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Roundtable on Sustainable Palm Oil Annual Surveillance Audit Report Report no.: ASA2_18502207 Surveillance assessment against the RSPO Principles & Criteria NI Malaysia year 2010 Sime Darby Plantation Sdn. Bhd. SOU 11 Kerdau Palm Oil Mill Level 3A, Main Block, Plantation Tower, No 2, Jalan PJU 1A/7, Ara Damansara, 47301 Petaling Jaya, Selangor Darul Ehsan,Malaysia. Date of Assessment: 14 – 18 May 2013 Report prepared by: Dian S. Soeminta (RSPO Lead Auditor) Certification Body: TUV Rheinland Malaysia Sdn. Bhd. No. 26 – 32, Jalan Perindustrian USJ 1/6, Taman Perindustrian USJ 1, 47600 Subang Jaya, Selangor Darul Ehsan, Malaysia. Tel: +6 03 8024 2400 Fax: +6 03 8023 1505 www.tuv.com

Roundtable on Sustainable Palm Oil on Sustainable Palm Oil Annual Surveillance Audit Report ... PJU 1A/7, Ara Damansara, 47301 Petaling Jaya, Selangor Darul Ehsan, Malaysia

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Roundtable on Sustainable Palm Oil

Annual Surveillance Audit Report Report no.: ASA2_18502207

Surveillance assessment against the

RSPO Principles & Criteria NI Malaysia year 2010

Sime Darby Plantation Sdn. Bhd. SOU 11 Kerdau Palm Oil Mill

Level 3A, Main Block, Plantation Tower, No 2, Jalan PJU 1A/7, Ara Damansara,

47301 Petaling Jaya, Selangor Darul Ehsan,Malaysia.

Date of Assessment: 14 – 18 May 2013 Report prepared by: Dian S. Soeminta

(RSPO Lead Auditor)

Certification Body: TUV Rheinland Malaysia Sdn. Bhd.

No. 26 – 32, Jalan Perindustrian USJ 1/6, Taman Perindustrian USJ 1,

47600 Subang Jaya, Selangor Darul Ehsan, Malaysia.

Tel: +6 03 8024 2400 Fax: +6 03 8023 1505

www.tuv.com

TABLE OF CONTENTS

1.0 SCOPE OF ANNUAL SURVEILLANCE AUDIT 3 

1.1 National Interpretation Used 3 1.2 Type of Assessment 3 1.3 Certification Details 3 1.4 Location and Maps 4 1.5 Organisational Information / Contact Person 9 1.6 Description of Supply Base 10 1.7 Actual production volumes, tonnages and projected outputs. 11 1.8 Dates of Plantings and Replanting Cycles 11 1.9 Area of Plantation (Total, Planted and Mature) 12 1.10 Progress Against Time Bound Plan 13 1.11 Compliance to Rules for Partial Certification 14 1.12 Progress of associated smallholders or outgrowers towards RSPO compliance 15 1.13 (Revised) Approximate Tonnages Certified 15 

2.0 ASSESSMENT PROCESS 16 

2.1 Certification Body 16 2.2 Qualifications of Lead Assessor and Assessment Team 16 2.3 Assessment Methodology & Agenda 17 

3.0 ASSESSMENT FINDINGS 19 

3.1 Summary of Findings 19 3.2 Status of Previously Identified Non-conformities 30 3.3 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions 34 3.4 Noteworthy Positive Components 38 3.5 Issues Raised by Stakeholders and Findings Pertaining to Issues 39 

4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INTERNAL

RESPONSIBILITY 39 

4.1 Date of Next Surveillance Visit 39 4.2 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client 39 

APPENDICES 40 

Appendix 1: Details of Revised Certificate (if applicable) 40 Appendix 2: List of Abbreviations 41 Appendix 3: List of Stakeholders Interviewed and Contacted 42 Appendix 4: Observations and Opportunities for Improvement 43 

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1.0 SCOPE OF ANNUAL SURVEILLANCE AUDIT

1.1 National Interpretation Used

The operations of the palm oil mill(s) and its supply base of FFB were assessed against the Malaysia National Intepretation year 2010 of the RSPO Principles & Criteria.

1.2 Type of Assessment

Ths 2nd annual surveillance certification assessment was carried out on 1 mill and 5 estates under Kerdau Palm Oil Mill owned by Sime Darby Plantation Sdn. Bhd. The date of certification of this unit was May 11 to 18, 2009.

1.3 Certification Details

The details of RSPO certification of Sime Darby Plantation Sdn Bhd, SOU 11 Kerdau Palm Oil Mill are as per the table below

Table 1: RSPO Certification details of Kerdau Palm Oil Mill

RSPO Membership no.: 1-0008-04-000-00

RSPO Certificate no.: 18502207 001

(Prevously C819155CU-RSPO-01.2011)

Date of first RSPO certificate & validity: 07/07/2011 valid until 06/07/2016

Date of certification audit: May 11 to 18, 2009

Date of previous surveillance audit: June 18 to 22, 2012

Date of revised RSPO certificate & va-lidity (if applicable):

-

CPO tonnages claimed: 48,075 MT

PK tonnages claimed: 11,368 MT

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1.4 Location and Maps

Figure 1: Location of SOU Kerdau estates and mill in Pahang, Malaysia

Kerdau POM & Estates

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Figure 2: Kerdau Estate GPS Surveyed Map

Kerdau POM

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Figure 3: Sg. Mai Estate GPS Surveyed Map

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Figure 4: Location map of Mentakab Pahang

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Figure 5: Jentar Estate estate map

Figure 7: Chenor Estate estate map

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Table 2: GPS locations for all estates and mills included in annual surveillance assessment

Note * : During the 1st certification audit, Chenor estate was part of SOU 12 Jabour, since 2010 Sime Darby management decided to include Chenor estate in the SOU 11 Kerdau and all FFB from Chenor estate is now supplied to Kerdau Palm Oil Mill

1.5 Organisational Information / Contact Person

SOU 11 Kerdau estates are owned and operated by Sime Darby Plantation Sdn. Bhd, among the largest player in oil palm industry in Malaysia. The company has 65 individual “Strategic Operating Units” units (SOU’s) and each SOU comprises a number of individual estates In Malaysia there are 39 SOU’s with 140 individual estates, extending to 229,470 ha. In Indonesia there are 26 SOU’s, (Known as companies) with 90 individual estates, extending to 295,156 ha. It is noted that 21 SOU’s (In Malaysia) have either been certified or are currently in the process of being certified.

Sime Darby Plantation Sdn. Bhd is merger of Sime Darby Berhad, Golden Hope Plantations berhad and Kum-pulan Guthrie Berhad which was done on November 2007. The company represents one of the five core Divi-sions of Sime Darby group and is involved in the following: Oil Palm cultivation, Agribusiness & Food, Research and Development. The Plantation division has location in several Malaysia locations such as peninsular Malay-sia, Sabah and Serawak and Indonesia location such as Kalimatan, Sumatera and Sulawesi. Company has to-tal 524,624 hectares of planted oil palm. All products from Sime Darby Plantation Sdn. Bhd is supplied to their division’s downstream operations which has location in 15 countries around the world. Its business activites in-clude the following; Edible oil refining, production of oils and fats products, Oleochemical and Biodisel. Along-side oil palm, the division is also involved in agri business activities and cultivationof rubber.

In keeping with the aspiration of making sustainable future real for everyone, Sime Darby Plantation Sdn.Bhd claims to make a conscious and concerted effort towarda conservation and protection of the environment, the rehabilitation of forests, protection of wildlife and promotion of the well being of the communities in which it op-erates.

Contacts details of the company are as follows:

Name of mill / es-tate

Location GPS locations

Lati-tude

Long-titude

Kerdau Palm Oil Mill

Kilang Kelapa Sawit Kerdau, Wakil Pos Kerdau, 28010 Temerloh Pahang

3º34’07”

102º18’28”

Kerdau Estate Ladang Kerdau, Wakil Pos Kerdau 28010 Temerloh, Pahang

3º34’07” 102º18’28”

Jentar Estate Ladang Jentar, Wakil Pos Kerdau, 28010 Temerloh , Pahang

3º34’07” 102º18’28”

Mentakab Estate

Ladang Mentakab/ Lanchang/ Edensor, c/o Lanchang Division, 28500 Lanchang, Pahang Darul Makmur.

3º28’67” 102º10’95”

Sg Mai Estate Ladang Sungai Mai, 27000 Je-rantut, Pahang

3º48’50” 102º21’40”

Chenor Estate* Ladang Chenor (KT), Sungai Jerik, 26400 Bandar Pusat Jengka, Pa-hang

3º34’07” 102º18’28”

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1.6 Description of Supply Base

The Kerdau palm oil mill sourced FFB from below mentioned group estate and smallholders under Sri Kerdau Sdn. Bhd., a FFB collector from smallholder. Table 3: FFB Supply Information for Kerdau Palm Oil Mill June 2013 to May April 2013

FFB Contributors FFB supplied

Tonnes %

Company owned estates:

Chenor estate 39,716.45 16.88

Jentar estate 25,407.22 10.80

Kerdau estate 45,014.12 19.13

Mentakab estate 57,850.06 24.58

Sungai Mai estate 58,310.41 24.78

Sub Total 226,298.26 96.16

Smallholders / outgrowers:

Sri Kerdau Commodities 9,038.39 3.84

TOTAL 235,336.65 100

Company Name: Sime Darby Plantation Sdn. Bhd.

Kerdau Palm Oil Mill

Address: Head Office : PSQM, Level 3A, Main Block, Plantation Tower, No. 2, Jalan PJU 1A/7, Ara Damansara, 47301 Petaling Jaya, Selangor Darul Ehsan, Malaysia.

Mill Location: Kilang Kelapa Sawit Kerdau,

Wakil Pos Kerdau, 28010 Temerloh Pahang

Contact Person: Muhammad Ali Nuruddin

Telephone: 03-78484376/019-4904599

Email: [email protected]

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1.7 Actual production volumes, tonnages and projected outputs.

Table 4: Certified tonnages claimed, certified tonnages purchased or sold, total and projected CPO and PK production from Kerdau Palm Oil Mill

*Data from period of one year starting from June 2012 to April 2013

** The product not sold yet as CSPO claimed but ISCC claimed only. The Palm Kernel production exceed than certified tonnage claimed because after 3 years from certification audit the company’s productivitie increase following the increment of mature area.

1.8 Dates of Plantings and Replanting Cycles

Information on the dates of plantings is as per the table below. Table 5: Age and year of plantings of company estate supplying to Kerdau Mill

Age & Year of Plantings Estate

Chenor Jentar Kerdau Mentakab Sungai Mai

0 – 5 yrs(2008 – 2012) 108 626.31 995.07 472.40 - 5-10 yrs(2003 – 2007) - - - - 163.42 10-15 yrs(1998 – 2002) 791 - 611.63 1149.80 914.25 15-20 yrs(1993 – 1997) 384 - 194.06 867.78 1403.43 20-25 yrs(1988 – 1992) 421 1356.70 - 186.88 166.66 25 - 30yrs(1982 - 1987) 176 - 1429.04 265.83 -

TOTAL 1880 1983.01 3229.80 2942.69 2647.76

Amount (MT)

CPO PK

Certified tonnages claimed 48,075 mt 11,368 mt

Certified tonnages sold** - -

Certified tonnages purchased* - -

Actual Production for certified product* 44,354.98 11,474.66

Actual Total production * 48,168.26 12,368.76

Projected certified output for next 12 months 53,304.77 13,960.77

Projected total output for next 12 months 55,104.77 14,433.27

Actual Conversion factor OER: 20.59% KER: 5.21%

Projected Conversion factor OER: 20.97 % KER: 5.49%

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Table 6: Planned and actual oil palm replanting activities for SOU 11 Sime Darby Plantation Sdn. Bhd.

Year Total planned replanting area for each estate (ha) Actual total ar-

ea replanted (ha) Chenor Jentar Kerdau Mentakab Sungai Mai

2010/2011 - 203.00 227.00 200.61 - 630.61

2011/2012 108.00 135.04 79.28 271.79 - 594.11

2012/2013 - 162.42 160.38 265.83 - 588.63

2013/2014 176.00 201.15 57.39 119.10 - 553.64

2014/2015 151.00 298.73 417.45 67.78 - 934.96

2015/2016 83.00 344.00 - - - 427

Total 518 1344.34 941.5 925.11 - 3728.95

1.9 Area of Plantation (Total, Planted and Mature)

Table 7: Oil Palm Planted Area Summary, FFB Production and Average yield/ha for Sime Darby Plantation Sdn. Bhd. SOU 11 Kerdau Palm Oil Mill

Estate NameTotal area

(ha)

Oil Palm Planted area

(ha)

Mature (Production)

area (ha)

Immature (Non-production)

area (ha)

FFB Production*

(tonnes)

Average yield/ ha

Chenor 2001.27 1880 1772 108 42,406.59 22.98Jentar 2234.0 1983.01 1356.70 626.31 26,904.12 21.05Kerdau 3446.93 3229.80 2450.79 779.01 43,489.59 17.44

Mentakab 3273.09 2942.69 2470.29 472.40 57,294.55 23.19Sungai Mai 2816.08 2647.76 2647.76 0 55,679.31 21.03

TOTAL 13,771.37 12,683.26 10,697.54 1985.72 225,774.16 21.11

Table 8: Land use data for SOU 11 Sime Darby Plantation

Estate Name

Total area (ha)

Oil Palm Planted

Area (ha)

HCV/

Potential HCV areas*

(ha)

Land used for other purposes (ha)

Nursery Cleared

Area Mill

Other Land

Chenor 2001.27 1880 11.22 4 - - 106.05

Jentar 2234.0 1983.01 73 - - - 177.99

Kerdau 3446.93 3229.80 7.45 16 65 20 108.68

Mentakab 3273.09 2942.69 116 8.09 - - 206.31

Sungai Mai 2816.08 2647.76 3.78* - - - 168.32

TOTAL 13,771.37 12,683.26 207.67 28.09 65 20 767.35

*Include in productive area

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1.10 Progress Against Time Bound Plan

Table 9: RSPO Certification Timebound Plan for Sime Darby Plantation (SDP)

Financial year (July – June) Targeted Achieved

June 2008 5 SOUs Sime Darby Plantation has had all its SOUs (Malaysian & Indonesian) completing the RSPO Main Assessment.

