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 in scope than the Sustainability Policy.

3. High-level position of responsibility for sustainability?

The company's sustainability steering committee, chaired by the CEO, 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 also 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. Reports gender balance of 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. Reports gender balance of 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?

[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 with WWF-Malaysia to establish a vital wildlife corridor linking Tabin Wildlife Reserve and the isolated Silabukan Kecil Forest Reserve, creating a sustainable ecosystem to support wildlife for generations to come.

9. Sustainability report published within last two years?

The company published its latest sustainability report for 2023.

10. Reports through standardised reporting systems?

The company's latest sustainability report, published after January 1, 2023, is prepared in accordance with the Global Reporting Initiative (GRI) Standards - Core Option. The new GRI standards require a different specific text to be stated for any report published after January 1st 2023.

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?

The company has published a summary of its climate risk assessment.

13. Lists countries and operations?

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

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)?

358919 - The RSPO ACOP 2023 states 358,919 ha as the total landbank controlled for palm oil.

16. Total oil palm planted area (ha)?

287181 - The company reports its total oil palm planted area as 287,181 ha in 2023.

17. Scheme smallholders planted area (ha)?

21282 - The company reports that the total land under scheme smallholders is 21,282 ha, according to its RSPO ACOP 2023.

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

7987 - The company reports a total unplanted area in its RSPO ACOP 2023 as 7,987 ha.

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

24476 - The company reports 24,949 ha of conservation set-aside areas in its annual report 2023. However, the RSPO ACOP 2023 indicates that the company has 24,476 ha of conservation set-aside areas.

20. Maps of estates/management units?

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

21. Maps of all scheme smallholders?

22. Maps of all third-party supplying plantations?

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

23. Number of company-owned mills?

33 - The company reports that it has 32 palm oil mills in its annual report 2023. However, the RSPO ACOP 2023 states that the company has 33 palm oil mills.

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?

1812 - The company reports that it has 1,812 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 15 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 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 2023.

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

80.65% - The company reports that it has 76% RSPO-certified areas in its annual report 2023. However, the RSPO ACOP 2023, which is more up to date, states that the company has 80.65% RSPO-certified areas.

43. Percentage of mills RSPO-certified?

78% - The company reports that 78% of its mills are RSPO-certified.

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?

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 contradictory information.

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

43.31% - The company reports the total percentage of scheme/plasma smallholders (ha) RSPO-certified in its RSPO ACOP 2023.

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 within five years.

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

19.68% - 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 2023.

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

16.81% - The RSPO ACOP 2023 states that 16.81% 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 56.16% of RSPO-certified palm oil is sold 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 1.67% 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 96% of its estates and 100% 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. This commitment has been in place since 2018.

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 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.

60. Criteria and cut-off date for defining deforestation and/or ecosystem conversion 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 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. Additionally, in 2022, the company monitored 11.1 million ha of supplier land area.

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 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.

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 collaborates with non-governmental organisations such as Bringing Back Our Rare Animals (BORA) to protect the dwindling population of Bornean Bantengs and enhance the food supply for elephants, Bantengs, and other wildlife by planting Ficus trees and Napier grass. It also supports 'Persatuan Pelindung Harimau Malaysia' in preserving the Malayan tiger and its natural habitat through a community-based approach.

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, 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. However, it is unclear if these assessments cover all estates planted or planned to be planted since January 2015.

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, 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. However, it is unclear if these assessments cover all estates planted or planned to be planted since January 2015.

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 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.

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] Peer review reports for all of the company's standalone HCS assessments since April 2015 are 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?

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

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 NPP 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)?

17126 - The company reports that it has a 17,126 ha landbank on peat. Data as of 2023.

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 best management practices for peatland in its own reporting.

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

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

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 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.

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 reports that its operation centres conduct regular field patrols to identify and extinguish any hotspots. Additionally, it has strategically positioned reservoirs, water ponds, and fire towers across its estates, equipped with firefighting tools, water pumps, and dedicated vehicles on standby for immediate response. The company has also installed weather stations and provides annual training to firefighting teams during dry weather conditions.

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

The company reports that it detected 26 hotspots and 20 fires within its concessions in 2023.

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

389 - The company reports that it detected 215 hotspots and 174 fires within the surrounding landscape in 2023.

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

The company commits to reducing its GHG emissions intensity by 25% by 2029/2030 compared to the 2018/2019 baseline. This target includes Scope 1 and Scope 2 emissions.

