Evidence to continuously prevent and discourage illegal or Complied to regularly educate the workforce hunting, fishing or collecting activities were maintained and about the status of these RTE implemented in SOU 16. Signages as well as routine species, and appropriate patrolling activities were utilised for this purpose. disciplinary measures shall be instigated in accordance with company rules and national law if any individual working for the company is found to capture,

Intertek RSPO Report: June 2014

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 26 of 48 (SOU 16 Kok Foh: ASA-03) harm, collect or kill these species.

Major Compliance 5.2.4 Where a management plan Management plans were established and monitoring Complied has been created there shall be outcomes were reviewed by the estate managers. Ongoing ongoing monitoring: monitoring of the management plan on the status of HCV • The status of HCV and RTE and RTE was noted. species that are affected by plantation or mill operations shall be documented and reported; • Outcomes of monitoring shall be fed back into the management plan.

Minor compliance 5.2.5 Where HCV set-asides with Currently, there was no instance of HCV set-aside that Complied existing rights of local communities conflicts with the rights of local communities. Therefore, have been identified, there shall be the negotiated agreement of such nature is not applicable. evidence of a negotiated agreement that optimally safeguards both the HCVs and these rights.

Minor compliance Criterion 5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner. Indicators Findings and Objective Evidence Compliance 5.3.1 All waste products and Documented identification of all wastes were reflected in Complied sources of pollution shall be the Waste Management Plan for the current year identified and documented. (2013/2014). All identified waste products and sources of pollution including the Scheduled Waste List were Major Compliance documented, maintained and reviewed adequately. Updates for the action plan were recorded in the Management Plans for waste reduction programs dated as follows : Kok Foh POM - 13/02/14 Kok Foh Estate - 18/07/13 Sg. Sabaling Estate – 31/01/2014 Muar River Estate - 01/03/14 5.3.2 All chemicals and their The Waste management plan for estates and mill were Complied containers shall be disposed of implemented. SOP for the handling of domestic waste, responsibly. schedule waste and recycling were maintained and implemented. Major compliance Wastes were categorized into Domestic Waste, Clinical Waste, Scheduled Waste and Recycled Waste (glass, paper, plastic, aluminum, and scrap metal) and operational plans have been developed and implemented effectively. The operational plans and reduction of waste programs were documented and have been implemented .The segregating of recyclable waste material has been implemented throughout SOU 16 PMU. This was verified at the mill and estates audited. Scheduled wastes such as SW305, SW306, SW307, SW311, SW312, SW409, SW410, SW404, SW425 , SW102, SW103 are disposed off to the authorized

Intertek RSPO Report: June 2014

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 27 of 48 (SOU 16 Kok Foh: ASA-03)

recycling contractor – GPLANTER- Sdn Bhd. and Hiap Huat Chemical Sdn Bhd. 5.3.3 A waste management and Waste management are carried out as per Waste Complied disposal plan to avoid or reduce Management Plans established. The composting plant pollution shall be documented and which is located adjacent to the mill recycles waste from implemented. the POM such as the EFB and POME. The compost from the composting plant is used for land application at Kok Major compliance Foh Mas Estate which is adjacent to the composting plant. POME - 50% are used at composting plant, 50% are discharged to estate land at Kok Foh estate. The discharge is noted to be in compliance with the Environmental Quality Act 1974 (Act 127) and Regulations. Criterion 5.4 Efficiency of fossil fuel use and the use of renewable energy is optimised. Indicators Findings and Objective Evidence Compliance 5.4.1 A plan for improving The mill production output records and the boilers Complied efficiency of the use of fossil fuels operational records were monitored monthly and had and to optimise renewable energy included monitoring of the renewable energy usage. shall be in place and monitored. Monthly records of energy consumption were available and maintained at POM. Palm fiber and PK shells were used as Minor Compliance part of renewable energy sources and data on quantities are monitored and submitted to the HQ on monthly basis. Palm fiber and PK shell composition ratio was 70:30. Consumption data on renewable energy was at 0.8 mt / CPO. This was monitored by POM engineers for further continual efficiency improvements. Monitoring records on diesel consumption available and maintained by Mill and all estates. These were monitored by POM engineers for further continual efficiency improvements. Criterion 5.5 Use of fire for preparing land or replanting is avoided, except in specific situations as identified in the ASEAN guidelines or other regional best practice. Indicators Findings and Objective Evidence Compliance 5.5.1 There shall be no land Zero open burning policy upheld in SOU 16 as per SOP Complied preparation by burning, other than Section B2 - Felling/Land Clearing & Land Preparation in specific situations as identified in dated Nov 2008. SOU16 management is strictly complying the ‘Guidelines for the with the Malaysian environmental law – EQA and Implementation of the ASEAN Policy on Zero Burning’ 2003, or Regulations 1974. comparable guidelines in other No physical evidence of open burning was noted during regions. site audits.

Major Compliance 5.5.2 Where fire has been used for Previous crop were felled or mowed down, chipped and Complied preparing land for replanting, there shredded. No evidence of open burning of previous crop shall be evidence of prior approval carried out as per SOP mentioned above. of the controlled burning as specified in ‘Guidelines for the Implementation of the ASEAN Policy on Zero Burning’ 2003, or comparable guidelines in other regions.

Minor Compliance Criterion 5.6

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 28 of 48 (SOU 16 Kok Foh: ASA-03)

Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and monitored. Indicators Findings and Objective Evidence Compliance 5.6.1 An assessment of all Aspect and impact assessment performed has been Complied polluting activities shall be updated for FY2013/2014. conducted, including gaseous emissions; particulate/soot POME that was discharged was controlled, monitored and emissions and effluent (see results of effluent sampling were meeting DOE Criterion 4.4). requirements. DOE was notified and results declared to DOE periodically. Authorisation letter from DOE to Major Compliance discharge POME after processing by effluent ponds was verified during this audit. The online Continuous Emission Monitoring System for the Gunung Mas POM has been established with DOE . No violations from DOE have been received for FY2013/2014 to date. 5.6.2 Significant pollutants and Significant pollutants and greenhouse gas (GHG) New requirement greenhouse gas (GHG) emissions emissions were identified, e.g. POME, diesel / fuel and of RSPO P&C shall be identified, and plans to fertilizer usage have been documented at the PMU. It is (2013). Follow reduce or minimise them noted that the SDPSB Sustainability Department from HQ up action at next implemented. have already established plans for implementation and audit. monitoring of GHG emissions. Major compliance 5.6.3 A monitoring system shall be Monitoring and reporting of the significant pollutants to New requirement in place, with regular reporting on water, gaseous emissions to air and contamination on land of RSPO P&C progress for these significant are available. Tools and systems used include the DOE (2013). Follow pollutants and emissions from online CEMS monitoring for air emissions, water quality at up action at next estate and mill operations, using appropriate tools. discharge points as per DOE regulations and Scheduled audit. Waste disposal were adhering to DOE requirements. It

was verified that the POME is treated using aerobic and Minor compliance anaerobic ponds. Effluent waste-water samples were regularly taken every six months and tested by the laboratory mill officer in charge and analyzed to ensure compliance to DOE requirements. Records are maintained and were verified on-site to have met the permissible regulatory limits.

