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SGS RSPO (Principles & Criteria) Doc. Number: GP 7003A Doc. Version date: 01 April 2013 Page: 1 of 58 SGS RSPO, SGS (Malaysia) Sdn. Bhd., No. 26, Jalan Anggerik Vanilla, 31/93, Kota Kemuning, 40460 Shah Alam, Malaysia CONTACT PERSON: ABDUL HAYE SEMAIL Tel: +6 (03)5121 2320 - Fax: +6 (03)5122 5927 WWW.SGS.COM RSPO PRINCIPLES & CRITERIA CERTIFICATION REPORT Public Summary Information Project Number: MY01827 Certificate No.: SGS-RSPO/PM-00201 Validity Period: 03/02/2009 02/02/2014 Report Ref. No.: MY01827 Surveillance 04 Evaluation RSPO Membership No.: 010-04(O) Client Name: IOI Corporation Bhd Website: http://www.ioigroup.com/ business/busi_plantoverv iew.cfm Scope: Purchase of FFB from the supplying estates of Pamol Oil Mill having a capacity of 51MT/hour for the production and sales of CPO and Palm Kernel using the Segregation supply chain module D option Type of Certificate Holder: INDIVIDUAL Number of Mill: 1 Number of Sites: 1 Mill Capacity: 51 MT/hr ( MPOB licensed for 330,330 MT FFB ) Annual CPO Produced (MT): Produced: 54, 688.67 MT Address: Street and number: Town/City State/Country Zip/Postal code Country Head Office Head office: Level 8, Two IOI Square IOI Resort, 62502 Putrajaya Malaysia. Mill Address Physical address : Location :Pamol PL 086290119 Labuk/Sugut Sabah Pamol Mill P O Box 203, 90702 Sandakan Sabah Contact Person: 1. Mr. Too Heng Liew (Head of Sustainability, Malaysia / Indonesia) [email protected] 2. Mr. S.S Ragupathy (General Manager, Sandakan Region) 3. Mr S J Yeap, Sustainability Manager, Sabah [email protected] Country: Malaysia Plantation Unit Being Evaluated: Supply Base Name & Address Pamol Oil Mill Management Unit (Pamol Oil Mill and Estates, Labuk- Sugut ,Sandakan, Sabah) Bayok Estate Meliau Estate Nangoh Estate Rungus Estate Tindakon Estate Ulu Estate Total Certified Area (Ha): 13,502.4 Hectare ( Total certified area ) Total FFB Produced (MT): 255,843.89 MT / yr

RSPO PRINCIPLES & CRITERIA CERTIFICATION REPORT …...Pamol Oil Mill Management Unit (POM-PMU is located in Labuk-Sugut (also known as Beluran district) District in Sandakan division,

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Page 1: RSPO PRINCIPLES & CRITERIA CERTIFICATION REPORT …...Pamol Oil Mill Management Unit (POM-PMU is located in Labuk-Sugut (also known as Beluran district) District in Sandakan division,

SGS RSPO

(Principles & Criteria)

Doc. Number: GP 7003A

Doc. Version date: 01 April 2013

Page: 1 of 58

SGS RSPO, SGS (Malaysia) Sdn. Bhd., No. 26, Jalan Anggerik Vanilla, 31/93, Kota Kemuning, 40460 Shah Alam, Malaysia

CONTACT PERSON: ABDUL HAYE SEMAIL Tel: +6 (03)5121 2320 - Fax: +6 (03)5122 5927 WWW.SGS.COM

RSPO PRINCIPLES & CRITERIA CERTIFICATION REPORT

Public Summary Information

Project Number: MY01827 Certificate No.: SGS-RSPO/PM-00201

Validity Period: 03/02/2009 – 02/02/2014

Report Ref. No.: MY01827 Surveillance 04 Evaluation RSPO Membership No.:

010-04(O)

Client Name: IOI Corporation Bhd Website:

http://www.ioigroup.com/business/busi_plantoverview.cfm

Scope: Purchase of FFB from the supplying estates of Pamol Oil Mill having a capacity of 51MT/hour for the production and sales of CPO and Palm Kernel using the Segregation supply chain module D option

Type of Certificate Holder:

INDIVIDUAL

Number of Mill: 1 Number of Sites: 1

Mill Capacity: 51 MT/hr ( MPOB licensed for 330,330 MT FFB )

Annual CPO Produced (MT):

Produced: 54, 688.67 MT

Address:

Street and number:

Town/City

State/Country

Zip/Postal code

Country

Head Office

Head office: Level 8, Two IOI Square IOI Resort, 62502 Putrajaya

Malaysia.

Mill Address Physical address: Location :Pamol PL 086290119 Labuk/Sugut Sabah Pamol Mill P O Box 203, 90702 Sandakan Sabah

Contact Person:

1. Mr. Too Heng Liew (Head of Sustainability, Malaysia / Indonesia)

[email protected]

2. Mr. S.S Ragupathy (General Manager, Sandakan Region)

3. Mr S J Yeap, Sustainability Manager,

Sabah [email protected]

Country: Malaysia

Plantation Unit Being Evaluated:

Supply Base Name & Address

Pamol Oil Mill Management Unit

(Pamol Oil Mill and Estates, Labuk-Sugut ,Sandakan, Sabah)

Bayok Estate

Meliau Estate

Nangoh Estate

Rungus Estate

Tindakon Estate

Ulu Estate

Total Certified Area (Ha):

13,502.4 Hectare ( Total certified area )

Total FFB Produced (MT):

255,843.89 MT / yr

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Evaluation Date:

Main Assessment 25 -30 May 2008

ASA 01 10 – 12 November 2009

ASA 02 10 – 14 Jan 2011

ASA 03 21 – 23 Feb 2012

ASA 04 16-18th Jan 2013

End of Public Summary

TABLE OF CONTENTS

SUMMARY ............................................................................................................................................................... 3

List of Abbreviation ................................................................................................................................................ 4

1. scope of certification assessment ......................................................................................................... 5

1.1 National Interpretation Used ..................................................................................................................... 5

1.2 Certification Scope .................................................................................................................................... 5

1.3 Location and Maps .................................................................................................................................... 5

1.4 Description of Supply Base and Mill Processing Capacity ........................................................................ 7

1.5 Date of Planting and Cycle ........................................................................................................................ 8

1.6 Other Certification Held ............................................................................................................................. 8

1.7 Organizational Information and Contact Person ....................................................................................... 8

1.8 Time-bound Plan for Other Management Units ......................................................................................... 9

1.9 Area of Plantation...................................................................................................................................... 9

1.10 Date Certificate Issued and Scope of Certificate .................................................................................. 9

2. Assessment Process ............................................................................................................................... 9

2.1 Certification Body ...................................................................................................................................... 9

2.2 Assessment Methodology, Programme, Site Visits ................................................................................. 10

2.3 Qualification of Lead Assessor and Assessment Team .......................................................................... 11

2.4 Stakeholder Consultation and List of Stakeholders Contacted ............................................................... 11

3. Assessment Findings ............................................................................................................................ 11

3.1 Summary of Findings .............................................................................................................................. 11

3.2 Corrective Action Request ...................................................................................................................... 46

3.3 Noteworthy Positive & Negative Observation .......................................................................................... 46

3.4 Status of Non-Conformities Previously Identified .................................................................................... 46

3.5 Issues Raised by Stakeholders and Findings ......................................................................................... 46

4. Acknowledgement of Organization Internal Responsibility .............................................................. 47

4.1 Date of Next Surveillance Visit ................................................................................................................ 47

4.2 Date of Closing Non-Conformities ........................................................................................................... 47

4.3 Acknowledgement of Internal Responsibility and Formal Sign-off Assessment Findings........................ 47

APPENDIX A: CORRECTIVE ACTION REQUEST & OBSERVATION ............................................................... 48

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APPENDIX B: NON-CONFORMITIES PREVIOUSLY IDENTIFIED ..................................................................... 54

APPENDIX C: TIMEBOUND PLAN ....................................................................................................................... 57

APPENDIX D: LIST OF STAKEHOLDERS CONTACTED ................................................................................... 58

LIST OF TABLES

Table 1: Mill GPS Location .................................................................................................................................. 5

Table 2: Budgeted Yield from Supply Base (Financial Year) ............................................................................. 7

Table 3: Planting Age Profiles for all Supply Base Estates ................................................................................ 8

Table 4: Area Statement of the Supplying Estates ............................................ Error! Bookmark not defined.

Table 5: Assessment Program .......................................................................................................................... 10

Table 6: Auditors Profile ..................................................................................................................................... 11

LIST OF FIGURES

LIST OF APPENDICES

As above

SUMMARY

IOI acquired Pamol Estates from Unilever in 2003. There has been no new establishment of oil palm

plantation within the unit apart from re-planting.

Pamol Oil Mill Management Unit (POM-PMU) consist of 6 estates namely Ulu, Bayok, Rungus, Tindakon,

Nangoh and Meliau estate and it was among the first oil estates that were established in Sabah that were

developed in early 1960s and the Pamol Oil Mill at that time was the largest in Sabah when it was made

operational in 1967.

The main assessment was conducted in May 2008. The plantation unit has complied with the

requirement of yearly annual surveillance.

This audit is the fourth surveillance audit for the plantation Unit.

The organization chart is as below:

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LIST OF ABBREVIATION

Short Form Meanings

CAR Corrective Action Request

CHRA Chemical Health Risk Assessment

CPO Crude Palm Oil

DID Department of Drainage and Irrigation, Malaysia

DOE Department of Environment, Malaysia

EFB Empty Fruit Bunch

EIA Environment Impact Assessment

EMS Environmental Management System

EQA Environmental Quality Act

ERT Endangered, Rare and Threatened species

ESA Environmentally Sensitive Area

FFA Free Fatty Acids

FFB Fresh Fruit Bunches

FR Forest Reserve

Ha Hectare

HCV High Conservation Value

HDPE High Density Polyethylene

IPM Integrated Pest Management

ISO International Organisation for Standardisation

IUCN International Union for Conservation of Nature and Natural Resources

JCC Joint Consultative Committee

JUPEM Jabatan Ukur dan Pemetaan Malaysia (Department of Survey and Mapping Malaysia)

K Potassium

kW Kilowatt

M Meter

Mg Magnesium

Mm Millimeter

Mt Metric ton

MYNI Malaysia National Interpretation

N Nitrogen

NGO Non Governmental Organisation

OA Orang Asli (Indigenous People)

OER Oil Extraction Rate

OSH Occupational Safety & Health

P Phosphate

P & C Principles and Criteria

PK Palm Kernel

POME Palm Oil Mill Effluent

PPE Personal Protective Equipment

PT Pejabat Tanah (Coding for Pahang Land Office)

SOP Standard Operating Procedures

Sdn Bhd Sendirian Berhad (Private Limited)

SEIA Social and Environment Impact Assessment

Sg Sungai

SGS Societe Generale de Surveillance

SOP Standard Operating Procedures

SPC Senior Plantation Controller

USECHH Use and Standards of Exposure of Chemicals Hazardous to Health

WHO World Health Organisation

yr Year

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1. SCOPE OF CERTIFICATION ASSESSMENT

1.1 National Interpretation Used

The operations of the mill and their supply based of FFB were assessed against the

Roundtable on Sustainable Palm Oil (RSPO), Principles and Criteria (P&C) – Malaysia

National Interpretation (MY-NIWG dated 26th

April 2008).

1.2 Certification Scope

The scope of certification includes the production of Pamol Oil Mill and its supply base

according to the standard of Roundtable on Sustainable Palm Oil (RSPO), Principles and

Criteria (P&C) – Malaysia National Interpretation (MY-NIWG dated 26th

April 2008) and

RSPO Supply Chain Certification Standard dated 25 November 2011.

1.3 Location and Maps

Pamol Oil Mill Management Unit (POM-PMU is located in Labuk-Sugut (also known as

Beluran district) District in Sandakan division, Sabah, in the country of Malaysia (Figure 1).

More detailed information on the estates location and layouts is shown in Figures 2. The GPS

locations of the mills are shown in Table 1.

Table 1: Mill and Supply Base GPS Location

Mill/Supply Base Longitude Latitude

Pamol Oil Mill E5 59 48 N117 23 28

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Figure 1: Location Map for Pamol Oil Mill Management Unit

Figure 2: Estates and Mills Location Map

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1.4 Description of Supply Base and Mill Processing Capacity

The FFB is sourced from 6 estates which are directly managed by IOI Corporation Bhd. The

budgeted crop yields from each estate are listed in Table 2 below.

Table 2: Budgeted Yield from Supply Base (2011/12)

Name of estate

Plantation area Annual FFB

Production (MT)

Production

(ha)

HCV

(ha)

Ulu 1680 3.39 24,797.38

Bayok 1722 43.19 35,061.21

Rungus 2467 7.9 55,159.96

Tindakon 1041 22.30 22,860.64

Meliau 2706 176.1 73,614.08

Nangoh 1864 213.80 44,350.62

Total 11,480 466.68 255,843.89

Table 3: Mill Processing Data (July 11/Jun12)

Financial Year

(FY11/12)

Mill Production Figures (MT) (Audited Estate)

FFBs Received FFBs Processed CPOs Produced PKs Produced

Certified Crop 255,843.89 255,843.89 54,668.67 11,666.05

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Outside Crop 0 0 0 0

Total 255,843.89 255,843.89 54,668.67 11,666.05

1.5 Date of Planting and Cycle

In Pamol Oil Mill Management Unit of IOI Corporation Bhd the palms ware considered

matured when approaching 3 years after planting and will be replanted when they reach the

age of 25 years. A replanting program for all estates involved are available ( See Appendix E )

and being projected for the next five (5) financial years (FY 12/13 to FY 16/17). The age profile

for all the estates are simplified in Table 3 below.

