Malaysia is composed of West Malaysia, also known as Peninsular Malaysia, and East Malaysia consisting of the states Sabah and Sarawak. Responsibilities for forestry are divided between the federal and state governments. The forestry departments of each state are responsible for regulating forest exploitation and management. The departments of the 11 states of Peninsular Malaysia come under the umbrella of the Forestry Department of Peninsular Malaysia, while the departments of Sabah and Sarawak are autonomous.
According to the FAO (2015), Malaysia has around 22.2 million hectares of forested land, which constitutes to 67.6% of the total land area. Around 20.2 million hectares of the forested land is primary or otherwise naturally regenerated forest, and around 2.0 million hectares is planted forest. In Malaysia timber can be harvested from 3 different sources (NEPCon, 2016):
- Natural (or semi-natural) forests
Natural forests are under state ownership, except for some alienated (privatised) land where forest clearance is permitted for private use. For the forests under state ownership a basic distinction can be made for forests inside the Permanent Reserved Forests (PRF) and on state land outside the PRF. The state has the management rights of these forests, but these are transferred to private parties via private concessions in the PRF, or harvesting permits in state lands.
- Timber plantations
Timber plantations are often established in the PFR, where management rights of the state are transferred to private parties via private concessions. Timber plantations are rarely established on state land, although state land which has a former status of PFR could hold timber plantations. Here the state has the management rights, which are transferred to private parties via harvesting permits. Timber plantations are seldom established on private land, since it is usually more profitable to grow oil palm or rubber (for latex).
- Agricultural areas
Rubber plantations on agricultural areas account for approximately 1 million hectares of the total area of planted forest, being the main timber source from agricultural areas. This timber originates mainly from rubber plantations that are being cleared for oil palm or for another rotation of rubber. The land is primarily privatised (alienated) land, but to a limited extent also state owned land inside and outside the PFR.
About 22% of the Permanent Reserved Forest (PRF) is not used for commercial production, but is designated as protected. Such protected forests are managed by the state and include: non-harvestable forest (areas above certain altitudes and slopes), virgin jungle reserves, recreational forest, catchment forest and reservoirs and forest for federal purpose. National Parks, Wildlife & Bird Sanctuaries cover approximately 1,9 million hectares of forest.
The forest sector varies quite significantly from one region of Malaysia to another. Nearly all timber production in Sarawak is from natural forests; that state accounted for nearly 60 per cent of total natural forest production in Malaysia in 2012, while Peninsular Malaysia accounted for 28 per cent and Sabah for 12 per cent. While Sabah relies heavily on natural forest production, plantations have become increasingly important there, accounting for just over one-third of log production in 2013, mainly for pulp. In Peninsular Malaysia, most production is from natural forest production and clearance of rubber plantations (Hoare, 2015).
Much of Malaysia’s forests are degraded: for example, 80 per cent of forests in Sabah and Sarawak have been heavily impacted by logging. At the same time, there are high levels of deforestation in the country: satellite data indicate that the annual deforestation rate was 1.6 per cent between 2000 and 2012. Expansion of timber, pulp and agricultural plantations (which include oil palm and rubber) has been the main driver of forest loss in the country (Hoare, 2015).
Malaysian natural forests can be distinguished in three forest types:
- dry inland forests, accounting for the great majority of the Malaysian forests. Common tree species found in these forests include Anisoptera, Dipterocarpus, Dryobalanops, Hopea, Shorea and Parashorea.
- peat swamp forests, with species such as Gonystylus bancanus (Ramin), Durio carinatus and various Shorea species.
- mangrove forests.
Production and export
According to ITTO (2015) the Malaysian industry produced in 2014 about 20.5 million m3 of logs, of which around 17% is exported. Total exports of the main primary timber products have a value of around 3 billion US dollars.
The forestry sector in Malaysia comprises four major sub-sectors with regard to wood-based materials and goods. Sawn timber, veneer and panel products (i.e. plywood), mouldings and builders’ joinery and carpentry (i.e. doors, windows, etc.), and, lastly, furniture and associated components. The majority of plywood is produced in Sarawak (about 70 per cent), while 20 per cent comes from Sabah and the remaining 10 per cent from Peninsular Malaysia. Sawn timber is produced mainly in Peninsular Malaysia (nearly 70 per cent); 20 per cent comes from Sarawak and 10 per cent from Sabah (Hoare, 2015). The industry is predominantly owned by Malaysian companies and roughly 80-90% of these businesses are small and medium enterprises (Forest Legality Alliance).