Principle 6: Responsible consideration of employees and of individuals and communities affected by growers and millers

Criteria 6.1 Aspects of plantation and mill management that have social impacts, including replanting, are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continual improvement. Indicators Findings and Objective Evidence Compliance 6.1.1 A social impact assessment (SIA) Initial Social Impact Assessment (SIA) was done in Apr including records of meetings shall be documented. 2009. An action plan was developed and monitored for the Social Assessment FY2013/14 dated 17 May 2014

Major Compliance has been documented and implemented were reviewed by the respective estate(s) audited (Muar River estate, Sg. Sabaling estate & Kok Foh estate) and Kok Foh Palm Oil Mill in Kok Foh Estate. The review mechanism had

appropriately involved stakeholders such as the sustainability team

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INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 29 of 48 (SOU 16 Kok Foh: ASA-03)

Meetings of minutes held periodically had discussed, reviewed and addressed social issues such as repairs and upgrade for line-site facilities, road conditions, health and welfare, gender issues, social and religious activities, sports and recreational needs. The social impact plans at SOU 16 and their implementation with time-lines and responsible person-in- charge has adequately demonstrated their continuous

efforts to mitigate negative impacts and promoting the positive impacts which include: - Road maintenance within the PMU areas - Organizing sports and recreational activities - Corporate Social Responsibility (CSR) activities - Up-keeping of religious sites such as Hindu temples and mosques. - Up-keeping of educational buildings such as crèches and schools. - Donation to the religious activities and programs such as Deepavali and etc.

The 5S Quality Environment programs, implementation and certification for Kok Foh Mill in since May 2012 and continued implementation till to date are well maintained.

However, Social Impact Assessment (SIA) done in Apr 2009 was already 5 years. Reassessment could Observation be conducted as soon as possible. An Observation was raised

6.1.2 There shall be evidence that the Stakeholders meeting was conducted by respective Complied assessment has been done with the participation of affected parties. PMU’s and recorded in the meeting minutes and log book for year 2013/2014. Major Compliance The participation of both internal and external stakeholders (including local from Governmental organizations) which was evident with the list of participants recorded. Minutes of meetings as appended to the SIA Report were maintained as records. List of stakeholders were verified and included government bodies, group associated stakeholders, neighbouring estates and small holders, management staff and workers (incl. representative of migrant workers i.e. Indonesians), Contractors/suppliers and health clinic staff. 6.1.3 Plans for avoidance or mitigation Management Plan for Social Impact Assessment Complied of negative impacts and promotion of the positive ones, and monitoring of FY2013/14 SOU 16-Kok Foh was available. impacts identified, shall be developed The management of estate and mill has monitored the in consultation with the affected impacts identified, developed in consultation with the parties, documented and timetabled, affected parties’ i.e. foreign workers. including responsibilities for implementation. Sighted records of appointed teams headed by estate managers assisted by assistant managers. The roles and Major Compliance responsibilities of these appointed officials were defined. 6.1.4 The plans shall be reviewed as a The PMU has planned to review the SIA plans (FY Complied minimum once every two years and updated as necessary, in those cases 2013/2014) at least once a year for follow-up and where the review has concluded that updating to current practices and implementation. The changes should be made to current review is to include the participation of affected parties practices. There shall be evidence that such as foreign workers. the review includes the participation of

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INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 30 of 48 (SOU 16 Kok Foh: ASA-03) affected parties.

Minor Compliance 6.1.5 Particular attention shall be paid It was verified that there were no smallholder schemes in Not applicable to the impacts of smallholder schemes (where the plantation includes such a the PMU. scheme).

Minor Compliance Criteria 6.2 There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties. Indicators Findings and Objective Evidence Compliance 6.2.1 Consultation and communication Documented policies and procedures are available for Complied procedures shall be documented. internal and external communication and consultation. Major Compliance Estate managers are the nominated persons responsible for communication with the stakeholders. The organization has a list of stakeholders including local authorities, government departments, suppliers, contractors and their neighbours. Interviews with representatives of Gender Committee, workers’ association representatives, neighbouring village representative, internal workers, workers’ dependents, and mosque and temple representatives revealed open and transparent communication and consultation. These interviews confirmed the effectiveness of PMU consultation and communication processes with the internal and external stakeholders. 6.2.2 A management official Social officers for mill and each estate were appointed by Complied responsible for these issues shall be nominated. the respective mill / estate managers, who had held meetings for the communication and consultation with the Minor Compliance local communities and other affected or interested parties on any social issues arising. Appointment records sighted show evidence the existence of a management official for these issues. Interviews with mill and estate managers verified the understanding of their roles and responsibilities. 6.2.3 A list of stakeholders, records of List of stakeholders are sighted in the list of stakeholders all communication, including confirmation of receipt and that efforts at SOU 16 is noted to have included relevant affected parties. The stakeholders’ communications file has been are made to ensure understanding by affected parties, and records of actions maintained and communication records and actions taken taken in response to input from were available. However, Department of Occupational stakeholders, shall be maintained. Safety and Health (DOSH) and Department of Minor NC Environment (DOE) was not included in the # 3 of 3 Minor Compliance stakeholders list. Thus, Minor NCR was raised during the audit Noted that there are open and transparent methods for communication and consultation which has taken into consideration the local conditions including migrant workers and job opportunities for local people. Verified that consultations with various stakeholders had been held and recorded in the minutes of meeting that include actions taken in response to input from stakeholders. Criteria 6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all affected parties. Indicators Findings and Objective Evidence Compliance

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INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

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6.3.1 The system, open to all affected Flow chart and Procedure on Handling Disputes including Complied parties, shall resolve disputes in an effective, timely and appropriate any land related matters as noted in Appendix 3 dated manner, ensuring anonymity of 1/11/2008 & Appendix 5 dated 1/11/2008. complainants and whistleblowers, No case of any dispute was raised since 2008 in the where requested. Stakeholder Complaints and Grievance record book.

