date: 18 dec 20 dec report 2018cciglobe.com/files/mhc_mav.pdf · executive summary organization...

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CCI-QP-07-07A 1 Assessment Report Date: 18 Dec to 20 Dec 2018 Company name MHC PLANTATION BHD Address Kompleks Pejabat Behrang 2020, Jalan Persekutuan 1, P.O. Box 9, 35900 Tanjung Malim, Perak Darul Ridzuan Report no MS18MM018 Status of audit Main Assessment If surveillance NA [Disclaimer: The audit report has been generated to reflect the compliance of the company toward the MSPO standard and every criterion’s have been in every effort MSPO 253O:2013 Part 3

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Page 1: Date: 18 Dec 20 Dec Report 2018cciglobe.com/files/MHC_MAV.pdf · Executive Summary Organization Information MHC Plantation Bhd was situated at the Hilir Perak District, Perak Darul

CCI-QP-07-07A

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Assessment

Report

Date: 18 Dec to 20 Dec

2018

Company name MHC PLANTATION BHD

Address Kompleks Pejabat Behrang 2020, Jalan Persekutuan 1, P.O. Box 9,

35900 Tanjung Malim, Perak Darul Ridzuan

Report no MS18MM018

Status of audit Main Assessment If surveillance NA

[Disclaimer: The audit report has been

generated to reflect the compliance of the

company toward the MSPO standard and

every criterion’s have been in every effort

taken to ensure the accuracy of the

assessment and reporting produced. As the

assessment is been carried out based on

sampling, certain areas or processes may not

be able to verified on its compliances. ]

MSPO 253O:2013 Part 3

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Thank you for your trustful cooperation during our audit of your organization. This report has been prepared of

every effort to ensure the accuracy of the information recorded. The assessment is based on sampling on the

records, practice, documents and personnel, therefore the final results of the assessment is of representative

towards the system implementation of the organization. This report may generated to record as much of the

system implementation information but may still limited due to the sampling .This report details the assessment

results including strengths, opportunities, and weaknesses. These results were presented to your management at

the closing meeting of the audit. You can use these results to improve the effectiveness of your management

system. We look forward to continuing our partnership towards sustainable business success. This report has been

prepared in compliance to the ISO 17021:2011 requirements.

To ensure the next assessment will be carry out in compliance to the ISO 17021:2011, please remember to

immediately notify CARE Certification International about any significant change to your company at any point of

time. Together we will then coordinate appropriate measures to maintain your current certification. Such

circumstances include, for example, changes relating to the legal, commercial, organizational status or ownership,

organization and management (e.g. key managerial, decision making or technical staff), contact address and sites,

scope of operations under the certified management system, and major changes to the management system and

processes. Together we CARE and will then ensure the smoothness of the upcoming assessment. Thank you for

your persistence of support.

Signed for on behalf of CCI Signed for on behalf of client

Sign

Name Mohamad Zulkefli Bin Md Isa Company stamp

Date 20/12/2018

Email [email protected]

Fax no 038073 2688

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Section A General Information General

Audit objectives

To verify that the system initial implementation is in accordance

to requirements of the standard adopted. To verify that the system implementation is continuously in

accordance to the requirements of the standards adopted. To verify that the system implementation is continuously after

and in third years of implementation is in accordance to the standards adopted.

Other, (please specify)

Integrate Assessment No

Issue of certificate Yes

Scope of Certification

Scope of certification in English The Provision of Planting and Harvesting of Fresh Fruit Bunch

(FFB) By Organised Plantation

Requirement not being applicable P7 - Development of New Planting

Justification The company doesn’t have any new planting activities.

Other language than above NA

Changes from Previous registration No

Extension/changes of scope date NA

Contact Details

Management Representative Mr Ganesan A/L Amiappan

Alternate contacts Logeswari Vasudevan

Management Representative contact no. +601126548519

E-mail address [email protected]

Fax Number +6054590003

Fixed Line Number +6054590001/2

NO OF SPOC/ GROUP MEMBERS 10

Section B Previous Audit Result The result of the last audit system have been reviewed, in particular to ensure appropriate correction and

corrective action has been implemented to address any nonconformities identified. This review has concluded

that:

No nonconformities have been raised during last assessment.

Any nonconformities identified during last previous audit have been corrected and the corrective action continuous

to be effective.

The management system has not adequately addressed non conformity identified during previous audit

activities and the specific issue has been re-defined in the nonconformity section of this report.

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Section C Conclusion

The audit team conducted a process based audit focusing on significant aspects/risk objectives required by

the standard(s). The audit methodology used is based on 3P which were People, Paper and Practice.

The audit team concludes and express

CONGRATULATION and has

CONGRATULATION however some processes need to address non-compliance(s) but others has

SORRY and the organization has not established and maintained its management system in line with the

requirements of the standard and

demonstrated

not demonstrated

the ability of the system to systematically achieved agreed requirements within the scope of the

organizations.

Base on the record, there is/are NIL unresolved issue.

Therefore the audit team recommends that based on the results of this audit and the system's

demonstrated state of development and maturity, management system certification be:

Granted (initial certification or recertification)

Granted upon the acceptance of the noncompliance(s)

Continued (surveillance)

Continued (surveillance) upon the acceptance of the noncompliance(s)

Withheld

suspend until satisfactory corrective action(s) is completed

Others (please specify)

Note :

The assessment and recommendation for the initial or continue was based on random samples and therefore

nonconformities may exist which have not been identified. All the pages should be attached if the organization wishes to

copy and delivered to the interested party.

Section D (For Recertification only)

1 The company has demonstrated effective implementation and maintenance/improvement on its

management system

Yes No

2 The internal audit program has been fully implemented and demonstrates its effectiveness as a

tool for maintaining and improving the management system.

Yes No

3 The management review process demonstrates its capability to ensure the continuing suitability,

adequacy and effectiveness of the management system

Yes No

3 The management review process demonstrates its capability to ensure the continuing suitability,

adequacy and effectiveness of the management system

Yes No

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4 Throughout the audit process, the management system demonstrates overall conformance with

the requirements of the audit standard

Yes No

Section E Auditor and Auditees Names

CCI Assessors

Attendance during opening and closing meeting

Team leader Name Designation

Mohamad Zulkefli Md Isa Mr. Ganesan A/L Amiappan

Mr. Kanjentheran A/L Virdhasalam

Mr. Perumal A/L Kathiah

Mr. Suppyah A/L Murugasu

Mr. Amirul Rijaluddin Bin Azmi

Mr. Ahmad Hisyamuddin Mohd Razali

Logeswary A/P Vasudevan

Sr. Plantations Manager Yew Lee

Estate

Manager Behrang Estate

Manager Batang Padang Estate &

Champion Estate

Assistan Manager Kuala Bikam Estate

Cadet Yew Lee Estate

Cadet Batang Padang Estate

Sustainability Officer

Team member

Erwan Kartika (EK)

Mohamad Hafis Mustafa (MH)

Nabila Seth (NS)

Trainee auditor

Nurdini binti Mohd Jobly

Observer

NA

Section F Audit Process Matrix

Next Audit Matrix (legend “ ” plan to cover & covered, “ ” for uncover)

Planned month & year 12/2018 11/2019 11/2020 11/2021 11/2022

Internal Audits

Stakeholder consultation / survey

Use of logo

Follow-up from previous audit finding

4.1 Management Commitment & Responsibility

4.1.1 MSPO Policy

4.1.2 Internal audit

4.1.3 Management Review

4.1.4 Continual Improvement

4.2 Transparency

4.2.1 Transparency of information and documents relevant

to MSPO requirements

4.2.2 Transparent method of communication and

consultation

4.2.3 Traceability

4.3 Compliance to legal requirements

4.3.1 Regulatory requirements

4.3.2 Land use rights

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4.3.3 Customary rights

4.4 Social responsibility, health, safety and employment condition

4.4.1 Social impact assessment (SIA)

4.4.2 Complaints and grievances

4.4.3 Commitment to contribute to local sustainable

development

4.4.4 Employees safety and health

4.4.5 Employment conditions

4.4.6 Training and competency

4.5 Environment, natural resources, biodiversity and ecosystem services

4.5.1 Environmental management plan

4.5.2 Efficiency of energy use and use of renewable energy

4.5.3 Waste management and disposal

4.5.4 Reduction of pollution and emission

4.5.5 Natural water resources

4.5.6 Status of rare, threatened, or endangered species

and high biodiversity value area

4.5.7 Zero burning practices

4.6 Best Practices

4.6.1 Site management

4.6.2 Economic and financial viability plan

4.6.3 Transparent and fair price dealing

4.6.4 Contractor

4.7 Development of new planting

4.7.1 High biodiversity value NA

4.7.2 Peat land NA

4.7.3 Social and Environmental Impact Assessment (SEIA) NA

4.7.4 Soil and topographic information NA

4.7.5 Planting on steep terrain, marginal and fragile soils NA

4.7.6 Customary land NA

Assessment man days for the next assessment : 6 md. Recertification: 2022

Note: Recertification should be carry out minimum 2 months prior to the expiry of the certificate

Section G Audit Summary Summary of Area Audited

BUSINESS AREAS DETAILS OF AUDITED SUMMARY

Auditor Date Time

ZU 18/12/2018 8.30

Opening Meeting

a) introduction of the participants, including an outline of their roles;

b) confirmation of the scope of certification;

c) confirmation of the audit plan (including type and scope of audit, objectives and criteria), any changes, and other relevant

arrangements with the client, such as the date and time for the closing meeting, interim meetings between the audit team

and the client's management;

d) confirmation of formal communication channels between the audit team and the client;

e) confirmation that the resources and facilities needed by the audit team are available;

f) confirmation of matters relating to confidentiality;

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g) confirmation of relevant work safety, emergency and security procedures for the audit team;

h) confirmation of the availability, roles and identities of any guides and observers;

i) the method of reporting, including any grading of audit findings;

j) information about the conditions under which the audit may be premature terminated;

k) confirmation that the audit team leader and audit team representing the certification body is responsible for the audit and

shall be in control of executing the audit plan including audit activities and audit trails;

l) confirmation of the status of findings of the previous review or audit, if applicable;

m) methods and procedures to be used to conduct the audit based on sampling;

n) confirmation of the language to be used during the audit;

o) confirmation that, during the audit, the client will be kept informed of audit progress and any concerns;

p) opportunity for the client to ask questions.

Closing Meeting

a) informing the client that the audit evidence collected was based on a sample of the information; thereby introducing an

element of uncertainty

b) the method and timeframe of reporting, including any grading of audit findings;

c) the certification body's process for handling nonconformities including any consequences relating to the status of the

client's certification;

d) the timeframe for the client to present a plan for correction and corrective action for any nonconformities identified during

the audit;

e) the certification body's post audit activities;

f) information about the complaint handling and appeal processes.

g) Any diverging opinion that are not resolved.

h) opportunity for the client to ask questions.

Executive Summary

Organization Information MHC Plantation Bhd was situated at the Hilir Perak District, Perak Darul Ridzuan. Currently MHC Plantation manage 10 estate as below: 1) Yew Lee Estate 2) Behrang 2020 Estate 3) Kuala Bikam Estate 4) Batang Padang Estate 5) Champion Point Estate 6) Sungai Timah Estate 7) Muzwin Estate 8) Langkap Estate 9) Hutan Melintang Estate 10) Maju Perak Estate Assessment Process This is group certification for MHC Plantation where the company hold 10 estates under their management. The determination of the sample size are as per Malaysian Sustainable Palm Oil (MSPO) Risk Management (Doc No: MPOB/MSPO/RMP/06 dated 19 Nov 2013).The audit was based on the MSPO2503:2013 Part 3 Standard, procedure and other applicable requirements. The audit was devided into 2 which is Stage 1 and Stage 2. There is no issue during the 1st Stage Audit conducted on 25-29/10/2018 and found all the required document, procedure and form are available. Stage 2 audit was held on 18-20/12/2018 where the sample size of the audit is 5 eststes. The calculation of the sample size determination are as below: S= √n (RF) S= sample size, n= number of estate, RF= Risk Factor S=√10 (1.5) = 3.16 X 1.5 = 4.7 S= 5 estates The audit are planned follow the audit plan which consist of documentation review and site visit which total days of audit is 4 days. Total mandays for audit at MHC Plantation Bhd was 8 mandays including the stakeholders consultation. List of 5 sample estates are as below: i. Behrang 2020 ii. Yew Lee Estate iii. Kuala Bikam Estate iv. Batang Padang Estate v. Champion Point Estate Audit Team The audit was lead by Mr Mohamad Zulkefli who are have almost 8 years in the sustainable certification and other management system certification such as RSPO, ISCC, ISO 14001, ISO9001 etc and also attended the MSPO Lead Assessor Course conducted by SIRIM. The Co auditor : 1. Mohamad Zulkefli bin Md Isa as Head of Auditor for Law Aspects, Biodiversity Conservation, Social Aspect, Employee Welfare, etc. 2. Co auditor is Mr Erwan Kartika who are having more than 10 year experince and certified in ISO, RSPO, MSPO

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certification system. 3. Co auditor is Mohamad Hafis Mustafa who are having experince in palm oil industry for almost 5 years and attended the MSPO certification conducted by SIRIM. 4. Co auditor is Nabila Seth binti Mohamed Niven who are attended and passes the lead assessor course for QMS by BSi in Jan 2011. She had also attended several training related to QMS e.g. ISO 17021, RSPO.

