Table 1: Monthly certified CPO shipment details ...................................................................................7 Table 2: Fresh Fruit Bunch production (mt) from July 2008 to October 2009 .......................................9 Table 3: Crude Palm Oil production (mt) from July 2008 to October 2009..........................................10 Table 4: Palm Kernal production (mt) from July 2008 to October 2009 ..............................................11
List of Maps
Map 1: Overview map of POM-PMU......................................................................................................8
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Lead Auditor Kishokumar Jeyaraj, has post graduate degree in Forestry and landuse. Is an expert in natural resources management planning, mapping and stakeholder consultation. Has been involved in certification and verification of forestry, environmental and oil palm industries for more than 15 years.
Auditor Tunku Mohammed Nazim Yaacob is a graduate in Ecology with more than 30 years experience in ecology and wildlife management. Tunku is a trained ISO 14000 lead auditor and expert in landuse and management planning. Has gathered many years experience of auditing in forest management and other natural resources sector at national and international levels. Has attended RSPO Lead Auditor Training Course and conducted a number of RSPO audits in Malaysia and Indonesia.
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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 languages & forms to allow for effective participation on decision making.
MA2008 Pamol Estate management maintain a list of stakeholders that are relevant in the estate management. The same list is made available to the audit team and is used for in the stakeholder consultation process. There is a mechanism to ensure that documents are publicly available, as stipulated in the individual management plans. Website provides adequate information.
SA2009 Engagement with relevant stakeholders is transparent and now guided by documented procedures. These procedures have now been documented and directed by flowcharts. A complete stakeholder list exists in estates and mill.
Records of information requests have been maintained and filed together with a copy of the written response in all estates.
Policies on commitment have been made which have been translated into operating procedures and implemented in all estates and mill.
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.
MA2008 There is a mechanism to ensure that documents are publicly available, as stipulated
in the individual management plans. 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
There is adequate documentation of records of complaints and grievances available in each of the estates and the mill. Similarly, the negotiation procedures are clearly documented and presented in the individual management plans. The estate also maintains adequate documentation of grievances which have been resolved.
SA2009 The major CAR raised for lack of a social impact assessment was made available at
the CAR close out visit (18th-19
th July 2008). At the time of surveillance, the SIA has
been reviewed and upgraded and is more comprehensive with time bound plans. The SIA is publicly available.
Criterion 2.1 There is compliance with all applicable local, national and ratified international laws and regulations.
MA2008 There is a complete register of laws and regulations, available at all estates and mills. The Managers have demonstrated adequate knowledge of the national laws and
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state ordinances, especially pertaining to OSH and labour related legislation.
Company OSH and staff/worker management is based on: Sabah Labour Ordinance (Sabah CAP.67); All relevant laws related to OSH; Immigration Act 1959/63 (Act 155); Industrial Relations Act, are general complied with. Legal environmental requirements are also in place.
All necessary renewable permits pertaining to crop production and milling are in place and displayed in the form of certificates in the group offices and respective mills. Legal requirements for machinery maintenance and power generation have also been complied with. Workers health requirements and pesticide regulations have also been fulfilled.
There is a complete register of relevant national laws and regulations, available at all estates and mills. The relevant laws have been systematically addressed and individual files tracking compliance exist. Current procedures are generally acceptable. List and copies of relevant national laws were viewed at each estate. The list also included relevant international laws and conventions ratified by the Malaysian government. However, the list given in the Internal Group Environmental Management & Monitoring Plans was considered incomplete.
Managers have demonstrated adequate knowledge of the national laws and state ordinances, especially pertaining to OSH, labour related legislation and environmental requirements. Evidence of implementation is shown in the form of circulated memos, documentation management procedures and estate practice.
The estate and mill managers have been given the task of implementing legal requirements on site. Tracking changes in laws is seen as a corporate task handled by the company’s headquarters and the relevant changes are passed on to individual estate managers in the form of memos or instructions to modify or change. However, system for tracking any changes in laws is considered inadequate (Minor CAR-01). The system to track changes was not considered sufficient to cover all federal laws and state enactments that are related to estate activities. The system to track changes has only been developed over the audit period and is yet to be tested and supportive of tracking changes in legal requirements in all aspects related to the plantation industry.
General observations and interviews at the estate and with surrounding communities produced no examples of non-compliance of laws enforced. There is evidence of compliance with most legal requirements. However, there are some examples where the estates have acted without checking whether their actions were within their legal rights. This included:
• Timber being taken from an adjacent forest reserve where estate boundary markers had not been maintained (see 2.1.3 below).
• Historical planting up to the edges of streams.
Also, there is no evidence of written permission from the Sabah Labour Department for documentation purposes for the introduction of new dimensions pertaining to levy deductions wages and other aspects of employee’s welfare (see 6.5.2) but the issue has since been resolved.
SA2009 Estate boundaries have been systematically marked in areas adjacent to other forms of landuse (sensitive areas). POM-PMU is committed to leaving a stream buffer strips at time of replanting. The progress is indicated in maps. Levy and other deductions have been undertaken with the consent of workers. This has been clearly explained to the workers and consent forms have been signed by individual workers. As of 1
st April 2009, levy and Fomema fees will be fully borne by the company thus no
deductions will be made.
Evidence of compliance with legal requirements –licenses displayed at company offices.
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All Standard Operating Procedures are cross reference to legal requirements to ensure compliance. The list of relevant national laws has been reviewed and available in the estate level Environmental Management & Monitoring Plans.
POM-PMU has completed the exercise of legal compliance and implementation review. This is reflected in the StOP where relevant legal requirements are cross reference to operations. Where seldom enforced law are concerned, a review is in process.
In addressing the minor CAR-01, the following actions have been taken:
• Collecting information
The system for tracking changes in the law has been amended. Using information gathered from: 1) news papers, 2) law changes tracked by MDC Book Publications, 3) circulars from industry associations – MPOA, etc, the company sectors that receive new information ensure the ‘Sustainability Term’ is notified,
• Assessment
The ‘Sustainability Team: 1) evaluate the change in the law, 2) assess current practices and submit suggestions for changes to senior company management.
• Authorised response
‘Senior Management’ issue Memo/Policy in accordance with changes. The ‘Sustainability Team’ circulates the new policy/memo to the operating units concerned.
• Implementation and monitoring
The ‘Sustainability Team’ monitors implementation through their routine internal audits. Minor CAR-01 is now closed.
Criterion 2.2 The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights.
MA2008 Legal ownership of the land within Pamol estates are tabulated under Table 3 of this report. All estates evaluated have been purchased and already have a history of more than 30 years of establishment. Land titles explicitly state the land is to be used for ‘oil palm’ –confirmed by observation. Buffalo rearing is considered an integral part of oil palm cultivation.
The ‘deer farm’ at Nangoh was not mentioned from the terms stated in the land title and though the deer farm had been approved by the state wildlife authorities, it has not been endorsed by the state land authorities (Minor CAR 02). The term ‘deer farm’ implies a separate agricultural venture outside the expressed conditions of the land title.
There is no evidence of current land use conflict nor local community disputes.
Legal boundary markers exist for all estates and all estates have had their boundary mapped by the company using a 1 metre differential Global Positioning System (GPS).
The estates have the capability to locate all boundary marker sites. Cadastral maps were viewed which indicate the absolute positions of the original ground pegs. At least two of these have been located by the Global Positioning System (GPS) field
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team at Nangoh Estate. This team is equipped with GPS tools to undertake surveys with accuracy acceptable to JUPEM (Jabatan Ukur dan Pemetaan, Malaysia- National Survey and Mapping Department).
Not all the original boundary markers have been located along estate boundaries, especially the forest reserve boundary (Minor CAR-03). Should these markers have been located and maintained at Meliau Estate, conflict with forestry regulations could have been avoided.
There is no documentary evidence showing the necessary action taken to resolve the local community request for the release of 20acres of land at Nangoh Estate for infrastructural development for the local community of Nangoh Sub-District, which includes a new clinic (see also indicators 6.2.3 and 6.3.2)
Surrounding local communities, through their village committees and local representatives have requested the company to allocate 20 acres of land for development of a clinic. The community has sent at least five letters and organised a meeting between IOI representatives and the community to discuss the status of their request. To date, there is no documentation from IOI showing the company’s response to the request, although there is evidence from an interview with the local community leader that the company has asked the local community to seek the permission from the District Office before the company can take necessary action (Minor CAR-04).
During the close CAR visit, it was observed that the company has provide the documentation, i.e. letter dated 12 June 2008 which adequately describes measures taken to resolve the 20 acres clinic area with the community. MINOR CAR 004 is closed.
SA2009 Legal ownership intact and no record of new infringement or land claims by local communities.
A letter has been received from the District Office - Sokongan untuk memelihara hidupan liar. Rujukan PDBLN: 100-28/48/19 acknowledging the presence of the deer farm on the estate and stating they have no objection to the activity as long as it is undertaken for educational and conservation purposes (minor CAR 02 is closed)..
Land tenureship documents are available. However, land use status of Rungus and Tindakon are still under tobacco (Observation 09 is raised).
Survey data, corrected using Survey Dept procedures to ‘close’ the survey, has been used by trained company staff to resurvey the boundary, relocate original pegs where they still remain and put in replacement markers where necessary. Though the exercise has not been completed, it is understood that the ‘sensitive’ boundary sections along forest reserves, rivers, etc. have been surveyed and marked on the ground. During surveillance 01, the audit team observed that markers placed along river buffers and areas bordering the forests (CAR 003 is closed).
A request by the company through their letter dated 12th of June 2008 for information
on capital required and development plan has yet to be complied with by the applicant.
CAR 004-2008 was closed during CAR close out visit on 18th July 2009.
The company has provided the documentation, i.e. letter dated 12 June 2008 which adequately describes measures taken to resolve the 20 acres clinic area with the community.
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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.
MA2008 All estates evaluated have in their possession details maps of the plantation extent. Pockets of local community land have also been identified. In Pamol estates, there are areas set aside as conservation areas where a landscape estate extent is provided.
The company has made effort to trying to re-designate riparian strips in the the estates. There is also a policy to re-establish riparian reserves in block adjacent to rivers. The local riverine communities will be allowed to use these areas for subsistence as an informal recognition of their customary rights.
No records of disputes exist as all the estates were bought in a developed state. It is not known if the previous owners had resolved any previously arising issues fairly. Currently no serious customary or legal use rights disputes evident
There is anecdotal evidence that the company has taken reasonable measures to avoid damage to other peoples’ use rights, property, resources or livelihoods. The company does not disallow the local communities living within their boundaries to reside or utilise the natural resources as well as infrastructure within the estates.
Only in the PAMOL group of estates are there local community settlements. The estates have a 40 year history of establishment it is evident that the local community is generally happy with the oil palm estates and there is no evidence of any serious disputes even though there is no evidence of participatory mapping conducted. This minor weakness is linked to criteria 6.1.1 and 8.1.4.
SA2009 In instances where there have been requests for land or user rights, the areas have been identified on maps and the matters either resolved or under discussion with the appropriate authorities.
Criterion 3.1 There is an implemented management plan that aims to achieve long-term economic and financial viability.
MA2008 Plantation management documents covering the next 5 years is available describing, among others the following elements: 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.
Information on crop sales and sale prices, and financial liabilities for the estates and mill were not available at the respective locations. Such information would be available in the Annual Report which is externally audited.
Ten year replanting programme for each estate are available.
Plantation management plan also exists in the form of maps for each estate. The maps indicate the boundary of the estates as well as the blocks or the compartment. The rivers and streams within the estates were marked together with the access road.
The annual plan is only in the form of annual budget determined by the Headquarters for each estate. The budget include allocation for the operation, estimate on expenses for harvesting, social programmes as well as possible environmental safeguards.
In summary, commitment to long term economic is demonstrated by the following:
• Annual operations and improvement budget for all operations at the estate
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level. The budget details planting, maintenance and fertilisation programmes and associated cost involved. The annual budget also includes details of general estate maintenance. Workers facilities upgrade and new developments are also captured in the annual budget.
• The estates have a 10 year replanting programme which is adhered to and taken into account in the respective annual budget.
• Crop production is monitored on a block by block basis for individual estates and a feedback mechanism is in place to analyse crop production trends supporting continuous improvement.
