Kulim (Malaysia) Bhd

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

The company meets this indicator through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own sustainability policy.

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

The company has published a sustainable palm oil policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has established a sustainability and initiative department, chaired by the Head of the Sustainability & Innovation Division.

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

The company's managing director is on the board and has a responsibility for sustainability.

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

2 (25%) - The company reports two (25%) women in the senior management team.

6. Percentage or number of women board members?

1 (33%) - The company reports that is has 1 female board member.

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

[Externally verified] The company is a member of GRI. The company's parent company is a member of UNGC and SASPO.

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

The company reports that it collaborates with WCS and the Management and Ecology of Malaysian Elephants (MEME) to research human-elephant conflict in oil palm plantations. It also collaborates with the Johor National Parks Corporation, Wildlife Department, Forestry Department and the Police on anti-poaching programmes.

9. Sustainability report published within last two years?

The company has published its latest sustainability report for 2020-2021. Data as of Dec 2021. The latest Integrated Report 2022 also includes the sustainability statement.

10. Reports through standardised reporting systems?

The company's reports have been prepared in accordance with GRI standards 101: Foundation requirements.

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 has disclosed plans to conduct a climate risk assessment in the near future.

13. Lists countries and operations?

Malaysia - Johor (23 plantations, 5 mills), Indonesia - South Sumatera (2 plantations).

14. Lists countries sourcing from?

The company states that all FFBs are sourced locally from Malaysia and Indonesia.

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

74786 - The company reports the total land area managed for oil palm as 74,786 ha in its integrated report 2022. The RSPO ACOP 2022 states that the company has 77,082.78 ha of total land area managed/controlled for oil palm.

16. Total oil palm planted area (ha)?

63558 - The company reports 63,558 ha of total oil palm planted area in its RSPO ACOP 2022.

17. Scheme smallholders planted area (ha)?

0 - The company reports 0 ha of total scheme smallholders planted area in its RSPO ACOP 2022.

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

7225 - The company reports 7,225 ha of total unplanted area in its RSPO ACOP 2022.

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

1407.35 - The company reports 1,407.35 ha of conservation set-aside area, including a high conservation value (HCV) area.

20. Maps of estates/management units?

The concession boundaries have been made available to the RSPO and the company declares no new concession acquisition or change in the ownership of existing concessions was undertaken according to RSPO ACOP 2022.

21. Maps of all scheme smallholders?

22. Maps of all third-party supplying plantations?

23. Number of company-owned mills?

5 - The company reports that it has five palm oil mills.

24. Names and locations of company-owned mills?

The company reports the names and coordinates of all five mills in GFW Universal Mill List.

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

The company reports that two out of five mills source only from company-owned operations, and that the remaining mills source from company-owned operations and third parties.

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

The company reports that in 2022, FFB produced by its own mills was 1,030,864 (MT), and purchased FFB from external suppliers was 378,273 (MT).

27. Number of third party supplying mills?

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

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

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

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

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

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

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

31. 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.

32. 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.

33. Percentage of supply traceable to mill level?

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

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

The company commits to achieve 100% traceability to plantation level by the year 2025.

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

The company reports that 87.52% of FFB supplied to own mills is traceable to plantation level. All five mills have IP certifications.

36. 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.

37. Publishes traceability data at refinery level?

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

38. Publishes traceability data at crusher level?

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

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

[Externally verified] 2004 - Kulim (Malaysia) joined the RSPO in 2004, and its parent company, Johor Corporation, joined in 2009. Kulim is now reported under its parent company, Johor Corporation.

40. 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?

[Externally verified] 2009 - The company reports RSPO membership since 2004 and almost all plantations have been fully certified since January 2009.

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

The company is now reported under its parent company, Johor Corporation which submitted its recent RSPO ACOP 2022.

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

79.09% - The RSPO ACOP 2022 states that the company has 79.09% of RSPO-certified areas.

43. Percentage of mills RSPO-certified?

[Externally verified] 100% - The company reports that all five mills are RSPO certified.

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

2025 - The company commits to achieve 100% RSPO certification of estates and mills by 2025. This is within five years.

45. Time-bound plan for achieving 100% RSPO certification of all palm product processing facilities within 5 years?

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

46. Percentage of scheme smallholders (ha) RSPO-certified?

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

2025 - The company commits to achieve 100% RSPO certification of scheme/associated smallholders and outgrowers by 2025. This is within 5 years.

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

9.8% - The company's RSPO ACOP 2022 states that 9.8% of FFB supply from independent smallholders, outgrowers, and third-party FFB suppliers are RSPO-certified.