2008/2009 20 SOUs ( from Malaysia and Indonesia)

2009/2010 20 SOUs ( from Malaysia and Indonesia)

2010/2011 17 SOUs ( from Malaysia and Indonesia)

Table 10: Status RSPO certification for all Palm Oil Mill under Sime Darby Plantation Sdn Bhd

Status Malaysia Indonesia Total Remarks

Certified 39* 16 55**

*Effectively only 36 SOUs certified (starting July 2012): Jeleta Bumi POM and Mostyn POM have been closed down. Sepang POM has been con-verted to third party oil mill and not included in the RSPO Certification timebound plan.

**Total SOUs certified 52 SOUs.

RSPO EB Re-view

0 7*** 7***

• Pending review by RSPO EB.

*** Effectively only 6 SOUs as Tamiang POM had ceased operation & combined with Blang Simpo POM.

Total SOUs 39* 23 62**** **** Revised number of SOUs for SDP is 58 beginning FY 2012/2013.

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Table 11. Other RSPO Supply Chain Certified Facilities under Sime Darby Plantation (SDP)

No Business Unit RSPO SCCS Certification

Trading Option

Date of SCCS Certi-fication Process

Certification Body

Certification Date

1 Unimills B.V. SG & MB Jan – March 2009 Control Union Certified on 28

June 2011

2 SD Biodiesel SG & MB Jan – March 2010 SIRIM Certified on 25

March 2011

3 SD Jomalina SG & MB Oct – Dec 2010 SIRIM Certified on 10

March 2011

4 SD Kempas MB Jul- Sept 2011 SIRIM Certified on 19

Aug 2011.

5 SD Austral MB Jan – March 2012 SIRIM Certified on 13

April 2012.

6 NURI – SD Jomalina MB Jan – March 2012 SIRIM Certified on 13

April 2012.

7 Kernel Crushing Plant – Carey Island (KCP)

SG & MB Jan – March 2012 SIRIM Certified on 13

April 2012.

8 Morakot MB July - August 2012 SGS Certified 10 Sept

2012

9 Emery Oleochemical SG & MB March - June 2012 BUREAU VERITAS

Certified 8 Oct 2012

10 Hudson & Knights MB March – June 2012 SIRIM Certified Dec

2012

11 SDEPL - FY 2012/2013 TBI

12 GH Nhabe - FY 2012/2013 TBI

1.11 Compliance to Rules for Partial Certification

Compliance of the uncertified management units of Sime Darby Sdn. Bhd against the rules for partial certification according to RSPO Certification System clause 4.2.4 was assessed by Documentation review. A summary of findings is as stated below.

Partial Certification Requirements Audit Findings

(a) The parent organization or one of its ma-jority owned and / or managed subsidiaries is a member of RSPO.

Sime Darby Plantation Sdn. Bhd is RSPO member with membership number is 1-0008-04-000-00.

(b-d) A challenging time-bound plan for certi-fying all its relevant entities is submitted to the Certification Body (CB) during the first certification audit. The time-bound plan should contain a list of subsidiaries, estates and mills.

Any revision to the time-bound plan or to the circumstances of the company shall cause the plan to be reviewed. for whether it is still appropriate, such that changes to the time-bound plan are permitted only where the or-ganisation can demonstrate that they are justified

Company has timebound plan both for Malaysia site and Indonesia site as determined on the table 9 above.

(e) No replacement of primary forest or any area identified as containing High Conserva-tion Values (HCVs) or required to maintain or

According to previous assessment report which is carried by Control Union there are 10,317 ha in 28 estate planting between November 2005 to 2007

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enhance HCVs in accordance with RSPO criterion 7.3. Any new plantings since Janu-ary 1st 2010 must comply with the RSPO New Plantings Procedure

and 1,215 ha in 4 estates planted after November 2007. No information regarding HCV assessment. As no HCV assessments were conducted, the company cannot demonstrate compliance with this rule.

(f) Land conflicts, if any, are being resolved through a mutually agreed process, e.g. RSPO Grievance procedure or Dispute Set-tlement Facility, in accordance with RSPO criteria 6.4, 7.5 and 7.6.

According to information from Sime Darby Man-agement and interview with local communities sur-rounding company’s area, they have good relation-ship and no conflict appear relating to land dispute in all of Sime Darby’s SOUs.

(g) Labour disputes, if any, are being re-solved through a mutually agreed process, in accordance with RSPO criterion 6.3.

During this audit there is currently no case of signifi-cant labour dispute among Sime Darby Plantation’s SOUs which audited by the team. Another SOU’s compliance regarding this issue would have been as-sessed by other certification bodies.

(h) Legal non-compliance, if any, are being resolved in accordance with the legal re-quirements, with reference to RSPO criteria 2.1 and 2.2.

Some legal compliance was identified, for SOU 11 several non conformities have been identified. For other SOUs compliance regarding this issue would have been assessed by other certification bodies.

1.12 Progress of associated smallholders or outgrowers towards RSPO compliance

There are no associated smallholders supplying to Kerdau POM, only independent outgrower supply to Kerdau POM through one FFB agent i.e. Sri Kerdau Commodities Sdn.Bhd, there are no specific planning by Kerdau POM for independent outgrowers towards to RSPO compliance..

1.13 Approximate Tonnages Certified

The approximate tonnages certified shall be the same as per the original certificate, which is as follows Crude Palm Oil (CPO) : 48,075 mt Palm Kernel (PK) : 11,368 mt

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2.0 ASSESSMENT PROCESS

2.1 Certification Body TUV Rheinland Malaysia Sdn. Bhd. is member of Group TÜV Rheinland Group, a global leader in independent testing and assessment services. The TÜV Rheinland Group was established in 1872 with offices located in over 490 locations in 62 countries on all five continents. TUV Rheinland Malaysia offers certification for a wide range of management systems according to established international standards including ISO 9001, ISO 14001, OHSAS 18001, SA 8000, as well as CDM Validations and Verifications. TUV Rheinland Malaysia’s office is lo-cated in Subang Jaya, Malaysia.

2.2 Qualifications of Lead Assessor and Assessment Team The assessment team members of this surveillance audit are:

Name Position Qualifications / Experience

Dian S. Soeminta Lead Auditor

Education: Bachelors Degree in Forestry - Bogor Agriculture In-stitute. Indonesia, (1990 to 1995). Trainings attended: ISO 9001:2000 lead assessor course 1996 - Neville Clark; ISO 14001 lead assessor course - PE Interna-tional; OSHAS: 2007 training, Sustainable Forest Management (SFM) - Forest Stewardship Council (FSC) system training; RSPO P & C lead Auditor Training by Pro Forest in March 2011. Chain of Custody training for FSC System. SCC-RSPO by David Ogg Consulting March 2012. Working experience: Professional forester since 1995 to 2000. Lead Auditor for Forest Stewardship Council (FSC), Sustainable Forest Certification (SFC) and Chain of Custody (COC) Certifica-tion, Lead auditor for Environmental Management System (EMS) and Quality Management System (QMS) audits. Conducted sus-tainable forest management certification audits on FSC and In-donesian Ecolabel Institute (Lembaga Ecolabel Indonesia - LEI) standards for 20 companies, 50 COC FSC/LEI audits, and EMS and QMS audits at more than hundred companies for TUV Rheinland Indonesia. Instrumental in the preparation of TUV Rheinland Indonesia for Sustainable Forest Management Certifi-cation System and TUV Rheinland Malaysia for RSPO Certifica-tion. Member of Task Force for Indonesian National Interpreta-tion (Guidance on scheme smallholder RSPO certification). De-veloped TUV Rheinland RSPO Gap Assessment Checklist and report template.

Fadli Auditor

Education: Bachelor of Anthropology, Department of Anthropol-ogy - University of Indonesia, Jakarta. Trainings attended: Sustainable Natural Production Forest Management (Pengelolaan Hutan Alam Produksi Lestari - PHAPL) assessor training (May 2003); Forest Plantation Man-agement (August 2003) training - Indonesian Ecolabel Institute (LEI), Forest Management and Agriculture Auditor Training; ISO 9001:2008, ISO 14000:2004, OHSAS 18001:2007 trainings - Smartwood/Rainforest Alliance; SA8000 training - SA Interna-tional; RSPO Lead Auditor Training -Indonesian Palm Oil Com-missions. Working experience: Experienced as lecturer for D3 Tourism program, University of Indonesia. Social Aspect Auditor of PT. TUV International Indonesia for Sustainable Forest Management and RSPO Principles & Criteria. Researcher of Stakeholder

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Mapping With CSR Indonesia.

Azizan Zakaria

Auditor

Education: Master of Engineering (Environmental) - Universiti Pu-tra Malaysia, B. Eng in Chemical Engineering - University of Wales, Swansea Trainings attended: ISO9001: Lead Auditor Training/Course, In-ternal Auditor Training of IMS (ISO9001, ISO14001 & OHSAS18001) Working experience: 10 years experience in chemical man-agement and polyurethane production and internal auditing for process compliance with integrated Environmental Management System (EMS) and OSH Management System.

Yusof Nizar Auditor

Education: Diploma in Public Administration- MARA Institute of Technology, Malaysia (1991). Certificate of Safety and Health Officer-Malaysian Insurance Institute (2003). Bachelor of Corpo-rate Administration (Hons)-MARA University of Technology, Ma-laysia (2003), Master of Science in Occupational Safety and Health Management-Northern University of Malaysia (2011), Candidate for Phd in Occupational Safety and Health Manage-ment-Northern University of Malaysia. Trainings attended: ISO 9001:2000 IRCA/IATCA Lead Auditor Training-International Management & Technology Limited (Kuala Lumpur), ISO 14001:2004 IEMA Approved EMS Advanced Lead Auditor Training Course-Aspects Moody Certification Ltd (United Kingdom). OH&SMS IRCA Certified Lead Auditor Training Course-Moody International (Kuala Lumpur). MS 1722 Lead Au-ditor Training-Niosh Certification (Kuala Lumpur) Working experience: Experience in managing, consulting, train-ing and auditing quality, environmental, occupational safety and health management systems such as ISO 9001:2008, ISO 14001:2004, OHSAS 18001:2007, MS1722:Part 1:2005 from 1996-Current. Contract Trainer of OSH & Environmental Legal & Other Requirements Lead Auditors course for SIRIM Training Services Sdn Bhd & NIOSH Certification Sdn Bhd. Contract Au-ditor for Environmental Management System for Sirim QAS In-ternational (2006). Department of Occupational Safety and Health Malaysia (DOSH) Registered Safety and Health Officer (2003-2006). Approved Human Resources Development Fund (HRDF) Trainer (2011). Assessor for Prime Minister’s Hibiscus Award and involving assessment for oil and gas companies, plantations industries, manufacturings, utilities, cleaning and transportations services (2003-2011). OSH and Environmental Auditor for TUV Rheinland Malaysia RSPO Principles & Criteria.

2.3 Assessment Methodology & Agenda The surveillance assessment was conducted from May 14 to May 18, 2013 as per the assessment program be-low. The assessment was carried out in accordance with TUV Rheinland Malaysia’s RSPO audit procedure as well as the RSPO Certification Systems document. During assessment, the qualified TUV Rheinland assessors used the RSPO standard as endorsed for the country in which the assessment took place and recorded their findings. Due to the location and proximity of the estates, combined with common management systems, it was possible to carry out both field and document assessments of all estates and the mill within the time frame without com-promising the integrity of the assessment in anyway. Sampling 4 estates and 1 mill were visited and the assessment team carried out field and document assess-ments of compliance to all the RSPO principles and criteria. Common systems were identified and specific evi-dence was recorded for individual estates. Interviews were conducted at all estates and the mill. The company proposed the correction and corrective action for all identified non conformities raised to the certi-fication body 30 days after the closing meeting. Verification of closure of major non-conformances was con-

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ducted through document checked 1 month after the closing meeting of the surveillance audit and implementa-tion of corrective actions for minor non-conformities will be verified during the next suriveillance audit. The sur-veillance audit agenda is as explained below. Surveillance audit Agenda.

