Kuala Lumpur Kepong Bhd

1. Sustainable palm oil policy or commitment for all its operations?

The company meets this indicator through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own sustainability policy.

2. Sustainable palm oil policy or commitment applies to all suppliers?

The company has published a Supplier Code of Conduct which applies to all suppliers, it is more limited ins cope than the Sustainability Policy.

3. High-level position of responsibility for sustainability?

The company's sustainability steering committee is chaired by the CEO and includes senior management representatives from the plantation, manufacturing, property, sustainability, and legal & company secretary departments. However, the high-level responsibility for sustainability is with the CEO who is a board member.

4. One or more members within the board of the company have responsibility for sustainability?

The company reports that CEO leads the sustainability steering committee.

5. Percentage or number of women in senior management team?

2 (33.33%) - The company reports that it has two women in the senior management team. However, the gender balance is not directly reported but calculated from profile photos.

6. Percentage or number of women board members?

2 (22%) - The company reports that it has two (22%) women as board members.

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with palm oil production?

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with palm oil production?

The company reports that it has initiated a 'Konservasi Hutan Desa (KONTANDES)' project in collaboration with Aksenta, Belantara, and Lembaga Pengelolaan Hutan Desa (LPHD) which aims to maintain high-quality forest and biodiversity and promotes community welfare through sustainable practices. It also partners with SMK Kampung Pasir Putih and SMK Dato' Haji Mohd Taib in Ipoh to set up hydroponic farming facilities to educate children about responsible agriculture.

9. Sustainability report published within last two years?

The company published its latest sustainability report for 2022.

10. Reports through standardised reporting systems?

The company states that its sustainability report 2022 is prepared in accordance with the Global Reporting Initiative (GRI) Standards - Core Option.

11. Verification report on compliance with POIG Charter, if a POIG member?

This indicator is disabled as the company is not a POIG member.

12. Climate risks assessment available?

13. Lists countries and operations?

Plantations, Mills, Refineries and Crushers - Malaysia (Johor, Kedah, Kelantan, Negeri Sembilan, Pahang, Perak, Sabah, Selangor), Indonesia (Bangka Belitung, Central Kalimantan, East Kalimantan, Lampung, North Kalimantan, North Sumatra, Riau, and South Sumatra) and Liberia.

14. Lists countries sourcing from?

The company provides maps of its mills and processing facilities and their supplier lists which are located in Indonesia, Malaysia, and Liberia.

15. Total land area managed/controlled for oil palm (ha)?

355485 - The company reports the total landbank controlled for palm oil as 355,485 ha in its annual report 2022. The RSPO ACOP 2022 states 358,845 ha as the total landbank controlled for palm oil.

16. Total oil palm planted area (ha)?

289650 - The company reports its total oil palm planted area as 289,650 ha in its RSPO ACOP 2022.

17. Scheme smallholders planted area (ha)?

22094 - The company reports total land under scheme smallholders in its RSPO ACOP 2022 as 22,094 ha.

18. Unplanted (areas designated for future planting) (ha)?

8540 - The company reports a total unplanted area in its RSPO ACOP 2022 as 8,540 ha.

19. Conservation set-aside area, including HCV area (ha)?

22963 - The company reports 14,809 ha of HCV areas and 8,154 ha of other conservation areas excluding HCV areas.

20. Maps of estates/management units?

The company reports that its concession boundaries have been made available to the RSPO in 2022.

21. Maps of all scheme smallholders?

22. Maps of all third-party supplying plantations?

The company has published coordinates of supply bases of all suppliers on its traceability webpage, but no maps or estate boundaries are visible.

23. Number of company-owned mills?

32 - The company reports that it has 32 palm oil mills in its annual report 2022. The RSPO ACOP 2022 states that the company has 33 palm oil mills, however it is managing one mill for its largest stakeholder, Batu Kawan Berhad.

24. Names and locations of company-owned mills?

The names and locations of all company-owned mills are available on the company website. The names and locations of some mills are also available on the GFW database.

25. Number (or percentage) of company-owned mills that source from company-owned operations and third parties?

The company has disclosed the supply bases for all its 32 mills separately.

26. Reports total volumes (or percentages) sourced by company-owned mills that come from company-owned operations and third-parties?