49. 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.

50. Sells RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

The company's RSPO ACOP 2022 states that it sells 59.55% of RSPO-certified palm oil through segregated or identity-preserved supply chains.

51. Processes/trades RSPO-certified palm oil through Segregated or Identity Preserved supply chains?

This indicator is disabled as the company only reports a Grower ACOP.

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

53. Malaysia Sustainable Palm Oil (MSPO) certified?

[Externally verified] All of the company's estate and mills are 100% MSPO-certified.

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

[Externally verified] The company is certified under ISCC.

55. Commitment to zero conversion of natural ecosystems?

The company commits to zero conversion of natural ecosystems.

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

The company commits all suppliers to zero conversion of natural ecosystems.

57. Commitment to zero deforestation?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have been therefore awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to zero deforestation in its own reporting. However, the commitment is made after 1 Jan 2020.

58. Commitment to zero deforestation applies to all suppliers?

The company's commitment to zero deforestation applies to all suppliers. The policy was introduced after January 2020.

59. Criteria and cut-off date for defining deforestation?

The company commits to no land clearing damaging primary forests or areas required to protect or enhance HCVs since November 2005, and no land clearing damaging HCVs or HCS forest since November 2018, through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also defines deforestation as HCV and HCS areas with a cut-off date of October 2021 in its own reporting.

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

The company defines deforestation as HCV and HCS areas with a cut-off date of October 2021. The company states that it works closely with business partners for the application of the policy for business interest, and also ensures that the policy is communicated to third parties and suppliers, however it does not clearly commit all suppliers to this policy.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it monitors deforestation in its supply base through its subscription to the GFW satellite provider which covers its buffer zone boundary along forest reserve areas.

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

[Externally verified] The company reports that it monitors deforestation in its supply base through its subscription to the GFW satellite provider. The company reports that monitoring covers 10,715.38 Ha. This information is externally verified by Control Union.

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

0 - As of 2022, The company states that it has not detected any evidence of deforestation within its boundaries since 2018.

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

0 - As of 2022, The company states that it has not detected any evidence of deforestation within its suppliers' operations since 2018.

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

The company commits to restore ecosystems to their prior condition in cases of conversion within its own operations since its October 2021 cut-off date.

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

The company commits suppliers to restore ecosystems to their prior condition in cases of conversion within their own operations. The commitment has been in place since October 2021.

67. Implementing a landscape or jurisdictional level approach?

68. Biodiversity policy?

The company has a general statement to promote the conservation and development of biodiversity. However, the scope and targets were not reported.

69. Biodiversity policy applies to all suppliers?

70. 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. The company has also identified several species of conservation concerns, referencing the international system of species classification (IUCN).

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it has been maintaining wildlife corridors linking natural habitats within its estates since 2011. The company through its conservation group, KWD, collaborates with the Johor National Parks Corporation, Wildlife Department, Forestry Department, and the Police on 'anti-poaching programmes'.

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

The company commits to no hunting of all species in its operations.

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

The company commits all suppliers to 'no illegal or inappropriate hunting'. However, it is not a clear commitment to no hunting or only sustainable hunting of species.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to conduct High Conservation Value (HCV) assessments in its own reporting.

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

The company states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. However, its not clear if all suppliers are required to conduct HCV assessments.

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

[Externally verified] The High Conservation Value (HCV) assessments for planting undertaken prior to January 2015 are available for PT Harapan Barito Sejahtera, PT Wahana Semesta Kharisma and PT Sawit Sumber Rejo on the RSPO NPP Website.

77. High Conservation Value (HCV) assessments for all estates planted/planned planting since January 2015?

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

78. High Conservation Value (HCV) or combined HCV/HCS management and monitoring plans for all estates planted/planned planting since January 2015?

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

80. 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?

81. 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.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to the High Carbon Stock (HCS) Approach in its own reporting.

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

The company commits to the HCS Approach and that it works closely on the application of the commitment and other relevance with its business partners including suppliers. This is not a clear commitment covering all suppliers.

84. High Carbon Stock (HCS) assessments available?

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

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

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to conduct social and environmental impact assessments in its own reporting.

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

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

[Externally verified] The SEIA reports are publicly available for PT Harapan Barito Sejahtera, PT Wahana Semesta Kharisma, and PT Sawit Sumber Rejo on the RSPO NPP website.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to no planting on peat of any depth in its own reporting.

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

The company commits all suppliers to no planting on peat of any depth.

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

15827 - The company reports 1,380 ha of peatland in Malaysia and 14,447 ha in Indonesia. Data as of 2022.

