This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012), as the proposed project is expected to have limited adverse E&S risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures, as described in the following sections. Key E&S risk and issues associated with this Project include: capacity and Environmental and Social Management System (ESMS) in alignment with IFC's PSs; the development of an environmental and social impact assessment (ESIA) that meets IFC PSs for the new line and cogeneration plant; adequacy of HR / OHS management systems for fair and safe working conditions; fire hazard and emergency preparedness, including consideration of climate change scenario of floods and extreme heat; oversight of construction and contractors; resource efficiency and pollution prevention, particularly air emissions, liquid effluents, water sustainability, and waste management; community health and safety; stakeholder engagement and grievance mechanism; and supply chain management for waste paper and  biomass fuel sourced from rubber wood chips, oil palm nutshell and hay.

PS1: Assessment and Management of Environmental and Social Risks and Impacts

XSD’s E&S policy focuses on compliance with national E&S laws and regulations. XSD adopted its ESMS from its previous operations in China and enhanced it to meet Malaysia's E&S requirements and industry good practices in areas where the requirements are more stringent. These areas include the establishment of buffer zones, community engagement, and a formal grievance mechanism.

The ESMS includes risk identification, management programs, emergency preparedness and response, monitoring and evaluation, organizational roles, training, and stakeholder engagement, and is generally in line with IFC Performance Standards (PS) requirements. E&S permits obtained include the environmental license, land use certificates, land use planning permits, and environmental/wastewater discharge permits.

The ESMS also consists of components required in IFC PS1, such as policy on workforce protection, grievance mechanism and a designated Gender Based Violence and Harassment Mechanism (CGM), and supply chain management including traceability, risk screening and fiber/recycle paper and biomass sourcing, EHS incident investigation and reporting procedures. XSD has obtained ISO 9001:2015, ISO 14001:2015, ISO 45001:2018 and FSC (chain of custody) RoHS (Restriction of Hazardous Substances), REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals), and ISEGA (safety of materials) certification.

Identification of E&S Risks and impacts. The Environmental Impact Assessment (EIA) studies for the establishment of the plant in Penang cover multiple production lines with a total capacity of 750,000 TPA, a wastewater treatment system, and a steam plant, on 300 acres (approximately 120 hectares) of project land. The EIA includes a social impact assessment component and was approved by the provincial Department of Environment in 2018. This EIA scope includes the proposed expansion for an additional production line. The review of available EIAs confirmed that key E&S risks, impacts, and mitigation measures for the pre-construction, construction, and operational stages are defined in these studies. Identified E&S impacts for operations and production include emissions of particulate matter (PM), waste management of solid and hazardous waste, wastewater and its byproducts (e.g., sludge), as well as dust, odor, noise, and impacts on local communities (e.g., especially road safety).

Another EIA was developed for the biomass cogeneration plant, which aligns with the requirements of IFC’s Performance Standards (PSs) and the World Bank Group's Environmental, Health, and Safety Guidelines for Thermal Power Plants.

Organizational Capacity and training. The overall accountability for the E&S function is under the Chief Executive Officer. Responsibilities are shared among various departments, including Production, Purchasing, Engineering, and Environmental, Social, Safety, and Health (ESSH).

The HSSE department has a total of five staff members with designated corporate responsibility for environment, safety, community engagement, and management of the security team. The safety specialist is supported by production line safety staff for workshop safety, while the construction department is responsible for construction activities, including safety. The head of the procurement department is responsible for purchasing biomass and wastepaper materials in accordance with corporate sustainable policies and processes.

The Human Resources (HR) department has a team of five members, including one staff member of Malaysian nationality. HR collaborates with the production and operation departments to plan, develop, and deliver training to all workers, as well as manage worker welfare.

XSD has a comprehensive E&S training program for all its employees. New employees receive extensive induction training, which includes a factory visit, security, environmental and safety management system, SOPs and work permits, hazard identification and risk assessment, occupational illnesses, fire prevention, and firefighting. Environmental staff additionally receive training on laws and regulations, including terms and conditions of permits, solid/hazardous waste management, wastewater, emissions and GHG, noise, monitoring and reporting, and emergency planning. Employees generally receive refresher training at least once a year.