Audit Summary

Stakeholder Consultation

Stakeholder public notification was sent through email on 16/11/2018 by Care Certification International to inform and response for any non-compliance conducted by estate towards stakeholder. Noted that no response from stakeholder which define NIL non-compliance conducted by estate. During audit on 18/12/2018, Care Certification International has interviewed random stakeholder for the response toward estate. Stakeholders has been interviewed as below: Yew Lee Estate/ Kuala Bikam Estate/ Batang Padang/ Champion Point Estate 1. Mr Kwan Kwont Kunt (KML Enterprise) – Backhoe Contractor 2. Mr Sheikh Mohamad – Harvesting, manuring & spraying contractor 3. Mr Vince Tan (Transportation Enterprise) – FFB Transportation 4. Tn Ahmad Saad, Tn Mohd Faizul & Tn Nizamree – Balai Polis Chuk Chak 5. Mr Pang (Tractor Pang Enterprise) – Excavator Contractor Behrang 2020 Estate 6. Tn Arshad, Tn Azizul – Balai Polis Behrang 7. Tn Nazrul – Balai Bomba Tanjung Malim 8. Key Seng Miyn (KM Land) – Developer 9. Land Surveyor Batang Padang Estate/ Champion Point Estate 10. Mr Mohd Anheri – Representative from Kg Attan Duri Langkap/ Auxiliary Police of Batang Padang Estate. Issues discussed such: 1. Complaint - No complaint raised 2. Positive Practice by Estate - Complaint procedure, MSPO introduction been explained during stakeholder meeting at Anson Hotel. (All invited stakeholder) - Contractor’s employees who stayed inside estate housing quarter were provided with free utilities such water and electricity. (Sheikh Mohamad) - Employer has update to police once the new foreign worker been recruited. (Tn Ahmad Saad) - Estate has installed with a few phase of guard gate to ensure the security of the estate area (Tn Ahmad Saad) - Estate has comply with safety aspect by Bomba requirement such diesel storage, fire hose & etc (Tn Nazrul) - Do not received any report/complaint toward estate (Tn Arshad & Tn Ahmad Saad) - Seen various of safety signage to educate and warn the employees for the safety (Land Surveyor) 3. Idea for Improvement - To conduct fire drill annually for emergency respond training should be conducted to all estate (Tn Nazrul) - To prepare the local emergency contact number office at auxiliary post for any emergency cases respond (Tn Nazrul) - To conduct perimeter boundary inspection/patrolling regularly (Land Surveyor) - To repair the estate road regularly (Mr Key Seng) - To install spotlight/ reflector sticker at pole gate in front of Batang Padang Office for night sight. (Mr Mohd Anheri) In conclusion, the stakeholder meeting had undergone successfully with no complaint from internal and external stakeholder. Hence, as a stakeholders are well aware on the requirement of MSPO and details on MSPO such estate complaint procedure, requirement with act for contractor, agreed to be audited by MSPO auditor & etc.

Estates Information

LIST OF GROUP MEMBERS

1. ESTATE INFORMATION

NAME OF ESTATE LOCATION COORDINATE

Behrang 2020 Estate Tanjung Malim 3 o 43‘ 08.9

N 101 o 28’37.3”E

Yew Lee Estate Hilir Perak, Teluk Intan 3 o 57’55.0”

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N101 o 19’01’75”E

Kuala Bikam Estate Hilir Perak, Teluk Intan 3o 59’09.6”

N101 o 13’38.5”E

Batang Padang Estate Hilir Perak, Teluk Intan 4 o 01’32”

N101o 05’13.2”E

Champion Point Estate Hilir Perak, Teluk Intan 3 o 57’36.6”

N100 o 57’52.1”E

Sungai Timah Estate Hilir Perak, Bagan Datuk 4 o 02’39.2”

N 100 o 59’29.6”E

Muzwin Estate Hilir Perak, Bagan Datuk 3 o 48’38.5”

N101 o 06’18.1”E

Langkap Estate Hilir Perak, Bagan Datuk 3 o 48’38.5”

N101 o 06’18.1”E

Hutan Melintang Estate Hilir Perak, Bagan Datuk 3 o 50’41.9“

N101 o 07’09.2”E

Maju Perak Estate Hilir Perak, Bagan Datuk 3 o 50’41.9”

N101 o 07’09.2”E

2. AREA STATEMENT AND FFB FORECAST

ESTATE TOTAL AREA

(HA)

PLANTED

AREA (HA)

FFB TON/ YEAR

(as per year 17)

YIELD TON/

YEAR

Behrang 2020 Estate 184.42 183.43 279.60 20.58

Yew Lee Estate 344.94 341.74 309.60 16.89

Kuala Bikam Estate 399.00 390.90 292.32 17.36

Batang Padang Estate 348.89 331.40 211.92 18.58

Champion Point Estate 81.10 81.10 341.64 23.76

Sungai Timah Estate 284.30 279.20 211.92 21.30

Muzwin Estate 396.60 380.41 341.64 19.47

Langkap Estate 359.36 359.36 219.12 16.28

Hutan Melintang Estate 388.10 384.05 255.00 15.06

Maju Perak Estate 415.22 415.22 118.68 8.86

TOTAL 3201.94 3146.81 2581.44 178.14

P1: Management Commitment & Responsibility

Criterion 1 Malaysian Sustainable Palm Oil (MSPO) Policy

Indicator Requirement Findings

4.1.1.1

A policy for the implementation of MSPO shall be established

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Yew Lee Plantation Estate, Kuala Bikam, Batang Padang Estate, Champion Estate and Behrang 2020 Estate had 14 policy in Bahasa Malaysia while 10 Policy in English which cover all sustainability element. The policy been established on 29th August 2018 signed by Group Managing Director, Tan Sri Mah King Thian. The policy has been display in office wall and established as per below : i. MHC Plantatins Bhd Sustainability Policy ii. MHC Plantations Bhd Environment Policy iii. MHC Plantations Bhd Occupational, Safety & Health Policy iii.MHC Plantations Bhd Human Right Policy iii. MHC Plantations Bhd Whistleblower Policy Policy has been brief to workers and staff in the Attendance List for Policy Briefing dated 17/12/2018 4.1.1.2 The policy shall also emphasize commitment to continual improvement.

Yew Lee Plantation Estate, Kuala Bikam, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Sighted that the policies was established and had shown emphasize towards commitment for continual improvement to ensure on sustainablility

Criterion 2 Internal Audit

Indicator Requirement Findings

4.1.2.1

Internal audit shall be planned and conducted regularly to determine the strong and weak points and potential area for further improvement.

Yew Lee Estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate sighted the internal audit plan were established by lead internal auditor, Mr. K Perumal dated on 25,26 & 29/10/2018 lead by Mr Perumal and assist by Hapsah, Jessica. Verified the competency of the auditor and sighted attend the MSPO Internal Audit Training 23/10/2018 conducted by SRZ Corporate Services. Sighted inside the internal audit plan covers for all estates and mills. Verified the estates had received the audit plan Ref No: MHC MSPO Internal Audit Plan 2018v1. The notification of internal audit plan were discuss in the meeting dated on 23/10/2018 4.1.2.2 The internal audit procedures and audit results shall be documented and evaluated,

followed by the identification of strengths and root causes of nonconformities, in order to implement the necessary corrective action

Sighted that Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Internal audit Standard Operating Procedure with Document no: MHCP-SOP-09, dated on 16/07/2018. Yew Lee Estate verified that Non conformities findings will discuss after internal audit by Ms. Logeswary Vasudevan internal Audit Report sighted that NC : 6 and OFI : 2

4.1.2.3 Report shall be made available to the management for their review.

Yew Lee Estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate as follow sighted that Non Conformances follow up was done in the Management Review Meeting dated on 13/12/2018 at Meeting Room, Batang Padang Estate. Behrrang Estate Internal audit was lead by Mr Perumal, verified the Internal Audit Report dated 26/10/2018 with 24 NCR and 7 OFI been raised during the MSPO Internal Audit. Verified the Findings And Action Plan Report and found all the necessary action taken was sufficient and closed by 10/12/2018. Champion Point Estate Internal audit was lead by M. Gengatharan and verified the Internal Audit Report dated 26/10/2018 with 25 NCR and 13 OFI been raised during the MSPO Internal Audit. Verified the Findings and Action Plan Report and found all the necessary action taken was sufficient and closed by 10/12/2018. Criterion 3 Management Review

Indicator Requirement Findings

4.1.3.1 The management shall periodically review the continuous suitability, adequacy and effectiveness of the requirements for effective implementation of MSPO and decide on any changes, improvement and modification.

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Yew Lee Estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Sighted the Management Review meeting dated on 13/12/2018 and the agenda discussed were the element of internal audits covering MSPO, follow up actions from management reviews, recommendation for improvement, effectiveness of the MSPO maangement system and progress and etc.

Criterion 4 Continual improvement

Indicator Requirement Findings

4.1.4.1 The action plan for continual improvement shall be based on consideration of the main social and environmental impact and opportunities of the company.

MHC plantation SDN BHD sighted Social Impact Assesment Report dated on assessement date 13th -17th November 2018. Sighted that Yew Lee Estate in working environment/ condition Area concern, matter raised by stakeholder and remarks from management provided. There was evidence as below : Capital Expenditure Budget 2019 for Staff/workers housing repairs Sighted that Environmental Management Plan/Pollution Prevention Plan dated on 14/12/2018 and prepared by Amirul Rijaluddin 4.1.4.2 The company shall establish a system to improve practices in line with new information

and techniques or new industry standards and technology, where applicable, that are available and feasible for adoption.

Yew Lee Estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate, verified the management had establish and implement Solar System with CCTV Solar camera stated in the Quotation N&A System Enterprise dated on 3/08/2018 Sighted the company had added another new practices as plan in the CAPEX budget year 2019 below as: i. Implement Spreader (Mini) for fertilizer ii. Auto gate for main gate iii. Repair housing and store 4.1.4.3 An action plan to provide the necessary resources including training, to implement the

new techniques or new industry standard or technology (where applicable) shall be established.

OBS 1 (Champion Point Estate & Yew Lee Estate) Noted the new technology was implemented for solar power, advice management to establish the action plan including the monitoring of power usage, training etc for the solar power system.

P2: Transparency

Criterion 1 Transparency of information and documents relevant to MSPO requirements

Indicator Requirement Findings

4.2.1.1

The management shall communicate the information requested by the relevant stakeholders in the appropriate languages and forms, except those limited by commercial confidentiality or disclosure that could result in negative environmental or social outcomes.

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate has invited stakeholder by 'Borang Balas Kehadiran' and follow up with stakeholder response. As per invitation form Yew Lee Estate to Winstar Transport Enterprise and email by [email protected] Stakeholder meeting was done Anson Hotel meeting room dated on 7/9/2018 with evidence of the discussion regards MSPO with attendece list attended by internal and external stakeholder.

4.2.1.2 Management documents shall be publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes.

Sighted that Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate, the communication were divided into two category external and internal. For internal normally the interaction between employee and employer through complaint box and complaint form and display in front of the office. For external communication one way channel through email address: [email protected], Office No : 05-6261133 and H/p no : 012-5450320. Memo was diplay at Security Gate with bi lungguage.

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Criterion 2 Transparent method of communication and consultation

Indicator Requirement Findings

4.2.2.1 Procedures shall be established for consultation and communication with the relevant stakeholders

Sighted that Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate has established procedure for consultation and communication dated on 16/7/2018 This SOP has been communicated to all stakeholders during stakeholder meeting dated 7/09/2018 held at Anson Hotel, Teluk Intan. Records of complaints and grievances were implemented by Issues of stakeholder logbook for Stakeholder/supplier and Internal. 4.2.2.2 A management official shall nominated officials at the operating unit responsible for

issues related to indicator 1 (4.2.2.1)

Noted that official management representative nominated responsible for issue related to communication, stakeholder management and legal compliance officer MHC Plantation Bhd has appointed Mrs. Logeswary Vasudevan dated on 13/8/2018 4.2.2.3 List of stakeholders, records of all consultation and communication and records of action

taken in response to input from stakeholders should be properly maintained.

Sighted that Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate list of stakeholder updated and records properly maintained. Stakeholder list include contractors, stutory bodies, Neighbouring estate and supplier.