Major Compliance This was confirmed through interviews conducted with various staff, workers, contractors, suppliers, local community representatives of SOU16 during the current surveillance assessment. The PMU has an established and documented system for dealing with complaints and grievances and it was well implemented. 6.3.2 Documentation of both the There has been no dispute issue requiring any resolution Complied process by which a dispute was resolved and the outcome shall be and thus though the mechanism was available there was available. no apparent case as was verified during current surveillance. Major Compliance Mechanisms are appropriately established and implemented. Records of meeting and any resolutions or outcomes are maintained through Minutes or in Complaints Log. Criteria 6.4 Any negotiations concerning compensation for loss of legal, customary or user rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions. Indicators Findings and Objective Evidence Compliance 6.4.1 A procedure for identifying legal, The documented procedure for identifying legal and Complied customary or user rights, and a procedure for identifying people customary rights and procedure for identifying people entitled to compensation, shall be in entitled to compensation have been maintained. Current place. latest version in SPMS Manual 01/ 11/2008. Social Policy established by Sime Darby Plantation is Major Compliance available and maintained at website link: www.simdearbyplantation.com/sustainability There were no borders which were adjacent to any villages or native land in the PMU. Therefore, no cases requiring any negotiation or compensation pertaining to these criteria. There have been no changes in this status as at the period of verification on site. 6.4.2 A procedure for calculating and There is a procedure for calculating and distributing Complied distributing fair compensation (monetary or otherwise) shall be compensation. To date, there has been no dispute by any established and implemented, parties relating to legal, customary or user rights at the monitored and evaluated in a PMU. participatory way, and corrective There have been no claims or disputes relating to legal actions taken as a result of this and customary rights. As such, the application of the evaluation. This procedure shall take procedure for calculating and distributing compensation into account: gender differences in the power to claim rights, ownership and has not been invoked. access to land; differences of transmigrants and long-established communities; and differences in ethnic groups’ proof of legal versus communal ownership of land.

Minor Compliance 6.4.3 The process an d outcome of any The process is made available via website link: Complied negotiated agreements and compensation claims shall be www.simdearbyplantation.com/sustainability

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 32 of 48 (SOU 16 Kok Foh: ASA-03) documented, with evidence of the So far, there has been no dispute by any parties relating participation of affected parties, and to legal, customary or user rights at the SOU 16 Kok Foh made publicly available. PMU. Therefore the process and outcome of compensation could not be observed. Major Compliance Criteria 6.5 Pay and conditions for employees and for contract workers always meet at least legal or industry minimum standards and are sufficient to provide decent living wages. Indicators Findings and Objective Evidence Compliance 6.5.1 Documentation of pay and Labour policy is documented and publicly available. Complied conditions shall be available. Labour policy addresses migrant workers who mostly Major Compliance come from Indonesia. Employment conditions meet legal requirement. Employment agreements, stating all statutory fringe benefits and eligible incentives are available. Stated conditions in the employment agreement includes working hours, overtime, leave and medical benefits, maternity leave for women, insurance coverage, deductions, resignation notice period, company rules, etc., which are in compliance with applicable legal requirements. The payment slip was easy to understand. Foreign workers are legally employed directly by respective PMU and work permits were available and verified to be satisfactory. Pay and conditions are documented in letters of employment. MAPA circular No. 20/2013 dated 21 May 2013 has been used as basis for calculation for pay and benefits. Minimum wages for Peninsular Malaysia as stipulated by Minimum Wage Order 2013 were adhered to by the mill and estate management. Offer letter, employment agreements with applicable terms and conditions and accompanying appendices conditions are documented in Bahasa Malaysia and have been explained to and understood by the employees. The PMU also provides free housing and piped water supply, free electricity, medical benefits, mosques, church and welfare amenities that in overall constitutes a decent living for the employees. The documented pay and conditions are verified to be satisfactorily implemented. Pay and conditions documented in the employment contract and found to be in accordance with the Employment Act. 6.5.2 Labour laws, union agreements Pay and conditions are provided as per the enforced Complied or direct contracts of employment detailing payments and conditions of current agreements negotiated by NUPW and AMESU employment (e.g. working hours, who represent local as well as foreign workers. deductions, overtime, sickness, holiday Documented employment contract verified for migrant entitlement, maternity leave, reasons workers had covered all issue such as working hours, for dismissal, period of notice, etc.) deductions, overtime, sickness, holiday entitlement, shall be available in the languages maternity leave, and reasons for dismissal, period of understood by the workers or explained carefully to them by a notice made available in Bahasa Malaysia which is management official. understood by the workers (local and foreign workers)

Major Compliance 6.5.3 Growers and millers shall provide The estate management was noted to have complied with Complied adequate housing, water supplies, medical, educational and welfare Workers’ Minimum Standard of Housing and Amenities

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INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 33 of 48 (SOU 16 Kok Foh: ASA-03) amenities to national standards or Act 1990 (Act 446). above, in accordance with Workers’ Minimum Standard of Housing and Workers minimum standards for housing and amenities Amenities Act 1990 (Act 446) or above, adhered for all estate workers including migrant workers from Indonesia, Nepal, Bangladesh and Sri Lanka. where no such public facilities are available or accessible (not applicable Line site inspections was adequately done for Kok Foh to smallholders). mill and estates by the medical assistant and recorded in the inspection logbooks. Minor Compliance Site visits to workers’ homes and interviews with their dependents revealed their general satisfaction with their housing conditions and amenities.