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

The company reports that its planted area on pet has stayed as 1,380 ha between 2020-2022.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to best management practices for peat only in its own reporting.

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

The company commits to best management practices for peat only and states it this applies to all suppliers.

95. 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. The company also reports that it has enhanced its water management system by constructing weirs in strategic locations to maintain optimum water levels on peat soil.

96. Commitment to zero burning?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to zero burning in its own reporting.

97. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

98. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it has subscribed to GeoRSPO to monitor concession areas by satellite technology and has identified hotspots and fires at its own estates. It also conducts training on firefighting and set up fire monitoring towers for every 500 ha of its plantation, and a station for a fire emergency response team.

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

The company reports that one fire was recorded in its estates in 2022.

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

1 - The company reports one fire within the surrounding landscape in 2022.

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

The company commits to reducing its GHG emissions intensity by 50% by the year 2025. The target includes scope 1, 2, and 3 emissions.

102. GHG emissions intensity?

The company reports its GHG emissions intensity as 0.93 MT CO2e per MT of CPO and PK in 2022. This includes scope 1, 2 and 3 emissions.

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

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

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

105. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports its GHG emission intensity as 1.23 mtCO2e/ mtCPO (2020), 1.13 mtCO2e/ mtCPO (2021), and 0.93 mtCO2e/ mtCPO . The information is externally verified by Control Union.

106. Methodology used to calculate GHG emissions?

The RSPO requires companies to assess their GHG emissions through the Palm GHG calculator. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also uses the PalmGHG V4 calculator to measure its gross carbon emissions on an annual basis.

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

The company reports that 100% of its mills were equipped with methane capture facilities.

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

The company reports that it remained below its yearly target of 1.2 m3 per tonne of FFB in 2022, however it does not report a base year or base figure.

109. Water use intensity?

1.13 - The company reports its water consumption intensity as 1.13 m3 per tonne FFB in 2022.

110. Progress towards commitment on water use intensity?

[Externally verified] The company reports water consumption intensity as 1.13 m3 per tonne FFB (2022) and 1.11 m3 per tonne FFB (2021). The figures have improved over time but are kept within a yearly target of 1.2 m3 per tonne of FFB.

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

The company reports that it strives to keep BOD levels in line with the Johor Department of Environment requirements. However, this is an unclear commitment and no legal limits are stated.

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

[Externally verified] The company reports that BOD levels are within legal limits across all of its mills.

113. 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 that it treats POME through microbial digestion before discharging it into waterways.

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

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

115. Commitment to protect natural waterways through buffer zones?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to protect natural waterways through buffer zones.

116. 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. The company also reports that it has created buffer zones near water bodies in order to protect them.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to minimise the use of chemicals in its own reporting.

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

The company commits to minimising chemical use, but does not specify pesticides and fertilisers. It states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. This is not a clear commitment covering all suppliers.

119. Commitment to no use of paraquat?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to no use of paraquat in its own reporting.

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to no use of World Health Organisation (WHO) Class 1A and 1B pesticides in its own reporting.

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

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention in its own reporting.

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

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

The company reports its chemical usage of herbicide and paraquat in litre/hectare.

126. 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. The company also reports that it uses organic fertilisers, derived from EFB (a waste product from the milling process) to reduce water pollution from heavy metals.

127. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it uses an Integrated Pest Management (IPM) approach including the use of barn owls to control the rodent population and certain plants that acts as natural pest eradicators.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it generates two types of waste including bio-based and scheduled waste, bio-based waste is managed through composting while scheduled waste is disposed of by licensed contractors.

129. Commitment to human rights?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to the UN Declaration on Human Rights in its own reporting.

130. Commitment to human rights applies to all suppliers?

The company commits to human rights, but does not reference the Universal Declaration of Human Rights or equivalent. The company states that it works closely on the application of the commitment and other relevance with its business partners including suppliers. This is not a clear commitment covering all suppliers.

131. Progress on human rights commitment?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company reports that it has collaborated with the 'Human Rights Commission' of Malaysia (Suhakam) and other stakeholders to assess the group's labour practices and improve ESG efforts and initiatives.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to respect indigenous and local communities' rights in its own reporting.

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

The company commits to protecting the rights of local communities and indigenous peoples in relation to FPIC. It is unclear if the commitment applies to all suppliers.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to respect legal and customary land tenure rights in its own reporting.

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

The company reports that it will protect cultural heritage and customary land use when conducting new land developments. This commitment applies to all suppliers.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to free, prior, and informed consent (FPIC) in its own reporting.

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

The company commits all suppliers to respect FPIC.