The company has disclosed the percentage break-up of the sources of FFB supply for each all its 32 mills. No overall percentages are provided and cannot be calculated.

27. Number of third party supplying mills?

864 - The company reports that it has 864 third-party supplying mills.

28. Names and locations of all third-party supplying mills?

The company publishes the names and coordinates of all third-party supplying mills.

29. Number (or percentage) of third party supplying mills that source from their own plantations and third party plantations?

30. Reports total volume (or percentages) sourced from third-party supplying mills that come from the supplying mills' own operations and third parties?

31. Total volume (or percentage) sourced for refineries that comes from intermediary traders and/or refiners rather than directly from mills?

The company reports a percentage figure for each refinery that comes from intermediary traders and refiners rather than directly from mills. However, no total figure is provided and cannot be calculated. This information is from 2018.

32. Time-bound commitment to achieve 100% traceability to mill level?

The company has already achieved 100% traceability to mill level.

33. Percentage of supply traceable to mill level?

The company reports that 100% of the supply is traceable to the mill level. Additional points are awarded based on SCC IP and SG certifications.

34. Time-bound commitment to achieve 100% traceability to plantation level?

The company has already achieved 100% traceability to plantation level for mills but does not report a time-bound target for crushers and refineries.

35. Percentage of fresh fruit bunches (FFB) supply to own mills traceable to plantation level?

The company reports that it has already achieved 100% traceability to the plantation level. Additional points are awarded as four of the company's mills have Identity Preserved certification.

36. Percentage of supply from third-party mills traceable to plantation level?

Additional points are awarded as the company has IP certification.

37. Publishes traceability data at refinery level?

The company publishes traceability data for all three of its refineries.

38. Publishes traceability data at crusher level?

The company publishes traceability data for all five of its crushers.

39. Member of the Roundtable on Sustainable Palm Oil (RSPO)?

[Externally verified] 2004 - The company has been a member of the Roundtable on Sustainable Palm Oil (RSPO) since 2004.

40. RSPO-certified within three years of joining the RSPO or by November 2010, for companies joining prior to finalisation of the RSPO certification systems in November 2007?

[Externally verified] 2009 - The company achieved its first RSPO certification in 2009.

41. Submitted most recent RSPO Annual Communication of Progress (ACOP)?

The company has submitted its latest RSPO ACOP 2022.

42. Percentage of area (ha) RSPO-certified?

78.34% - The company reports that it has 69% RSPO-certified areas in its annual report 2022. However, the RSPO ACOP 2022 states that the company has 78.34% RSPO-certified areas.

43. Percentage of mills RSPO-certified?

78.78% - The company reports that it has 75% RSPO-certified mills in its annual report 2022. However, the RSPO ACOP 2022 states that the company has 78.78% RSPO-certified mills.

44. Time-bound plan for achieving 100% RSPO certification of estates and mills within 5 years?

2025 - The company commits to achieve 100% RSPO certification of estates and mills by 2025. This is within 5 years.

45. Time-bound plan for achieving 100% RSPO certification of all palm product processing facilities within 5 years?

2018 - The company has already achieved 100% RSPO-certification of all palm product processing facilities.

46. Percentage of scheme smallholders (ha) RSPO-certified?

0% - The company reports the total percentage of scheme/plasma smallholders (ha) RSPO-certified in its RSPO ACOP 2022.

47. Time-bound plan for achieving 100% RSPO certification of scheme/associated smallholders and outgrowers within 5 years or target already achieved?

2028 - The company commits to achieve 100% RSPO certification of scheme/associated smallholders and outgrowers by 2028. Target is in five years.

48. Percentage of FFB supply (tonnes) from independent smallholders/outgrowers/third-party FFB suppliers that is RSPO-certified?

19.85% - The company reports the percentage of FFB supply (tonnes) from independent smallholders/outgrowers/third-party FFB suppliers that is RSPO-certified in its RSPO ACOP 2022.

49. Percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that is RSPO-certified?

22.59% - The RSPO ACOP 2022 states that 22.59% of all palm oil and oil palm products handled/traded/processed are RSPO-certified.

