Kuala Lumpur Kepong Bhd

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

The company has published a sustainable palm oil policy which covers all palm oil operations.

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

The company has published a sustainable palm oil policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

Sustainability Working Committee lead by the Group Plantations Director.

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

CEO leads the Sustainability Steering Committee.

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

1 (14.28%) - The company has one woman out of the total seven members as a part of its senior management team.

6. Percentage or number of women board members?

2 (22.22%) - The company has two woman out of the total nine members as a part of its 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 member of HCSA.

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

The company has partnered with Wild Asia to support smallholders with RSPO certification. Further, the company's sustainability team in Indonesia embarked on a community-based forest conservation project in 2020 in the Berau Regency of East Kalimantan in Indonesia.

9. Sustainability report published within last two years?

The company published its latest Sustainability Report for 2021.

10. Reports through standardised reporting systems?

The company reports that its 2021 Sustainability Report is prepared in accordance with the GRI Standards - Core option.

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

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

12. Climate risks assessment available?

13. Lists countries and operations?

Plantation - Malaysia (Peninsular and Sabah), Indonesia (Belitung Island, Sumatra, as well as Kalimantan) and Liberia. The company provides maps of Indonesia, Malaysia, and Liberia with the location of its mills, crushers, refineries, and biogas operations.

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)?

356113 - The company reports the total landbank controlled for palm oil as 275,037 ha in its Annual Report 2021. However, the RSPO ACOP 2021 reports 356113 ha of total landbank controlled for palm oil. The company has reported contradictory figures( more than 5%) for the same time period.

16. Total oil palm planted area (ha)?

275037 - The figure excludes smallholder areas. Data as of 2021.

17. Scheme smallholders planted area (ha)?

22441 - The company reports total land under scheme smallholders in its RSPO ACOP 2021.

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

14018 - The company reports a total unplanted area in its RSPO ACOP 2021.

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

22413 - The company reports 13594 ha HCV areas and 8819 ha other conservation areas excluding HCV areas.

20. Maps of estates/management units?

The concession boundaries have been made available to the RSPO in 2021 as well as the company uploaded a concession map(s) in shapefile format.

21. Maps of scheme smallholders?

22. Names and locations of all third-party supplying plantations?

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

23. Number of company-owned mills?

33 - The company reports it owns a total of 31 palm oil mills, 15 in Malaysia, 15 in Indonesia, and 1 in Liberia. However, the RSPO ACOP 2021 reports a total of 33 mills. Contradictory figures are published from the same time period.

24. Names and locations of company-owned mills?

The names and locations of company owned mills are available on the company website.

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 31 mills.

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 31 mills. No overall percentages are provided and cannot be calculated.

27. Number of third party supplying mills?

The company reports the list of third party supplying mills in relation to the KLK OLEO traceability.

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

Names and coordinates of all the supplying mills are available.

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 for 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 in March 2020, KLK POMs have achieved 100% traceability to plantations. As for refineries and KCPs, we have achieved 100% traceability to POMs. Additional points are awarded as eight out nine of the company's processing facilities have either SG or IP certification.

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

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

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

As of March 2021, KLK POMs have achieved 100% traceability to plantations. Additional points are awarded as many 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 two refineries with IP certification.

37. Publishes traceability data at refinery level?

Traceability to plantation level is reported by the company for all four of its KCPs.

38. Publishes traceability data at crusher level?

Traceability to plantation level is reported by the company for all of its KCPs. However, the information is not externally verified.

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

[Externally verified] 2004 - The company is 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)?

2021 ACOP is submitted.

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

[Externally verified] 69.15% - The company reports the percentage of area RSPO certified in its RSPO ACOP 2021.

43. Percentage of mills RSPO-certified?

[Externally verified] 69.69% - 23 out of the total 33 mills of the company 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?

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

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

[Externally verified] 7.13% - The company reports the total percentage of scheme/plasma smallholders (ha) RSPO-certified in its RSPO ACOP 2021.

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.

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

[Externally verified] 15.79% - The company reports the percentage of FFB supply (tonnes) from independent smallholders/outgrowers/third-party FFB suppliers that is RSPO-certified in its ACOP 2021.