Criterion 3 Traceability

Indicator Requirement Findings

4.2.3.1 The management shall establish, implement and maintain a standard operating procedure to comply with the requirements for traceability of the relevant product(s).

Sighted that Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Procedure for traceability has been established by the management dated 10/09/2018. A clear procedure and proper guideline to trace the FFB prodoction from harvesting until deliver to the mill comply with certification under Malaysia sustainable palm oil. 4.2.3.2 The management shall conduct regular inspections on compliance with the established

traceability system

Noted that Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate daily FFB production was recoded in daily ffb log book and monthly monitored by traceability officer.

4.2.3.3 The management should identify and assign suitable employees to implement and maintain the traceability system

Sighted that Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate maintain the traceability system by appointment letter provided.M HC Plantation Bhd appointed Mr. Amirul Rijaluddin as a Traceability Officer for Yew Lee Estate dated on 11/12/2018,has been signed by Mr. A. Ganesan (Senior Plantation Manager) 4.2.3.4 Records of sales, delivery or transportation of FFB shall be maintained.

Sighted that Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate maintain and monitored traceability system allign with procedure. Yew Lee Estate FFB delivery to Anson Oil Industries Sdn Bhd was recorded via daily depatch notes management system record. The management has established inspection checklist for traceability system includes Oil palm harvesting activities, harvester, mandore/checker and driver/loader. Sample of record of tracebility as per below : i. Weightbirdge FFB depatch- Tick No. : FFB00086857, Date : 01/12/2018, Net weight :58.30 mt ii. delivery order -sample evidence of iii. FFB note despatch note - Tick No : 61471 Date : 1/12/2018 FFB Agreement between Yew Lew Holdings Sdn Bhd Anson Oil Industries Sdn Bhd dated on 1/8/2018

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P3: Compliance to legal requirements

Criterion 1 Regulatory requirements

Indicator Requirement Findings

4.3.1.1.

All operations are in compliance with the applicable local, state, national and ratified international laws and regulations

All operation in Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate provided license and comply Verified all the available license required for the Yew Lee Estate operation as below: a) Akta Lembaga Minyak Sawit Malaysia 1998, No. Lesen 501260302000 valid until 31/03/2019 b) Borang 9, Akta Syarikat 196, No. Syarikat 16736 Yew Lee Holdings Sdn Bhd c) Borang 2 Peraturan-peraturan standard-standard minimum perumahan dan kemudahan pekerja 1990, Peraturan 38(1)(a), Kelulusan No.: OK(TI) 2/200, d) Akta Bekalan Elektirk 1990, Lesen Bagi Pepasangan Persendirian, Lesen No: 2018/02389 valid unitl 25/07/2018 Verified all the available license required for the Batang Padang Estate operation as below: a) Akta Lembaga Minyak Sawit Malaysia 1998, No. Lesen 506818803000 valid until 31/03/2019 Aktiviti - Menjual dan mengalih b) Akta Lembaga Minyak Sawit Malaysia 1998, No. Lesen 506744111000 valid until 31/08/2019 Aktiviti - menghasilkan, menjual dan mengalih dan menyimpan. c) Permit Barang Kawalan Berjadual, No. Siri : A035636, Jenis Barang Kawalan Berjadual - Minyak Diesel tidak bersubsidi date on 10/4/2018 until 9/4/2019 4.3.1.2 The management shall list all laws applicable to their operations in a legal requirements

register

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Sample of List of legal requirement register available during assessment. Verified the List of Laws and registered as below: 1. Malaysian Palm Oil Board 1998 2. Occupational Safety & Health ACt, 1994 3. Environmental Quality Act 1997 4. Crop protection - Pesticide Act 1974 5. Land & Wildlife protection - Protection of wildlife Act(Am. 2006) 4.3.1.3 The legal requirements register shall be updated as and when there are any new

amendments or any new regulations coming into force.

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Verified that listed legal register with total 40 legal listed. New ammendment updated and by Ms. Logeswary Vasudevan. Last reviewed on 12/12/2018 4.3.1.3 The management should assign a person responsible to monitor compliance and to track

and update the changes in regulatory requirements.

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Noted that official management representative nominated responsible for issue related to communication, stakeholder management and legal compliance officer MHC Plantation Bhd has appointed Mrs. Logeswary Vasudevan dated on 13/8/2018 Criterion 2 Land used right

Indicator Requirement Findings

4.3.2.1

The management shall ensure that their oil palm cultivation activities do not diminish the land use rights of other users

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Verified Behrang Estate the Geran Tanah for no hak milik total of 183.43 ha a. #46476 b. #46474 c. #46475 d. HS(D) 19014 Noted that initially the land title was meant for agriculture, then converted to housing purpose. However due to the demand is slowed for Behrang 2020 township, so the 183.43 ha was plant for oil palm. Eventhough the title was changed to housing and industrial, the Pejabat Daerah Dan Tanah, Slim River dated 27/07/2011 stated the remisyen cukai tanah pertanian pertanian sehingga pindahmilik dibuat kepada pembeli/pemaju. Meaning that pejabat tanah is endorced the title to be a plantation for temperary.

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4.3.2.2 The management shall provide documents showing legal ownership or lease, history of land tenure and the actual use of the land.

Sighted and verified Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate the Land Grant as per 4.3.2.1

4.3.2.3 Legal perimeter boundary markers should be clearly demarcated and visibly maintained on the ground where practicable.

Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate boundary stone clearly available. Yew Lew Estate boundary stone located clearly as below: a) Block 2 boundary located beside Lembaga Air Perak (LAP) b) Buffer Zone boundary located at Block 3 and 4 area 4.3.2.4 Where there are, or have been, disputes, documented proof of legal acquisition of land

title and fair compensation that have been or are being made to previous owners and occupants; shall be made available and that these should have been accepted with free prior informed consent (FPIC).

There is no land dispute issue as the whole estate block is owned by Yew Lee Estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 estate. As of to-date there was no complaint on land matter.

Criterion 3 Customary rights

Indicator Requirement Findings

4.3.3.1

Where lands are encumbered by customary rights, the company shall demonstrate that these rights are understood and are not being threatened or reduced.

No customer rights land

4.3.3.2 Maps of an appropriate scale showing extent of recognized customary rights shall be made available

No customery rights land

4.3.3.3 Negotiation and FPIC shall be recorded and copies of negotiated agreements should be made available.

No cutomary rights land

P4: Social responsibility, health, safety and employment condition

Criterion 1 Social impact Assessment (SIA)

Indicator Requirement Findings

4.4.1.1

Social impacts should be identified and plans are implemented to mitigate the negative impacts and promote the positive ones

MHC plantation SDN BHD sighted Social Impact Assesment Report dated on assessement date 13th -17th November 2018 Sighted that Yew Lee Estate in working environment/ condition Area concern, matter raised by stakeholder and remarks from management provided. There was evidence shows Capital Expenditure Budget 2019 for Staff/workers repairs Sighted that Environmental Management Plan/Pollution Prevention Plan dated on 14/12/2018 and prepared by Amirul Rijaluddin MHC plantation SDN BHD sighted Social Impact Assesment Report dated on assessement date 13th -17th November 2018. Sighted that Batang Padang Estate had further Action plan for social issues and complaints. Yew Lee Estate and Behrang 2020 Estate Verified the Social Impact Assessment Report with assessment date on 13th – 17th November 2018. The SIA report content of data collections method, demography information, finding and recommendation action

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plan. Noted that the report is integrated with other operating unit (estate and mill). The SIA Report for Yew Lee Estate is including finding, issues, complaint, suggestion etc. There is several complaint pertaining to working environment and condition issue includes housing complex not well maintained - clogged drains, roof damaged etc. Seen the action will be taken by the management. Seen the positive aspect e.g. management provide house complex, annual dinner, give training, good relationship. Criterion 2 Complaints and grievances

Indicator Requirement Findings

4.4.2.1

A system for dealing with complaints and grievances shall be established and documented

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Governing procedure is Complaint & Grievances Procedures MHC-SOP-11 and applicable to the complaint related with safety, health, workers welfare, land dispute, sexual harassment etc. The complaint is recorded in the Complaint Form-05 and Complaint Log Book. All the complaint will be categorized as below: - High Impact respond < 24 days. - High Impact < 3 days - Medium < 5 days - Low impact < 14 days 4.4.2.2 The system shall be able to resolve disputes in an effective, timely and appropriate

manner that is accepted by all parties.

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Noted that there are 7 complaint received since July 2018 pertaining to the worker housing quarters due to damage and spoilt of equipment and structure. All of the complaint have been resolved and rectified accordingly with photo before and after. Behrang 2020 Noted that there are 17 complaint received since Jan 2018 pertaining to the worker housing quarters due to damage and spoilt of equipment and structure. All of the complaint have been resolved and rectified accordingly with photo before and after. There is no complaint. 4.4.2.3 A complaint form should be made available at the premises, where employees and

affected stakeholders can make a complaint.

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Observe the Complaint & Grievances Form and Complaint Box is available at the Office. Besides that for external stakeholder they can request the form from office or email/call directly to manager.

4.4.2.4 Employees and the surrounding communities should be made aware that complaints or suggestions can be made any time

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Batang Padang Estate Verified that stakeholder meeting dated on 17/10/2018 had been discuss that stakeholder be able to respond to complaints that are raised by their neighbours or stakeholders Records of complaints and grievances were implemented by Issues of stakeholder logbook for Stakeholder/supplier and Internal. For external communication one way channel through email address: [email protected], Office No : 05-6261133 and H/p no : 012-5450320. Memo was diplay at Security Gate with bi lungguage. For internal, seen the briefing to workers on how to make a complaint & grievances procedures and form as as per attendance record and memo. - Yew Lee: 04/09/2018 Besides that seen the notice and memo at the sign board estate, guard house & office if there is any complaint and grievances can be forwarded to - Yew Lee: [email protected] and tel no. 012-5450320 or 05-6261177. - Behrang 2020: Tel no 019-5569933.

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4.4.2.5 Complaints and resolutions for the last 24 months shall be documented and made available to affected stakeholders upon request.

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Noted that there are received 7 complaint for Yew Lee and 16 complaint for Behrang 2020 pertaining to the worker housing complex due to damage and spoilt of equipment and structure. All of the complaint have been resolved and rectified accordingly with photo before and after. Batang Padang Estate Governing procedure as per Dacument No : MHCP- SOP-11 dated 16/07/2018 has mention complaints will usually be resolved within 24 hours and latest in 14 days. Criterion 3 Commitment to contribute to local sustainable development

Indicator Requirement Findings

4.4.3.1 Growers should contribute to local development in consultation with the local communities.

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate are owned by the MHC Plantation Bhd and seen the CSR activities for education, religion, relief of poverty such as: - repairing the road for Lembaga Air Perak - pusat kecermelangan pendidikan orang asli Kg Kerawit - bangunan Perpustakaan Awam Teluk Intan - Rumah Orang Tua Langkap - Masjid Bandar Behrang - Kuil HIndu Behrang Sighted that MHC Plantation Bhd donated to Yayasan Orang Asli Perak Majlis Perasmian Kecermerlangan Pendidikan Irang Asli Kg. Kerawat, Simpang Pulai Dated on 29 Jun 2010 Batang Padang Estate Verified that Bank Voucher dated on 10/07/2018 from Batang Padang Estate, donation for temple festival for year 2018 Criterion 4 Employees safety and health

Indicator Requirement Findings

4.4.4.1

An occupational safety and health policy and plan shall be documented, effectively communicated and implemented

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Occupational, Safety & Health Policy policy been established on 29th August 2018 signed by Group Managing Director, Tan Sri Mah King Thian. The policy has been display in office wall. Policy briefing to workers and staff in Bahasa Malaysia and Bahasa Tamil. The policies attendence dated on 4/09/2018, 26/10/2018, 27/10/2018, 29/10/2018 and 17/12/2018.

4.4.4.2 The occupational safety and health plan shall cover the following:

a) A safety and health policy, which is communicated and implemented Policy briefing to workers and staff in Bahasa Malaysia and Bahasa Tamil. The policies attendence dated on 4/09/2018, 26/10/2018, 27/10/2018, 29/10/2018 and 17/12/2018. OSH Policy was established and approved by the Group MD, Tan Sri Mah King Thian dated 14/06/2018 Verified that estate Sustainability OSH Training Programme as an OSH plan that includes the SHE committee meeting, medical checkup, HIRADC training, annual medical surveillance, 1st Aid training. b) The risks of all operations shall be assessed and documented

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Verified the HIRARC Records and listed the HIRARC dated on 13/08/2018 for all activities in estate such as chemical & pesticide, harvesting, tractor drivers, manuring and general workers. Verified the HIRARC to have identified Estate such as activity for: a. Pesticide Spraying: - Risk: chemical exposure, skin irritation, poisoning etc. - Control: provide training, PPE, set ERT team, safety signage etc. b. Fertilizer: - Risk: body pain, injury, skin irritation etc. - Control: training, PPE, establish SOP. c. Harvester:

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- Risk: body injury, body pain, eye irritation. - Control: establish SOP, PPE, roll call, trained workers d. FFB Loader: - Risk: body injury, body pain, - Control: PPE, Training, SOP, Other process includes storing chemical, driver etc. CAR 1 (Batang Padang Estate) No evidence of risk assessment was available for nursery operation c) An awareness and training programme which includes the following requirements for employees exposed to pesticides: i) all employees involved shall be adequately trained on safe working practices; and ii) all precautions attached to products shall be properly observed and applied.

