Sarawak Oil Palms Bhd

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

SOPB Oil Palms Sustainability Policy (OPSP).

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

The company's policy states "SOPB expected its external suppliers and contractors to fully comply with this commitment by January 2020, where MSPO is mandated".

3. High-level position of responsibility for sustainability?

The company states it has a Group Sustainability Committee (GSC), led by the CEO, and that "the GSC is responsible for overall policy implementation", reporting and stakeholder engagement.

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

The company states "The Sustainability Governance structure comprises of the Board of Directors (BOD), Group Management Committee (GMC) and Group Sustainability Committee (GSC).".

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

Male titles are used for all ten members of the senior management team. Gender balance is not directly reported by the company.

6. Percentage or number of women board members?

2 (16%) - The company reports having two female board members as of 2018.

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

[Externally verified] Sarawak Oil Palm Plantation Owners Association (SOPPOA).

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

The company reports taking part in various meetings and training sessions to support MSPO certification processes and uptake, as well as collaboration with both governmental bodies and universities in various research projects relating to palm oil sustainability.

9. Sustainability report published within last two years?

Sustainability report included in 2019 annual report.

10. Reports through standardised reporting systems?

The company's latest annual report is prepared in accordance to GRI standards but not published on the GRI website.

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

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

12. Climate risks assessment available?

The company only states "The Company plantations are exposed to the risk of damages from climatic charges, diseases, forest fires and other natural forces. The Company has underlying best plantation practices and policy in place aimed at monitoring and mitigating those risks.".

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

121,994 - The company reports its total area under lease.

14. Total oil palm planted area (ha)?

87,571 - Total planted area.

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

2,334 - Native Customary Rights (NCR) land development.

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

21 - Land held for future development.

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

210 - A peat swamp forest of 210 ha located in Tinbarap Estate had been designated for conservation since 2015.

18. Maps of estates/management units?

Some of the company's concessions are available on GFW. A company webpage lists the addresses of its estates, but these do not allow the exact locations or boundaries of the estates to be determined. The company also has a request form on its website to request estate location maps.

19. Maps of scheme/plasma smallholders?

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

21. Number of company-owned mills?

7 - The company operates seven mills in Malaysia.

22. Names and locations of company-owned mills?

The company publishes the locations of all seven mills.

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

All mills source from company-owned and third party operations.

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

65% of FFB is sourced from company-owned estates and the rest from third party operations.

25. Number of third party supplying mills?

36

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

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

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

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

The company's refinery sources directly from mills.

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

The company has achieved 100% traceability to mill level.

31. Percentage of supply traceable to mill level?

The company has achieved 100% traceability to mill level.

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

The company commits to be fully traceable to plantation level by the end of 2021.

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

Since 2014, all SOPB palm oil mills are 100% traceable to the plantation level.

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

35. Publishes traceability data at refinery level?

The company reports traceability data for its refinery to mill level only.

36. Publishes traceability data at crusher level?

The company reports traceability data for its crusher to mill level only.

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

The company has informed ZSL that it is in the process of applying.

38. 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?

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

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

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

42. Percentage of mills RSPO-certified?

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

44. Year expected to achieve 100% RSPO certification of all palm product processing facilities?

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

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

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

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

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

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

This indicator is disabled as the company does not operate in Indonesia.

51. Malaysia Sustainable Palm Oil (MSPO) certified?

The company states it has achieved 100% MSPO certification of its estates, mills and processing facilities.

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

ISCC.

53. Commitment to zero deforestation or zero conversion of natural ecosystems?

The company commits to the protection of HCV, HCS and peat areas.

54. Commitment to zero deforestation or zero conversion of natural ecosystems applies to all suppliers?

The company's policy states "SOPB expected its external suppliers and contractors to fully comply with this commitment by January 2020, where MSPO is mandated".

55. Criteria for defining deforestation?

The company commits to no development of HCV, HCS areas and peat with a cut-off date of January 2020.

56. Evidence of monitoring deforestation?

57. Evidence of monitoring deforestation in supplier operations?

58. Amount of illegal/non-compliant deforestation recorded in own operations?

59. Amount of illegal/non-compliant deforestation recorded in supplier operations?

The company investigates grievances pertaining to deforestation reported via its grievance system, however, a total figure for non-compliant deforestation could not be reliably calculated.

60. Commitment to restoration of non-compliant deforestation/conversion?

61. Commitment to restoration of non-compliant deforestation/conversion applies to all suppliers?

62. Implementing a landscape or jurisdictional level approach?

63. Commitment to biodiversity conservation?

The company commits to biodiversity conservation.

