SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

RSPO Annual Surveillance 2 Assessment Report

PT. Brahma Binabakti – Brahma Binabakti Mill ,

This annual surveillance assessment report has been prepared in accordance with RSPO requirements and the information included is the result of a full RSPO assessment of the Mills and supply base as included in the scope of the certificate.

Prepared by: Tuti Suryani Sirait (Lead Assessor)

PT. SUCOFINDO (Sucofindo International Certification Services – SICS) Graha Sucofindo B1 Floor, Jl. Raya Pasar Minggu Kav. 34, Jakarta 12780 Indonesia Contact Person: TutiSuryaniSirait Phone: (62-21) 7983666; Fax: (62-21) 7987015 Email:[email protected]

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List of Contents Page

A Scope of the Certification Assessment ...... 4

A.1. National Interpretation Used ...... 4

A.2. Assessment Type (Estate and Mill) ...... 4

A.3. Location Map ...... 4

A.3.1. Location Address of the Mill and Approximate Tonnages Certified

(CPO and PKO) ...... 5

A.4. Description of Supply Base ...... 5

A.4.1. General Description ...... 5

A.4.2. Location of Supply Base ...... 6

A.4.3. Statistic of Supply Base ...... 6

A.5. Organizational Information and Contact Person ...... 8

A.5.1 Audit Againstthe Rules for Partial Certification ...... 9

A.6 Date Certificate Issued and Scope of Certificate ...... 9

B. Assessment Process ...... 10

B.1. Certification Body ...... 10

B.2. Qualifications of the Assesment Team ...... 11

B.2.1. Qualifications of the Lead Assessor and Assessment Team ...... 11

B.3. Assesment Methodology ...... 12

B.3.1. General Overview ...... 12

B.4. Stakeholder Consultation ...... 15

B.4.1. Summary of How Stakeholder Consultation was Organized ...... 15

B.5. Date of Next Surveillance Visit ...... 19

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C. Assessment Findings ...... 19

C.1. Lead Assessor’s Summary and Recommendation for Certification ...... 19

C.2. Summary of the Findings by Criteria ...... 20

D. Certified Organization’s Acknowledgement of Internal Responsibility...... 79

D.1. Formal Sign-Off the Assessment Findings ...... 79

D.2. Statement by the Certifier Body on Behalf of PT. Sucofindo SBU-SICS ...... 80

Appendix-1 List of Abbreviation ...... 81

Appendix-2 Map ...... 83

Appendix-3 NCR ...... 87

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A. Scope of the Certification Assessment

A. 1. National Interpretation Used

The management of the Palm Oil Mill(s) and associated suppliers of Fresh Fruit Bunches (FFB) were assessed for compliance against the RSPO Principle and Criteria 2013, RSPO Certification Systems 2007, and RSPO Suply Chain Certification Systems 2014. A. 2. Assessment Type (Estate and Mill)

Certification Unit : PT. Brahma Binabakti – Brahma Binabakti Mill located at Desa Bukit Baling, Kecamatan Sekernan, Kabupaten Batang Hari – Jambi, INDONESIA A.3. Location map

Please see Appendix-2 Map: 1. Map of Location, 2. Land area, 3. Topography and 4. HCV areas

Sumatera Island - Indonesia

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A. 3. 1. Location address of the mill and approximate tonnages certified (CPO and PK)

Annual Output Name of Location GPS No Actual (2016) Projected (2017) Mill Address Reference CPO PK CPO PK

1. PT. Brahma Desa Suko Awin Latitude: Binabakti Jaya, Kecamatan 01o20’52.81” S Sekernan, Longitude: 15,655 3,787 17,864 4,303 Kabupaten Muaro 103o19’3.20” E Jambi, Provinsi Jambi, Indonesia

A.4. Description of Supply Base

A. 4. 1. General description

PT. Brahma Binabakti operates 1 palm oil mill. The raw material/ FFB for PT. Brahma Binabakti - Brahma Binabakti Mill is supplied from the own estate i.e.: Brahma Binabakti Estate.The raw material/ FFB for PT. Brahma Binabakti - Brahma Binabakti Mill is also supplied from Plasma i.e.: 1.

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Plasma 1; 2. Plasma 2 and outside fresh fruit bunch 42,28%. All estates are operated under one management of PT. Brahma Binabakti. All estates located in Jambi, Indonesia. PT. Brahma Binabakti is a member of RSPO and they are implementing a program to achieve RSPO Certified Palm Oil for all its production.

A. 4. 2. Location of the supply base

GPS No. Estate Name Location Latitude Longitude

Desa Bukit Baling, Brahma Binabakti Kecamatan Sekernan, o o 1 Estate Kabupaten Muaro Jambi, 01 21’ 38,04” S 103 21’ 38,04” E Provinsi Jambi, Indonesia

Desa Bukit Baling, Kecamatan Sekernan, Plasma 1 o o 2 Kabupaten Muaro Jambi, 01 23’ 37,88” S 103 24’ 19,96” E Provinsi Jambi, Indonesia

Desa Bukit Baling, Kecamatan Sekernan, Plasma 2 o o 3 Kabupaten Muaro Jambi, 01 27’ 05,31” S 103 23’ 11,26” E Provinsi Jambi, Indonesia

Desa Teluk Ketapang, Kecamatan Pemayung, 4 Plasma Pemayung 01 o 28’ 30,33” S 103° 26’ 25.09” E Kabupaten Batang Hari, Provinsi Jambi, Indonesia

A.4.3 Statistic of supply base (2016)

Planting Age/Planting Planted No Estate Name FFB/Year CPO/Year Pk/Year Year Year Area

1994 22 1,006.45 16,832 3,687 892 Brahma 1 1995 21 1,161.10 21,122 4,627 1,119 Binabakti 1996 20 848.07 15,399 3,373 816 Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 6of 124

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1997 19 185.11 3,513 770 186 1998 18 397.14 7,155 1,567 379 2005 11 28,08 515 113 27 2006 10 279.21 2,901 635 154 2007 9 446.93 4,032 883 214 Total 4,352.09 71,469 15,655 3,787

1996 20 2,474.00 37,706 7,586 1,924 Plasma 1 1997 19 1,326.00 20,992 4,224 1,071 1998 18 478.00 8,958 1,802 457 Total 4,278 67,656 13,612 3,452 2006 10 850.00 12,053 2,425 615 Plasma 2 2007 9 998.00 12,032 2,421 614 Total 1,848.00 24,085 4,846 1,229 2 2010 6 57.42 352 71 18 Plasma 2011 5 573.64 4,812 968 246 Pemayung 2012 4 10.38 - - - Total 641.44 5,164 1,039 264 Total Plasma 6,767.44 96,905 19,497 4,945 Out growers 119,548 21,630 6,101

Total 119,548 21,630 6,101

Grand Total 287,922 56,782 14,833

ESTIMATED PRODUCTION 2017

Planting Age/Planti Planted Estimated Estimated Estimated No Estate Name Year ng Year Area FFB/Year CPO/Year PK/Year

