Assessment Report - Care Certification International
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Date: 14 November to 14 November Assessment Report 2018 [Disclaimer: The audit report has been generated to reflect the compliance of the company toward the MSPO standard and every criterion’s have been in every effort taken to ensure the accuracy of the assessment and reporting produced. As the assessment is been carried MSPO 253O:2013 out based on sampling, certain areas or processes may not be able to verified on its Part 4 compliances. ] Company name Sime Darby Plantations Sdn. Bhd. Bukit Puteri Palm Oil Mill – SOU 10 Address K/B31, Sungai Koyan, 27650 Raub, Pahang Darul Makmur. Malaysia. Report no MS18SM0040 Status of audit Surveillance If surveillance No.1 1 CCI-QP-07-07A
Thank you for your trustful cooperation during our audit of your organization. This report has been prepared of every effort to ensure the accuracy of the information recorded. The assessment is based on sampling on the records, practice, documents and personnel, therefore the final results of the assessment is of representative towards the system implementation of the organization. This report may generated to record as much of the system implementation information but may still limited due to the sampling .This report details the assessment results including strengths, opportunities, and weaknesses. These results were presented to your management at the closing meeting of the audit. You can use these results to improve the effectiveness of your management system. We look forward to continuing our partnership towards sustainable business success. This report has been prepared in compliance to the ISO 17021:2011 requirements. To ensure the next assessment will be carry out in compliance to the ISO 17021:2011, please remember to immediately notify CARE Certification International about any significant change to your company at any point of time. Together we will then coordinate appropriate measures to maintain your current certification. Such circumstances include, for example, changes relating to the legal, commercial, organizational status or ownership, organization and management (e.g. key managerial, decision making or technical staff), contact address and sites, scope of operations under the certified management system, and major changes to the management system and processes. Together we CARE and will then ensure the smoothness of the upcoming assessment. Thank you for your persistence of support. Signed for on behalf of CCI Signed for on behalf of client Sign Name : IC : Name Mohammad Hafizuddin Bin Rossley Company stamp Date 14/11/2018 Email admin@cciglobe.com Fax no 038073 2688 2 CCI-QP-07-07A
Section A General Information General Audit objectives To verify that the system initial implementation is in accordance to requirements of the standard adopted. To verify that the system implementation is continuously in accordance to the requirements of the standards adopted. To verify that the system implementation is continuously after and in third years of implementation is in accordance to the standards adopted. Other, (please specify) Integrate Assessment No Issue of certificate Yes Scope of Certification Scope of certification in English The provision of Fresh Fruits Bunch (FFB) processing by palm oil mill Requirement not being applicable nil Justification nil Other language than above No Changes from Previous registration No Extension/changes of scope date NA Contact Details Management Representative En Amirul Akmal Daud Alternate contacts En Hazrul bin Zulkefli Management Representative contact no. +6012-5896199 E-mail address hazrul.zulkifli@simedarbyplantation.com Fax Number +(603) 7848 4363 Fixed Line Number +(603)78484366 NO OF GROUP MEMBERS 1 Section B Previous Audit Result The result of the last audit system have been reviewed, in particular to ensure appropriate correction and corrective action has been implemented to address any nonconformities identified. This review has concluded that: No nonconformities have been raised during last assessment. Any nonconformities identified during last previous audit have been corrected and the corrective action continuous to be effective. The management system has not adequately addressed non conformity identified during previous audit activities and the specific issue has been re-defined in the nonconformity section of this report. Section C Conclusion 3 CCI-QP-07-07A
The audit team conducted a process based audit focusing on significant aspects/risk objectives required by the standard(s). The audit methodology used is based on 3P which were People, Paper and Practice. The audit team concludes and express CONGRATULATION and has CONGRATULATION however some processes need to address non-compliance(s) but others has SORRY and the organization has not established and maintained its management system in line with the requirements of the standard and demonstrated not demonstrated the ability of the system to systematically achieved agreed requirements within the scope of the organizations. Base on the record, there is/are NIL unresolved issue. Therefore the audit team recommends that based on the results of this audit and the system's demonstrated state of development and maturity, management system certification be: Granted (initial certification or recertification) Granted upon the acceptance of the noncompliance(s) Continued (surveillance) Continued (surveillance) upon the acceptance of the noncompliance(s) Withheld suspend until satisfactory corrective action(s) is completed Others (please specify) Note : The assessment and recommendation for the initial or continue was based on random samples and therefore nonconformities may exist which have not been identified. All the pages should be attached if the organization wishes to copy and delivered to the interested party. Section D (For Recertification only) 1 The company has demonstrated effective implementation and maintenance/improvement on its Yes No management system 2 The internal audit program has been fully implemented and demonstrates its effectiveness as a Yes No tool for maintaining and improving the management system. 3 The management review process demonstrates its capability to ensure the continuing suitability, Yes No adequacy and effectiveness of the management system 3 The management review process demonstrates its capability to ensure the continuing suitability, Yes No adequacy and effectiveness of the management system 4 Throughout the audit process, the management system demonstrates overall conformance with Yes No the requirements of the audit standard 4 CCI-QP-07-07A
Section E Auditor and Auditees Names CCI Assessors Attendance during opening and closing meeting Team leader Name Designation Mohamad Hafizuddin As per Appendix 1 Team member Badrul Hisham Johari Kasim Trainee auditor NA Observer Section F Audit Process Matrix Next Audit Matrix (legend “ ” plan to cover & covered, “ ” for uncover) Planned month & year 11/2018 11/2019 11/2020 11/2021 11/2021 Internal Audits Stakeholder consultation / survey Use of logo Follow-up from previous audit finding 4.1 Management Commitment & Responsibility 4.1.1 MSPO Policy 4.1.2 Internal audit 4.1.3 Management Review 4.1.4 Continual Improvement 4.2 Transparency 4.2.1 Transparency of information and documents relevant to MSPO requirements 4.2.2 Transparent method of communication and consultation 4.2.3 Traceability 4.3 Compliance to legal requirements 4.3.1 Regulatory requirements 5 CCI-QP-07-07A