64. Commitment to biodiversity conservation applies to all suppliers?

65. Identified species of conservation concern, referencing international or national system of species classification?

Biodiversity studies on woody trees, birds, mammals, fishes and herpertofauna (reptiles and amphibians) have been conducted in the Tinbarap Conservation Area (TCA).

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

The company reports an ongoing project in collaboration with Sarawak Forestry Corporation, to rehabilitate its Tinbarap Conservation Forest. This was the only example of habitat management/restoration found.

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

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

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

The company's policy states "New development areas will undergo integrated HCV and High Carbon Stock Approach ("HCSA") assessments to determine the planting areas".

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

The company's policy states "SOPB expected its external suppliers and contractors to fully comply with this commitment by January 2020, where MSPO is mandated".

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

72. 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.

73. 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.

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

75. 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?

76. 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.

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

The company's policy states "New development areas will undergo integrated HCV and High Carbon Stock Approach ("HCSA") assessments to determine the planting areas".

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

The company's policy states "SOPB expected its external suppliers and contractors to fully comply with this commitment by January 2020, where MSPO is mandated".

79. High Carbon Stock (HCS) assessments available?

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

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

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

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

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

The company's policy states "No New Development on Peat Areas regardless of depth".

84. Commitment to no planting on peat of any depth applies to all suppliers?

The scope of the company's policy is unclear and states "SOPB expected its external suppliers and contractors to fully comply with this commitment by January 2020, where MSPO is mandated". However the annual report states that no new development on peat regardless of depth applies to all suppliers.

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

Approximately 65% of the Sarawak Oil Palms 2010 yield was planted on peat. Data more than five years old (2011).

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

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

The company commits to best management practices for soils and peat.

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

The company's sustainability policy only refers to best management practices on peat, and the scope of the policy for suppliers is unclear.

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

The company provides examples on its website and found in MSPO audit reports.

90. Commitment to zero burning?

The company commits to zero burning.

91. Commitment to zero burning applies to all suppliers?

The company's policy states "SOPB expected its external suppliers and contractors to fully comply with this commitment by January 2020, where MSPO is mandated".

92. Evidence of fire monitoring and management?

The company states that firefighting sessions are conducted on a regular basis but does not provide any additional examples of management and monitoring activities.

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

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

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

96. GHG emissions intensity?

The company reports Scope 1 and 2 emissions but it is not reported as intensity.

97. GHG emissions from land use change?

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

98. Progress towards commitment to reduce GHG emissions intensity?

The company Scope 1 GHG emission figures from 2017 to 2019 but progress is not reported as intensity figures. Emissions have decreased for the company's plantations, but increased for the company's mill, refinery and biodiesel plant.

99. Methodology used to calculate GHG emissions?

ISCC toolkits based on EU Renewable Energy Directive (RED).

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

One mill has biogas capture.

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

102. Water use intensity?

1.5 - MT water per MT FFB processed (mills); 0.59 m3 per MT of CPO processed (downstream operations). Data as of 2018.

103. Progress towards commitment on water use intensity?

The company reports water intensity figures for both mills and downstream operations, the latter of which has not improved from 2017-2018.

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

The company commits to ensure BOD discharge levels comply with statutory requirements.

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

The company reports the average BOD levels of its mills for 2018 and 2019 however it does not specify the required legal limits for BOD.

106. Treatment of palm oil mill effluent (POME)?

The company gives examples of treatment, however, it is not externally verified.

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

108. Commitment to protect natural waterways through buffer zones?

SOPB had formally reviewed and established group guidance on the Protection of Riparian Buffer Zone and Slope Policy (2016) for the plantations to maintain buffer zones, however it only specifies along "main rivers", and not all waterways.

109. Implementation of commitment to protect natural waterways through buffer zones?

The company only provides photographs of its buffer zones with relevant signage.

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

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

112. Commitment to no use of paraquat?

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

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

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

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

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

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

119. Implementation of commitment to minimise inorganic fertiliser use?

The company states that "residues such as pruned fronds, empty fruit bunches (EFB) and mill by-products were recycled as top soil enrichment and organic fertilizer to reduce the use of chemicals, fertilizer, greenhouse gaseous (GHG) emissions and to improve soil fertility".

120. Integrated Pest Management (IPM) approach?

The company states it implements IPM.

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

The company's Environmental Sustainability Policy refers to proper disposal of waste and further evidence can be found in MSPO audit reports under "Criterion 4.5.3: Waste management and disposal".

122. Commitment to human rights?

The company makes this commitment in its sustainability policy.

123. Commitment to human rights applies to all suppliers?

The company's policy states "SOPB expected its external suppliers and contractors to fully comply with this commitment by January 2020, where MSPO is mandated".

