SGS RSPO Doc

SGS RSPO Doc. Number: GP 7003A

(Principles & Criteria) Doc. Version date: 01 April 2013 Page: 1 of 65

RSPO PRINCIPLES & CRITERIA CERTIFICATION REPORT

Public Summary Information

Certificate No.: SGS-RSPO/PM-MY15/1751 Project Number: MY03638 26th March 2015 to 25th March Validity Period: 2020 Report Ref. No.: n.a RSPO Membership No.: 1-0086-06-000-00 http://www.gentingplantations. Client Name: Genting Plantations Berhad Website: com/ Scope: Production of 33,713.284 MT of Crude Palm Oil and 9,888.021 MT of Palm Kernel at Genting Ayer Item Oil Mill with a capacity of 60MT/hour using the Mass Balance (MB) Module E.

Type of Certificate INDIVIDUAL Holder: 1 Palm Oil Mill + 3 supply Number of Mill: 1 Number of Sites: base estates

Projected Annual CPO Mill Capacity: 60 TPH & PK Produced (MT): CPO 34,041.813 ( 2015) PK 9,809.076

Address: Head Office Contact Person: 10th Floor, Wisma Genting, Chew Jit Seng Jalan Sultan Ismail, 50250 K.L Street and number: [email protected]

Town/City Mill Address Genting Plantations Berhad State/Country Batu 54, Jalan Johor, Air Hitam, Zip/Postal code 86100 Johor 3rd Floor, Wisma Genting, Country Jalan Sultan Ismail, 50250 K.L Tel: +603-2333 3082 (DL) Fax: +603-2333 6575

Country: Malaysia Plantation Unit Supply Base Name & Address Total Certified Area 8,959.58 Being Evaluated: a. Genting Sri Gading Estate (Ha): b. Genting Sungei Rayat Total FFB Produced 168,148.39 Estate (MT): c. Genting Kulai Besar Estate ( 2013 )

End of Public Summary

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

SGS RSPO Doc. Number: GP 7003A

(Principles & Criteria) Doc. Version date: 01 April 2013 Page: 2 of 65

TABLE OF CONTENTS SUMMARY ...... 3 BASIC EVALUATION INFORMATION ...... 4 List of Abbreviations ...... 5 1. Scope of Certification Assessment ...... 6 1.1 National Interpretation Used ...... 6 1.2 Certification Scope ...... 6 1.3 Location and Maps ...... 6 1.4 Description of Supply Base and Mill Processing Capacity ...... 10 1.5 Date of Planting and Cycle ...... 12 1.6 Other Certification Held ...... 13 1.7 Organizational Information and Contact Person ...... 13 1.8 Time-bound Plan for Other Management Units ...... 13 1.9 Area of Plantation or Plantation Area? ...... Error! Bookmark not defined. 1.10Date Certificate Issued and Scope of Certificate ...... 14 2. Assessment Process ...... 14 2.1 Certification Body ...... 14 2.2 Assessment Methodology, Programme, Site Visits ...... 14 2.3 Qualification of Lead Assessor and Assessment Team...... 16 2.4 Stakeholder Consultation and List of Stakeholders Contacted ...... 17 3. Assessment Findings ...... 18 3.1 Summary of Findings ...... 18 3.2 Corrective Action Request ...... 56 3.3 Noteworthy Positive & Negative Observations ...... 56 3.4 Status of Non-Conformities Previously Identified ...... 56 3.5 Issues Raised by Stakeholders and Findings ...... 56 4. Acknowledgement of Organization’s Internal Responsibility ...... 58 4.1 Date of Next Surveillance Visit ...... 58 4.2 Date of Closing Non-Conformities ...... 58 4.3 Acknowledgement of Internal Responsibility and Formal Sign-off on Assessment Findings ...... 58 APPENDIX A: CORRECTIVE ACTION REQUEST & OBSERVATION ...... 59 APPENDIX B: NON-CONFORMITIES PREVIOUSLY IDENTIFIED ...... 62 APPENDIX C: TIMEBOUND PLAN ...... 63 APPENDIX D: LIST OF STAKEHOLDERS CONTACTED...... 64

LIST OF TABLES Table 1: Mill GPS Location ...... 6 Table 2: Budgeted Yield from Supply Base (Financial Year) ...... 11

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Table 3: Age Profiles for all Supply Base Estates ...... 13 Table 4: Area Statement of the Supplying Estates ...... 14 Table 5: Assessment Program ...... 15 Table 6: Auditors Profile ...... 16

LIST OF FIGURES Figure 1: Map for Genting Sri Gading Estate (Batu Pahat, Johor) ...... 7 Figure 2: Map for Genting Sungei Rayat Estate (Tanjung Division) ...... 8 Figure 3: Map for Genting Sungei Rayat Estate (Bangkar Division) ...... 9 Figure 4: Map for Genting Kulai Besar Estate ...... 10

SUMMARY Genting Plantations Berhad (Genting Plantations)* currently has over 228,382 hectares of plantation land in Malaysia and Indonesia. Since its inception, Genting Plantations (formerly known as Asiatic Development Berhad) has established itself as a reputable and reliable palm oil producer as well as one of the lowest-cost palm oil producers in Malaysia SGS has conducted the main assessment of Genting Ayer Item POM comprising 1 mill and 3 estates. SGS concludes that Genting Ayer Item complies with the requirements of RSPO P&C 2007, Malaysia National Interpretation 2008 and RSPO Supply Chain Standard 2014. A total of 2 majors, 1 minor and 7 observations were raised during the main assessment, SGS recommends approval of Genting Ayer Item Palm Oil Mill and its supply base of 3 plantations as a producer of RSPO certified sustainable palm oil after all the major CARs were successfully closed with objective evidence provided.

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BASIC EVALUATION INFORMATION MAIN EVALUATION Evaluation Dates: 16th – 18th December 2014 Team Leader/Team: James Ong, Faisal and Hoo Boon Han External Peer Reviewed: Please refer to the approval report Date: 25 Mar 15 Report approved by: Haye Semail Date: 26th Mar 2015 Certification approved by: Kenny Looi Date: 26th Mar 2015 Database logged by: Shahziela Othman Date: 26th Mar 2015 SURVEILLANCE 1 Evaluation Dates: Team Leader/Team: Report approved by: Date:

SURVEILLANCE 2 Evaluation Dates: Team Leader/Team: Report approved by: Date:

SURVEILLANCE 3 Evaluation Dates: Team Leader/Team: Report approved by: Date:

SURVEILLANCE 4 Evaluation Dates: Team Leader/Team: Report approved by: Date:

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LIST OF ABBREVIATION

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

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1. SCOPE OF CERTIFICATION ASSESSMENT

1.1 National Interpretation Used The operations of the mill and their supply base of FFBs were assessed against the Roundtable on Sustainable Palm Oil (RSPO), Principles and Criteria (P&C) – Malaysia National Interpretation (MY-NIWG dated 26th April 2008).

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

1.3 Location and Maps Genting Plantation’s Ayer Item Oil Mill is located at the District of Batu Pahat, in the state of Johor, Malaysia. More detailed information on the estates location and layouts is shown in Figures 1, 2 and 3. The GPS locations of the mill and the 3 estates are shown in Table 1. Table 1: Mill and Supply Base GPS Location

Mill/Supply Base Longitude Latitude

Mill Genting Ayer Item Oil Mill E 103o 12’ 38.9” N 1o 51’ 27.5”

1 Genting Sri Gading Estate E 103o 1’ 5.6” N 1o 50’ 17.8”

2 Genting Sungei Rayat Estate E 103o 0’ 38.5” N 1o 54’ 14.5”

3 Genting Kulai Besar Estate E 103o 36’ 39.5” N 1o 36’ 55.3”

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Figure 1: Map for Genting Sri Gading Estate (Batu Pahat, Johor)

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Figure 2: Map for Genting Sungei Rayat Estate (Tanjung Division)

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Figure 3: Map for Genting Sungei Rayat Estate (Bangkar Division)

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Figure 4: Map for Genting Kulai Besar Estate GP 7003A Page 11 of 65

1.4 Description of Supply Base and Mill Processing Capacity The FFBs are sourced from their supply base estates which are directly managed by Genting Plantations Berhad as well as from surrounding independent smallholders. The actual crop yield from each estate is listed in Table 2 below. Table 2: Actual and Budgeted Yield from Supply Base Estates

Estates FFBs Name of Estates Actual (2013) Projected (2015)

GSGE 68,055.50 65,210.00

GSRE 52,802.98 58,240.00

GKBE 47,289.91 43,616.00

Total 168,148.39 167,066.00

Table 3: Area Statement of Plantation (FY 2014)

Plantation area Name of estate Title area Immature Production Conservation HCV *Others (ha) (ha) (ha) GSGE 3,650.48 533.89 2,984.52 7.35 6.00 118.72

GSRE 2376.17 153.96 2178.55 0.50 0.50 42.66

GKBE 2932.93 186.66 2114.76 0 7.50 624.01**

Total 8,959.58 874.51 7,277.83 7.85 14.00 785.39 *Others : Transmission tower, Quarry, Roads, line site, rivers, water catchment area, office building etc. TNB 34.24 Building/Infrastructure 21.00 Highway (Ring Road) 22.84 Quarry Hanson 46.54 Quarry Pati PHSB 38.67 3rd Quarry 38.40 Ex-Mill 7.57 ALD (Asiatic Land Development) 225.13 Water Body 18.78 Steep/Rocky 3.03 Acquired Area (JPO) 90.24 Property Development 24.06 Small holder - Rohaizat Corp 53.51 **624.01

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Table 4: Mill Processing Data (2013)

Mill Production Figures (MT) (Audited Estate) Financial Year (FY 2013 ) CPO Produced PK Produced

GSGE 13,689.841 4,015.196

GSRE 10,608.378 3,111.410

GKBE 9,415.065 2,761.415

Total 33,713.284 9,888.021 From other Genting estates not part of the nil nil Certification Unit Outside Crop 21,371.362 6,268.166 (smallholders etc ) Total 55,084.646 16,156.187

OER: 19.92% KER: 5.84%

Table 5: Projected Mill Processing Data (2015)

Mill Production Figures (MT) Financial Year ( FY 2015 ) CPO Produced PK Produced

GSGE 13,232.102 3,808.744

GSRE 11,735.360 3,388.360

GKBE 9,074.351 2,611.972

Total to claim Certified 34,041.813 9,809.076

OER: 20.15% KER: 5.80% From other Genting estates not part of the 7,254.000 2,088.000 Certification Unit Outside Crop 7,979.400 2,140.200 (smallholders etc ) Total 49,275.213 14,037.276

OER: 20.15% KER: 5.80%

1.5 Date of Planting and Cycle A replanting program is available for all estates involved and being projected for the next five (5) financial years (2014 – 2019). The age profiles for all the estates are summarized ed in Table 5 below. GP 7003A Page 13 of 65

Table 6: Planting Age / Age Profiles for all Supply Base Estates (FY2015)

Planting Age (Ha) Name of Immature Prime 1 Prime 2 Past Prime Due for supplying Total Young >20-25 years replanting estate 1-3 years >7-15 years >15-20 years >3-7 years > 25 years

GSGE 305.36 577.97 784.23 441.8 1,397.40 0 3,506.76

GSRE 12.40 445.89 885.89 511.35 40.32 436.66 2,332.51

GKBE 188.19 258.54 342.92 456.82 215.92 605.57 2,067.96

7,907.23 *For GKBE and GSGE, their planted hectareages were reduced for FY 2015 due to land acquisition by the Group’s Property arm for housing development.

1.6 Other Certifications Held ISCC EU & ISCC PLUS (For Genting Air Item Oil Mill & all 3 supply base estates). ISO QMS 9001:2008, OHSAS 18001:2007, /MS: 1722:2011, ISO EMS 14000:2005 (For Genting Air Item Oil Mill).

1.7 Organizational Information and Contact Person The details of the company’s contact person are as follows:

Name Chew Jit Seng

Vice President Designation Sustainability 3rd Floor, Wisma Genting, Jalan Address Sultan Ismail, 50250 Kuala Lumpur Contact No 03-23333082

Email Address [email protected]

1.8 Time-bound Plan for Other Management Units Genting Plantations Berhad is a member of RSPO since 14 November 2006; the membership number with RSPO is 1-0086-06-000-00. Genting Plantations Berhad* (""Genting Plantations""), is a 54.7%-owned subsidiary of the Genting Group, one of the fastest-growing plantation companies listed on the Main Board of Bursa Malaysia. .* Formerly known as Asiatic Development Berhad Genting Plantations currently has over 228,328 hectares of plantation land in Malaysia and Indonesia. Since its inception, Genting Plantations has established itself as a reputable and reliable palm oil producer as well as one of the lowest-cost palm oil producers in Malaysia Genting Plantations has developed a time-bound plan (Appendix C). Genting Plantations (Ayer Item Mill) will use the experience gained from achieving certification of this first plantation unit (comprising of Ayer Item Oil Mill and its supplying estates ) to implement the RSPO Supply Chain in parallel with the remainder of its operations. GP 7003A Page 14 of 65

The SGS assessment team considers that Genting Plantations is on the right track with a timebound plan which is reasonable and challenging, given the widespread geographic locations of its properties, the resources required and the numbers of smallholders involved.

1.9 Plantation Area The areas of supplying estates for this operating unit are listed in Table 5. Details of production area (mature/immature) are also listed.

Table 7: Area Statement of the Supplying Estates (FY2014)

Estates Area (Ha) Name of supplying estate Immature Mature Area Non-Cultivated Total (Ha)

GSGE 305.36 3,201.40 143.72 3,650.48

GSRE 12.40 2,320.11 43.66 2,376.17

GKBE 173.38 2,037.63 721.92 2,932.93

1.10 Date Certificate Issued and Scope of Certificate The certificate issue date is the date of RSPO approval of this assessment report. This certification scope is: Production of CPO and Palm Kernel at Genting Air Item Oil Mill with capacity of 60MT/hour, in total of CPO is 34,041.813mt/year and PK is 9,809.076mt/year using MB module.

2. ASSESSMENT PROCESS 2.1 Certification Body SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 80,000 employees, SGS operates a network of over 1,650 offices and laboratories around the world. The RSPO Programme is the SGS Group’s RSPO Certification Programme internationally accredited by the RSPO Executive Board to carry out oil palm plantation and supply chain certification/verification and accreditation for global RSPO certification.

2.2 Assessment Methodology, Programme, Site Visits The assessment was conducted between 16th December 2014 – 18th December 2014 and involved an oil mill (Genting Ayer Item Oil Mill) and 3 supplying estates located in the state of Johor, for Genting Plantations.. The audit covers documentation review, internal procedures, management system, field inspection as well as identification of any significant environment and social issues. A sample of stakeholders was consulted during the assessment to get their feedback on the company and its management, if any. . The level of sampling to take place during a certification assessment shall include every mill and be based on a minimum sample of 0.8√y where y is the number of management sub-units. During the site assessment, the sample size of Genting Ayer Item management unit shall be GP 7003A Page 15 of 65

determined by the formula (0.8√3) =1.38 round up = 2. The 2 estates sampled were Genting Sri Gading and Genting Sungei Rayat Estates, besides Genting Ayer Item Palm Oil Mill. The methodology for objective evidence collection included physical site inspection, observation of tasks and processes, interview with workers, families and stakeholders, documentation review and monitoring data. The assessment program is included as shown in Table 6 below.

