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  • Latest update: July 2019
  • Next scheduled: July 2020

  • About this company:

    Golden Pharos Bhd is an investment holding company

  • Landbank
    134,143 hectares
  • Market cap:
    7,815,974 USD
  • Thomson Reuters ticker:
    GROS.KL
  • Bloomberg ticker:
    GPB:MK
  • ISIN:
    MYL5649OO008
  • Website:

Company assessment: Golden Pharos Bhd – July 2019

Assessment date:

Total: 25.2% 31 / 123
  • Sustainability policy and leadership Sustainability policy and leadership
    4 / 11 36.4%
    • Partial
      0.5 / 1

      1. Sustainable forestry policy or commitment for all its operations?

      The company reports it is in the process of finalising its sutainability policy. Some general principles are outlined regarding economic and social sustainability, and the company has some environmental commitments already for timber

    • No
      0 / 1
      No source

      2. Sustainability policy or commitment applies to all sourcing?

    • Yes
      1 / 1

      3. High-level position of responsibility for sustainability?

      The company has set up a sustainability committee which is led by the CEO

    • No
      0 / 1

      4. One or more board members have responsibility for sustainability?

      The company shows that the sustainability committee reports to the Board, but ultimate responsibility is not clear

    • Yes
      1 / 1

      5. Percentage or number of women board members?

      0 (0%) - The company explicitly reports on the genders of board members in its 2018 annual report. It shows there are no women on the board

    • Partial
      0.5 / 1

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

      2 (17%) - The company does not explicitly report the number or percentage of women in the senior management team. It only provides photographs and names of staff on the team

    • Yes
      1 / 1

      7. Sustainability report published within last two years?

      The company published its inaugural sustainability report this year, for 2018

    • No
      0 / 1
      No source

      8. Member of multiple industry schemes or other external initiatives to improve forest management or transparency?

    • No
      0 / 1
      No source

      9. Activities with government, NGOs or academic institutions to improve the sustainability of forest products?

    • No
      0 / 1
      No source

      10. Climate risks assessment available?

    • No
      0 / 1
      No source

      11. Natural capital assessment available?

  • Landbank, mills and traceability Landbank, mills and traceability
    6.5 / 21 31%
    • Yes
      1 / 1

      12. Lists countries and operations?

      Malaysia ("forest concession management, harvesting and distribution, sawmilling and value-added processing of wood-based products")

    • Yes
      1 / 1

      13. Total area of natural forest designated for wood/wood fibre production (ha)?

      129,143 - The company reports concessions of 20,234 ha (Cherul Forest Concession) and 108,900 ha (Dungun Timber Complex) in its 2018 annual report. Management control of the Cherul Forest Concession is reported in a contradictory way but the hectarage figure reported appears to be consistent

    • Partial
      0.5 / 1

      14. Total area of forest plantation (ha)?

      5,000 - The company refers to a plantation of karas trees, but gives no hectarage figure and it is unclear if work has started to develop this plantation yet. It also refers to 5,000 hectares of plantation on its concessions to ensure "a sustainable supply of logs into the future". It is not clear if this area has yet been planted, or whether this covers all the company's plantation landbank

    • No
      0 / 1
      No source

      15. Area of plantation/natural forest within outgrower schemes (ha)?

    • No
      0 / 1
      No source

      16. Unplanted (areas designated for future development as plantation forest) (ha)?

    • Partial
      0.5 / 1

      17. Conservation set-aside and/or HCV area (ha)?

      3,524 - Conservation set-aside for two concessions are reported in its FSC audit reports, of 209 ha conservation area/HCV for DTC (under KPKKT) and 3,127 ha conservation area + 202 HCV for CFC (under Pesama). The annual report gives a contradictory figure of 3,524 ha HCV forest set aside. It is also not clear if these areas cover all the company's landbank set aside for conservation

    • No
      0 / 1
      No source

      18. Area of Intact Forest Landscape (ha)?

    • Partial
      0.5 / 1

      19. Number of Forest Management Units (FMUs)?

      The company has at least 2 FMUs – Cherul Forest Concession (CFC) and Dungun Timber Complex (DTC). It is not clear whether the company has a separate FMU for the proposed 5,000 ha of karas trees it makes reference to

    • No
      0 / 1

      20. Maps of forest management units (FMUs)?

      The company provides static maps through its subsidiary websites for some FMUs, but they are limited in detail, it is unclear if they cover all FMUs, and they are undated

    • Partial
      0.5 / 1

      21. Forest management plans available for all FMUs?

      There is a FMP available for CFC concession, and the subsidiary KPKKT states it is in the process of developing a new FMP for its concession, but this does not appear to be available yet. It is also not clear whether these two FMPs would cover all of the company's operations

    • Partial
      0.5 / 1

      22. Monitoring of forest management plan implementation?

      Some monitoring information is available, but detailed performance against specific FMP management objectives was not found

    • 23. Company has provided valid legal documents to Open Timber Portal on use rights (at the time of SPOTT assessments)?