138. 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). Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

139. Examples of local stakeholder engagement to prevent conflicts?

140. Details of process for addressing land conflicts available?

The RSPO Principles and Criteria 2018 contain requirements for addressing land conflicts. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has established a 'Women OnWards ("WOW") Programme' which supports and promotes gender equality as well as advances the knowledge and skills of its female employees.

142. Commitment to mitigate impacts on food security?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also states that it embraces the national food security programme.

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

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

144. Commitment to provide essential community services and facilities?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to providing essential services and facilities to communities living nearby.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has donated RM25 million for public and social development such as Yayasan JCorp, schools and NGOs. It also runs outreach programmes that focus on five key areas: community well-being, sports, welfare, education, and infrastructure development.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to providing business opportunities for local communities in its own reporting.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to the ILO's Declaration on Fundamental Principles and Rights at Work in its own reporting.

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

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. Control Union has externally verified some activities such as the establishment of core labour standards and sexual harassment policies.

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

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to eliminate gender-related discrimination with regard to employment in its own reporting.

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

The company's commitment to eliminate discrimination regarding employment is applicable to external stakeholders but does not specify suppliers. It is also unclear if it relates to gender discrimination.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company has established the 'Women OnWards ("WOW") Programme' to support and promote gender equality, and also to advance the knowledge and skills of its female employees.

153. Percentage or number of temporary employees?

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

154. Percentage or number of women employees?

1044 (12.16%) - The company reports that it has 1044 (12.16%) women employees in 2022.

155. Commitment to pay a Living Wage?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to pay only minimum wage in its own reporting.

156. Commitment to pay a Living Wage applies to all suppliers?

157. Progress on commitment to pay a Living Wage?

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

158. Reporting of salary by gender?

The company reports the average basic salary ratio by gender by employment category.

159. Commitment to address occupational health and safety?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to addressing occupational health and safety in its own reporting.

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

The company commits all suppliers to address health and safety at work for all workers.

161. Provision of personal protective equipment and related training?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The Control Union reports that the company has conducted training on PPE.

162. Time lost due to work-based injuries?

1.44 - The company reports a Lost Time Accident Rate (LTAR) of 1.44 in 2022.

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

0 - The company recorded zero fatalities as a result of work-based accidents in 2022.

164. Commitment to support smallholders?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years.

165. Programme to support scheme smallholders?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also has a 'Smallholder Inclusion Programme' in which it pays a premium of RM2 per tonne of certified FFB purchased to encourage the adoption of sustainability certification. It has also made payments to two certified scheme smallholders that supply them. In 2021, this premium was increased to RM6 per tonne of certified FFB to encourage more smallholders to apply for RSPO certification.

166. Percentage of scheme smallholders involved in programme?

[Externally verified] 12% - The company reports that as of December 2022, 12% of scheme smallholders are involved in its programme.

167. Programme to support independent smallholders?

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company supports independent smallholders and traders for certification journeys by introducing them to certification bodies and programmes to assist with progress. It also provides technical support wherever possible.

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

[Externally verified] 2 - The company reports there are here are two outgrowers (non-certified) involve in the smallholders' program in 2022. The information is externally verified by Control Union.

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

The company describes the processes it uses to prioritise and engage with suppliers.

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

[Externally verified] 100% - Control Union externally verifies that 100% of the company's suppliers are assessed on compliance with the company's FFB purchasing agreement.

171. Suspension or exclusion criteria for suppliers?

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

173. Proportion of supply from suppliers that is verified as deforestation- and/or conversion-free (DCF)?

174. 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.

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

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

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

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

177. 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.

178. 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.

179. 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.

180. Commitment to ethical conduct and prohibition of corruption?

The company makes this commitment through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also commits to ethical conduct and the prohibition of corruption in its own reporting.

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

The company commits all suppliers to ethical conduct and the prohibition of corruption.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's RSPO-certified landbank. The company also reports that it has 'ABMS Awareness Programmes' under which it conducts training for directors and a 'Bribery Risk Assessment' to identify and evaluate the exposures within the group to mitigate and prevent potential risks.

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

184. Whistleblowing procedure?

The RSPO Principles and Criteria 2018 contain guidance and requirements on whistleblowing procedures. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company has its own whistleblowing policy which also includes information on how the whistleblower is protected.

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

The company adheres to this criteria through the RSPO Principles and Criteria 2018. Full points have therefore been awarded on the basis of the company's RSPO-certified landbank (>75%) and a further commitment to be 100% certified within 5 years. The company also has its own grievance system which is open to all stakeholders.

186. Details of complaints and grievances disclosed?

The company only lists the number of grievances per year.