MY02203 Summary Report against RSPO MYNI Requirement for IOI Corporation Bhd, Gomali mill & estates Page 1 OILPALM PLANTATION MANAGEMENT SURVEILLANCE AUDIT REPORT Project Nr: MY02203 Certificate Nr: SGS-RSPO/PM-00573 Validity Period: 23 Aug 2010 – 22 Aug 2015 Report Ref #: MY02023-04 Gomali 2011 Surv 01 Report Client: IOI Corporation Bhd RSPO membership #: 010-04(O) Web Page: http://www.ioigroup.com/business/busi_plantoverview.cfm Address: Head office: Level 8, Two IOI Square IOI Resort, 62502 Putrajaya Malaysia. Contact: Mr. Too Heng Liew Head of Sustainability Phone No.: 03-89478691 E-mail: [email protected]Country: Malaysia Plantation Unit being Evaluated Gomali oil mill and its supply base plantation in Negeri Sembilan, Pahang and Johor. Company Contact Person: Mr. Too Heng Liew Address: Gomali Palm Oil Mill 5 mile, Jln Gemas – Batu Anam K.B. No 102, 85109 Batu Anam, Segamat, Johor Tel: 07-949 8245 Fax 07-949 9245 Email: [email protected]Evaluation dates: Main Evaluation 10 – 14 August 2009 Surveillance 1 23-25 August 2011 Surveillance 2 August 2012
2.1 Annual Surveillance Audit methodology (program, site visits)
During the 3 days annual surveillance audit, 6 estates as well as the CPO mill were visited
by the audit team. Management documents both at the group as well as the estate levels
were reviewed. Standard operation procedures documented for the estate and the mill
operations were also reviewed. Records of production, report, training etc were inspected.
The audit team visited various operation sites such as replanting, manuring, pesticide
application, harvesting, environmental sampling, fragile soil areas, etc.
Discussions were held with the top estate managers as well as ground staff. Interviews were
also held with workers and local communities living in and around the area.
Table 8: Annual Surveillance Audit Schedule
Date Activities Notes
23 August 2011
Opening meeting Briefing by IOI Discussion on assessment schedule.
Documentation review Documents for review were made available. Documents were reviewed at the mill.
Visit to the mill Receipt of FFB, Mill operation, Mill design, OSH aspects, POME, EFB, CPO production Environmental monitoring records, Licensing
24 August 2011
Visit to: - Bahau - Kuala Jelai - Regent
Areas covered include harvesting area, spraying, fertilizing, chemical storage, workshop, waste management system, quarters, clinic, local communities, orang asli, bufferzone, riparian and nursery. In addition, a documentation review was conducted at each of the visited estate.
25 August 2011
Visit to: - Tambang - Paya Lang - Gomali
Closing meeting Preliminary results of the surveillance audit were presented to the management.
2.2 Team members
Table 9: Summary of team member’s experience
Evaluation Team Notes
Lead Auditor Abdul Haye Semail, B.Sc. Abdul Haye is a forester by profession with nearly 15 years experience in forest harvesting and plywood industry. As a trained assessor, he has been involved in forest certification and chain of custody for the last 5 years. Trained by RSPO for auditing against RSPO P&C and involved in a number of plantation assessments and inspection of palm oil mill.
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Team Leader James Ong, a B.Agric Sc. holder and agronomist in SGS (M) Sdn Bhd. He has many years experience in agriculture sector in Malaysia having worked in estates as well in the agrochemical and fertiliser industry. He is well versed with agrochemical and fertiliser applications. Has undergone ISO and RSPO Lead Auditor training and involved in a number audits on oil palm plantations.
Auditor Norashikin Rasikon, B.Sc., holds a degree in forestry, has been involved in certification for the last three years, and has trained under the ISO system and chain of custody evaluation. Currently entrusted in preparing documents for certification system and responsible for maintaining records and report in compliance to accreditation requirement under various certification schemes.
2.3 Certification body
Founded in 1878, the SGS Group is the world’s largest auditing, inspection, testing and verification organisation. Truly global and benefiting from a unique international network of more than 1180 offices, 321 laboratories and 50,000 full time staff, the SGS Group is able to provide its international clientele with a comprehensive range of services in more than 145 countries.
SGS has no manufacturing, trading or financial interests which could compromise its independence. Its guarantee of independence, its reputation for professionalism, integrity and impartiality, as well as its remarkable international network, place the SGS Group in a unique position.
The QUALIPALM Programme managed by SGS Malaysia is the SGS Group’s Oil Palm
Certification Programme accredited by the RSPO. Currently with about 500 staff nationwide,
SGS Malaysia offers verification, inspection and certification services under various sectors
such as agriculture, mineral, oil & gas, system certification as well as natural resources
covering forestry and oil palm.
2.4 Stakeholder notification and consultation
A wide range of stakeholders were contacted 4 weeks before the planned evaluation to inform them
of the evaluation and ask for their views on relevant palm oil sustainability issues. These included
environmental interest groups, local government agencies and forestry authorities, social groups and
workers’ unions etc. See Appendix E for stakeholder’s details and comments.
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3.0 Annual Surveillance Audit findings
3.1 Findings
Principle 1: COMMITMENT TO TRANSPARENCY
Criterion 1.1
Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate language & forms to allow for effective participation in decision making.
1.1.1 Records of requests and responses must be maintained. Compliance
Major
S01 Findings:
Records of requests and responses are maintained
Objective evidence:
The company maintains adequate information which is available for public.
Documented procedures exist for stakeholder information request at the corporate and estate levels. Records of requests and responses are viewed at the estate level. To enhance the communication with the stakeholder, the HQ has developed the mechanism to response to the stakeholders. The established mechanism is made available to the auditing team during the audit (Observation 01 closed). Verification at the IOI’s website confirmed that the website provides adequate information. In addition, the stakeholder lists also available at the Mill and Estates.
The auditing team also observed that there is a mechanism to ensure that documents are publicly available, as stipulated in the individual estate management plans.
The company is in compliance to this requirement: Y
Criterion 1.2
Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes.
1.2.1/ 1.2.2/ 1.2.3/ 1.2.4/ 1.2.5/ 1.2.6/ 1.2.7
Land titles / user rights (C 2.2) Safety and health plan (C 4.7) Plans and impact assessments relating to environmental and social impacts (C 5.1, 6.1, 7.1, 7.3) Pollution prevention plan (C 5.6) Details of complaints and grievances (C 6.3) Negotiation procedures (C 6.4) Continuous improvement plan (C 8.1)
S01 There is a mechanism in place to ensure that documents are publicly available, as stipulated in the individual management plans covering the following documents:
o Land titles / user rights o Safety and health plan o Plans and impact assessments relating to environmental and
social impacts o Details of complaints and grievances o Negotiation procedures o Continuous improvement plan
All relevant legal documents covering land titles and licenses have been displayed for viewing. Safety and health plan as well as environmental and social impact assessment are also available. In addition, There is adequate documentation of complaints and grievances available in each estates including those that have been resolved and the mill. The negotiation procedures are clearly presented in the individual management plans.
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The company is in compliance to this requirement: Y
Principle 2: COMPLIANCE WITH APPLICABLE LAWS AND REGULATION
Criterion 2.1
There is compliance with all applicable local, national and ratified international laws and regulations.
2.1.1 Evidence of compliance with legal requirements.
Compliance
Major
S01 Findings:
Inadequate evidence of compliance with legal requirements.
Objective evidence:
Visit to the Mill observed that the Envirocarbon Sdn. Bhd., the company responsible for production or activated carbon from palm kernel shell are found to be operating without license from authority (New Major CAR 18).
Closing out of Major CAR
Gomali has submitted the corrective action evidence to close the Major CAR issued. Based on the evidence, the Envirocarbon Sdn. Bhd. has appointd Env Consultancy and Monitoring Services Sdn. Bhd. as the Consultant for Registration of the Kiln Process Chimney under the Environmental Quality (Clean Air) Regulations, 1978. Subsequently, has prepared and submitted the application for the written approval for the installation of LEV (c/w Chimney Systems) on September 2011. The consultant also has prepared the Ambient Air Monitoring Report dated December 2011 as well as the Isokinetic & Air Emission Monitoring Report dated January 2012. The DOE also has responded to the application letter through their letter dated 15 March 2012 stating provisions and conditions that need to be comply for the installation of the LEV (Major CAR 18 closed).
The company is in compliance to this requirement: Y
2.1.2 A documented system, which includes written information on legal requirements.
Compliance
Minor
S01 Findings:
In sufficient documented system including written information on legal requirements.
Objective evidence:
Hard copies of all relevant legal documents such as laws, licences and permits are viewed at the estate office. However, the auditing team observed that the copies of laws available at the estate office are not completed as per the list of the laws listed within the RSPO standard (New Minor CAR 19).
The company is in compliance to this requirement: N
2.1.3 A mechanism for ensuring that they are implemented. Compliance
Minor
S01 Findings:
Mechanism for ensuring the system is implemented is available.
Objective evidence:
A Minor CAR 01 was issued during the Main Evaluation regarding to lack of documented system to ensure that full legal compliance is met. The company has taken action to appoint the responsible person for monitoring any changes of laws and regulations. A copy of laws also found to be compiled at the Mill’s office. (Minor CAR 01 closed).
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The company is in compliance to this requirement: Y
2.1.4 A system for tracking any changes in the law. Compliance
Minor
S01 Findings:
A system for tracking any changes in the law is available.
Objective evidence:
There is a mechanism in place to advise the estates and mill of changes in the laws when it affects their operations.
The IOI sustainability team based in IOI Research Centre in Batang Melaka, Melaka is responsible to monitor any changes to all relevant laws & regulations.
The company is in compliance to this requirement: Y
Criterion 2.2
The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights.
2.2.1 Evidence of legal ownership of the land including history of land tenure. Compliance
Major
S01 Findings:
Legal ownership of the land including history of land tenure is available.
