Asa3 OPMC41747

INTERTEK CERTIFICATION INTERNATIONAL SDN BHD
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Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

Masai Palm Oil Mill – Annual Surveillance Audit (ASA-03) (2021) [Remote Audit]
KECK SENG (MALAYSIA) BERHAD

Masai Palm Oil Mill
M008A
Masai, Johor, Malaysia
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MSPO CERTIFICATION
ANNUAL SURVEILLANCE AUDIT
PUBLIC SUMMARY REPORT
Keck Seng (Malaysia) Berhad

Masai Palm Oil Mill
MSPO Certificate No: M008A
Masai, Johor, Malaysia
Certificate No: INTERTEK MSPO M008A

Start Date: 10 December 2018
Expiry Date: 09 December 2023
Audit Type Audit Dates

Initial Certification Audit 28 – 30 Aug 2018
Annual Surveillance – 01 21 – 24 Oct 2019
Annual Surveillance – 04
Re-Certification
Intertek Certification International Sdn Bhd

D-28-3, Level 28, Menara Suezcap 1, No. 2, Jalan Kerinchi, Gerbang Kerinchi Lestari, 59200 Kuala Lumpur, Malaysia.
Tel +603 7931 0032 Fax +603 7931 0419 Email: ia.mysbaenquiry@intertek.com
Website: www.intertek.com
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Table of Contents
1.0 SCOPE OF AUDIT .................................................................................................................................................. 4
1.1 Introduction .......................................................................................................................................................... 4
1.2 Location (Address, GPS, and Map) of Palm Oil Mill ............................................................................................ 4
1.3 Other Certifications Held and Use of RSPO Trademarks & Logos ...................................................................... 4
1.4 Organizational Information / Contact Person ....................................................................................................... 4
1.5 Tonnages Verified for Certification ...................................................................................................................... 5
1.6 Abbreviations Used.............................................................................................................................................. 7
2.0 AUDIT PROCESS ................................................................................................................................................... 8

2.1 Audit Methodology, Plan and Site Visits .............................................................................................................. 8
2.2 Date of Next Scheduled Visit ............................................................................................................................... 8
2.4 Certification Body ................................................................................................................................................ 8
2.3 Qualifications of the Lead Auditor and Audit Team .............................................................................................. 8
2.5 Process of Stakeholder Consultation ................................................................................................................... 8
3.0 AUDIT FINDINGS .................................................................................................................................................. 10

3.1 Summary of Findings ......................................................................................................................................... 10
3.2 Status of Identified Noncompliance and Corrective Actions, Observations and Positive Elements. ................ 277
4.0 AUDIT CONCLUSION AND RECOMMENDATION .............................................................................................. 35

4.1 Acknowledgement of Internal Responsibility and Confirmation of Audit Findings .............................................. 35
4.2 INTERTEK – MSPO Certificate Details for Keck Seng (Malaysia) Berhad – Masai Palm Oil Mill...................... 36
APPENDIX A: Qualifications of Lead Auditor and Audit Team ..................................................................................... 37

APPENDIX B: Audit Plan .................................................................................................................................................. 38
APPENDIX C: Location Map of Keck Seng (Malaysia) Berhad – Masai Palm Oil Mill.................................................. 41
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1.0 SCOPE OF AUDIT
1.1 Introduction
This Surveillance Audit (ASA-03) was conducted on Masai POM on 26 to 29 October 2021, to assess the organization’s
operations of the palm oil mill are in compliance against the MSPO Part 4 (MS 2530-4: 2013) General Principles for Palm
Oil Mills.
1.2 Location (Address, GPS, and Map) of Palm Oil Mill

Masai Palm Oil Mill is wholly owned by Keck Seng (Malaysia) Berhad, as indicated in Table 1 below, which includes the
address and GPS location of the mill. The location maps are provided in Appendix C.
Table 1: Address of Palm Oil Mill, and GPS Location

GPS Reference
Name Address
Latitude Longitude
Masai Palm Oil Mill 9 Miles, Kong Kong Road, 81757 1.540346O N 103.964895O E
Capacity: 60 mt/Hr Masai, Johor, Malaysia.
Table 1-1: Registered Name of Palm Oil Mill and MPOB License
Registered Company
Designated Mill Name MPOB License No. MPOB License Validity
Mill Name
Keck Seng (Malaysia) Berhad Masai Palm Oil Mill 500026504000 01/04/2021 – 31/03/2022
1.3 Other Certifications Held and Use of RSPO Trademarks & Logos
Currently, the other certification held by Masai POM of Keck Seng (Malaysia) Berhad are RSPO P&C, MSPO SCCS, and
Food Safety Management System (ISO 22001) Certifications which are still valid.
The MSPO’s trademarks and logo are not being used by the POM / Estates audited. Instructions for use were provided and
acknowledged by the POM / Estates through a signed Memorandum of commitment agreeing to adhere to the latest “MSPO
Rules on Use of Logos and Trademarks”, provided prior to the Audit.
1.4 Organizational Information / Contact Person

Keck Seng (Malaysia) Berhad (Head Office):-
Name : Mr. Ho Chung Kain
Position : Director (Plantation Sustainability)
Address : Keck Seng (Malaysia) Berhad, 9 Miles, Kong Kong Road, 81757 Masai, Johor, Malaysia.
Tel : +60 7-255 1111
Fax : +60 7-255 5117
Email : hochungkain@keckseng.org
Masai POM (Head Office):-

Name : Mr. Chua Teck Ngin
Position : General Manager
Tel : +60 7-255 1111
Fax : +60 7-255 5117
Email : chuatn@keckseng.com
Masai POM (Site):-

Name : Mr. Teo Aik Chong
Position : Senior Mill Manager
Tel : +60 7-255 1111
Fax : +60 7-255 5117
Email : teoac@keckseng.com
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1.5 Tonnages Verified for Certification

1.5.1 The supply base i.e., FFB sources to the POM are from the 8 estates (Keck Seng Oil Palm Estate, Tong Hing
Estate, Sg. Layang Estate, Kota Tinggi Oil Palm Plantations, Sin Lian Oil Palm Plantations, Lian Huap Oil Palm Plantations,
Johore (Masai) Plantations, and Lim & Lim Plantations) which are owned and managed by Keck Seng (Malaysia) Berhad.
All of these 8 estates are MSPO Part 3 Certified. The FFB supply from the said own estates contributed about 20% of the
total supply to the POM.
The POM has also been receiving FFB (about 80% of total FFB) from external suppliers, i.e., outgrowers and independent
smallholders, which are also located within the Masai region at Johor state, Malaysia throughout its certification period.
The breakdown of all the suppliers and their tonnages of FFB supplied to the Masai POM & Estates Grouping based on the
reporting period for actual previous 15 months are as follows:
Table 5: Tonnages Verified for Certification

(Period: Oct 2020 – Sept 2021)
FFB Processed (MT) Main Processing
# Estate /Supplier CB
Oct 20 – Dec 20 Jan 21 – Sept 21 Palm Oil Mill
A Management Unit (own estates) (under certification)
1 Johor (Masai) Plantation 2,283.08 6,488.02
2 Keck Seng Oil Palm 24.47 91.07
3 Kota Tinggi Oil Palm 1,167.39 2,502.59
4 Lian Huap Oil Palm 2,179.62 6,885.55
5 Lim & Lim Plantation 3,560.89 10,172.53
Masai POM INTERTEK
6 Sin Lian Oil Palm 1,596.32 4,358.59
7 Sungai Layang Estate 508.68 1,161.86
8 Tong Hing Estate 0.00 206.00
(a) Sub-total by Management Unit Estates
11,320.45 31,866.21
FFB:
B External / Other Supplies (certified) [Outgrowers]:
1 Lam San Estate 4,774.47
2 Lam Cheng Estate 1,309.79
3 Sg. Plentong Estate 1,076.01
4 Cempaka Merpati 995.17
5 Senai Estate 8,744.50 Masai POM INTERTEK
6 Ladang Bukit Layang 1 3,927.95
7 Ladang Bukit Layang 2 1,618.47
(b) Sub-total by External / Other Supplies
22,446.39
(certified) [Outgrowers]:
C External / Other Supplies (non-certified) [Outgrowers]:
1 Cempaka Merpati (M) S/B 160.89 834.28
2 Koperasi Cahaya Baru Bhd 1,537.31 3,522.22
3 Koperasi Cahaya Baru Bhd 5.65 3.72
4 Lam Cheng Estate 319.51 990.28
5 Lam San Rubber Estate 919.60 3,854.87
6 Ladang Bukit Layang 1,158.03 -
Masai POM INTERTEK
7 Ladang Bukit Layang (2) 486.23 -
8 Lembaga Kemajuan Tanah Persekutuan 612.31 2,122.70
9 Senai Estate 1,204.28 7,540.22
10 Sg. Plentong Estate 65.71 1,010.30
(c) Sub-total by External / Other Supplies
6,469.52 19,878.59
(non-certified) [Outgrowers]:
D External / Other Supplies (non-certified) [Smallholders]:
1 A.Rahim Bin Mahidi 7.57 50.1
Masai POM INTERTEK
2 Abd Rahman Bin Budin 40.37 92.11
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3 Abd Rahman Bin Budin 2 7.94 0

4 Abdoll Rahman Bin Ahmad 18.13 47.3
5 Abdoll Rahman Bin Ahmad 2 1.63 3.86
6 Bahrom Bin Saring 32.18 103.98
7 Chop Soon Guan (1) 21177.4 67971.53
8 Chop Soon Guan (2) 83.89 244.98
9 Chop Soon Guan (3) 670.62 3323.75
10 Guan Leng Trading S/B 2148.13 7392.92
11 Hong Huat Trading Co (2) 1513.44 4649.17
12 Hong Huat Co (1) 8384.93 28426.89
13 Lee Seng Trading Co 60.37 228.13
14 Lim He Yeck (1) 11.21 61.63
15 Norlizah Binti Madi 12.98 20.98
16 Yoong Shing Sdn Bhd 89.75 374.68
17 Saadiah Binti Surip (1) 17.03 155.17
18 Saadiah Binti Surip (2) 6.96 17.3
19 YS Aquaculture Trading Sdn Bhd 74.31 294.91
(c) Sub-total by External / Other Supplies
34,358.84 113,459.39
(non-certified) [Smallholders]:
Grand total (A) + (B) + (C): 52,148.81 169,106.35
Note: No FFB supplied from Tong Hing Estate as they are in replanting phase.
1.5.2 Total annual volumes / tonnages of FFB supplied from the supply base to Masai POM & Estates Grouping during
the previous, current, and projected period are as follows:
Table 6: Annual Tonnage of FFB (Certified & Non-certified)

FFB Produced FFB Produced (Actual) FFB Produced
Jan 21 – Dec 21 Jan 22 – Dec 22
Estate / Supplier (Estimate) Oct 20 – Dec 20 Jan 21 – Sept 21 (Projection)
MT % MT % MT % MT %
Grouping estates:
54,782.40 21.50% 11,320.45 21.71% 31,866.21 18.84% 53,104.00 20.98%
(under certification)
External Suppliers:
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
(certified)
External Suppliers:
200,000.00 78.50% 40,828.36 78.29% 133,337.98 78.85% 194,900.00 77.01%
(non-certified)
Total: 254,782.40 100.0% 52148.81 100.0% 169106.35 100.0% 253,104.00 100.0%
SCCS Model for

MB MB MB MB
POM
1.5.3 The annual certifiable tonnages of CPO and PK production by Masai POM & Estates Grouping from the supply
base/ suppliers as assessed and verified during the current assessment and projected for next 12 months are detailed as
follows:
Table 7: Annual Tonnages under Certification – FFB, CPO & PK

Production Production (Actual) Production
POM Jan 20 – Dec 20 Jan 22 – Dec 22
(Estimate) Oct 20 – Dec 20 Jan 21 – Sept 21 (Projection)
Total FFB Processed (MT) 54,782.40 11,320.45 35,768.37 58,204.00
OER: OER: OER: OER:

Total CPO Produced (MT) 10,573.00 2,210.88 6,774.53 11,233.72
19.30% 19.53% 18.94% 19.30%
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KER: KER: KER: KER:

Total PK Produced (MT) 3,314.34 638.47 2,124.64 3,521.34
6.05% 5.64% 5.94% 6.05%
1.6 Abbreviations Used

BOMBA Fire Services Department IPM Integrated Pest Management
CB Certification Body ISCC International Sustainability & Carbon Certification
CHRA Chemical Health & Risk Assessment IUCN International Union for Conservation of Nature
CPO Crude Palm Oil JAS Jabatan Alam Sekitar
CSDS Chemical Safety Data Sheets JKKP Jabatan Kesihatan dan Keselamatan Pekerja
CSPO Certified Sustainable Palm Oil KER Kernel Extraction Rate
CSPK Certified Sustainable Palm Kernel LTA Lost Time Accidents
DOE Department of Environment MPOB Malaysia Palm Oil Board
DOSH Department of Occupational Safety and Health MSDS Material Safety Data Sheets
EFB Empty Fruit Bunch MTCS Malaysia Timber Certification Scheme
EHS Environmental Health & Safety NC Non-Compliance or Non-Conformance
EIA Environmental Impact Assessment NGO Non-Government Organization
FASSB Felda Agricultural Services Sdn Bhd OER Oil Extraction Rate
FELDA Federal Land Development Authority OHS Occupational Health & Safety
FFB Fresh Fruit Bunch PEFC Programme for the Endorsement of Forest Certification
FGVHB FGV Holdings Berhad PK Palm Kernel
FGVPISB FGV Palm Industries Sdn Bhd UOC Plantation Management Unit
FGVPM FGV Plantations (M) Sdn Bhd POM Palm Oil Mill
FTPSB Felda Tekno Plant Sdn Bhd POME Palm Oil Mill Effluent
GAP Good Agriculture Practice PPE Personal Protective Equipment
HCV High Conservation Values SCCS Supply Chain Certification Standard
Intertek Intertek Certification International Sdn Bhd SOP Standard Operating Procedures
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2.0 AUDIT PROCESS
2.1 Audit Methodology, Plan and Site Visits