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate i) Provided SOP for training and briefing, Document No: MHCP-SOP-08, Effective date : 16/07/2018 Chemical Safety Management training material include the objective of the chemical safety. Verified that Estate Sustainability/OSHA Programme 2019, provide Training Needs Analysis for harvester,sprayer, permix, manuring and etc ii) Batang Padang Estate -Attendance list for 'Latihan Mengenai Aktiviti Meracun dated on 29/11/2018, venue at Ladang Batang Padang and trained by Mr. K. Perumal .Attached with chemical material used for sprayer. - Minute meeting for Briefing and Training Based on Work Operation (Penabur Baja)Procedure dated on 6/8/2018, conducted by Mr. Hisyamuddin. After briefing, 'Borang penilaian' given to trainee for management feedback. Governing procedure is Briefing & Training MHCP-SOP-08 Seen the following record: a. TNA for harvesting, spraying, premix, manuring, driver etc. b. Estate Sustainability/OSHA Training Programme 2018 that determine the month, training type, target group, done. c. Memo d. Photo e. Attendance record/list and signature. Verified the following training to have conducted for: Yew Lee Estate a. Chemical spillage dated 30/11/2018 by manager b. Environmental dated 30/11/2018 by Environment officer. c. Spraying & Manuring dated 6/8/2018 by cadet asst. d. Fertilizer dated 6/8/2018 by cadet asst. e. Harvester dated 7/8/2018 & 25/9/2018. Behrang 2020 Estate a. Spraying dated 12/2/2018 by Mr. Kajen & Michael b. Tractor driver dated 12/6/2018 by Mr. Kajeen. c. Harvesting dated 16/4/2018, 12/6/2018 & 27/8/2018 by Mr. Kajen. d. Safety training dated 12/6/2018 by Mr. Kajeen. e. Use of PPE dated 12/6/2018 & 27/8/2018 by Mr. Kajeen. d) The management shall provide the appropriate personal protective equipment (PPE) at the place of work to cover all potentially hazardous operations as identified in the risk assessment and control such as Hazard Identification, Risk Assessment and Risk Control (HIRARC). Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Sighted PPE issued and list of PPE to workers as per job function. PPE 'Taklimat Penggunaan PPE semasa Meracun dated on 27/11/2018 PPE Issuance record sighted Employee name, designation, type of PPE issued and etc. Yew Lee Estate The PPE is provided as per below: a. Spraying - respiratory mask, wellington rubber boots, goggles, nitrile glove, safety helmet. b. Driver - safety boots, helmet. c. Manuring - face mask, glove, goggle The Employees PPE Issuance Records is the evidence of PPE given to worker and sample taken for workers to have provided to them; Dineshkumar & Ajithkumar - sprayer - safety helmet, cotton & rubber glove, coverall, respirator, mask, goggle. Behrang 2020 Estate Seen the Safety Personal Equipments as an evidence of PPE given to workers. Behrang 2020: To standardize the form of PPE usage, Training record since Anson mill and Yew Estate are using same form.

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CAR 2 (Behrang 2020 Estate) During site visit, seen the manurer wore surgical mask during manuring activity, however, refer to CHRA #JKKPHIE 127/171-2(20)-2018/A180709 the assessor has recommend to wear the face mask type 8210 (Behrang 2020 Eestate)

e) The management shall establish Standard Operating Procedure for handling of chemicals to ensure proper and safe handling and storage in accordance to Occupational Safety Health (Classification Packaging and Labeling) Regulation 1997 and Occupational Safety Health (Use and Standard of Exposure of Chemical Hazardous to Health) Regulation 2000. Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate SOP sighted Document No: MHCP-SOP-OIP, Effective dated : 01/08/2018 USECHH Reg 2000 Verified Chemical Health Risk Assesment Report, CHRA Assesor : Lim Suet Lai daten in 5th July 2018 Kuala Bikam Estate i) Annual Medical surveillance report on Occupational Exposure to organophosphate for Gandhi Suresh checked by Dr. Lee Teik Leong Batang Padang Estate i) Annual Medical surveillance report on Occupational Exposure to organophosphate for Rizaul Islam and Mohammad Eqbal Hossain checked by Dr. Lee Teik Leong dated on 28/11/2018 Verified in CHRA report medical surveillance for organophosphate is recommended on yearly basis for Nursery (General Workers) and Fertilising and Spraying work unit. Champion Point Estate i) Occupational Exposure to organophosphate for Masdania checked by Dr. Lee Teik Leong dated on 28/11/2018 Yew Lee Estate and Behrang 2020 Estate Seen the MHC Plantations Bhd's SOP that having SOP for replanting, weeding, pruning, circle sanitation, supplying, EFB mulching, ablation, water mgt, bunds, manuring, application of organise fertilizer, harvesting etc. Seen the following record for CPL and USECHH regulation: Yew Lee Estate - Seen the Daftar Bahan Kimia Membahayakan Kesihatan dated 4/1/2018 registered 3 chemicals. - 27 Safety Data Sheet has been compiled e.g. calcium carbonate, agrobien, chaser, rockphasphate etc. - CHRA dated 6/6/2018 report no#JKKPHIE 127/171-2(20) - 2018/A180603 by CNL Consultant for assess risk to health of employees & contractor working in th eplant from exposure to chemicals hazardous to health. - PPE Issuance Record. - Warning sign/safety signage - PPE, Safety First. - Annual Medical Surveillance dated Aug 2018 for chemical handling - mixer, sprayer e.g. Manikandan P3106775, Murugavel R 0978427, Najamudin AU 154026. Done by Dr. Lee Teik Leong. Behrang 2020 Estate - Seen the Senarai Bahan Kimia Membahayakan Kesihatan dated 27/2/2013 registered 7 chemicals e.g. Krush (Glyphosate Pottassium 48.7%) and N-Hance (Metsulfuron-Methyl 20%) - 12 Safety Data Sheet has been compiled e.g. Krush and N-Hance. - CHRA dated 5/7/2018 report no#JKKPHIE 127/171-2(20) - 2018/A180709 by CNL Consultant for assess risk to health of employees & contractor working in the plant from exposure to chemicals hazardous to health. - PPE Issuance Record. - Warning sign/safety signage - PPE, Safety First. - Annual Medical Surveillance dated Aug 2018 for chemical handling - mixer, sprayer e.g. Sadrihadi pp no#80324398, Michael IC no#841107-08-6075, Kaliappan P0197522. Done by Dr. Vigneswaran. CAR 3 (Kuala Bikam Estate) During site visit at Block 3, sighted the chemical mixing activity was done in the field. f) The management shall appoint responsible person(s) for workers' safety and health. The appointed person(s) of trust must have knowledge and access to latest national regulations and collective agreements.

Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Batang padang Estate has appointed Mr. Ganesan A/L Amiappan as a 'Pengerusi Jawatankuasa Keselamatan & Kesihatan Pekerjaan dated on 18/12/2018 valid on 17/12/2020 Kuala Bikam Estate has appointed Mr. Amirul Rijaluddin as a 'Jawatankuasa Keselamatan & Kesihatan Pekerjaaan dated on 18/12/2018

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Batang Padang Estate & Champion Estate has appointed Mr. Perumal A/L Kathiah as a 'Jawatankuasa Keselamatan & Kesihatan Pekerjaaan dated on 18/12/2018 valid until 17/12/2019 Yew Lee Estate & Behrang 2020 Estate Seen the appointment letter dated 18/12/2018 to Mr. Ganesan A/L Amiappan as a Chairman of SHE for MHC Plantation Bhd that responsible person for workers safety & health. He is having vast experience in estate and plantation industry for about 30 years. g) The management shall conduct regular two-way communication with their employees where issues affecting their business such as employee's health, safety and welfare are discussed openly. Records from such meetings are kept and the concerns of the employees and any remedial actions taken are recorded. Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Verified the OSH Committee Ladang Kuala Bikam & Ladang Yew Lee conducted on 20/09/2018, chaired by Senior Plantation Manager and attendance list dated on 20/11/2018. Any Safety & Health issue raised in OSH meeting. Yew Lee Estate and Behrang 2020 Estate Verified the Safety & health Committee minute meeting and conducted regularly dated 20/11/2018, 08/08/2018 (Yew Lee) and Behrang 2020 (4/2/2018, 16/7/2018) and sighted the meetinf was discussed on the issue oef the PPE, safety signage, housekeeping, safety training, safe work etc. h) Accident and emergency procedures shall exist and instructions shall be clearly understood by all employees. Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate has establish incident and emergency reporting flow chart include Major and Minor Accident in case of emergancy signed by Senior Plantation Manager. All the accident and emergency procedures exist and explained to the workers during the training. Yew Lee Estate Verified that ' Spillage and environment meeting' conducted by Ms. Komalahshini & Mr. Ganesan dated on 30/11/2018 attended by workers and staff adjourned at 3p.m Kuala Bikam Estate Fire Drill Briefing for Fire Extinguisher conducted by Ms. Gayathri Supayyah dated on 15/11/2018 attended by workers. Batang Padang Estate and Champion Estate Verified that ' Latihan menggunakan pemadam api' conducted by Mr. Hisyamuddin dated on 1/12/2018 attended by workers Yew Lee Estate and Behrang 2020 Estate Governing procedure is Incident Reporting Flowchart and Emergency Response Plan. According to Mr. Kajen from Behrang 2020, the BOMBA Tanjung Malim is agreed to join the Fire & Evacuation Drill on Jan 2019 and this drill will be participated by all estate. i) Employees trained in First Aid should be present at all field operations. A First Aid Kit equipped with approved contents should be available at each worksite Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate has verified that First aid training conducted on 15/10/2018 at Anson Hotel involved Field Supervisors trained by Mr. Jeffrey Aziz. Training Material for First Aid Training provided and has been kept in the Training Record File Kuala Bikam Estate First aider Ms. Gayathr A/P conducted training to all workers dated on 26/10/2018 First Aid Kit available in Estate Office and Estate Operation. Batang Padang & Champion Estate First aider Mr. Perumal A/L Kathiah conducted training to all workers dated on 1/12/2018 First Aid Kit available in Estate Office, Workshop, linesite and operation area. Yew Lee Estate and Behrang 2020 Estate First Aid training conducted for a. Yew Lee workers on 08/12/2018 by cadet Amirul. b. Yew Lee and Behrang 2020 staffs on 15/10/2018 and 16/10/2018 by SRZ Consultant. c. Behrang 2020 workers on 24/10/2018 by Hospital Tanjung Malim officer. 1st Aid kit is available in office and field area. j) Records shall be kept of all accidents and be reviewed periodically at quarterly intervals.

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Yew Lee estate, Kuala Bikam Estate, Batang Padang Estate, Champion Estate and Behrang 2020 Estate Noted management was recorded all the accident and will be reviewed during the OSH Committee meeting quarterly. Batang Padang Estate Verified that ' Minit Mesyuarat JKKP' dated on 14/02/2018 at Batang Padang Estate Yew Lee Estate Governing procedure is Incident Reporting Flowchart Noted there are 3 cases of accident for 2018 as follow: a. Kannan Ganesan dated 06/07/2018 – debris insert to eye – NIL MC. b. Sardin dated 04/10/2018 – angle wounded due to hit by branch - 11 days MC. c. Sivandi dated 6/10/2018 - finger injury due to grinder - 31 days MC. The form of JKKP 7 & 8 were recorded for above case. Behrang 2020 Estate There is no accident happen for 2018 year. Criterion 5 Employment conditions

Indicator Requirement Findings

4.4.5.1 The management shall establish policy on good social practices regarding human rights in respect of industrial harmony. The policy shall be signed by the top management and effectively communicated to the employees

Yew Lee Estate, Kuala Bikam Estate, Batang Padang Estate,Behrang 2020 and Champion Estate Sighted management establish the Human Rights Policy dated 18/01/2018 and approved by Managing Director, Tan Sri Mah King Thian, observe the content of the policy are include: a) committed to treating people with dignity and respect in the workplace b) committed to protection of human rights c) not threaten or diminish, directly or indirectly, the resources of tenure rights of indigenous people d) not support of illegal, abusive, enforced or child labor e) Respect freedom of association and the right to collectively bargain, enabling employee to join a union and voluntary negotiate. Communication of the policy sighted done by display at the notice board, briefing on policy to the stakeholder during the stakeholder meeting. 4.4.5.2 The management shall not engage in or support discriminatory practices and shall provide

equal opportunity and treatment regardless of race, colour, sex, religion, political opinion, nationality, social origin or any other distinguishing characteristics.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Refer to Human Right policy and mentioned no discrimination on race, gender, nationality or physically disability. The company seek to maintain a workplace free from discrimination. Refer to MSPO policy and mentioned no discrimination on race, gender, nationality, religion and political view. The company seek to maintain a workplace free from discrimination. 4.4.5.3 Management shall ensure that employees’ pay and conditions meet legal or industry

minimum standards and as per agreed Collective Agreements. The living wage should be sufficient to meet basic needs and provide some discretionary income based on minimum wage.

