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 sustainable palm oil policy applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has sustainability working committee (SWC) which is headed by the chief sustainability officer responsible for sustainability.

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

The company reports its board of directors oversee sustainability and climate-related strategy.

5. Reports gender balance of senior management team?

24% - The company reports that it has 24% women in the senior management team.

6. Reports gender balance of board members?

2 (25%) - The company reports that it has two (25%) 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?

[Externally verified] The company is a member of POCG.

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

The company reports that it has launched the Konservasi Hutan Desa (KONTANDES) project in collaboration with Aksenta, Belantara, and Lembaga Pengelolaan Hutan Desa (LPHD). This project aims to maintain high-quality forests and biodiversity while promoting community welfare through sustainable practices. Additionally, the company collaborated and the Earthworm Foundation (EF) have partnered to implement the Human-Elephant Coexistence (HEC) project aims to strengthen the local resilience in navigating the challenges associated with oil palm cultivation, particularly the human-elephant conflicts, and to manage them through targeted monitoring and mitigation efforts.

9. Sustainability report published within last two years?

The company published its latest sustainability report for 2024.

10. Reports through standardised reporting systems?

The company's latest sustainability report 2024 has been prepared in accordance with GRI 1: Foundation 2021.

11. Climate risks assessment available?

The company has conducted a climate risk assessment.

12. Lists countries and operations?

Malaysia, Indonesia, and Liberia - Plantations, Mills, Refineries and Crushers.

13. Lists countries sourcing from?

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

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

362510 - The RSPO ACOP 2024 states 362,510 ha as the total landbank controlled for palm oil.

15. Total oil palm planted area (ha)?

293472 - The company reports its total oil palm planted area as 293,472 ha in 2024.

16. Scheme smallholders planted area (ha)?

18036 - The company reports that the total land under scheme smallholders is 18,036 ha, according to its RSPO ACOP 2024.

17. Unplanted area (areas designated for future planting) (ha)?

6313 - The company reports a total unplanted area in its RSPO ACOP 2024 as 6,313 ha.

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

23567 - The company reports 27,480 ha of conservation set-aside areas in its annual report 2024 and 23,567 ha in its RSPO ACOP 2024. However, contradictory figures have been reported.

19. Maps of estates/management units?

The company reports that it has submitted all concession maps to RSPO, no new concessions have been added and no changes in ownership of concessions have occurred since the submission of maps to RSPO.

20. Maps of all scheme smallholders?

The company reports the names and coordinates for a single point per smallholder only.

21. Maps of all third-party supplying plantations?

The company has published the coordinates of supply bases for all suppliers on its traceability webpage. However, estates boundary is not available.

22. Number of company-owned mills?

34 - The company reports that it has 34 palm oil mills in its annual report 2024 and RSPO ACOP 2024.

23. 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.

24. 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 mills separately.

25. 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 mills. However, no overall percentages are provided and it cannot be calculated.

26. Number of third party supplying mills?

1300 - The company reports that it has 1,300 third-party supplying mills.

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

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

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

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

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

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

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

32. 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.

33. 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.

34. 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 15 of the company's mills have Identity Preserved certification and data is externally verified by control union.

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

The company reports 93% of supply from third-party mills traceable to plantation level. Additional points are awarded as, data is externally verified by control union.

36. Publishes traceability data at refinery level?

[Externally verified] The company publishes traceability data for all of its refineries. The information is externally verified by Control Union.

37. Publishes traceability data at crusher level?

[Externally verified] The company publishes traceability data for all its crushers. The information is externally verified by Control Union.

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

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

39. 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?

2009 - The company achieved its first RSPO certification in 2009.

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

The company has submitted its latest RSPO ACOP 2024.

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

83.19% - The company reports that it has 78% RSPO-certified areas in its annual report 2024. However, the RSPO ACOP 2024, which is more up to date, states that the company has 83.19% RSPO-certified areas.

42. Percentage of mills RSPO-certified?

82.35% - The company reports that 82.35% of its mills are RSPO-certified in their RSPO ACOP 2024.

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

2026 - The company commits to achieve 100% RSPO certification of estates and mills by 2026. This is within 5 years.