Asia is the major export market destination for Malaysia’s timber products, notably Japan (plywood being the main product exported) but also others such as India, Thailand and China (logs, sawnwood and plywood). The US and the EU are other important markets importing significant volumes of wood-based products from Malaysia, plywood, sawnwood and furniture. The US and EU markets are predominantly supplied by Peninsular Malaysia (Hoare, 2015).
Commonly harvested species from natural forests include Meranti (Shorea spp.), Keruing (Dipterocarpus spp.), and Merbau (Intsia spp.), although much more species are harvested. Commonly harvested species from plantations include Acacia (Acacia spp.), Eucalyptus (Eucalyptus spp.) and Rubberwood (Hevea brasiliensis).
Sources of information
- FAO Global Forest Resources Assessment 2015
- Fordaq - timber trade network
- Forest Legality Alliance risk tool – Malaysia
- Hoare, A. (2015) Illegal Logging and Related Trade: The Response in Malaysia. A Chatham House Assessment. Energy, Environment and Resources | January 2015
- ITC (International Trade Centre) calculations based on UN Comtrade statistics
- ITTO (2011) Status of tropical forest management 2011
- ITTO (2015) Biennial review and assessment of the world timber situation 2013-2014
- NEPCon forestry risk profile - Malaysia
- NEPCon (2016) Supply Chain Mapping of Malaysian Timber and Wood-Based Industries. Produced by NEPCon on behalf of WWF-Malaysia
- World Port Source - Map of ports in Malaysia with container liner service.
Malaysia is composed of West Malaysia, also known as Peninsular Malaysia, and East Malaysia consisting of the states Sabah and Sarawak. Generally, while forestry matters are managed by State governments, under the Constitution the Federal government can enact laws to harmonise and standardise State enactments. To this end, the National Forestry Act 1984 was formulated and later adopted by the individual States in Peninsular Malaysia.
The forestry and timber agencies in Malaysia who issue harvesting permits, licenses and log transport documents are:
- Forestry Department Peninsular (FDPM) and the State Forestry Departments.
- Sabah Forestry Department (SFD)
- Sarawak Forestry Corporation (SFC) and Forest Department Sarawak (FDS).
Any company or person wishing to take or remove timber from a forest area must first have a valid harvesting license. The first step to securing a harvesting license is to obtain approval from the state authorities or the relevant state forestry departments. Both are involved when issuing licences for concessions. For tender and minor licenses only the relevant state forest department is applicable. There is no requirement to get approval for harvesting on alienated / private land if the timber is not going to be traded.
Only companies or persons registered with the State Forestry Departments are eligible to apply for the harvesting license. Concession licenses are awarded through open tender or by direct award by State Forestry Department. In Peninsular Malaysia, concessions are categorized by size, each with its own length of tenure. Concessions up to 1000 hectares in area are allocated for 1–2 years; 1,001–2000 hectare concessions are allocated for 1–5 years; 2,001–20,000 hectares are allocated for 10–30 years; and those exceeding 20,001 hectares are allocated for 20–30 years.
A licensee-to-be must prepare a Forest Harvesting Plan for the approval of the State Forestry Departments before a license is issued for the permanent forest reserve. The Licensee must then register its classification mark with the State Forestry Departments.
A Forest Harvesting Plan is not required for Alienated land. The owner of Alienated (privately owned land) and Stateland will have to apply for a harvesting permit from the State Forest Department.
Concession or Harvest permits will not be issued if relevant fees have not been paid by the Forest Management Enterprise or private land owner. The following harvesting permits can be obtained:
- Timber Licence (Form 1 - Licence to take forest produce), applicable for PFR and Stateland;
- Minor licence (Form 3) - Minor Licence to take major forest produce not exceeding 70 cubic meters or any minor forest produce, applicable for PFR and Stateland;
- Removal licence (Form 5): To remove timber from alienated land and reserved forest.