Table 8: Assessment Program

Date Time Auditor Area / Department / Process / Function Key Contact

15 All Travelling & Meeting up stakeholder (if any) Gwen, Sivaji Dec & Team

Genting Sri Gading Estate (GSGE)

All Gwen, Sivaji 0930  Introduction to the audit by SGS & Team  Briefing by the SGS on the auditing approach  Formulation of audit schedule  Field Visit @ GSGE:  Spraying, Manuring, Worker’s PPE and Mandore’s First Aid Kit, Interview workers  Boundary Stone @ Soga Forest Reserve 16  Riparian Buffer zone Dec  Water management in acid sulphate area  Landfill ( HBH )  Storage Chemical ,POL, fertiliser emergency shower and wash area,  Scheduled Waste and Tripled rinsed empty container storage, Line Site 1230 Lunch 1400 Document Review

1630 Presentation of Findings of Estate 1

0830 All Genting Sungei Rayat Estate ( Bangkar and Tanjung Division ) Gwen, Sivaji  Boundary Stone at Bindu Forest Reserve & Team  Riparian & Bufferzone  IPM Barn Owl, Beneficial plant , EFB  Harvesting, and CDA operator , PPE of 17th workers, first aid kit of mandores. Interview Dec internal and outsource workers on payslip, agreement etc  Replant area OP14 /OP87E  Tidal watergate and water management at acid sulphate area  Landfill (HBH)  Line site, clinic and HA interview ( FJ) GP 7003A Page 16 of 65

Date Time Auditor Area / Department / Process / Function Key Contact  Storage Chemical, POL, fertilizer emergency shower and wash area ( HBH )  Scheduled Waste and Tripled rinsed empty container storage Line Site (HBH)

1230 Lunch  Documentation Review 1430  Interview with Internal and external stakeholders: Forestry ,Kluang ( FJ )

1630 Presentation of Findings of estate Ayer Item Palm Oil Mill Opening Meeting & presentation  Interview with FFB Suppliers  Mill records on production RE usage , water usage, Fossil fuel 0900  Mill Site & facilities visit  Document review relevant to the P&C (for Mill )  Interview FFB suppliers 18th  Supply Chain audit Gwen, Sivaji Dec  SOP & Team  Record Keeping  Training Sing Mah Division : POME application, Peat Area ,main 1000 drains and water level monitoring 1130 Preparation for Closing Meeting 1300 Lunch

2.3 Qualification of Lead Assessor and Assessment Team SGS (Malaysia) Sdn Bhd holds copies of educational qualifications, certificates and audit logs for each of the audit team members. SGS has evaluated the qualifications and experience of each audit team member and has registered the following designations for conducting RSPO Assessment. Summary of auditors’ educational background and experience are listed in Table 7 below. Table 9: Auditors Profile

Evaluation Team Notes

Team Leader- James S H Ong, a Bachelor of Agriculture Science holder and agronomist in Plantation SGS (M) Sdn Bhd. He has many years working experience in agriculture sector in Malaysia and has been working in estates as well in the agrochemical and fertilizer industry. He is well versed with agrochemical and fertilizer applications. Has undergone ISO 14001 and RSPO Lead Auditor GP 7003A Page 17 of 65

training for both P&C as well as the Supply Chain and has already been involved in RSPO and ISCC certification audits since 2010.

Auditor 1 – Mohd Faisal Jaafar is a degree holder in forestry from Universiti Putra Social , Legal & Malaysia. Faisal has 7 years of experience in operating Malaysian Timber Safety Certification Scheme with specialization in forest management certification and forest plantation management certification. As a qualified Forest Management Certification auditor, he was involved mainly in auditing issues on environmental, social as well as safety and health. Has undergone the necessary RSPO Lead Auditor Training Course and ISO 14000 Lead Auditor course and has gathered substantial auditing experience pertaining to RSPO since 2012.

Auditor 2 – Hoo Boon Han is the SGS SEAP Program Coordinator, Bio Fuels Environment and Sustainability. He has successfully completed the RSPO Lead auditor training Supply Chain course for both P&C as well as the Supply Chain. He is experienced in environmental monitoring & audit, carbon accounting & reduction, wastewater treatment, waste management and sustainable development experience across Southeast Asia.

2.4 Stakeholder Consultation and List of Stakeholders Contacted A wide range of stakeholders were contacted 4 weeks before the planned evaluation to inform them of the evaluation and to ask for their views on relevant palm oil sustainability issues. These included environmental interest groups, local government agencies and forestry authorities, social groups and workers’ unions etc. Stakeholder consultation took place in the form of meetings and interviews. Meetings with government agencies such as the Department of Forestry were held at their respective premises within and near the estates and Ayer Item Oil mill. In all the interviews and meetings, the purpose of the audit was clarified at the outset followed by an evaluation of the relationship between the stakeholder and the company before discussions proceeded in accordance with relevant RSPO principles, criteria and indicators. See Appendix D for stakeholder’s details and comments. GP 7003A Page 18 of 65

3. ASSESSMENT FINDINGS 3.1 Summary of Findings 3.1.1 Principles & Criteria As outlined, objective evidence was obtained separately for each of the RSPO indicators and criterion for the mills and estates. The results for each indicator from each of the operational areas were evaluated to provide an assessment of conformity. A statement is provided for each of the RSPO indicators in order to support the findings of the assessment team. Two (02) Major Non-conformities and one (1) Minor Non-conformity were identified during this assessment. Some weaknesses identified as potential areas for improvement have led to the seven (07) Observations raised. There were no Non-conformities raised in the Supply Chain audit of the Palm Oil Mill. Details for each of the Non-conformities and observations are given in Appendix A. Major Non- conformities have to be closed out within the period of 60 days after the main assessment. Minor Non-compliances and Observations will be followed up during the next Annual Surveillance Audit which is scheduled to be conducted within the period of twelve months after the RSPO approval of the Main Assessment.

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

Findings In compliance: Yes: X No: Objective Records of requests and responses are maintained as per the company’s Sustainable evidence: Management Procedure Manual entitled Procedures on Requests and Responses (SMP-GPB-25) dated 14 August 2014. During the Main Assessment, the audit team observed that the company has compiled a list of stakeholders that may be relevant to the management’s operations. The stakeholder list includes estates within the group, local schools, local communities, statutory bodies, contractors, FFB suppliers, visitors, neighbouring plantations and NGOs. The company maintained both soft and hard copy record and evidences of communication with stakeholders. The Enquiry Registry Book has been maintained since 2010. Stakeholders have a choice of both verbal and written request. It was also observed that a Women and Children Committee has been established to handle internal stakeholders (i.e. workers’) issues. Criterion 1.2: Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes 1.2.1 Land titles / user rights (C 2.2)

Findings In compliance: Yes: X No: Objective None of the documents listed in Criterion 1.2 are made publicly available in the public domain. evidence: However, the management of the company has issued a letter to all stakeholders on the availability of the above documents to all stakeholders on request. The letter, signed by the manager of the estates and mill is available dated 01 January 2014. 1.2.2 Safety and health plan (C 4.7)

Findings In compliance: Yes: X No: Objective Refer 1.2.1 evidence: 1.2.3 Plans and impact assessment relating to environmental and social impacts GP 7003A Page 19 of 65

(C 5.1, 6.1, 7.1, 7.3)

Findings In compliance: Yes: X No: Objective Refer 1.2.1 evidence: 1.2.4 Pollution Prevention Plan (C 5.6)

Findings In compliance: Yes: X No: Objective Refer 1.2.1 evidence: 1.2.5 Details of complaints and Grievances (C 6.3)

Findings In compliance: Yes: X No: Objective Refer 1.2.1 evidence: 1.2.6 Negotiation procedures (C 6.4)

Findings In compliance: Yes: X No: Objective Refer 1.2.1 evidence: 1.2.7 Continuous improvement plan (C 8.1)

Findings In compliance: Yes: X No: Objective Refer 1.2.1 evidence: Principle 2: Compliance with Applicable Laws and Regulation Criterion 2.1: There is compliance with all applicable local, national and ratified international laws and regulations. 2.1.1 Evidence of compliance with legal requirements Major

Findings In compliance: Yes: X No: Objective The company maintains all relevant documents pertaining to laws and legal as follows: evidence: Items Validity Diesel Storage (Genting Sri Gading Estate) No. (32) 25 Mar 2014 – 24 Mar 2015 PPDNKK/J/BP/PBK 0013 with serial number J 011163 Certificate of Fitness (Genting Sri Gading Estate) – Air Valid until 29 July 2015 Receiver No. JH PMT 17731 MPOB License for Selling and Transporting FFB 01 May 2014 to 30 April 2015 (Genting Sri Gading Estate) - No. 508592902000 Diesel Storage (Genting Sungei Rayat Estate) No. (61) 14 Jun 2014 – 13 Jun 2015 PPDNKK/J/BP/PBK 0048 with serial number J 011316 Diesel Storage (Genting Sungei Rayat Estate – Sing Mah 19 Jan 2014 – 18 Jan 2015 Division) BPGK.JH(KLU) 201 SK with serial number J 014171 MPOB License for Selling and Transporting FFB 01 May 2014 to 30 April 2015 (Genting Sungei Rayat Estate) - No. 508590202000 MPOB License for Selling and Transporting FFB - 01 Apr 2014 to 31 Mar 2015 (Genting Sungei Rayat Estate) No. 501298102000 Certificate of Fitness (Genting Sungei Rayat Estate) – Air Valid until 04 September 2015 Receiver No. JH PMT 14835 Certificate of Fitness – Steriliser No. 4 (Genting Ayer Valid until 09 October 2015 Item POM) No. JH PMT 101 Certificate of Fitness – Dandang Tiub Air Yoshimine Valid until 09 October 2015 GP 7003A Page 20 of 65

(Genting Ayer Item POM) No. PMD 3107

Certificate of Fitness – Dandang Tiub Air Yoshimine Valid until 09 October 2015 (Genting Ayer Item POM) No. PMD 3219 Certificate of Fitness – Water Softener Tank (Genting Valid until 09 October 2015 Ayer Item POM) No. PMT 101270 Certificate of Fitness – Air Receiver (Genting Ayer Item Valid until 09 October 2015 POM) No. PMT 107958 JH Certificate of Fitness – Pressure Filter (Genting Ayer Item Valid until 09 October 2015 POM) No. PMT 23683 Certificate of Fitness – Mid Steel Steam Separator Valid until 09 October 2015 (Genting Ayer Item POM) No. PMT 35004 Certificate of Fitness – Steriliser 3 (Genting Ayer Item Valid until 09 October 2015 POM) No. PMT 65743 Certificate of Fitness – Bi-Drum Watertube Boiler Valid until 16 May 2015 (Genting Ayer Item POM) No. JH PMD 965 Certificate of Fitness – Air Compressor (Genting Ayer Valid until 16 May 2015 Item POM) No. JH PMT 15029 Certificate of Fitness – Water Softener Tank (Genting Valid until 16 May 2015 Ayer Item POM) No. JH PMT 15030 Certificate of Fitness – Vacuum Deaerator Vessel Valid until 16 May 2015 (Genting Ayer Item POM) No. JH PMT 15031 Certificate of Fitness – Palm Oil Crane (Genting Ayer Valid until 16 May 2015 Item POM) No. PMA 7088 Diesel Storage (Genting Ayer Item POM) No. (15) 20 Sept 2014 – 19 Sept 2015 PPDNKK/J/BP/PBK 0069 with serial number J 011344 License to Operate Palm Oil Mill under Section 18(1) Valid until 30 June 2015 Environmental Quality Act, 1974 (Genting Ayer Item POM) Approval of Compliance against DOE requirements i.e. Valid until 30 June 2015 Environmental Quality (Prescribed Activities) (Crude Palm Oil Mill) Regulations, 1977 and Environmental Quality (Clean Air) Regulations, 1978 – License No. 002156 for operating Palm Oil Mill at capacity of not more 60m3/FFB (Genting Ayer Item POM) MPOB License for Selling and Transporting (FFB, CPO, Valid until 31 January 2015 PK), Buying and Transporting (FFB), Storaging (CPO & PKO) and Processing (FFB) No. 500056704000 (Genting Ayer Item POM) Weighbridge Stamping License No. B 681554 (Genting Until 14 April 2015 Ayer Item POM)

All staffs or workers working in the boiler station are also qualified. The audit team noted that all of them had undergone an inspection test and their competency has been certified and approved by the Department of Occupational Safety and Health (DOSH) to be in compliance with Regulation No. 5(2) Factory and Machineries (Competency Approval-Examination) Regulations, 1970. Examples of approvals verified are as follows:  Shaharudin Mohamad – Approval No. PA/65/ 89 dated 11 October 1989;  Ahmad Yunos Dahiran- Approval No. J.34/98 dated 12 June 1998;  Kamal Arbak – Approval No. J. 07/2000 dated 18 April 2000; and  Mohd Rashid Mirah Yusof – Approval No. J 110/05 dated 15 March 2005;

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Besides the above, there is an Audiometric Testing Programme conducted on all workers stationed at high pitch area such as thresher station, press station, boiler station, workshop, kernel plant, oil room and engine room. The latest programme was conducted on 09 March 2014. Based on the result, the audit team noted that a total of 35 persons had undergone the test out of which 20 workers were declared as having hearing impairment. Based on report, the audit team observed that those workers identified as having mild hearing impairment are required to undergo annual audiometric test as required by the Regulation 22(b) of the Factories and Machinery (Noise Exposure) Regulation, 1989. No workers were identified as having severe hearing impairment. The auditor has sampled and interviewed several workers who have undergone the test during the field visit and the result of the interview confirmed that they have undergone the test in March 2014. In addition, the interview also confirmed that the occupational health doctor who conducted the test had recommended that the workers are strictly required to wear hearing protection devices. In addition, the land titles for each of the estates are also available. Examples of land titles verified during the audit are as follows: (repeated below under section 2.2.1) No. Title No. Area Estate 1. CT 5237 3,062.7730 2. G 570 7.1604 3. G 20597 2.9618 4. G 9516 4.4262 5. G 2171 18.6534 6. G 2367 8.6754 7. G 2412 16.0103 8. G 2415 8.1442 9. G 2469 9.3583 10. G 2470 29.9973 11. G 2471 10.4459 12. G 2472 19.3737 13. G 2473 23.3705 14. G 2474 11.9635 15. G 2475 28.3785 Genting Sri Gading 16. G 2510 40.4938 17. G 2668 21.0057 18. G 2708 20.0193 19. G 3245 7.6297 20. G 3789 15.1504 21. G 3831 11.3564 22. G 6055 10.1171 23. G 7240 2.9087 24. G 11676 11.9382 25. G 19003 19.9687 26. G 19004 75.2461 27. CT 8143 4.0468 28. CT 8144 4.0493 29. CT 8145 3.5460 30. CT 8146 4.0468 GP 7003A Page 22 of 65

