TSH Resources Bhd

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

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

3. High-level position of responsibility for sustainability?

Head of Sustainability Department.

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

The Group Managing Director sits on the Board of Directors and has set specific sustainability objectives and timelines.

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

6. Percentage or number of women board members?

2 (20%) - The company reports two female board members.

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 works with local and international NGOs and the Sabah Forestry Department on sustainable management of the forests surrounding its estates. However, this is not clearly focused on reducing negative environmental or social outcomes associated with palm oil production.

9. Sustainability report published within last two years?

The company has a sustainability statement within its 2019 Annual Report.

10. Reports through standardised reporting systems?

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

103,927 - Data as of 2019.

14. Total oil palm planted area (ha)?

42,109 - The 2019 Annual Report states that 42,109 ha has been planted.

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

4,404 - Data as of 2019.

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

40,272 - Data as of 2019.

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

17,195 - Sum of HCV areas and other conservation areas reported in the 2019 RSPO ACOP.

18. Maps of estates/management units?

The company uploaded its estate location concession maps with its ACOP 2018 and declared that the map data submission represented 100% of its concession sites (both RSPO certified and uncertified).

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 owns seven mills.

22. Names and locations of company-owned mills?

All of the company's mills are available on GFW.

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

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

25. Number of third party supplying mills?

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

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

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

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

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

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

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

29. 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.

30. 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.

31. Percentage of supply traceable to mill level?

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

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

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

34. 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.

35. Publishes traceability data at refinery level?

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

36. Publishes traceability data at crusher level?

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

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

2014 - The company has been a member since 2014.

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?

2020 - The company joined the RSPO in 2014 and achieved its first certification in 2016.

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

2019.

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

Indonesia (West Sumatra, Central Kalimantan, East Kalimantan, North Kalimantan), Malaysia (Sabah).

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

18.31% - 18,217.78 ha as of 2019.

42. Percentage of mills RSPO-certified?

71.4% - Five mills certified as of 2019.

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

2021

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

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

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

0% - Data as of 2019.

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

2023

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

0% - Data as of 2019.

48. 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.

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

Mass balance.

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

Some of the company's operations are ISPO certified.

51. Malaysia Sustainable Palm Oil (MSPO) certified?

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

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

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

55. Criteria for defining deforestation?

HCV, HCS and peat. No cut-off date is given.

56. Evidence of monitoring deforestation?

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

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?

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?

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

63. Commitment 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?

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

66. 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.

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 commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. It also makes this commitment in its Sustainability Statement section of its annual report.

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

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)?

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

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

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

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)?

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. It also makes this commitment in its Sustainable Palm Oil Policy.

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 commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also makes this commitment in its Sustainable Palm Oil Policy.

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

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

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

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

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

89. 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.

90. Commitment to zero burning?

91. Commitment to zero burning applies to all suppliers?

92. Evidence of fire monitoring and management?

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

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?

10.4 tCO2/ha and 2.35 tCO2/tCPO. Data covers certified units only.

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 reports a change in GHG emissions, from 7.92 tCO2/ha and 4.96 tCO2/tCPO in 2017 to 10.4 tCO2/ha and 2.35 tCO2/tCPO in 2019, however data only covers certified units.

99. Methodology used to calculate GHG emissions?

PalmGHG.

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

Some of the company's mills are equipped with methane/biogas capture.

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

102. Water use intensity?

1.3 - m3 per mT of FFB produced (2019).

103. Progress towards commitment on water use intensity?

The company reports an improvement in water use intensity, from 1.18 m3 per mT of FFB produced in 2017 to 1.13 m3 per mT of FFB produced in 2019.

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

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

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

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports it does this in its 2019 annual report.

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

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

108. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways through buffer zones.

109. 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.

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?

The company commits 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?

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

120. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports this in its annual report.

121. 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.

122. Commitment to human rights?

The company commits to human rights, but does not reference the UN Declaration of Human Rights.

123. Commitment to human rights applies to all suppliers?

The company commits to respect the human rights of its employees, and does not refer to the UN Declaration on Human Rights.

124. Progress on human rights commitment?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also states it carries out annual training for employees on topics such as human rights.

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

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

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

The company commits to respect land tenure rights, but only in relation to FPIC.

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

The company commits to respect land tenure rights, but only in relation to FPIC. The policy applies to suppliers.

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

The company commits under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower. The company also makes this commitment itself.

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

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

The RSPO Principles and Criteria 2018 contain guidance and requirements on the process to conduct free, prior and informed consent (FPIC). Points have therefore been awarded on the basis of the company's commitments under the RSPO New Planting Procedures (NPP) as an RSPO member reporting as a grower.

132. Examples of local stakeholder engagement to prevent conflicts?

The company states it carried out town hall meetings and community development programmes on issues including land-related claims and compensation.

133. Details of process for addressing land conflicts available?

The company provides an SOP on conflict resolution that includes issues related to land.

134. 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.

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?

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

138. Commitment to provide essential community services and facilities?

The company commits to contribute to the surrounding community.

139. 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. Examples are also given in the annual report.

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

The company reports to "have set up a Plantation Training Acedemy in Kalimantan Tengah, with purpose of recruiting and training suitable local workers to mitigate any labour shortage" but does not make a clear commitment to provide work opportuntities for local communities.

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

The company commits to six of the eight Fundamental ILO Conventions: it does not mention Minimum Age and Equal Remuneration.

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

The company's policy, which applies to suppliers, only commits to some of the eight Fundamental ILO Conventions.

143. 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.

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?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company states it offers annual training to employees on topics including equal opportunity and no discrimination.

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?

2,074 (25.8%) - Total female employees.

149. Commitment to pay at least minimum wage?

The company has a commitment to pay at least minimum wage across all of its operations.

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

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

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

152. Reporting of salary by gender?

153. Commitment to address occupational health and safety?

The company has a commitment to address occupational health and safety.

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

155. 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. In addition, the company mentions training and protective clothing for workers who handle pesticides.

156. Time lost due to work-based injuries?

10.08 - Loss Time Injury Frequency Rate (LTIFR) 2019 (Incidents/1 million man-hours worked).

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

0 - The company reports no fatalities in 2019.

158. Commitment to support smallholders?

The company mentions its objective to assist scheme smallholders through services as part of the Plasma Scheme, and provides details on its role within the scheme. However, it does not have a clear commitment to support inependent smallholders.

159. Programme to support scheme/plasma smallholders?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. In addition, the company states that it supports plasma smallholders through providing advice, seed stock, financial support, fertilisers and pesticides.

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

The company only states "Todate, TSH has assisted in establishing 14 Smallholder Cooperatives under the Plasma Scheme in Indonesia.".

161. Programme to support independent smallholders/outgrowers?

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

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 only states that it performs audits on its suppliers' compliance with local environmental regulations, especially when it comes to waste management and land clearing.

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

165. Suspension or exclusion criteria for suppliers?

The company states it "shall not establish or maintain business relationships with suppliers and contractors who are not aligned with these principles" in the sustainable palm oil policy, but no further details on steps that will be taken and timeframes for action are given.

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?

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

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

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

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

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

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

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

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

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

173. 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 does not source from mills.

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and prohibition of corruption.

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

The company's Anti Bribery and Corruption Policy applies to the group's "business dealings with commercial ("private sector") and Government ("public sector") entities" but it is not clear if this covers all suppliers.

176. 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.

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

178. Whistleblowing procedure?

The company states it has a whistleblowing procedure but no details are given on the steps taken and on how whistleblowers are protected.

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

The company allows for grievances to be reported but no details are given on the steps taken.

180. Details of complaints and grievances disclosed?