POLICIES AND COMMITMENTS

Environment and biodiversity policy

We at United Plantations Berhad are committed to sustainable development through protection of the environment and conservation of biodiversity. Our objectives:

• Conducting our operations under the best principles of agriculture, that is compatible with the natural environment and in full support of Integrated Pest Management techniques and Best Management Practices for existing plantations on peat.
• Promoting the conservation and development of biodiversity within our group of plantations.
• We want to ensure that our agricultural operations comply with the following criteria:
  • No development on high carbon stock (HCS) forests
  • No development on high conservation value (HCV) areas
  • No new development on peatland regardless its depth
  • Not to operate or develop within international or nationally designated protected areas
  • Compliance with all relevant laws and National Interpretation of RSPO and MSPO Principles and Criteria.

We strive to maintain an open and dynamic approach towards continuous improvements in respect of conservation in HCV, HCS areas and reduction of greenhouse gas (GHG) Emissions. We ensure No Deforestation and No New Development on Peat within our operations.

• Continuously working to mitigate our water footprint related to our operations, maintaining buffers along natural waterways, harvesting rainwater, frugal water usage, monitoring of its quality and judicious use of pesticides and weedicides.
• We are committed to reduce and phase-out chemicals that fall under the WHO Class 1A & 1B and Stockholm or Rotterdam Conventions. We will continue working with stakeholders to determine and implement alternative pest control strategies to totally phase-out these chemicals when effective and suitable alternatives are available.
• Continuously working on sound soil management e.g. determining appropriate amount and composition of nutrients based on annual leaf nutrient analysis, empty fruit bunches systematically applied in field, planting of leguminous cover crops.
• Continuously working towards a dynamic and innovative waste management and utilization system aimed towards zero waste and recycling.
• Continuously focusing on promoting new technologies with low environmental impact as well as reducing greenhouse gas (GHG) emissions.
• Capturing, poaching and hunting of native tree species and animals, especially Endangered, Rare and Threatened species are prohibited. However, we respect the traditional rights of indigenous groups and communities to hunt in legal, non-commercial and sustainable manner without involving Endangered, Rare and Threatened species and jeopardizing long-term viability of the species.
• The key environmental milestones achieved are as follows:
  • Zero-burn policy (1989)
  • No primary forest clearing policy (1990)
  • No biodiesel production/supply policy (2003)
  • Methane capturing facilities introduced (2006)
  • HCV assessment introduced (2007)
  • Total phase-out of Paraquat (2010)
  • No new development on peat (2010)
  • HCS assessment and Land Use Change Analysis for new plantings (2014)
• We will strive to commit our employees, contractors, suppliers, trading partners and stakeholders to adhere to this policy and thereby focus on traceability within our supply chain.

Occupational safety and health policy

We at United Plantations Berhad are committed to secure the safety and health of all our employees at work. In the operation of our activities, we strive to maintain a safe and healthy working environment for our employees, customers and the public.
We value our workplace Safety and Health as paramount importance to the well-being of all our employees and our respective Managers/Heads of Departments are responsible in implementing this policy.
In striving to secure a safe and healthy work environment we shall:

• • Devote our continuous efforts to accident prevention, by conducting Hazard Identification, Risk Assessment and Risk Control (HIRARC) on all our operations.
  • Provide continuous training and supervision to all categories of employees to build and promote a safe and healthy work environment in full compliance with legislative requirements.
  • Equip and train employees to use appropriate protective equipment and to develop a health and safety conscious citizen.
  • Ban the use of Paraquat weedicide (1, 1’-Dimethyl-4, 4’-bipyridinium dichloride).
  • Commit to reduce and phase-out chemicals that fall under the WHO Class 1A & 1B and Stockholm or Rotterdam Conventions. We will continue working with stakeholders to determine and implement alternative pest control strategies to totally phase-out these chemicals when effective and suitable alternatives are available.
  • Ensure fire safety plan is implemented and continuously trained for its preparedness within our organization and neighboring communities.
  • Develop a culture of individual responsibility and accountability for the employee’s own well being as well as those of the personnel and facilities under their control.
  • Strive to commit our employees, contractors, suppliers, trading partners and stakeholders to adhere to this policy as well as Safety and Health regulations and standards.

Human rights policy

We at United Plantations Berhad are committed to the protection and advancement of human rights including prohibiting retaliation, intimidation and harassment against Human Rights Defenders (HRD), whistleblowers, complainants and community spokespersons.

