Report No.: R9314/18-1 Kuala Lumpur Berhad, Tuan Mee Grouping Page 1 of 72 ReKuala-certification Lumpur (Transfer CB)Kepong Berhad

RSPO Membership No: 1-0014-04-000-00

PLANTATION MANAGEMENT UNIT Tuan Mee Grouping , Darul Ehsan,

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

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RE-CERTIFICATION ASSESSMENT

PUBLIC SUMMARY REPORT

KUALA LUMPUR KEPONG BERHAD

RSPO Membership No: 1-0014-04-000-00

PLANTATION MANAGEMENT UNIT Tuan Mee Grouping Sungai Buloh, Selangor, Malaysia

Certificate No: RSPO 931488 Issue Date (Re-Cert): 10 September 2018 Expiry date: 09 September 2023 Initial Certification Issued date: 10 September 2013

Assessment Type Assessment Dates Re-Certification Assessment (Transfer CB) 7, 10 –11 May 2018 Annual Surveillance Assessment (ASA-01) Annual Surveillance Assessment (ASA-02) Annual Surveillance Assessment (ASA-03) Annual Surveillance Assessment (ASA-04)

Intertek Certification International Sdn Bhd D-28-3, Level 28, Menara Suezcap 1, No. 2, Jalan Kerinchi, Gerbang Kerinchi Lestari, 59200 Kuala Lumpur, Malaysia. Tel: +00 (603) 7931 0032 Fax: +00 (603) 7931 0419 Email: [email protected] Website: www.intertek.com

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TABLE OF CONTENTS

Section Content Page No 1.0 SCOPE OF ASSESSMENT 4 1.1 Introduction 4 1.2 Location (address, GPS and map) mill, estates and hectarage 4 1.3 Description of supply base (fruit sources) 4 1.4 Year of plantings and cycle 5 1.5 Summary of Land Use – Conservation and HCV Areas 6 1.6 Other certifications held and Use of RSPO Trademarks 6 1.7 Organizational information/contact person 6 1.8 Tonnages Verified for Certification 7 1.9 Time Bound Plan and Multiple Management Units 8 1.10 Abbreviations Used 9 2.0 ASSESSMENT PROCESS 10 2.1 Assessment Methodology, Plan & Site Visits 10 2.2 Date of next scheduled visit 10 2.3 Qualifications of the Lead Assessor and Assessment Team 10 2.4 Certification Body 10 2.5 Process of Stakeholder consultation 11-12 3.0 ASSESSMENT FINDINGS 13 3.1 Summary of findings 13-48 3.2 Status of Identified Noncompliance and Corrective Actions, Observations 49-52 and Identified Positive Elements 3.3 Summary of Feedback Received from Stakeholders and Findings 53 4.0 ASSESSMENT CONCLUSION AND RECOMMENDATION 54 4.1 Acknowledgement of Internal Responsibility and Confirmation of Assessment 54 Findings

4.2 Intertek RSPO Certification Details for the PMU 55

APPENDICES Appendix A Qualifications of the Lead Assessor and Assessment Team 56 Appendix B Assessment Plan 57-58 Appendix C Maps of location – Mill and Estates 59-62 Appendix D Photographs of Assessment findings at the PMU 63 Appendix E Time Bound Plan for Other Plantation Management Units 64-72

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1.0 SCOPE OF ASSESSMENT

1.1 Introduction This Re-certification / Transfer Assessment was conducted on the Plantation Management Unit (PMU) Tuan Mee Grouping of Kuala Lumpur Kepong Berhad (hereafter abbreviated as KLK), on 7, 10–11 May 2018, to assess the organization’s operations of the mill and its supply bases for compliance against the RSPO Principles and Criteria (Apr 2013), Malaysian National Interpretation (MYNI 2014) and the RSPO Supply Chain Certification Standard (Jun 2017) for the Palm Oil Mill.

The plantation management unit (PMU) or management unit is equivalent to a certification unit as defined in the RSPO Certification Systems Document. Each PMU consists of one mill and its supply bases which are made up of estates owned and/or managed by KLK.

1.2 Location (address, GPS and map) of palm oil mill and estates The Tuan Mee Grouping consists of one (1) palm oil mill, namely Tuan Mee Palm Oil Mill and one (1) estate only as indicated in Table 1 below, which includes the addresses and GPS locations of the mill and estate. The location maps are provided in Appendix C. Table 1: Address of Palm Oil Mill, Estate and GPS Location GPS Reference Name Address Latitude Longitude KLK Tuan Mee Batu 24, Jalan -Kepong, Palm Oil Mill N 3°15’54.2’’ E 101°27’49.5’’ 47000 Sg. Buloh, Selangor D.E., Malaysia (Capacity: 22 MT/hour) Batu 24, Jalan Kuala Selangor-Kepong, Tuan Mee Estate N 3°16’7.4’’ E 101°27’20.5’’ 47000 Sg. Buloh, Selangor D.E., Malaysia

1.3 Description of supply base (fruit sources)

The supply base, i.e. FFB sources to the POM at Tuan Mee Grouping PMU are currently from the abovementioned estate of this PMU, other certified KLK Groupings estates and Outside Crop Producers (OCP). The FFB from the PMU estate and other certified KLK Groupings estates are certified FFB. The FFB from OCP are considered as non- certified FFB. Details of the planted hectarage for the FFB supply to the PMU are as shown in Table 2 below.

Table 2: Estate Area Summary Area Summary (ha) Area Summary (ha) – Current Estate (Year 2016) (Jan to Dec 2017) Certified Area Planted Area Certified Area Planted Area Tuan Mee Estate 2,686 2,427 2,678 2,411 Total: 2,686 2,427 2,678 2,411 Note: This Assessment covered the overall land use for oil palm plantation areas, and the identified Conservation / unplantable areas including HCV (if any) marked out at the estate.

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1.4 Summary of plantings and cycle The age profile of the planted oil palms is as shown in Table 3. Table 3: Age Profile of Planted Oil Palms (Year 2017) Year of Cycle of Mature OP (ha) Immature OP (ha) Total (ha) Estate Name Planting Planting – Above 3 years – 3 years & below

Tuan Mee Estate 1990 1st 30 30

1992 1st 164 164

1993 1st 21 21

1994 1st 113 113

1995 1st 23 23

1997 1st 62 62

1998 1st 79 79

2000 1st 248 248

2001 1st 145 145

2002 1st 134 134

2003 1st 19 19

2004 1st 209 209

2005 1st 205 205

2006 1st 144 144

2007 1st 124 124

2008 1st 91 91

2010 1st 82 82

2011 1st 40 40

2012 1st 76 76

2016 2nd 106 106

2017 2nd 141 141

2018 2nd 155 155

Total: 2009 402 2411

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1.5 Summary of Land Use - Conservation and HCV Areas The summary of Conservation and HCV Areas as identified in the PMU during this assessment is as shown in Table 4 below: Table 4: Conservation and HCV Areas

# Statement of Land Use (Ha) Year 2016 Year 2017 Hectarage – Ha Hectarage – Ha 1 Planted Area (ha) – Oil Palm 2,427 2,411 - Mature (Production) 2,180 2,009 - Immature (Non-Production) 247 402 2 Conservation Area (ha) - comprising buffer zones along small streams, hilly areas, 8.1 8.1 swampy and unplantable areas 3 HCV Area (ha) - comprising buffer zones near river riparian, forest 0 0 reserves, water catchments, burial & religious sites

1.6 Other certifications held and Use of RSPO Trademarks KLK-Tuan Mee Grouping is also certified to the International Sustainability and Carbon Certification (ISCC). 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” during the assessment.

1.7 Organizational information / Contact Person

At Head Office: Mr. Sin Chuan Eng Sustainability Head Kuala Lumpur Kepong Berhad Wisma Taiko, 1, Jalan S.P. Seenivasagam, 30000 Ipoh, Perak Darul Ridzuan, Malaysia Tel: +605-240 8000, 241 7844 Fax: +605-240 8114 Email: [email protected]

At KLK Tuan Mee Grouping - PMU: Mr. How Yong Chian Palm Oil Mill Manager Kuala Lumpur Kepong Berhad Tel: +603-6038 3245 Fax: +603-6038 4786 Email: [email protected]

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1.8 Tonnages Verified for Certification

1.8.1 The breakdown of all the suppliers and their tonnages of FFB supplied to the POM at Tuan Mee Grouping based on the reporting period for current assessment are as shown in Table 5 below:

Table 5: Tonnages Verified for Certification (Jan to Dec 2017) FFB Processed Main Receiving RSPO P&C # Estate /Supplier (MT) Palm Oil Mill Certification By CB A PMU Estate: 1. Tuan Mee Estate 50,204.12 Tuan Mee Oil Mill Intertek B Other KLK Certified Estates: 1 Sg. Gapi 6,640.89 Tanjung Malim POM CuC 2 Changkat Asa 407.16 Tanjung Malim POM CuC 3 Kombok 1,185.14 Padang POM CuC 4 351.46 Jeram Padang POM CuC 5 Kerling 94.02 Tanjung Malim POM CuC Sub-Total Other certified Estates: 8,678.67 Total Certified: 58,882.79 C External / Other Suppliers: 1 Shalimar (Euro Asia) 4,642.15 2 Berjunrtai (Euro Asia) 5,204.55 3 Sg. Rambai 19,108.53 4 Landtha 14,478.86 5 Poh Lim 709.84 Sub-total from OCP: Non-certified: 44,143.93

1.8.2 Total annual tonnages of FFB supplied from the supply base to Tuan Mee Grouping POM during the previous period, current assessment and projected period are as shown in Table 6 below:

Table 6: Annual Tonnages of FFB FFB Processed in FFB Processed in FFB for Processing Estate / Supplier Year 2016 Year 2017 in Year 2018 - Actual - Actual - Projected MT % MT % MT % Tuan Mee Grouping 43,720.85 63.42 50,204.12 48.73 48,599 50.07 Certified PMUs under KLK Group 7,692.40 11.16 8,678.67 8.42 7,963 8.20 OCP - Uncertified 17,520.04 25.42 44,143.93 42.85 40,500 41.73 Total 68,933.29 100 103,026.72 100.00 97,062 100 SCCS Model for POM MB MB MB

1.8.3 The annual certified tonnages of CPO and PK production by the PMU from the supply base/suppliers as assessed and verified during the current assessment are detailed as shown in Table 7 below:

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Table 7: Annual Certified Tonnages of CPO and PK

Year 2016 Year 2017 Year 2018 POM - Actual - Actual - Projected Total Certified FFB 51,413.25 58,882.79 56,562 Processed (MT)

Total Certified CPO OER: OER: OER: 10,936.17 11,913.71 11,880 Production (MT) 21.27% 20.23% 21.00%

Total Certified PK KER: KER: KER: 2,559.32 2,996.33 2,940 Production (MT) 4.98% 5.09% 5.20%

The POM has established and maintained procedures for the book keeping and monitoring requirements for the CPO at the mill. It is verified the POM has procedures for the “Mass Balance – MB” model in accordance with the RSPO Supply Chain Certification Standards (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 and Multiple Management Units

The Time Bound Plan (TBP) includes the subsidiaries, mills and estates owned by KLK except for the Paloh Palm Oil Mill in Johor and Mill 1 in Sabah. These two mills are excluded from the TBP as they are meant for out growers and smallholders. This exclusion has been communicated to RSPO in year 2015.

All the palm oil mills and estates in Malaysia have been certified. The TBP indicated the status and progress of the palm oil mills and estates in Indonesia, which is monitored by Pak Stephen and reviewed every 3 months with the Sustainability Head based in KLK Office in Ipoh, Perak, Malaysia.

The TBP is achievable, unless otherwise, due to unforeseen circumstances. The various risks that may affect the achievement of the TBP include: • Appointment of certification bodies and their availability. • Uncertainties relating to the Laws and Regulations in Indonesia. • In Indonesia, ISPO precedes other certification standards. • In Indonesia, there are difficulties in the mobilizing internal resources due to its geographical locations. Details of the updated TBP as submitted by KLK and reviewed by Intertek are shown in Appendix E.

KLK had conducted an internal audit on the uncertified units or holdings to determine compliance against Clause 4.5 (Minimum requirements for multiple management units) of the RSPO Certifications Systems for Principles & Criteria (Jun 2017). The Internal audit reports had identified the issues involved, on-going corrective actions and monitoring. The Joint Venture in Liberia does not required internal audit as it is part of EPO, which is a stand-alone entity.

Uncertified Units in Indonesia are: Indonesia - Region Name of POM Name of Estate Kaltim Berau Kebun Malindomas Perkebunan, Kebun Hutan Hijau Mas, Kebun Anugrah Surya Mandiri Riau Nilo 2 Kebun Mutiara Belitung Parit Sembada Kebun Alam Karya Sejahtera Kalteng KMA Kebun Karya Makmur Abadi Kalteng MAP Kebun Mulia Agro Permai Kebun Menteng Jaya Sawit Perdana

The latest TBP dated 06/05/2018 was reviewed and changes were verified during the assessment. In Kaltim region, the Berau POM is targeted to be certified by end 2018. In Riau region, Kebun Mutiara of Nilo 2 POM had been audited in Mar 2018 and awaiting certificate. In Belitung region, Kebun Alam Karya Sejahtera of Parit Sembada POM is targeted to be certified by end 2018. For the Sumatra Utara region, the Gohor Lama and Padang Bharang mills been merged and named as Stabat mill. In Kalteng region, the KMA and MAP mills are targeted to be certified by end 2018.

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1.10 Abbreviations Used

CB Certification Body LTA Lost Time Accidents CHRA Chemical Health & Risk Assessment Intertek Intertek Certification International Sdn Bhd CPO Crude Palm Oil KLK Kuala Lumpur Kepong Berhad CSDS Chemical Safety Data Sheets MSDS Material Safety Data Sheets CSPO Certified Sustainable Palm Oil MTCS Malaysia Timber Certification Scheme CSPK Certified Sustainable Palm Kernel NCR Non-Conformance Report EFB Empty Fruit Bunch NGO Non-Government Organization EHS Environmental Health & Safety OER Oil Extraction Rate EIA Environmental Impact Assessment OHS Occupational Health & Safety Programme for the Endorsement of Forest Effluent Treatment Plant ETP PEFC Certification FFB Fresh Fruit Bunch PK Palm Kernel GAP Good Agriculture Practice PMU Plantation Management Unit HCV High Conservation Values POM Palm Oil Mill IPM Integrated Pest Management POME Palm Oil Mill Effluent ISCC International Sustainability & Carbon Certification PPE Personal Protective Equipment IUCN International Union for Conservation of Nature SCCS Supply Chain Certification Standard KER Kernel Extraction Rate SOP Standard Operating Procedures

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2.0 ASSESSMENT PROCESS

2.1 Assessment Methodology, Plan and Site Visits

Since 04 Apr 2018, Intertek 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 Tuan Mee Grouping regarding the environmental, biodiversity, community development and other relevant issues.

The Assessment team conducted the current assessment on 7, 10–11 May 2018, in which the single estate (viz., Tuan Mee Estate) of Tuan Mee Grouping, as well as the palm oil mill were assessed for compliance against the RSPO requirements. Since there is only one estate in the PMU, there is no sampling of estates and this estate shall be assessed at every assessment.

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 using the process approach auditing technique 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).

Tuan Mee Grouping POM was also assessed against the requirements of 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 the “Mass Balance – MB” Model requirements. These include documented procedure, purchasing and goods in, record keeping, sales and goods out, processing, monitoring and traceability of the CSPO and CSPK quantities, training for staff and claims.

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

After completion of the on-site field assessment, Intertek also performed the evaluation of conformity against the RSPO Certification System requirements for CB. The assessment report, findings and associated documents were evaluated through an independent review by the Intertek Internal Technical Reviewer/Panel (and an External Peer Review in the case of an Initial Assessment or Re-certification Assessment) prior to the approval of this report and decision on continued certification by Intertek.

2.2 Date of next scheduled visit

The next scheduled visit will be the Annual Surveillance Assessment to be carried out within a 12-month period prior to the annual certificate anniversary date.

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 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, KLK and Intertek. E-mails were sent to applicable stakeholders including government agencies, NGOs and local communities. E-mails and telephone enquiries were made prior to the actual assessment and stakeholder’s response and feedback received were followed up accordingly.

During the assessment, stakeholders were interviewed and their feedbacks were recorded. Among the stakeholders consulted were workers, trade union leaders, women representatives; local community leaders, representatives of government departments / agencies, NGOs, suppliers and contractors.