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

[Externally verified] 18.83% - The company reports the total CSPO and CSPK (in tonnes) and the RSPO certified CSPO and CSPK (in tonnes) in its RSPO ACOP 2021.

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

[Externally verified] The company reports that 46.45% of RSPO-certified palm oil sells through Segregated or Identity Preserved supply chains.

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

[Externally verified] The company reports that 2.2% of RSPO-certified palm oil processes/trades through Segregated or Identity Preserved supply chains.

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

[Externally verified] The company reports that 80% of its estates and 92% of its palm oil mills in Indonesia are ISPO certified. This is externally verified on the Mutu International website.

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company reports that 100% of its estates and palm oil mills in Malaysia are MSPO certified and the certificates 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] ISCC.

55. Commitment to zero conversion of natural ecosystems?

56. Commitment to zero deforestation?

The company commits to zero deforestation.

57. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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

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

The company has only specified the criteria of forests that are not to be deforested in supplier operations.

60. 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.

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

The company has collaborated with Earthqualizer to monitor deforestation in supplier operations through satellite monitoring. However, the company does not report the extent of the area monitored and timeframe. This is also not externally verified.

62. 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. Information is between two and five years old and is not recorded since the RSPO cut-off date of November 2018.

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

64. Commitment to restoration of deforestation/conversion?

The company commits to restore ecosystems to their prior condition in cases of conversion within its own operations.

65. Commitment to restoration of deforestation/conversion applies to all suppliers?

The company states a commitment for its suppliers to develop a Recovery Plan for all non-compliant deforestation and peatland development with a cut-off date of 31 December 2015.

66. Implementing a landscape or jurisdictional level approach?

The company reports running a collaborative forest and biodiversity conservation project in the Berau Regency (East Kalimantan) of Indonesia in collaboration with the Village Forest Management Institution in both the Dumaring and Biatan Ilir Villages (LPHD Dumaring and Biatan Ilir), as well as local authorities in Dumaring and Biatan Ilir. However, this information is not externally verified.

67. 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.

68. Biodiversity policy applies to all suppliers?

69. 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 also reports the list of species of conservation concern however, they are not referenced using an international or national system of species classification.

70. 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 also reports that it works closely with non-governmental organisations and the State Wildlife Agency when rare and endangered species are found within the HCV sites. Their habitats are conserved and appropriate management and monitoring plans are implemented.

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

The company reports its commitment to prohibiting wildlife hunting, but only in HCV set aside areas.

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

The company commits its suppliers to no hunting, but only in HCV set aside areas.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

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

The company commits all suppliers to conduct HCV assessments.

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

[Externally verified] A HCV assessment summary and associated management and monitoring plans are available for PT Anugrah Surya Mandiri and PT Tekukur Indah.

76. High Conservation Value (HCV) assessments for all estates planted since January 2015?

[Externally verified] HCV assessment of PT Karya Makmur Abadi is available on both the HCVRN website and on RSPO NPP, while the HCV assessments of Kuala Gris Estate and PT Putra Bongan Jaya are available only on the RSPO NPP but associated HCV assessment documents not publicly available.

77. High Conservation Value (HCV) management and monitoring plans for all estates planted since January 2015?

[Externally verified] Kuala Gris and Kemasul Estate and PT Karya Makmur Abadi summary reports and management plans are publicly available on RSPO NPP.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

79. 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?

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

[Externally verified] Only PT Karya Makmur Abadi's assessment was publicly available and found to be satisfactory. The company has two combined HCV-HCS assessments since Nov 2017 are publicly available but have not been peer reviewed.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

82. 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.

83. High Carbon Stock (HCS) assessments available?

[Externally verified] High Carbon Stock (HCS) assessments for many concessions of the company are available on the HCSA database.

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

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

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

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

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

[Externally verified] Three SEIAs are publicly available on the RSPO website.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

89. 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.

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

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

The company states that it applies best management practices on peatland that exists within its plantations, including periodically monitoring the water table level and evaluating peatland areas that are planted with oil palm for replanting suitability and drainability requirements. However, no figure of area-specific to peatland was disclosed.