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal

    • 24. Company has provided valid legal documents to Open Timber Portal on forest management (at the time of SPOTT assessments)?

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal

    • 25. Company has provided valid legal documents to Open Timber Portal on timber harvesting (at the time of SPOTT assessments)?

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal

    • 26. Number of company owned pulp and paper mills?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't own pulp or paper mills. Please note that ZSL has been unable to confirm this

    • 27. Maps or addresses of company owned pulp and paper mills?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't own pulp or paper mills. Please note that ZSL has been unable to confirm this

    • Yes
      1 / 1

      28. Number of company owned sawmills?

      3

    • No
      0 / 1

      29. Maps or addresses of company owned sawmills?

      The company provides vague addresses of its sawmills, but the exact location cannot be found online using these addresses

    • No
      0 / 1
      No source

      30. Number of supplier mills?

    • No
      0 / 1
      No source

      31. Maps or addresses of supplier mills?

    • Partial
      0.5 / 1

      32. Procedures to trace raw materials to country of harvest?

      The company has some CoC certification which counts as the procedure for the certified portion of all raw materials the company sources

    • Partial
      0.5 / 1

      33. Procedures to trace raw materials to FMU level?

      The company has some CoC certification which counts as the procedure for the certified portion of all raw materials the company sources

    • No
      0 / 2
      No source

      34. Percentage of supply traceable to country level (above 80%)?

    • No
      0 / 2
      No source

      35. Percentage of supply traceable to FMU level (above 75%)?

  • Deforestation and biodiversity Deforestation and biodiversity
    3 / 12 25%
    • No
      0 / 1
      No source

      36. Commitment to zero conversion of natural forest?

    • No
      0 / 1
      No source

      37. Zero conversion commitment applies to all sourcing?

    • No
      0 / 1
      No source

      38. Commitment to minimise the impact of logging roads?

    • No
      0 / 1
      No source

      39. Commitment to protect forest areas from illegal activities?

    • No
      0 / 1
      No source

      40. Evidence of monitoring deforestation?

    • No
      0 / 1
      No source

      41. Amount of deforestation recorded?

    • Yes
      1 / 1

      42. Commitment to biodiversity conservation?

    • Partial
      0.5 / 1

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

      The company makes reference to a "rare and endangered" tree species it protects on its land. Further examples of species or habitat management were not found

    • No
      0 / 1

      44. Implementing a landscape-level approach to biodiversity conservation?

    • Partial
      0.5 / 1

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

      The company refers to one species it has identified as rare and endangered (Dipterocarpus sarawakensis) but does not refer to a specific classification system used

    • No
      0 / 1
      No source

      46. Commitment to sustainably manage the use of non-timber forest products (NTFPs)?

    • Yes
      1 / 1

      47. Commitment not to use genetically modified organisms?

      The company has committed to not be directly or indirectly involved in the introduction of genetically modified organisms in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004)

  • HCV, HCS and impact assessments HCV, HCS and impact assessments
    4 / 8 50%
    • Partial
      0.5 / 1

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

      The company does not have a direct commitment to conduct HCV assessments across all of its operations. However, the company has committed to not be directly or indirectly involved in the destruction of high conservation values in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004). For this half a point is awarded

    • Partial
      0.5 / 1

      49. HCV commitment applies to all sourcing?

      The company has committed to not be directly or indirectly involved in the destruction of high conservation values in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004). For this half a point is awarded

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

      This indicator is disabled until sufficient number of HCV ALS licensed assessors are available for the location where the company operates

    • Yes
      1 / 1

      51. High Conservation Value (HCV) assessments available?

      Summaries of the following HCV assessments are available: Pesama Timber Corporation Sdn Bhd (PESAMA), Kumpulan Pengurusan Kayu Kayan Terengganu Snd Bhd (KPKKT). These summaries cover the years 2013-17. It is not clear whether these assessments cover all the company's operations

    • Yes
      1 / 1

      52. High Conservation Value (HCV) management and monitoring plans available?

      The following M&M plans are available: Pesama Timber Corporation Sdn Bhd (PESAMA), Kumpulan Pengurusan Kayu Kayan Terengganu Snd Bhd (KPKKT)

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      54. High Carbon Stock (HCS) assessments available?