Since 24 September 2021, Intertek has initiated public communications and notifications and invited the relevant
stakeholders before the audit to provide feedback and comments on their concern (if any) on the POM regarding the
environmental, biodiversity, community development and other relevant issues.
On 26 October 2021, the Audit Team of Intertek conducted the surveillance audit (ASA-03) in which the Masai Palm Oil Mill
was audited for compliance against the MSPO Part 4 (MS 2530-4: 2013) General Principles for Palm Oil Mills requirements.
During the on-site audit, relevant documents, and records, including Standard Operating Procedures (SOP), management
plans, hectarage development, FFB, CPO and PK production, oil palm age profile, operational controls and measures,
operational data and records, training records, etc. were reviewed and verified for compliance. The Audit Team covered
the palm oil mill and estate operations, agricultural practices, pest management, pesticide and fertilizer application,
occupational health and safety, social accountability, environment, and other requirements. Stakeholders’ interviews were
conducted during the audit and feedback obtained as part of information and evidence gathering. (See Section 2.5 – Process
of Stakeholder Consultation).
After completion of the on-site field audit, Intertek also performed the evaluation of conformity against the MSPO Certification
System requirements for CB. The Audit Report, findings and associated documents were evaluated through an independent
review by the Intertek Internal Technical Reviewer/Panel and the External Peer Reviewer (only required for Initial / Re-
Certification audits) prior to the approval of this report and decision on continued certification by Intertek.
The details of the Audit Plan (actual on-site) are provided in Appendix B.
Details of the findings and actions taken are provided in Section 3.2 of this report.
2.2 Date of Next Scheduled Visit

The next scheduled visit will be the Annual Surveillance Audit to be carried out within a 12-month period prior to the annual
certificate anniversary expiry date.
2.4 Certification Body

Intertek Certification International Sdn Bhd is part of the Intertek Group, which is a worldwide technical services
organization dedicated to reducing clients' risks by providing technical inspection services, management system
certification in quality, environmental, occupational safety & health and product certification, RSPO SCC, ISCC, Marine
Sustainability Chain-of-Custody, MTCS and PEFC Chain-of Custody certification in applicable industry sectors including the
agricultural and forestry sectors. Intertek operates globally providing clients with a wide-ranging technical inspection
expertise and access to thousands of skilled specialists worldwide. Intertek Group’s certification business is ranked in the
top 10 worldwide and is globally offering certification across a wide range of industries.
2.3 Qualifications of the Lead Auditor and Audit Team

Competency details of the Lead Auditor and Audit Team are given in Appendix A.
2.5 Process of Stakeholder Consultation

For Initial/Recertification Audit, stakeholder consultations began with notification of the upcoming audit through the websites
of Intertek. Emails were sent to applicable stakeholders including government agencies, NGOs, local communities,
representatives of indigenous people (Orang Asal / Orang Asli) and previous landowners / users (if any).
Emails and telephone enquiries were made prior to the actual audit and stakeholder’s response and feedback received were
followed up accordingly.
For Annual Surveillance Audit, stakeholder consultations began with notification of the upcoming audit through the websites
of Intertek.
During the audit, stakeholders were interviewed, and their feedbacks were recorded. Among the stakeholders consulted at
site, included workers, trade union leaders, women representatives; local community leaders, previous landowners / users
(if any), goods and services suppliers and contractors.
Among the stakeholders consulted was the as follow:

List of Stakeholders Contacted
Internal Stakeholders Union/Contractors/Local Communities
Estate’s Health Assistant Kg. Kong Kong Laut Village Representatives
Masai POM Workers Sundry Shop Owner
Estate’s Workers FFB Suppliers (Independent Smallholder)
FFB Suppliers (Outgrower) – email not responded
Contractors
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Government Departments NGO

Badan Kawal Selia Air Johor (BAKAJ) – email not There is no complaint made towards PMU. Thus, NGO
responded was not contacted.
Department of Labour - email not responded
Masai Police Station - email not responded
SK Cahaya Baru - email not responded
Issue Description
1 Feedback:
The Village Representatives of Kg. Kong Kong Laut was appointed about 1 year ago. Due to Covid-19
outbreak, he said he never had the chance to get to know the Keck Seng’s Management better. As for
stakeholder’s consultation, Keck Seng had submitted to him a letter containing information about Keck Seng
such as policy and grievance channel and a letter of response for him to reply. As of now, there is no issue
between them, but the villagers did informed him to be aware of their boundary with Keck Seng to avoid
disputes and to ensure there are no pollution to the river. He hopes that this good relationship could be
maintained, and Stakeholder’s Consultation can be made face-to-face.
Management Response:
Noted all the comments.
Audit Team Comment:
No further action.
2 Feedback:
Hup Seng and Co. runs sundry shops at labour quarters. They sell basic groceries items such as sugar,
milk, cooking oil, rice etc. The owner mentioned that the price of items is slightly higher than those sold
outside because of the distance in bringing the goods in. The workers too have option to buy their daily
needs at “Kedai Aceh” located at neighbouring village. The sundry shop also allows workers to buy goods in
advance and will only pay once they get their salary without extra charges. This were confirmed with
workers during interview.
Management’s response:
Noted the comments.
Audit team’s comments:
No further issue.
3 Feedbacks:
Contractors confirmed good business relationship with the UoC. Tender process was transparent, and terms
of contracts are fair. However, in the contract agreement, there is no specified date mentioned for payment
to be made by the UoC to Contractor. During interview, contractors mentioned that payments they received
are usually late. The work done for previous month will only be paid at the end of next month. This cause
unease for them to conduct business. They hope that the management would be able to revise the terms
and conditions for payment to obtain a win-win situation. Other than that, they do not have any issue.
Complaint and grievance procedure were known, and their workers were provided with valid contract
agreement, payslip and wages meets minimum wage, socso and epf contribution where necessary.
Management Responses:
Management was noted with the payment issue and will consult the contractors for improvement.
Audit Team Comment:

A non-conformance has been raised for this issue under indicator 5.1.6.
4 Feedbacks:
FFB Suppliers contacted were independent smallholders. They mentioned good relationship with the mill
and Masai POM manage to give them a better price compare to other. Although the payment are quite late
these past 2 months but still acceptable. The ISH also have good understanding of the FFB price calculation
and all receipts specifying price for the particular month, weight, deductions, penalty if any, were clearly
stated in the receipts and understood by them. As of now, they do not have any issue or complaint towards
management and satisfied with current practice.
Management Responses:
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Noted all comments.

Audit Team Comment:
No further action.
3.0 AUDIT FINDINGS
3.1 Summary of Findings

Certification Unit : Keck Seng (Malaysia) Berhad – Masai POM Audit Dates : 26 – 29 Oct 2021
Auditor/s : Nor Ezani Ahmad (NEA), Mohd Hafiz Mat Hussain (MH) and Mohamad Amirul Saifullah (MAS)
Principle 1: Management Commitment & Responsibility

INDICATORS FINDINGS AND OBJECTIVE EVIDENCE COMPLIANCE
4.1.1: MSPO Policy
4.1.1.1: Policy for the Keck Seng (Malaysia) Berhad has documented a policy for the Complied
implementation of MSPO shall implementation of MSPO, titled RSPO & MSPO Statement Policy,
be established. Revision 02, which was signed by Executive Director on 13 July
2020. The policy is available at website: http://masai.Keckseng.com/
images/pdf/RSPO%20and%20MSPO%20Statement%20Policy%20
(ENG)%20v2.pdf. It also displayed at notice boards surrounding the
estates and well communicated to all workers and staffs of the
estates through briefing.
The company has documented its policy as Sustainable palm oil
production through legal compliance, economically viable,
environmentally appropriate, and socially beneficial management,
and operations.
4.1.1.2: The policy shall also The policy had also clearly stated the company’s commitment which Complied
emphasize on the commitment included continual improvement in the overall aspects of plantation
to continual improvement with management and community development.
the objective of improving the
milling operation.
4.1.2: Internal audit
4.1.2.1: Internal audit shall be The Internal Audit Procedure stated that audit shall be planned and Complied
planned and conducted carried out at least once a year. It also stated that additional internal
regularly to determine the audits shall be conducted based upon the number of non-
strong and weak points and conformances raised, new process or changes in system and any
potential area for further issues raised by interested parties.
improvement.
4.1.2.2: The internal audit Internal Audit Procedure available as in Internal Audit Procedure Complied
procedures and audit results (SPOP-GEN-01, Rev.02, Date: 12/06/2020). The internal audit was
shall be documented and conducted by Internal Audit Department from Headquarters of Keck
evaluated, followed by the Seng (Malaysia) Berhad on 21 – 22 September 2021 by 2 Internal
identification of strengths and Auditors. There were 2 NCRs issued during the audit. Checklist of
root causes of nonconformities, the Internal Audit was based on MSPO Part 4 Standard. All of the
in order to implement the NCRs were closed and addressed by estates management
necessary corrective action. accordingly. Overall, the internal audit was effectively implemented.
Audit results evaluated and corrective actions taken on the non-
conformances, which have all been closed.
4.1.2.3: Reports shall be made The audit report was documented and made available. The status of Complied
available to the management findings raised during internal audit were discuss accordingly during
for their review. Management Review Meeting which were conducted by own estate.
4.1.3: Management Review
4.1.3.1: The management shall Referred to Management Review Procedure (SPOP-GEN-01, Complied
periodically review the Rev.00, Date: 03/07/2018), management are committed to conduct
continuous suitability, MRM at least once a year as to review the performance of the
adequacy, and effectiveness of management towards the implementation of RSPO P&C Standard.
the requirements for effective The management of Masai POM & Estates Grouping has conducted
implementation of MSPO and MRM on 22 October 2021, which was chaired by Executive Director
decide on any changes, and attended by General Manager (Plantation), Sustainability
improvement, and modification. Personnel, all key personnel of mill and estates.
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The meeting was discussed on Results of Internal Audits, Customer

(Internal/External) Feedback, Process Performance and Product
Conformity, Status of Preventive and Corrective Actions, Follow-Up
Actions from Management Reviews, Changes That Could Affect the
Management System, Recommendations for Improvement.
The minutes for all meetings were available for verification. Overall,
the MRM conducted found to be effectively conducted.
4.1.4: Continual Improvement
4.1.4.1: The action plan for Action plans for continual improvement at the POM were Complied
continual improvement shall be documented, implemented, and monitored. Amongst the
based on a consideration of the improvement has been impleted are:
main social and environmental ▪ upkeep effluent pond by concrete piling between Pond 1 and
impact and opportunities for the Pond 2
company. ▪ upkeep mill building by installing provision roof, v-crimp, and lip
channel.
In term of social parts, main contribution of the POM to the local