Housing, electricity and water supply

Workers are given a small patch of land to grow

vegetables/fruit trees and keep poultry around their houses in order to reduce the cost of living. The workers staying in the estate are provided with 24 hours electricity supply. Clean water supply comes from treated water supplied by the company owned by the state government

Schools

The migrant workers’ does not have any children staying at the PMU. Sundry shops The availability of sundry shops within the estates which helped the staff and workers get their sundries nearby. From interviews with the workers in PMU it was found that most household sundries, including frozen foodstuffs were available on sale. Crèche ( Rumah Asuhan Kanak-kanak) No crèche in the estates audited since all the local workers’ children were went for school. Medical clinics There is a clinic in every estate which is manned by an Estate Medical Assistant (MA). Visiting Medical Officer comes once a month to monitor the services provided and to review the referred cases. Basic medical treatment of minor ailment and first aids such as toilet and suturing (T&S) of small laceration wounds are provided. Sharp bins are available in all clinics and content of the bins are disposed through proper channel, i.e. collected by licensed collector. 6.5.4 Growers and millers shall make Food for the workers provided through sundry shops in Complied demonstrable efforts to monitor and where able, improve workers’ access each of the PMU estates verified to be adequate and to adequate, sufficient and affordable affordable. food.

Minor Compliance Criteria 6.6 The employer respects the rights of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel. Indicators Findings and Objective Evidence Compliance 6.6.1 A published statement in local File on the minutes of meetings with NUPW / worker Complied languages recognising freedom of association shall be available. union representatives have been maintained. Meetings held for FY 2013/2014 at SOU16 has been verified. Major Compliance The published statement which recognizes the

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employee’s freedom of association, was found to be available and widely displayed in all notice boards of the PMU as per Section 8, Employment Act 1955 and Section 5 (1) Akta Perhubungan Perusahaan 1967. National Union of Plantation Workers (NUPW) is a platform through which the members negotiate collectively with the management of PMU. 6.6.2 Minutes of meetings with main Management policy on Sime Darby Plantation Group Complied trade unions or workers representatives shall be recognition on freedom of association has been published documented. and maintained since 2009. The policy is available in English and also in Bahasa Malaysia for ease of Minor Compliance understanding by the estate workers / staff and displayed prominently in notice boards. Records of meetings were documented, kept and available. Criteria 6.7 Children are not employed or exploited. Indicators Findings and Objective Evidence Compliance 6.7.1 There shall be documentary Documented policy is a minimum age of 18 for Complied evidence that minimum age requirements are met. employment. This policy is fully well understood and fully adhered to by all mill and estate managers at SOU 16. Major Compliance Examination of employment records and interview with workers confirmed that this requirement is in compliance. This policy is displayed at strategic public places. The birth date in the Identification card and birth certificate of a new employee is used as the verification for age. The implementation was verified through checks on Senarai Maklumat Petugas Ladang. Interviews with workers in the estates and at the Mill confirmed implementation of the stated policy. Criteria 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited. Indicators Findings and Objective Evidence Compliance 6.8.1 A publicly available equal Social Policy stipulating equal opportunities policy has Complied opportunities policy including identification of relevant/affected been documented and publicly available via website link: groups in the local environment shall www.simdearbyplantation.com/sustainability as well as be documented. prominently displayed in notice boards at various office areas (inside and outside office). Major Compliance The policy stressed on non-discrimination based on race, caste, nationality, religion, gender, sexual orientation, disability/handicap, and union/political affiliations. However, positive discrimination for the benefit of certain society groups may be allowed after consultation. 6.8.2 Evidence shall be provided that Non discrimination policy has been issued since 2009 and Complied employees and groups including local communities, women, and migrant has been adhered to. workers have not been discriminated Wage records inspected and rates confirmed as being against. non discriminatory for male, female and both local as well as migrant workers. Major Compliance Compliance to relevant regulatory requirements such as Employment Act 1955, immigration Act 1959/63 and Workmen’s Compensation Act 1952 are observed when recruiting workers from Indonesia. The employment of foreign workers was implemented without affecting the opportunities for local communities. Local workers are covered under SOCSO scheme and

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the migrant workers are covered under Foreign Workers Compensation scheme (FWCS). Interviews with migrant workers’ dependents revealed their satisfaction with the PMU for job opportunities and they enjoy all common welfare amenities like free housing, water and electricity supplies, medical care, and transportation of school children. They are aware of the “aduan” mechanism by which they can make any complain or request to the management. Interview with a women migrant workers revealed that she is a gender representative and there has been no known cases of any sexual harassment or violence against women at the field or at the housing areas. 6.8.3 It shall be demonstrated that Depending on the nature of work positions, The PMU Complied recruitment selection, hiring and promotion where relevant are based on management takes into considerations the needs for skills, capabilities, qualities, and technical qualifications/experience and related skills in medical fitness necessary for the jobs recruitment selection, hiring and promotion exercises. available. It was verified that the promotions to higher position at the estates and POM were based on evaluations which Minor Compliance considered the skill, capabilities, qualities and medical fitness of the employees. A verification of job advertisement and related records evidenced that a recent employment of an administration assistant and was carried out in a non-discriminative manner. The necessary qualifications and conditions were clearly stated in the job advertisement. Terms and conditions of work were spelled out in the offer letter as well. Criteria 6.9 There is no harassment or abuse in the work place, and reproductive rights are protected. Indicators Findings and Objective Evidence Compliance 6.9.1 A policy to prevent sexual and all Gender Policy dated April 2009 signed by the Sime Darby Complied other forms of harassment and violence shall be implemented and Plantation Managing Director has been established and communicated to all levels of the implemented. workforce. Gender Committees have been established at all mill and estates. Periodic meetings noted held during the Major Compliance FY2013/2014.The meeting agenda covered prevention of sexual harassment , violence against women, protection of women reproductive rights, recreational and social activities, reflected communication on harassment issue, general understanding of sexual harassment in the workplace and the mechanism to report an alleged sexual harassment or violence. 6.9.2 A policy to protect the Grievance process flowchart dated April 2009 with a Complied reproductive rights of all, especially of women, shall be implemented and specific mechanism to deal with women communicated to all levels of the concerns/grievances has been established. workforce. Committee meeting minutes file and record books addressing any grievances including women concerns is Major Compliance maintained. Noted that there has been no incidence recorded/reported on sexual harassment and violence against women. Local female staff is fully aware that they are entitled for two months paid maternity leave. Records evidenced and workers interviews that every women field worker who is handling agrochemicals is issued a reminder letter informing them of their