Table 4: Planting Age Profiles for all Supply Base Estates

Age category (year) Ulu Bayok Rungus Tindakon Nangoh Meliau

Immature /Replant 466 204 0 466 0 0

Over 25 Years 0 0 0 0 0 0

21 to 25 Years 58 176 0 0 1117 0

16 to 20 Years 0 99 1160 781 367 2706

7 to 15 Years 613 977 896 0 380 0

3 to 6 Years 285 470 411 260 0 0

1 to 2 Years 258 0 0 0 0 0

Total Production Area 1680 1722 2467 1041 1864 2706

HCV Area 3.39 43.19 7.9 22.30 213.80 176.1

Conservation Area - - - - - -

*Total not cultivated 153.54 240.74 123.32 50.05 201.55 116.55

Total certified area ( ha ) 1836.93 2209.93 2598.22 1579.35 2279.35 2998.65

1.6 Other Certification Held

Pamol Oil Mill Management Unit is also certified under ISCC

1.7 Organizational Information and Contact Person

The company contact person details are as follows:

Name Mr. Too Heng Liew

Designation Head of Sustainability (Malaysia/Indonesia)

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Level 8, Plantation Department Two IOI Square, IOI Resort 62502 Putrajaya Malaysia

Contacts Tel: 03-89478888

Fax: 03-89478989 Email [email protected]

1.8 Time-bound Plan for Other Management Units

IOI Corporation Bhd is a member of RSPO and has been involved in the certification since

2004 and the membership number with RSPO is 010-04(O)

IOI Corporation Bhd owns and operates 12 mills with a milling capacity of 4,100,000 MT

producing about 800,000 MT of palm oil and a plantation hectareage of about 250,000 ha of oil

palm of different ages in Malaysia and Indonesia.. IOI Corporation Bhd has developed a time-

bound plan (Appendix C) for the phased implementation of the RSPO P&C, commencing with

mills and estates. IOI Corporation Bhd will use the experience gained from achieving

certification of the first few mills and estates to implement the RSPO P&C in parallel with the

remainder of its operations. The SGS assessment team considers that IOI Corporation Bhd is

on the right track which is reasonable and challenging, given the widespread geographic

locations of its properties, the resources required and the numbers of smallholders involved.

1.9 Area of Plantation

The areas of supplying estates for this operating unit are listed in Table 4. Details of production

area (mature/immature) are also listed.

1.10 Date Certificate Issued and Scope of Certificate

The certificate issue date is the date of RSPO approval of this assessment report. This

certification scope is [scope of certification]

2. ASSESSMENT PROCESS

2.1 Certification Body

Founded in 1878, the SGS Group is the world’s largest auditing, inspection, testing and

verification organization. Truly global and benefiting from unique international network of more

than 1180 offices, 321 laboratories and 50’000 full time staff, the SGS Group is able to provide

its international clientele with a comprehensive range of services in more than 145 countries.

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SGS has no manufacturing, trading or financial interests which could compromise its

independence. Its guarantee of independence, its reputation for professionalism, integrity and

impartiality, as well as it remarkable international network, place the SGS Group in a unique

position.

The RSPO Programme is the SGS Group’s RSPO Certification Programme internationally

accredited by the RSPO Executive Board to carry out oil palm plantation and supply chain

certification/verification and accreditation for global RSPO certification.

2.2 Assessment Methodology, Programme, Site Visits

The assessment was conducted in 16th – 18

th January 2013 audit days and involving 3 Estates

and the Mill of Pamol Oil Mill Management Unit. The audit covers documentation review,

internal procedures, management system, field inspection as well as identification of any

significant issues for both environment or social issues. A sample of stakeholders was

consulted during the assessment to get their feedback on the management doing.

The assessment was conducted based on random samples and therefore nonconformities may

exist which have not been identified. The methodology for objective evidence collection

included physical site inspection, observation of tasks and processes, interview with workers,

families and stakeholders, documentation review and monitoring data.

The assessment program is included as shown in Table 5 below.

Table 5: Assessment Program

Date Location Activities

16th

Jan 2013

Opening meeting

Bayok Estate

Opening ,Introduction and briefing on status of

Pamol Sabah Unit by Mr Yeap

Opening by SGS

Scheduling

Field visit – EFB applied area, palms planted on

mounted platform , Sg Wan Yang riparian buffer

zone and planting of forest trees to rehabilitate

bufferzone, interview loaders and manurers on

payslip and housing condition, fertiser applied

areas

Lunch

Storage facilities, diesel skid tank, waste

management, staff quarters , HA interview

Document review

17th

Jan 2013

Nangoh / Meliau

Estate

Pamol Mill

Muster at Bayok

Riparian Bufferzone , Landfill , Sg Paliau

riparian reserve management

Harvesting, Loose fruit collector , Frond Stack ,

Interview with workers and mandore, First aid kit

Chemical , Lubricants storage , workshop , oil

trap, Linesite and chicken coop site, domestic

and recycling effort, Clinic, Creche, Deer farm

Document review.

RSPO Supply chain

Document review,

Mill visit – Good Milling practices, safety ,

Scheduled Waste storage Area, first aid Kit ,

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MSDS

Preparation of findings

Discussion with Mr Yeap

18th

Jan 2013

Closing Meeting

Pamol Guest

House

Preparation of Findings

Findings & Recommendations

2.3 Qualification of Lead Assessor and Assessment Team

SGS Malaysia Sdn Bhd holds copies of educational qualifications, certificates and audit logs for

each of the audit team members. SGS has evaluated the qualifications and experience of each

audit team member and has registered the following designations for conducting RSPO

Assessment. Summary of auditors’ educational background and experience are listed in Table

6 below.

Table 6: Auditors Profile

Evaluation Team Notes

Team Leader James S H Ong, B. Agr. Sc is an agronomist by training. He has years

experience in the agriculture sector in Malaysia having worked as Assistant

Plantation Manager in a number of estates in Malaysia. He is familiar with

agricultural practices, agrochemical and fertiliser operations. Has undergone

ISO , RSPO and ISCC Lead Auditor training and has been involved in a

number of audits on oil palm plantations and supply chain audits.

Auditor 1 –

Plantation

As above

Auditor 2 –

Environment and

Social

Mohd Faisal Jaafar is a degree holder in forestry from Universiti Putra

Malaysia. Faisal has a 7 years experience in operating Malaysian

Timber Certification Scheme with specialization in forest management

certification and forest plantation management certification. Has

undergone the necessary ISO 9000 Lead Auditor course and has

gathered substantial auditing experience pertaining to forest

certification.

2.4 Stakeholder Consultation and List of Stakeholders Contacted

As there were no complaints received prior to the audit, moreover this was the fourth

surveillance, no stakeholder meeting was conducted.

3. ASSESSMENT FINDINGS

3.1 Summary of Findings

3.1.1 Principles & Criteria

As outlined, objective evidence was obtained separately for each of the RSPO Indicators and criterion

for the mills and estates. The results for each indicator from each of the operational areas were

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evaluated to provide an assessment of conformity. A statement is provided for each of the RSPO

indicators in order to support the findings of the assessment team.

There were 1 Major Non-conformities and 3 Minor Non-conformities identified during this assessment.

Some areas identified with potential areas for improvement has led to 5 Observations raised. Details

for each Non-conformities and observations are given in Appendix C. Major Non-conformities has

been closed out within the period of 60 days after the assessment. Minor Non-compliances and

Observations will be followed up during the next Annual Surveillance Audit which is scheduled to be

conducted within the period of twelve months after the RSPO approval of Main Assessment.

Principle 1: Commitment to Transparency

Criterion 1.1: Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate language & forms to allow for effective participation in decision making.

1.1.1 Records of requests and responses must be maintained. Major

Findings In compliance: Yes: x No:

Objective evidence:

The Website http://www.ioigroup.com/business/busi_plantoverview.cfm

provides information on their plantation responsibilities, corporate social responsibilities and commitment to sustainability compliance.

En Abdul Rahman Zainal , Asst manager is responsible for social, environment liaison officer as well as the safety coordinator

In Bayok Estate, records of request and responses are kept in the ‘Request Bayok’ that records the request of stakeholders internal or external.

However it was noted that in Bayok Estate the villagers list was not updated in the Dec 2012 list of stakeholders.

Observation 19

Criterion 1.2: Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes

1.2.1 Land titles / user rights (C 2.2)

Findings In compliance: Yes: x No:

Objective evidence:

Copies of management documents like land titles are available at the estates and are available for viewing

1.2.2 Safety and health plan (C 4.7)

Findings In compliance: Yes: x No:

Objective evidence:

The website http://www.ioigroup.com/business/busi_plantoverview.cfm has the safety and

health policy that is publicly available.

It is also posted at the estates and the mill notice board.

1.2.3 Plans and impact assessment relating to environmental and social impacts

(C 5.1, 6.1, 7.1, 7.3)

Findings In compliance: Yes: x No:

Objective evidence:

The plans and impact assessment relating to environmental and social impacts and policy are

publicly available on the website http://www.ioigroup.com/business/busi_plantoverview.cfm .

In addition the environmental improvement plan is found to be contained within the EIA

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Management Action Plans & Continuous Improvement Plan which is reviewed annually.

1.2.4 Pollution Prevention Plan (C 5.6)

Findings In compliance: Yes: x No:

Objective evidence:

The pollution prevention plan is also available in the website

http://www.ioigroup.com/business/busi_plantoverview.cfm under the policy known as

Environmental Policy.

The Pollution Prevention plan is also included in the EIA Management Action Plans & Continuous Improvement Plan which is reviewed annually.

1.2.5 Details of complaints and Grievances (C 6.3)

Findings In compliance: Yes: x No:

Objective evidence:

The details of complaints and procedure are also publicly available on the same website.

It has the following commitment :

We actively seek solutions to grievances and disputes through negotiations and other due processes. These sets of handling procedures are developed to guide us through in our resolutions with the stakeholders involved:

Boundary Disputes Handling

Squatters Disputes Handling

Social Issues Handling

1.2.6 Negotiation procedures (C 6.4)

Findings In compliance: Yes: x No:

Objective evidence:

Similarly the negotiation procedure are also available in the website .

As in 1.2.5, the following are the commitment:

We actively seek solutions to grievances and disputes through negotiations and other due processes. These sets of handling procedures are developed to guide us through in our resolutions with the stakeholders involved:

Boundary Disputes Handling

Squatters Disputes Handling

Social Issues Handling

1.2.7 Continuous improvement plan (C 8.1)

Findings In compliance: Yes: x No:

Objective evidence:

The continuous improvement plan is included in the EIA Management Action Plans & Continuous Improvement Plan which is reviewed annually.

Principle 2: Compliance with Applicable Laws and Regulation

Criterion 2.1: There is compliance with all applicable local, national and ratified international laws and regulations.

2.1.1 Evidence of compliance with legal requirements Major

Findings In compliance: Yes: x No:

Objective evidence:

Compliance to legal requirements are maintained. Permits and trading licenses are available and renewed.

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In Pamol Estate, the land title was viewed

No. of land titles : 1 Country Lease 085310327

Transferred to IOI or Pamol Estates ( Sabah ) : 29/5/1997

Hectareage: 10000ac ( Ulu and Bayok )

In the Mill some of the licences and permit viewed were :

MPOB licence 500134204000 ( 1/8/2012- 31/7/2013 ) for 330,000 MT

DOE Licence : 000781 (30/6/2013)

DOE for Land Irrigation and land application ( Alur air( Pengairan Ladang ) dan atas Tanah ) 1/7/2012 – 30 June 2013)

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

Findings In compliance: Yes: x No:

Objective evidence:

A documented system including written information on legal requirements is available.

Responsible Dept: HR Dept, RSPO team, IOI Adminstration & legal, Safety and health, Individual Estate managers, Visiting medical officer, Area Security Advisor

2.1.3 A mechanism for ensuring that they are implemented Minor

Findings In compliance: Yes: x No:

Objective evidence:

Currently, the person/team responsible for ensuring implementation remains the responsibility of the ‘Sustainability Team’ who carry out internal audit for each estate and mill

2.1.4 A system for tracking any changes in the law Minor

Findings In compliance: Yes: x No:

Objective evidence:

As described above the mechanism of tracking the changes of laws is contained in the IOI File No. 5. The person responsible for monitoring the changes and communicating it to the group remains the ‘Sustainability Team’ who carry out internal audit for each estate and mill

Each estate updates the list of relevant laws and regulations that are required to maintain various legal permits

Criterion 2.2: The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights.

2.2.1 Evidence of legal ownership of the land including history of land tenure Major

Findings In compliance: Yes: x No:

Objective evidence:

The IOI provided the evidences of ownership of land by providing the evidence of land titles for both POM and the supplying estates.

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

Major

Findings In compliance: Yes: x No:

Objective evidence:

Based on the above observation, it is confirmed that all of the land titles are for agricultural crops such as Palm Oil, Cocoa and/or any agricultural crops of economic value. None of the land titles observed carries a title other than agricultural crops.

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2.2.3 Evidence that boundary stones along the perimeter adjacent to state land and other reserves are being located and visibly maintained

Minor

Findings In compliance: Yes: x No:

Objective evidence:

In Bayok , boundary stones where available are maintained.

The GIS team from IOI ( Sabah ) surveyed in August 2012 to verify its boundary.

Overall, the auditor observed that the estates occupation and operation comply with the terms of the land title. .

2.2.4 Where there are, or have been, disputes, proof of resolution or progress towards resolution by conflict resolution processes acceptable to all parties are implemented. (CF 2.3.3, 6.4.1 and 6.4.2)

Minor

Findings In compliance: Yes: x No:

Objective evidence:

In Bayok, no land disputes were reported.