development was demonstrated in the provision of facilities and
monetary contributions, where feasible. Some of the examples are
as listed below:
▪ Provision of domestic water supply by Syarikat Air Johor (SAJ)
to Keck Seng housing quarters.
▪ In progress to upgrade kindergarten within complex with new
white board and emergency door.
▪ Provision of playground and community hall at KS Quarters
▪ Continuous contribution to students staying in the workers
quarters by subsidising the school bus and tutorial classes fees.
▪ Continuous contribution to the local religious communities, e.g.,
mosques and temples.
▪ Continuous contribution to surrounding villages, e.g., supplying
water during festivities, donation for sports tournaments.
4.1.4.2: The company should Action plans for continual improvement at the POM were Complied
establish a system to improve documented, implemented and monitored.
practices in line with new ▪ Installation of one unit of Electrostatic Precipitator System
information and techniques; and (ESP) to reduce dust emission limit to < 150 mg/Nm3 under the
for disseminating this Environmental Quality (Clean Air) Regulation 2014.
information throughout the ▪ Construction and commissioning a tertiary polishing plant to
workforce. achieve BOD level < 20 ppm as per DOE requirement.
▪ Effluent treatment plant upgrading.
▪ Replace air preheater at boiler 6.
Principle 2: Transparency
4.2.1: Transparency of Information and Documents Relevant to MSPO Requirements
4.2.1.1: The management shall The management has adopted an open and transparent method of Complied
communicate adequate communication and consultation when dealing with relevant parties
information to other e.g., its workers, government agencies, contractors, neighbouring
stakeholders on environmental, plantations by personal invitation to attend the internal and external
social and legal issues relevant stakeholders’ consultation meetings.
to sustainable practices in the Languages used in written communications are in Bahasa Malaysia
relevant languages and forms. and English, coupled with verbal native dialects.
Information related to Keck Seng (M) Sdn Bhd. was communicated
during external stakeholder’s consultation on 7 October 2021 as
sighted in “Maklumbalas Stakeholder” and “Akuan Penerimaan Dasar
Polisi Syarikat” by Head of Villagers Kg. Kong Kong Laut.
4.2.1.2: Management Management documents such as Policies, Stakeholder consultation Complied
documents shall be publicly processes, Financial Annual Reports are available upon request and
available, except where this is at the Keck Seng (M) Berhad website: masai.keckseng.com
prevented by commercial
confidentiality or where
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disclosure of information would Any commercially confidential information will need special request
result in negative environmental before being provided.
or social outcomes.
4.2.2: Transparent Method of Communication and Consultation
4.2.2.1: Procedures shall be Procedures for consultation and communication with the relevant Complied
established for consultation and stakeholders were documented as follows:
communication with the ▪ Procedures to Handle and Response the Request/Enquiries
relevant stakeholders. from Stakeholders” (RSPO-CRI-1.1.2)
▪ Stakeholders Consultation and Communication Procedures
(RSPO-CRI-6.1.1)
▪ Handling of Social Dispute (RSPO-CRI-6.3.1A)
4.2.2.2: The management shall The Mill Manager are responsible for issues raised by local Complied
nominate management officials communities and other affected or interested parties. Sustainability
at the operating unit responsible Manager nominated to coordinate activities of the stakeholders, GCC,
for issues related to Indicator 1 HC, SHC, etc. Sighted appointment letter issued for Ms. Wong Kit
(4.2.2.1). Ying dated 1st February 2021.
4.2.2.3: A list of stakeholders, The list of stakeholders (Doc. No.: RSPO-CRI-1.1.1) was made 20211029-N1
records of all consultation and available during the audit with latest revision on 15th September 2021. (Minor)
communication and records of The stakeholders comprise government agencies such as the Labour
action taken in response to Department, Immigration Department, Safety and Health Department
input from stakeholders shall be etc. Neighbouring estates and smallholders, neighbouring villages,
properly maintained. schools, canteen/shop operators, suppliers, contractors, etc were
also included. The lists provided were used for selection of
stakeholder’s consultation. Stakeholder’s consultation for this audit
was conducted via phone call since the audit was conducted remotely
and to curb the spread of Covid-19. However, it was noted that the
lists were not sufficiently included all relevant stakeholders such as
neighbouring village, and construction site. Some email and phone
numbers provided in the list were also invalid. Therefore, a minor non-
conformance was raised under this indicator.
4.2.3: Traceability
4.2.3.1: The management shall The organisation has established Product Identification and Complied
commit itself to implement and Traceability Procedure (SOP-PRO-02, Rev.03, Date: 13/09/12)
maintain the requirements for related to traceability matters. All information such as the name and
traceability and shall establish a address of the seller/buyer, product(s) identification including the
standard operation procedure applicable supply chain models (mass balance, segregation), the
for traceability. quantity of the products delivered, the loading or delivery date, related
transportation documentation with a unique identification number are
includes into transactions documents between the customer and the
organisation.
4.2.3.2: The management shall The management has conducted regular inspections on compliance Complied
conduct regular inspections on with the established traceability system via internal and external
compliance with the established audits. Sighted group Annual Report 2020 dated 27 April 2021. In
traceability system. addition, sighted Corporate Governance Report submitted to KLSE
dated 31 December 2019 received with no negative responds.
4.2.3.3: The management shall The Palm Oil Mill Organization Charts and job responsibilities of Complied
identify and assign suitable employees (Mill Manager, Engineers, Assistant Engineers,
employees to implement and Technicians, Security Officer, Weighbridge Operator, Laboratory
maintain the traceability system. Chemist, and Clerks) have been suitably defined for the
implementation and maintenance of the traceability procedure.
Interviews of the relevant staff confirmed their knowledge of the
traceability requirements for their respective areas of operations.
4.2.3.4: Records of storage, All records of CPO and PK produced and delivered out, on a daily Complied
sales, delivery or transportation basis, were maintained and verified to be traceable via the Delivery
of crude palm oil and palm Note and Weighbridge Ticket which were maintained at the POM
kernel shall be maintained. office. The POM monitors the stock volumes of CPO in the storage
tanks and PK in the silo on a daily basis and recorded in the Daily
Progress Report.
All PK are supplied to a Kernel crushing plant nearby i.e., Ragamo
Sdn Bhd which is also a subsidiary under the Keck Seng Group.
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The CPO are further processed by another subsidiary, i.e., Keck

Seng Refinery Sdn Bhd, which is also located nearby.
The transaction between the mill and Ragamo based on Sales
Contract which were prepared by mill management and verified by
Ragamo representative.
Principle 3: Compliance to Legal Requirements

4.3.1: Regulatory Requirements
4.3.1.1: All operations shall be Legal register covering the applicable local and international laws and Complied
in compliance with applicable regulations are available at the estate. The relevant legislations
local, national and ratified identified and listed were among others regarding safety and health,
international laws and environmental management, pollution management, chemical
regulations. handling, usage & storage, schedule waste management, labour
laws, Unions, EPF, SOCSO, Housing and Amenities.
Levy and other deductions have been taken with the consent of the
workers in accordance with the Employment Act 1955, FOMEMA
(The Foreign Workers Medical Screening Expert) fees, for the health
screening of foreign workers which was borne by the company and
carried out as per the Ministry of Health guidelines.
Licenses and permits (License for Trading, License for Employment
of Foreign Workers, Workers’ Wages Deduction Permit, Domestic
and Consumer Permit for Keeping Diesel, Petrol & Fertilizer, MPOB
license, DOSH (Department of Occupational Safety and Health)
Certificates, DOE (Department of Environment Permit, etc.) were
renewed and evidenced to be valid.
Among those checked as follows:
1. Licensed Manufacturer as from 30 Dec 1977, License No.: A
000137
2. MPOB License 500026504000 (01/04/2021 – 31/03/2022) for
288,000 mt per year.
3. Majlis Perbandaran Pasir Gudang License No.: L2020072710
until 31/12/2022
4. CF for machineries: JH PMD 908 (valid until 03/02/2022), JH
PMT 1255 (valid until 13/10/2022), JH PMT 1483 (valid until
13/12/2022), JH PMT 1486 (valid until 13/10/2022).
5. DOE License/Jadual Pematuhan: 004716 (validity period
1/7/2021-30/6/2022) for 60mt/hr and method of POME discharge
100% through land irrigation (BOD limit <20 mg/l).
6. Diesel license ref # KPDNKK.J-JB/26/5A/11/340 (P/D) (P13) for
60,100 ltr, valid until 01/09/2022.
7. License to Divert or Abstract River Water ref #
BAKAJ/334/300/05/01/07/01. The maximum amount of water
abstraction allowed: 480 m3/day, until 31 Dec 2021.
8. Competence persons:
• AESP: NW-SRO-AE-R-4466-R, valid until 21/11/2022
• Steam engineer: 162/2013 (2nd grade)
• Boilerman: J127/08 (1st Grade)
• FFB Grader serial no: 01050
• Electrical charge man: A4, PJ-T-4-B-1059-1995
• CePSWaM – certificate of competency: CePSWaM/04000,
certified since 26 Aug 2020
• CePPOME – certificate of competency: CePPOME/00142,
certified since 28 Aug 2020
4.3.1.2: The management shall The organization has listed all local and international laws applicable Complied
list all relevant laws related to to their operations in a Legal Requirements Register (LRR) in
their operations in a legal softcopies and its Intranet. The list was updated in October 2021.
requirement register.
4.3.1.3: The legal requirements The organization has placed soft copies of the local and international Complied
register shall be updated as and laws applicable to their operations and maintain a list of laws in a
when there are any new Legal Requirements Register (LRR) in its intranet. This legal register
includes Minimum Wages Order 2020, OSH (Noise Exposure)
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amendments or any new Regulations 2019, Workers Minimum Standard of Housing and
regulations coming into force. Amenities (Nurseries) (Amendment) Regulations 2020, Prevention
and Control of Infectious Diseases (Measures within the Infected
Local Areas) Regulations 2020, and Prevention and Control of
Infectious Diseases (Measures within the Infected Local Areas)
(Movement Control) (Amendment) Regulations 2021. Thus, previous
year non-conformance has been closed.
4.3.1.4: The management Tracking of regulatory requirements and communication of changes Complied
should assign a person is performed by the KM Leong (HR Executive).
responsible to monitor The documents are available to all levels of management.
compliance and to track and
update the changes in
regulatory requirements.
4.3.2: Land Use Rights
4.3.2.1: The management shall Communities surrounding the company POM and plantation areas Complied
ensure that their oil palm milling are able to move freely without any issues or problems. Verified
activities do not diminish the during site inspection that no such limitations had occurred.
land use rights of other users.
4.3.2.2: The management shall The POM is located within Keck Seng Estate. Copies of the land titles Complied
provide documents showing of Keck Seng Estate were maintained and noted to be legally owned
legal ownership or lease, by the Keck Seng (M) Berhad.
history of land tenure and the
actual legal use of the land.
4.3.2.3: Legal perimeter Locations of several boundary stones and markers were visited and Complied
boundary markers should be verified to be within the boundary perimeter of the POM.
clearly demarcated and visibly
maintained on the ground,
where practicable.
4.3.2.4: Where there are, or Verified that there was no dispute on the land occupied by the POM. Complied
have been disputes, As such, the process of fair compensation and FPIC is currently not
documented proof of legal required to be applied.
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).
4.3.3: Customary Rights
4.3.3.1: Where lands are Not applicable as this is titled land which are not encumbered by Not
encumbered by customary customary rights. Applicable
rights, the company shall
demonstrate that these rights
are understood and are not
being threatened or reduced.
4.3.3.2: Maps of an appropriate Not applicable as this is titled land which are not encumbered by Not
scale showing extent of customary rights. Applicable
recognized customary rights
shall be made available.
4.3.3.3: Negotiation and FPIC Not applicable as this is titled land which are not encumbered by Not
shall be recorded, and copies of customary rights. Applicable
the relevant agreements should
be made available.
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Principle 4: Social Responsibility, Health, Safety and Employment Condition

4.4.1: Social Impact Assessment (SIA)
4.4.1.1: Social impacts should Social Impact Assessment (SIA) report and Management Plans for Complied
be identified, and plans should the unit were originally documented by an external party, i.e. Wild
be implemented to mitigate the Asia, in June 2012 and in September 2017. The plan developed in
negative impacts and promote the SIA has been reviewed annually by the unit since then with latest
the positive ones. review on 5/7/2021. The plans developed includes monitoring of
negative impacts and enhancement of positive ones.
Stakeholder consultation for Keck Seng group was conducted on
7/10/2021 via informed letter to relevant stakeholders including
suppliers, contractors, neighbouring estates, transporters,
government agencies, etc. Letter of response and monitoring records
were retained and made available as evidence that actions had been
taken.
4.4.2: Complaints and Grievances
4.4.2.1: A system for dealing In dealing with complaints and grievances, the management had Complied
with complaints and grievances established “Social Policy” in 16 July 2020 for English Version and
shall be established and revised on 15 September 2021 for Malay Version, both signed by the
documented. Managing Director, Datuk Ho Kian Hock. In the third point of the policy
mentioned grievances from the stakeholders will be resolved fairly
according to written procedures and policies.
In addition, the PMU also established a few procedures related to
complaints and grievances as listed below.
1. Procedures “To Handle and Response the Request/Enquiries
from Stakeholders” (RSPO-CRI-1.1.2)
2. Stakeholders Consultation and Communication Procedures
(RSPO-CRI-6.1.1)
3. Handling of Social Dispute (RSPO-CRI-6.3.1A)
A Complaints / Grievance Register is maintained. Verified that issues
registered are mainly on housing repairs, road conditions, water and
electricity disruptions, etc. The complaints are reviewed with
appropriate actions taken and recorded.
4.4.2.2: The system shall be The procedure and flowchart outlined the mechanism whereby all Complied
able to resolves disputes in an complaints or grievances will be received and be acted upon by the
effective, timely and appropriate Social Liaison Officers who will investigate the matter and resolve
manner, which is accepted by with the affected parties. Complaints and grievances are investigated,
all parties. addressed and resolved based on their severity. Minor complaints
will normally be resolved within 2-3 working days, whilst major
complaints and grievances will be resolved based on priority and
budget availability. No complaints related to sexual harassment
received so far, but the procedures stated such issues will be handled
with the utmost privacy and confidentiality by the Gender Committee
(GC). Sampled Latest GC meeting minutes was dated 18/10/2021.
Verified that there were no instances of any serious disputes.
4.4.2.3: A complaint form All complaints and grievances received are documented either in the Complied
should be made available at the form of meeting minutes, e.g. GC, Safety and Health meetings and
premises, where employees annual stakeholder consultations or complaint forms. Decisions and
and affected stakeholders can actions/responses to the complaints and grievances received are
make complaints. documented with sufficient supporting documents. Other than
reports made to the gender representatives, all other complaints and
grievances are accessible to public. It was noted that complaints can
be made to many different venues for the workers to raise their
concerns to the management, especially through frequent meetings
between workers and the management.
4.4.2.4: Employees and The Management informed the invited employees and surrounding Complied
surrounding communities communities at the internal and external stakeholders’ consultations
should be made aware of its regarding their complaint / grievance procedures and feedback
existence and that complaints mechanism. Stakeholder consultation session for Keck Seng group
or suggestions may be made at was conducted on 7 October 2021 via Informed Letter. Participation
any time. of external stakeholders were verified based from Letter of Response
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from contractors, suppliers, government agencies, police,

neighbouring estates, etc.
4.4.2.5: Complaints and The complaint forms that recorded the nature of complaints and the Complied
solutions within the past 24 resolutions had been maintained and available for the past 3 years.
months shall be documented
and be made available to
affected stakeholders upon
request.
4.4.3: Commitment to Contribute to Local Sustainable Development