• Internal agronomic visits undertaken by the research division of IOI on a biannual basis to determine crop production efficiency for each individual estate is a firm commitment to long term economic and financial viability. The focus is on optimising crop production through sustained methods. The agronomic internal assessment includes analysis of yields, foliar nutrient, nutrient conservation, systematic soil survey and analysis, pest damage control, erosion control, fruit setting, general health of the crops, etc. Site management benefits from improvement recommendations targeting fertilising, pest management and general field maintenance. Agronomic reports are circulated to individual estate management for implementation. The agronomic recommendations also help support the formulation of the annual budget to promote sustainability.
• Occupational safety and environmental risk assessment with associated planning and implementation is also a dimension added to improve long term economic and financial viability.
A general indicator of IOI’s commitment to long term economic sustainability is the continuous yield increase in their mature areas in the estates evaluated. This is an indication of sustained viability and commitment to improvement.
SA2009 Financial viability can be determined. Information on crop sales and sale prices and financial liabilities for the estates and mill are made available to the auditors. Annual budgets for the mill and estate operations are available. Budgets include allocations for social & environmental/biodiversity conservation programme.
Adequate evidence of financial viability showing profit and loss is readily available.
Criterion 4.1 Operating procedures are appropriately documented and
consistently implemented and monitored
MA2008 Procedures were documented at group level and then translated into StOPs for individual estates where needed. Procedures exist for most operations both in the estates and mills in the form of written documents. The StOPs covering elements mentioned in criteria 4.2-4.8 are sufficient to ensure consistent implementation. The StOPs reflect best industry practices as detailed in IOI’s agricultural policy document.
StOPs for crop production and field maintenance are consistently implemented in all the estates evaluated. Where field management is concerned, the operating procedures have become standard practice understood by all field management staff. Procedures for the whole crop management cycle are provided to all management staff and training provided to ensure standard and consistent implementation. Input from the research division for continuous StOP review and improvement demonstrates the implementation of an adaptive management approach.
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A comprehensive monitoring framework is in place, especially for field operations is in place. The general estate/mill management hierarch ensures that relevant procedures both in the estates and mill are implemented. The management structure of all the estates and mills ensures that procedures are effectively implemented and monitored. General monitoring is in the form of task supervision and satisfactory task completion reports to senior management in individual estates and mills. A series of daily task completion forms serving as monitoring documents exist for all important field and mill operations. These serve as records of implementation and monitoring. Procedures for environmental monitoring exist and the same level of management control is placed on these procedures.
SA2009 StOP has been reviewed and revised and there is a commitment that this will be done annually.
Records of monitoring of actions taken available and maintained. Results of monitoring are used to revise StOP.
Criterion 4.2 Practices maintain soil fertility at, or where possible improve
soil fertility to a level that ensures optimal and sustained yield.
MA2008 In all the estates evaluated there has been a high standard of soil fertility maintenance implementation that meets normal industry practice of ensuring optimal nutrition for planting material according to soil type and climate. Fertilizer inputs are monitored.
Measures taken that contribute to soil fertility include: use of buffalo and wide wheel carts create relatively little soil compaction; tolerating soft weeds during the life of the palms and conserving organic matter at replanting; applying fertilisers to frond stacks.
Examples of soil fertility maintenance is attempted through the following procedures:
a. Inter-row frond heap stacking to ensure organic matter enrichment of the soil. The frond stacks decay at a natural rate and not only ensure that nutrients are slowly returned to the soil but also ensure soil structure is maintained by organic matter input. Oil palm root masses are concentrated under the frond stacks.
b. Fertilizer application is not within the individual palm circle but on the inter-row frond stacks. This ensures that wash of fertilizer is minimised as it is protected from the elements by the frond stack. The fertilizer granules penetrate the frond stacks initiating a slow release mechanism. The frond stacks are devoid of competitive weeds and the root mass beneath the frond stacks increases nutrient absorption by the roots of individual palms.
c. Empty Fruit Bunches (EFB) application around the circles of immature palms provides primarily potassium and phosphorous in smaller quantities. The EFB application also serves to increase pH marginally and soil moisture retention is ensured. EFB application in mature fields undertaken in estates with marginal soils. Planting blocks with poorer soils or with low yields are subjected to EFB applications. Besides nutrients, EFB application also serves to:
• Increases soil organic matter content.
• Improves soil structure.
• Increase infiltration and aeration.
• Reduces run-off.
• Improves soil water retention.
• Increases soil micro fauna activity.
• Increases cation exchange capacity.
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d. In replanting areas, the zero burning policy and its implementation has promoted windrowing and chipping of old palm trunks ensuring organic matter and nutrient retention in the fields.
e. Palm oil mill effluent (POME) is also applied to fields adjacent to Palm oil mills. The POME is a source of Nitrogen, phosphorous, potassium and Magnesium. The practice of returning nutrient to the fields is demonstrated by POME and EFB application.
f. Legume cover-crop (LCC) establishment in replanting areas promotes nitrogen fixing and this activity persists until the cover is shaded out by canopy closure.
The above supplement the periodical application of inorganic, magnesium, nitrogen, phosphorous and potassium. Trace elements are applied in selected fields with deficient soils.
Check on nutrient status in the field is undertaken by foliar (frond) sampling supported by soil nutrient status analysis. This is done at the very least annually to establish nutrient uptake by the palms and also to determine the annual fertilizer application recommendations. The monitoring results are presented in the form of a fertilizer recommendation report for each estate. IOI’s agronomic unit under the research division systematically undertakes monitoring and recommends changes to improve soil fertility to ensure optimal and sustained yield.
SA2009 Fertilizer inputs are monitored. At the group level, soil organic carbon studies are being undertaken. Water quality monitoring is undertaken in streams in the individual estates to determine fertilizer run-off. Monitoring of nutrient status through tissue and soil sampling is consistently being undertaken. Monitoring of EFB and POME application areas is consistently being undertaken. The estates have adhered to the company’s zero burning policy.
Criterion 4.3 Practices minimise and control erosion and degradation of soils.
MA2008 Soil management types mapped and mechanical properties understood by the estates. Items listed under the Malaysian National Interpretation (MNI 2008) are covered by the StOPs and were observed to be consistently applied throughout the estates, except for those noted below.
Soil erosion is significantly minimised in all the estates evaluated. The following are implemented:
a. In replanting areas the original stand is felled and chipped and left in the field to provide ground cover. Rapid Legume Cover Crop (LCC) establishment is a priority to reduce soil exposure to rain. In areas where LCC establishment as in difficult, the practice is to delay inter-row spraying to maintain weed vegetation cover to prevent soil erosion, only circle weeding is done. More rigorous weed control is undertaken once steps to LCC establish is more extensively is successful.
b. In mature areas, the policy is to maintain non competitive “soft weeds” in the inter-rows to maintain ground cover. Frond heap stacks and “soft weed” rows (harvester paths) provide a significant ground cover minimising exposed extent of soil. EFB mulching both in replanting and mature areas also act as erosion control measures. Non competitive “soft weeds are also maintained in bare areas as a form of erosion control.
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c. In areas having greater than 15˚slopes, contour terracing has been implemented where possible and frond stacking along the contour terrace edges makes erosion control more effective. The general practice of bunding in terraces is also in place.
d. Roads are maintained and compacted on a regular basis. The existence of an annual road maintenance budget ensures that roads do not become a source of erosion in all the estates.
e. The policy of maintaining buffers along water courses has been adopted and phased implementation has been observed. The PAMOL group of estates have not only maintained of pockets of original vegetation along rivers as conservation areas but also have systematically creating buffer strips along all major water courses at the time of replanting. This is a policy that is being effectively implemented. Buffers along water courses are protected to prevent bank erosion.
f. Soil mapping undertaken in all the estates serves as erosion risk mapping as different soil types have different erosion potential. Individual estates have used this information to develop varying management responses to erosion control.
g. Road maintenance programme are outlined in estate documents. Observations suggest work schedule and execution effective, and equipment maintained in a proper working state.
The techniques recorded above are part of standard estate practice. Implementation is monitored through systematic task completion in individual estates. The monitoring is continuous activity which is linked to budget control.
Even though there is topographic information of the estates, slope maps over 30m length have not been generated to indicate where slopes exceed 25°( as mentioned in guidance for Sabah) (Minor CAR-05). Such areas need to be identified, mapped and marked on the ground prior to replanting. However it was observed that there are areas that have been identified to be steep and also having very friable soils that are not planted and original vegetation (secondary forest) covers are maintained. Though riparian areas along major stream ways have been identified and mapped, natural streams under 1 m width have not been surveyed, mapped or marked on the ground, and such areas have not been identified for restoration ( as mentioned in item 10. of the MNI2008).
During the close CAR visit, the audit team was given evidence that the company has produced slope maps for all the estates identifying and delineating areas with slopes of more than 25 degrees. MINOR CAR 005 is closed.
SA2009 Soil erosion minimisation is comprehensively covered in the StOP. These procedures are consistently applied in individual estates encompassing the requirements of the standard.
At time of replanting, it was ensured that cover crop establishment was undertaken effectively minimising exposure of soil.
They have comprehensive road maintenance programme which has taken into consideration the minimisation of erosion and road wash. Road maintenance has taken into consideration effective side drains, silt traps and water run-off into the fields. Direct run-off of road wash into streams is minimal.
All river/stream buffers and the extent of ox-bow lakes have been identified and mapped in all estates. Buffers have been established in larger rivers bordering the estates. Re-vegetation is in progress for banks stabilisation. A plan of action has
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been drawn up to establish stream buffers within the estate at time of replanting (this is in progress).
Criterion 4.4 Practices maintain the quality and availability of surface and
ground water
MA2008 The estates visited have minimum impact on water resources in their respective locations. All the estates are located in high rainfall areas with abundant surface water. In fact PAMOL estates are in flood prone area and thus the question of water management is one of flood management. The estates have adequate hydrological knowledge and appropriate measure have been taken to mitigate flooding impact. Poor site selection cannot be attributed to current ownership and management. The current management practices demonstrate the ability to adequately keep fields
drained without negative impacts and sustain crop production.
For alluvial soils, riverine buffers have been given for main rivers. Tidal areas protected by flood gates that controls water flow rate and reduces bank erosion. Main rivers continue to erode and develop oxbow lakes. In some area the original riverine buffers have been eroded and palms are being lost. The potential extent of the ox-bow erosion areas has not been mapped, and has not been noted where it exceeds prescribed buffer widths of 50m or 20m.
Riverine buffers of 50m or 20m have been given for large and medium sized rivers in accordance with Sabah Water Resources Enactment , 1998 for water ways with a width greater than 3m. These areas have been mapped, they have not been planted and in some cases they have been identified as HCV 4 areas for conservation management. Monitoring is done according to a StOP and chemical analysis according to standard protocols. Water quality monitoring records were viewed and selected sampling points visited in the field. An example of how these monitoring records are used for management comes from Meliau Estate. There, comparison can be made between water quality entering and leaving the estate. It was noted that E. coli and mineral oils increased in out-going water. The estate has now banned washing vehicles in natural waterways. One weakness that was observed was that results or stream water analysis returned to the estate indicate assessment is accepted without question (dissolved oxygen levels unexpectedly high where the results should have been queried). Water monitoring results are not accompanied with notes on thresholds that would prompt a management response. Field workers have been trained not to apply fertilisers and spray up to the edge of streams. Observations indicate that sprayers have not fully understood spraying instruction and on occasion, spray up to the edge of waterways. Riparian along small streams (anak sungai) however was not adequately identified and marked for conservation in areas scheduled for replanting (Minor CAR 06). The natural streams that have not been mapped are assumed to have a width of less than 3m. However, field observations suggest that this may not always be the case (Nangoh blocks 00K and 93A). Without full knowledge of the streams in each estate, managers cannot ensure they are consistently in compliance with the enactment.
During the close CAR visit, the company provide evidence that the buffer zones along major rivers have been adequately identified on the map. Similarly, buffer zones for
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smaller streams also have been identified and buffers being establish where possible and there is a commitment to establish more buffers at the time of replanting (MINOR CAR 006 is closed).