Sungai Bikam Estate Verified the records of Month end payslip as at Sept 2018 1. (KBE83) Sheikh Ferdous – Salary for Oct 2018 = RM1,269.14 2. (KBE5) Palani Sabarinath - Salary for Oct 2018 = RM1,63.70 3. Kannappa Pachappa - Salary for Sep 2018 = RM1,156.17 Sighted the contract agreement for: - 1. Sheikh Ferdous – date joint 7/5/2018 2. Palani Sabarinath - date joint 30/1/2014 3. Kannappa Pachappa– date joint 10/07/2018 Verified the records of payment to workers; 1. Moula – Emp. No: 1174 – Salary for Oct 2018 = RM 1,648.55 2. Norfariddah – Emp. No: 1263 – Salary for Oct 2018 = RM1,381.15 3. Mohamad Shahrin – Emp. No: 1279 – Salary for Oct 2018 = RM1,943.30 Sighted the contract agreement for:- 1. Nor Fardidah Binti A. hamid 2. Moula Datu Mohamad 3. Mohd Shahrin Saharudin All the agreement is under MAPA/NUPW and employment ordinance 1965. Sighted the ‘Perintah Gaji Minimum’ – RM38.46/day. Yew Lee Estate Verified pay slip for month of October for the workers as below: a) Malairaj Jeya Chandran

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Rate: RM38.46 Working day: 29 days X RM38.46 = RM1115.34, Pub. Holiday: RM38.46, OT(1.5) = RM331.66 Total paid = RM1535.46 Verified the Checkroll Book found Malairaj working on Sunday 4 days, found the working days not calculate as double pay. b) Rajendran Manikandan- Payslip for Sep 2018 Basic Rate: RM38.46 Working day: 27 days X RM38.46 = RM1038.42, Pub. Holiday: 3 days (RM115.38), OT (1.5)= RM439.81, Petrol Allowance= RM112.50 Total paid= RM1706.11 CAR 4 (Yew Lee Estate, Batang Padang Estate, Kuala Bikam Estate) i) Verified the Checkroll Book found Malairaj working on Sunday 4 days on November 2018, found the working days not calculate as double pay (Yew Lee Estate) ii) To attach extension of the contract agreement for workers with expiry contract agreement, Hamkadidi (Batang Padang Estate) & palani sabarinath (Kuala Bikam Estate) iii) Refer to checkroll for month November 2018, estate has deducted the monthly salary to harvester (Hamkadidi) because harvest the unripe bunches with total RM300 were deducted. (Rate deduction = rm10/1bunch) which were violated the Employment Act 1955, section 24. (1) (Batang Padang Estate) 4.4.5.4 Management should ensure employees of contractors are paid based on legal or industry

minimum standards according to the employment contract agreed between the contractor and his employee

i. Contractor Agreement between Kuala Bikam Estate and Asnah Binti Abu Asan for Harvesting Contract Agreement with Kuala Bikam Estate dated on 1/01/2018 to 31/12/12018 ii. Contract Agreement between Kuala Bikam Estate and Perniagaan Traktor Pang Enterprise dated on 12/11/2018 iii. FFB Agreement between Kuala Bikam Estate and Anson Oil Industries Sdn Bhd 1/08/2018 to 31/7/2019 attached with schedule 1 - Method of calculating FFB net prices iv. Transportation agreement between Kuala Bikam Estate and Winstar Transport Enterprise dated on 11/01/2018 to 31/12/2018 Batang Padang Noted Labour Registration record card for harvester - Hamkadidi, Passport-A3143484, Sex-Male, DOB-31/12/1985, DOJ-11/12/12. Kontrak Kerja made on 11/12/2012, sighted the validation period was 2year. The wage rate for harvesting divide - Field 1,4,9 - RM33/mt & Field 8 - RM35/mt The benefit such medical been offered free of charge for treatment at panel doctor, travelling fee after expiration of 2 year services, transporation to working area, housing with free utilities (water & electricity). Noted the Checkroll for month November 2018 for harvester: Field 1 : 53.99mt x rm33 = RM1781.67 Field 4 : 11.56mt x rm33 = RM381.48 Field 8 : 45.83mt x rm35 = RM1604.05 Total month = rm3767.20 Deduction = RM300 (compound due to harvest unripe bunches) Checkroll analysis for month Novmeber 2018 total amount paid - rm 3467.20 Payslip dated 05/12/2018 Gross payment - rm3467.20 Deduction (Advance) - rm400 nett payment - rm3067.20 Yew Lee Estate Verified the pay slip for month of Sept 2018 for harvesting contractor Asanah Kasi Enterprise as below: a) Shahad= RM68.10 X 25 = RM1,702.58 b) Siddik = RM68.10 X 25 = RM1,702.50 Found the contractor employee payment are paid based on legal minimum standard. OBS 2 (Kuala Bikam Estate) To include signed contract Agreement with date 4.4.5.5 The management shall establish records that provide an accurate account of all

employees (including seasonal workers and subcontracted workers on the premises). The records should contain full names, gender, date of birth, date of entry, a job description, wage and the period of employment.

All employee record are as per Labour registration record card Daftar Pekerja- Peraturan-Peraturan Kerja 1957 and verified the record for Sheikh Ferdous, Palani Sabarinath and Kannappa Pachappa Behrang 2020 Estate Checkroll logbook, Verified the list of the employee data from local & foreign workers particular record book dated November 2018.

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Yew Lee Estate Sighted the data contain name, gender, status, date of birth, date of entry, designation, etc. All employee record are as per Labour Registration Record Card and the record content of name, gender, DOB, date entry etc and verified the record for below employee: a) Marikandan Rejendran, Passport# P3106775, Date join: 16/04/2017 b) Saravanakumar Suvananti, Passport#M2662072, Date join: 24/04/2015 c) Mohd Norizal Mat Mahayudin, NRIC#801110-08-6125, Date join: 25/05/2018 OBS 3 (Kuala Bikam Estate) To provide employee master list that records full name, gender, date of birth and etc 4.4.5.6 All employees shall be provided with fair contracts that have been signed by both

employee and employer. A copy of employment contract is available for each and every employee indicated in the employment records

Kuala Bikam Estate Verified contracts with employee for below employees: i. Sheikh Ferdous – date joint 7/5/2018 ii. Palani Sabarinath - date joint 30/1/2014 iii. Kannappa Pachappa– date joint 10/07/2018 Sighted the agreement content are as per Akta Pekerjaan 1955 with wages rate, working time, annual leave, sick leave, public holiday etc. Behrang 2020 Estate Contract agreement dated 05/02/2018 for Aman passport:A2549258, with total daily RM38.46 (8hour) & RM33/MT as per listed price rate for harvesting. Noted the contract for 2 year from date of joined. Working hour Monday - Saturday (6.30 - 2.30pm) The agreement been signed by both parties, employees & employer. Yew Lee Estate Verified contracts with employee for below employees: a) Sankar Murugavel, agreement dated on 24/06/2015 b) Marikandan Rajendran, agreement dated 16/04/2017 c) Saravanakumar Sivanandi, agreement dated 24/04/2015. Sighted the agreement content are as per Employee Act 1955 with wages rate, working time, annual leave, sick leave, public holiday etc. 4.4.5.7 The management shall establish a time recording system that makes working hours and

overtime transparent for both employees and employer.

Time records of employee is based on the check roll book Kuala Bikam Estate (manual). Salary calculation by software system Verified the salary calculation as per 4.4.5.3 and found accurate with the system calculation. Behrang Estate Piece rate for Harvester (Aman), noted the total weigh for November 2018 was 108.23MT. The tonage divide by two (1 team : Aman & Zakiudin). Noted the Payslip for month November 2018 was 54.11mt x 33 = RM1785.63. Yee Lew Estate Observe the Yew Lee Estate establish the time recording system as per Check Roll Book and verified the time recording for month of October, November and December 2018. 4.4.5.8 The working hours and breaks of each individual employee as indicated in the time

records shall comply with legal regulations and collective agreements. Overtime shall be mutually agreed and shall always be compensated at the rate applicable and shall meet the applicable legal requirement

Kuala Bikam Estate Verified the check roll book - 2018. Verified the OT record, Public Holiday for employee. All the payment is follow the legal regulations and collective agreements. Behrang 2020 Estate Verified the check roll book October 2018. Verified the OT record for employee. All the payment is follow the legal regulations and collective agreements. Yew Lee Estate Noted the working hours and breaks for the Yew Lee Estate as per below: TIme in : 6.30am Break: 11.00 - 11.30am Time out: 2.30pm

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4.4.5.9 Wages and overtime payment documented on the pay slips shall be in line with legal regulations and collective agreements

Kuala Bikam Estate Verified the pay slip and check roll book, working time records and found the calculation is sufficient as per legal regulation. Verified the pay slip and OT calculation as per 4.4.5.4

4.4.5.10 Other forms of social benefits should be offered by the employer to employees, their families or the community such as incentives for good work performance, bonus payment, professional development, medical care and health provisions

Kuala Bikam Estate Refer to employment contract as below: Section 3 : Contract Agreement Period Section 6 : Medical benefit to the employee is eligible for medical treatment/sick pay as per labour law act 1955 Section 8 : Acommodation - provide free house with water and electricity Behrang Refer to employment contract as below: Section 5: Hostel provided free by employer. Section 12: Employer will provide the healthcare facility and provide medical benefit to the employee Section 11: Foreign Workers Compensation Scheme Policy provided by the Employer Deceased in the event of any employee dies in the cause of his employment To attach extension of the contract agreement for workers Refer to agreement and interview employee noted Yew Lee Estate offered other benefits and incentives as below: a) Petrol allowance b) Medical benefits- panel clinik Klinik KM Bala c) yearly bonus d) workers housing e) Free electricity and water supply. 4.4.5.11 In cases where on-site living quarters are provided, these quarters shall be habitable and

have basic amenities and facilities in compliance with the Workers' Minimum Standards Housing and Amenities Act 1990 (Act 446) or any other applicable legislation.

Kuala Bikam Estate Site visit at the worker’s quarters and found all the basic amenities and facilities was provided sufficiently such as electricity and fresh water. Noted the employee quarters for mill and estate are located in same area. Batang Padang Estate Weekly inspection conducted on 12/05/2018, 20/11/2018, 13/11/2018 & etc. Verified with auditee, the inspection on cleanliness, drain perimeter, toilet & etc. Noted in the record, all item check were in good condition Champion Point Refer to the Borang 2: Peraturan Standard-Standard Minimum Perumahan Dan Kemudahan Pekerja 1990, Peraturan 38(1)(a) stated the building/ housing plan drawing (Ruj.PK(TI)2/2000 was approved on 05/05/2000 by Pengarah Tenaga Kerja Negeri Perak. Site visit to the line site sighted the cleanliness of the housing area was maintain and and every house was occupied with the ration 1 room for 2 employee. OBS 4 (Champion Estate) Weekly inspection not yet conducted as the housing were completed built in August 2018. 4.4.5.12 The management shall establish a policy and provide guidelines to prevent all forms of

sexual harassment and violence at the workplace

Yee Lew Estate, Kuala Bikam Estate, Behrang Estate, Batang Padang Estate, Champion Estate Establish the Grievence and redress procedure for sexual harassment in the workpalce dated 14th June 2018 signed by Group Managing Director, Tan Sri Mah King Thian Sighted estate establish the flow chart for action to be taken, to prevent all form of sexual harassment and violence at workplace. Sighted management establish the Human Rights Policy dated 18/01/2018 and approved by Managing Director, Tan Sri Mah King Thian, observe the content of the policy are include: a) respect freedom of association and the right to collectively bargain, enabling employee to join a union and voluntary negotiate

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4.4.5.13 The management shall respect the right of all employees to form or join trade union and allow workers own representative(s) to facilitate collective bargaining in accordance with applicable laws and regulations. Employees shall be given the freedom to join a trade union relevant to the industry or to organize themselves for collective bargaining. Employees shall have the right to organize and negotiate their work conditions. Employees exercising this right should not be discriminated against or suffer repercussions.