4.3.2 Land use rights 4.3.3 Customary land rights 4.4 Social responsibility, health, safety and employment condition 4.4.1 Social impact assessment (SIA) 4.4.2 Complaints and grievances 4.4.3 Commitment to contribute to local sustainable development 4.4.4 Employees safety and health 4.4.5 Employment conditions 4.4.6 Training and competency 4.5 Environment, natural resources, biodiversity and ecosystem services 4.5.1 Environmental management plan 4.5.2 Efficiency of energy use and use of renewable energy 4.5.3 Waste management and disposal 4.5.4 Reduction of pollution and emission including green house gas 4.5.5 Natural water resources 4.6 Best Practices 4.6.1 Mill management 4.6.2 Economic and financial viability plan 4.6.3 Transparent and fair price dealing 4.6.4 Contractor Assessment man days for the next assessment : 3 md. Recertification: 3 Note: Recertification should be carry out minimum 2 months prior to the expiry of the certificate Section G Audit Note Summary of Area Audited BUSINESS AREAS DETAILS OF AUDITED SUMMARY Auditor Date Time HF 14/11/2018 9.30 Opening Meeting a) introduction of the participants, including an outline of their roles; b) confirmation of the scope of certification; c) confirmation of the audit plan (including type and scope of audit, objectives and criteria), any changes, and other relevant arrangements with the client, such as the date and time for the closing meeting, interim meetings between the audit team and the client's management; d) confirmation of formal communication channels between the audit team and the client; e) confirmation that the resources and facilities needed by the audit team are available; f) confirmation of matters relating to confidentiality; g) confirmation of relevant work safety, emergency and security procedures for the audit team; h) confirmation of the availability, roles and identities of any guides and observers; i) the method of reporting, including any grading of audit findings; j) information about the conditions under which the audit may be premature terminated; k) confirmation that the audit team leader and audit team representing the certification body is responsible for the audit and shall be in control of executing the audit plan including audit activities and audit trails; l) confirmation of the status of findings of the previous review or audit, if applicable; 6 CCI-QP-07-07A
m) methods and procedures to be used to conduct the audit based on sampling; n) confirmation of the language to be used during the audit; o) confirmation that, during the audit, the client will be kept informed of audit progress and any concerns; p) opportunity for the client to ask questions. Closing Meeting a) informing the client that the audit evidence collected was based on a sample of the information; thereby introducing an element of uncertainty b) the method and timeframe of reporting, including any grading of audit findings; c) the certification body's process for handling nonconformities including any consequences relating to the status of the client's certification; d) the timeframe for the client to present a plan for correction and corrective action for any nonconformities identified during the audit; e) the certification body's post audit activities; f) information about the complaint handling and appeal processes. g) Any diverging opinion that are not resolved. h) opportunity for the client to ask questions. Executive Summary The audit was based on the MSPO2503:2013 Part 4 Standard, procedure and and applicable requirements. There is 4 NC and 1 OFI been raise during the last year audit for 2nd stage assessment audit conducted on 9-11/10/2018 and found all the NC were closed accordingly and the evidence is adequate. The audit were done one whole day with total mandays for audit at Bukit Puteri POM is four (3) mandays for this surveillance 1 audit. The audit was lead by Mr Mohamad Hafizuddin who are have almost 8 years in the sustainable certification and other management system certification such as RSPO, ISCC, ISO 14001, ISO9001 etc and also attended the MSPO Lead Assessor Course conducted by SIRIM. Co auditor is Mr Johari Kasim who are experienced in the RSPO and ISCC Certification for almost 7 years and attended the MSPO Lead Assessor Course conducted by SIRIM. Co auditor is MR Badrul Hisham Bin Hj Baharin who are having experince in palm oil industry for almost 8 years and attended the MSPO Lead Assessor conducted by SIRIM. Audit Summary Principle 1: Management Commitment & Responsibility Sighted management establish 16 policy towards sustainability policy. Communication of the policy sighted done by display at the notice board, briefing during MSPO awareness training and explain the policy to the stakeholder during the stakeholder meeting. Sighted 6 Project for Continual Improvement Programs as sighted in Kaizen Charter: 1. To install staircase and platform for water pipeline strainer cleaning and maintenance works. This programs give an improvement on safety during the mill operations 2. To reduce oil loss at raw effluent to FFB from 0.60 to 0.50- The potential benefit is saving the cost RM150, 000 3. To increase yearly sales revenue of scrap iron from RM0 to RM25,000.00 4. To increase mill utilization from 40% to 50% 5. To improve safety during conveyor crossing 6. To improve safety during CPO dispatch Bukit Puteri POM establish the procedure for internal audit and already done the Internal Audit on as per email Internal Audit notification. Bukit Puteri POM conducted the MRM on 22/03/2018 chaired by Chairman, the agenda is cover all the MSPO Principle matters such as Employee Safety & Environmental, Employee Condition, Continual Improvement, CAR Status etc. Principle 2: Transparency Generally, Bukit Puteri Palm Oil Mill communicate the information with stakeholders and public through meeting with stakeholders. The mill management annually organize get together with local communities as part of promoting MSPO requirements as per SOP (Pihak Berkepentingan). The recent meeting was held on 22 March 2018. For every issue raised the Mill management has prepared management plan on social impact assessment. Bukit Puteri POM has established procedure for stakeholder (SOP: Stakeholder Procedure) and Complaints Procedure. Records of complaints and grievances were implemented by Complaints Form for Stakeholder/supplier and Internal. So far nil complaint were receive and been recorded. Principle 3: Compliance to legal requirements During audit sighted Bukit Puteri POM is had establish the list of legal requirement and verified the 7 CCI-QP-07-07A