4.4.3.1: Palm oil millers should Main contribution of the POM to the local development was Complied
contribute to local development demonstrated in the provision of facilities and monetary contributions,
in consultation with the local where feasible. The mill management is also encouraging their
communities. Where the mill is workers to be actively participating in activities conducted by the
an integral part of a plantation, surrounding communities.
such contribution to local 1. Continuous contributions to nearby schools especially in term of
community development may permission to use field roads for sports activities, teaching
be regarded as a joint effort by materials, sports equipment, music instruments, study visit to the
the mill and the plantation. POM. Face masks and chemical reading equipment were also
donated to the nearby schools during river contamination
incidents occurred in the area.
2. Continuous contribution to students staying in the workers
quarters by subsidising the school bus and tutorial classes fees.
3. Continuous contribution to the local religious communities, e.g.,
mosques and temples.
4. Continuous contribution to surrounding villages, e.g., supplying
water during festivities, donation for sports tournaments.
5. Continuous support to local contractors which quite a few are
already in business with the mill for more than one generation.
4.4.4: Employees Safety and Health
4.4.4.1: An occupational safety Occupational Safety and Health (OSH) plan in compliance with Complied
and health policy and plan Occupational Safety and Health Act 1994, its regulations and the
which is in line with approved industrial codes of practice was documented and
Occupational Safety and Health implemented.
Act 1994 and Factories and Keck Seng (Malaysia) Berhad has established Safety and Health
Machinery Act 1967 (Act139) Policy, dated 1/4/2018 (Version 6) signed by General Manager. OSH
shall be documented, effectively Policy found to be clearly displayed at POM and in the estates office.
communicated, and Adequate posters, regulations, newsletters were prominently
implemented. displayed on notice boards. Interviewed workers demonstrated
awareness towards occupational safety and health.
The Safety & Health Officer is in charge of safety and health planning,
operation and coordination. Mill Manager and Estate Managers /
Assistants are also directly involved.
The OSHA Plan include the establishment and implementation of
CHRA, medical surveillance, health checks, Emergency Drill, First
Aid training, Line site Inspection, Chemical Store Inspection,
Audiometric test, PPE training, etc.
POM has also conducted the annual Emergency Preparedness and
Response (EPR) drill.
Programmes for protecting workers’ health and safety were
satisfactorily implemented.
Safety audits conducted at quarterly intervals as part of the
Sustainability Operation Audit for the estates.
4.4.4.2: The occupational safety Keck Seng (Malaysia) Berhad has established Safety and Health 20211029-M1
and health plan shall cover the Policy, dated 1/4/2018 (Version 6) signed by General Manager. (Major)
following: Safety and health policy briefing was conducted accordingly to the
a) A safety and health policy, workforce. On the other hand, the management had displayed the
which is communicated policy on the notice board. Through interview with workers, they were
and implemented. understood on issue related to OSH and MSPO.
Risk assessment carried out on all operations, where health and
safety are an issue, in order to determine the significant hazards and
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b) The risks of all operations implement control measures. Significant hazards determined and
shall be assessed and documented include noise exposure, pesticides/chemicals, accident,
documented. fire, fuel spillage, working at heights, working in enclosed space, hot
c) An awareness and training work, lightning, electrocution, machinery, etc. Control measures
programme which includes include the use of PPE, fire drill training, first aid training, etc. and
the following requirements “permit to work system” for the mill.
for employees exposed to SOP for coronavirus disease of 2019 (Covid-19) was established by
chemicals used at the palm the management of Keck Seng (Malaysia) Bhd in March 2020. This
oil mill: procedure was identified all the requirement to handle this issue
i) all employees involved (Covid-19), including personal hygiene, social distancing, quarantine
are adequately trained procedure, estate operations and mill operations. MITI approval to
on safe working operate the business for Keck Seng (Malaysia) Berhad has been
practices; and granted on 19/6/2020 for all complex.
ii) all precautions SOP for HIRARC is based on DOSH guidelines. Revision was done
attached to products on accordingly for mill activity which include FFB grading, loading
should be properly ramp, capstan, sterilization, crane, threshing press station, kernel
observed and applied. crusher plant, oil room, boiler/powerhouse, effluent, workshop etc.
d) The management shall Verified that additional HIRARC reviews also made by the Safety &
provide the appropriate Health team upon occurrence of incidences or accidents.
personal protective CHRA was conducted on 14/9/2015 until 24/11/2015 by NM
equipment (PPE) at the Laboratory Sdn Bhd. Based on the report (CHRA(J)/15-09/02), the
place of work to cover all work unit for production, laboratory, store, water treatment plant,
potentially hazardous boiler. The action plan based on recommendation by the assessor
operations as identified in was established and monitored accordingly.
the risk Audit and control Medical surveillance for POM was conducted 19-22/7/2020 by Klinik
such as Hazard Malaysia (HQ/08/DOC/00/567) for respective workers. Based on the
Identification, Risk Audit reports, all workers were found fit to work.
and Risk Control Airborne contamination for chemicals hazardous to health monitoring
(HIRARC). was conducted on 21/5/2020 by Eurofins NM Laboratory Sdn Bhd
e) The management shall (HQ/17/JHI/00/00011). Based on the report, the monitoring exercise
establish Standard has indicated that the exposure level of airborne contaminants for the
Operating Procedure for selecte workers did not exceed the permissible exposure limit as
handling of chemicals to stipulated under the Schedule I of Occupational Safety and Health
ensure proper and safe (USECHH) Regulations 2000.
handling and storage in Inspection, Testing and Assessment of LEV System was conducted
accordance to on 4/12/2019 by Tekun EOSH Sdn Bhd (HQ/11/JHII/00/178). Based
Occupational Safety Health on the report, face velocity and duct velocity of fume hood cupboard
(Classification Packaging are accepted for their operation activities.
and Labeling) Regulation Monthly LEV monitoring was conducted accordingly by the
1997 and Occupational management to check on the cleanliness, lighting, and fan system by
Safety Health (Use and Lab Operator.
Standard of Exposure of
Chemical Hazardous to Baseline Noise Risk Assessment for Masai POM was conducted on
Health) Regulation 2000. 15/11/2019 by OSH Safety & Health Services (HQ/14/PEB/00/38).
Work areas with high noise levels had been identified, viz., boiler
f) The management shall station, engine room, sterilization unit and kernel press where noise
appoint responsible level exceeded 82 db. Mill management have taken steps to reduce
person(s) for workers' the noise levels by more frequent lubrication of machinery, reducing
safety and health. The the exposure time to high noise and mandatory use of ear plugs and
appointed person(s) of trust ear mufflers. Warning signs sighted at high noise areas and ear plugs
shall have knowledge and and ear mufflers to be worn. There are also warning signs to use other
access to latest national PPE such as helmet and safety boots.
regulations and collective
agreements. Audiometry is an important part of Industrial Code of Practice (ICOP),
under the ICOP Management of Occupational Noise Exposure and
g) The management shall Hearing Conservation Program 2019. The purpose of this screening
conduct regular two-way audiometry is to detect the presence of Occupational Noise Related
communication with their Hearing Disorders (ONRHD) which is reportable under the ICOP. All
employees where issues suspected ONRHD cases will be recommended to undergo medical
that affect their business examination (ME) by the same Occupational Health Doctor (OHD).
such as those related to Annual and baseline audiometric test was conducted on
employees’ safety, health 13/27/11/2019 for 207 workers by Central Clinic
and welfare are discussed (HQ/15/DOC/00416). Based on the report there was no workers
openly. Records from such found with hearing impairment and standard threshold shift. The
meetings shall be kept and employees exposed to high noise levels were interviewed. The
the concerns of the workers are aware of the danger of hearing loss due to prolonged
employees and any
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remedial actions taken exposure to high noise. The workers knew about the complaints
shall be recorded. process and mechanism available.
h) Accident and emergency
procedures shall exist and A formal training programme on all aspects of OSH and MSPO has
instructions shall be clearly been established and implemented. Training for various categories of
understood by all operators, including all field and office staff, with regards to individual
employees. duties and training needs had been reviewed and found to be
i) Employees trained in First complied. The records of training were available at estate office.
Aid shall be present at all
mill operations. First Aid Suitable PPE has been provided to the workers based on the
equipment should be information in the SDS, CHRA recommendation, and outcome of
available at each worksite. HIRARC assessments. During site visit, it is noted that all workers are
using appropriate PPE that has been issued to them, according to
j) Records shall be kept of all their assigned job e.g.: Sterilizer Station, Press Station, loading ramp,
accidents and be reviewed oil room, and boiler. According to the interviewed workers, the PPE
periodically at quarterly issued to them are provided free of charge. Management maintaining
intervals. the PPE issuance record by individual workers.
The operating unit comply with Regulation requiring balance of

remaining solution to be kept under lock and key. During visit it at
chemical store, it was noted that all the chemicals are kept in the store
and securely locked and comply with regulation.
The responsible persons are the Manager and Assistant Manager of

the mill. Safety committee appointment letter was verified.
JKKP meeting members consist of employer & employee

representatives. Records of regular meetings between the
responsible person and workers were maintained. There was no
major issue. All the agenda was discussed accordingly during OHS
meeting.
Accident and emergency procedure was established, i.e., POM

Emergency Response Plan Procedure (SOP-ERP-01, Rev:02, Date:
3/5/2017). Accident and emergency procedures had been briefed to
staff, workers, contractors, and visitors. During interview with the
workers, they understand and explained well to the auditor on how
they need to do when accident and emergency happened.
Management of mill also provides fire extinguishers, which located at
strategic places, e.g., housing area, storage area, skid tanks area,
etc. Fire hose also provided at boiler area, sterilizer area. All workers
area trained with management conducted fire drill which latest on
13/1/2020.
Records of incident and accident were available. JKKP 8 was

submitted to DOSH accordingly through MyKKP.
The first aid kits available at worksites, such as boiler station, mill
workshop, mill loading ramp, FFB grading station, sterilizer station,
and office.
First aiders competency certificate available. Workers trained in First
Aid were present in the mill and field operations. Training for workers
in First Aid was carried out in the mill and records maintained.
However, the number of First-aiders available at POM is inadequate
compared to the Number of First-aiders Required under the
Guidelines on First-Aid in Workplace (2nd Edition) by the Department
of Occupational Safety and Health (DOSH) Malaysia. Therefore, a
major non-conformance has been raised under this indicator.
4.4.5: Employment Conditions

4.4.5.1: The management shall In dealing with human rights, the group had established “Social Complied
establish a policy on good Policy” signed by its Manager Director which covered the necessary
social practice regarding human aspects of human rights related issues. Among others, it states
rights in respect of industrial company’s commitment to treat people fairly irrespective of race,
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harmony. The policy shall be gender, caste, national origin etc, prohibit retaliation against Human
signed by the top management Rights Defenders (HRD), respect formation of trade unions etc. The
and communicated to the employees are informed through briefing during muster, or during
employees. Gender Committee (GC) and Joint Consultative Committee (JCC)
meetings. The policy is also displayed at notice boards in the office.
Evidences that the workers understood the policies regarding human
rights were observed in the estates through their actions and
explained in different parts of this report, examples.
• Rights for equal treatment – all workers understood that they
must be paid based on the minimum wages set by the
government, they are provided with and have been utilising their
medical coverage, they are entitled for paid annual leave, public
holidays and sick leave, etc.
• Right for freedom to practice religious obligations – All Muslim
workers understood they are allowed to perform Friday pray
every week and non-Muslim workers understood they are
allowed to stay in their belief.
• Rights for freedom of speech –workers understood they are
represented by the Joint Consultative and have been
participating in meetings to express their concerns on their well
beings.
Rights to freedom of movement – All foreign workers understood they
are to keep their own travelling documents safe while in their custody.
They also understood they must comply that their passport must be
returned to the office for work permit renewal purposes.
4.4.5.2: The management shall In dealing with non-discriminatory practices, the Social Policy Complied
not engage in or support statements adopted by the PMU as mentioned above recognises
discriminatory practices and equal opportunity. The first point of the policy mentioned as follows:
shall provide equal opportunity “To treat our people fairly in term of recruitment, progression, terms
and treatment regardless of and conditions of work and representation, irrespective of race, ethnic
race, colour, sex, religion, origin, caste, national origin, gender, colour, disability, sexual
political opinion, nationality, orientation, gender identity, union membership, political affiliation,
social origin, or any other religion and /or age.“
distinguishing characteristics.
4.4.5.3: Management shall Employment contract with all benefit provided to workers were briefed Complied
ensure that employees’ pay, accordingly for better understanding. Briefing on minimum wages
and conditions meet legal or were also given accordingly. The employment contracts are all signed
industry minimum standards as by both parties, estates management and workers The employment
per Collective Agreements. The contract verifies RM1,200 per month and RM46.15 per day under
living wage should be sufficient Order 4 MWO for areas in any City Council or Municipal Counsel and
to meet basic needs and under Order 5 MWO 2020 for piece rated workers. Payslip review
provide some discretionary and verify there are no wages paid below the Minimum Wages Order
income based on minimum 2020. Overtime rate (during normal overtime, rest day overtime and
wage. public holiday overtime) was paid accordingly. This were verified
through sample payslip for February, May and September 2021.
4.4.5.4: Management should At the POM, no incident where workers received less than stipulated Complied
ensure employees of minimum wages due to allowable and approved deductions, e.g.,
contractors are paid based on SOCSO, EPF, payments for personal loans or insurances. All
legal or industry minimum workers are paid on monthly basis and workers non-attendances are
standards according to the either covered with annual or medical leaves applications. Sample
employment contract agreed contractors Hoh Boon Hock Construction paid his workers
between the contractor and his accordingly.
employee.
4.4.5.5: The management shall The management had maintained a site-specific list that provide an Complied
establish records that provide accurate record of employees. This includes their full names,
an accurate overview of all Employee ID, Nationality, IC or Passport No., Gender, Date of Birth,
employees (including seasonal Date Joined, Age, Job Description and Wages Payable. A brief
workers and subcontracted information on job description was contained in the employment
workers on the premises). The contract signed by both parties.
records should contain full
names, gender, date of birth,
date of entry, a job description,
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wage and the period of

