Kulim (Malaysia) 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 communicates this in its own reporting.

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

The company states that it works closely with business partners for the application of the policy for business interest, and also ensures that the policy is communicated to third parties and suppliers, but the compliance of the same by all the suppliers is unclear.

3. High-level position of responsibility for sustainability?

The company has established a Sustainability and Initiative Council, which is chaired by the Chief Operating Officer, Operations Division.

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

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

2 (22.22%) - The company reports that two women members are on the senior management team.

6. Percentage or number of women board members?

1 (10%) - The gender balance is not directly reported by the company, but calculated by board members' profiles.

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

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

The company collaborates with multiple stakeholders to protect local communities and wildlife, such as the Wildlife Conservation Society and the Johor Department of Wildlife. The company also provides opportunities to improve community well-being and livelihoods through collaboration with NGOs to reduce negative environmental or social outcomes associated with palm oil production.

9. Sustainability report published within last two years?

The latest Integrated Report 2021 includes the Sustainability Statement.

10. Reports through standardised reporting systems?

The Sustainability Report 2019 was prepared in accordance with the GRI Standards Core option but, the information is over two years old. However, Integrated Report 2021 is prepared in accordance with GRI Standards but it is unclear if GRI core or comprehensive standards.

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?

The company has 23 plantations in Johor, Malaysia, and two in South Sumatera, Indonesia.

14. Lists countries sourcing from?

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

76192.7 - The company reports total land area managed/controlled for oil palm is 74,511 ha in its Integrated Report 2021. However, RSPO ACOP 2021 reports the same as 76,192.70 ha. Considering the latest figure reported in ACOP 2021.

16. Total oil palm planted area (ha)?

63158 - The company has specified the total area planted with oil palm as 63,158 ha in its Integrated Report 2021. However, ACOP 2021 includes planted and infrastructure areas.

17. Scheme smallholders planted area (ha)?

0 - The RSPO ACOP 2021 reports total scheme smallholders planted area as 0 ha.

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

7224.97 - The company reports 7,224.97 ha unplanted (areas designated for future planting) in its ACOP 2021.

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

1407.35 - The company reports contradictory figures in the same time period. The company reports that it has 276.25 ha as conservation land in its Integrated Report 2021. The RSPO ACOP 2021 reports the same figure for other conservation land set aside, excluding HCV areas (276.25) and 1,131.10 ha for HCV areas. This totals 1,407.35 ha.

20. Maps of estates/management units?

The concession boundaries have been made available to the RSPO and the company declares no new concession acquisition or change in the ownership of existing concessions was undertaken according to ACOP 2021.

21. Maps of scheme smallholders?

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

23. Number of company-owned mills?

5 - The company owns five mills.

24. Names and locations of company-owned mills?

The company has reported all names and coordinates of all the five mills in the GFW Universal Mill List.

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

The company reports that two out of five mills source only from company-owned operations, however, the remaining mills source from company-owned operations and third parties.

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

The company reports that in 2021, FFB produced by its own mills was 1,030,864 (MT), and purchased FFB from external suppliers was 378,273 (MT).

27. Number of third party supplying mills?

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not source from third-party supplying mills.

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

This indicator is disabled as the company does not own refineries.

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

This indicator is disabled as the company does not source from third-party supplying mills.

33. Percentage of supply traceable to mill level?

This indicator is disabled as the company does not source from third-party supplying mills.

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

The company reports that it aims to achieve 100% traceability to suppliers' plantations by 2023 and states that all own supply is traceable to plantation level.

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

The RSPO reports the 86.71% of FFB supplied to own mills is traceable to plantation level. Five mills have IP certification and information is externally verified by Control Union.

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

This indicator is disabled as the company does not source from third-party supplying mills.

37. Publishes traceability data at refinery level?

This indicator is disabled as the company does not own refineries.

38. Publishes traceability data at crusher level?

This indicator is disabled as the company does not own palm kernel crushing facilities.

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

[Externally verified] 2004 - Kulim (Malaysia) joined the RSPO in 2004, and its parent company, Johor Corporation, joined in 2009. Kulim is now reported under its parent company, Johor Corporation.

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 reports RSPO membership since 2004 and almost all plantations have been fully certified since January 2009.