Emergency Preparedness and Response Plans (EPRPs). The paper industry is considered highly sensitive to fire risks due to the combustible nature of the materials handled, stored, and produced in the factory. XSD has documented an emergency response plan (ERP) for its operations, with clearly defined roles and responsibilities for various teams responsible for evacuation, rescue, and firefighting. Signage is displayed at various locations across the facilities, along with fire extinguishers, alarm call points, evacuation route maps, and hose reels. Smoking is prohibited throughout the site. Smoke/fire sensors, an automatic sprinkler system, and firefighting water/pumps are equipped in storage areas and certified by the local fire department. XSD will hire a qualified fire safety consultant to conduct a fire safety audit covering all plant areas. The audit must consider the cumulative fire risks associated with the operations (ESAP#1).

XSD’s emergency response procedures (ERP) are in accordance with national regulation. The ERP includes: (i) emergency risk assessment report, response resources, and ERP; (ii) hazardous substance release/leakage and response procedure; (iii) ERP for fire events; (iv) ERP for dust explosion accidents; (v) ERP for diesel leakage (fire) accidents; and (vi) ERP for typhoon and flood control, vii) ERP for heat weather. XSD conducts annual training on safety, security, fire prevention and firefighting, and firefighting drill and all training recorded.

Monitoring and review. XSD has a monitoring mechanism that includes key performance indicators (KPIs) such as safety statistics, energy and water consumption, air emissions, and wastewater discharge. Biomass and sewage sludge are transferred to the cogeneration thermal power plant. XSD has retained an E&S consulting firm to conduct third-party environmental audits every four months to track the effectiveness of the mitigation measures developed in the ESIA. Additionally, frequent external environmental monitoring reports are conducted, including weekly wastewater monitoring, monthly river monitoring, sewage treatment plant monitoring, and environmental inspections, quarterly point source emission and ambient air quality and noise level monitoring, and environmental inspection reports every four months. All these reports are submitted to the Department of Environment (DoE) to demonstrate compliance. Moving forward, XSD will install an online monitoring system to monitor the real time wastewater effluent and air emission from the boilers (ESAP#2).

XSD has developed a production safety accident management system, which includes OHS accident classification, OHS accident notification and rescue procedures, and OHS accident investigation and reporting. An accident log with investigation reports and evidence of corrective actions is maintained.

Supply chain management. XSD has a purchasing department responsible for sourcing wastepaper. XSD meets the SIRIM QAS International Guidelines (Malaysia certificate) for the importation and inspection of wastepaper to Malaysia. The company has a supply chain management system and procedures certified by the Forest Stewardship Council (FSC) for responsible sourcing. This certification process has helped XSD identify products that are sourced responsibly and produced in a sustainable and ethical manner.

XSD has developed several measures to ensure responsible sourcing, including: i) contractual language prohibiting the use of child labor and forced labor, and requirements to follow national regulations on Occupational Health and Safety (OHS); ii) a supplier risk assessment screening procedure; iii) supplier database. XSD sources wastepaper from America, Europe, Japan, and locally in Malaysia. Moving forward, XSD will monitor suppliers to verify their compliance with contractual requirements, including child and forced labor, safe working conditions, and no deforestation requirements. The company will establish exit strategies for suppliers who do not meet XSD’s requirements. XSD sources biomass from large local cooperatives. The supply chain system and procedures will be extended to all suppliers, including those providing biomass materials as fuel for the cogeneration plant. To avoid that biomass is sourced from deforestation tree suppliers, XSD will undertake a risk assessment prior to the commencement of the supply to the cogeneration plant (ESAP#3).                                                   

PS2: Labor and Working Conditions

XSD employs around 820 individuals, with plans to recruit 400-500 more with the plant capacity expansions, aiming to increase female representation from current 16% to 20%. The workforce includes Malaysian (70%), Chinese (18%), and Bangladeshi (12%) workers. XSD directly employs all workers, including those engaged in catering, gardening, and security, with all workers having permanent employment contracts. Additionally, road cleaning on the plant premises is conducted by a third-party team of six under a corporate contract.