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

Among the list of key stakeholders consulted was the following:

Government Agencies (by emails) 1. Land and Mines Office, Selangor 2. Department of Environment, Selangor 3. Department of Forestry, Selangor 4. Department of Immigration, Selangor 5. Department of Irrigation & Drainage, Selangor 6. Department of Labour, Selangor 7. Department of Occupational Safety & Health, Selangor 8. Department of Wildlife & National Parks, Selangor 9. Pertubuhan Keselamatan Sosial (SOCSO), Selangor

Statutory Bodies (by emails) 10. Malaysian Palm Oil Board (MPOB) 11. Malaysian Palm Oil Board (MPOB) - Central Region 12. Malaysia Palm Oil Association (MPOA) 13. Malaysia Palm Oil Association Kuala Lumpur (MPOA)

NGOs (by emails) 14. All Women’s Action Society (AWAM) 15. BCSDM - Business Council for Sustainable Development in Malaysia 16. Center for Orang Asli Concerns COAC 17. Centre for Environment, Technology and Development, Malaysia - CETDEM 18. Eco Knights 19. ENO Asia Environment 20. Environmental Management and Research Association of Malaysia (ENSEARCH) 21. Environmental Protection Society Malaysia (EPSM) 22. Friends of the Earth, Malaysia 23. Future in Our Hands Society, Malaysia 24. Global Environment Centre 25. Institute of Foresters, Malaysia (IRIM) 26. JUST - International Movement for a Just World 27. Malaysian CropLife & Public Health Association (MCPA) 28. Malaysian Environmental NGOs – MENGO 29. Malaysian National Animal Welfare Foundation – MNAWF 30. Malaysia Nature Society, Selangor 31. Malaysian Plant Protection Society (MAPPS) 32. National Council of Welfare & Social Development Malaysia - NCWSDM 33. National Union of Plantation Workers (NUPW) 34. Partners of Community Organisations (PACOS) 35. Pesticide Action Network Asia and the Pacific (PAN AP) 36. Proforest - South East Asia Regional Office 37. R.E.A.C.H. - Regional Environmental Awareness Cameron Highlands 38. SUARAM - Suara Rakyat Malaysia 39. SUHAKAM - National Human Rights Society - Persatuan Kebangsaan Hak Asasi Manusia 40. Sustainable Development Network Malaysia (SUSDEN) 41. Tenaganita Sdn Bhd

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42. The Malaysian Forum of Environmental Journalist (MFEJ) 43. TRAFFIC Southeast Asia - Wildlife trade & trafficking monitoring programme 44. Transparency International - Malaysian Chapter 45. Treat Every Environment Special Sdn Bhd. (TrEES) 46. United Nations Development Programme - UNDP Malaysia 47. Wetlands International (Malaysia) 48. Wild Asia Sdn Bhd 49. World Wide Fund for Nature (WWF) Malaysia

Local community (On-site interviews) 50. Consultative Committee & Gender representatives 51. Workers & Workers representatives 52. Village Heads & representatives 53. Suppliers & Contractors representatives

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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 The PMU has established and implemented a documented Complied growers and millers provide adequate procedure SOP 1.0 “Stakeholders Engagement/Negotiation” information Issue/Rev 1/0 dated 01/06/2015 that identified the mechanism for upon request for information on Request and Respond, Consultation & Meeting and Complaint & (environmental, social and/or legal) issues relevant to Grievances. RSPO Criteria to relevant Date of public notification of this assessment of the PMU was made stakeholders for effective participation on 04 Apr 2018. in decision making. There were no further request for information/issues from external Minor Compliance stakeholders. 1.1.2 Records of requests for The PMU had established and maintained an updated site specific Complied information and responses shall be maintained. list of internal stakeholders, external stakeholders, government departments/agencies, consultants, contractors, suppliers, Major Compliance transporters, etc.

The POM and estate have conducted their respective internal and external stakeholders’ consultations. Meeting minutes were adequately maintained. The meetings and consultations were noted to be attended by the various categories of stakeholders. Records of participants and feedback given were maintained and appropriate actions taken. 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 Management documents relating to environmental, social and legal Complied that are made available to the issues were verified to be maintained and available to the public. public shall include, but are not necessarily limited to: The following types of mandatory documents are available to the public upon request: Major Compliance  land titles/user rights,

 occupational health and safety plan,  plans and impact assessments relating to environment and social impacts,  pollution prevention plans,  details of complaints & grievances,  negotiation procedures  continuous improvement plan  Public summary of certification assessment report.  Human Rights Policy. These publicly available documents include key indicators of performance like waste management and disposal plans for the mill and estates.

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Also, Continual Improvement Action Plans include targets for waste reduction and pollution prevention.  Land titles/user rights Copies of all land titles were available and have been maintained at Complied (Criterion 2.2); the POM and Estates. HQ kept the original copies.  Occupational health and safety Safety Policy and HIRARC documented for the mill and estates. Complied plans (Criterion 4.7); The HIRAC was also reviewed on 01 Jan 2018. Occupational Safety and Health Plans have been established and documented for the POM and estates. The Plans had been reviewed (annually), up-dated and approved by the respective managers for the mill and estates. The OSH Programme 2018 include the following:  Safety & Health Committee meetings were held quarterly.  Annual medical surveillance,  Accident Reporting & Investigation,  Workplace inspection,  CHRA assessment,  Air compressors annual inspection,  Warning signs,  Chemical Register,  SOP for safe work,  PPE usage,  MSDS/CSDS,  JKKP 8 reporting of accidents annually,  Emergency Response Plan (ERP),  Emergency drills,  Inspections (line site, fire extinguisher, first aid box, chemical store, ELCB, PPE checklist, Vehicle daily inspection, gen set maintenance, ramp inspection, bridge and tanks inspection),  Monthly KPI Report on HSE performance,  Monthly Safety inspection & audit by Safety Officer, CHRA report for POM issued on 22 May 2014 is still valid and recommendations were verified to have been adhered on-site. Next CHRA assessment scheduled for year 2019. Programmes for protecting workers’ health and safety were satisfactorily implemented.  Plans and impact assessments Environmental aspect and impact assessment conducted for the Complied relating to environmental and POM and estate and reviewed on 22 Nov 2017. Management social impacts (Criteria 5.1, Action Plan and Continual Improvement Plan documented and 6.1, 7.1 and 7.8); implemented. Social Impact Assessment was also carried out and suitably reviewed in Mar 2018 by the KLK Sustainability Team together with the respective Mill and Estate Managers. Positive and negative impacts identified. Action plans were documented and implemented.  HCV documentation summary The Assessment report on ‘Internal HCV and Conservation Areas’ Complied (Criteria 5.2 and 7.3); were reviewed on 05 Mar 2017. The Management Action Plans were implemented and monitored at the respective estates.  Pollution prevention and Pollution Prevention Management Plans were reviewed on 22 Nov Complied reduction plans (Criterion 5.6); 2017. Action items include mitigation measures for pollution control (smoke emission, POME / effluent discharge), pesticides reduction, scheduled wastes (chemicals, drums, tyres, used PPE, hydraulic oil) and organic/domestic wastes disposal, reuse and recycling (paper, glass, plastic, scrap iron).

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 Details of complaints and The mill and respective estates had maintained the Complaints and Complied grievances (Criterion 6.3); Grievances Logbook. Logbook entries were examined and found to be in order. Employees Consultative Council (ECC) representatives interviewed had confirmed that there were no serious issues.  Negotiation procedures Presently, there is no conflict/dispute requiring negotiation or Complied (Criterion 6.4); compensation pertaining to this criterion at this PMU. Negotiation procedure was maintained The status on the ongoing negotiations on land issues against KLK Group plantations in Indonesia are detailed in Section 1.9: Time Bound Plan.  Continual improvement plans Continual Improvement Plans in key operations for the mill and Complied (Criterion 8.1); estates have been identified, documented and implemented.

 Public summary of certification Public summary of certification assessment reports are available Complied assessment report; from the company upon request.  Human Rights Policy (Criterion The Human Rights Policy was documented and incorporated as Complied 6.13). part of the Sustainability Policy dated 01 Jun 2015 approved by CEO, Tan Sri Dato’ Seri Lee Oi Hian. Copies of the policy found to be displayed at prominent locations in the POM and estate. Briefing and communication to all levels of the workforce, both administrative and operations departments were provided. Criterion 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 Code of ethical conduct and integrity for mill and estate Complied committing to a code of ethical incorporated as part of the Sustainability Policy dated 01 Jun 2015. conduct and integrity in all operations and transactions, which shall be Copies of the policy were found to be displayed at prominent documented and communicated to all locations in the POM and estate. levels of the workforce and operations. Briefing and communication to all levels of the workforce, both Minor Compliance administrative and operations departments were provided and verified to be recorded and understanding by personnel was confirmed via interviews done at POM & estate during current assessment.

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 SOP 2.0 “List & Summary of Applicable Laws and Regulation” Complied relevant legal requirements shall be established for identification, implementation & compliance and available. review of legal requirements applicable to the company. Major Compliance The company has established a common Legal Register for both mill and estate identifying relevant applicable legal requirements, Licenses, Permits, Certificates and compliances status. Example of the legislations and legal requirements identified in the register as follows: • OSHA and Regulations Act 1994 • Factories and Machinery Act 1967, Regulations 1970 • National Land Code 1965

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• Environmental Quality Act 1974 • Environmental Quality (Scheduled Wastes) Regulations 2005 • Pesticides Act and Regulations Act 149 • Poison Act Regulations 1952 (Act 356) • Industrial Relations Act and Regulation Act 177 • Workmen’s Compensation Act 1952 • Trade Union Act 1959 • Land Acquisition Act 1960 • Sales Tax Act 1972 • MPOB Licence • Diesel and petrol permits • Road Transport Act 1987 (Act 333) • Weight and Measures Act 1972, regulations 16, 28A, 45) The Legal Register covering the applicable local and international laws and regulations is available at the mill and estate and was verified to be reviewed for any relevant updates. Legal compliance checklists used for monitoring the validity and renewal of permit/licenses: Steam engineers (Grade 1 and 2), boilermen and electricians were noted to be with valid certificates from relevant authorities (DOSH and Energy Commission). The POM has maintained a boiler register that indicate the date of commission, cleaned, inspected, tested or repaired. Valid certificates of fitness for boilers, sterilizers, air receivers, thermal deaerator, steam separator, vacuum oil dryer, etc. issued by DOSH. Valid license for diesel generators issued by Energy Commission (“Suruhanjaya Tenaga”). Valid licenses for authorized gas tester (ACT), authorized entrant and standby by person for confined space activities in POM. Occupational Health and Safety Act 1994 – safety and health meetings to be conducted at quarterly intervals. Noise Monitoring Report is available. Legal documents (work permits, passports) of foreign workers in the estates. Insurance coverage is available for foreign workers in the estates. Based on the site observations, interviews and records checked, there was evidence of compliance with the relevant laws, regulations, local and international laws at the POM and estate. There were no cases of any violation or actions imposed by relevant authorities. Statutory returns to relevant authorities found to be in compliance. 2.1.2 A documented system, which The listing of all the relevant laws applicable included the Complied includes written information on legal international laws and conventions ratified by the Malaysian requirements, shall be maintained. government are documented in the Legal Register. Minor Compliance The documented system for identifying, determining, reviewing and updating applicable legal and other requirements has been satisfactorily implemented. 2.1.3 A mechanism for ensuring The mechanism for ensuring compliance involved updating (when Complied compliance shall be implemented. necessary) and an annual review with the compliance status Minor Compliance indicated in the Legal Register was implemented. The PMU had also conducted an internal audit for determining compliance of its operations with legal requirements and records were maintained.

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 17 of 72 Re-certification (Transfer CB)

2.1.4 A system for tracking any Changes and amendment in laws and regulations are monitored Complied changes in the law shall be through the following manner. implemented. • Enquiring the laws books publisher. Minor Compliance • Communication with law/enforcement officers. The PMU subsequently ensured that the changes were adequately updated. Legal Register reviewed on 28/02/2018. Based on the site observations, interviews and records updated, the system used is appropriate to the operations at the PMU. Criterion 2.2 The right to use the land is demonstrated, and is not legitimately contested by local people who can demonstrate that they have legal, customary or user rights. Indicators Findings and Objective Evidence Compliance 2.2.1 Documents showing legal Copies of the land titles of estate were maintained and noted to Complied ownership or lease, history of land tenure (confirmation from community be legally owned by the KLK Group. leaders based on history of customary The original copies are maintained by the Corporate Head Office. land tenure, recognised Native The legal use of the land confirmed to be for the cultivation of oil Customary Right (NCR) land) and the palms and agricultural use. actual legal use of the land shall be There were no recorded or known disputes over the ownership of available. the land. Major Compliance 2.2.2 There is evidence that physical It was verified that there has been no change to the stated land Complied markers are located and visibly maintained along the legal boundaries titles and designated use for cultivation of oil palm and particularly adjacent to state land, agricultural use. NCR land and reserves. Locations of several boundary stones and pole markers were Minor Compliance visited and verified to be within the boundary perimeter of the estates. On-site verification confirmed that there has been no planting beyond the legal demarcated boundary areas of the mill and estates. 2.2.3 Where there are or have been There has been no dispute on the land rights in this PMU. As Complied disputes, additional proof of legal such, the process of fair compensation and FPIC is currently not acquisition of title and evidence that required to be applied. fair compensation has been made to The company has SOP 3.0 “Responsible Development for New previous owners and occupants shall Planting” dated 01/05/2016, which defined the FPIC process for be available, and that these have been acquiring land and disputes management under Attachment 2.0. accepted with free, prior and informed consent (FPIC). Land Acquisition (For OP Planting). Minor Compliance 2.2.4 There shall be an absence of There were no land conflicts in this PMU. Not significant land conflict, unless applicable requirements for acceptable conflict resolution processes (see Criteria 6.3 and 6.4) are implemented and accepted by the parties involved. Major Compliance 2.2.5 For any conflict or dispute over There are no land disputes in the PMU. As such the process of Not the land, the extent of the disputed participatory mapping is not applicable for verification of applicable area shall be mapped out in a implementation. participatory way with involvement of affected parties (including neighbouring communities and relevant authorities where applicable). Minor Compliance 2.2.6 To avoid escalation of conflict, No evidence that the palm oil operations have instigated violence Not there shall be no evidence that palm in maintaining peace and order in their current and planned applicable oil operations have instigated violence operations.

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 18 of 72 Re-certification (Transfer CB)

in maintaining peace and order in their current and planned operations. Major Compliance Criterion 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 The map provided had indicated only the features inside the Major NC# showing the extent of recognised legal, plantation. Information on a wider landscape level including SH-01 customary or user rights (Criteria 2.2, the neighbours and its surroundings were not made known 7.5 and 7.6) shall be developed in the map. through participatory mapping involving affected parties (including The lands at the PMU are legally owned by KLK and no other users neighbouring communities where were identified in the land area. applicable, and relevant authorities). The existing estates are not encumbered by any customary land Major Compliance rights and therefore the process of participatory mapping is not required. 2.3.2 Copies of negotiated agreements The lands at the PMU are legally owned by KLK. Records are Complied detailing the process of free, prior and available to show such land acquisition complied with legal informed consent (FPIC) (Criteria 2.2, requirements without infringement of any legal rights that require 7.5 and 7.6) shall be available and free, prior and informed consent (FPIC). shall include: a) Evidence that a plan has been developed through consultation and discussion with all affected 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 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 All relevant information shall be No cases of land claims in this PMU. Not available in appropriate forms and As such this process is not applicable for verification. applicable languages, including assessments of impacts, proposed benefit sharing, and legal arrangements. Minor Compliance 2.3.4 Evidence shall be available to This process is not applicable during current assessment. Not show that communities are applicable represented through institutions or representatives of their own choosing, including legal counsel.

Major Compliance

Principle 3: Commitment to long-term Economic & Financial Viability Criterion 3.1

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 19 of 72 Re-certification (Transfer CB)

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 Business Plans for 3 years (FY 2017/2018, FY 2018/2019, FY Complied (minimum three years) shall be 2019/2020) for the PMU have been prepared by the Palm Oil Mill documented that includes, where and estates. appropriate, a business case for scheme smallholders. Details of the Business Plans include the following: Major Compliance (1) Staff and Labour requirements; (2) Crop projection; FFB yield/ha trends; (3) Mill extraction rates; OER & KER trends; (4) Cost of Production; Cost/mt FFB trends; (5) Cost of Production; Cost/MT CPO trends; (6) Financial indicators covering cost of labour, supervision, maintenance, depreciation, etc.). (7) Provisions for sustainability efforts and improvement programmes (environmental, social, Occupational Safety & Health, training, etc.). The Mill and Estate Managers monitor the operational performance against Key Performance Indications and targets (costs, FFB yields, quality, productivity, pesticides usage, fertilizers usage, etc.) There is evidence of monitoring of costs against budget to achieve specified targets. Performances are discussed in the monthly meetings held at the PMU and issues and actions needed are recorded for follow up in the next monthly meeting. The records of these meetings were available and verified during the audit. Monthly, quarterly, half-yearly and yearly reports are submitted to the HQ. 3.1.2 An annual replanting programme Annual replanting program for the estate had been prepared for Complied projected for a minimum of five years five years (FY2017/2018 to FY2021/2022). (but longer where necessary to reflect the management of fragile soils, see The replanting areas (ha) are as follows: Criterion 4.3), with yearly review, shall Estate 2017/18 2018/19 2019/20 2020/21 2021/22 be available. Tuan Mee 150 94 136 0 76 Minor Compliance A replanting cycle of 25 years has been adopted by the group.