A system is in place to resolve land disputes and is documented in ‘Grievance Procedure for Land Owner Issues’ which is detailed in the social management plan for estates and mill.

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

2.3.1 Where lands are encumbered by customary rights, participatory mapping should be conducted to construct maps that show the extent of these rights.

Major

Findings In compliance: Yes: x No:

Objective evidence:

In Bayok , no customary rights issues since IOI took over the land .

Customary use of land for community purposes have been identified either on maps (places of worship, burial grounds, and archaeological site) and maintained.

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

Findings In compliance: Yes: x No:

Objective evidence:

Maps are maintained in the estates.

Customary use of land for community purposes have been identified either on maps (places of worship, burial grounds, and archaeological site) and maintained.

2.3.3 Copies of negotiated agreements detailing process of consent (C 2.2, 7.5, 7.6) Minor

Findings In compliance: Yes: x No:

Objective evidence:

Currently, there are no claims on legal or customary rights exist for the estate.

Negotiation procedures are also available publicly under the ‘Social Handling Issues’

Principle 3: Commitment to Long-Term Economic and Financial Viability

Criterion 3.1: There is an implemented management plan that aims to achieve long-term economic and financial viability

3.1.1 Annual budget with a minimum of 2 years of projection Major

Findings In compliance: Yes: x No:

Objective evidence:

In Bayok , the annual budget was viewed : Bayok Estate Budget 2012/13

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Under the 5 year management plan the annual budget with a minimum 2 years of projection is available : 2011 - 2016

Ref: IOI Corporation Bhd- Pamol Group Bayok Estate - 5 years Business plan

3.1.2 Annual replanting programme projected for a minimum 5 years with yearly review Minor

Findings In compliance: Yes: x No:

Objective evidence:

The replanting programme is yearly reviewed.

Ref: Management file. Under the 5 – year management plan the replanting programme 2013 – 2017 is documented

See Appendix E

Principle 4: Use of Appropriate Best Practices by Growers and MIllers

Criterion 4.1: Operating procedures are appropriately documented and consistently implemented and monitored.

4.1.1 Documented Standard Operating Procedures (SOP) for estates and mills Major

Findings In compliance: Yes: x No:

Objective evidence:

In Bayok, the documented Standard Operating Procedures (StOPs) was viewed and found to be

maintained .

Procedures were documented at Group level and then translated into StOPs for individual estates where needed. Procedures exist for all operations both in the estates and mill .The StOPs reflect best industry practices as detailed in IOI’s agricultural policy document.

4.1.2 Records of monitoring and the actions taken are maintained and kept for a minimum of 12 months

Minor

Findings In compliance: Yes: x No:

Objective evidence:

The SOPs are monitored annually and any actions are recorded.

Criterion 4.2: Practices maintain soil fertility at, or where possible improve soil fertility to a level that ensures optimal and sustained yield.

4.2.1 Monitoring of fertilizer inputs through annual fertilizer recommendations Minor

Findings In compliance: Yes: x No:

Objective evidence:

Annually, IOI estates like Bayok will receive their fertiliser recommendation report from their R&D.

Annual fertilizer recommendations and records of monitoring of fertiliser inputs are available

Ref: Fertiliser Recommendation & Requirement for Jan 2012 - Dec 2012.

Ref: F99A ERP recommended – 3 kg/palm

Amount applied today : 3 kg/palm

Delayed due to flood.

Manager(Agronomy) : Chua Soon Tat

Ref: Amended fertiliser recommendation for Jan 2012 – Dec 2012 ( 1st

amendment ) contained the recommendation by Mr Chua Soon Tat ( Manager (Agronomy ) dated 28th June 2012.

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Fertiliser applied is recorded in the Fertiliser Application file.

4.2.2 Evidence of periodic tissue and soil sampling to monitor changes in nutrient status Minor

Findings In compliance: Yes: x No:

Objective evidence:

In Bayok there is evidence of periodic foliar and soil sampling are taken on January 25, 2012

Sampling was done for both soil ( frond heap, palm circle etc ) and foliar . Foliar sampling is done annually whereas soil sampling is done every 5 years.

4.2.3 Monitor the area on which EFB, POME and zero-burn replanting is applied Minor

Findings In compliance: Yes: x No:

Objective evidence:

EFB is applied in Bayok Estate and records are monitored in the EFB Transport (Daily ) file

The record show that on 31/12/12 , in field F02B, the amount of EFB transported and applied: 4.52 MT

Application is also recorded in the EFB application map

No POME applied

During replanting Zero-burning advocated

Criterion 4.3: Practices minimize and control erosion and degradation of soils.

4.3.1 Documented evidence of practices minimizing soil erosion and degradation (including maps)

Minor

Findings In compliance: Yes: x No:

Objective evidence:

Ref: Good Agriculture Practices ( Bahasa Malaysia ) is available in the Estates.

Under the section ‘ Pemuliharaan Tanah dan Penteresan’ – documents practices that minimizes soil erosion are available.

Slope/Contour map available in the GIS file.

All slopes are <25 degrees

Since Bayok estate is low lying, the file has also has a erosion- proned identification map along the main river, Sg Labuk.

4.3.2 Avoid or minimize bare or exposed soil within estates Minor

Findings In compliance: Yes: x No:

Objective evidence:

Bayok advocates circle weeding , no blanket spray and maintenence of inter-row vegetation

4.3.3 Presence of road maintenance programme Minor

Findings In compliance: Yes: x No:

Objective evidence:

Bayok

In Bayok Estate , map of road maintenance programme file.

In the Budget file , for Bayok Estate, RM232,046 was budgeted and as of to-date Dec2012 : RM45,032.79 allocated out.

In the road maintenance file, a road repair schedule dated 9 june 2012 for FY 12/13 is documented. The ‘Road Team’ will make their rounds to the estate during the alternate months. It was scheduled to be in Bayok on Jan 11 – 20 but

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due to the flood the programme was delayed.

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

Minor

Findings In compliance: Yes: x No:

Objective evidence:

No peat found

4.3.5 Best management practices should be in place for other fragile and problem soils (e.g. sandy, low organic matter and acid sulphate soils)

Minor

Findings In compliance: Yes: x No:

Objective evidence:

No evidence of fragile or problem soils.

Areas where slopes greater than 25° are not planted with oil palm

Criterion 4.4: Practices maintain the quality and availability of surface and ground water.

4.4.1 Protection of water courses and wetlands, including maintaining and restoring appropriate riparian buffer zones at or before replanting along all natural waterways within the estate.

Major

Findings In compliance: Yes: No: x

Objective evidence:

Although there is a commitment to protect water courses and wetlands especially the natural waterways are included in the Environmental Management Plan as well as in the StOP, however in the following it was shown that protection of watercourses was not maintain.

In Bayok field 09B the Buffer zone that was not marked was sprayed. Similarly in

Meliau, along the Sungai Paliau riparian reserve it was shown that worker has intruded and actively practicing farming.

Major 32

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

Major

Findings In compliance: Yes: x No:

Objective evidence:

No construction of bunds/weirs/dams across the main rivers or waterways passing through an estate.

This was observed in Bayok estate.

Due to the low lying nature of the land, watergates are used to control rising water from the main river especially during the rainy season.

4.4.3 Outgoing water into main natural waterways should be monitored at a frequency that reflects the estates and mills current activities which may have negative impacts (Cross reference to 5.1 and 8.1)

Major

Findings In compliance: Yes: x No:

Objective evidence:

In Bayok Estate, the Environmental Compliance Report June 2012 – Sept 2012 was viewed.

The river monitoring results is available for the following sampling points:

W1 – Meliau – Sg Padau Lawan – Sg Padau Madau

W2 – Nangoh – Sg Labuk

W3 – Tindakon - Sg Kimansi

W4 - Bayok - Sg Labuk

Based on the analysis, the consultant Kiwiheng Wood and Environmental Consultants

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Sdn Bhd reported that the parameters are well within the limits of Class III of the NWQSM ( National Water Quality Standard for Malaysia ) except for BOD .

For the Palm Oil Mill, the following records were viewed for compliance to this indicator :

Monthly analysis of effluent test report available in the IOI PPOM Effluent test & Analysis file

Latest result /report : 11/12/12 . Land Irrigation ( @Facultative Pond ) BOD : 66mg/l , Land application ( @Pond No. 4 ) BOD :168 mg/l

Ref: Borang Penyata sukutahunan ( effluent )

Wastewater not discharged into waterways. 80% for Land application : 20% for Land irrigation .

Latest submission to the Quarterly Jab Alam Sekitar submiited 8/1/13 for the period 1/10/12 – 31/12/12.

For the period Oct – Dec , the BOD reading ( in mg/l ) analysed were :

178, 198, 168 respectively for land application and 62,50,66 respectively for land irrigation for the respective months.

4.4.4 Monitoring rainfall data for proper water management Minor

Findings In compliance: Yes: x No:

Objective evidence:

Rainfall monitored daily and monthly.

In Bayok ,the estate recorded an annual rainfall of 3399 ( 2012 ) ,monthly rainfall ( Dec 2012 ) of 741mm and as of Jan 15, the January monthly rainfall was 152mm.

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

Findings In compliance: Yes: x No:

Objective evidence:

Pamol Mill

Ref : Water consumption monitoring file

Summary of water consumption for the month is available.

Raw water is obtained from Sg Tungud. It will be pumped to:

Overhead tank

Kota Pamol,

Taman Muhibbah

The overhead tank water will be used for the mill boiler , mill processing and cleaning. For the month of Dec 2012, the water usage m3/MT FFB was 0.76

The raw water treated with chlorine will be piped to Kota Pamol and Taman Muhibbah . Kota Pamol includes Bayok, Ulu , school, mill quarters, research quarters.

A flowmeter is available to monitor water usage.

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

Minor

Findings In compliance: Yes: x No:

Objective evidence:

No drainage water into protected or conservation area

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4.4.7 Evidence of water management plans Minor

Findings In compliance: Yes: x No:

Objective evidence:

Ref: Water Management Plan for Pamol Grouping is available and maintained in the estates visited like Bayok Estate.

For water usage supplied by the mill , water usage is monitored by the Mill.

For estates not receiving treated water from the mill, the estate will individually monitor the usage.

Criterion 4.5: Pests, disease, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques.

4.5.1 Documented IPM system Minor

Findings In compliance: Yes: x No:

Objective evidence:

Reference is found in the Group StOPs for Estate Operations under the Index 10 has the IPM protocol , the identification of the pest as well as the control.

The active IPM that is currently being monitored frequently are for the problem / pest such as :

a) Rat

b) Ganoderma

4.5.2 Monitoring extent of IPM implementation for major pests Minor

Findings In compliance: Yes: x No:

Objective evidence:

Ref: Senarai Laporan Penilaian Kualiti Buah./ FFB Delivery & Quality Assessment

The estates carry out daily rat damage surveys through the use of forms IC2 (Estate daily Infield Grading Report) that record both old and new/fresh rat damage percentages.

In Bayok on 14/1/13, the IC2 record a damage of 59 new damage out of 2128 FFB which is equivalent to 2.77% for the fields 04B.

No baiting in 2012 as the damage was below the 5% fresh damage.

No barn owl in Sabah

4.5.3 Recording areas where pesticides have been used Minor

Findings In compliance: Yes: x No:

Objective evidence:

Records of areas where pesticide applied are recorded in the Stock Issue Book , Stock Requisition Note and in the Costing Book

Ref: Stock Issue Book

In Bayok Store Requisition Note cum Store Issue Book eg 10/1/13 , Glyphosate 41% ( BM Glyphosate ) was issued to Field 99D

Amount issued out : 30 lit

Use: circle spray

Costing Book Circle Strip spraying , selective spraying/Mature Total cost : RM12.65

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4.5.4 Monitoring of pesticide usage units per hectare or per ton crop e.g. total quantity of active ingredients (a.i) used/tone of oil

Minor

Findings In compliance: Yes: No: x

Objective evidence:

Ref : RSPO Priciples E.4- Use of appropriate best practices by Growers and Mills .

In Meliau, the usage of methamidophos during the FY 12/13 not captured in the Pesticide monitoring file.

Minor 33

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

4.6.1 Written justification in Standard Operating Procedures (SOP) of all agrochemical use

Major

Findings In compliance: Yes: x No:

Objective evidence:

Although Bayok Estate has the written justification of most of the products frequently used , however justification of use for some products still available at the store like Pursuit, Topsin and Anvil , no written justification use was available

Observation 20 – Raised

4.6.2 Pesticides selected for use are those officially registered under the Pesticides Act 1974 (Act 149) and the relevant provision (Section 53); and in accordance with ESECHH Regulations (2000)

Major

Findings In compliance: Yes: x No:

Objective evidence:

The Pamol Estates uses only officially registered products .

4.6.3 Pesticides shall be stored in accordance to the Occupational Safety and Health Act 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations

Major

Findings In compliance: Yes: x No:

Objective evidence:

Pesticide were stored in accordance to appropriate storage guidelines with proper structure , roofing , flooring and roofing.

However in Bayok and Ulu, some of the the triple rinsed Kencis tins were not properly rinsed as the chemical were still found in the tins. In addition it was kept in the open resulting in rust and rainwater in the tins.