Attention also need to be given to the mill particularly at the EFB receipt area where wash water transporting spillages and leaks, and run off from the EFB yard are drained to waterways without monitoring or appropriate treatment. Downstream of the mill and fields are riverine HCV areas. These are considered as protected areas. The impact of untreated runoffs on these areas has yet to be assessed and subjected to appropriate mitigation measures with relevant stakeholders.
SA2009 Progress of demarcation of identified buffer zones along streams is delayed and inconsistent (New Minor CAR 021 is raised).
No new construction obstructing water flow in streams. Water quality monitoring has been improved by increasing the number of parameters. The results are reviewed and any negative indications are being addressed. Run-off from EFB yard is now contained and monitored.
Water quality monitoring results have been verified and explanation by consultants is found to be sufficient where accuracy is concerned. Rainfall monitoring is consistent and adequate especially when the area is subjected to seasonal flooding.
At the mill, flow meters with certificate for calibration have been very recently installed for in-coming raw water and after-treatment. But as yet there is no monitoring data from these new meters (Observation 010 is raised).
Evidence for monitoring water utilisation is adequate as new meter with calibration has just been installed.
Individual estates and the mill have Environmental management and monitoring plans. These plans are now operational and consistently implemented ensuring that downstream riverine areas are not polluted.
Individual estates and mill has site specific water management plans which have ensured better onsite water management.
Criterion 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques.
MA2008 In all the estates evaluated, elements of IPM have been observed. Pest and weed infestation is recorded as minimal in these estates. The introduction of biological control is being promoted and the use of Barn Owls for rat control is also being investigated. Some attempt has been made to establish beneficial predator and parasitoid host plants e.g. Tunera subulata, Cassia cobannensis, Antigonon leptopus, Averrhoa carambola. Grazing by buffalo reduces chemical usage in the field as the animals consume the weeds. Buffalo grazing in the inter-rows is seen to be effective in the PAMOL estates. IOI is investigating the full implementation of IPM and a phased approach has been taken.
Estate management staff is aware of the toxicity indices for all pesticides used in the estate and appropriate briefing and training regard this is given.
The Internal Group Environmental Management & Monitoring Plan outlines the approach to IPM. This covers weeding, diseases and pests management. An adaptive management approach is taken. Biological control methods are employed, with routine field monitoring where a census is taken of indicator species. When tolerance thresholds are breached, a chemical response is initiated. Census records viewed.
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StOP is available for the control of all major pests and has been consistently implemented. See 4, 5, and 1 above. Records of application were viewed and field visits maid confirming application was made according to current schedules. Records of chemical usage are available for both mature and immature palms in the form of measurement units such as litres or kilograms. Records of pesticides program planned for each block and areas treated are also available.
It was however observed that the monitoring on the effectiveness of IPM system implemented is inadequate (Minor CAR 07). There is no evidence of pesticides usage being monitored on per hectare basis.
SA2009 No evidence of prophylactic use of Cypermetrin within the PMU. A monitoring programme determines the time of Cypermetrin use when population thresholds are exceeded.
Guidelines on IPM in place and implementation are in progress. The implementation of IPM is being monitored. (Minor CAR 007-2008 has been closed).
Records where pesticides have been used are also in place. Records of pesticide usage units per ha (total quantity of active ingredients) are in place for all estates.
However it was observed that the thresholds for IPM response for rat damage is not adequate. Records indicate over baiting (new Minor CAR 022 is raised).
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.
MA2008 All agrochemicals used are on the official registered as required by the Malaysian pesticides act 149 (1974). The IOI plantation group has reduced the number of chemical in its estates. Glyphosate is the main systemic herbicide used for general field spraying. Paraquat is only used in immature fields and IOI has demonstrated the reduction of spraying rounds in these areas. Records indicate that spraying rounds are being reduced in mature areas indicating positive action by the estates evaluated. Warfarin as rat bait is not extensively used as rat damage is minimal in all estates evaluated. The use of buffaloes to graze the planting blocks in the PAMOL estates is seen as step to reduce the use of herbicides.
For example, records of reduction of paraquat used (in litres) in all Pamol estates
since 2004 is as follows:
Prophylactic use of Cypermethrin is specified for 24 months after replanting to control
Estate 2004 2005 2006 2007
Ulu 4200 2400 1000 500
Bayok 4243 1399 1212 1141
Rungus 5225 2035 1315 985
Tindakon 4165 1735 1161 520
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rhinoceros beetle. The use of the chemical is not for the entire life cycle of oil palm
planting. The treatment is necessary in the first year of re-planting based on the fact
that the beetle bred in the decomposing mulch (which is not burnt). Without proper
treatment, the pest will quickly spread to a new re-planting field. Such a practice
(cypermethrin application) in that specific situation is within the national best practice
guideline.
Chemical mixing and application is thoroughly supervised. Sprayers are not allowed
to mix chemicals. The mixing is done by estate supervisory management staff and
transported to the field for application. The sprayers are briefed on safety and
spraying techniques before beginning any task and are appropriately protected and
are knowledgeable in emergency response. Knapsack sprayers are used with
appropriate nozzle size to ensure effective ground level spraying.
Chemical storage is observed to be satisfactorily stored according to the Malaysian
Occupational Safety and Health and pesticide regulatory requirements. StOPs exist
for chemical storage and handling. Chemical are placed in secure separate stores
away from habitation and water courses. Spillage containment exists. Material
safety data sheets are available for all chemicals stored and the relevant personnel
well versed in the information in these sheets. Storage of knapsack sprayers is also
done with the necessary care. Used Chemical containers were disposed of by
burying in isolated perched sites away from water courses, but at the time of
assessment, the company has changed the policy to store empty chemical container
and disposed it off through Department of Environment (DOE) approved agent.
Pesticide application is undertaken with minimal risk and impacts. Chemical
concentrations are not maximised and only tested optimal concentrations are used for
all herbicides. All necessary precautions are in place and spillage is minimal. IOI
does not practice aerial spraying.
The company undertakes residue testing as part of its commitment to food safety and
traceability compliance upon client’s request. To date, no buyer has requested for
such testing at the CPO mill. The test is normally carried out at the Group’s refinery in
Sandakan or in Europe.
StOPs are available together with CHRA but there is no written justification for use of specific chemical in specific activities (Minor CAR 08). Chemicals are prescribed without adequate written justification and explanation why alternatives are not acceptable.
Warning notices on chemical use were observed to be posted in Bahasa Malaysia at storage areas. Staff handing chemicals and applying chemicals in the field have been kept informed of safety considerations. Field workers interviewed understood chemicals represented a danger and the need to avoid ingestion, but had little understanding of the specific risks to themselves from each chemical they had handled.
There is documentation of annual medical surveillance conducted in the mills and individual estates. Examination by Hospital Assistant identifies pregnancy. Pregnant women reassigned to alternative tasks. Pregnant and breast-feeding women are allocated less arduous and risky work, e.g. assigned as general cleaners with daily wage. A provision for female workers to be excused from pesticide work for confirmed pregnant and breast-feeding women is available in the estate and mill management plans.
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SA2009 There is a group level SOP for chemicals, identifying the active ingredients and specifying their use. Written justification of chemicals used available (Minor CAR 008 is closed)..
It was verified that the pesticides used are only those registered / allowable under the Pesticide Act 1974. CHRA available for all estates and mill. There evidences that showed that medical examination is conducted on a monthly basis for all workers handling chemicals.
The pesticides are stored in accordance to the Occupational Safety and Health Act 1994 and Regulations and Orders and Pesticides Act 1974 and Regulations. Records of pesticide use are maintained.
An exercise has been undertaken to determine the understanding of risks involved in handling chemicals. A scoring mechanism has been devised to rate workers performance and understanding. This is link to a training needs assessment.
Early pregnancy detection is further enhanced by monitoring menstrual cycle and making available pregnancy test kit in estate’s clinic.
There is a firm commitment from POM-PMU to minimise use of Type 1A and 1B chemicals especially Brodifocum (Type 1B), Carbofuran (Type1B) Methamidophos (Type 1B). A
4.6.8
At the time of surveillance Ebor/Brodifocum (Type 1B), Carbofuran (Type1B) Methamidophos (Type 1B) are still kept in stock (New Minor CAR 23 is raised).. A plan of action for reduction of use or elimination has been formulated for the estates. However commitment to reduction of use is to be ascertaining during the next surveillance audit.
CPO is being tested for pesticide residues, heavy metals and mineral oils as requested by the buyers..
Criterion 4.7 An occupational health and safety plan is documented, effectively communicated and implemented.
MA2008 IOI has documented an occupational health and safety plan, which include health and
safety policy, working procedure for all tasks, training, monitoring system and etc.
The implementation of health and safety policy and procedures are considered
adequate.
Workers have been adequately trained in safe working practices and PPE supplied for all workers, both in the estates and mills. There is a daily briefing by the mandors (supervisors) during the Muster Call for workers prior to commencing work, whereby workers are reminded of OSH requirements and their PPE checked.
In general, it was observed that:
• A safety and health policy is available (Occupational Safety, Health and Staff Welfare Policy), as stipulated in the individual management plans for estates and mill. The health and safety policy is communicated to new workers and staff during induction training and via mandores at the muster call every morning which is documented at the estate level.
• There is a Safety and Health Chairman (usually the estate manager) and a Safety and Health Secretary cum safety Coordinator (assistant manager or staff at the executive level) at each estate and mill.
• Health and safety committee exists whereby meetings are held on a quarterly
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• Emergency response plan is available for each estate and mill.
Accident reporting and investigation procedure in place, as stipulated in the individual management plans for estates and mill.
Though there are records of OSH meetings attended by estate management and representatives of the working groups, there are no records of OSH meetings between the worker representatives and their respective working groups (Minor CAR-09). This lack of regular meeting between the representative and the workers is considered as an inadequate implementation and adherence to OSH procedures.
It is understood that workers are kept informed of OSH related instructions from management by their respective ‘mandores’, but there is no evidence that OSH issues from the workers and brought up management attention other than through direct communications channels. There is no documentation of company policy on the provision of PPE which is available to employees. The provision for PPE is not communicated effectively to the workers, which have resulted in confusion and discontent, in some instances e.g. the minutes of meeting of the health and safety committee of the mill (Kilang PAMOL) dated 10 April 2008 (item no. 7.5) shows that there was an issue among the workers regarding the deduction of wages for PPE (safety shoes). Evidence of the resolution of this issue is not available (see 6.5.2)
Copies of accident reports are available. Accident Statistics and Analysis is conducted on a monthly basis for estates and mill.
Local workers and staff are covered under SOCSO whereby a small percentage is deducted from their monthly wages. In addition, staff are covered under three (3) types of insurance, which includes:
• Group Term Life Insurance
• Hospital and Surgical Insurance
• Personal Accident Insurance
Foreign workers are covered under the Foreign Worker Compensation insurance as per the Workmen Compensation Act 1952, which includes repatriation expenses and personal accident coverage (accidental death, permanent total disablement, temporary disablement and medical expenses).
SA2009 OSH procedures are in place. Each estate has a functioning committee and there is a mechanism for raising safety concern and issues prior to OSH meetings. The tasks of committee members are clearly defined. There are records of follow up meeting / briefing by the worker’s representative to the respective work group (Minor CAR 009 is closed). Individual OSH plan exists for estates and mill and plans are reviewed annually. A more comprehensive operational risks assessment is being undertaken for all estates and mill
Accident records are maintained and periodically reviewed. There is a documented
procedure for investigating cause of accident and subsequent line of action. All
workers are covered by accident insurance.
Criterion 4.8 All staff, workers, smallholders and contractors are appropriately trained
MA2008 Staff training records were observed to be well maintained at all sites visited. Meliau
Estate has training plan for the year 2008. From the records and documentation, the
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company has well documented and systematicly implement its health and safety
programme. There is evidence that OSH Operating Procedure Training is conducted
available for sprayers, manuring, rat baiting, bagworm injection, harvesters, drivers,
tractor passengers, ramp operators, chemical store.
Timetable for training and monitoring of Health and Safety is available for the
following:
o OSH Training(quarterly)
o DOSH Seminar by mill (quarterly)
o First Aid Training
However it was observed that the company has not adequately carry out assessment of training needs both for the estate and the mill (Minor CAR- 010). Similarly, there was no evidence of individual training records for employees that could be used for the purpose of assessment on the training needs.