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 POM has documented the following procedures: (SOPs) for estates and mills shall be 1. SOPs for Palm Oil Mill operations from reception of FFB, documented. Major Compliance Weighbridge, Loading Ramp, Sterilization, Hoisting & Threshing, Empty Bunch Conveyor, Press & Digester, Clarification, Depericaroer Station, Nut & Kernel, Boiler, Engine Room, Raw Water Treatment Plant, Effluent Treatment Plant, Workshop Practices, etc. for the processing until the delivery of processed oil and POME management. nd 2. Laboratory and Milling Control Handbook (2 Revision, 1999), 3. Sustainability Manual & SOPs (01 Jun 2015). 4. Procedures for Safe Work Rev. 1/2017- SOPs for safe working practices for all operations in the POM.

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 20 of 72 Re-certification (Transfer CB)

5. Guidelines for Hazard Identification, Risk Assessment and Risk Control (DOSH) – OSH Hazards & Risk Assessment on mill activities and HIRARC.

6. Supply Chain Procedure SOP 18.0 Issue 3 / Rev. 2 dated 05/05/2018.

An observation raised concerning the SOPs for Palm Oil Mill operations did not have any issue or revision control status Obs # to ensure that the latest version of these procedures are OCL-01 being used.

The estates have the following SOPs: 1. Group SOP for Estate Operations - Good Agricultural Practices (GAP) that incorporated the policy statement, objective and recommended best practices - The GAPs cover harvesting, field upkeep, nutrition, pests and diseases, conservation, by-product, replanting nursery, field identification, roads and drains. 2. Sustainability Manual & Sustainability SOPs (01 Jun 2015). 3. Guidelines for Hazard Identification, Risk Assessment and Risk Control (DOSH) – OSH Hazards & Risk Assessment on estate activities and HIRARC.

Relevant Key Performance Indicators (KPIs) specified for quality, environment, safety and cost control at the POM and estate. 4.1.2 A mechanism to check The implementation of the SOPs was verified to be consistently consistent implementation of performed. procedures shall be in place. Records of implementation were verified which included system Minor Compliance monitoring via internal audits and monitoring of operational activities at the field. Internal audits on the POM and estate conducted by the Sustainability Team on 05/03/2018 and 06/03/2018 respectively. Corrective actions taken on the non-conformances raised and the non-conformances were closed off.

Monitoring (i.e. daily, weekly and monthly) was done by Field Supervisors and Mandores. Records had been kept by the staff concerned for each operation to monitor the procedure and progress of work and these records would be checked by the Assistant Manager and the Manager regularly.

On-site assessment confirmed that the records were satisfactorily maintained. Location: Tuan Mee Palm Oil Mill and Estate There were cases of absconded workers in the estate. Reports were made to the nearest police station and Labour Minor NC# Office in a timely manner. However, the estate management JMD-01 was not able to provide evidence that the Human Resource Department (HRD) at HQ had been informed so that HRD can submit the necessary documents to the Immigration Department in accordance with the SOP. 4.1.3 Records of monitoring and any Records of monitoring and actions taken had been maintained for Complied actions taken shall be maintained and available, as appropriate. more than 12 months at the mill and estates. Minor Compliance Daily Muster chits and briefing records were available at POM and at estate. Actual operational and field activities were verified during on-site audit at the POM and estate.

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 21 of 72 Re-certification (Transfer CB)

Verified that estates monitoring records on spraying, manuring and harvesting operations were maintained and available at the estate. 4.1.4 The mill shall record the origins The mill received FFB from its own estates, diverted FFB from Complied of all third-party sourced Fresh Fruit other KLK certified estates and FFB from out growers. Verified Bunches (FFB). that the records indicated the source origin of FFB. 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 SOPs for GAP as established are maintained and reviewed by the Complied good agriculture practices, as contained in Standard Operating Estate Management. Procedures (SOPs), are followed to Agronomist report dated 22/08/2017 by Agronomist from Applied manage soil fertility to a level that Agricultural Resources. ensures optimal and sustained yield, where possible. Annual fertilizer inputs had been reviewed by the Agronomist and Minor Compliance monitoring records were also reviewed by the respective Estate management. GAP for minimization of soil erosion and maintenance of soil fertility is also maintained via the frond stacking and selective pesticide weeding activities. Soil sampling and leaf sampling records provided guide for the fertilizer application and all recommendations had been properly followed at estate levels. Pesticides spraying records were available and maintained. Samples checked for usage and inventory records for the months between Nov 2017 and Mar 2018. Evidences provided and field audit verified that good agricultural practices were adhered. 4.2.2 Records of fertiliser inputs shall The fertilizer application records at the estate over the past 12 Complied be maintained. Minor Compliance months were checked. The monthly summary of fertilizer applied per hectarage had been verified to be satisfactorily maintained and updated. 4.2.3 There shall be evidence of Leaf sampling and analysis had been carried out annually in Jan- Complied periodic tissue and soil sampling to monitor changes in nutrient status. Mar 2017. Soil sampling and analysis (a 5 year cycle) carried out Minor Compliance in Feb-Mar 2017. The leaf and soil sampling and analysis reports dated 22/08/2017 were sighted. Fertilizer recommendations by the Agronomist for identified estate blocks to sustain the long term soil fertility and nutrient efficiency were satisfactorily followed. 4.2.4 A nutrient recycling strategy shall EFB mulching had been carried out at immature palms and for Complied be in place, and may include use of mature areas along the inter-row. Empty Fruit Bunches (EFB), Palm Oil Records of the quantities of EFB mulching including locations Mill Effluent (POME), and palm applied were maintained at the estate. residues. Minor Compliance No application of POME in the estate. Effluent water discharged at final discharge point. Criteria 4.3 Practices minimise and control erosion and degradation of soils. Indicators Findings and Objective Evidence Compliance 4.3.1 Maps of any fragile/marginal Based on the soil maps and field visit verification dome om-site, Complied soils shall be available. there was no fragile soil or marginal soils on the estate. Major Compliance Soil series were noted as follows: Home and Caledonian Division – Serdang, Bungor, Keledang, Local Alluvium, Batu Lapan.

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 22 of 72 Re-certification (Transfer CB)

Coalfields Division – Serdang, Bungor, Local Alluvium, Sg. Buloh, Batu Lapan, Munchong. Bukit Darah Division – Serdang, Bungor, Local Alluvium, Munchong, Batu Lapan. 4.3.2 A management strategy shall be The PMU has a SOP (Best Management Practices) for erosion Complied in place for plantings on slopes control during replanting or any activities involving earth between 9 and 25 degrees unless disturbance. Steps taken for erosion control are soil stabilization, specified otherwise by the company’s run-off control and sediment trapping to mitigate the disturbed SOP. Minor Compliance earth entering waterways. There was no soil erosion noted during the field visit. No soil erosion encountered at estates audited as leguminous cover crop, macuna bracteata was well established. Planting terraces constructed on land with slope more than 6o. 4.3.3 A road maintenance programme Road maintenance programme and budget allocated for year Complied shall be in place. Minor Compliance 2018 are available at the estate. The programme covers road grading, compacting and patching which were progressively implemented. Estate roads were verified to be in satisfactory condition at the fields visited. 4.3.4 Subsidence of peat soils shall be It was confirmed during on-site assessment that there is no Not minimised and monitored. A Applicable documented water and ground cover presence of any peat soil on the estates. management programme shall be in place. Major Compliance

4.3.5 Drainability assessments where There was no peat soil on the estates as confirmed by auditor’s Not necessary will be conducted prior to Applicable replanting on peat to determine the on-site assessment long-term viability of the necessary drainage for oil palm growing. Minor Compliance

4.3.6 A management strategy shall be Based on the estate soil maps and visit to the estates, there were Complied in place for other fragile and problem soils (e.g. podzols and acid sulphate no other fragile and problematic soils on the estates. soils). 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 There is a generic Water Management Plan (SOP 5.0) management plan shall be in place. documented for the POM and estate that include frequency of Minor Compliance sampling for water analysis at river, final discharge point, tube wells, etc. However, the POM and estate shall establish, Minor NC# document and implement a site specific Water Management OCL-01 Plan that clearly identify the single catchment pond and tube wells (4 nos.) as the water source for the POM and water usage for the line sites. Specific information (such as estimated pond capacity, flow rate of tube wells), issues (supply, usage, shortage, control) and actions have to be included in the plan. Water samples were taken twice a year from the catchment pond and tested for pH, BOD, COD, Suspended Solids, Ammoniacal Nitrogen and Water Quality Index. The water for domestic use to staff and workers’ housing at the estate is from the water treatment plant in the POM that draws water from the catchment pond. Treated water samples taken

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 23 of 72 Re-certification (Transfer CB)

twice a year and tests carried out on parameters (pH, Turbidity, aluminium, free chlorine and E.Coli) to meet the Ministry of Health Specification for Drinking Water. Rainfall data found to be monitored as part of the water management plan. There is no river or waterway passing through the estate. 4.4.2 Protection of water courses and Appropriate buffer zones with signages and markings had been Complied wetlands, including maintaining and maintained along streams passing through the estate. restoring appropriate riparian and other buffer zones (refer to national best practice and national guidelines) shall be demonstrated. Major Compliance

4.4.3 Appropriate treatment of mill Water samples were taken at monthly intervals at the outlet of the Complied effluent to required levels and regular monitoring of discharge quality, shall final discharge at the POM effluent pond. Tests conducted for pH, be in compliance with national BOD, COD, Total Solids, Suspended Solids, Oil & Grease, regulations (Criteria 2.1 and 5.6). Ammoniacal Nitrogen and Total Nitrogen. Analysis results were Minor Compliance noted to be within DOE requirements. BOD level for the period Oct 2016 to Sep 2017 ranged from 41 to 71 ppm (within the DOE limit of 100 ppm). Stack emission monitoring by CEMS – Refer to 5.6.3

4.4.4 Mill water use per tonne of Fresh Water usage in the mill from Oct 2016 to Sep 2017 ranged from Complied Fruit Bunches (FFB) (see Criterion 0.19 to 1.54 m3/tonne FFB. The average usage of 1.36 m3/tonne 5.6) shall be monitored. FFB was noted to be within the industrial norm of 1.2 to 1.5 Minor Compliance m3/tonne FFB. 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 IPM Plan includes the planting of beneficial plants and control of Complied Pest Management (IPM) plans shall damage by pest and plant diseases. be monitored. Major Compliance The estate has a programme for planting of 3 types of beneficial plants for biocontrol, i.e. Cassia cobanensis, Antigonon leptopus and Turnera subulata. Noted that the planting ratio on of 60-20- 20 basis is adhered. Records on areas planted and the planned stretches for planting has been indicated in the estate field map. Barn owl used for the control of rodents (rats). Barn Owl boxes census carried out and location maps available. Rat baiting is appropriately applied according to census results obtained. The pest infestation was minimal on the estate. Verified that presently, there were no cases of infestation by other pests such as bagworms and rhinoceros beetles. 4.5.2 Training of those involved in IPM IPM training conducted by for all those involved in IPM Complied implementation shall be demonstrated. Minor Compliance implementation. Training records for staff and workers on IPM implementation for the past 12 months were available and was verified to be satisfactorily maintained at the estate office. 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 Register of agrochemicals use with written justification is available Complied used shall be demonstrated. The use (SOP 6.0 Appendix 2.0 Issue 1 / Rev 0 dated 01/06/2015).

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 24 of 72 Re-certification (Transfer CB) of selective products that are specific Examples of chemicals used are as follows: to the target pest, weed or disease  Glyphosate isopropyl amine 41% – Supremo and which have minimal effect on non-  Indaziflam 45.5% - Alion target species shall be used where available. Verified that the specific pesticides had been used to deal with Major Compliance the respective target pest, weed or disease. 4.6.2 Records of pesticides use Records of pesticides and their active ingredients used, LD50, Complied (including active ingredients used and their LD50, area treated, amount of area treated, amount of a.i. applied per ha, and number of active ingredients applied per ha and applications have been maintained. number of applications) shall be provided. Major Compliance

4.6.3 Any use of pesticides shall be The KLK Group Policy for the estate to minimize the use of Complied minimised as part of a plan, and in pesticides in accordance with IPM plan is maintained. accordance with Integrated Pest Management (IPM) plans. There shall The pesticide reduction program is monitored on usage per be no prophylactic use of pesticides, hectare basis. except in specific situations identified Todate, there were no prophylactic use of pesticides carried out at in industry’s Best Practice. the estates. Major Compliance

4.6.4 Pesticides that are categorised Since 01/07/2011, no usage of paraquat as stated in KLK Group Complied as World Health Organisation Class Policy. 1A or 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 (there are no contractor’s workers engaged Complied used or applied by persons who have for spraying) have attended training on the safe handling and completed the necessary training and application of pesticides in compliance with Regulation 22 of the shall always be applied in accordance Pesticides Act 1974. with the product label. Appropriate safety and application equipment shall Appropriate safety and application equipment (safety boots, safety be provided and used. helmets, rubber boots, cartridge masks, safety goggles, gloves All precautions attached to the and overalls) have been provided and used by the pesticides products shall be properly observed, operators. applied, and understood by workers (see Criterion 4.7). All precautions attached to the pesticides (MSDS) have been Major Compliance observed, applied and understood by the workers. The estate has adequate facilities for mixing of pesticides and cleaning up after work. There are suitable storage areas for PPE. Programme and training records verified to be satisfactory. The training include spraying technique, precautions and symptoms of toxic reactions such as skin disorders, rashes, mouth and throat pain, breathing difficulties or nail problems. Verified during field inspection and interviews with workers performing spraying and manuring activities at the estate. Portable warning signboards noted to be displayed at areas of spraying activity (5th Schedule).

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

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First Aid Kits found to be available (as per 4th Schedule) at the field blocks during pesticides spraying in the fields. The contents and usage were satisfactorily recorded. 4.6.6 Storage of all pesticides shall be Storage of pesticides found to be kept under lock and key and its Complied according to recognised best use in accordance with the Occupational Safety and Health Laws practices. All pesticide containers shall and Regulation 9 of the Pesticides Act 1974. be properly disposed of and not used for other purposes (see Criterion 5.3). Emergency showers and eye wash are available at the mixing Pesticides shall be stored in area and near the pesticides store in case of accidents and tested accordance to the Occupational Safety to be functional. and Material Safety Data Sheets (MSDS) are available in the store. Health Act 1994 (Act 514) and Regulations and Orders, Pesticides The MSDS are in English and Bahasa Malaysia (understood by Act 1974 (Act 149) and Regulations. the workers). Major Compliance Used chemical containers were either reused as containers for spraying solution. For disposal as scheduled waste, empty pesticide containers are triple rinsed and pierced at the bottom. 4.6.7 Application of pesticides shall be Pesticides had been applied using the Best Management Complied by proven methods that minimise risk Practices that minimize risk and impacts. and impacts. Minor Compliance The pesticide operators found to understand the use of the right nozzle, spray drift, spray quality and run-off. Programme and training records verified to be satisfactory. 4.6.8 Pesticides shall be applied The company has a policy not to carry out any aerial application Complied aerially only where there is documented justification. Communities of pesticides. shall be informed of impending aerial This policy is verified to be adhered at the PMU. pesticide applications with all relevant information within reasonable time prior to application. Major Compliance

4.6.9 Evidence of continual training to The Annual Training Plan includes training on pesticides handling. Complied enhance knowledge and skills of All new pesticides operators were trained before being assigned employees and associated to work with pesticides. In addition, based upon training needs, smallholders on pesticide handling the existing pesticide operators (there are no contractor’s workers shall be demonstrated or made available. (see Criterion 4.8). engaged for spraying) attended continual training to enhance their Minor Compliance knowledge and skills on pesticides handling. Training attendance and records for 2017 for related personnel were verified to be maintained. Information and safety precautions on the pesticides displayed on the notice board and next to the pesticides in the store. 4.6.10 Proper disposal of waste Scheduled waste had been disposed of through Malek Family Complied material, according to procedures that Resources Technology Sdn. Bhd., a licensed contractor approved are fully understood by workers and by DOE. managers shall be demonstrated (see Criterion 5.3). Records of scheduled waste collection at 180 days interval Minor Compliance verified to be satisfactorily maintained. 4.6.11 Specific annual medical Annual medical surveillance in accordance with OSHA USECHH surveillance for pesticide operators, and documented action to treat related 2000 requirements Schedule 1 and 2 for all pesticide operators in all the estates were implemented. health conditions, shall be demonstrated. It was verified that the CHRA report dated Sep 2013 for the estate Major Compliance is within the 5 year validity period and recommendations made

has been satisfactorily followed. Medical surveillance examination carried out for a total of 68 workers (including sprayers) on 21 Mar 2018. Samples of the medical surveillance reports were checked and no abnormalities reported by the Medical Doctor. The medical reports showed that there was no case of low blood cholinesterase levels. An observation raised concerning the list of 68 workers sent for the medical surveillance. The list should identify the Obs#

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

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sprayers and also the medical surveillance reports of the OCL-02 sprayers should be reviewed by a responsible staff to confirm that the sprayers are fit for work with pesticides as declared by the Medical Doctor. It is confirmed by the Estate Manager that any worker with such health condition would be considered as unfit for work with pesticides and re-designated to other types of field work. No such cases are found in the estate as at the date of assessment. Pesticides operators were interviewed during field visits and feedback received that they do not have any symptoms of toxic reactions such as skin disorders, rashes, mouth and throat pain, breathing difficulties or nail problems. Besides the annual medical surveillance, monthly clinical tests (to check lungs gastro intestinal, urinary system, nails, skin, etc.) also carried out by Health Assistant on sprayers and records maintained indicate no cases of toxic reactions. 4.6.12 No work with pesticides shall Verified from records, field inspections and interviews that no Complied be undertaken by pregnant or breast- feeding women. pregnant or breast-feeding woman had been offered or engaged Major Compliance in work involving pesticides handling.