evaluation assessment is had been done for the compliance legal requirement assessment. All the requirements evaluated if there is ammendment or additional legal requirement. Noted the mill land title is belong to Sime Darby Plantation Berhad Bhd under the below lot# (Borang 11BK) H.S.(D)/H.S.(M) No: HSD 30 No lot: PT 856 Luas Lot: 2000 Ekar Verified the land titile terms : i. Syarat-syarat nyata - Tiada ii. Sekatan -sekatan kepentingan - Tiada Principle 4: Social responsibility, health, safety and employment condition 1) Social Noted Bukit Puteri POM conducted the Stakeholder Meeting on 22/03/2018 with involvement from the stakeholders such as Ketua Kampung, smallholders, sister estate, contractor, supplier etc. Bukit Puteri POM establish the Management Plan On Social Impact Assessment from the feedback collected during the Stakeholder Consultation. Bukit Puteri POM establish the Prosedur Aduan for dealing with complaints and grievances. All stakeholder are freely to request the Complaint Form from the Mill Management and submit by insert to the Complaint Box in front of the mill's guard house. The communities surrounding was aware with the complaint procedure and briefed was done in the stakeholder consultation and most of the mill workers are from the local communities. No complaintreceived and been verified during this assessmnet of audit. 2) Health & Safety Policy was established and endorsed by the Chairman of company which shown the committed from top management toward implementation of safety & health in working area. Bukit Puteri POM establish the Safety Plan which has planned for Safety Training & briefing, OSH Committee meeting, Chemical Handling etc. HIRARC for mill operation such as laboratory, loading ramp, sterilizer, threshing etc. was established in order to assess the risk in order to provide the control for the medium and higher risk level. Verified the HIRARC and required PPE such as hand glove, ear plug, safety shoe, safety helmet etc. were implemented as in HIRARC. 3) Employee condition Social and Humanity management Policy were sighted displayed at the strategic area such as notice board, guard post and conducted a briefing during row call to Bukit Puteri POM employees. The stakeholder also been explained on the policies available during the stakeholder meeting. Refer to Social and Human Right, has mentioned of no discrimination allowed and to provide equal opportunity regardless of race, colour, sex, nationality etc. The company seek to maintain a workplace free from discrimination. Verified the employee pay slip and found the calculation of the OT and basic salary was comply with the minimum standards with sufficient employee contract agreement. This discrimination-free was further strengthened by an employee representative during interviews with the staff . Principle 5:Environment, natural resources, biodiversity and ecosystem services Sighted management establish Environmental Policy on January 2015 and approved by the Managing Director. Communication of the policy sighted done by display at the notice board, briefing during MSPO awareness training to employee and explain the policy to the stakeholder during the stakeholder meeting. Bukit Puteri POM has identified environmental objective in Environmental Management & Improvement Plan to comply with Environmental Quality Act 1974, specifically in Scheduled waste regulation 2005 and Environmental Quality Act. Other are to create clearer and cleaner environment by making continuous improvement, practice conservation of natural resources and promote environmental awareness among all employees & third parties for better working environment. Jabor POM establish the Environmental Impact Assessment and identified the aspect & impact of mill operation to the environment. Jabor POM establish the comprehensive assessment report of water usage as per Water Management Plan for FY 2018. Principle 6: Best practices Bukit Puteri POM establish the SOP for mill operation were properly documented. Verified the Bukit Puteri POM year 2018 budget as per Capital Expenditure Budget For Year 2017/2018 consist of budget for buildings, electrical, plant & machinery, water supply, office equipment and furniture & fittings and Budget Mill Processing Cost Summary For Financial Year 2018 consist of maintenance & repair, general machinery etc. The price rate of the FFB was calculated consistently as per MPOB rate . The contract agreement with contractors is fairly price dealing and agreed by both party. As a conclusion verified the mill ahd maintain the management system in according to compliance of MSPO 2530:2013 part 4. For this period of review there is only 1 Observation of findings. Stakeholder Consultation 8 CCI-QP-07-07A
For this period of review there is no stakeholder consultation been conducted due to surveillance audit. Introduction 1. Location of the mill NAME OF MILL LOCATION COORDINATE Bukit Puteri Oil Mill Peti Surat 31, Sungai Koyan, N 04° 12’ 09” , E 101°51’ 45” 27650, Raub, Pahang. 2. Approximate tonnage certified per year NAME OF MILL CPO PK Bukit Puteri Oil Mill 10,107.33 6459 3. Location of the supply base NAME LOCATION Bukit Puteri Estate Peti Surat 31, Sungai Koyan, 27650, Raub, Pahang. Green Agro Pyramid Business Lot No. 48444, Along Jalan Tambun, 31400, Kinta, Perak. Trading Noor Azlan Bin Kasmani Kampung Keledek, Bukit Betong, 27200, Kuala Lipis, Pahang. Pertiwi Palms Sdn Bhd Sungai Tempuai, Mukin Batu Yon, 25350, Lipis, Pahang. CK Teik Enterprise Sdn Bhd Lot 1312, Petak 2, Jalan Bukit Kukus, Mukim Lunas, 09000, Kulim, Kedah. 4. Statistic of the supply base NAME ESTIMATE TONNES FFB/YEAR Bukit Puteri Estate 48,410.79 Green Agro Pyramid Business 1,800 Trading Noor Azlan Bin Kasmani 3,600 Pertiwi Palms Sdn Bhd 10,800 CK Teik Enterprise Sdn Bhd 1,800 9 CCI-QP-07-07A
Audit Checklist P1: Management Commitment & Responsibility Criterion 1 Malaysian Sustainable Palm Oil (MSPO) Policy Indicator Requirement Findings 4.1.1.1 A policy for the implementation of MSPO shall be established BUKIT PUTERI POM The management has established sustainable policy as sign by Sime Dary Managing Director on January 2015. As sighted 16 Policy towards Sustainability I. Safety & Health Management Policy II. Quality Management Policy III. Social & Humanity Management Policy IV. Corporate Policy Statement V. Polisi Keselamatan Makanan VI. Polisi Perlindungan Orang Utan VII. Polisi Perlindungan Kanak-Kanak VIII. Polisi Lean Six Sigma IX. Polisi Perlindungan Cerun & Sungai X. Environmental Managemenet Policy XI. Polisi Sosial XII. Polisi Alam Sekitar & Kepelbagaian Biologi XIII. Polisi Keselamatan & Kesihatan Pekerjaan XIV. Polisi Jantina XV. Polisi Karbon XVI. Polisi Kualiti Verified the policy had been display in office general board.Verified the policy had been brief to all employees, contractors and FFB suppliers during the MSPO Awareness Training dated 8/10/2018 4.1.1.2 The policy shall also emphasize commitment to continual improvement with the objective of improving the milling operation. SIME DARBY BUKIT PUTERI POM The management has established a Polisi Lean Six Sigma as policy to emphasize on the engagement and commitment to produce sustainable palm oil with the objective of improving the milling and estate operation for continual improvement to be implemented on the estate operation Continual Improvement Programs as sighted in Kaizen Charter: i) To install staircase and platform for water pipeline strainer cleaning and maintenance works. This programs give an improvement on safety during the mill operations ii) To reduce oil loss at raw effluent to FFB from 0.60 to 0.50- The potential benefit is saving the cost RM150, 000. Criterion 2 Internal Audit Indicator Requirement Findings 4.1.2.1 Internal audit shall be planned and conducted regularly to determine the strong and weak points and potential area for further improvement. SIME DARBY BUKIT PUTERI POM Sighted the internal audit programmed in the “Program Internal Audit and Proposed Assessment Plan for SOU 10: Bukit Puteri Plan Dated 21 March 2018. The internal audit was conducted on 21 March 2018 as sighted in internal audit plan. The assessment was conducted by Mr Hazrul Zulkifli and Mr Selvarani Ayeri. Seen the assessment covers requirements needed by the MSPO scheme and estate best practices which are result with 3 Major nonconformances had been raised. 