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

2025 - The company reports it achieved 100% RSPO certification for all its palm product processing facilities in 2018. However, the company's annual report states that the company acquired IJM Plantations in 2021 and is now aiming for 2025 to certify the remaining palm product processing facilities. This is conflicting information.

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

42.23% - The company reports the total percentage of scheme/plasma smallholders (ha) RSPO-certified in its RSPO ACOP 2024.

46. 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 within five years.

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

31.77% - 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 2024.

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

18.09% - The RSPO ACOP 2024 states that 18.09% of all palm oil and oil palm products handled/traded/processed are RSPO-certified.

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

The company reports that 61.88% of RSPO-certified palm oil is sold through segregated or identity-preserved supply chains.

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

The company reports that 7.16% of RSPO-certified palm oil processes/trades through segregated or identity-preserved supply chains.

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

[Externally verified] The company reports that 97% of its estates and 100% of its palm oil mills are ISPO-certified. The information is externally verified by Control Union.

52. 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.

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

[Externally verified] The company is certified under ISCC.

54. Commitment to zero conversion of natural ecosystems?

The company commits to prevent the conversion of natural ecosystems, including HCS, HCV and other designated conservation areas. However, it does not commits to zero conversion of all natural ecosystems.

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

The company commits to prevent the conversion of natural ecosystems, including HCS, HCV and other designated conservation areas applies to all suppliers. However, it does not commits to zero conversion of all natural ecosystems.

56. 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. This commitment has been in place since 2018.

57. Commitment to zero deforestation applies to all suppliers?

The company commits to zero deforestation applies to all suppliers.

58. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

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 and no conversion of High Carbon Stock (HCS) forests and High Conservation Value (HCV) areas after 30 August 2018.

59. Criteria and cut-off date for defining deforestation and/or ecosystem conversion in supplier operations?

The company defines deforestation for suppliers as no conversion of HCV and HCS areas and specifies any deforestation/conversion past 2018 will not be accepted in supplier operations.

60. Cross-commodity zero deforestation commitment?

61. Cross-commodity zero deforestation commitment applies to all suppliers?

62. Target date to achieve zero deforestation?

63. Target date to achieve zero deforestation in supplier operations?

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also engages with Earthqualizer as a satellite monitoring service provider to monitor deforestation and ecosystem conversion. The information is externally verified by Control Union.

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

[Externally verified] The company reports that it collaborated with Earthqualizer to monitor deforestation in supplier operations through satellite monitoring. It receives bi-weekly supplier monitoring reports, enabling proactive engagement with its suppliers. The company also uses geospatial monitoring tools and satellite imagery to track land use changes, ensuring that all palm oil sources are free from deforestation and peatland development. This is externally verified by Control Union.

66. 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 2018. However, the information is undated.

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

68. 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.

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

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

70. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company has launched a collaborative 'Forest and Biodiversity Conservation Project' in the Berau Regency of East Kalimantan, Indonesia. This initiative involves partnerships with Aksenta, Belantara, and Lembaga Pengelolaan Hutan Desa (LPHD) to preserve high-quality forests and biodiversity while promoting community welfare through sustainable practices. The company is also working with Earthworm Foundation alongside other sponsors on the Sabah Landscape Project to co-develop interventions aimed at safeguarding sustainable livelihood options for smallholders and conserving key High Conservation Value (HCV) areas focusing on community land. This is externally verified by Control Union.

71. Biodiversity policy?

The company has a commitment to protect biodiversity. However, company does not have clear target and scope for protection of biodiversity.

72. Biodiversity policy applies to all suppliers?

The company has a commitment to protect biodiversity applies to all supplier. However, company does not have clear target and scope for protection of biodiversity.

73. 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. The information is externally verified by Control Union.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it collaborates with WWF Malaysia, establishing a vital pathway for wildlife to traverse between these forest reserves. The company also collaborated with BORA, KLK, along with other partners, has undertaken the planting of Napier grass and Ficus trees at the Malambabula Wildlife Habitat Restoration Area within the Tabin Wildlife Reserve. The information is externally verified by Control Union.

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

The company commits to no hunting of rare, threatened, or endangered ("RTE") only, and sustainable hunting by local communities for subsistence purposes.

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

The company commits suppliers to no hunting of rare, threatened, or endangered ("RTE") only, and sustainable hunting by local communities for subsistence purposes.