50. Sells RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

The company reports that 48.22% of RSPO-certified palm oil sells through segregated or identity-preserved supply chains.

51. Processes/trades RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

The company reports that 2.60% of RSPO-certified palm oil processes/trades through segregated or identity preserved supply chains.

52. Indonesia Sustainable Palm Oil (ISPO) certified (100%)?

The company reports that 83% of its estates and 88% of its palm oil mills are ISPO certified.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company reports that 100% of its estates and palm oil mills are MSPO certified and the certificates of all these estates and mills are available on the MSPO website.

54. Certified under voluntary sustainability certification scheme (e.g. ISCC, SAS, RSB)?

[Externally verified] The company is certified under ISCC.

55. Commitment to zero conversion of natural ecosystems?

56. Commitment to zero conversion of natural ecosystems applies to all suppliers?

57. Commitment to zero deforestation?

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to no deforestation in its own reporting.

58. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to no development of HCV, HCS, or peatland areas. This commitment has been in place since 2019.

59. Criteria and cut-off date for defining deforestation?

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

60. Criteria and cut-off date for defining deforestation in supplier operations?

The company has only specified the criteria of forests that are not to be deforested in supplier operations. However, no cut-off date was specified.

61. Evidence of monitoring deforestation and/or ecosystem conversion?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

62. Evidence of monitoring deforestation and/or ecosystem conversion in supplier operations?

The company reports that it has collaborated with Earthqualizer to monitor deforestation in supplier operations through satellite monitoring. It receives bi-weekly supplier monitoring reports that help the company to take proactive action by engaging with its suppliers. However, it does not report the extent of the area monitored.

63. Amount of deforestation and/or ecosystem conversion recorded in own operations since cut-off date?

0 - The company reports that no illegal or non-compliant deforestation has been recorded as of August 2020, it is unclear if this since the cut-off date. Information is between two and five years old.

64. Amount of deforestation and/or ecosystem conversion recorded in supplier operations since cut-off date?

65. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

The company commits to restore ecosystems to their prior condition in cases of conversion within its own operations. This commitment has been in place since 2018.

66. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

The company commits suppliers to restore ecosystems to their prior condition in cases of conversion within their own operations. No cut-off date is provided.

67. Implementing a landscape or jurisdictional level approach?

The company reports that it has a collaborative 'Forest and Biodiversity Conservation Project' in the Berau Regency (East Kalimantan) of Indonesia in collaboration with the Aksenta, Belantara, and Lembaga Pengelolaan Hutan Desa (LPHD) which aims to maintain a high-quality forest and biodiversity and promotes community welfare through sustainable practices.

68. Biodiversity policy?

The company has a biodiversity conservation policy, but it does not have time-bound targets and does not clearly apply both within and beyond HCV/HCS/set-asides.

69. Biodiversity policy applies to all suppliers?

70. Identified species of conservation concern, referencing international or national system of species classification?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company has also identified several species of conservation concern according to the IUCN Red List.

71. Examples of species and/or habitat conservation management?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it works closely with non-governmental organisations and the State Wildlife Agency for rare and endangered species found within the HCV sites. The habitats of species are conserved and appropriate management and monitoring plans are implemented. Additionally, the company has also started a community patrolling project to raise awareness for the plight of the Malayan tiger and its habitat.

72. Commitment to no hunting or only sustainable hunting of species?

The company commits to prohibit wildlife hunting, but only in HCV set-aside areas.

73. Commitment to no hunting or only sustainable hunting of species applies to all suppliers?

74. Commitment to conduct High Conservation Value (HCV) assessments?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to conduct HCV assessments in its own reporting.

75. Commitment to conduct High Conservation Value (HCV) assessments applies to all suppliers?

The company commits all suppliers to conduct HCV assessments.

76. High Conservation Value (HCV) assessments for planting undertaken prior to January 2015, and associated management and monitoring plans?

[Externally verified] The High Conservation Value (HCV) assessments for planting undertaken prior to January 2015, and associated management and monitoring plans are available for PT Anugrah Surya Mandiri and PT Tekukur Indah on the RSPO NPP Website.

