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CCI-QP-07-07A 1 Assessment Report Date: 24 th October to 26 th October 2018 Company name Atlas Group of Companies - Atlas Batang Melaka Estate - Atlas Paloh Rubber Estate - Atlas Pagoh Muar Estate - Serkam Estate - Gading Estate Address HQ address : 12, Jalan Bukit Gedong, 75050 Melaka. Report no MS18MM0023 Status of audit Main Assessment If surveillance NA [Disclaimer: The audit report has been generated to reflect the compliance of the company toward the MSPO standard and every criterion’s have been in every effort taken to ensure the accuracy of the assessment and reporting produced. As the assessment is been carried out based on sampling, certain areas or processes may not be able to verified on its compliances. ] MSPO 253O:2013 Part 3

Date: 07 October 2013cciglobe.com/files/AP_MAV.pdf- Serkam Estate - Gading Estate Address HQ address : 12, Jalan Bukit Gedong, 75050 Melaka. Report no MS18MM0023 Status of audit Main

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  • CCI-QP-07-07A

    1

    Assessment

    Report

    Date: 24th October to 26th October

    2018

    Company name Atlas Group of Companies

    - Atlas Batang Melaka Estate

    - Atlas Paloh Rubber Estate

    - Atlas Pagoh Muar Estate

    - Serkam Estate

    - Gading Estate

    Address HQ address : 12, Jalan Bukit Gedong, 75050 Melaka.

    Report no MS18MM0023

    Status of audit Main Assessment If surveillance NA

    Date: 07 October

    2013

    [Disclaimer: The audit report has been generated to reflect the compliance of the company

    toward the MSPO standard and every criterion’s have been in every effort taken to ensure

    the accuracy of the assessment and reporting produced. As the assessment is been carried

    out based on sampling, certain areas or processes may not be able to verified on its

    compliances. ]

    MSPO 253O:2013

    Part 3

  • CCI-QP-07-07A

    2

    Thank you for your trustful cooperation during our audit of your organization. This report has been prepared of

    every effort to ensure the accuracy of the information recorded. The assessment is based on sampling on the

    records, practice, documents and personnel, therefore the final results of the assessment is of representative

    towards the system implementation of the organization. This report may generated to record as much of the

    system implementation information but may still limited due to the sampling .This report details the assessment

    results including strengths, opportunities, and weaknesses. These results were presented to your management at

    the closing meeting of the audit. You can use these results to improve the effectiveness of your management

    system. We look forward to continuing our partnership towards sustainable business success. This report has been

    prepared in compliance to the ISO 17021:2011 requirements.

    To ensure the next assessment will be carry out in compliance to the ISO 17021:2011, please remember to

    immediately notify CARE Certification International about any significant change to your company at any point of

    time. Together we will then coordinate appropriate measures to maintain your current certification. Such

    circumstances include, for example, changes relating to the legal, commercial, organizational status or ownership,

    organization and management (e.g. key managerial, decision making or technical staff), contact address and sites,

    scope of operations under the certified management system, and major changes to the management system and

    processes. Together we CARE and will then ensure the smoothness of the upcoming assessment. Thank you for

    your persistence of support.

    Signed for on behalf of CCI Signed for on behalf of client

    Sign

    Name Mohamad Zulkefli Bin Md Isa Company stamp

    Date 24-26/10/2018

    Email [email protected]

    Fax no 038073 2688

  • CCI-QP-07-07A

    3

    Section A General Information General

    Audit objectives

    To verify that the system initial implementation is in accordance

    to requirements of the standard adopted.

    To verify that the system implementation is continuously in

    accordance to the requirements of the standards adopted.

    To verify that the system implementation is continuously after

    and in third years of implementation is in accordance to the

    standards adopted.

    Other, (please specify)

    Integrate Assessment No

    Issue of certificate Yes

    Scope of Certification

    Scope of certification in English The Provision of Planting and Harvesting of Fresh Fruit Bunch (FFB) By Organised Plantation

    Requirement not being applicable P7 - Development of New Planting

    Justification The company doesn’t have any new planting activities.

    Other language than above NA

    Changes from Previous registration No

    Extension/changes of scope date NA

    Contact Details

    Management Representative Edwin Tan Keng Kum

    Alternate contacts Chee Teng Heng

    Management Representative contact no. +6012 780 4818

    E-mail address [email protected]

    Fax Number 06-2842 987

    Fixed Line Number 06-2824 290

    NO OF SPOC/ GROUP MEMBERS 5

    Section B Previous Audit Result The result of the last audit system have been reviewed, in particular to ensure appropriate correction and

    corrective action has been implemented to address any nonconformities identified. This review has concluded

    that:

    No nonconformities have been raised during last assessment.

    Any nonconformities identified during last previous audit have been corrected and the corrective action continuous

    to be effective.

    The management system has not adequately addressed non conformity identified during previous audit

    activities and the specific issue has been re-defined in the nonconformity section of this report.

  • CCI-QP-07-07A

    4

    Section C Conclusion

    The audit team conducted a process based audit focusing on significant aspects/risk objectives required by

    the standard(s). The audit methodology used is based on 3P which were People, Paper and Practice.

    The audit team concludes and express

    CONGRATULATION and has

    CONGRATULATION however some processes need to address non-compliance(s) but others has

    SORRY and the organization has not established and maintained its management system in line with the

    requirements of the standard and

    demonstrated

    not demonstrated

    the ability of the system to systematically achieved agreed requirements within the scope of the

    organizations.

    Base on the record, there is/are NIL unresolved issue.

    Therefore the audit team recommends that based on the results of this audit and the system's

    demonstrated state of development and maturity, management system certification be:

    Granted (initial certification or recertification)

    Granted upon the acceptance of the noncompliance(s)

    Continued (surveillance)

    Continued (surveillance) upon the acceptance of the noncompliance(s)

    Withheld

    suspend until satisfactory corrective action(s) is completed

    Others (please specify)

    Note :

    The assessment and recommendation for the initial or continue was based on random samples and therefore

    nonconformities may exist which have not been identified. All the pages should be attached if the organization wishes to

    copy and delivered to the interested party.

    Section D (For Recertification only)

    1 The company has demonstrated effective implementation and maintenance/improvement on its

    management system

    Yes No

    2 The internal audit program has been fully implemented and demonstrates its effectiveness as a

    tool for maintaining and improving the management system.

    Yes No

    3 The management review process demonstrates its capability to ensure the continuing suitability,

    adequacy and effectiveness of the management system

    Yes No

    3 The management review process demonstrates its capability to ensure the continuing suitability,

    adequacy and effectiveness of the management system

    Yes No

    4 Throughout the audit process, the management system demonstrates overall conformance with

    the requirements of the audit standard

    Yes No

  • CCI-QP-07-07A

    5

    Section E Auditor and Auditees Names

    CCI Assessors

    Attendance during opening and closing meeting

    Team leader Name Designation

    Mohamad Zulkefli Md Isa As per attached Attendance List

    Team member

    Badrul Hisham Bin Hj Baharin

    Mohammad Hafizuddin Bin Rossley

    Mohamad Hafis Bin Mustafa

    Trainee auditor

    NA

    Observer

    NA

    Section F Audit Process Matrix

    Next Audit Matrix (legend “ ” plan to cover & covered, “ ” for uncover)

    Planned month & year 07/2018 07/2019 07/2020 07/2021 07/2022

    Internal Audits

    Stakeholder consultation / survey

    Use of logo

    Follow-up from previous audit finding

    4.1 Management Commitment & Responsibility

    4.1.1 MSPO Policy

    4.1.2 Internal audit

    4.1.3 Management Review

    4.1.4 Continual Improvement

    4.2 Transparency

    4.2.1 Transparency of information and documents relevant

    to MSPO requirements

    4.2.2 Transparent method of communication and

    consultation

    4.2.3 Traceability

    4.3 Compliance to legal requirements

    4.3.1 Regulatory requirements

    4.3.2 Land use rights

    4.3.3 Customary rights

    4.4 Social responsibility, health, safety and employment condition

    4.4.1 Social impact assessment (SIA)

  • CCI-QP-07-07A

    6

    4.4.2 Complaints and grievances

    4.4.3 Commitment to contribute to local sustainable

    development

    4.4.4 Employees safety and health

    4.4.5 Employment conditions

    4.4.6 Training and competency

    4.5 Environment, natural resources, biodiversity and ecosystem services

    4.5.1 Environmental management plan

    4.5.2 Efficiency of energy use and use of renewable energy

    4.5.3 Waste management and disposal

    4.5.4 Reduction of pollution and emission

    4.5.5 Natural water resources

    4.5.6 Status of rare, threatened, or endangered species

    and high biodiversity value area

    4.5.7 Zero burning practices

    4.6 Best Practices

    4.6.1 Site management

    4.6.2 Economic and financial viability plan

    4.6.3 Transparent and fair price dealing

    4.6.4 Contractor

    4.7 Development of new planting

    4.7.1 High biodiversity value NA

    4.7.2 Peat land NA

    4.7.3 Social and Environmental Impact Assessment (SEIA) NA

    4.7.4 Soil and topographic information NA

    4.7.5 Planting on steep terrain, marginal and fragile soils NA

    4.7.6 Customary land NA

    Assessment man days for the next assessment : 8 md. Recertification: 2023

    Note: Recertification should be carry out minimum 2 months prior to the expiry of the certificate

    Section G Audit Summary Summary of Area Audited

    BUSINESS AREAS DETAILS OF AUDITED SUMMARY

    Auditor Date Time

    ZU 24-26/10/2018 8.30

    Opening Meeting

    a) introduction of the participants, including an outline of their roles; b) confirmation of the scope of certification; c) confirmation of the audit plan (including type and scope of audit, objectives and criteria), any changes, and other relevant

    arrangements with the client, such as the date and time for the closing meeting, interim meetings between the audit team

    and the client's management;

    d) confirmation of formal communication channels between the audit team and the client; e) confirmation that the resources and facilities needed by the audit team are available; f) confirmation of matters relating to confidentiality; g) confirmation of relevant work safety, emergency and security procedures for the audit team; h) confirmation of the availability, roles and identities of any guides and observers; i) the method of reporting, including any grading of audit findings; j) information about the conditions under which the audit may be premature terminated; k) confirmation that the audit team leader and audit team representing the certification body is responsible for the audit and

  • CCI-QP-07-07A

    7

    shall be in control of executing the audit plan including audit activities and audit trails;

    l) confirmation of the status of findings of the previous review or audit, if applicable; m) methods and procedures to be used to conduct the audit based on sampling; n) confirmation of the language to be used during the audit; o) confirmation that, during the audit, the client will be kept informed of audit progress and any concerns; p) opportunity for the client to ask questions.