1) Found that, there is no training has been conducted for COBC Training and Whistle Blowing Training 2) Sighted the latest contract (1/12/2017-31/12/2018) for Pertiwi Palms Sdn Bhd (PC/1217/FFB01115L) and Noor Azlan Bin Kasmani (P/C1217/FFN01114L) are not sign and stamp 3) 1 Permanent Standard Threshold Shift (PSTS) cases reported to DOSH through JKKP 7 by the mill management in June 2017 as stipulated in NADOPOD Regulation 2004 4.1.2.2 The internal audit procedures and audit results shall be documented and evaluated, followed by the identification of strengths and root causes of nonconformities, in order to implement the necessary corrective action 10 CCI-QP-07-07A
SIME DARBY BUKIT PUTERI POM The internal audit was conducted on 21 March 2018 as sighted in internal audit plan. The assessment was conducted by Mr Hazrul Zulkifli and Mr Selvarani Ayeri. Seen the assessment covers requirements needed by the MSPO scheme and estate best practices which are result with 3 Major nonconformances had been raised. 4) Found that, there is no training has been conducted for COBC Training and Whistle Blowing Training 5) Sighted the latest contract (1/12/2017-31/12/2018) for Pertiwi Palms Sdn Bhd (PC/1217/FFB01115L) and Noor Azlan Bin Kasmani (P/C1217/FFN01114L) are not sign and stamp 6) 1 Permanent Standard Threshold Shift (PSTS) cases reported to DOSH through JKKP 7 by the mill management in June 2017 as stipulated in NADOPOD Regulation 2004 4.1.2.3 Report shall be made available to the management for their review. BUKIT PUTERI POM The findings from internal audit were responded by the estate management during the “Management Review” of SOU Bukit Puteri RSPO & MSPO Internal audit on 22 March 2018. The audit findings, root cause and corrective action plan for internal audit findings has been discussed and reviewed during the meeting. Criterion 3 Management Review Indicator Requirement Findings 4.1.3.1 The management shall periodically review the continuous suitability, adequacy and effectiveness of the requirements for effective implementation of MSPO and decide on any changes, improvement and modification. BUKIT PUTERI POM Sighted the MRM dated on 22 March 2018 at estate’s office attended by 4 staff including estate manager. The management has conducted the staff and management meetings once per months. Last staff meetings were conducted on 15 Sept 2018 attended by 10 staff including POM Manager En Mohd Aerman Bin Ahmad. The minutes seen included of review Mill & Cost Performance, issue related to staff, and reviews on OSH matters. Criterion 4 Continual improvement Indicator Requirement Findings 4.1.4.1 The action plan for continual improvement shall be based on consideration of the main social and environmental impact and opportunities for the company. BUKIT PUTERI POM Sighted 6 Project for Continual Improvement Programs as sighted in Kaizen Charter: 1. To install staircase and platform for water pipeline strainer cleaning and maintenance works. This programs give an improvement on safety during the mill operations 2. To reduce oil loss at raw effluent to FFB from 0.60 to 0.50- The potential benefit is saving the cost RM150, 000 3. To increase yearly sales revenue of scrap iron from RM0 to RM25,000.00 4. To increase mill utilization from 40% to 50% 5. To improve safety during conveyor crossing 6. To improve safety during CPO dispatch 4.1.4.2 The company shall establish a system to improve practices in line with new information and techniques, and for disseminating this information throughout the workforce. BUKIT PUTERI POM -The SEMUA 2.0 as part of solution for data capture of Mandore and FFB recorder FFB count to send to mill as part utilizing digital technologies to digitize data at source and automate data flow. - The training of SEMUA 2.0 is being provided on-going basis by the Sime Darby HQ Support Team. P2: Transparency Criterion 1 Transparency of information and documents relevant to MSPO requirements Indicator Requirement Findings 4.2.1.1 The management shall communicate adequate information to other stakeholders on environmental, social and legal issues relevant to sustainable practices in the relevant languages and form. 11 CCI-QP-07-07A
BUKIT PUTERI POM Communication the information with stakeholders and public through meeting with stakeholders. The lasts stakeholders meeting was conducted on 22March 2018 which combined with Bukit Puteri Estate stakeholders meetings. The meeting were attend by 24 attendee including District Health Officer Mr Mohd Isham Ilias, Pejabat Kesihatan Lipis, District Labour Department Officer, Mr Mohd Khairi B. Siran and Head Village RTP Sungai Ular and Kg Keledek. The management has maintained a complaint and grievance log book that was established for tracking of external and internal complaint from stakeholders. 4.2.1.2 Management documents shall be publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes. BUKIT PUTERI POM Sighted in the “Sustainable Plantation Management System” manual date 01/11/2008, section “Documentation & Communication”- Clause 3.2, where appropriate information on sustainable activities will be made available to the general public/ stakeholders through yearly annual reports, circular, agreements, Sime Darby website and other publications. Specific request for information from interested parties shall be channeled to the PSQM, Communication Department and Legal Department of Sime Darby Criterion 2 Transparent method of communication and consultation Indicator Requirement Findings 4.2.2.1 Procedures shall be established for consultation and communication with the relevant stakeholders BUKIT PUTERI POM There is a flow chart titled dated 1/11/2018 “ Sustainable Plantation Management System” – for Internal {Appendix 5.5.3.1} and external { Appendix 5.5.3.2} established for communicating and reporting of EMS, OHS and social issues with relevant stakeholders. Sighted complaint and grievances log book that been documented accordingly. - The lasts stakeholders meeting was conducted on 22March 2018 which combined with Bukit Puteri Estate stakeholders meetings. The meeting were attend by 24 attendee including District Health Officer Mr Mohd Isham Ilias, Pejabat Kesihatan Lipis, District Labour Department Officer, Mr Mohd Khairi B. Siran and Head Village RTP Sungai Ular and Kg Kelede. Some issues had been raised during the meetings such as: i) The CPO transporter from Bukit Puteri POM to Refineries Mill request confirmation from POM regarding misleading weight from POM and Refineries Mill. . ii) District Health Officer requests corporation from BPOM and BPE to submit data regarding new staff and general workers. 