Our objectives are as follows:

• We adhere to the fundamental elements of International Labour Organization (ILO) Convention and the United Nations Declaration on Human Rights, the Rights of Indigenous Peoples and other core values as ratified by the countries in which we operate.
• We ensure all personnel are treated fairly and protected from any form of discrimination that would constitute a violation of their human rights.
• We ensure equal opportunities provided to all personnel. The process of recruitment, promotion and remuneration are solely based on individual qualification and performance regardless of religion, race, age, gender, nationality or physical disability.
• We respect the rights of all personnel to form, join and participate in registered trade unions and to bargain collectively.
• We respect the rights of people in communities impacted by our activities. We will seek to identify adverse social and environmental impacts through their respective assessments and take appropriate steps to avoid, minimize and/or mitigate them.
• We respect land tenure rights as well as recognize duties and responsibilities associated with tenure rights.
• SWe respect customary or native rights of indigenous and local communities and we commit to Free, Prior and Informed Consent (FPIC) in all negotiations prior to commencing any new operations.
• We resolve all complaints and grievances through an open, transparent and consultative process.
• We will not tolerate the use of child or forced labour, slavery or human trafficking in any of our plantations and facilities. We are using the definition from the United Nations Convention on the Rights of the Child which defines ‘child’ as anyone who is less than 18 years old.
• We will strive to commit our employees, contractors, suppliers, trading partners, contracted security forces, associated local communities and stakeholders to adhere to this policy.

Gender policy

We at United Plantations Berhad are committed to maintaining a workplace free from harassment of any kind, including harassment based on an employee’s race, colour, religion, gender, national origin, ancestry, disability, marital status and sexual orientation. In line with the policy, we shall;

• Endeavour to prevent sexual harassment and all other forms of violence against women and workers in the workplace or in the course of an employee’s work.
• Adopt a specific complaints and grievance procedure and mechanism to address gender-based issues.
• Encourage effective participation of women in decision-making by their representation as members of various committees, such as the Occupational Safety And Health Committee.
• Establish a Gender Committee to implement and monitor the policy.
• To protect the Reproductive Rights and Motherhood responsibilities of women as under the Universal Declaration of Human Rights and labour laws.
• We will communicate to our employees, contractors and suppliers to adhere to the values of this policy.

Guest workers policy

We consider our foreign workers as guests and they are partners in our business along with our local workers.

• No forms of forced labour or trafficked labour are used.
• No difference is made between guest and local workers.
• All guest workers are in possession of a valid work permit in accordance with Malaysian Immigration Regulations, 1963.
• All guest and local workers are covered under the purview of “Workers’ Minimum Standards of Housing And Amenities Act 1990”.
• There will be no contract substitution.
• Passports of guest workers shall be voluntarily submitted to the respective management for safe custody and will be readily made available on request.
• We will ensure that our contractors employ guest workers with valid work permits and all statutory payments and just wages are made timely.
• We will endeavor to make “The Home Away From Home” of our guest workers an enriching experience with good memories.

Code of conduct and business ethics

We consider our foreign workers as guests and they are partners in our business along with our local workers.
A key element in United Plantations (UP) is our Code Conduct and Business Ethics. We implement responsible and ethical business policies and practices in all aspects of our operations.

Standard of Conduct
We conduct our operations with honesty, integrity and openness, and with respect for the human rights and interests of our employees. We shall similarly respect the legitimate interests of those with whom we have relationships.

Obeying the Law
UP Group, directors and our employees are required to comply with the laws and regulations of the countries in which we operate. UP will promote and defend our legitimate business interests. UP will cooperate with governments and other organizations, both directly and through bodies such as trade associations, in the development of proposed legislation and other regulations which may affect our legitimate business interests.

Consumers
UP is committed to providing quality products and services which consistently offer value in terms of price and which are safe for their intended use. Products will be accurately and properly labelled, advertised and communicated.

Shareholders
UP will conduct its operations in accordance with internationally accepted ethics of good corporate governance. We will provide timely, regular and reliable information on our activities, structure, financial situation and performance to all shareholders.

Business Partners
UP is committed to establishing mutually beneficial relations with our suppliers, customers and business partners. In our business dealings, we expect our business partners to adhere to business ethics consistent with our own.

Community Involvement
UP strives to be a trusted corporate citizen and as an integral part of society, to fulfil its responsibilities to the societies and communities in which we operate.

The Environment
UP is committed to making continuous improvements in the management of our environmental impact and to the longer-term goal of developing a sustainable business.

Competition
UP believes in vigorous yet fair competition and supports the development of appropriate competition laws. UP and its employees will conduct their operations in accordance with the principles of fair competition and all applicable regulations.