Management and harvesting plans are prepared by the FMEs, and have to be approved before harvesting can take place. In Peninsular Malaysia, felled logs are inspected for payment of royalties and Forest Department CESS at the Forest Checking Stations (FCS) manned by the State Forestry Department officials. Once payment is made, a Removal Pass (RP) is issued for each lorry load. The Removal Pass is a legal and controlled document printed only by Government-approved agency/company. The Removal Pass carries a record of the type/species, volume of produce, and the royalty and Forest Department CESS payable. Once the royalty is paid, each log is stamped with the royalty mark at the FCS. The stamping of logs only takes place in the case of Natural Forest Management (NFM), while plantation logs are stamped randomly. Timber tracking systems are used only for logs harvested from permanent reserved forests. Peninsular Malaysia has a paper-based tagging system and a Removal Pass system to trace logs from the forests to the mills. The licensee must ensure that all logs transported from the Forest Checking Stations to the mills are accompanied by a Removal Pass or Exchange Removal Pass (ERP). An Exchange Removal Pass is issued by the relevant State Forestry Department in cases where the loads have been inspected during transit or for a load transported from one mill to another.
The quantity of logs received by the mills as recorded in the Removal Pass will also be kept and maintained by the mills. The mills are required to keep a log book containing information on logs stored and processed in these mills.
The holders of the RP/ERP are the primary processing mills (that is, the sawmills and plywood mills). Value-added processing mills, which usually source their timber supplies from primary processing mills, do not possess a RP/ERP.
Any company/person engaged in the export of timber products must register with the Malaysian Timber Industry Board (MTIB). To register with MTIB, a company must first be a member any of the eight associations recognised by MTIB. Upon approved registration, MTIB will issue a Certificate of Registration depending on the types of application, i.e. timber exporter, timber supplier, timber processor or jetty operator. Registered companies are allowed to export these products upon obtaining an Export License from MTIB. Export licenses will be issued following online application and submission of all required supporting documents including a Removal Pass. In the case of export timber, MTIB is responsible for conducting the final check at the company premise before the timber can be transported to the port for export. This includes inspection of the timber itself and the required documentation. Every shipment must pass through this procedure before any export is allowed.
Parties wishing to commercially harvest timber shall be legally registered with the Sabah Forestry Department. Any company or person/Organisation who intends to harvest forest produce from a forest area needs to have a valid harvesting licence. In Sabah a harvesting license can be in the form of:
- Sustainable Forest Management License Agreement/Long-term License Agreement (SFMLA/LTL) for concessions on PRF.
- Form I license: short-term license for logging activities on forest reserve or State land.
- Form IIB: Normally issued for harvesting from alienated land, where timber can be harvested for land clearance for agricultural purposes (mostly oil palm, rubber and other short-term crops).
Concessions can be issued for natural forest and plantations only on Permanent Reserved Forest (PRF), and are subject to the following requirements:
- The licensee (SFMLA/LTL) shall have an approved Annual Work Plan (AWP) containing maps and description of areas and types of operations to be carried out during the year. The licensee is required to obtain approval for the AWP based on the 10-year Forest Management Plan (FMP) and/or 10-year Plantation Development Plan (PDP). The Forest Management Plan describes the long-term management approach for the SFMLA areas based on forest types, terrain and current conditions of the FMU. It also outlines adequate planning and site preparation for harvesting operations.
- The licensee shall have a Comprehensive Harvesting Plan (CHP) containing total and net production areas; harvesting volumes, diameter, limits, species and protected areas that are approved by Sabah Forest Department.
In a concession, there are many compartments known as coupes. Under the principle of SFM, one company is permitted to harvest only a few coupes at any given time in accordance to the Forest Management Plan, CHP and Annual Work Plan. The coupe permit validity is normally 15 years depending on the conditions of the license. The company is not permitted to operate in any area for which it has not yet been issued a coupe permit even though that area may be within its concession.
A licensee must register a Property Hammer Mark, and the Property Hammer Mark must be stamped at the end of each log produced (natural forest), and per batch for plantation timber. Additionally, the licensee must incise each extracted log with a serial number. Daily felling and extraction is recorded on official documents, and harvested trees are inspected by the District Forestry Officer (DFO) prior to removal. The DFO marks the harvested trees with the SFD Inspection Hammer Mark, after which the marked logs can be transported to the approved stumping area for royalty assessment. All timber to be transported must be accompanied by a Removal Pass (RP) upon payment of the royalties to the government, or a Transit Pass for transportation of logs from the extraction area to the royalty assessment area. After royalty has been assessed at the stumping area or in a later stage the trees are marked with a SFD Royalty Hammer Mark. For plantation logs from Permanent Reserved Forest area the licensee records the production based on volume or weight and submits the records to the District Forestry Officer (DFO) for the issuance of a Transit Pass. Royalty paid logs are accompanied by a Timber Disposal Permit (TDP) which provides details of logs, including: the licence where the logs were extracted, the serial number, log specification by species, log diameter and length, date of scaling and reference to the royalty payment receipt.