77. 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.

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

The company commits all suppliers to conduct HCV assessments.

79. 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.

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

[Externally verified] The HCV assessments of PT Karya Makmur Abadi, Kuala Gris and Kemasul Estate and PT Putra Bongan Jaya are available on both the HCVRN website and the RSPO NPP. Further, the HCV assessment of PT Jabontara Eka Karsa - Koperasi Harapan Bersama and PT Steelindo Wahana Perkasa are available only on the HCVRN website. The information is externally verified by Control Union.

81. 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, Kuala Gris and Kemasul Estate and PT Putra Bongan Jaya are available on both the HCVRN website and the RSPO NPP. Further, the HCV assessment of PT Jabontara Eka Karsa - Koperasi Harapan Bersama and PT Steelindo Wahana Perkasa are available only on the HCVRN website. The information is externally verified by Control Union.

82. 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.

83. 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?

84. 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 Jabontara Eka Karsa - Koperasi Harapan Bersama, Kuala Gris Estate and Kemasul Estate, PT Steelindo Wahana Perkasa and PT Putra Bongan Jaya are available on the HCVRN website and have been reviewed as satisfactory.

85. 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.

86. 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.

87. 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 one New Planting Area (LIBINCO) are available on the HCSA website.

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

[Externally verified] Peer review reports for all of the company's standalone HCS assessments since April 2015 are published on the HCSA website.

89. 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.

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

The company commits all suppliers to conduct social and environmental impact assessments.

91. 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 NPP website.

92. 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.

93. 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.

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

17126 - The company reports that it has a 17,126 ha landbank on peat. Data as of 2024.

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

[Externally verified] The company reports that the landbank or area planted on peat has not increased from FY2023 to FY2024. The information is externally verified by Control Union.

96. 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 best management practices for peatland in its own reporting.

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

The company commits all suppliers to best management practices for peat and soil.

98. 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 progress in implementing management practices to conserve soil. These practices include using biofertilisers and palm by-products, such as empty fruit bunches and oil palm trunks, to mitigate poor growing conditions, improve soil structures, and reduce the impact of inherent soil limitations. The information is externally verified by Control Union.

99. 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.

100. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

101. 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 reports that it uses on-the-ground monitoring to detect and mitigate the risk of fire outbreaks and conduct an annual training for its firefighting teams. The information is externally verified by Control Union.

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

The company reports that it detected 53 hotspots and 44 fires within its concessions in 2024.

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

367 - The company reports that it detected 197 hotspots and 170 fires within the surrounding landscape in 2024.

104. Time-bound commitment to reduce absolute greenhouse gas (GHG) emissions?

The company commits to reach net zero by 2050 for scope 1&2 emissions. However, it does not commits to reduce absolute greenhouse gas (GHG) emissions.

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

The company commits to reducing its GHG emissions intensity by 25% by 2030 compared to the 2019 baseline. This target includes Scope 1 and Scope 2 emissions.

106. Absolute GHG emissions?

1350320 - The company reports plantation (Scope 1, 2 and 3), Scope 1 and 2 for Refinery & KCP, and Scope 1 and 2 for Oleochemical as 1,350,324 mt CO2eq).

107. GHG emissions intensity?

0.4 - The company reports GHG emissions intensity 0.40 mt CO2 eq/mt CPO. Data as of 2024.

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

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

110. Progress towards commitment to reduce absolute GHG emissions?

The company' emissions from plantation (Scope 1, 2 and 3), Scope 1 and 2 for Refinery & KCP, and Scope 1 and 2 for Oleochemical have reduced from 1,422,948 tCO2e from Scope 1 and 2 for in FY2023 to 1,350,324 tCO2e in FY2024.

111. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports a reduction in GHG emission intensity from 0.45 mt CO2 eq/mt CPO in FY2023 to 0.40 mt CO2 eq/mt CPO in FY2024. The information is externally verified by Control Union.

112. 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.

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

The company reports that nine out of 34 (26.47%) company-owned mills have methane capture.

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

115. Water use intensity?

1.26 - The company reports its average water consumption intensity for plantations as 1.26 m³/mt FFB processed, refinery & KCP as 0.27m³/mt FFB processed and for oleochemicals as 2.85 m³/mt production volume for 2024.