employment.
4.4.5.6: All employees shall be All employees are provided with employment contracts in accordance Complied
provided with fair contracts that with the regulations. The terms of employment are clearly specified
have been signed by both in the contracts and in the collective agreement, which included
employee and employer. A position offered, period of employment, salary, overtime rate, rest
copy of employment contract days every Sundays, rate of pay when working on rest days, days
shall be made available for and hours of work, approved deductions, termination of employment,
each and every employee holiday pay, rate of pay when working on holidays, leave pay, sick
indicated in the employment leave, maternity leave, etc. The job offer is signed by the Mill
records. Manager or his Assistant and the employee. Sample employment
contract for KSOP093. Interview with the employees confirmed that
they received a copy of the employment contract.
4.4.5.7: The management shall The management had installed a time recording machine that records Complied
establish a time recording the working hours and is linked to the database containing the details
system that makes working of each employee.
hours and overtime transparent Data recorded by the time recording machine are used for calculating
for both the employees and the working hours and overtime. Sampled sighted was for worker
employers. KSOP093 for the month of February, May and September 2021.
Total overtime recorded was within permissible amount. Permission
from Labour Department for overtime up to 124 hours dated 18 July
2019, BHG. PU/9/134/ Jld 22(24) was sighted.
4.4.5.8: The working hours and The working hours of the employees and overtime rates are specified Complied
breaks of the individual worker in the employment contract, i.e., 8 hours per day. The working hours,
indicated in the time records breaks and overtime rates are in accordance with the regulations.
shall comply with legal
regulations and collective
agreements. Overtime shall be
mutually agreed upon and shall
meet the legal requirement
applicable.
4.4.5.9: Wages and overtime Pay slips clearly showed the basic pay, number of days worked, any Complied
payment documented on the allowable deductions and net amount. Any payments for overtime,
pay slips shall be in line with public holiday, rest day whenever applicable, are also shown on the
legal regulations and collective pay slips.
agreements.
4.4.5.10: Other forms of social The employees are offered shift incentives, training, access to Complied
benefits should be offered by medical care and other benefits such as free housing and subsidised
the employer to employees, water from Syarikat Air Johor (SAJ) and electricity supplies. The free
their families or community medical services covered the workers and their dependents.
such as incentives for good
work performance, bonus
payment, support of
professional development,
medical care provisions and
improvement of social
surroundings
4.4.5.11: In cases where on-site The estates complied with the Workers’ Minimum Standard of Complied
living quarters are provided, Housing and Amenities Act 1990 (Act 446) by providing adequate
these quarters shall be housing, water supplies, medical, educational, and public amenities
habitable and have basic to their local workers. Workers are provided with free living quarters
amenities and facilities. constructed of permanent materials that have living rooms,
bedrooms, kitchen, and toilets. All the houses are supplied with
adequate treated water from the estates owned water treatment
facility or main public work and electricity. Housing inspection was
conducted accordingly by EHA and Visiting Medical Officer (VMO)
once a month. Among those check including sanitation, hygiene and
safety aspects.
There is no landfill at the estate. Domestic waste is collected and
disposed by a contractor at a site monitored by DOE.
4.4.5.12: The management Policy to prevent sexual and other forms of harassment and violence Complied
shall establish a policy to are documented in Keck Seng (M) Berhad Social Policy signed by its
prevent all forms of sexual
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harassment and violence at the Managing Director. The policy spells out the Company’s commitment
workplace. as follows:
“To prevent sexual harassment and all other forms of violence against
women and to protect their reproductive rights. This commitment shall
not only apply in workplaces but also in society at large. We are
committed to our employees, visitors, clients, customers and
contractors entering our premises to ensure their safety and
preventing from any sexual harassments.”
It was noted that policy was communicated to all level of workforce.
4.4.5.13: The management The published statement recognising right of all employees to form or Complied
shall respect the right of all join trade union is available in the Social Policy. The implementation
employees to form and join of this can be seen through formation of Joint Consultative Committee
trade union and allow workers’ (JCC) where workers are free to elect their own representatives and
own representative(s) to to represent themselves in JCC Meeting. Results of meetings were
facilitate collective bargain in recorded, and the minutes are available for verification. Workers’
accordance with applicable representatives are from different job description such as general
laws and regulations. workers, drivers, laboratory, workshops, etc. Sampled JCC meeting
Employees shall be given minutes was dated 20/10/2021. Workers managed to raised their
freedom to join trade unions concerns accordingly and evident of action taken.
relevant to the industry or
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.
4.4.5.14: Children and young In the 7th Point of Social Policy states that the Company would never Complied
persons shall not be employed engage forced labour or trafficked labour or child labour who is less
or exploited. The minimum age than 16 years. This policy is widely available at the office estates and
shall comply with local, state at the workers quarters and verified to acknowledge by workers
and national legislation. during interview. There was no evidence of any child labour being
used at the estates audited. Inspection of the employment records
including site visit to the estate fields confirmed that this requirement
has been complied with.
4.4.6: Training and Competency

4.4.6.1: All employees and Training programme planned for year 2021 includes training for all Complied
contractors shall be categories of workers. Appropriate trainings on safe working
appropriately trained. A training practices are planned for workers exposed to machinery, harvesters,
programme shall include pesticides operators and manure applicators.
regular Audit of training needs The training programme included the various types of training such
and documentation, including as firefighting and fire drill, understanding SDS, first aid training as
records of training. well as company’s policies. The trainings were conducted for year
2021 and evaluation carried out on each of the trainings to determine
its effectiveness. Records of training for each employee, including
new employees were maintained.
4.4.6.2: Training needs of A formal training programme on all aspects of MSPO requirements Complied
individual employees shall be have been established and implemented.
identified prior to the planning Training for various categories of operators, including all operation
and implementation of the and office staff, with regards to their duties and training needs had
training programmes in order to been reviewed and found acceptable.
provide the specific skill and
competency required to all
employees based on their job
description.
4.4.6.3: A continuous training Training programme planned for year 2021 includes training for all Complied
programme shall be planned categories of workers. Trainings were conducted based on categories
and implemented to ensure that of workstations.
all employees are well trained in
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their job function and The training programme included the various types of training such
responsibility in accordance to as firefighting and fire drill, exposure to high noise levels and control
the documented training measures for protection of hearing and audiometric tests,
procedure. understanding SDS and first aid training as well as social aspects,
environmental aspects, sustainability aspects, and company’s
policies.
Principle 5: Environment, Natural Resources, Biodiversity and Ecosystem Services

4.5.1: Environmental Management Plan
4.5.1.1: An environmental policy Keck Seng (M) Berhad subscribe to Environment Policy signed by its Complied
and management plan in Managing Director (Issue Date: 07 October 2011, Revision: 0). The
compliance with the relevant policy on environment was developed in accordance with the relevant
country and state environmental country and state laws. The policy was communicated to all levels of
laws shall be developed, the workforce through briefings and placement of the policy on notice
effectively communicated, and boards.
implemented.
4.5.1.2: The environmental The Environmental Management Plan was reviewed in September Complied
management plan shall cover 2021. No addition was made to the EIA. It included the environmental
the following: policy and also the objectives.
a) An environmental policy The Environmental Aspects and Impacts Assessment (EIA) was
and objectives. conducted and documented. No changes made to the aspect and
b) The aspects and impacts impacts as the process remained the same. The scope of
analysis of all operations. assessment had included issues such as the management of mill
effluents, maintenance of roads, drainage system, transportation of
FFB, schedule waste and garbage disposal, accordingly to the local
requirements. The EIA report had also included the action plans and
recommendations to mitigate the negative effects and to promote the
positive ones. The assessment had also included the relevant
stakeholders to identify impacts and develop the mitigation measures
such as relevant conservation activities.
4.5.1.3: An environmental The EIA document had also included the development of the Complied
improvement plan to mitigate Environmental Improvement Plan for the mitigation of negative
the negative impacts and to impacts and promotion of positive impacts. Buffer zones along the
promote the positive ones, shall mill reservoir were demarcated. Maintenance and clearing of
be developed, effectively overgrown natural vegetation and debris along the reservoir in the
implemented, and monitored. mill, meant for mill and domestic use, was also carried out.
Desludging of effluent ponds, installation of CCTV, screw press for
BOD reduction, were included as improvement in the plan.
The POME and EFB were delivered/recycled to the plantation for
fertiliser and moisture retention purposes.
The implementation and monitoring of the documented
environmental improvement plan were found to be satisfactorily
implemented.
4.5.1.4: A programme to The programme to promote the positive impacts is mostly Complied
promote the positive impacts concentrated on the reduction of BOD level at the final discharge.
should be included in the This is included in the continual improvement plan for the installation
continual improvement plan. of ESP (electrostatic precipitator) to the mill.
4.5.1.5: An awareness and There were a number of training programmes established and being Complied
training programme shall be implemented. Apart from the Environmental Awareness policy and
established and implemented to objectives training, schedule waste training, Chemical
ensure that all employees stocking/stacking were also included and trained to the affected
understand the policy and employees.
objectives of the environmental
management and improvement
plans and are working towards
achieving the objectives.
4.5.1.6: Management shall Regular meeting has already in place to discuss environmental Complied
organize regular meetings with issues. The meeting is to be held at least once in every three months.
employees where their
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concerns about environmental The latest meeting was conducted on 7/10/2021 and found to be
quality are discussed. effective.
4.5.2: Efficiency of Energy Use and Use of Renewable Energy
4.5.2.1: Consumption of non- Usage of non-renewable energy is monitored monthly. Record on the Complied
renewable energy shall be usage of diesel and electricity is available for review. Monthly records
optimized and closely on the consumption were maintained for comparison to optimize the
monitored by establishing use of the non-renewable energy at the POM.
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.
4.5.2.2: The oil palm premises Records on the usage of non-renewable energy for machineries Complied
shall estimate the direct usage involved in the mill operations were maintained and available. Diesel
of non-renewable energy for usage for office vehicle was also recorded and monitored. Data is
their operations, including fossil being compiled for comparison and monitored to optimize efficiency
fuel, and electricity to determine on the use of non-renewable energy. Records maintained had
energy efficiency of their showed proper control of the fuel usage.
operations. This shall include
fuel use by contractors,
including all transport and
machinery operations.
4.5.2.3: The use of renewable At the POM, use of renewable energy is mainly in the use fibre and Complied
energy should be applied where shell as fuel for the boiler.
possible.
4.5.3: Waste Management and Disposal
4.5.3.1: All waste products and All waste products and sources of pollution were identified and Complied
sources of pollution shall be documented.
identified and documented. The documentation and identification of all the waste products such
as scheduled waste, domestic waste, clinical waste and recyclable
waste such as metal, plastic, mill waste and polluting materials e g.
EFB, POME, stack emissions and boiler ashes were maintained and
monitored.
Scheduled Waste identified included spent lubricant oil (SW 305),
spent hydraulic oil (SW 306), used chemical containers/drums (SW
409), used filters (SW 410), clinical waste (SW 404) and used
batteries (SW 102), amongst others. All Scheduled Waste identified
were labelled accordingly.
4.5.3.2: A waste management A waste management and disposal plan has been documented and Complied
plan to avoid or reduce pollution implemented. Segregation of wastes, i.e., general wastes and
shall be developed and scheduled wastes was verified to be satisfactory carried out in the
implemented. POM. Proper storage areas were identified for the storage of the
The waste management plan recyclable wastes at the POM.
should include measures for: Schedule waste disposal was done by an appointed contractor that is
a) Identifying and monitoring licensed by the Department of Environment.
sources of waste and The solid waste management and disposal plan for household waste
pollution. is subcontracted to Urus Kekal Enterprise and disposal was to sites
b) Improving the efficiency of approved by local authority. Disposal chit to the site was made
resource utilization and available during the audit. Recycling of crop residues / biomass i.e.,
recycling of potential EFB, kernel shell, and POME (decanter cake) had been
wastes as nutrients or implemented. It was also verified previous year non-conformance has
converting them into value- been satisfactorily closed and no occurrence of the same issue in
added by-products. current audit.
4.5.3.3: The management shall Standard operating procedure for the handling of used chemicals Complied
establish Standard Operating classified as Scheduled Waste has been developed and adhered to
Procedure for handling of used accordingly. No changes made to the procedure. Record on the
chemicals that are classified usage and disposal were well recorded and documented at the POM.
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under Environment Quality Schedule waste was disposed of by a DOE license contractor,
Regulations (Scheduled Waste) Modern Energy Sdn Bhd in accordance with the EQA requirement.
2005, Environmental Quality
Act, 1974 to ensure proper and
safe handling, storage, and
disposal.
4.5.3.4: Domestic waste should The disposal of household waste was contracted out to third party Complied
be disposed as such to handlers and the disposal is in accordance to the rules and regulation
minimize the risk of of the local authority. No landfill practise being conducted here.
contamination of the
environment and watercourses.
4.5.4: Reduction of Pollution and Emission
4.5.4.1: An assessment of all All polluting activities were assessed through the aspect and impact Complied
polluting activities shall be method and are documented. The activities are inclusive of green gas
conducted, including emissions, chemicals, fertilizer, scheduled waste, solid waste, and
greenhouse gas emissions, household waste.
scheduled wastes, solid wastes Data relating to such activities were collected and analysed. GHG
and effluent. emissions calculation is up to date and has been compiled for Jan-
Dec 2020.
4.5.4.2: An action plan to The action plan has been established and implementation is ongoing. Complied
reduce identified significant Improvement such as on consumption of diesel, stack sampling
pollutants and emissions shall monitoring, ambient air quality monitoring is regularly conducted as
be established and required by the DOE.
implemented.
4.5.4.3: Palm oil mill effluent Significant pollutants and greenhouse gas (GHG) emissions were Complied
(POME) shall be treated to identified, e.g., POME, diesel / fuel usage have been documented at
ensure compliance with the POM.
standards as stipulated in the Monitoring and reporting of the significant pollutants to water,
relevant Environmental Quality gaseous emissions to air and contamination on land are available and
(Prescribed Premises) (Crude adhered to and is within the Malaysian Environmental Air Quality
Palm Oil) Regulations 1977. Regulations, 1978 Standard and Limits.
POME discharge limits and Tools and systems used include the DOE online CEMS monitoring
method should be in for air emissions, water quality at discharge points as per DID
accordance with the respective regulations and SW disposal were adhering to DOE requirements.
state and national policies and
regulations. It was verified that the POME is treated using aerobic and anaerobic
ponds, tank digester and tertiary filtration membrane, before the final
discharge. Water samples were regularly taken monthly and tested
by POM environment officer in charge and analysed to ensure
compliance to DOE requirements at the final discharge point. The
discharged water is 100% used for land application into the nearby
estate, Lim & Lim, before going into Sungai Serai.
Water quality analysis of Sungai Serai was conducted monthly.
Records are maintained and verified on-site to have met the
permissible regulatory limits (e.g., BOD < 100 ppm). For the mill, the
reading has always been less than 20 ppm. This was conducted by
Lotus Laboratory Services Sdn Bhd. Records are maintained and
verified on-site to have met the permissible regulatory limits.
Water samples collected and analysis carried out at twice a year for
treated water. The treated water for domestic use meets all the
required parameters, including that of bacterium count (WHO
Specification for Drinking Water Quality).
Ambient air monitoring report was conducted quarterly and the result
complied to the Malaysian Ambient Air Quality Standard.
Monthly report on the environmental monitoring was also done and
submitted to DOE.
4.5.5: Natural Water Resources
4.5.5.1: The management shall A water management plan was reviewed in 2021. There is no named Complied
establish a water management river crossing the estates. There are only small streams that later
plan to maintain the quality and lead to the main river outside the estate boundary, i.e Sungai Serai
availability of natural water and Sungai Johor.
resources (surface and ground
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water). The water management The Water Quality Index of these natural small streams was
plan may include: monitored twice a year. Record on the water quality was made
a) Assessment of water available during the audit. No rainwater harvesting being conducted
usage and sources of at the housing site for other alternative uses.
supply.
b) Monitoring of outgoing
water which may have
negative impacts into the
natural waterways at a
frequency that reflects the
estate’s current activities.
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.).
4.5.5.2: Where open discharge The POME was discharged for land irrigation at the nearest estate Complied
of POME into water course is i.e., Lim & Lim Estate, and not directly into any water courses.
practiced, mills should
undertake to gradually phase it
out in accordance to the
applicable state or national
regulations.
Principle 6: Best Practices