4.2.2.2 A management official shall nominated officials at the operating unit responsible for issues related to indicator 1 (4.2.2.1) BUKIT PUTERI POM - En Khairul Shahrin Bin Mohd Yusof, POM Assistant Manager II has been nominated as officer to responsible to communication and consulation with the local communities and other interested parties. Sighted appointment letter date on 17 July 2017. 4.2.2.3 List of stakeholders, records of all consultation and communication and records of action taken in response to input from stakeholders should be properly maintained. BUKIT PUTERI POM The POM Management had maintained as per document list of stakeholders for FY 2018/19 consist of 17 contractors, 22 suppliers, 4 local communities, 27 government agencies and others. The last meetings was on 22 March 2018, sighted the attendance record attached with the minutes of meeting. Criterion 3 Traceability Indicator Requirement Findings 4.2.3.1 The management shall commit itself to implement and maintain the requirements for traceability and shall establish a standard operating procedure for traceability. BUKIT PUTERI POM The estate has implemented SOP for Tracebility Doc No: Appendix 15, dated May 2016 and SOP on Sustainable Supply Chain and Traceability SD/SDP/PSQM/001 dated 01/3/15 as to provide guideline to establish sustainable supply chain and traceability for FFB. Data capturing {bunch counting / grading} is done using conventional way of manual recording using bunch counter that link to “SEMUA 2.0’ System. This is a mobile solution for data capture of Mandore and FFB recorder FFB count, utilizing digital technologies to digitize data at source and automate data flow. 4.2.3.2 The management shall conduct regular inspections on compliance with the established traceability system 12 CCI-QP-07-07A
BUKIT PUTERI POM - The mill assistant management holds the responsibility on regular inspection, whereby the effectiveness of monitoring seen captured in the internal audit by PSQM. Aside there is also daily routine visit by the manager and annually visit by sustainability team members 4.2.3.3 The management should identify and assign suitable employees to implement and maintain the traceability system BUKIT PUTERI POM The management has appointed Mr Khairul Shahrin Bin Mohd Yusof, POM Assistant Manager ii for Bukit Puteri POM as officer to responsibility to maintain the traceability system. As sighted appoint letter date 17/07/2017. As per required performs to follows: I. Daily implementation of the MQMS II. Maintence of MQMS Manual and other documents (Review, Amendments and Update) III. Maintenance of the records, to ensure is controlled as per procedure IV. Calibaration of test equipments V. Overall in charge to ensure product dispatched by Estate meets customer requirements VI. Responsible for OSH, Environmentl and Quality Aspects VII. Records keeping for 10 years VIII. Monitor compliance and update change regulatory requirements. IX. Others related issues with regards to ISCC/RSPO/MSPO 4.2.3.4 Records of storage, sales, delivery or transportation of crude palm oil shall be maintained. BUKIT PUTERI POM -All data recorded as per SOP such as Date, Name of Supplier, Vehicle Number, Time In, Block, FFB Quality and Signature of Driver. The amount of FFB processed was crosschecked against the amount received. - The record of CPO Storage was recorded on the Daily Production Summary Report. As per date 14.11.2018 Total 869.176 Mt. - Record of Sales CPO had been record on Dispatched (Buyer’s and Group Mills) as per date 14.11.2018 Total: 503.580 Mt - Record of FFB Received: i) Ticket No: 98942 Supplier: E297-E-Bukit Puteri D.O No: 117027 Date 10/11/2018 Net Weight: 5540kg ii) Ticket No: 98782 Suppler: Noor Azlan Bin Kasmani D.O No: 0234 Date 7/11/2018 Net Wieght: 7290kg - Record of CPO Dispatch: Ticket No:003687 Customer: SDP NURI-Sime Darby Plantation Berhad Do No: 3301 Vehicele No: NDH6109 Date: 10/11/2018 Nett Weight: 38680kg Contract No: S/CCE/1810/CPO00107D - Record of PK Dispatch: Ticket No: 003600 Customer: Lee Oil Mills- Lee Oil Mills Sdn Bhd Do No: 1351 Vehicle No: CDJ8855 Date: 13/8/2018 Nett Weight: 35120kg Contract No: S/CCE/1808/PK0093 P3: Compliance to legal requirements Criterion 1 Regulatory requirements Indicator Requirement Findings 4.3.1.1. All operations are in compliance with the applicable local, state, national and ratified international laws and regulations BUKIT PUTERI POM The management has establish SOP - Legal Requirement Register dated on 10/12/2008 . As mention in procedure at least once a year or when there are changes in the legislation and/or other requirements assessment of compliance should be evaluate. 13 CCI-QP-07-07A
Verified during the audit, list of license and Permit related to the mill : DOE License: Lesen Premis Minyak Kelapa Sawit Mentah: No Lesen: 004160 Date Expired: 30 Jun 2019 Syarat Nyata DOE: ii. Fire Certificate - Akta Perkidmatan Bomba 1998. The certificate already expired on 10 Jan 2018. Sighted the management has made a progress on renewal the fire certificate. iii) Calibrate been conducted on 27 Feb 2018 v. MPOB License no : 536632004000 started 1 March 2018 until 28/02/2019 1) Sell and Transfer PK,CPO SPO 2) Buy and Transfer FFB 3) Store PK,CPO, SPO 4) Mengilang FFB iv) Lesen Penggunaan Sumber Air: No Lesen: SWUL/LPSA/106/2018 Expired Date on 31/12/2018 v) Lesen Bagi Pepasangan Persendirian Akta Bekalan Elektrik 1990: No Lesen: 2018/02552 Expired Date: 19/09/2019 List of Certificate of Fitness: 1) Water Softener No.3-PH PMT 3077- 5/2/2019 2) Empire Water Tube Boiler: -PH PMD 66- 5/2/2019 3) Air Receeiver- PH PMT 2290- 5/2/2019 4) Air Recevier –PH PMT 3639- 5/2/2019 4.3.1.2 The management shall list all laws applicable to their operations in a legal requirements register BUKIT PUTERI POM -Documented procedure has been established and implemented; refer to Estate/Mill Quality Management System, Level 2: Standard Operating Manual, Appendix 5.2.4: Procedure for Legal and Other Requirements dated 10 December 2008. List of applicable legal and other requirements was made available during the assessment and compiled in the QSHE/04/5.2.4 folder. All the legal and other requirements were register accordingly in the legal requirement register including FM (Steam Boiler and UPV) (Amendment) Regulation 2017. The evaluation was last carried out on 14/07/2018 by Assistant Manager and approved by Estate Manager. As to date, Bukit Puteri POM had complied with all the applicable local, state, national and ratified international laws and regulations. 4.3.1.3 The legal requirements register shall be updated as and when there are any new amendments or any new regulations coming into force. BUKIT PUTERI POM The LORR seen last reviewed and updated on 14/07/2018 by the Mr Khairul Shahrin and approved POM Manager. There is SOP Manual [Appendix 5.2.4a] that guides the operating units on how to monitor the progress of applicable law and regulations. The Group Sustainability Team [PSQM] will update the estates if there are any changes in the legal requirements. Observation: Since the POM is engage Auxiliary Police, the Police Act 1967 Seksyen 47-50 and Undang-Undang Negeri Pahang Enakmen 5 Enakmen Sumber Air 2007 for water abstracting has yet been listed on LOR to be monitor and reviewed by the management. 4.3.1.4 The management should assign a person responsible to monitor compliance and to track and update the changes in regulatory requirements. BUKIT PUTERI POM -Sighted management appoint Mr Khairul Shahrin Bin Mohd Yusof, Assistant Manager Bukit Puteri Palm Oil Mill date 1 July 2017 Function as follow: I. Ensuring LRR up to date and amend any new regulation coming into force. II. Documenting and issuing of document and report III. Monitoring compliance and track update and changes in regulatory requirements. Criterion 2 Land used right Indicator Requirement Findings 4.3.2.1 The management shall ensure that their oil palm milling activities do not diminish the land use rights of other users 14 CCI-QP-07-07A
