Golden Pharos

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

The company's sustainability commitments are reported as a part of its sustainability report covering multiple dimensions of sustainability across the company's operations.

2. Sustainable forestry policy or commitment applies to all suppliers?

3. High-level position of responsibility for sustainability?

The company has set up a sustainability committee which is headed by the CEO, Mr. Zulkifli bin Omar.

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

The company's board of directors sit at the top of the company's sustainability governance structure and are recommended on ESG matters by the Chief Sustainability Officer (CSO).

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

2 - The company reports 14 members as a part of its senior management team, out of which 2 are women.

6. Percentage or number of women board members?

0 - The company reports 6 members as part of its board of directors, out of which none are woman.

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

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with timber and pulp production?

The company reports collaborating with organisations such as WWF to identify threatened and endangered mammal species. In addition, the company has also entered into a partnership with Forest Research Institute Malaysia (FRIM) for the protection and restoration of HCVFs.

9. Sustainability report published within last two years?

The sustainability report was published in 2023 as a part of the company's Annual report covering the year 2022.

10. Reports through standardised reporting systems?

11. Climate risks assessment available?

12. Natural capital assessment available?

13. Lists countries and operations?

Malaysia (forest concessions, sawmills, plywood mill).

14. Lists countries sourcing from?

The company reports that its sourcing of timber is mainly from its own forests and sourcing from alternative suppliers is done through local contractors/suppliers from Malaysia.

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

123962 - The company controls 123,962 ha of forest concessions in Malaysia.

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

0

17. Total area of forest plantation (ha)?

144 - The company reports that as of 31 December 2022, it has 144 ha of planted forests.

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

0

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

0

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

4588 - The company reports that it has identified HCV forest with a total of 4,588 ha reserved as HCVF. The company also reports permanently preserved forests of 20,243 ha. The total area under conservation is unclear.

21. Area of Intact Forest Landscape (ha)?

0

22. Number of Forest Management Units (FMUs)?

2 - The company reports it operates two FMUs under its subsidiary KPKKT, Cherul Forest Concession (CFC) and Dungun Timber Complex (DTC).

23. Maps of forest management units (FMUs)?

The company provides static maps of all FMUs on the subsidiary website and in the FM plans.

24. Forest management plans available for all FMUs?

Forest management plans are available for all FMUs of the company.

25. Monitoring of forest management plan implementation available?

Monitoring of forest management plan implementation is available in the FM plans of the company FMUs, however, the information reported is not externally verified.

26. Company has provided valid legal documents to Open Timber Portal on use right (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.

27. 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.

28. 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.

29. Names and locations of all third-party supplying FMUs?

30. Number of company owned sawmills?

2 - The company owns two sawmills.

31. Names and locations of company owned sawmills?

32. Number of company-owned pulp and paper mills?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

33. Names and locations of company-owned pulp and paper mills?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

34. Reports total volumes (or percentages) sourced by company-owned sawmills that come from company's own operations and third-parties?

35. Reports total volumes (or percentages) sourced by company-owned pulp and paper mills that come from company's own operations and third-parties?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

36. Number of third party supplying mills?

37. Names and locations of all third party supplying mills?

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

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

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

40. Percentage of supply traceable to country of harvest?

41. Procedures to trace raw materials to FMU level?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

42. Percentage of supply traceable to FMU level?

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

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

The FSC certificates of the company's forest concessions Kumpulan Pengurusan Kayu Kayan Trengganu Sdn Bhd. (KPKKT) and Pesama Timber Corporation Sdn. Berhad are now suspended/terminated.

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

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

47. Percentage area (ha) FSC FM certified?

The company has FSC FM certification for CFC (20,243 ha) and DTC concessions ( 124,071 ha), however, the FSC certificates of these concessions are now terminated and/or suspended by FSC.

48. Time-bound plan for achieving 100% FSC FM certification of FMUs within 10 years?

49. Percentage of wood/wood fibre supply (tonnes) from all suppliers that comes from FSC FM certified areas?

50. Commitment to source only wood/wood fibre that meets FSC Controlled Wood and/or PEFC Controlled Sources requirements?

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

52. Commitment to zero conversion of natural ecosystems?

53. Commitment to zero conversion of natural ecosystems applies to all suppliers?

54. Commitment to zero deforestation?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification.

55. Commitment to zero deforestation applies to all suppliers?

56. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's partial FSC FM or CoC certification.