Brahma 1994 22 1,006.45 18,362 4,040 973 1 Binabakti 1995 21 1,161.10 22,152 4,873 1,174

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1996 20 848.07 18,091 3,980 959 1997 19 185.11 4,059 893 215 1998 18 397.14 8,254 1,816 437 2005 11 28,08 555 122 29 2006 10 279.21 4,316 949 229 2007 9 446.93 5,411 1,191 287 Total 4,352.09 81,200 17,864 4,303

1996 20 2,474.00 40,503 8,101 2,147 Plasma 1 1997 19 1,326.00 22,594 4,519 1,197 1998 18 478.00 8,403 1,681 445 Total 4,278 71,500 14,301 3,789 2006 10 850.00 14,634 2,927 776 Plasma 2 2007 9 998.00 17,016 3,403 902 2 Total 1,848.00 31,650 6,330 1,678 2010 7 57.42 462 102 24 Plasma 2011 6 573.64 5,655 1,244 300 Pemayung 2012 5 10.38 33 7 2 Total 641.44 6,150 1,353 326 Total Plasma 6,767.44 109,300 21,984 5,793 3 Outgrower 156,781 29,005 8,309 Total - 156,781 29,005 8,309

Grand Total 347,281 68,853 18,405

A.5. Organizational Information and Contact Person

1. Company Name PT. Brahma Binabakti

2. PersonL Contact Tjandra Karya Hermanto

3. Vice Management Rudy Prasetya

4. Company Address Jl. Sultan Thaha no. 4 Pasar Jambi, kota Jambi

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36113

5. Company Status PMDN

6. Phone/Fax 021-57944939 / 021-57944745

7. E-mail [email protected]

8. Website www.tap-agri.com

9. RSPO Membership Number 1-0147-13-000-00

A.5.1. Audit Against the Rules for Partial Certification

The team found that PT Brahma Bina Bhakti has its own identity/number of RSPO member. Actually the company is under Triputra Agro Persada holding but the holding itselt has its own number of RSPO member. Information gathered from RSPO representative of Indonesia (RILO) stated the company with its own identity/member should be assessed within the company only for partial certification scheme; therefore the Audit against the rules for partial certification is not applicable to Triputra Group but still applicable to the smallholders which supplied FFB to the PT.Braham Bina Bhakti. There are Smallholders ie 1. Plasma 1; 2. Plasma 2. During ASA 1 company does not have a detailed plan related to the proposed Certification Plasma 1, 2 and 3. When assurance to the KUD, Information was obtained that socialization / training is merely the best practices and has not related to the preparatory activities of Plasma Certification. This has been issued as Minor Nonconformity No. 31.

At the time of ASA 2 PT Brahma Binabakti has made a time-bound plan for plasma certification starting from 2018 to 2020. In 2017 there is already a socialization of the RSPO certification process to plasma 1. However, the time-bound plan is not certain to be completed within 3 years after PT. Brahma Binabakti is certified (issued certificate in 2015) so that the time-bound plan that has been made is inadequate. This has been issued as Major Nonconformity No. 12.

At the time of follow up audit of PT. Brahma Binabakti has made remedial actions to review and revise the time bound certification of PT Brahma Binabakti plasma so that all plasma will be certified in 2018. Conclusion : Conform

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A.6. Date Certificate Issued and Scope of Certificate

Name of Client PT Brahma Binabakti – Brahma Binabakti Mil

Client Number RSPO 00009

Certificate Number RSPO 00009

Certification Decision Date May, 26th 2015

Issued by PT SUCOFINDO, SBU SICS

Address Graha Sucofindo, SBU SICS. Jl Raya Pasar Minggu Kav 34 Jakarta 13640

Telephone /Fax Tel.: +62-21-7983666 / Fax.: +62-21-7987015

Email [email protected]

Website www.sucofindo.co.id

Scope :

Mill Brahma Binabakti Mill

Estate Brahma Binabakti Estate

Projected mass balance CPO & PK CPO: 17,864 MT and PK : 4,303 MT

Certification Registration Code SICS-00003

Type of Certification Single site

Certifier Triyan Aidilfitri

Signed

B. Assessment Process

B. 1. Certification Body SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES (SUCOFINDO ICS), which was formed in 1994, is one of the strategic business unit that provides certification services for leading The Company.SucofindoCertification by International Certification Services is Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 10of 124

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recognized nationally and international.Quality Management System Certification by SUCOFINDO ICS has obtained accreditation from National Accreditation Committee (KAN- Indonesia). Lead Auditors and Auditors of SUCOFINDO ICS are trained professionals in the field of international standards, auditing and management systems and are registered in the IRCA (International Register of Certified Auditors) and IEMA (Institute of Environmental Management & Assessment), UK. SUCOFINDO ICS certification process is supported by experts at PT. SUCOFINDO who understand the industry sectors and services in Indonesia. SUCOFINDO ICS Operational is supported by a network of branch and representative offices of PT. SUCOFINDO spread in 45 cities across Indonesia. The services provided by International Certification Services Sucofindo are:  Quality Management System Certification  Environmental Management System  ISO 22000 :2005  OHSAS 18000 Certification  Hazard Analytical Critical and Control Point (HACCP) Certification  Good Manufacturing Practice (GMP) Audit  Product Certification  Sustainable Forest Management Certification  Products Organic Food Certification  RSPO certification  ISPO Certification  Certification of Integrated Management System Certification (SMT)  Training

B. 2. Qualifications of the Assessment Team

B. 2. 1. Qualifications of the Lead Assessor and Assessment Team Tuti Suryani Sirait (ATL) : Graduated from Institute Agriculture in Bogor (IPB), 1991 She has more than 10 years audit experiences in auditing HACCP, GMP, ISO 9001:2008, ISO 22000:2005, ISPO and RSPO. She has successfully completion training RSPO by Komisi RSPO, Jakarta, SCC Standard Training by David Ogg & Partner – Jakarta, ISPO Lead Auditor Training by Komisi ISPO, Jakarta, Lead Auditor Training of ISO 9000/19011 organized by SICS – Sucofindo, ISO 22000 : 2005 FSMS Auditor / Lead Auditor by Moody International, Singapore; Lead Assessor for Food Safety Management System (HACCP&GMP) by QAS Sydney, Australia and Social Lead Auditor Training (SA 8000) from Social International Audit (SIA), Turkey. She is actively participated in RSPO meeting to discuss RSPO P & C and also as a trainer inISPO Lead auditor training.

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Ronald E Butar-Butar (Auditor) S1 graduated from Catholic University Faculty of Agriculture. Work Experience (Best Practice Estates) in oil palm estates for 6 years. He has successfully completion Lead Auditor Training ISPO by Komisi ISPO. He has completion In House Training RSPO for 4 days.

Sarsongko Wachyutomo (Auditor)

Graduated from Gadjah Mada University, Yogyakarta. He has successfully completion Lead Auditor Training ISPO by Komisi ISPO, Lead Auditor RSPO by Proforest and Diameter, Bogor, High Conservation Value (HCV) by HCV-NI and Auditor Training VLK by Pusdiklat Kehutanan, Bogor.