Observation 21

4.6.4 All information regarding the chemicals and its usage, hazards, trade and generic names must be available in language understood by workers or explained carefully to them by a plantation management official at operating unit level

Major

Findings In compliance: Yes: x No:

Objective evidence:

Although most of the information regarding the chemicals and its usage, hazards, trade and

generic names are available in language understood by workers or explained carefully to them by a plantation management official at operating unit level, nevertheless in Bayok Estate :

a) MSDS for Pursuit missing b) MSDS a.i for Anvil was wrong

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c) MSDS for the correct generic brand of glyphosate missing

Similarly at the Mill – MSDS for lubricant s found in the store was to be incomplete

Observation 22

4.6.5 Annual medical surveillance as per CHRA for plantation pesticide operators Major

Findings In compliance: Yes: x No:

Objective evidence:

In Bayok Estate , the annual medical surveillance as per CHRA for the female plantation

pesticide operators were viewed and found to be in compliance.

No of female sprayers : 31

Date of annual medical surveillance: 12 July 2012

Doctor : Dr Shaji A/L Prathap Gopal, Klinik Elopura Sdn Bhd, Sandakan

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

Findings In compliance: Yes: x No:

Objective evidence:

No spraying work with pesticides for confirmed pregnant and breast-feeding women were found.

The Hospital Assistant will check monthly their status monthly and records were viewed. .

4.6.7 Documentary evidence that use of chemical categorized as World Health Organization Type 1A or 1B, or listed by the Stockholm or Rotterdam Conventions and paraquat, is reduced and/or eliminated. Adoption of suitable economic alternative to paraquat as suggested by the EB pending outcome of the RSPO study on IWM

Minor

Findings In compliance: Yes: x No:

Objective evidence:

Use of chemical categorized as World Health Organization Type 1A or 1B, or listed by the Stockholm or Rotterdam Conventions and paraquat, is reduced.

However in Meliau/Nangoh, in the month of March and april , incidence of bagworm Darma trima were beyond the threshold and a class I chemical , methamidophos was used as the chemical ( trunk injection ) after getting approval from the authorities .

Balance of the chemical was kept as the incidence was below the threshold.

4.6.8 Documented justification of any aerial application of agrochemicals. No aerial spraying unless approved by relevant authorities

Major

Findings In compliance: Yes: x No:

Objective evidence:

No aerial spraying

4.6.9 Evidence of chemical residues in CPO testing, as requested and conducted by the buyers

Minor

Findings In compliance: Yes: x No:

Objective evidence:

No request received

4.6.10 Records of pesticides use (including active ingredients used, area treated, amount applied per hectare and number of applications) are maintained for either minimum of 5 years or starting November 2007

Minor

Findings In compliance: Yes: x No:

Objective Records of pesticide used , area treated, amount applied , costing of both material as well as

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evidence: labour is recorded in the costing book.

Records since the 1st audit is still maintained.

Criterion 4.7: An occupational health and safety plan is documented, effectively communicated and implemented

4.7.1 Evidence of documented Occupational Safety Health (OSH) plan which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967 (Act 139)

Major

Findings In compliance: Yes: x No:

Objective evidence:

In Meliau / Nangoh Estate, evidence of documented Occupational Safety Health (OSH) plan

which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967 (Act 139) are available such as :

a) Documented policy : Policy on Safety , Health & Staff Welfare (Polisi Keselamatan dan Kesihatan Pekerja ) ( 2008 ) is posted on the notice board.

b) In Meliau/Nangoh with reference to the Management file - Safety and risk assessment section. Risk assessed in early 2012 : identification of the risk, analysis of the risk, and the control/ risk control Occupational Safety & Health Risk Assessment

c) Conducted by Jimi Dalinting, the appointed Safety and Health Manager for this Pamol Unit

d) Training Ref : Safety and Health Training Programme File. Training Records: Safety training Programme 2012 and 2013.

E.g. On 8 Jan 2013 a safety training was conducted for Manual application of fertiliser by Mr Rayjack Modi Field Supervisor, Meliau.

On 23rd

Dec 2012 , a training was done on First aid conducted by Fatimah Hj Tasman, Health Assistant .

MSDS on 10/12/12

e) PPE – Issuance and replacement records available : PPE Stock Record and Replacement. Appropriate PPE were used by harvester Aidil Abdul in Nangoh and loose fruit collector Matilda, Marlin etc . From PPE records, in December 2012, 10 white helmets were issued to new workers.

f) Records of meeting : Ref Committee chart /appointment letter /Committee meeting Minutes file. Based on their records their quarterly meeting were conducted on 25

th Oct 2012, 20 July 2012, 25 Apr 2012, 26 Jan 2012.

g) The meetings were attended by the manager, representatives of the staff and workers.

h) ERP for accident, chemical spillage, fire were posted at the chemical store.

However even though the OSH is documented yet the following are lapses found in the implementation:

In Bayok, cigarette butts found at the Diesel skid tanks where a ‘ No smoking sign ‘ was posted.

In the mill workshop , the First Aid Kit was missing.

Observation 23 – Raised

4.7.2 Records should be kept of all accidents and periodically reviewed at quarterly intervals

Major

Findings In compliance: Yes: X No:

Objective evidence:

In Meliau Estate, the accident records were viewed.

Ref: Accident and Investigation Report ( Including KPI ) file

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a) Monthly accident KPI / KPI accident

b) Pengukuran dan Pemantauan kemalangan

a) Analisa Pemantauan & Penilaian/ Accident Investigation

b) Statistic kemalangan/ Accident summary

c) Accident Reporting AR1 Form

JKKP-8 is submitted to the Jab keselamtan dan kesihatan Pekerjaan

In Meliau Estate, the latest accident recorded : 9/12/12 En Bahar b Abo. His leg was cut by parang. Recorded in the Clinic Accident Report Book

4.7.3 Workers should be covered by accident insurance Major

Findings In compliance: Yes: x No:

Objective evidence:

Ref: Foreign workers Compensation Scheme Policy ( FWCS ) MSIG for the period : 1/10/2012 – 30 Sept 2013 for 430 workers. New workers are also insured.

Policy Number DJ 08544937-FWC

Insurance cover: Workmen compensation, Repatriation Expenses, Personal Accident

Local workers are covered under the SOCSO scheme

No claims has been recorded for the since the last financial year

Criterion 4.8: All staffs, workers, smallholders and contractors are appropriately trained.

4.8.1 A training programme (appropriate to the scale of the organization) that included regular assessment of training needs and documentation, including records of trading for employees are kept

Major

Findings In compliance: Yes: x No:

Objective evidence:

The Safety and Health training plan and programme 2012/13 of Bayok Estate was viewed and was found to be appropriate . Records of attendees were also kept.

In it , some of the trainings in the file are :

Loader training for new worker Mohammad Sharil Darwis

14 /8/12 Cara Kerja Selamat menyembur Racun , 7 sprayers. Trainer : Andy Kassim , Estate Assistant Manager

24/8/12 Buffer zone training. 14 sprayers. By Andy Kassim , Estate Assistant Manager

Principle 5: Environmental Responsibility and Conservation of Natural Resources and Biodiversity

Criterion 5.1: Aspects of plantation and mill management, including replanting, that have environmental impacts are identified and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement.

5.1.1 Documented aspects and impacts risk assessment that is periodically reviewed and updated

Major

Findings In compliance: Yes: x No:

Objective evidence:

Documented Environmental Impact Assessment (EIA) i.e. EIA Management Action Plans & Continuous Improvement Plan is available dated 31

st March 2012 (Bayok), 4

th

January 2013 (Nangoh and Meliau) and 31st December 2012 (Pamol POM).

The revised version prepared by the estates manager and approved by the plantation controller specifies the updates of the aspect s and impacts identified following to the EIA that has been conducted.

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5.1.2 Environmental improvement plan to mitigate the negative impacts and promote the positive ones, is developed, implemented and monitored

Minor

Findings In compliance: Yes: x No:

Objective evidence:

Environmental improvement plan is found to be contained within the EIA Management Action Plans & Continuous Improvement Plan dated 31

st March 2012 (Bayok), 4

th

January 2013 (Nangoh and Meliau) and 31st December 2012 (Pamol POM).

The established plan is formulated to mitigate the negative impacts and promote the positive ones. The plan is found to be implemented and adequately monitored as per the aspects and impacts identified.

Criterion 5.2: The status of rare, threatened or endangered species (ERTs) and highly conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations.

5.2.1 Identification and assessment of HCV habitats and protected areas within land holdings and attempt assessments of HCV habitats and protected areas surrounding landholdings

Major

Findings In compliance: Yes: x No:

Objective evidence:

Areas within the estates with High Conservation Value (HCV) have been identified for biodiversity and environmental protection. Management to conserve the HCV value has been initiated. These areas have been identified on Geographical Information System (GIS maps), and marked in the field. Ecological types have been identified and a provisional list of species present drawn up. These HCVs have identified habitats for ERT species such as the Proboscis Monkey. Assessment of the sites have identified the areas as unsuitable for palm cultivation and having values that would benefit from conservation. Evaluation of threats to the sites have been undertaken and incorporated into the management plan where the site is being managed in accordance to the prescribed management plan. Regular monitoring activities of these sites is undertaken to prevent degradation due to human activities. In addition, the conservation areas has been identified and protected in Bayok estate where the proboscis monkeys are present comprise of about 43 ha of riverine forest with dominant ficus species. For connectivity purposes, the company has identified and demarcated about 40 m of river buffer along the main river which eventually connecting the 43 ha conservation area with the buffer zones along the river which could be wider habitat for the fauna. The proboscis monkey from other locations can eventually mixed with those in the conservation area.

5.2.2 Management plan for HCV habitats (including ERTs) and their conservation Major

Findings In compliance: Yes: x No:

Objective evidence:

The revised version of HCV Management Action Plans and Continuous Improvement Programme for estates are evident and include proscriptive activities for social engagement with local communities, information on wildlife, security patrols and maintenance of facilities. Field management is evidently supported through budget allocated for soil and water conservation.

In addition, plans and monitoring programme and continuous improvement plan as well as progress towards achieving key objectives identified within the management action plans is also highlighted within the document.

5.2.3 Evidence of a commitment to discourage any illegal or inappropriate hunting, fishing or collecting activities and developing responsible measures to resolve human-wildlife conflicts

Minor

Findings In compliance: Yes: x No:

Objective evidence:

The management of the individual estates has taken action to discourage any illegal or inappropriate hunting fishing or collecting activities. IOI Pamol has erected many ‘no

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hunting’ sign within the estates and conducted a number of awareness training to the workers and local communities to discourage hunting and disturbance to the natural areas.

Criterion 5.3: Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner.

5.3.1 Documented identification of all waste products and sources of pollution Major

Findings In compliance: Yes: x No:

Objective evidence:

Documented identification of all wastes products identified within the estates and mill is highlighted within the EIA document. The plan contains the identification of the pollutions, the environmental impact of the pollution, the improvement (action) plan, documents that need to be reviewed and management review comments. The document specifies the following pollution source that has been identified as follows:

Palm Oil Mill Effluent (POME) – Pollutant;

Empty fruit bunch (EFB) – mill waste product;

Fibre/Shell/Boiler ash (mill waste product after burning fibre and shell);

Scheduled Waste Store- spent oil/lubricants and empty chemical containers – layout of storing used oil/lubricant and empty chemical containers;

Workshop- incidents that may occur following to the spillage or leakage oil from vehicle;

Scrap metal;

Pruned oil palm fronds;

Diesel – design of oil trap;

Usage of diesel generator;

Efficient usage of electricity and office papers;

Pesticides store/premixing of chemical area – for weeding and [pests operations;

Clinical waste;

Recreational park (only in Meliau and Nangoh);

Washing of floor lubricant, CPO from Marshal yards, ramp etc. (Pamol POM);

Noise pollution (Pamol POM);

Smoke emission (Pamol POM);

Generator (Pamol POM);

Jetty and CPO dispatch from mill storage tank (Pamol POM);

Landfill; and

Domestic waste e.g. bottles, tin, tyres, plastic etc, sewage and garden residue.

5.3.2 Having identified wastes and pollutants, an operational plan should be developed and implemented to avoid or reduce pollution

Minor

Findings In compliance: Yes: No: x

Objective evidence:

Operational plan has been developed for each of the identified pollutants.

Visits to the storage area and documented evidence that records are kept.

In Nangoh , records of chemical container disposal are kept in the Triple Rinsing file

Date: 22 Nov 2012

The HSE manager , Mr Jimi Dalinting issued a ‘triple rinse certificate’ to indicate 10 ‘bm Glyphosate’ containers and 340 ‘bm Cergas’ containers were triple rinsed.

On 22/11/12 , 150 kg ( as above ) was collected by Newgates Industries (Borneo) Sdn Bhd , the licensed disposal operator.

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However, some non-compliance to this indicator were still found :

Bayok /Meliau Estate – Recycle bins were used as domestic waste disposal bins

Bayok Estate – fluorescent lighting tube found indiscrimately thrown on the garden patch at the staff quarters

Palm Oil Mill – fluorescent tube and bulbs were found at the scrap /rubbish site when it should be in the Scheduled Waste store

Meliau Estate – reuse of chemical container as water container in the worker chicken coop

Meliau Estate - metal drum clamps thrown over the fence into the chicken coop site

Minor CAR 34 -Raised

5.3.3 Evidence that crop residues/biomass are recycled (Cross reference C 4.2) Minor

Findings In compliance: Yes: x No:

Objective evidence:

Currently, crop residues/biomass like EFB is recycled as it sent to Meliau and Nangoh which are the nearest estates to the Mill and applied within the palm rows .

Both these estate consumed approximately 95% of the EFB sent. The rest are sent to tor estate like Bayok Estate.

The auditing team note that application is made on block by block basis and each of dispatch is recorded on a daily and tonnage basis.

The shell and fibre are used as renewable energy source in the mill boiler.

Criterion 5.4: Efficiency of energy use and use of renewable energy is maximized.

