Johor Plantations Group Bhd (previously Kulim (Malaysia) Bhd)

1.1.. Is the company an RSPO member?

Kulim (Malaysia) Berhad has been an RSPO member since 2004.

1.2.. Has the company submitted its most recent Annual Communication of Progress (ACOP) report to the RSPO?

Yes.

1.3.1.. In the company's most recent and up-to-date RSPO ACOP report, does the company refer to itself as an oil palm grower?

Kulim correctly refer to themselves as an oil palm grower.

1.3.2.. In the company's most recent and up-to-date RSPO ACOP report, does the company state all the countries and regions in which it operates?

Kulim did not state all the countries in which the company operates. Kulim did not include its acquisition of up to 74% of the equity in PT Wisesa Inspirasi Nusantara (PT WIN), North Barito, Central Kalimantan.

1.4.1.. Has the company set any public targets to be 100% RSPO-certified?

2016 (this target does not include Kulim's operations outside of Malaysia).

1.4.2.. Has the company missed any of its public targets to be 100% RSPO-certified?

No.

1.5.. What percentage of the company's total plantation estates is RSPO-certified?

50.3 -
50.3% of Kulim's licensed landbank is RSPO certified

Calculation: 46,136 ha (total area RSPO certified) divided by 91,805 ha (stated licensed landbank incl. Indonesia) x 100.

1.6.. Are the company's RSPO Principles and Criteria certification assessments publicly available?

Link to Kulim's RSPO Principles and Criteria certification assessments.

1.7.1.. Has the company set any public targets for its third party suppliers to be 100% RSPO-certified?

2019.

1.7.2.. Has the company missed any public targets for 100% of its independent FFB suppliers to be RSPO-certified?

Yes.

1.8.1.. Has the company set any public targets for scheme smallholders to be 100% RSPO-certified?

2019.

1.8.2.. Has the company missed any public targets for 100% of its scheme smallholders to be RSPO-certified?

Yes.

1.9.. What percentage of the company's scheme smallholder plantations is RSPO-certified?

22.42 -
22.42% of Kulim's scheme smallholder plantations are RSPO certified

Calculation: 1,312 ha of scheme smallholder plantations out of a total of 5,851 ha had been RSPO certified = 1,312 ha divided by 5,851 ha x 100

(data found was more than one year old)
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2.1.1.. Does the company have a publicly available statement detailing its land acquisition criteria?

No information could be found using the research protocols.

2.1.2.. Does this statement apply to all of the company's scheme smallholders and independent FFB suppliers?

No information could be found using the research protocols.

2.2.1.. Has the company publicly disclosed its total landbank area for oil palm cultivation?

91805 - Yes, licensed landbank is 91,805 ha.

2.2.2.. Has the company publicly disclosed its total planted area?

47202 - Yes, planted area is 47,202 ha.

2.2.3.. Has the company publicly disclosed its total scheme smallholder area?

5851 - Yes, scheme smallholder hectarage is 5,851 ha (figure stated does not include Kulim's acquisition of PT WIN in Central Kalimantan and data found was more than one year old).

2.2.4.. Has the company publicly disclosed its total area of land managed for conservation that is set aside (i.e. including areas of High Conservation Value)?

65.86 - Yes, landbank for conservation is 65.86 ha.

2.3.1.. Are all of the company's concession maps publicly available for all countries in which it operates?

Company concession boundary maps have been made publicly available and can be viewed in the Toolkit's mapping tool. However, ZSL is currently unable to ascertain if the maps disclosed constitute 100% of the companies' palm oil estates. This page will be updated once the information has been made available.

2.3.2.. Are all of the company's scheme smallholders' concession maps publicly available for all countries in which it operates?

No scheme smallholder concession maps have been made publicly available by Kulim and are therefore unavailable to view on the SPOTT mapping tool.

3.1.1.. Does the company have a publicly available statement to address deforestation resulting from its operations?

Yes.

3.1.2.. Does this statement apply to all its scheme smallholders and independent FFB suppliers?

No information could be found using the research protocols.

3.2.1.. Does the company have a publicly available commitment to undertake Free, Prior and Informed Consent (FPIC) prior to any new planting taking place?

Yes.

3.2.2.. Does the company make its Free, Prior and Informed Consent (FPIC) process publicly available?

The following Kulim subsidiaries which have a publicly available FPIC process are as follows:

PT Sawit Sumber Rejo

PT Wahana Semesta Kharisma

PT Harapan Barito Sejahtera

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3.3.1.. Does the company have a publicly available commitment to conduct SEIA (Social and Environmental Impact Assessments) assessments prior to any new planting taking place?