Agit Supriadi (Auditor) Graduated from Institute Agriculture in Bogor. He has successfully completion Lead Auditor Training ISPO by Komisi ISPO, Lead Auditor RSPO by Proforest and Diameter, Bogor.

Puji Sulistiono (Auditor): He was graduated from Bogor Agricultural University (IPB) majoring in Agricultural Engineering (bachelor) and Civil/Environmental Engineering (master). Experienced as research assistant in several agricultural development project and as engineer in several water infrastructure project. He was completed several training such as IRCA Reg. Lead Auditor Training for ISO 14001 and ISO 9001, Occupational Health and Safety Expert Training (AK3 Umum) from Ministry of Manpower - RI, Lead Auditor Training in Indonesian Sustainable Palm Oil (ISPO) from Komisi ISPO, Ministry of Agriculture - RI.

Bagus Ferry (Observer) He was graduated from Bogor Agricultural University (IPB). He has successfully completion Lead Auditor Training ISPO by Komisi ISPO.

B.3. Assessment Methodology

B. 3. 1. General Overview The assessment was carrying out in conformity with the SBU SICS RSPO manual and procedures for auditor and certifier. The assessment was conducted by qualified auditors and referred to RSPO standard. Partial certification audit conducted during compliance audit to check compliance with Final RSPO Certification System for partial certification. The opening and closing meeting audit was conducted at the office of estate and then continues in Mill’s and estate’s offices. Stakeholders meeting was conducted once, during compliance

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audit.

SurveillanceAudit Number of assessor participating: 5 auditors Number of days spent for the assessment on site: 5 days Total number of mandays used for the assessment on site: 25 days

Date/Time Functions / areas / Department / activities to be audited Auditor(s) (include related requirements) 13 Mar 2017 Day 1st (Monday) 09.00 -10.25 Trip form Jakarta to Jambi Team 10.25-13.00 Trip from Jambi to sites Team 14.00-14.30 Opening Meeting All 14.30-17.00 Check completeness of previous NCR minor and observation Team from ASA 1 17.00 End of audit day 2

14 Mar 2017 Day 2nd (Tuesday) 08:00-12.00 Check completeness of previous NCR minor and observation from ASA 1 12.00-14.00 Lunch Break 14.00-17.00 Document audit  Compensation to legal and customary right (6.4) SSW  Legality regarding land (2.2.1, 2.2.2) & 1.2.1 regarding land title  NPP (7.1-7.8)  FPIC (2.3)  Worker welfare (6.5) TSS  Anti-discrimination (6.8)  Schemed Smallholder (6.1.5)  Best practice at estate (4.1) RB  Erosion control and peat (4.3)  Land dispute and conflict (2.2.3, 2.2.4, 2.2.5, 2.2.6)  Development of local businesses (6.11)

 Safety in pesticide (4.6.5 – 4.6.12) AGT  Pest management (4.5 Pesticide (4.6.1 – 4.6.4)  Environmental impact assessment (5.1) and 1.2.1 PS

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regarding EIA POME for land application (4.4.3) 17.00 End of audit day 2

15 Mar 2017 Day 3rd (Wednesday]) 07:30 Visit estate Visit to harvesting, spraying and manuring TEAM Visit to HCV location Visit to housing facility, warehouses, bathing facility, day care Visit to BPN Pole Visit to land application 12:00-14.00 Break 14:00-16.00  Best practice mill (4.1) RB  Practices maintain soil fertility (4.2)  Water management at estate (4.4.1)  Complaint handling 6.3 Business plan (3.1)  NKT/HCV (5.2) and 1.2.1 SSW regarding HCV  Protection of water courses and wetlands (4.4.2)  Partial Certification  SCCS RSPO  FFB reception from small holder and local business (6.10) TSS  Child labour (6.7)  Social responsibility (6.1.1 – 6.1.4)  Water efficiency at mill (4.4.4) AGT  Water for worker (4.4.1)  Occupational health and safety and legal requirement regarding heath and safety ( 4.7)  Training 4.8  Compliance to regulation (2.1) Waste management (5.3) PS 16.00-17.00 Visit to mill Team 17.00 End of audit day 3

16 Mar 2017 Day 4th (Thursday) 08:00  Stakeholder consultation TEAM 12:00-14.00 Break 14:00  Forced labour (6.12) TSS Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 14of 124

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 Human right (6.13)  Sexual harassment (6.9)  Use of fire for preparing land or RB replanting (5.5)  Continuous improvement (8.1)  Trade Union (6.6)  Ethical conduct (1.3) SSW  Information provision (1.1, 1.2)  Consultation and communication 6.2,  Renewable energy (5.4) PS  GHG mitigation (5.6)  Water management at mill AGT (4.4.1) 17:00 End of audit day 4

17 Mar 2017 Day 5 (Friday) 08.00-12.00 Continuing pending matter TEAM 12.00-14.00 Break 14.00-15.00 Reporting TEAM 15:00 Closing meeting ALL

B. 4. Stakeholder Consultation B. 4. 1. Summary of How Stakeholder Consultation was Organized

Stakeholders Consultation part 1 at District Office Pemayung, Thursday, 16 March 2017, 10.00-12.00

Issue Company Responses Assessor Findings

Kuak Village Head, Mr. Peri Yulman

1. Transport related demand during flood, so . Conform that the company provides transportation

assistance so that workers can come to the workplace (site) 2. The handover of community land for plasma land so far has been running smoothly and safely 3. The company employs local workers,

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especially from the Village of Kuap Senanin Village Head , Mr. Muhammad

1. Villagers give up land voluntarily. Land Conform measurement submitted already using coordinate point (GPS)

2. Religious proposals submitted by the village are always responded by the company. Likewise with other proposals, the response given the company no longer one week after the proposal submitted. Communication of village members with the Company is running smoothly.

3. In the Pemayung subdistrict there is no indigenous tribe (Suku Anak Dalam – Jambi)

Lubuk Ruso Village Head, Mr. Syaukani Darma

The company always gives CSR to the Conform village. Hopefully this year the CRS given increased

Ola Rambahan Village Head, Mr. Rojali

1. The village proposal on road improvement Conform has been responded by the company. The company has improved access to village roads. Companies should be involved in village planning.

2. The company has socialized the animals and plants that are protected to the village community. Protected animals include Ungko, Deer, Tiger, various species of birds

Chief of Akso Dano KUD , Mr. Junaidi

1. Currently comparison between the area of In early 2017, a meeting Conform own estate is 270 Ha and plasma is 413 between the company and Ha. The number of plasma farmers 202 KUD was established. The results of the meeting

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people. discuss the monthly payments. The meeting was 2. The current payment method is done proven with the minutes. Is quarterly. KUD propose to the company to currently being formulated change the payment into every month. by the company.

Stakeholders Consultation part 2 at District Office Sekernan, Thursday, 16 March 2017, 15.00-17.00 PM

Issue Company Responses Assessor Findings

Representative Office of Manpower and Transmigration Kab. Muaro Jambi, Mr M. Amin NS

1. Currently wages in kab. Muara Jambi still Conform follows the provincial minimum wage (provincial minimum wage) because there is no wage council in the district. Muara jambi.