5.4.1 Monitoring of renewable energy use per ton of CPO or palm product in the mill Minor

Findings In compliance: Yes: x No:

Objective evidence:

Boiler efficiency has been calculated by Pamol Oil Mill.

The record was maintained on daily basis that is kept within the Power House Logsheet – Kilowatt Hours Record.

The calculation is made using actual data such as total fibre, shell as well as total usage of water.

Based on record, for 2012 average tonne FFB processed for every kilowatt hours is recorded at 0.399 tonne/kWh

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

Minor

Findings In compliance: Yes: x No:

Objective evidence:

Records of usage of fossil fuel are available and compared to the volume of the FFB processed.

All records are kept within the Power House Logsheet – Kilowatt Hours Record.

For 2012, the average consumption for every metric tonne FFB processed is 1.795lit/mt FFB.

Criterion 5.5: Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN Guidance or other regional best practice.

5.5.1 No evidence of open burning. Where controlled burning occurs, it is as prescribed Major

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by the Environmental Quality (Declared Activities) (Open Burning) Order 2003

Findings In compliance: Yes: x No:

Objective evidence:

IOI Pamol Estate Sabah advocates a zero-burning policy during replanting

5.5.2 Previous crop should be felled/mowed down, chipped/shredded, windrowed or pulverized/ploughed and mulched

Minor

Findings In compliance: Yes: x No:

Objective evidence:

Refer indicator 5.5.1. in general, all felled trunks are chipped and windrowed

5.5.3 No evidence of burning waste (including domestic waste) Minor

Findings In compliance: Yes: No: x

Objective evidence:

Meilau and Nangoh , open burning of waste ( include plastics ) seen in front of the workers quarters near the deer farm

Minor 31 Maintained

Criterion 5.6: Plans to reduce pollution and emissions, including greenhouse gases are developed, implemented and monitored.

5.6.1 Documented plans to mitigate all polluting activities (Cross reference C 5.1) Major

Findings In compliance: Yes: x No:

Objective evidence:

The pollution prevention plan is available within the EIA document. The plan contains the identification of the pollutions, the environmental impact of the pollution, the improvement (action) plan, documents that need to be reviewed and management review comments.

Activities that contribute to the mitigation of polluting activities from waste management at the mill and estates has been implemented according to the EIA-improvement (action) plan that includes attenuating concentrated mill wastes- EFB, fibre, shell, ash & POME, by distribution to the field, recycling of waste materials – metals, plastics, etc.

Several action plans has been taken for improving the identified pollution activities or sources, for example, the wastewater analysis is done every week and submitted to DOE on a monthly basis.

Furthermore, Water Quality Analysis (NWQSM) is also has been conducted every 6 months. Furthermore, there is also a Water Quality Index analytical monthly report that has been established at POM level and submitted to external lab for analysis.

Boiler stack emission is also monitored and discharge form the effluent pond is monitored quarterly. Water quality of adjacent rivers is also monitored through the Water Management Plan. In order to reduce the emission of GHG at the mill, in particular methane, Pamol has been implementing the monitoring programme of POME release for land application or land irrigation that shall be in accordance to the local Sabah DOE requirements.

5.6.2 Plans are reviewed annually Minor

Findings In compliance: Yes: x No:

Objective evidence:

Environmental management and monitoring plan are reviewed annually for all estates and mill. The revised version of the plan dated 31

st March 2012 (Bayok), 4

th January

2013 (Nangoh and Meliau) and 31st December 2012 (Pamol POM) are made available to

the auditing team during the Annual Surveillance Audit 04.

5.6.3 Monitor and reduce peat subsidence rate through water table management (Within Minor

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ranges specified in C 4.3)

Findings In compliance: Yes: x No:

Objective evidence:

Not Applicable.

Principle 6: Responsible Consideration of Employees and of Individuals and Communities by Growers and Millers

Criterion 6.1: Aspects of plantation and mill management, including replanting, that have social impacts are identified in a participatory way and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored to demonstrate continuous improvement.

6.1.1 A documented social impact assessment including records of meetings Major

Findings In compliance: Yes: x No:

Objective evidence:

The documented Social Impact Assessment (SIA) – Management Action Plans & Continuous Improvement Plan dated 23 November 2012 (Bayok), 4

th January 2013

(Meliau and Nangoh) is available.

The documents listed a series of sections relating to social of which one of it is on Social Impact Assessment (Section 15.0) that specifies methodology, social surveillance assessment and continuous improvement of social impact assessment.

The SIA is acted as the medium for an active impact assessment document where a reasonable amount of consideration has been given to mitigate social impacts for employees and surrounding local communities affected by the plantations and mill.

In addition a Social Action Plan is established on annual basis with a view to resolve social issues adequately, in terms of clearly outlining the responsibilities for mitigation and monitoring.

6.1.2 Evidence that the assessment has been done with the participation of affected parties

Minor

Findings In compliance: Yes: x No:

Objective evidence:

All records of meetings, consultation takes place during the SIA is incorporated in the assessment document. List of the stakeholders consulted are also available within the document.

Furthermore, consultation during the establishment of Social Action Plan is also conducted.

The evidence of such participative consultation with the relevant and affected stakeholders that was held on 23 November 2012 is evident within the document in the form of signed attendance list as well as pictorial evident showing the consultation that takes place.

The minutes of the meeting of the consultation is also maintained.

6.1.3 A timetable with the responsibilities for mitigation and monitoring is reviewed and updated as necessary

Minor

Findings In compliance: Yes: x No:

Objective evidence:

There is Social Action Plan established specifying the issues and strategies to be implemented and reviewed on a yearly basis. In general, the action plan specifies the following plan:

Line site cleaning;

Fire fighting training;

Line site sanitation check;

Employee consultative meeting;

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ELCB check;

Grievance procedure training;

Sexual harassment policy training;

Group policy training;

Line site structure checks;

Annual impact review;

Security guard training;

Sport day;

Labour day celebration;

Emergency response training;

Annual thanksgiving fest;

Meeting with representative of places of worship; and

Checking of estate amenities.

Furthermore, Social Action Plan also specifies the responsible person to implement and the timeframe for the action plan to be conducted.

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

6.2.1 Documented consultation and communication procedures Major

Findings In compliance: Yes: x No:

Objective evidence:

The consultation and communication procedures is found to be integrated within the SIA document under the following sections:

8.0: Grievance Procedure;

9.0: Sexual Harassment Procedure;

10.0: Stakeholder Request Procedure;

11.0: Grievance Procedure for Land Owner Issues

In general, the above-mentioned procedures describe the procedures and mechanism to be taken should any stakeholders being the external or internal wish to communicate with the company on any issues concerning their interest. Example of communications procedures and mechanisms viewed are as follows:

i) Grievance reporting flowchart

ii) Sexual Harassment reporting flowchart

iii) Stakeholder request procedure (corporate and estate level)

iv) Grievance procedure for land owner issues

6.2.2 A nominated plantation management official at the operating unit responsible for these issues

Minor

Findings In compliance: Yes: x No:

Objective evidence:

IOI Pamol has assigned the Social Liason Officer as the responsible person in handling all matters and issues pertaining to socials that covers the following responsibilities:

Welfare and social needs of stakeholders (i.e. workers, suppliers, smallholders Kampong etc directly related to estate).

Periodic visits to line site and social amenities to ensure that buildings are in good order (through Hospital Assistant).

Periodic visits to neighbouring stakeholders on a reactive manner to ensure that social issues are being taken care of (to have consultation to ensure that communication chain is available and maintained).

Identification of social issues affecting stakeholders and neighbouring community/ies and to decide upon mitigation plans to solve social issues after consultation with the

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manager.

Maintenance and monitoring of grievance issues and facilitate feedback mechanism to ensure that a line of communication is available.

Monitoring of crèche and day care centre to ensure that children are being well taken care of and adequately educated.

To stakeholder’s requests and ensure that requests are followed up with a response.

Grievance issues (encompassing social, work, repairs, etc.) and ensuring that proper follow up is conducted (this is to be documented).

Safety and health aspect of line site / estate / workers etc.

Other social issues arising / ad hoc social issues (this is situation dependent). An appointment letter signed by the estates manager appointing the liaison officer is available.

6.2.3 Maintenance of a list of stakeholders, records of all communication and records of actions taken in response to input from stakeholders

Minor

Findings In compliance: Yes: No: x

Objective evidence:

List of stakeholders at estate and mill level and records of communication is available. These include local banks, contractors, vendors, local authority services, government agencies including the list for NGOs, neighbouring mills and estates etc.

The absence of an updated list for 2012 was already raised under 1.1.1 as Observation 19

Criterion 6.3: There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties.

6.3.1 Documentation of the process by which a dispute was resolved and the outcome Major

Findings In compliance: Yes: x No:

Objective evidence:

All records of complaints and grievances external and internal are kept within the Grievance/Request Record Book.

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

To address all the grievances and complaints raised by the relevant interested stakeholders, IOI Pamol has established the procedures covering the above-mentioned grievance and sexual harassment procedures highlighted in 6.2.2 to resolve the grievance raised in the form of flow chart that is formulated in both English and Malay language and is found to be posted on the company’s notice board.

Furthermore the procedure to resolve the grievances involving land issues is established. Among others, the mechanism highlights the way of resolving the grievances through the following steps:

Direct Negotiation;

Arbitration if Direct Negotiation is not able to solve the grievance;

Native Court if Arbitration is not able to solve the grievance; and

Civil Court as the ultimate platform if Native Court is not able to solve the grievance.

6.3.2 The system resolves disputes in an effective, timely and appropriate manner Minor

Findings In compliance: Yes: x No:

Objective evidence:

The established grievance procedures specify the estimated time that required to be taken for each of the process to be addressed before proceed to the subsequent process.

During the Annual Surveillance Audit the Grievance/Request Record Book are viewed

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and all request and grievances are recorded on a case by case basis stating following items:

the details of the complainant,

the date complaints recorded; and

the action taken following the complaints raised.

Based on the records showed, the auditing team observed that generally the follow-up action has been taken within 5 working days from the day the complaints received.

6.3.3 The system is open to any affected parties Minor

Findings In compliance: Yes: x No:

Objective evidence:

The system for dealing with complaints and grievances is open to all affected parties and interviews with workers and stakeholders indicate that no discrimination has taken place. The system is open to any affected parties through:

i. Employees Consultative Committee (ECC).

ii. Gender representation (at least a designated gender representative).

iii. Designated grievance book which is endorsed by the complainants when action has been taken to resolve a grievance.

Criterion 6.4: Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions.

6.4.1 Establishment of a procedure for identifying legal and customary rights and a procedure for identifying people entitled to compensation

Major

Findings In compliance: Yes: x No:

Objective evidence:

As stated in Indicator 6.3.1, the procedure to resolve the grievances involving land issues is established. Among others, the mechanism highlights the way of resolving the grievances through the following steps:

Direct Negotiation;

Arbitration if Direct Negotiation is not able to solve the grievance;

Native Court if Arbitration is not able to solve the grievance; and

Civil Court as the ultimate platform if Native Court is not able to solve the grievance.

6.4.2 A procedure for calculating and distributing fair compensation (monetary or otherwise) is established and implemented. This takes into account gender differences in the power to claim rights, ownership and access to land; and long-established communities; differences in ethnic groups’ proof of legal versus communal ownership of land.

Minor

Findings In compliance: Yes: x No:

Objective evidence:

IOI Pamol has a procedure in place for calculating and distributing fair compensation. That can be divided into two sections as follows:

a. The procedures for compensation involving workers:-

- In general, this procedures deal with the procedures for retrenchment benefits for workers that is formulated based in the national industrial standard, National Union of Plantation Workers (NUPW) and IOI Pamol agreement.

b. The procedures for compensation involving land owners:-

- This procedures for dealing on any issues relating to land and native customary rights that is formulated step wise from the receipt of the grievance from the land owner.

6.4.3 The process and outcome of any compensation claims is documented and made Minor

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publicly available

Findings In compliance: Yes: x No:

Objective evidence:

No incidences of compensation of claims occur.

Criterion 6.5: Pay and conditions for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages.

6.5.1 Documented of pay and conditions Major

Findings In compliance: Yes: x No:

Objective evidence:

There is evidence of documentation of rates of pay, contracts of employment, terms and conditions of employment made available in languages understood by workers or explained carefully by management personnel of the individual operating unit.

The appointment letter of staff contain the clear details of job description, work location, salary and other terms such as annual leaves, medical benefits etc. Similarly, offer letter extended to the foreign workers contain the similar details with additions of terms and conditions wage calculation, overtime, housing, deduction for levy, payment to FOMEMA, legal age, prohibition of marriage, conflict resolutions as well as termination of work permit and prohibition against strike.

6.5.2 Labour laws, union agreements or direct contracts of employment detailing payments and conditions of employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc) are available in the language understood by the workers or explained carefully to them by a plantation management official in the operating unit

Minor

Findings In compliance: Yes: x No:

Objective evidence:

Employment contract for foreign workers available. There are terms of reference for signed contracts between employers and employees stipulating the position, working hours, type of work, location of work, workers’ responsibility, wages, allowances, holidays, rest days, annual leave, fringe benefits, levy deductions (for foreign workers), dismissal, etc.

The appointment letter of staff contain the following elements:

Job description;

Work location;

Salary;

Increment and bonus;

Duration of employment;

Public holidays (12 days per annum, including four (4) compulsory holidays, i.e. Labour Day, Agong’s Birthday, National Day and State Governor’s Birthday;

Annual leave;

Medical benefit, i.e. free medical attention;

Group insurance coverage;

Employees Provident Fund (EPF);

Notice of Termination;

Transfers;

Other employment; and

Confidentiality.