Objective evidence:
Evidence of legal ownership of the land is maintained in individual estates’ offices. The land was purchased by IOI in 1980s and at that time, most of it was already under oil palm.
A copy of occupation and premise use license was viewed: Lesen untuk menduduki atau menggunakan premis yang di tetapkan (# 002103) dated 24 July 2007. Seksyen 18(1) Akta Kualiti Alam Sekeliling 1974. (Environmental Quality Act, 1974).
The company is in compliance to this requirement: Y
2.2.2 Growers must show that they comply with the terms of the land title. [This indicator is to be read with Guidance 2].
Compliance
Major
S01 Findings:
The term of condition provided evidence that the company does comply with the terms of the land title.
Objective evidence:
The estates comply with the terms of the land title.
The company is in compliance to this requirement: Y
2.2.3 Evidence that boundary stones along the perimeter adjacent to state land and other reserves are being located and visibly maintained.
Compliance
Minor
S01 Findings:
Boundary stones along the perimeter adjacent to state land and other reserves can be located and visibly maintained.
Objective evidence:
All estates have their boundary marked with boundary markers. In addition, Gomali has a special mapping team with accurate GPS equipment for boundary verification.
The company is in compliance to this requirement: Y
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2.2.4 Where there are, or have been, disputes, proof of resolution or progress towards resolution by conflict resolution processes acceptable to all parties are implemented. CF 2.3.3, 6.4.1 and 6.4.2.
Compliance
Minor
S01 Findings:
There is no dispute reported at the time of audit. Interviews with the villagers indicate the same.
Objective evidence:
No dispute evidenced.
The company is in compliance to this requirement: Y
Criterion 2.3
Use of the land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent.
2.3.1 Where lands are encumbered by customary rights, participatory mapping should be conducted to construct maps that show the extent of these rights.
Compliance
Major
S01 Findings:
Evidence of mapping conducted to construct maps that show the extent of the customary rights.
Objective evidence:
Details of all the worshipping places have been documented and mapped in the HCV document. In addition, discussion and consultation with the effected parties agreed to earmark the area as HCV. Following to the discussion and consultation, the management documentation is developed to manage such areas (Observation 02 closed).
The company is in compliance to this requirement: Y
2.3.2 Map of appropriate scale showing extent of claims under dispute. Compliance
Major
S01 Findings:
Evidence of appropriate scale map showing the extent of claims under dispute.
Objective evidence:
Map on the disputed land by the villagers as described under 2.2.4 with GPS points is available.
The company is in compliance to this requirement: Y
2.3.3 Copies of negotiated agreements detailing process of consent. (C2.2, 7.5 and 7.6).
Compliance
Minor
S01 Findings:
A copy of negotiated agreements detailing process of consent is available.
Objective evidence:
Record of process covering discussion and consultation with the effected parties with regard to the earmarking and protection of worshipping places is available.
The company is in compliance to this requirement: Y
Principle 3: COMMITMENT TO LONG-TERM ECONOMIC AND FINANCIAL VIABILITY
Criterion 3.1
There is an implemented management plan that aims to achieve long-term economic and financial viability.
3.1.1 Annual budget with a minimum 2 years of projection. Compliance
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Major
S01 Findings:
Annual budget with a minimum 2 years of projection is available.
Objective evidence:
Planning documents covering the next 5 years viewed mentioned: planting material, crop project and yield trends, mill extraction rate, and budgeted production costs. Each of the Estates and Mill have identified the items and drawn up a budget to cover their operational needs for the next 5 years. All plans are also reviewed annually.
The company is in compliance to this requirement: Y
3.1.2 Annual replanting programme projected for a minimum of 5 years with yearly review.
Compliance
Minor
S01 Findings:
Evidence of annual replanting programme projected for a minimum of 5 years with yearly review.
Objective evidence:
The plantation management unit has a good re-planting programme. A ten year replanting programme is available in individual estates and the programme is reviewed annually.
The company is in compliance to this requirement: Y
Principle 4: USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS:
Criterion 4.1
Operating procedures are appropriately documented and consistently implemented and monitored.
4.1.1 Documented Standard Operating Procedures (StOPs) for estates and mills.
Compliance
Major
S01 Findings:
Evidence of documented Standard Operating Procedures (StOPs) for estates and mills.
Objective evidence:
Main Evaluation resulted in the issuance of Observation 03 for the StOPs that does not cover all activities in the Estates for example the waste disposal. ASA1 evidenced that the Gomali has taken action to establish the committee to review the StOPs to cover all activities in the Estates. The revised StOPs dated 6 June 2011 including the StOPs for ‘Tapak Penolahan Effluent’ is made available to the auditor during the audit (Observation 03 closed).
The company is in compliance to this requirement: Y
4.1.2 Records of monitoring and the actions taken are maintained and kept for a minimum of 12 months.
Compliance
Minor
S01 Findings:
Records of monitoring and the actions taken are maintained and kept for a minimum of 12 months.
Objective evidence:
During the Main Evaluation, the Minor CAR 02 was issued due to Insufficient records of monitoring and weak mechanism to undertake such monitoring of StOPs. Verification during the ASA1 evidenced that the implementation of the StOPs is monitored and all records of implementation is kept including the monitoring as well as actions taken following the monitoring (Minor CAR 02
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closed).
The company is in compliance to this requirement: Y
Criterion 4.2
Practices maintain soil fertility at, or where possible improve soil fertility to a level that ensures optimal and sustained yield.
4.2.1 Monitoring of fertilizer inputs through annual fertilizer recommendations. Compliance
Minor
S01 Findings:
Evidence of monitoring of fertilizer inputs through annual fertilizer recommendations.
Objective evidence:
Based on the record, the Plantation Adviser makes two visits per year to each estate and checks fertilizer application as well as other field practices. The R&D unit collects annual foliar samples for analysis of nutrients and some trace elements, eg boron. Data captured are analysed for optimisation of FFB yield and review of the fertiliser programme. Soil sampling is conducted over 25 % of the area yearly for the same purpose.
Data on the locations where EFB and mill effluent are applied is also collected. Such an area will be monitored in term of FFB production, nutrient and soil condition.
The company is in compliance to this requirement: Y
4.2.2 Evidence of periodic tissue and soil sampling to monitor changes in nutrient status.
Compliance
Minor
S01 Findings:
Evidence of periodic tissue and soil sampling being carried out to monitor changes in nutrient status.
Objective evidence:
A programme is in place for the annual collection of nutrient samples from both leaf tissue and soil. These are used to assess the nutrient state of the palms and their soils, and used to guide subsequent fertiliser needs. Based on the record the auditing team observed that the tissue/foliar sampling is conducted yearly in all blocks while soil sampling is done on 20 % of the total hectareage in a rotational manner, in particular once every 5 years.
The company is in compliance to this requirement: Y
4.2.3 Monitor the area on which EFB, POME and zero-burn replanting is applied.
Compliance
Minor
S01 Findings:
Evidence of monitoring of the area which EFB, POME and zero-burn replanting is applied.
Objective evidence:
Gomali practices a zero burning policy. However, because of significant losses of palms from Ganoderma infection, an official application is made to the DoE and permission received to undertake controlled burning at replanting to sterilise the fields.
EFB, boiler ash and POME are applied in trenches and direct spraying to frond heaps–subject to transport limitations, and records monitoring the amounts applied are available.
The company is in compliance to this requirement: Y
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Criterion 4.3
Practices minimise and control erosion and degradation of soils.
4.3.1 Documented evidence of practices minimizing soil erosion and degradation (including maps).
Compliance
Minor
S01 Findings:
Documented evidence of practices minimizing soil erosion and degradation (including maps) is available.
Objective evidence:
A Minor CAR 03 was raised during the Main Evaluation relating to inconsistent implementation of the StOPs in some area resulting in chronic soil erosion. Visit during the ASA1 confirmed that all areas prone to soil erosion has been identified and documented in the StOPs. In addition, an action plans to minimize soil erosion and establishment of plant to improve the texture of fragile soil (Minor CAR 03 closed).
The company is in compliance to this requirement: Y
4.3.2 Avoid or minimize bare or exposed soil within estates. Compliance
Minor
S01 Findings:
Evidence of minimized bare or exposed soil within estates.
Objective evidence:
Visit to the field evidenced that in general, ground is covered with soft grasses and pruned fronds. In addition, there is also evidence of historical soil erosion control area observed through terracing.
The company is in compliance to this requirement: Y
4.3.3 Presence of road maintenance programme. Compliance
Minor
S01 Findings:
Objective evidence:
Minor CAR 04 was issued during the Main Evaluation due to the road maintenance programme available but it has not been undertaken for some time in some of the estates. ASA1 evidenced that Gomali has taken action to implement the road maintenance programme at erosion prone area. In addition, there is also evidence of silt pits observed during the field visit (Minor CAR 04 closed).
The company is in compliance to this requirement: Y
4.3.4 Subsidence of peat soils should be minimised through an effective and documented water management programme.
Compliance
Minor
S01 Findings:
Not applicable as there are not peat soil in Gomali estates.
Objective evidence:
NA
The company is in compliance to this requirement: Y
4.3.5 Best management practices should be in place for other fragile and problem soils (e.g. sandy, low organic matter and acid sulphate soils).
Compliance
Minor
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S01 Findings:
Best management practices are in place for other fragile and problem soils (e.g. sandy, low organic matter and acid sulphate soils).
Objective evidence:
Gomali has implemented various practices to protect soils that prone to erosion covering the following:
leguminous cover crop applied in new planting areas;
cut and stacked fronds act as physical barriers to trap run-off and eroding soils and subsequently increased soil biomass when it degrades;
EFB and biomass solids in POME returned to selected fields;
once the leguminous cover crop begins to die back, soft weeds and ferns are tolerated in inter-rows, and competing woody plants removed; conservation terraces where constructed at the time of planting with stop bunds;
fronds are stacked on the lip of terraces, but contour stacking is not consistently implemented on other slopes;
road design generally minimises water run-off and soil erosion, with wash-out drains returning nutrients and soil mass back to pits in the fields; and
the banks of some waterways are vegetated to help retain soils.