Yes.

3.3.2.. Are all SEIA assessments conducted after November 2005 publicly available?

There is public availability of some of Kulim's SEIA assessments:

**Central Kalimantan:** PT Harapan Barito Sejahtera, PT Sawit Sumber Rejo, PT Wahana Semesta Kharisma, no further SEIA assessments could be found

**Malaysia:** No SEIA assessments could be found
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3.4.1.. Does the company have a publicly available commitment to conduct High Conservation Value (HCV) assessments prior to any new planting taking place?

Yes.

3.4.3.. Are all of the company's High Conservation Value (HCV) assessments conducted after November 2005 publicly available?

There is public availability of some of Kulim's HCV assessments:

**Central Kalimantan:** PT Harapan Barito Sejahtera, PT Sawit Sumber Rejo, PT Wahana Semesta Kharisma, no further HCV assessments could be found

**Malaysia:** No HCV assessments could be found
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3.4.4.. Does the company make its High Conservation Value (HCV) management and monitoring plans for all of its estates publicly available?

There is public availability of some of Kulim's HCV management plans:

**Central Kalimantan:** PT Harapan Barito Sejahtera, PT Sawit Sumber Rejo, PT Wahana Semesta Kharisma, no further HCV management plans could be found

**Malaysia:** No HCV management plans could be found
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3.6.. Does the company have a publicly available Water Management Plan or equivalent for its operations?

Yes.

3.7.. Does the company have a publicly available Integrated Pest Management Plan for its operations?

Yes.

3.8.. Does the company have a publicly available commitment to not use WHO Class 1A and 1B pesticides and paraquat, or time-bound plan for phasing out their use?

Information could only be found for the phasing out of paraquat.

3.9.. Has the company been mentioned in any relevant media stories and/or reports that make reference to wildlife conflict or deforestation within the company's plantation estates and/or its scheme smallholders' or independent FFB suppliers' plantations?

No relevant media stories could be found using the research protocols.

4.1.1.. Does the company have a publicly available statement stating that it is committed to a strict 'no new development on peat' policy?

No information could be found using the research protocols.

4.1.2.. Does this policy apply to all its scheme smallholders and independent FFB suppliers?

No information could be found using the research protocols.

4.2.. What percentage of the company's landbank for oil palm cultivation is located on peat?

2.7 -
Approximately 2.7% (1,380 ha) of Kulim's licensed landbank is located on peat soil

Calculation: 1,380 ha (total stated hectarage located on peat soil) divided by 51,160 ha (stated licensed landbank) x 100

(figure stated does not include Kulim's acquisition of PT WIN in Central Kalimantan)
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5.1.1.. Does the company have a publicly available statement stating that it is committed to a strict policy of zero burning?

Yes.

5.1.2.. Does this policy apply to all its scheme smallholders and independent FFB suppliers?

No information could be found using the research protocols.

5.2.. Has the company been mentioned in any relevant media stories and/or reports that make reference to fires found within the company's plantation estates and/or its scheme smallholders' or independent FFB suppliers' plantations?

No relevant media stories could be found using the research protocols.

6.1.1.. Does the company have a publicly available time-bound plan to reduce greenhouse gas (GHG) emissions?

Yes.

6.1.2.. Does this time-bound plan apply to all its scheme smallholders and independent FFB suppliers?

Yes.

6.2.. Does the company publicly report on progress made towards achieving its time-bound plan?

Yes.

6.3.. Does the company publicly report its GHG emissions from land use change associated with new planting?

Yes.

7.1.. Are all of the company's mill locations publicly available for all countries in which it operates?

No palm oil mill locations have been made publicly available by Kulim and are therefore unavailable to view on the SPOTT mapping tool.

7.2.. What percentage of the company's total palm oil mills is RSPO-certified?

80 -
80% of Kulim's palm oil mills are RSPO certified

Calculation: 4 palm oil mills RSPO certified divided by 5 palm oil mills (total number stated) x 100
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7.3.. What percentage of the company's total fresh fruit bunches (FFBs) purchased from independent suppliers (not including outgrowers and scheme smallholders) is RSPO-certified?

No information could be found using the research protocols.

7.4.. Does the company have a public commitment to move towards Segregated and/or Identity Preserved certified sustainable palm oil (CSPO)?

No information could be found using the research protocols.

7.5.. Does the company prioritize certified sustainable palm oil (CSPO) from Segregated or Identity Preserved supply chain models over Mass Balance or GreenPalm?

Book & Claim, Mass Balance, Segregated.