77. High Conservation Value (HCV) assessments for all estates planted/planned planting since January 2015?

[Externally verified] The HCV assessments of PT Karya Makmur Abadi and Kuala Gris and Kemasul Estate are available on both the HCVRN website and the RSPO NPP. Further, the HCV assessments of PT Jabontara Eka Karsa - Koperasi Harapan Bersama is available on the HCVRN website while the HCV assessment of PT Putra Bongan Jaya is available only on the RSPO NPP but associated HCV assessment documents are not publicly available.

78. High Conservation Value (HCV) or combined HCV/HCS management and monitoring plans for all estates planted/planned planting since January 2015?

[Externally verified] The HCV assessments of PT Karya Makmur Abadi and Kuala Gris and Kemasul Estate are available on both the HCVRN website and the RSPO NPP. Further, the HCV assessments of PT Jabontara Eka Karsa - Koperasi Harapan Bersama is available on the HCVRN website while the HCV assessment of PT Putra Bongan Jaya is available only on the RSPO NPP but associated HCV assessment documents are not publicly available.

79. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS)?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

80. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS) applies to all suppliers?

81. Satisfactory review of all High Conservation Value (HCV) assessments undertaken since January 2015 by the HCV ALS Quality Panel?

[Externally verified] The HCV assessments of PT Karya Makmur Abadi, PT Putra Bongan, PT Jabontara Eka Karsa - Koperasi Harapan Bersama and Kuala Gris Estate, and Kemasul Estate are available on the HCVRN website and are reviewed as satisfactory.

82. Commitment to the High Carbon Stock (HCS) Approach?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to apply the HCS Approach in its own reporting.

83. Commitment to the High Carbon Stock (HCS) Approach applies to all suppliers?

The company commits all suppliers to apply the HCS Approach, as defined by the HCS Approach Toolkit.

84. High Carbon Stock (HCS) assessments available?

[Externally verified] The High Carbon Stock (HCS) assessments for all the company's concessions including, PT Menteng Jaya Sawit, PT Putra Bongan Jaya, PT Steelindo Wahana Perkasa, PT Karya Makmur Abadi, PT Karya Makmur Abadi (Plasma), PT Tekukur Indah and Palm Bay Estate Phase 1 New Planting Area (LIBINCO) are available on the HCSA website.

85. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

[Externally verified] All of the company's concession standalone HCS assessments since April 2015 have peer review reports published on the HCSA website.

86. Commitment to conduct social and environmental impact assessments (SEIAs)?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

87. Commitment to conduct social and environmental impact assessments (SEIAs) applies to all suppliers?

88. Social and environmental impact assessments (SEIAs) available, and associated management and monitoring plans?

[Externally verified] The social and environmental impact assessments (SEIAs) for Kuala Gris and Kemasul Estate, PT Anugrah Surya Mandiri, and PT Tekukur Indah are publicly available on the RSPO website.

89. Commitment to no planting on peat of any depth?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to no planting of peat of any depth in its own reporting.

90. Commitment to no planting on peat of any depth applies to all suppliers?

The company commits all suppliers to no planting on peat of any depth.

91. Landbank or planted area on peat (ha)?

92. Implementation of commitment to no planting on peat of any depth?

93. Commitment to best management practices for soils and peat?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to good agriculture practices for peatland in its own reporting.

94. Commitment to best management practices for soils and peat applies to all suppliers?

The company only commits to best management practices for peat, this applies to all suppliers.

95. Evidence of best management practices for soils and peat?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports its own progress in applying management practices to conserve soils and peat which includes empty fruit bunches and oil palm trunks and fronds being mulched, composted, and recycled as organic materials to maintain soil properties at an optimum level.

96. Commitment to zero burning?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to no burning in its own reporting.

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

98. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it conducts fire awareness training covering the correct alarming procedure and first responder training using different types of fire extinguishers and other methods to prevent fire from spreading. Additionally, the company has established fully equipped firefighting teams that undergo yearly firefighting training and practices strict surveillance which includes erecting reservoirs and fire towers at strategic locations and daily web-monitoring of fire hotspots within and surrounding the estates. Further, the emergency response teams are properly trained to contain and control leakages or fires in the processing plants.

99. Details/number of hotspots/fires in company estates?

The company reports that it detected nine hotspots within its concessions in Indonesia in 2021, but all were categorised as false detection.