57. Criteria and cut-off date for defining deforestation in supplier operations?

58. Evidence of monitoring deforestation and/or ecosystem conversion?

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

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

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

62. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

63. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

64. Implementing a landscape or jurisdictional level approach?

65. Biodiversity policy?

66. Biodiversity policy applies to all suppliers?

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

The company has identified species of conservation concern, referencing the IUCN Red List, CITES, and the Wildlife Protection Act 2010. However, the information reported is not externally verified.

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

The company has entered into a partnership with Forest Research Institute Malaysia (FRIM) for the protection and restoration of HCVFs. However, limited information is reported by the company.

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

The company only reports a commitment to no hunting of endangered, rare, or threatened species.

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

71. Commitment to protect forest areas from illegal activities?

The company only reports a commitment to forest protection which includes 'protection from encroachment'.

72. Commitment to protect forest areas from illegal activities applies to all suppliers?

73. Evidence of protecting forest areas from illegal activities?

The company reports it protects its concessions from encroachment by installing gates/berms that would reduce the potential for encroachment and wildlife harassment. These measures will be strengthened through regular patrols with the help rendered by the enforcement division of JPNT and relevant concerned authorities such as the police, army, PERHILITAN. Limited information is reported by the company.

74. Commitment to no use of genetically modified organisms?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification.

75. Commitment to no use of genetically modified organisms applies to all suppliers?

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its own commitment to conducting High Conservation Value (HCV) assessments.

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

78. High Conservation Value (HCV) assessments available?

The High Conservation Value (HCV) assessments are available for the company concessions, however, these are not externally verified.

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

High Conservation Value (HCV) management and monitoring plans are available for the company concessions, however, these are not externally verified.

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

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

82. High Carbon Stock (HCS) assessments available?

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

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

The company commits to conduct social and environmental impact assessments.

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

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

Social and environmental impact assessments (SEIAs) are available, however, the management and monitoring plans are only available for some FMUs of the company and provide limited details.

87. 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.

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

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

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

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

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

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

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

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

95. Commitment to reduced impact logging?

The company commits to Reduced Impact Logging (RIL) and specifically mentions minimising the impact of logging roads along with other RIL practices.

96. Commitment to reduced impact logging applies to all suppliers?

97. Evidence of implementing reduced impact logging practices?

The company reports multiple examples of minimising impacts of logging roads and other reduced impact logging practices in its FM plan. However, the information reported is not externally verified.

98. Commitment to zero burning?

99. Commitment to zero burning applies to all suppliers?

100. Evidence of fire monitoring and management?

101. Details/number of hotspots/fires in company FMUs?

102. Details/number of hotspots/fires in suppliers operations?

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

104. GHG emissions intensity?

The company reports GHG emission figures (scope 1 and scope 2) separately for all its operations, however, the figures are not reported as intensity.

105. GHG emissions from land use change in company's own operations (scope 1)?

106. GHG emissions from land use change in supplier operations (scope 3)?

107. Progress towards commitment to reduce GHG emissions intensity?

The company reports GHG emission figures (Scope 1, 2, 3) separately for all its operations in 2021 and 2022. However, the figures are not reported as intensity and some operations show an increase in emissions in 2022 as compared to 2021.

108. Methodology used to calculate GHG emissions?

The company reports using the Intergovernmental Panel on Climate Change (IPCC) GHG Protocol for quantifying GHG emissions.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

110. Water use intensity?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

111. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

112. Time-bound commitment to improve water quality (BOD or COD)?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

113. Progress towards commitment on water quality (BOD or COD)?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

114. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

116. Proportion of processing facilities with closed-loop water treatment system?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

117. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways using buffer zones.

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

The company provides limited evidence that buffer or riparian zones are in place in its FMUs.

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

The company commits to minimise the use of chemicals but does not mention chemical fertilisers or pesticides.

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

121. Evidence of eliminating chlorine and chlorine compounds for bleaching?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

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

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

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

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

127. Implementation of commitment to minimise inorganic fertiliser usage?

128. Integrated Pest Management (IPM) approach?

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

The company reports having a waste management plan, however, limited details are provided on its implementation.

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its own commitment to the Universal Declaration of Human Rights.

131. Commitment to human rights applies to all suppliers?

132. Progress on human rights commitment ?

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also reports its own commitment to respecting indigenous people's rights, however, the commitment does not reference the UN Declaration/ILO Convention.