SA2009 Assessment on training needs is conducted through assessing workers job function and performance. Individual employees are assessed through questionnaires. Through this process employees’ weaknesses related to job functions are identified and an appropriate training programmes formulated (Minor CAR 010 is closed).
Current training programme is available, but implementation has been significantly delayed at the mill (New Minor CAR-024 is raised).
Criterion 5.1 Aspects of plantation and mill management 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.
MA2008 The Environmental Protection (Prescribed Activities) (Environmental Impact
Assessment) Order, 2005, listed ‘development of agricultural estate or plantation
involving change in type of crops covering an area of 100ha or more but less than
500 hectares’ as a prescribed activity which requires preparation and submission of a
Proposal for Mitigation Measures (PMM) report to Environmental Protection
Department (EPD), Sabah, for review and approval. Relevant to this requirement, all
estates in Pamol group of plantations were established prior to the enforcement of
EIA regulation in Sabah. As such, there was no official EIA done for the group apart
from Nangoh and Meliau Estate in 1988 which was submitted to the Department of
Environment (DOE).
Now, according to EPD, under the new Act (2005), replanting is defined as a
‘development’ project which means that all oil palm plantations has to either submit
an EIA report or PMM to EPD.
In compliance to the requirement, the company however, has dedicatedly prepared
and submitted quarterly environmental monitoring report to the DOE both for Nangoh
and Meliau Estate and that provide results of water quality monitoring etc associated
with oil palm plantation operations.
Since acquiring the management of Pamol estates from the previous owner in 2003,
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IOI has not developed any new areas or carried out expansion of the existing estates.
The company only carried out some replanting to replace old palms in the following
locations since 2004:
As part of effort to address the comments highlighted by the report reviewer, a
discussion was held with Sabah’s Environmental Protection Department (EPD)
Enforcement Officer on 20 October 2008 (after receipt of review comments) that
pointed out that under the Environmental Protection (Prescribed Activities)
(Environmental Impact Assessment) Order, 2005, replanting in existing plantation
require submission of PMM or EIA to EPD.
IOI has made a commitment to immediately pursue compliance on this matter and will
submit the necessary documentation to comply with the necessary instruction /
guidance made by the the Department of Environment (DOE).
As part of meeting the RSO standard, an Internal Group Environmental Management & Monitoring Plans has been produced and put to use by the estates. This document focuses on field practices. Together, these documents have identified management needed for regulatory compliance as well as best industry practices. Observations indicate the company has adopted environmental resource conservation and conservation of biological diversity as a part of estate operating activities.
An Environmental Risk Assessment (which is schedules at half-yearly/quarterly intervals)and Environmental Action Plan was also been developed for the PAMOL Group. The company also has established an accident risk evaluation to identify systematically the risks on safety and health which may affect, or arise from the activities. The accident risk evaluation report is still at the testing stage. An EIA documents identifying point sources of emission to water and air as required for regulatory compliance and actions required by the EIA are being undertaken.
The guidelines mentioned above do not include a mechanism to systematically identify potential aspects and impacts of risk to the environment from estate and mill activities that have not already been identified. This would limit continuous improvement to those areas previously identified and not encourage a more adaptive management approach.
The environmental risk assessment has not yet been repeated and updated, something which will be addressed in due course. Currently there was no mechanism to review and update aspect and impact of risk assessment (Minor CAR 011).
General observations however suggest that environmental conditions at the mill, workshops, fields, housing and amenities areas are well maintained at above industry norms.
Estate 2004 2005 2006 2007 2008
Ulu 285 132
Bayok 124 82 - 257 63
Rungus - - 199 73 -
Tindakon - - - - 72
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MYNI requires that environmental improvement plan to mitigate the negative impacts and promote the positive ones, is developed, implemented and monitored. To this respect, at the time of assessment, no specific improvement plan to promote positive impacts have been documented at the Pamol estate level (Minor CAR 012). It would be expected for such plan would, where applicable, identify targets for management performance at each estate, and set quantifiable indicators to monitor management performance for key the areas where management action has been identified.
SA2009 A mechanism is now in place to undertake an annual review of aspects and impacts for all work sectors. The first of these annual reviews documented as part of the ‘ EIA management action plan and continuous improvement plan’ , has been undertaken and the results recorded with notes identifying the staff responsible and outlining time bound and specific follow-up actions (Minor CAR 011 is closed).
A mechanism is now in place to undertake an annual review for gaps in environmental management issues. The first of these annual reviews has been undertaken and the results recorded with notes identifying the staff responsible and outlining time bound and specific follow-up actions (Minor CAR 012 is closed)..
It was, however, observed that there was no mechanism to monitor the effectiveness of protocols to identify review for gaps in aspects and impacts (New Observation 011 is raised).
Criterion 5.2 The status of rare, threatened or endangered species (ERTs) and high 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
MA2008 Areas within the estates with High Conservation Value (HCV) have been identified for biodiversity and environmental protection (pls see map attached). Management to conserve the HCV value has been initiated. These areas have been identified on Geographical Information System (GIS maps), and marked in the field. Ecological types have been identified and a provisional list of species present drawn up. Currently, Universiti Malaysia Sabah (UMS) has been engaged to undertake a biological survey. These HCVs have identified habitats for ERT species such as the Proboscis Monkey.
Assessment of the sites have identified the areas as unsuitable for palm cultivation and having values that would benefit from conservation. The assessments have not yet progressed to identifying and evaluating threats to conservation values and sources of those threats. (See management plans in 5.2.2 below).
Management Plans for HCV areas are contained within estate management documents and include proscriptive activities for social engagement with local communities, information on wildlife, security patrols and maintenance of facilities. Field management is evidently supported through budget allocated for soil and water conservation.
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HCV areas have been sign posted and meetings held with local communities to explain that the areas have been intentionally set aside. Local community interviews confirm the actions of the company are understood. Interviews suggest local communities have no significant dependence on these areas for food, materials or cultural practices. There has been significant effort made to develop the amenity value of HCV to promote their conservation objective.
A provisional list of ERTs has been compiled from historical observations. There are records of routine monitoring of species numbers. The ERTs identified include the Proboscis Monkey. A UMS survey team has been engaged and is currently undertaking a systematic assessment of the HCV sites. Recommendations from UMS could be considered as input from ‘expert stakeholders’. Improvements being investigated for HCVs includes: linking forest patches through riparian future reserves.
The management of the habitat for ERT however does not have sufficient monitoring indicators for their conservation (Minor CAR 013). Proboscis Monkey is present at Bayok Estate and their habitat protected from threat from human activity. But no management is directed towards improvements in habitat quality – food plants and shelter that has been degraded by historical disturbance and fragmentation.
SA2009 Evaluation of threats to the sites have been undertaken and incorporated into the management plan. The site is being managed in accordance to the management plan. Regular monitoring of these sites is undertaken to prevent degradation due to human activities ( Minor CAR 013 is closed).
Concerning the Proboscis monkey habitat in the HCV3 areas, a ‘Report on Proboscis monkey’ was commissioned in 2008 which gave recommendations for conservation management actions. The suggested actions include: monitoring population numbers, security patrols, planting of woody trees, etc. Though the report can be accepted as sufficient to close the current minor CAR 013, further consideration will need to be given to manage both habitat and the very small local population of only 3 effective breeding pairs should the population show any signs of falling or
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Criterion 5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner.
MA2008 Waste generated by the operation in the mill and estates have adequately identified. The EIA document identifies regulated waste, and observations confirm that domestic, agricultural and process wastes have been identified and consistently managed according to operating procedures. Waste is generally managed in a responsible manner suitable for the type and volume of waste produced.
Scheduled wastes were observed to be consistently collected, stored and disposed in accordance to StOPs. Other wastes were observed to be separated and the wastes that were not recycled – metals, dense plastics, etc. were sent to landfill. These were dedicated sites in the estates located on mineral soils above the water table. Where possible, waste products are recycled or used as beneficial bi-products in the field. Crop residues / biomass are recycled. Field wastes – fronds, bunch stumps are kept in the fields. At the mill, fibre is used as a boiler fuel at the CPO mill and surplus fibre & shell transported out for use as biomass fuel at the refinery located near Sandakan town. POME, EFB and ash used as ‘manures’ in the field in accordance with best industry practices.
Not all source of pollution have been identified (See 5.3.1 above) and consequently those not identified have not been subject to management attention. Waste produces leachates which are not treated before they leave the factory and enter local water system (Minor CAR 014). Of the wastes and pollutants identified, minor omissions include: discarded tires in the field which are potential mosquito breeding sites and derelict vehicles including a school bus which could be a hazard to children had not been sent for final disposal.
Not all potential sources of pollution have been identified. Pollution sources from old disposal sites and non-point release have not been identified and their risks assessed as required under 5.1.1. Had a periodic risk assessment been undertaken, the following items may have been noted and addressed:
• Surface run-off and wash water from the mill are drained directly to local streams without trapping oils, fats and sediments, and treatment of water.
• Mill bi-products and wastes that include: EFB, fibre, shell, boiler ash and clinker, flue ash, etc. are stored in open ground without any containment to collect leachates before they enter local surface and ground water.
• Old open dump/store of organic wastes and ashes have leachates entering local surface and ground water.
• Buffalo holding yards and ponds drain into local streams near housing areas with no monitoring for E.coli and other potential impacts to water
• Production of N2O from loss of nitrogen fertilisers in the field. (See 5.6 below.)
SA2009 E. coli is being monitored in waterways. Record of monitoring and its results are available (Minor CAR 014 is cosed).
Stock piles of fibre and ash that were previously stored in the open and were subject to leaching have been cleared from the mill compound. New ash and fibre discharged on to hard surfaces with surface drains that have sediment traps. Some fibre is stored under the shelter of the existing ramp.
It was observed that 6 units of oil and sediment traps had been installed on drains as they leave the mill fenced area. It should be noted that no monitoring has been planned or done to monitor the effectiveness of these measures.
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The process of identifying new sources of pollution has been undertaken and mitigation measure identified in all estates and mill. The environmental management and monitoring plan is to be reviewed annually. However it was observed that historical wastes are a potential source of contaminants to water and have not been treated (new Minor CAR 025 is raised).
Ground observation shows that crop residues and biomass are being recycled.
Criterion 5.4 Efficiency of energy use and use of renewable energy is maximised.
MA2008 As described earlier, the fibre and kernel shell were burnt in the boiler to generate energy either at the CPO mill or at the refinery. Assessment of energy use and monitoring of its usage is only undertaken as part of budgetary control. As part of continuous improvement process, IOI is planning to develop a biomass power generation plant using shells and EFB in its refinery in Sandakan.
Fossil fuel (diesel and petrol) use in the vehicles, generator sets and other machinery are monitored. Use of buffalo for crop evacuation has significantly reduced the use of fossil fuel in the operation. Indicator 5.4.1 of the MYNI requires that renewable energy use in the mill is monitored compared to the CPO production. It was observed that the rate of use of fibre in the Pamol mill is not monitored against energy production or the CPO production. There was no record of fiber input into the boiler (Minor CAR 015). With no baseline value for renewable energy use and periodic monitoring, it is not possible to observe trends. It was noted that the boilers go through sub-stoichiometric cycles when unburnt carbon is released to the atmosphere. Flue ash was observed to contain unburnt carbon.
At the time of close CAR visit, the company has provide evidence of monitoring records of fibre usage in boilers in the mill for the month of June 2008 and there is a commitment to undertake this on a monthly basis. MINOR CAR 015 is closed.
SA2009 The use of fibre in boilers is undertaken on a monthly basis and the amount of renewable energy used per ton of CPO is also available. However this is based on mere estimate. Thus the amount of fibre consume seems to be inaccurate. There has been no attempt to ensure the estimates are based on actually usage. Calibration for estimating renewable energy use is weak and needs to be updated. Baseline values should be credibly determined (New Observation 012 is raised).
Similarly, records of usage of fossil fuel available, but does not differentiate sector of use (New Observation 013 is raised)..
0Criterion 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 guidelines or other regional best practice.
MA2008 In line with legal procedure and best management practices, IOI does not use fire in the plantation management. IOI has a zero burning policy and physical clearing means are used.