2. In 2016 there are no reports of work accidents in PT BBB.

3. The company undertakes a MOU with a third party related to the wholesale work to be reported to the Manpower Office

Representative Office of Estate Crops Kab. Muaro Jambi, Mr. Hendri Agustian

1. Disbun has conducted plantation grade Conform assessment on PT BBB. PT BBB got grade I.

2. The company has formed a fire care group

3. SPUP has been made, but can not be given to the company

Representative of Environmental and Forestry Agencies

1. No public complaints related to Conform environmental pollution.

2. The Company already reports regular environmental monitoring and

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management

Tanjut Lanjut Village Head, Mr.Edi Sugito

1. The company always responds to the Conform proposals submitted by the village. Response is usually by mail, short message or telephone.

2. No land conflicts

3. No environmental pollution

Ketua KUD

1. Companies provide tangkos, solid and ash Conform for fertilizer in plasma plantations

2. Communication between the company and the board of KUD runs smoothly

3. The company repaired the ditch and culvert in the plasma plantation 2, so the flood condition in plasma 2 was reduced

4. Related planting plan KUD hope can still cooperate with company. KUD proposes that the felling of oil palm trees should begin in stage.

5. Payments made by the company run smoothly

6. Technical guidance in preparation for RSPO certification to farmers has been done

7. With regard to the RSPO certification plan already undertaken:

A. Identification of land that already has a certificate of 1200 Ha B. Land of 2000 Ha of production forest status will be cultivated into Other Use Areas (APL) C. Best practices socialization has been

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done for example related to harvesting, fertilizer and maintenance activities

B. 5. Date of Nexts Surveillance Visit One (1) year after date of 2017 surveillance audit C. Assessment Findings

C. 1. Lead Assessor’s Summary and Recommendation for Certification

The Surveillance audit has been carried out through field visit to mill and estate using RSPO principle and criteria 2013 and RSPO Supply Chain Certification Standard 2014

Audit Team has published the nonconformities, comprising 7 majors and 5 observations. The company has made the corrective actions to the respectives nonconformities graded as 5 observations. All of the major findings have been closed. The team will see the evidence of implementation on the next surveillance audit.

Since there are no major non conformities unsettled, the audit team found that PT. Brahma Binabakti mill and its estates is still complying against RSPO P&C 2013 and RSPO SCCS 2014. Therefore, certification can be continued to PT. Brahma Binabakti (Mill and supply bases).

12 June 2017

Tuti S.Sirait

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C. 2 Assessment Findings

C.2.1 Summary of Findings

1 COMMITMENT TO TRANSPARENCY

1.1 Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages & forms to allow for effective participation in decision making.

1.1.1 Evidence should be provided that information is received in appropriate form(s) and language(s) by relevant stakeholders. Information will include Minor information on the RSPO mechanisms for stakeholder involvement, including information on their rights and responsibilities.

The Company has determined the type / level of information provided to stakeholders as required by the RSPO P & C. At the time public meeting with stakeholders that is Akso Dano cooperative, they already understand the mechanism to request information from the company. no SOP / SUPP / II / 2017/001 dated February 20, 2017 Revision 02 related Reception and Handling of Requests for Information have set the frequency of updating the list of stakeholders conducted every 6 months. The Company has appointed The KTU officer as responsible personnel to receive and reply for any information request. Companies should make provisions related to complaints submitted by email from stakeholder to the company. Conclusion : Observation No. 9

1.1.2 Records of requests for information and responses shall be maintained.

Major

The related SOP (No SOP / SUPP / II / 2017/001 dated February 20, 2017 Revision 02) has been revised. The company has set up a hierarchy of officers who provide information replies to relevant stakeholders. Officers who provide information starting from the level of Assistant KTU to the highest level of the Board of Directors in the head office.The approved grant period is provided within a maximum of 5 business days. For the type of information that is not approved will be given the answer within a maximum of 2 working days. In point 4.8.4 states every incoming letter requires a response no later than 14 working days. All requests for information are listed in the company logbook containing the accepted date and the date of the response to the request. Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 20of 124

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Conclusion : Conform

Management documents are publicly available except where this is prevented 1.2 by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes

1.2.1 Publicly available documents shall include, but are not necessarily limited to:  Land titles/user rights (Criterion 2.2)  Occupational health and safety plans (Criterion 4.7);  Plans and impact assessments relating to environmental and social impacts  (Criteria 5.1, 6.1, 7.1 and 7.8);

Major  HCV documentation (Criteria 5.2 and 7.3);  Pollution prevention and reduction plans (Criterion 5.6);  Details of complaints and grievances (Criterion 6.3);  Negotiation procedures (Criterion 6.4);  Continual improvement plans (Criterion 8.1);  Public summary of certification assessment report;  Human Rights Policy (Criterion 6.13). The company has the procedure (SOP No. 106 181 / TAP / PRO-CSR-HO / VI/13) that the content has been completed as required under RSPO standards for public accessed such as the concession, Complaints & Grivence Procedure, Negotiation Procedure, Continues improvement, Public Summary of the Certification audit report, and Human Rights Policy. The Company has been disseminated type of relevant information and can be accessed by all relevant parties to the stakeholders. The Company has set up the website of PT. BBB under the group name Triputra Agro Persada. In the website, the procedure of Complaint System has been addressed as a part of disseminion of communication procedure. Conclusion : Conform

1.3 Grower and millers commit to ethical conduct in all business operation and transaction

1.3.1 There shall be a written policy committing to a code of ethical conduct and

Minor integrity in all operations and transactions, which shall be documented and communicated to all levels of the workforce and operations.

The Company already has a Business Ethics Policy. Policy are listed on the instruction no. 004 /

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K-DIR / II / 2013 date February, 22. In each SPK has been stated a prohibition of all forms of corruption, bribery and fraudulent. Sampling has been taken from FFB Suppliers, they have understood of this policy and commit to ethical conduct and integrity in their operation and transaction. Conclusion: Conform

2 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

2.1 There is compliance with all applicable local, national and ratified international laws and regulations.

2.1.1 Evidence of compliance with relevant legal requirements shall be available.

Major

At the time of ASA, it is found that there are planted areas for 785 ha which planted in Forest Area (based on Forestry Minister Decree No. 727/2012) without release of forest area decree. This is not in accordance with Government regulation number 104 of 2015. This finding was issued as Major Nonconformity. At the time of ASA 2 visit, the status of the area is still the same so that in accordance with RSPO cerfication system, client is suspended per date March, 31, 2017 The meeting is held among client, RSPO secretariat and Sucofindo to resolve this case. RSPO asked the client to make the responsible timeplan to achieve the legal status for this are. The company has submitted the evidence for the coorective action. On May 5, 2017 the auditor clarified the status of the release process of PT. Brahma Binabakti to one of the data processing staff at the Directorate of Inauguration and Structuring of Forest Areas, Ministry of Environment and Forestry, on behalf of Mr. Opik Sukarsana.

