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Established in 1933, Kulim (Malaysia) is a subsidiary of the Johor Corporation. Kulim is engaged

  • Parent company:
    Johor Corporation
  • Landbank (oil palm):
    115,378 hectares
  • Bloomberg ticker:
    Private company
  • RSPO member?
    Yes
  • Website:

Company assessment: Kulim (Malaysia) Bhd – November 2017

SPOTT assesses companies against over 100 indicators across ten categories. Click on the icons or bars below to expand each category for further details, scoring and links to reports and sources.

Assessment date:

Total: 56.5% 67.5 / 119.5
  • Sustainability policy and leadership Sustainability policy and leadership 3.5 / 6 58.3%
    • Companies should publish sustainability policies or similar covering their entire supply chain — including third party suppliers — implemented and enforced through high-level leadership that engages with wider industry schemes.

    • Yes
      1 / 1
      Source

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

      The company has a Sustainability Handbook that details its policies

    • No
      0 / 1
      Source

      2. Policy or commitment applies to direct and third-party suppliers?

    • Yes
      1 / 1
      Source

      3. High-level position of responsibility for sustainability?

      The Sustainability Department is headed by a Deputy Manager

    • Yes
      1 / 1
      Source

      4. Sustainability report published within last two years?

      The company includes a sustainability report in their 2016 annual report

    • No
      0 / 1
      Source

      5. Member of multiple industry schemes or other external initiatives to improve sustainability in relation to palm oil?

    • n/a
      -
      No source

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

      This indicator is disabled as it is not applicable to this company.

    • Partial
      0.5 / 1
      Source

      7. Activities with government and/or NGOs to improve palm oil sustainability?

      The company collaborates with NOG's and governments on the issues of poaching and encroachment, but are not focussed on wider sustainability issues

  • Landbank, maps and traceability Landbank, maps and traceability 8.5 / 13 65.4%
    • Companies should publicly report figures on their total landbank and details of different areas under their management. They should also disclose maps of their management areas and provide details on traceability of their products, both to mill and plantation level.

    • Yes
      1 / 1
      Source

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

      115,378 - The company also reports an area of 164,494 ha in its 2016 ACOP however this seems like a reporting error, as it clearly states in its 2016 Annual Report that its total landbank is 115,378 ha

    • Yes
      1 / 1
      Source

      9. Total oil palm planted area (ha)?

      55,680 - The company also reports a planted area of 117,013 ha in its 2016 ACOP however this seems like a reporting error, as it clearly states in its 2016 Annual Report that its total planted area is 55,680 ha

    • Partial
      0.5 / 1
      Source

      10. Plasma/scheme smallholders planted area (ha)?

      2,683.47 - 0ha reported in RSPO ACOP 2016. Data more than one year old

    • Yes
      1 / 1
      Source

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

      38,947.2 - Kulim is now being reported on under its parent company, Johor Corporation

    • Yes
      1 / 1
      Source

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

      8,533.89 - Sum of HCV areas and other conservation areas. Kulim is now being reported on under its parent company, Johor Corporation

    • Partial
      0.5 / 1
      Source

      13. Area for infrastructure (ha)?

      3,500 - The company reports 3,500 hectares to include "reserved land, building, sites etc." Not clearly just for infrastructure

    • Yes
      1 / 1
      Source

      14. Number of company owned mills?

      5 - Kulim is now being reported on under its parent company, Johor Corporation

    • Partial
      0.5 / 1
      Source

      15. Maps or coordinates of company owned mills?

      Mill locations have been made available on Global Forest Watch. However, ZSL is currently unable to ascertain if the maps disclosed constitute 100% of the company's palm oil mills

    • n/a
      -
      No source

      16. Number and names of supplier mills?

      This indicator is disabled as it is not applicable to this company.

    • Yes
      1 / 1
      Source

      17. Maps of estates/management units?

      Concession boundaries have been made available to the RSPO and the company declares these represent 100% of their concession sites, but not all may not be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO

    • No
      0 / 1
      No source

      18. Maps of scheme/plasma smallholders?

    • n/a
      -
      No source

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

      This indicator is disabled as it is not applicable to this company.

    • No
      0 / 1
      No source

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

    • n/a
      -
      No source

      21. Percentage of supply traceable to mill level (above 80%)?

      This indicator is disabled as it is not applicable to this company.