4.6.1: Mill Management
4.6.1.1: Standard operating POM has documented the following SOPs: Complied
procedures shall be (1) POM-PRO-01 Operation of Weighbridge & FFB Grading
appropriately documented and (2) POM-PRO-02 Operation of Loading Ramp
consistently implemented and
monitored. (3) POM-PRO-03 Operation of Capstan
(4) POM-PRO-04 Operation of Sterilizers
(5) POM-PRO-05 Operation of Crane
(6) POM-PRO-06 Operation of Thresher
(7) POM-PRO-07 Operation of Pressing Station
(8) POM-PRO-03 Operation of Deprecaper
(9) POM-PRO-04 Operation of Kernel Plant Recovery
(10) POM-PRO-05 Operation of Clarification
Occupational Safety & Health documents includes hazards

identification, risk assessment and control measures. The hazards
include noise, chemicals, heat, fire, fuel spillage, working at heights,
working in enclosed space, hot work, lightning, electrocution,
machinery, etc. Control measures include the use of PPE, fire drill
training, first aid training, etc. and “permit to work system” for the mill.
Records of ‘Permit to Work’ including gas entry and stand-by permits
issued by NIOSH to the competent personnel at the POM was verified
to be maintained and found to be in order.
Relevant Key Performance Indicators (KPIs) specified for quality,
environment, safety, and cost control.
4.6.1.2: All palm oil mills shall The POM had adhered to its SOPs and Best Management Practices Complied
implement best practices. (BMP).
BMP implemented include:
▪ Water Management QM-WM-01 Rev 01 (25/01/2015)
▪ POM Waste & Pollution Management Plan QM-W&PMP-03 Rev
04 (02/01/2017)
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▪ Recycling – sludge oil and boiler ash

▪ Renewal Energy – 100% biomas burned
4.6.2: Economic and Financial Viability Plan
4.6.2.1: A documented Business Plans for the 3 years (2021, 2022 and 2023) were prepared Complied
business or management plan and available at the Palm Oil Mill and Estates office.
shall be established to Details of the Business Plans for the POM includes the following:
demonstrate attention to (1) Mill extraction rates = OER and KER trends;
economic and financial viability
through long-term management (2) Cost of Production = Cost/MT CPO trends;
planning. (3) Forecast prices;
(4) Financial indicators = Cost of labour, cost of supervision,
depreciation costs, salaries/allowances, cost of materials, etc.).
The Business Plans also include provisions for sustainability efforts

and improvement programmes (environmental, social, Occupational
Safety & Health, training, etc.).
Mill and Estate Managers monitor the operational performance
against Key Performance Indications and targets (costs, FFB yields,
quality, productivity, pesticides usage, fertilizers usage, etc.)
There is evidence of monitoring of costs against budget to achieve
specified targets.
Performances are discussed in the monthly meetings held at the UoC
and issues and actions needed are recorded for follow up in the next
monthly meeting. The records of these meetings were available and
verified during the audit.
Monthly, quarterly, half-yearly and yearly reports are submitted to the
Head Office.
4.6.3: Transparent and Fair Price Dealing
4.6.3.1: Pricing mechanisms for Verified that the POM has signed contracts with the FFB suppliers. Complied
the products and other services The POM applied the pricing mechanism according to PORLA
shall be documented and formula and MPOB prices. There was also no evidence to suggest
effectively implemented. any unfair business practices with the other service providers as seen
in the signed contracts.
4.6.3.2: All contracts shall be Based on contracts agreed between contractors/service providers Complied
fair, legal, and transparent and and the estates, it is evident that all parties understand the contractual
agreed payments shall be made agreements they enter into, and that contracts are fair, legal and
in a timely manner. transparent.
Interview with parties concerned confirmed that business practices
with local businesses were conducted in a fair and transparent
manner. It was further verified that payments to contractors and other
service providers were within the period specified in the contract
agreement.
4.6.4: Contractor
4.6.4.1: In case of the During external stakeholder’s consultations on and during training, Complied
engagement of contractors, the contractors are made to understand MSPO requirements.
they shall be made to Information such as policies and procedures are provided.
understand the MSPO Monitoring records on Road Tax, Driving License and Insurances is
requirements and shall provide available. Checks done on sample basis verified that the licenses and
the required documentation and insurance coverage were still valid.
information.
4.6.4.2: The management shall Contract agreements are signed between the group and the Complied
provide evidence of agreed contractors. The terms and conditions of the contract are explained
contracts with the contractor. to the contractor. A copy of the contract is given to the contractor.
Sighted the agreement by the contractors concerning compliance to
MSPO requirements in the performance of the work task. Sampled
contracts sighted were between estate management with Hock Boon
Huat Construction.
4.6.4.3: The management shall Contract agreement between the mill management and their Complied
accept MSPO approved contractors were reviewed during the audit. However, there is no
auditors to verify the Audits evidence that contractors performing task agreed to be assessed by
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through a physical inspection, if MSPO approved auditors. Therefore, a minor non-conformance has
required. been raised under this indicator.
3.2 Status of Identified Noncompliance and Corrective Actions, Observations and Positive Elements.
The status of the Noncompliance (NC) and Observation (OBS) identified against the MSPO Part 3 Compliance Indicators is
as per the details below:
NC
Audit Type Year OBS Follow Up Status
Major Minor
Annual Surveillance Audit 2021 1 2 1 ▪ 1 Major NC was closed on 27/01/2022 by off-site
(ASA-03) verification due to Covid-19 unsafe condition.
▪ 2 Minor NCs will be verified during next audit
(ASA-04).
Annual Surveillance Audit 2020 1 3 2 ▪ 1 Major NC was closed on 12/01/2021 by off-site
(ASA-02) verification due to travel restriction as the
implementation of Conditional Movement Control
Order (CMCO)
▪ 3 Minor NCs were closed 29/10/2021.
3.2.1 Year 2021 - Annual Surveillance Audit (ASA-03): 1 Major NC

MSPO
NC# Details of Non-Conformance (NC)
Indicator
20211029-M1 4.4.4.2 Date Issued: 29 October 2021
(Major) Requirement:
The occupational safety and health plan shall cover the following:
…………………………………………………………………………..
i) Employees trained in First Aid shall be present at all mill operations. First Aid equipment
should be available at each worksite.
…………………………………………………………………………..
Statement of Nonconformance:
Number of First-aiders are inadequate.
Evidence of Nonconformance:
Location: Masai POM
The number of First-aiders available at POM is inadequate compared to the Number of First-
aiders Required under the Guidelines on First-Aid in Workplace (2nd Edition) by the
Department of Occupational Safety and Health (DOSH) Malaysia.
Root Cause Analysis, Correction(s), and Corrective Action(s) by Auditee Representative
Root Cause Analysis (RCA):
Lack of knowledge and understanding on the requirement of Guidelines on First Aid in
Workplace.
Correction(s):
To source for training provider to conduct in house training to estate and mill staff/worker.
Minimum 20pax.
Corrective Action(s):
Basic First Aid Training was conducted by CERT Academy on 19 and 20 January 2022. Total
4 pax from Factory and 16 pax from Estate attended the training.
CA Implementation timeline:
26th January 2022. Please refer to Appendix no.2 Basic First Aid Training.
Verification on Corrective Action(s): by Lead Auditor / Auditor

The supporting evidence and documents were verified and found adequate.
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Further verification was done through phone interview with Management and Sustainability
Executives to verify the effectiveness of the corrective action taken.
Based on the evidence, documents, and phone interview with selected personnel, it can
conclude that the corrective action was implemented accordingly. Thus, the Major finding was
closed. The continuous implementation shall be verified again in the next assessment.
Conclusion:
The actions taken and implementation needed were found to have satisfactorily addressed
the issue and accepted for closure.
NC Status Closed by Auditor: NEA & MAS Date Closed: 27/01/2022
Verification of Effectiveness:
NC Status Verified by Auditor: Date Verified:
3.2.2 Year 2021 - Annual Surveillance Audit (ASA-03): 2 Minor NCs