He explained that the process of releasing forest areas is as follows: 1. Application by the applicant 2. Preliminary review by processing staff and forwarded to Section Head for concept of current regional status and regional history according to previous decisions. 3. If the concept has been approved by the Section Head (Echelon 4) it will be forwarded to the Head of Sub-Directorate (Echelon 3) 4. If the Head of Sub-Directorate has agreed then it will be forwarded to the Director (echelon 2) 5. If the Director has agreed then it will be forwarded to the Director General (echelon 1). 6. Wait for response from the Director General. 7. If the Director General has agreed then it will be conceptualized assistance to the integrated team from multi parties 8. Once the concept of an integrated team is approved it will be issued decree for the formation of an integrated team by the minister

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9. An integrated team preparation to the field. 10. Field verification 11. Preparation of recommendation report by integrated team 12. The report then reported to the minister by the Director General 13. Based on the report that given, the minister will issue decree on the release of forest area, its boundary and the establishment of new forest area.

Decree of Minister of Public Works and Public Housing No. 238 / KPTS / M / 2016 concerning the Granting of Water Resources Utilization Permit to PT BBB for Industrial Enterprises in Sungai Sekawan dated May 9, 2016 is available and valid for 5 (five) years. Terms of the permit: Maximum debit quota: 16.55 liters / sec Schedule of taking: 24 hours Location of take: Sungai Sekawan, Suko Awin Jaya Village, Kec. Sukernan, Kab. Muaro Jambi, Prov. Jambi Coordinates: S 01 21 20.2 E 103 19 19.5

Liability:  Daily water collection report, and monthly water quality test result every 3 (three) months to BWS Sumatera VI, Dinas PSDA  Calibration of volumetric meter every 1 (one) year  Daily measurement of daily water level per 3 (three) months to BWS VI, PSDA Service Monthly Water Utilization Report of Sungae and has been reported to BWS Sumatra VI

Monthly Water Utilization Report of Sungai Sekawan for the period October - December 2016 was available and has been reported to BWS Sumatra VI Water quality testing of river has been done by UPTB Lab Environment of Jambi Province on September 1, 2016 with evidence of LHU no. 990 / LHU / L2JBI / IX / 16 - Upstream and Downstream Sekawan River - PP No. 82/2001 Class II with BOD, COD, TSS, oil & fat, NH3-N, pH parameters and all parameters are still in accordance with the required quality standards.

Evidence of the flow meter calibration has been available with evidence of Test Result Certificate No. 510.31 / DPP / Met / SKHP / III / 2017 from UPTD Metrology Disperindag on March 14, 2017 for 3 (three) flow meter units for process, boiler and domestic needs. Conclusion: Major NCR No.7

2.1.2 A documented system, which includes written information on legal

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Minor requirements, shall be maintained.

The Company has set a periodic evaluation to meet regulatory and written in the TAP/SOP/120 – SHE / 001 BAB III (Legal and Other Requirements). SPO Officer recapitulate compliance regulations in each unit, which includes in the area of legality, agronomy, best practices mill, employment, SMK3, and the environment. Conclusion: Conform

2.1.3 A mechanism for ensuring compliance shall be implemented.

Minor

The Company has made a legal compliance verification through internal audit conducted with frequency once a year. SHE Sustainability Officer PT. Brahma Binabakti recapitulates and evaluate compliance regulations in each unit estate and mill. The Company has evaluated the compliance with laws and regulations regularly. A list of applicable and appropriate legislation that in line with the company's activities was available in Annex 1 (MI-005 / MD / SUST / XII / 2012) and evaluated on March 2017. Evaluation of compliance related to PUPR Candidate No. 37 of 2015 was available with evidence of the Decree of the Minister of Public Works and Public Housing no. 238 / KPTS / M / 2016 concerning the Granting of Water Resources Utilization Permit to PT BBB for Industrial Enterprises in Sungai Sekawan dated May 9, 2016 and valid for 5 (five) years. Proof of payment of withdrawal and utilization tax of surface water has been available based on evidence of recording no. 000541 as of February 23, 2017 for the use of water 38,239 m3.

Conclusion: Conform

2.1.4 A system for tracking any changes in the law shall be implemented.

Minor

The Company has established TAP/SOP/120 – SHE / 001 BAB III which regulate the mechanism of updating the latest regulations relating to the Company's activities. Conclusion: Conform

2.2 The right to use the land is demonstrated, and is not legitimately contested by local people who can demonstrate that they have legal, customary or user rights

2.2.1 Documents showing legal ownership or lease, history of land tenure and the

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actual legal use of the land shall be available. Major

Location Permits PT Brahma Binabakti has location permits ie: 1. The Company had estate location permits based on the Decree Governor of the Jambi Province No. 101/ 1990 dated March 31, 1990 regarding reserve land for the Rubber Plantation PT BBB. Estate is located in location A Hulumendahara river and location B Kaos River in Sekernan district, Batang Hari regency with an area of ± 6.500 Ha. 2. Location permits explained that the reserve land covering an area 6.500 Ha for rubber plantation PT Brahma Binabakti was divided to each location.Location A (Sungai Hulumendahara covering an area 3500 Ha located approximately KM 45-KM 60 right the way Jambi-Merlung and Area B (River Kaos) covering an area 3000 Ha located around Km 42- KM 60 in left the road Jambi - Merlung in Sekernan district, Batang Hari regency. 3. The Company had letter decree of with No. 529/ 2011 concerning amendments to the decision of Muaro Jambi regency No. 24/2011 concerning location permit for development of Palm Oil Estate PT Brahma Binabakti (Smallholder I) in Suko Awin Jaya village, Tanjung Lanjut village, Sekernan district, Muaro Jambi covering an area 6.830 Ha 4. The Company had letter decree of Muaro Jambi regenct with No. 25/ 2011 concerning location permit development of Palm Oil Estate PT Brahma Binabakti (Smallholder II) in Suak Putat village, Tanjung Lanjut village, Bukit Baling village, Gurunggung village, Sekernan district, Muaro Jambi covering an area 5.350 Ha 5. The Company had mill location permits based on Decree Letter Head of the Land Office Batang Hari No. 4/1997 dated March 17, 1997 covering an area ± 50 Ha located in Bukit Baling village, Sekeran district, Batang Hari Regency. 6. Company also had location permits from Head of Badan Pelayanan Terpadu Satu Pintu Batang Hari Regencywith No. 08/2011 regarding location permit for development plan of Palm Oil Estate PT. Brahma Binabakti in Pemayung district, Batang Hari regency, Province Jambi covering an area 6.400 Ha 7. There is decree Head of Badan Penanaman Modal dan Pelayanan Perizinan Terpadu Batang Hari Regency No. 66/2014 concerning the extension of the location permit for the development plan of oil palm estate PT Brahma Binabakti In Pemayung district, Jambi Province, Batang Hari covering an area of 6000 Ha. Plantation Business Permit (IUP) Related Document of Plantation Business Permit (IUP) ie : 1. Decree of Minister Agriculture No: HK.350 / E4.379 / 04.90 dated April, 18 1990 concerning the approval of business principles rubber plantation covering an area 6.000 ha in Sekernan district, Batang Hari regency, Jambi province. This permit set a net area about 6.000 ha from