116. Progress towards commitment on water use intensity?

The company reports a reduction in plantation water intensity from 1.28 m³/mt FFB processed in 2023 to 1.26 m³/mt FFB processed in 2024, reduction in refinery & KCP (m3 /mt production volume) from 0.26m³/mt FFB processed in 2023 to 0.27m³/mt FFB processed in 2024. However, the oleochemical water intensity (m³/mt production volume) increased from 2.63 in 2023 to 2.85 in 2024.

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

The company commits to maintain BOD and COD levels within legal limits. However, the information is over two years ago.

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

The company reports an increase in average COD emissions from plantations, rising from 221 Mg/L in 2023 to 444 Mg/L in 2024. Additionally, figures for oleochemical operations are not available.

119. 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 convert palm oil mill effluent (POME) into biogas for energy. The information is externally verified by Control Union.

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

The company reports that it treats PORE.

121. 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.

122. 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 also reports that it 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. However, this information is now between two and five years old.

123. 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 commits to minimise the use of chemicals, including pesticides and chemical fertilisers.

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

The company commits to minimise the use of chemicals including pesticides only applies to all suppliers.

125. 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 commits to no use of paraquat.

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

The company commits to no use of paraquat applies to all suppliers.

127. 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 commits to no use of World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers.

129. 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 commits to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention.

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

The company commits to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers.

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

The company reports the agrochemical Intensity 0.90 (mt/ha) and consumption figures of fertilisers, herbicides and pesticides for 2024.

132. 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 25% potential reduction in inorganic fertiliser input by launching a semi-commercial biofertiliser evaluation trial. Additionally, company aim to inoculate a total of 72,400 DxP seeds, and field trials in 2025 will evaluate AA N-Fix's effectiveness in supporting reduced fertiliser use while maintaining or enhancing growth and yield.

133. 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 that it uses a natural pest management approach, including cultivating plants with natural repellent properties against common pests and insects and encouraging the growth of predator populations, such as barn owls, to control the rodent population and also provide training on sustainable agricultural practices, pest management, and efficient fertiliser use to smallholders.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it implements waste segregation at all operational sites, separating recyclable materials such as plastics, paper, and metal from organic waste. The recovered materials are sent to certified recycling partners, helping to reduce the volume of waste sent to landfills. Additionally, hazardous waste, such as chemicals and used oil, is collected and disposed of through certified hazardous waste management companies to prevent environmental contamination.

135. 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.

136. Commitment to human rights applies to all suppliers?

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

137. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it appointed a third party to conduct a human rights risk assessment across its estates and mills in Peninsular Malaysia.

138. Commitment to respect Indigenous Peoples' 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.

139. Commitment to respect Indigenous Peoples' and local communities' rights applies to all suppliers?

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

140. 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.

141. 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.

142. 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.

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

The company commits all suppliers to respect FPIC.

144. 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.

145. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company reports hosting surveys, town halls, training programmes. It has a human-elephant coexistence project to prevent conflict between smallholders and also conducts community outreach activities and development programs to prevent conflicts. The is externally verified by Control Union.

146. 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.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports to established a gender committee across its operations in Malaysia, Indonesia, and Liberia, which meets quarterly to gather feedback from the ground on challenges faced by the workforce.

148. 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.

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

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, including donating food supplies to 300 Orang Asli families in Royal Belum State Park, providing assistance to Cianjur earthquake victims in Indonesia, and donating special meals and personal care items to 11,550 inmates across Sungai Buloh, Taiping, and Tapah prisons.

150. 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.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also report to improving the quality of life for local communities by providing infrastructure development, and healthcare initiatives. Additionally, they have launched Yayasan Sekolah SMP PWS - KLK junior high school at PT Pinang Witmas Sejati in South Sumatra providing educational opportunities for the children.

152. 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.

153. 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.

154. 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.

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company has approached KPMG (third party body) to conduct the assessment of independent verification assessment report. For KLK Berhad on the ILO Indicators of forced labor for peninsular Malaysia covering three regions including Northern, central and southern region. The assessment covers engagement objectives, important context, and interview sessions. The information is externally verified by Control Union.

156. 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 commits to eliminate gender related discrimination with regards to employment.

157. 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.