As described in the earlier sections, materials generated during land clearing for replanting were chipped and left to rot on site. In areas visited, it was observed that palm trunks felled are cut into small slices and windrowed. The practice was
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Domestic waste generated at the mill as well as housing within the estate were collected and disposed off site of at the landfills. No sign of open burning were observed.
SA2009 There was no evidence of open burning of domestic waste and during replanting as the company has a strict open burning policy. The standard procedure for chipping of old trunk prior to planting was observed being practiced in all areas visited during the surveillance visit.
Criterion 5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and monitored.
MA2008 Environmental Risk Assessment and EIA documents prepared have covered parts of the assessment of polluting activities. Boiler stack emission is monitored and oxidation pond effluent is monitored at least twice a year. Water quality of adjacent rivers is also monitored.
The relevant activity relevant to enhancing carbon sequestration and storage undertaken by IOI is includes re-vegetation of riparian areas.
Prescriptive approaches to control GHG including NOx are mentioned in the Internal Group Environmental Management & Monitoring Plan. Observation of activities that contribute to the mitigation of polluting activities from waste management at the mill and estates include: attenuating concentrated mill wastes- EFB, fibre, shell, ash & POME, by distribution to the field; recycling of waste materials – metals, plastics, etc.
Not all polluting activities outside regulatory requirements however have been taken into consideration (Minor CAR 016). This is true for activities related to the production of GHG where not all potential pollution generating activities have been identified through risk assessment reviews, and considered for management response.
There was no peat soil within Pamol estates.
SA2009 5.6.1
Annual ‘Special Existing Environmental Issues Management Plan’ has been documented and identify sources of pollution (Minor CAR 016 is closed).. Environmental management and monitoring plan are reviewed annually for all estates and mill.
However, at the time of surveillance visit, it was observed that there was no programme to develop and implement management controls for production of Green House Gases (new Minor CAR 026 is raised).
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.
MA2008 The company has developed a framework for carrying out social impact assessment as per the guidance document and is planning to carry out the assessments for each estate. The report which is essential for short and medium term in handling potential
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impacts and to mitigate impacts which have arisen has not been produced.
The company has documented evidence of passive impact assessment, i.e. a reasonable amount of consideration to mitigate social impacts for employees and communities affected by the plantations and mills as well as resolution of impacts, only if grievances are brought to the attention of the managers e.g.: roads, repairs for housing woes, assistance in times of duress, etc.
There is evidence of active social engagements with stakeholders, especially the employees and local communities. The estate managers and their Social Liaison Officers have made the effort to engage with their employees through the Employees Consultative Council (ECC) and the local communities through intermittent visits to the villages. There is a timetable with responsibilities for mitigation and monitoring of social aspects as stipulated in the estate and mill management plans. However, only social impacts raised through consultation with the employees are documented, i.e. minutes of meetings but there is no documented evidence for participatory social impact assessment with the local communities.
In summary, at the time of main assessment, there was no evidence of a documented social impact assessment carried out through consultation with affected communities (Major CAR 017).
At the time of close-out visit, and subsequently thereafter, the company has provide baseline documentation of a social impact assessment (SIA) (non-restrictive format) for each estate carried out through consultation with communities. The report contain basic social element description and identifies potential impacts and measures to mitigate such impact (Major CAR-017 is closed).
Eventhough its was observed that there were no major social issues within Pamol estate management, but to fully comply with the MYNI requirement, the exercise carried out and the report require improvement in the following areas :
• It needs to cover more social areas not just limited to gauging the impacts related to employment and living conditions.
• The description of methodology adopted is only limited to sampling techniques. A detailed description of social research methodology adopted which gives a clear indication of the reliability of data collected, data analysis and validation techniques is not provided in the SIA.
• The document should also has updated time-bound social plans linking the impacts with mitigation measures.
• Adequate maps which clearly show the communities and key elements such as extent of community land, land status etc. relative to the estate.
• Community socio-economic profile
• Overall conclusions linking the SIA to the management plans.
SA2009 All estates and the mill have their own specific social impact assessment and management plans. The plans were developed through a consultative process with a broad range of stakeholders. The social impact plan has time bound mitigation measures with assigned responsibilities. The plan is supported by maps. There is a commitment that these plans would be reviewed annually. The estates and mill specific social impact assessment and plans were undertaken through a participatory approach. Records of participation and feedback from stakeholders are documented and available for scrutiny. A timetable with responsibilities for mitigation and monitoring is no longer generic and is at site specific. There is a commitment in the document stating that annual review
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Criterion 6.2 There are open and transparent methods for communication and consultation
between growers and/or mills, local communities and other affected or interested
parties.
MA2008 There is evidence of active consultation with local communities with the village heads on a sporadic basis whereby the managers attempt to impart information on company decisions/policy, e.g. non-acceptance of local communities FFB at the company mills.
There is little evidence to support effective communication and consultation mechanisms designed in collaboration with local communities. There is evidence of intermittent meetings with the local communities in Tindakon estate but the frequency of these meetings is unknown.
Communications do not take into account differential access to information to different levels of local community, e.g. women and ordinary members of the community. The communications with the local community is at the village administration level or village elites. The impact arising from communication with village representatives alone results in information not being adequately disseminated to the larger community. For example, there are requests by the local communities for consideration/assistance by the company for the following:
• Acceptance of local communities (smallholders) FFB at the mills
• For the gate at the Cocos Village to be opened 24 hours to enable them to use the route for emergencies.
Though the company has conveyed company decisions pertaining to the two examples above adequately to the village representatives, the villagers are still unclear of company decisions.
The company has appointed / nominated a Social Liaison Officer in early 2008 that is
responsible for all estates and the mill with clear roles and responsibilities tabulated in
the estate management plan.
There is also a Gender Representative (usually female) appointed for each estate and mill, whose duties include attending to grievances pertaining to gender issues, especially in sexual harassment. The Gender Representative is also in-charge of communicating the Policy on the Prevention and Eradication of Sexual Harassment in the Workplace to the workers and staff.
There is a list of stakeholders available which is comprehensive, involving all stakeholders, e.g. government agencies, non-governmental organizations, village representatives, sundry shop owners, HUMANA, etc. 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 (see weakness). One weakness however was observed where there is inadequate documentation of action taken in response to input from stakeholders who are non-employees, e.g. the local communities. The status of queries from the local community pertaining to the request of land claims for the clinic and infrastructure development (20 acre) at Nangoh Estate is not known.
SA2009 The unit has an improved documentation and communication procedures in the social impact assessment and management action plan. The procedures include grievance mechanism, information request, land dispute mechanism etc. It was also observed that record of communication with stakeholders exist and the unit is open and receptive to stakeholder’s request.
There is a social liaison officer for each estate ensuring that the social management plan is implemented and monitored. Adequate documentation has been provided and the land claim is being addressed.
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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.
MA2008 There is evidence of a mutually agreed system for dealing with complaints and grievances for employees, which is implemented and accepted by all parties. The mechanism is as follows:
1. Estate Consultative Committee (ECC) which has representation from different level of workers who are elected by the workers.
2. There is grievance report book at all estates and the mill
3. For field workers: Report to mandore�supervisor�Assistant manager�Manager
4. For staff: Report to manager
5. Report to Social Liaison Officer/Gender Representative
For other stakeholders, e.g. the local communities, the following steps are 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 (frequency uncertain);
4. The company holds meetings with community representatives (minutes of meetings dated 11 January 2008 at Tindakon 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.
There is adequate evidence to demonstrate that the system is open to any affected parties. 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.
There is evidence of documentation of grievances which have been resolved and the
outcome accepted by the workers (signature of workers obtainedd for every
grievance resolved). There is evidence that generally disputes are resolved in an
effective, timely and appropriate manner.
SA2009 Documentation of grievances is adequately maintained. Based on discussion and evidence gathered during the surveillance visit, it could be concluded that the system is fair and open to all affected parties.
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.
MA2008 Pamol estates have been established by Unilever in 1960s and IOI Corporation Bhd has acquired the estate about 10 years ago. Based on documented history, the estate was established by felling forested land granted by Sabah government. The programme was part of the effort to upgrade rural socio-economic scenario by
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It was observed during the evaluation that there was no issues pertaining to compensation of legal customary rights to local communities as far as Pamol estates management and operation is concerned. The local communities were employed by the management to work in the plantation. Most of the communities within the area were brought by the plantation management and has been living there since the establishment of the estates in 1960s.
The company has provides amenities such as school, clinic, infrastructures etc for the communities. The community has the standard Jawatankuasa Kemajuan dan Keselamatan Kampung (JKKK) establishment, that meet once a month to discuss and act on any issues brought by the member of the community. The chairman of the JKKK report to the higher authority of the government. The estate management maintain close rapport with the leaders and consider issues brought by the JKKK leaders are official complaints where action will be taken
There are evidences that the company has effectively acted on complaints made by the community for example on the assistance given in resolving water woes of their employees by providing one tank for two units.
SA2009 The company continue to provide necessities to the communities living nearby and maintain good rapport with the community leaders. There was no records on issues of compensation or complaints from the communities.
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.
MA2008 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 appointment letter of staff contain the clear details of job description, work location, salary and other terms such as annual leaves, medical benefits etc. Similarly, offer letter extended to the foreign workers contain the similar details with additions of terms and conditions wage calculation, overtime, housing, deduction for levy, payment to FOMEMA, legal age, prohibition of marriage, conflict resolutions as well as termination of work permit and prohibition against strike.
There was however an unresolved issue pertaining to deduction of pay for various purposes (Minor CAR018). The deductions are still carried out despite an earlier (unresolved) query by representatives of the Labour Department on their visit on 21/06/2006 to the Human Resources division at the Sandakan Regional Office.
During the close out visit, the audit team observed adequate evidence of documentation pertaining to dissemination of information related to maternity leave, allowance, sick pay and reimbursement of delivery costs etc. The document dated 4
th
July 2008 is adequate in addressing the non compliances sighted during the main assessment. MINOR CAR 018 is closed.
SA2009 It was observed that employment contract is more comprehensive and covers all necessary elements to ensure employee protection. There is evidence that the contracts are explained to the foreign workers in their mother tongue before acceptance.
Regarding to the HUMANA school at PAMOL, the following improvements were planned and observed:
i. Expansion plan of HUMANA School to accommodate more students in the near future. At present, the unit is in the site selection process.
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ii. Multimedia equipment has been provided to the school.
iii. Local teachers from nearby villages are being hired to accommodate increasing number of students.
Activities planned for HUMANA School are clearly outlined in their social impact assessment and management action plan.
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..
MA2008 Workers were hired through a proper contract where appointment letter is issued. There is no published statement in local languages, either in employment contracts or appointment letters or other types of documentation recognizing freedom of association. This observation is true for Malaysian employees only. In the context of foreign labour, the company is limited by Malaysian Immigration Laws which states that foreign workers are prohibited from engaging in any kind of trade union.
Any issues between employer and employees are brought up to the Employees Consultative Committee (ECC). As described in the earlier sections of this report, minutes of meetings of the ECC are available at the estates and mills.
According to the Sabah Labour Ordinance provided below, it is implicit that freedom of association is not restricted by the company. Discussion with the workers does not show that this is a big issue as far as Pamol estates is concern.
SA2009 The ECC handles minor issues dealing with repair of amenities and provision of facilities. Where foreign workers are concerned, freedom of association is subjected to Malaysian labour and immigration regulations. Since there is no workers union existing in the estate for Malaysian, there is no internal process to facilitate a mechanism for collective bargaining for Malaysians (New Minor CAR-027).
Published statement in local languages that recognises freedom of association is available in the following languages:
i. Chinese
ii. Tagalog
iii. Kadazandusun
iv. Bahasa Indonesia
v. Bahasa Melayu
vi. English
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.
MA2008 There is evidence of clear definition of working age and working hours in the workers’ terms of reference/agreement. There is documented evidence that the minimum age requirement is met.
There is no evidence on any employment of minors in any of the estates and mill visited. Verification of the list of employees records show that all workers were above 17 years of age.
SA2009 Employee records show that employment age requirement is met. Ground observation during surveillance visit also does not show evidence to suggest
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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.
MA2008 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, except for positive discrimination.
The company does pay maternity allowances to both local and foreign workers as stipulated in the Sabah Labour Ordinance. The company maintains a Register of Maternity Leave and Allowances (which complies with Section 94A, of the Sabah Labour Ordinance) for foreign and local workers and staff.