    Closing Meeting

    a) informing the client that the audit evidence collected was based on a sample of the information; thereby introducing an element of uncertainty

    b) the method and timeframe of reporting, including any grading of audit findings; c) the certification body's process for handling nonconformities including any consequences relating to the status of the

    client's certification;

    d) the timeframe for the client to present a plan for correction and corrective action for any nonconformities identified during the audit;

    e) the certification body's post audit activities; f) information about the complaint handling and appeal processes. g) Any diverging opinion that are not resolved. h) opportunity for the client to ask questions.

    Executive Summary

    Organisation Information Atlas Group of Companies was established in Melaka and the head quarters office address as above. The compnay

    currently operated 5 estates situated in Melaka and Johor. The estate are: 1) Atlas Batang Melaka Estate 2) Atlas Paloh Rubber Estate

    3) Atlas Pagoh Muar Estate 4) Serkam Estate 5) Gading Estate

    Assessment Process

    This is group certification for Atlas Group of Companises where the company hold 5 estates under their management. The determination of the sample size are as per Malaysian Sustainable Palm Oil (MSPO) Risk Management (Doc No: MPOB/MSPO/RMP/06 dated 19 Nov 2013).The audit was based on the MSPO2503:2013 Part 3 Standard, procedure

    and other applicable requirements. The audit was devided into 2 which is Stage 1 and Stage 2. There is no issue during the 1st Stage Audit conducted on 03/09/2018 conducted by Mohamad Hafizuddin and Badrul Hisham and found all the required document, procedure and form are available.

    Stage 2 audit was held on 24-26/10/2018 where the sample size of the audit is 4 eststes. The calculation of the sample size determination are as below:

    S= √n (RF) S= sample size, n= number of estate, RF= Risk Factor S=√5 (1.5) = 2.23 X 1.5 = 3.3

    S= 4 estates Base on sampling 4 estate were selected for this assessment . Below are the estates name which been selected for the

    asssessment : i. Atlas Paloh Rubber Estate ii. Serkam Estate

    iii. Atlas Batang Melaka Estate iv. Gading Estate

    For Stage 2 audit required 10 mandays including the stakeholder consultation. Audit Team

    The audit was lead by Mr Mohamad Zulkefli who are have almost 8 years in the sustainable certification and other management system certification such as RSPO, ISCC, ISO 14001, ISO9001 etc and also attended the MSPO Lead Assessor Course conducted by SIRIM. The Co auditor :

    1. Mohamad Hafis Bin Mustafa as an Auditor for the Occupational Safety and Health Aspects, Environmental Aspects etc. 2. Mohammad Hafizuddin bin Rossley as Auditor for Good Practice in Plantation Management and Palm Oil Mill and

    New Planting Plantation. 3. Badrul Hisham bin Baharin as Auditor for Good Practice in Plantation Management and Palm Oil Mill and New Planting Plantation.

    The Stakeholder consultation was conducted by Mr. Badrul Hisham.

    Stakeholder Consultation

    Stake holder consultation conducted on 24-25/10/2018 with two site which is Atlas Paloh Rubber Estate and Serkam

    Estate. Conducted by auditor - En Badrul Hisham Hj Baharin

  • CCI-QP-07-07A

    8

    Date: 24/10/2018

    Time: 10.00 am Venue: Office, Atlas Paloh Rubber Estate

    List of attendance: 1. Gan Ser Heng - Harvesting & Spraying Contractor. 2. Lim Guan Cher - Fruits Dealer, EURO Oil Sdn Bhd

    3. Koperal Zaili Bin Ismail - Pondok Polis Kangkar Baru. 4. Khairunazmi - MODOS’S Estate 5. Lai Tong Yeun - Chong Fatt Hardware

    Ghan Ser Heng (contractor harvesting/sparying) Since 30 years.

    Already brief for MSPO from estate assistant manager. Payment is good. Estate provided houses to contractor workers. 17 harvesters and 4 sprayers. Water supply is free and electricity need to pay. Got agreement and will continue once a year. Payment paid by cash. All his workers were provided with PPE during working. No pending payment. Legal

    workers from Indonesia. He knows about complaint form and understand how to make a complaint. Lim Guan Cher (EURO Oils Sdn Bhd) – Fruit Dealer

    Miss Lim never come to stakeholders meeting before. She do not knowsthere is an opportunity to make a compliant and how to make a complaint. Her business more than 28 tahun in this estate as FFB dealer at Paloh. She also has their own lorry transport. The nearest mill is at Batu 8, Labis. This company also do harvesting, pruning and spraying services

    to smallholders nearby. Koperal Zaili Bin Ismail and Koperal Nazmi.

    They attended the stakeholders meeting. Since 5 years ago service in this area. No issue until this time of review. Estate establish a good repo with Pondok Polis Kangkar Baru. No safety issue and crime. CSR from estate such as Rumah Terbuka Hari Raya etc.

    Khairunazmi (MODOS’S Estate) Asst. Mgr Ldang Mados Paloh. Distance 4km from Atlas estate. Atlas Paloh Rubber estate is negbour with MODOS

    estate. Got boundary stone and trenching. Always invite Atlas estate for any event such as Maulidur Rasul etc. never attend to atlas stakeholders meeting due to busy. No issue on boundary, workers abundant etc. Always hope that Atlas plantation support each other and response to MSPO requirement.

    Lai Tong Yeun (Chong Fatt Hardware) This company supply agricultural tools and equipment. Since 20 years ago supply tools to Atlas. The shop is about

    4km from estate. Attend the stakeholders meeting in the estate. This company also do some civil works such as line site repair and electrical repair. No issue of payment until this time of review. No sexual harassment issue.

    25/10/2018 - Serkam Estate Gan Chee Seng – Transport contractor

    The contact job since 15 years ago. Attended the MSPO briefing by assistant manager dated 23/10/2018. He understands about MSPO benefits. Until now no issue on payment and all related document is transparent. Good relationship between estate management and contractor. The management practice yearly contract agreement. No

    sexual harassment issue at this time of review. Chio Kuang Hu –Harvesting contractor

    Since 20 years ago service in this estate. Yearly contract basis and agreement was transparent. He has 10 harvesters. All the harvester is staying in the estate and the estate provided 4 units’ houses for them. Estate provide them free water and subsidy on electricity. All the harvesters are from Indonesian and all are legal employees. Attended the

    briefing of MSPO conducted by estate manager. The contractor understands how to make a complaint. There is no complaint regarding social issue in this estate. Good relationship between contractor and estate management

    Estates Information

    LIST OF GROUP MEMBERS

    1. ESTATE INFORMATION

    NAME OF ESTATE LOCATION COORDINATE

    Atlas Paloh Rubber Esate 9MS, Yong

    Peng-Paloh road,

    83700, Yong Peng,

    2°06’57.3“N 102°47’55.5“E

  • CCI-QP-07-07A

    9

    Johor

    Serkam Estate SG33448, Bt16,

    Serkam, 77000, Jasin,

    Melaka

    2°11'51.8"N 102°23'41.7"E

    Batang Melaka Estate 73300, Batang Melaka,

    Negeri Sembilan

    2°28'45.1"N 102°25'55.4"E

    Atlas Pagoh Muar Estate Jalan Sengkang,

    84600, Pagoh, Muar,

    Johor

    2°06'5 7.6"N 102°47'53.3"E

    Gading Estate Bt16, Jalan Gading,

    Kesang Pajak,

    77000, Jasin,

    Melaka

    2°18'55.7"N 102°21'03.6"E

    2. AREA STATEMENT AND FFB FORECAST

    ESTATE TOTAL AREA (HA) PLANTED

    AREA (HA)

    FFB TON/ YEAR

    (as per year 17)

    YIELD TON/ha/

    YEAR

    Atlas Paloh Rubber Esate 640.33

    637.52 12,731 19.97

    Serkam Estate 349.19 342.42 8087 23.62

    Batang Melaka Estate

    306.71 304.06 6862 22.57

    Atlas Pagoh Muar Estate 199.00 199.00 5174 26.00

    Gading Estate

    177.06 177.06 3186 18

    TOTAL

    1,672.29 1660.06 36040

  • CCI-QP-07-07A

    10

    Audit Checklist

    P1: Management Commitment & Responsibility

    Criterion 1 Malaysian Sustainable Palm Oil (MSPO) Policy

    Indicator Requirement Findings

    4.1.1.1

    A policy for the implementation of MSPO shall be established

    Atlas Paloh Rubber Estate / Serkam Estate / Atlas Batang Melaka Estate/ Gading Estate Sighted management establish 4 policies such as MSPO Policy, Human Resource and Social Policy, Occupational Safety and Health Policy, Environment, Natural Resource, Biodiversity and Ecosystem Policy. Communication of the policy sighted done by display at the notice board, briefing during operation meeting and explain the policy to the stakeholder during the stakeholder meeting. Sighted the Malaysia Sustainable Palm Oil policy, was established on 1st July 2018 signed by Chee Kim Hoon and Tan Hin Toe as a Director. Verified the management had added another 3 policies in order to support implemetation of MSPO as per below : i) Human Resource and Social Policy. ii) Occupational Safety and Health Policy iii) Environmental, Natural Resource, Biodiversity and Ecosystem Policy Verified the policy had been display in office wall, row call area, line site etc. Verified the policy had been brief to all employee during row call. 4.1.1.2 The policy shall also emphasize commitment to continual improvement.