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 Occupational Safety and Health (OSH) plan in compliance with Complied plan shall cover the following: OSH Act and Factory & Machinery Act 1967 was documented and implemented. 4.7.1 An occupational health and OSH Policy found to be clearly displayed at POM and in the safety policy shall be in place. An occupational health and safety plan estate office. Adequate posters, regulations, newsletters were covering all activities shall be prominently displayed on notice boards. Interviewed workers documented and implemented, and its demonstrated awareness towards occupational safety and health. effectiveness monitored. The Safety & Health Officer is in charge of safety and health Major Compliance planning, operation & coordination. Mill & Assistant Mill Managers and Estate Managers / Assistant Estate Managers are also directly involved. Records on training had been verified at the POM and estate. Analysis on the understanding of training by the workers had been verified. 4.7.2 All operations where health and Risk assessment carried out on operations where health and Complied safety is an issue shall be risk safety is an issue in order to determine the significant hazards. assessed, and procedures and actions Significant hazards determined and documented include noise shall be documented and implemented exposure, pesticides/ chemicals exposure, accident, fire. to address the identified issues. All precautions attached to products shall Procedures and actions implemented to mitigate the hazards. be properly observed and applied to Assessment of noise levels in the POM was done on 10/10/2017 the workers. and Consultant Report is available. Work areas identified with Major Compliance high noise levels are the boiler station and engine room where noise level exceeded 85 db. Mill management have taken steps to reduce the noise levels by construction of a room to isolate the gen sets, reducing the exposure time to high noise and mandatory use of both ear plugs and ear mufflers. Annual audiometric test conducted for all mill staff and workers. The latest audiogram was carried out for all 71 POM employees on 10/05/2017. There were 11 employees whose audiometric reports indicated slight hearing impairment and taken measures to reduce noise exposure. There was no case of worker with a significant threshold shift. Baseline audiogram and occupational and medical history records of workers maintained. The employees exposed to high noise levels were interviewed. The workers are aware of the danger of hearing loss due to prolonged

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exposure to high noise. The workers knew about the complaints process and mechanism available. “Permit to work” system applied at the POM. Staff and workers have been trained and certified by NIOSH for gas entrant and stand-by involving work in confined space. Appropriate PPE (safety boots, safety helmets, rubber boots, cartridge masks, safety goggles, gloves, overalls, ear plugs, ear mufflers) verified to be provided to and being used by the workers. Associated training provided to address safety and health issues. Warning signs sighted at high noise areas and ear plugs and ear mufflers to be worn. There are also warning signs to use other PPE such as helmet and safety boots. An audit for determining compliance with the minimum standards had been conducted on all types of PPE used. Adequate fire extinguishers and hose reels found to be located at strategic locations, operational and maintained in good conditions. Location map of fire extinguishers is available. First Aid equipment was available at POM, estates and at worksites. Samples of First Aid box was checked and contents found to be complete and in usable order during field visit. Training for workers in First Aid was carried out in the mill and estates and records maintained. The POM and estates have established their accident reporting KPI and incident monitoring implemented. Yearly reporting of JKKP8 regulations was submitted to JKKP on time, i.e. in January of each year. Supporting documentations and evidences of cases reported are maintained and adequately followed up including status of compensation payments made to victims / workers. The Safety & Health Officer maintains records on the rate of accidents to workmen, trends in rate of accidents, fatalities and non-fatalities captured to prevent mishaps. Verified that additional HIRARC reviews also made by the Safety & Health team upon occurrence of incidences or accidents. 4.7.3 All workers involved in the Training programme planned for year 2018 has included all Complied operation shall be adequately trained in safe working practices (see categories of workers. Criterion 4.8). Adequate and Appropriate trainings on safe working practices are planned for: appropriate protective equipment shall - workers exposed to machinery and high noise levels, be available to all workers at the place - workers working in confined space, of work to cover all potentially - harvesters and loaders, hazardous operations, such as - pesticides operators and manurers. pesticide application, machine operations, and land preparation, Records of the trainings conducted in year 2017 are available and harvesting and, if it is used, burning. trainings held included firefighting, fire drill, first aid training, Major Compliance Emergency Response Team training and SOP training for sprayers, manurers, harvesters, loaders, tractor drivers, contractors and contractors’ workers (for FFB transportation). The above trainings were conducted and records were maintained. Evaluations were carried out on each of the trainings to determine its effectiveness. 4.7.4 The responsible person/persons The responsible person (usually the Mandore or Headperson) had Complied shall be identified. There shall be been identified. Records of regular meetings between the records of regular meetings between responsible person and workers to discuss about health and the responsible person/s and workers. safety had been verified to be satisfactory. Understanding of the Concerns of all parties about health, safety and welfare shall be discussed safety and health requirements was also verified during interviews at these meetings, and any issues at field visit with the respective mandores available on duty. raised shall be recorded.

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Major Compliance

4.7.5 Accident and emergency Accident and emergency procedures had been written in English Complied procedures shall exist and instructions and Bahasa Malaysia and briefed to staff, workers, contractors shall be clearly understood by all and visitors. workers. Accident procedures shall be Workers trained in First Aid were present in the mill and field available in the appropriate language of the workforce. Assigned operatives operations. First Aid Kits are kept unlocked for emergency use. trained in First Aid should be present First Aid Kits were available at worksites and contents were in both field and other operations, and checked to be sufficient. Records on all accidents had been first aid equipment shall be available verified to be maintained satisfactorily. at worksites. Records of all accidents Quarterly review on accident cases had been carried out during shall be kept and periodically quarterly meeting of Safety, & Health Committee. Records on the reviewed. status of follow up done were updated. Minor Compliance

4.7.6 All workers shall be provided Medical care had been provided to all the workers. Complied with medical care, and covered by accident insurance. Local workers are covered by SOCSO, whereas foreign workers Minor Compliance are covered by Foreign Workers Compensation Scheme with insurance company. 4.7.7 Occupational injuries shall be Records on Lost Time Accident (LTA) metrics for 2017 was Complied recorded using Lost Time Accident (LTA) metrics. verified to be satisfactorily maintained. Minor Compliance No cases of incidences and accidents for year 2017 as reported in the JKKP8 submitted to DOSH. 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 Training on RSPO P&C and RSPO Supply Chain were conducted Complied shall be in place that covers all aspects of the RSPO Principles and on 24/04/2018 and 16/01/2018 respectively. Interviews confirmed Criteria, and that includes regular the satisfactory level of understanding on the requirements. assessments of training needs and Training for various categories of operators, including all field and documentation of the programme. office staff, with regards to their duties and training needs had Major Compliance been reviewed on annual basis and appropriate training including

‘on-job’ training / supervision and briefings were satisfactorily documented. This was further confirmed during interviews done with sampled workers at the POM and estate. 4.8.2 Records of training for each Records of training provided for each employee, including new Complied employee shall be maintained. Minor Compliance employees were available and found to be satisfactorily maintained.

Principle 5: Environmental responsibility and conservation of natural resources and biodiversity Criteria 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 The Environmental Aspect and Impacts Assessment were Complied assessment (EIA) shall be conducted and well documented. For both the POM and estate, it documented. was reviewed on 22 Nov 2017. The scope of assessment had included the management of mill effluents, management of pests Major Compliance and disease palms (IPM), maintenance of roads, drainage system fertilizing, spraying, transportation of FFB, schedule waste and garbage disposal, accordingly to the local requirements. The report had also included the action plans and recommendations to mitigate the negative effects and to promote the positive ones. The assessment had also included the relevant stakeholder to

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identify impacts and develop the mitigation measures such as relevant conservation activities applicable to the mill and estates. 5.1.2 Where the identification of The environmental management plan is in place and documented. Complied impacts requires changes in current This includes the potential impacts and measures to mitigate the practices, in order to mitigate negative negative impacts. The identification of responsible person was effects, a timetable for change shall be also included. developed and implemented within a The environmental management plan is being implemented comprehensive action plan. The action satisfactorily and effectively. plan shall identify the responsible person/persons.

Minor Compliance 5.1.3 This plan shall incorporate a The monitoring of the documented environmental improvement monitoring protocol, adaptive to plans is ongoing. operational changes, which shall be Implementation and monitoring of the documented environmental implemented to monitor the improvement plans was reviewed on Jan 2018. The review has effectiveness of the mitigation taken into consideration the mitigation of negative impacts and measures. The plan shall be reviewed promotion of positive ones. as a minimum every two years to At the POM, the POME, ash and EFB is being delivered/recycle to reflect the results of monitoring and the plantation for fertiliser and moisture retention purposes. where there are operational changes Record on the delivery and usage of POME and EFB was made that may have positive and negative available during the audit. environmental impacts. At the various divisions (Home Division, Jeram Division, Bukit Minor Compliance Darah Division, Coalfield Division) of the estate visited, it was found that the disposal of plantation waste materials was properly monitored and recorded. The waste materials (mostly fertilizer bags and plastics) were recycled and recorded in a register book. Stacking of fronts was also done effectively. Monitoring and implementation of the environmental improvement plan were adhered to and found to be effectively implemented. It was observed that signages and the riparian marker along Obs# the management areas, especially, the water catchment area SH-01 were faded and not clearly visible. Criteria 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 in a HCV assessment was conducted in house by the sustainability High Conservation Value (HCV) team and documented in a report dated 28 Jan 2018. There was assessment that includes both the no HCV present inside the estate area. planted area itself and relevant wider The exercise has also taken into consideration all aspects of landscape-level considerations (such environmentally sensitive areas such as pond that is inside the as wildlife corridors). management areas.

Visits to site confirmed that Tuan Mee estate, which is divided into Major Compliance Home Division, Jeram Division, Bukit Darah Division and Coalfield Division are all surrounded by palm oil estates, belonging to either companies or smallholders. Environmentally sensitive areas present in the estate had been identified and being monitored. Perimeter boundaries bordering the estates with other lands were well demarcated with markers. Trenches were also dug to clearly demarcate the perimeter boundary of the estate. At some instances, estate roads also serves as perimeter boundary. Refer to However, some details were missing in the map provided as Major NC# it concentrates only on the inside of the plantation. There SH-01 under

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was no mention or indication on its surrounding neighbours. Indicator Map does not present the landscape level of the situation. 2.3.1

5.2.2 Where rare, threatened or Record showed no presence of the HCV/RTE within their Complied endangered (RTE) species, or HCVs, plantation boundary. However, occurrence of RTE, if any, will be are present or are affected by recorded. Nevertheless, a monitoring plan is in place and plantation or mill operations, measures being taken to maintain/enhance the surrounding appropriate measures that are management area. The measures were actively implemented and expected to maintain and/or enhance on-going monitoring being done. them shall be implemented through an Regular patrols within the mill and estates were being carried out action plan. and findings recorded by the Estate executives to monitor the management areas. Major Compliance Monitoring and control of any illegal hunting, fishing or collecting activities was also implemented. Also, signage that prohibit hunting, fishing and water polluting activities were verified on-site, found to have been satisfactorily maintained. 5.2.3 There shall be a programme to Program to educate the workforce about the status of RTE is in Complied regularly educate the workforce about place. the status of these RTE species, and The training program on the awareness of this subject matter was appropriate disciplinary measures conducted and extended to include officials and workers of the shall be instituted in accordance with estate. Training has been conducted on 24 May 2017 and also company rules and national law if any on 4 May 2018. Record on the training program was made individual working for the company is available during the audit. found to capture, harm, collect or kill There was also evidence of commitment to discourage any illegal these species. or inappropriate hunting, fishing or collecting activities via the

signage erected around the affected areas which prohibit such Minor Compliance activities. 5.2.4 Where an action plan has been The status of HCV and RTE species that are affected by Complied created there shall be ongoing plantation or mill operations was documented and reported; monitoring: Management plans were established and on-going monitoring • The status of HCV and RTE species was done by the Estate manager. that are affected by plantation or mill The overall management and status of HCV/RTE at the Tuan Mee operations shall be documented and estate were reviewed and monitored and is on-going. reported; • Outcomes of monitoring shall be fed Verification made during on-site assessment found it to be back into the action plan. effectively implemented.

Minor Compliance 5.2.5 Where HCV set-asides with It was verified that there has been no instance of HCV set-aside Complied existing rights of local communities that conflicts with the rights of local communities at the Tuan Mee have been identified, there shall be evidence of a negotiated agreement estate and mill. that optimally safeguards both the HCVs and these rights.

Minor Compliance Criteria 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 sources All waste products and sources of pollution were identified and Complied of pollution shall be identified and documented. documented. The documentation and identification of all the waste products such as scheduled waste, domestic waste, clinical waste and Major Compliance recyclable waste such as metal, plastic, mill waste and polluting materials, e g. EFB, POME, Stack emissions and Boiler ashes were maintained and monitored at the mill.

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Scheduled Waste identified included spent hydraulic oil (SW 305), spent lubricant oil (SW 306), used chemical containers/drums (SW 409), used filters (SW 410), clinical waste (SW 404) and used batteries (SW 102). Records on the usage and disposal were well recorded and documented. Segregation of wastes i.e. general wastes and scheduled wastes was verified to be satisfactory carried out in estate and mill. Proper storage areas were identified for the storage of the recyclable wastes at the estate and mill. 5.3.2 All chemicals and their At the mill, the disposal of used chemicals and containers were Complied containers shall be disposed of done in accordance with their schedule on waste management as responsibly. planned. Stores for scheduled waste were inspected and audited at site i.e. Major Compliance mill, and disposal was done by scheduled waste disposal company authorized and licensed by Department of Environment. The mill has a proper Scheduled Waste Store for storing scheduled waste until time of disposal by DOE authorized waste disposal contractor. An inventory on all the chemical and containers used was available and up to date. 5.3.3 A waste management and The waste management and disposal plan were in place at both Complied disposal plan to avoid or reduce the mill and estate. It has been documented and implemented as pollution shall be documented and required and is being carried out responsibly. implemented. Segregation of wastes, i.e. general wastes and scheduled wastes was verified to be satisfactory carried out. Proper storage areas Minor Compliance were identified for the storage of the recyclable wastes at the estates and mill. Appropriate secondary containment for the diesel skid tanks, chemical and scheduled waste storage areas was verified to be maintained at the mill. Scheduled waste disposal was done by an appointed contractor that is licensed by the Department of Environment. Latest disposal consignment was on the 23 Dec 2017 by Malek Family Resources Technology Sdn Bhd. The solid waste management and disposal plan using landfills was available at the estate. The landfill, managed by the Local Authority (government) is used mainly for disposal of household / line site waste. Recycling of crop residues / biomass i.e. EFB and POME had been implemented. Management of EFB application plans and progress reports were verified to be satisfactory. Recycling bins of three different colour codes for specific recycle waste were available in the mill and estate. Criteria 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 efficiency of Monthly record on energy consumption for both renewable and Complied the use of fossil fuels and to optimise non-renewable sources were kept and documented. It is renewable energy shall be in place monitored to optimise use of renewable energy. Data is being and monitored. compiled for comparison and control for future improvement. Visit to the mill showed evident that they are compiling the data, Minor Compliance document it for further action to improve on their efficiency of using the renewable and non-renewable energy. At the mill, the monthly record was tabulated to show/record the amount of FFB processed, CPO produced, palm kernel produced, the usage of

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water, diesel usage, electrical power usage, fiber & shell usage and also the B.O.D level of the effluent discharge. Apart from using diesel, electricity generation was through steam turbine and boiler where Palm fiber and PK shells were used as renewable energy/fuel. At the estate, diesel consumption was also monitored on a monthly basis. It was verified that energy usage are being monitored especially at the mill for better control and comparison of trends. Criteria 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 Tuan Mee estate had observed the policy of ‘Zero open burning’ Complied preparation by burning, other than in for any replanting, if any, at the estate. specific situations as identified in the Field inspections made at the estate, showed no evidence of open ‘Guidelines for the Implementation of burning. the ASEAN Policy on Zero Burning’

2003, or comparable guidelines in other regions.

Major Compliance 5.5.2 Where fire has been used for The estate adhered to the ‘zero burning ‘policy for replanting at Complied preparing land for replanting, there the estates. The old trees were chopped and left to rot at site. shall be evidence of prior approval of the controlled burning as specified in Also, there was no evidence of any burning of domestic waste at ‘Guidelines for the Implementation of the housing line. Sanitary landfill was only available at Jeram the ASEAN Policy on Zero Burning’ Division and the area, and the area is managed by the locality, 2003, or comparable guidelines in gazetted by the government. other regions.