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responsibility to communicate with the management as soon as pregnancy is confirmed or breastfeeding is planned. The reminder letter states that alternative job that does not require agrochemical handling will be offered. The PMU confirmed that there is no pregnant or breastfeeding woman worker among all the women agrochemical handlers now. 6.9.3 A specific grievance mechanism Complaint and grievance procedures “Prosedur Complied which respects anonymity and protects complainants where requested shall be Menangani Aduan dan Rungutan dan Polisi Pemberian established, implemented, and Maklumat / whistle blowing” are available to manage communicated to all levels of the grievances and complaints from internal and external workforce. stakeholders. Onsite audits verified that the complaint and grievance Minor Compliance procedure and whistle blowing procedure are displayed outside staff offices, muster call stations and at the public areas. Management confirmed that there has been no report of sexual harassment in the PMU so far. Criteria 6.10 Growers and millers deal fairly and transparently with smallholders and other local businesses. Indicators Findings and Objective Evidence Compliance 6.10.1 Current and past prices paid for Pricing mechanism for FFB following MPOB guidelines is Complied Fresh Fruit Bunches (FFB) shall be publicly available. documented and available at mill office. A file with the rates for transport contractors, worker supply and other Minor Compliance services is maintained. 6.10.2 Evidence shall be available that FFB prices were made available via website link: Complied growers/millers have explained FFB pricing, and pricing mechanisms for www.simdearbyplantation.com/sustainability FFB and inputs/services shall be The POM has treated out-growers and other local documented (where these are under business fairly. Pricing mechanism for FFB is fair and the control of the mill or plantation). transparent and FFB grading as per MPOB approved / licensed graders and based MPOB specification. Current Major Compliance and past prices paid for FFB were publicly available and verified through interviews. Mechanisms are available to the public upon request. 6.10.3 Evidence shall be available that Evidenced in agreements made with MAPA, NUPW & Complied all parties understand the contractual AMESU. Allowances are standardized such as for agreements they enter into, and that contracts are fair, legal and transport and other subsistence. transparent. Stakeholder interviews conducted during this assessment with suppliers, contractors, and relevant parties including Minor Compliance local and foreign workers confirmed that understand the contractual agreements (such as terms and payment) they enter into with the PMU. They also consider the

business transactions as fair and transparent. 6.10.4 Agreed payments shall be made Through interviews made, there is no evidence to suggest Complied in a timely manner. of any unfair business practices with the local businesses. Minor Compliance Payroll for Kok Foh mill and estates (Jan-April 2014) were available. Interviews with employees and contractors confirmed that payments are received in a timely manner. Criteria 6.11 Growers and millers contribute to local sustainable development where appropriate. Indicators Findings and Objective Evidence Compliance 6.11.1 Contributions to local File on social contributions and activities were maintained Complied development that are based on the and noted contributions issued for occasions such as

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 37 of 48 (SOU 16 Kok Foh: ASA-03) results of consultation with local festivities of local community, religious, social, communities shall be demonstrated. educational and burial contributions for estate family members. Minor Compliance 6.11.2 Where there are scheme It was verified that there were no smallholder scheme in Not applicable smallholders, there shall be evidence that efforts and/or resources have been the PMU (see also 6.1.5).. allocated to improve smallholder productivity.

Minor Compliance Criteria 6.12 No forms of forced or trafficked labour are used. Indicators Findings and Objective Evidence Compliance 6.12.1 There shall be evidence that no Audit of employment records such as work permits in an Complied forms of forced or trafficked labour are used. estate office confirmed that all migrant workers were recruited through legal means and according to the Major Compliance regulatory requirements. Interviews with migrant workers and their dependents in the housing are confirmed that there were no forced or trafficked labours. 6.12.2 Where applicable, it shall be There was no evidence of contract substitution and this Complied demonstrated that no contract was confirmed from interviews with workers and relevant substitution has occurred. stakeholders. Minor Compliance 6.12.3 Where temporary or foreign The special policy on recruitment of foreign workers Complied workers are employed, a special labour policy and procedures shall be “Polisi Pengambilan Pekerja Asing” and equal established and implemented. opportunities “Polisi Kesetaraan Peluang” are established and the implementations are verified to be satisfactory. Major Compliance Review on employment contracts of foreign workers also confirmed that the policies, including minimum wages have also been duly implemented. Criteria 6.13 Growers and millers respect human rights. Indicators Findings and Objective Evidence Compliance 6.13.1 A policy to respect human rights The Human Rights Policy is in progress of being New shall be documented and communicated to all levels of the documented. requirement of workforce and operations (see Criteria RSPO P&C 1.2 and 2.1). (2013) - Follow up action at Major Compliance next ASA. 6.13.2 As long as children of plantation Not applicable for this PMU in Negeri Sembilan and Not Applicable workers of Sabah and Sarawak are not Johor. secured a right to go to government school, the plantation companies should engage in a process to secure the children of the plantation workers access to education as a moral obligation.

Minor Compliance

Principle 7: Responsible development of new plantings

SOU 16 Kok Foh has a documented procedure for this development but has not carried any new plantings after Nov 2005. Therefore, the requirements of Principle 7 are not applicable during this assessment.

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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 continual improvement in key operations. Indicators Findings and Objective Evidence Compliance 8.1.1 The action plan for continual improvement shall be implemented, based on a PMU had planned and progressively implemented the Complied consideration of the main social following continual improvement items: and environmental impacts and opportunities of the grower/mill, and shall include a range of Indicators covered by these Principles and Criteria.

As a minimum, these shall include, but are not necessarily be limited to:

• Reduction in use of pesticides(Criterion 4.6); Increase planting of beneficial plants from 1 Dm/ha to 2Dm/ha ( Turnera subulata, Cassia cobanensis and Antigonon leptopus ). Noted that paraquat had been discontinued in estates since 2010. Segregation of disposal of waste (steel, glass, plastic & • Environmental impacts (Criteria organic) .Environmental impacts and action plans were 4.3, 5.1 and 5.2); monitored, implemented and reviewed periodically.

80% of EFB had been used for compost production and 20% for mulching in mature and immature palms. • Waste reduction (Criterion 5.3); 50% of POME produced had been utilized for compost production and 50% had been used for land application as a source of nutrients. Noted that the SOU is progressing towards the minimum or zero waste concepts.