1. 12234 5.8806 2. 122398 39.9374 3. 132010 17.8567 4. 132011 9.7377 5. 82843 40.4685 6. 82847 394.1638 7. 83288 13.1143 8. 83292 34.8788 9. 83295 6.4952 10. 88834 371.0689 11. 88988 15.6309 12. 89354 8.0785 13. 91717 10.8759 14. 91722 17.9832 15. 91729 43.2507 Genting Sungei Rayat 16. 99154 11.3894 17. 99274 451.3401 18. 101445 12.5275 19. 122697 140.8304 20. 87521 26.1882 21. 99155 5.0434 22. 81255 15.2768 23. 3968 3.8015 24. 2390 1.8641 25. 2224 1.9728 26. 1218 0.8170 27. 3967 2.0993 28. 65 1.4594 29. 1550 1.8084 30. 1462 2.3143

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

Findings In compliance: Yes: X No: Objective The management unit maintains a copy of the relevant laws and legislations pertaining to palm oil evidence: mill and plantation operations as listed in the standard. It was observed that the list has been adequately reviewed with the latest revision conducted on 14 August 2014. 2.1.3 A mechanism for ensuring that they are implemented Minor

Findings In compliance: Yes: X No: Objective The company is using Legal Requirement Register (LRR) as a mechanism for implementing the evidence: laws as reflected in the SMP Procedures i.e. Procedures on Regional, National and International Laws (SMP-GPB) dated 14 August 2014. Currently the company has appointed the Chief Clerk from each of the estates as the person responsible for monitoring the changes in law and distributing the information to the mill and plantations. The appointed person is occasionally assisted by the personnel from the head office on the latest updates of the laws. 2.1.4 A system for tracking any changes in the law Minor GP 7003A Page 23 of 65

Findings In compliance: Yes: X No: Objective System for tracking the changes in the law is reflected within the above-mentioned SMP dated 14 evidence: August 2014. All changes of laws are communicated through the head office to the appointed personnel i.e. the Chief Clerk of each of the estates. For instance, the new regulations pertaining to abolishment of requirement to acquire permit for storage of fertilizer has been communicated to the estates through an email dated 04 November 2014. Criterion 2.2: The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights. 2.2.1 Evidence of legal ownership of the land including history of land tenure Major

Findings In compliance: Yes: X No: Objective The land titles for each of the estates are also available. Example of land titles verified during the evidence: audit are as follows: No. Title No. Area Estate 31. CT 5237 3,062.7730 32. G 570 7.1604 33. G 20597 2.9618 34. G 9516 4.4262 35. G 2171 18.6534 36. G 2367 8.6754 37. G 2412 16.0103 38. G 2415 8.1442 39. G 2469 9.3583 40. G 2470 29.9973 41. G 2471 10.4459 42. G 2472 19.3737 43. G 2473 23.3705 44. G 2474 11.9635 45. G 2475 28.3785 Genting Sri Gading 46. G 2510 40.4938 47. G 2668 21.0057 48. G 2708 20.0193 49. G 3245 7.6297 50. G 3789 15.1504 51. G 3831 11.3564 52. G 6055 10.1171 53. G 7240 2.9087 54. G 11676 11.9382 55. G 19003 19.9687 56. G 19004 75.2461 57. CT 8143 4.0468 58. CT 8144 4.0493 59. CT 8145 3.5460 60. CT 8146 4.0468 GP 7003A Page 24 of 65

31. 12234 5.8806 32. 122398 39.9374 33. 132010 17.8567 34. 132011 9.7377 35. 82843 40.4685 36. 82847 394.1638 37. 83288 13.1143 38. 83292 34.8788 39. 83295 6.4952 40. 88834 371.0689 41. 88988 15.6309 42. 89354 8.0785 43. 91717 10.8759 44. 91722 17.9832 45. 91729 43.2507 Genting Sungei Rayat 46. 99154 11.3894 47. 99274 451.3401 48. 101445 12.5275 49. 122697 140.8304 50. 87521 26.1882 51. 99155 5.0434 52. 81255 15.2768 53. 3968 3.8015 54. 2390 1.8641 55. 2224 1.9728 56. 1218 0.8170 57. 3967 2.0993 58. 65 1.4594 59. 1550 1.8084 60. 1462 2.3143

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

Findings In compliance: Yes: X No: Objective Based on the above observation, it is confirmed that all of the land titles are for agricultural crops evidence: such as Oil Palm and/or any agricultural crops of economic value. However, there is one case whereby one land title (Land title no. 131989) still carries the purpose of other crop planting i.e. rubber tree. Based on the above, the company has taken action to amend the land title to suit the purpose of planting oil palm. Evidence of communication with the land office is available. 2.2.3 Evidence that boundary stones along the perimeter adjacent to state land and Minor other reserves are being located and visibly maintained

Findings In compliance: Yes: X No: Objective The boundary stone at both the Soga Forest Reserve and the Bindu Forest Reserve were evidence: checked during the audit and was able to be located and visibly maintained. GP 7003A Page 25 of 65

a) GPS coordinate at the Soga Forest Reserve N 01° 49’ 28.6” E 102°58’ 53.9” (Beside F2012B) b) GPS coordinate at the Bindu Forest Reserve N 01° 55’ 16.1” E 102°59’ 47.3” (Beside F84B) 2.2.4 Where there are, or have been, disputes, proof of resolution or progress towards Minor resolution by conflict resolution processes acceptable to all parties are implemented. (CF 2.3.3, 6.4.1 and 6.4.2)

Findings In compliance: Yes: X No: Objective Genting Plantation does not have any land disputes. But a system to resolve land disputes is evidence: documented in the ‘Negotiations and Compensations Procedure. Criterion 2.3: Use of the land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent. 2.3.1 Where lands are encumbered by customary rights, participatory mapping should Major be conducted to construct maps that show the extent of these rights.

Findings In compliance: Yes: X No: Objective All the three estates are with proper legal title. The establishment of the plantations do not evidence: diminish legal or customary rights of any communities. As described earlier, these two estates’ land is with clear and undisputed boundaries. Clear physical boundary demarcation with legally recognized plan is observed during site visits. In addition there are no disputes/claims by the neighbors on the estate’s land.

2.3.2 Map of appropriate scale showing extent of claims under dispute Major

Findings In compliance: Yes: X No: Objective Customary use of land for community purposes have been identified either on maps (places of evidence: worship, burial grounds, and archaeological site) and maintained. 2.3.3 Copies of negotiated agreements detailing process of consent (C 2.2, 7.5, 7.6) Minor

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

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

Findings In compliance: Yes: x No: Objective Annual budget for the following year is found in the ‘Summary of Ex-Estate cost – Oil Palm for evidence: Fiscal year 2015, Version V1 (01/01/15 – 31/12/15) and is available . In addition, the projection for the year 2015 – 2019 is also sighted. The budget and projection is normally reviewed by the estate management during August the following year. Similar budget and projection were available for the Oil Mill. 3.1.2 Annual replanting programme projected for a minimum 5 years with yearly review Minor

Findings In compliance: Yes: x No: Objective The replanting program is available as below: evidence: Estate 2014 2015 2016 2017 2018 2019

GSGE 105.01 302.20 314.26 284.73 312.15 0.00 GSRE 12.40 0 110.77 162.70 36.80 118.54 GP 7003A Page 26 of 65

GKBE 88.08 40.34 60.67 64.12 52.84 33.85

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

Findings In compliance: Yes: x No: Objective Genting Plantations Berhad documents their procedures and manual in the followings: evidence: a) Standard Operating Procedure for operations (in Bahasa Malaysia) b) Sustainability Management Procedure manual c) Review on GENP’s Oil Palm manual (30/8/13) The above documents were also sighted at GSRE. The documented Standard Operating Procedures (SOP) for Genting Ayer Item Oil Mill is also available : a) Safe Operating Procedures b) Sustainability Management procedure manual Some of the Safe Operating Procedures checked in the manual were : a) SOP-MGR-01 Duties and Responsibilities b) SOP-PRD-01 Weighbridge c) SOP-PRD-02 Grading d) SOP-PRD-04 Sterilizer e) SOP-PRD-10 Press and Digester f) SOP-PRD-14 Boiler g) SOP-PRD-17 ETP h) SOP-LAB-02 CPO and PK Despatch 4.1.2 Records of monitoring and the actions taken are maintained and kept for a Minor minimum of 12 months

Findings In compliance: Yes: x No: Objective Monitoring of operation e.g. manuring is done by the Genting Plantation Research Centre (GPRC) evidence: monthly and they will present a summary known as Quality Manuring Control (QMC) assessment to the estate after the visit. A score (Poor, Fair or Satisfactory) will be given for each field and operation inspected. In the November 2014 report, it was noted that: Out of 31 fields inspected, 1 field had ‘outstanding ‘score, 6 fields have a’ AA1’ score and 24 fields have ‘AA2’ score. They also monitor on the FFB quality. Seven (7) inspections per month were conducted by the QCTIR (Quality Control Team Inspection Report) Team (comprising Oil Mill, Estate and the GPRC personnel). Results are presented to the estate immediately and the management will respond accordingly to the conclusion of the report. In the latest QCTIR Report for 9/12/14 GSGE had a score of 99.8%. Other monitoring done is on harvesting, P&D Census, Vehicle service and daily vehicle checklist. Criterion 4.2: Practices maintain soil fertility at, or where possible improve soil fertility to a level that ensures optimal and sustained yield. 4.2.1 Monitoring of fertilizer inputs through annual fertilizer recommendations Minor

Findings In compliance: Yes: x No: Objective The GPRC agronomist provides an annual manuring programme . evidence: The ‘Final Amended 2014 Fertiliser Recommendation’ done by the agronomist, Mr. Chia Chai GP 7003A Page 27 of 65

Chua was available. Based on the recommendation, the average dosage available for : a) Mature palm, b) Immature palm c) EFB application Application for 2014 is on time. During the audit, the correct dosage was manually applied around the palm during the field inspection. Similar agronomic recommendation (dated 5/5/14) is also provided by GPRC. Based on the recommendation the average dosage of total fertilizers for : a) Mature palm is 9.36 kg/palm b) Immature palm is 4.65 kg/palm Recommendation for the coming year, 2015, is also available. 4.2.2 Evidence of periodic tissue and soil sampling to monitor changes in nutrient Minor status

Findings In compliance: Yes: x No: Objective Foliar tissue is sampled for analysis annually and the last result was obtained in March-April 2014. evidence: Soil sampling to monitor changes in nutrient status will be done every 5 years and the result of the last sampling done in Sept – Oct 2013 was sighted, test report no: PR652014. Samples of soil from palm base and frond row were analyzed for pH, Org C, N, P, K, Ca, Mg, Na, CEC and mechanical analysis. Soil analysis report No: SR 12/13 was sighted. Similar records were also found in GSRE. 4.2.3 Monitor the area on which EFB, POME and zero-burn replanting is applied Minor

Findings In compliance: Yes: x No: Objective Records of EFB application is recorded in the EFB Mulching Record Book for each Division. evidence: Based on the recommendation, 40 MT / ha was advised and the record for OP95B (40 ha) showed that 1160.29 MT was applied. Similar EFB records are found at GSRE. In Field 86C of Bangkar Division, the recommended application was 20MT/ha and record showed that 24.9MT/ ha was applied. EFB is applied on the frond stack in single layer. The POME is not discharge into waterways. The Oil Mill has a licence No: 002156 from the DOE to discharge the POME under the category ‘ Atas Tanah’ or Land application . The nearest river, Sg Linau is about 5 km away from the site of the land application. The POME is pumped from the final discharge (at the Aerobic Pond 6) and later flows under gravity into the fields. The fields at Sing Mah Division that receives the POME are F02, F06 and F99A, with a total area of about 80 ha. Furrows are constructed along the pruned frond rows. A worker, Mr Amirulah is responsible to control the flow into the furrows so as to minimize overflow. Collection and Overflow pits are constructed at the end of the furrow rows to prevent spillage. The furrows at F02 were visited during the audit. Genting Plantation Berhad advocates Zero Burning Policy during replanting. This was verified as no burning was sighted during the visit to F14 (formerly P87E) in GSRE.

Criterion 4.3: Practices minimize and control erosion and degradation of soils. 4.3.1 Documented evidence of practices minimizing soil erosion and degradation Minor (including maps)

Findings In compliance: Yes: x No: Objective The estate will refer to the following procedures for guidance on 4.3.1 : evidence: a) Steep land Management SMP –GPB-10 b) Riparian Buffer zone management SMP-GPB-14 c) Weeding : Weed Management : Policy on Blanket spraying and erosion control , OPM-6 GP 7003A Page 28 of 65

The estate also has a file known as File 32: Soil Management, where the following are identified for reference : a) Soil Map b) Slope class and topography map c) Soil Management plan d) High Erosion Risk area maps Based on the slope classes map, the followings were identified in GSGE: Slope Class Description Percentage of total area 0° - 2° Flat 47.50% 2° - 6° Undulating 47.58% 6° - 12° Rolling 4.72% 12° - 20° Hilly 0.10% >20° Steep 0.10% The steep area covering 5.16 ha was sighted and was set aside as conservation area in F2012B. Similar soil maps and slope maps were sighted at GSRE for each division i.e. Bangkar, Sing Mah and Tanjung. 4.3.2 Avoid or minimize bare or exposed soil within estates Minor

Findings In compliance: Yes: x No: Objective In the estates , practices to avoid and minimize bare or exposed soil are found such as: evidence: a) Weed spraying is confined within the palm circles b) Spot spraying of problematic weeds such as broadleaf weeds , lallang and Stenochlaena ferns c) Maintenance of soft grasses d) In the replanting area, leguminous cover crop was planted after the old stand is chipped and stacked and after weeding rounds to control some of the VOPs and noxious weeds. e) Pruned fronds are stacked in T-shape formation in the palm rows f) EFB are placed on exposed area as well as along the frond stacks 4.3.3 Presence of road maintenance programme Minor

Findings In compliance: Yes: x No: Objective The road maintenance programme is found in the ‘Road Maintenance programme’ file . evidence: In Sri Gading , the following budget was allocated for 2014 and the to-date expenditure is: Budget ( RM) Actual as of Nov ‘14 Roads 186,700 145,200 Bridges 19,000 24,000 Path ( Rotorslashing 65,000 9,600 and cambering for mechanization )

In GSRE , the following budget was allocated for 2014 and the to-date expenditure is: Budget ( RM ) Actual as of Nov ‘14 Roads 102,600 78,300 Bridges 33,400 91,500 Path ( Rotorslashing 50,000 93,100 GP 7003A Page 29 of 65

and cambering for mechanization )

4.3.4 Subsidence of peat soils should be minimized through an effective and Minor documented water management programme

Findings In compliance: Yes: No: x Objective Soil type in GSGE are: : evidence: a) Rengam – Jerangau ( 53.66%) b) Holyrood-Lunas (8.37%) c) Sedu-Parit Botak ( 37.97% ) No peat soils were found in GSGE. A map on soil type in GSRE is also available. The soil types are Briah, Sedu-Parit Botak, Pelepah, Serdang-Bugor-Munchongand Rasau. In the Sing Mah Division, it was identified that 338.75 ha is peat. The peat areas are identified in the Sing Mah soil map. However, no documented evidence was available that subsistence of peat is minimized through an effective and documented water management program. In addition, no documented evidence was found to show that subsidence has ceased in the peat area. MINOR CAR 01 4.3.5 Best management practices should be in place for other fragile and problem soils Minor (e.g. sandy, low organic matter and acid sulphate soils)

Findings In compliance: Yes: x No: Objective For the acid sulphate soils like Sedu , a SOP for water management plan was sighted in the water evidence: management plan and practices file to: a) reduce the acidity in the acid sulphate soil b) Flush stagnant water in affected area c) To rehabilitate palm growth in low-lying area d) Optimize production The water management of GSGE at Field 99C was visited during the audit. The water gate and water weir procedure is documented in the file. In GSRE, the water gate at F97 was visited and the worker, Muhiddin was interviewed and he was aware of the monitoring of the water level at the watergate. Besides acid suphate soils. GSRE has about 338 ha of peat . During audit, field F10A in Sing Mah Division (on peat) was visited. Main and collection drains to maintain the water level were sighted along the field. GSRE has started to place a measuring ruler so that the water level is maintained at about 50 – 70cm from the surface. Criterion 4.4: Practices maintain the quality and availability of surface and ground water. 4.4.1 Protection of water courses and wetlands, including maintaining and restoring Major appropriate riparian buffer zones at or before replanting along all natural waterways within the estate.