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land reserve covering an area 6.500 ha brutto commodities rubber. 2. Letter of Approval of Change Type Plant PT. Brahma Binabakti, Jambi Province of the Directorate General Plantation - Department of Agriculture Number: HK.350 / E5.363 / 05.96 dated May 28, 1996. The change of Commodity rubber with an area of 6.000 ha to the type of commodity rubber and oil palm plantations with a total area of 6.000 hectares (Rubber with an area of 3000 ha and 3.000 ha of oil palm) on an concession area about 6.220 Ha. 3. PT Brahma Bina Bakti already have Plantation Business Registration License (SPUP) from the Directorate General of Plantation Production Number: HK.350 / 425 / Dj.Bun.5 / VI / 2001 dated June 6, 2001. This SPUP set business a rubber plantation culture with plantation area of 6.220 Ha and processing unit type Latek Pekat with a capacity 3.500 tons / year. 4. Decree of the Head of the Investment Coordinating Board (Badan Koordinasi Penanaman Modal) No. 2/1 / IU / IV / domestic / Agriculture / Industry / 2010 dated May 20th, 2010 concerning business licenses in the framework of the Merger (Merger). The business sectors were rubber and palm oil plantation integrated with the palm oil industry and palm kernel. The capacity license for FFB production was 67 800 tonnes / year, latex rubber plantation was 3,500 tons / year, crude palm oil (CPO) was 60,000 tons / year, and palm kernel was 12,720 tons / year. The land area was listed in the permit was 2,820.00 ha for palmoil plantation and 3390.00 hectares for rubber plantation and 726.00 m2 for the industry. If the license has been stated that the shortage of FFB as many as 193,200 tonnes (equivalent to 8,050 hectares) was supplied from around smallholder, the company could carry out product diversification within the scope of the edible oil industry (crude oil) and vegetable. 5. PT. Brahma Bina Bakti applied for changes in types of plant and processing on SPUP No. HK.350/425/Dj.Bun.5/VI/2001 through a letter no. 105492/BBB/SPM-R01-HO/IX/13, dated September, 2nd 2013. 6. Forestry and Plantation Letter No. 525/1193 / Dishutbun / 2013, dated September, 24th 2013 approved the recommendation of Plantation Business Permit (IUP) covering an area of 3,661 hectares of oil palm and its management with a capacity of 60 tons / hour and Aquaculture Plantation Business Permit (IUP- B) of rubber covering 2,559 hectares located in the village of Suko Awin District of Sekernan, Muaro Jambi. 7. The Company has processed the changes in plant type and processing on SPUP no. HK.350/425/Dj.Bun.5/VI/2001 and obtained the letter from One-Door Integrated Service Agency (Badan Pelayanan Terpadu Satu Pintu) no. 503/213/BPTSP/XI/2013 dated November, 15th2013. The letter explained that the issuance of changes in plant type and processing of the license was still in process in the Agency One Stop Muaro Jambi. 8. The Company has obtained the Letter of Approval of Changes in Plant Type and Processing of the SPUP (Plantation Business Registration Letter) No. HK.350/425/Dj.Bun.5/VI/2001 PT. Brahma Binabakti from One-Door Integrated Service Agency (Badan Pelayanan Terpadu Satu Pintu) of Muaro Jambi Regency number: 503/01/BPTSP/2013 dated 20 November 2013 from originally Rubber commodity and Latex Processing into rubber and palm oil

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commodities along with oil palm processing with a 60 tonnes/hour capacity with a total area of rubber plants of 2,559 Ha and oil palm of 3,661 Ha. 9. The Company has obtained Decree Letter from Regent of Batang Hari no. 640 year 2013 on granting permission of plantation business permit for cultivation (IUP-B to PT Brahma Binabakti with area of 3,500 hectares in the Pemayung district.

HGU Decree : 1. Decree of the State Minister of Agrarian/ Head of National Land Agency Number: 61/HGU/BPN/95dated of 2 October 1995 concerning the granting of Exploitation Right for 25 years (up to 31 December 2020) to PT. Brahma Binabakti of 6,220 Ha of land located in forest group of S. Hulumendahara-S. Kaos, Batanghari Regency, Jambi Province. 2. Decree of the Head of the Regional Office of National Land Agency of Jambi Province Number: 07/HGU/BPN.15/2014 concerning the granting of Exploitation Right for 35 years to PT. Brahma Binabakti of 453.3 Ha 3. Decree of the Head of the Regional Office of National Land Agency (Badan Pertanahan Nasional) of Jambi Province Number: 08/HGU/BPN.15/2014 concerning the granting of Exploitation Right PT. Brahma Binabakti of563.783 Ha, located in Muaro Jambi Regency, Jambi Province. HGU Certificate: 1. HGU Certificate No. 2 with location in Bukit Baling Village, Sekeran District, Batang Hari Regency, Jambi Province. The area covered is based on the letter of measurement No. 1814/ 1996 dated 1 May 1996 of 28,200,000 m2 2. HGU Certificate No. 3 with location inBukit Baling Village, Sekeran District, Batang Hari Regency, Jambi Province. The area covered is based on the letter of measurement No. 1815/ 1996 dated 1 May 1996 of 34,000,000 m2. 3. Revision of HGU certificate No. 3 on 20 November 1998 to become 33,902,275 m2 due to the purchase of 97,725 m2 by PGN. 4. HGU Certificate no. 94 – 108 that is issued by National Land Agency (Badan Pertanahan Nasional)of Muaro Jambi Regency in 2014 with total area of 453.3 Ha in accordance with Decree Letter no. 07/HGU/BPN.15/2014. 5. HGU Certificate no. 77 – 93 that is issued by National Land Agency (Badan Pertanahan Nasional) of Muaro Jambi Regency in 2014 with total area of 563.783 Ha in accordance with Decree Letter no. 08/HGU/BPN.15/2014. SK HGB: Decision of the Head of National Land Agency (Badan Prtanahaan Nasional) No: 34 / HGB / BPN / 2000 dated May 29th, 2000 providedHak Guna Bangunan to PT. Kirana Sekernan for 30