MHC Plantations Bhd Whistleblower Policy 29th August 2018 This estate doesn’t have union society. Sighted management establish the Human Rights Policy dated 18/01/2018 and approved by Managing Director, Tan Sri Mah King Thian, observe the content of the policy are include: a) Respect freedom of association and the right to collectively bargain, enabling employee to join a union and voluntary negotiate. 4.4.5.14 Children and young persons shall not be employed or exploited. The minimum age shall

comply with local, state and national legislation. Work by children and young persons is acceptable on family farms, under adult supervision, and when not interfering with their education. They shall not be exposed to hazardous working conditions.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Kuala Bikam Estate Verified the employee name list, the is no underage worker. The youngest employee age is above 18 years old

Criterion 6 Training and competency

Indicator Requirement Findings

4.4.6.1 All employees, contractors and relevant smallholders are appropriately trained. A training programme (appropriate to the scale of the organization) that includes regular assessment of training needs and documentation, including records of training shall be kept.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Provided SOP for training and briefing, Document No: MHCP-SOP-08, Effective date : 16/07/2018 Chemical Safety Management training material include the objective of the chemical safety ii)Estate Sustainability/OSHA Programme 2019, provide Training Needs Analysis for harvester,sprayer, permix, manuring and etc. Training for tractor driver dated on 6/8/2018 by Mr. Amirul Rijaluddin Training for harvester & FFB loader (contractor) dated on 25/09/2018 by Mr. Ganesan (Senior Plantation Manager) Latihan Keselamatan & Kesihatan Pekerjaan for sprayer dated on 8/05/2018 by Mr. A. Ganesan . Verified Estate Sustainability/ OSHA Training Programme 2018 and listed training such as SOP Training, First Aid Training, and Scheduled Waste Management etc. Verified the training record and sample as below: a) Oil spillage training dated 30/11/2018 attended by Logeswaran, Din, Muhamad Amirul etc b) Latihan Alam Sekitar dated 30/11/2018 attended Logeswaran, Muhamad Amirul etc. c) Training for manuring and spraying dated 06/08/2018 attended by all sprayer and harvester. 4.4.6.2 Training needs of individual employees shall be identified prior to the planning and

implementation of the training programmes in order to provide the specific skill and competency required to all employees based on their job description.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Estate Sustainability/OSHA Programme 2019, provide Training Needs Analysis for harvester,sprayer, permix, manuring and etc Training for tractor driver dated on 6/8/2018 by Mr. Amirul Rijaluddin Training for harvester & FFB loader dated on 25/09/2018 by Mr. Ganesan (Senior Plantation Manager) Latihan Keselamatan & Kesihatan Pekerjaan for sprayer dated on 8/05/2018 by Mr. A. Ganesan Verified the Training Need Analysis for year 2018 and sighted the need of training related to safety, management, environmental for target group of harvester, sprayer, manuring operator, tractor driver etc.

4.4.6.3 A continuous training programme should be planned and implemented to ensure that all employees are well trained in their job function and responsibility, in accordance to the documented training procedure.

Provided SOP for training and briefing, Document No: MHCP-SOP-08, Effective date : 16/07/2018 Chemical Safety Management training material include the objective of the chemical safety ii)Estate Sustainability/OSHA Programme 2019, provide Training Needs Analysis for harvester,sprayer, permix, manuring and etc Training for tractor driver dated on 6/8/2018 by Mr. Amirul Rijaluddin Training for harvester & FFB loader dated on 25/09/2018 by Mr. Ganesan (Senior Plantation Manager) Latihan Keselamatan & Kesihatan Pekerjaan for sprayer dated on 8/05/2018 by Mr. A. Ganesan

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Yew Lee Estate establish the SOP: Briefing And Training (Doc#MHCP-SOP-08) dated 16/07/2018 and verified the training program and training record as per 4.4.6.1

P5 Environment, natural resources, biodiversity and ecosystem services

Criterion 1 Environmental management plan

Indicator Requirement Findings

4.5.1.1 An environmental policy and management plan in compliance with the relevant country and state environmental laws shall be developed, effectively communicated and implemented.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Sighted the policies related environmental signed by Tan Sri Mah King Thian (Group Managing Director) dated 14/06/2018, the policies such: 1. Environment and Biodiversity Policy / Polisi Alam Sekitar dan Biodiversiti Summary detail - Conducting IPM techniques, promoting the conservation and development of biodiversity, comply with HCS, HCV, peat soil, protected area & law, continuous improvement & etc. 2. MHC Plantations BHD Environmental Policy / Dasar Alam Sekitar MHC Plantation BHD Summary detail - Comliance with legal, educate employees, reduce, recycle the waste, reduce the hazardous release, communicate and distribute the policy to stakeholder, execute efficiency of energy and water where practicable in form of economic and operation, continual improvement. Noted the attandance list for policy briefing conducted on 17/12/2018 to employees by Manager. 4.5.1.2 The environmental management plan shall cover the following:

a) An environmental policy and objectives. b) The aspects and impacts analysis of all operations

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Verified the Environmental Aspect Impact Assessment And Evaluation for Year 2019 and sighted assessment done to all activity such as weeding, manuring, spraying, P&D control, housing and compund etc. Sample as below: a) Process: P& D Control Activity: Spraying, Impact Evaluation= used of material: Score= 220, discharge to air: Score= 260, Discharge to land: Score= 260 b) Process: Harvesting & collecting Activity: Harvesting FFB, Impact Evaluation= use of material: Score= 220, Discharge to land: Score= 220 OBS 5 (Yew Lee Estate) Refer to MHC Plantation BHD Policy, the objective such execute efficiency of energy where practicable in form of economic and operation were not stated in any environmental plan.

4.5.1.3 An environmental improvement plan to mitigate the negative impacts and to promote the positive ones, shall be developed, effectively implemented and monitored.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Noted environmental management plan/ pollution prevention plan dated 14/12/2018. The plan has identified all 8 objectives with the mitigating measure for each objectives. Champion Point Noted environmental management plan/ pollution prevention plan dated 14/12/2018. The plan has identified all 11 objectives with the mitigating measure for each objectives. Kuala Bikam Estate Verified the Environment Management Plan dated 11/12/2018 and sighted the plan for objectives as below: a) reduce any run-off pesticide to land Mitigate measure: recollect the surplus water at chemical mixing area b) reduce the released exhaust emmission to air Mitigate measure: scheduled maintenance for all vehicle 4.5.1.4 A programme to promote the positive impacts should be included in the continual

improvement plan

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Noted environmental management plan/ pollution prevention plan dated 14/12/2018. The training/program been included in mitigation measures for the continual improvement plan. Kuala Bikam Estate Noted the all element in the EMP will promote the positive impact and element in the Pollution Prevention

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Plan (PPP) will promote the negative impact

4.5.1.5 An awareness and training programme shall be established and implemented to ensure that all employees understand the policy and objectives of the environmental management and improvement plans and are working towards achieving the objectives.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Noted the envrionment Training Matrix (Plan) foer year 2018. Programme planned such environmental committee meeting, environmental awareness training, waste management training, housekeeping training & oil spillage training. Champion Point Estate Noted the record of Domestic waste management training on 02/12/2018 OFI To update the programme conducted into the training matrix form. Kuala Bikam Estate Refer to the Environment Training Matrix for year 2018 and sighted management plan the training for Environmental Awareness Training, Waste Management Training, Oil Spillage Training etc. 4.5.1.6 Management shall organize regular meetings with employees where their concerns about

environmental quality are discussed

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Noted the meeting dicuss on environmental concern in OSHC meeting on 08/08/2018 attended by management and employees representative. Item discuss on the scheduling the cleanlines of housing area. OFI To include other agenda of environmental such scheduled waste invnetory/status, zero burning monitoring, other current status of environmental management plan. Champion Point Estate Noted MRM on 13/12/2018 discuss on environmental improvement plan on management of scheduled waste. Noted Kuala Bikam Estate already organize meeting regard the environental issue together with the MRM on 13/12/2018 and 30/11/2018 Criterion 2 Efficiency of energy use and use of renewable energy

Indicator Requirement Findings

4.5.2.1 Consumption of non-renewable energy shall be optimized and closely monitored by establishing baseline values and trends shall be observed within an appropriate timeframe. There should be a plan to assess the usage of non-renewable energy including fossil fuel, electricity and energy efficiency in the operations over the base period.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Estate monitored the Diesel usage for year 2018 & 2017 by monthly basis. The quantity diesel/MT: Nov - 2.06 Oct - 1.21 Sept - 0.28 Aug - 0.91 & etc The quantity electricity kWh: Nov - 1810 Oct - 1768 Sept - 1768 Aug - 1950 Champion Point Estate Quantity diesel/FFB/Month: Oct - 0.3 Sept - 0.3 Aug - 0.34 July - 0.8 Yew Lee Estate and Champion Point OFI: To develop the diesel record into the graph for clear trend montoring.

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4.5.2.2 The oil palm premises shall estimate the direct usage of nonrenewable energy for their operations, including fossil fuel, and electricity to determine energy efficiency of their operations. This shall include fuel use by contractors, including all transport and machinery operations.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Noted the company has remarks the average of diesel usage from previous year which was 1.01 liter/month for diesel and average of electircity usage from previous year which was 1786kWh/month. OBS 6 (Champion Estate) Average for estimation for diesel not yet identified. 4.5.2.3 The use of renewable energy should be applied where possible

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Verified the estate has apply the solar energy for the light at gate and office. Champion Point Estate Estate fully utalize solar energy for electricity supply at housing area, no office in the estate. Only 1block with 2 unit of house. Criterion 3 Waste management and disposal Indicator Requirement Findings 4.5.3.1 All waste products and sources of pollution shall be identified and documented.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate All waste type in the "Waste Management Plan" such Scheduled waste, domestic waste, industrial waste. The SW generated as per List Of Waste Produced By Yew Lee Estate and listed the SW such as SW 110, SW 409, SW 410, SW 408, and domestic waste such as rubbish, Industrial waste such as scrap metal, tyre & etc. Kuala Bikam Estate Verified in the Waste Management Plan dated 01/09/2018 and sighted identified waste as below a) Scheduled waste- SW408 (contaminated soil, debris with mineral oil), SW410 (Rages, plastic, papers contaminated with scheduled waste), Sw409 (Disposed containers, bags contaminated with chemicals) b) Domestic waste- rubbish and sewage c) Industrial waste- recycled plastics from triple rinsed pesticide container 4.5.3.2 A waste management plan to avoid or reduce pollution shall be developed and

implemented. The waste management plan should include measures for: a) Identifying and monitoring sources of waste and pollution. b) Improving the efficiency of resource utilization and recycling of potential wastes as nutrients or converting them into value-added by-products.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Sighted in Waste Management Plan for Yew Lee Estate has identified for Scheduled waste, Domestic waste, Industrial waste. The sample as below: a. Type: Scheduled waste SW code/description - i) SW408 Contaminated soil, debris or matter resulting from clean-up of a spill, ii) SW410 Rags, plastics, papers or filter contaminted with sw, iii) SW110 Electronic waste, iv) SW409 Disposed containers, bags or equipment contaminate with chemical Location: Scheduled waste store Action to be taken - Collect & record, store all the SW into the SW store, Label the SW, dispose through license contractor, Triple rinse for SW409 only. PIC - Amirul b. Type: Domestic waste Decription - Rubbish & sewage Action to be taken - Collect, recycling, monitor by weekly inspection PIC - Manikandan c. Industrial waste Behrang 2020 Estate, Kuala Bikam Estate Refer to the Waste Management Plan 2018 sighted management monitored the waste with below action taken: a) Schedule waste- collect & records, stored and disposed to the licensed container b) Domestic waste- collect from line site and send to landfill at Block 6 every Tuesday and Friday c) Industrial Waste- Disposed item to the licensed contractor. Verified the SW Management as below: a) Inventory SW409- empty container with to date balance is 22.