• Pollution and greenhouse gas Significant pollutants and greenhouse gas (GHG) (GHG) emissions (Criteria 5.6 and 7.8); emissions were identified, e.g. POME, diesel / fuel and fertilizer usage have been documented at the PMU. It is

noted that the SDPSB Sustainability Department from HQ have already established plans for implementation and monitoring of GHG emissions

• Social impacts (Criterion 6.1); Continual improvements planned and /or implemented FY2013/2014 include computers assistance for education , paint contribution to religious temple , gender committee activities ,social activities for local communities and upgrading of housing units for line-site workers.

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• Optimising the yield of the Increase the number of vehicles for infield collection of supply base. FFB, and to replace the old tractors with new ones.

Major compliance

3.1.1 Supply Chain Certification Standards Findings - on CPO Mill

The Supply Chain model applied at SOU 16 - Kok Foh POM during this current surveillance assessment is Module E: Mass Balance (MB).

Details of findings are as follows:

E.1 Documented procedures Indicators Findings and Objective Evidence Compliance E.1.1 Documented procedures – SOP for RSPO Supply Complied The facility shall have written procedures and/or Chain Certification System and Traceability ver1 work instructions to ensure the implementation of issue 1 dated Mar 2013 Module E (Mass Balance). all the elements specified in these requirements. • Module E applied at this POM include: This shall include at minimum the following: (i) FFB receipt (ii) FFB processing into CPO & PK (iii) Sales & dispatch (iv) Training (v) Claim as MB model. a) Complete and up to date procedures covering Documented Supply Chain Procedure dated Mar Complied the implementation of all the elements in these 2013 has included all the requirements for requirements controlling the FFB receipt, processing, sale and CPO dispatch, training and claims for Mass Balance (MB) Module for the Palm Oil Mill. Implementation complied with all the requirements. b) The name of the person having overall PMU’s Mill Manager, Mr. Ghazali Said identified as Complied responsibility for and authority over the the person responsible for the Supply Chain implementation of these requirements and aspects of FFB receipts, processing and shipping compliance with all applicable requirements. This of CPO, PK and palm products. Interview of Mill person shall be able to demonstrate awareness of the facilities procedures for the implementation of Manager and other relevant staff confirmed their this standard. knowledge of the RSPO Supply Chain Certification requirements for the respective areas of operations. E.1.2 The SOP covers the receiving of FFB supply from Complied The facility shall have documented procedures for Sime Darby’s own estates i.e. SOU 16 and other receiving and processing certified and non- certified SOUs and also the Outside Crop certified FFBs. Producers (OCP). Crop from OCPs are uncertified FFB. The source of supply of both certified and non-certified FFBs was clearly identified on the receiving documents (FFB Consignment Note from own estates / Delivery Order or FFB Dispatch from OCP and weighbridge tickets). All supplies of FFB were subjected to verification of documents by weighbridge personnel and quality checks by lab personnel. All Storage tanks at the POM are designated as Mass Balance (MB) CPO.

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E.2 Purchasing and goods in Indicators Findings and Objective Evidence Compliance E.2.1 The Mill verifies and records tonnages and supply Complied The facility shall verify and document the volumes source of FFB received at the weighbridge in the of certified and non-certified FFBs received. delivery documents and weighbridge tickets and these are reported on a daily and monthly basis. Details entered into the computer system and also recorded in a log book. Daily and monthly summary of all FFB. Summary of Production Report for July 2013 to May 2014 to date were verified to be MB palm products. Confirmed proper documentation and traceability of certified and non-certified FFB E.2.2 SOU 16 POM has an internal monitoring and Complied The facility shall inform the CB immediately if reporting mechanism for advising the CB of there is a projected overproduction. production variations. So far, there is no projected overproduction reported. E.3 Record keeping Indicators Findings and Objective Evidence Compliance E.3.1 Records and reports include all aspects of FFB Complied The facility shall maintain accurate, complete, up- reception from own estates and outside suppliers, to-date and accessible records and reports FFB processed and production of CPO and PK. covering all aspects of these requirements. Records and reports found to be accurate, complete, up-to-date, retrievable and properly maintained and controlled. E.3.2 SOP stated a retention period of a minimum of 5 Complied Retention times for all records and reports shall be years for all records and reports. Verified that this at least five (5) years. requirement has been satisfie E.3.3 Inspection of records and reports at the Palm Oil Complied The facility shall record and balance all receipts of Mill confirmed that the data (daily, monthly and RSPO certified FFB and deliveries of RSPO year to-date) on FFB, CPO and PK were up-to-date certified CPO, PKO and palm kernel meal on a and accessible as seen in the Production Book. three-monthly basis. There is no production of PKO and palm kernel meal at the said POM facility. Deduction and conversion ratios for the volumes of CPO delivered from the Palm Oil Mill have been appropriately carried out and recorded. All deliveries of the MB sales were from positive stock and no short selling is practiced. E.3.4 SOP stated that Global Trading and Marketing Complied The following trade names should be used and (GTM) Department shall specify the trade name in specified in relevant documents, e.g. purchase the purchase and sales contract as ‘RSPO and sales contracts, e.g. *product name*/SG or CSPO/MB or Mass Balance’. Segregated. The supply chain model used should be clearly indicated. Traceability was evidenced for the Production Report for Jul 2013 – May 2014 which was verified as evident from records (FFB Delivery Documents, Weighbridge Ticket, FFB & Truck Daily Summary, Production Report, CPO Storage Report, and CPO Delivery Orders. E.3.5 PK is sold to SIME FUTURES (80%) and other Complied In cases where a mill outsources activities to an palm kernel buyers (20%) based in Selangor.

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Report No.: R9281/12-3 Sime Darby Plantation Sdn Bhd Page 41 of 48 (SOU 16 Kok Foh: ASA-03) independent palm kernel crush, the crush still falls under the responsibility of the mill and does not need to be separately certified. The mill has to ensure that the crush is covered through a signed and enforceable agreement. E.4 Sales and good out Indicators Findings and Objective Evidence Compliance E.4.1 Examined samples of sales contracts, invoices and Complied The facility shall ensure that all sales invoices delivery documents for CPO and PK delivered to issued for RSPO certified products delivered buyers. include the following information: Above documents contained the information (a) to a) The name and address of the buyer; (e) as listed in Indicator E4.1 b) The date on which the invoice was issued; c) A description of the product, including the applicable supply chain model (Mass Balance); d) The quantity of the products delivered; e) Reference to related transport documentation. E.5 Training Indicators Findings and Objective Evidence Compliance E.5.1 Competence and training needs identification Complied The facility shall provide the training for all staff as carried out resulting in Training Plan Year 2013. required to implement the requirements of the Supply Chain Certification Systems. Refresher SCCS Training was carried out for 11 persons on 16 Apr 2014. Training materials and attendance records / certificates are available and filed. Performance evaluation carried out . Interview with mill personnel confirmed their awareness of MB module implemented and maintained.