Business Integrity and Corruption
UP has a zero tolerance to fraud, bribery and corruption and this applies to all dealings by our employees, suppliers, consultants, agents and any person associated with UP.

UP as a responsible corporate citizen has been and shall continue to give scholarships and donations to deserving cases on the condition that this is not corruptly given as defined under Section 17 A(1) of MACC Amendment Act 2018. However, UP has a general policy of not giving political contributions to any political parties or candidates.

UP does not prohibit the giving of meals and gifts in the course of business dealings as long as these are of reasonable value not in cash and are not corruptly given.

We commit to the principles of Free, Prior and Informed Consent and adhere to these principles in all our negotiations and interactions with stakeholders.

Conflicts of Interests
All UP directors and employees are expected to avoid personal activities and financial interests which would be in conflict with their responsibilities to the Group. UP directors and employees must not seek gain for themselves or others through misuse of their positions.

Policy on documents that can be publicly made available

In line with our commitment to transparency the following documents are publicly available on request.

• Land titles/user rights
• Occupational health and safety plans
• Plans and impacts assessments relating to environment and social impacts
• HCV documentations
• Pollution prevention and reduction plans
• Details of complaints and grievances
• Negotiation procedures
• Continual improvement plans
• Public summary of RSPO certification assessment report
• Human Rights Policy

The Company’s Standard Operating Procedures and Field Management Manuals are confidential documents and are guidelines for various operations. The contents must not be disclosed to any third party without authorization by the Company.

Whistleblower policy

We are committed to high standards of ethical, moral and legal business conduct. This policy aims to provide an avenue for employees, suppliers and other stakeholders to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing.

This policy is intended to cover protection for the whistleblower when raising concerns regarding United Plantations Berhad, such as concerns regarding:

• Incorrect financial reporting;
• Unlawful activity;
• Activities that are not in line with United Plantations Berhad policy, including the Code of Business Conduct; and
• Activities, which otherwise amount to serious improper conduct.

Safeguards

Harassment or Victimization – harassment or victimization for reporting concerns under this policy will not be tolerated.

Confidentiality – Every effort will be made to treat the complainant’s identity with confidentiality.

Anonymous Allegations – This policy encourages employees, suppliers and other stakeholders to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be explored appropriately, but consideration will be given to:

• The seriousness of the issue raised;
• The credibility of the concern; and
• The likelihood of confirming the allegation from attributable sources.

Bad Faith Allegations – Allegations in bad faith may result in disciplinary action.

Information can be provided direct to any of the following persons by telephone or in writing:

Members of the Executive Committee:
Y.Bhg. Dato’ Carl Bek-Nielsen
Tel. No. 05-6411411
Mr. Martin Bek-Nielsen
Tel:
Mr. Loh Hang Pai
Tel. No. 05-6366261

Company Secretary:
Mr. Ng Eng Ho    
Tel. No. 05-6411411

Address:
United Plantations Berhad, Jendarata Estate, 36009 Teluk Intan, Perak

Malaysian sustainable palm oil (mspo) policy

We at United Plantations Berhad are committed to comply and implement all requirements and principles of MSPO.

All operating units under United Plantations Berhad shall adhere to the following key principles of MSPO to which the management shall provide leadership and commitment:

• Management commitment and responsibility
• Transparency
• Compliance to legal requirements
• Social responsibility, health, safety and employment condition
• Environment, natural resources, biodiversity and ecosystem services
• Best practices
• Development of new plantings

Our objectives are to:

• Comply with the laws and regulations of the countries in which we operate.
• Maintain an open and dynamic approach towards continuous improvement in respect of social responsibilities, environment protection, best practices and economic development.
• Establish traceability within the supply chain as an important step towards production of sustainable palm oil products.
• Strive to commit our employees, contractors, suppliers, trading partners and stakeholders to adhere to our Company Policies and cooperate with them in an ambition to find mutual improvements.
• Our Company Policies are:
  • Environment and Biodiversity Policy
  • Human Rights Policy
  • Occupational Safety and Health Policy
  • Gender Policy
  • Guest Workers Policy
  • Code of Conduct and Business Ethics
  • Whistleblower Policy
  • Corporate Social Responsibility (CSR) Policy

Responsible sourcing policy

Introduction

As an important step towards improving our sustainability focus within environmental, social and economic areas of our business, UP is committed to high standards in responsible sourcing. For the third-party FFB suppliers, UP focused on supply that is produced in a manner that excludes the destruction of forest, the exploitation of workers, local communities and based on responsible agronomic practices.