The company is in compliance to this requirement: Y
Criterion 4.4
Practices maintain the quality and availability of surface and ground water.
4.4.1 Protection of water courses and wetlands, including maintaining and restoring appropriate riparian buffer zones at or before replanting along all natural waterways within the estate.
Compliance
Major
S01 Findings:
Inadequate demonstration of the protection of water courses and wetlands, including maintaining and restoring appropriate riparian buffer zones at or before replanting along all natural waterways within the estate.
Objective evidence:
Main Evaluation observed that Minor CAR 05 was issued due to bufferzone are not identified and demarcated along most of river streams. Visit to the bufferzones during the ASA1 evidenced that Gomali has taken action to identify and demarcate most of the visited bufferzone along river streams. However, the auditing team is of the view that the process taken is insufficient to close the Minor CAR due to a visit in one bufferzone in Bahau Estate evidenced that the Bufferzone is not properly demarcated (Minor CAR 05 remained outstanding).
The company is in compliance to this requirement: N
4.4.2 No construction of bunds/weirs/dams across the main rivers or waterways passing through an estate.
Compliance
Major
S01 Findings:
No evidence on construction of bunds/weirs/dams across the main rivers or waterways passing through an estate.
Objective evidence:
No construction of bunds, weirs and dams were observed in the estates.
The company is in compliance to this requirement: Y
4.4.3 Outgoing water into main natural waterways should be monitored at a frequency that reflects the estates and mills current activities which may have negative impacts (Cross reference to 5.1 and 8.1).
Compliance
Major
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S01 Findings:
Outgoing water into main natural waterways is monitored at a frequency that reflects the estates and mills current activities.
Objective evidence:
Outgoing water into natural waterways is being monitored for water quality. Sample points are mapped and a schedule for sampling has been drawn up. Records showed that latest Water Monitoring was done on 9 July 2011 at 5 stations along Sg Sebaling river.
The company is in compliance to this requirement: Y
4.4.4 Monitoring rainfall data for proper water management. Compliance
Minor
S01 Findings:
Rainfall data for proper water management is monitored.
Objective evidence:
Rainfall data are being monitored and daily record are available in all Estates.
The company is in compliance to this requirement: Y
4.4.5 Monitoring of water usage in mills (tonnage water use/tonne FFB processed).
Compliance
Minor
S01 Findings:
Water usage in mills (tonnage water use/tonne FFB processed) is monitored.
Objective evidence:
Water usage for the mill is being monitored. Daily record & Monthly Monitoring of water usage in mills (tonnage water ly record use/tonne FFB processed) available. Based on record the usage for 2011untill July is 0.92m3/FFB compared to the usage for 2010 during the same period which is 0.96m3/FFB.
The company is in compliance to this requirement: Y
4.4.6 Water drainage into protected areas is avoided wherever possible. Appropriate mitigating measures will be implemented following consultation with relevant stakeholders.
Compliance
Minor
S01 Findings:
Not applicable.
Objective evidence:
There was no drainage into protected areas. The forest reserves are located upstream of the estates.
The company is in compliance to this requirement: Y
4.4.7 Evidence of water management plans. Compliance
Minor
S01 Findings:
Water management plan is available.
Objective evidence:
Water management plan for all estates available. In general, the plan covers the operating units particularly the estates. The plan also identifies water management plans for the POM (water source, usage for both FFB processing and domestic, water treatment for POM and domestic, monitoring of quality, consumption, wastewater (POME) treatment and management etc) Water management plans for Gomali estates that includes soil moisture conservation programme, EFB mulching, terracing, buffer zones and rivers, sampling and water quality
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monitoring, sewage and septic and domestic water usage, and nursery and office.
Aspects of water management are also covered under the ‘Group Internal Environmental Management and Monitoring Plan’, focusing principally on meeting legal requirements. This document covers: conserving sources for abstraction; managing riparian areas; contamination by estate and mill activities; monitoring ground and surface water quality, and consumption of water.
The company is in compliance to this requirement: Y
Criterion 4.5
Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques.
4.5.1 Documented IPM system. Compliance
Minor
S01 Findings:
Adequate documented IPM system observed.
Objective evidence:
The Main Evaluation resulted in the issuance of Minor CAR 06 on lack of mechanism to monitoring herbicide usage. ASA1 evidenced that there is mechanism in place to monitor the usage of herbicide as follows:
o Training is given to the herbicide sprayers for not to spray on the bare ground or area which has not much vegetation e.g. due to prolonged dry period;
o Monitoring on the application of herbicide to ensure no spraying on the bare areas; and
o Justification is established for the area requires chemical spraying.
Minor CAR 06 closed.
The company is in compliance to this requirement: Y
4.5.2 Monitoring extent of IPM implementation for major pests. Compliance
Minor
S01 Findings:
IPM implementation for major pests is monitored.
Objective evidence:
The estate has the procedures to monitor for the presence and location of pests and the current severity of their effects. Record on the implementation of IPM is maintained.
The company is in compliance to this requirement: Y
4.5.3 Recording areas where pesticides have been used. Compliance
Minor
S01 Findings:
Recording areas where pesticides have been used is available.
Objective evidence:
Records of types and dosage of pesticides used, the blocks where the pesticides have been applied, and the dates of application are maintained.
The company is in compliance to this requirement: Y
4.5.4 Monitoring of pesticide usage units per hectare or per ton crop e.g. total quantity of active ingredient (a.i.) used/ tonne of oil.
Compliance
Minor
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S01 Findings:
Pesticide usage is monitored.
Objective evidence:
Pesticide usage is monitored and recorded based on units used per ha. The practice appears to be consistent within all areas sampled.
The company is in compliance to this requirement: Y
Criterion 4.6
Agrochemicals are used in a way that does not endanger health or the environment. There is no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. Where agrochemicals are used that are categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented.
4.6.1 Written justification in Standard Operating Procedures (StOPs) of all agrochemicals use.
Compliance
Major
S01 Findings:
Written justification in Standard Operating Procedures (StOPs) of all agrochemicals use is available.
Objective evidence:
There is a written justification for the chemicals used that highlights the objective for control and the appropriate chemicals to be used.
The company is in compliance to this requirement: Y
4.6.2 Pesticides selected for use are those officially registered under the Pesticides Act 1974 (Act 149) and the relevant provision (Section 53A); and in accordance with USECHH Regulations (2000).
Compliance
Major
S01 Findings:
Pesticides use are those that officially registered under the Pesticides Act, 1974 (Act 149) and the relevant provision (Section 53A); and in accordance with USECHH Regulations (2000).
Objective evidence:
Chemicals used are registered. All chemicals in use have been assessed in the Chemical Health Risk Assessment (CHRA) document.
The company is in compliance to this requirement: Y
4.6.3 Pesticides shall be stored in accordance to the Occupational Safety and Health Act 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations.
Compliance
Major
S01 Findings:
Pesticides used in estates are not sufficiently stored in accordance to the Occupational Safety and Health Act, 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations.
Objective evidence:
Visit to the Bahau Estate evidenced the triple rinsing and perforated procedure is inconsistently implemented at the chemical storage area (New Minor CAR 20)
The company is in compliance to this requirement: N
4.6.4 All information regarding the chemicals and its usage, hazards, trade and generic names must be available in language understood by workers or explained carefully to them by a plantation management official at operating unit level.
Compliance
Major
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S01 Findings:
Information regarding chemicals and its usage, hazards, trade and generic names is available in language understood by workers or explained carefully to them by a plantation management official at operating unit level.
Objective evidence:
Main Evaluation has resulted in the issuance of Minor CAR 07 relating to lack of evidence that information on chemicals is available in language understood by workers. Visit during the ASA1 evidenced that Gomali has established the information on chemicals and its usage, hazards, trade and generic names in language understood by the workers such as Bahasa Melayu and Bangladesh languages (Minor CAR 07 closed).
The company is in compliance to this requirement: Y
4.6.5 Annual medical surveillance as per CHRA for plantation pesticide operators.
Compliance
Major
S01 Findings:
Annual medical surveillance is conducted as per CHRA for plantation pesticide operators
Objective evidence:
CHRA up to date. Medical examinations carried out for pesticides operators with records available for screening for the operators as per in the CHRA.
The company is in compliance to this requirement: Y
4.6.6 No work with pesticides for confirmed pregnant and breast-feeding women.
Compliance
Major
S01 Findings:
No evidence of confirmed pregnant and breast-feeding women work with pesticides.
Objective evidence:
Random interviews with estate hospital assistant, pesticide sprayers and mixers indicated that there are no confirmed pregnant and breast feeding women in the pesticide handling related operations.
The company is in compliance to this requirement: Y
4.6.7 Documentary evidence that use of chemicals categorised as World Health Organisation Type 1A or 1B, or listed by the Stockholm or Rotterdam Conventions and paraquat, is reduced and/or eliminated. Adoption of suitable economic alternative to paraquat as suggested by the EB pending outcome of the RSPO study on IWM.
Compliance
Minor
S01 Findings:
Documentary evidence that use of chemicals categorised as World Health Organisation Type 1A or 1B, or listed by the Stockholm or Rotterdam Conventions and paraquat, is reduced and/or eliminated is available.
Objective evidence:
There is no evidence of usage of chemicals categorised as WHO Type 1A or 1B or those listed by the Stockholm or Rotterdam Conventions.
The company is in compliance to this requirement: Y
4.6.8 Documented justification of any aerial application of agrochemicals. No aerial spraying unless approved by relevant authorities.