Human Resources (HR) policies and procedures. XSD’s HR policies and procedures are designed to comply with host country legal labor requirements regarding working hours, wages, overtime payment, paid leave, and social benefits. The company has developed a code of conduct that applies to all employees and third-party workers. This code of conduct requires employees to behave in a socially responsible manner and maintain high standards of ethics and integrity. It covers areas such as nondiscrimination, no harassment, anti-money laundering, anti-bribery, protection of intellectual property, and protection of privacy. The HR policies, procedures, and the code of conduct are easily accessible to all employees.

Working conditions and Terms of Employment and Retrenchment. Terms of employment and working conditions are clearly specified and include procedures related to recruitment, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and firing, vacation, other leave, retirement, and maintaining a respectful workplace, gender equality, and harassment. All employees have signed employment contracts that outline key employment terms and conditions, including job descriptions, workplace locations, duration of employment, salary and benefits, leave entitlements, welfare and social insurance, probation and notice periods, and provisions for training. Since the establishment of the plant, there have been no retrenchments, and none are planned for the foreseeable future.

Worker’s organization. XSD’s employees are not unionized, the company respects freedom of association. Employees can raise their grievances through the company’s intranet, face-to-face meeting, or by talking to HR department and/or management directly. XSD’s management has no restrictions on workers forming or joining a labor union or entering into collective bargaining agreements.

Non-discrimination and Equal Opportunity. The HR policy specifies non-discrimination and equal opportunity and zero tolerant on sexual harassment and has communicated to all workers. All the hiring and promotion are merit-based. There is no difference in terms of salary for female and male employees with the same experience.

Workers Grievance Mechanism (WGM). A WGM has been set up, and employees can provide feedback on discriminatory incidents or unfair treatment and behavior through telephone, text message, mailbox, and comment boxes placed in the plant where privacy is provided. Grievances emanating from the workforce normally be brought in person to the HR manager, or anonymously channel through to HR.  The WGM have a survivor-centric specific mechanism for anonymous grievance and complaints regarding gender-based violence and harassment and is publicized to all workers.

Protection of workforce. XSD does not hire workers below the age of 18 years. The HR team checks birth and school certificates during the hiring process. No forced labor practices are used, HR staff is responsible for obtaining work permits and renewals for expats and migrant workers. HR confirms that all employees have valid work permits, and HR has a schedule on renewal requirements. Contractors are required to strictly follow the national labor law and hire only employees older than 18 years of age. 

Workers Accommodation. XSD provides free accommodation to expatriates in nearby communities. A visit to the expatriates’ accommodation and the cogeneration construction site confirmed that the provided housing aligns with IFC/EBRD workers’ accommodation guidelines. XSD adheres to Malaysia's regulatory requirements by contracting certified providers to manage accommodation and related needs for its migrant workers at no cost to them. However, a visit to the migrant workers’ accommodation revealed substandard conditions. Issues such as insufficient space per person, inadequate sanitation facilities, poor lighting, and subpar furniture were noted. These conditions fall short of the expectations set by IFC/EBRD workers’ accommodation guidelines.

XSD will develop a migrant worker accommodation improvement and oversight management plan to meet the accommodation conditions set by the IFC/EBRD workers’ accommodation guidelines (ESAP#4). XSD will monitor the implementation and evaluate the compliance (ESAP#5).  The plan will include upgrades of accommodation to address the shortcomings and increased oversight with designated staff responsible for evaluating and monitoring the living conditions of migrant workers regularly.

Occupational health and safety (OHS). XSD has developed an Occupational Health and Safety (OHS) management system, this system includes specific elements such as: (i) OHS policy; (ii) identification of OHS risks; (iii) Standard Operation Procedures (SOPs) for the management of high-risk activities, including work permit system; (vi) emergency response planning; (v) internal audit; (vi) incident investigation and reporting; and (vii) management review.

The enforcement of wear Personal Protective Equipment (PPE) observed in the production workshop, including the use of earplugs in high-noise areas. There have been no fatalities since the plant's establishment in 2022. XSD's incident investigation and reporting procedures categorize incidents (e.g., medical treatment, minor, major). Based on the records, loss time and non-loss time injuries were individually reported, root cause analyses were conducted, and improvements were proposed and implemented. Moving forward, XSD will conduct a comprehensive analysis of all incidents that have occurred over the past three years. Based on this analysis, XSD will develop a safety improvement plan aimed at reducing the occurrence of future incidents (ESAP#6).