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

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 within its operations in Malaysia and Indonesia, which convenes quarterly to gather feedback from the workforce on the challenges they encounter.

159. Percentage or number of temporary employees?

27% - The company reports that it has 27% of temporary employees in 2024.

160. Reports gender balance of employees?

10450 (20%) - The company reports that it has 20% female employees in 2024.

161. 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 fair and equitable wages across its operations.

162. Commitment to pay a living wage applies to all suppliers?

The company commits all suppliers to pay minimum wage only.

163. Progress on commitment to pay a living wage?

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 task force that has developed a template for assessing prevailing wages and in-kind benefits provided to workers. However, no further details were provided, and this information is now between two and five years old.

164. Reporting of salary by gender?

165. 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.

166. 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.

167. Provision of personal protective equipment and related training?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it provides occupational health and safety training to its employees. The information is externally verified by Control Union.

168. Time lost due to work-based injuries?

21.12 - The company reports a Lost Time Injury Frequency rate for 21.12 for 2024. Calculated as no. of LTI x 1,000,000/total man hours worked.

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

4 - The company reports four fatalities as a result of work-based accidents in 2024.

170. 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 support smallholders.

171. Programme to support scheme smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also provide comprehensive training on health and safety, fertilising for KHSB, and SOP for waste management under 'Plasma Scheme Program' in 2024. The information is externally verified by Control Union.

172. Percentage of scheme smallholders involved in programme?

[Externally verified] The company reports a total of 13,463 scheme and independent smallholders involved in the programme. However, it has not report a separate data for scheme smallholders. The information is externally verified by Control Union.

173. Programme to support independent smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also provide comprehensive training on sustainable agricultural practices, pest management, and efficient fertiliser use to smallholders and offers financial incentives, access to quality seeds, and assistance in achieving certification under schemes such as RSPO and MSPO in 2024. However, type of smallholder is unclear.

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

[Externally verified] The company has reported a total of 13,463 scheme and independent smallholders involved in the programme. However, it has not provided separate data for independent smallholders. The information is externally verified by Control Union.

175. 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 Sabah, Peninsular Malaysia, and Riau in 2023. Further, it operates an online portal for suppliers to input traceability data and utilises an NDPE self-assessment tool.

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

[Externally verified] The company reports that 36 mills in Indonesia, 39 mills in Sabah and 59 mills in Peninsular Malaysia are involved in the supplier engagement in regards to the code of conduct agreement. However, it does not report the number or percentage of suppliers assessed. The information is externally verified by Control Union.

177. 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.

178. 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.

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

[Externally verified] The company has reported deforestation and conversion free (DCF) proportion on the basis of its region (48.3% for Peninsular, 68.8% for Sabah, 64.0% for Indonesia). The information is externally verified by Control Union.

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

The company committed to engage with all high-risk mills by FY2022. However, it is unclear whether this target has been achieved. The company reports it will engage with high-risk mills to enhanced monitoring and targeted engagement strategies, which include workshops, direct meetings, and providing technical assistance to address non-compliance issues, but does not report a time-bound plan.

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

[Externally verified] The company reports that it conduct workshops, meetings, and provide technical assistance to help high risk mills to become compliant with sourcing policies. The information is externally verified by Control Union.

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

[Externally verified] The company reports high-risk mill analysis had been conducted in collaboration with Earthqualizer on annual basis. The information is externally verified by Control Union.

183. 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.

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

[Externally verified] The company reports it regularly conduct assessment of all own and third party supplying mills with the collaboration with Daemeter. The company proactively monitors its supplying mills, prioritising high risk mills due to potential deforestation, fire, or peatland degradation. The information is externally verified by Control Union.

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

[Externally verified] The company regularly reports the risk level of all own and third party supplying mills identified in its supply chain. Also, it conduct workshops, direct meetings, and technical assistance to address non-compliance for high-risk mills. The information is externally verified by Control Union.

186. 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.

187. 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.

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

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 an anti-bribery and anti-corruption (ABAC) committee to assess the effectiveness of ABAC controls and compliance. Additionally, the company provides anti-bribery and anti-corruption training to all directors and employees.

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

190. 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.

191. 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.

192. Details of complaints and grievances disclosed?

The company provides details of grievances on its website, including the date, subject matter, company names, stakeholder names, and status.