Date Location/ Main sites

Main activities

14 May Kerdau Es-tate Kerdau Mill

Opening meeting and Introduction Document Review: OSH Manual, OSH Policy SOP, legal compliance records, minutes of meeting for safety and health committee, HIRARC formats, accident records and statistics, noise monitoring report, Medical Surveillance report, CHRA report, training records, permits, Emergency Procedures and Records of OSH implementation; Records of EMS implementation; Document Review: Haz-ardous waste inventories & manifest, fertilizer application records, chemical ap-plication records, chemical stock inventoryetc. On-site visit: Mill, receiving bay, weight bridge area, Operation area, Engine room, scheduled waste store. Budget plan Checking for Incoming FFB Data Mill tour; Visiting POME ; Visiting Composting project Interview with local Workers and Migrant worker; Interview with FFB supplier Sri Kerdau Commodity; Interviews: Assistant Mill Manager, Wireman, Charman, Engine Driver, Workers at mill and receiving bay and Pahang Zone representatives.

15 May Jentar Es-

tate Document Review: OSH Manual, OSH Policy, legal compliance records, chemi-cal stock card, MSDS, medical surveillance report, HIRARC formats, CHRA re-port, training records and SOP including Social Impact Assessment, CSR pro-gram records, workers pay slips, insurance records. On-site visit: chemical store/temporary store, chemical mixing area, diesel tank area, scheduled waste store, clinic, plantation, fertilizer store, Workshop Check-ing boundery stone Visit Housing area Visit water Cathment area, Visit Green Lung. Interviews: Estate Manager, Manurers, harvesters, Store Clerk, Hospital Assis-tant, Mandores and Pahang Zone representatives Interview with worker, Sprayer

16 May2013

Kerdau Mill Supply Chain Certification audit

16 May2013

Sg Mai Es-tate

Document Review: OSH Manual, OSH Policy, HIRARC formats, legal compliance records, chemical stock card, MSDS, medical surveillance re-port, CHRA report. Minutes of meeting for safety and health committee, foreign workers compensation scheme, training records, On-site visit: Chemical Store, chemical mixing area, Diesel Tank Area, sched-uled waste store, fertilizer store, plantation, workshop Visiting Replanting loca-tion; Visiting boundary stones with Forest reserve Jengka; Beneficial plan loca-tion block 97A; Riparian watercourses block 90A; Land slope area; Ware-house/Chemica store Interviews: Estate Manager, cutters, sprayers, harvesters, Store Clerk, Hospital Assistant, Mandores and Pahang Zone representatives Interview with villager in Pekan Sungai Jerik ; Interview with Sprayer ; Interview with Harvester

17 May2013

Mentakab Estate/ Lanchang Division

Document Review: OSH Manual, Chemical Stock Card, HIRARC formats, MSDS, Medical Surveillance report, CHRA report. accident report and statistics, training records. On-site visit: chemical store, chemical mixing area, Diesel Tank Area, sched-uled waste store, clinic, fertilizer store, workshop, plantation and workers clean-ing room. Interviews: Estate Manager, cutters, harvesters, Store Clerk, Hospital Assistant, Mandores and Pahang Zone representatives

18 May2013

Kerdau Es-tate

Closing Meeting and Presentation of Audit Findings

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Kerdau Palm Oil Mill- Pahang-

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3.0 ASSESSMENT FINDINGS

3.1 Summary of Findings The following is a summary of findings during this surveillance audit for the criteria listed in the RSPO Principles & Criteria Malaysia National Interpretation year 2008.

Principle 1: Commitment to transparency

Criteria assessed: CR1.1, CR1.2 Criteria not assessed: Findings: There is no change on company’s procedure regarding request of information management. The pro-cedure was available for all relevant stakeholders that wish to request for information including workers, government agencies such as Malaysian Palm Oil Board (MPOB), and so on. As explained on the pro-cedure, that all incoming information through phone calls, walk in, mail or email will be received by company’s staff, and it will be reported to estate assistants before it is reported to the higher level man-agement who will decide whether the information will be issued or not. All incoming information is rec-orded on a form. It was sighted on the log book in the past one year that most incoming information to each estate management more about request of donation, and mechanism to approve request of dona-tion is clearly stated on the procedure. Some of request of donation has been fulfiled where some still waiting for the response from estate management for approval. As stated on the management notifcation there are some documents made available to the public based on stakeholder requests, and these documents include land titles, safety and health plan, plans and impact assessments relating to environmental and social impacts, pollution prevention plans, de-tails of complaints and grievances, negotiation procedures, and continuous improvement plans. As seen at Kerdau Palm Oil Mill found publicly available document is Safety and Health Manual Ver-sion 1:2008 covering 17 chapters. Concerned area under the Annexure A Summary of Penalty Under OSHA 1994. The OSH Policy Annexure A also that authorised by the Executive Vice President on April 2008 is available. Compliance status: Full Compliance

Principle 2: Compliance with applicable laws and regulations

Criteria assessed: CR2.1, CR2.2, CR2.3 Criteria not assessed: Findings: A mechanism for ensuring legal compliance is implemented, as checked on site such as, a wireman on compresssor in workshop found having certificate of Fitness i.e. PMT no. 75953, the mill has written approval for chimneys i.e. appoval letter from DOE dated 19th August 2009 for one unit boiler, one unit chimney and one unit multicyclone dust collector at Kerdau mill. High noise level from mill operation was monitored as reported in November 2011 (GST/1111/24T3(3) and results were found to be in compliance with Noise Exposure Regulation 1989. For the estates, tracking the changes of Legal and other requirements is responsibility of the TQEM-Plantation in the Standard Operation Manual Version 1:2008. There is evidence of legal compliance in validity of required estate permits and licenses. For example, in Jentar estate compressor (Air receiver tank) at workshop PH PMT 3304 found valid until 20th April 2014. At workshop Sg. Mai estate found pressure vessel (compressor) PH PMT 2834 having valid certificate of fitness that will be expired on 17th January 2014. While in Kerdau Estate, there was documented evidence on information on legal and other requirements as in Legal and Other Requirements Register approved by Estate Manager dated 30/7/11. At Kerdau Mill, sampled requirement on Permit (PMT) under FMA 1967 for certificated machinery especially compressor PH PMT 1318 (Mill W/shop), PMT 75171 and PMT 75170 were still

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valid. Another evidence of compliance was in Kerdau Estate, the compressor PH PMT 2801 at work-shop have valid permit as sample on legal compliance requirement related to FMA 1967. A Legal Compliance Register approved by Estate Manager dated 30/7/11 is available. The company conducts regular legal compliance checks using compliance score cards. In Chenor Estate, the Evalua-tion of Compliance Score Card shown 100% Compliance status and approved by Estate Manager on 18/10/11 and there were 15 legal requirements listed and 2 other requirements. In Jentar estate, the evaluation of compliance score card for legal compliance was reviewed and approved by estate man-ager on 28th February 2013. Status 100% compliance. However, it was found that compliance checks results were not accurate, as seen from evaluation of compliance Score Card approved by Mill Manager and Jentar estate manager. It was found the score card does not reflect actual compliance status as evidence found that some of the legal requirements wrongly decided as “Not Applicable” even actually those are “Applicable” and should be included in the evaluation of compliance process such as: 1. Environmental Quality (Clean Air) Reg. 1978 requirements for written approval for chimney, fuel burn-

ing equipment, air emission standard etc, for the mill.

2. At Jentar estate, legal requirement register under page 8, for part V (Notice of occupation for Factory & Registration & Use of Machinery under Section 37,38,34,39,35,43,44. Factories and Machinery (Safety, Health and Welfare) Regulations, provision of Regulations 24, 25 and 26.

Company has a system for tracking any changes in the law, however revised Environmental Quality Assurance 1974 revised August 2012 was not identified and included in the Legal Register, revised EQA 1974 not identified in Jentar estate, Sg. Mai estate and Kerdau Mill. The estates and mill staff still not aware with the changes. The right to use land can be demonstrated, and there are no disputes on land use with local communi-ties. Kerdau Palm Oil mill located in Kerdau estate which has land titles from the Land and Surveying Department of Pahang state bandar pekan Mukim Kerdau Lot No. PT 575 with total area 4856.22 ha registered in September 9, 1987 valid for 99 years with land use right No. 060803HSD00005401. There are 22 land title for Mentakab estate with total area 3273.09 ha SOU 11 can show that they comply with the terms of the land title as seen on payment evidence dated Feburary 22, 2012 to Pahang Darul Makmur state. Boundary stones were sighted and well maintained at the border between company’s estate and other land owners, as seen on the border of Kerdau estate with FELCRA, Mentakab estate with Forest re-serve area, Program to monitor and maintenance of Boundary stone and Markers has been estab-lished, as seen on boundary stone maintenance records in Mentakab, Jentar and Sg. Mai estate. There are six monthly maintenance program records on March 2013 available on each estate. The company has boundary stones survey map to inform about the existing boundary stone. Repainting of the boundary stones and markers will be done annually including clearing the bushes and maintaining the cleanliness of the location of the boundary stones and marker. All these activities are the responsi-bility of the assistant field conductor together with a certified surveyor. Plantation managers and the senior manager will verify implementation of all programs annually. As confirmed to local communities’ surronding SOU 11 estates, there is no land owned by this compa-ny identified as encumbered with customary rights in all estates. Compliance status: Non Compliance NCR 2013-01 of 09 Evaluation of Compliance Score Card approved by Mill Manager and Estate Managers was found not reflecting actual compliance status as evidence found that some of the legal requirements wrongly de-cided as “Not Applicable” even actually those are “Applicable” and should be included in the evaluation of compliance process, such as: 1. Environmental Quality (Clean Air) Reg. 1978 requirements for written approval for chimney, fuel burn-

ing equipment, air emission standard etc, for the mill.

2. At Jentar estate, legal requirement register under page 8, for part V (Notice of occupation for Factory &

RSPO 2nd Annual Surveillance Audit Report

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Kerdau Palm Oil Mill- Pahang-

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Registration & Use of Machinery under Section 37,38,34,39,35,43,44. Factories and Machinery (Safety, Health and Welfare) Regulations, provision of Regulations 24, 25 and 26.

NCR 2013-02 of 09 Found Revised Environmental Quality Act 1974 that was revised on August 2012 not identified and in-cluded in the Legal Register. The Mill and Estate sampled not aware of this changes as according to par-agraph 6.1 of the Standard Operating Manual version 1:2008, stated that identify changes of Legal and other Requirements is the responsibility of the PSQM Department.

Principle 3: Commitment to long-term economic and financial viability

Criteria assessed: CR3.1 Criteria not assessed: - Findings: Annual budget for fiscal year July 2012 to June 2013 was available on Kerdau POM, the information stated on the annual budget is Operational expenditure (Opex) Capex and other operation cost. There is also planning for Kerdau mill from year 2011 to 2016 that will be revised every year following current condition. Each estate has their own annual budget such as annual budget for Sg. Mai estate for fiscal year 2013/2014 and 2014/2015. In July 2012 to June 2013 company has budget for CPO production is 55,104.77 kg, PK production is 14,433. 27, OER is 20.97% and KER 5.49%. Sime Darby plantation head issued revised letter for re-planting program in SOU 11, according to that letter and as determined on SD Agricultural reference Manual, the planning for next 5 years as seen on the table 6 section 1.8 above and actual replanted area for year 2011/2012 are 588.63 ha. Replanting will be conducted for plantation area which has cri-teria such as for coastal estate, fields which are older than 20 years and whose average annual yield is less than 20 mt/ha/year or have attained an average palm height of more than 15 m; for Inland estate fields which are older than 20 years and whose average annual yield is less than 18 mt/ha/year or have attained and average palm height of more than 15 m. For the next 5 year there will be total 3728.95 Ha plantation in 4 estates under SOU 11 will be replanting as explained on Table 6 section 1.8 above. Compliance status: Full Compliance

Principle 4: Use of appropriate best practices by growers and millers

Criteria assessed: CR4.1, CR4.2, CR4.3, CR4.4, CR4.5, CR4.6, CR4.7, CR4.8 Criteria not assessed: - Findings: There is no changes on company’s documented SOPs for estate operations as seen on Sime Darby Agriculture Reference Manual issued by Sime Darby Plantation Head Office, covering nursery practic-es, land clearing and preparation, soil conservation & terracing, road construction and maintenance, establishment of leguminous cover crops (LCC), planting density and planting technique, upkeep of immature and mature palms, pest and diseases, manuring, EFB application, harvesting, bunch census and palm thinning. Some changes in company’s mill operation due to company implement RSPO sup-ply chain system and ISCC especially for incoming FFB, incoming CPO/PK order and outgoing product dispact to cover SCCS requirement, the other SOP still not changes such as reception, sterilizer sta-tion, press station, threshing, oil room (clarification), kernel plant, lab, CPO dispatch, engine room, electric, workshop, vehicles, and boiler station. Internal audits are conducted annually at estates, e.g. the internal audit report for Kerdau estate and palm oil mill January 2013 was sighted. Recommendation for fertilizer was issued annually by the Sime Darby Research & Development De-partment which includes fertilizer recommendations. Actual fertilizer applications are recorded monthly and available in each estate such as records of fertilizer activities in Jentar estate, Sg. Mai and Men-takab estate. The application of fertilizer was mostly on schedule as recommended. Leaf analysis is consistently conducted annually and results for each estate are available in each estate, analysis is

RSPO 2nd Annual Surveillance Audit Report

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Kerdau Palm Oil Mill- Pahang-