Findings In compliance: Yes: No: x Objective The estate will refer to the SMP procedure : Riparian Buffer zone Management SMP-GPB-14 as evidence: guideline to protect the water courses in the estate. About every fifth palm along the natural waterways that flows through the estate, palms were marked with red paint to indicate to the weedicide sprayingoperators (sprayers) and manure operators not to spray or apply fertilizer within the riparian buffer zone . However, in GSGE at F96A, there seemed to be some spot spraying of woodies within the riparian buffer zone At GSRE, the riparian buffer zone in F84C was visited and there were also some evidence of spraying done on the marked palms as well as within the area. GP 7003A Page 30 of 65

MAJOR 02 4.4.2 No construction of bunds/weirs/dams across the main rivers or waterways Major passing through an estate

Findings In compliance: Yes: x No: Objective No construction of weirs was found along the main river, Sg Simpang Kanan. evidence: Weirs,watergates and bunds were only found within the estate for the management of the acid sulphate areas like F97 in GSRE. 4.4.3 Outgoing water into main natural waterways should be monitored at a frequency Major that reflects the estates and mills current activities which may have negative impacts (Cross reference to 5.1 and 8.1)

Findings In compliance: Yes: x No: Objective In GSRE, outgoing water into the main natural waterways is monitored twice a year. In the latest evidence: analysis report done in November 2014, sampling points of the inlet (P09B) and outlet (P10B) were sampled and analysed. The Certificate of analysis report JB/WE/8470-8471/14 was sighted. Parameters tested were pH, COD, BOD, SS, AN, P, DO and E. Coli. The results show that there was no marked or negative impact of the estate operation to the parameters analysed as the water quality upstream and downstream does not show significant differences and are within limit. The POME is not discharged into waterways. The Oil Mill has a licence No: 002156 from the DOE for discharging the POME under the category ‘Atas Tanah’ or Land application. The nearest river, Sg Linau is about 5 km away from the site of the land application. The Mill complies with the local DOE A.S 4 to submit analysis of the POME every quarterly. Based on the licence, the allowable BOD limit is 500mg/l. The followings are the BOD results for the 2014. Quarter BOD mg/l Jul – Sept ‘14 197, 223, 129 Apr – Jun ‘14 220, 163, 177 Jan – Mar ‘14 126, 322, 260 Results show that GAOIM complies with the limit set by DOE. 4.4.4 Monitoring rainfall data for proper water management Minor

Findings In compliance: Yes: X No: Objective The rain water monitoring is available as below: evidence: Estate 2011 2012 2013 Jan - Nov 2014

GSGE 3,064 3,409 2,731 2,626

GSRE 2166 2520 1868 1794

GSME (Div of GSRE) 2161 2303 1966 1690

GKBE 2919 3176 3036 2443

KBND (Div of GKBE) 2214 2584 2595 1829

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

Findings In compliance: Yes: x No: Objective The mill monitors the monthly water consumption for the mill and for domestic usage. evidence: Month Sept Oct Nov FFB Processed 24,789.690 24,368.850 21,587.310 GP 7003A Page 31 of 65

Processed usage m3 24,084 42,010 40,700 Water usage (m3/MT FFB ) 0.97 1.72 1.89

4.4.6 Water drainage into protected areas is avoided wherever possible. Appropriate Minor mitigating measures will be implemented following consultation with relevant stakeholders.

Findings In compliance: Yes: x No: Objective No water draining to protected areas or into the Forest Reserves. evidence: 4.4.7 Evidence of water management plans Minor

Findings In compliance: Yes: x No: Objective The water management plan is documented in File No: 28: Water Management Plan and evidence: Practices. It identifies the areas of concern , the action plan and monitoring as well as the PIC / Status for each area identified such as: a) Flood area b) Water quality c) Water Pollution d) Syarikat Air Johor (SAJ) water e) Optimize water and reduce wastage f) River water g) Assessment of water usage

The times and heights of the high and low waters (tides) is also available for GSRE as they are managing a tidal watergate. However, the water management plan for the peat area for GSRE Sing Mah Division was not included in the plan. OBSERVATION 01 GAIOM has established a water management plan for the raw water Treatment Plant & Drinking Water Plant to supply both raw water and drinking water for mill operation and domestic usage. The function of the Raw treatment Plant is to clarify the raw water for processing and boiler usage. The raw water is drawn from the Raw water Catchment Pond where it will be pumped to the treatment plant prior to its use in the oil mill. The Drinking water plant is to clarify the drinking water for domestic usage as the Mill and the workers do not receive piped government water from the Water authorities. The water for domestic use is obtained from tube well. The Oil Mill has the local SPAN licence approval to draw water for use. Criterion 4.5: Pests, disease, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques. 4.5.1 Documented IPM system Minor

Findings In compliance: Yes: X No: Objective Documented IPM is found in the Oil Palm Manual under ‘Pest and disease (revision June 2013 ) evidence: OPM 5 . It identified the pest such as : a) bagworms b) nettle caterpillars c) Grasshopper d) Rhinoceros beetles GP 7003A Page 32 of 65

e) Bunch moth f) Vertebrates such as rats g) Pest & Diseases in nursery h) Ganoderma It also shows the lifecycles, type of species as well as the chemical , physical and biological control method recommended. 4.5.2 Monitoring extent of IPM implementation for major pests Minor

Findings In compliance: Yes: X No: Objective The estates monitor the followings for IPM : evidence: a) Rats b) Pheromone trap ( only for GSGE ) c) Barn Owl boxes and maps d) Beneficial plant location

Based on the latest barn owl report dated Nov 28, 2014, the following was the occupancy rate. a) No. of Boxes: 210 b) Occupancy rate: 38% c) Ratio 1:16 ha d) Total Birds: 107 For rats, baits will be applied when the census records a fresh damage of 5%. Baiting will commence and rounds will be repeated after 4 days. Baiting will cease when acceptance is less than 20%. In September 10, 2014, a census was carried out by GPRC and the report showed that in Field OP08B the fresh damage was 5.96%. The estate then carried out the baiting on the 11th Sept 2014. By the 5th round, the bait acceptance level had fell below 20% and the baiting was stopped. In GSRE, census by the mandore and staff in Oct 2014 was sighted. Census was being done and recorded in the ‘Bagworm Census Record’ for field OP06D for bagworm population and stage of growth. In November 3, 2014, as the small larvae population was above the threshold at 10 larvae / frond, the GSRE Manager, Mr Shangkar had made the decision for chemical intervention . Methamidophos was trunk injected at the rate of 7.5 ml/ hole as recommended. Two holes were drilled and the chemical injected into these holes and sealed with soil/earth. A post-trunk injection census was done on the 25/11/14 and showed that the population was within the threshold and the operation was stopped. Census is done monthly to monitor the bagworm population.

4.5.3 Recording areas where pesticides have been used Minor

Findings In compliance: Yes: X No: Objective Both the estate audited i.e. GSGE and GSRE have recorded pesticide use in the appropriate evidence: Costing Book. It shows : a) Date b) Field c) Ha covered d) Manday e) Chemical and quantity GP 7003A Page 33 of 65

f) Labour cost g) Material cost h) Total cost i) Cost per ha j) Store requisition number ( reference ) 4.5.4 Monitoring of pesticide usage units per hectare or per ton crop e.g. total quantity Minor of active ingredients (a.i) used/tone of oil

Findings In compliance: Yes: X No: Objective Monitoring of pesticide usage units per hectare, per ton crop e.g. total quantity of active evidence: ingredients (a.i.) used/tonne of oil is available for individual active ingredient as well as total for insecticide, herbicide, fungicide as well as for rodenticide. kga.i/mt FFB kg a.i/MT oil FY kg a.i/hectare processed 2010 1.96 0.103 0.528 2012 1.59 0.073 0.377 2013 2.07 0.106 0.532 2014 ( till Nov ) 2.17 0.109 0.546 Monitoring is also done in a graph. For GSRE similar monitoring is done. kg a.i/mt FFB kg a.i/MT oil FY kg a.i/hectare processed 2010( only GSRE ) 1.32 0.073 0.377 2012 2.60 0.124 0.636 2013 2.31 0.101 0.508 2014 ( TILL Nov ’14 ) 2.12 0.106 0.529

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

Findings In compliance: Yes: No: X Objective SOP for the all agrochemicals is available, however, no written justification of all agrochemical use evidence: was sighted although recommendations for the use of the chemicals is provided in the SOP manual. MAJOR 03 4.6.2 Pesticides selected for use are those officially registered under the Pesticides Act Major 1974 (Act 149) and the relevant provision (Section 53); and in accordance with ESECHH Regulations (2000)

Findings In compliance: Yes: X No: Objective The pesticides used by these two estates are registered under the Pesticides Act 1974 (Act 149) evidence: and the relevant provision (Section 53); and in accordance with USECHH Regulations (2000) a) Multiphos (Hextar) b) Ally (Du Pont) c) Comet (Dow ) d) Supremo ( Hextar ) e) Ken Amine 600 ( Kenso ) f) Butik S ( Felda ) GP 7003A Page 34 of 65

g) Dipterex ( Bayer ) h) Kencis ( Kenso ) i) Paranox 13 4.6.3 Pesticides shall be stored in accordance to the Occupational Safety and Health Major Act 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations

Findings In compliance: Yes: x No: Objective The pesticides were stored in appropriate condition with the following aspects noted: evidence: a) Concrete building b) Natural and artificial ventilation c) Lighting d) Cemented floor e) Pallet and trays f) The store is under Lock and key g) Spill kit ( saw dust ) h) Measuring equipment i) Weighing scale j) MSDS k) At the premix area, emergency shower and eyewash were available . l) At the premix area a sump is provided to collect any spillage. m) Containers are triple rinsed and punctured before collection by registered agent? n) Workers are provided a shower area to wash themselves after operation. o) An area is also provided for the PPE to be hung to dry p) Another store is provided for keeping spraying and manuring equipment 4.6.4 All information regarding the chemicals and its usage, hazards, trade and generic Major names must be available in language understood by workers or explained carefully to them by a plantation management official at operating unit level

Findings In compliance: Yes: x No: Objective MSDS in the local language and in English, hazard signs posted at the door, emergency response evidence: procedure for spillage were posted on the wall. 4.6.5 Annual medical surveillance as per CHRA for plantation pesticide operators Major

Findings In compliance: Yes: x No: Objective In GSGE, Annual medical surveillance as per CHRA for the following plantation pesticide evidence: operators were checked and found to be in compliance with requirement: a) Jahiruddin Mallick ( 3/6/14 ) b) Sree Onnoda Sonkor ( 15/5/14) c) Abu Munsi ( 15/5/14) d) Abul Kashem ( 3/6/14 ) e) Mahrudin ( 25/9/13) Evidence was presented to show that Mr Mahrudin went back for vacation 9/3/14 – 3/5/14 and he missed his annual surveillance. However, till the date of main audit, he has not been sent for a medical surveillance OBSERVATION 02 In GSRE, the medical surveillance of the CDA spray operators as well as the workers involved in the trunk injection operation were viewed and were found to be updated and were passed to be ‘fit GP 7003A Page 35 of 65

for work’ by the OHD doctor , Dr. Noraida Zainudin, Klinik Nur, Batu Pahat. The following workers’ reports were sighted and found to be in order: a) Abdul High ( 6/5/2014) – CDA sprayer b) Bhagirathi Pradhan ( 6/5/2014)- CDA Sprayer & Trunk injector ‘Plugger’ c) Sivalingam Anadharajan( 6/5/2014) – Trunk injection Driller d) Sahidul Islam (6/5/2014) – Trunk Injector Chemical handler

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

Findings In compliance: Yes: X No: Objective There were no female spraying operators. evidence: 4.6.7 Documentary evidence that use of chemical categorized as World Health Minor Organization Type 1A or 1B, or listed by the Stockholm or Rotterdam Conventions and paraquat, is reduced and/or eliminated. Adoption of suitable economic alternative to paraquat as suggested by the EB pending outcome of the RSPO study on IWM

Findings In compliance: Yes: x No: Objective In Genting Plantations, some chemicals categorized as World Health Organization Type 1A or 1B evidence: such as paraquat or methamidophos are allowed to be used. In weeding, the paraquat (a.i. 13%) is still allowed by the management. The Table below shows that the estates are monitoring the yearly usage. 2010 2011 2012 2013 2014 GSGE Kg a.i 0.18 - 0.247 0.265 0.28 / ha GSRE, Kg 0.113 - 0.217 0.152 0.19 a.i / ha This trend is due to the following situations: a) Continuous replanting b) Rainfall c) VOPs and control of Stenocleana ferns The above records showed that paraquat usage was not reduced or eliminated in GSRE while increasing trend of usage was evident from 2010 to 2014 in GSGE. Nonetheless, the company has a plan to terminate the use of Paraquat by July 2015 and substitute its usage with other suitable alternative herbicides such as Basta and Glyphosate as highlighted in Indicator 8.1.1 OBSERVATION 03 4.6.8 Documented justification of any aerial application of agrochemicals. No aerial Major spraying unless approved by relevant authorities

Findings In compliance: Yes: No: Not applicable Objective No aerial application done. evidence: 4.6.9 Evidence of chemical residues in CPO testing, as requested and conducted by Minor the buyers