BUKIT PUTERI POM Land title indicates the lands belonging to the Sime Darby. Sighted a sample of land title: (Borang 11BK) H.S.(D)/H.S.(M) No: HSD 30 No lot: PT 856 Luas Lot: 2000 Ekar 4.3.2.2 The management shall provide documents showing legal ownership or lease, history of land tenure and the actual use of the land. BUKIT PUTERI POM Land title indicates the lands belonging to the Sime Darby. Sighted a sample of land title: (Borang 11BK) H.S.(D)/H.S.(M) No: HSD 30 No lot: PT 856 Luas Lot: 2000 Ekar 4.3.2.3 Legal perimeter boundary markers should be clearly demarcated and visibly maintained on the ground where practicable. BUKIT PUTERI POM Sighted the mill boundary markers by the fencing surrounding the mill area 4.3.2.4 Where there are, or have been, disputes, documented proof of legal acquisition of land title and fair compensation that have been or are being made to previous owners and occupants; shall be made available and that these should have been accepted with free prior informed consent (FPIC). As to date, no land disputes issue been recorded. Criterion 3 Customary rights Indicator Requirement Findings 4.3.3.1 Where lands are encumbered by customary rights, the company shall demonstrate that these rights are understood and are not being threatened or reduced. No customary rights 4.3.3.2 Maps of an appropriate scale showing extent of recognized customary rights shall be made available No customary rights 4.3.3.3 Negotiation and FPIC shall be recorded and copies of negotiated agreements should be made available. No customary rights P4: Social responsibility, health, safety and employment condition Criterion 1 Social impact Assessment (SIA) Indicator Requirement Findings 4.4.1.1 Social impacts should be identified and plans are implemented to mitigate the negative impacts and promote the positive ones 15 CCI-QP-07-07A
Social Impact Assessment has been conducted by the team, lead by Social & Environment Projects Unit PSQM Department. Assessment date 17th - 18th September 2015. There are sighted a few feedbacks from Local communities, sample below: a) To provide better and save school transportation for mill and estate workers' children. b) To perform fogging activity at housing complex area. c) To provide quality PPE to workers. Internal and External stakeholder meeting has been conducted accordingly latest by 06/04/2017. Sighted the Management Plan on Social Impact Assessment FY 2018, dated 06/07/2018. Seen the area of concern, action plan, person in-charge and date of completion. Criterion 2 Complaints and grievances Indicator Requirement Findings 4.4.2.1 A system for dealing with complaints and grievances shall be established and documented Internal and external communication procedure was available. Sighted the complaint book at the office lobby. No complaint from stakeholders at this time of review. Sighted the Buku Laporan Kerosakan Rumah Pekerja - all issues were handle properly. 4.4.2.2 The system shall be able to resolve disputes in an effective, timely and appropriate manner that is accepted by all parties. Acknowledgement of the decision by both parties in complaints and grievances procedure. Sighted respond to the complaint were stated in the procedure will takes within 24 month 4.4.2.3 A complaint form should be made available at the premises, where employees and affected stakeholders can make a complaint. Complaint book are sighted in the office lobby. 4.4.2.4 Employees and the surrounding communities should be made aware that complaints or suggestions can be made any time All stakeholders were freely to write their complaint the mill management thru complaint book and submit the issues. The communities surrounding was aware with the complaint procedure and explanation was done during the stakeholder consultation and most of the mill workers are from the local communities. 4.4.2.5 Complaints and resolutions for the last 24 months shall be documented and made available to affected stakeholders upon request. Sighted the record of complaint were maintained since 2015 until today. As at year 2018 no complaint receive from the relevant stakeholder.. Criterion 3 Commitment to contribute to local sustainable development Indicator Requirement Findings 4.4.3.1 Palm oil mill should contribute to local development in consultation with the local communities. Where the mills in an integral part of plantation, such contribution to local community development may be regarded as a joint effort by the mill and the plantation. 16 CCI-QP-07-07A
Sighted record of CSR activity for 2018 are available. Example; 1. Donation to SK Kampung Keledek for sport activities, dated 26/04/2018. 2. Donation to SK (FELDA) Sungai Koyan for sport karnival, dated 02/02/2018. Criterion 4 Employees safety and health Indicator Requirement Findings 4.4.4.1 An occupational safety and health policy and plan shall be documented, effectively communicated and implemented Occupational Safety Policy sighted in document dated on January 2015. ESH Plan for FY2017/2018.That include in few area as example: 12 Area. 1. ESH Risk management. 2. ESH Structure. 3. Incident reporting 4. Health and Hygiene monitoring 4.4.4.2 The occupational safety and health plan shall cover the following: a) A safety and health policy, which is communicated and implemented • OSH Policy date on January 2015. • Communication on the Policy sighted in document Training plan and ESH Plan. • HIRARC has been conducted based working station example Loading Ramp. • Boiler use. • Operating machine There is one minor accident has been reported for year 2018, dated 05/07/2018. The worker is given one day MC only. The mill did the fresher on their SOP to their workers and put more safety signage’s at risk place. OSH Meeting has been conducted every 3 months, Last conducted in 27/08/2018. Verified the meeting agenda and list of attendance. b) The risks of all operations shall be assessed and documented Verified the HIRARC for mill operation such as laboratory, loading ramp, sterilizer, threshing etc. The HIRARC was reviewed on 17/11/2018 for 4 areas which is; Grinding machine, cutting machine, welding set and gas cutting torch. c) An awareness and training programme which includes the following requirements for employees exposed to pesticides: i) all employees involved shall be adequately trained on safe working practices; and ii) all precautions attached to products shall be properly observed and applied. ii. Sighted the relevant awareness training had been included in the ESH program for year 2017/18. Sighted training for Chemical Safety Training had been conducted dated on 28/12/2018 - Kursus Rawatan Air Mentah conducted by chemical supplier named NAKO. Seen the attendance list. ii. Sighted MSDS and Chemical handling procedure were in place at the Chemical store. d) The management shall provide the appropriate personal protective equipment (PPE) at the place of work to cover all potentially hazardous operations as identified in the risk assessment and control such as Hazard Identification, Risk Assessment and Risk Control (HIRARC). 17 CCI-QP-07-07A