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conducted by Sime Darby Research Sdn. Bhd. Soil analysis still not conducted again because compa-ny will conduct every 5 years, the last soil analysis was conducted on March 02, 2012. Fertiliser rec-ommendation for Jentar estate dated issued on 24 February 2012 with types of fertilizer recommended are Muriate of Potash (MAP), Ammonium Chloride (AC), Kieserite, Compund 25 (CCM25), Compound 44 (CCM44). For 2013 the study has been done in January but the analysis results are not yet re-ceived. Leaf analysis for Sg. Mai estate was done on 14 December 2012 with major element of Ash, N, P, K, Mg, Ca detected in % on dry matter. Fertliser recommendations dated 14 Dec 2012 from Sime Darby Research & Dev with types of fertilizer recommended are Muriate of Potash (MOP), Ammonium Chloride (AC), Rock Phosphate (RP). Fertliser recommendation for Mentakab estate dated 21 January 2013 from Sime Darby Research & Dev with types of fertilizer recommended are Ammonium Chloride (AC - 25% N) and Muriate of Potash (MOP - 60% K2O) Guidance to protect watercourses stated on Sustainable Plantation Management System (SPMS) Ap-pendix 14, version 1, 1 January 2010 as the best practice to include protection of water courses and wetlands, including maintaining and restoring appropriate riparian buffer zone or before replanting along the natural waterways within the estate. In the Slope and River Protection Policy also highlighted the issue dated April 2011. In Jerantut division, there are some hilly area which has slope > 25˚, how-ever there is no topography map and the company has no identification of the area which has high po-tential erosion. In addition, the company also has no program to prevent soil erosion and degradation Effluent treatment test report is done on a monthly basis and conducted internally by Sime Darby Re-search Sdn Bhd in Kerdau estate which is accredited with MS ISO/IEC17025 (SAMM No 030), to ensure BOD is below 100 mg/l is complied with Environmental Quality (Sewage and Industrial Effluent) Regula-tions 1979, paragraph 8 (Discharge of effluent). There is found effluent analysis report on February and March for pH and Suspended Solids parameters exceeded government standard however no action taken by the mill, and this is raised as a non conformity. Sime Darby Plantation: Plantation Quality Management System, Appendix 7, Version 1, 1/11/2008 - SOP for taking water samples from streams/rivers has clearly described that frequency of water sam-pling shall be carried out on quarterly basis (Jan, Apr, Jul, Oct) however, records show that the sam-pling is not done according to schedule and this was raised as a nonconformity. In Jentar estate, water analysis done on quarterly basis with latest on 3 May 2013 and 3 February 2013. Latest test was in Oc-tober 2012 with results showing no traceability of pesticide. However for last year test analysis only done on 22 May 2012 and 16 October 2012 which is not accordance to the frequency quarterly. Water analysis was done on quarterly basis with latest on April 2013 but no report is available. Previous test was done in 23 January 2013 with results showing no traceability of pesticide. In Mentakab Estate, wa-ter analysis done on 7 May 2013 with no tracebility of pesticides. All results are satisfactory based on Class I of INWQS from natural wateways. All estates conduct monitoring of rainwater as seen on rainfall recorded latest 101.90 ml (April 2013) and 189.20 ml (Mar 2013) in Jentar estate and for Sg. Mai the rainfall recorded latest 222 ml (April 2013) and 74 ml (Mar 2013). Total to date recorded is 749.5 ml. At Mentakab estate, rainfall recorded latest 122 ml (Apr 2013) and 186.5 ml (Mar 2013). Total to date recorded is 625.50 ml (2013). Water monitoring usage from July 2012 - Mar 2013 is sighted between 1.24 - 1.83 tonnes of water per ton of FFB. All estates has contingency plan during water shortage. As water management program company establishes a contingency plan during water shortage for 2012/2013 dated 5 July 2012. (1) To purchase water from Perbadanan Air Pahang (2) To train staff / educate to conserve water - collect rainwater for recycle. Road maintenance activity in Sg. Mai estate only road grading program. Total road maintenance pro-gram for year 2012/2013 i.e. 3718.42 ha (3 maintenance rotation) as seen on Machinary Rental book November, December 2012. The company has a detailed SOP on Pests and Diseases management , which includes description of various pests (including bagworms, nettle cat-erpillars, rats, rhinoceros beetles, grasshoppers, bunch moths, etc) and diseases (including seed-ling blight, early leaf disease, ganoderma, leaf spot, leaf rot, blast, etc). The SOP includes methods of conducting pest census, rate of chemical treatment, control measures and critical hazard levels for main pests, and also states that prophylactic spraying is not recommended. Beneficial plants establishment year 2012/2013 were conducted in all estate, it was al-so observed in the field that there are areas that have been planted with beneficial plants such as Tunera subulata, Antigonen leptopus, and Cassia cobanensis. These plants attract natural predators of leaf-eating insects, and are a form of biological control of leaf pests. In Jentar estate Barn owl census

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Kerdau Palm Oil Mill- Pahang-

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was conducted every 6 months and the latest in Feb 2013 and April 2013 in Sg. Mai Estate, Ganoder-ma census latest in April 2013. Monitoring pesticide usage per hectare and per tonne FFB production was conducted on July 2012 - April 2013 in Jentar estate. Chemical name used Blazer 250/Kenlon, Ally, Touch Up, Basta and Hextar Cyper. Usage recorded as 0.152 kg per hectare to 0.321 kg per hectare. Quantity kg per tonne FFB recorded from 0.126 kg per hectare to 0.229 kg per hectare. In Sg. Mai estate monitoring was conduct-ed on August 2012 to April 2013 chemical name used Ally, Touch Up, and Amine, Sodium Chlorate, wet & stick and Glyphosate. Usage recorded as 0.012 kg per hectare to 1.592 kg per hectare. Quantity kg per tonne FFB recorded from 0.001 to 0.230. While for Mentakab estate monitoring of pesticide us-age kgs per ha is 0.004 to 0.290 while per tonne FFB is 0.001 to 0.131. The chemicals used are Thiram, Ally, Touch Up, Hextar Cyper, Basta and Kenlon. There were records (stock card) being used at chemicals store as evidence sampled in 3 plantations estate (Jentar, Sg, Mai and Mentakab). In Mentakab Estate, there was no spraying activity going on during audit as the spraying cycle was just completed before the audit according to the Estate Manag-er. As evidence at all estate sampled during the audit (Jentar, Sg. Mai and Mentakab) shared the same OSH Manual dated 28/8/08 that covered by procedure for handling agrochemicals. It was found in all estates chemical being stored in a safe and proper condition and locked in the Chemical Store. The availability of signage displayed at Chemical Mixing Area. They also have MSDS Corner and displayed MSDS for Sodium Cloride, Diuran and Basagran for reference during daily op-eration. Medical surveillance for 4 sprayers in Jentar estate was conducted in 27th July 2012 from Sulaiman Temerloh Clinic with good result, for Mentakab estate medical surveillance was conducted on 27th July 2012 for 12 sprayers also the result are good. No women workers identified as involve with pesticides activities, especially spraying. Sampled at Block 7 Jentar estate, Supervisor, Mandore and Sprayer also mentioned the same as name displayed in the Human Resources Development Chart in the Meeting Room, similar condition in Sg. Mai estate no woman workers involve with spraying activities. There was no work related to pesticides for pregnant and breastfeeding women, this is confirmed also with every estate manager. The existing Safety and Health Policy were communicated to foreign workers and local workers, as in-terviewed on site. The Safety and Health Policy displayed in office Conference Room, Notice Board. Signed by April 2011 by Executive Vice President. In Jentar estate there is OSH Manual documenting OSH plan and in line with OSHA 1994 requirements. 2 sprayers were interviewed to determine their understanding on OSH Policy, the level of understanding need to be improved as they not able to ex-plain the policy well. OSHA Policy signed by Executive Vice President displayed in the Meeting Room. Sg. Mai estate and Mentakab estae using the same OSH Policy being displayed in the meeting room. The HIRARC is not updated and reviewed properly in all area, some activity in Kerdau mill, such grass cutting activity was not identified in the HIRARC, this is raised as a non conformity. Interviewed grass cutter, he said that the activity is being conducted daily at mill, quarters and workers housing area. There were possibility of property damage and injury as a result of hard object flying from the blades rotation. HIRARC was revised on 3rd May 2013 prepared by company’s Environmental Health and safety staff. There is scoring system to decide control of risk however this is no documented in the Op-erational Safety and Health Manual Version1:2008. Evidence found few high risk activities identified in the HIRARC that have high score for risk but not having any proposal for action taken, e.g. at Boiler Station - Step 4: Boiler workers at boiler silencer (12), Boiler Section: Firing- Step 1: Feed fibre & shell mixture from furnace door (9), Step 3: Feed sufficient fuel (8), Section: Shell Elevator-Step 2: Fill bucket with shell (9), Step 5: Feeding shell by using Bobcat tractor (9), Section Boiler- Step 1: Open all main steam trap bypass (12), Step 5: Fuel feeding (8) etc. According to OSH Manual, under para 7.5 (b) Control measures for newly identified high risk activities shall be recommended to the HIRARC team to be recorded in the HIRARC form and implemented. In Jentar estate HIRARC 2012/2013 reviewed on 4th April 2013 by estate staff and approved by Estate Manager. For Road Surfacing Step1 (8), Con-struction of run-offs Step 1 (8) not having any recommended risk control too. At Sungai Mai estate scrap yard near scheduled waste store observed old tyres kept in the open space and trapped water and observed larvaa in them. This was not identified in the HIRARC (biological hazard) revised in 19th March 2013, this is raised as a non conformity. Several awareness and training programme relating safe working practices was done such as. In Kerdau mill, Wheel Loader (Caterpillar) drivers were trained 14th March 2013 attended by 8 training participant as seen on training evidence such as photo of evidence attached to the attendance list. Training on Safe Chemical & Schedule Waste Handling conducted on 30th November 2011 for chemi-

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cal storage staff however Sg. Mai Store Clerk not attended any chemical management training. It was sighted during site/mill visit, several workers without proper PPE such as evidence at Mill’s En-gine Room and Jentar estate, issuance of PPE has been recorded on PPE records book (2013) . Safety and Health Committee displayed in the Meeting Room Sg. Mai estate. Chairman is the estate manager and comprised of 7 employer representatives and 6 employees consecutive meeting absent. In Sg. Mai estate there is OSH Committee Organization Chart 2012/2013 the Chairman is Estate man-ager, Secretary is Manager Asistant, and there are 7 employer representatives. There is a Safety & health committee Minutes of Meeting on 12th April 2013 and 11th January 2013. There is accident and emergency procedures exist and instructions as found on the mill, i.e. Procedure Crisis Management, & Emergency Preparedness and Response Plan (EPR) Chapter 13 in the OSH Manual & Emergency Preparedness and Response Procedure in Standard Operation Manual Version 1:2008 however the procedure not explaining the detail element of preparedness especially type of equipments needed and the needs to maintain then in good working condition. Hose Box for fire hy-drant found not in good working condition and maintained as evidence found during touring the mill op-eration area. There is found in Jentar estate Accident Investigation and Reporting Procedure under OSH Manual Ver 1:2008 capter 14. Emergency procedure were understood when sampled with man-dores. The mandores from Jentar estate was attended training and briefing by Medical Assistant as well as from Sg. Mai estate, the training evidence was found for 1st Aid Training conducted on 12th September 2013 conducted by 11 training participant. It was found that first aid box at worksite was not always available at worksites such as at Block 9K4 in Kerdau Estate, mandore not having it when asked. The mandore for group of harvesting workers at Kerdau Estate was found also not having the first aid box as it was kept by the other group under his care. While in Block 99 (Kubur Tamil) in Mentakab Estate, the mandore has a small first aid box and not sufficient to be used for 12 harvesters under his care. Spraying mandors at block 7 Block 03S and 975B of Jentar estate had first aid kits but mandore at Block 2 left his first aid kit at home. Chemical Safety Data Sheet available at worksite. This was raised as an observation. There is no accident reported in sampled area Jentar estate and Sg. Mai estate. All worker including foreign workers has been covered by accident insurance i.e. FWCS in policy no FW036128 cover from 1st July 2012 until 30th June 2013 for workers no. U361727 and B0154544 at block 03 S. A training programme was established as seen in Jentar estate, there is training program for year 2012/2013-Training Requirement for Operating Units (Estate) listing 21 trainings to be conducted from July 2012 until June 2013. Some trainings were observed not conduted according to schedule: Chemi-cal Safety Training (April), Defensive Driving Training (April), Safety Committee Training (December), Legal Compliance training (January). Training evidence was found in Mentakab estate i.e. Tractor and lorry driver’s test conducted on 16th May 20 13 and Spraying on 26th April 2013. Compliance status: Non Compliance NCR 2013-03 of 09: There was found an effluent analysis report dated February and March for pH and suspended solids parameters was exceeded the government standard, however there was no action taken by the mill. NCR 2013-04 of 09:

The company has established map of locations which have potential erosion, but there is no company plan (documented evidence) of practices minimizing soil erosion and degradation such as for area 25° and sandy soil e.g Jerantut Division etc.