Note: Malaysian Immigration Laws (as per letter dated: 10 December 2007): ref: IM.101/S.A/306/4.KL.6) prohibits foreign workers who are pregnant are not allowed to be employed.
However it was found that the company has not made payment of maternity allowance to workers. There were also evidences of slight disparity in terms of pay to different group of workers which was not adequately justified by the management (as per company memo dated 28 January 2008, Sub: Rates of Pay) (Minor CAR 019).
At the time of close CAR visit, the followings were observed:
• The company has adequate documentation on maternity allowances paid to foreign workers and has provided reasonable explanation as to the mechanism of payment for maternity allowances according to the Sabah Labour Ordinance.
• The management has revised the daily wage rates from RM10 to RM12 for women workers, which is now the same as that for the male workers (refer to company internal memo dated 30
th June 2008: Revision of Total Daily Wage for
Foreign Workers).
With such evidence of actions taken by the company, MINOR CAR 019 is closed.
SA2009 As observed during the main assessment, documented policy on equal opportunities is available and communicated to all employees.
There is no evidence of discrimination when a cross section of employees was interviewed. A functioning grievance mechanism is in place. The ECC also looks into allegation of discrimination if reported. There has been a wage revision for employees.
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.
MA2008 There is a policy on “the prevention and eradication of sexual harassment in the workplace” (memo dated 6 December 2006). There is also a Gender Representative (usually female) appointed for each estate and mill, whose duties include attending to grievances pertaining to gender issues, especially sexual harassment. The Gender Representative is also in-charge of communicating the Policy on the Prevention and Eradication of Sexual Harassment in the Workplace to the workers and staff.
SA2009 As noted during the main assessment, policy on sexual harassment exists and communicated to all employees. Training needs for the interpretation of sexual
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harassment policy has been identified but yet to be implemented.
A specific grievance mechanism for handling sexual harassment exists. However, awareness regarding sexual harassment and the mechanism for implementation is poorly understood by employees (new Minor CAR 028 is raised).
Criterion 6.10 Growers and mills deal fairly and transparently with smallholders and other local businesses.
MA2008 Pamol mill does not deal with smallholders. All FFB processed by the mill are sourced from IOI estates evaluated under this exercise.
There was no evidence to suggest that the company has conduct in unfair business with their contractors and sub contractors (re planting activities etc).
MA2009 Not applicable as Pamol does not deal with smallholders and outgrowers.
Criterion 6.11 Growers and millers contribute to local sustainable development wherever appropriate.
MA2008 There is evidence that preference for employment is given to members of local communities for all positions, especially in the mill and offices. Anecdotal evidence indicates that members of the local communities shy away from field work/manual labour.
The company’s Corporate Social Responsibility (CSR) evidently contribute to various programmes such as:
• Humana Child Aid Society Sabah,
• Education foundation (Tan Sri Dato’ Lee Shin Cheng Foundation) & scholarships (e.g. the annual Yayasan’s Young Achievers’ Awards Programme),
• Student adoption programme (Tan Sri Dato’ Lee Shin Cheng Foundation; memo dated 8 May 2007);
The company also provide assistance in kind to communities and employees for the utilisation of company infrastructure such as schools, mobile healthcare facilities and other amenities provided by the company. The company also provide technical advice to the communities on Good Agricultural Policy (GAP) to smallholders near Ladang Ulu.
The community are granting access through the estate roads which is maintained by the company. As a low lying area, the company has facilities to deal with natural disaster such as flood, which is normally extended to the authorities and local communities.
SA2009 POM-PMU continues to contribute to local development. Contribution to local communities is specified in the social impact assessment and management actions plan.
Criterion 7.1 A comprehensive and participatory independent social and environmental impact assessment is undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management and operations.
MA2008 This whole Principle is not applicable to this assessment as all Pamol estates in Sandakan Region have been planted with oil palm since 1960s prior to acquisition by IOI. There are no new plantings. The company is only involved in re-planting
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programme after felling of old palms and there is no plan for expansion.
SA2009 The POM-PMU has undertaken an independent EIA for replanting in the estates. The report was accepted by the Environmental Protection Department of Sabah on 26
th of August 2009 with conditions. The EIA document was reviewed and found to
be adequate for replanting purposes only. For details of acceptance by the EPD, refer to Appendix 2.
A Letter: KELULUSAN LAPORAN EIA BAGI “PROPOSED REPLANTING OF 12,169 HECTARES OF OIL PALM PLANTATION WITHIN PAMOL GROUP PLANTATION AREAS, TELUPID, BELURAN DISTRICT, SABAH BY IOI CORPORATION BERHAD. RUJUKAN: JPAS/PP/17/600-1/11/1/74(73), DATED: 01 SEPTEMBER 2009. has been issued by the EPD Sabah.
Criterion 7.2 Soil surveys and topographic information are used for site planning in the
establishment of new plantings, and the results are incorporated into plans and
operations.
MA2008 Pls see 7.1.
Criterion 7.3 New plantings since November 2005, have not replaced primary forest or any area required to maintain or enhance one or more High Conservation Values.
MA2008 Pls see 7.1
Criterion 7.4 Extensive planting (to be determined by SEIA) on steep terrain, and/or on marginal and fragile soils, is avoided.
MA2008 Pls see 7.1
Criterion 7.5 No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions.
MA2008 Pls see 7.1.
Criterion 7.6 Local people are compensated for any agreed land acquisitions and relinquishment of rights, subject to their free, prior and informed consent and negotiated agreement.
MA2008 Pls see 7.1.
Criterion 7.7 Use of fire in the preparation of new plantings is avoided other than in specific cases as identified in the ASEAN Guidance or other regional best practice.
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.
MA2008 IOI as a plantation group has demonstrated commitment to continuous improvement. The active research division promotes improvement in crop production. There are policies to support improvement efforts. As an established plantation company, IOI continue to monitor its performance. Over the years the company has recorded good results in terms of production.
The Internal Group Environmental Management & Monitoring Plans addresses environmental risk, providing guidance for the environmental risks associated with specific areas of estate and mill activities. IPM system in place that employs
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biological control methods and undertake routine pest census. When monitoring results indicate thresholds have been exceeded, a chemical response is initiated.
Almost all agricultural wastes from the mill, workshops and fields are recovered for beneficial use. Biomass is used to substitute fossil fuel; grasses used to feed buffalo; domestic waste separation is practiced. Items connected with regulatory compliance have been addressed and are consistently monitored.
The company has documented evidence of impact assessment, i.e. a reasonable amount of consideration to mitigate social impacts for employees and communities affected by the plantations and mills as well as resolution of impacts, only if grievances are brought to the attention of the managers e.g.: roads, repairs for housing woes, assistance in times of duress, etc.
There are also evidences of active social engagements with stakeholders, especially the employees and local communities. The estate managers and their Social Liaison Officers have made the effort to engage with their employees through the Employees Consultative Council (ECC) and the local communities through visits to the villages.
A weakness however is observed where currently, there is no internal mechanism is developed to capture performance and expenditure in social and environmental aspects (Minor CAR 20), which is required under indicator 8.1.6.
SA2009 The POM-PMU is committed to reducing the use of Class 1A and 1B chemicals. Cypermethrin is not use on a prophylactic basis. For rat control, the course of over baiting has been identified and a commitment to rectification is in place. Pest monitoring program is in place with identified thresholds so that IPM implementation can be expanded.
Environmental impact mitigation is undertaken at estates and mill levels. Individual environmental management & monitoring plans are reviewed annually to identify gaps and continuous improve environmental management. The POM-PMU has also developed a Special Existing Environmental Issues Management Plan for immediate mitigation of environmental impacts.
The unit continue to maximize recycling of wastes.
There is a mechanism which supports annual review of environmental plans. The POM-PMU is undergoing a learning process and preliminary of indicators has just been implemented to monitor environmental management performance.
Social impact assessment and management action plan are to be reviewed annually to ensure continuous improvement in social management. (Minor CAR 20 has been closed).
The annual review of both social and environmental plans is linked to performance. Indicators have been identified to gauge performance. Expenditure on social and environmental management can be determined as the accounting programme has specialised codes identifying these aspects
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A total of 1 Major Corrective Action Requests (CARs) and 19 Minor CARs were raised in the 2008
certification audit. One Major CAR and 6 Minor CARs were closed during the CAR close out visit on
the 18th of July 2008. At the time of first surveillance, sufficient objective evidence was presented to
close out the 13 outstanding Minor CARs.
A total of 8 new Minor CARs and 5 observations have been raised in the first surveillance on POM-
PMU. The certificate condition requiring compliance to an EIA has also been fulfilled. The EIA report
prepared has been submitted and duly approved by the Sabah Environmental Protection Department
on the 26th of August 2009. The document was found to be adequate to demonstrate compliance to
the Sabah law and requirement of the MYNI, as well for mitigating replanting impacts.
The first annual surveillance (2009) has recorded no major CARs. In view of this finding, it is
recommended that this unit remain certified.
3.2 Maintenance of certification
During the surveillance evaluation, it is assessed if there is continuing compliance with the
requirements of the MYNI. Any areas of non-conformance are raised as one of two types of
Corrective Action Request (CAR):
.01 Major CARs - which must be addressed and closed out urgently with an agreed short time frame since the organisation is already a certified organisation. Failure to close out within the agreed time frame can lead to suspension of the certificate.
.02 Minor CARs - which must be addressed within an agreed time frame, and will normally be checked at the next surveillance visit
The full record of CARs raised over the certification period is listed under section below. The table below provides a progressive summary of findings for each surveillance.
SURVEILLANCE 1
Issues that were hard to assess
After the duly review process by secretariat, the RSPO has agreed with SGS recommendation to a conditional certificate to Pamol Sabah. One of the fundamental issue was the need to take the necessary action to fully comply to the Sabah environmental law pertaining to the EIA requirement.
Pamol Sabah has taken the necessary action to carry out an EIA for its replanting programme and submitted the report to the Sabah Environmental Protection Department (EPD). The EPD has accepted and approved the report in September 2009.
Other issues of importance relates to environmental monitoring, chemical use, IPM as well as health and safety aspect of workers.
Number of CARs closed 13 Outstanding CARs were closed.
Nr of CARs remaining open 0 Outstanding CARs from previous evaluations were not closed.
New CARs raised 0 New Major CARs and 8 Minor CARs were raised.
Certification Decision The management of the oil palm mill and estates of Pamol Sabah remains certified as:
� The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole certification unit
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� The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole certification unit covered by the scope of the certificate.
3.3 Status of non conformities in 2008 and new non conformities raised in 2009
Presented below is the tabulated form of non conformities closed during the surveillance. To
present a comprehensive record of non conformities that can be track over time, the con
conformities raised during the 2009 surveillance are also presented in the same table.
List of Corrective Action Requests
CAR # MYNI Indicator
CAR Detail
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
System for tracking any changes in law is inadequate
Objective Evidence:
The company has appointed personnel for tracking the changes in law but it was observed that the system had not been adequately implemented. Recent changes in laws / regulations were not updated.
01 2.1.4
Close-out evidence:
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• The system for tracking changes in the law has been amended. Using information gathered from: 1) news papers, 2) law changes tracked by MDC Book Publications, 3) circulars from industry associations – MPOA, etc, the company sectors that receive new information ensure the ‘Sustainability Term’ is notified,
Assessment
• The ‘Sustainability Team: 1) Evaluate the change in the law, 2) assess current practices and submit suggestions for changes to senior company management.
Authorised response.
• ‘Senior Management’ issue Memo/Policy in accordance with changes. The ‘Sustainability Team’ circulate the new policy/memo to the operating units concerned.
Implementation and monitoring
• The ‘Sustainability Team’ monitor implementation through their routine internal audits.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
Deer farm at Nangoh Estate may infringed the conditions of the land title
Objective Evidence:
The land title for Nangoh Estate stated that the land was to be used for oil palm only. Though a permit has been obtained from the Sabah Wildlife authorities to raise deer, no permission has been sought from the land office to undertake activity not mentioned on the Land Title.
Close-out evidence:
02 2.2.2
A letter has been received from the District Office – Sokongan untuk memelihara hidupan liar. Rujukan PDBLN:100-28/48/19 acknowledging the presence of the deer farm on the estate and stating they have no objection to the activity as long as it is undertaken for educational purposes.