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years with an area of 492,280 m2 located in the village of Bukit Baling, District of Sekernan, Regency of Batanghari, Province of Jambi, whis is described in measurement certificate dated September 23rd, 1999 No. 05 / BKB / 1999. HGB Certificate HGB certificate no. 2, located in Bukit Baling Village, Sakernan District, Batanghari Regency, and Jambi Province with an area of 49,228 ha, which is ended on October, 9th 2030. The company has had a Standing Instruction No.027 / MI-DIR / XII / 2012, which contains instructions on how to manufacture and maintenance concession boundary markers such as the size of the mark, the type and color of paint, as well as the identity of the article reporting deadline. However, maintenance and monitoring reporting of the concession boundary markers should be reported every month before the 7th of each month was not appropriate. The last reporting was reported once in the last 3 months i.e from July to September 2013. The Company has reported the maintenance and monitoring of the concession boundary marker in accordance with a standing instruction. Release of forest area The company had permit letter regarding the release of forest area through Decree of Minister Forestry No. 125 / Kpt-II / 1993 dated February 27, 1993. Letter explained the release of some forest group S. Hulumendahara - S. Kaos located in Batang Hari regency, Jambi covering an area of 6.220 (Six Thousand and Two Hundred Twenty) ha for the cultivation of rubber plantations with the name of PT.Brahma Binabakti. There are observations finding on previous audit, i.e PT. Brahma Binabakti does not have HGU for Pemayung Estate. During surveillance audit the company shows corrective action in the form of Letter of Assignment Preparation Measurement issued by BPN Regional Office of Jambi province on March 3, 2017. In the letter it is known that on March 6, 2017 until March 10, 2017 there are taskforce for preparing cadastral measurements of PT. Brahma Binabakti in Pemayung District covering an area of 2.463.500 m2. In the absence of SK HGU for the Pemayung area, the area is excluded from the scope of certification and included in the Company's time bound.

There is a major finding in the previous audit that there are areas of plasma that has been planted for 189 ha in the concession area of PT. Brahma Binabakti. This is not correct accordance to Government Regulation No. 40 1996. During surveillance audit the company has taken the corrective action i.e identified the location of the plasma as outlined in the map the location and conduct negotiations with land owners. Last negotiations conducted on November 8th to November 12th 2016, with the agreement that some landowners request that their land be removed from the company's HGU. Some again requested that their land be owned by the company but was given a replacement for another adjacent land. Corrective actions have been considered adequate so the finding can be closed.

Conclusion: Conform

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2.2.2 Legal boundaries shall be clearly demarcated and visibly maintained.

Minor

PT. Brahma Binabakti has a Standing Instruction No. 027 / MI-DIR / XII / 2012. The company already has a list of inventory coordinates HGU. Sampling at visit time to poles border No. KP 39 (S 01°20’40,7”; E 103°24’16, it found that the pole is in good condition. Conclusion: Conform

2.2.3 Where there are or have been disputes, additional proof of legal acquisition of title and evidence that fair compensation has been made to previous Minor owners and occupants shall be available, and that these have been accepted with free, prior and informed consent (FPIC).

The information of land dispute is with the village community who have finished 8 issue of dispute through Muaro Regent Decree No.25 of 2011. Conclusion: Conform

2.2.4 There shall be an absence of significant land conflict, unless requirements for acceptable conflict resolution processes (see Criteria 6.3 and 6.4) are Major implemented and accepted by the parties involved. Until now, there are no areas that are still disputed by others. Related to land disputes between the Company and the NGO FMP (Farmer Community Forum), the Company has been doing land dispute resolution process in accordance with the agreement of both parties.

Conclusion: Conform

2.2.5 For any conflict or dispute over the land, the extent of the disputed area shall be mapped out in a participatory way with involvement of affected parties Minor (including neighbouring communities where applicable). The Company already has mapping-related areas of conflict in accordance with SOP No. 106 899 / TAP / PRO-CSR-HO / XI / 16 and the boundaries are adjacent to areas of conflict as well as the coordinates of the area.

Conclusion: Conform

2.2.6 To avoid escalation of conflict, there shall be no evidence that palm oil operations have instigated violence in maintaining peace and order in their Major current and planned operations.

In procedure of acceptance and resolution of complaints from stakeholders (106899 / TAP / PRO-CSR-HO / VI / 13) points 4.3.3 included all parties must refrain to keep the peace and avoid any form of intimidation, either directly or indirectly from any parties. In addition, the company has a procedure of land acquisition (002 / TAP / PRO-SCP-HO / IV / 10). The

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procedure containedthe provision of granting compensation process transparentlyand fairly, involved government and traditional leader. Conclusion: conform

2.3 Use of land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent.

2.3.1 Maps of an appropriate scale showing the extent of recognised legal,customary or user rights (Criteria 2.2, 7.5 and 7.6) shall be developed Major throughparticipatory mapping involving affected parties (including neighbouringcommunities where applicable, and relevant authorities).

The Company has had SOP of Land Acquisition (002/TAP/PRO-SCP-HO/IV/10). In point 4.1.3 has stated land acquisition and compensation based on FPIC.

Conclusion: Conform 2.3.2 Copies of negotiated agreements detailing the process of free, prior and informed consent (FPIC) (Criteria 2.2, 7.5 and 7.6) shall be available and shall Minor include: a) Evidence that a plan has been developed through consultation and discussion with all affected groups in the communities, and that information has been provided to all affected groups, including information on the steps that shall be taken to involve them in decision making; b) Evidence that the company has respected communities’ decisions to give or withhold their consent to the operation at the time that this decision was taken; c) Evidence that the legal, economic, environmental and social implications for permitting operations on their land have been understood and accepted by affected communities, including the implications for the legal status of their land at the expiry of the company’s title, concession or lease on the land. The Company requires certain documentation requirements that must be stored in any settlement of the conflict and compensation. It is listed in the SOP Acquisition of land (002 / TAP / PRO-SCP-HO / IV / 10) and SOP Acceptance and resolution of complaints from stakeholders (106 899 / TAP / PRO-CSR-HO / VI / 13). All data is stored in a separate file for each case. Related to compensation to Mr. Pajrin in Afd E, Block E1 PT. Brahma Binabakti have to take corrective action as follows : a. SOP is equipped with a sample map for the future, complete with coordinates, scale, approved by the party claimed, witnesses, and the approval of the company

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b. Minutes of Measurement Result of Land No. 01 / BBBS / 1/2014 has been improved by adding the approval of the authorities on behalf of the village. c. Receipts are received by Mr. Pajrin as the landlord Related to the observations findings on previous audit, PT. Brahma Binabakti has make corrective action i.e: agreement on release of land of Mr. Pajrin been repaired by bringing the signature page of the witnesses be under the signature of Mr. Parjin, the Board of Directors and Chief of Desa Jaya Suko Awin (Hidayah). Corrective actions have been considered adequate therefore, the previous observation can be closed. Conclusion: Conform

2.3.3 All relevant information shall be available in appropriate forms and languages, including assessments of impacts, proposed benefit sharing, Minor and legal arrangements.

There was a relinquishment of rights letter between the company and claim maker; Mr. Pajrin dated February 11, 2014. The relinquishment of rights agreement was made in 3 pieces and there are initials on each of the sheet and also signatures of the witnesses made in a same page. Therefore the previous observation can be closed.

Conclusion : Conform

2.3.4 Evidence shall be available to show that communities are representedthrough institutions or representatives of their own choosing, Major including legalcounsel.