Findings In compliance: Yes: x No: Objective According to Mill manager, Mr Jamhuri Lee Abdullah, there was no request from any buyer on the evidence: testing of chemical residues in CPO. . However, an analysis was done by MPOB in 2013 for monitoring purposes. 4.6.10 Records of pesticides use (including active ingredients used, area treated, Minor amount applied per hectare and number of applications) are maintained for either GP 7003A Page 36 of 65

minimum of 5 years or starting November 2007

Findings In compliance: Yes: x No: Objective The estates have started to monitor pesticides use since 2009. . However, due to the change from evidence: the SAP to the Lintramax software recording system, the record for 2011 was lost in transition. Monitoring of pesticide usage units per hectare, per ton crop e.g. total quantity of active ingredients (a.i) used/tonne of oil is available for individual active ingredient as well as total for insecticide, herbicide, fungicide as well as for rodenticide. kg a.i/mt FFB kg a.i/MT oil FY kg a.i/hectare processed 2010 1.96 0.103 0.528 2012 1.59 0.073 0.377 2013 2.07 0.106 0.532 2014 ( till Nov ) 2.17 0.109 0.546 Monitoring is also done in a graph. For GSRE similar monitoring is done. kg a.i/mt FFB kg a.i/MT oil FY kg a.i/hectare processed 2010( only GSRE ) 1.32 0.073 0.377 2012 2.60 0.124 0.636 2013 2.31 0.101 0.508 2014 ( TILL Nov ’14 ) 2.12 0.106 0.529

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

Findings In compliance: Yes: X No: Objective Safety and Health Policy dated 21 December 2009 and signed by the company’s Chief Operating evidence: Officer & President is available that among others specifies the requirement of the company to comply with the requirement of the Occupational Safety and Health Act 1994. Safety and Health Plan is available that transmit the commitment of the company to provide a safe & Healthy working environment to all its workers as well as other stakeholders such as contractors, external stakeholders and visitors. The plan dated 22 June 2014, also specifies the objectives of the plan which states as follows:  To provide and maintain a working environment that is safe without risk to health and adequate as regard to welfare at work;  To provide information, instruction, training and supervision to enable workers to perform their work in a safe manner;  To achieve ZERO accident rate;  To promote on OSH campaign to create the importance of environment, safety and health to all operatives;  To encourage commitment of all employees in eliminating risk; and  Continuous improvement on OSH management Based on record, the audit team noted that each of the estates has identified the responsible person for coordinating the occupational safety and health within these two estates. For Genting Sri Gading Estate and Genting Sungei Rayat Estate, the Senior Assistant Manager and Assistant Manager were respectively appointed., The letter of appointment dated 01 January 2014 and 26 March 2013 and signed by the Manager of these estates was made available to the audit team during the audit. With regard to the Ayer Item POM, the Manager has been appointed as the responsible person dealing with the OSH since November 2009. Besides the above, there is also evidence of Emergency Response Plan (OM-GPB-04) dated 01 January 2010 which has been established and found to be attached together with the Occupational Safety and Health Manual. In addition, the flowchart detailing the procedure to be taken in case emergency occur is also stated in the procedure. Among the details highlighted are GP 7003A Page 37 of 65

as follows:  Objective;  Responsibility (ERT);  Organization Chart;  Record;  Information to be attached as and when accident occur;  Fire Extinguisher;  First Aid Kit;  Basic utilities to be prepared at working sites Training plan for 2014 is available that also includes the requirement for Occupational Safety and Health Training that covering the first aid training, fire drill, safe operating procedures and daily briefing of PPE as well as the MSDS training. Safety & Health Committee has been established and is chaired by the respective assistant manager of the estate. The organization chart was made available to the audit team during the audit. It showed the list of the responsible personnel that consist of Chairman, Secretary and representatives from the workers as well as the company’s top management. Safety and health committee meeting is conducted quarterly. Based on records the meetings have been conducted according to the OSHA as follows: Date Details/Venue 24 Jan 2014 Meeting conducted in Genting Sri Gading Estate. Minutes of Meeting is available 31 March 2014 Meeting conducted in Genting Sri Gading Estate. Minutes of Meeting is available 24 June 2014 Meeting conducted in Genting Sri Gading Estate. Minutes of Meeting is available 03 Oct 2014 Meeting conducted in Genting Sri Gading Estate. Minutes of Meeting is available 15 Sept 2014 Meeting conducted in Genting Sungei Rayat Estate. Minutes of Meeting is available 20 Jun 2014 Meeting conducted in Genting Sungei Rayat Estate. Minutes of Meeting is available 21 March 2014 Meeting conducted in Genting Sungei Rayat Estate. Minutes of Meeting is available 25 Sept 2014 Meeting conducted in Genting Ayer Item POM. Minutes of Meeting is available 27 Jun 2014 Meeting conducted in Genting Ayer Item POM. Minutes of Meeting is available 17 Mar 2014 Meeting conducted in Genting Ayer Item POM. Minutes of Meeting is available

Furthermore, the HIRARC is also available at all estates visited. The audit team notes that the HIRARC dated 04 Jun 2014 (Genting Sri Gading Estate), 30 April 2014 (Genting Sungei Rayat Estate) and 01 September 2014 (Genting Ayer Item POM) is updated according to occurence of any accident that occurs within the validity of the HIRARC. The company has appointed the designated qualified first aider to train the ground workers and field staff pertaining to the safety and health as well as basic usage of the first aid kit. Observed that the dedicated personnel have undergone a proper training on 24 & 25 November 2014 by the Academy of Safety and Emergency Care. Training also has been conducted to field workers whereby based on records, latest training was conducted on 17 June 2014 (Genting Sri Gading Estate) and 07 Dec 2014 (Genting Sungei Rayat Estate) by the hospital assistant. The training was conducted for all staffs and appointed first GP 7003A Page 38 of 65

aiders of all estates. Evidence of training in the form of training records and attendees were available during the audit. Hazardous signage (including no smoking sign) were also being placed at all designated hazardous areas such as workshop, chemical store and scheduled waste store. 4.7.2 Records should be kept of all accidents and periodically reviewed at quarterly Major intervals

Findings In compliance: Yes: X No: Objective Accident records are found to be updated on a monthly basis (using JKKP 6 form) for both Mill and evidence: Estates. Observed also JKKP 8 is used for reporting the accident records at a yearly basis. Observed that latest submissions were conducted as follows:  15 January 2014 – Genting Sri Gading Estate;  11 January 2014 – Genting Sungei Rayat Estate;  22 January 2014 –.Genting Ayer Item POM 4.7.3 Workers should be covered by accident insurance Major

Findings In compliance: Yes: x No: Objective Foreign workers are covered under the FWCS accident insurance scheme. During the audit, the evidence: insurance/ certificate policies for 200 workers (internal and outsourced workers) were sighted and found to be valid.

Local workers are covered under the SOCSO scheme whereas for staff and executives , besides SOCSO, Genting Plantations also has a Group Accident Policy insurance cover for them. All Workers (both local and foreign) are duly covered by valid accident insurance policy. Local Workers are compulsory to subscribe to EPF and SOCSO in addition to their accident insurance policy. Observed examples of insurance policy as follows:  Genting Sri Gading Estate – LONPAC Insurance – Policy No. W/14/WF01/013205/KUL-29 with a validity from 01 Feb 2014 to 31 Jan 2015;  Genting Sungei Rayat Estate – LONPAC Insurance – Policy No. W/14/WF01/013121/KUL-22 with a validity from 01 Jan 2014 to 31 Dec 2014; and  Genting Ayer Item POM – LONPAC Insurance – Policy No. W/14/WF01/013114/KUL-004-22 with a validity from 01 Jan 2014 to 31 Dec 2014.

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

Findings In compliance: Yes: x No: Objective The training programme of the estate for 2014 was viewed and was found to be appropriate to the evidence: training needs as it includes: a) Road safety b) sprayer and calibration c) CDA training d) ERP and first aid kit e) Manuring f) Harvesting g) Tractor Driver h) Use of mechanical harvesting equipment “Cantas” i) P&D GP 7003A Page 39 of 65

j) SOP k) Fire Extinguisher l) New worker Orientation Training for trunk injection on 10/7/14 was viewed and an evaluation form was also provided to check on the understanding. However, the evaluation form did not touch on the specifics of the procedure related to the operation e.g. dosage, PPE required, height of the drill etc. OBSERVATION 04 For the Oil Mill, the trainings conducted and planned for 2014 were sighted . The Oil Mill training records are kept in 3 files namely: a) Training Records ( under ISO 9001:2008 ( 2014 ) b) Training Record ( Under ISO 14001, OHSAS, MS 1722 ( 2014 ) ) c) Sustainability Training Record ( 2014 ) The training plan shows : a) Proposed persons to attend b) Designation of the person attending c) Rationale of the training planned d) Intended scope of training e) Date f) Trainer /Venue Training that has been conducted will be summarized to show the : a) Training No. b) Date conducted c) Training Title d) Trainer e) Venue and f) Status

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

Findings In compliance: Yes: x No: Objective For Genting Sri Gading Estate and Genting Sungei Rayat Estate, environmental aspects and evidence: impacts assessment updated 25/11/2014 and 2/12/2014 were noted respectively. The assessment includes all the activities in plantation such as pesticide spraying, manuring, chemical receiving and storage etc. The environmental impact aspect assessment (doc no: SP-MGR-02-F01-2 dated 03 September 2014) has listed all the activities in the different locations such as generation of steam in boiler and generation of electricity in engine room. 5.1.2 Environmental improvement plan to mitigate the negative impacts and promote the Minor positive ones, is developed, implemented and monitored

Findings In compliance: Yes: x No: Objective The environment improvement & management plan updated on 11th December 2014 incorporated evidence: the source, negative impacts, improvement/mitigation plan and monitoring & action plan. Below GP 7003A Page 40 of 65

are the samples: a. Loss of HCV areas and ERT species- Protection and demarcation of HCV areas within estate as sensitive areas. b. Soil erosion into waterways causing loss of water quality of natural waterways and water bodies- Identification of high risk-erosion areas (steep, bare ground etc); waterways and water bodies, floodplains. c. Water pollution- Groundwater pollution from waste water, septic tanks or landfill d. Greenhouse gas emissions- Loss of carbon sink from peat soil, water table management The mill has implemented the technology of continuous desludging of POME using geotube and 100% are applied at land application. During onsite visit to field F02, 06 and 99A confirmed that the POME discharge to nearby field via piping into flatbeds and furrows. Action plans, monitoring and continuous improvement program for each environmental impact is available. Criterion 5.2: The status of rare, threatened or endangered species (ERTs) and highly conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations. 5.2.1 Identification and assessment of HCV habitats and protected areas within land Major holdings and attempt assessments of HCV habitats and protected areas surrounding landholdings

Findings In compliance: Yes: x No: Objective The inventory of the HCV sites was conducted from 6th to 7th February 2010 by Dr Yap Son evidence: Kheong which covered all the southern region estates of Genting Plantations.. Based on the findings of the assessment, the management and monitoring plan for HCV areas report dated 10th October 2014; High Conservation Value (HCV) areas have been identified such as the estate shares a boundary with the Soga Forest Reserve, presence of protected fauna in Soga Forest Reserve, natural stream that flows through the estate, Hindu Temple and cemeteries. While in Genting Sungai Rayat estate, no HCV present within the plantation except the riparian buffer belt present, temples for local communities Ancient burial site. The estate neighboring Bindu forest reserve with protected fauna. 5.2.2 Management plan for HCV habitats (including ERTs) and their conservation Major

Findings In compliance: Yes: x No: Objective The management and monitoring plan for HCV areas report dated 10th October 2014 is available evidence: during onsite audit. The common management plan for different HCV mainly focus on signage (Barring any hunting, collecting and hunting activities), establish buffer zone as per guideline and to avoid any chemical weeding or manuring activities on palms within buffer zone. 5.2.3 Evidence of a commitment to discourage any illegal or inappropriate hunting, Minor fishing or collecting activities and developing responsible measures to resolve human-wildlife conflicts

Findings In compliance: Yes: x No: Objective The management of the individual estates has taken action to discourage any illegal or evidence: inappropriate hunting, fishing or collecting activities. Genting Plantations has erected ‘no hunting’ signs at the boundary near forest reserve at Sri Gading Estate, conducted a number of awareness training/meeting to the workers and local communities to discourage hunting and disturbance to the natural areas. The latest stakeholder meeting conducted on 18 May 2014. However, the signage to discourage hunting was not sighted in areas bordering the Forest Reserve at Sungei Rayat Estate. OBSERVATION 05 Criterion 5.3: Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner. 5.3.1 Documented identification of all waste products and sources of pollution Major

Findings In compliance: Yes: x No: GP 7003A Page 41 of 65

Objective Documented identification of all waste products identified within the estates and mill is highlighted evidence: within the identification, segregation and storage of waste document (dated on 22 July, 2014). The document contains the source of pollutions/wastes, main type of pollutions/waste and main concern/ remarks. The document specifies the following pollution sources that have been identified as follows:  Workshops- Leakages of oil  Line sites- domestic and recyclable waste  Chemical stores- chemical containers, paper box, leakage of chemical.  Clinic- Clinical waste etc. 5.3.2 Having identified wastes and pollutants, an operational plan should be developed Minor and implemented to avoid or reduce pollution

Findings In compliance: Yes: x No: Objective During onsite audit at Genting Sri Gading estate, landfill shows no signs of scattered litter or has evidence: any odor. A layer of soil will cover on the domestic waste when it reaches a certain level of height. A signboard with the open and close date of the landfill is available. All the scheduled waste containers were triple rinse and punctured for storage appropriately. All plastic (HDPE) pesticide containers were collected by a licensed collector, G planter. Records are available and the latest delivery made on 12 Dec 2014. For other scheduled waste such as SW305- Spent Lubricating Oil, w collection is done by licensed contractor- OLST PETRO- Chemical Sdn Bhd. Consignment note: 1080029 dated 7 Oct 2014 was available during onsite visit. Similar procedures are applicable to Sungei Rayat estate and all records for waste disposal are available onsite. At the oil mill, the scheduled waste store is in the proper storage and lock area. Consignment note for the schedules waste are updated, example: Inventory no (152941) and dated 17 Dec 2014. For landfills, appointed workers will segregate the waste after collecting from the line site prior to sending it to the designated landfill. This indicates that there is a lack of awareness in implementing the segregation at source amongst the workers. OBSERVATION 06 5.3.3 Evidence that crop residues/biomass are recycled (Cross reference C 4.2) Minor

Findings In compliance: Yes: x No: Objective Crop residues such as pruned fronds are stacked in T-shape formation along alternate palm rows evidence: as observed during onsite audit. Fiber is used as fuel for the boiler in the mill. Boiler ash is sent to certain estates based on the request. Criterion 5.4: Efficiency of energy use and use of renewable energy is maximized. 5.4.1 Monitoring of renewable energy use per ton of CPO or palm product in the mill Minor

Findings In compliance: Yes: x No: Objective The renewable energy (Fibre) use record is available and up to date. evidence: Following is the summary mill boiler fuel monitoring from Sep-Nov 2014 (using fibre ) Month CPO Fibre usage RE MT/CPO Sept 5,031.401 3,160.601 0.628 Oct 5,116.628 3,114.066 0.609 Nov 4,356.684 2,846.925 0.653

5.4.2 Monitoring of direct fossil fuel use per ton of CPO or kW per ton palm product in Minor the mill (of FFB where the growers has no mill)

Findings In compliance: Yes: x No: GP 7003A Page 42 of 65

Objective Diesel consumption from 2009 to 2013 was monitored in Genting Sri Gading Estate and Genting evidence: Sungei Rayat Estate. Sungai Gading Estate: The diesel consumption per ton FFB in 2013 is 1.22 liter/tonne FFB. Sungei Rayat Estate: The diesel consumption per ton FFB in 2013 is 0.85 liter/tonne FFB.