Training plans covering various aspects, including OHS, are developed annually. All employees receive induction and training on safety and management systems, hazard identification and risk assessment, fire prevention and firefighting, and dust explosion, including explosion and firefighting drills. There have been no fire incidents since the plant began operations. 

Workers Engaged by Third Parties. XSD’s engineering department is responsible for evaluating the design and procurement, as well as overseeing the construction contractor for the additional production line. The construction of the cogeneration plant will be completed in January 2025, while the construction contractor for the additional production line has yet to be awarded. The total construction workforce is expected to reach 300 at its peak.

OHS risks are managed by construction contractors in accordance with national requirements, including the use of personal protective equipment, accident reporting, and safety supervision. To ensure that contractors adhere to the project’s E&S commitments, XSD will develop a Construction Contractor Oversight Management Plan (OCMP). This plan will include general and project-specific E&S and OHS requirements and conditions for the construction, in line with IFC’s Good Practice Note “Managing Contractors: Environmental and Social Performance” (ESAP#7). The OCMP will include: i) compliance register of regulatory OHS compliance, regulatory construction ESMPs, labor practice, and measures to address grievance as well as requirements that might relate to potential heat-related stress and illnesses, exacerbated chronic conditions, and emergency preparedness in case of floods that could impact workers and the environment.

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency. XSD’s environmental management system (EMS) includes a resource efficiency policy as part of its sustainable development strategy and circular economy.

No groundwater is extracted or used for production activities. Processing water is drawn from the local Karangan River, resulting in an approximate 1.3% loss of river flow. Minor impacts during the wet season were concluded in the ESIA with survey findings. Moving forward, XSD will conduct water flow monitoring during the dry season to assess impacts on downstream users. Based on these findings, XSD will develop a water use management plan, which will include stream gauging and measures to minimize the impact of water intake for the plant (ESAP#8).

The plant currently sources electricity from the grid and steam from a biomass boiler, which consumes biomass residue and dry sludge from XSD’s processes as feedstock. The annual electricity consumption from the grid will be reduced from 45MW to 12MW when the 28MW cogeneration plant and 6MW solar panels become operational in 2025.

The cogeneration plant, currently under construction, will convert thermal energy to both electricity and steam, achieving higher overall efficiency compared to separate heat and power systems. This means less fuel is required to produce the same amount of energy. Based on current data from XSD, once the cogeneration power plant is operational, electricity and steam consumption will equate to 450 kWh/ton of paper and 0.3 GJ of steam per ton of paper, respectively. Processed water is reused, and ultimate water consumption equates to about 9 tons of fresh water per ton of paper. These water consumption figures are within the WBG EHS Guidelines for Pulp and Paper Mills (specific for Recovered Paper Mill).

Greenhouse Gases. XSD uses biomass fuel for steam and most of the electricity needs when the cogeneration is operational in April 2025. Biomass will be considered carbon neutral, so the GHG emission of the cogeneration plant is considered limited. The use of gasoline or other fossil fuels by the company is mainly for forklift. The project use of energy and emissions are expected to have greenhouse gas emission of more than 25,000 tons carbon dioxide equivalent per year after the expansion funded by IFC. The company will develop a procedure to use an internationally recognized methodology to monitor and report its annual GHG emission levels (ESAP#9).

Wastewater Treatment. Wastewater containing high concentration of total suspended solids (TSS), COD and BOD generated from the process. This effluent stream was sent to the on-site IETS (Industrial Effluent Treatment System) for treatment, the process of which mainly includes pretreatment (filter, coagulation), anaerobic and aerobic treatment. About 20% of the total effluent amount of the wastewater is pretreated and recycled to the production line. The rest will be further treated to meet Standard A (as defined by local environmental department DOE) and then discharged to the Karangan river. The current capacity of the existing IETS is 12500m3/d which will be expanded to 22000m3/d to meet the demand of the expansion project in 2027. Recent monitoring result of the discharged wastewater showed that the values of relevant parameters comply with local regulatory standard and applicable WBG EHS Guidelines for Pulp and Paper Mills, except for AOX, TN and TP, which are not monitored or reported in effluent monitoring. XSD will include these indicators in future effluent currently monitored. XSD will include these indicators in future monitoring to ensure compliance (ESAP#10). Sanitary wastewater is treated onsite by septic tanks to a permitted level before discharge. The effluents meet both local regulatory requirements and IFC General EHS Guidelines limits.