Compliance
Major
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S01 Findings:
No evidence of aerial spraying.
Objective evidence:
No use of aerial application of agrochemicals within IOI Gomali Estates.
The company is in compliance to this requirement: Y
4.6.9 Evidence of chemical residues in CPO testing, as requested and conducted by the buyers.
Compliance
Minor
S01 Findings:
No evidence of chemicals residues in CPO testing, as requested and conducted by the buyers.
Objective evidence:
No buyers have requested for testing hence there is no evidence.
The company is in compliance to this requirement: Y
4.6.10 Records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) are maintained for either a minimum of 5 years or starting November 2007.
Compliance
Minor
S01 Findings:
Records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) are maintained.
Objective evidence:
Records of pesticide usage are maintained for 5 years.
The company is in compliance to this requirement: Y
Criterion 4.7
An occupational health and safety plan is documented, effectively communicated and implemented.
4.7.1 Evidence of documented Occupational Safety Health (OSH) plan which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967(Act 139).
Compliance
Major
S01 Findings:
Inconsistency in the implementation of the Personnel Protective Equipments (PPEs) as required by the Occupational Safety Health (OSH) plan which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967(Act 139).
Objective evidence:
Minor CAR 08 was issued during Main Evaluation relating to lapses in implementation, and incomplete awareness and understanding of OSH matters. Observation made during the ASA1 evidenced that Gomali has taken action to organize the training on the Occupational Safety and Health in particular training on the safe working condition. The record of the training is kept (Minor CAR 08 closed).
However, the ASA1 evidenced a non-conformance whereby there is inconsistency in the implementation of the Personnel Protective Equipments (PPEs). The auditing team observed that in some estates that the sprayers are not using goggles and long-sleeve shirt during spraying activities. (New Minor CAR 21).
The company is in compliance to this requirement: N
4.7.2 Records should be kept of all accidents and periodically reviewed at quarterly intervals.
Compliance
Major
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S01 Findings:
Records of all accidents are kept and periodically reviewed at quarterly intervals.
Objective evidence:
Accident records are being maintained and summarized on monthly basis in Accident Frequency Rate (AFR) for the Year 2011 form. The form consist Lost Time Accident (MC 5 Days & Above), Lost Time Accident (MC 1 – 4 days), First Aid Cases (No. MC), Off-Work Accident Cases (OWC) and Fatality Cases (FC).
The accident records had been reviewed quarterly during the safety meeting.
The company is in compliance to this requirement: Y
4.7.3 Workers should be covered by accident insurance. Compliance
Major
S01 Findings:
Workers are adequately covered with accident insurance.
Objective evidence:
All workers are covered by accident insurance under RHB Insurance Berhad.
The company is in compliance to this requirement: Y
Criterion 4.8
All staff, workers, smallholders and contractors are appropriately trained.
4.8.1 A training programme (appropriate to the scale of the organization) that includes regular assessment of training needs and documentation, including records of training for employees are kept.
Compliance
Major
S01 Findings:
Inadequate training programme that includes regular assessment of training need and documentation, including records of training for employees.
Objective evidence:
Main Evaluation resulted in the issuance of Minor CAR 09 relating to inadequate training given to contractors to fulfill safety requirements. Visit during ASA1 evidenced that training programme is placed under the GPOM Safety and Health for the year 2011. Besides safety training, technical training program is included such as shovel driving, striliser Operator, effluent treatment plant training. Contractors used for servicing equipment were also provided safety briefing, training and use of PPE. List of attendance is also available. Technical training attendance is also available eg Engine Operation Training In addition, there is also a training for premixing the chemicals conducted. The attendance list for the training also kept (Minor CAR 09 closed).
Although there are various trainings conducted, there is no training assessment conducted for each of the trainings conducted. In addition, there is also evidence that the Health Assistance is not attending any proper chemical handling training (New Minor CAR 22).
The company is in compliance to this requirement: N
Principle 5 : ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY
Criterion 5.1
Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement.
5.1.1 Documented aspects and impacts risk assessment that is periodically Compliance
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reviewed and updated. Major
S01 Findings:
Evidence of documented aspects and impacts risk assessment that is periodically reviewed and updated.
Objective evidence:
Main Evaluation has resulted in the issuance of Minor CAR 10 relating to incomplete aspect and impact assessment. Verification during the ASA1 confirmed that the Gomali has taken action to conduct the detailed environment assessment to ensure all potential impacts are included (Minor CAR 10 closed).
Aspects are documented and verified. Based on the record, the negative and positive impacts are assessed and are reviewed annually. However in most of the aspects, the Person In Charge (PIC) is not identified (New Observation 05).
The company is in compliance to this requirement: Y
5.1.2 Environmental improvement plan to mitigate the negative impacts and promote the positive ones, is developed, implemented and monitored.
Compliance
Minor
S01 Findings:
Evidence of environmental improvement plan to mitigate the negative impacts and promote the positive ones, is developed, implemented and monitored.
Objective evidence:
Minor CAR 11 was issued during the Main Evaluation due to the Environmental improvement plan to mitigate the negative impacts and promote the positive ones is incomplete. Observation during the ASA1 evidenced that the Environmental Improvement Plan has been completed. The plan that was reviewed in June 2011 contained the management action plan and programme (Minor CAR 11 closed).
The company is in compliance to this requirement: Y
Criterion 5.2
The status of rare, threatened or endangered species (ERTs) and highly conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations.
5.2.1 Identification and assessment of HCV habitats and protected areas within land holdings; and attempt assessments of HCV habitats and protected areas surrounding landholdings.
Compliance
Major
S01 Findings:
Inadequate evidence of identification and assessment of HCV habitats and protected areas within land holdings; and attempt assessments of HCV habitats and protected areas surrounding landholdings.
Objective evidence:
During the Main Evaluation, a Minor CAR 12 relating to the Macro level HCV assessment does not include the on-site assessment covering the stakeholder consultation. ASA1 confirmed that the HCV assessment has been reviewed in June 2011. Based on the record, the auditing team was of the view that the assessment requires further identification and assessment of HCV habitats and protected area within landholding, with the participation of relevant stakeholder. (Minor CAR 12 is up graded to Major CAR 23).
Closing out of the Major CAR
Gomali has conducted a 30-day stakeholder consultation on 18 October 2011 covering various stakeholders relevant to the HCV such as the Department of Environment (DOE), Department Land and Mineral (PTG), Department of Orang Asli Development (JAKOA), Department of Wildlife and National Parks (PERHILITAN), Johor State Forestry Department (Johor FD) and the World Wide
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Fund for Nature (WWF). However, until the end of the 30-day period, there were no single responses received from the stakeholders (Major CAR 23 closed).
The company is in compliance to this requirement: Y
5.2.2 Management plan for HCV habitats (including ERTs) and their conservation.
Compliance
Major
S01 Findings:
Evidence of management plan for HCV habitats (including ERTs) and their conservation.
Objective evidence:
During the Main Evaluation, a non-conformance relating to the management plan for identified HCV habitats (macro assessment) have yet to be fully implemented (Minor CAR 13) was identified. Verification during the ASA1 evidenced that the management plans with time bound have been included in the HCV Assessment. However, the person-in-charge to carry-out the action has yet to be identified (refer to Observation 05) (Minor CAR 13 closed)
The company is in compliance to this requirement: Y
5.2.3 Evidence of a commitment to discourage any illegal or inappropriate hunting, fishing or collecting activities, and developing responsible measures to resolve human-wildlife conflicts.
Compliance
Minor
S01 Findings:
Adequate evidence of a commitment to discourage any illegal or inappropriate hunting, fishing or collecting activities, and developing responsible measures to resolve human-wildlife conflicts.
Objective evidence:
Field visit evidenced that the sign posts have been erected to discourage all forms of hunting.
The company is in compliance to this requirement: Y
Criterion 5.3
Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner.
5.3.1 Documented identification of all waste products and sources of pollution. Compliance
Major
S01 Findings:
Evidence of documented identification of all waste products and sources of pollution.
Objective evidence:
Partial listing of waste products and sources of pollution were evidenced during the Main Evaluation resulting in the issuance of Minor CAR 14. During the ASA1, all the waste products and sources of pollution have been re-identified. In addition, there is evidence of recycling demonstrated through establishment of recycling centre. Non-recyclable waste (eg. Schedule waste) was disposed through licensed agent (Minor CAR 14 closed).
The company is in compliance to this requirement: Y
5.3.2 Having identified wastes and pollutants, an operational plan should be developed and implemented, to avoid or reduce pollution.
Compliance
Minor
S01 Findings:
Operational plan to avoid or reduce pollution is not properly implemented.
Objective evidence:
There is an evidence of used Chemical containers and scheduled waste that is not
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disposed off in a proper manner. In addition there is also evidence of oil leaking into drainage system (New Minor CAR 24).
The company is in compliance to this requirement: N
5.3.3 Evidence that crop residues / biomass are recycled (Cross ref. C4.2). Compliance
Minor
S01 Findings:
Crop residues / biomass are recycled
Objective evidence:
The auditing team observed that the palm fronds and bunch stalks are retained in the field. On the other hand, EFB and other fibres as well as mineral ash are returned to the fields subject to transport constraints. In addition there is also a POME licenced by DOE for application by shallow pans and direct spraying to frond stacks.
The company is in compliance to this requirement: Y
Criterion 5.4
Efficiency of energy use and use of renewable energy is maximized.
5.4.1 Monitoring of renewable energy use per tonne of CPO or palm product in the mill.
Compliance
Minor
S01 Findings:
Evidence of monitoring of renewable energy use per tonne of CPO or palm product in the mill.
Objective evidence:
A non-conformance relating to in sufficient efforts to estimate the renewable energy used in the boiler to allow monitoring of energy used and determine trends (Minor CAR 15) was issued during the Main Evaluation. Visit during the ASA1 evidenced that the Gomali Palm Oil Mill has recorded the actual weight of FFB and fibers used for boiler. Trend of the renewable fuel input against the energy produced for every month is available (Minor CAR 15 closed).