In the mill, the direct fossil fuel use record is available and up to date. Following is the summary of diesel used per tonne CPO monitoring by the mill for the Sep-Nov 2014 period: Diesel used per Month CPO Diesel ton CPO Sept 5031.401 1200 0.238 Oct 5116.628 725 0.142 Nov 4356.684 3000 0.688

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

Findings In compliance: Yes: x No: Objective No burning policy is available and signed by Mr Yong Chee Kong (President & Chief Operating evidence: Officer) dated 10 Aug 2011 and no evidence of open burning was observed during onsite visit to the line site as well as the areas surrounding the office. 5.5.2 Previous crop should be felled/mowed down, chipped/shredded, windrowed or Minor pulverized/ploughed and mulched

Findings In compliance: Yes: x No: Objective Inspection of one of the replanting areas in Sungei Rayat confirmed that the trunks of the evidence: replanted old palms were felled and chipped to 4-6” thick and windrowed for decomposition in situ. 5.5.3 No evidence of burning waste (including domestic waste) Minor

Findings In compliance: Yes: x No: Objective No evidence of burning of waste including domestic waste was observed during the site visit. evidence: Similar observation within the operation area as all domestic wastes are sent to designated landfill. Criterion 5.6: Plans to reduce pollution and emissions, including greenhouse gases are developed, implemented and monitored. 5.6.1 Documented plans to mitigate all polluting activities (Cross reference C 5.1) Major

Findings In compliance: Yes: x No: Objective The pollution prevention plan is available within the EAI document. The plan contains the evidence: identification of the pollution sources, the environmental impact of the pollution, the improvement (action) plan, documents that need to be reviewed and management review comments. The following environmental monitoring have been carried out: a. POME Analysis b. Smoke density indicator readings c. Ambient air monitoring point 1 & 2 d. Chimney Gas Emission Monitoring Report All the monitoring parameters complied with and are under the permission limit. 5.6.2 Plans are reviewed annually Minor

Findings In compliance: Yes: x No: Objective Management plan are reviewed annually and approved by the Sustainability Manager and GP 7003A Page 43 of 65

evidence: respective manager. Following updated plan as below: a. Waste management Plan (for estates and mill) dated 9 Dec 2014 b. Environment Improvement & Management plan dated 11 December 2014 c. Pollution Prevention Plan for Genting Ayer Item Mill dated 28th Nov 2014 5.6.3 Monitor and reduce peat subsidence rate through water table management (Within Minor ranges specified in C 4.3)

Findings In compliance: Yes: X No: Objective Peat area only available in Sungei Rayat Estate-Sing Mah Division which is nearby the mill. The evidence: estate was already developed since the 1950s. During onsite visit at the Block 10A, it was confirmed that the water tables are monitored and control is at 50-70cm. Measurement meter is available at each control point.

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

Findings In compliance: Yes: X No: Objective The documented Social Impact Assessment (SIA) dated 18 September 2014 (Genting Sri Gading evidence: Estate) and 16 September 2014 (Genting Sungei Rayat Estate and Genting Ayer Item POM) are available.

The documents listed a series of sections relating to social aspects of which one of it is on Social Impact Assessment that summarizes the issues raised by both external and internal stakeholders as well as actions to be taken with the details are as follows:

Aspects Impacts Management Plan Identified Flood issues in Accessibility  The estate to operate the water gate leading to Kg. Baru Kg. Baru based on the water level on Parit Safety and health Sulong 7;  The safety and welfare of people staying in Kg. Loss and damage to Baru’s downstream areas are given the most property priority.

Impact to local business

Stress and psychological effects

Dusty Road Compromise the  Consideration being given for alternative road due to cleanliness and materials to be utilized during the road transportation healthiness of housing maintenance process of FFB by and households  Estate to install an additional signage speed trucks limit i.e. 20km/hour  To advise the lorry driver to reduce the speed  To water the road as and when necessary  Construction of road-hump Permission for Affecting the company’s  To attend to the requests by the stakeholder estates image plan/layout Desilting the drain in Kg. Baru Request for Nil  To request the temple committee to write to assistance by estate’s management instead of verbal request the head of temple to repair GP 7003A Page 44 of 65

the damaged chariot Contract Workers are not aware  Estate to give one copy of their contract agreement not of their pay agreement. A copy of the agreement to be provided to displayed at the estate’s notice board workers Price list from Workers are not aware  Estate to provide the pricing list sundry shops of the prices of goods  Two assistants to monitor the implementation are not available

In addition, the above management plan is found to contain the due dates and reports on the progress made together with the name of the person in-charge. 6.1.2 Evidence that the assessment has been done with the participation of affected Minor parties

Findings In compliance: Yes: X No: Objective All records of meetings, consultations which took place during the SIA was incorporated in the evidence: assessment document. List of the stakeholders consulted are also available in the document. An example of stakeholders meeting for SIA assessment and consultation held on 17 September 2014 was noted to have been attended by various stakeholders such as relevant government authorities, NGOs, local communities and numerous organizations from the private sectors. 6.1.3 A timetable with the responsibilities for mitigation and monitoring is reviewed and Minor updated as necessary

Findings In compliance: Yes: X No: Objective A timetable for mitigation and monitoring has been duly carried out with the incorporation of an evidence: action plan to manage the various aspects and impacts identified as shown in Indicator 6.1.1. Each identified aspect and impact has its due date for the implementation of its management plan and the name of the person in-charge while progress made has to be monitored and reported at regular intervals.

Criterion 6.2: There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties. 6.2.1 Documented consultation and communication procedures Major

Findings In compliance: Yes: X No: Objective The company has established the Consultation & Communication Procedure (Internal/External) evidence: [Ref No.: SMP-GPB-17] dated 11 October 2013 that among others specifies the procedures to resolving issues pertaining to social, environmental issues and RSPO implementations. In summary, the procedures describe the responsibility of personnel identified, procedures and mechanism to be taken should any stakeholders being the external or internal wish to communicate with the company on any issues concerning their interest. Furthermore, the audit team also noted that the company has established a specific flow chart in terms of procedures and means to resolve the issues raised by the interested stakeholders starting from the receiving of the report until the resolution. In addition, the flow chart also states the estimated time taken for addressing the issues for each of the procedure stages. 6.2.2 A nominated plantation management official at the operating unit responsible for Minor these issues

Findings In compliance: Yes: X No: Objective There is evidence of the nominated plantation and mill officer to be the responsible personnel in evidence: dealing with social issues. Currently, the company has appointed the estate managers for all respective estates as well as assistant mill manager as the responsible personnel in receiving the internal & external communication with the employees, local communities and other interested stakeholders. The letter of appointment that is signed by the estate and mill managers is made available to the auditor during the audit. Observed the appointment letter specifies the following roles:  Investigates any issues on social issues, identify the causes and takes corrective and preventive actions on identified issues GP 7003A Page 45 of 65

 Investigate complaints and grievances registered in Complaint & Grievance book, and takes appropriate action upon consultation with the Estate Manager  Facilitates internal & external stakeholder consultation and communication regarding social, environmental, safety and health and welfare issues  Conduct evaluation of compliances based on the social management plan  Carries out any projects or work on social issues assigned by the Estate Manager 6.2.3 Maintenance of a list of stakeholders, records of all communication and records of Minor actions taken in response to input from stakeholders

Findings In compliance: Yes: x No: Objective List of stakeholders at estate and mill level and records of communication are available. evidence: These include local banks, contractors, vendors, local authority services, government agencies including the list for NGOs, neighbouring mills, surrounding local communities and estates. In addition, there is also evidence that the company has conducted an official stakeholder consultation for the external stakeholders. Based on records, the audit team observed that the latest consultation was conducted on 10 December 2014 and was attended by stakeholder groups i.e. smallholders and local communities. With regard to the engagement with the Forestry Department on the consultation pertaining to the Soga FR and Bindu FR, the audit team notes that the company has taken action to engage with the Batu Pahat Ranger Office (both estates). Unfortunately, there is no response from the Department. The audit team has taken action to consult with the District Forest Office (DFO) during the audit through the stakeholder consultation process. Interview with the District Forest Officer (DFO) of Kluang during the on-site stakeholder consultation showed that the reason why no response from the department is due to any instruction for response to the company shall be given from the District Forest Office and that the Ranger Office did not convey the massage to the DFO. Based on the above, the DFO is of the view that for any communication to be made with the Forestry Department must go through the District Forest Officer for any matters pertaining to the conservation and enforcement on the FRs within its district. This can ensure proper collaboration and smooth enforcement can be made between both parties. Observation is issued to monitor this. OBSERVATION 07 Criterion 6.3: There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties. 6.3.1 Documentation of the process by which a dispute was resolved and the outcome Major

Findings In compliance: Yes: X No: Objective All records of complaints and grievances external and internal are kept within the evidence: Complaints/Grievances Record Book as a means to record the complaints raised on ad-hoc basis. The form is found to be containing the details as follows:  Details of complainant;  Date;  Nature of complaints i.e. social, damage of PPE, housing issues, sexual harassment, environmental, cleanliness etc.  Details of complaint/issues;  Details of receiver;  Action taken;  Date of action taken; and  Investigation needs (if any).

As of the date of the audit, there are no complaints received from outsiders and workers except on certain normal matters pertaining to the broken/obsolete amenities within the workers line site and request of replacement of PPEs.

To address all the grievances and complaints raised by the relevant interested stakeholders, the company has established the procedures on Complaints & Grievances Procedure [Ref No.: SMP- GPM-19] dated 14 August 2014 to resolve the grievance raised. In addition a flow chart is formulated in Malay language and is found to be posted on the company’s notice board. 6.3.2 The system resolves disputes in an effective, timely and appropriate manner Minor GP 7003A Page 46 of 65

Findings In compliance: Yes: X No: Objective The established grievances procedures specify the estimated time required to be taken for each evidence: of the process, to be addressed before proceed to the subsequent process. As stated in the documented procedures, all grievances need to be addressed within 10 working days. During the audit, Complaints/Grievances Record Book was inspected for requests and grievances recorded since 2009 until September 2014. There are no new grievances raised since then. Based on records, the auditing team observed that generally the follow-up action has been taken within 14 working days from the day the complaint was received as per set procedures. 6.3.3 The system is open to any affected parties Minor

Findings In compliance: Yes: X No: Objective The above system is found to be open to affected parties. Based on records, the briefing of the evidence: above system has been conducted to the internal stakeholders i.e. workers and mandores on 09 December 2014. Evidence of briefing in the form of attendance list and signature/finger-print stamp is available during the audit. Criterion 6.4: Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions. 6.4.1 Establishment of a procedure for identifying legal and customary rights and a Major procedure for identifying people entitled to compensation

Findings In compliance: Yes: X No: Objective A procedure for identifying legal and customary rights and a procedure for identifying people evidence: entitled to compensation is available within the Sustainability Management Procedure entitled Negotiation, Compensations and handling Procedure (SMP-GPB-18) is available dated 14 August 2014. The procedure included the following elements:  Land and Boundary Disputes o Handling Land and Boundary Disputes  Compensation and Claim Procedures on Overplanted and Underplanted Land Issues o Land and Boundary Disputes by Estate o Encroachment by smallholders, third parties, government etc  Squatter Disputes 6.4.2 A procedure for calculating and distributing fair compensation (monetary or Minor otherwise) is established and implemented. This takes into account gender differences in the power to claim rights, ownership and access to land; and long- established communities; differences in ethnic groups’ proof of legal versus communal ownership of land. Findings In compliance: Yes: X No: Objective A procedure for calculating and distributing fair compensation is available within the Sustainability evidence: Management Procedure entitled Negotiation, Compensations and handling Procedure (SMP- GPB-18) is available dated 14 August 2014.that include identification procedure, calculating and distributing fair compensation procedure and documentation on outcome of compensation. 6.4.3 The process and outcome of any compensation claims is documented and made Minor publicly available

Findings In compliance: Yes: X No: Objective This Unit does not have any customary rights issues with the local communities. evidence: Criterion 6.5: Pay and conditions for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages. 6.5.1 Documented of pay and conditions Major

Findings In compliance: Yes: X No: Objective Workers are paid by cheque. All the pays of workers are well documented. Every worker is evidence: provided with a monthly pay slip with a signed acknowledgement from the workers. Based on records, the audit team noted that every worker is paid the recently government decreed minimum wage and this is well in line with the company’s commitment. The estates also GP 7003A Page 47 of 65

encourage the workers to keep on improving their productivities in order to earn more. Samples of payslip are checked and it is evident that most workers earned more than the minimum wage. Samples of verified payslips are as follows: Name Working field Abu Munsi Sprayer Muhamad Sprayer Wagiyo Manuring Abdul Husin Manuring Norliza Mandore - Sprayer Gulzar Harvester Abdul Salam Harvester Noman Harvester Abdullah Harvester Muksin Harvester

All of the above verified payslips are above the minimum wage requirements set by the government i.e. RM 900 for Peninsular Malaysia required under the Minimum Wages Order 2012.With regard to the terms and conditions for employment, the details of terms and conditions of employment are described in their offer letters and contract agreement. The above document includes contract agreement, wages and other employment benefits, workers’ repatriation, workers’ passport. Employment agreement and related conditions are available. There are terms of reference or signed contracts between employer and employees stipulating the position, working hours, type of work, location of work, workers’ responsibility, wages, allowances, holidays, rest days, annual leave, fringe benefits, levy deductions (for foreign workers), dismissal, etc. Direct contracts of employment are observed to contain sufficient details on rates of wages and conditions of employment written in the language understood by the workers. Procedurally, a management official will also explain the payment rates and terms and conditions of employment to a newly recruited worker. Random employment agreement verified during the surveillance audit are as follows: Work Field Name Date Joined Manuring Wagiyo 01 Oct 2013 Spraying Abu Munsi 01 January 2014 Harvester Gulzar 01 Oct 2013 Harvester Noman 01 January 2014 General Worker 01 Jul 2011 Hairul (Processing) Fireman Hossain Belal 01 Jul 2011 General Worker 01 Feb 2012 Shabudin (Processing)

However, for contractors who are engaged for the harvesting process, an agreement between the company and the contractors are available, for instance, the contract between Genting Sri Gading Estate and Low Chong Huai dated 01 January 2014 is verified. Observed that the contract contains all prescribed requirements for the contractors to have a valid agreement with the workers. Based on the above, the audit team has verified the following as per example i.e. Negandra’s contract and found that the contract dated 23 October 2013 contains the followings:  Daily Rate;  Off-day;  Overtime rate;  Rate of Allowance workers entitled  Duration of Termination of Notice; GP 7003A Page 48 of 65

 Annual Leave; and  Employment Date. 6.5.2 Labour laws, union agreements or direct contracts of employment detailing Minor payments and conditions of employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc) are available in the language understood by the workers or explained carefully to them by a plantation management official in the operating unit Findings In compliance: Yes: X No: Objective Verification during the audit showed that the contract agreements have been written in the evidence: language understood by the workers. Further verification during the interview with the workers confirmed that they have been appropriately briefed on the terms and conditions of the contract on the day of signing the agreement with the company. With regard to the contractors’ workers, interview with the workers showed that they understood the terms and conditions specified in the contract and that they have been briefed by their peers on the day of signing the agreement. 6.5.3 Growers and millers provide adequate housing, water supplies, medical, Minor educational and welfare amenities in accordance with Workers’ Minimum Standard of Housing and Amenities Act 1990 (Act 446) or above, where no such public facilities are available or accessible (not applicable to smallholders) Findings In compliance: Yes: X No: Objective Housing of adequate quality is provided, with workers generally housed with two persons to a evidence: room. Houses have electricity, piped water, indoor washrooms, sewerage, waste collection service, etc. Medical facilities and services are provided. Education at primary level is supported for children from the estate as well as the surrounding area. Social, cultural and recreational activities and places of worship are supported. Public health services provided in housing areas. Physical amenities are provided, effectively operated and maintained to a standard equivalent to an urban authority. Criterion 6.6: The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel. 6.6.1 Documented minutes of meetings with main trade unions or workers Major representatives

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

With regard to the workers representative, the auditor observed that there is evidence of workers representatives i.e. there is one representing each of the various groups of the workers present such as Indonesian and Philippines, (representing their respective field work) that has been elected in a democratic manner through a voting process by their fellow colleagues. .