The offer letter (Surat Tawaran Kerja) for migrant workers contains the following:

Job description;

Contract duration and hours;

Work location;

Employee responsibility;

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Wage calculation (80% basic piece rate and 20% statutory benefits, i.e. public holiday, sick leave, sick pay, overtime, annual leave and rest days);

Overtime;

Leave: public holidays, sick leave, hospitalisation, annual leave and rest days. All of the leave days are included in the salary and will be paid accordingly;

Facilities: housing, transportation, medical treatment at estate clinic, insurance;

Deduction of levy to the Malaysian Government;

Legal working age: 18-50 years; and

Termination of work permit.

6.5.3 Growers and millers provide adequate housing, water supplies, medical, educational and welfare amenities in accordance with Workers’ Minimum Standard of Housing and Amenities Act 1990 (Act 446) or above, where no such public facilities are available or accessible (not applicable to smallholders)

Minor

Findings In compliance: Yes: x No:

Objective evidence:

Workers have access to clean water, segregated sanitary and bathing facilities and electricity.

All employees are given adequate housing, medical, educational and welfare amenities and waste disposal facilities in accordance with Workers’ Minimum Standard of Housing and Amenities Act.

Disposal of domestic solid wastes at the line site is conducted at least twice a week.

Criterion 6.6: The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel.

6.6.1 Documented minutes of meetings with main trade unions or workers representatives

Major

Findings In compliance: Yes: x No:

Objective evidence:

Employees Consultative Committee (ECC) at POM and estates has been established. The ECC handles minor issues dealing with repair of amenities and provision of facilities. Where foreign workers are concerned, freedom of association is subjected to Malaysian labour and immigration regulations.

Chaired by the manager of the mill and Social Liasion Officer has taken responsibility as the Secretary. In addition, a representative from workers are appointed and nominated among the workers. There is also a representative representing the management of the company.

Based on the committee records, the representative of the workers can be divided into the following work division:

Harvester;

Carrier and Cutters;

General Workers;

Tide gate;

Driver loaders;

Sprayer; and

Manurer.

An appointment letter for each of the representative is available highlighting the role and responsibilities as a member of the committee as follows:

Assisting in effective establishing and implementing the procedures for each of the programmes that has been scheduled;

Conducting the study on issues pertaining to cleanliness, housing, social etc and subsequently report such issues to the top management and to provide recommendation for improvement plan;

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To revised the periodic occupational consultative policy within working station;

To recommend to the top management on rehabilitation and enhancement plan and to record such recommendation; and

To inspect the working station as well as the linesites to establish the good and healthy working environment.

Since last Annual Surveillance Audit, the ECC has been conducted for the following estates:

Estates Date

Bayok 27 March 2012;

14 June 2012;

18 September 2012; and

28 December 2012.

Meliau 26 January 2012;

26 April 2012;

20 July 2012; and

25 October 2012.

Nangoh 20 January 2012;

20 April 2012;

20 July 2012; and

19 October 2012

6.6.2 A published statement in local languages recognizing freedom of association Minor

Findings In compliance: Yes: x No:

Objective evidence:

A valid freedom of association policy is available in all local languages i.e. Malay, English, Chinese, Kadazandusun, Tagalog and Indonesian language.

The policy is found to be posted on the company’s notice and information wall.

Criterion 6.7: Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programmes. Children are not exposed to hazardous working conditions.

6.7.1 Documented evidence that minimum age requirement is met Major

Findings In compliance: Yes: x No:

Objective evidence: Policy statement for no child labour dated 5th November 2009 endorsed by the Group is

available. The policy indicates that IOI Corporation adopted a policy of only workers above 18 years old is employed by the company.

Employment records evidenced that employment age requirement is met. Ground observation during surveillance visit also does not show evidence to suggest employment of underage workers.

Criterion 6.8: Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation union membership, political affiliation or age is prohibited.

6.8.1 A publicly available equal opportunities policy Major

Findings In compliance: Yes: x No:

Objective evidence:

There is a publicly available equal opportunities policy which states that the company is an equal opportunity employer, whereby the company does not practice discrimination based on race, caste, national, origin, disability, gender, sexual orientation, union membership, political affiliation, or age.

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6.8.2 Evidence that employees and groups including migrant workers have not been discriminated against

Minor

Findings In compliance: Yes: x No:

Objective evidence:

There is no evidence of discrimination when a cross section of employees was interviewed. A functioning grievance mechanism is in place.

The ECC also looks into allegation of discrimination if reported.

Criterion 6.9: A policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied.

6.9.1 A policy on sexual harassment and violence and records of implementation Major

Findings In compliance: Yes: x No:

Objective evidence:

A policy on sexual harassment exists. The policy was also written in the Malay language and displayed on the notice boards. No evidence or practices that contradict this policy were observed.

Interviewed with Gender Committee was conducted and found there were no incident of sexual harassment happened in the estate.

In addition, similar interview evidenced that the company provide fair and just treatment to women.

6.9.2 A specific grievance mechanism is established Minor

Findings In compliance: Yes: x No:

Objective evidence:

A mechanism for recording harassment is also available. No evidence or practices that contradict this policy were observed. Discussion with the workers shows that the company provide fair and just treatment to women. Grievance mechanism for sexual harassment is in place. A documented sexual harassment grievance mechanism exists.

A Gender Representative appointed for each estate and mill, whose duties covering the following:

Assisting in establishing the procedures for handling sexual harassment in workplace;

To review the effectiveness of the established procedures for handling sexual harassment and to provide recommendation to the top management for improving the established procedures;

To report to the top management on any unhealthy ethics within the workplace and to provide the recommendation for improvement purpose; and

To review the effectiveness of the sexual harassment program conducted.

The Gender Representative is also in-charge of communicating the Policy on the Prevention and Eradication of Sexual Harassment in the Workplace to the workers and staff.

Based on records, the Gender Committee Meeting has been conducted for the visiting estates as follows:

Estates Date

Bayok 18 September 2012;

14 June 2012; and

27 March 2012.

Meliau 24 February 2012; and

17 August 2012.

Nangoh 23 March 2012; and

11 September 2012

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Criterion 6.10: Growers and mills deal fairly and transparently with smallholders and other local businesses.

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

Findings In compliance: Yes: x No:

Objective evidence:

Not applicable as Pamol oil mill is not sourcing FFB from outside suppliers including smallholders. All contractual agreements are legal and appear to be fair and transparent. Interviews with suppliers and contractors at the estates reveal that all payments are made in a timely manner.

6.10.2 Current and past prices paid for FFB shall be publicly available Minor

Findings In compliance: Yes: x No:

Objective evidence:

Not applicable as Pamol oil mill is not sourcing FFB from outside suppliers including smallholders. All contractual agreements are legal and appear to be fair and transparent. Interviews with suppliers and contractors at the estates reveal that all payments are made in a timely manner.

6.10.3 Evidence that all parties understand the contractual agreements they enter into and that contracts are fair, legal and transparent

Minor

Findings In compliance: Yes: x No:

Objective evidence:

Not applicable as Pamol oil mill is not sourcing FFB from outside suppliers including smallholders. All contractual agreements are legal and appear to be fair and transparent. Interviews with suppliers and contractors at the estates reveal that all payments are made in a timely manner.

6.10.4 Agreed payments shall be made in a timely manner Minor

Findings In compliance: Yes: x No:

Objective evidence:

Not applicable as Pamol oil mill is not sourcing FFB from outside suppliers including smallholders. All contractual agreements are legal and appear to be fair and transparent. Interviews with suppliers and contractors at the estates reveal that all payments are made in a timely manner.

Criterion 6.11: Growers and millers contribute to local sustainable development wherever appropriate.

6.11.1 Demonstrable contributions to local development that are based on the results of consultation with local communities

Minor

Findings In compliance: Yes: x No:

Objective evidence:

The individual estates and the mill have a very basic form of corporate social responsibility (CSR), which usually involves stakeholders, in particular local communities and smallholders approaching the company for contributions and donations on various occasions such as:

Religious celebrations,

For the upkeep and maintenance of schools,

Family day,

School sports day,

Request to use estates facilities; and

Providing security support for local communities.

Contribution to workers also is evident such as providing the usage of facilities for wedding event, the donation following to death of workers, during the wedding of the workers as well as donation for medical treatment of workers who suffer from serious illness such as cancer.

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All activities and contribution rendered are recorded in the Social and Grievance Record for each of the financial year.

Principle 7: Responsible Development of New Plantings

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

Criterion 7.1: A comprehensive and participatory independent social and environmental impact assessment is

undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management and operations.

7.1.1 An independent and participatory social and environmental impact assessment (SEIA) to be conducted and documented (Cross ref. to C 7.2, 7.3, 7.4, 7.5, 7.6).

Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.1.2 The results of the SEIA to be incorporated into an appropriate management plan and operational procedures developed, implemented, monitored and reviewed.

Minor

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.1.3 Where the development includes smallholder schemes of above 500ha in total, the impacts and implications of how it is managed should be documented and a plan to manage the impacts produced.

Minor

Findings In compliance: Yes: No:

Objective evidence:

No new planting

Criterion 7.2: Soil surveys and topographic information are used for site planning in the establishment of new

plantings, and the results are incorporated into plans and operations.

7.2.1 Soil suitability maps or soil surveys adequate to establish the long-term suitability of land for oil palm cultivation should be available.

Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.1.2 Topographic information adequate to guide the planning of drainage and irrigation systems, roads and other infrastructure should be available.

Minor

Findings In compliance: Yes: No:

Objective evidence:

No new planting

Criterion 7.3: New plantings since November 2005, have not replaced primary forest or any area required to

maintain or enhance one or more High Conservation Values.

7.3.1 A HCV assessment, including stakeholder consultation, is conducted prior to any conversion.

Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.3.2 No conversion of Environmentally Sensitive Areas (ESAs) to oil palm as per Peninsular Malaysia’s National Physical Plan (NPP) and Sabah Forest Management Unit under the Sabah Forest Management License Agreement.

Major

Findings In compliance: Yes: No:

Objective No new planting

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evidence:

7.3.3 No new plantings on floodplains (reference to be made to State DID). Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.3.4 Dates of land preparation and commencement are recorded. Minor

Findings In compliance: Yes: No:

Objective evidence:

No new planting

Criterion 7.4: Extensive planting (to be determined by SEIA) on steep terrain, and/or on marginal and fragile

soils, is avoided.

7.4.1 All new plantings should not be cultivated on land more than 300m above sea level and on land more than 25 degrees slope unless specified by local legislation (Ref: MSGAP Part 2: OP 4.4.1.3 & 4.4.1.4).

Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.4.2 Where planting on fragile and marginal soils is proposed, plans shall be developed and implemented to protect them without incurring adverse impacts (e.g. hydrological) or significantly increased risks (e.g. fire risk) in areas outside the plantation.

Minor

Findings In compliance: Yes: No:

Objective evidence:

No new planting

Criterion 7.5: No new plantings are established on local peoples’ land without their free, prior and informed

consent, dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions.

7.5.1 This activity should be integrated with SEIA required by C 7.1 Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

Criterion 7.6: Local people are compensated for any agreed land acquisitions and relinquishment of rights,

subject to their free, prior and informed consent and negotiated agreement.

7.6.1 Documented identification and assessment of legal and customary rights. Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.6.2 Establishment of a system for identifying people entitled to compensation. Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.6.3 This activity should be integrated with the SEIA required by C 7.1. Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.6.4 Establishment of a system for calculating and distributing fair compensation (monetary or otherwise).

Major

Findings In compliance: Yes: No:

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Objective evidence:

No new planting

7.6.5 The process and outcome of any compensation claims should be documented and made publicly available.

Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.6.6 Communities that have lost access and rights to land for plantation expansion are given opportunities to benefit from plantation development.

Minor

Findings In compliance: Yes: No:

Objective evidence:

No new planting

Criterion 7.7: Use of fire in the preparation of new plantings is avoided other than in specific cases as

identified in the ASEAN Guidance or other regional best practice.

7.7.1 No evidence of clearing by burning. This activity should be integrated with the SEIA required by C 7.1

Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

7.7.2 Evidence of approval for controlled burning, as per Environmental Quality (Declared Activities) (Open Burning) Order 2003.

Major

Findings In compliance: Yes: No:

Objective evidence:

No new planting

Principle 8: Commitment to Continuous Improvement in Key Areas of Activity

Criterion 8.1: Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations.

8.1.1 Minimize use of certain pesticides (C 4.6) Major

Findings In compliance: Yes: x No:

Objective evidence:

Herbicide Paraquat is no longer in use.

Monitoring of chemical used available is in place

Type 1A and 1B chemical are also monitored and used when there is an outbreak e.g. bagworms

8.1.2 Environmental impacts (C 5.1) Major

Findings In compliance: Yes: x No:

Objective evidence:

Environmental Plan for both the estates and mill arereviewed annually.

In the Pamol Mill , some actions are employed to reduce its environmental impacts such as :

Desludging of aerobic pond No. 2&3

Winnowing system installed 2012 to separate the kernel form the shell

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

Findings In compliance: Yes: x No:

Objective Pamol Mill

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evidence: Usage of ‘Geo-tubes ‘ to improve the effluent system by trapping the solids in the wastewater. This has been going on since 2010.

The solids will be made into compost for the estates.

8.1.4 Pollution prevention plans (C 5.6) Major

Findings In compliance: Yes: x No:

Objective evidence:

As above , this is documented in ther annually reviewed ‘Environmental Impact Assessment and Management Action Plans’ that provides a list of aspects and impacts, given as a list of contents, for which a response is planned.