The company is in compliance to this requirement: Y
5.4.2 Monitoring of direct fossil fuel use per tonne of CPO or kW per tonne palm product in the mill (or FFB where the grower has no mill).
Compliance
Minor
S01 Findings:
Evidence of monitoring of direct fossil fuel use per tonne of CPO or kW per tonne palm product in the mill.
Objective evidence:
Records of usage of fossil fuel are available and compared to the volume of the FFB processed and the CPO output as observed in the Fossil Fuel Consumption Report. The company used it as one of the performance indicator and make effort to reduce fuel usage while increasing the productivity. In 2011 (Jan – Jul) the total consumption per FFB is 1.70 lit / FFB and 8.09lit / CPO.
The company is in compliance to this requirement: Y
Criterion 5.5
Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN Guidance or other regional best practice.
5.5.1 No evidence of open burning. Where controlled burning occurs, it is as prescribed by the Environmental Quality (Declared Activities) (Open Burning) Order 2003.
Compliance
Major
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S01 Findings:
Evidence of open burning but controlled as prescribed by the Environmental Quality (Declared Activities) (Open Burning) Order 2003.
Objective evidence:
There is evidence of limited open burning was practiced to sterilise fields of Ganoderma prior to replanting with rubber under conditions imposed by the DOE. Wastes including horticultural wastes are collected and transported to landfill cells.
The company is in compliance to this requirement: Y
5.5.2 Previous crop should be felled/mowed down, chipped/shredded, windrowed or pulverized/ ploughed and mulched.
Compliance
Minor
S01 Findings:
Previous crop is felled and chipped/shredded.
Objective evidence:
Previous crop observed to be felled and is chipped and windrowed either with leguminous plants cover or buried prior to replanting.
The company is in compliance to this requirement: Y
5.5.3 No evidence of burning waste (including domestic waste). Compliance
Minor
S01 Findings:
No evidence of burning waste (including domestic waste).
Objective evidence: No evidence of burning wastes that originates from estate and mill.
The company is in compliance to this requirement: Y
Criterion 5.6
Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and monitored.
5.6.1 Documented plans to mitigate all polluting activities (Cross ref to C5.1). Compliance
Major
S01 Findings:
Documented plans to mitigate all polluting activities is available.
Objective evidence:
The ‘Group Environmental Impact Assessment and Management Action Plans’ provides plans for action for those potentially polluting activities that have been identified. Based on records, the auditing team observed that Wastewater analysis done (weekly) and submitted monthly. This include stack sampling (2 x per year) as well as ambient air monitoring (4 x per year) done by Env Consultancy & Monitoring Services Sdn. Bhd. dated 12 July 2011
There is also evidence of legal compliance for FD: BOD < 5,000ppm. It is evidenced that for 2010 and 2011 the BOD recorded was < 150ppm.
The company is in compliance to this requirement: Y
5.6.2 Plans are reviewed annually. Compliance
Minor
S01 Findings:
Evidence of plans are reviewed annually
Objective evidence:
An observation 04 was issued during the Main Evaluation relating to No guidelines to review pollution prevention plans. ASA1 confirmed that the EIA covering the
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Management Action Plans are review annually. Latest revision dated 27th June
2011 is available that involved the IOI Sustainability team as well as the Estate management. The review process includes consultation relating to 1) identification of operations (aspect) that has environmental impact 2) Identification of waste and pollutants and implement plans to reduce the pollution 3) identification of HCVs and review 4) identification of stakeholders (Observation 04 closed).
The company is in compliance to this requirement: Y
5.6.3 Monitor and reduce peat subsidence rate through water table management. (Within ranges specified in C 4.3).
Compliance
Minor
S01 Findings:
Not applicable as There was no peat soil within Gomali group of estates.
Objective evidence:
NA
The company is in compliance to this requirement: Y
PRINCIPLE 6: RESPONSIBLE CONSIDERATION OF EMPLOYEES AND OF INDIVIDUALS AND COMMUNITIES BY GROWERS AND MILLERS
Criterion 6.1
Aspects of plantation and mill management, including replanting, that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement.
6.1.1 A documented social impact assessment including records of meetings. Compliance
Major
S01 Findings:
Evidence of documented social impact assessment including records of meetings.
Objective evidence:
SIA is available (reviewed on 25th July 2011) and done with the participation of
identified stakeholders. Records of all meetings available. The SIA is viewed as an active impact assessment document where a reasonable amount of consideration has been given to mitigate social impacts for employees and communities affected by the plantations and mill.
The SIA has a social action plan with seeks resolve social issues adequately, in terms of clearly outlining the responsibilities for mitigation and monitoring. Maps delineating locations of stakeholders and social economic profiling is also provided. The company is seen to engage with identified stakeholders in a participatory manner.
The company is in compliance to this requirement: Y
6.1.2 Evidence that the assessment has been done with the participation of affected parties.
Compliance
Minor
S01 Findings:
Evidence that the assessment has been done with the participation of affected parties.
Objective evidence:
ASA1 confirmed that there is an evidence that the company’s management has conducted the stakeholders meeting to discuss on the social issue (Impact and Aspect) that was conducted on 6 July 2011.
The company is in compliance to this requirement: Y
6.1.3 A timetable with responsibilities for mitigation and monitoring is reviewed Compliance
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and updated as necessary. Minor
S01 Findings:
Evidence of A timetable with responsibilities for mitigation and monitoring that is reviewed and updated as necessary.
Objective evidence:
A timetable with responsibilities for mitigation and monitoring is reviewed annually and updated from time to time.
The company is in compliance to this requirement: Y
Criterion 6.2
There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties.
6.2.1 Documented consultation and communication procedures. Compliance
Major
S01 Findings:
Incomplete documented consultation and communication procedures.
Objective evidence:
The consultation and communication procedure is integrated in Social Impact Assessment. However, the auditing team found that the consultation and communication procedure between growers and/or miller, local communities and other affected or parties is incomplete (New Minor CAR 25).
The company is in compliance to this requirement: Y
6.2.2 A nominated plantation management official at the operating unit responsible for these issues.
Compliance
Minor
S01 Findings:
Evidence of nominated plantation management official at the operating unit responsible for these issues.
Objective evidence:
Gomali had appointed Social Liaison Officer to responsible in these issues. The responsibilities of the Social Liaison Officer in the unit cover the following:
Welfare and social needs of stakeholders (i.e. workers, suppliers, smallholders Kampong etc directly related to estate).
Periodic visits to linesite and social amenities to ensure that buildings are in good order (through Hospital Assistant).
Periodic visits to neighbouring stakeholders on a reactive manner to ensure that social issues are being taken care of (to have consultation to ensure that communication chain is available and maintained).
Identification of social issues affecting stakeholders and neighbouring community/ies and to decide upon mitigation plans to solve social issues after consultation with the manager.
Maintenance and monitoring of grievance issues and facilitate feedback mechanism to ensure that a line of communication is available.
Monitoring of crèche and daycare centre to ensure that children are being well taken care of and adequately educated.
To stakeholder’s requests and ensure that requests are followed up with a response.
Grievance issues (encompassing social, work, repairs, etc.) and ensuring that proper follow up is conducted (this is to be documented).
Safety and health aspect of linesite / estate / workers etc.
Other social issues arising / ad hoc social issues (this is situation dependent).
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An appointment letter of the social liaison officer is available. Example in Gomali POM, Mr. Muhammad Afiq (Assistant Manager) has been appointed on 1
st June
2011 while in Gomali Estate, Mr. Phan Tsu Han (Cadet Assistant) has been appointed as the Social Liaison Officer. The appointment letter dated 13 June 2011 is available.
The company is in compliance to this requirement: Y
6.2.3 Maintenance of a list of stakeholders, records of all communication and records of actions taken in response to input from stakeholders.
Compliance
Minor
S01 Findings:
List of stakeholders, records of all communication and records of actions taken in response to input from stakeholders are maintained.
Objective evidence:
A comprehensive list of stakeholders is available. The list covers all stakeholders, e.g. government agencies, non-governmental organizations, village representatives and sundry shop owners. The stakeholder list also includes the names of each employee. There is documented evidence of communication with stakeholders and records of actions taken to resolve grievances of employees.
The company is in compliance to this requirement: Y
Criterion 6.3
There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties.
6.3.1 Documentation of the process by which a dispute was resolved and the outcome.
Compliance
Major
S01 Findings:
Process by which a dispute was resolved and the outcome is documented.
Objective evidence:
There is evidence that a mutually agreed documented process for dispute and conflict resolution. Worker’s representative has been briefed on the procedure involved.
There is also evidence of documentation of grievances which have been resolved and the outcome accepted by the workers (signature of workers obtained for every grievance resolved). The records of grievances appeared in a structured manner and viewed as adequate.
The company is in compliance to this requirement: Y
6.3.2 The system resolves disputes in an effective, timely and appropriate manner.
Compliance
Minor
S01 Findings:
The system to resolves disputes in an effective, timely and appropriate manner is evidenced.
Objective evidence:
The records indicate that all disputes raised were resolved appropriately within the time frame accepted by parties.
The mechanism for resolving disputes is enhanced by the following:
5. Estate Consultative Committee (ECC) which has representation from different level of workers who are elected by the workers.
6. There is grievance report book at all estates and the mill
7. For field workers: Report to mandoresupervisorAssistant managerManager
8. For staff: Report to manager
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9. Report to Social Liaison Officer/Gender Representative
For other stakeholders, e.g. the local communities, the following is observed:
1. Community representatives write-in to the company (applicable to other stakeholders as well);
2. Community representatives meet the manager at the estate (applicable to other stakeholders as well);
3. The Social Liaison Officer visits the community representatives
4. The company holds meetings with community representatives (minutes of meetings dated ...... for ............. estate)
5. Local community invites company representatives to their village committee meetings whenever necessary. There is evidence that company representatives, e.g. estate managers have actively participated in these meetings.