E.6 Claims Indicators Findings and Objective Evidence Compliance E.6.1 Based on documents and records verified on-site, Complied The facility shall only make claims regarding the no claims made that can constitute a breach of the use of or support of RSPO certified palm oil that RSPO Rules for Communications and Claims as to are in compliance with the RSPO Rules for date. Communication and Claims. RSPO Trademark License No. for Sime Darby Plantation is RSPO-1106024.

3.1.2 Status on Supply Chain on POM: Based on the documents and records presented during the on-site verifications made, it is concluded that the SOU 16 Kok Foh POM has been able to comply with the requirements of the RSPO SCCS under the ‘MB’ module and is thus eligible for ‘MB’ trading for its palm products for FY Jul 2013 – Jun 2014.

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3.2 Status of Identified Noncompliance and Corrective Actions, Observations and Positive Elements.

3.2.1 Summary Status of Identified Noncompliances and Observations. The status of the Noncompliances (NCR) and Observations (OBS) identified against the MYNI Compliance Indicators is as per the details below: Assessment Type Year Noncompliance (NCR) Observations (OBS) Main Assessment 2009 5 - Minor 1 Annual Surveillance - 01 2012 2 - Minor 2

Annual Surveillance - 02 2013 2 (1- Major & 1-Minor) 0 Annual Surveillance - 03 2014 3 - Minor 3

3.2.2 Year 2013: Annual Surveillance Assessment (ASA-02)

NCR # Indicator/ Details of NCR Category

1 of 2 4.4.1 Date issued: Date due: Date closed: Major 14/06/2013 14/07/2013 23/05/14 Nonconformance: Some palms had been planted within the buffer zone along the stream in Field 11C, 2011 replanting, Division, on St. Helier Estate.

Root Cause and Corrective Action (replied): There was an oversight at the estate. Survey is taking place to re-check the replanting at Buffer zones and is expected to complete by end August 2013. The Buffer zone made will be followed strictly and the palms planted will be clearly marked and no spraying of pesticides will be allowed. See attachment on ‘Briefing for Buffer zone area’ at St. Helier. [Reply communicated on 3 July 2013]

Verification (for effective closure): During surveillance (ASA-03): Verification on site during ASA-03, confirms that the buffer zones have been adequately established at St Helier and sampled estates. Adequate signages have also been established to demarcate the buffer zones and control operational activities within the buffer zone areas.

Hence the nonconformance was effectively addressed and closed.

2 of 2 5.2.3 Date issued: Date due: Date closed: Minor 14/06/2013 14/07/2013 23/05/14 Nonconformance: At the Pertang, Sg. Gemas, Sg. Senarut and St. Helier estates, the estate signages and monitoring of activities at the HCV areas particularly when adjacent to Forest Reserves are not adequately done.

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Root Cause and Corrective Action (replied): The estate erected 3 signages adjacent to Jementah forest. Maintenance of signages has been overlooked. However it was not covering all the monitoring activities as stipulated

New signage’s (3 units) were ordered comprises allowable and non- allowable activities. Will introduce recording book to monitor wildlife along the boundary with forest reserve.

Verification (for effective closure): During surveillance (ASA-03): Signages have been erected and maintained at the Pertang, Sg. Gemas, Sg. Senarut, St. Helier estates and the 3 sampled estates during the on-site surveillance assessment. Monitoring activities have been adequately addressed by the PIC from estates sampled.

Hence the nonconformance was effectively addressed and closed.

3.2.3 Y ear 2014: Annual Surveillance Assessment (ASA-03) NCR # Indicator/ Details of NCR Category

1 of 3 4.3.2 Date issued: 23 May 2014 Date closed: Next Surveillance Minor Nonconformance: In F 13A on Muar River estate, a section of land with slope > 6°, based on visual judgment, there was no provision of planting terraces as stated in the SOP for planting on slopes (slope between > 6°).

Reply on Root Cause and Corrective Action Plan: There was oversight at the area. To construct water conservation terraces at 32m intervals. Target month to complete in June 2014.

On-Site Verification on Corrective Action taken: (Within 60 days for Major NCR) Not applicable Verification (for effective closure): During Next Surveillance

NCR # Indicator/ Details of NCR Category

2 of 3 4.3.2 Date issued: 23 May 2014 Date closed: Next Surveillance Minor Nonconformance: In F 14A on Muar River estate, a section of land with slope of about 5°, based on visual judgment, there was no provision of water conservation terraces, if the slope were >6°, as stated in the SOP for planting on slope (slope between 2° to 6°).

Reply on Root Cause and Corrective Action Plan: There was oversight at the area. To construct water conservation terraces at 32m intervals. Target month to complete in June 2014.

On-Site Verification on Corrective Action taken: (Within 60 days for Major NCR) Not applicable

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Verification (for effective closure): During Next Surveillance

NCR # Indicator/ Details of NCR Category

3 of 3 6.2.3 Date issued: 23 May 2014 Date closed: Next Surveillance Minor Nonconformance: List of stakeholders for Palm Oil Mill (POM) did not include the relevant authorities such as Department of Occupational Safety and Health (DOSH) and Department of Environment (DOE).

Reply on Root Cause and Corrective Action Plan: There was a missed out when the list was updated and re-typed. The List of stakeholders for Palm Oil Mill (POM) has been amended to include the relevant authorities such as Department of Occupational Safety and Health (DOSH) and Department of Environment (DOE).

On-Site Verification on Corrective Action taken: (Within 60 days for Major NCR) Not applicable. Verification (for effective closure): During Next Surveillance Audit

Note: Any Major or Minor NC raised shall be verified and closed off in accordance with the ICI procedure for closure of NC and will be reported in the next assessment report.

3.2.4 Summary and Status of Observations The Observations (OBS) identified during current assessment and follow up done on the previous assessment are detailed as per below. Note: The progress made on the observations listed will be reviewed during the subsequent Annual Surveillance Assessment on the action and implementations taken.