124. Progress on human rights commitment?

The company only states that "our employees are frequently updated on the Group's Social and Community policy".

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

The company recognises the rights of indigenous and local communities in relation to FPIC only, and does not refer to the UN Declaration on the Rights of Indigenous Peoples or to the ILO Indigenous and Tribal Peoples Convention (no. 169).

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

The company recognises the rights of indigenous and local communities in relation to FPIC only, and does not refer to the UN Declaration on the Rights of Indigenous Peoples or to the ILO Indigenous and Tribal Peoples Convention (no. 169). The scope of the company's policy for suppliers is unclear.

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

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

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

The company commits to respect legal and customary land rights but only in relation to FPIC. The scope of the company's policy for suppliers is unclear.

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

The company makes this commitment in its sustainabiliy policy.

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

The scope of the company's policy is unclear and states "SOPB expected its external suppliers and contractors to fully comply with this commitment by January 2020, where MSPO is mandated".

131. Details of free, prior and informed consent (FPIC) process available?

The process is publicly available.

132. Examples of local stakeholder engagement to prevent conflicts?

The company mentions conducting workshops, meetings, seminars and dialogue sessions with smallholders, out growers, and local communities in order to strengthen relationships with the Group, but no further details were given.

133. Details of process for addressing land conflicts available?

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

135. Commitment to mitigate impacts on food security?

136. Commitment to mitigate impacts on food security applies to all suppliers?

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

138. Commitment to provide essential community services and facilities?

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

The company's Vision Care Project involves eye checks for local communities who did not have access to eye care services, and the company has provided disaster relief to local communities affected by floods and fire. Information is self-reported.

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

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

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

The Social and Community Policy does not apply to suppliers. The company only refers to no child labour, no forced labour, freedom of association and collective bargaining in its Oil Palms Sustainability Policy, and the scope of this policy for suppiers is unclear.

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

The company states "Each operation unit has established its own Workers' Committee where each representative in the Committee is selected by the workers themselves. This Committee serves as an alternative channel for the workers to convey or relay problem or issue faced by them." Also, workers are frequently updated on the Group's Social and Community policy, which contains human rights commitments, but limited details are given. Information has not been externally verified.

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

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

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

The company has Sexual/Gender Committee with equal speaking rights for genders at each operational unit, but it is not clear what its role is. This information is self-reported.

147. Percentage or number of temporary employees?

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

148. Percentage or number of women employees?

3,901 (34%) - Data as of 2019.

149. Commitment to pay at least minimum wage?

The company makes this commitment in its Social and Community Policy.

150. Commitment to pay at least minimum wage applies to all suppliers?

151. Progress on commitment to pay at least minimum wage?

152. Reporting of salary by gender?

The company states that 100% of men and women are paid the minimum wage, but no further information is given.

153. Commitment to address occupational health and safety?

The company has an Occupational Safety and Health Policy.

154. Commitment to address occupational health and safety applies to all suppliers?

155. Provision of personal protective equipment and related training?

The company provides PPE and states training on protective equipment is reinforced following fatal accidents. It also mentions providing training to suppliers of chemicals. Provision of PPE can be found in externally verified MSPO reports under "Criterion 4.4.4: Employees safety and health".

156. Time lost due to work-based injuries?

For 2019, the company reports a lost-time injury rate (number of lost-time injuries per one million man-hours worked) for its plantations (7.95), milling (5.52) and downstream operations (3.08).

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

2 - The company reports two fatalities in the plantation and downstream sectors.

158. Commitment to support smallholders?

The company commits to support smallholders however the types of smallholder are not specified.

159. Programme to support scheme/plasma smallholders?

160. Percentage of scheme/plasma smallholders involved in programme?

161. Programme to support independent smallholders/outgrowers?

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

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

The company has a Supplier Engagement Procedure.

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

The company states that 134 senior representatives from 71 major plantation companies, refiners and suppliers attended the Inaugural Dialogue on SOPB Oil Palms Sustainability Policy 2019.

165. Suspension or exclusion criteria for suppliers?

If a supplier fails to comply with the Sustainability Policy, the engagament process will be inititated and a follow up assessment will be carried out within 6 months to track progress.

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

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

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

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

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

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

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

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

174. Commitment to ethical conduct and prohibition of corruption?

The company has a Code of Business Conduct & Ethics policy.

175. Commitment to ethical conduct and prohibition of corruption applies to all suppliers?

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

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

178. Whistleblowing procedure?

The company has a Whistleblowing Policy.

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

The company reports that grievances can be lodged through thewWhistleblowing mechanism.

180. Details of complaints and grievances disclosed?

The company has a grievance list on its website.