MSPO
Indicator
20211029-N1 4.2.2.3 Date issued: 29 October 2021
(Minor) Requirement:
List of stakeholders, records of all consultation and communication and records of action taken
in response to input from stakeholders
Statement of Non-conformance:
Current list of contact and details of stakeholders is not updated.
Evidence of Non-conformance:
Location: Masai POM
The list of stakeholders (Doc. No.: RSPO-CRI-1.1.1) was made available during the audit with
latest revision on 15th September 2021. The lists provided were used for selection of
stakeholder’s consultation. Stakeholder’s consultation for this audit was conducted via phone
call since the audit was conducted remotely and to curb the spread of Covid-19. However, it
was noted that the lists were not sufficiently included all relevant stakeholders such as mill’s
canteen owner. Some email and phone numbers provided in the list were also invalid.
Root Cause Analysis, Correction(s) & Corrective Action(s) by Auditee Representative
Overlook to review & update the contact and details of the stakeholders list.
Correction(s):
To update the contact and details.
To review & update the contact and details of the list by 1 month before conduct yearly
stakeholders meeting.
4th Dec 2021. Please refer to Appendix no.3 LIST OF STAKEHOLDERS REV15.
The CAP was accepted. The effective implementation of the corrective action will be verified
during next audit. Status “Open”.
Conclusion:
NC Status Closed by Auditor: Date Closed:
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MSPO
Indicator
(Minor) Requirement:
The management shall accept MSPO approved auditors to verify assessments through a
physical inspection if required.
Statement of Non-conformance:
There is no evidence that contractor agreed to be assessed by auditors.
Evidence of Non-conformance:
Contract agreement between the mill management and their contractors were reviewed
during the audit. However, there is no evidence that contractors performing task agreed to
be assessed by MSPO approved auditors.
Overlook the clause on the acceptance of assessment by MSPO approved auditors.
Correction(s):
To include additional clause on the acceptance of assessment by MSPO approved
auditors in the new contractor’s agreement.
Additional clause on the acceptance of assessment by MSPO approved auditors has been
included in the contractor’s agreement.
26th January 2022. Please refer to Appendix no.1 Estate Contractor Agreement.
The CAP was accepted. The effective implementation of the corrective action will be
verified during next audit. Status “Open”.
Conclusion:
NC Status Closed by Auditor: Date Closed:
3.2.3 Year 2021 - Annual Surveillance Audit (ASA-03): 1 Observation
Status
MSPO
OBS # Details of Observation Opened Closed Remark,
Indicator
Date Date (if any)
20211029-O1 4.4.4.1 Location: Masai POM 29 Oct 2021 - Next Audit
(Observation) (1) The monitoring of Recommendation from
Assessor of CHRA Report could be further
enhance by tabulating the recommendation
and update the status of each
recommendation when necessary.
(2) The monitoring of Recommendation from
Assessor of NRA Report could be further
enhance by tabulating the recommendation
and update the status of each
recommendation when necessary.
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3.2.4 Year 2020 – Annual Surveillance Audit (ASA-02): 1 Major NC

MSPO
Indicator
202010-M1 4.4.4.2 Date Issued: 14 October 2020
Major
Requirement:
The occupational safety and health plan should cover the following:
……………………………..
b) The risk of all operations shall be assessed and documented.
……………………………..
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 Labelling) Regulation 1997
and Occupational Safety Health (Use and Standard of Exposure of Chemical
Hazardous to Health) Regulation 2000.
……………………………..
i) Employees trained in First Aid shall be present at all mill operations. First Aid
equipment should be available at each worksite.
j) Records shall be kept of all accidents and be reviewed periodically at quarterly
intervals.
Statement of Non-Conformance:
Risk assessment and action plan is not comprehensive and ineffective.
Evidence of Non-Conformance:
(1) Risk assessment has not taken into consideration of metal scrap placed along the mill
road. The scrap was left at the area without any barricade.
(2) Masai POM operate in same compound with Keck Seng Refinery. However, the
general risk assessment was not identified.
(3) The reverse sensor for shovel at the FFB grading station was not functioning.
(4) Oxyacetylene tank was not equipped with safety equipment.
(5) Items in the first aid box was not replenished as required at the weighbridge room and
steriliser station. Not all item listed in the list was available.
(6) Chemical register was not updated as the last register was updated on 14/3/2013 by
former Sr. Manager (Laboratory).
(7) Records of accident happened (JKKP 6) on 22 April 2020 was not available for
verification.
Root Cause Analysis, Correction(s) & Corrective Action(s) by Auditee Representative:
(1) There is no dedicated person-in-charge to monitor the storage area of mill compound,
especially on safety matter.
(2) Safety Officer of the mill presumed that the risk assessment was done by refinery
safety team.
(3) Shovel driver is not aware the reverse sensor is part of safety features that need to be
maintain at the shovel. Thus, they do not alert the management when the reverse
censor is malfunction.
(4) Person-in-charge of the Oxyacetylene tank has overlooked the safety equipment on
Oxyacetylene tank as he felt that it is not important.
(5) No monitoring of first aid box items and condition conducted by the management.
(6) Current Sr. Manager of Laboratory assumed that the Chemical Register only be
updated when there are any changes of person-in-charge of the lab.
(7) The administration staff is still not clear which case need to be report to JKKP.
Correction(s):
(1) To install clear signage and barricades for identified the area of metal scrap, plant
equipment and recycled material storage area.
(2) To generate a general risk assessment for workers during walking into main gate
towards to palm oil mill working stations.
(3) To repair the malfunction reverse signal of shovel.
(4) To install the flash back arrestor at all the oxyacetylene and acetylene tanks.
(5) To refill incomplete items in the first aid kit
(6) To update the chemical registration.
Page 30 of 41
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(7) To complete the documentation for the accident as per requirement.
(1) To assign a PIC for always monitor the storage area.
(2) Safety Officer ensure that risk assessment is cover all activities of the mill and to review
all the risk assessment when necessary.
(3) To include the reverse signal into the shovel driver checklist.
(4) To include the flash back arrestor into the workshop safety checklist.
(5) To train the importance of safety feature of equipment or machineries at the mill to the
person-in-charge of that particular equipment or machinery, i.e., shovel and
oxyacetylene and acetylene tanks
(6) To generate a checklist for first aid box monitoring
(7) The new lab manager will be assigned to be PIC for updating the chemical registration
in the future.
(8) To give refresher briefing to the administration staff regarding reporting system related
to JKKP, especially for any accident case MC is more than 4 days using JKKP 6 Form.
CA Implementation Timeline:
November 2020
Off-site verification was done due to travel restriction as Malaysian Government announced
the implementation of Movement Control Order (MCO).
Following supporting evidence and documents were verified:
(1) Sighted pictorial of metal scrap area which was barricades, and the management has
erected the identification signage of designated area.
(2) Sighted HIRARC – General Risk, which was conducted by Mill Safety & Health Officer
and Mill Engineer on 31 Oct 2020 and approved by Senior Mill Manager on 02 Nov
2020.
(3) Viewed the video of shovel operated which verified from the video that the reverse
sensor of the shovel is functioning.
(4) Sighted record of amended shovel driver checklist which was incorporated reverse
sensor as part of it.
(5) Sighted Register of Chemicals Hazardous to Health of Laboratory which was prepared
by Lab Chemist and approved by Lab Manager on 11 Nov 2020.
(6) Sighted pictorial of oxyacetylene tanks at mill and estate, which was equipped with
safety equipment, i.e., flashback arrestor device, and guide chain.
(7) Sighted training records for foreman and shovel driver regarding SOP for handling
oxyacetylene tanks and shovel. Both trainings were done in Nov 2020.
(8) Sighted pictorial of complete first aid kit at the weighbridge room and steriliser station.
(9) Sighted checklist for first aid kit monitoring, latest on 14 Dec 2020.
Further verification was done through phone interview with Senior Mill Manager, Safety &
Health Officer, Mill Engineer, Lab Manager, Shovel Driver of Masai POM and Sustainability
Manager, to verify the effectiveness of the corrective action taken.
conclude that the corrective action was implemented effectively. Thus, the Major finding
was closed. The continuous implementation shall be verified again in the next assessment.
Conclusion:
The actions taken and implementation needed were found to have satisfactorily addressed
the issue and accepted for closure.
NC Status Closed by Auditor: MAS & MH Date Closed: 12 Jan 2021
The corrective action taken found to be sufficient and effective. It is implemented
accordingly. No similar non-compliance found during the audit. Thus, the Major NC raised
during previous assessment was remain closed.
NC Status Verified by Auditor: MAS Date Verified: 29/10/2021
3.2.5 Year 2020 – Annual Surveillance Audit (ASA-02): 3 Minor NC

MSPO
Indicator
Minor Requirement:
Page 31 of 41
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The legal requirements register shall be updated as and when there are any new
amendments or any new regulations coming into force.
Legal Requirements Register is not updated.
The management has established Legal Requirements Register as a list of all relevant and
applicable laws and regulations to its operation. However, the list is not inclusive of new
amendments and new regulations that is already in force.
Root Cause Analysis, Correction(s) & Corrective Action(s) by Auditee Representative:
Personnel in charge of lawnet.my is not aware on list of all relevant and applicable laws and
regulations to mill and estates operation.
To revise and update a list annually to ensure all new law and regulation is updated in a list.
August 2021
Evidences submitted as above for the corrective actions done with attached evidences at
the audited sites were verified on-site. The actions taken and implementation were found to
have satisfactorily addressed the issue and acceptable for closure.
Conclusion:
conclude that the corrective action was implemented accordingly and found to have
satisfactorily addressed the issue and accepted for closure. The continuous implementation
shall be verified again in the next audit.
NC Status Closed by Auditor: MAS Date Closed: 29/10/2021
MSPO
Indicator
202010-N2 4.5.3.2 Date Issued: 14 October 2020
Minor Requirement:
A waste management plan shall be developed and implemented, to avoid or reduce
pollution. The waste management plan should include measure for:
a) Identifying and monitoring sources of waste and pollution.
b) Improving the efficiency and recycling potential of mill by-products by converting them
into value-added products.
The implementation of waste management plan is inadequate.
1) At the Boiler ash storage area, it was observed that the leachate had stayed stagnant
at the area and not properly directed to the drain that lead to the effluent pond.
2) At the FFB washing area, wastewater was seen clogged and stayed stagnant. It was
not properly directed to the drain for proper disposal.
3) At Designated Metal Scrap / collection area:
▪ Various type of scrap material including rubber tyres, tubes, wood, and plastic
materials were noted mixed and dump at the location.
▪ No separate designated location was identified for the other types of domestic and
recyclable waste materials.
Negligence for monitor the area of boiler ash storage area and FFB washing area.
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(1) To build a new perimeter drain at the boiler ash storage area to direct the leachate go
into effluent treatment system.
(2) To include boiler ash storage area into the environmental checklist.
(3) To build a new drain at FFB washing area to direct the water to proper disposal.
(4) To include FFB washing area into the environmental checklist.
(5) To clearly separate the scrap material and recyclable material c/w proper signage.
(6) To assign a PIC for manage the area.
August 2021
Conclusion:
NC Status Closed by Auditor: MH Date Closed: 29/10/2021
MSPO
Indicator
202010-N3 4.6.4.2 Date Issued: 14 October 2020
Minor Requirement:
The management shall provide evidence of agreed contracts with the contractor.
Specific clauses meeting applicable legal requirement, disallowing child, forced and
trafficked labour are not available in contract document with contracted third party.
Contract with Agensi Pekerjaan Cosmo Sdn. Bhd. did not specify the clauses on meeting
applicable legal requirement, disallowing child, forced and trafficked labour.
Administration executive is not aware the contract with Agensi Pekerjaan Cosmo Sdn Bhd
did not specify the clause on meeting applicable legal requirements, disallowing child,
forced and trafficked labour.
(1) To renew the Cosmo contract with the additional clauses which are meeting applicable
legal requirement, disallowing child, forced and trafficked labour.
(2) To review all third-party contract and ensure all of them are including the clauses of
meeting applicable legal requirement, disallowing child, forced and trafficked labour.
August 2021
Conclusion:
Page 33 of 41
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NC Status Closed by Auditor: NEA Date Closed: 29/10/2021
3.2.6 Year 2020 – Annual Surveillance Audit (ASA-02): 2 Observation(s)

Status
MSPO
OBS # Details of Observation Opened Closed Remark,
Indicator
Date Date if any
202010-O1 4.3.1.1 Information on the skid tank and the dimension 14 Oct 2020 29/10/2021 -
Observation written on the bund wall of the skid tank has
already faded.
202010-O2 4.4.6.1 Training on policies established by the 14 Oct 2020 29/10/2021 -
Observation company was conducted accordingly. Training
materials were both in English and Bahasa
Malaysia. Upon review of both documents, it
was found that the company Social Policy in
Malay language was not of exact translation of
the original policy in English language.
3.2.7 Identified Positive Elements

1) The Management Unit has provided proper infrastructure such as roads, housing and sport facilities for its
workers, local residents and communities within the operational management of the Management Unit.
2) The Management Unit has contributed towards the local economy in providing business and employment
opportunities. It has made significant economical contributions towards the socio-economic development of
the local communities surrounding the Management Unit.
3) The company has continued to maintain and carried out CSR activities such as financial funding for education,
social and religious activities.
4) The company has continued to maintain and implement the safety measures and pollution prevention
programs and activities.
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4.0 AUDIT CONCLUSION AND RECOMMENDATION

Based on the findings above, Keck Seng (Malaysia) Berhad – Masai Palm Oil Mill had been able to demonstrate its
compliance with the MSPO Part 4 (MS 2530–4: 2013) General Principles for Palm Oil Mills.
Therefore, it is recommended that the certification of Keck Seng (Malaysia) Berhad – Masai Palm Oil Mill be approved and
continued.
Signed for and on behalf of

Intertek Certification International Sdn Bhd
……………………………………
NOR EZANI AHMAD
Lead Auditor
Date:
4.1 Acknowledgement of Internal Responsibility and Confirmation of Audit Findings

This is to acknowledge and confirm the audit visits described in this report and the acceptance of the contents and findings
in this audit report.
Signed for and on behalf of