8.1.5 Social impacts (C 6.1) Major

Findings In compliance: Yes: x No:

Objective evidence:

Management plan file (4/1/13) done yearly

a) SIA

b) EIA

c) Safety plan

d) Watermanagmemt plan

e) 5 year business plan

f) 5 year chemical,fertiliser and diesel usage

g) Continual improvement plan

Pamol Mill

Installing of lightning arrestors within the mill compound for safety purposes

New toilets installed to replace old

8.1.6 A mechanism to capture the performance and expenditure in social and environmental aspects

Minor

Findings In compliance: Yes: x No:

Objective evidence:

Meliau / Nangoh

The draft will be prepared by the estate and the employees ( during the ECC Meeting ) and discussed with the PC Mr Ashwin and after approval it will be rectified by the GM before bringing the budget to tthe Group plantation Director during the budget meeting.

Budget for social, environmental and safety and health is now available inside estates and mill accounts. For example :

a) In Meliau 2012/2013 a budget, RM28,956 has been allocated under the code GC 40 for the following programmes : waste disposal, IPM, streams, water analysis, riparian HCV, Erosion.

b) For social aspects GC 41, a budget RM18, 800 is allocated for : Linesite clearing, stakeholder meetings ( external ) .

c)

3.1.2 Supply Chain

For supply chain, the Pamol Oil Mill has decided to use Module D in this assessment. The findings

and objective evidence find during the assessment are outlined in the table below. The results for

each indicator from each of the operational areas were evaluated to provide an assessment of

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conformity. A statement is provided for each of the RSPO indicators in order to support the findings of

the assessment team.

Project Number: Part of the RSPO P&C audit. MY01827

Client:

IOI Corporation Bhd

Pamol Oil Mill

RSPO membership #

010-04(O)

Country: Malaysia

Scope:

Purchase of FFB for the production and sales of CPO and Palm Kernel using the Segregation supply chain module D option

Type of certificate: Single Mill Supply Chain Certification

Number of Sites 1

Certificate Number: N/A as this is a Palm Oil Mill certified under the RSPO P&C

Date of Issue: N/A

Date of Expiry: N/A

RSPO trademark license code:

This is the second Supply Chain assessment

Contacts Job Description: Mr Kanny @ Paul Sitip , Mill Manager

Name: Mr Kanny @ Paul Sitip

Address:

Street and number: Town/City

State/Country Zip/Postal code

Country

Physical address: Location :Pamol PL 086290119 Labuk/Sugut Sabah Pamol Mill P O Box 203, 90702 Sandakan Sabah

Postal address: As per Physical address

Tel: 089 515975/ 639/633

Cell Phone : 013 8106066

Fax: 089 515975

Web Site Address:

Email: [email protected]

Standard: RSPO Supply Chain Certification Standard dated 25 November 2011

Date of last report update 18 June 2012

Category Mill / Plantation

Approximate Number of Employees 144 ( workers and staff )

Palm Oil Product Categories Approximate Annual Purchases ( Jul 11 – Jun 12)

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Processed FFB 255,843.89 MT / yr

Sale as RSPO Certified

CPO Produced: 54, 688.67 ( opening stock at beginning of FY 4,776.135 MT )

Despatched 56,469.763 MT /yr

PK Produced : 11,668.05 ( opening stock at beginning of FY 165.601 MT )

Despatched : 11,564.02 MT /yr

Module D: Segregation

Module D.1: Documented Procedures

Criterion D.1.1: The facility shall have written procedures and/or work instructions to ensure the implementation of all the elements specified in these requirements.

D.1.1.1 Complete and up to date procedures covering the implementation of all the elements in these requirements

Findings In compliance: Yes: x No:

Objective evidence:

The facility has the StOPs that documents the procedures of the management of the oil mill operations and covering the implementation of all the elements in the supply chain requirements

D.1.1.2 The name of the person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements

Verifiers and guidance:

This person shall be able to demonstrate awareness of the facilities procedures for the implementation of this standard.

Findings In compliance: Yes: x No:

Objective evidence:

The Mill Manager , Kanny @ Paul Sitip has a Job Description that he is responsible for the CoC / traceability , safety health, social and environment documentation.

He demonstrated understanding on the requirements and implementation of the RSPO supply Chain standard.

Criterion D.1.2: The facility shall have documented procedures for receiving and processing certified and non-certified FFBs.

Findings In compliance: Yes: x No:

Objective evidence:

The POM only received FFB from their supply base estates

Module D.2: Purchasing and Goods In

Criterion D.2.1: The facility shall verify and document the volumes of certified and non-certified FFBs received.

Findings In compliance: Yes: x No:

Objective evidence:

The facility receives only from the supply base estate and the figures are documented in the a) Daily report b) Final figure for the month

Criterion D.2.2: The facility shall inform the CB immediately if there is a projected overproduction.

Findings In compliance: Yes: x No:

Objective evidence:

The facility has procedure to inform CB on overproduction.

Ref; RSPOSC/SOP/SG/3 ( 15th Sept 2012 )

In the training report file , a training was conducted by Mr Yeap Su Jin on RSPO SC Segregation and in 10.1 – 10.3 , states that in the event of overproduction, the mill is required to inform the IOI marketing Department immediately.

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The marketing dept shall inform CB of the additional amount

Module D.3: Record Keeping

Criterion D.3.1: The facility shall maintain accurate, complete, up-to-date and accessible records and reports covering all aspects of these requirements.

Findings In compliance: Yes: x No:

Objective evidence:

The facility maintain accurate , complete up to date and accessible records of all aspects of these requirements .

a) Daily Production Report

b) Monthly Summary

Criterion D.3.2: Retention times for all records and reports shall be at least five (5) years.

Findings In compliance: Yes: x No:

Objective evidence:

Records will be kept for at least 5 years

Criterion D.3.3: The facility shall record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO, PKO and palm kernel meal on a three-monthly basis.

Findings In compliance: Yes: x No:

Objective evidence:

Monthly records available and the three month basis is now available

Ref: Mass Balance calculation (internal process & output) for financial year 2011/12 available for FFB and CPO.

Records of Palm Kernel balances, despatch are also available.

Criterion D.3.4: The following trade names should be used and specified in relevant documents (e.g. purchase and sales contracts, *product name*/SG or Segregated). The supply chain model used should be clearly indicated.

Findings In compliance: Yes: x No:

Objective evidence:

Supply base estate are their own estates. The mill will receive :

a) FFB Despatch chit

b) Gate pass from Mill gate security

c) Weigh bridge ticket of the mill

Only Meliau and Nangoh has their own weighbridge.

Final figure is the Mill’s weighbridge weight

Outgoing documents specifies CPO/SG

Module D.4: Sales and Good Out

Criterion D.4.1: The facility shall ensure that all sales invoices issued for RSPO certified products delivered include the following information:

a) The name and address of the buyer

b) The date on which the invoice was issued

c) A description of the product, including the applicable supply chain model (Segregated)

d) The quantity of the products delivered

e) Reference to related transport documentation

Findings In compliance: Yes: x No:

Objective evidence:

The facility despatches the product to IOI Edible Oils Sdn Bhd , Sandakan for their sales. POM documentation will state that the product is despatched.

The Mill will prepare a delivery Order stating the following :

a) To : IOIEO S/B

b) Date: 19/12/12

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c) Product : CSPO ( stamped SG )

d) Quantity: Mill wt : 1200.067 MT, Barge wt : 1201.638

e) Barge No: Hai heng No:65

f) Contract No: 0842/1212 & 8655/1212 ( part of a larger shipment )

g) CPO Shipment Report

The shipper will prepare the following documents:

Documents available :

a) Notification from Transporter / shipment schedule

b) Bill of lading ( no SG is printed as this is a legal shipping doc which the facility is not allowed to deface ) . However SG is stamped on the attached documents

c) Dry certificate

d) Notice of vessel readiness

e) Pre-inspection advice

f) Note of protest of discrepancy of cargo figures

g) Time sheet

h) Certificate of Tankers

i) IOI CoC

j) CPO Shipping Barge and Pipeline inspection Checklist

k) Sounding Report

Module D.5: Processing

Criterion D.5.1: The facility shall assure and verify through clear procedures and record keeping that the RSPO certified palm oil is kept segregated from non-certified material including during transport and storage and be able to demonstrate that is has taken all reasonable measures to ensure that contamination is avoided. The objective is for 100% segregated material to be reached. The systems should guarantee the minimum standard of 95% segregated physical material; up to 5% contamination is allowed.

Findings In compliance: Yes: x No:

Objective evidence:

The POM only receives SG material from their own supply base estate

Criterion D.5.2: The facility shall provide documented proof that the RSPO certified palm oil can be traced back to only certified segregated material.

Findings In compliance: Yes: x No:

Objective evidence:

The POM only receives SG material from their own supply base estate

Criterion D.5.3: In cases where a mill outsource activities to an independent palm kernel crush, the crush still falls under the responsibility of the mill and does not need to separately certified. The mill has to ensure that:

a) The crush operator conforms to these requirements for segregation

b) The crush is covered through a signed and enforceable agreement

Findings In compliance: Yes: x No:

Objective evidence:

No outsourcing except transport

Module D.6: Training

Criterion D.6.1: The facility shall provide the training for all the staff as required to implement the requirements of the Supply Chain Certification System.

Findings In compliance: Yes: x No:

Objective Supply chain training conducted

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evidence: a) 3/12/12 Training RSPO supply chain /CPO Mills : Segregation

b) 15/12/12 Training Air lock, emergency spill kit& oil trap

Module D.7: Claims

Criterion D.7.1: The facility shall only make claims regarding the use of or support of RSPO certified palm oil that are in compliance with the RSPO Rules for Communication and Claims.

Findings In compliance: Yes: x No:

Objective evidence:

No claims made by the Palm Oil mill facility

3.2 Corrective Action Request

There are total of 1 Major and 2 Minor were raised. Please refer to the Appendix A for the

details findings and relevant correction actions have been taken.

The Major non-conformance was closed after the Unit submitted evidence within 60 days to

show compliance to the requirement.

3.3 Noteworthy Positive & Negative Observation

5 new Observations were raised

3.4 Status of Non-Conformities Previously Identified

Please refer to Appendix B for the previous audit.

One of the Minor raised in the previous identified was closed and another maintained (Minor

CAR 31 ) .

The 3 Observations previously identified were closed

3.5 Issues Raised by Stakeholders and Findings

No stakeholder issues raised

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4. ACKNOWLEDGEMENT OF ORGANIZATION INTERNAL RESPONSIBILITY

4.1 Date of Next Surveillance Visit

The next surveillance audit is planned before on 17/1/14

4.2 Date of Closing Non-Conformities

Reference Class Issued Close

4.3 Acknowledgement of Internal Responsibility and Formal Sign-off Assessment Findings

SGS Malaysia acknowledges and confirms acceptance of the Report contents and including

the assessment findings. SGS Malaysia accepts the responsibility for addressing the

opportunities of improvement detailed in this report.

Signed on behalf of IOI Corporation Bhd Signed on behalf of SGS Malaysia Sdn Bhd

Mr. Too Heng Liew Head of Sustainability

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(Malaysia/Indonesia)

APPENDIX A: CORRECTIVE ACTION REQUEST & OBSERVATION

CAR #

Indicator CAR Detail

M32 4.4.1 Date

Recorded> 16-17/1/13

Due

Date> 16-17/3/13

Date

Closed> 24/1/13

Non-Conformance:

The protection of water courses and wetlands, including maintaining and restoring appropriate

riparian buffer zones at or before replanting along all natural waterways within the estate was not

implemented

Objective Evidence:

Although there is a commitment to protect water courses and wetlands especially the natural waterways are included in the Environmental Management Plan as well as in the StOP, however in the following it was shown that protection of watercourses was not maintain.

In Bayok field 09B the Buffer zone that was not marked was sprayed. Similarly in

Meliau, along the Sungai Paliau riparian reserve it was shown that worker has intruded and actively practicing farming.

Major 32

Close-out evidence:

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CAR #

Indicator CAR Detail

On 24/1/13 , Pamol submitted pictorial evidence to show that they fenced the area

using barbed wire and erected a signboard to warn workers not to disturb the riparian

zone. A warning letter was issued to the worker as well as a training for workers of

Meliau Estate concerning the maintenance of the riparian buffer zone along the Sungai

Paliau.

Their internal investigations have shown that the 2 workers responsible for clearing the

riparian have both been given warning letters. The plants that they planted were also

cut down to discourage further encroachment as well as to allow faster regeneration.

New signboards and riparian markers installed with barbed wire. Training also given for

workers.

Similarly , in Nangoh and Bayok, training was provided on 24/1/13 to the mandores of

the weeding, harvesting and spraying gang to remind them on the maintenance and

the importance of the riparian buffer zone

Major 32 Closed

033 4.5.4 Date

Recorded> 17/1/13

Due

Date> 17/1/14

Date

Closed>

Non-Conformance:

Monitoring of pesticide usage units per hectare or per ton crop e.g. total quantity of active

ingredients (a.i) used/tone of oil was incomplete

Objective Evidence:

Ref : RSPO Priciples E.4- Use of appropriate best practices by Growers and Mills .

In Meliau, the usage of methamidophos during the FY 12/13 not captured in the Pesticide monitoring file.

Minor 33

Close-out evidence:

CAR Detail

034 5.3.2 Date

Recorded> 16-17/1/13

Due

Date> 16-17/1/14

Date

Closed>

Non-Conformance:

Although having identified wastes and pollutants, an operational plan was developed however

implementation to avoid or reduce pollution was still lacking in some sites

Objective Evidence:

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CAR #

Indicator CAR Detail

Operational plan has been developed for each of the identified pollutants.

Visits to the storage area and documented evidence that records are kept.