Based on interviews made with the workers’ representatives, it was found that they have set up their own committees among themselves to discuss issues concerning their rights i.e. workers welfare, benefits, wages etc. All issues raised are subsequently brought up to the JCC Meeting to be discussed with the management.

In addition, it was also confirmed through worker interviews that currently all matters concerning their rights are channelled via the committee through their respective representatives who are also members of the committee. Based on recordavailable for 2014, the company has conducted the following JCC meetings: Venue Date Genting Sri Gading Estate  26 November 2014;  27 September 2014; GP 7003A Page 49 of 65

 27 February 2014. Genting Sungei Rayat Estate  26 June 2014;  24 March 2014; Genting Ayer Item POM  14 October 2014  16 May 2014

The minutes of the Meetings mentioned above were maintained and made available to the auditing team during the main audit. 6.6.2 A published statement in local languages recognizing freedom of association Minor

Findings In compliance: Yes: X No: Objective The company does not restrict Malaysian nor foreign workers to form workers union. evidence: In all estates and mill, a published statement of policy dated 03 August 2009 in local language recognising freedom of association was placed on the notice board of the management office. The statement reads “Kami melarang segala jenis keganasan, diskriminasi dan gangguan yang berkaitan dengan bangsa, agama, tempat asal, hilang upaya, kehamilan, umur dan jantina. Sesiapa pun tidak akan dinafikan tentang hak infividu, kebebasan untuk menganggotai kesatuan sekerja dan peluang setara” which means “workers are free to follow or participate in any agencies registered under the Malaysian laws. This statement is an addition to the existing workers’ contract from the Management”.

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

Findings In compliance: Yes: X No: Objective Genting Plantations complies to the Employment Act 1955 concerning the employment of evidence: workers. The company has a copy of the policy posted on notice board in the offices of the estates and mill that the company does not employ persons under 16 years old. Personal information of workers showed that all workers are all above 16 years old. There is no evidence of use of children employed both in the mill or estate operations. Employment record shows that the minimum age of employee is 19 years old. Criterion 6.8: Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation union membership, political affiliation or age is prohibited. 6.8.1 A publicly available equal opportunities policy Major

Findings In compliance: Yes: X No: Objective A social policy which states that the company provides equal opportunity for all was available i.e. evidence: People Policy (Polisi Insan) dated 03 August 2009. . The policy is posted on the notice board for public viewing at the entrance of the oil mill. There were no evidences of any form of discrimination based on race, national origin, religion, gender, union and political affiliation and which is covered in the policy as well. In addition, Sexual Harassment Policy dated 03 August 2009 together with SOP on mechanism for the prevention and eradication of sexual harassment and violence in the workplace are also available. 6.8.2 Evidence that employees and groups including migrant workers have not been Minor discriminated against

Findings In compliance: Yes: X No: Objective There is no evidence to show the occurrence of any discrimination against foreign workers. Based evidence: on records, the auditing team observed that equal opportunities are demonstrated through the following issues:  Similar daily wages for foreign and local workers. GP 7003A Page 50 of 65

 Similar working hours and treatment for foreign and local workers.  Basic amenities and facilities are provided on equal terms to foreign and local workers.  Well balanced representation of foreign and local workers in JCC meetings.  Well balanced representation of foreign and local workers in Gender Committee meetings. Interview with workers (including foreign workers) indicates that there is no such discrimination occurs in the workplace. In addition, the auditing team noted that the company is currently implementing the equal opportunities for workers through the followings:  Training is given to the workers on a yearly basis covering training relating to their working station, personnel training such as communication skills and safety and health training;  All employees are covered with working insurance; and  Termination is conducted based on local laws and is stated in the workers employment agreement. Criterion 6.9: A policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied. 6.9.1 A policy on sexual harassment and violence and records of implementation Major

Findings In compliance: Yes: X No: Objective Sexual Harassment Policy dated 03 August 2009 together with SOP on mechanism for the evidence: prevention and eradication of sexual harassment and violence in the workplace are also available. No evidence or practices that contradict this policy were observed. Discussion with female staff shows that the company provide fair and just treatment to women. In addition there is a gender committee and a nominated gender representative established at all estates and mill. Based on records, the meetings were conducted as follows: Estates Date Genting Sri Gading Estate  15 March 2014 Genting Sungei Rayat Estate  31 October 2014 Genting Ayer Item POM  22 May 2014

6.9.2 A specific grievance mechanism is established Minor

Findings In compliance: Yes: X No: Objective A SOP on “Mechanism for the Prevention and Eradication of Sexual Harassment and Violence in evidence: the Work Place” is also in place. The SOP SMP-GPB-20 dated 11 October 2013 specifies the followings:  Definition, o Sexual coercion o Sexual annoyance  Form of sexual harassment o Verbal harassment o Non-verbal/gestural harassment o Visual harassment o Psychological harassment o Physical harassment  Procedures to be taken on sexual harassment,  Flowchart for procedures to be taken on sexual harassment,  Protective and remedial measures,  Form of disciplinary action to be taken, Criterion 6.10: Growers and mills deal fairly and transparently with smallholders and other local businesses. GP 7003A Page 51 of 65

6.10.1 Pricing mechanisms for FFB and inputs/services shall be documented Major

Findings In compliance: Yes: X No: Objective Ayer Item POM has established Sales and Purchase Agreement as the mechanism on FFB evidence: pricing. The Sales and Purchase Agreement contains information : 1.0 Quantity 2.0 Delivery 3.0 Quality 4.0 Weights 5.0 FFB Price Calculation 6.0 Payment 7.0 Insurance 8.0 Legislations/Rules/Guidelines/Schemes 9.0 Force Majeure 10.0 Warranty 11.0 Notice 12.0 Duration Current and past prices paid for FFB are available for inspection at the mill that is found to be supplied by the HQ of the company. Copies of Sales and Purchase Agreement signed by the mill management with independent suppliers are available for verification during the audit i.e. Agreement between the company and the following independent small-growers:  Wong Ton Yang dated 01 June 2014;  Sia Tian Ho dated 01 January 2014; and  Low Tong Seng dated 01 January 2014 6.10.2 Current and past prices paid for FFB shall be publicly available Minor

Findings In compliance: Yes: X No: Objective Ayer Item Palm Oil Mill posts the prevailing FFB price obtained daily from MPOB website at the evidence: weighbridge station for the viewing convenience of the independent FFB suppliers. In addition, the small-growers can also contact the mill directly for information on the latest FFB price. 6.10.3 Evidence that all parties understand the contractual agreements they enter into Minor and that contracts are fair, legal and transparent

Findings In compliance: Yes: X No: Objective Based on the above verified contract an agreement, the audit team notes that the contracts have evidence: been established in the English language. Random interview with the representatives from the above mentioned suppliers during the audit showed that they are able to understand the contractual agreements as well as the terms and conditions stated in the agreement. 6.10.4 Agreed payments shall be made in a timely manner Minor

Findings In compliance: Yes: X No: Objective Based on the contract, the payment shall be made in three phases i.e. 18th day, 28th day (present evidence: month) and 10th day of the following month after the shipment of the FFB. Based on records, the audit team notes that the payment has been made in a timely manner as per required by the contracts. For instance, payment for Mr. Low for November has been made on 17 November 2014 (for shipment from 01 Nov to 15 Nov), 28th Nov (shipment from 16 Nov to 25 Nov) and 7th Dec (for shipment from 26 to 30 Nov). GP 7003A Page 52 of 65

Criterion 6.11: Growers and millers contribute to local sustainable development wherever appropriate. 6.11.1 Demonstrable contributions to local development that are based on the results of Minor consultation with local communities

Findings In compliance: Yes: X No: Objective The individual estates and the mill have a very basic form of corporate social responsibility (CSR), evidence: which usually involves stakeholders, especially the local communities and workers. In general, the following events and contributions have been rendered by the company:  religious celebrations;  Opportunities for employment for local communities;  family day,  donation to school i.e. fire extinguisher  estate school children education aid  blood donation;  medical check-up for malaria and filiarisis diseases; and  sports day. All activities and contribution rendered are recorded for each of the financial year.

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

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

Findings In compliance: Yes: x No: Objective In GSRE, under the Continuous Improvement file, they have identified Paraquat , methamidophos evidence: and rat bait as some of the chemicals that they plan to reduce or minimize. For Paraquat , they plan to eliminate the use by July 2015. Alternative herbicides like Basta and Glyphosate are being tested for its effectiveness. However for Stenochlaena , study is still being done to find a better alternative to Paraquat. For rat problem , they plan to initiate an ‘Import Barn Owl project’ to increase the population to improve the present barn owl occupancy rate of: a) Bangkar : 48% b) Tanjung: 49% c) Sing Mah: 30% For bagworm, they plan to increase the planting of beneficial plants i.e. Cassia sp, Antigonon sp and Turnera sp. 8.1.2 Environmental impacts (C 5.1) Major

Findings In compliance: Yes: x No: GP 7003A Page 53 of 65

Objective For Genting Sri Gading Estate and Genting Sungei Rayat Estate, environmental aspects and evidence: impacts assessment were updated on 25/11/2014 and 2/12/2014 respectively. The assessment includes all the activities in the plantations such as pesticide spraying, manuring, chemical receiving and storage etc. The environmental impact aspect assessment (doc no: SP-MGR-02-F01-2 dated 03 September 2014) have included all the activities in the different locations such as generation of steam in boiler and generation of electricity in engine room, agrochemical waste handling & management- Chemical storage, application and usage of fertilizer/ pesticides.

8.1.3 Maximizing recycling and minimizing waste or by-products generation Major

Findings In compliance: Yes: x No: Objective The mill uses various methods to recycle its processing wastes satisfactorily. The systems evidence: implemented include: a. Decanter cake- Mixed with sludge to form slurry and sprayed onto EFB in the composting plant b. Boiler ash-applied onto fields with low pH c. EFB-used as boiler fuel d. EFB fibre-100% used in composting e. Kernel shell- sell f. POME effluent- used back in land irrigation 8.1.4 Pollution prevention plans (C 5.6) Major

Findings In compliance: Yes: x No: Objective Pollution prevention plans dated 28th November 2014 is already in operation for different sources evidence: of pollution identified: a. The POME is not discharged into waterways. The Oil Mill has a licence No: 002156 from the DOE for discharge the POME under the category ‘Atas Tanah’ or Land application. The nearest river, Sg Linau is about 5 km away from the site of the land application. b. The Mill complies with the local DOE A.S 4 to submit analysis of the POME every quarterly. Based on the licence, the allowable BOD limit is 500mg/l. c. Boilers- Chimney; Installed Multi-Dust Cyclones, stack monitoring

8.1.5 Social impacts (C 6.1) Major

Findings In compliance: Yes: x No: Objective The documented Social Impact Assessment (SIA) dated 18 September 2014 (Genting Sri Gading evidence: Estate) and 16 September 2014 (Genting Sungei Rayat Estate and Genting Ayer Item POM) are available.

The documents listed a series of sections relating to social of which one of it is on Social Impact Assessment that summarizes the issues raised by both external and internal stakeholders as well as actions to be taken. 8.1.6 A mechanism to capture the performance and expenditure in social and Minor environmental aspects

Findings In compliance: Yes: x No: Objective The individual estates and the mill have a very basic form of corporate social responsibility (CSR), evidence: which usually involves stakeholders, especially the local communities and workers. In general, the following events and contributions have been rendered by the company:  religious celebrations;  Opportunities for employment for local communities;  family day,  donation to school i.e. fire extinguisher  estate school children education aid  blood donation; GP 7003A Page 54 of 65

 medical check-up for malaria and filiarisis diseases; and  sports day. All activities and contribution rendered as well as activities for pollution management and environmental monitoring is recorded for each of the financial year.

3.1.2 Supply Chain (Module E used by the mill) For supply chain, Genting Ayer Item Mill has decided to adopt the Module E (CPO Mill: Mass Balance) for this assessment. The findings and objective evidence found during the assessment are outlined in the table below. The results for each indicator from each of the operational areas were evaluated to provide an assessment of conformity. A statement is provided for each of the RSPO indicators in order to support the findings of the assessment team. As to date, there is no any transaction for RSPO certified product yet for Genting Ayer Item Mill. Module E- CPO Mill: Mass Balance

Module E.1: Documented Procedures Criterion E.1.1: The facility shall have written procedures and/or work instructions to ensure the implementation of all the elements specified in these requirements. E.1.1.1 Complete and up to date procedures covering the implementation of all the elements in these requirements

Findings In compliance: Yes: x No: Objective The company has the up to date procedures titled: Supply Chain, Traceability and Mass Balance evidence: (doc no: SMP-GPB-23; dated 21st November 2014) The procedures describe the improved controls on Mass Balance and Traceability. E.1.1.2 The name of the person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements

Verifiers and guidance: This person shall be able to demonstrate awareness of the facilities procedures for the implementation of this standard. Findings In compliance: Yes: x No: Objective As stated in the procedures clause 11.0: Assistant Mill Engineer or Chief Clerk can be appointed evidence: by Mill Manager as a responsible person. In Genting Ayer Item Mill, Mohd Isa as the chief clerk is the person in charge and he demonstrated awareness for the implementation of Supply Chain system. Criterion E.1.2: The facility shall have documented procedures for receiving and processing certified and non- certified FFBs. Findings In compliance: Yes: x No: Objective As stated in the procedure clause 7.0, RSPO certified FFB suppliers are stamped with valid evidence: RSPO stamps before the load can be weighed. If the valid RSPO stamp is not sighted, the WB shall not weigh the load before verification by the certified FFB suppliers.