Date Recorded>
29 May 2008
Due Date>
28 Oct 2009
Date Closed>
12 Nov 2009
Non-Conformance:
Boundary stones not clearly visible along the perimeter
03 2.2.3
Objective Evidence:
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Maps showing the boundary of the estates are available but only one boundary stone was observed in Nangoh estate where the signboards were posted by the Sabah Forestry Department. At Meliau estate boundary signboards have also been erected by the Sabah Forestry Department, but the original estate boundary markers have not been located and maintained.
Close-out evidence:
Survey data, corrected using Survey Dept procedures to ‘close’ the survey, has been used by trained company staff to resurvey the boundary, relocate original pegs where they still remain and put in replacement markers where necessary. Though the exercise has not been completed, it is understood that the ‘sensitive’ boundary sections along forest reserves, rivers, etc. have been surveyed and marked on the ground. Markers were noted along river buffers and forests.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
18 July 08
Non-Conformance:
No documentary evidence that necessary actions has been taken to resolve the 20 acre land matter in Nangoh estate.
Objective Evidence:
The company has documents on a number of land issues within Pamol Estate but does not maintain any documentary evidence on matters to resolve a 20 acre area with the respective community.
Close-out evidence:
04 2.2.4
The company has provided documentation, i.e. letter dated 12 June 2008 which adequately describes measures taken to resolve the 20 acres clinic area with the community. MINOR CAR 004 is closed.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
18 July 2008
Non-Conformance:
No slope maps indicating areas above 25 degrees.
Objective Evidence:
There are no documents available to show that the company has undertaken slope analysis to identify the location and extent of slopes greater than 25 degrees within Pamol estates.
Close-out evidence:
05 4.3.1
The company has provided slope maps for all the estates identifying and delineating areas with slopes of more than 25 degrees.
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Small streams (anak sungai) and their riparian areas have not been identified and marked for conservation in areas scheduled for replanting.
Objective Evidence:
The company has adequately identified and allocated buffer zones / riparian reserves along major rivers within the estate but not has done so for smaller streams..
Close-out evidence:
06 4.4.1
The company has identified and allocated buffer zones along major rivers. Buffer zones for smaller streams have been identified and buffers being establish where possible and there is a commitment to establish more buffers at the time of replanting.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
Inadequate monitoring on the effectiveness of IPM system.
Objective Evidence:
The company has an IPM system but there was no records to show that the company has monitored the necessity and effectiveness of such practices.
Close-out evidence:
07 4.5.2
There are SOPs for the implementation of non-chemical controls for pests and palm infections.. SOPs are also in place for routine census to monitor for pest damage to palms and crop prior that set thresholds for a chemical response. Currently, the company is satisfied that the infection and damage are within acceptable limits and consider the protocols for monitoring the IPM system and its implementation as effective.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
No Justification for the use of chemicals in the estates.
Objective Evidence:
SOPs are available together with CHRA but there is no written justification for use of specific chemicals in specific crop maintenance activities
08 4.6.1
Close-out evidence:
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There is a group level SOP for chemicals, identifying the active ingredients and specifying their use.
CAR 008-2008 has been closed.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
Inadequate implementation and adherence to OSH procedures (e.g lack of regular meetings between the representative and the workers)
Objective Evidence:
Procedures on OSH is available but it was observed that it was not adequately followed to ensure its effectiveness and continuous improvement.
Close-out evidence:
09-2008
4.7.1
OSH procedures are in place. Each estate has a functioning committee and there is a mechanism for raising safety concern and issues prior to OSH meetings. The tasks of committee members are clearly defined. Individual OSH plan exists for estates and mill and plans are reviewed annually. A more comprehensive operational risks assessment is being undertaken for all estates and mill.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
Assessment of training needs inadequate.
Objective Evidence:
Training programme is documented and implemented but there was no proper assessment on the needs, appropriateness, timeliness of the training required at various stages of plantation operations.
Close-out evidence:
010 4.8.1
Assessment on training needs is conducted through assessing workers job function and performance. Individual employees are assessed through questionnaires. Through this process employees’ weaknesses related to job functions are identified and an appropriate training programmes formulated.
011 5.1.1 Date Recorded>
29 May 2008
Due Date>
28 May 2008
Date Closed>
12 Nov 2009
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No mechanism to review and update aspect and impact of risk assessment
Objective Evidence:
Aspect and impact of operations were identified but there was no description and implementation of a mechanism to review and update the elements.
Close-out evidence:
A mechanism is now in place to undertake an annual review of aspects and impacts for all work sectors. The first of these annual reviews documented as part of the ‘ EIA management action plan and continuous improvement plan’ , has been undertaken and the results recorded with notes identifying the staff responsible and outlining time bound and specific follow-up actions
CAR 011-2008 has been closed.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
No specific improvement plan to promote positive impact
Objective Evidence:
Environment management documents have not taken into consideration the promotion and sustenance of positive impacts.
Close-out evidence:
012-2008
5.1.2
A mechanism is now in place to undertake an annual review for gaps in environmental management issues . The first of these annual reviews has been undertaken and the results recorded with notes identifying the staff responsible and outlining time bound and specific follow-up actions .
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
The management of the habitat for ERT does not have sufficient monitoring indicators for their conservation
Objective Evidence:
013 5.2.1 & 5.2.2
HCV areas within the holdings were identified and plans for conservation were developed but it does not include monitoring management effectiveness.
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Concerning the Proboscis monkey habitat in the HCV3 areas, a ‘Report on Proboscis monkey’ was commissioned in 2008 which gave recommendations for conservation management actions. The suggested actions include: monitoring population numbers, security patrols, planting of woody trees, etc. Though the report can be accepted as sufficient to close the current CAR 013, further consideration will need to be given to manage both habitat and the very small local population of only 3 effective breeding pairs should the population show any signs of falling or reproduction rate decline.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
Uncontained waste produce leachate which are not being treated before they leave the factory and enter local water system
Objective Evidence:
Observed waste that were not properly contained (e.g ash, kernel etc) and were left in an open area where its leachate flows freely into drains.
Close-out evidence:
014 5.3.2
Stock piles of fibre and ash that were previously stored in the open and were subject to leaching have been cleared from the mill compound. New ash and fibre discharged on to hard surfaces with surface drains that have sediment traps. Some fibre is stored under the shelter of the existing ramp.
It was observed that 6 units of oil and sediment traps had been installed on drains as they leave the mill fenced area. It should be noted that no monitoring has been planned or done to monitor the effectiveness of these measures.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
18 June 08
Non-Conformance:
No records of use of fibre in the boilers
Objective Evidence:
Fibre is used for boiler however there are no records of the quantity used compared to the energy generated, and thus a baseline from which improvements to efficiency can be made is yet to be established
015 5.4. 1 & 5.4.2
Close-out evidence:
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The company has provided monitoring records of fibre usage in boilers in the mill for the month of June 2008 and there is a commitment to undertake this on a monthly basis.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
Not all polluting activities outside regulatory requirements have been taken into consideration – activities related to the production of GHG.
Objective Evidence:
The company has identified polluting activities relevant to legal compliance but has not identified and planned to control other elements that are not covered by the legislation especially those activities that could possibly emit GHGs.
Close-out evidence:
016 5.6.1 & 5.6.2
Potential sources for polluting emissions including Green House Gases (GHG) have been identified in the ‘Special Existing Environmental Issues Management Plan’ (SEEIMP) under ‘Waste Management Plans’ . These review management actions.
Date Recorded>
29 May 2008
Due Date>
28 July 2008
Date Closed>
18 July 08
Non-Conformance:
No evidence of a documented social impact assessment undertaken through consultation with affected communities
Objective Evidence:
The company has developed a framework for undertaking a social impact assessment as per the guidance document (SOP- Guidance on undertaking a SIA- 29
th January, 2008) and is planning to carry out the
assessments for individual estates. The report is essential for short and medium term mitigation of potential impacts, but has yet to be produced.
Close-out evidence:
M017 6.1.1& 8.1.4
The company has managed to provide baseline documentation of a social impact assessment (SIA) (non-restrictive format) for each estate within Pamol Sabah plantation.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
18 July 08
Non-Conformance:
018 6.5.2
Provision of maternity leave, allowance, sick pay and reimbursement of delivery cost are not adequately documented and disseminated.
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Conditions on a number issues such as maternity leaves, allowances, sick pay etc. were not clearly documented and communicated across the board to the workers.
Close-out evidence:
There is evidence of adequate documentation pertaining to dissemination of information related to maternity leave, allowance, sick pay and reimbursement of delivery costs dated 4
th July 2008.
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
18 July 08
Non-Conformance:
There is evidence of discrimination based on gender and national origin pertaining to maternity allowance
Objective Evidence:
There is evidence that the company grants maternity allowance for Malaysian workers and staff, but not to foreign workers. There is also evidence of a slight disparity in terms of pay to different groups of workers which has not been adequately justified by management.
Close-out evidence:
019 6.8.1
• The company has adequate documentation on maternity allowances paid to foreign workers and has provided reasonable explanation as to the mechanism of payment for maternity allowances according to the Sabah Labour Ordinance.
• The management has revised the daily wage rates from RM10 to RM12 for women workers, which is now the same as that for the male workers (refer to company internal memo dated 30
th June 2008: Revision of
Total Daily Wage for Foreign Workers).
Date Recorded>
29 May 2008
Due Date>
28 May 2009
Date Closed>
12 Nov 2009
Non-Conformance:
No mechanism to capture performance and expenditure in social and environmental aspects
Objective Evidence:
There is no documentation or any other evidence of such a mechanism existing.
020 8.1.6
Close-out evidence:
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Surveillance 01Evaluation for RSPO MYNI Requirement for
Details of management actions and expenditure on social and environmental activities are recorded under codes: 40 Environmental 41Social, 42OSH, 43 Training. And summarised for each month in the estate and mill accounts.
For issues initiated by the stakeholders, records are kept in the communications files where a copy of the written response and actions taken are also filed. Examples would include the supply of potable water as a result of a stakeholder request.
CAR # Indicator CAR Detail
Date Recorded>
12 Nov 2009
Due Date>
Surv 02 Date
Closed>
Non-Conformance:
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:
Buffer zones have been identified and partially demarcated along rivers and streams
Close-out evidence:
21 4.4.1
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
Non-Conformance:
Monitoring of pesticide usage units per hectare or per ton crop e.g. total quantity of active ingredient (a.i.) used/ tonne of oil.
Objective Evidence:
Thresholds for IPM response for rat damage not adequate.
Records indicate over baiting.
Close-out evidence:
22 4.5.4
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
23 4.6.7
Non-Conformance:
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Surveillance 01Evaluation for RSPO MYNI Requirement for
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.
Objective Evidence:
At the time of surveillance Ebor/Brodifocum (Type 1B), Carbofuran (Type1B) Methamidophos (Type 1B) are still kept in stock. A plan of action for reduction of use or elimination has been formulated for the estates. However commitment to reduction of use is to be ascertain during the next surveillance audit.
Close-out evidence:
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
Non-Conformance:
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.
Objective Evidence:
Current training programme is available, but implementation has been significantly delayed at the mill.
Close-out evidence:
24 4.8.1
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
Non-Conformance:
Having identified wastes and pollutants, an operational plan should be developed and implemented, to avoid or reduce pollution.
Objective Evidence:
Historical wastes are a potential source of contaminants to water and have not been treated.
Close-out evidence:
25 5.3.2
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Surveillance 01Evaluation for RSPO MYNI Requirement for
Documented plans to mitigate all polluting activities
Objective Evidence:
No programme to develop and implement management controls for production of Green House Gases.
Close-out evidence:
26 5.6.1
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
Non-Conformance:
Documented minutes of meetings with main trade unions or workers representatives.
Objective Evidence:
The ECC handles minor issues dealing with repair of amenities and provision of facilities. Where foreign workers are concerned, freedom of association is subjected to Malaysian labour and immigration regulations. Since there is no workers union existing in the estate for Malaysian, there is no internal process to facilitate a mechanism for collective bargaining for Malaysians.
Close-out evidence:
27 6.6.1
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
Non-Conformance:
Grievance mechanism not adequately communicated to the employees.