    • Partial
      1 / 2
      Source

      22. Percentage of fresh fruit bunches (FFB) from own mills traceable to plantation level (is above 75%)?

      26.5% - The RSPO reports the company has two mills that are identity preserved, covering 30,618 ha. This means that approximately 26.5% is traceable to plantation out of a total landbank of 115,378 ha

    • n/a
      -
      No source

      23. Percentage of fresh fruit bunches (FFB) from supplier mills traceable to plantation level (is above 75%)?

      This indicator is disabled as it is not applicable to this company.

  • Deforestation and biodiversity Deforestation and biodiversity 8.5 / 12 70.8%
    • Companies should commit to address deforestation and to set aside areas for conservation. They should report on any activities to manage or restore habitat in their conservation areas, or monitor deforestation in their supply chains. They should also provide evidence of species conservation and biodiversity protection.

    • Yes
      0.5 / 0.5
      Source

      24. Commitment to address deforestation?

    • Yes
      1 / 1
      Source

      25. Commitment to zero deforestation?

    • No
      0 / 1
      No source

      26. Deforestation commitment applies to scheme smallholders and independent suppliers?

    • Yes
      1 / 1
      Source

      27. Criteria for defining deforestation?

      HCV, primary forest, peat areas

    • No
      0 / 1
      Source

      28. Evidence of monitoring deforestation?

      The company only states that "Special attention will be given to FFB traders who provide services to outgrowers who own land assets near primary forests and peat land. Closer monitoring mechanism will be established to strengthen our commitment to prevent any exploitation of HCV areas for oil palm cultivation"

    • Yes
      1 / 1
      Source

      29. Commitment to set aside areas for conservation?

    • Yes
      1 / 1
      Source

      30. Evidence of habitat management and/or habitat restoration?

      The company launched the Natural Corridor Initiative, that links natural habitats separated by human modified landscapes. "To create these natural corridors we have an annual tree planting event rebranded as Infaq 1 Warisan, which brings together employees as well as members of the public to play their part in enhancing biodiversity in our estates"

    • Partial
      0.5 / 1
      Source

      31. A landscape-level approach?

      The company states "In any development, Kulim will also take into account the conservation of biodiversity and the protection of cultural and customary land use within the context of a sustainably managed landscape" but no further details are given. The company also has a natural corridor initiative to plant wildlife corridors

    • Yes
      0.5 / 0.5
      Source

      32. Commitment to biodiversity conservation?

    • Yes
      1 / 1
      Source

      33. Commitment to not endanger species of conservation concern, referencing international or national system of species classification?

      The company states it is committed to protecting the national biodiversity and endangered species, and makes reference to the IUCN Red List

    • Yes
      1 / 1
      Source

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

    • No
      0 / 1
      No source

      35. Commitment not to operate within internationally and nationally designated protected areas?

    • Yes
      1 / 1
      Source

      36. Evidence of species conservation activities?

      The company undertakes anti-poaching activities, build wildlife corridors and donate to the Orangutan Land Trust

  • HCV, HCS and impact assessments HCV, HCS and impact assessments 4.5 / 10 45%
    • Companies should commit to the High Conservation Value (HCV) and High Carbon Stock (HCS) approaches, and to conduct social and environmental impact assessments (SEIA). They should develop and publish monitoring and management plans, and provide evidence through SEIA, HCV and HCS assessments, typically published in summary form due to the sensitive nature of certain sites.

    • Yes
      1 / 1
      Source

      37. Commitment to High Conservation Value (HCV) approach?

    • No
      0 / 1
      No source

      38. HCV commitment applies to scheme smallholders and independent suppliers?

    • Partial
      0.5 / 1
      Source

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

      The company does not have a explicit commitment itself, but commits under the RSPO NPP through its parent company Johor Corporation being an RSPO member

    • Yes
      1 / 1
      Source

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

      There is public availability of the following HCV assessments:
      Central Kalimantan: PT Harapan Barito Sejahtera, PT Sawit Sumber Rejo, PT Wahana Semesta Kharisma

    • No
      0 / 1
      Source

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

      The company states that 307 hectares were planted according to RSPO NPP procedures in Indonesia in 2015 but no HCV assessments found

    • No
      0 / 1
      Source

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

      The company states that 307 hectares were planted according to RSPO NPP procedures in Indonesia in 2015 but no HCV management and monitoring plans found

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      44. Commitment to the High Carbon Stock (HCS) approach?