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

The company commits to good agriculture practices for peatland only.

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports its own progress in applying management practices to conserve soils and peat which includes empty fruit bunches and oil palm trunks and fronds being mulched, composted, and recycled as organic materials to maintain soil properties at an optimum level. It also introduces additional holistic practices on peatland protection such as periodical monitoring of water table level and evaluating peatlands planted with oil palm for its suitability for replanting and drainability requirements.

95. Commitment to zero burning?

The company commits to no burning.

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to no burning.

97. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports examples of fire monitoring and management including its collaboration with the local government to provide manpower and machines to combat hotspots even if they are outside our concession areas.

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

The company only states ""the prolonged extremely dry spell experienced in Sumatra and Central Kalimantan during the Fourth Quarter of the FY led to several minor fire incidents inside and outside our concessions"".

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

The company only states ""the prolonged extremely dry spell experienced in Sumatra and Central Kalimantan during the Fourth Quarter of the FY led to several minor fire incidents inside and outside our concessions"".

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

The company commits to reduce GHG emissions intensity by 69% by the year 2022.

101. GHG emissions intensity?

The company reports GHG emission intensity as 0.25 (mt CO2 eq/mt prod vol) for FY 2021.

102. GHG emissions from land use change?

103. Progress towards commitment to reduce GHG emissions intensity?

The company reports progress in GHG intensity but the intensity is not improving. The GHG emissions intensity for FY 2019 was 0.24 mt CO2eq/mt prod vol. FY 2020 was 0.25 mt CO2eq/mt prod vol. and FY 2021 was 0.26 mt CO2eq/mt prod vol. Also, the information reported is not externally verified.

104. Methodology used to calculate GHG emissions?

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

Only seven mills have biogas capture, three in Malaysia and three in Indonesia, and one in Liberia.

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

107. Water use intensity?

0.3 - The company reports that during FY 2021 water consumption intensity was 0.30 (mt CO2eq/mt prod vol).

108. Progress towards commitment on water use intensity?

The company reports a reduction in water use intensity over time specific to palm oil operations. Water Consumption Intensity - (mt CO2eq/mt prod vol) FY2019 - 1.67, FY2020 - 1.43, and FY2021 - 1.30.

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

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

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

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

111. 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 has also reported treatment of palm oil mill effluent in its own repoting.

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

113. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways through buffer zones.

114. 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 has collaborated on a habitat restoration project for wildlife. The project 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 or buffer zones.

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

The company commits to minimise the use of chemical fertilisers and pesticides.

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

The company only commits its suppliers to prohibit the use of highly toxic, bio-accumulative, and persistent pesticides.

117. Commitment to no use of paraquat?

The company commits to not use paraquat.

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

The company commits all suppliers to not use paraquat.

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

The company commits to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits to not use Stockholm and Rotterdam Convention chemicals.

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

The company commits suppliers to not use Stockholm and Rotterdam Convention chemicals.

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

The company reports that the average fertiliser consumption for Malaysia, Indonesia and Liberia is 1.28 mt/ha and the average herbicide consumption for plantation operations is 2.35 litre/ha since 2017.

124. 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 its own information however, the average fertiliser consumption for 2021 (1.28 mt/ha) has increased as compared to 2020 (1.26 mt/ha).

125. Integrated Pest Management (IPM) approach?

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

126. 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 having its own waste management system in place to avoid negative impacts, this includes scheduled waste disposal and repurposing biomass waste for example using empty fruit bunches as fertiliser in plantations.

127. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

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

129. 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 in 2020, it engaged with BSR, a global non-profit sustainable business consultancy, to conduct independent Human Rights Assessments at two selected operations in West Malaysia and Indonesia.

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

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

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

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

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

The company also reports its own commitment to respect legal and customary land tenure rights but only in relation to FPIC.

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

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

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

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

The company commits all suppliers to respect FPIC.