    Atlas Paloh Rubber Estate / Serkam Estate / Atlas Batang Melaka Estate/ Gading Estate Sighted the policy established had shown emphasize towards commitment for continual improvement for principle 1 until principle 7 Continual Improvement Programme was established and sighted the continual improvement document. Moving toward for implementation in future. Sample below: - 1. First aider training - Action Plan: Quotation received from St. John to arrange training appoitment - Nov. 2018 2. Fire fighting training with fire deparment - Action Plan: To arrange with Gemencheh fire department - Dec 2018 3. Refresher training for safety and health at work place - Action plan: To arrange with DOSH deparment - Dec 2018 Criterion 2 Internal Audit

    Indicator Requirement Findings

    4.1.2.1

    Internal audit shall be planned and conducted regularly to determine the strong and weak points and potential area for further improvement.

    Atlas Paloh Rubber Estate / Serkam Estate / Atlas Batang Melaka Estate/ Gading Estate Group of Atlas Plantation have established Internal Audit procedure and the result of finding issues had been discussed during MRM. Internal audit was conducted for each estate in the group. The internal audit date is below: - Atlas Paloh Rubber Estate - 13/09/2018 Serkam Estate - 14/09/2018 CTTD Gading Estate - 14/09/2018 Atlas Batang Melaka Estate - 18/09/2018 There are four (4) estates was audited, Atlas Batang Melaka, Atlas Pagoh, YWH Serkam and CTTD Gading estates. The agenda is cover all the MSPO Principle matters such as Employee Safety & Environmental, Employee Condition, Continual Improvement etc. and cover the issue for estates. From the group, there are 7 observations raised in the 1st Internal Audit. Sighted the Internal Audit report.

    ../../../../User/Desktop/Auditors%20Job/Care%20Cert/Care%20Cert/MSPO%20Matter/MSPO%20Guidance%20-%20Part%202%20(Smallholders).xlsx#RANGE!B9../../../../User/Desktop/Auditors%20Job/Care%20Cert/Care%20Cert/MSPO%20Matter/MSPO%20Guidance%20-%20Part%202%20(Smallholders).xlsx#RANGE!B9../../../../User/Desktop/Auditors%20Job/Care%20Cert/Care%20Cert/MSPO%20Matter/MSPO%20Guidance%20-%20Part%202%20(Smallholders).xlsx#RANGE!B38../../../../User/Desktop/Auditors%20Job/Care%20Cert/Care%20Cert/MSPO%20Matter/MSPO%20Guidance%20-%20Part%202%20(Smallholders).xlsx#RANGE!B38

  • CCI-QP-07-07A

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    4.1.2.2 The internal audit procedures and audit results shall be documented and evaluated, followed by the identification of strengths and root causes of nonconformities, in order to implement the necessary corrective action

    Atlas Paloh Rubber Estate Sighted the Internal Audit procedure 2018. The internal audit at Atlas Paloh Rubber Estate was conducted on 13/09/2018. All the audit result was proper documented and evaluated. All rised issues will discuss in management review meeting. Serkam Estate Sighted the Internal Audit procedure 2018. The internal audit at Serkam Estate was conducted on 14/09/2018. All the audit result was proper documented and evaluated. All rised issues will discuss in management review meeting. Atlas Batang Melaka Estate Sighted the Internal Audit procedure 2018. The internal audit at Atlas Batang Melaka Estate was conducted on 18/09/2018. All the audit result was proper documented and evaluated. All rised issues will discuss in management review meeting. 4.1.2.3 Report shall be made available to the management for their review.

    Atlas Paloh Rubber Estate / Serkam Estate / Atlas Batang Melaka Estate/ Gading Estate Sighted the Internal Audit Report, dated 13/09/2018. The report verified and edequate. No NCR was rised and any OBS matter was discused in management review meeting. Sample of OBS are: - 1. SIA report still in progress 2. No CSR record 3. Environment impact assessment still in progress. Criterion 3 Management Review

    Indicator Requirement Findings

    4.1.3.1 The management shall periodically review the continuous suitability, adequacy and effectiveness of the requirements for effective implementation of MSPO and decide on any changes, improvement and modification.

    Atlas Paloh Rubber Estate / Serkam Estate / Atlas Batang Melaka Estate/ Gading Estate Verified the MSPO Management Review Meeting, dated 3rd October 2018, held in 1B, Level 1, Wisma Tan Cheng Tiong, No 1A, Jalan Tun Sri Lanang, 75100, Melaka. The estate conducted group MRM meeting. Sighted the meeting agenda and name list of attendance. The agenda discussed all elements of MSPO requirement from principle 1 until principle 7. Sighted the Assessment Report Review dated 11th October 2018, report no. MS001. Sighted the action plan and target in the report. The agenda discussed all elements of MSPO requirement from principle 1 until principle 7. Criterion 4 Continual improvement

    Indicator Requirement Findings

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

    Atlas Paloh Rubber Estate / Serkam Estate / Atlas Batang Melaka Estate/ Gading Estate Sighted and Verified the management had listed the document for continual improvement for MSPO implementation. Verified 'Environment Management and Improvement Plan 2018 '. Sample below; - 1. Improve on managing recycle items - Provide recycle bin - office compound 2. Septic waste - Engage certified contractor for schedule waste - line-site, office, staff quarters.

    4.1.4.2 The company shall establish a system to improve practices in line with new information and techniques or new industry standards and technology, where applicable, that are available and feasible for adoption.

    ../../../../User/Desktop/Auditors%20Job/Care%20Cert/Care%20Cert/MSPO%20Matter/MSPO%20Guidance%20-%20Part%202%20(Smallholders).xlsx#RANGE!B38

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    Atlas Paloh Rubber Estate / Serkam Estate / Atlas Batang Melaka Estate/ Gading Estate Sighted the Training Plan 2018. The estate has plan several training for their workers such as spraying technique, safety driving for tractors driver, fire drill etc. There is no technology came in into this estate especially on FFB evacuation.

    4.1.4.3 An action plan to provide the necessary resources including training, to implement the new techniques or new industry standard or technology (where applicable) shall be established.

    Atlas Paloh Rubber Estate / Serkam Estate / Atlas Batang Melaka Estate/ Gading Estate The estate not yet plan for new techniques or new industry standard or technology for the year 2018/2019 (OBS)

    P2: Transparency

    Criterion 1 Transparency of information and documents relevant to MSPO requirements

    Indicator Requirement Findings

    4.2.1.1

    The management shall communicate the information requested by the relevant stakeholders in the appropriate languages and forms, except those limited by commercial confidentiality or disclosure that could result in negative environmental or social outcomes.

    The management shall communicate the information requested by the relevant stakeholders in the appropriate languages and forms. Request, response and release of information must be recorded. If got any request by the stakeholders, they must come to the management and management will give a link to serve into goggle drive. Generally, communicate the information with stakeholders and public through meeting with stakeholders. The management annually organize get together with local communities as part of promoting MSPO requirements as per Procedure. The recent meeting was held on 05/07/2018. For every issue raised the estate management will prepare management plan on social impact assessment. 4.2.1.2 Management documents shall be publicly available, except where this is prevented by

    commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes.

    Communication procedure was applicable to all estate. Sighted the communication were divided into two categories external and internal. For internal normally the interaction between employee and employer through interview (face to face, e-mail, letter and suggestion form. All the information regarding company activities can be review by external parties such as stakeholder and society through google drive Sighted Reference Document List. Example publicly documents listed: 1. Internal memo and external memo. 2. Management minute of meeting 3. Minute of safety and health committee 4. Comment from external stakeholder 5. Complaint Investigation report. 6. Record for outgoing and incoming information. 7. Land tittle 8. Safety and health plan 9. Environmental impact assessment 10. Pollution prevention plan 11. Complaint and grievance 12. Procedure for communication 13. Continues Improvement plan. 14. List of stakeholder 15. Human right policy Criterion 2 Transparent method of communication and consultation

    Indicator Requirement Findings

    4.2.2.1 Procedures shall be established for consultation and communication with the relevant stakeholders

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    Governing Procedure : "Prosedur Komunikasi dan Informasi" and "Prosedur Menangani Aduan dan Rungutan" This procedure has been communicated to all stakeholders during stakeholder meeting dated 05/07/2018. Records of complaints and grievances were implemented by Complaints Form for Stakeholder/supplier and Internal and the form kan be reached at estate office. No complaint receive at this time of review. Scheme manager has been appointed, operation supervisor as person who are responsible in communication & consultation. List of stakeholder has been maintained as per document list of stakeholder date on 05/07/2018 In the list of stakeholder company has divided into a few categories as follow. Government / Statutory Bodies: - - Pondok Polis - Villages - Estates - Ketua kampung - Surau Committee 4.2.2.2 A management official shall nominated officials at the operating unit responsible for

    issues related to indicator 1 (4.2.2.1)

    Noted that official management representative nominated responsible for issue related to stakeholder; sighted the appointment letter for Azman Bin Abd Halil, dated 20 June 2018.