When the truck arrives at the mill, logs, trucks and RPs are recorded by the SFD in the log Arrival Book kept at the mill and the used RPs are stamped as 'Used Removal Pass'. The organisation must register the Property Hammer Mark for sawmill/plymill processing and incise a serial number on all logs for sawmill processing.
A company intending to export timber and timber products must possess an Annual Export License from the MTIB. The company declares timber and timber products to be exported to the District Forestry Officer with a valid export permit or annual export license with supporting documents such as Log summary, Sales Contract, Invoice, Packing List and a declaration on the source of processed timber to be exported. A timber export permit is issued by SFD to these persons/companies upon satisfaction of all export requirements.
Sarawak got a new Chief Minister in early 2014. Many changes in the forest sector has been proclaimed and it is worth being aware that the situation in the forest sector may change within the coming years. On 2nd March 2016, the Chief Minister released a press statement titled “Sarawak Government is Committed to Combat Illegal Logging,” highlighting the state government’s ongoing efforts including amendment of the Forests Ordinance in 2015 to “provide for more deterrent penalties for forest offences”. The Chief Minister also claimed that “The Government will no longer issue any more new timber licence in the State land and Permanent Forest Estate, except under very special circumstances involving the development of verified Native Customary Right (NCR) or alienated land.”
Currently, parties wishing to commercially harvest timber shall be legally registered with the Forest Department Sarawak. The Sarawak Timber Industry Development Corporation Ordinance, 1973 also requires those involved in establishment, manage or operate any mills, manufacturing, sale, distribution or marketing of timber and timber products, to register with STIDC. Timber may be harvested in Sarawak from Gazetted Forests meant primarily for sustainable timber production and agriculture plantation. There are three types of harvesting licence in Sarawak:
- Forest Timber Licence (FTL)
- Occupation Ticket (OT) Licence (Clearing of forest for plantations and native land)
- Mangrove and Belian (Iron Wood) Licence
Each forest concession area must hold a Forest Timber License (FTL), which can be obtained from the Director of Forests. Attached to the FTL is the Forest Management Plan (FMP) which sets out management and harvesting prescriptions. When issuing concessions, there could be a call for tender; however the Director of the Sarawak Forestry Department has the power to issue licenses and permits under conditions as he deems appropriate. Thus information relating to the allocation of concessions is not publicly available. Presently, timber concessions are issued for a period between 5–10 years.
The Forest Department of Sarawak (FDS) issues the FTL in conjunction with an approved General Harvesting Plan (GP), which has been prepared by the concessionaire. The General Harvesting Plan (GP) show the layout and size of coupes, harvesting sequence, proposed road networks, camp sites, log dumping point and other general planning particulars.
Before extraction can commence, the permit holder is required to prepare a Detailed Harvesting Plan (DP) and submit it for approval. The Sarawak Forestry Corporation (SFC) processes and approves the Detailed Harvesting Plan (DP), which contains operations prescriptions at coupe level, the layout of logging blocks, surveyed road networks, protected or conservation areas as well as the proposed harvesting methods.
After approval of the DP the felling permit (commonly known as a Permit to Enter Coupe - PEC) is issued and endorsed by Sarawak Forestry Corporation (SFC), which allows for harvesting in the approved block. The PEC process requires verification of satisfactory ground compliance in terms of coupes and block boundary demarcation, preparation of topographical work map, road alignment and construction, tree enumeration before endorsement of blocks for logging. Enumeration is not applicable to planted forest.