100. Details/number of hotspots/fires within surrounding landscape/smallholders?

The company only states that "the prolonged extremely dry spell experienced in Sumatra and Central Kalimantan during the fourth quarter of the FY led to several minor fire incidents inside and outside our concessions." However, the information is between two to five years old.

101. Time-bound commitment to reduce greenhouse gas (GHG) emissions intensity?

The company commits to reducing its GHG emissions intensity by 69% by the year 2022. However, it does not include scope 1 and 2 emissions.

102. GHG emissions intensity?

The company reports its GHG emission intensity as 0.23 (mt CO2 eq/mt prod vol) in 2022. However, it does not include scope 1 and 2 emissions.

103. GHG emissions from land use change in company's own operations (scope 1)?

104. GHG emissions from land use change in supplier operations (scope 3)?

105. Progress towards commitment to reduce GHG emissions intensity?

The company reports a reduction in its GHG emissions intensity from 0.26 mt CO2 eq/mt prod vol (2021) to 0.23 mt CO2 eq/mt prod vol (2022). However, it does not include scope 1 and 2 emissions.

106. Methodology used to calculate GHG emissions?

The RSPO requires companies to assess their GHG emissions through the Palm GHG calculator. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

107. Percentage of mills with methane capture (100%)?

The company reports that eight out of 32 (25%) company-owned mills have methane capture.

108. Time-bound commitment to improve water use intensity?

109. Water use intensity?

1.3 - The company reports its water consumption intensity as 1.30 (m3/mt prod vol) in 2022.

110. Progress towards commitment on water use intensity?

The company reports water consumption intensity as 1.30 m3/mt prod vol (2022) and 1.30 m3/mt prod vol (2021). The figures water use intensity over time but intensity not improving.

111. Time-bound commitment to improve water quality (BOD and COD)?

The company commits to maintain BOD and COD levels within legal limits.

112. Progress towards commitment on water quality (BOD and COD)?

[Externally verified] The company's BOD and COD figures can be found in RSPO audit reports for certified mills. However, not all mills are certified, and data is not available for successive years.

113. Treatment of palm oil mill effluent (POME)?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it monitors palm oil mill effluent to ensure that it complies with the legal limits for BOD.

114. Treatment of palm oil refinery effluent (PORE)?

115. Commitment to protect natural waterways through buffer zones?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to protect natural waterways through buffer zones in its own reporting.

116. Implementation of commitment to protect natural waterways through buffer zones?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it has collaborated on a habitat restoration project for wildlife. It focuses on restoring the grazing pastures for elephants and the tembadau or borneon banteng, a species of cattle found in Southeast Asia, and also the riparian and buffer zones.

117. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates this in its own reporting.

118. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers, applies to all suppliers?

119. Commitment to no use of paraquat?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates this in its own reporting.

120. Commitment to no use of paraquat applies to all suppliers?

121. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates this in its own reporting.

122. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers?

123. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates this in its own reporting.

124. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers?

125. Chemical usage per ha or list of chemicals used?

The company reports that the average fertiliser consumption for Malaysia, Indonesia and Liberia is 1.1 mt/ha and the average herbicide consumption for plantation operations is 2.35 litre/ha since 2017.

126. Implementation of commitment to minimise inorganic fertiliser use?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports a decrease in average fertiliser consumption from 1.28 mt/ha in 2021 to 1.1 mt/ha in 2022.

127. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports using Integrated Pest Management System (IPMS) for pest management by promoting breeding of beneficial insects and plants. Further, it reports that the barn owls help to control rat population and minimise rodent damage, while plants such as antigonon, leptopus, turnera, subulate, and cassia cobanensis provide shelter and supplementary food such as nectar for beneficial insects. Additionally, the shredded palm biomass spread across the field effectively prevents potential breeding grounds of pests such as rhinoceros beetles and rodents.

128. Waste management system in place to avoid negative impacts?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it takes proactive steps to keep track of scheduled waste (oils, lubricants, fuel filters, chemicals, pesticide containers) and dispose of them in full compliance with environmental laws and regulations applicable in the location of operation.