    4.2.2.3 List of stakeholders, records of all consultation and communication and records of action taken in response to input from stakeholders should be properly maintained.

    Atlas Paloh Rubber Estate Sighted stakeholder meeting dated on 05/07/2018. Verified the list of stakeholderwhich total of 8 supplier/contractor, 1 neighbouring estates, 1 neighbouring villages and 1 government agencies.department. Ladang Batang Melaka Verified the relevant stakeholder such as contractor, employee and supplier were well brief ragarding the complaint procedure, complaint form during stakeholder meeting dated on 8/10/2018. Verified record of communication and consultation were kept in file traceabiliy. Criterion 3 Traceability

    Indicator Requirement Findings

    4.2.3.1 The management shall establish, implement and maintain a standard operating procedure to comply with the requirements for traceability of the relevant product(s).

    Procedure for traceability has been established by the management "MSPO Estate Operations Manual". However, the procedure and guideline to trace the FFB production from harvesting until deliver FFB to the mill should be develop more details and practice the implementation. (OBS). 4.2.3.2 The management shall conduct regular inspections on compliance with the established

    traceability system

    The management has established a mechanism to monitoring and record with all tasks to the workers. Sighted ‘Check roll harvesting’, ‘FFB daily record', ‘Despacth slip’ & a logbook to monitoring task on estate field such as harvesting work and manuring work.

    4.2.3.3 The management should identify and assign suitable employees to implement and maintain the traceability system

    The management has appoint En Azman Bin Abdul Halil, dated on 04/10/2018 as personnel in charge for traceability . Function perform as per PIC Traceability stated in appointment letter. Sighted the block harvesting in the field. 4.2.3.4 Records of sales, delivery or transportation of FFB shall be maintained.

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    Sighted the traceability records; harvesting interval, harvesting block, weighbridge ticket to estate ramp, weighbridge ticket to FFB dealer. Sighted the daily FFB dispatch. OBS The estate need to do FFB quality check (FFB grading) and establish the FFB grading format. Estate also required to do flow chart for FFB traceability for easy monitoring P3: Compliance to legal requirements

    Criterion 1 Regulatory requirements

    Indicator Requirement Findings

    4.3.1.1.

    All operations are in compliance with the applicable local, state, national and ratified international laws and regulations

    Ladang Getah Atlas Paloh The Management has established list of legal requirement register. Sighted the legal register for Atlas Group of Companies. Noted that 100% compliance on the evaluation. All the requirements evaluated at least once a year. Ladang Getah Atlas Paloh has established record which was updated on yearly basis. Record in the office showed, done appropriately. List of licenses related to the estate are:- 1. Permit Barang kawalan Berjadual - Diesel (Euro 2M) 9,000 liter per year. - Series No: J032947. Validity : 14/01/2018 - 13/01/2019. 2. MPOB License no: 501270102000 validity 01/04/2018 - 31/03/2019. 3. Verified latest report and meeting of OSH committee 2018. Ladang Getah Atlas Paloh. Seen the List of Laws and registered for a. Environmental matters: - EQA 1974 e.g. Prescribe premises (CPO) regulations 1977, Clean Air Regulation 1978, SW regulations 2005 b. Safety & Health matters - OSHA 1994: c. Industrial Relations Act, 1967 d. Employee matters e.g. employmentact 1955, trade union act 1959 e. Pesticide act 1974 f. Food act 1983 – 16th schedule of Malaysia food g. Akta rahsia rasmi 1972 Verified the following legal compliance for: a. MPOB license No: 501270102000 valid till 31/03/2019. b. Permit Kawalan Barangan Berjadual No: J032947 due date 13/01/2019. c. OSH committee last meeting was held Ladang Serkam The Management has established list of legal requirement register. Noted that 100% compliance on the evaluation. All the requirements evaluated at least once a year as per procedure "Compliance to legal requirement" dated on 1/7/2018. Ladang Serkam has established LRR record which was updated on yearly basis. Record in the office showed LRR was done appropriately. List of licenses related to the estate are:- 1. Permit Barang kawalan Berjadual - Diesel 200L/day .- Series no: M 007311. Validity : 25/5/2018 -25/11/2018. 2. Perakuan Penetuan Timbang dan Sukat - No. Siri Alat - A13415055 dated on 20/7/2018 validity until 20/7/2019 , No. Pelekat Keselamatan - 1.3K-023369 3. MPOB License no: 501285902000 validity 1/4/2018-31/3/2019. 4. Verified lates report and meeting of OSH committee 3/6/2018. Ladang Serkam: Seen the List of Laws and registered for etc: a. Environmental matters: - EQA 1974 e.g. Prescribe premises (CPO) regulations 1977, Clean Air Regulation 1978, SW regulations 2005 b. Safety & Heath matters: - OSHA 1994: c. Land & Wildlife protection matters e.g. National Land Code 1965 d. Employee matters e.g. employmentact 1955, trade union act 1959

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    Ladang Batang melaka Licenses and permit been listed and monitored in List of Licenses and Permits. The listed license as per sample below : i. MPOB license - Atlas batang Melaka Estate (license no : 501887302000) valid until 1/8/2018-31/7/2019. ii. Perakuan penentuan Timbang dan Sukat - Akta Timbang Sukat 1972 dated on 17/7/2018 ( Siries no : A 16220435 Weighcom SE5R 40,000 x 10kg ). The date of validity been identified in the list as well. 4.3.1.2 The management shall list all laws applicable to their operations in a legal requirements

    register

    Ladang Getah Atlas Paloh/ Ladang Serkam/Ladang Batang Melaka/ Gading Estate : List of legal register are available a sighted, has been update date on 1/07/2018. List of Legal document sighted that has been covered all the related palm oil industry. In the Scheme manager level sighted that operation supervisor are nominated as Person who are responsible with the changing of the law requirement. Mechanism of Changing has been establishing in document system of changing of Law requirement. The legal register was last updated on 1/07/2018. There are laws and regulations identified in the legal register. Some of applicable laws sighted includes: • OSHA and regulations 1994 (Act 514) • Poison Act and Regulations 1952 (Act 366) • MPOB • Employees Social Security Act and Regulations (Act 4) • Industrial Relations Act and Regulations (Act 177) • Trade Union Act and Regulations • Employees Provident Fund Act 1991 Management unit legal compliance status has been stated for each of the law identified in the current status column of the legal register titled “List and Summary of Applicable Laws and Regulations”. As evidence of the compliance as per below: • MPOB Licence • Diesel Licence 4.3.1.3 The legal requirements register shall be updated as and when there are any new

    amendments or any new regulations coming into force.

    Ladang Getah Atlas Paloh Verified the Estate List of Laws and acts updated and listed legal applicable to the estet operation suc as Income Tax Act 1967, Immigration Act 1959, OSHA 1994, FMA 1967, EQA 1974, Trade Union Act, Minimum Wages Order Act etc. Verified the legal list: a) Workers Minimum Standards of Housing and Amenities, Section 23- Weekly inspection of workers housing. However, the estate only did twice per month for line-site inspection (OBS) b) Regulation(OSH Committee) 1996- Section 12: Workplace inspection- done monthly basis dated June - Oct 2018. c) Peraturan (Penggunaan Dan Standard Pendedahan Bahan Kimia Berbahaya kepada Kesihatan) 2000- Section 9: Penaksiran Risiko- Verified the CHRA Report dated20/07/2018 done by OSH SAFETY CONSULTANCY (M) SDN BHD. Medical Surveillance- for workers involve with chemical as below: a) Daryani - W627779 - Dated 18/09/2018 b) Rahman - B3623435 - Dated 18/09/2018 c) Sahar - AU318464 - Dated 18/09/2018 Ladang Serkam: Verified the legal list: a) Workers Minimum Standards of Housing and Amenities, Section 23- Weekly inspection of workers housing- done inspection seen the record for month Sept, August. b) Regulation(OSH Committee) 1996- Section 12: Workplace inspection- done monthly basis c) Peraturan (Penggunaan Dan Standard Pendedahan Bahan Kimia Berbahaya kepada Kesihatan) 2000- Section 9: Penaksiran Risiko- Verified the CHRA Report dated 15/08/2018 done by Ganesraoo A/L nagarajoo - JKKP HIE 127/171-2 (357) Medical Surveillance- for workers involve with chemical as below: a) Anton dated 11/10/2018 b) Wijianto dated 11/10/2018 c) Asrofi dated 11/10/2018

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    The examination were done to all sprayer with total 3 workers at Klinik S0hvindir conducted by Dr. vijayndhran Balakrishnan and certified the sprayer as medically fit. Ladang Batang Melaka: Verified the legal list: a) Workers Minimum Standards of Housing and Amenities, Section 23- Weekly inspection of workers housing- done inspection seen the record for month Sept, August. b) Regulation(OSH Committee) 1996- Section 12: Workplace inspection- done monthly basis c) Peraturan (Penggunaan Dan Standard Pendedahan Bahan Kimia Berbahaya kepada Kesihatan) 2000- Section 9: Penaksiran Risiko- Verified the CHRA Report dated 15/08/2018 done by Ganesraoo A/L nagarajoo - JKKP HIE 127/171-2 (357) Medical Surveillance- for workers involve with chemical as below: a) Mazlan Bin Ibrahim dated 9/10/2018 b) Shatesh A/L Gnanasekaran dated 9/10/2018 c) Kartik A/L Subramaniam dated 9/10/2018 d) Tamilarasan A/L Rajagopal dated 9/10/2018 The examination were done to all sprayer with total 4 workers at Klinik Sohvindir conducted by Dr. vijayndhran Balakrishnan and certified the sprayer as medically fit. 4.3.1.3 The management should assign a person responsible to monitor compliance and to track

    and update the changes in regulatory requirements.