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

Kulim is now reported under its parent company, Johor Corporation which submitted its recent RSPO ACOP 2021.

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

[Externally verified] 80.01% - The 2021 RSPO ACOP reported 80.01% of the area is RSPO-certified.

43. Percentage of mills RSPO-certified?

[Externally verified] 100% - The company reports that all five 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?

This indicator is disabled as the company is only a grower or miller.

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

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

2025 - The company commits to achieve 100% RSPO certification of scheme/associated smallholders and outgrowers by 2025. This is within 5 years.

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

[Externally verified] 7.16% - The company reports the percentage of FFB supply (tonnes) from outgrowers only that are RSPO-certified. However its RSPO ACOP 2021 clearly specifies that the company only sources from outgrowers.

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

This indicator is disabled as the company is only a grower or miller.

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

[Externally verified] The company sells 58.72% RSPO-certified palm oil through Segregated or Identity Preserved supply chains.

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

This indicator is disabled as the company only reports a Grower ACOP.

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

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] The company reports that 100% of its estates and mills were MSPO certified since 2019.

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

[Externally verified] The company reports that all its mills are ISCC certified and also, to maintain the highest quality in its process, it complies with the Environmental Management System ISO 14001:2015.

55. Commitment to zero conversion of natural ecosystems?

The company commits to "zero conversion of natural ecosystems", this does not clearly apply to all natural ecosystems and no reference is made to the AFI definition.

56. Commitment to zero deforestation?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have been therefore 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.

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?

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.

59. Criteria and cut-off date for defining deforestation 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. The company reports that it monitors deforestation in its supply base through its subscription to Global Forest Watch satellite provider on a monthly basis. The monitoring covers its buffer zone boundary along forest reserve areas. This data is externally verified by Control Union.

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

[Externally verified] The company reports it uses Global Forest Watch satellite monitoring to continuously monitor deforestation in supplier operations. It does not report the extent of the area monitored. This information is externally verified by Control Union.

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

The company reports that it did not detect any evidence of deforestation within its concessions in 2022. The figure is not reported since the RSPO cut-off date of 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 applying the RSPO Remediation and Compensation Procedure where there has been land clearing without prior HCV assessment since November 2005, or without prior HCV-HCSA assessment since November 2018, through the RSPO Principles and Criteria 2018. However, a commitment covering restoration of all non-compliant deforestation/conversion was not found. Partial 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.

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

The company commits all suppliers to restoration of deforestation or conversion but does not specify a cut-off date beyond which deforestation or conversion would not be accepted.

66. Implementing a landscape or jurisdictional level approach?

The company reports that it supports sustainable development activities like investing in training and development of employees and promoting optimum land use to ensure long-term sustainability and productivity for agricultural use. However, it is not clear if efforts are at a landscape or jurisdictional level. This data is externally verified by Control Union.

67. Biodiversity policy?

The company commits to promoting the conservation and development of biodiversity, however this does not clearly apply both within and outside of 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.

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 states that it has been maintaining wildlife corridors linking natural habitats within its estates since 2011. The company through its conservation group, KWD, collaborates with the Johor National Parks Corporation, Wildlife Department, Forestry Department, and the Police on anti-poaching programmes.

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

The company commits to no hunting of all species in its operations.

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

The company commits suppliers to "no illegal or inappropriate hunting", it is not a clear commitment too hunting or only sustainable hunting of species.

73. 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 communicates this in its own reporting.

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

The company states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. However, compliance of the same by all suppliers is unclear.

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

[Externally verified] There is public availability of the following HCV assessments: PT Harapan Barito Sejahtera and PT Sawit Sumber Rejo.

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

This indicator is disabled as the company has not undertaken any new planting since January 2015.

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

This indicator is disabled as the company has not undertaken any new planting since January 2015.

78. 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.

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?

This indicator is disabled as the company has not undertaken any new planting since January 2015.

81. 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 communicates this in its own reporting.

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

The company states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. However, compliance of the same by all the suppliers is unclear.

83. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company has not undertaken any new planting since January 2016.

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

This indicator is disabled as the company is: only a processor/trader; or has had no new planting since April 2015, unless it has undertaken HCS assessments that are not for new planting; or all new planting is since November 2017 AND has all been covered under combined HCV-HCS assessments.