129. Commitment to human rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to the Universal Declaration of Human Rights in its own reporting.

130. Commitment to human rights applies to all suppliers?

The company commits suppliers to the Universal Declaration of Human Rights.

131. Progress on human rights commitment?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that in 2020, it engaged with BSR, a global non-profit sustainable business consultancy, to conduct independent human rights assessments at two selected operations in West Malaysia and Indonesia.

132. Commitment to respect indigenous and local communities' rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to the UN Declaration on the Rights of Indigenous Peoples in its own reporting.

133. Commitment to respect indigenous and local communities' rights applies to all suppliers?

The company commits suppliers to the UN Declaration on the Rights of Indigenous Peoples.

134. Commitment to respect legal and customary land tenure rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to respect legal and customary land tenure rights in relation to FPIC in its own reporting.

135. Commitment to respect legal and customary land rights applies to all suppliers?

The company commits all suppliers to respect legal and customary land tenure rights but only in relation to FPIC.

136. Commitment to free, prior and informed consent (FPIC)?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to FPIC in its own reporting.

137. Commitment to free, prior and informed consent (FPIC) applies to all suppliers?

The company commits all suppliers to respect FPIC.

138. Details of free, prior and informed consent (FPIC) process available?

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

139. Examples of local stakeholder engagement to prevent conflicts?

The company reports hosting meetings and dialogues, joint exercises, and training with local communities. It also conducts community outreach activities and development programmes to prevent conflicts.

140. Details of process for addressing land conflicts available?

The RSPO Principles and Criteria 2018 contain requirements for addressing land conflicts. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

141. Supports the inclusion of women across palm oil operations, including addressing barriers faced?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company has created a gender committee across its Malaysia and Indonesia operations that convene on a quarterly basis to obtain feedback from the ground on challenges faced by the workforce.

142. Commitment to mitigate impacts on food security?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

143. Progress on commitment to mitigate impacts on food security?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has a community outreach programme through which it donated food supplies to 260 indigenous families in Belum State Park, Perak.

144. Commitment to provide essential community services and facilities?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

145. Progress on commitment to provide essential community services and facilities?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports some examples of essential community services and facilities such as providing education to children of plantation workers and constructing roads and bridges.

146. Commitment to provide business/work opportunities for local communities?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

147. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to Free and Fair Labour Principles in its own reporting.

148. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies to all suppliers?

The company commits all suppliers to Free and Fair Labour Principles.

149. Progress on commitment to respect all workers' rights?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank.

150. Commitment to eliminate gender related discrimination with regards to employment?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also communicates this in its own reporting.

151. Commitment to eliminate gender related discrimination with regards to employment applies to all suppliers?

The company commits all suppliers to prevent employment-related discrimination based on gender.

152. Progress on commitment to eliminate gender related discrimination with regards to employment?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has established a gender committee across its Malaysia and Indonesia operations that convene on a quarterly basis to obtain feedback from the ground on challenges faced by the workforce.

153. Percentage or number of temporary employees?

28.5% - The company reports that it has 28.5% of temporary employees in 2022.

154. Percentage or number of women employees?

9168 (21.3%) - The company reports that it has 9,168 (21.3%) female employees in 2022.

155. Commitment to pay a Living Wage?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to pay a living wage in its own reporting.

156. Commitment to pay a Living Wage applies to all suppliers?

The company commits all suppliers to pay only minimum wage.

157. Progress on commitment to pay a Living Wage?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has established a decent living wage taskforce that has developed a template for the assessment of prevailing wage and in-kind benefits provided to workers. However, no further details were provided.

158. Reporting of salary by gender?

159. Commitment to address occupational health and safety?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to address health and safety in its own reporting.

160. Commitment to address occupational health and safety applies to all suppliers?

The company commits all suppliers to address health and safety at work for all workers.

161. Provision of personal protective equipment and related training?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it provides personal protective equipment and related training in relation to palm oil operations to all its employees.

162. Time lost due to work-based injuries?

The company reports a Lost Time Injury Frequency rate for KLK plantation: Malaysia (30.33), Sabah (14.04), Indonesia (60.43), and Liberia (0.30) and for KLK OLEO as (1.76). Calculated as recordable incidents x 1,000,000/total working hours.