UP therefore recognizes the important role it can play in encouraging a transition to more sustainable practices and commits to building a traceable supply chain. As a step to ensure that our suppliers join us on the journey of full sustainability in the palm oil industry, we have established a Supplier Code of Conduct. This Code includes a requirement for all our suppliers of palm oil and their supply chain to adhere to Fundamental International Labour Organisation (ILO) Conventions and the UN Declaration on Human Rights, the Rights of Indigenous Peoples, environmental protection and anti-corruption and to national laws in the country of which the supplier operates.
Specifically, based on our responsible sourcing policy UP makes the following commitments:

1. 1. Environmental Management
      To source Fresh Fruit Bunches (FFBs) that are produced sustainably whereby the supplier complies with the following criteria:
      • No development on high carbon stock forest (HCS).
      • No development on high conservation value forest (HCVF) areas.
      • No new development on peat lands regardless of depth.
      • Reductions of Greenhouse Gases (GHG) emissions.
      • No use of Paraquat weedicide and a commitment to reduce and phase-out pesticides that are categorized as World Health Organization Class 1A or 1B and Stockholm Conventions.
      • Zero burning for preparation or clearing of land areas.
      • Capturing, poaching and hunting of native tree species and animals, especially Endangered, Rare and Threatened species are prohibited.
      • Identify adverse environmental impacts through their respective assessments (EIA) and take appropriate steps to avoid, minimize and/or mitigate them.
      • Not to operate or develop land within international or nationally designated protected areas.
   2. Human Rights Protection
      To ensure suppliers adhere to the following criteria:
      • Prohibit child labour, illegal, and forced labour.
      • All employees are treated fairly and protected from any form of discrimination.
      • Equal opportunities provided to all employees regardless of religion, race, age, gender, nationality, or physical disability.
      • Compensate workers by providing at least minimum wages and benefits in accordance to all applicable laws and regulations.
      • Respect rights of all employees to form, join, and participate in registered trade unions and to bargain collectively.
      • Respect land tenure rights as well as recognize duties and responsibilities associated with tenure rights.
      • Respect customary or native rights of indigenous and local communities and to commit to Free, Prior and Informed Consent (FPIC) in all negotiations prior to commencing any new operations.
      • Resolve complaints and grievances through an open, transparent, and consultative process.
      • Identify adverse social impacts through their respective assessments (SIA) and take appropriate steps to avoid, minimize and/or mitigate them.
   3. Occupational Safety & Health (OSH)
      To ensure suppliers adhere to the following criteria:
      • Provide continuous training and supervision to all categories of employees to build and promote a safe and healthy work environment in full compliance with legislative requirements.
      • Equip and train employees to use appropriate protective equipment and to develop a health and safety conscious citizen.
      • Develop a culture of individual responsibility and accountability for the employee’s own well-being as well as those of the personnel and facilities under their control.
      • Ensure fire safety plan is implemented and continuously trained for its preparedness within our organization and neighboring communities.
   4. Traceable Supply Chains

To ensure that the Fresh Fruit Bunches (FFBs) actually come from plantations that live up to our Supplier Code of Conduct. UP shall therefore engage with the suppliers to develop traceable and transparent supply chains.

1. 1. Community development and social impact

Suppliers are to drive positive socio-economic impact for local communities and committed to mitigate the impacts on food security, as well as respect and contribute to the quality of life and wellbeing of the communities. Suppliers are to engage effectively with communities and to resolve complaints and conflicts through an open and transparent manner through consultation.

1. 1. Legal compliance

Supplier complies with the legal requirements and standards of its industry under all applicable national and local laws.

Working with our FFB suppliers
UP takes responsibility for ensuring our Sustainable Palm Oil Policy is communicated to all our FFB suppliers.  Our FFB suppliers are expected to meet the requirements of this policy and evaluated against the expectations of our policy and by signing our Supplier Code of Conduct.  Implementations of these commitments shall include the following mechanism:

• Suppliers shall be engaged regularly via discussions, assessments and site-based training sessions where necessary.
• General questionnaires pertaining to our commitments shall be sent to our suppliers to measure their conformance.

We expect our suppliers to share similar principles and commitments thereby jointly building a sustainable palm oil supply chain and will recognize the efforts made by our suppliers showing progress and commitments towards sustainable palm oil.

We believe that this policy will support the transformation of the palm oil supply chain. We only work with suppliers that actively commit to sustainable palm oil in line with our responsible sourcing policy.