Minor Compliance Criteria 5.6 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 polluting Assessment on all polluting activities including gaseous Complied activities shall be conducted, including emissions, particulate and effluent has been made and gaseous emissions, particulate/soot documented. emissions and effluent (see Criterion Monitoring of mill gas emissions is being done online using the 4.4). Continuous Emissions Monitoring System (CEMS) and supported by the Ringelmann Smoke Chart. Report showed evident that the Major Compliance emission is within the permissible limits of DOE as verified by documents made available during the on-site visit to the mill. POME treatment, monitoring and land application is monitored, maintained and adhered to DOE regulations. Records were made available at both the POM and estate during the audit. 5.6.2 Significant pollutants and Identification of significant pollutants and greenhouse gas (GHG) Complied greenhouse gas (GHG) emissions emissions has been done and documented, e.g. POME, diesel / shall be identified, and plans to reduce fuel, water, chemical and fertilizer. Their usage have been or minimise them implemented. recorded and documented at both the POM and estate.

Fibre and shell are being used as fuel for the boiler, as substitute Major Compliance for energy and as a measure to reduce the use of diesel at the POM. The plan has been implemented but the changes have not been very significant.

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Also at the estates, the use of chemicals is only done when necessary and when there is no other option available. 5.6.3 A monitoring system shall be in Monitoring and reporting of the significant pollutants to water, Complied place, with regular reporting on gaseous emissions to air and contamination on land are in place. progress for these significant Tools and systems used include the DOE online CEMS pollutants and emissions from estate monitoring for air emissions, supported by the Ringelmann Smoke and mill operations, using appropriate Chart, boiler stack monitoring done once every 4 months (latest tools. report dated 17 Oct 2017). The schedule waste disposal (latest dated 19 Mar 2018) were adhering to DOE requirements. Minor Compliance Water quality at discharge points was also monitored as per DID regulations, Raw/waste water was analysed quarterly while the treated water being analysed twice yearly and complied with the requirements. Water samples at the final discharge point were regularly taken and tested by mill environment officer in charge and analyzed monthly to ensure compliance to DOE requirements at final discharge points. The water samples were sent for analysis. This analysis was conducted by Organo (Asia) Sdn Bhd. Records are maintained and verified on-site the B.O.D to have met the permissible regulatory limits. Palm GHG summary report has also been documented for tabulated for financial year period (Oct 2016 – Sep 2017) using RSPO formula version 3.0.1.

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

Criterion 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 At the PMU, social impact assessment is conducted using various Complied (SIA) including records of meetings methods, i.e. annual internal and external stakeholders meetings, shall be documented. bi-annual generic internal and external surveys as well as topic Major Compliance specific surveys mostly involving the internal stakeholders. Each of this activity is appropriately documented and analysed. For example annual external stakeholders meetings was conducted at the POM on 12 Feb 2018 involving 13 participants. Four comments were received from the participants and actions taken to address the comments were verified to be satisfactory by the auditor. The annual external stakeholders meeting for the estate was conducted on 29 Mar 2018. Latest bi-annual generic survey involving external stakeholders was conducted by the POM on 02 Mar 2018 involving ten participants. Topical surveys were conducted by both the POM and the estate, e.g. at the POM, topical survey on water tank replacement was conducted on 08 Mar 2018 involving 14 respondents. Meanwhile, at the estate, topical surveys on construction of new quarters involving 20 respondents and on oil palm replanting activities involving 23 respondents conducted on 19 Apr 2018. 6.1.2 There shall be evidence that the The group has considered issues of social impact to employees Complied assessment has been done with the and communities affected by their activities. Records of meeting participation of affected parties. with stakeholders indicated discussions held were generally on Major Compliance matters pertaining to access roads and use rights, working conditions, cultural/festival activities, health facilities and other

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community concerns as stated in 6.1.1. In all minutes of stakeholders, women’s committee and trade union representative meetings list of attendance and photos of the session were kept in file showing evidence of participation of affected parties. Through verification of entries made in the stakeholder logbook in POM, the estate and interviews made, it was clear that the workers are well informed of issues related to their rights. 6.1.3 Plans for avoidance or mitigation For each comments received during meetings or surveys Complied of negative impacts and promotion of conducted by the POM and the estate, a time table of activities the positive ones, and monitoring of were developed with time frame on implementation plans and impacts identified, shall be developed persons responsible. Comments received through the meetings, in consultation with the affected stakeholder logbook, etc., were recorded and also indicated with parties, documented and timetabled, status either continuous, completed or pending. including responsibilities for implementation. Major Compliance 6.1.4 The plans shall be reviewed as a The plans are reviewed annually together with affected parties, Complied minimum once every two years and especially the workers, who were consulted during the internal updated as necessary, in those cases stakeholder and trade union representative meetings. where the review has concluded that changes should be made to current practices. There shall be evidence that the review includes the participation of affected parties. Minor Compliance 6.1.5 Particular attention shall be paid There are no smallholder schemes at the PMU. Thus this is not Not to the impacts of smallholder schemes applicable. applicable (where the plantation includes such a scheme). Minor Compliance Criterion 6.2 There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties. Indicators Findings and Objective Evidence Compliance 6.2.1 Consultation and communication KLK Grievance Procedure is available via website links provided Complied procedures shall be documented. below; Major Compliance 1. http://www.klk.com.my/wp- content/uploads/2016/06/GrievanceProcedure.pdf 2. http://www.klk.com.my/sustainability/grievance-procedure/ 3. http://www.klk.com.my/sustainability/egrievance-form/ The PMU has adopted an open and transparent method of communication and consultation when dealing with relevant parties, e.g. its workers, government agencies, contractors, neighbouring plantations by personal invitation to attend the internal and external stakeholders’ meetings as well as surveys on general and specific issues. 6.2.2 A management official Records sighted show evidence of appointed teams headed by Complied responsible for these issues shall be the Managers and assisted by Assistant Managers. e.g. Mr. Mohd nominated. Fariez, Senior Mill Assistant for Tuan Mee POM and Mr. Izzat Minor Compliance Abdullah, Assistant Manager at Tuan Mee Estate. 6.2.3 A list of stakeholders, records of The list of stakeholders, communication and actions taken were Complied all communication, including maintained in file. Consultations with various stakeholders held confirmation of receipt and that effort and meeting minutes have been verified to be satisfactory during are made to ensure understanding by the audit.

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Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 35 of 72 Re-certification (Transfer CB) affected parties, and records of actions taken in response to input from stakeholders, shall be maintained. Minor Compliance Criterion 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 6.3.1 The system, open to all affected Both the POM and estate have established complaints and Complied parties, shall resolve disputes in an grievances procedures and they were all well implemented. effective, timely and appropriate Stakeholder logbooks were sighted in all audited estates and manner, ensuring anonymity of actively used by workers. complainants and whistleblowers, where requested. Timelines for response to complaints and grievances are Major Compliance indicated in the logbook. Generally respond time for minor requests will be within 2-3 days. Stakeholder Logbooks are for complaints which are not private and confidential in nature. For reports which are related to private matters such as sexual harassment reports separate logbooks are prepared. Complainants are given the option whether the make the report personally or through nominated workers’ representatives. It is verified during on-site interviews that there were no incidents of dispute or grievance of a serious nature. 6.3.2 Documentation of both the The PMU have a system for handling compensation claim in an Complied process by which a dispute was effective, timely and appropriate manner. So far there has not resolved and the outcome shall be been any dispute raised which was verified during on-site available. interviews with the workers. Major Compliance Criterion 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, There are borders of KLK Tuan Mee Estate adjacent to villages in Complied customary or user rights, and a the area. However, from the minutes of meeting between external procedure for identifying people stakeholders and the estate management as well as interviews entitled to compensation, shall be in conducted by the auditors throughout the audit period, it was place. concluded that there were no issues related to legal, customary or Major Compliance user rights over the land developed by the estate. 6.4.2 A procedure for calculating and The KLK Group has a procedure for calculating and distributing Complied distributing fair compensation compensation which is available for verification. The procedure is (monetary or otherwise) shall be written in Land acquisition (for OP planting) SOP 3A issue/rev 1/0 established and implemented, dated 01/01/2017. It outlines the procedure for identifying legal, monitored and evaluated in a participatory way, and corrective customary or user rights. The procedures stated that the actions taken as a result of this compensation shall take into account issues such as proof of legal evaluation. This procedure shall take versus communal ownership in ethnic group, communities’ period into account: gender differences in the of residing and origins and gender difference in the ability to claim power to claim rights, ownership and rights. access to land; differences of transmigrants and long-established To date, there has been no dispute by any parties reported at the communities; and differences in ethnic PMU. groups’ proof of legal versus communal ownership of land. Minor Compliance

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6.4.3 The process and outcome of any To date, there has been no dispute by any parties reported. Complied negotiated agreements and Therefore the process and outcome of compensation could not be compensation claims shall be observed. documented, with evidence of the participation of affected parties, and made publicly available. Major Compliance Criterion 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 Offer letters and work contracts for local staff and foreign workers Complied conditions shall be available. were verified. The contracts met the industry minimum standards, Major Compliance including extra pays under the statutory fringe benefits. The pay slips for workers at the estates and mill were verified to contain all necessary information and can easily be understood by the workers, e.g. type and rate of works completed, days offered, days worked, days absent, total deduction, etc. Review of field workers’ pay slips showed that the calculation of pay is clearly itemised, for example, normal working day rate, normal working day overtime rate, rest day work, rest day work overtime, public holiday work, public holiday work overtime, annual leave pay in December, sick leave pay and deductions. 6.5.2 Labour laws, union agreements All employment contracts are in languages understood by the or direct contracts of employment workers, e.g. in Bahasa Indonesia for Indonesian workers, in detailing payments and conditions of Bengali language for Bangladesh workers and in Tamil language employment (e.g. working hours, for Indian workers. Through interviews it was verified that the deductions, overtime, sickness, contracts were clearly understood by the foreign workers when holiday entitlement, maternity leave, they were able to give correct responds on daily minimum rate, reasons for dismissal, period of notice, medical entitlement, public holiday entitlement and pay for work etc.) shall be available in the languages understood by the workers during public holiday, etc. Local workers are covered by NUPW- or explained carefully to them by a MAPA agreement which is written in English. management official. Location: Tuan Mee Estate Major Compliance Although direct contract of employment detailing payments Major NC# and condition of payment is available in the languages JMD-01 understood by the workers including in Bangladeshi language. However, it was found the translation of employment contract in Bangladeshi language does not correspond with the authoritative employment contract in English language. During the audit, workers found to have received below minimum wages are those worked less than offered working days by the POM or the estate mainly due to absenteeism, but there also cases such as long unpaid holidays. All workers at the POM and at the estate, except harvesters, carriers and loaders, are paid based on daily rate. 6.5.3 Growers and millers shall The PMU has provided adequate housing, water supplies, Complied provide adequate housing, water medical, educational and welfare amenities in accordance with supplies, medical, educational and Local - Workers’ Minimum Standard of Housing and Amenities Act welfare amenities to national 1990 to the workers. standards or above, where no such public facilities are available or accessible. Housing, electricity and water supply Minor Compliance The workers are staying in the housing quarters provided by the PMU. No rental charges by the PMU. Maintenance of the houses is the responsibility of the PMU as well. Electricity and water are supplied for 24 hours daily. The housing quarters are inspected

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

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by the Medical Assistant once a week. Fogging for anti-malaria purposes are conducted periodically.

Schools A primary government Tamil based school is located within the boundary of the PMU. The PMU is providing cleaning services for the school including rubbish collection and grass cutting in the surrounding area. There are also other primary government schools located in the vicinity of the PMU for local children from the PMU. School buses are allowed to enter and exit to ferry the school children to and from the schools.

Sundry shops At least three sundry shops available within the boundary of the PMU. From interviews with the workers in PMU it was found that most household sundries, including frozen foodstuffs were available on sale. Fresh food, such as fish, chicken, vegetable and meat are also brought in by fresh food suppliers into the estates in food trucks at least twice a week. Price in the sundry shops are still affordable and appropriate for the location of the group. The prices in the sundry shops were also inspected by relevant authorities. The PMU at the same time is located near to townships such as Sungai Buloh, Ijok and .

Medical clinics The clinic located in Tuan Mee Division is shared with two other divisions, i.e. Bukit Darah and Caledonia. Jeram Division is using a panel clinic due to its considerable distance from the estate clinic. At least thirty one workers are accommodated at Jeram Division. Workers at Coalfield Division is accommodated at Tuan Mee Division thus they are also sharing the use of estate clinic. The estate clinic is managed by an experienced Medical Assistant. Medical services for the PMU is free of charge. Record of visiting Medical Doctor were also sighted. Medical fees for workers sent to local hospital are also covered by the PMU. 6.5.4 Growers and millers shall make The PMU has ensured that the workers have access to adequate, Complied demonstrable efforts to monitor and sufficient and affordable food by providing the workers with local improve workers’ access to adequate, sundry shops within their compounds. sufficient and affordable food. The estate is located near townships such as Sungai Buloh, Ijok Minor Compliance and Puncak Alam as explained above in 6.5.3. Public transport is available for the workers. Criterion 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 The published statements of policy which recognises employee’s Complied languages recognising freedom of freedom of association is established in “KLK Sustainability association shall be available. Policy” dated 01 Jun 2015. It was noted that the policy is Major Compliance available and widely displayed to the public. Under clause 3.2 (v) of the policy it indicates Freedom of Association and Right to Collective Bargaining where workers are allowed to join collective association.

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

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6.6.2 Minutes of meetings with main The PMU allowed the workers to join trade unions and this Complied trade unions or workers evidence through deduction of their wages directly to pay National representatives shall be documented. Union for Plantation Workers [NUPW] and periodic meetings of Minor Compliance NUPW representatives with the PMU management. Latest trade union representative meeting with the management was on 28 Dec 2017 with 7 attendees. NUPW representatives, who received formal invitation to attend NUPW State Committee meeting during working days will be paid at daily rate. Latest invitation received was on 29 Dec 2017 to Mr. V. Singaram and it was verified that in his pay slip, he was considered as working for the whole month. Criterion 6.7 Children are not employed or exploited. Indicators Findings and Objective Evidence Compliance 6.7.1 There shall be documentary The published statements of policy which recognises no child Complied evidence that minimum age labour is established in “KLK Sustainability Policy” dated 01 Jun requirements are met. 2015. Under clause 3.2 (ii) of the policy it indicates that the group Major Compliance and its suppliers/contractors shall not employ or support the use of child labour. During the audit there was no evidence of any child labor being used at the PMU. Inspection of the employment records including site visit to the estates and interviews confirmed that this criterion has been complied with. Criterion 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited. Indicators Findings and Objective Evidence Compliance 6.8.1 A publicly available equal The published statements of policy which recognises employee’s Complied opportunities policy including freedom of association is established in “KLK Sustainability identification of relevant/affected Policy” dated 01 Jun 2015. Under clause 3.2 (ii) of the policy it groups in the local environment shall indicates that the group and its suppliers/contractors shall ensure be documented. equal opportunities in the work place. All decisions shall be made Major Compliance based on business needs, job requirements and individual qualifications and without regard to race, religion or gender. Inspections including interviews in the estate, checking of the employment records including foreign workers, pay slips and deductions of wages (according to law) confirmed that this criterion had been maintained. 6.8.2 Evidence shall be provided that Based on interviews and feedback from the employees, foreign Complied employees and groups including local workers, review of NUPW meeting minutes and Stakeholder communities, women, and migrant Logbooks, it is verified that there has been no issue of workers have not been discriminated discrimination at the PMU. against. Major Compliance 6.8.3 It shall be demonstrated that The PMU demonstrated that staff are hired and promoted based Complied recruitment selection, hiring and on specific criteria. However, promotion to higher position promotion are based on skills, sometime take a longer period mainly due to the position sought capabilities, qualities, and medical is not yet vacant. fitness necessary for the jobs available. For foreign workers, hiring is mainly conducted through Minor Compliance employment agents and handled by the KLK head office in Ipoh. It was verified that there is no discrimination on promotion as both male and female, local and foreign workers have equal opportunity to be promoted.

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

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Criterion 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 The published statements of policy which recognises no tolerance other forms of harassment and on sexual harassment and violence is established in “KLK violence shall be implemented and Sustainability Policy” dated 01 Jun 2015 under clause 3.2 (ix). communicated to all levels of the There are women committees in both the POM and estate workforce. specifically to address areas of concerns to women. These committees headed by the managers and members are Major Compliance representatives from all areas of work. The minutes of meetings were documented and kept. For example, in Tuan Mee Estate, latest women’s committee meeting was conducted on 23 Apr 2018 and in Tuan Mee POM, it was conducted on 24 Apr 2018. The policy statements on prevention of sexual harassment, protection of gender and women reproductive rights were widely available and displayed in local languages and English. Policy to prevent all forms of harassment and violence is available. Harassment report book was sighted and up to the audit date no report receive by the person responsible. However, it was confirmed by the auditor that the person Obs# responsible is not aware of the “personal and confidential” JMD-01 status of the report book. The report book was kept in an open area which is easily accessible to all instead of keeping it in a lock and key location. 6.9.2 A policy to protect the The management of the estate and POM are aware that pregnant Complied reproductive rights of all, especially of and breastfeeding women must be exempted from work women, shall be implemented and associated with potentially hazardous chemicals. However, since communicated to all levels of the there were no child bearing women workers within the group, thus workforce. this policy cannot be verified during the audit.