Keck Seng (Malaysia) Berhad – Masai Palm Oil Mill
……………………….………..
NAME:
Designation:
Date:
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4.2 INTERTEK – MSPO Certificate Details for Keck Seng (Malaysia) Berhad – Masai Palm Oil Mill
Certificate No MSPO 008A
Start Date: 10 Dec 2018
Expiry Date: 09 Dec 2023
Organisation Keck Seng (Malaysia) Berhad
Address of Head Office 9 Miles, Kong Kong Road, 81757 Masai, Johor, Malaysia.
Name of Estates Keck Seng (Malaysia) Berhad – Masai Palm Oil Mill
Address of Estates 9 Miles, Kong Kong Road, 81757 Masai, Johor, Malaysia.
MPOB License No. 500026504000
GPS Coordinate Latitude: 1.540346O N
Longitude: 103.964895O E
Standard MSPO Part 4 (MS 2530–4: 2013) General Principles for Palm Oil Mills
Certification Scope Sustainable Management of Palm Oil Mill with Capacity of 60 MT per Hour.
The annual certified tonnages / volumes at the mill are detailed as follows:
Masai Palm Oil Mill Annual Tonnages (MT)
Certified CPO 8985.41
Certified PK 2763.11
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APPENDIX A: Qualifications of Lead Auditor and Audit Team
Ms. Nor Ezani Ahmad – Assessor / Technical Expert
(Social Responsibility, Workers Welfare, HCV, and Safety & Health)

– Master’s in Science (Research) Advancement of Biodiversity (UMS)
Ms. Nor Ezani Ahmad has 3 years of working experience in the oil palm plantation sector specialized in sustainability. She
started her career in oil palm sector attached to a large public listed plantation organization since 2017. She was involved
in Internal Audits for estates and mills within the organization with regards to compliance with RSPO and MSPO
requirements, dealing with traceability of FFB suppliers (smallholders and dealers), one of SEIA Assessor and Trainer for
Cadet Planters and Cadet Engineers Programme. She has successfully completed RSPO Principles & Criteria Lead Auditor
Course, ISO9001:2015 Lead Auditor in Quality Management System Course, ISO45001:2018 Lead Auditor in Occupational,
Health and Safety Management System, MSPO Lead Auditor Course, SA 8000 Training Course and HCV Assessor Course.
She is well-versed in the oil palm sector focusing on Social Aspects, OSH issues (e.g., employment terms and conditions,
gender issues, workers welfare etc.) as well as environmental related matters (e.g., HCV Management etc.). She is also a
Provisional Auditor for Malaysian Sustainable Palm Oil (MSPO) certification.
Mr. Mohamad Amirul Saifullah Mohamad Senan (MAS) – Lead Auditor / Team Leader / Technical Expert
(Palm Oil Mill, GAP, Integrated Pest Management, Safety and Health, and Supply Chain)
– Bachelor of Agricultural Science (UPM)
Mr. Mohamad Amirul has more than 6 years working experience in the oil palm plantation operations, agriculture, safety, and health related
field. He was attached to a large publicly listed plantation organisation since 2012. His job responsibilities include supervision and monitoring
to ensure that all estate operations are complying to the RSPO, ISCC and MSPO requirements and regulations, Good Agricultural Practice,
and other standard operation procedures. He was involved in the Internal Audits of plantation operations for compliance with the RSPO,
ISCC and MSPO requirements. He has successfully completed and passed RSPO Principles & Criteria Lead Auditor Course and the RSPO
Supply Chain Certification Lead Assessor Course in Jan 2019, ISO 9001:2015 Lead Auditor Quality Management Systems Training Course,
Lead Auditor Occupational Health & Safety Management System (ISO 45001:2018) Training Course, and the MSPO Lead Auditor for
OPMC and Supply Chain Course in 2018. He had been involved in ISO 9001, RSPO P&C, RSPO SCC, MSPO Part 3, MSPO Part 4 and
MSPO SCC auditing since December 2018 within Malaysia. He has good on-field knowledge in the Palm Oil sector such as industry
fundamentals on good agricultural practices (GAP), best management practices (BMP), sustainability, social and OHS issues (e.g., worker
welfare issues and social matters such as employment terms, gender issues, worker welfare etc.) environmental matters (e.g., pollution
control, conservation of resources). He is a qualified Lead Auditor for both the RSPO, MSPO, and ISO 9001:2015 certification audits, and
qualified Auditor for ISO 45001:2018 certification audits.
Mr. Mohd Hafiz Mat Hussain (MH) – Auditor / Technical Expert

(Palm Oil Mill, Environment, GAP, Integrated Pest Management, Safety and Health, Conservation & HCV Area and Supply Chain)
- Bachelor’s in Technology and Plantation Management (UiTM)
Mr. Mohd Hafiz has more than 5 years working experience in the oil palm plantation operations, agriculture, safety, and health related field.
He was attached to a large publicly listed plantation organisation from 2009-2013. His job responsibilities include supervision and monitoring
to ensure that all estate operations are complying to the RSPO requirements and regulations, Good Agricultural Practice, and other standard
operation procedures. He had spent 6 years being previously engaged with international CBs in conducting certification audits of plantation
operations for compliance with the RSPO and MSPO requirements. He had completed the ISO 9001 Lead Auditor Course, ISO 14001 Lead
Auditor Course and OHSAS 18001 Lead Auditor Course in 2013, Endorsed RSPO P&C Lead Auditor Course in 2014, MSPO Awareness
Training in 2014 and Endorsed RSPO SCCS Lead Auditor Course in 2016. He had been involved in ISO9001, ISO14001 and OHSAS
18001 auditing since May 2013 within Malaysia, Brunei, Indonesia and RSPO auditing within Malaysia, Papua New Guinea, Solomon
Islands, Gabon, and Liberia. He has good on-field knowledge in the Palm Oil sector such as industry fundamentals on good agricultural
practices (GAP), best management practices (BMP), sustainability, social, OHS issues (e.g., worker welfare issues and social matters such
as employment terms, gender issues, worker welfare etc.) and environmental matters (e.g., pollution control, conservation of resources).
He is a qualified Lead Auditor for both the RSPO and MSPO certification audits.
Page 37 of 41
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APPENDIX B: Audit Plan
Appendix B-1: Audit Plan (Actual)
Time Auditors and Audit Activity

Date
(Note 3) Audit Team
26/10/2021 9:00 am – 9:30 am Opening Meeting and Briefing via Microsoft Teams
Tuesday (to be attended by representatives from the Estates as well)
9:30 am – 1:00 pm Remote Audit – Document Review and Audit (including site visit) on
Day 1 Respective MSPO Part 4: P1 to P6 at Masai Palm Oil Mill
Method for Remote Audit – Document Review and Audit, including Site Visit:
• Through Interview & Site Audit, get objective evidence with the use of ICT, such as:
WhatsApp Voice Call/Video Call/Messaging, Microsoft Teams Voice Call/Video
Call/Messaging
• Documented Information submitted/shared screen during interview through ICT, such
as: Email, WhatsApp Voice Call/Video Call/Messaging, Microsoft Teams Voice Call/Video
Call/ Messaging
NEA MH MAS
▪ Principle 1 ▪ Principle 1 ▪ Principle 1
▪ Principle 6
1:00 pm – 2:00 pm Lunch Break
2:00 pm – 6:00 pm Continue Remote Audit at Masai Palm Oil Mill
6:00 pm – 7:00 pm Team Meeting and Discussion

Date
(Note 3) Audit Team
27/10/2021 9:00 am – 1:00 pm Remote Audit – Document Review and Audit (including site visit) on
Wednesday Respective MSPO Part 3: P1 to P7 at Lian Huap Oil Palm Plantations
Day 2 Method for Remote Audit – Document Review and Audit, including Site Visit:
Call/Messaging
• Documented Information submitted/shared screen during interview through ICT, such
as: Email, WhatsApp Voice Call/Video Call/Messaging, Microsoft Teams Voice
Call/Video Call/ Messaging
NEA MH MAS
▪ Principle 7 (if applicable) (if applicable)
(if applicable)
11:00 am – 1:00 pm NEA
Stakeholders’ Consultation on the following categories (see Notes 1 and 2 below):
• Contractors
• Suppliers
• Transporters
Page 38 of 41
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• NGOs
• Government Department / Agencies
• Local Community
Notes:
1. It is mandatory for the UOC to inform Intertek and provide the information (as a
minimum the no. of stakeholders in each applicable category and contact number) on
the stakeholders prior to the audit.
2. This will facilitate the random and impartial selection of stakeholders (including
independent and organized smallholders, where applicable) and to meet the sample size
requirement
Lunch Break
Continue Remote Audit at Lian Huap Oil Palm Plantations
Team Meeting and Discussion

Date
(Note 3) Audit Team
Thursday Respective MSPO Part 3: P1 to P7 at Lim & Lim Plantations
Call/Messaging
• Documented Information submitted/shared screen during interview through ICT, such as:
Email, WhatsApp Voice Call/Video Call/Messaging, Microsoft Teams Voice Call/Video
Call/ Messaging
NEA MH MAS
(if applicable)
2:00 pm – 6:00 pm Continue Remote Audit at Lim & Lim Plantations
6:00 pm – 7:00 pm Team Meeting and Discussion

Date
(Note 3) Audit Team
Friday Respective MSPO Part 3: P1 to P7 at Johore (Masai) Plantations
WhatsApp Voice Call/Video Call/Messaging, Microsoft Teams Video Call/Messaging
• Documented Information submitted/shared screen during interview through ICT, such as:
Email, WhatsApp Voice Call/Video Call/Messaging, Microsoft Teams Video Call/ Messaging
NEA MH MAS
Page 39 of 41
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(if applicable)
2:00 pm – 4:00 pm Continue Remote Audit at Johore (Masai) Plantations
4:00 pm – 4:30 pm Preparation for Closing Meeting
4:30 pm – 5:00 pm Team Meeting and Discussions with POM & Estate Management Representatives
via Microsoft Teams
5:00 pm – 6:00 pm Closing Meeting & Briefing via Microsoft Teams
(to be attended by representatives from the POM & Estates)
Appendix B-2: Audit Team Competency Matrix

Lead Auditor / Auditors / Technical Experts
MSPO Principle
NEA MH MAS
Principle 1: Management Commitment and Responsibility ✓ ✓ ✓

Principle 2: Transparency ✓ ✓ ✓
Principle 3: Compliance to Legal Requirements ✓ ✓ ✓
Principle 4: Social Responsibility, Health, Safety and Employment Condition ✓ ✓ ✓
Principle 5: Environment, Natural Resources, Biodiversity, and Ecosystem Services ✓ ✓ ✓
Principle 6: Best Practices ✓ ✓ ✓
Principle 7: Development of New Plantings (Applicable to MSPO Part 3 only) ✓ ✓ ✓
Page 40 of 41
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APPENDIX C: Location Map of Keck Seng (Malaysia) Berhad – Masai Palm Oil Mill
Appendix C-1:
Keck Seng (Malaysia) Berhad – Masai Palm Oil Mill
GPS Coordinate:
Latitude: 1.540346O N
Longitude: 103.964895O E
-End of Report-
Page 41 of 41

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INTERTEK CERTIFICATION INTERNATIONAL SDN BHD

Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

KECK SENG (MALAYSIA) BERHAD

Masai, Johor, Malaysia

Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

ANNUAL SURVEILLANCE AUDIT

PUBLIC SUMMARY REPORT

Keck Seng (Malaysia) Berhad

Certificate No: INTERTEK MSPO M008A

Audit Type Audit Dates

Intertek Certification International Sdn Bhd

Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

2.0 AUDIT PROCESS ................................................................................................................................................... 8

3.0 AUDIT FINDINGS .................................................................................................................................................. 10

4.0 AUDIT CONCLUSION AND RECOMMENDATION .............................................................................................. 35

APPENDIX A: Qualifications of Lead Auditor and Audit Team ..................................................................................... 37

Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

1.0 SCOPE OF AUDIT

1.2 Location (Address, GPS, and Map) of Palm Oil Mill

Table 1: Address of Palm Oil Mill, and GPS Location

1.4 Organizational Information / Contact Person

Masai POM (Head Office):-

Masai POM (Site):-

Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

1.5 Tonnages Verified for Certification

Table 5: Tonnages Verified for Certification

Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

3 Abd Rahman Bin Budin 2 7.94 0

Grand total (A) + (B) + (C): 52,148.81 169,106.35

Table 6: Annual Tonnage of FFB (Certified & Non-certified)

Total: 254,782.40 100.0% 52148.81 100.0% 169106.35 100.0% 253,104.00 100.0%

SCCS Model for

Table 7: Annual Tonnages under Certification – FFB, CPO & PK

Total FFB Processed (MT) 54,782.40 11,320.45 35,768.37 58,204.00

OER: OER: OER: OER:

Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

KER: KER: KER: KER:

1.6 Abbreviations Used

CB Certification Body ISCC International Sustainability & Carbon Certification

CPO Crude Palm Oil JAS Jabatan Alam Sekitar

CSPO Certified Sustainable Palm Oil KER Kernel Extraction Rate

CSPK Certified Sustainable Palm Kernel LTA Lost Time Accidents

DOE Department of Environment MPOB Malaysia Palm Oil Board

EFB Empty Fruit Bunch MTCS Malaysia Timber Certification Scheme

EHS Environmental Health & Safety NC Non-Compliance or Non-Conformance

EIA Environmental Impact Assessment NGO Non-Government Organization

FGVHB FGV Holdings Berhad PK Palm Kernel

GAP Good Agriculture Practice PPE Personal Protective Equipment

HCV High Conservation Values SCCS Supply Chain Certification Standard

Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

2.0 AUDIT PROCESS

2.1 Audit Methodology, Plan and Site Visits

2.2 Date of Next Scheduled Visit

2.4 Certification Body

2.3 Qualifications of the Lead Auditor and Audit Team

2.5 Process of Stakeholder Consultation

Among the stakeholders consulted was the as follow:

Report No. : M008A/18-4 Keck Seng (Malaysia) Berhad

Government Departments NGO