Year 2013: ASA-02 : Nil Observations

Year 2014: ASA-03: Three (3) - Observations as per below: Status RSPO Opened Closed Follow up Ref No: MYNI Location Details of Observation date date remarks, Indicator (if any) 1 of 4 4.3.3 PMU – On Muar River Estate, some gullies 23 May - To follow up Muar River were found along the main roads 2014 during next

estate and field roads, with silt deposits at Surveillance. the lower portions of the roads being sign of soil erosion, both in the mature and immature areas.

2 of 4 5.3.1 PMU HCV documentation needs to be 23 May - To follow up estates updated, including hectarages, in a 2014 during next

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timely manner. Surveillance.

3 of 4 6.1.1 PMU – Social Impact Assessment (SIA) 23 May - To follow up POM and done in Apr 2009 was already 5 2014 during next estates years. Reassessment could be Surveillance. conducted as soon as possible.

3.2.5 Identified Positive Elements 1. The continued improvement observed through the achieved 5S Good Housekeeping Practices, Safety & Health and Kaizen implementation and maintenance activities throughout the PMU. 2. The continued improvement of housing for line –sites were commendable at the PMU.

3.3 Issues Raised by Stakeholders and Findings

During the current Annual Surveillance Assessment (ASA-03), all pertinent feedback from the stakeholder consultations process on the environmental and social performance of SOU 16 Kok Foh operational issues were reviewed and followed up for verification on-site and these had been accordingly incorporated into the report findings. See table below.

Stakeholders’ Feedback PMU Response Intertek verification / Further action from comment on further PMU (if any) action (if any) Government Agencies Comunication done via email on 9 Apr 2014. See list under para 2.5. No response needed No response needed. Nil

No feedback received. Non-Governmental

Organizations Comunication done via email on 9 April 2014. See list under para 2.5. No response needed No response needed. Nil No feedback received. Local Communities

At SOU 16 Kok Foh grouping PMU management to Verified during on-site PMU, a total of 11 stakeholders continue to engage assessment that the Nil comprising village heads, stakeholders through PMU has established contractors , suppliers , stakeholder meetings and conducted transporters were interviewed and communication stakeholder meetings . during the on-site assessment. mechanisms that have Communication The feedback was positive and been established. mechanisms for there were no outstanding complaints , queries concerns raised . and suggestions were also verified to have that have been established and practiced.

To be further verified during next surveillance audit. Other Interested parties Comunication done via email on 9 April 2014. See list under para 2.5. No response needed No response needed. Nil No feedback received.

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4.0 Assessment Conclusion and Recommendation

Based on the findings above, Sime Darby SOU 16 Kok Foh had been able to demonstrate its overall compliance with the current requirements of RSPO Principles and Criteria (Apr 2013), Malaysian National Interpretation (MY- NI 2010) and the RSPO Supply Chain Certification Standard (Nov 2011) for Palm Oil Mill.

Therefore, it is recommended that the certification of Sime Darby SOU 16 Kok Foh to be continued.

Signed for and on behalf of Intertek Certification International Sdn Bhd

Mohan Thavarajah

Mr. Mohan Thavarajah Lead Assessor

Date: 27 June 2014

4.1 Acknowledgement of Internal Responsibility and Confirmation of Assessment Findings

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

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4.2 Intertek RSPO Certificate details for SOU 16 Kok Foh

Certificate No: RSPO 928188 (ICI Cert.) (Previous CB cert: C819157CU-RSPO-01.2011)

Issue date: 7 July 2012 (Original issue date: 7 July 2011)

Expiry date: 6 July 2016

Organization Sime Darby Plantation Sdn Bhd

Address of Head Office: PSQM Level 3A, Plantation Tower, No. 2, Jalan PJU 1A/7, Ara Damansara, 47301

Petaling Jaya, Selangor RSPO Membership No: 1-0008-04-000-00

Plantation Management Unit: SOU 16 Kok Foh

Address of Palm Oil Mill: Kok Foh Palm Oil Mill, 72109 Bahau, Negeri Sembilan, Malaysia

Standards: RSPO Principles and Criteria (Apr 2013) Malaysian National Interpretation (MY- NI, November 2010) and RSPO Supply Chain Certification Standards (November 2011) for the Palm Oil Mill. Certification scope: Production of Crude Palm Oil and Palm Kernels

Supply Chain model for Mass Balance (MB) CPO & PK:

Details of the Mill and Estates / Supply bases covered by this certificate and the tonnage approved are:

GPS Reference Name Address Latitude Longitude Kok Foh POM Kok Foh Palm Oil Mill, 72109 Bahau, 2°47.08” N 102°30.25’ E (Capacity 40mt/hr) Negeri Sembilan, Malaysia Kok Foh Estate, 72109 Bahau, Kok Foh estate 2°47.08” N 102°30.25’ E Negeri Sembilan, Malaysia Sg. Senarut Estate, 85100 Batu Anam, Sg. Senarut estate 2°34.16’ N 102°45.20’ E Johor, Malaysia Muar River Estate, Locked Bag No.503, Muar River estate 2°34’26” N 102°45’08” E 85009 Segamat, Johor, Malaysia Pertang Estate, 72300 Simpang Pertang, Pertang estate 2°57’25” N 102°18.12’ E Negeri Sembilan, Malaysia Sg. Gemas Estate, 73400 Gemas, Sg. Gemas estate 2°34.73” N 102°38.86’ E Johor, Malaysia Bukit Pilah Estate, 73500 Rompin, Bukit Pilah estate 2°33.73” N 102°55.91’ E Negeri Sembilan, Malaysia St. Helier Estate, 72100 Bahau, St. Helier estate 2°33.72” N 102°33.73’ E Negeri Sembilan, Malaysia Sg. Sabaling Estate, 72100 Bahau, Sg. Sabaling estate 2°50.56” N 102°29.03’ E Negeri Sembilan, Malaysia

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The annual certifiable tonnages of CPO and PK production as assessed and verified during the current Annual Surveillance Assessment (ASA-03) are detailed as follows:

FY Jul 2013 / Jun 2014 FY Jul 2014 / Jun 2015 POM Actual + Projected (2 months) Projected Total FFB Processed (MT) 172,390.55 188,356.24 Total CPO Production (MT) 38,132.79 OER: 22.12% 41,193.51 OER: 21.87% Total PK Production (MT) 9,533.20 KER: 5.53% 10,303.09 KER: 5.47% SCCS Model for POM MB MB

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