    • n/a
      -
      Source

      45. High Carbon Stock (HCS) assessments?

      This indicator is disabled as according to 2016 RSPO ACOP no new planting has occurred

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

      47. Social and environmental impact assessment (SEIAs) undertaken, and associated management and monitoring plans?

      There is public availability of the following SEIA assessments:
      Central Kalimantan: PT Harapan Barito Sejahtera, PT Sawit Sumber Rejo, PT Wahana Semesta Kharisma

  • Peat, fire and GHG emissions Peat, fire and GHG emissions 9 / 17 52.9%
    • Companies should commit to protect peatland and undertake best management practices for soils and peat. They should also have policies on zero burning and to reduce their greenhouse gas (GHG) emissions. Companies should report their GHG emissions, as well as any fires that occurred in or around their estates, along with plans for managing and monitoring fires.

    • Partial
      0.5 / 1
      Source

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

      The company states it has an on-going commitment to no peat development but they do not specify of any depth

    • No
      0 / 1
      No source

      49. Peat commitment applies to scheme smallholders and independent suppliers?

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

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

      1,380

    • Partial
      0.5 / 1
      Source

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

      The company only details best management practices for soils

    • Partial
      0.5 / 1
      Source

      53. Commitment to zero burning?

      The company only states it has a zero-burning approach for replanting

    • No
      0 / 1
      No source

      54. Zero burning commitment applies to scheme smallholders and independent suppliers?

    • No
      0 / 1
      No source

      55. Evidence of management and monitoring fires?

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

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

    • Yes
      1 / 1
      Source

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

      The company states "Kulim targets to cut the Group's overall carbon footprint to 58% by 2020"

    • No
      0 / 1
      No source

      59. GHG commitment applies to scheme smallholders and independent suppliers?

    • Yes
      1 / 1
      Source

      60. GHG emissions?

    • Yes
      1 / 1
      Source

      61. GHG emissions from land use change?

    • Yes
      1 / 1
      Source

      62. Methodology used to calculate GHG emissions?

      PalmGHG Version 3.0.1

    • Yes
      1 / 1
      Source

      63. Progress towards commitment to reduce GHG emissions?

    • Partial
      0.5 / 1
      Source

      64. Percentage of mills with methane capture (is above 75%)?

      2 (40%)

  • Water, chemical and pest management Water, chemical and pest management 8 / 12 66.7%
    • Companies should commit to managing water use and water quality, providing evidence through time-bound reduction plans, policies on toxic chemical use and treatment of palm oil mill effluent (POME).

    • Yes
      1 / 1
      Source

      65. Time-bound commitment to improve water use?

      The company has an on-going target to reduce water usage to 1.2 m3 per tonne of FFB which was met in 2016 at 1.15 m3 per tonne FFB

    • Partial
      0.5 / 1
      Source

      66. Time-bound commitment to improve water quality?

      The company only has a commitment to "maintain the quality of ground and surface waters" and seeks to prevent pollution, but does not have a time-bound commitment

    • Yes
      1 / 1
      Source

      67. Progress towards commitment on water use?

      The company has an on-going target to reduce water usage to 1.2 m3 per tonne of FFB which was met in 2016 at 1.15 m3 per tonne FFB

    • No
      0 / 1
      No source

      68. Progress towards commitment on water quality?

    • Yes
      1 / 1
      Source

      69. Protection of natural waterways through buffer zones?

    • Partial
      0.5 / 1
      Source

      70. Evidence of treating palm oil mill effluent (POME)?

      The company only states that organic fertilisers are produced from treated and dried POME, but no further details are given

    • Yes
      1 / 1
      Source

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

    • Yes
      1 / 1
      Source

      72. No use of paraquat?

    • No
      0 / 1
      No source

      73. No use of World Health Organisation (WHO) Class 1A and 1B pesticides?

    • No
      0 / 1
      No source

      74. No use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

    • Yes
      1 / 1
      Source

      75. Integrated Pest Management (IPM) approach?

    • Yes
      1 / 1
      Source

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

      Herbicide use per hectare

  • Community, land and labour rights Community, land and labour rights 10 / 18 55.6%
    • Companies should commit to respect human rights, including those of indigenous peoples and local communities, consulted with free, prior and informed consent (FPIC). Companies should respect the rights of workers, report relevant workforce data, and comply with health and safety legislation.