    • Partial
      0.5 / 1

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

      The company refers to both EIAs and SIAs, but does not make a clear commitment to conduct them prior to all new development

    • Partial
      0.5 / 1

      56. Social and environmental impact assessments (SEIAs) available?

      The company has made some EIA and SIA assessments available. However, not all are available, and not all those available have associated management and monitoring plans

    • 57. Company has provided valid legal documents to Open Timber Portal on impact assessments (at the time of SPOTT assessments)?

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal

  • Soils, fire and GHGs Soils, fire and GHGs
    0.5 / 14 3.6%
    • No
      0 / 1
      No source

      58. Commitment to best management practices for soils and/or peat?

    • No
      0 / 1
      No source

      59. Commitment to reduced impact logging?

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      61. Commitment on peatland planting applies to all sourcing?

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      63. Evidence of best management practices for soils and/or peat?

    • No
      0 / 1
      No source

      64. Commitment to zero burning?

    • No
      0 / 1
      No source

      65. Commitment to zero burning applies to all sourcing?

    • Partial
      0.5 / 1

      66. Evidence of management and monitoring fires?

      The company has evidence of fire management activities for subsidiary KPKKT, but no monitoring activities could be found

    • No
      0 / 1
      No source

      67. Details/number of hotspots/fires in FMUs controlled by the company?

    • No
      0 / 1
      No source

      68. Time-bound commitment to reduce GHG emissions intensity?

    • No
      0 / 1
      No source

      69. Progress towards reducing GHG emission intensity?

    • No
      0 / 1
      No source

      70. Report GHG emissions from land use change?

    • No
      0 / 1
      No source

      71. Methodology used to calculate GHG emissions?

  • Water, chemical and waste management Water, chemical and waste management
    0 / 9 0%
    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      74. Commitment to protection of natural waterways through buffer zones?

    • 75. Evidence of treatment of pulp and paper mill effluent?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't own pulp or paper mills. Please note that ZSL has been unable to confirm this

    • No
      0 / 1
      No source

      76. Evidence of sawmill run-off containment and wastewater treatment?

    • 77. Time-bound commitment to improve water use intensity?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't own pulp or paper mills. Please note that ZSL has been unable to confirm this

    • 78. Progress towards commitment on water use intensity?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't own pulp or paper mills. Please note that ZSL has been unable to confirm this

    • 79. Commitment to eliminate chlorine and chlorine compounds for bleaching?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't own pulp or paper mills. Please note that ZSL has been unable to confirm this

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      83. Integrated Pest Management (IPM) approach?

    • No
      0 / 1
      No source

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

  • Community, land and labour rights Community, land and labour rights
    11 / 22 50%
    • Yes
      1 / 1

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

      The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which defines human rights as those established through the UN Declaration of Human Rights

    • Yes
      1 / 1

      86. Commitment to human rights applies to all sourcing?

      The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which defines human rights as those established through the UN Declaration of Human Rights

    • Yes
      1 / 1

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

      The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which encompasses the rights of Indigenous and Tribal Peoples as established by the ILO Convention 169

    • Partial
      0.5 / 1

      88. Commitment to respect legal and customary property rights?

      The company has committed to not be directly or indirectly involved in the violation of traditional rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which encompasses customary rights. This policy does not reference legal rights and no reference to legal rights could be found in company sources

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      90. FPIC commitment applies to independent suppliers?

    • No
      0 / 1
      No source

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

    • Partial
      0.5 / 1

      92. Examples of local stakeholder engagement to prevent conflicts?

      Subsidiary Pesama has minutes of a 2016 meeting with stakeholders, including some representatives of a village near CFC, for the purpose of discussing any issues raised. Further examples of local stakeholder engagement to prevent conflicts were not found

    • Yes
      1 / 1

      93. Details of process for addressing land conflicts available?

    • No
      0 / 1
      No source

      94. Commitment to support the inclusion of women across forestry operations, including addressing barriers faced?

    • No
      0 / 1
      No source

      95. Commitment to provide essential community services and facilities?

    • 96. Company has provided valid legal documents to Open Timber Portal on population rights (at the time of SPOTT assessments)?

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal

    • Partial
      0.5 / 1

      97. Commitment to respect all workers' rights?

      The company commits to respecting employee rights, but does not specify that this applies to all workers, including e.g. temporary and casual workers

    • Yes
      1 / 1

      98. Reference to Fundamental ILO Conventions?

      The company has committed to not be directly or indirectly involved in the violation of any of the ILO Core Conventions. This commitment is made through the FSC Policy for Association (FSC-POL-01-004)

    • No
      0 / 1
      No source

      99. Commitment to eliminate gender related discrimination with regards to employment and occupation?

    • 100. Company has provided valid legal documents to Open Timber Portal on labour regulations (at the time of SPOTT assessments)?