Air Emissions. Burning biomass generally produces fewer pollutants like sulfur dioxide (SO2) and nitrogen oxides (NOx) compared to coal. A recent monitoring (conducted in April 2024) result of the current boiler stack emission showed that all values of the current monitored parameters (PM, SO2 and NOx) of a 75t/h biomass-fired boiler are under the limits of both local regulatory requirements and WBG EHS Guidelines for Thermal Power Plants. Two new 75t/h biomass-fired boilers are being installed in the cogeneration plant to replace the previous one. XSD will continue to use treated and pressed biomass as fuel for the cogeneration. Baghouses also will be equipped to remove dust from the flue gas, with a designed removal rate of >99.9%. PM (Particulate Matter) concentration in the stack emission is expected to reach below 30mg/m3, according to the cogeneration plant engineering design information. An online air emission monitoring system will be also equipped with the boiler to monitor parameters including temperature, SO2, NOx and CO and PM. All values of cogeneration monitor parameters are expected to be under the limits of both local regulatory requirements and WBG EHS Guidelines for Thermal Power Plants. The main raw materials used for coating are modified starch, calcium carbonate, porcelain clay, synthetic latex, etc., all of which are environmentally friendly products without ecological pollution. The amount of air emission from the paper/board production lines is very limited.

Noise. XSD is following national regulations on noise emission limits at the boundary of its facility during the construction phase and during the operation phase which are considered aligned with the WBG General EHS Guidelines requirements for residential receptors, considering the surrounding industrial facilities. The closest residential facility is approximately 250m from the boundary of the plant. The latest quarterly noise monitoring results (date) indicated no exceedance above national standards. Thus, the noise impacts to the surrounding community are considered limited. XSD will utilize its existing community grievance mechanism to monitor any grievances on noise impacts and address them accordingly.

Waste Management. Solid wastes are mainly characterized by (i) recyclable material such as plastics and metal from the wastepaper; ii) sludge from IETS; and (ii) hazardous wastes (HW) from laboratory testing, waste oil, filter element, used batteries, etc. HW are being managed in accordance with national waste management standards, disposals are handled by licensed third parties, while recyclables sold to other business. The onsite HW storage has relevant design and emergency preparedness equipment. All combustible non-hazardous solid wastes will be transferred to the cogeneration plant for incineration. Most of the sludge (80% to 100%) from IETS will be reused as fill material in the middle layer of the paper product, while the rest of the sludge will be disposed by a local licensed collector.

Hazard material management. A few hazardous materials, including sodium hydroxide solution and hydrogen peroxide solution, are used in the XSD facility. These raw materials are stored in different tanks on concrete floors with secondary containment. Material safety data sheet (MSDS) with handling SOP for each material and warning signs are also in place. No large volume of organic solvents is stored in the facility or will be used in the expansion facility which IFC is going to finance. XSD has developed a Chemical and Hazardous Material Management Plan to manage sourcing, storage, handling and disposal of chemicals and hazardous materials used in the facility.

PS4: Community Health, Safety & Security

Community Health and Safety.  All reported ambient emissions, emissions at sources, and effluent levels from XSD are within the WBG EHS Guidelines for Pulp and Paper Mills (2007). XSD’s production facilities are in a closed compound next to an industrial park, with no nearby communities. Potential community health and safety issues identified include traffic, noise, and emergency preparedness (e.g., chemical spills, fires). There have been no fire incidents since the plant began operations in 2022.

Road Traffic Safety. Approximately 100-120 15-ton trucks travel to and from the XSD plant every day. These trucks are contracted either by suppliers or by XSD to transport materials and finished products. XSD manages traffic safety risks by contracting legal entities with good safety track records. The company has developed three designated truck routes to diversify traffic and restrict the use of roads that pass through local communities. Trucks are restricted from entering and exiting between 8:30am and 8:30pm, with a speed limit of 20km/hour. The current expansion will result in increased traffic, XSD will provide defensive training to drivers, particular those who are contracted by XSD (ESAP#11).