Module E.2: Purchasing and Goods In Criterion E.2.1: The facility shall verify and document the volumes of certified and non-certified FFBs received. Findings In compliance: Yes: x No: Objective In the procedure, flowchart on overview of Traceability, Mass Balance and Bookkeeping evidence: Procedures is available. It describes procedures in receiving certified FFB and non-certified FFB suppliers. The chief clerk updates FFB received records in MB worksheet on monthly basis. Criterion E.2.2: The facility shall inform the CB immediately if there is a projected overproduction. Findings In compliance: Yes: x No: GP 7003A Page 55 of 65

Objective Up to date, there is no overproduction. evidence:

Module E.3: Record Keeping Criterion E.3.1: The facility shall maintain accurate, complete, up-to-date and accessible records and reports covering all aspects of these requirements. Findings In compliance: Yes: x No: Objective Up to date, the company does not have any certified crops. evidence: The documents and records available such as: a) RSPO Supply Chain training record b) Weighbridge ticket c) Production Report d) Delivery order e) Sales contract Criterion E.3.2: Retention times for all records and reports shall be at least five (5) years. Findings In compliance: Yes: x No: Objective As stated in the procedures clause, the retention times for all records and reports shall be at least evidence: 10 years Criterion E.3.3 a. The facility shall record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO, PKO and palm kernel meal on a three-monthly basis. b. All volumes of palm oil and palm kernel oil that are delivered are deducted from the material accounting system according to conversion ratios stated by RSPO. c. The facility can only deliver Mass Balance sales from a positive stock. However, a facility is allowed to sell short. Findings In compliance: Yes: x No: Objective Up to date, the mill did not purchase/sales any certified FFB. evidence: The company demonstrates sample records and update the accumulated volume of certified and non-certified FFB’s received in the POM on monthly basics. Criterion E.3.4: The following trade names should be used and specified in relevant documents (e.g. purchase and sales contracts, *product name*/MB or Mass Balance). The supply chain model used should be clearly indicated. Findings In compliance: Yes: x No: Objective Based on the mock up sales contract from mill’s HQ, the trade name and supply chain model are evidence: clearly indicated. Criterion E.3.5: In cases where a mill outsources activities to an independent palm kernel crush, the crush still falls under the responsibility of the mill and does not need to be separately certified. The mill has to ensure that the crush is covered through a signed and enforceable agreement. Findings In compliance: Yes: x No: Objective The mill did not outsource activities to an independent palm kernel crusher and the palm kernel is evidence: only sold locally.

Module E.4: Sales and Good Out Criterion E.4.1: The facility shall ensure that all sales invoices issued for RSPO certified products delivered include the following information: a) The name and address of the buyer b) The date on which the invoice was issued GP 7003A Page 56 of 65

c) A description of the product, including the applicable supply chain model (Segregated) d) The quantity of the products delivered e) Reference to related transport documentation Findings In compliance: Yes: x No: Objective Up to date, no production of any RSPO certified product yet. evidence: The sales contract will be prepared by Headquarter instead of mill and will be checked during surveillance audit. The requirements all describe in the clause 7.7.5 and clause 9 of the Procedure: Supply Chain, Traceability and Mass Balance.

Module E.5: Training Criterion E.5.1: The facility shall provide the training for all the staff as required to implement the requirements of the Supply Chain Certification System. Findings In compliance: Yes: x No: Objective The training was conducted on 3 Dec 2014 and all the relevant personnel have joined the training evidence: such as: assistant manager, chief clerk, office clerk, weighbridge officers etc.

Module E.6: Claims Criterion E.6.1: The facility shall only make claims regarding the use of or support of RSPO certified palm oil that are in compliance with the RSPO Rules for Communication and Claims. Findings In compliance: Yes: x No: Objective Up to date, the facility did not use any claim. evidence:

3.2 Corrective Action Requests A total of 2 Majors and 1 Minor were raised. Please refer to the Appendix A for the detailed findings and relevant correction actions that have been taken.

3.3 Noteworthy Positive & Negative Observations There were 07 Observations raised. Please refer Appendix A. The noteworthy positive points are as follows: a. Field Workers and Mandores – Ability to demonstrate correct, safe and healthy practices during the field audit in complying with the standard is commendable e.g. PPE b. Staff and executives: Transparency and openness in cooperating with the auditors throughout the audit – able to provide the necessary documents and records for smooth auditing is highly appreciated.

3.4 Status of Non-Conformities Previously Identified This is the main audit.

3.5 Issues Raised by Stakeholders and Findings GP 7003A Page 57 of 65

A list of stakeholders contacted is included as Appendix C. Stakeholders did not provide any comments in writing regarding the Genting Plantations Berhad’s environmental and social performance and commitment. All interviewed stakeholders have positive comments about Genting Plantations. GP 7003A Page 58 of 65

4. ACKNOWLEDGEMENT OF ORGANIZATION INTERNAL RESPONSIBILITY 4.1 Date of Next Surveillance Visit The next surveillance audit is planned before November 2015.

4.2 Date of Closing Non-Conformities

Reference Class Issued Closed

m01 Minor 18 Dec 14 M02 Major 18 Dec 14 30 Jan 2015 M03 Major 18 Dec 14 30 Jan 2015

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

GP 7003A Page 59 of 65

APPENDIX A: CORRECTIVE ACTION REQUEST & OBSERVATION

CAR # Indicator CAR Detail Date Next Date 18 Dec 14 Due Date> 30 Jan 2015 Recorded> surveillance Closed> Non-Conformance:

Water management program did not include peat area in GSRE’s Sing Mah Division. Objective Evidence: m01 4.3.4 No documented evidence was available to show that subsistence of peat is minimized through an effective and documented water management program. In addition no documented evidence was found to show that subsidence has ceased in the peat area (GSRE Sing Mah Division.) Close-out evidence: The water management at peat area had been included in the water management programme dated 2nd Han 2015. Study/assessment in progress to proved the cease of peat subsidence. Date Date 18 Dec 14 Due Date> 18 Feb 15 30 Jan 2015 Recorded> Closed> Non-Conformance:

Riparian buffer zones was not completely maintained and restored appropriately. Objective Evidence: However in GSGE, F96A there seemed to be some spot spraying of woodies done within the riparian buffer zone. M02 4.4.1 In GSRE, the riparian buffer zone in F84C was visited and there were evidence of some spraying done on the marked palms as well as within the area. Close-out evidence: Retrain the sprayers, manuring workers and Mandores. Training done on 30th Dec 2014 and 8th Jan 2015 for GSRE and GSGE respectively. Training assessment was carried out on 9th Jan 2015. All the participants are aware of maintaining Riparian buffer zones where spraying and fertilizer applications are strictly disallowed. Date Date 18 Dec 14 Due Date> 18 Feb 15 30 Jan 2015 Recorded> Closed> Non-Conformance:

No written justification in SOP for agrochemical used. Objective Evidence: M03 4.6.5 SOP for the all agrochemicals is available, however, no written justification of all agrochemical use was sighted although recommendations for the use of the chemicals is provided in the SOP manual. Close-out evidence: Document “SOPs and Written Justification for Pesticides Used”: Doc No: SMP-GBP-28 describe the justification for the usage for different types of Pesticides.

OBSERVATIONS

OBS # Indicator Observation Detail Date Date 18 Dec 14 Due Date> N.A Recorded> Closed>

OBS 01 4.4.7 Non-Conformance: Incomplete water management plan. Objective Evidence: GP 7003A Page 60 of 65

OBS # Indicator Observation Detail The water management plan for the peat area for GSRE Sing Mah Division was not included in the plan. Date Date 18 Dec 14 Due Date> N.A 30 Jan 2015 Recorded> Closed> Non-Conformance:

One of the workers did not undergo the medical surveillance. Objective Evidence: Evidence was presented to show that Mr Mahrudin went back for vacation 9/3/14 – 3/5/14 and OBS 02 4.6.1 he missed his annual surveillance. However till the date of main audit, he has not been sent for a medical surveillance. Close-out evidence: Sent the missed out Sprayer to Annual Medical Surveillance on 24th Dec 2014. Prepare Check list and continue monitoring. The above sprayer was sent to Annual Medical Surveillance and certified fit for spraying work. Verified the certificate of fitness and confirmed that Mr Mahrudin is fit for the work. Date Date 18 Dec 14 Due Date> N.A Recorded> Closed> Non-Conformance:

Documentary evidence that use of paraquat did not indicate the trend is reducing and/or OBS 03 4.6.7 eliminated. Objective Evidence: In GSGE, it is noted that from the records, paraquat usage is not reduced or eliminated. Close-out evidence:

Date Date 18 Dec 14 Due Date> N.A Recorded> Closed> Non-Conformance:

No specific procedures for the trunk injection operation which is important for the training of the operators. OBS 04 4.8.1 Objective Evidence: The evaluation form did not touch on the specifics of the procedure related to the trunk injection operation e.g dosage, PPE required, height of the drill etc. Close-out evidence:

Date Date 18 Dec 14 Due Date> N.A Recorded> Closed> Non-Conformance:

Evidence of a commitment to discourage any illegal or inappropriate hunting, fishing or collecting activities at Sungei Rayat - Bindu Forest Reserve is not sighted. OBS 05 5.2.3 Objective Evidence: The signage to discourage hunting was not sighted bordering Bindu Forest Reserve at Sungei Rayat. Close-out evidence:

Date Date 18 Dec 14 Due Date> N.A OBS 06 5.3.2 Recorded> Closed> Non-Conformance: GP 7003A Page 61 of 65

OBS # Indicator Observation Detail Hazardous waste was not properly disposed. Objective Evidence: In GSRE, although a worker has been appointed to segregate the domestic waste from line- site prior sending to landfill, organic material and scheduled waste (bottle 2D oil) were still found in the recycle bin. It indicates that the workers lack of awareness in segregation of domestic waste at source. Close-out evidence:

Date Date 18 Dec 14 Due Date> N.A Recorded> Closed> Non-Conformance:

No proper channel i.e. through District Forest Office for the engagement and communication made with the department observed at both Sri Gading and Sungei Rayat Estates which is bordering with Soga FR and Bindu FR respectively. Objective Evidence: With regard to the engagement with the Forestry Department the audit team notes that there is no proper channel i.e. through District Forest Office for the engagement and communication OBS 07 6.2.3 made with the department observed in both Sri Gading and Sungei Rayat Estates which is bordering with Soga FR and Bindu FR respectively; pertaining to the conservation and enforcement of both Forest Reserves. Interview with the District Forest Officer (DFO) of Kluang during the on-site stakeholder consultation showed that the District Forest Office has not received any official engagement and communication made by the company. Based on the above, the DFO is of the view that for any communication to be made with the Forestry Department must go through the District Forest Officer for any matters pertaining to the conservation and enforcement on the FRs within its district. This can ensure proper collaboration and smooth enforcement can be made between both parties. Close-out evidence:

GP 7003A Page 62 of 65

APPENDIX B: NON-CONFORMITIES PREVIOUSLY IDENTIFIED

This is a main assessment audit

GP 7003A Page 63 of 65

APPENDIX C: TIMEBOUND PLAN

Jan Feb Mac Apr May Jun Jul Aug Sep Oct Nov Dec

Genting Ayer Item 2014 Oil Mill (covering 3 group estates) **

Genting Central Region Northern Sabapalm Oil Mill (covering 4 Region 2015 (covering 1 group group estates) (covering 2 estate) *** *** group estates) ***

PT Mulia Oil Mill Genting Genting (covering 4 group Jambongan Oil Tanjung Oil Mill 2016 estates) *** Mill (covering 1 (covering 5 group estate) *** group estates) ***

Genting Mewah Oil Genting PT Golden Hill Genting Indah Mill (covering 1 group Trushidup Oil Mill Oil Mill (covering Oil Mill 2017 estate) *** (covering 2 group 3 group estates) (covering 3 estate) *** *** group estate) ***

PT GAL Oil Mill

2018 (covering 1 group estate) ****

PT SAP Oil Mill (planning for 2019 construction) (covering 1 group estate) *** * Certified Oil Mill ** Completed the Audit *** In Preparation **** Under construction

GP 7003A Page 64 of 65

APPENDIX D: LIST OF STAKEHOLDERS CONTACTED

Stakeholder Type of Issues raised Comments/Action Stakeholder Taken

Johor State External The Department is Refer Indicator 6.2.3 for details Forestry Stakeholders positive towards the Department – - Government client and based on interview conducted, Kluang District authorities there are no negative Forest Office issues highlighted by the Department against the management of the client, except on the engage and mutual communication between two parties pertaining to the Soga FR and Bindu FR that are bordering the Genting Sri Gading and Genting Sungei Rayat Estates respectively. Harvesters, Internal The stakeholders are Not applicable as no sprayers, Stakeholders generally happy with the issues were raised manurers, company. They also confirmed that the Mandores company has briefed ,staff , HA , etc them on the implementation of the new minimum wages rules. All wages are paid timely and are in accordance with jobs executed by the workers. NUPW External The stakeholder Not applicable as no Representative stakeholder – interviewed is generally issues were raised. happy on the company’s NGO For further elaboration, approach towards the please refer Indicators (Workers workers pertaining to the 6.5.1 and 6.5.3 Union) following:

 Wages – has implemented the minimum wages rules as agreed;

 Amenities – feedback received from the workers showed they are generally happy on the amenities given to them. Mr. Sia Tian External No issue was raised. In Not applicable as no Ho & Mr. Low Stakeholder general, the discussion issues were raised

GP 7003A Page 65 of 65

Tong Seng – FFB is mainly to fulfill the For further elaboration, Supplier Criterion 6.10 please refer findings requirement. Based on within Criterion 6.10 the feedback received, the audit team notes that both of them have signed a valid agreement with the company pertaining to the purchase and sale agreement of FFB. In addition, there is also no issue pertaining to the pricing of FFB which has been periodically updated by the company to them. Furthermore, the payment made by the company to the suppliers are on time as per in the agreement. Mr. Low External No issue was raised. In Not applicable as no Chong Huai Stakeholder general, the discussion issues were raised is mainly to fulfill the – Harvesting For further elaboration, Indicators 6.5.1 and please refer findings Contractor 6.5.2 requirement. within Indicators 6.5.1 & Based on the feedback 6.5.2 received, the audit team notes that the contractor has a valid agreement signed between him and the company. With regards to the agreement with his workers, the audit team notes that he has established an agreement that is in line with the requirement of Employment Act 1955.

Hafiz Waste Waste segregation; Interviewed with the segregation recycling person in charge for waste segregation.

Weighbridge Worker Supply Chain System Supply Chain ticket officer: implementation Hissam