NCR 2013-05 of 09:

Sime Darby Plantation: Plantation Quality Management System, Appendix 7, Version 1, 1/11/2008-SOP for taking water samples from streams/rivers has clearly described that frequency of water sampling shall be carried out on quarterly basis (jan, Apr, Jul, Oct) however, records show that the sampling is not done

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according to schedule

NCR 2013-06 of 09:

The Hazard Identification and Risk Assesment and Control (HIRARC) were not conducted effectively as evidence found:

1. Grass cutting activity that is being conducted daily at mill, quarters and workers housing area was not identified in the HIRARC document.

2. According to OSH Manual, under paragraph 7.5(b), control measures for newly identified high risk ac-tivities shall be recommended to the HIRARC team to be recorded in the HIRARC form and implemented. Found in the newly revised HIRARC (2013), there were no recommended actions taken for some identi-fied hih risk activities scored more than 8 but there was no proposal for action taken, i.e. for Section Boil-er- Step 1 (Score 12), Road surfacing- Step 1 (Score=8) Construction of run-offs Step 1 (Score=8)

3. Potential Biological Hazard at workplace from old tyres kept at scrap yard near scheduled waste store in Sg. Mai Estate was not identified in the HIRARC which was newly revised on 19th March 2013.

Principle 5: Environmental responsibility and conservation of natural resources and biodiversi-ty

Criteria assessed: CR5.1, CR5.2, CR5.3, CR5.4, CR5.6 Criteria not assessed: CR 5.5. Findings: Environmental Impact Evaluation in Kerdau mill has been conducted and no changes from previous evaluation. Environmental Aspect and Impact Assessment Identification have been reviewed 9 March 2013 with no changes from previous assessment prepared by QMO (Quality Management Officer) and approved by Mill Manager. However, no assessment on empty containers at laboratory and wastewater treatment plant. In Mentakab estate, environmental aspect and impact Evaluation has been conducted and no changes from previous evaluation it have been reviewed on 8 February 2013, for Sg. Mai estate evaluation was conducted on 25 Jan 2013. The company has establish Environmental Management Program such as Environment Management Programme 2012/2013 dated 6 Jan 2013 for Kerdau mill i.e. (1) to ensure final discharge below 100 mg/l with monthly sampling to R&D (2) to ensure smoke density reading below rengelment 2 with con-trol shell in boiler, proper operation and to submit by monthly the reading to DOE. For Jentar estate Environment Management Programme 2012/2013 dated 6 July 2013 (1) manage domestic waste ac-cording to SPMS, Appendix 9 (2) Ensure quality of water river (Sg Krau) are according to EQA 1974 (3) Dusty road (concrete road). And for Sg. Mai estate Environment Management Programme 2012/2013 dated 9 July 2013 (1) minimize dust along the road from main entrance to office (2) Ensure scheduled waste is disposed before 180 days or 20 tonne whichever comes first - training, inventory and pro-gramme FY2012/2013 dated July 2012. The company revised biodiversity assessment for all SOU 11 area in year 2012 even most information determined on the report still refer to the previous version of the biodiversity assessment document. The revisions made were only to comply with previous year audit findings. There are no other signifi-cant changes to the document. According to the company’s revised Biodiversity baseline assessment, there are 6 potential HCV areas in Jentar estate i.e. Water Catchment location at blocks OP 86KA, OP 89KG and OP 86KH, Workshop area location on Linesite compound, Bukit Kitab location on OP 88JN, Jentar estate has set aside 13 ha of Bukit Kitab as Biodiversity area for its demographic pattern and with has slope more than 25o, in-cluding abandoned area location in waste land. Jentar estate has also set aside 175 ha as biodiversity area for its demographic pattern, including boundary to forest reserves located at blocks OP 88JA, 87JB, & JC, 87JD,87JE &JF,87JG,87JH,87JI,87JK,88JK,88JL,88JM of Jentar estate located beside Kuala Krau Forest Reserve separated road. There are 5 protected areas in Sg. Area estate as stated on biodiversity plan i.e. boundary area with Forest reserves i.e. block 03S; 00SA; 00SB; 00SC;00SD; Riparian along Sg. Mai river with total area 7.3. Worship area i.e. Mosque and Hindu's temple; water catchment area; used effluent pond. As explained on biodiversity plan, most of estate is dominated by production system of oil palm, and for some open area around estate housing mill effluent have biodeversity potential such as underbrush

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plant. Several bird species were found during assement, such as Oriolus chinensis (Black-naped Ori-ole), Halcyon smyrnensis (White-Throated Kingfisher), centropus sinensis (Greater Caoucal), Common Myna and Dove. Birds are commonly recorded at replanting area, immature palm fields, effluent pond and human settlements area. The mammal diversity found in the field such as Rat (Rattus tiomanicus), Longtailed macaque (Macaca fascicularis) squirrel and Barn Owl. The estate still has potential attack by elephant from Kemasul Forest Reserve. The company has revised Biodiversity action plan for year 2012/2013, for example in Mentakab estate there are 5 action plan for identified HCVs such as:

- To educate sprayers to not spray at buffer zones. Frequent check of the buffer zone including signage of “Buffer Zone”, No Hunting, No Fishing, No Swimming, and No Spraying and marking of the buffer zone along boundary to reserve forest (Kemasul reserve forest)

- To ensure there is no encroachment (trenching) and availability of warning sign. - To monitor the cleanliness of worship area by follow the rubbish collection schedule and grass cut

schedule at worship area (Field no. OP 87B Mosques, Field OP 98A & OP87B Tample) - Tree Forest Planting - Construct electrical fencing boundary at field 11A, B and C.

To prevent human-wildlife conflict with elephant from Kemasul reserve forest, there is a letter issued by Mentakab estate to Jabatan Perhilitan negeri Pahang. The letter was issued on December 27, 2011 be-fore the 1st surveillance audit. According to explanation from Mentakab estate staff, the officer from Jabatan Perhilitan came to the estate to see the impact of elephant attraction to the field on December, 2012, but no documented evidence regarding that visit. The company made Working Program for Elephant Control year 2012/2013. As stated on the working plan several activities will be done such as,

- Construction of Elephant Trenching to repair the existing trench becomes deeper and wider. - Electrical fencing construction - Maintenance of Electrical fencing - Road Grading-Boundary Road

At the 2nd surveillance audit the electrical fencing still under construction by subcontractor “Silent Proto-col Enterprise”. There is record of monitoring to see oil palm damage caused by elephant as seen on “census palms Elephants Damage Book”, as recorded on the book there were 442 trees broken. There is no more monitoring record for year 2013 because no more palm trees on the field nearby the Kemasul Forest. The potential of elephant attraction still happen, company should continue monitor the elephant activi-ties inside plantation area. No evidence of hunting, fishing or other activites at the mill and plantation estates. Signage have been put in place to remind or warned of the commitment. Both in Jentar estate and Kerdau mill, domestic waste are segregated accordingly to plastic, glass and paper and available at mill area in Sustainable Plantation Mgmt System, Appendix 9, version 1, 1/11/2008. Scheduled waste has been identified in Mill Quality Mgmt System, Section VII, version 1, 1/11/2008. Waste Management Plan 2012/2013 dated 8 July 2012 is sighted. Scheduled waste: used batteries, lubricant oil, used rags are identified at worksyop. Domestic waste: rubbish, sewage are identified at of-fice,store. Recycled waste: EFB, compost and scrap iron identified from mill, compost plant and scrap yard. Kualiti Alam is the authorized contractor to collect the scheduled waste with latest collection on 22 Jan 2013 (ref: 0021546) i.e. SW410, SW324, SW409, SW110 and SW306. Previous collection was on 4 Sept 2012 (ref: 0026477). License issued from DOE to Kuality Alam for collection of various type of scheduled waste is valid from 1 May 2013 to 30 Apr 2014 and renewed yearly. Authorized to disposed, stored, incinerate the scheduled waste. Waste Management Plan 2012/2013 in Jentar estate dated 3 July 2012 is sighted. Scheduled waste: used batteries, lubricant oil, used rags are identified at worksy-op. Domestic waste: rubbish, sewage are identified at office, store. G-Planter Sdn Bhd is the authorized contractor to collect washed pesticide containers (triple rinse) by the Johor Agricultural Dept dated 14 June 2010. This is accordance to a letter from DOE dated 7 Nov 2002 stated that the rinsed pesticide is not considered as scheduled waste and can be disposed under certain conditions. Waste Manage-ment Plan 2012/2013 in Sg. Mai dated 7 February 2013 is sighted. Scheduled waste: used batteries (SW102), lubricant oil (SW305), used rags SW409), empty pesticide containers (SW410) are identified. Domestic waste: rubbish, sewage are identified at office, store. Clinical waste (SW404). Kualiti Alam is the authorized contractor to collect the Schedule Waste as sighted from the agreement dated 12 July

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2012. License issued from DOE to Kuality Alam for collection of various type of scheduled waste is val-id from 1 May 2013 to 30 Apr 2014 and renewed yearly. Authorized to disposed, stored, incinerate the scheduled waste. Inventory of SW Fifth Schedule as sighted as in 31 March 2013 with SW305, SW409, SW425, SW102. In Mentakab estate, was found that G-Planter Sdn Bhd and Alivirgo Sdn Bhd are the authorized contractors to collect scheduled waste, with license issued by the DOE valid from 1 May 2013 - 30 Apr 2014. However, storage of Scheduled Waste is not accordance to the Environmental Quality (Scheduled Waste) Regulations, 2006 where it was sighted that containers are not properly or clearly labelled as specified in Third Schedule and not marked with waste code as in First Schedule for identification and warning purposes. The date when the scheduled waste are first generated, name, address and tele-phone no. of waste generator are not clearly labelled on containers that are used to store the sched-uled wastes. It was sighted also some empty containers are left in drain at Jerantot Division. Record of fibre used per ton FFB (0.48) and shell per ton FFB (0.05) with combined usage at 0.53 per t FFB in Kerdau mill. Record of renewable energy usage (mt) / CPO (mt) is sighted between 2.49 - 2.63 t per ton CPO. Diesel usage per ton FFB (July 2012 - April 2013) between 0.2 Litres/tonnes FFB to 1.38 litres/tonnes FFB. In Jentar estate there is permit to store diesel from Ministry of Consumer with capacity 11,000 Li-tres.(ref:PPDNKK/TLOH/SK/05/94-D) valid from 3 July 2012 to 2 July 2013. Average usage of diesel is recorded between1.60 to 3.00 litres per ton of FFB. In Sg. Mai estate, average diesel usage is 1.31 to 2.59 litres per ton of FFB from August 2012 - April 2013. Permit to store diesel from Ministry of Con-sumer with capacity 15,000 Liter (ref:PPDNKK.JRT.03/02/39 (PA) PD) valid from 18 October 2012 to 17 October 2013. In Mentakab estate, average diesel usage is 0.24 to 0.70 litres per ton of FFB from July 2012 - March 2013. Permit to store diesel from Ministry of Consumer with capacity 6,000 liter (ref: PH/TLOH(SK)324/81 (P/D)) is valid from 21 November 2011 to 20 November 2012. However, there is no evidence to show that the permit has been renewed even the application to renew the permit has been submitted dated 15 October 2012 and until now there is no permit has been provided yet. In Ker-dau estate, average diesel usage is 0.36 to 1.14 litres per ton of FFB from July 2012 - March 2013. Permit to store diesel from Ministry of Consumer with capacity 15,000 liter valid from 19 January 2012 to 20 January 2013. Similar with Mentakab estate there is no evidence to show that the permit has been renewed even company already submit the application for renewal on 15 December 2012 and till now there is no permit has been provided yet. Since the delay in approval is from the local authorities, this was raised as an observation. Kerdau mill has established Pollutions Preventive Management Plan 2012/13 prepared dated 6 July 2012 with mitigation action to control pollution. Pollution source such as workshop, linesite/housing, chemical store, effluent and emission with means of mitigation to control the pollution. Also included monitoring and action plan for each mitigation. In Jentar estate, the Pollutions Preventive Management Plan 2012/2013 is prepared dated with mitigation action to control pollution. Pollution source - work-shop, linesite/housing, chemical store/mixing area, diesel store, landfill and transport with means of mit-igation by monitoring. In Sg. Mai estate, the Pollutions Preventive Management Plan 2012/13 prepared dated 16 July 2012 with mitigation action to control pollution. Pollution source include vehicle/ machin-ery exhaust, noise, disposal of containers and domestic waste. Compliance status: Non Compliance NCR No. 2013- 07 of 09 Storage of Scheduled Waste is not accordance to the Environmental Quality (Schedule Waste) Regula-tion 2006, where it was sighted that containers are not properly or clearly labeled as specified in Third Schedule and not marked with waste code as in First Schedule for identification and warning purposes. The date when the scheduled waste are first generated, name, address and tel no of waste generator are not clearly labeled on containers that are used to store the scheduled waste.