Security Personnel. All security personnel are direct employees of XSD, under the EHHS department, and are subject to the standard employee recruitment process. They receive training from a qualified external trainer on topics such as professional behavior, good conduct, and neutralizing security scenarios, including the exercise of restraint where the use of force becomes inevitable. Security staff do not carry weapons. The roles and responsibilities of the Security Section include supporting OHS management, safety training and education, accident prevention, and response. Security personnel do not have the right to detain or conduct body searches. Their main tasks are to observe movements in and out of the facility, protect company property, monitor for violations or acts against the company, and report these to the authorities and the company.

PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

The Project is in the Peninsular Malaysian ecoregion that is characterized by moist tropical forests and peatlands.  The ecoregion has been predominantly cleared in lowland areas but maintains forest cover at altitude, playing host to lush evergreen forests. The project area located near Kulim is in a lowland area that has been cleared for agricultural purposes such as palm oil and plantations.

A review of the Project’s indicates that biodiversity surveys have been conducted for aquatic and terrestrial values.  The waterways surrounding the project site (Karangan River) indicates that the waterway is heavily impacted by surrounding land uses with most species presented either widespread within coastal rivers of Malaysia or introduced.  The terrestrial biodiversity values identified a population of Long tailed macaque Macaca fascicularis IUCN EN that are present within the primarily modified Project site.  This species is widespread throughout Southeast Asia and would not trigger critical habitat.  No other species of conservation concern was identified.

Risks to aquatic ecosystems were considered by the EIA from the abstraction and discharge of water from the Karangan River which has been assessed under PS3.  There are unlikely to be ongoing impacts to aquatic biodiversity values from the Project, however, impacts on ecosystem services requires further analysis to understand risks on downstream users and ecosystems (a per ESAP# 8). Terrestrial biodiversity values will be impacted by project clearing of existing exotic vegetation; however, a Wildlife Management Plan (WMP) will be prepared to manage risk from clearance activities, including managing the population of M. fascicularis on the site (ESAP#12).

Regarding supply chain risks, the project will use biomass as fuel within the plant.  The EIA indicates that the biomass with be from rubber trees, oil palm nutshells and hay obtained within a 270km radius of the plant.  A review of Global Forest Watch data within this region of Malaysia indicates that there is a deforestation risk (loss of natural and critical habitats) within Kedah State which will need to be managed.  To ensure that the Project maintains a low risk of deforestation within the supply chain, XSD will fulfill the requirements as outlined in ESAP#2.

Comprehensive stakeholder engagement activities were conducted during the development of the ESIA between January and June 2019. A total of 400 local households participated in activities such as surveys, focus group discussions, and Townhall meetings. Post-ESIA, XSD developed a community engagement mechanism with CSR initiatives to promote health, safety, culture, education, and the livelihood of local communities. XSD has committed to monthly community programs, allocated budget, and delivery approaches for the past three years since the plant's operation. The company has prioritized recruitment from local communities, resulting in over 50% of its employees are from local communities. This recruitment priority has fostered a strong and collaborative relationship with the local communities.

XSD has delivered monthly community-promoting programs including the donation and distribution of daily necessities (food, cooking materials) to local community households as a flood relief initiative, support to vulnerable groups (disabled, single mothers, orphans, elders), environmental promotion through fishing release programs, construction of local roads, sponsorship for students in need, as well as hosting celebrations for New Year and Ramadhan, and provision of equipment and materials to educational facilities. XSD has engaged with local authorities and relevant departments for the delivery of these monthly initiatives.

The community grievance mechanism is embedded with continuous and frequent engagement activities. Community grievances can be raised to XSD personnel or filed anonymously through the local government. This reflects the cultural and cherished relationship between XSD and the local communities and demonstrates the practicality of the grievance mechanism. For example, an anonymous grievance about transportation noise was raised through the local authority to the company, which addressed the issue promptly.

By encouraging and facilitating anonymous grievances through local government channels, XSD ensures that community members feel safe and respected when voicing their concerns. This approach has strengthened the trust and collaboration between the company and the local communities.                                                   

Company: XSD International Paper SDN. BHD

Contact: Jacky Chen

Title: Chief Financial Officer

Address: Malaysia, Kedah, Padang Serai, No. 441, Bangunan

Email: jacky.chen@xsdcorp.com