102. GHG emissions intensity?

The company reports its Oleochemical's GHG intensity as 0.21 (mt CO2 eq/mt prod vol) and the plantation's average GHG Intensity as 455 (kg CO2 eq/mt CPO) in 2023. This figure includes 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 Oleochemicals' GHG intensity from 0.23 (mt CO2 eq/mt prod vol) in 2022 to 0.21 (mt CO2 eq/mt prod vol) in 2023, and a decrease in the plantation's average GHG intensity from 476 (kg CO2 eq/mt CPO) in 2022 to 455 (kg CO2 eq/mt CPO) in 2023.

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 nine out of 32 (28.12%) company-owned mills have methane capture.

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

109. Water use intensity?

1.27 - The company reports its average water intensity for plantations as 1.27 m³/mt FFB processed and for oleochemicals as 1.73 m³/mt prod vol for 2023.

110. Progress towards commitment on water use intensity?

The company reports a reduction in average plantation water intensity from 1.40 m³/mt FFB processed in 2022 to 1.27 m³/mt FFB processed in 2023. However, the average oleochemical water intensity increased from 1.30 m³/mt prod vol in 2022 to 1.73 m³/mt prod vol in 2023.

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)?

The company reports an increase in average COD emissions from plantations, rising from 151.80 mg/L in 2022 to 1,634.25 mg/L in 2023. Additionally, figures for oleochemical operations are not available.

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 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.

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 the consumption figures of fertilisers, herbicides and pesticides for 2023. However, these are not provided as intensity figures.

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 reports a decrease in average fertiliser consumption from 1.28 mt/ha in 2021 to 1.1 mt/ha in 2022. Additionally, it uses bio-fertilisers to mitigate poor growing conditions, improve soil structures, and reduce the impacts of inherent soil limitations.

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 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.

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 track scheduled waste (including oils, lubricants, fuel filters, chemicals, and pesticide containers) and dispose of it in full compliance with environmental laws and regulations applicable to the location of operations.

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 it appointed a third party to conduct a human rights risk assessment across its estates and mills in Peninsular Malaysia.

132. 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 in its own reporting.

133. 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.

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 sessions with local communities. It has a human-elephant coexistence project to prevent conflict between smallholders and also conducts community outreach activities and development programs 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 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.

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, 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.

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 providing essential community services and facilities, such as enhancing infrastructure in rural areas, distributing school bags, uniforms, and essential stationery items to students across Malaysia, and offering healthcare services to communities in Liberia.

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

153. Percentage or number of temporary employees?

27.6% - The company reports that it has 27.6% of temporary employees in 2023.

154. Reports gender balance of employees?

20.4% - The company reports that it has 20.4% female employees in 2023.

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 minimum wage only.

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 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.

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 occupational health and safety training to its employees.

162. Time lost due to work-based injuries?

The company reports a Lost Time Injury Frequency rate for KLK plantation: Malaysia (19.73), Indonesia (47.04), and Liberia (25.04) and for KLK OLEO as (1.50). 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 2023.

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 in 2021, it launched an 'Indonesian Plasma Scheme' initiative for the development of oil palm plantations for smallholders and small growers. However, this information is now between two and five years old.

166. Percentage of scheme smallholders involved in programme?

6751 - The company states that it allocated 9,840 ha to approximately 6,751 scheme smallholders under the plasma scheme in 2021. However, the percentage of the total scheme smallholders was not provided, and this information is now between two and five years old.

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 reports that in 2020, it launched the 'Bornion Smallholders Project,' which assisted participating smallholders and outgrowers in obtaining RSPO certification with the facilitation of Wild Asia. However, this information is now between two and five years old.

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

60 - The company reports that a total of 56 smallholders and four outgrowers continued to uphold their certification status and remained members of the Wild Asia Group under the 'Bornion Smallholders Project.' However, the percentage of total independent smallholders and outgrowers was not provided, and this information is now between two and 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 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.

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

76 - The company reports that a total of 76 participants from 66 palm oil mills attended workshops and received training on the company's requirements in 2023.

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 committed to engage with all high-risk mills by FY2022. However, it is unclear whether this target has been achieved.

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

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 reports that it has established an anti-bribery and anti-corruption (ABAC) committee to assess the effectiveness of ABAC controls and compliance. In 2023, it conducted an annual ABAC Control Self-Assessment (CSA) to evaluate the effectiveness of the implemented oversight, risk management, and controls. Additionally, the company provides anti-bribery and anti-corruption training 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, including the date, subject matter, company names, stakeholder names, and status.