A licensee is required to register the company property mark with the Director of Forests. At the Forest Landing the licensee marks both ends of each log with his registered Property Mark, affixes a unique pre-approved Log Production Identity (LPI) tag to each log. The licensee then scales and grades each log and submits log details in the Daily Production Return (DPR) to the SFC, together with their Log Specification Form and Log Specification Summary. SFC then checks to ensure that harvesting operations have taken place within approved areas in compliance with FTL terms and conditions and that licensees have used only approved LPI numbers. SFC checks the DPR information and uploads this into LoTS. LoTS is an ICT tool used in Sarawak to monitor and control the movement of logs. After this the licensee moves the logs from the licensed area to the Forest Checking Station where logs are royalty assessed and physically inspected.
SFC conducts the royalty assessment of the logs by embossing the Government hammer mark 'JH' (which stands for Jabatan Hutan / Forest Department) at both ends of the logs. Harwood Timber Sdn Bhd (HTSB), a subsidiary of the Sarawak Timber Industry Development Corporation (STIDC), carries out the physical inspection of logs to ensure they have been royalty assessed. Resulting from the assessment and inspection activities, SFC issues a Removal Pass (Royalty) while HTSB issues an Endorsement Clearance Certificate (ECC) as well as Transportation Pass or Shipping Pass, both pre-requisites to SFC’s issuance of a Transit Removal Pass (TRP) confirming logs for local processing to be delivered to local mills. Upon arrival at mills, logs are inspected by both SFC and HTSB and reconciled with ECC and TRP. All mills must have a valid mill license issued by the FDS and all mills, except sawmills, need to have a manufacturing license from STIDC demonstrating registration as manufacturer. The mill licences and registration issued are valid for only one year and subject to annual renewal.
Exporters need to be in the possession of a certificate of registration with the STIDC. STIDC is also responsible for issuance of Export Licenses for every shipment of timber and timber products from Sarawak. The issuance of export licenses is done through an ePermit System at STIDC's portal. Additionally, exported sawn timber shall be accompanied with a grading certificate.
Logs for export are first physically inspects by the HTSB to ensure that (i) export consignments do not include any logs supposed to be reserved for milling and (ii) royalty has been paid on them. HTSB then issues an Export Clearance Certificate (ExCC) as a pre-requisite to SFC’s issuance of a final Removal Pass (Transit/Export). STIDC issues the Export Licence, and finally the Royal Malaysian Customs Department undertakes customs clearance.
The below listed key documents are based on the applicable legislation and are considered to play a key role in demonstrating legal origin. The full list of applicable legislation is accessible here (NEPCon).
Trade and export
Bans and quota
- There is a total ban on the export of round logs from Peninsular Malaysia.
- For Sabah only 40% of the total harvest volume may be exported as logs.
- Sarawak has a log reservation quota of 60% log production in the state has to be processed within the state, which is monitored by Harwood Timber Sdn Bhd.
Cites and protected spieces
A list of protected tree and plant species from Malaysia is available here (source: NEPCon, 2016).
There are also some tree species listed on CITES Appendix II from Malaysia:
- Ramin (Gonystylus spp.). The CITES listing applies to all parts and derivatives of the tree, except seeds; seedling or tissue cultures obtained in vitro, in solid or liquid media, transported in sterile containers; and cut flowers of artificially propagated plants.
- Agarwood (Aquilaria spp.). The CITES listing applies to all parts and derivatives except: seeds and pollen; seedling or tissue cultures obtained in vitro, in solid or liquid media, transported in sterile containers; fruits; leaves; exhausted agarwood powder, including compressed powder in all shapes; and finished products packaged and ready for retail trade; this exemption does not apply to beads, prayer beads and carvings.
- Himalayan yew (Taxus wallichiana). The CITES listing applies to all parts and derivatives except: seeds and pollen; and finished products packaged and ready for retail trade.
- Chinese yew (Taxus chinensis). The CITES listing applies to all parts and derivatives except: seeds and pollen; and finished products packaged and ready for retail trade.
- Serpentine wood (Rauvolfia serpentine). The CITES listing applies to all parts and derivatives except: seeds and pollen; and finished products packaged and ready for retail trade.
The following Management Authorities are responsible for the issuance of CITES export permits:
- The Malaysian Timber Industry Board (MTIB) for Peninsular Malaysia and Sabah. Exportation of CITES are subject to annual export quota imposed by MTIB. CITES Export Permit for Ramin and Agarwood will be approved and issued by MTIB by submitting all required documents including Removal Pass.
- The Forest Department Sarawak for Sarawak
National action on timber legality
Malaysia was one of the first countries to begin negotiating a VPA with the EU in January 2007, and negotiations are ongoing.