Record for PPE Distribution are available. All potential area has been identified according to the HIRARC. e) The management shall establish Standard Operating Procedure for handling of chemicals to ensure proper and safe handling and storage in accordance to Occupational Safety Health (Classification Packaging and Labeling) Regulation 1997 and Occupational Safety Health (Use and Standard of Exposure of Chemical Hazardous to Health) Regulation 2000. Verified document on procedure Chemical Safety Management. Sighted during site visit at chemical store the pictorial work instruction for chemical handling and SDS were in place. f) The management shall appoint responsible person(s) for workers' safety and health. The appointed person(s) of trust must have knowledge and access to latest national regulations and collective agreements. Verified the safety and health committee organisation chart and noted the secretary of the OSH Committee will responsible for any safety issue for the company. Sighted the appointment letter for all the committee members were dated on 21/3/2018. g) The management shall conduct regular two-way communication with their employees where issues affecting their business such as employee's health, safety and welfare are discussed openly. Records from such meetings are kept and the concerns of the employees and any remedial actions taken are recorded. Safety and health committee are available. That has been conducted quarterly basis as per OSHA 1994. h) Accident and emergency procedures shall exist and instructions shall be clearly understood by all employees. Emergency preparedness and response procedure are available. i) Employees trained in First Aid should be present at all field operations. A First Aid Kit equipped with approved contents should be available at each worksite Sighted the first aid training certificate conducted by Academy of Safety and Emergency Care on 22/2/2018. Total participant who attend the training is 4 (involves laboratory, electrical man, mandore etc). Seen the certificate of training for Lydiyawati Binti Abu Bakar. j) Records shall be kept of all accidents and be reviewed periodically at quarterly intervals. There are no accident has been reported in 2017-2018. Criterion 5 Employment conditions Indicator Requirement Findings 4.4.5.1 The management shall establish policy on good social practices regarding human rights in respect of industrial harmony. The policy shall be signed by the top management and effectively communicated to the employees 18 CCI-QP-07-07A
Sighted management established Social Policy and gender Policy dated November 2015 and approved by MD. The policy content included below: a) comply with all labor law and regulation b) Implement fair and reasonable working contract and requirement c) To respect the employees’ rights to associate and join unions d) To provide reasonable wages that meet living requirement Communication of the policy sighted done by display at the notice board, briefing on policy to the stakeholder during the stakeholder meeting. 4.4.5.2 The management shall not engage in or support discriminatory practices and shall provide equal opportunity and treatment regardless of race, colour, sex, religion, political opinion, nationality, social origin or any other distinguishing characteristics. Refer to Social Policy and Gender Policy had mentioned no discrimination on race, gender, nationality, religion and political view. The company seek to maintain a workplace free from discrimination. 4.4.5.3 Management shall ensure that employees’ pay and conditions meet legal or industry minimum standards and as per agreed Collective Agreements. The living wage should be sufficient to meet basic needs and provide some discretionary income based on minimum wage. Verified the employee pay slip and found the calculation of the OT and basic salary was complying with the minimum standards. Samples below; 1- Mohd Hishamudin - Salary date Oct 2018. Gross salary RM1,507.57 2- Zuriami Taha - Salary date Oct 2018. Gross salary RM1,246.16 3- Mohamad Taufik - Salary date Oct 2018. Gross salary 1,717.23 4.4.5.4 Management should ensure employees of contractors are paid based on legal or industry minimum standards according to the employment contract agreed between the contractor and his employee Verified the contract agreement and found sufficient and the payment salary of contractor employee were according minimum wages standard requirement. 4.4.5.5 The management shall establish records that provide an accurate overview of the employees (including seasonal workers and subcontracted workers on the premises). The records should contain full names, gender, date of birth, date of entry, a job description, wage and the period of employment. Verified the list of the employee data from Mill & Foreign Workers Particular were recorded in the system SAP and sighted the data contain name, gender, date of birth, date of entry, job description and wage rate. 4.4.5.6 All employees shall be provided with fair contracts that have been signed by both employee and employer. A copy of employment contract is available for each and every employee indicated in the employment records As per 4.4.5.4 4.4.5.7 The management shall establish a time recording system that makes working hours and overtime transparent for both employees and employer. 19 CCI-QP-07-07A
Time records of employee is based on the Punch Card and the salary calculation by System SAP. Verified the salary calculation as per 4.4.5.3 and found accurate with the system calculation. 4.4.5.8 The working hours and breaks of each individual employee as indicated in the time records shall comply with legal regulations and collective agreements. Overtime shall be mutually agreed and shall always be compensated at the rate applicable and shall meet the applicable legal requirement Verified the record of working hours were generated through punch card and be manually key by the clerk in to the SAP system. Verified records of payslip of employee , the payment of OT were as per employment act and collective agreement. 4.4.5.9 Wages and overtime payment documented on the pay slips shall be in line with legal regulations and collective agreements Verified the pay slip and punch card working time records and found the calculation is sufficient as per legal regulation. 