    Ladang Serkam/Ladang Batang Melaka/ Atlas Paloh Rubber Estate/ Gading Estate Mr Edwin Tan Keng Kum (Assistant Manager) been nominated as Legal Requirement Register Officer to monitor compliance of regulatory requirement, track and update the changes in regulatory requirement, perform any further function that may be required by employer to enable the implementation of MSPO. The functions are listed in one nomination letter dated on 4/10/2018 and signed by CEO. Function as follow; 1. Ensuring LRR up to date and amend any new regulation coming into force 2. Documenting and issuing of document and report 3. Monitoring compliance and track update and changes in regulatory requirements. Criterion 2 Land used right

    Indicator Requirement Findings

    4.3.2.1

    The management shall ensure that their oil palm cultivation activities do not diminish the land use rights of other users

    Atlas Paloh Rubber Estate Sighted the grant Estate land is 1,035.5889 Ha . Land titles and documents were available during assessment. a) No. Hakmilik - 93372 b) No Lot: Lot 1589 c) Luas Lot: 1,035.5889 Ha d) Kategori kegunaan tanah: Pertanian e) Syarat - syarat nyata: Tananam getah (NCR) Ladang Serkam Estate area is 349.19 Ha . Land titles and grant documents were available during assessment. a. Land Grant b. Plan Tanah c. Receipt payment of "Cukai Tanah Negeri Melaka" Ladang Batang Melaka Estate area is 306.45 Ha. The land title as per land grant (Geran Tanah ). Sighted Grant for Atlas Batang Melaka Estate with total grant of 13. Non-Compliance 1- Atlas Paloh Rubber Estate Syarat - syarat nyata: Tananam getah (NCR) - Atlas Paloh Rubber Estate The land title terms stated in the grant is for rubber planting. 4.3.2.2 The management shall provide documents showing legal ownership or lease, history of

    land tenure and the actual use of the land.

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    Atlas Paloh Rubber Estate Sighted the grant Estate land is 1,035.5889 Ha . Land titles and documents were available during assessment. a) No. Hakmilik - 93372 b) No Lot: Lot 1589 c) Luas Lot: 1,035.5889 Ha d) Kategori kegunaan tanah: Pertanian e) Syarat - syarat nyata: Tananam getah (NCR) Ladang Serkam Verified total grant for Ladang Serkam is 4 and nil "Syarat - syarat nyata inside the land title. Below are the evidence of grant for ladang Serkam : i. No hak Milik : 46397 , no lot : 5989 , luas lot : 295.6 ha , Kategori penggunaan tanah ; tiada, syarat-syarat nyata - nil. ii. No hak Milik : 20119 , no lot : 1737, luas lot : 14.3537 ha, Kategori penggunaan tanah ;tiada, syarat-syarat nyata - nil. iii. No hak milik : 46398 , no lot : 5988, luas lot : 37.66 ha, kategori penggunaan tanah: tiada, syarat-syarat nyata - nil iv. No hak milik : 2988, no lot : 1735, luas lot :1.892 ha, kategori penggunaan tanah : tiada, syarat-syarat nyata - nil Verified the category of land use for the above gran were nil as stated inside the grant. Ladang Batang Melaka Sighted Grant for Atlas Batang Melaka Estate with total grant of 13. Below are the sample taken : i. No hakmilik : 61632 , lot no: 3813 , luas lot : 4.0291 Ha, land title : "Pertanian" ii. No hakmilik : 61637 , lot no : 3818 , luas lot : 3.5865 Ha, land title : " Pertanian" iii. No hakmilik : 61636 , lot no : 3817, luas lot :3.7762 Ha, land title : "Pertanian". The land title were verified for 13 grant for Atlas Batang Melaka Estate is "Pertanian"/ Agriculture. 4.3.2.3 Legal perimeter boundary markers should be clearly demarcated and visibly maintained

    on the ground where practicable.

    Serkam Estate/Batang Melaka Estate/ Atlas Paloh Rubber Estate/ Gading Estate Boundary were by boundry roads , fencing and trenches are available and visible during site observation. The management establish map close up boundary location. Observe the estate map to show the block identification. 4.3.2.4 Where there are, or have been, disputes, documented proof of legal acquisition of land

    title and fair compensation that have been or are being made to previous owners and occupants; shall be made available and that these should have been accepted with free prior informed consent (FPIC).

    Serkam Estate/ Batang Melaka Estate/ Atlas Paloh Rubber Estate/ Gading Estate There is no land dispute issue as the whole estate block is owned by Atlas Group. As of to-date there was no complaint on land matter. No record on FPIC process because there is no community surround of plantation area Criterion 3 Customary rights

    Indicator Requirement Findings

    4.3.3.1

    Where lands are encumbered by customary rights, the company shall demonstrate that these rights are understood and are not being threatened or reduced.

    The plantation was not planted at customary rights land

    4.3.3.2 Maps of an appropriate scale showing extent of recognized customary rights shall be made available

    The plantation was not planted at customary rights land

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    4.3.3.3 Negotiation and FPIC shall be recorded and copies of negotiated agreements should be made available.

    The plantation was not planted at customary rights land

    P4: Social responsibility, health, safety and employment condition

    Criterion 1 Social impact Assessment (SIA)

    Indicator Requirement Findings

    4.4.1.1

    Social impacts should be identified and plans are implemented to mitigate the negative impacts and promote the positive ones

    Serkam Estate /Batang Melaka Estate/ Atlas Paloh Rubber Estate/ Gading Estate As per Social Impact Assessement procedure were inside MSPO Estate Operation Manual dated on 1/7/2018. Sighted the SIA procedure compromises most of the following activities as per sample below : - participates in the environmental design of the planned intervention - identifies interested and affected peoples - facilitates and coordinates the participant of stakeholder - collect baseline data to allow evaluation and audit of the impact assessment process and the planned intervention itself - identifies and describes the activities which are likely to cause impact Sighted the Social Impact Assessment report dated on1/8/2018. Criterion 2 Complaints and grievances

    Indicator Requirement Findings

    4.4.2.1

    A system for dealing with complaints and grievances shall be established and documented

    Serkam Estate/ Batang Melaka Estate / Atlas Paloh Rubber Estate/ Gading Estate Establish Prosedure complaints and grievances - inside the MSPO operation manual dated on 1/7/2018 and cover to both internal and external complaint. Company has establish the communication method through i) face to face, ii) electronic (Google drive & email), iii) printed (letter) and iv) Suggestion/feedback box (suggestion/ feedback form) to fill the form and revert to company management. As at todate no record of complaint receive from stakeholder or employee. 4.4.2.2 The system shall be able to resolve disputes in an effective, timely and appropriate

    manner that is accepted by all parties.

    Serkam Estate/Batang Melaka Estate/ Atlas Paloh Rubber Estate/ Gading Estate Verified Buku Rekod Aduan and complaint form. As to date no external or internal complaint reveiced by estate. Sighted the procedure to resolve issues or complaint were stated in Procedure for Consultation and Communication dated on 1/7/2018. Sighted inside the procedure the management will response within 2 weeks from the date receive of complaints. 4.4.2.3 A complaint form should be made available at the premises, where employees and

    affected stakeholders can make a complaint.

    Ladang Serkam/Ladang Batang Melaka/ Atlas Paloh Rubber Estate Sighted complaint form was located a at the management office. For internal complaint sighted will recorded in the Buku Rekod Aduan. 4.4.2.4 Employees and the surrounding communities should be made aware that complaints or

    suggestions can be made any time

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    Atlas Paloh Rubber Estate The employee and surrounding communited are aware with the complaint procedure with briefing was done during the stakeholder meeting on 5/07/2018. OBS Verified some of stakeholder were not involves in the stakeholder meeting. According to the stakeholdeer, dealer of FFB ( ramp) Ms Lim, is not aware on the procedure of complaint. Batang Melaka Estate Verified the relevant stakeholder such as contractor , employee and supplier were well brief ragarding the complaint procedure , complaint form during stakeholder meeting dated on 8/10/2018. Serkam Estate/ Gading Estate The surrounding communities been explained on the procedure and form during stakeholder meeting. 4.4.2.5 Complaints and resolutions for the last 24 months shall be documented and made

    available to affected stakeholders upon request.