Objective Evidence:
A specific grievance mechanism for handling sexual harassment exists. However, awareness regarding sexual harassment and the mechanism for implementation is poorly understood by employees.
Close-out evidence:
28 6.9.2
List of Observations
MY01827
Surveillance 01Evaluation for RSPO MYNI Requirement for
1.1.1 Records of requests and responses must be maintained
Date Recorde
d> 28 May 2008 Date Closed> 12 Nov 2009
Observation:
Weaknesses observed in engagement with stakeholders.
Follow-up evidence:
01 1.1.1
Records of information requests have been maintained and filed together with a copy of the written response in all estates.
Policies on commitment have been made which have been translated into operating procedures and implemented in all estates and mill.
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.
Date Recorde
d> 28 May 2008 Date Closed> 12 Nov, 2009
Observation:
There is no evidence of participatory mapping conducted. There are no maps which show the extent of community rights.
Follow-up evidence:
02 2.3.1
In instances where there have been requests for land or user rights, the areas have been identified on maps and the matters either resolved or under discussion with the appropriate authorities.
3.1.1 Annual budget with a minimum 2 years of projection
Date Recorde
d> 28 May 2008 Date Closed> 18 July 2008
Observation:
Financial viability of the estate cannot be ascertained due to lack of information.
Follow-up evidence:
03 3.1.1
Observation 03 closed.
Adequate evidence of financial viability showing profit and loss is readily available.
04 4.4.3 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).
MY01827
Surveillance 01Evaluation for RSPO MYNI Requirement for
Accuracy of water quality monitoring result is questionable, which relates to competency of the consultants and in-house expertise.
Follow-up evidence:
Observation 04 closed.
Water quality monitoring results have been verified and explanation by consultants is found to be sufficient where accuracy is concerned.
4.4.5 Monitoring of water usage in mills (tonnage water use/tonne FFB
processed).
Date Recorde
d> 28 May 2008 Date Closed> 12 Nov 2009
Observation:
Water monitoring exists but no program to calibrate equipment.
Follow-up evidence:
05 4.4.5
At the mill, flow meters with certificate for calibration have been very recently installed for in-coming raw water and after-treatment. But as yet there is no monitoring data from these new meters.
4.5.1 Documented IPM system
Date Recorde
d> 28 May 2008 Date Closed> 12 Nov 2009
Observation:
Inadequate IPM system.
Follow-up evidence:
06 4.5.1
Maintained.
There is a documented guideline for IPM in place and implementation is in progress.
6.2.3 Maintenance of a list of stakeholders, records of all communication
and records of actions taken in response to input from stakeholders.
Date Recorde
d> 28 May 2008 Date Closed> 18 July 2008
07 6.2.3
Observation:
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Surveillance 01Evaluation for RSPO MYNI Requirement for
There is inadequate documentation of action taken in response to input from stakeholders who are non-employees, e.g. the local communities. The status of queries from the local community pertaining to the request of land claims for the clinic and infrastructure development (20 acre) at Nangoh Estate is not known.
Follow-up evidence:
Adequate documentation has been provided and the land claim is being addressed.
A published statement in local languages recognizing freedom of
association.
Date Recorde
d> 28 May 2008 Date Closed> 12 Nov 2009
Observation:
No published statement recognising freedom of association for Malaysian employees.
SABAH CAP. 67 LABOUR ORDINANCE Incorporating latest amendments - Act A1238/2005
Part II
Contracts Of Service CHAPTER IV - TERMS AND CONDITIONS
9C Contracts of service not to restrict rights of employees to join, participate in or organize trade unions Nothing in any contract of service shall in any manner restrict the right of any employee who is a party to such contract—
(a) to join a registered trade union; (b) to participate in the activities of a registered trade union, whether as an officer of such union or otherwise; or (c) to associate with any other persons for the purpose of organizing a trade union in accordance with the Trade Unions Act 1959. [Act 262].
08 6.6.2
Follow-up evidence:
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Surveillance 01Evaluation for RSPO MYNI Requirement for
Observation 08 has been closed at the time of surveillance.
Published statement in local languages that recognizes freedom of association is available in the following languages:
i. Chinese
ii. Tagalog
iii. Kadazandusun
iv. Bahasa Indonesia
v. Bahasa Melayu
vi. English
OBS # Indicator Observation Detail
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
Non-Conformance:
Growers must show that they comply with the terms of the land title.
Objective Evidence:
Land tenureship documents are available. Land use status of Rungus and Tindakon are still under Tobacco.
Close-out evidence:
09 2.2.2
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
Non-Conformance:
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
Objective Evidence:
Evidence for monitoring water utilisation inadequate as new meter with calibration has just been installed.
Close-out evidence:
010 4.4.5
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
011 5.1.1
Non-Conformance:
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Surveillance 01Evaluation for RSPO MYNI Requirement for
Documented aspects and impacts risk assessment that is periodically reviewed and updated.
Objective Evidence:
No mechanism to monitor the effectiveness of protocols to identify review for gaps in aspects and impacts
Close-out evidence:
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
Non-Conformance:
Monitoring of renewable energy use per tonne of CPO or palm product in the mill.
Objective Evidence:
The use of fibres in boilers are undertaken on a monthly basis and the amount of renewable energy used per ton of CPO is also available. However this is based on mere estimate. Thus the amount of fibre consume seems to be inaccurate. There has been no attempt to ensure the estimates are based on actually usage. Calibration for estimating renewable energy use is weak and needs to be updated. Baseline values should be credibly estimated.
Close-out evidence:
012 5.4.1
Date Recorded>
12 Nov 2009
Due Date>
Date
Closed>
Non-Conformance:
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).
Objective Evidence:
Records of usage of fossil fuel available, but does not differentiate sector of use.
Close-out evidence:
013 5.4.2
MY01827
Surveillance 01Evaluation for RSPO MYNI Requirement for
NAME OF THE PLANTATION MANAGEMENT UNIT: Estates Size (ha) Location Other Information
Pamol Sabah Oil Mill, Sabah (Audited in May 2008). Meliau Estate. 2,998 Sandakan, Sabah Bayok Estate. 2,210 Sandakan, Sabah Tindakon Estate. 1,579 Sandakan, Sabah Rungus Estate. 2,560 Sandakan, Sabah Nangoh Estate. 1,834 Sandakan, Sabah Ulu Estate. 2,331 Sandakan, Sabah Sugut Estate (certification under IJM)
713 Sandakan, Sabah 100% Crop sent to IJM Plantation Oil Mill.
Sakilan Oil Mill, Sabah (Audited in November 2008). Sakilan Estate. 2,142 Sandakan, Sabah Linbar 1 Estate. 2,458 Sandakan, Sabah Linbar 2 Estate. 1,842 Sandakan, Sabah Pamol Kluang Oil Mill, Peninsular (Audited in April 2009). Pamol Barat Estate. 2,213 Kluang, Johor Mamor Estate. 1,902 Kluang, Johor Pamol Timur Estate. 2,167 Kluang, Johor Swee Lam Estate. 1,234 Kluang, Johor Unijaya Estate. 1,194 Kluang, Johor Kahang Estate. 2,271 Kluang, Johor Gomali Oil Mill, Peninsular (Audited in August 2009). Bukit Serampang. 2,725 Tangkak, Johor Gomali. 3,595 Segamat, Johor Sagil. 2,518 Tangkak, Johor Paya Lang 1,476 Segamat, Johor Tambang. 2,020 Segamat, Johor
MY01827
Surveillance 01Evaluation for RSPO MYNI Requirement for
Reagent Estate. 2,313 Tampin, N. Sembilan Kuala Jelai. 678 K. Pilah, N. Sembilan Bukit Dinding. 1,660 Bentong, Peninsular Bahau. 3,028 K. Pilah, N. Sembilan Bertam Estate 734 Malacca. Jasin Lalang 2305 Malacca Baturong Oil Mill, Sabah (Audited in September 2009). Baturong 1 2,822 Lahad Datu, Sabah Baturong 2 2,351 Lahad Datu, Sabah Baturong 3 1,858 Lahad Datu, Sabah Cantawan 1,452 Lahad Datu, Sabah Bukit Leelau Oil Mill, Peninsular (to be certified in December 2009). Bukit Leelau Estate. 2,096 Pekan, Pahang Merkassar Estate 1,216 Pekan Rompin,
Ladang Sabah Oil Mill (to be certified in August 2010) Luangmanis 2505 Sandakan, Sabah Terusan Baru / Mayvin 4 2118 Sandakan, Sabah Moynod. 2804 Sandakan, Sabah Laukin. 1998 Sandakan, Sabah Sg. Sapi. 1220 Sandakan, Sabah Labuk 1646 Sandakan, Sabah Bimbingan 1. 1795 Sandakan, Sabah Bimbingan 2 1735 Sandakan, Sabah
Syarimo Oil Mill, Sabah. (to be certified in June 2011). Syarimo 1 Syarimo 1 Syarimo 1 Syarimo 2 Syarimo 2 Syarimo 2 Syarimo 3 Syarimo 3 Syarimo 3 Syarimo 4 Syarimo 4 Syarimo 4 Syarimo 5 Syarimo 5 Syarimo 5 Syarimo 6 Syarimo 6 Syarimo 6 Syarimo 7 Syarimo 7 Syarimo 7 Syarimo 8 Syarimo 8 Syarimo 8 Syarimo 9 Syarimo 9 Syarimo 9 Leepang Oil Mill, Sabah (to be certified in April 2011). Permodalan 1. 2,131 Lahad Datu, Sabah Permodalan 2. 1,829 Lahad Datu, Sabah Permodalan 3. 2,437 Lahad Datu, Sabah Permodalan 4. 1,760 Lahad Datu, Sabah Leepang 1. 2,229 Lahad Datu, Sabah Leepang 5. 1,658 Lahad Datu, Sabah Morisem 5. 1,798 Lahad Datu, Sabah Morisem B Oil Mill, Sabah (to be certified March 2011). Tas 1,168 Lahad Datu, Sabah
MY01827
Surveillance 01Evaluation for RSPO MYNI Requirement for
Halusah. 760 Lahad Datu, Sabah Morisem 1 1,919 Lahad Datu, Sabah Morisem 2 1,892 Lahad Datu, Sabah Morisem 3. 1,886 Lahad Datu, Sabah Morisem 4. 1,909 Lahad Datu, Sabah Leepang 2. 2,003 Lahad Datu, Sabah Leepang 3. 1,846 Lahad Datu, Sabah Leepang 4 1,388 Lahad Datu, Sabah Rinwood Pelita, Miri (to be audited by certification unit concerned) Sejap Estate Total 5,000 ha
Planted 1,863 ha
Baram, Sarawak 100% crop sent to Boustead & Rimbunan Hijau, oil mills, which do not belongs to IOI.
Tegai Estate Total 4,040 ha Planted 1,694
ha
Baram, Sarawak 100% crop sent to Boustead & Rimbunan Hijau oil mills, which do not belongs to IOI.
Harita Group, Indonesia PT Kalimantan Prima Agro Mandiri (PT KPAM)
20,000 Kalimantan, Indonesia
PT Berkat Nabati Sejahtera (PT BNS)
13,500 Kalimantan, Indonesia
PT Sukses Karya Sawit (PT SKS)
13,500 Kalimantan, Indonesia
PT Bumi Sawit Sejahtera (PT BSS)
11,000 Kalimantan, Indonesia
PT Ketapang Sawit Lestari (PT KSL)
24,500 Kalimantan, Indonesia
Company is focusing on PT SKS (5000 hectares) and PT. BNS (5000 hectares) to complete planting by the end of 2009. Planting started in January 2009 (PT SKS) and March 2009 (PT BNS). As that of August 2009, 3310 hectares were cleared for planting in PT BNS, while in PT SKS 1913.87 hectares were cleared. Both operating units had cleared total about 5200 hectares and planted about 3300 hectares until August 2009. The rest of the land, P.T. KPAM, PTBSS, and PT KSL cultivation permits are yet to receive from the Government at the time of audit. PT SKS and PT BNS the tentative scheduled for RSPO audit around December 2012 and by then IOI will build up oil mill there in 2012 when 2009 planting gets matured.
MY01827
Surveillance 01Evaluation for RSPO MYNI Requirement for