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b) Noted KBE will follow the SW Management as per legal as per KBE- Rosk Based Audit for Scheduled Waste with planned by Jan 2019 to: i) Register ESWISS to DOE and start inventory record ii) put standard SW storage signage 4.5.3.3 The management shall establish Standard Operating Procedure for handling of used

chemicals that are classified under Environment Quality Regulations (Scheduled Waste) 2005, Environmental Quality Act, 1974 to ensure proper and safe handling, storage and disposal.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Sighted Procedure of "Schedule Waste Management". The procedure has mention on the handling, storage, labelling & etc. Yew Lee Estate Noted logbook inventory updated monthly basis. Empty chemical container inventory: Nov - generated 2, todate 80 Oct - generated 3, todate 78 Sept - generated 3, todate 75 Aug - generated 2, todate 72 & etc. Behrang 2020 Estate Noted logbook inventory updated monthly basis. SW110 Electronic waste 13/12 - generated 2, todate 10 07/12 - generated 2, todate 8 22/11 - generated 2, todate 6 & etc. Sighted during site visit, the scheduled waste store were properly label with "scheduled waste store" and "danger" sign. The site inventory updated by supervisor. Batang Padang Estate Inventory for empty chemical container/disposal record available for year 2018 Nov - generated 0, todate 26 Oct - generated 0, todate 26 Sept - generated 0, todate 26 Aug - generated 5, todate 26 Champion Point Estate Inventory for emtpy chemical container/disposal record available for year 2018 Nov - generated 0, todate 12 Oct - generated 3, todate 12 Sept - generated 0, todate 9 Noted for the Scheduled Waste Management, Kuala Bikam Estate will follow as per Guidelines For Packaging, Labelling And Storage Of Scheduled Wastes In Malaysia OBS 7 (All Estates) To register in eswis 4.5.3.4 Empty pesticide containers shall be punctured and disposed in an environmentally and

socially responsible way, such that there is no risk of contamination of water sources or to human health. The disposal instructions on manufacturer’s labels should be adhered to. Reference should be made to the national programme on recycling of used HDPE pesticide containers.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Site visit to the SW Store in sighted all the empty pesticide container was punctured and done the triple rinsing Verified during site visit, the empty chemical container were punctured once after triple rinse. Verified in the waste management plan, there was planned for recycling programme. Behrang Estate Verified at site visit, all empty chemical container being used for premix of chemical. label of "skull" sprayed on the container. OBS 8 (Kuala Bikam Estate) Noted Kuala Bikam Estate practice the triple rinsing and advise management to establish the SOP for triple rinsing

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4.5.3.5 Domestic waste should be disposed as such to minimize the risk of contamination of the environment and watercourses.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Yew Lee Estate Domestic waste dispose on every 2 days to dumping into landfill at block 01. Noted the Domestic waste collection schedule available. Behrang 2020 Estate Verified during site visit, there 3 block with 5 unit of worker housing. Seen the individual rubbish bin available and the domestic waste will be collected by local authorities (Majlis Daerah Tanjung Malim), 3 times a week. Champion Point Estate Domestic waste will be taken and dispose on every 2 days to dumping into landfill field 01. Noted the Domestic waste collection schedule available. Site visit to the land fill at Block 6 and sighted all the domestic waste was disposed at the land fill. The collection of the domestic waste was done twice a week Criterion 4 Reduction of pollution and emission

Indicator Requirement Findings

4.5..4.1 An assessment of all polluting activities shall be conducted, including greenhouse gas emissions, scheduled wastes, solid wastes and effluent

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Yew Lee Estate Aspect impact assessment conducted for all polluting activities including scheduled waste, tractor transporatation, domestic waste & etc, Evaluation score with 280 - 500 : will required for further action. The sample as below: Process - Scheduled waste store Activity - Receiving storage and disposal Env. Aspect - Spillage Env. Load item - Lubricant/chemical Legislation - EQA 1974 Evaluation - 190 Process - Harvesting & Collecting Activity - FFB recording Env. Aspect - Use of vehicle Env. Load item - Motorcycle Legislation - NIL Evaluation - 360 Noted, the emission of smoke been included in the environmental management plan, and been indentified for the mitigation measure. Champion Point Estate Aspect impact assessment conducted for all polluting activities including scheduled waste, tractor transporatation, domestic waste & etc, Evaluation score with 280 - 500 : will required for further action. The sample as below: Process - Office Activity - Office Operation Env. Aspect - Waste Disposal Env. Load item - Rubbih/ Ink Catridge Legislation - EQ (SW) Reg 2005 Evaluation - 250 Process - FFB Transportation Activity - Lorry/ Tractor inspection for product safety Env. Aspect - Relase to air Env. Load item - Exhaust smoke Legislation - EQ (Control of Emission from diesel engine) (Amendement) Reg 200 Evaluation - 360 Noted, the emission of smoke been included in the environmental management plan, and been indentified for the mitigation measure.

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4.5.4.2 An action plan to reduce identified significant pollutants and emissions shall be established and implemented

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate As per environmental management plan/ pollution prevention plan.

Criterion 5 Natural water resources

Indicator Requirement Findings

4.5.5.1 The management shall establish a water management plan to maintain the quality and availability of natural water resources (surface and ground water). The water management plan may include:

a) Assessment of water usage and sources of supply.

Yew Lee Estate Estate received treated water from Anson Palm Oil Mill, monthly record received been recorded by mill to issues payment invoice every month. Behrang 2020 Estate Estate used bore well water for water supply at housing area. Champion Point Estate Water usage from Lembaga Air Perak for supply to housing area. The usage as below: 16/08/2018 - 17/10/2018 : RM134.39 20/06/2018 - 16/08/2018 ; RM117.91 01/07/2018 - 20/06/2018 : RM 63.26 b) Monitoring of outgoing water which may have negative impacts into the natural waterways at a frequency that reflects the estate’s current activities

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Yew Lew Yee Noted water sampling conducted on 28/11/2018 to Union Laboratories Sdn Bhd, sampling result: pH 5.9 DO 7.21 TSS 51 BOD 3 COD 18 Ammonical Nitrogen ND Champion Point Noted no natural water passed through/ boundary with the estate c) Ways to optimize water and nutrient usage to reduce wastage (e.g. having in place systems for re-use, night application, maintenance of equipment to reduce leakage, collection of rainwater, etc.).

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Champion Point Sighted water management plan 2018 - 2019. The plan identified item such Objective, requirement, action plan, frequency, status. Noted the plan has identified 4 objectives. Sample as below: Objective: Optomizing natural water resources Requirement: Assessment of water usgae and sources of supply Action Plan: Record usage of water according to sources of supply Frequency: Once a year Status: - OBS 9 (Yew Lee Estate) Action not yet available for the optimizing water and nutrient usage which to reduce the wastage. d) Protection of water courses and wetlands, including maintaining and restoring appropriate riparian buffer zones at or before planting or replanting, along all natural waterways within the estate.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Behrang 2020 Estate Verified, no natural water in the estate, however during site visit sighted the artificial drain been maintained for its riparian buffer zone by no chemical activities. Champion Point Verified, no natural water in the estate

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CAR 5 (Yew Lee Estate) 4.5.5.1.d) Natural Water Resources d) During site visit, sighted spraying activity traces at the buffer zone area (Block 3) and at river bank of Sungai Sungkai river e) Where natural vegetation in riparian areas has been removed, a plan with a timetable for restoration shall be established and implemented. Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Not applicable Refer to 5.7.1.d f) Where bore well is being use for water supply, the level of the ground water table should be measured at least annually.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Not applicable Behrang 2020 Estate Noted the estate used the bore well for employees water supply, however, ground water table not yet measured. Noted, the letter replied from Lembaga Air Perak #Bil(53)DLM.LAP WS.SR/295 JLD 2 dated 07/05/2018 subject "PERMOHONAN BERKALAN AIR UNTUK RUMAH PEKERJA LADANG BEHRANG 2020", stated in letter LAP suggest the estate to provide tank and water pump for supply the water, also appoint licensed plumber for further implementation.

4.5.5.2 No construction of bunds, weirs and dams across main rivers or waterways passing through an estate.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Verified during site audit, no constuction of bunds were sighted.

4.5.5.3 Water harvesting practices should be implemented (e.g. water from road-side drains can be directed and stored in conservation terraces and various natural receptacles).

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Yew Lee Estate During site visit, verified water harvesting available by stacking the frond to maintain the soil moisture, road side drain & etc. Behrang 2020 Estate Noted during site visit, the water harvesting collected at housing area for cleaning usage. Criterion 6 Status of rare, threatened, or endangered species and high biodiversity value area Indicator Requirement Findings

4.5.6.1 Information shall be collated that includes both the planted area itself and relevant wider landscape-level considerations (such as wildlife corridors). This information should cover:

a) Identification of high biodiversity value habitats, such as rare and threatened ecosystems, that could be significantly affected by the grower(s) activities. Identification of high biodiversity value habitats, such as rare and threatened ecosystems, that could be significantly affected by the grower(s) activities. Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate The identification of the high biodiversity value as per Biodiversity & High Conservation Value (HCV) Assessment Report December 2018. From the HCV Identification sighted the findings as below: a) Mammals and reptiles- wild pig, bearded pig, leopard cat and common palm b) Birds- ayam hutan, Pucung Merah, Bangau Kendi, Bangue Besar etc b) Conservation status (e.g. The International Union on Conservation of Nature and Natural Resources (IUCN) status on legal protection, population status and habitat requirements of rare, threatened, or endangered species), that could be significantly affected by the grower(s) activities. Refer to the Biodiversity Assessment and sighted no any endangered species identified as per IUCN List.

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4.5.6.2 If rare, threatened or endangered species, or high biodiversity value, are present, appropriate measures for management planning and operations should include:

a) Ensuring that any legal requirements relating to the protection of the species are met

Sighted the Biodiversity Management Plan and listed the plan for conservation for river reserve area and forest boundaries dated 18/12/2018

b) Discouraging any illegal or inappropriate hunting, fishing or collecting activities and developing responsible measures to resolve human-wildlife conflicts During site visit, sighted management erect the "No Hunting", "No Fishing" signage at the estate main entry gate, river etc

4.5.6.3 A management plan to comply with Indicator 1 shall be established and effectively implemented, if required.

Sighted the Biodiversity Management Plan and listed the plan for conservation for river reserve area and forest boundaries dated 18/12/2018

Indicator 7 Zero burning practices

Indicator Requirement Findings

4.5.7.1 Use of fire for waste disposal and for preparing land for oil palm cultivation or replanting shall be avoided except in specific situations, as identified in regional best practice.

Site visit at the line site and replanting area, sighted no open burning was practiced.

4.5.7.2 A special approval from the relevant authorities shall be sought in areas where the previous crop is highly diseased and where there is a significant risk of disease spread or continuation into the next crop.

No open burning practices for replanting

4.5.7.3 Where controlled burning is allowed, it shall be carried out as prescribed by the Environmental Quality (Declared Activities) (Open Burning) Order 2003 or other applicable laws.

No open burning practices for replanting

4.5.7.4 Previous crops should be felled or mowed down, chipped and shredded, windrowed or pulverized or ploughed and mulched.

Site visit at the replanting area and sighted the previous crops was felled, chipped and shredded

P6: Best Practices

Criterion 1 Site management

Indicator Requirement Findings

4.6.1.1 Standard operating procedures shall be appropriately documented and consistently implemented and monitored.

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Sighted MHC Plantation Bhd establish the Standard Operating Procedures for the operation such as replanting, weeding, pruning and other operation. Yew Lee Estate Site visit at the Blok 3 for prunning activity sighted the prunners follow the SOP by retain 2 whorls below the lowest ripe bunch for the palm 3 years. Verified the harvesting activity at Block 5 and sighted the harvesting activity as per SOP by maintain 12-15 days harvesting interval with minimum of 2 rounds of harvesting per month. Sighted the cutter cut ripe bunches after detected 3-5 detached loose fruits on the ground. Kuala Bikam Estate Site visit at Block 2 for harvesting activity and noted the harvesting was done by the contractor and noted management have done the briefing to the harvester to ensure they follow the SOP. Spraying activity was held in BLock 3 by the check roll workers, however found the mixing activity was done in the field. Champion Point Estate Site visit to the harvesting activity at Block 2 and the activity was done by the check roll employer. Batang Padang Estate Site visit at Block 6 for spraying activity by contractor and noted management conducted the SOP Training to the contractor’s workers. OBS 10 (Kuala Bikam Estate) Noted the harvesting activity was done by the contractor, advice management to provide training to the contractor workers to ensure them aware with the SOP 4.6.1.2 Where oil palm is grown within permitted levels on sloping land, appropriate soil

conservation measures shall be implemented to prevent both soil erosion as well as siltation of drains and waterways. Measures shall be put in place to prevent contamination of surface and groundwater through runoff of either soil, nutrients or chemicals.

Yew Lee Estate Site visit at the hilly area Block 1 and sighted management maintain the terrace by planted cover crop (Pueraria javanica). Kuala Bikam Estate, Champion Point Estate and Batang Padang Estate Noted the area was flat area and sighted maintain the drain and waterways surrounding the field.

4.6.1.3 A visual identification or reference system shall be established for each field.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Verified the report for soil type and found the soil type for the area is Serdang, Munchong, Sogomana etc. Sighted the soil series map was available and stated the type of soil for every block. The block identification was sighted as per estate map.

Criterion 2 Economic and financial viability plan

Indicator Requirement Findings

4.6.2.1 A documented business or management plan shall be established to demonstrate attention to economic and financial viability through long-term management planning.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Verified the Yearly Budget 2019 for all MHC Plantation Bhd estate and sighted the budget contain of the monthly budgeted crop, cost for weeding, prunning, manuring, pest & disease etc.