    Ladang Serkam/Ladang Batang Melaka/ Atlas Paloh Rubber Estate/ Gading Estate As per 4.4.2.2 As at todate no complaint receive from the relevant stakeholder. The complaint and resolution record were not yet available. However, in the procedure not stated for the record keeping for at least minimum 24 months. (OBS) Criterion 3 Commitment to contribute to local sustainable development

    Indicator Requirement Findings

    4.4.3.1 Growers should contribute to local development in consultation with the local communities.

    Atlas Paloh Rubber Estate Verified CSR activities were recorded and kept in the files Social Activities Entertaiment Expenses and recorded CSR as below: a) Food distribution during Hari Raya Festival dated 13/06/2018 b) Hari Memancing ladang Getah Atlas Paloh - particant all estate Ladang Batang Melaka Verified the estate did the annual contribution activities for Annual Prayer requested by internal temple. Sighted recent CSR activities dated on 22/10/2018. Obs- The CSR activities were not been recorded in a proper filing .(ladang Batang Melaka). Verified no records of communication for CSR activities. Ladang Serkam Verified the CSR record: i) Own employee – During Hari Raya feast, the rice 5kg, cooking oil and soft drink for each employee, refer receipt #T030125026. ii) Outsider – Company has allowed outsider to pass though the estate road freely based on the estate allowed time (5.00 – 7.00 pm) Criterion 4 Employees safety and health

    Indicator Requirement Findings

    4.4.4.1

    An occupational safety and health policy and plan shall be documented, effectively communicated and implemented

    Atlas Paloh Rubber Estate/Ladang Batang Melaka/Ladang Serkam Sighted the OSH policy were established on 01/07/2018. Seen the policy been communicated thru: - row call - displayed in notice board. Sighted the policy were sign by the CEO. 4.4.4.2 The occupational safety and health plan shall cover the following:

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    a) A safety and health policy, which is communicated and implemented

    Atlas Paloh Rubber Estate/ Batang Melaka Estate/ Ladang Serkam Estate/ Gading Estate: Sighted the policy have been brief in - row call - displayed in notice board Evidene on the photo & slide. b) The risks of all operations shall be assessed and documented

    Atlas Paloh Rubber Estate/Ladang batang Melaka: Sighted the HIRARC dated 1 July 2018 for the following activities: a. Field activities b. Linesite c. Landfill d. Replanting e. Chemical handling f. Office & security g. Workshop Below are the Sample list operation being assessed; 1. Harvesting Activity – Carrying pole to work place Hazard - cut by sickle struck by the pole Risk Level – 2 (Low) 2. Weeding Activity – mixing of chemical hazard - slip trip or fall Risk level – 2 (Low) Ladang Serkam i) HIRARC available developed by Mr Edwin Tan, but not identified the date (OBS), ii) CHRA conducted by Mr Ganesraoo #JKKP HIE 127/171-2 (357) dated 15/08/2018, iii) Housing weekly inspection conducted by Mr Gao. iv) During Site Visit 1. Path at block OP16, culvert and the path through the drain were not visible clearly because of cover crop vegetation, which may cause the incident while passing through the drain. (OBS) 2. Warning sign at diesel storage is inadequate. (OBS) c) An awareness and training programme which includes the following requirements for employees exposed to pesticides: i) all employees involved shall be adequately trained on safe working practices; and ii) all precautions attached to products shall be properly observed and applied.

    Atlas Paloh Rubber estate: Verified the following activities and worker: a. spraying worker named Rahman, Bilal, darwanto for "Latihan Meracun" dated 27/7/2018 It was recorded in the Safety Briefing / Training file. Verified 10 training been plan in the training plan year 2018 which related to Occupational Safety Health. Sighted that the sprayer and the madore are aware on the pesticide handling. Verified that the chemical were mixing at the chemical store, chemical mixing area. Sighted that all the sprayers are wearing proper PPE such as glove, apron, boot, google and mask. The PPE was given by the management as mention by the sprayer during interview. Verified with the mandore that the staff will conduct daily PPE inspection before the worker goes for the work. Ladang Batang Melaka : Verified the following traing have been conducted for those activities with exposed to pesticide; a. "Latihan prosedur kerja meletak racun tikus" dated on 24/7/2018 - employee involve - S. Prabu, G. Shatesh b. "Latihan meracun ubat kumbang" dated on 3/7/2018 - Mazlan, Janet Ladang Serkam i) Training on PPE conducted by 3M authorized dealer dated 30/08/2018. ii) SDS available at site and office for the references.

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    d) The management shall provide the appropriate personal protective equipment (PPE) at the place of work to cover all potentially hazardous operations as identified in the risk assessment and control such as Hazard Identification, Risk Assessment and Risk Control (HIRARC).

    Atlas Rubber Estate Seen the PPE were provided by the management for each operation need for PPE as per identified in the risk assessment. Below are the sample of PPE provided and been recorded in the PPE issuance (Issue Book): 1. Safety helmet issued to Sudirman (harvester) dated on 4/8/2018 2. Gloves issued to Rahman ( sprayer) dated on 12/9/2018 3. Googles issued to Rahman ( Sprayer) dated on 12/9/2018 4. Aprons issued to Sahar ( Sprayer ) dated on 12/9/2018 Ladang Batang Melaka Seen the employee have given appropriate PPE. Below are the sample taken through PPE issuance record. 1. Employee name: Teguh Triyatno as a harvester - PPE given :- glove(30/8/2018), safety glass(1/9/2018), safety helmet(1/7/2018) 2. Employee name : S. Prabu as sprayer - PPE given ;- glove, mask respirator, safety boots, safety google, apron dated on 2/9/2018. Obs- Sighted in the list of PPE and Types of activities is not included the sickle cover as part of PPE. Ladang Serkam PPE distribution record (Rekod Pembekalan Peralatan Perlindungan Diri) available for each employee. Verified the Penuai Kelapa Sawit has received PPE such kasut getah, helmet, pelindung mata, sarung tangan, kasut getah panjang, sarung sabit, sarung pahat, sarung tangan kain and pelindung mata. The pesticide work not yet conducted from past 3 month. e) The management shall establish Standard Operating Procedure for handling of chemicals to ensure proper and safe handling and storage in accordance to Occupational Safety Health (Classification Packaging and Labeling) Regulation 1997 and Occupational Safety Health (Use and Standard of Exposure of Chemical Hazardous to Health) Regulation 2000.

    Atlas Paloh Rubber Estate Verified the List of Chemicals Hazardous Chemical to Health as at 7/7/2018 and it was identified based on the processes: a. Weeding & maintenance = total is 9 - hextar, Amine, Monex, Genee 15, Basta 15, Ken Up, Garlon, Storm, Ally . b. Manuring – total is 5 - Dolomite, Real Strong Compound, ganoe Ef, Rock Phosphate, Ammonium Sulphate Noted, it will be revised if there is new chemical to be registered. The Chemical List stated the product name, ohysical form, no of worker involved, PPE, active ingredient, CSDS, Class – toxic, irritant, harmful, label, name and address of supplier. Verified the SOP chemical Handling, Chemical Storage, Spill handling procedure were noted in the MSPO operation manual dated on 1/7/2018. Site visit at the store chemical all the relevant SOP - chemical handling, chemical storage, spill handling were in place at the storage area. Sighted the chemical spill kit is in place and in good condition. Sighted also the the types of PPE need to be use were noted in the List of PPE and Types in the MSPO Operation manual dated on 1/7/2018 were accordance to the CHRA report dated on20/7/2018. Batang Melaka Estate Verified the List of Chemicals Hazardous Chemical to Health as at 7/7/2018 and it was identified based on the processes: a. Weeding & rat baiting = total is 2 - Ally , Blocus Beta . b. Manuring – total is 5 - Dolomite, Real Strong Compound, ganoe Ef, Rock Phosphate, Ammonium Sulphate Noted, it will be revised if there is new chemical to be registered. The Chemical List stated the product name, ohysical form, no of worker involved, PPE, active ingredient, CSDS, Class – toxic, irritant, harmful, label, name and address of supplier. Verified the SOP chemical Handling, Chemical Storage, Spill handling procedure were noted in the MSPO operation manual dated on 1/7/2018. Site visit at the store chemical all the relevant SOP - chemical handling, chemical storage, spill handling were in place at the storage area. Sighted the chemical spill kit is in place and in good condition. Sighted also the the types of PPE need to be use were noted in the List of PPE and Types in the MSPO Operation manual dated on 1/7/2018 were accordance to the CHRA report dated on23/7/2018. Serkam Estate/ Gading Estate Verified during site visit, Procedure of handling chemical such i) Chemical Storage, ii) Chemical Handling, iii) Spill

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    handling.