The company is in compliance to this requirement: Y
6.3.3 The system is open to any affected parties. Compliance
Minor
S01 Findings:
The system is open to any affected parties.
Objective evidence:
There is evidence that the system is open to all parties and discussion with workers and stakeholders indicate that no discrimination has taken place.
There is adequate evidence to demonstrate that the system is open to any affected parties (see 6.3.2). Internal complaints are dealt with mechanisms such as the Employees Consultative Committee (ECC) with gender representation (at least a designated gender representative) and a designated grievance book which is endorsed by the complainants when action has been taken to resolve a grievance. Other internal mechanisms and external mechanisms are as per 6.3.2.
The company is in compliance to this requirement: Y
Criterion 6.4
Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions.
6.4.1 Establishment of a procedure for identifying legal and customary rights and a procedure for identifying people entitled to compensation.
Compliance
Major
S01 Findings:
Procedures for identifying legal and customary rights and people entitled to compensation are established.
Objective evidence:
Social impact evaluation was done and there was no loss of legal or customary rights to communities, indigenous people of stakeholders.
The company is in compliance to this requirement: Y
6.4.2 A procedure for calculating and distributing fair compensation (monetary or otherwise) is established and implemented. This takes into account gender differences in the power to claim rights, ownership and access to land; and long-established communities; differences in ethnic groups’ proof of legal versus communal ownership of land.
Compliance
Minor
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S01 Findings:
A procedure for calculating and distributing fair compensation (monetary or otherwise) is established and implemented.
Objective evidence:
Gomali has a procedure in place for calculating and distributing fair compensation. The procedures are for retrenchment of surplus workers from conversion of rubber to oil palm. Retrenchment benefits are based on the national industrial standard, National Union of Plantation Workers (NUPW) and Gomali agreement.
The company is in compliance to this requirement: Y
6.4.3 The process and outcome of any compensation claims is documented and made publicly available.
Compliance
Minor
S01 Findings:
The process and outcome of any compensation claims is documented and made publicly available.
Objective evidence:
There is a procedure in documenting outcome of compensation claims which also includes public consultation. So far there was no compensation payment made for loss of legal and customary rights relevant to oil palm plantation management and operation in Gomali.
The company is in compliance to this requirement: Y
Criterion 6.5
Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages.
6.5.1 Documentation of pay and conditions. Compliance
Major
S01 Findings:
There is evidence of documented pay and conditions.
Objective evidence:
i) There is documentation of salary in the form of pay slips and payment records for contract workers and company workers detailing the basic pay, deductions, overtime, bonuses, allowance etc. In general, the workers are paid decent salaries and above industry minimum. The salary is paid on time.
ii) There is documentation of legalisation of migrant workers.
iii) A separate employment agreement is drawn up for foreign workers at all estates and the mill, outlining their pay and conditions.
The company is in compliance to this requirement: Y
6.5.2 Labour laws, union agreements or direct contracts of employment detailing payments and conditions of employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc) are available in the language understood by the workers or explained carefully to them by a plantation management official in the operating unit.
Compliance
Minor
S01 Findings:
Labour laws, union agreements or direct contracts of employment detailing payments and conditions of employment are available in the language understood by the workers.
Objective evidence:
Employment contract for workers (both locals and foreign workers) available in
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respective language i.e. Bahasa Malaysia, English Nepal and Bangladesh.
There are terms of reference or signed contracts between employers and employees stipulating the position, working hours, type of work, location of work, workers’ responsibility, wages, allowances, holidays, rest days, annual leave, fringe benefits, levy deductions (for foreign workers), dismissal, etc.
There is evidence of documentation of rates of pay, contracts of employment, terms and conditions of employment made available in languages understood by workers or explained carefully by management personnel of the individual operating unit.
The company is in compliance to this requirement: Y
6.5.3 Growers and millers provide adequate housing, water supplies, medical, educational and welfare amenities in accordance with Workers’ Minimum Standard of Housing and Amenities Act 1990 (Act 446) or above, where no such public facilities are available or accessible (not applicable to smallholders).
Compliance
Minor
S01 Findings:
Evidence of adequate housing, water supplies, medical, educational and welfare amenities provided by the company.
Objective evidence:
Workers have access to clean water, segregated sanitary and bathing facilities and electricity. All employees are given adequate housing, medical, educational and welfare amenities and waste disposal facilities in accordance with Workers’ Minimum Standard of Housing and Amenities Act.
Facilities provided by the estates and mill are as follows:
o Ambulance o Estate clinic/dispensary o Creche o Football field o Government school o Housing o Community hall o Shops o Places of worship o Clean water o Electricity supply o Security o Clubhouse o Notice boards
The company is in compliance to this requirement: Y
Criterion 6.6
The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel.
6.6.1 Documented minutes of meetings with main trade unions or workers representatives.
Compliance
Major
S01 Findings:
Evidence of documented minutes of meetings with main trade unions or workers representatives.
Objective evidence:
Trade union representatives are recognised by management. Minutes of meeting are kept at the state level head quarters of the union.
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Minutes of meetings of the various meetings between workers unions/representatives and employers are available at the estates and mills for example 1) A Meeting between AMESU & NUPW representatives was conducted on 21
st June 2011, 2) Meeting of the Employees Consultative Committee was
conducted on 9 June 2011 and was attended by all workers representative including contractors’ representative and foreign representative, and 3) Meeting with Estate Coordination Committee (ECC) was conducted on 13 July 2011 to discuss on the impact and aspect for SIA.
The company is in compliance to this requirement: Y
6.6.2 A published statement in local languages recognizing freedom of association.
Compliance
Minor
S01 Findings:
A published statement in local languages recognizing freedom of association is available.
Objective evidence:
A valid freedom of association policy is available in all local languages.
The company is in compliance to this requirement: Y
Criterion 6.7
Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programmes. Children are not exposed to hazardous working conditions.
6.7.1 Documented evidence that minimum age requirement is met. Compliance
Major
S01 Findings:
There is documented evidence that the minimum age requirement is met.
Objective evidence:
No evidence of child labour or under age workers in mill and estate operations. The company has a clearly defined minimum working age policy of 18 years and above.
The company is in compliance to this requirement: Y
Criterion 6.8
Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited.
6.8.1 A publicly available equal opportunities policy. Compliance
Major
S01 Findings:
A publicly available equal opportunities policy is available.
Objective evidence:
There is a publicly available equal opportunities policy which states that the company is an equal opportunity employer, whereby the company does not practice discrimination based on race, caste, national, origin, disability, gender, sexual orientation, union membership, political affiliation, or age.
The company is in compliance to this requirement: Y
6.8.2 Evidence that employees and groups including migrant workers have not been discriminated against.
Compliance
Minor
S01 Findings:
There is evidence that employees and groups including migrant workers have not been discriminated against.
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Objective evidence:
Based on the interview conducted with some workers, there are no evidence of migrant workers been discriminated against. All workers had been equally treated.
The company is in compliance to this requirement: Y
Criterion 6.9
A policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied.
6.9.1 A policy on sexual harassment and violence and records of implementation.
Compliance
Major
S01 Findings:
A policy on sexual harassment and violence and records of implementation is available.
Objective evidence:
A policy on sexual harassment exists and a mechanism for recording grievances for official review is also available.
The company is in compliance to this requirement: Y
6.9.2 A specific grievance mechanism is established. Compliance
Major
S01 Findings:
There is evidence that a specific grievance mechanism is established.
Objective evidence:
Minor CAR 16 was issued during the Main Evaluation relating to incomplete understanding of established grievance mechanism by gender representatives. Verification during the ASA1 evidenced that a meeting with all woman workers are conducted at least in 6 monthly bases. During the meeting, all workers were given training/briefing on sexual harassment awareness and discussion on any relevant topic. Records of minutes of meeting is also kept and made available to the auditor where the latest meeting was conducted on 22 April 2011 (Minor CAR 16 closed).
The company is in compliance to this requirement: Y
Criterion 6.10
Growers and mills deal fairly and transparently with smallholders and other local businesses.
6.10.1 Pricing mechanisms for FFB and inputs/services shall be documented. Compliance
Major
S01 Findings:
Pricing mechanisms for FFB and inputs/services is documented.
Objective evidence:
A transparent mechanism exists for establishing FFB prices and for input and services.
The company is in compliance to this requirement: Y
6.10.2 Current and past prices paid for FFB shall be publicly available. Compliance
Minor
S01 Findings:
Current and past FFB prices paid are publicly available.
Objective evidence:
Current and past FFB prices paid are made publicly available.
The company is in compliance to this requirement: Y
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6.10.3 Evidence that all parties understand the contractual agreements they enter into, and that contracts are fair, legal and transparent.
Compliance
Minor
S01 Findings:
There is evidence that all parties understand the contractual agreements they enter into, and that contracts are fair, legal and transparent.
Objective evidence:
All contractual agreements are legal and appear to be fair and transparent. The contractual agreements between Gomali and the outgrower i.e. Sembilan Tani also is verified and found to be fair and transparent.
The company is in compliance to this requirement: Y
6.10.4 Agreed payments shall be made in a timely manner. Compliance
Minor
S01 Findings:
Agreed payments is made in a timely manner.
Objective evidence:
Interviews with suppliers and contractors at the estates reveal that all payments are made in a timely manner.
The company is in compliance to this requirement: Y
Criterion 6.11
Growers and millers contribute to local sustainable development wherever appropriate.
6.11.1 Demonstrable contributions to local development that are based on the results of consultation with local communities.
Compliance
Minor
S01 Findings:
Evidence of demonstrable contributions to local development that are based on the results of consultation with local communities.