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

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's partial FSC FM or CoC certification. The company also reports its own commitment to respect legal and customary land tenure rights, however, the commitment is reported in relation to FPIC.

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

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

The company reports its commitment to free, prior, and informed consent (FPIC).

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

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

140. Examples of local stakeholder engagement to prevent conflicts?

The company provides very limited details on local stakeholder engagement to prevent conflicts, stating, to ensure it maintains a constructive dialogue with the Orang Asal community, its subsidiary companies KPKKT and PESAMA are active members of the Joint Consultative Committee, which is tasked with addressing any forest land ownership conflicts that may arise.

141. Details of process for addressing land conflicts available?

The company has procedures in place for addressing land conflicts.

142. Supports the inclusion of women across forestry operations, including addressing barriers faced?

The company reports limited information to support the inclusion of women across forestry operations. Also, information on addressing barriers faced is not reported by the company.

143. 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.

144. Commitment to enable sustainable use of non-timber forest products (NTFPs) by local communities?

145. Commitment to provide essential community services and facilities ?

The company reports a commitment to provide essential community services and facilities.

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

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

The company reports a commitment to provide business/work opportunities for local communities.

148. 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.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company's own reporting only covers a commitment to 'Freedom of Association, Right to Organise and Collective Bargaining, No Forced Labour, and Child Labour.'.

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

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

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

The company reports a commitment to maintain a non-discriminatory workplace with regard to gender and also has a gender equality policy in place.

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

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

The company has a procedure in place to deal with cases of sexual harassment in the workplace and mentions that no incidents of discrimination were reported during FY2022. However, the information reported is not externally verified.

155. Percentage or number of temporary employees?

134 (31%) - The company reports that in 2022 it had 134 contract workers and a total workforce of 432.

156. Percentage or number of women employees?

121 (28%) - The company reports that 28% of its total workforce is women. Data as of December 2022.

157. Commitment to pay a living wage?

The company only commits to paying the minimum wage.

158. Commitment to pay a living wage applies to all suplliers?

159. Progress on commitment to pay a living wage?

1800 - The company only reports the ratio of the minimum wage to the local minimum wage by country of operation. However, evidence that all workers are paid a living wage is not reported by the company.

160. Reporting of salary by gender?

1750 - The company reports a ratio of entry-level wages versus minimum wages for men and women. However, the information is not split as per the employee category or significant locations of operation in line with GRI reporting.

161. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification. The company's own commitment to addressing health and safety does not reference the ILO Code of Practice on Safety and Health in Forestry Work.

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

163. Provision of personal protective equipment and related training?

Limited, externally verified points have been awarded on the basis of the company's FSC Chain of Custody certification (FSC-STD-40-004 V3-1) as the requirements do not fully meet the SPOTT indicator criteria. The company's own reporting states that as per safety regulations, its logging and sawmill workers are provided with personal protective equipment (PPE) and are trained to use the gear in the event of a mishap. However, own reporting is not externally verified.

164. Time lost due to work-based injuries?

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

0 - The company reports zero deaths in 2022.

166. Commitment to support smallholders?

167. Programme to support outgrower scheme and/or independent smallholders?

168. Number or percentage of outgrower scheme and/or independent smallholders involved in programme?

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

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

171. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1). Partial points have been awarded as the requirements do not fully meet the SPOTT scoring criteria.

172. Timebound action plans (including Key Performance Indicators) for suppliers to be in compliance with timber and pulp sourcing commitments?

173. Proportion of direct and indirect supply that comes from FMUs which are compliant with timber and pulp sourcing policies?

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 commits all suppliers to ethical conduct and prohibition of corruption.

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

The company reports it provides regular training on existing policies to ensure its employees conduct themselves with the utmost integrity and assurance. Additionally, the company has also established an Integrity Governance Unit (IGU) to oversee all activities and complaint management, which reports directly to both the MACC and the board semi-annually. In 2022, there were no incidents of corruption. However, the information reported is not externally verified.

177. 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.

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

179. 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.

180. Whistleblowing procedure?

The company reports its whistleblowing policy and procedure.

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

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification. The company's own reporting also mentions having a grievance mechanism open to all stakeholders, however, the flow chart of grievances is only reported for local communities.

182. Details of complaints and grievances disclosed?