4.6.2.2 Where applicable, an annual replanting programme shall be established. Long term replanting programme should be established and review annually, where applicable every 3-5 years

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Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Verified the 5 Year replanting Proggrame for year 2018-2022 and sighted for Yew Lee Estate replanting only plan for year 2018 and no replanting until 2022. Kuala Bikam Estate Noted at this period no replanting rpoggrame was establish due the the crop profile is planted on 2008. Batang Padang Estate Verified the 5 Year replanting Program for year 2018-2022 and sighted for BPE replanting plan for year 2018 (Field 5: 20.20Ha), 2021 (Field 8: 40.50ha) and 2022 (Field 4/9: 81.40 Ha). 4.6.2.3 The business or management plan may contain:

a) Attention to quality of planting materials and FFB. b) Crop projection: site yield potential, age profile, FFB yield trends. c) Cost of production: cost per tonne of FFB. d) Price forecast. e) Financial indicators: cost benefit, discounted cash flow, return on investment.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Verified the budget for year 2019, and sighted the plan was contain of: a) Monthly budgeted crop for fields in year 2019= Total= 6,010 b) crop projection= Yield per hactare= 20.03 c) Cost of production= Mature area, Field 1, 2,5,6, 7A and 7C= RM780,490.00 c) Cost of production= RM131.36/MT Kuala Bikam Estate Verified the budget for year 2019, and sighted the plan was contain of a) Monthly budgeted crop for fields in year 2019= Total= 8,600 MT b) Crop projection= Yield per hactare= 21.77 c) Cost of production= Mature area, Field 1,2 ,3 4,5,6 ,7 ,8 9,10 = RM1,237, 046 = RM143.64/ Ha 4.6.2.4 The management plan shall be effectively implemented and the achievement of the goals

and objectives shall be regularly monitored, periodically reviewed and documented.

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Noted the management have their Management Meeting by monthly basis to discuss the overall achievement of the management plan objectives. verified the minute of meeting as below: a) Minutes of 6th Management Meeting dated 12/09/2018 b) Minuted of 3rd Management Meeting dated 19/06/2018 From the minute meeting sighted the agenda aof the meeting is to discuss on the labour issue, FFB production, MSP0 and other matters. Criterion 3 Transparent and fair price dealing

Indicator Requirement Findings

4.6.3.1 Pricing mechanisms for the products and other services shall be documented and effectively implemented.

Noted all the FFB prices was agreed with the Anson Oil Industries Sdn Bhd, the management of Anson Oil Industries will display the daily FFB prices at the weighbridge office. Sighted the pricing mechanisme was attached together with the agreement as per Schedule 1 below: Method of calculating FFB net prices: (A-C0T)*O + (B)* K- F A= MPOB CPO deleivered average northern Malaysia price B= MPOB palm kernel average norther Malaysia price C= MPOB Cess of RM13 T= CPO transport RM28/ MT F= Mill processin fee at RM60/MT *O= OER at 19.25% *K= KER at 5% 4.6.3.2 All contracts shall be fair, legal and transparent and agreed payments shall be made in

timely manner

Verified the contract of FFB suppliying to the Anson Oil Industries as below: a) Champion Estate Fresh Fruit Bunch Agreement between Anson Oil Industries Sdn Bhd dated 01/08/2018 b) Batang Padang Estate Fresh Fruit Bunch Agreement between Anson Oil Industries Sdn Bhd dated 01/08/2018

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Criterion 4 Contractor

Indicator 1 Requirement Findings

4.6.4.1 Where contractors are engaged, they shall understand the MSPO requirements and shall provide the required documentation and information

Yew Lee Estate, Kuala Bikam Estate, Behrang 2020 Estate, Batang Padang and Champion Estate Noted during the stakeholder meeting, management already brief to the contractors on the MSPO requirement. Verified the attendance list of stakeholder during the stakeholder meeting on 07/09/2018 and sighted contractors attend the briefing such as Lee Yoon Hin from Winstar Transport, Pang See Hui from Tractor Pang etc

4.6.4.2 The management shall provide evidence of agreed contracts with the contractor.

Yew Lee Estate Verified the contract agreement between the contractor as below: a) Harvesting Contract Agreement between Asanah binti Abu Asan (Ref:MHC/OPE/CA/YLE/Bil (01) 01/2018 with the content of harvesting fruits quality, payment term etc. Kuala Bikam Estate Verified the contract agreement between the contractor as below: a) Harvesting Contract Agreement between Asanah binti Abu Asan (Ref:MHC/OPE/CA/KBE/Bil (02) 01/2018 with the content of harvesting fruits quality, payment term etc. Batang Padang Estate Verified the contract agreement between the contractor as below: a) Perjanjian Kontrak BPS between Shaikh Din Mohammad Shaikh A.B. Rashid (Ref:MHC/OPE/CA/BPE/Bil (03) 01/2018 with the content of manuring term and condition etc. b) Transportation Agreement between Winstar Transort Enterprise (Ref# BPE 01/01/2018) with the content of FFB transportation term and condition. Champion Estate Verified the contract agreement between the contractor as below: a) Harvesting Contract Agreement between Punitha A/P Kanasan (Ref:MHC/OPE/CA/CPE/Bil (09) 03/2018 with the content of harvesting fruits quality, payment term etc. 4.6.4.3 The management shall accept MSPO approved auditors to verify assessments through a

physical inspection if required

During site visit, the Asanah binti Abu Asan allowed auditor interview the harvester at Kuala Bikam Estate and Yew Lee Estate Batang Padang Estate During site visit, contractor allowed to interview the workers

4.6.4.4 The management shall be responsible for the observance of the control points applicable to the tasks performed by the contractor, by checking and signing the assessment of the contractor for each task and season contracted

Management observe the tasks performed by the contractor by daily check by the field staff. OBS 11 (Yew Lee Estate) Noted field staff was observe the contractor task daily, advise management to establish the inspection/ assessment criteria on the daily contractor task.

P7: Development of new plantings

Criterion 1 High biodversity value

Indicator Requirement Findings

4.7.1.1 Oil palm shall not be planted on land with high biodiversity value unless it is carried out in compliance with the National and/or State Biodiversity Legislation.

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4.7.1.2 No conversion of Environmentally Sensitive Areas (ESAs) to oil palm as required under Peninsular Malaysia’s National Physical Plan (NPP) and the Sabah Forest Management Unit under the Sabah Forest Management License Agreement. For Sabah and Sarawak, new planting or replanting of an area 500ha or more requires an EIA. For areas below 500ha but above 100ha, a Proposal for Mitigation Measures (PMM) is required

Not Applicable

Criterion 2 Peat Soil

Indicator Requirement Findings

4.7.2.1 New planting and replanting may be developed and implemented on peat land as per MPOB guidelines on peat land development or industry best practice.

Not Applicable

Criterion 3 Social and Environmental Impact Assessment (SEIA)

Indicator Requirement Findings

4.7.3.1 A comprehensive and participatory social and environmental impact assessment shall be conducted prior to establishing new plantings or operations.

Not Applicable

4.7.3.2 SEIAs shall include previous land use or history and involve independent consultation as per national and state regulations, via participatory methodology which includes external stakeholders.

Not Applicable

4.7.3.3 The results of the SEIA shall be incorporated into an appropriate management plan and operational procedures developed, implemented, monitored and reviewed.

Not Applicable

4.7.3.4 Where the development includes smallholder schemes of above 500ha in total or small estates, the impacts and implications of how each scheme or small estate is to be managed should be documented and a plan to manage the impacts developed, implemented, monitored and reviewed.

Not Applicable

Criterion 4 Soil and topographic information

Indicator Requirements Findings

4.7.4.1 Information on soil types shall be adequate to establish the long-term suitability of the land for oil palm cultivation

Not Applicable

4.7.4.2 Topographic information shall be adequate to guide the planning of planting programmes, drainage and irrigation systems, roads and other infrastructure

Not Applicable

Croterion 5 Planting on steep terrain, marginal and fragile soils

Indicator Requirements Findings

4.7.5.1 Extensive planting on steep terrain, marginal and fragile soils shall be avoided unless permitted by local, state and national laws.

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Not Applicable 4.7.5.2 Where planting on fragile and marginal soils is proposed, plans shall be developed and

implemented to protect them and to minimize adverse impacts (e.g. hydrological) or significantly increased risks (e.g. fire risk) in areas outside the plantation.

Not Applicable 4.7.5.3 Marginal and fragile soils, including excessive gradients and peat soils, shall be identified

prior to conversion

Not Applicable Criterion 6

Indicator Requirements Findings

4.7.6.1 No new plantings are established on recognised customary land without the owners’ 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

Not Applicable 4.7.6.2 Where new plantings on recognised customary lands are acceptable, management plans

and operations should maintain sacred sites.

Not Applicable 4.7.6.3 Where recognized customary or legally owned lands have been taken-over, the

documentary proof of the transfer of rights and of payment or provision of agreed compensation shall be made available

Not Applicable 4.7.6.4 The owner of recognised customary land shall be compensated for any agreed land

acquisitions and relinquishment of rights, subject to their free prior informed consent and negotiated agreement.

Not Applicable 4.7.6.5 Identification and assessment of legal and recognised customary rights shall be

documented.

Not Applicable 4.7.6.6 A system for identifying people entitled to compensation and for calculating and

distributing fair compensation shall be established and implemented.

Not Applicable 4.7.6.7 The process and outcome of any compensation claims shall be documented and made

publicly available.

Not Applicable 4.7.6.8 Communities that have lost access and rights to land for plantation expansion should be

given opportunities to benefit from the plantation development.

Not Applicable

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Observation for Improvement Details

OBS 1 (Champion Point Estate & Yew Lee Estate) 4.1.4.3 Noted the new technology was implemented for solar power, advice management to establish the action plan including the monitoring of power usage, training etc for the solar power system. OBS 2 (Kuala Bikam Estate) 4.4.5.4 To include signed contract Agreement with date OBS 3 (Kuala Bikam Estate) 4.4.5.5 To provide employee master list that records full name, gender, date of birth and etc. OBS 4 (Champion Estate) 4.4.5.11 Weekly inspection not yet conducted as the housing were completed built in August 2018. OBS 5 (Yew Lee Estate) 4.5.1.2 Refer to MHC Plantation BHD Policy, the objective such execute efficiency of energy where practicable in form of economic and operation were not stated in any environmental plan OBS 6 (Champion Estate) 4.5.2.2 Average for estimation for diesel not yet identified. OBS 7 (All Estates) 4.5.3.3 To register in eswis OBS 8 (Kuala Bikam Estate) 4.5.3.4 Noted Kuala Bikam Estate practice the triple rinsing and advise management to establish the SOP for triple rinsing OBS 9 (Yew Lee Estate) 4.5.5.1 Action not yet available for the optimizing water and nutrient usage which to reduce the wastage. OBS 10 (Kuala Bikam Estate) 4.6.1.1 Noted the harvesting activity was done by the contractor, advice management to provide training to the contractor workers to ensure them aware with the SOP. OBS 11 (Yew Lee Estate) 4.6.4.4 Noted field staff was observe the contractor task daily, advise management to establish the inspection/ assessment criteria on the daily contractor task. OFI 1 (Batang Padang Estate) 4.4.4.2 HIRARC approval should issue date OFI 2 (Batang Padang Estate) 4.4.5.4 To include signed in the Agreement with date issued OFI 3 (Kuala Bikam Estate) 4.4.5.10 To include Foreign Workers Compensation Scheme (FWCS) Insurance Compensation for workers in contract agreement

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OFI 4 (Yew Lee & Champion Point) 4.5.1.5 To update the status programme in the training matrix. OFI 5 (Behrang 2020 Estate) Site visit - Signage flammable at petrol storage not yet displayed/erected. OFI 6 (Behrang 2020 Estate) 4.5.3.2 According to auditee, the rubbish/domestic waste from housing and office area will be disposed through Local Authorities not as per waste management plan. OFI 7 (Behrang 2020 Estate) 4.5.3.3. During site visit, noted the scheduled waste label for SW110 not yet labelled. OFI 8 (Behrang 2020 Estate) 4.5.2.1 To develop the diesel record into the graph for clear trend montoring. OFI 9 (Behrang 2020 Estate) 4.4.2.2 To mention and identify the complaint category as per MHC-SOP-11 into the Complaint Form so that the respond time will ease to monitor. OFI10 (Behrang 2020 Estate) 4.5.1.6 To include other agenda of environmental such schedule waste inventory/status, zero burning monitoring other current status of environmental management plan

During the assessment 5 nonconformities were identified.

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APPENDIX 1

MAPS OF ESTATE FOR BATANG PADANG ESTATE, YEW LEE ESTATE, CHAMPION

ESTATE AND BATANG PADANG ESTATE

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APPENDIX 2

MAPS OF ESTATE FOR KUALA BIKAM ESTATE AND SUNGAI TIMAH ES