Objective evidence:
The social impact assessment has included local communities and neighbouring stakeholders. A plan of action has been drawn out to contribute to local activities. The unit management has donated money for local school activities, water supply to neighbouring villages and provides facilities for many activities.
The unit has provided adequate support for a Chinese and Tamil School in Gomali estate. Provision of electricity supply to school is also facilitated by the unit.
The estate and mill levels have demonstrated a budget to accommodate ad-hoc requests for donations which the examples is listed as follows:
23/06/11 – Contribution to Tabung Kebajikan, Pendidikan & Warga Emas Persatuan Bekas Polis Malaysia;
12/04/11 – Contribution to Chinese and Indian Temple celebration;
19/07/11 – Contribution to Pertubuhan Amal Sayang Permata Malaysia; and
Gomali has decided to donate 3 acre land for Tamil school building. The agreed letter dated 12/08/2011 is available during the audit.
The company is in compliance to this requirement: Y
P7: RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS
This whole Principle is not applicable to this assessment as there are no new plantings. The company is only involved in re-planting programme after felling of old palms and there is no
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plan for expansion.
P8: COMMITMENT TO CONTINOUS IMPROVEMENT IN KEY AREAS OF ACTIVITY
Criterion 8.1
Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations.
8.1.1 Minimise use of certain pesticides (C4.6). Compliance
Major
S01 Findings:
Evidence of use of certain pesticides is minimise.
Objective evidence:
Gomali management has issued a memo to replace paraquat herbicide with other alternatives.
Continuous planting of beneficial plant is evident to increase population of pest predators of leaf eating caterpillars/bagworms.
The company is in compliance to this requirement: Y
8.1.2 Environmental impacts (C5.1). Compliance
Major
S01 Findings:
Evidence of commitment to minimize environmental impacts.
Objective evidence:
Gomali has documented records of storage and disposal that is reviewed on a monthly. Monthly scheduled waste records are sent to DOE. The scheduled waste is disposed by the authorized scheduled waste collector on a 6 monthly basis.
The company is in compliance to this requirement: Y
8.1.3 Maximizing recycling and minimizing waste or by-products generation. Compliance
Major
S01 Findings:
Evidence of maximizing recycling and minimizing waste or by-products generation.
Objective evidence:
Domestic waste systematically collected at 2-3 times a week. Segregation of glass, plastic, aluminium, paper for recycling purpose is implemented at the line site.
The company is in compliance to this requirement: Y
Evidence of commitment to implement pollution prevention plans.
Objective evidence:
The ‘Group Environmental Impact Assessment and Management Action Plans’ provides plans for action for those potentially polluting activities that have been identified. Based on records, the auditing team observed that Wastewater analysis done (weekly) and submitted monthly. This include stack sampling ( 2 x per year ) as well as ambient air monitoring ( 4 x per year ) done by Env Consultancy &
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Monitoring Services Sdn. Bhd. dated 12 July 2011.
The company is in compliance to this requirement: Y
8.1.5 Social impacts (C6.1). Compliance
Major
S01 Findings:
Evidence of commitment to review social impact.
Objective evidence:
There is a commitment to review social impacts and social management plan on an annual basis.
The company is in compliance to this requirement: Y
8.1.6 A mechanism to capture the performance and expenditure in social and environmental aspects.
Compliance
Minor
S01 Findings:
Evidence of commitment to establish a mechanism to capture the performance and expenditure in social and environmental aspects.
Objective evidence:
Main Evaluation has resulted in the issuance of a Minor CAR 17 relating to the mechanism exists to capture expenditure, but this does not necessarily capture the quality and effectiveness of performance (social and environment). ASA1 evidenced that Gomali has taken action to monitor the quality and effectiveness of social and environmental performance over 2011 (Jan-June) covering the following indicators:
Changes of number of grievances per month;
Trends for POME effluent BOD;
Trends for WQI analysis;
Trends for diesel usage; and
Trends for pesticide usage
Minor CAR 17 closed
The company is in compliance to this requirement: Y
3.2 The ASA1 has resulted in the closing out of 15 Minor Corrective Action Requests (CARs). 2 Major CARs was issued during the ASA1 of which the 1 of the Major CAR was upgraded from existing Minor CAR. However, the 2 Major CARs were subsequently closed out within 3 months after the ASA1 audit date following submission adequate corrective action evidences. 1 Minor CAR was maintained and another 6 Minor CARs was issued. Details of the CAR are as listed in section Appendix A.
With no outstanding Major CAR, the IOI Corporation Berhad’s management of Gomali
Mill and its plantation supply base in Negeri Sembilan, Pahang, Melaka and Johor is
now recommended for maintenance of certification against the RSPO P&C MYNI
requirements. The issues highlighted as Minor CARs must be adequately addressed and the
adequacy of the actions taken need to be verified during the Annual Surveillance Audit 2 to
be conducted within 12 months from the date of ASA1.
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4 Chain of Custody
Fresh Fruit Bunches (FFB) produced by the plantation are transported to and processed at
Gomali Oil Mill which is located in Segamat, Johor. The mill with a capacity of 120 metric
tonne FFB per hour received and processed raw materials (FFB) from the supplying estates
as described in this report.
From the plantation, the FFB were delivered by trucks where details on the delivery
documents allow traceability of the fruits to a group of harvesting block in each district or
sector. Records of FFB deliveries and input into the processing line are well maintained by
the company. Similarly, records of CPO and palm kernel output are also maintained on daily
basis.
As far as chain of custody is concern, the mill (and the plantation) currently does not have a
document standard operation procedures (StOPs) that identify the critical control points
(CCPs) and described the method used in identifying, segregating and recording at each
point identified. The document also need to identify the person in charge (or the
management representative) responsible for the implementation and maintenance of the
whole system and ensuring its integrity.
5 Acknowledgement of Internal Responsibility and Formal Sign-Off of Assessment Findings
It is acknowledged that the assessments cited in this report have been carried out as
stipulated and we confirm the acceptance of the assessment report contents including
assessment findings.
Sign on behalf of:
Mr. Too Heng Liew Head of Sustainability (Malaysia/Indonesia)
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APPENDIX A: CORRECTIVE ACTION REQUEST
CAR # Indicator CAR Detail
01 2.1.3 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
No documented system to ensure that full legal compliance is met. The operating unit has yet to undertake monitoring of compliance.
Objective Evidence:
Close-out evidence:
The company has taken action to appoint the responsible person for monitoring any changes of laws and regulations. A copy of laws also found to be compiled at the Mill’s office.
CAR # Indicator CAR Detail
02 4.1.2 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Insufficient records of monitoring and weak mechanism to undertake such monitoring of StOPs
Objective Evidence:
Close-out evidence:
The implementation of the StOPs is monitored and all records of implementation is kept including the monitoring as well as actions taken following the monitoring.
03 4.3.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Inconsistent implementation of the estate plans and StOPs for soil conservation has resulted in chronic soil erosion in the older planting areas.
Objective Evidence:
Close-out evidence:
all areas prone to soil erosion has been identified and documented in the StOPs. In addition, an action plans to minimize soil erosion and establishment of plant to improve the texture of fragile soil.
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CAR # Indicator CAR Detail
04 4.3.3 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Road maintenance programme available but it has not been undertaken for some time in some of the estates.
Objective Evidence:
Close-out evidence:
Gomali has taken action to implement the road maintenance programme at erosion prone area. In addition, there is also evidence of silt pits observed during the field visit.
05 4.4.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> dd mmm yy
Non-Conformance:
Inconsistent buffer zones identification and demarcation along rivers and streams.
Objective Evidence:
Gomali has taken action to identify and demarcate most of the visited bufferzone along river streams. However, the auditing team is of the view that the process taken is insufficient to close the Minor CAR due to a visit in one bufferzone in Bahau Estate evidenced that the Bufferzone is not properly demarcated (Minor CAR 05 remained outstanding).
Close-out evidence:
06 4.5.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Guidelines on IPM in place and implementation is in progress. There is no mechanism to evaluate these actions.
Objective Evidence:
Close-out evidence:
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CAR # Indicator CAR Detail
There is mechanism in place to monitor the usage of herbicide as follows:
o Training is given to the herbicide sprayers for not to spray on the bare ground or area which has not much vegetation e.g. due to prolonged dry period;
o Monitoring on the application of herbicide to ensure no spraying on the bare areas; and
o Justification is established for the area requires chemical spraying.
07 4.6.4 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Understanding of hazards among workers is inconsistent. There is lack of evidence that information on chemicals is available in language understood by workers.
Objective Evidence:
Close-out evidence:
Gomali has established the information on chemicals and its usage, hazards, trade and generic names in language understood by the workers such as Bahasa Melayu and Bangladesh languages.
08 4.7.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Policy and Safety Operating Procedures (SaOP) are in place. Communication and implementation is inconsistent.
Operational risks assessment incomplete.
Inadequate training in safe working condition.
Inadequate and inconsistent use of PPE for estate workers.
Minutes available.
Accident and emergency procedures not clearly understood by all workers.
Objective Evidence:
Close-out evidence:
Gomali has taken action to organize the training on the Occupational Safety and Health in particular training on the safe working condition. The record of the training is kept.
09 4.8.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
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CAR # Indicator CAR Detail
Inadequate training given for contractors to fulfill safety requirement.
Objective Evidence:
Close-out evidence:
training programme is placed under the GPOM Safety and Health for the year 2011. Besides safety training, technical training program is included such as shovel driving, striliser Operator, effluent treatment plant training. Contractors used for servicing equipment were also provided safety briefing, training and use of PPE. List of attendance is also available. Technical training attendance is also available eg Engine Operation Training In addition, there is also a training for premixing the chemicals conducted. The attendance list for the training also kept.
10 5.1.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Incomplete aspects and impacts assessment.