85. 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. The company also communicates this in its own reporting.

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] There is public availability of the following SEIAs: PT Harapan Barito Sejahtera and PT Sawit Sumber Rejo.

88. 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 communicates this in its own reporting.

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)?

15721 - The company has 1,274 ha of peat land in Malaysia and 14,447 ha in Indonesia as of 31 December 2021.

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

The company reports its landbank on peat in 2019 was 1,380 ha, however, in 2021 the company reported 1,274 ha of peat land in Malaysia and 14,447 ha in Indonesia.

92. 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 has a commitment to best management practices for peat only.

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

The company states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. However, compliance of the same by all suppliers was unclear.

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 reports that it has enhanced its water management system by constructing weirs in strategic locations to maintain optimum water levels on peat soil while pumping out excess water using two 160 Kilovolt AMP (KVA) gensets and eight units of 30-horse power water pumps.

95. 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 has a commitment to zero burning.

96. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero 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 has subscribed to GeoRSPO to monitor concession areas by satellite technology and report hotspots and fires at its own estates. It also conducts training on firefighting and set up fire monitoring towers for every 500 ha of the plantation, and a station for a Fire Emergency Response Team.

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

The company reports there were no fires in its concessions in 2021.

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

3 - The company reports that there were three recorded fires within surrounding landscapes in 2021.

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

The company commits to reduce GHG emissions intensity by 50% by the year 2025.

101. GHG emissions intensity?

The company reports its GHG emissions intensity as 1.13 MT CO2 e per MT of CPO and PK in 2021.

102. GHG emissions from land use change?

This indicator is disabled as the company has not undertaken any new planting since January 2015.

103. Progress towards commitment to reduce GHG emissions intensity?

The company reports that net emissions have decreased from over 1.25 MT CO2 (MT CPO/PK) in 2019 to 1.23 MT CO2 (MT CPO/PK) in 2020 to 1.13 MT CO2 e per MT (MT CPO/PK) in 2021. However, the data is not externally verified.

104. 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. The company practices management methods prescribed by RSPO that includes the utilisation of the PalmGHG V4 calculator to identify the Group's gross carbon emissions on an annual basis.

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

The company reports only three out of five mills or 60% of the total of its mills were equipped with biogas plants that capture methane.

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

The company's reduction target was achieved at 1.10 m3 per tonne FFB in 2020.

107. Water use intensity?

1.11 - The company reports its water use intensity as 1.11 m3 per tonne FFB in 2021.

108. Progress towards commitment on water use intensity?

The company reports progress towards commitment on water use intensity in m3 per tonne FFB; 1.17 (2017), 1.10 (2018), 1.06 (2019), 1.10 (2020), 1.11 (2021). However, the intensity is not improving, and also intensity reported in 2021 is not within the target. The information is not externally verified.

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

The company reports that it strives to keep BOD levels "in line with the Johor Department of Environment requirements". This is an unclear commitment.

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

[Externally verified] The company reports an average reduction in the BOD level from 2015-2019, figures decreased from 2015-2017 and then went up in 2018 and decreased again in 2019 to a level that is higher than in 2017. Control Union reports that the company has been successful in maintaining the BOD below he Johor Department of Environment requirements but does not specify what the legal limits are.

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 also claims to treat palm oil mill effluent (POME).

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

This indicator is disabled as the company does not own refineries.

113. 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 has a commitment 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 reports the implementation of commitment to protect natural waterways through buffer zones.

115. 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 states it minimises the use of chemicals in its own reporting.

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

The company states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. However, compliance of the same by all# suppliers is unclear. The policy only refers to minimising chemical use and not pesticides or fertilisers specifically.

117. 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.

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

119. 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.

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

121. 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.

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

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

The company reports chemical usage of herbicide and paraquat (active ingredients in litre/hectare).

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 states an example of implementation of its commitment to reducing water pollution from heavy metals, wherever feasible the group combines inorganic with organic fertilisers derived from EFB.

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 states that it has an Integrated Pest Management (IPM) approach.

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 has a waste management system in place to avoid negative impacts.

127. 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 provides a commitment to human rights in its own reporting.

128. Commitment to human rights applies to all suppliers?

The company states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. However, compliance of the same by all suppliers is unclear.