    f) The management shall appoint responsible person(s) for workers' safety and health. The appointed person(s) of trust must have knowledge and access to latest national regulations and collective agreements. Atlas Paloh Rubber Estate Sighted the Appointment Letter for Setiausaha Jawatankuasa KKP was given to En. Azman Bin Abd jalil and En Zhaahirul Tukiman which responsible for any emergency cases of accidents or any matter untowrad emergency incidents on the estate. Ladang Batang Melaka Sighted the Appointment Letter for Pegawai keselamatan dan kesihatan was given to En. Peter Santhiago A/L Patrick which responsible for any emergency cases of accidents or any matter untowrad emergency incidents on the estate. Verified for Atlas Group had appoint Mr edwin tan keng Kum as MSPO Officer which responsible in updating the latest regulation and colective agreement and will deiver to respective estate. Ladang Serkam Appointment letter for safety and health responsible person is available, verified the letter to Mr Devan A/L Rajoo has been appointed on date 04/10/2018. g) The management shall conduct regular two-way communication with their employees where issues affecting their business such as employee's health, safety and welfare are discussed openly. Records from such meetings are kept and the concerns of the employees and any remedial actions taken are recorded. Atlas Paloh Rubber Estate: Seen the Organisasi Jawatankuasa Keselamatan & Kesihatan Pekerjaan that consist mgt (3) and workers (8). The last meeting was held on 21/9/2018. . Verified the OSH meeting were conducted once in a 3 month. Evidence record for month June , March 2018. The minute of meeting kept and documented in the Principle 4, Criteria 4 file. The agenda includes pemantauan & pengukuran KKP, kemalangan, keracunan & penyakit, laporan kemalangan, laporan pemeriksaan tempat kerja, latihan, PPE etc.- Verified during the last meeting held in 21/9/2018 - stated nil accident cases starting from Jan until June 2018. Ladang Batang Melaka NCR - verified there is no evidence of 2 way communication in discussion of employee's health, safty and welfare are discussed openly between estate managemnt and employee. However briefing of safety had been done through morning briefing and training. Non- Compliance 2- Batang Melaka/ Ladang Serkam Verified there is no evidence of 2 way communication in discussion of employee's health, safty and welfare are discussed openly between estate managemnt and employee. However briefing on safety had been done through morning briefing and training. Two- way communication on discussion of safety and health related was not yet conducted h) Accident and emergency procedures shall exist and instructions shall be clearly understood by all employees.

    Atlas Paloh Rubber Estates/ Batang Melaka Estate/ Serkam Estate/ Gading Estate Sighted various emergency procedure / Pelan Tindakan Kecemasan for: a. Meracun b. Memotong Buah c. Pekerjaan Am dan Sebagainya d. Traktor & Pemandu Lori e. Stor Racun f. Stor Baja g. Kebakaran h. hakisan Tanah Noted there is an Emergency Response Committee 2018 that responsible for the various type of emergency as above. Verified the evacuation plan in case of emergency were display in the office , notice board, and worker quarters.

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    i) Employees trained in First Aid should be present at all field operations. A First Aid Kit equipped with approved contents should be available at each worksite Atlas Paloh Rubber Estates/Ladang Batang Melaka Obs -Notice that the first aider appoint by the estate will be attend training in Nov 2018 and will be conducted by St. John Ambulance Bachang. During site visit at the store chemical, office, fertiliser store were in place with aedequate of content . Ladang Serkam First aider training certificate available for Mr R. Devan Rao A/L Rajoo. The validation date till April 2020. j) Records shall be kept of all accidents and be reviewed periodically at quarterly intervals. Atlas Paloh Rubber Estate/Ladang Batang Melaka As verified in the accident record - nil accident cases as at todate were recorded due to no cases. OBS- Ladang Serkam No accident been recorded for todate. However, during site visit and interviewing with harvester, there are accident (cut at knee) during cutting the stalk last 2 month. However, the record of accident were not available.

    Criterion 5 Employment conditions

    Indicator Requirement Findings

    4.4.5.1 The management shall establish policy on good social practices regarding human rights in respect of industrial harmony. The policy shall be signed by the top management and effectively communicated to the employees

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Establish the Human Resource & Social Policy and approved by the Director, Mr Chee Kim Hoon dated 01/07/2018. The policy was contain of the commitment of the: i) Comply with the Employment Act 1955, Undustrial Relation ACt 1967 etc ii) Provide equal opportunity and teatment to all employees iii) Employee remuneration and employment terms and conditions iv) Prevent all forms of sexual harrasment Sighted policy was communicated during the morning briefing, display at the office and other strategic plase within the estate compund. 4.4.5.2 The management shall not engage in or support discriminatory practices and shall provide

    equal opportunity and treatment regardless of race, colour, sex, religion, political opinion, nationality, social origin or any other distinguishing characteristics.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Site visit and interview sighted no any discriminatory were sighted and all emplyee are treated equally by provide the living quarter, salary and other benefits as per workers contract agreement.

    4.4.5.3 Management shall ensure that employees’ pay and conditions meet legal or industry minimum standards and as per agreed Collective Agreements. The living wage should be sufficient to meet basic needs and provide some discretionary income based on minimum wage.

    Atlas Paloh Rubber Estate/ Batang Melaka Estate Verified the workers agreement and sighted the payment was meet the Minimum Wage Act and as per agreemnt with MAPA/ NUPW and sample as below: 1) Gan Tin Hai: Post: General Workers, Wages: RM38.46/ Day 2) Masitah Bt Jasmin: Post: General Workers, Wages: RM38.46/Day 3) Nakim, Post: General Workers, Wages: RM38.46/ Day Serkam Estate Verified sample of the payslip and contract agreement of estate employee name Mubhan. The piece rate based on palm age (ex OP92 – 32/mt, OP95 – 30/mt, OP96 – 30/mt, OP02 – 29/mt & etc), verified the payslip for month September 2018 is RM 1661.89 (gross), total balance is RM1589.73 (after deduction of advance and additional payment for holiday pay). 4.4.5.4 Management should ensure employees of contractors are paid based on legal or industry

    minimum standards according to the employment contract agreed between the contractor and his employee

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    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Verified the contractor workers wages for harvesting and sighted the working time was recorded in the REcord Of Normal & Evertime Work and payment was recorded in the payment slip. Sample records of payment for month of September are as below: a) Andrian, Slip# 11401, Wages: RM1001.34 b) Muhamad Saleh, Slip# 11409, Wages: RM1,83.72 c) Muhamd Safari, Slip# 11410, Wages: RM1,414.87 For Ladang Serkam no contractor employee were used by the estates. 4.4.5.5 The management shall establish records that provide an accurate account of all

    employees (including seasonal workers and subcontracted workers on the premises). The records should contain full names, gender, date of birth, date of entry, a job description, wage and the period of employment.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Employee record are available in the Employee Register, verified the record available such Name, Nationality, Date of birth, date of entered, date start employment, passport no, passport expiry date, visa number, visa expiry date, fomema issue and insurance due date. The job description and wage are stated in the Worker Contract Agreement.

    4.4.5.6 All employees shall be provided with fair contracts that have been signed by both employee and employer. A copy of employment contract is available for each and every employee indicated in the employment records

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Verified the employee contracts and and sighted fair contracts for contain of contractual periods, notice of termination, annual leave, working hour, holidays etc. Sample of signed agreement as below: a) Rajendran a/l Ramalingam, Position: General Workers, agreement date 01/07/2018 b) Supardi, Position: General Workers, agreement date 01/07/2018 c) Muhrim, Position: General Workers, agreement date 01/07/2018 4.4.5.7 The management shall establish a time recording system that makes working hours and

    overtime transparent for both employees and employer.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate The time recording for employees for working hours and overtime are as per Check Roll Book for each operation. Verified the time recording for general workers as per Check Roll Book- General Workers for month of October 2018. For overtime, the recording are as per Workers Daily Outurn For the Month: Sept and the the overtime was fixed only 2 hours per day. 4.4.5.8 The working hours and breaks of each individual employee as indicated in the time

    records shall comply with legal regulations and collective agreements. Overtime shall be mutually agreed and shall always be compensated at the rate applicable and shall meet the applicable legal requirement

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Esate The working hours and breaks of each individual are as per agreement and the working time are as below: Working Time: 6.30am - 2.30pm Break Time: 10.30 am - 11.00 am 4.4.5.9 Wages and overtime payment documented on the pay slips shall be in line with legal

    regulations and collective agreements

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Verified the Pay Slip for September 2018 as below: a) Kalavathi- Daily Rate: RM38.46 X 25 days = RM961.50, Public Holiday = RM76.92 Deducted for: EPF= RM115.00, PERKESO= RM5.25 b) Kahfi: Daily Rate: Daily Rate: RM 38.46 X 29 Days = RM1,115.34, Public Holiday= RM 76.92 Indonesian workers no deducted for KWSP and PERKESO.

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    4.4.5.10 Other forms of social benefits should be offered by the employer to employees, their families or the community such as incentives for good work performance, bonus payment, professional development, medical care and health provisions

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Refer to agreement sighted other social benefit was provided such as medical, bonus, electricity for RM25 rebate, workers quarters etc. 4.4.5.11 In cases where on-site living quarters are provided, these quarters shall be habitable and

    have basic amenities and facilities in compliance with the Workers' Minimum Standards Housing and Amenities Act 1990 (Act 446) or any other applicable legislation.