    • No
      0 / 1
      No source

      77. Commitment to human rights, referencing the UN Declaration of Human Rights or UN Guiding Principles on Business and Human Rights?

    • Partial
      0.5 / 1
      Source

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

      The company only states that they take into account the protection of cultural and customary land use but no reference customary ownership rights or legal land rights

    • No
      0 / 1
      No source

      79. Commitment to respect indigenous and local communities' rights, referencing the UN Declaration on the Rights of Indigenous Peoples or ILO 169?

    • Yes
      1 / 1
      Source

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

    • No
      0 / 1
      No source

      81. FPIC commitment applies to independent suppliers?

    • No
      0 / 1
      No source

      82. Free, prior and informed consent (FPIC) process?

    • No
      0 / 1
      No source

      83. Process for addressing land conflicts?

    • Partial
      0.5 / 1
      Source

      84. Commitment to ensure food security for local communities?

      The company only mentions a commitment to national food security

    • Partial
      0.5 / 1
      Source

      85. Commitment to respect all workers' rights?

      The company has a commitment to protect labour rights but it is not clear if this is for all workers

    • Yes
      1 / 1
      Source

      86. Reference to Fundamental ILO Conventions or Free and Fair Labour Principles?

    • Yes
      1 / 1
      Source

      87. Total number of employees?

      8,487

    • No
      0 / 1
      No source

      88. Percentage or number of temporary employees?

    • Yes
      1 / 1
      Source

      89. Percentage or number of women employees?

      11.5%

    • Partial
      0.5 / 1
      Source

      90. Minimum wage that the company pays?

      The company states "Kulim labour policies are grounded on good labour practices and its commitment to protect labour rights with the implementation of non-discriminatory policies, minimum wage, overtime wages, freedom of association and the right to collective bargaining", but it is not clear if this applies to all workers

    • Yes
      1 / 1
      Source

      91. Commitment to address occupational health and safety?

    • Yes
      1 / 1
      Source

      92. Lost time accident rate?

      3.51

    • Yes
      1 / 1
      Source

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

      0

    • Yes
      1 / 1
      Source

      94. Provision of personal protective equipment and pesticide training?

  • Certification standards Certification standards 8.5 / 15.5 54.8%
    • Companies should become members of credible certification standards and report in accordance with all appropriate categories of membership. The Roundtable on Sustainable Palm Oil (RSPO) requires members registered as growers to submit data relating to certification targets for their estates, scheme smallholders and independent fresh fruit bunch (FFB) suppliers, via an annual communications of progress (ACOP) report.

    • Yes
      1 / 1
      Source

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

      2004 - Kulim (Malaysia) joined the RSPO in 2004, and its parent company, Johor Corporation, joined in 2009. Kulim is now being reported on under its parent company, Johor Corporation

    • Yes
      0.5 / 0.5
      Source

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

      Kulim is now being reported on under its parent company, Johor Corporation

    • Yes
      0.5 / 0.5
      Source

      97. Listed all countries and regions in which operates in most recent RSPO Annual Communication of Progress (ACOP)?

      The company reports it operates in Indonesia (Central Kalimantan, South Sumatra) and Malaysia (Johor, Pahang)

    • No
      0 / 0.5
      Source

      98. Time-bound plan for achieving 100% RSPO certification of estates within 5 years or achieved 100% RSPO-certification of estates?

      2025 - Time-bound plan more than 5 years away

    • No
      0 / 0.5
      Source

      99. Time-bound plan for achieving 100% RSPO certification of scheme/associated smallholders within 5 years or achieved 100% RSPO-certification of scheme/associated smallholders?

      2025 - Time-bound plan more than 5 years away

    • n/a
      -
      No source

      100. Time-bound plan for achieving 100% RSPO certification of all supply chains?

      This indicator is disabled as it is not applicable to this company.

    • Yes
      0.5 / 0.5
      Source

      101. RSPO-certified within three years of joining the RSPO or by November 2010, for companies joining prior to finalisation of the RSPO certification systems in November 2007?