Malaysia operates a Timber Legality Assurance System (TLAS) in Peninsular Malaysia (known as MYTLAS) and Sabah (known as the Sabah TLAS). A Sarawak TLAS is currently under development.
The Malaysian Timber Legality Assurance System (MYTLAS), which is managed by the Malaysian Timber Industry Board (MTIB), is in place and issuance of a TLAS license is subject to inspection of the timber consignment by MTIB. MYTLAS certificates are being issued for exports on a voluntary basis, since it is not obligatory but is being presented to industry as a tool to help those exporting to the EU meet the due diligence requirements of the EU Timber Regulation (EUTR).
The Sabah TLAS is also operating and being implemented by the SFD. However, neither the MYTLAS nor the Sabah TLAS is yet approved under the FLEGT VPA process. Global Forestry Services (GFS) conducts independent monitoring for the Sabah Forestry Department covering Reduced Impact Logging & legal compliance to the Sabah Timber Legality Standard (TLAS) for all forests, manufacturing, trade and export companies on Sabah.
Third party certification
Over 5 million hectares of the Malaysian forests are covered by forest management certificates. The principal certification scheme in Malaysia is the Malaysian Timber Certification Scheme (MTCS). The MTCS has also been endorsed by the Programme for the Endorsement of Forest Certification (PEFC) system since 2009. It covered most of the permanent reserved forest on the Peninsular, with 8 certificates covering around 4.5 million hectares. However, the certificates of Kelantan State Forestry Department and Johor State Forestry Department were recently suspended. The remaining 6 certificates cover around 3.7 million hectares. Currently there is 1 MTCS certificate issued on Sabah and 1 issued on Sarawak covering together an additional 140 thousand hectares of natural forests. Additionally, on Sarawak there are also 2 MTCS certificates covering forest plantations.
The Forest Stewardship Council (FSC) is another important certification scheme in Malaysia, covering 673,334 hectares. These forests are mainly located on Sabah, and the remaining part of 126,940 hectares are located on the Peninsular.
Other initiatives regarding external verification of Malaysian forest products have been deployed by Global Forestry Services (GFS). The involved companies can be verified on the GFS website, both under the GFS Wood Tracking Program (WTP) and the GFS Legal Verification Programme. GFS is not an accredited certification body and there is no accreditation associated with legality verification. However, GFS has formal procedures to operate in compliance to ISO guides 62 and 66.
Sources of information
- CITES database
- EU FLEGT Facility – Malaysia
- EU FLEGT Facility (2012) MALAYSIA: Scoping Baseline Information for Forest Law Enforcement, Governance and Trade. Baseline study 8 By Chen Hin Keong, James Hewitt and Thang Hooi Chiew
- Forest Legality Alliance risk tool - Malaysia
- Forestry Department Peninsular Malaysia - Licensing (Yield License)
- FSC report “Facts & Figures” – January 2016.
- GFS Global Forestry Services
- Understanding forest tenure in South and Southeast Asia. Case study: Sabah forest ownership. Global Forestry Services Inc.
- Government of Australia and Government of Malaysia. Country specific guideline for Malaysia (Peninsular)
- Government of Australia and Government of Malaysia. Country specific guideline for Malaysia (Sabah)
- Government of Australia and Government of Malaysia. Country specific guideline for Malaysia (Sarawak)
- Hoare, A. (2015) Illegal Logging and Related Trade: The Response in Malaysia. A Chatham House Assessment. Energy, Environment and Resources | January 2015
- Ministry of Resource Planning and Environment (2012) Legality Verification of Logs in Sarawak.
- Malaysia – EU FLEGT VPA webpage
- Malaysian Timber Certification Council
- NEPCon (2013) Evaluation and revision of the Sabah TLAS standard and audit checklists
- NEPCon forestry risk profile - Malaysia
- NEPCon (2016) Supply Chain Mapping of Malaysian Timber and Wood-Based Industries. Produced by NEPCon on behalf of WWF-Malaysia.
- Press statement: Sarawak Government is Committed to Combat Illegal Logging
- Sabah TLAS document revised as at 12 March 2013.
- Sarawak Timber Industry Development Corporation (STIDC) – Registration & Licensing
- SmartWood Standard for Verification of Legal Compliance (VLC) in Sabah, Malaysia
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