Principle 6: Responsible consideration of employees and of individuals and communities af-fected by growers and mills

Criteria assessed: CR6.1, CR6.2, CR6.3, CR6.4, CR6.5, CR6.6, CR6.7, CR6.8, CR6.9, CR6.11 Criteria not assessed: 6.4, CR6.10 Findings:

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There is a documented social Impact assessment (SIA) for estate plantation and mill Pahang region made by Sime Darby research and development department on March 2009, made with participatory company’s stakeholders as informed on the SIA document. However The Social Impact Assessment report does not cover the Orang Asli Community Suku Jah Hut who live at a reserved area inside Sg. Mai Estate and Kampong Leleh community who live next to Mentakab Estate. This is inconsistent with RSPO requirement. The company made an action plan to mitigate and monitor all identified negative impacts, yearly monitoring plan made on each estate, same condition with the document social impact assessment, the action plan also not included management for impact to: the Orang Asli suku Jah Hut in Sg. Mai Estate and Kampong Leleh community in Mentakab Estate, this is raised as non conformi-ties. There have been no changes to company’s documentation such as a documented consultation and communication procedure is determined on standard operation manual (SOM), subsection 5.5 Man-agement responsibilities, appendix 5.5.3.2. Procedure for external communication ver. 1, year 2008, is-sue date 01/11/2008. Plantation manager still nominated as plantation management official at the op-erating unit responsible for social issues based on standard operation manual (SOM), subsection 5.5 Management responsibility, appendix 5.5.3.2 procedure for external communication ver. 1, year 2008, issue date 01/11/2008. The company maintains and updates their stakeholder list. The list consists of community surrounding company’s area, contractors, suppliers/vendors, and government but does not include the “Orang Asli” or native community of the Suku Jah Hut. The procedure for handling social conflict or grievance stated on Plantation Quality Management Sys-tem explains about the mechanism for handling social conflict or grievance. No grievances / serious disputes noted during surveillance audit. There is evidence of documentation of pay and conditions for all estate and mill workers. Workers are provided with pay slips which include information such as basic pay, piece rates, fixed allowances and deductions made (for electrical and water consumption RM 10 per month for contractor worker only), payment for overtime and total wages, the payment slip available in Bahasa Indonesia, English and Bangla, because most of company’s field workers are foreign worker. Since Malaysia government now issue requirement about minimum wages, the company now implement minimum wages as required, in fact the total wages that paid to the workers has been exceed from government standard. Workers are provided with working agreements available in Malay and English languages and include in-formation such as the relevant supervisor of the worker, employee position, and salary and wages. During previous surveillance audit, it was found that there is no documented working agreement between Chin Tong Hua and their workers who works for Chenor estate to do harvesting. The contractor Chin Tong Hua now has no longer become SOU 11 subcontractor since they have no more workers to be employed in SOU 11. The company provide adequate housing, water supplies, medical, educational and welfare amenities in accordance with Workers’ Minimum Standard of Housing and Amenities Act 1990 (Act 446) such as housing and aother facility such as mosque, church, sport center etc that are company’s standard in all estate and mill under Sime Darby Plantation . There are no changes on company’s statement for freedom of association of workers, it was sighted documented minutes of meetings with main trade unions or workers representatives dated August 11, 2012 for all representative workers under SOU 11. Statement of minimum age requirement is available on company’s regulation document. There is no any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual ori-entation, union membership, political affiliation, or age found in SOU 11 this is confirmed by interviewed worker on the filed during site visit. The company has good commitment to provide equal opportunities to all workers for good position according to its competency and requirement. The policy regarding to sexual harassment and all other forms of violance agaiunst women, workers and community dated on February 2011 still available and no changes, In Jentar and Sg. Mai estate also has sexual harassment policy signed by Executive Vice President documented in Gender Policy dated April 2011 posted at Operation Room. The company made special mechnism for sexual harassment and grievance and establish gender committee in - SOU 11 Jentar, Sg. May and Mentakab as stated on procedure to handling social issue, no. SPMS appendix 5. No sexual harassment and or violance again woman found or reported until the surveillance audit. It was confirmed by the subcontractor, the estate management and mills has fairly and transparently

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with smallholders and other local businesses. FFB pricing mechanism is conducted by MPOB, the mill has no authority to define FFB price. But for other jobs, the company and local business can make good agreement regarding price, working plan etc. The company can demonstrate their contributions to local development, according to information from local communities; company has good relationship with communities surrounding plantation area. The company provides donation as part of their corporate social responsibility as seen on Jentar estate re-ords of donations dated January 2013 to local villages such as Kampong Juhut. Compliance status: Non Compliance NCR no. 2013-08 of 09 The Social Impact Assessment report does not cover Orang Asli Community Suku Jah Hut who live in re-served area inside Sg. Mai Estate and Kampong Leleh community who live next to Mentakab Estate.

CR no. 2013-09 of 09

There is no evidence that social impact action plan has cover management for impact to the Orang Asli suku Jah Hut in Sg. Mai Estate and Kampong Leleh community in Mentakab Estate

Principle 7: Responsible development of new plantings

Criteria assessed: CR7.1, CR7.2, CR7.3, CR7.4, CR7.5, CR7.6, CR7.7 Criteria not assessed: - Findings: No findings related to new development area because the company has no development area pro-gram. According to company’s plantation statement document, and plantation history document such land almost all plantation is mature plantation, immature plantation only from replanting activities during 2008-2011. Compliance status: Not Applicable

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

Criteria assessed: CR8.1 Criteria not assessed: - Findings: The company has demonstrated their performance to make correction and corrective action from last year audit finding such as improvement regarding the usage of PPE for almost all workers. The com-pany has revised their Biodoversity document, and management of waste both domestic and sched-uled waste. Similar as during the previous surveillance audit, the company has documented general mitigation measures for negative environmental impacts and reduction of chemicals as identified in the Environ-mental Impact Assessment. There is also evidence of implementation of aspects of the plan, i.e. the estates have ceased usage of paraquat since year 2010 and replaced with alternative chemicals, vehi-cle drivers are trained to drive within speed limits to reduce air pollution due to excessive dust and scrap metal is collected by a supplier. The estates also have a documented action plan for management of identified wastes to reduce pollu-tion as explained under CR5.3. While some aspects of the plan have not yet been implemented, such as composting of organic waste and recycling of domestic waste, certain aspects of the plan are being implemented, e.g. re-use of used tyres for landscaping and flower pots, reselling of used batteries to a licensed collector and reselling of scrap metal to collectors. All estates capture their performance and expenditure in social and environmental aspects in a monthly estate manager’s report which include details of monthly actual expenditure against budgeted actual

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expenditure for activities such as road maintenance works, weeding and manuring, desilting of drains, soil and water conservation (maintenance of platforms and terraces), and donations and activities car-ried out for workers and local communities. Compliance status: Full Compliance

3.2 Status of Previously Identified Non-conformities

A total of 7 nonconformances were identified during the 1st surveillance audit in year 2012. These consisted of 1 Major non conformities and 6 minor non-conformities. During this surveillance assessment, it was found that there was sufficient evidence for closure of all non-conformities. The following is a description of the evidence of action taken to close the non-conformities raised during the previous assessment, as well as auditor’s con-clusions on the status of the non-conformities.

Criterion 4.7. (Minor indicator 1) The appropriate personal protective equipment (PPE) are used for each risk assessed operation. i. Companies to provide the appropriate PPE at the place of work to cover all potentially haz-ardous operations such as pesticide application, land preparation, harvesting and if used, burn-ing. Non-conformance 2012-01 of 07 (Minor non-conformity) It was sighted during site/mill visit, several workers without proper PPE, with evidence as follows: -Evidence at Mill’s Engine Room, there were 4 workers not wearing ear plugs while doing maintenance and Engine Driver interviewed outside the Engine Room was not wearing ear plug. - At Block 9K47 in Kerdau Estate found 3 workers not wearing PPE (gloves, goggles, vest, helmet). -At Block 87K1 in Kerdau Estate, harvester and cutter not wearing goggle. -At Scheduled Waste Store found 2 Bangladeshi workers arranging used fertilizer bags (Potassium Chloride) not wearing any gloves even required by the MSDS. -At Block 99 (Kubur Tamil), harvesters not wearing goggle as recommended in the OSH Manual dated 20/8/08 and HIRARC 30/3/09 recommended action. It was found that first aid kits at worksites were not available or inadequate, with evidence as follows: -Block 9K4 in Kerdau Estate, mandore not having it when asked. -Mandore for harvesting worker at Kerdau Estate sampled also not having the first aid box as it was kept by the other group under his care. - Block 99 (Kubur Tamil) in Mentakab Estate, the mandore has a small first aid box which is not suffi-cient to be used for12 harvesters under his care. CORRECTION Kerdau Mill: Mill Assistant. has provided the workers with new PPE (ear plug) and continuous monitoring time by time by the management and also implements monthly PPE checking. In Kerdau Estate correction was done immediately. 1. All said workers were given the proper PPE as required. 2. Recorded in PPE issue book to verify issue and usage. 3. Person in charge is Assistant. 4. Provide goggles to all harvesters on site. 5. Provide all mandore and head gang with the first aid box. 6. Additional first aid box will be issued of a gang or workers send away from the big group. 7. To provide mandore at Block 99 (Kubur Tamil) at Mentakab Estate with bigger and more sufficient

first aid box. CORRECTIVE ACTION PLAN The implementation will be lead by each respective Division Assistant in-charge,such as: 1. Tighten up the supervision to ensure full compliance by all workers. 2. Proper record book is established to record the issue of PPE item. 3. Continuous briefing especially during muster. 4. First aid box inspection will be conducted monthly by MA.

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5. To ensure first aid box kept by mandore is checked every morning during muster. Verification during 2nd Surveillance Audit: It was sight during onsite audit all workers have been provided by appropriate PPE and first aid kit available on site both mill and estates. It was also verified onsite workers use PPE. Records monitoring of PPE showed that the company provides helmet, mask, safety shoes ear muff etc, and it showed that patrol program for consistency implementation. Auditor Conclusions:Closed

Criterion 5.2. (Major indicator 2) Management plan for HCV habitats (including ERTs) and their conservation.

Non-conformance 2012-02 of 07 (Major non-conformity) There was no evidence of implementation of biodiversity action has been taken such as: - Evidence of development schedule for annual monitoring conservation area. - Evidence of establishment fact sheet for internal and external (to increase the nature conservation awareness) - Raise awareness of HCV and protected wildlife to employees. - etc The action plan also still not sufficient since there is no assigned person to implement the planning and timeline to conduct action plan. CORRECTIONS 1)To establish new Action Plan that cater: a-Annual monitoring plan of conservation area, example; 1) Erect more signage on awareness of Biodiversity enhancement. Eg: No Fishing, No Hunting. b- To provide training or refreshment training for employees on Biodiversity and HCV to ensure their awareness. c- To make sure all action plans has a person incharge included for any action taken in the plan. CORRECTIVE ACTION PLAN 1) To work with Wildlife Department (JabatanPerhilitan) regarding any future monitoring and consultan-

cy. 2) Enrichment planting by introducing specific tree species to attract wildlife and improve biodiversity

area. Vefification Result: The company has new Biodiversity action plan for year 2012/2013, for example in Mentakab estate there are 5 action plans for identified HCVs such as:

- To educate sprayer to not spray at buffer zone. Frequent check of the buffer zone including signage of “ Buffer Zone”, No Hunting, No Fishing, No Swimming, and No Spraying and marking of the buffer zone along boundary to reserve forest (Kemasul reserve forest)

- To ensure there is no encroachment (trenching) and availability of warning sign. - To monitor the cleanliness of worship area by follow the rubbish collection schedule and grass cut

schedule at worship area (Field no. OP 87B Mosques, Field OP 98A & OP87B Tample) - Tree Forest Planting - Construct electrical fencing boundary at field 11A, B and C.

The time schedule and assigned person in charge was explained on the action plan. Similar action plan also found at Kerdau estate. Training evidence for sprayer regarding how to spray and the area no al-lowed for spraying in Riparian river as sight on training records. Trenching and electrical fencing construction was sight at block 2011 A, the poles has been built along the boundary Kemasul Forest. Tree planting evidence was sight at block 95 A at Lanchang estate Auditor Conclusions: Closed

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Criterion 5.2. (Minor indicator 3) Evidence of a commitment to discourage any illegal or inap-propriate hunting fishing or collecting activities, and developing responsible measures to re-solve human-wildlife conflicts. Non-conformance 2012-03 of 07 (Minor non-conformity) There was found in Lanchang division has potential human-wildlife conflict with elephant from Kemasul reserve forest, however there is no documented measurement plan has been developed. It was sighted on the field elephant destroyed young oil palm tree at replanting area. CORRECTION 1) Write a letter to Jabatan Perhilitan regarding Mentakab Estate boundaries with the Kemasul Re-

serve Forest as well as to inform them about elephant invasion in replanting area. CORRECTIVE ACTION PLAN 1) To develop a schedule and monitoring plan for elephant trenching inspection and maintenance as well as to include any future recommendations provided by PERHILITAN should there is any attacktion Person in charge is Assistants and staff. Verification result during 2nd Surveillance audit: There is a letter issued by Mentakab estate to Jabatan Perhilitan negeri Pahang; however the letter is not new, the letter was issued on December 27, 2011 before the 1st surveillance audit. According to ex-planation from Mentakab estate staff, the officer from Jabatan Perhilitan came to the estate to see the impact of elephant attraction to the field on December, 2012, but no documented evidence regarding that visit. The company made Working Program for Elephant Control year 2012/2013. As stated on the working plan several activities will be done such as,

- Construction of Elephant Trenching to repair the existing trench becomes deeper and wider. - Electrical fencing construction - Maintenance of Electrical fencing - Road Grading-Boundary Road

At the 2nd surveillance audit the electrical fencing still under construction by subcontractor “Silent Proto-col Enterprise”. There is record of monitoring to see oil palm damage caused by elephant as seen on “census palms Elephants Damage Book”, as recorded on the book there were 442 trees broken. There is no more monitoring record for year 2013 because no more palm trees on the field nearby the Kemasul Forest. The potential of elephant attraction still happen, company should continue monitor the elephants activi-ties inside plantation area. Auditor Conclusions: Closed with Observations

Criterion 5.3. (Minor indicator 2) Having identified wastes and pollutants, an operational plan should be developed and implemented, to avoid or reduce pollution.