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal

    • Yes
      1 / 1

      101. Percentage or number of temporary employees?

      160 (32.85%)

    • Yes
      1 / 1

      102. Percentage or number of women employees?

      29%

    • Partial
      0.5 / 1

      103. Payment of minimum wage?

      The company states it complies with the Minimum Wage Order 2018, but no evidence that minimum wage is paid across all operations was found

    • No
      0 / 1
      No source

      104. Reporting of salary by gender?

    • Partial
      0.5 / 1

      105. Commitment to address occupational health and safety, referencing the ILO Code of Practice on Safety and Health in Forestry Work?

      The company has a commitment to address health and safety, but does not reference the ILO Code of Practice on Safety and Health in Forestry Work

    • Partial
      0.5 / 1

      106. Time lost due to work-based injuries?

      2 - The number of 'serious' accidents since the last audit is reported in KPKKT's FSC audit report as two, and in Pesama's as zero. These two reports do not clearly cover all company operations

    • Partial
      0.5 / 1

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

      0 - The number of 'serious' accidents since the last audit is reported in both KPKKT's and Pesama's FSC audit reports as zero. However, these two reports do not clearly cover all company operations

    • Partial
      0.5 / 1

      108. Provision of personal protective equipment and related training?

      The company refers to training its staff, including through various training courses on health and safety, and subsidiary KPKKT refers to personal protective equipment, but clear evidence of training and PPE being provided to all staff was not found

  • Certification standards Certification standards
    0 / 14 0%
    • No
      0 / 1
      No source

      109. Time-bound plan for achieving 100% third-party legality verification of FMUs or achieved?

    • No
      0 / 1
      No source

      110. Time-bound plan to source only wood/wood fibre that is in legal compliance verified by a third party?

    • No
      0 / 1

      111. Percentage area (ha) verified as being in legal compliance by a third party?

      The company has some FSC certification but it is not clear exactly what percentage of its landbank this covers

    • No
      0 / 1
      No source

      112. Percentage of all wood/wood fibre supply traded/processed verified as being in legal compliance by a third party?

    • No
      0 / 1
      No source

      113. Time-bound plan for achieving 100% FSC FM certification of FMUs or achieved 100% FSC-certification of FMUs?

    • No
      0 / 1
      No source

      114. Commitment to source only wood/wood fibre that meets FSC Controlled Wood requirements?

    • No
      0 / 2

      115. Percentage area (ha) FSC FM certified?

      The company has FSC certification for CFC (20,243 ha) and DTC concessions (106,697 ha), but it is not clear if this covers all land under the company's operations. It also makes reference to 5,000 ha of plantation land but no further details are given and there are no FSC records for this

    • No
      0 / 2
      No source

      116. Percentage of wood/wood fibre supply from outgrower scheme and/or independent suppliers that is FSC FM certified?

    • No
      0 / 2

      117. Percentage of all wood/wood fibre supply traded/processed that are FSC certified (above 75%)?

      The company states that timber it sources "is mainly from the Group’s own certified forest" but the percentage of its total supply FSC certified is not clear

    • No
      0 / 2
      No source

      118. Percentage area (ha) PEFC certified (excluding FSC certified area)?

  • Smallholders and suppliers Smallholders and suppliers
    0 / 6 0%
    • No
      0 / 1
      No source

      119. Programme to support outgrower scheme smallholders?

    • No
      0 / 1
      No source

      120. Percentage of outgrower scheme smallholders involved in programme?

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      122. The company has a Due Diligence System (DDS)?

    • No
      0 / 1
      No source

      123. Suspension or exclusion criteria for suppliers?

    • No
      0 / 1
      No source

      124. Percentage of suppliers assessed and/or engaged on compliance with company requirements?

  • Governance and grievances Governance and grievances
    2 / 6 33.3%
    • Yes
      1 / 1

      125. Commitment to ethical conduct and prohibition of corruption?

    • 126. Company has provided valid legal documents to Open Timber Portal on legal registration (at the time of SPOTT assessments)?

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal

    • No
      0 / 1
      No source

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

    • 128. Company has provided valid legal documents to Open Timber Portal on taxes, fees and royalties (at the time of SPOTT assessments)?

      This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal

    • Yes
      1 / 1

      129. Whistleblowing procedure?

    • No
      0 / 1
      No source

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

    • No
      0 / 2
      No source

      131. Details of grievances disclosed?

Media monitor: Golden Pharos 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.

Category filter:
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Scoring criteria: Golden Pharos Bhd

Scoring criteria 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 indicator framework contains 131 indicators across 10 categories.

SPOTT is a ZSL initiative.
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