In the event that UP becomes aware of a supplier violating or breaching the above policies or our Supplier Code of Conduct and thereby is viewed as a high-risk supplier (self-assessment scored below 50%), UP shall immediately request for corrective measures to be implemented with time-bound action plan to remediate such non-compliance within 60 days. We will moreover through dialogue and cooperation, encourage, and coach the supplier to resolve the non-compliance. If a supplier is unable or unwilling to take the necessary actions to conform to the expectations outlined in our policy, UP will as a last resort terminate its commercial relationship with the supplier.
UP will report the annual progress related to the implementation of this policy in the Annual Sustainability Report.

Supplier code of conduct

Code of ethics and governance
Suppliers shall commit to adhere to ethical, honest, and transparent business practices and governance.

Human and workers’ rights
Suppliers shall adhere to the best human resource practices which respects universal human rights as laid out in the UN Guiding Principle on Human Rights and Business.

Child Labour
Suppliers shall not use child labour as defined by the national laws in the country of operation. Suppliers shall not employ individuals below the age of 18.

Voluntary Employment
Suppliers must hire employees on a voluntary basis and does not use any form of slave, bonded, prison or forced labour or engage in any other forms of human trafficking.

Freedom of Association / Collective Bargaining
Suppliers shall respect the rights of employees to form and join trade unions and bargain collectively in a lawful and peaceful manner subject to and in accordance with applicable law.

Migrant Labour/Guest Workers
Suppliers recognize the unique legal, social and cultural situations that migrant workers/guest workers face and will ensure that such workers are treated with dignity, respect and in accordance with the same standards as apply to local workers.

Abuse, Harassment and Disciplinary Action
Suppliers shall not engage in physical, mental, verbal, sexual or any other abuse, inhumane or any other form of harassment. Supplier shall treat all employees with respect and dignity and complies with local legislation on disciplinary practices.

Fair and equal treatment
Suppliers’ terms and conditions of employment including hiring, training, working conditions, compensation, benefits, or promotions are based on individual’s qualifications, performance, skills and experience.

Compensation and benefits
Suppliers shall fairly compensate all employees by providing wages and benefits in accordance with all applicable laws.

Working hours
Suppliers shall comply with all applicable laws regarding normal working hours, rest periods and overtime hours.

Occupational Safety & Health (OSH)
Suppliers shall commit to secure the safety and health of all their employees at work and strive to maintain a safe and healthy working environment. Supplier shall comply with all applicable laws pertaining to health and safety in the workplace.

Environment
Suppliers shall comply with all applicable environmental laws and regulations and continuously strive to improve environmental performance.

Responsible Agricultural Practices
Oil palm plantation-based suppliers shall commit to Responsible Agricultural Practices and strive towards finding the right balance between Economic, Social and Environmental aspects of business. These suppliers shall commit to the following principles: –

• No deforestation
• No new development on peat soils
• Reduction of Greenhouse Gasses (GHG)
• Increased focus and respect for local and indigenous communities including small holders and benefit of their socio-economic development.

Traceability
Suppliers shall live up to this Code of Conduct and committed towards a traceable palm oil supply chain.

Commitment on UP’s Supplier Code of Conduct

Introduction

UP has an important responsibility to ensure the safety and quality of our products. We are committed to ensure the sustainability of the palm oil sector and to encourage sustainable practices in all areas of our supply chain.
Our Supplier Code of Conduct reflects our commitment to conducting business in an ethical, legal, and responsible manner. We expect the same or similar commitments from our suppliers and collaborating parties in their supply chain. We strive to do business with responsible suppliers who treat their employees with respect and dignity, comply with applicable laws and regulations.

Compliance

Suppliers must comply with the legal requirements and standards of its industry based on all applicable laws and maintain documentation and records demonstrating compliance with such laws and the requirements of this or a similar Supplier Code. Suppliers are responsible for educating and monitoring collaborating parties in their supply chain.

Should a supplier fail to comply with the requirements of this Supplier Code of Conduct and thereby is viewed as a high-risk supplier (self-assessment scored below 50%), UP shall immediately request for corrective measures to be implemented to remediate such non-compliance with time-bound action plan within 60 days. If suppliers fail to show genuine remediation requirements, UP will as a last resort, terminate commercial relationships with the supplier.

Declaration by Supplier

We, the undersigned hereby confirm that:

• We understand and accept the content of UP’s Supplier Code of Conduct
• We will provide upon UP’s request relevant documentation supporting our compliance with the Code subject to mutual consent.

Name of Company:
Business license/registration no.:
Name of officer:
Position:
Date:
Company stamp:

Summary of Materiality Matters

Sustainability Governance Management Structure