Objective Evidence:
Close-out evidence:
Confirmed that the Gomali has taken action to conduct the detailed environment assessment to ensure all potential impacts are included
11 5.1.2 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Environmental improvement plan to mitigate the negative impacts and promote the positive ones is incomplete.
Objective Evidence:
Close-out evidence:
The Environmental Improvement Plan has been completed. The plan that was reviewed in June 2011 contained the management action plan and programme
12 5.2.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed>
Non-Conformance:
Macro level HCV assessment available. However this has not been followed by an on-site assessment created through stakeholder consultation
Objective Evidence:
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CAR # Indicator CAR Detail
The HCV assessment has been reviewed in June 2011. Based on the record, the auditing team was of the view that the assessment requires further identification and assessment of HCV habitats and protected area within landholding, with the participation of relevant stakeholder. (Minor CAR 12 is up graded to Major CAR 23).
Close-out evidence:
13 5.2.2 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Management plan for identified HCV habitats (macro assessment) have yet to be fully implemented.
Objective Evidence:
Close-out evidence:
Verification during the ASA1 evidenced that the management plans with time bound have been included in the HCV Assessment.
14 5.3.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Partial listing of waste products and sources of pollution.
Objective Evidence:
Close-out evidence:
All the waste products and sources of pollution have been re-identified. In addition, there is evidence of recycling demonstrated through establishment of recycling centre. Non-recyclable waste (eg. Schedule waste) was disposed through licensed agent
15 5.4.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Efforts has been made to estimate the renewable energy used in the boiler but this estimate is not sufficient to monitor the energy used and observe trend.
Objective Evidence:
Close-out evidence:
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CAR # Indicator CAR Detail
Gomali Palm Oil Mill has recorded the actual weight of FFB and fibers used for boiler. Trend of the renewable fuel input against the energy produced for every month is available.
16 6.9.2 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Inadequate training has been provided to create awareness of women’s rights as regards sexual harassment grievance procedures.
Objective Evidence:
Close-out evidence:
A meeting with all woman workers are conducted at least in 6 monthly bases. During the meeting, all workers were given training/briefing on sexual harassment awareness and discussion on any relevant topic. Records of minutes of meeting is also kept and made available to the auditor where the latest meeting was conducted on 22 April 2011.
17 8.1.6 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Mechanism exists to capture expenditure, but this does not necessarily capture the quality and effectiveness of performance (social and environment).
Objective Evidence:
Close-out evidence:
Gomali has taken action to monitor the quality and effectiveness of social and environmental performance over 2011 (Jan-June) covering the following indicators:
Changes of number of grievances per month;
Trends for POME effluent BOD;
Trends for WQI analysis;
Trends for diesel usage; and
Trends for pesticide usage
M18 Date
Recorded>
25 August 2011
Due Date>
25 Nov 2011
Date Closed>
19 March 2012
Non-Conformance:
Inadequate evidence of compliance with legal requirements.
Objective Evidence:
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CAR # Indicator CAR Detail
Visit to the Mill observed that the Envirocarbon Sdn. Bhd., the company responsible for production or activated carbon from palm kernel shell are found to be operating without license from authority
Close-out evidence:
Gomali has submitted the corrective action evidence to close the Major CAR issued. Based on the evidence, the Envirocarbon Sdn. Bhd. has appointd Env Consultancy and Monitoring Services Sdn. Bhd. as the Consultant for Registration of the Kiln Process Chimney under the Environmental Quality (Clean Air) Regulations, 1978. Subsequently, has prepared and submitted the application for the written approval for the installation of LEV (c/w Chimney Systems) on September 2011. The consultant also has prepared the Ambient Air Monitoring Report dated December 2011 as well as the Isokinetic & Air Emission Monitoring Report dated January 2012. The DOE also has responded to the application letter through their letter dated 15 March 2012 stating provisions and conditions that need to be comply for the installation of the LEV
19 2.1.2 Date
Recorded>
25 August 2011
Due Date>
S02 Date
Closed>
Non-Conformance:
In sufficient documented system including written information on legal requirements.
Objective Evidence:
Hard copies of all relevant legal documents such as laws, licences and permits are viewed at the estate office. However, the auditing team observed that the copies of laws available at the estate office are not completed as per the list of the laws listed within the RSPO standard.
Close-out evidence:
20 4.6.3 Date
Recorded>
25 August 2011
Due Date>
S02 Date
Closed>
Non-Conformance:
Pesticides used in estates are not sufficiently stored in accordance to the Occupational Safety and Health Act, 1994 (Act 514) and Regulations and Orders and Pesticides Act 1974 (Act 149) and Regulations.
Objective Evidence:
Visit to the Bahau Estate evidenced the triple rinsing and perforated procedure is inconsistently implemented at the chemical storage area.
Close-out evidence:
21 4.7.1 Date
Recorded>
25 August 2011
Due Date>
S02 Date
Closed>
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CAR # Indicator CAR Detail
Non-Conformance:
Inconsistency in the implementation of the Personnel Protective Equipments (PPEs) as required by the Occupational Safety Health (OSH) plan which is in compliance with OSH Act 1994 and Factory and Machinery Act 1967(Act 139).
Objective Evidence:
However, the ASA1 evidenced a non-conformance whereby there is inconsistency in the implementation of the Personnel Protective Equipments (PPEs). The auditing team observed that in some estates that the sprayers are not using goggles and long-sleeve shirt during spraying activities.
Close-out evidence:
22 4.8.1 Date
Recorded>
25 August 2011
Due Date>
S02 Date
Closed>
Non-Conformance:
Inadequate training programme that includes regular assessment of training need and documentation, including records of training for employees.
Objective Evidence:
Although there are various trainings conducted, there is no training assessment conducted for each of the trainings conducted. In addition, there is also evidence that the Health Assistance is not attending any proper chemical handling training.
Close-out evidence:
M23 5.2.1 Date
Recorded>
25 August 2011
Due Date>
25 Nov 2011
Date Closed>
22 November 2011
Non-Conformance:
Inadequate evidence of identification and assessment of HCV habitats and protected areas within land holdings; and attempt assessments of HCV habitats and protected areas surrounding landholdings.
Objective Evidence:
The HCV assessment has been reviewed in June 2011. Based on the record, the auditing team was of the view that the assessment requires further identification and assessment of HCV habitats and protected area within landholding, with the participation of relevant stakeholder.
Close-out evidence:
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CAR # Indicator CAR Detail
Gomali has conducted a 30-day stakeholder consultation on 18 October 2011 covering various stakeholders relevant to the HCV such as the Department of Environment (DOE), Department Land and Mineral (PTG), Department of Orang Asli Development (JAKOA), Department of Wildlife and National Parks (PERHILITAN), Johor State Forestry Department (Johor FD) and the World Wide Fund for Nature (WWF). However, until the end of the 30-day period, there were no single responses received from the stakeholders.
24 5.3.2 Date
Recorded>
25 August 2011
Due Date>
S02 Date
Closed>
Non-Conformance:
Operational plan to avoid or reduce pollution is not properly implemented.
Objective Evidence:
There is an evidence of used Chemical containers and scheduled waste that is not disposed off in a proper manner. In addition there is also evidence of oil leaking into drainage system.
Close-out evidence:
25 6.2.1 Date
Recorded>
25 August 2011
Due Date>
S02 Date
Closed>
Non-Conformance:
Incomplete documented consultation and communication procedures.
Objective Evidence:
The consultation and communication procedure is integrated in Social Impact Assessment. However, the auditing team found that the consultation and communication procedure between growers and/or miller, local communities and other affected or parties is incomplete.
Close-out evidence:
APPENDIX B: OBSERVATIONS
OBS # Indicator Observation Detail
01 1.1.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Request for information via IOI Group General line was unsuccessful.
Objective Evidence:
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OBS # Indicator Observation Detail
Close-out evidence:
The company maintains adequate information which is available for public.
Documented procedures exist for stakeholder information request at the corporate and estate levels. Records of requests and responses are viewed at the estate level. To enhance the communication with the stakeholder, the HQ has developed the mechanism to response to the stakeholders. The established mechanism is made available to the auditing team during the audit.
02 2.3.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Customary use of land for places of worship is still being practice in all the estate. These sites have not been cataloged and mapped and a consultative approach has not been taken where the management of these sites is concerned.
Objective Evidence:
Close-out evidence:
Details of all the worshipping places have been documented and mapped in the HCV document. In addition, discussion and consultation with the effected parties agreed to earmark the area as HCV. Following to the discussion and consultation, the management documentation is developed to manage such areas.
03 4.1.1 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
Standard operating procedures for both mill and estate (StOPs) exist. This does not cover all estates activities for example waste disposal.
Objective Evidence:
Close-out evidence:
Gomali has taken action to establish the committee to review the StOPs to cover all activities in the Estates. The revised StOPs dated 6 June 2011 including the StOPs for ‘Tapak Penolahan Effluent’ is made available to the auditor during the audit.
04 5.6.2 Date
Recorded>
14 August 2009
Due Date>
S01 Date
Closed> 25 August
2011
Non-Conformance:
No guidelines to review pollution prevention plans
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OBS # Indicator Observation Detail
Objective Evidence:
Close-out evidence:
the EIA covering the Management Action Plans are review annually. Latest revision dated 27
th June 2011 is available that involved the IOI Sustainability
team as well as the Estate management. The review process includes consultation relating to 1) identification of operations (aspect) that has environmental impact 2) Identification of waste and pollutants and implement plans to reduce the pollution 3) identification of HCVs and review 4) identification of stakeholders.
05 5.1.1 Date
Recorded>
25 August 2011
Due Date>
S02 Date
Closed>
Non-Conformance:
Person In Charge responsible for the assessing and reviewing the environmental aspects is not identified.
Objective Evidence:
Close-out evidence:
Aspects are documented and verified. Based on the record, the negative and positive impacts are assessed and are reviewed annually. However in most of the aspects, the Person In Charge (PIC) is not identified.