    Atlas Paloh Rubber Estate/ Batang Melaka Estate/ Gading Estate Site visit at living quarters and sighted all workers are provide with the workers quarters. Noted the living quarters are adequate with toilet, living hall and electricy were supply by TNB. For water supply, estate management supply the water for resident usage by treated onsite water treatment. Ladang Serkam During site visit, verified the housing provided been meet the regulatory such electricity and water supply, clean housing area, proper perimeter drainage system, functional toilet and septic tank. Interview with employees, found most of them are provided with basic amenities and been located 2 pax/ house. Weekly inspection conducted by Supervisor, any non-conformance will be taken action the status of the finding been monitor accordingly in the logbook. 4.4.5.12 The management shall establish a policy and provide guidelines to prevent all forms of

    sexual harassment and violence at the workplace

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Establish the Human Resource & Social Policy and approved by the Director, Mr Chee Kim Hoon dated 01/07/2018. The policy was contain of the commitment of the: i) Comply with the Employment Act 1955, Industrial Relation ACt 1967 etc ii) Provide equal opportunity and teatment to all employees iii) Employee remuneration and employment terms and conditions iv) Prevent all forms of sexual harrasment 4.4.5.13 The management shall respect the right of all employees to form or join trade union and

    allow workers own representative(s) to facilitate collective bargaining in accordance with applicable laws and regulations. Employees shall be given the freedom to join a trade union relevant to the industry or to organize themselves for collective bargaining. Employees shall have the right to organize and negotiate their work conditions. Employees exercising this right should not be discriminated against or suffer repercussions.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Noted management respect the right of the employee to form or join trade union and the commitment are as per Human Resource & Social Policy where the management will commit the Industrial Act 1967, Part II Trade Union.

    4.4.5.14 Children and young persons shall not be employed or exploited. The minimum age shall comply with local, state and national legislation. Work by children and young persons is acceptable on family farms, under adult supervision, and when not interfering with their education. They shall not be exposed to hazardous working conditions.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Refer to the employee register list and sighted no under age workers been hired by estate.

    Criterion 6 Training and competency

    Indicator Requirement Findings

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    4.4.6.1 All employees, contractors and relevant smallholders are appropriately trained. A training programme (appropriate to the scale of the organization) that includes regular assessment of training needs and documentation, including records of training shall be kept.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Estate establish the training program as per Schedule In-House Training Programme For Workers- June 2018 - Dec 2018 and listed planned training for Sprayer Training, Biodiversity Training, MSPO Awareness Training etc. Atlas Paloh Rubber Verified Training records and found adequate training was conducted to the workers as below: a) Teknik Dan SOP Keselamatan Kerja Untuk Pemotong dated 17/08/2018 conducted by Field Conductor attended by Azman, Andrian, Sardi etc b) Latihan Prosedur Kerja Meletak Racun Tikus dated 24/07/2018 conducted by Cadet Planter attended by Halil, Kahpi, Rajendran etc. c) Spraying Technique dated 08/01/2018 conducted by Cadet Planters attended by Daryati, Trawanto, Bilal etc Serkam Estate Training programme planned such First aider, fire-fighting and refresher for training for safety and health at work. 4.4.6.2 Training needs of individual employees shall be identified prior to the planning and

    implementation of the training programmes in order to provide the specific skill and competency required to all employees based on their job description.

    Atlas Paloh Rubber Estate/ Batang Melaka Melaka Not conducted the training need analysis before do planning for the training. Ladang Serkam Training need available for those training. The training plan has included the action plan and location/sources. Non-Compliance 3- Atlas Paloh Rubber Estate/ Batang Melaka Estate No evidence on the training need analysis been conducted.

    4.4.6.3 A continuous training programme should be planned and implemented to ensure that all employees are well trained in their job function and responsibility, in accordance to the documented training procedure.

    Atlas Paloh Rubber Estate/Ladang Batang Melaka Sighted no training plan been establish by the company however record of training can be trace in training file. Ladang Serkam Refer 4.6.1, a continuous training programme been planned for year 2018. Non-Compliance 3- Atlas Pagoh Rubber Estate/ Batang Melaka Estate No training programmed and scheduled been recorded as well as training evaluation been done to the employee in order to check the competency and understanding level of employee after training been conducted. P5 Environment, natural resources, biodiversity and ecosystem services

    Criterion 1 Environmental management plan

    Indicator Requirement Findings

    4.5.1.1 An environmental policy and management plan in compliance with the relevant country and state environmental laws shall be developed, effectively communicated and implemented.

    Atlas Paloh Rubber Estate/ Batang Melaka Estate/ Serkam Estate/ Gading Estate Sighted Environmental, Natural Resources, Biodiversity and Ecosystem Policy available dated 01/07/2018 signed by Directors (Mr Chee Kim Hoon and Tan Hin Toe)

    4.5.1.2 The environmental management plan shall cover the following: a) An environmental policy and objectives. b) The aspects and impacts analysis of all operations

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    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Environmental Aspects and Impacts Evaluation available. The total of activities/ process are 7s (harvesting FFB, spraying, application of fertilizer, pruning, rait bait application Asir 5G application and RB pheromone application. The sample as below: Activities: Harvesting FFB and loading of FFB, Significant Activities: Movement and idling of tractor, Aspect: i) Smoke emission from tractor, ii) Noise emitted from tractor, iii) Leakage of engine oil from tractor, trailer, iv) Leakage of diesel from tractor. OBS However, the aspect impact were not covered for other activities/ process available in estate. (OBS)

    4.5.1.3 An environmental improvement plan to mitigate the negative impacts and to promote the positive ones, shall be developed, effectively implemented and monitored.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Serkam Estate Verified the Pollution and Emission Management Plan. The plan has identified for activities such i) all running vehicle, ii) operation of diesel engine, iii) Running of vehicles, iv) Harvesting – operating using harvesting machine & etc. The status of completion and action such hearing test record need to verified for its needed, otherwise need to remove and maintained the required only. (OBS) Ex: Emission: Emission of noise Sourcer: Operation of diesel engine Action: To provide sound level test & hearing test record for operator handling diesel engine Frequency: Daily monitoring at work area Record: Record of maintenance Responsibility: M/ AM/ Field Staff Training: Diesel engine operation Non-Compliance 7 Ladang Serkam & Batang Melaka Estate Environmental plan was not yet developed 4.5.1.4 A programme to promote the positive impacts should be included in the continual

    improvement plan

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate OBS Refer to 4.1.3, the positive impact were not yet identified in the plan (OBS) 4.5.1.5 An awareness and training programme shall be established and implemented to ensure

    that all employees understand the policy and objectives of the environmental management and improvement plans and are working towards achieving the objectives.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Verified the Scheduled in-house training programme for workers for Jun 2018 – Dec 2018, the environmental training has included in the programme such i) Biodiversity training (Completed July 2018), ii) Briefing for MSPO guidelines (completed June 2018), General safety/cleanliness briefing (In progress) 4.5.1.6 Management shall organize regular meetings with employees where their concerns about

    environmental quality are discussed

    Atlas Paloh Rubber Estate Verified the Minute meeting of OSH Committees No03/2018 dated 21/09/2018. The minutes has mention on the cleanliness at worker quarters. The meeting attended by management team and employees representative. Non-compliance 8- All estates Regular meetings with employee on environmental was not yet conducted Criterion 2 Efficiency of energy use and use of renewable energy

    Indicator Requirement Findings

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    4.5.2.1 Consumption of non-renewable energy shall be optimized and closely monitored by establishing baseline values and trends shall be observed within an appropriate timeframe. There should be a plan to assess the usage of non-renewable energy including fossil fuel, electricity and energy efficiency in the operations over the base period.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Gading Estate/ Batang Melaka Estate The record of non-renewable energy (electricity and diesel) available, however the monitoring to observed the usage for past few year not yet available. Non Compliance 4- Atlas Paloh Rubber Estate The record of non-renewable energy (electricity and diesel) available, however the monitoring to observed the usage for past few year not yet available 4.5.2.2 The oil palm premises shall estimate the direct usage of nonrenewable energy for their

    operations, including fossil fuel, and electricity to determine energy efficiency of their operations. This shall include fuel use by contractors, including all transport and machinery operations.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Gading Estate/ Batang Melaka Estate Refer 5.2.1, the monitoring record shall include the contractor usage.

    4.5.2.3 The use of renewable energy should be applied where possible

    Atlas Paloh Rubber Estate/ Serkam Estate/ Gading Estate/ Batang Melaka Estate During site visit and interview the Estate Manager, no any renewable energy applied for the estate operation at the period of assessment. Criterion 3 Waste management and disposal Indicator Requirement Findings 4.5.3.1 All waste products and sources of pollution shall be identified and documented.

    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate Refer to MSPO Manual, the company has documented the identified source of pollution such scheduled waste, solid waste, food waste, recyclable and waste water. 4.5.3.2 A waste management plan to avoid or reduce pollution shall be developed and

    implemented. The waste management plan should include measures for: a) Identifying and monitoring sources of waste and pollution. b) Improving the efficiency of resource utilization and recycling of potential wastes as nutrients or converting them into value-added by-products.

    Atlas Paloh Rubber Estate Non-Compliance- Atlas Paloh Rubber Estate Waste management plan were not yet developed, Thus, the company was not yet to made decision on disposing the empty chemical container and the empty fertilizer beg was currently declare as domestic waste, not scheduled waste. The plan should included with the decision on handling each type of waste and the program on enhancing the recycling waste into value-added product. (NC) OBS- Ladang Serkam Scheduled waste (Pendaflour lamp) found in the dumping site. 4.5.3.3 The management shall establish Standard Operating Procedure for handling of used

    chemicals that are classified under Environment Quality Regulations (Scheduled Waste) 2005, Environmental Quality Act, 1974 to ensure proper and safe handling, storage and disposal.

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    Atlas Paloh Rubber Estate/ Serkam Estate/ Batang Melaka Estate/ Gading Estate All estate was establish the Standard Operating Procedure for handling of used chemicals available such: i) Prosidur Pelupusan, ii) Membilas bekas racun/ pam racun sete