Major Compliance 6.9.3 A specific grievance mechanism The grievance process flowchart and procedures are displayed in Complied which respects anonymity and the estate and POM offices. The grievance mechanism protects complainants where established at the PMU has been maintained. There are gender requested shall be established, committees specifically to address areas of concern to women. implemented, and communicated to all levels of the workforce. These committees headed by the managers and members are representatives from all areas of work. The minutes of meetings

were documented and kept. Minor Compliance Criterion 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 FFB prices are publicly displayed at the POM based on current Complied Fresh Fruit Bunches (FFB) shall be prices as determined by MPOB. These prices are available publicly available. publicly access at MPOB website. Minor Compliance 6.10.2 Evidence shall be available that Price mechanism is generally understood by the industry players Complied growers/millers have explained FFB as the POM is using FFB prices set by the MPOB. pricing, and pricing mechanisms for FFB and inputs/services shall be documented (where these are under the control of the mill or plantation). Major Compliance 6.10.3 Evidence shall be available that Based on employee contracts and meeting minutes (between the Complied all parties understand the contractual PMU managements and employees) it is evidenced that all

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 40 of 72 Re-certification (Transfer CB) agreements they enter into, and that parties understand the contractual agreements they enter into, contracts are fair, legal and and that contracts are fair, legal and transparent. transparent. Interviews with parties concerned confirmed that business Minor Compliance practices with local businesses are conducted in a fair and transparent manner. Work tenders are open to appropriate parties and reviewed by Tender Committee before approval. The contractors are monitored during work in progress to follow safety requirements. 6.10.4 Agreed payments shall be The PMU has a policy to ensure agreed payments were made in Complied made in a timely manner. a timely manner as per the contracts of agreement made. Minor Compliance Payments are made on time according to common practice of 60- day grace period. Criterion 6.11 Growers and millers contribute to local sustainable development where appropriate. Indicators Findings and Objective Evidence Compliance 6.11.1 Contributions to local Main contribution of the estates to the local development can be Complied development that are based on the demonstrated in the provision of facilities, services and where results of consultation with local feasible, monetary. For examples, in 2017 alone the PMU communities shall be demonstrated. received approximately 40 students from local and international Minor Compliance higher learning institutions for study tours, mainly on the issue of sustainable palm oil practices. Apart from that, the PMU participated in sports event organised by local communities, such as futsal on 23 Apr 2017 organised by the Labour Department. Tuan Mee Estate also provided rubbish collection and grass cutting services to the Tamil school located within its boundary. During the 14th General Election, the PMU management also performed their social responsibility by allowing public access to the voting station in the Tamil school. 6.11.2 Where there are scheme Not applicable. No scheme smallholders are associated with KLK Complied smallholders, there shall be evidence Tuan Mee PMU. that efforts and/or resources have been allocated to improve smallholder productivity Minor Compliance 6.11.2 Where there are scheme Not applicable. No scheme smallholders are associated with KLK Complied smallholders, there shall be evidence Tuan Mee PMU. that efforts and/or resources have been allocated to improve smallholder productivity Minor Compliance Criterion 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 Estate workers are sourced by the KLK appointed agents and Complied forms of forced or trafficked labour are handled via KLK Head Office in Ipoh. used. All procedures of bringing in foreign workers are with the approval Major Compliance from the Immigration Office. Based on records verified and interviews with some of the workers, it is confirmed that there has been no occurrence of forced nor trafficked workers in KLK estates or POMs. In fact, KLK has released the passports back to the workers throughout the group. The workers however were reminded they are responsible if any untoward incidents happened with the passports in their custody. The management on the other hand is still responsible in assisting the workers to monitor the passport

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

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and work permit expiry dates, sending them for FOMEMA test until collecting work permit from the Immigration. 6.12.2 Where applicable, it shall be No issue of contract substitution has been found and this was Complied demonstrated that no contract confirmed through interviews mainly with internal stakeholders. substitution has occurred. Minor Compliance 6.12.3 Where temporary or migrant The policy statement established in “KLK Sustainability Policy” Complied workers are employed, a special dated 01 Jun 2015 under clause 3.2 covers both local and foreign labour policy and procedures shall be workers as its states that “KLK is committed to ensuring that the established and implemented. rights of all employees, including contract, temporary and migrant Major Compliance workers…” Implementation of this policy is evident as explained above, for example, all decisions related to hiring of new workers shall be made based on business needs, job requirements and individual qualifications and without regard to race, religion or gender. Also mentioned above that the equal opportunity policy was adopted and implemented by the PMU and verified to have covered all necessary aspects of including migrant workers related issues. Freedom of association as earlier mentioned permitted not only to the local workers but also to the foreign workers. This policy is communicated to all workers during annual refresher training and to all new intakes. Criterion 6.13 Growers and millers respect human rights. Indicators Findings and Objective Evidence Compliance 6.13.1 A policy to respect human The published statements of policy which recognises human right Complied rights shall be documented and is established in “KLK Sustainability Policy” dated 01 Jun 2015. communicated to all levels of the Under clause 3.1 of the policy it indicates that the group workforce and operations (see Criteria recognises the inherent dignity of the individual and supports the 1.2 and 2.1). Universal Declaration of Human Rights by the United Nations. Major Compliance This policy is communicated to all workers during annual refresher training and to all new intakes. Communication of this policy to external stakeholders is conducted during the external stakeholders meeting.

Principle 7: Responsible development of new plantings Todate the PMU has not carried any new plantings after Nov 2005 which may be applicable under requirements of the RSPO New Planting Procedure.

The requirements of Principle 7 were verified to be ‘Not applicable’ to this PMU during this assessment.

It was verified during current on-site assessment that the PMU has declared and submitted its Land Use Change details for analysis for its plantings since Nov 2005 as per the calculations specified in the RSPO PalmGHG v 3.0.1. The record of submission made to the RSPO Secretariat for the current year was done on 10 Mar 2018.

See Summary of Net GHG Emissions submitted by Tuan Mee POM in the Tables below.

Based on the details provided in the record of submission, it is also verified that there is no potential liability under the RSPO Remediation and Compensation Procedure at this PMU.

SUMMARY OF NET GHG EMISSIONS

All information and data below as submitted by Tuan Mee POM was verified against the retrieved summary report generated through PalmGHG Calculator Version 3.0.1.

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GHG Table 1: Summary of Net GHG Emissions (Oct 2016 - Sep 2017)

Emissions per Product tCO2e/tProduct CPO 0.84 PK 0.84

Production t/yr FFB processed 96033.47 CPO Produced 19506.999

Extraction % OER 20.31 KER 5.02

GHG Table 2: Summary of Net GHG Emissions

Land use ha OP planted area 5147.7 OP planted on peat 0 Conservation (forested) 0 Conservation (non-forested) 0 Total 5147.7

GHG Table 3: Summary of Field Emissions and Sinks

Own Crop Group 3rd Party Total tCO2e tCO2e/ha tCO2e tCO2e/ha tCO2e tCO2e/ha tCO2e tCO2e/ha Emissions 21295.25 8.86 - - - - 21295.25 8.86 Land Conversion 1349.93 0.9 - - - - 1349.93 0.9 *CO2 Emissions 1832.89 0.8 - - - - 1832.89 0.8 from Fertiliser **N2O Emissions 224.01 0.1 - - - - 224.01 0.1 Fuel 0 0 - - - - 0 0 Consumption Peat Oxidation ------Sinks - - - - Crop -20195.81 -8.47 - - - - -20195.81 -8.47 Sequestration Conservation 0 0 - - - - 0 0 Sequestration Total 4506.27 2.19 - - - - 4506.27 2.19

GHG Table 4a: Summary of Mill Emissions and Credits

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tCO2e tCo2e/tFFB Emissions POME 11561.97 0.12 Fuel Consumption 192.65 0 Grid Electricity 407.86 0 Utilisation 0 0 Credits Export of Grid 0 0 Electricity Sales of PKS 0 0 Sales of EFB 0 0 Total 12162.48 0.13

GHG Table 4b: Palm Oil Mill Effluent (POME) Treatment

Divert to compost 0 % Divert to anaerobic digestion 100 %

GHG Table 4c: POME Diverted to Anaerobic Digestion

Divert to anaerobic pond 100 % Divert to methane capture (flaring) 0 % Divert to methane capture (electricity generation) 0 %

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Principle 8: Commitment to continual improvement in key areas of activity

Criteria 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 The POM has identified and implemented the following Complied improvement shall be implemented, Continual Improvement Action Plans for the FY Oct 2017 – Sep based on a consideration of the main 2018: social and environmental impacts and opportunities of the grower/mill, and 1. Reduce GHG emission – service mill vehicles regularly and shall include a range of Indicators maintain boiler efficiency. covered by these Principles and 2. Avoid dengue infection – fogging once every month. Criteria. 3. Reduce usage of diesel by substituting with fibre and shell. As a minimum, these shall include, but 4. Recycling of EFB, ash and decanter cake as fertilizer to the are not necessarily be limited to: estate (field application). • Reduction in use of pesticides(Criterion 4.6); • Environmental impacts (Criteria 4.3, The estates have identified and implemented the following 5.1 and 5.2); Continual Improvement Action Plans for the FY Oct 2017 – Sep • Waste reduction (Criterion 5.3); • Pollution and greenhouse gas (GHG) 2018: emissions (Criteria 5.6 and 7.8); 1. Chemical usage reduction – spraying pump calibration. • Social impacts (Criterion 6.1); 2. GHG Reduction – regular servicing of tractors and briefing on • Encourage optimising the yield of the supply base. energy saving. 3. FFB Yield optimization – EFB mulching and desilting. Major Compliance 4. Waste reduction – Briefing on recycling programme.

Social Continual Improvement Action Plans for the POM and estates include the following: 1. In year 2017 alone the PMU received approximately 40 students from local and international higher learning institutions for study tours mainly on the issue of sustainable palm oil practices. 2. The PMU participated in sports event organised by local communities, such as futsal on 23 Apr 2017 organised by the Labour Department. 3. Tuan Mee Estate also provided rubbish collection and grass cutting services to the Tamil school located within its boundary. 4. During the 14th General Election, the PMU management also performed their social responsibility by allowing public access to the voting station in the Tamil school.

Evidence of results was available for the above continuous improvement action plans.

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

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3.1.1 Supply Chain Certification Standards Findings - on CPO Mill

The Supply Chain module applied at Tuan Mee Grouping POM during this assessment is Model E – CPO Mills: Mass Balance (MB).

Details of findings are as follows:

5. General chain of custody requirements for the supply chain Findings and Compliance Objective Evidence 5.1 Applicability of the general chain of custody requirements for the supply chain 5.1.1 Legal ownership and physical handling of RSPO Certified Sustainable oil palm Yes Complied products at a location under the control of the organization including outsourced contractors. 5.1.2 Trader and/or distributor shall pass on the certification number of the product Not applicable Complied manufacturer and the applicable supply chain model. 5.1.3 Member of the RSPO and shall register on the RSPO IT platform. Yes Complied 5.1.4 Processing aids do not need to be included within an organization’s scope of No processing aids Complied certification. 5.2 Supply chain model 5.2.1 Same supply chain model as its supplier Mass Balance (MB) Complied 5.2.2 Combination of supply chain models Only MB Complied 5.3 Documented procedures 5.3.1 Written procedures and/or work instructions Yes Complied 5.3.2 Internal audit procedure and internal audit conducted to determine compliance. Yes Complied 5.4 Purchasing and goods in 5.4.1 Purchases of RSPO certified oil palm products with all the specified information. Yes Complied 5.4.2 Mechanism for handling non-conforming oil palm products and/or documents. Yes Complied 5.5 Outsourcing activities 5.5.1 Outsourcing of activities Not applicable Complied 5.5.2 Outsourcing within the scope of its RSPO SC certificate Not applicable Complied 5.5.3 Names and contact details of all contractors used for the processing or physical Not applicable Complied handling of RSPO certified oil palm products. 5.5.4 Names and contact details of new contractor used for the processing or physical Not applicable Complied handling of RSPO certified oil palm products. 5.6 Sales and goods out 5.6.1 Sales of RSPO certified oil palm products with all the specified information. Yes Complied 5.7 Registration of transactions 5.7.1 Transaction registered in the RSPO IT platform and confirmed upon receipt. Yes Complied 5.7.2 RSPO IT Platform: Shipping Announcement, Traceability, Confirming Shipping Yes Complied Announcements. 5.8 Training 5.8.1 Training plan on RSPO SC Standards requirements and records of the training. Yes Complied 5.8.2 Appropriate training shall be provided Yes Complied 5.9 Record keeping 5.9.1 Accurate, complete, up-to-date and accessible records and reports maintained. Yes Complied 5.9.2 Retention times for all record and reports. Yes Complied 5.9.3 Volume purchased (input) and claimed (output) over a period of twelve (12) Yes Complied months. 5.10 Conversion factors 5.10.1 Conversion rate shall be applied to provide a reliable estimate for the amount Yes Complied of certified output available from the associated inputs. 5.10.2 Conversion rates shall be periodically updated. Yes Complied 5.11 Claims 5.11.1 Claims shall be in compliance with the RSPO Rules on Market Yes Complied Communications and Claims. 5.12 Complaints 5.12.1. Documented procedures for collecting and resolving stakeholder complaints. Yes Complied 5.13 Management review 5.13.1 Appropriate frequency of management review. Yes Complied

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5.13.2 All the specified inputs for the management review. Yes Complied 5.13.3 All the specified outputs from the management review. Yes Complied

Model E – CPO Mills: Mass Balance (MB) E.1 Definition Indicators Findings and Objective Evidence Compliance E.1.1 The POM processed FFB from its own supply base, diverted FFB Complied Certification for CPO mills is from other certified KLK Groupings estates and FFB from Outside necessary to verify the Crop Producers [see Section 1.3 Description of supply base volumes of certified and (fruit sources)]. The CPO Mill is therefore applying the Mass uncertified FFB entering the Balance (MB) model. mill and sales volume of RSPO certified products. A mill may be taking delivery of FFB from uncertified growers, in addition to those from its own and 3rd party certified supply base. In that scenario, the mill can claim only the volume of oil palm products produced from processing of the certified FFB as MB. E.2 Explanation Indicators Findings and Objective Evidence Compliance E.2.1 The estimated tonnage of CPO and PK products that could Complied The estimated tonnage of CPO potentially be produced by the POM is recorded in this Assessment and PK products that could Report. This figure represents the total volume of certified palm oil potentially be produced by the product (CPO and PK) that the certified mill is allowed to deliver in a certified mill shall be recorded year. The actual tonnage produced has been reported in Section by the CB in the public 1.8.2 Table 6 and Section 1.8.3 Table 7. summary of the P&C certification report. For an independent mill, the estimated tonnage of CPO and PK products shall be recorded in the RSPO IT platform, supply chain certificate and public summary audit report. This figure represents the total volume of certified oil palm product (CPO and PK) that the certified mill is allowed to deliver in a year. The actual tonnage produced shall then be recorded in each subsequent annual surveillance report. E.2.2 The POM meets all registration and reporting requirements for the Complied The mill shall also meet all appropriate supply chain through the RSPO Supply Chain managing registration and reporting organization (RSPO IT platform). requirements for the appropriate supply chain through the RSPO supply chain managing organization (RSPO IT platform).

E.3 Documented procedures E.3.1 A documented Supply Chain Procedure SOP 18.0 Issue 3 / Rev. 2 Complied dated 05/05/2018 has been established and implemented.