4.4.5.10 Other forms of social benefits should be offered by the employer to employees, their families or the community such as incentives for good work performance, bonus payment, professional development, medical care and health provisions Refer to employment contract as below: Section 5: Housing provided free by employer. Section 12: Employer will provide the healthcare facility and provide medical benefit to the employee Section 11: Foreign Workers Compensation Scheme Policy provided by the Employer Deceased in the event of any employee dies in the cause of his employment 4.4.5.11 In cases where on-site living quarters are provided, these quarters shall be habitable and have basic amenities and facilities. Site visit at the workers' quarters and found all the basic amenities and facilities was provided sufficiently such as electricity and fresh water. Noted the employee quarters for mill and estate are located in same area. However the mill quarter managed by POM management itself. 4.4.5.12 The management shall establish a policy and provide guidelines to prevent all forms of sexual harassment and violence at the workplace POM establish the gender Policy dated November 2018 and the guideline are as per Gender committee handbook first edition year 2014. 4.4.5.13 The management shall respect the right of all employees to form or join trade union and allow workers own representative(s) to facilitate collective bargaining in accordance with applicable laws and regulations. Employees shall be given the freedom to join a trade union relevant to the industry or to organize themselves for collective bargaining. Employees shall have the right to organize and negotiate their work conditions. Employees exercising this right should not be discriminated against or suffer repercussions. Palm Oil Mill show the respect the right of employees to join the trade union as per Social Policy dated November 2018 and verified total employees who join trade union under NUPW (14 employee) and AMESU (13 employee). Sighted the records of latest minutes meeting of NUPW dated on 02/04/2018 20 CCI-QP-07-07A
4.4.5.14 Children and young persons shall not be employed or exploited. The minimum age shall comply with local, state and national legislation. Work by children and young persons is acceptable on family farms, under adult supervision, and when not interfering with their education. They shall not be exposed to hazardous working conditions. Verified the in the employee recorded in the SAP system NIL under age workers work in the premise. Criterion 6 Training and competency Indicator Requirement Findings 4.5.6.1 All employees, contractors and relevant smallholders are appropriately trained. A training programme (appropriate to the scale of the organization) that includes regular assessment of training needs and documentation, including records of training shall be kept. Verified the Training Matrix for all employee for year 2018 and listed Training requirement for mill as per sample below: a) OSH Act & regulations awareness b) SOP for all mill sections c) RSPO supply chain certification standard 4.5.6.2 Training needs of individual employees shall be identified prior to the planning and implementation of the training programmes in order to provide the specific skill and competency required to all employees based on their job description. Verified the Training Record and attendance list as below: a) SOP Training (reception, oil room, press, kernel plant) dated 03/10/2018 conducted mill supervisor. b) Induction Training for new workers (COBC, Policies) dated 03/10/2018 conducted by Q&C Engineer. c) MSPO Awareness training dated 02/10/2018 . 4.4.6.3 A continuous training programme should be planned and implemented to ensure that all employees are well trained in their job function and responsibility, in accordance to the documented training procedure. Verified the Training Plan for Year 2018 and listed 27 planned training such as Act & Regulation, SOP Training, MSPO Awareness etc. P5 Environment, natural resources, biodiversity and ecosystem services Criterion 1 Environmental management plan Indicator Requirement Findings 4.5.1.1 An environmental policy and management plan in compliance with the relevant country and state environmental laws shall be developed, effectively communicated and implemented. Sighted management establish Environmental Policy dated January 2015 and approved by managing director. Communication of the policy sighted done by display at the notice board, briefing during Policy & COBC awareness training to employee dated 3/10/2018 . 4.5.1.2 The environmental management plan shall cover the following: a) An environmental policy and objectives. b) The aspects and impacts analysis of all operations 21 CCI-QP-07-07A
POM has identified environmental objective in Environmental Management Programme For Financial year 2018: i) To ensure final discharge below 100mg/lBOD ii) To ensure boiler smoke density reading operate below ringelman chart no.2 POM KKS Bukit Puteri establish the Environmental Impact Assessment and identified the aspect & impact of mill operation to the environment. Sample of the impact as below: a) Station: Laboratory Activity: Operation laboratory Env. Aspect: Waste disposal Impact: Create land contamination and community impact, Reduce impact of business impact. b) Station: Effluent Treatment Plant Activity: Treatment of effluent. Env. Aspect: Release to air Impact: Create global warning, air pollution, unpleasant working environment impact. c) Station: Clarification Activity: Maintenance of sludge pit pumps and pipes Env. Aspect: spillage Impact: Create impact Land contamination and unpleasant working environment. 4.5.1.3 An environmental improvement plan to mitigate the negative impacts and to promote the positive ones, shall be developed, effectively implemented and monitored. POM establish the Continual Improvement in Environment Management & Improvement Plan dated 9/07/2018 sample of the program as per below: i. Water pollution - disludging work for ETP Pond By Using Geotube Method ii. Air pollution - monitoring and maintenance on multi-dust cyclone system iii. High water usage - eliminate water wastage with dry cleaning - Rectify oil water leaking iv. High boiler consumption - rectify steam leakages - motor capacitor bank installation The progress of monitoring status of implemetation were still in progress. Pollutions preventive management plan 2018 dated on 9/7/2018 were cover pollution source contribute area as per sample below : i. Linesite/housing ii. Laboratory iii. Main store, chemical store, schedule waste store iv. genset/diesel store v. workshop vi. Transport vii. Effluent viii. Emmission 4.5.1.4 A programme to promote the positive impacts should be included in the continual improvement plan As per 4.5.1.3 4.5.1.5 An awareness and training programme shall be established and implemented to ensure that all employees understand the policy and objectives of the environmental management and improvement plans and are working towards achieving the objectives. Refer to the Training Record and sighted sufficient training related to environment and sample as below: i. Esh Training ii. SOP Training for water treatment plant iii. SOP Training for Chemical handling iv. Training in Schedule waste handling 4.5.1.6 Management shall organize regular meetings with employees where their concerns about environmental quality are discussed 22 CCI-QP-07-07A
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