163. Number of fatalities as a result of work-based accidents?

3 - The company reports three fatalities as a result of work-based accidents in 2022.

164. Commitment to support smallholders?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to this in its own reporting.

165. Programme to support scheme smallholders?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it has an 'Indonesian Plasma Scheme' initiative for the development of oil palm plantations for smallholders and small growers.

166. Percentage of scheme smallholders involved in programme?

6751 - The company states that it has allocated 9,840 ha to approximately 6,751 schemed smallholders under the plasma scheme. However, a percentage of the total of the company's scheme smallholders is not provided nor can it be calculated.

167. Programme to support independent smallholders?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also runs a 'Bornion Smallholders Project' which helps the participating smallholders and out-growers to obtain the RSPO certification with the facilitation of Wild Asia.

168. Percentage of independent smallholders/outgrowers involved in programme?

60 - The company reports a total of 56 smallholders and four out-growers to continue to uphold the certification status and stay on as members of the Wild Asia Group under the 'Bornion Smallholders Project'. However, a percentage of the total of the company's independent smallholders/outgrowers is not provided nor can it be calculated. This information is between two to five years old.

169. Process used to prioritise, assess and/or engage suppliers on compliance with company's policy and/or legal requirements?

The company reports that it held supplier compliance workshops in Kuala Lumpur, Sabah, and Riau in 2022. Further, it has an online portal for suppliers to enter traceability data, as well as a NDPE self-assessment tool.

170. Number or percentage of suppliers assessed and/or engaged on compliance with company's policy and/or legal requirements?

70 - The company reports that a total of 70 participants across multiple palm oil mills attended the workshop on the company's requirements in 2022.

171. Suspension or exclusion criteria for suppliers?

The company has a Sustainability Policy Non-Compliance Protocol, which lists the sustainability criteria by which suppliers are excluded, including steps that will be taken and timeframes for action.

172. Time-bound action plans (including Key Performance Indicators) for suppliers to be in compliance with palm oil sourcing commitments?

The company lists action plans and targets for suppliers to achieve policy compliance, for 95% of the total 3rd party volume to KLK OLEO. The remaining 5% covers KLK's own supply.

173. Proportion of supply from suppliers that is verified as deforestation- and/or conversion-free (DCF)?

174. Time-bound plan to engage with all high risk mills within 3 years?

The company commits to engage with all high-risk mills by FY2022.

175. Programme to support high risk mills to become compliant with sourcing policies?

The company only states it will hold regular engagement sessions with its suppliers in order to achieve compliance with its supplier code of conduct. No further details on the types of support could be found.

176. Regularly engages with a subset of high risk mills?

177. Procedures in place to assess all own and third party supplying palm oil mills for risk level?

The company has implemented a risk-based sustainability sourcing framework, however, only limited details of the procedure to assess mills are available.

178. Regularly assesses and categorises the risk level of all their own and third party supplying mills?

The company states it initiated NDPE compliance verification of external suppliers, however, it is not clear if the mills are reassessed on an annual basis for risk.

179. Regularly reports the risk level of all own and third party supplying mills identified in its supply chain?

180. Commitment to ethical conduct and prohibition of corruption?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to ethical conduct and the prohibition of corruption in its own reporting.

181. Commitment to ethical conduct and prohibition of corruption applies to all suppliers?

The company commits all suppliers to ethical conduct and the prohibition of corruption.

182. Progress on commitment to ethical conduct and prohibition of corruption?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has formed an anti-bribery and anti-corruption committee to review the effectiveness of ABAC controls and compliance matters. Further, the company also reports that it provides training on anti-bribery and anti-corruption to all directors and employees.

183. Disclosure of the company's management approach to tax and payments to governments?

184. Whistleblowing procedure?

The RSPO Principles and Criteria 2018 contain guidance and requirements on whistleblowing procedures. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own whistleblowing policy.

185. Own grievance or complaints system open to all stakeholders?

The company adheres to this criteria through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own grievance system which is open to all stakeholders.

186. Details of complaints and grievances disclosed?

[Externally verified] The company provides details of grievances on its website which includes date, issue, complainant category, actions taken and status.