In Nangoh , records of chemical container disposal are kept in the Triple Rinsing file

Date: 22 Nov 2012

The HSE manager , Mr Jimi Dalinting issued a ‘triple rinse certificate’ to indicate 10 ‘bm Glyphosate’ containers and 340 ‘bm Cergas’ containers were triple rinsed.

On 22/11/12 , 150 kg ( as above ) was collected by Newgates Industries (Borneo) Sdn Bhd , the licensed disposal operator.

However, some non-compliance to this indicator were still found :

Bayok /Meliau Estate – Recycle bins were used as domestic waste disposal bins

Bayok Estate – fluorescent lighting tube found indiscrimately thrown on the garden patch at the staff quarters

Palm Oil Mill – fluorescent tube and bulbs were found at the scrap /rubbish site when it should be in the Scheduled Waste store

Meliau Estate – reuse of chemical container as water container in the worker chicken coop

Meliau Estate - metal drum clamps thrown over the fence into the chicken coop site

Minor CAR 34 -Raised

Close-out evidence:

Minor Car 031

5.5.3 Date

Recorded> 17/1/13

Due

Date> 17/1/14

Date

Closed>

Non-Conformance:

There was evidence of burning waste (including domestic waste)

Objective Evidence:

Meilau and Nangoh , open burning of waste ( include plastics ) seen in front of the workers quarters near the deer farm

Minor 31 Maintained

Close-out evidence:

OBSERVATIONS

OBS # Indicator Observation Detail

19 1.1.1 Date

Recorded> 16/1/13

Due

Date>

Date

Closed>

Non-Conformance:

Records of requests and responses were not maintained.

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OBS # Indicator Observation Detail

Objective Evidence:

The Website http://www.ioigroup.com/business/busi_plantoverview.cfm

provides information on their plantation responsibilities, corporate social responsibilities and commitment to sustainability compliance.

En Abdul Rahman Zainal , Asst manager is responsible for social, environment liaison officer as well as the safety coordinator

In Bayok Estate, records of request and responses are kept in the ‘Request Bayok’ that records the request of stakeholders internal or external.

However it was noted that in Bayok Estate the villagers list was not updated in the Dec 2012 list of stakeholders.

Observation 19 - Raised

Close-out evidence:

20 4.6.1 Date

Recorded> 16/1/13

Due

Date>

Date

Closed>

Non-Conformance:

Written justification in Standard Operating Procedures (SOP) of some of the agrochemical used

was lacking

Objective Evidence:

Although Bayok Estate has the written justification of most of the products frequently used , however justification of use for some products still available at the store like Pursuit, Topsin and Anvil , no written justification use was available

Observation 20 – Raised

Close-out evidence:

21 4.6.3 Date

Recorded> 16/1/13

Due

Date>

Date

Closed>

Non-Conformance:

Although pesticides were stored in accordance to the Occupational Safety and Health Act 1994

(Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations

however the implementation of triple rinsing was not implemented well

Objective Evidence:

Pesticide were stored in accordance to appropriate storage guidelines with proper structure , roofing , flooring and roofing.

However in Bayok and Ulu, some of the the triple rinsed Kencis tins were not properly rinsed as the chemical were still found in the tins. In addition it was kept in the open resulting in rust and rainwater in the tins.

Observation 21- Raised

Close-out evidence:

Observation Detail

22 4.6.4 Date

Recorded> 16/1/13

Due

Date>

Date

Closed>

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OBS # Indicator Observation Detail

Non-Conformance:

Some information regarding the chemicals and its usage, hazards, trade and generic names

must be available in language understood by workers or explained carefully to them by a

plantation management official at operating unit level were missing

Objective Evidence:

Although most of the information regarding the chemicals and its usage, hazards, trade and

generic names are available in language understood by workers or explained carefully to them by a plantation management official at operating unit level, nevertheless in Bayok Estate :

a) MSDS for Pursuit missing b) MSDS a.i for Anvil was wrong c) MSDS for the correct generic brand of glyphosate missing

Similarly at the Mill – MSDS for lubricant s found in the store was to be incomplete

Observation 22- Raised

Close-out evidence:

23 4.7.1 Date

Recorded> 16-17/1/13

Due

Date>

Date

Closed>

Non-Conformance:

Some aspects of the implementation of the Occupational Safety Health (OSH) plan which is in

compliance with OSH Act 1994 and Factory and Machinery Act 1967 (Act 139) was lacking

Objective Evidence:

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OBS # Indicator Observation Detail

In Meliau / Nangoh Estate, evidence of documented Occupational Safety Health (OSH) plan

which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967 (Act 139) are available such as :

i) Documented policy : Policy on Safety , Health & Staff Welfare (Polisi Keselamatan dan Kesihatan Pekerja ) ( 2008 ) is posted on the notice board.

j) In Meliau/Nangoh with reference to the Management file - Safety and risk assessment section. Risk assessed in early 2012 : identification of the risk, analysis of the risk, and the control/ risk control Occupational Safety & Health Risk Assessment

k) Conducted by Jimi Dalinting, the appointed Safety and Health Manager for this Pamol Unit

l) Training Ref : Safety and Health Training Programme File. Training Records: Safety training Programme 2012 and 2013.

E.g. On 8 Jan 2013 a safety training was conducted for Manual application of fertiliser by Mr Rayjack Modi Field Supervisor, Meliau.

On 23rd

Dec 2012 , a training was done on First aid conducted by Fatimah Hj Tasman, Health Assistant .

MSDS on 10/12/12

m) PPE – Issuance and replacement records available : PPE Stock Record and Replacement. Appropriate PPE were used by harvester Aidil Abdul in Nangoh and loose fruit collector Matilda, Marlin etc . From PPE records, in December 2012, 10 white helmets were issued to new workers.

n) Records of meeting : Ref Committee chart /appointment letter /Committee meeting Minutes file. Based on their records their quarterly meeting were conducted on 25

th Oct 2012, 20 July 2012, 25 Apr 2012, 26 Jan 2012.

o) The meetings were attended by the manager, representatives of the staff and workers.

p) ERP for accident, chemical spillage, fire were posted at the chemical store.

However even though the OSH is documented yet the following are lapses found in the implementation:

In Bayok, cigarette butts found at the Diesel skid tanks where a ‘ No smoking sign ‘ was posted.

In the mill workshop , the First Aid Kit was missing.

Observation 23 – Raised

Close-out evidence:

Date

Recorded>

Due

Date>

Date

Closed>

Non-Conformance:

Objective Evidence:

Close-out evidence:

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GP 7003A Page 54 of 58

APPENDIX B: NON-CONFORMITIES PREVIOUSLY IDENTIFIED

30 5.3.2 Date Recorded>

22 Feb 2012

Due Date>

Surv 04 Date

Closed> 16/1/13

Non-Conformance:

Having identified wastes and pollutants, the facilities with an operational plan should have developed and implemented equipment to monitor and to avoid or reduce pollution

Objective Evidence:

a) Empty chemical containers found at linesite

b) Discriminate disposal of PPE eg boots, helmet found at line site

c) Old, rusty, broken tractor equipment , barbed wires etc found ‘dumped’ in an open area opposite line site and easily accessed by workers and children

( Minor CAR 30 - Raised)

Close-out evidence:

a) The empty chemical containers have been removed. Estates have also tightened up the work process whereby all empty chemical containers are triple rinsed and punctured immediately to prevent people from re-using them. Punctured containers are also stored in purpose built locked stores and disposed off through a licensed contractor.

b) The PPE have been removed. The estates have also made it mandatory for all used PPE be returned prior to replacement in an effort to eliminate indiscriminate disposal of PPE. Used PPE is treated as SW and is handled accordingly.

c) The old parts have been sold as scrap metal whilst the remaining parts in the area have been tidied and the area is now fenced and locked.

Minor CAR 30 closed

31 5.3.3 Date Recorded>

22 Feb 2012

Due Date>

Surv 04 Date

Closed> Maintained

Non-Conformance:

Evidence of burning waste (including domestic waste).

Objective Evidence:

Open burning of domestic waste ( plastic , wood etc ) at line site

(Minor CAR 31- Raised)

Close-out evidence:

Minor CAR 31 is maintained as there is burning of domestic waste in another site found during the audit . Please see above Appendix A.

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OBSERVATIONS

016 4.6.6 Date Recorded>

22 Feb 2012

Due Date>

Date

Closed> 16/1/13

Non-Conformance:

No work with pesticides for confirmed pregnant and breast-feeding women.

Objective Evidence:

A female worker , Hadesiah Tahang was recorded in the Medical Record Book 19/7/2011 to be MRP ( medically reported pregnant ) (pregnant 2 months ) but was shown to be still spraying in Sept 2011.The pregnancy test results from Dr Edmond Fernandez came back in Oct. 2011.

By that time the worker has gone back to Indonesia.

(Observation 16 - Raised)

Close-out evidence:

Workers whom handle chemicals are required to go for medical check-ups where they would also be checked for pregnancy. If found to be pregnant, the clinic is required to inform the estate immediately so that the worker can be assigned a different job that does not involve handling chemicals.

To prevent the workers from handling chemicals whilst they are breastfeeding, workers are not allowed to handle chemicals for 6 months after giving birth and they are required to sign a declaration that they are no longer breastfeeding before they can return to doing jobs that involve chemical handling.

(Observation 16 closed)

017 4.7.1 Date Recorded>

22 Feb 2012

Due Date>

Date

Closed> 16/1/13

Non-Conformance:

Evidence of documented Occupational Safety Health (OSH) plan which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967(Act 139).

c) An awareness and training programme on safety and health was lacking

Objective Evidence:

a) Use of chemical container for cooking ingredients at line site

b) Mosquitoes larva found in used tyre at 2 line sites

( Observation 17 - Raised)

Close-out evidence:

a) The chemical containers have been removed. The workers have also been reminded of the hazards related to chemicals and empty containers. They have also been reminded not to re-use empty chemical containers especially for storing food.

b) The tyres have been removed. Used tyres are stored covered until disposal or reuse as culverts, flower pots, etc.

Observation 17 closed

018 4.8.1 Date Recorded>

22 Feb 2012

Due Date>

Date

Closed> 16/1/13

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Non-Conformance:

No training was conducted for the Estate Hospital Assistant on the chemicals used and related laws.

Objective Evidence:

Estate Hospital Assistant was not trained in Chemical usage as required

( Observation 18 – Raised)

Close-out evidence:

A training course involving government departments such as the Department of Occupational Safety and Health, Health Department and the local hospital was organized by Safety & Health Manager to conduct a training session on chemical usage and safety in Pamol. The training included not only the estate HAs but also the management and workers as well.

Observation 18 closed

Page 57: RSPO PRINCIPLES & CRITERIA CERTIFICATION REPORT …...Pamol Oil Mill Management Unit (POM-PMU is located in Labuk-Sugut (also known as Beluran district) District in Sandakan division,

SGS RSPO

(Principles & Criteria)

Doc. Number: GP 7003A

Doc. Version date: 01 April 2013

Page: 57 of 58

SGS RSPO, SGS (Malaysia) Sdn. Bhd., No. 26, Jalan Anggerik Vanilla, 31/93, Kota Kemuning, 40460 Shah Alam, Malaysia

CONTACT PERSON: ABDUL HAYE SEMAIL Tel: +6 (03)5121 2320 - Fax: +6 (03)5122 5927 WWW.SGS.COM

APPENDIX C: TIMEBOUND PLAN

Time Bound plan

NEW SCHEDULE OF RSPO CERTIFICATION IN IOI ESTATES (SABAH AND PENINSULAR MALAYSIA) AS AT August 2011

Jan’08 Feb’08 Mar’08 Apr’08 May’08 Jun’08 Jul’08 Aug’08 Sep’08 Oct’08 Nov’08 Dec’08

Pamol Sabah Oil Mill (Covering 6 Estates) *

Sakilan Oil Mill (Covering 3 Estate) *

Jan’09 Feb’09 Mar’09 Apr’09 May’09 Jun’09 Jul’09 Aug’09 Sep’09 Oct’09 Nov’09 Dec’09

Pamol Kluang Oil Mill (Covering 6 Estates) *

Gomali Oil Mill (Covering 11 Estates) *

Baturong Oil Mill (Covering 4 Estates) *

Jan’10 Feb’10 Mar’10 Apr’10 May’10 Jun’10 Jul’10 Aug’10 Sep’10 Oct’10 Nov’10 Dec’10

Bukit Lee Lau Oil Mill (Covering 6 Estates) *

Mayvin Oil Mill (Covering 5 Estates) *

Pukin Oil Mill (Covering 4 Estates) *

Jan’11 Feb’11 Mar’11 Apr’11 May’11 Jun’11 Jul’11 Aug’11 Sep’11 Oct’11 Nov’11 Dec’11

Jan’12 Feb’12 Mar’12 Apr’12 May’12 Jun’12 Jul’12 Aug’12 Sep’12 Oct’12 Nov’12 Dec’12

Syarimo Oil Mill (Covering 9 Estates) ***

Ladang Sabah Oil Mill (Covering 8 Estates) ***

Morisem Oil Mill (Covering 9 Estates) ***

Leepang Oil Mill (Covering 7 Estates) ***

__ IOI Corp. Bhd. Membership on RSPO being suspended

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* Certified Oil Mill

** Completed the Audit

*** In Preparation

APPENDIX D: LIST OF STAKEHOLDERS CONTACTED

This is a surveillance audit

APPENDIX E: Replanting Programme

Replanting (Ha)

Ulu Bayok Rungus Tindakon Nangoh Meliau

2012/2013 0 275 0 224 0 0

2013/2014 194 0 256 285 129 172

2014/2015 263 0 0 264 220 183

2015/2016 0 0 0 0 199 189

2016/2017 0 0 0 0 296 231