      2009

    • Yes
      2 / 2
      Source

      102. Percentage of mills RSPO-certified (is above 75%)?

      5 (100%)

    • Partial
      1.5 / 2
      Source

      103. Percentage of area (ha) RSPO-certified (is above 75%)?

      60,637.9 (52.6%)

    • No
      0 / 2
      Source

      104. Percentage of scheme/associated smallholders (ha) RSPO-certified (is above 75%)?

      0 (0%)

    • Partial
      0.5 / 2
      Source

      105. Percentage of FFB supply (tonnes) from independent FFB suppliers that is RSPO-certified (is above 75%)?

      27,263.8 (7.5%) - The company reports that 27263.75 tonnes out of 53123.94 tonnes from outgrowers is certified, and that 0 tonnes out of 311653 tonnes from other 3rd party suppliers is certified

    • n/a
      -
      No source

      106. Percentage of all palm oil and oil palm products handled/traded/processed (tonnes) that are RSPO-certified (is above 75%)?

      This indicator is disabled as it is not applicable to this company.

    • Yes
      1 / 1
      Source

      107. Sells or processes/trades RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

      Book & Claim, Mass Balance, Identity Preserved

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      109. Malaysia Sustainable Palm Oil (MSPO) certified (100%)?

    • Yes
      1 / 1
      Source

      110. Certified under voluntary sustainability certification scheme (e.g. ISCC, SAN, RSB, etc.)?

      ISCC, ISO 14001

  • Smallholders and suppliers Smallholders and suppliers 2.5 / 9 27.8%
    • Companies should report details of any programmes or schemes to support both schemed and independent smallholders, as well as criteria to assess suppliers on compliance with company policies, and in what cases suppliers should be suspended or excluded due to non-compliance.

    • No
      0 / 1
      No source

      111. Programme to support scheme smallholders?

    • No
      0 / 1
      No source

      112. Details of support programme for scheme smallholders?

    • No
      0 / 1
      No source

      113. Number or percentage of scheme smallholders involved in programme?

    • Yes
      1 / 1
      Source

      114. Programme to support independent smallholders?

    • Yes
      1 / 1
      Source

      115. Details of support programme for independent smallholders?

      Assisting outgrowers or smallholder in achieving certification, incentives given for RSPO certified FFB, assisting outgrowers or smallholder in good agriculture practice and legal compliance

    • Partial
      0.5 / 1
      Source

      116. Number or percentage of independent smallholders involved in programme?

      The company states that "So far, two (2) outgrower groups have achieved certification and we continue to work with other outgrowers"

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      118. Suspension or exclusion criteria for suppliers?

    • No
      0 / 1
      No source

      119. Number or percentage of suppliers assessed and/or engaged?

  • Governance and grievances Governance and grievances 4.5 / 7 64.3%
    • Companies should operate in an ethical manner at all levels, providing accessible channels and clear procedures for both employees and external stakeholders to raise any grievance or complaint with the company, as well as allowing for whistleblowing.

    • Yes
      1 / 1
      Source

      120. Commitment to ethical conduct and prohibition of corruption?

    • Yes
      1 / 1
      Source

      121. Whistleblowing procedure?

    • Partial
      0.5 / 1
      Source

      122. Own grievance or complaints system?

      The company has a grievance system but cannot report all issues

    • Yes
      1 / 1
      Source

      123. Grievance system accessible to internal stakeholders (i.e. employees)?

    • Yes
      1 / 1
      Source

      124. Grievance system accessible to external stakeholders?

    • No
      0 / 2
      No source

      125. Details of grievances disclosed?

Media monitor: Kulim (Malaysia) Bhd

SPOTT gathers reports and stories from global media sources, covering specific company activities related to the assessment indicator categories. ZSL does not assess the validity of these reports.

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Research protocols: Kulim (Malaysia) Bhd

Research protocols guide how ZSL conducts SPOTT assessments and allocates scores to ensure a fair and consistent approach, setting the expectations for companies on how they should publish ESG data. The full palm oil indicator framework contains 125 indicators across 10 categories, aligned with corporate reporting initiatives.

Map of concessions: Kulim (Malaysia) Bhd

Explore our interactive mapping tool for a satellite view of deforestation and fires in and around concession sites of companies featured on the SPOTT scorecard. These data can support SPOTT users in conducting further research to verify whether or not company commitments are being implemented on the ground.

Use the map search bar to find specific company concessions or locations. Click the concession sites marked by pins to zoom in for more information, then go to the company pages of featured concessions to view their assessments.

Some of Kulim's mills are available on Global Forest Watch; however, ZSL is currently unable to ascertain if the maps disclosed constitute 100% of the company's palm oil mills. Concession boundaries have been made available to the RSPO and the company declares these represent 100% of their concession sites, but not all may not be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO. Some of the concessions are available on the SPOTT map.

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