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The site shall have written The procedure covered the implementation of all elements of MB procedures and/or work Model that include Organization Chart, Management Functions & instructions to ensure the Job Descriptions, FFB Delivery to mill, CPO/PK Delivery to implementation of all the customer, Record Keeping, Training, Claims. elements specified in these requirements. This shall include at minimum the following: a) Complete and up to date The documented procedure and its implementation confirmed to Complied procedures covering the have complied with all the specified requirements of Mass Balance implementation of all the (MB) Model E that include controlling the FFB receipt, processing, elements in these sales, CPO and PK dispatch, and records keeping. requirements b) The name of the person The POM Mill Manager, Mr. Mr. How Yong Chian has been Complied having overall responsibility for appointed as the person in charge for the overall responsibility and and authority over the authority for implementation and compliance with the documented implementation of these procedure. He is assisted by Assistant Mill Manager, Mr. Dinesh requirements and compliance Kumar. with all applicable He and other relevant staff under his charge demonstrated requirements. This person shall be able to demonstrate competence, skill and knowledge of the RSPO Supply Chain awareness of the site Certification Standard requirements and its implementation. procedures for the Interviews of the relevant staff confirmed their knowledge of the implementation of this RSPO Supply Chain Certification requirements for the respective standard. areas of operations. The Palm Oil Mill Organization Chart and job responsibilities of employees (Mill Manager, Assistant Mill Manager, Mill Engineers, Mill Assistant Engineers, Operations Supervisor, Weighbridge Operator, Laboratory Chemist, FFB Grader and clerks) have been suitably defined in the SOP. E.3.2 The SOP covers the receiving of FFB and verification of documents Complied The site shall have (delivery notes) to determine the origin, quantity and quality of the documented procedures for FFB. All supplies of FFB were subjected to verification of receiving and processing documents and quality checks by weighbridge personnel. The certified and non-certified Weighbridge Ticket for FFB indicated the date, vehicle number, FFBs. estate & field number and weight. Monthly FFB and CPO/PK Report and YTD Report for Jan – Dec 2017 were verified to have complied with requirements of the MB Model whereby the Palm Oil Mill received and processed FFB from its own estate, FFB diverted from other certified KLK Groupings estates and FFB from Outside Crop Producers. E.4 Purchasing and goods in Indicators Findings and Objective Evidence Compliance E.4.1 The Mill had maintained record of tonnages and supply source of Complied The facility shall verify and certified FFB from the respective estates at the weighbridge station, document the volumes of in the dispatch note and weighbridge ticket and these entered into certified and non-certified the computer system. FFBs received. Noted that there are FFB from Outside Crop Producers received and processed by the POM, which are considered as non-certified FFB using the Mass Balance Model. E.4.2 The documented Supply Chain SOP has specified that the Complied The facility shall inform the CB responsible POM personnel shall check production quantity against immediately if there is a the certified amount and notify RSPO, the CB and Sustainability projected overproduction of Department of any projected overproduction of certified tonnage. certified tonnage. So far, there is no projected overproduction.

E.5 Record keeping Indicators Findings and Objective Evidence Compliance E.5.1 The records and reports are available from the computerized Complied system. Also, hard copies of records and reports are properly filed

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a) The site shall record and and readily accessible. Inspection of records and reports at the Mill balance all receipts of RSPO confirmed these were accurate, complete and updated daily. As per certified FFB and deliveries of the SOP, the records and reports are archived and stored in the Mill RSPO certified CPO and PK Office for a minimum period of 5 years. on a real-time basis and / or three-monthly basis. Traceability was verified for the Production Report for Jan – Dec 2017 from the related records (FFB Delivery Note, Weighbridge b) All volumes of palm oil and palm kernel oil that are Ticket, FFB & Truck Daily Summary, Production Report, CPO & PK delivered are deducted from Storage Report, and CPO & PK Delivery Orders. the material accounting system Transaction documents and bookkeeping of CPO and PK are done according to conversion ratios daily and monthly summary report of FFB receipt, FFB processed, stated by RSPO. CPO production, PK production and balance stocks submitted to the c) The site can only deliver Head Office. Mass Balance sales from a The weighbridges at the Mill are duly calibrated and calibration positive stock. Positive stock certificates found to be in order. can include product ordered CPO is delivered to KL-Kepong Oleomas Sdn Bhd at , for delivery within three (3) Palm Oleomas (Rawang) Sdn Bhd at Rawang, Palm Oleomas months. However, a site is () Sdn Bhd at Klang and external buyers. allowed to sell short (i.e. product can be sold before it is There is no Palm Kernel mill for production of PKO at the POM. PK in stock). sold and delivered to external buyers. Deduction and conversion ratios for the volumes of CPO and PK delivered from the Palm Oil Mill have been appropriately done and recorded. All deliveries of the MB sales are from positive stock. The POM had maintained a monthly summary of all receipts of FFB, production tonnage and dispatch of CPO and PK. This inventory is balanced every 3 months.

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 POM has been able to comply with the requirements of the RSPO SCCS under the ‘MB’ Model and is thus eligible for ‘MB’ trading for its palm products for year 2017 and 2018.

3.1.3 Monitoring of Certified Products traded: Trading of the CSPO and CSPK was performed via RSPO PalmTrace by the KLK Group HQ. Based on the records maintained at the POM, the traded volumes relied on internal communications of the trading done by the KLK Group HQ, on the CSPO and CSPK delivered as verified during assessment for Jan – Dec 2017 are as follows:

Details as per RSPO Certification System Document

CPO (MT) PK (MT) Last year's (Projected) – Certified volume 12,599 3,085 (RSPO Certified)

(1) Last year's Actual sold volume 4,178.60 3,030.41 (RSPO Certified) (2) Last year's Actual sold volume 5,568.64 0 *(Other Schemes Certified) (3) Last Year's Actual sold volume 3,030.41 2,166.47 **Conventional Total for Last Year’s volume – Actual (1+2+3) 11,913.71 3,030.41

New (Projected) Certified Volume 11,880 2,940 (RSPO Certified) Notes: * The non PalmTrace volumes under ‘Other Schemes certified’ is basically ISCC. ** Remaining volumes traded are not claimed under ‘Certified’ and traded as ‘Conventional’ volume.

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3.2 Status of Identified Noncompliance and Corrective Actions, Observations and Positive Elements. 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 Observations Follow up status (NCR) (OBS) Surveillance Assessment - 04 2017 0 (0 Major, 0 Minor) 0 None required (by Control Union Certifications) Re-Certification Assessment 2018 4 (2 Major, 2 Minor) 4 Next assessment (Transfer to Intertek)

3.2.1 Year 2017, Surveillance Assessment - 04: 0 NCR (0 Major and 0 Minor)

3.2.2 Year 2017, Surveillance Assessment - 04: 0 Observation

3.2.3 Year 2018, Re-certification / Transfer CB: 2 Major NCRs NCR MYNI Details of NCR Indicator Major 2.3.1 Date issued: 11/05/2018 SH-01 Indicator requirement: Maps of an appropriate scale showing the extent of recognised legal, customary or user rights (Criteria 2.2, 7.5 and 7.6) shall be developed through participatory mapping involving affected parties (including neighbouring communities where applicable, and relevant authorities). Nonconformance: Location: Tuan Mee Palm Oil Mill and Estate The map provided had indicated only the features inside the plantation. Information on a wider landscape level including the neighbours and its surroundings were not made known in the map. Root Cause and Corrective Action: Root Cause: Stakeholders map is available during audit. However, the stakeholders were handwritten instead of printed as electronic format.

Corrective Action: Estate management has indicated the stakeholders and GPS coordinates in electronic format.

Verification (Corrective Action): Off-site verification carried out. The maps in digital format with the necessary details have been submitted for incorporation in the RSPO audit report. The corrective action satisfactorily addressed the non-conformance. NC status verified by auditor: Closed by OCL Date closed: 26/06/2018 Verification (for effectiveness): Next assessment.

NCR MYNI Details of NCR Indicator Major 6.5.2 Date issued: 11/05/2018

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JMD-01 Indicator requirement: Labour laws, union agreements or direct contracts of employment detailing payments and conditions of employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc.) shall be available in the languages understood by the workers or explained carefully to them by a management official. Nonconformance: Location: Tuan Mee Estate Direct contract of employment detailing payments and condition of payment is available in the languages understood by the workers including in Bangladeshi language. However, it was found the translation of employment contract in Bangladeshi language does not correspond with the authoritative employment contract in English language. Root Cause and Corrective Action: Root Cause: All workers had signed the employment contract in both language version. However, estate management had accidentally provide the old version of employment contract for some of the workers.

Corrective Action: Estate management has checked and ensure that the latest version of employment contract is provided and signed by workers. Verification (Corrective Action): Off-site verification carried out. Tuan Mee Estate submitted a revised version of direct employment contract in Bangladeshi language and the submission is sufficient to close the NC. The corrective action satisfactorily addressed the non-conformance. NC status verified by auditor: Closed by JMD & OCL Date closed: 26/06/2018 Verification (for effectiveness): Next assessment.

3.2.4 Year 2018, Re-certification / Transfer CB: 2 Minor NCRs NCR MYNI Details of NCR Indicator Minor 4.4.1 Date issued: 11/05/2018 OCL-01 Indicator requirement: An implemented water management plan shall be in place. Nonconformance: Location: Tuan Mee Palm Oil Mill and Estate There is a generic Water Management Plan (SOP 5.0) documented for the POM and estate that include frequency of sampling for water analysis at river, final discharge point, tube wells, etc. However, the POM and estate shall establish, document and implement a site specific Water Management Plan that clearly identify the single catchment pond and tube wells (4 nos.) as the water source for the POM and water usage for the line sites. Specific information (such as estimated pond capacity, flow rate of tube wells), issues (supply, usage, shortage, control) and actions have to be included in the plan.

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Root Cause and Corrective Action: Root Cause: A generic water management plan available during audit. However, site specific plan was not available.

Corrective Action: A site specific water management plan is prepared by respective management.

Verification (Corrective Action): Off-site verification carried out. Corrective Action Plan (CAP) for preparation of a site specific water management plan with the necessary information and action plans. The implementation of the CAP shall be verified at the next surveillance assessment.

NC status verified by auditor: CAP accepted by Date closed: Next assessment. OCL Verification (for effectiveness): Next assessment.

NCR MYNI Details of NCR Indicator Minor 4.1.2 Date issued: 11/05/2018 JMD-01 Indicator requirement: A mechanism to check consistent implementation of procedures shall be in place. Nonconformance: Location: Tuan Mee Palm Oil Mill and Estate There were cases of absconded workers in the estate. Reports were made to the nearest police station and Labour Office in a timely manner. However, the estate management was not able to provide evidence that the Human Resource Department (HRD) at HQ had been informed so that HRD can submit the necessary documents to the Immigration Department in accordance with the SOP. Root Cause and Corrective Action: Root Cause: Estate management had made police report on the absconded workers and sent all the relevant documents to Human Resource Department (HRD). At the same time, HRD had made the report to Immigration Department as well. However, the evidence of reporting to Immigration Department by HRD was not kept by respective operation centre.

Corrective Action: Estate management has obtained all the evidence of reporting to Immigration Department from Human Resource Department and a copy of notification will be kept by respective operation centre in the future. Verification (Corrective Action): Off-site verification carried out. Corrective Action Plan (CAP) is for the estate to keep a copy of the notification to Immigration Departmen. The implementation of the CAP shall be verified at the next surveillance assessment.

NC status verified by auditor: CAP accepted by Date closed: Next assessment. OCL Verification (for effectiveness): Next assessment.

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3.2.5 Year 2018, Re-certification / Transfer CB: 4 Observations Status MYNI Opened Closed Remark, Ref No: Location Details of Observation Indicator date date if any

OBS# 4.1.1 Tuan Mee The SOPs for Palm Oil Mill 11 May Follow up at OCL-01 POM operations did not have any 2018 next issue or revision control status assessment to ensure that the latest version of these procedures are being used. OBS# 4.6.11 Tuan Mee The list of 68 workers sent for 11 May Follow up at OCL-02 Estate the medical surveillance should 2018 next identify the sprayers and also assessment the medical surveillance reports of the sprayers should be reviewed by a responsible staff to confirm that the sprayers are fit for work with pesticides as declared by the Medical Doctor. OBS# 5.1.3 Tuan Mee It was observed that signages 11 May Follow up at SH-01 Estate and the riparian marker along 2018 next the management areas, assessment especially, the water catchment area were faded and not clearly visible. OBS# 6.9.1 Tuan Mee Policy to prevent all forms of 11 May Follow up at JMD-01 Estate harassment and violence is 2018 next available. Harassment report assessment book was sighted and up to the audit date no report receive by the person responsible. However, it was confirmed by the auditor that the person responsible is not aware of the “personal and confidential” status of the report book. The report book was kept in an open area which is easily accessible to all instead of keeping it in a lock and key location.

3.2.6 Identified Positive Elements

1) The PMU ensured implementation of its policies concerning sustainability and environmental requirements in its operation.

2) The PMU has contributed for social pollution prevention programs and activities.

3) The PMU demonstrated good safety awareness and compliance by its workforce.

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3.3 Summary of Feedback Raised by Stakeholders and Findings

Prior to and during the Assessment, written and verbal feedback communicated from the stakeholders on the environmental and social performance of the PMU operations were sourced. All pertinent feedback issues were reviewed and followed up for verification and these had been accordingly incorporated into the report findings. See table below:

3.3.1 Feedback Raised by Stakeholders (Surveillance Assessment ASA-04 – Year 2017) No issues from internal and external stakeholders arising from previous assessment as reported by previous CB.

3.3.2 Feedback Raised by Stakeholders (Re-certification / Transfer CB – Year 2018) Communication done via email on 04 Apr 2018 to various categories of stakeholders (see list under para 2.5):

Stakeholders’ Feedback PMU Response CB verification / Follow up comments comments (if any) Government Agencies: No feedback received. Ongoing consultations will Verified during on-site Nil be maintained. assessment that no No response needed. response needed. Non-Governmental Organizations: No feedback received. Ongoing consultations will Verified during on-site Nil be maintained. assessment that no No response needed. response needed. Local Communities - Stakeholders’ Consultation: Selected stakeholders representing the complete range of various stakeholder categories were invited for the Stakeholders’ Consultation on 11 May 2018. A total of 4 stakeholders (including transporters and local communities) were present at the consultation. They were interviewed by the auditors without the presence of any of the PMU staff. Concerns and suggestions received during interviews and stakeholder consultations: Ongoing consultations will be maintained. None No response needed. - Local Communities - Interviews: Interviews of sampled staff and workers were also conducted by the auditors during field visits on 07, 10 & 11 May 2018 at the PMU:

Staff/Workers sampling: POM = 18 males, 5 females Estate = 49 males, 12 females SPO Team = 4 males, 1 female

No issues raised by the sampled staff No response needed. No response needed. Nil and workers. Other Interested parties: 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, Kuala Lumpur Kepong Berhad Tuan Mee Grouping had been able to demonstrate its compliance with the RSPO Principles and Criteria (April 2013), Malaysian National Interpretation (MYNI 2014) and the RSPO Supply Chain Certification Standard (Jun 2017) for Palm Oil Mill.

Therefore, it is recommended that the certification of Kuala Lumpur Kepong Berhad Tuan Mee Grouping be approved and continued.

Signed for and on behalf of Intertek Certification International Sdn Bhd

Dr. Ooi Cheng Lee Lead Assessor

Date: 03 Jul 2018

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.

Signed for and on behalf of Kuala Lumpur Kepong Berhad

Ms. Lee Kuan Yee Senior Sustainability Manager (Plantations) Kuala Lumpur Kepong Berhad

Date: 03 Jul 2018

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4.2 INTERTEK- RSPO P&C Certificate details for KLK Tuan Mee Grouping

Certificate No: RSPO 931488 New issue date 10 Sept 2018 Expiry date 09 Sept 2023 Organization Kuala Lumpur Kepong Berhad Address of Head Office: Wisma Taiko, 1, Jalan S.P. Seenivasagam, 30000 Ipoh, Perak Darul Ridzuan, Malaysia RSPO Membership No: 1-0014-04-000-00 Plantation Management Unit: Tuan Mee Grouping Address of POM: Batu 24, Jalan Kuala Selangor-Kepong, 47000 Sg. Buloh, Selangor Darul Ehsan., Malaysia Standards: RSPO Principles and Criteria (Apr 2013); Malaysian National Interpretation (2014); RSPO Supply Chain Certification Standard (Jun 2017) for the Palm Oil Mill. Certification scope: Production of Crude Palm Oil and Palm Kernel Supply Chain module for POM Mass Balance (MB)

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

GPS Reference Certified Name Address Latitude Longitude Area (ha) KLK Tuan Mee Batu 24, Jalan Kuala Selangor- Palm Oil Mill Kepong, 47000 Sg. Buloh, N 3°15’54.2’’ E 101°27’49.5’’ (Capacity: 22 MT/hour) Selangor D.E., Malaysia Batu 24, Jalan Kuala Selangor- 2,678 Tuan Mee Estate Kepong, 47000 Sg. Buloh, N 3°16’07.4’’ E 101°27’20.5’’ Selangor D.E., Malaysia

The annual certified tonnages produced at the PMU are detailed as follows:

Tuan Mee POM Annual Tonnages (MT) Certified FFB 56,562 Certified CPO 11,880 Certified PK 2,940 Supply chain module Mass Balance (MB)

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Appendix A:

Qualifications of Lead Assessor and Assessment Team

Dr. Ooi Cheng Lee (OCL) Lead Assessor / Team Leader / Technical Expert (Palm Oil Mill, Environment, OHSAS, Social, HCV, Land Use and Supply Chain) - PhD in Welding, Cranfield University, UK - M.Sc. (Engineering) in Metallurgy, University of Birmingham, UK - B.App.Sc (Hons), Science University of Malaysia - Diploma in Translation for Science and Technology, Malaysia Translation Society Dr. Ooi Cheng Lee is an IRCA Lead Auditor and Lead Tutor for ISO 9001. He is also involved in auditing in other integrated management systems. He has successfully completed the RSPO Lead Assessor Course for Principles and Criteria (RSPO P&C) and the RSPO Supply Chain Certifications (RSPO SCC). He is currently involved in the management of all types of system and process/product certification in Intertek. He has more than 32 years work experience in product and process specifications, research & development, inspection and testing, quality assurance, engineering development, training, product certification, auditing and quality management system certification. He has conducted assessments of organizations in Malaysia, Singapore, Indonesia, Vietnam, Philippines, China, Myanmar, Cambodia and other regional countries. Assessments include those of rubber and oil palm plantations in Malaysia and Indonesia. His previous position as the General Manager of Lloyd’s Register Quality Assurance (LRQA) Malaysia include the management of all types of systems certification, including that of environmental (ISO 14001), safety & health (OHSAS 18001) and Clean Development Mechanisms (CDM). He is currently the General Manager in Intertek Certification International Sdn. Bhd. He is a member of the Internal Review Panel for RSPO Assessment reports since May 2011. He is part of the RSPO CB Assessment team which audited RSPO certified Plantation Management Units since 2012.