136. 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). Points have therefore been awarded on the basis of the company's commitments under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

137. Examples of local stakeholder engagement to prevent conflicts?

The company reports to host meetings, joint exercises, and training with local communities as well as community outreach activities and development programmes to prevent conflicts. However, the information reported is not externally verified.

138. Details of process for addressing land conflicts available?

139. 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 states examples to support women to become more involved in the industry, it provides facilities such as childcare centers for working parents.

140. Commitment to mitigate impacts on food security?

141. 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.

142. Commitment to provide essential community services and facilities?

143. 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 reports multiple examples in its Corporate Responsibility Report on its progress to provide essential community services and facilities.

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

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

The company commits to all Fundamental ILO Conventions.

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

The company commits all suppliers to all Fundamental ILO Conventions.

147. 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.

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

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

149. 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.

150. 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 it has Gender Committees in place to deal with relevant matters.

151. Percentage or number of temporary employees?

This indicator is disabled as the company has no temporary employees.

152. Percentage or number of women employees?

7496 - The company reports 6497 women employees and workers in plantations and 999 women employees and workers in its KLK Oleo division.

153. Commitment to pay a Decent Living wage?

The company commits to pay a Decent Living Wage to all workers.

154. Commitment to pay a Decent Living wage applies to all suppliers?

155. Progress on commitment to pay a Decent Living wage?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports having a Decent Living Wage Task Force which has developed a template for assessment of Prevailing Wage and in-kind benefits provided to workers. However, no further details are reported on this.

156. Reporting of salary by gender?

157. Commitment to address occupational health and safety?

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

158. 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.

159. 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 provides personal protective equipment (PPE) and related training in relation to palm oil operations.

160. Time lost due to work-based injuries?

The company reports Lost Time Injury Frequency (LTI- Incidents/1 million man-hours worked) rates for KLK plantation: Malaysia (27.74), Indonesia (54.62), and KLK OLEO: Malaysia (1.87), Indonesia (0.00), Other Countries (2.89).

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

4 - The company reports 4 occupational fatalities during FY 2021 in its plantations - Malaysia 2 and Indonesia 2.

162. Commitment to support smallholders?

The company has published a commitment to support smallholders.

163. Programme to support scheme smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports to have an Indonesian Plasma Scheme which is an initiative for the development of oil palm plantations for smallholders and small growers.

164. Percentage of scheme smallholders involved in programme?

6751 - The company states that it has allocated 9840 hectares to approximately 6,751 schemed smallholders under the Plasma Scheme. However, a percentage of the total of the company's scheme smallholders is not provided nor can it be calculated. The information reported is not externally verified.

165. 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 reports running a Bornion Smallholders' Project which helps the participating smallholders and out-growers to obtain the RSPO Certification with the facilitation of Wild Asia.

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

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

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

The company reports that in 2021 it held three workshops and two focus groups on supplier compliance and has an online portal for suppliers to enter in traceability data, as well as an NDPE self-assessment tool.

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

88 - The company reports a total of 88 participants, representing 51% of the third-party supplying mills attended the workshop on the company's requirements. However, the information is not externally verified.

169. 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.

170. 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 total 3rd party volume to KLK OLEO. The remaining 5% covers KLK's own supply.

171. Proportion of direct and indirect supply that comes from palm oil plantations which are compliant with palm oil sourcing policies?

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

The company commits to engage with all high risk mills by the year 2022.

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

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

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

175. 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.

176. 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.

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

178. Commitment to ethical conduct and prohibition of corruption?

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

179. 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.

180. 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 reports that it appointed an independent external consultant to conduct an Anti-Bribery and Anti-Corruption Adequate Procedures Review ("Review") in 2020. The review included a corruption risk assessment and gap analysis, to identify areas for improvement as well as analyse, assess and prioritise corruption risks within the group. The review also included training and awareness programs for the Directors and employees.

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

182. Whistleblowing procedure?

The company has its own whistleblowing policy.

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

The company has its own Group Employee Grievance Redressal Policy (GEGRP).

184. Details of complaints and grievances disclosed?

The company has give detail's of grievances disclosed on there grievances website. The company has given details of grievances disclosed on their website which include: date; issue; complainant category; actions taken; status.