Non-conformance 2012-04 of 07 (Minor non-conformity) 1. The collection of scheduled waste SW 409 is not done since 19/11/2011. This is against the rules and regulations of Scheduled Waste to keep not more than 6 months and less than 20MT whichever comes first. In addition there was no proper labelling according to Estate Quality Management System, Appendix 1.4.4. 2. Lead acid batteries kept as scheduled waste since Jan 2010 and no record of disposal until today. Only application of extension to store the lead batteries available dated 12/6/2012. CORRECTION 1) To apply for extension for SW 409 and Lead acid battery SW102 storage from DOE since the quanti-ty is insufficient for the collector to collect. 2) Arrangement to be made with QMO Pahang Zone to carry out collection scheduled waste together with other estate

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CORRECTIVE ACTION PLAN 1) To have a monitoring record and inventory in a form of logbook to make sure no lapse in any dis-posal of SW. Verification Result: It was sighted no more schedule waste were stored more than 6 months, e.g. for SW 409 and SW 102 incuding leas acid batteries. Scheduled waste was disposed to approve waste collector. Schedule waste balances was available on each schedule waste storage office to records incoming and outgoing schedule waste such as sighted at Mentakab estate schedule waste storage. Auditor Conclusions: Closed

Criterion 5.3. (Minor indicator 2) Having identified wastes and pollutants, an operational plan should be developed and implemented, to avoid or reduce pollution.

Non-conformance 2012 -05 of 07 (Minor non-conformity) Sighted SW409 & SW305 in the log book are not collected for more than 6 months recorded from date of generation on 23 Feb 2011 until collected on 30 Jan 2012. Application to extend the storage of the scheduled waste is unavailable. Found diesel oil spillage in Kerdau housing area and schedule waste mixed domestic waste in waste bin Polyclinic Lanchang division CORRECTION 1) To apply extension the storage of scheduled waste to DOE for SW 409 and SW 305. CORRECTIVE ACTION PLAN 1) To ensure all scheduled waste are disposed not more than 6 months or the quantity not exceed 20mt by establishing a scheduled monitoring plan and inventory in a logbook. - Person in charge is Assistants and Quality Management Officer. Verification Result: It was verified during 2nd surveillance audit company has renewed the extention permit for scheduled waste from DOE , it is available on each estate. It was sighted at Kerdau housing, the company provided two waste bins in front of the polyclinic of Kedau estate to prevent mixing between schedule waste and policlinic waste and no more waste mixed. There is also notification regarding not to mixed between domestic waste and policlinic waste. Auditor Conclusions: Closed

Criterion 5.5. (Minor indicator 3) No evidence of burning waste (including domestic waste).

Non-conformance 2012-06 of 07 (Minor non-conformity) There was some evidence found of burned domestic waste in front of some houses in Kerdau estate. And mixed domestic waste contaminated with diesel oil. CORRECTION 1) To clear out all the burned traces at linesite area and disposed of all domestic waste to landfill area. 2) To clear out all the diesel oil spillage with spillage kit, send off all scheduled waste into SW Store and dispose of all domestic waste to landfill area.

CORRECTIVE ACTION PLAN 1) To ensure everyday briefing on domestic waste handling and scheduled waste handling during eve-ryday Morning Muster is being implemented thoroughly and to make sure it is being recorded. -Person in charge is Assistants.

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Verification result: During audit was observed no more burned domestic waste in housing complex Kerdau estate and in oter estates. The company provides two types of waste bins to separated domestic waste and sched-uled waste in front of every house as found in Kerdau estate, Metakab and Jentar estate. Auditor Conclusions: Closed. Criterion 6.5. (Minor indicator 2 ) Labour laws, union agreements or direct contracts of employ-ment detailing payments and conditions of employment (e.g. working hours, deductions, over-time, 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. Non-conformance 2012-07 of 07 (Minor non-conformity) There is no documented working agreement between contractor Chin Tong Hua and their workers who works for Chenor estate as harvesting. CORRECTION 1) To make sure Chin Tong Hua provides the working agreement between contractor and their work-

ers. CORRECTIVE ACTION PLAN 1) To ensure all contractors to have the working agreement with their workers before signing the con-

tract agreement and start working with Sime Darby Plantation Sdn. Bhd.

Verification result: The contractor Chin Tong Hua now has no longer become SOU 11 subcontractor since theey have no more workers to be employed in SOU 11. Auditor Conclusions: Closed

3.3 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions

During this surveillance assessment, a total of 9 nonconformances were identified. These consisted of 2 major non-conformity and 7 minor non-conformities. For the major non-conformances, the company has taken the necessary corrective action to close these non-conformances within 60 days of completion of the assessment, and this was verified by the audit team through a document checked submitted by the company. For the minor non-conformances, the company has taken corrective action against these as well, and for those which could not be verified as closed through document checks, the closure of these minor non-conformities will be as-sessed during the next surveillance audit. A summary of all identified non-conformances, corrective actions taken and auditor conclusions is as below:

Criterion 2.1.1 (Major indicator): Evidence of compliance with relevant legal requirements

Non-conformance 2013-01 of 09 (Major non-conformity) Evaluation of Compliance Score Card approved by Mill Manager and Estate Managers was found not reflecting actual compliance status as evidence found that some of the legal requirements wrongly de-cided as “Not Applicable” even actually those are “Applicable” and should be included in the evaluation of compliance process, such as:

1. Environmental Quality (Clean Air) Reg. 1978 requirements for written approval for chimney, fuel burn-ing equipment, air emission standard etc, for the mill.

2. At Jentar estate, legal requirement register under page 8, for part V (Notice of occupation for Factory & Registration & Use of Machinery under Section 37,38,34,39,35,43,44. Factories and Machinery (Safety, Health and Welfare) Regulations, provision of Regulations 24, 25 and 26.

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Correction

Estate and Mill to change all the “Not Applicable” legal requirements in the LORR to “Applicable” and change the evaluation of compliance.

Corrective Action

PSQM Department will review the LORR for estate and mill and advise estate & mill in compliance and implementation of the LORR requirement. Verification Result: The company provide the revised LORR to include all information required, there ia actual status of le-gal compliance determined on revised LORR, all applicable regulation has been evaluated and stated as applicable, such as: 1. Environmental Quality (Clean Air) Reg. 1978, for written approval of chimney, fuel burning equip-ment, air emission standard etc. 2. Legal requirement register under page 8, for part V (Notice of occupation for Factory & Registration & Use of Machinery under Section 37,38,34,39,35,43,44. Factories and Machinery (Safety, Health and Welfare) Regulations, provision of Regulations 24,25 and 26. Auditor Conclusion: Closed

Criterion 2.1.4. (Minor indicator): A system for tracking any changes in the law.

Non-conformance 2013-02 of 09 (Minor non-conformity) Found Revised Environmental Quality Act 1974 that was revised on August 2012 not identified and in-cluded in the Legal Register. The Mill and Estate sampled not aware of this changes as according to paragraph 6.1 of the Standard Operating Manual version 1:2008, stated that Identify changes of Legal and other requirements is the responsibility of the PSQM Department Correction

To liaise with PSQM Department to include the newly revised Environmental Quality Act 1974 in the Es-tate and Mill Legal and Other Requirement Register (LORR)

Corrective Action PSQM Department will review the LORR for estate and mill and advise estate & mill on any new up-dates on Legal and Other Requirement Registers. Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of im-plementation to verified at next audit.

Criterion 4.1.2. (Minor indicator): Records of monitoring and the actions taken are maintained and kept for a minimum of 12 months.

Non-conformance 2013-03 of 09 (Minor non-conformity) There was found an effluent analysis report dated February and March for pH and suspended solids parameters was exceeded the government standard, however there was no action taken by the mill. Correction

Mill has budget and plan for desilting under this FY12/13 in order to reduce suspended solids and pH. Mill has obtained approval from DOE for the desludging works.

Mill also will seek advice from R&D to resolve or overcome this issue.

Corrective Action Mill to continue with every year proper desilting plan to avoid solid accumulation

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Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of im-plementation to verified at next audit.

Criterion 4.3.1. (Minor indicator): Documented evidence of practices minimizing soil erosion and degradation (including maps)

Non-conformance 2013-04 of 09 (Minor non-conformity) The company has established map of locations which have potential erosion, but there is no company plan (documented evidence) of practices minimizing soil erosion and degradation such as for area 25° and sandy soil e.g Jerantut Division etc. Corrections

The areas with the slope of more than 25˚ were identified and Estate has notified the agronomist to con-duct a GPS survey to confirm the area. The map of location which has potential erosion was established.

Corrective Action

To establish ground covers by planting mucuna sp at 1 plant per palm at slope and open areas as to avoid any future soil erosion. Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of im-plementation to verified at next audit. Criterion 4.4.3. (Major indicator 2): Outgoing water into main natural waterways should be moni-tored at a frequency that reflects the estates and mills current activities which may have nega-tive impacts (Cross reference to 5.1 and 8.1)Non-conformance 2013-05 of 09 (Major non-conformity) Sime Darby Plantation: Plantation Quality Management System, Appendix 7, Version 1, 1/11/2008 - SOP for taking water samples from streams/rivers has clearly described that frequency of water sam-pling shall be carried out on quarterly basis (Jan, Apr, Jul, Oct year 2012) however, records show that the sampling is not done according to schedule Correction:

For year 2013, both estates already sent water samples for testing according to the PQMS requirement.

Corrective Action:

Estate already appoint person in charge to manage the water sampling quarterly. The person in charge as below:

Sg. Mai Estate: The Asst. Manager Mentakab Estate : The Asst. Manager Verification result: The company submit result of water sampling testing both for Sg Mai estate and Mentakab Estate, ac-cording to the testing result from Sime Darby Research Sdn. Bhd, It was verified that water quality still comply with government regulation, such as: - Water test analisys result for Mentakab estate: IE-131/2013 period February 2013 for Lanchang

Division; IE-127/2013 period February for Endensor Divisin. - Water test analysis for Sg. Mai estate IE-070/2013 for period January 2013

Auditor Conclusion: Closed

Criterion 4.7.1 .b (Minor indicator 2): All operations have been risk assessed and documented.

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Non-conformance 2013-06 of 09 (Minor non-conformity) The Hazard Identification and Risk Assessment and Control (HIRARC) were not conducted effectively as evidence found:

1. Grass cutting activity that is being conducted daily at mill, quarters and workers housing area was not identified in the HIRARC document.

2. According to OSH Manual, under paragraph 7.5(b), control measures for newly identified high risk ac-tivities shall be recommended to the HIRARC team to be recorded in the HIRARC form and implemented. Found in the newly revised HIRARC (2013), there were no recommended actions taken for some identi-fied high risk activities scored more than 8 but there was no proposal for action taken, i.e. for Section Boiler- Step 1 (Score 12), Road surfacing- Step 1 (Score=8) Construction of run-offs Step 1 (Score=8)

3. Potential Biological Hazard at workplace from old tyres kept at scrap yard near scheduled waste store in Sg. Mai Estate was not identified in the HIRARC which was newly revised on 19th March 2013. Correction

1. To include the HIRARC for grass cutting activity at mill and estate.

2. Will liase with PSQM-ESH to advise the recommended action taken for HIRARC with highest score and to include the recommendation in the HIRARC.

3. To include the biological hazard potential at scrap yard in the HIRARC.

Corrective Action Will request PSQM-ESH Safety Officer to advise estate and mill during reviewing the HIRARC for the next financial year. Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of im-plementation to verified at next audit.

Criterion 5.3.2. (Minor indicator ): Having identified wastes and pollutants, an operational plan should be developed and implemented, to avoid or reduce pollution

Non-conformance 2013-07 of 09 (Minor non-conformity) Storage of Scheduled Waste is not accordance to the Environmental Quality (Scheduled Waste) Regu-lations, 2006 where it was sighted that containers are not properly or clearly labeled as specified in Third Schedule and not marked with waste code as in First Schedule for identification and warning pur-poses. The date when the scheduled waste are first generated, name, address and tel no of waste generator are not clearly labelled on containers that are used to store the scheduled wastes. Correction

To do labeling to the schedule waste storage at estate as per EQ (Schedule Waste) Reg 2006.

Corrective Action Plan

To conduct Scheduled Waste Refresher Training to SOU 11 on giving the awareness and competency in managing the scheduled waste.

Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of im-plementation to verified at next audit.

Criterion 6.1.2. (Minor indicator): Evidence that the assessment has been done with the partici-pation of affected parties

Non-conformance 2013-08 of 09 (Minor non-conformity) The Social Impact Assessment report does not cover Orang Asli Community Suku Jah Hut who live in reserved area inside Sungai Mai Estate and Kampong Leleh community who live next to Mentakab Es-tate.