129. Progress on human rights commitment?

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

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

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

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

132. 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 has its own commitment to respect legal and customary land tenures.

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

The company states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. However, compliance of the same by all suppliers is unclear.

134. 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 has an explicit commitment to FPIC.

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

The company states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. However, compliance with the same by all suppliers is unclear.

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). 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.

137. Examples of local stakeholder engagement to prevent conflicts?

138. 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.

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 is providing a platform for women to air their grievances, through WOW programme which supports and promotes gender equality as well as advances the knowledge and skills of its female employees.

140. 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. The company has also stated in its report that it embraces the national food security programme.

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?

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 provide a better quality of life to the workers and the community living nearby.

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 provides information on its contribution to the progress of the programmes such as Kelab Bola Sepak Johor Darul Takzim, Yayasan Johor Corporation, Kulim "X" MyFundAction, Tabung Bantuan Banjir JCorp, Johor Cerebral Palsy Association, School Uniform Project.

144. 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. The company also has a commitment in its own reporting.

145. 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 communicates this in its own reporting.

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

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. Control Union has externally verified some activities.

148. 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.

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

The company's commitment to eliminate discrimination with regard to employment is applicable to all external stakeholders but not specific to suppliers and it is also unclear if it relates to gender discrimination.

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 has launched a WOW programme, to support and promote gender equality, and also to advance the knowledge and skills of its female employees. This information is externally verified by Control Union.

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?

12.4% - The company reports the total percentage of women in the workforce is 12.40% in 2021.

153. Commitment to pay a Decent 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 only commits to pay minimum wages under Minimum Wages Order 2020.

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.

156. Reporting of salary by gender?

The company reports the average basic salary ratio of males to females is 0.94:1.06. However, the ratio of the basic salary and remuneration of women to men for each employee category, by significant locations of operation, is not included.

157. 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 has its own occupational health and safety policy.

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. Control Union reports that the company has conducted training on PPE.

160. Time lost due to work-based injuries?

1.03 - The company reports its Lost Time Accident Rate (LTAR) as 1.03 in the year 2021.

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

0 - The company reports zero fatalities as a result of work-based accidents in 2021.

162. 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.

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 has a Smallholder Inclusion Programme, in which it pays a premium of RM2 per tonne of certified FFB purchased to encourage the adoption of sustainability certification. It has also made payments to two certified scheme smallholders that supply them. In 2021, this premium was increased to RM6 per tonne of certified FFB to encourage more smallholders to apply for RSPO certification. This information is externally verified by Control Union.

164. Percentage of scheme smallholders involved in programme?

2 - The company has a Smallholder Inclusion Programme, in which it pays a premium of RM2 per tonne of certified FFB purchased to encourage the adoption of sustainability certification. It has also made payments to two certified scheme smallholders that supply them. However, the company provides some numbers of scheme smallholders supported, but it is unclear what the percentage is.

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 reports that it supports independent smallholders in their certification and has programmes to assist with this. It also provides technical support wherever possible. This information is externally verified by Control Union.

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

[Externally verified] The company reports that three out of 30 outgrowers have been RSPO certified while another 27 are working towards it. However it is unclear how many independent smallholders/outgrowers are involved in programme.

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

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

[Externally verified] 100% - Control Union reports that 100% of the company's suppliers are assessed and/or engaged on compliance with the company's FFB purchasing agreement.

169. Suspension or exclusion criteria for suppliers?

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

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?

This indicator is disabled as the company does not source from mills.

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

This indicator is disabled as the company does not source from mills.

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

This indicator is disabled as the company does not source from mills.

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

This indicator is disabled as the company is only a grower or miller.

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

This indicator is disabled as the company is only a grower or miller.

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

This indicator is disabled as the company is only a grower or miller.

178. 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 has a commitment to ethical conduct and 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 has ABMS awareness programmes under which it conducts training for directors and a Bribery Risk Assessment to identify and evaluate the exposures within the Group to mitigate and prevent potential risks in 2021. Control Union externally verified the publication of the anti-bribery and corruption policy in 2021.

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

182. 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 a whistleblowing policy that enables internal and external stakeholders to report cases.

183. 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 open to all stakeholders.

184. Details of complaints and grievances disclosed?

The company states that "No grievances were raised in 2018 and 2019".