Mr. Sazali Hasni – Assessor / Technical Expert (Environment, Conservation and HCV area) - Bachelor of Science (Forestry) Mr. Sazali Hasni (SH) has over 25 years work experience in the forestry sector. He is an IRCA Auditor for ISO 9001 and auditor for the PEFC Chain-of-Custody Certification. He has successfully completed training in the Intertek In House RSPO P&C, MYNI. He was a member in the stakeholder consultation and development of the Malaysian Criteria & Indicators (MC&I) for Forest management Certification. He has been involved in the auditing of Forest Management Certification for the Perak State Forestry Department and State Forestry Department. He has also been involved with a German based company in testing their criteria for carbon tracing in an oil palm plantation in 2011. He had also acted as the regional consultant to International Tropical Timber Organization (ITTO) for the Asia Pacific region in the Evaluation and Monitoring of Projects funded by the organization from 1994 to 1998. Projects funded are mainly forestry related such as reforestation, conservation, community forestry apart from other research based projects.

Mr. Jumat Majid – Assessor – Social Responsibility and Workers Welfare – BSc (Social Science) Mr Jumat Majid (JM) has over 13 years work experience in the agriculture sector. He has successfully completed the IRCA accredited Lead Auditor course in ISO 9001:2008 and RSPO P&C MY-NI Lead Assessor course. He has also successfully completed training programs in Organic Agriculture Development and had performed organic agriculture inspections and assessments for more than 6 years. He has been involved in NGO work in the areas of social impact assessments within the South East Asia region. He is part of the RSPO CB Assessment team which audited RSPO certified Plantation Management Units since 2010.

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Appendix B: Assessment Plan (Actual)

Date Time Assessors and Assessment Activity (Note 3) Asssessment Team 7 May 7.30 am – Travel to KLK Tuan Mee Palm Oil Mill 2018 8.30 am Monday 9.00 am – Opening Meeting and Briefing at POM Office 9.30 am (to be attended by representatives from the Estates as well) (Day 1) 9.30 am – Document Review and Assessment by all Assessors on respective 1.00 pm RSPO P&C: P1 to P8 at POM OCL SH JMD Site assessment at Site assessment at Site assessment at Palm Oil Mill Palm Oil Mill Palm Oil Mill  P1 Transparency  P2 Laws & regulations  P2 Laws & regulations  P2 Laws & regulations  P5 Environmental,  P6 Employees,  P3 Economic & Conservation & HCV Individuals & Financial Viability  P8 Continual Communities incl.  P4 Best Practices at Mill Improvement Gender Issues  P8 Continual  P8 Continual Improvement Improvement  SCC for POM  Verification of effectiveness of corrective actions for non-conformances  Review of Time Bound Plan  Verification for compliance with rules on Multiple Management Units 1.00 pm – Lunch Break 2.00 pm 2.00 pm - OCL SH JMD 5.30 pm Site assessment at Site assessment at Site assessment at Palm Oil Mill Palm Oil Mill Palm Oil Mill  P1 Transparency  P2 Laws & regulations  P2 Laws & regulations  P2 Laws & regulations  P5 Environmental,  P6 Employees,  P3 Economic & Conservation & HCV Individuals & Financial Viability  P8 Continual Communities incl.  P4 Best Practices at Improvement Gender Issues Estates  P8 Continual  P7 New Plantings Improvement  P8 Continual Improvement 5.30 pm – Travel to Hotel & Break 6.00 pm 6.00 pm – Team Meeting and Discussion 7.00 pm

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Date Time Assessors and Assessment Activity 10 May 8.30 am – OCL SH JMD 2018 12.30pm Site assessment at Tuan Site assessment at Tuan Site assessment at Tuan Thursday Mee Estate Mee Estate Mee Estate  P1 Transparency  P2 Laws & regulations  P2 Laws & regulations (Day 2)  P2 Laws & regulations  P5 Environmental,  P6 Employees, Individuals  P3 Economic & Financial Conservation & HCV & Communities incl. Viability  P8 Continual Gender Issues  P4 Best Practices at Improvement P8 Continual Estates Improvement  P7 New Plantings  P8 Continual Improvement 12.30 pm – Lunch Break 1.30 pm 1.30 pm - Continue site assessment at Site assessment at Tuan Mee Estate 5.30 pm 5.30 pm – Travel to Hotel & Break 6.30 pm 6.30 pm – Team Meeting and Discussion 7.30 pm

Date Time Assessors and Assessment Activity 11 May 8.30 am – OCL SH JMD 2018 11.00 am Site assessment at Mill Stakeholders’ Consultation on the following categories Friday  P1 Transparency (see Notes 1 and 2 below):  P2 Laws & regulations  Contractors (Day 3)  P3 Economic &  Suppliers Financial Viability  Transporters  SCC for POM  NGOs  Government Department / Agencies  Local Community Notes 1. It is mandatory for the PMU to inform Intertek and provide the information (as a minimum the no. of stakeholders in each applicable category and contact number) on the stakeholders prior to the assessment. 2. This will facilitate the random and impartial selection of stakeholders (including independent and organized smallholders, where applicable) and to meet the sample size requirement 11.00 am – Site assessment at POM or estates to follow up on any specific criteria/areas 12.30 pm 12.30 pm – Lunch Break 1.30 pm 1.30 pm – Preparation for Closing Meeting 3.30 pm 3.30 pm – Team Meeting and Discussions with POM Management Representative 4.30 pm 4.30 pm – Closing Meeting & Briefing at Palm Oil Mill Office 5.30 pm 5.30 pm Travel to Kuala Lumpur onwards

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Appendix C-1:

Location Map of KLK Tuan Mee Grouping, Sungai Buloh, Selangor, Malaysia

KLK Tuan Mee Grouping

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Appendix C-2-1: Map of Tuan Mee Estate and POM – Home and Caledonian, Coalfield Division

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Appendix C-2-2: Map of Tuan Mee Estate – Bukit Darah Division

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Appendix C-2-3: Map of Tuan Mee Estate – Jeram Division

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Appendix D:

Photographs of findings at KLK Tuan Mee Grouping

Tuan Mee Estate: Interviewing harvesters Tuan Mee Estate: Interviewing manurers

Tuan Mee Estate: Sprayers with PPE Tuan Mee Estate: Water catchment pond

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Appendix E:

Time Bound Plan Details of Time Bound Plan as submitted by Kuala Lumpur Kepong Berhad (as at 16 May 2018)

No POM ESTATE Location Licenses Planting Year Area (Ha) RSPO Target

1 Palm Oil Mill is expected to commission by Y2020 Only planted Butaw Estate Liberia Leasehold 1,418 Ha since 8,011 BY 2022

Sinoe

County 2012

2

LIBERIA Only planted Palm Bay Estate Liberia Leasehold 6,404 Ha since 13,007 BY 2022

County 2011

Grand Bassa Grand Bassa

TOTAL 21,018

1 Berau Kebun Malindomas Berau, KALTIM HGU & IUP 2006 7,971 Perkebunan

2 Kebun Hutan Hijau Mas Berau, KALTIM HGU & IUP 2006 7,317 BY 2018

3 Kebun Anugrah Surya Berau, KALTIM IL & IUP - 2,682 Mandiri

KALTIM 1 Jabontara Kebun Jabontara Eka Berau, KALTIM HGU & IUP 2007 14,086 CERTIFIED IN NOV Karsa Y2017

INDONESIA 1 Mandau Kebun Mandau* Riau, Sumatera HGU & IUP 14,799 CERTIFIED IN OCT Y2012

2 Nilo 1 Kebun Nilo Timur Riau, Sumatera HGU & IUP 12,860

RIAU, RIAU, CERTIFIED IN MEI Y2014

SUMATERA

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3 Nilo 2 Kebun Nilo Barat Riau, Sumatera HGU & IUP

Kebun Mutiara Riau, Sumatera IL & IUP 2005 1,400 AUDITED IN March Y2018; AWAITING CERTIFICATE 4 Tapung Kanan Kebun Sekarbumi Riau, Sumatera HGU & IUP 6,200 CERTIFIED IN APRIL Alamlestari Y2013

1 Steelindo Wahana Kebun Steelindo Belitung HGU & IUP 14,065 CERTIFIED IN Perkasa Wahana Perkasa JANAURY Y2015

2 Parit Sembada Kebun Parit Sembada Belitung HGU & IUP 3,990 CERTIFIED IN OCTOBER Y2016

BELITUNG Kebun Alam Karya Belitung IL & IUP 2009 2,336 BY 2018 Sejahtera

1 Stabat Kebun Basilam* Langkat, SUMUT IUP & HGU 2001 2,697

Kebun Tanjung Langkat, SUMUT IUP & HGU 2000 3,936 Beringin

Kebun Gohor Lama * Langkat, SUMUT IUP & HGU 1992 3,323

CERTIFIED IN AUGUST Kebun Padang Langkat, SUMUT IUP & HGU 1979 1,949 Y2017 Brahrang

INDONESIA

SUMATERA UTARA SUMATERA Kebun Bukit Lawang Langkat, SUMUT IUP & HGU 1995 1,377

Kebun Tanjung Langkat, SUMUT IUP & HGU 1991 2,407 Keliling*

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Kebun Bekiun Langkat, SUMUT IUP & HGU 1984 2,979

Maryke Langkat, SUMUT IUP & HGU 2007 2,704

1 KMA POM Kebun Karya Makmur Mentaya Hulu, IUP & HGU 2008 9397 Abadi KALTENG BY 2018 Kebun Karya Makmur Bukit Santuai IUP & IL 2008 3406 Abadi KALTENG MAP POM Kebun Mulia Agro Baamang, KALTENG IUP & HGU 2006 9,055 Permai

KALTENG Kebun Menteng Jaya Mentaya Hilir Utara, IL & IUP 2009 5,893 Sawit Perdana KALTENG

TOTAL 136,830

No POM ESTATE Location Licenses Area (Ha) RSPO Target 1 Batu Lintang POM Pelam Estate* Kulim, Kedah Land Title 2,960

2 Batu Lintang Estate* Serdang, Kedah Land Title 1,808

SIA CERTIFIED IN SEPT M 3 Subur Estate Batu Kurau, Perak Land Title 1,290 Y2013

4 Buntar Estate Serdang, Kedah Land Title 899

MALAYSIA

5 Changkat Chermin POM Lekir Estate Manjung, Perak Land Title 3,307 CERTIFIED IN SEPT

PENINSULAR PENINSULAR Y2013

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 67 of 72 Re-certification (Transfer CB)

6 Changkat Chermin Manjung, Perak Land Title 2,530 Estate

7 Raja Hitam Estate Manjung, Perak Land Title 1,497

8 Glenealy Estate* Parit, Perak Land Title 1,059

9 Serapoh Estate* Parit, Perak Land Title 936

10 Kuala Kangsar Estate* Padang Rengas, Perak Land Title 1,340

11 Allagar Estate Trong, Perak Land Title 773

12 Tuan Mee POM Tuan Mee Estate Sg Buloh, Selangor Land Title 2,678 CERTIFIED IN SEPT Y2013

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 68 of 72 Re-certification (Transfer CB)

No POM ESTATE Location Licenses Area (Ha) RSPO Target

13 Tanjong Malim POM Changkat Asa Estate* Tg Malim, Perak Land Title 1,714

14 Kerling Estate* Kerling, Selangor Land Title 619 CERTIFIED IN NOV Y2013

15 Sg Gapi Estate , Selangor Land Title 603

16 Jeram Padang POM Ayer Hitam Estate , Land Title 2,640

17 Batang Jelai Estate* Rompin, Negeri Sembilan Land Title 2,148

18 Jeram Padang* Bahau, Negeri Sembilan Land Title 2,114

19 Kombok Estate* , Negeri Sembilan Land Title 2,331

20 Ulu Pedas Estate* Pedas, Negeri Sembilan Land Title 922 CERTIFIED IN SEPT Y2012 21 Gg Pertanian Estate Simpang Durian, Negeri Sembilan Land Title 686

MALAYSIA

PENINSULAR MSIAPENINSULAR 22 Sg Kawang Estate* Lanchang, Pahang Land Title 1,889

23 Renjok Estate* Telemong, Pahang Land Title 1,578

24 Tuan Estate* Telemong, Pahang Land Title 1,353

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 69 of 72 Re-certification (Transfer CB)

No POM ESTATE Location Licenses Area (Ha) RSPO Target 25 Kuala POM Kerilla Estate* Tanah Merah, Kelantan Land Title 2,176

26 Pasir Gajah Estate Kuala Krai, Kelantan Land Title 2,107 CERTIFIED IN NOV Y2014

27 Sg Sokor Estate* Tanah Merah, Kelantan Land Title 1,603

28 Kekayaan POM Landak Estate Paloh, Johor Land Title 4,451

29 Kekayaan Estate Paloh, Johor Land Title 4,436

IA

S

30 Voules Estate* Tenang, Johor Land Title 2,969

31 Sg Penggeli Estate Bandar Tenggara, Johor Land Title 942

ULAR M ULAR 32 New Pogoh Estate* Tenang, Johor Land Title 1,545

MALAYSIA

PENINS 33 Fraser Estate Kulai, Johor Land Title 1,916 CERTIFIED IN OCT Y2011

34 Paloh Estate Paloh, Johor Land Title 2,029

35 Sg Bekok Estate Bekok, Johor Land Title 625

36 Ban Heng Estate Pagoh, Muar, Johor Land Title 631

37 See Sun Estate Renggam, Johor Land Title 589

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 70 of 72 Re-certification (Transfer CB)

No POM ESTATE Location Licenses Area (Ha) RSPO Target 1 Pinang POM Jatika Estate Tawau, Sabah Land Title 3,508

2 Sigalong Estate Tawau, Sabah Land Title 2,864

CERTIFIED IN MAR Y2009 3 Pangeran Estate Tawau, Sabah Land Title 2,855

4 Pinang Estate Tawau, Sabah Land Title 2,420

5 Mill II Pang Burong Estate Tawau, Sabah Land Title 2,548

6 Sri Kunak Estate Tawau, Sabah Land Title 2,770

CERTIFIED IN MAR Y2009 7 Tundong Estate Tawau, Sabah Land Title 2,155

8 Ringlet Estate Tawau, Sabah Land Title 1,834 SABAH MALAYSIA 9 Bornion POM Bornion Estate Kinabatangan, Sabah Land Title 3,233

10 Segar Usaha Estate Kinabatangan, Sabah Land Title 2,792

11 Lungmanis POM Tungku Estate Lahad Datu, Sabah Land Title 3,418

12 Bukit Tabin Estate Lahad Datu, Sabah Land Title 2,916 CERTIFIED IN JULY Y2010 13 Lungmanis Estate Lahad Datu, Sabah Land Title 1,656

14 Sg Silabukan Estate Lahad Datu, Sabah Land Title 2,654

15 Rimmer Estate Lahad Datu, Sabah Land Title 2,730

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 71 of 72 Re-certification (Transfer CB)

Above marked * is combination of total rubber and palm oil area within stated plantation where the exact certified or under certification of each plantation will be according to the respective public summary report.

Country Region Area (Ha) Peninsular 65,693 Malaysia Sabah 40,353

KALTIM 32,056

Riau 35,259

Indonesia Belitung 20,391

Sumatera Utara 21,372

KALTENG 27,751

Palm Bay 13,007 Liberia Butaw 8,011

GRAND TOTAL 263,893

Remarks:

1. KLK has acquired Selinsing division from Agro Harapan Lestari Sdn. Bhd (formerly known as Good Hope) in November 2016. Titled hectarage of Selinsing Division is 497Ha + 843Ha (Kuala Kangsar Home Division) = 1340Ha

2. KLK has sold 1012Ha to Aura Muhibbah Sdn. Bhd.

3. KLK has sold 32Ha from Allagar Estate and 4Ha from Lekir Estate to .

4. Rimmer POM has been closed due to extensive replanting plan at Lahad Datu Complex.

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD (188296-W)

Report No.: R9314/18-1 Kuala Lumpur Kepong Berhad, Tuan Mee Grouping Page 72 of 72 Re-certification (Transfer CB)

5. Paloh POM has been closed due to low FFB volume.

6. RSPO Compensation Concept Note has been endorsed by RSPO Compensation Panel on 14/2/2018.