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Correction:

To seek advice from PSQM Department to include the Orang Asli Community Suku Jah Hut (Sg. Mai Es-tate) and Kampung Leleh (Mentakab Estate) in the Social Impact Assessment Report.

Corrective Action:

Will liase with PQSM Department on amendment of Social Impact Assesment Report. Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of im-plementation to verified at next audit.

Criterion 6.1.3. (Minor indicator )

Non-conformance 2013-09 of 09 (Minor non-conformity) There is no evidence that social impact action plan has cover management for impact to the Orang Asli suku Jah Hut in Sungai Mai Estate and Kampong Leleh community in Mentakab Estate. Correction

To liase with PSQM Department to include Kampung Orang Ali Suku Jah Hut and Kampung Leleh in the Estate Social Action Plan.

Corrective Action Plan Will liase with PQSM Department on amendment of Social Action Assesment Report. Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of im-plementation to verified at next audit.

3.4 Noteworthy Positive Components

No. Criteria Positive observation

1. 5.1 Very clean in all company’s facility such as mill and estate.

2. 8.1 Good company commitment regarding implementation of RSPO

3. 4.3 Good implementation of action to prevent erosion such as construction of terracing for replanting area, construction water bunds in terracing area etc.

4. 6.5 Good attention to all workers including foreign workers, they all satisfy with company salary

5. 6.10 Good relationship between company and local community

6. 4.7 Good signages, warning and labeling on the aspect of safety and health observed at chemicals store, mixing area, workshop and by the road side.

7. 6.5.1 Company regulation regarding Service Gratuity Payment still not understod by the work-ers.

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3.5 Issues Raised by Stakeholders and Findings Pertaining to Issues

Below is a summary of issues raised by stakeholders interviewed on-site

No. Issues Raised

Company has good rela-1. tionship with local stake­

holder

Workers are satisfied with 2. company's facilities and

salary received.

Management Response

This is part of company' s social responsibility

Company aware that without workers, company will not have good income.

A TUVRheinland • Precisely Right.

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Audit Verification

Interview with local communities, most of them has positive im­presion for company's performance. It was sighted that com­pany provide good housing, mosques, churche, sport center etc.

4.0 CERTIFIED ORGANISATION'S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY

4.1 Date of Next Surveillance Visit

The next surveillance visit is planned for April 2014

4.2 Acknowledgements of Internal Responsibi lity and Formal Sign-Off by Client

It is acknowledged that the assessment visit was carried out as described in this report and we accept the as­sessment findings and report content.

Signed on behalf of Sime Darby

(ju ' " ... "' ... " " - ~ · . ............ ... . .... .... .. Name: c::: _I -.\ •. _ 1 Position: v / ~ti"'V'\,.

Date: /Wf (

1-t (to( (?::.

Signed on behalf of TUV Rheinland Malaysia

Dian S. Soeminta Lead Auditor Date: 16 August, 2013

QMF. RSPO-OO?b-11

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APPENDICES

Appendix 1: Details of Revised Certificate

Standard: RSPO Principles & Criteria for Sustainable Palm Oil Production: 2007; Malaysian National Interpretation: 2010

Certificate Registr. No.: 18502207 001

TÜV Rheinland Malaysia Sdn. Bhd., certifies:

Certificate Holder: Sime Darby Plantation Sdn. Bhd. SOU 11 - Kerdau Palm Oil Mill, (Subsidiary of Sime Darby Plantation Sdn. Bhd.), Wakil Pos Kerdau, 28010, Temerloh, Pahang, Malaysia, including its company-owned estates according to the annex

Scope: Palm Oil Production and Management System

An audit was performed, Report No. 18502207. Proof has been fur-nished that the requirements according to RSPO Principles & Criteria for Sustainable Palm Oil Production: 2007; Malaysian National Interpre-tation: 2010 are fulfilled. The due date for all future surveillance audits is 06-05 (dd.mm).

Validity: The certificate is valid from 1 October 2013 until 06 July 2016*. The certificate shall remain valid in period stipulated above provided that the certificate holder mentioned here continues to comply with the RSPO P&C requirements. Status of compliance of the certificate holder shall be based on the annual inspections conducted by TÜV Rheinland Malaysia Sdn. Bhd.

* Certificate validity is less than 5 years due to transfer of certification body. Previous certificate no. C819155CU-RSPO-01.2011 issued for this organization prior to CB transfer was valid from 07/07/2011 to 06/07/2016

GPS locations of processing units covered in scope: Name of Mill / Es-

tate Location

GPS Locations

Latitude Longitude

Kerdau Palm Oil Mill

Kilang Kelapa Sawit Kerdau, Wakil Pos Kerdau, 28010 Temerloh Pahang

3º34’07”

102º18’28”

Kerdau Estate

Ladang Kerdau, Wakil Pos Kerdau 28010 Temerloh, Pahang

3º34’07” 102º18’28”

Jentar Estate

Ladang Jentar, Wakil Pos Kerdau, 28010 Temerloh , Pahang

3º34’07” 102º18’28”

Mentakab Estate

Ladang Mentakab/ Lanchang/ Edensor, c/o Lanchang Division, 28500 Lanchang, Pahang Darul Makmur.

3º28’67” 102º10’95”

Sg Mai Estate

Ladang Sungai Mai, 27000 Jerantut, Pa-hang

3º48’50” 102º21’40”

Chenor Estate

Ladang Chenor (KT), Sungai Jerik, 26400 Bandar Pusat Jengka, Pahang

3º34’07” 102º18’28”

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CPO Tonnage Total Production*: PK Tonnage Total Production*: Company Estates FFB Tonnages*: FFB Tonnages from other sources*: CPO Tonnage claimed for certification: PK Tonnage claimed for certification:

48,168.26 tonnes 12,368.76 tonnes 226,298.26 tonnes 9,038.39 tonnes 48,075 tonnes 11,368 tonnes

* For June 2012 to April 2013

Appendix 2: List of Abbreviations

BOD Biological Oxygen DemandCHRA Chemical Health Risk AssessmentCPO Crude Palm OilDOE Department of EnvironmentDOSH/JKKP Department of Occupational Safety & Health / Jabatan Keselamatan &

Kesihatan PekerjaEAI EIA

Environmental Aspect and Impact Environmental Impact Assessment

EIE EMS ERTs

Environmental Impact Evaluation Environmental Management System Endangered, Rare & Threatened species

EQ / EQA ESH

Environmental Quality / Environmental Quality Act Environmental Safety & Health

FFB Fresh Fruit BunchesEFB Empty Fruit BunchesFMA Factory and Machineries ActHCV High Conservation ValueHIRARC Hazard Identification, Risk Assessment and Risk ControlHQ Headquarters IPM Integrated Pest ManagementJPAM Jabatan Pertahanan Awam Malaysia (Malaysia Civil Defense Department) KER Kernel Extraction RateLCC Leguminous Cover CropsLTA Lost Time AccidentLORR Legal and Other Requirement RegisterMOP Muriate of PotashMSDS Material Safety Data SheetsNGO Non-Government OrganizationNUPW National Union Plantation WorkersOER Oil Extraction RateOSH Occupational Safety & HealthPERKESO Pertubuhan Kebajikan Sosial (Social Welfare Organization)PKO Palm Kernel OilPMT Permit/Pendaftaran Mesin Tekanan (Permit / Registration of Pressure Machine)POM POME

Palm Oil Mill Palm Oil Mill Effluent

PPE Personal Protective EquipmentPSQM Plantation Sustainability and Quality Management QMO Quality Management OfficerR&D Research and DevelopmentSDP Sime Darby PlantationSDPA Sime Darby Plantation AcademySIA Social Impact AssessmentSPMS Sustainable Plantation Management SystemSOCSO Social Security Organization

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SOP Standard Operating ProcedureSOM Standard Operation ManualSOU Strategic Opération UnitSW Scheduled Wastes

Appendix 3: List of Stakeholders Interviewed and Contacted

No. Name of

Stakeholder Institution - Address Remark

Stakeholders Interviewed On-Site

1. Chong Shih Shun PSQM 2. Nadiah Mohamed Nazri PSQM 3. M. Fahrul B. Rosli PZO 4. Makhmud bin Kasim Jentar 5. Densy Nazrulizwan Sungai Mai estate 6. Amirrudin Abdul Darman Jentar Estate 7. Balakrishnan Mentakab estate 8. Muhammad Zulkefli bin

Md Isa PZO

9. Harun A Rusli PZO 9. Nurul Atiqah bt. Johari Kerdau estate

10. Muhammad Shokkeri Job Sg. Mai estate 11. Nasrudin M. Sharif Kerdau estate 12. Nazrulizwan Mohamed Sg. Mai Estate 13. Mohd Ezry Shazam Asst. Manager Chenor estate 14. Mulyadi Mill worker from Indonesia

15. Mr. Hairurrozikin, Mill worker from Indonesia 16. Mr. Tahiruddin, Technical supervisor Kerdau Estate 17. Mrs. Noriati, Kerdau Estate 18. Mr. Randir, Gardener at Kerdau Estate 19. Mr. Senduk, Gardener at Kerdau Estate 20 Mr. Lalbahadur, Manurers mandor at Kerdau Estate 21 Mr. HArendra, and Vijay

Prakash Workers at Kerdau Estate)

22 Mr. Indra and Mr. Herman Harvesters from Indonesia) 23

Mr. Khairul Azhar Supervisor East Division at Kerdau Es-tate

24 Mrs Salina and Mrs Rohani

Daycare worker at Kerdau Estate

25 Mr. Rahim, Indonesian worker 26 Mr. Saprah, Indonesian worker 27 Mr. Saman Arifin Indonesian worker 28 Mr. Hamdi Indonesian worker 29 Mr. M. Izri Chenor estate manager 30 Mr. Heri and Mr. Junaidi FFB loading worker at Chenor estate 31 Mr. Jariah and Mr. Nur-

samin and Mr. Junaidi Harvester at Chenor estate

32 Mr. Hamdani

Harvesting supervisor panen at Chenor

33 Madam Tan Leader of village Sungai Jerik 34 Mr. Ahmad Yani Carpenter at Chenor estate 35

Mr. Jefri Head of Union Worker at Chenor es-tate

36 Mr. Zainal Harvester at Mentakab estate 37 Paramedic Mentakab estate

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Appendix 4: Observations and Opportunities for Improvement

No. Observations / Opportunities for Improvement Criteria1. Company should define time period to responses incoming letter for request of infor-

mation. 1.1

2. Emergency shower in some estate still not working properly such as Kerdau estate, Mentakab, and Chenor estate.

4.7

3. ESH Policy not effectively communicated to foreign workers and local workers, as in-terviewed on site they still not understand about the policy

4.7

4. The HIRARC is not updated and reviewed properly in all area, it was found in many pages the recommendation for risk control still blank even the score is considered medium.

4.7

5. It was found that first aid box at worksite was not always available at worksites such as at Block 9K4 in Kerdau Estate, mandore not having it when asked. The mandore for group of harvesting workers at Kerdau Estate was found also not having the first aid box as it was kept by the other group under his care. While in Block 99 (Kubur Tamil) in Mentakab Estate, the mandore has a small first aid box and not sufficient to be used for 12 harvesters under his care. Spraying mandors at block 7 Block 03S and 975B of Jentar estate had first aid kits but mandore at Block 2 left his first aid kit at home.

4.7

6. Fire extinguisher should be at locations ready to use, not placed in locked box. 4.7

7. Sampling on Mentakab Estate (ME): Environmental Aspect and Impact Assessment based on Standard Operation manual (SOM), 2008, Sub-section 5.4, Appendix 5.4.1b issued 1/11/2008. However, there are no assessment of environmental aspects and im-pacts that may occur during "Abnormal" and "Emergency" situations of operations being carried out in Mentakab Estate as sighted in the Environmental Impact Evaluation, 2009

5.1.1

8. Kerdau Palm Oil Mill (KM), Kerdau Estate (KE) & Mentakab Estate (ME): Environ-ment Management Programme for 2011/2012 is sighted with the following activities 1. Zero spillage at POME application 2. Agrochemicals spillage: Containment via spillage kit, proper bunding and drain. However, the execution of the activities are not recorded or in place

5.1.2

9. The company should revise their biodiversity assessment considering existing ecosys-tem condition including thier surrounding area

5.2.1

10. There is no evidence to show that the permit for storage of diesel at Mentakab estate and Kerdau estate has been renewed even the application to renew the permit has been submitted dated 15 October 2012 by Mentakab estate and on 15 December 2012 by Kerdau estate. The estates should follow up on the application for the permit with the relevant authorities.

5.3.2

11. ALL sites: Pollution Prevention Plan for 2011/2012 is sighted at location Chemical Store/Mixing Area:

1) Agrochemical spillage - containment via spillage kit as well as proper bunding and drainage system into spillage sump and absorption trench. 2) Residues from washing and mixing area - spillage sump and absorption trench.

Both required site inspection by staff and store attendant, however there is no record of execution.

5.6.1

12. Payment slips received should be in a language which is understood by the workers. Currently payment received is in English which not so well understood by workers from other countries

6.5.1

13. Information on payment slip should made understandable by the relevant worker.

Company should implement monitoring of housing condition periodically.

6.5.3