In the procedure of land acquisition has already contained provisions of compensation document storage of 15 document types. The documentation was complete as required in the procedure. For example, there were document receipt and compensation minutes. Conclusion: conform

3 COMMITMENT TO LONG-TERM ECONOMIC AND FINANCIAL VIABILITY

3.1 There is an implemented management plan that aims to achieve long-term economic and financial viability

3.1.1 A business or management plan (minimum three years) shall be documented that includes, where appropriate, a business case for scheme smallholders. Major

The Company already has a business plan. It was prepared from 2014 until 2022. In the long- term business plan, the company has projected the fruit production or fruits derived from plasma. In the production plan, the company also have plans to make estimates related to

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production of CPO, OER and good production capacity for plasma and own estate. Conclusion: conform

3.1.2 An annual replanting programme projected for a minimum of five years (but longer where necessary to reflect the management of fragile soils, see Minor Criterion 4.3), with yearly review, shall be available. The Company has replanting plan program from 2018 until 2021. Replanting plan distribution of palm plantation PT Brahma Binabakti : • In 2018 the Company plans replanting of an area of 1,006 Ha • In 2019 the Company plans replanting of an area of 1,113 Ha • In 2020 the Company plans replanting of an area of 896 Ha • In the year 2021 the Company plans replanting of an area of 582 Ha Conclusion: conform

4 USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS

4.1 Operating procedures are appropriately documented and consistently implemented and monitored

4.1.1 Standard Operating Procedures (SOPs) for estates and mills shall be

Major documented.

The company has procedure land clearings with the principle of non-burning (zero burning). Land clearing methode have contained in Agronomy Procedure revision 1: TAP-PR / AGR / OP- 001 / V09-1. The company also has a SOP for Mill Operation set out in the Technical Guidelines Mill. Conclusion: conform

4.1.2 A mechanism to check consistent implementation of procedures shall be in

Minor place.

The Company has a monitoring mechanism for each activity, such as in the implementation of crop rotational that have been defined in the SOP (7 days). The Company has monitoring crop rotation for all afdeling and they also has a list of monitoring crop rotation. The company also has monthly reports as material control operational activities of the Company.

Conclusion: conform

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4.1.3 Records of monitoring and any actions taken shall be maintained and available, as appropriate. Minor

Company has the documentation for each activity that summarized for each month activities and recorded in the monthly progress report. Conclusion: conform

4.1.4 (M) The mill shall record the origins of all third-party sourced Fresh Fruit Bunches (FFB). Major Company has the data for each origin of FFB that incoming to PT. BBB Mill, the following is the documentation of the origin of FFB (kg) in 2016 and recorded in the "Statistics Of Supply Base (2016)". Supply Base FFB (Ton) Own Estate 71,469 Plasma I 67,656 Plasma II 24,085 Out grower 119,548

Conclusion: conform

4.2 Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield

4.2.1 There shall be evidence that good agriculture practices, as contained in Standard Operating Procedures (SOPs), are followed to manage soil fertility Minor to a level that ensures optimal and sustained yield, where possible. Company has SOP for soil sampling procedure (069 / PT / VIII / 2014) and leaf sampling (LSU) procedure (050 / PT / VIII / 2014). The frequency of the soil sampling conducted once every five years, while the Company conducted leaf sampling (LSU) for fertilizer recommendations once a year. The Company has been analyzing samples of the leaves that have been done on September 19, 2016, with reference number 51L / HAL-HPS / int / IX / 2016 to determine the nutrient content in plants. The nutrients that are measured include the percentage of N, P, K and Mg. The company also had analyzed soil samples to determine the available nutrients in the soil on November 17, 2016 by PT Hijau Persada Sejahtera with reference number 16S / HAL-HPS / Int / XI / 2016.

Conclusion: conform

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4.2.2 Records of fertiliser inputs shall be maintained.

Minor Company has SOP manual fertilization No. PPG / GMO / ASD / 45 / SOP to support optimal production by improving soil nutrient. The Company also conducts application of empty bunch to add nutrients to the soil as much as 26,105 tons at a dose of 40 tons/ha/year. To improve soil nutrients, the company also conducted fertilizing based on analysis of leaves that have been done. The realization of fertilization during 2016 were: Realization Type of Fertilizer (Kg) Jan-Des 2016 TAP COM 1 - TAP COM 2 440.469 TAP COM 3 3.203.593 Urea 824.049 Borate 54.915 DOLOMITE 175.874 KIESERITE 293.842 MOP 449.216

Conclusion: conform

4.2.3 There shall be evidence of periodic tissue and soil sampling to monitor changes in nutrient status. Minor Company has SOP for soil sampling procedure (069 / PT / VIII / 2014) and leaf sampling (LSU) procedure (050 / PT / VIII / 2014). The frequency of the soil sampling conducted once every five years, while the Company conducted leaf sampling (LSU) for fertilizer recommendations once a year. The Company has been analyzing samples of the leaves that have been done on September 19, 2016, with reference number 51L / HAL-HPS / int / IX / 2016 to determine the nutrient content in plants. The nutrients that are measured include the percentage of N, P, K and Mg. The company also had analyzed soil samples to determine the available nutrients in the soil on November 17, 2016 by PT Hijau Persada Sejahtera with reference number 16S / HAL-HPS / Int / XI / 2016.

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Conclusion: conform

4.2.4 A nutrient recycling strategy shall be in place, and may include use of Empty Fruit Bunches (EFB), Palm Oil Mill Effluent (POME), and palm residues after Minor replanting.

The Company also conducts application of empty bunch to add nutrients to the soil as much as 26,105 tons at a dose of 40 tons/ha/year. Conclusion: conform

4.3 Practices minimize and control erosion and degradation of soils.

4.3.1 Maps of any fragile soils shall be available.

Major The Company already had map to reflect the conditions of land suitability of palm oil with a scale of 1: 60,000. In the land condition map PT BBB indicates that the entire area of PT BBB currently on mineral land. Company also had the technical guidelines for the conservation of marginal areas. As for soil and water conservation techniques that Company has done such as:

• Maintenance of cover crops and vegetation

• Application of empty bunch

• Preparation of midrib

• Making rorak

• Terrace of contour

Conclusion: conform

4.3.2 A management strategy shall be in place for plantings on slopes above a certain limit (this needs to be soil and climate specific). Minor Company has SOP (060 / PT / VIII / 2014) manufacture of hooves as a management strategy for planting in slopes area with the aim of providing optimal space and potential soil fertility can be maintained in a long period of time and efforts to prevent erosion. Making hoof performed on bumpy areas with a slope of 12% -24%. The conservation techniques based on the slope: • Choppy area ( slope of 0-12%) should be planting wheat and preparing the midrib. • Corrugated area (slope of 12-24%) need to manufacture hoof • Hilly (slope of 24-38%) need terracing, contour • Very steep area (slope above 38%) are not proper to be planted

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Conclusion: conform

4.3.3 A road maintenance programme shall be in place.

Minor The Company has a plan and realization of road repair by hardening the road along the 21,395 meters and the realization data up to 1,620 meters until February 2017 with using grader. The company also has a road maintenance plan during the year 2017 that set out in the Annual Budget. To improve and maintain the quality of the road, the company is also working on creating the trenches, culverts and rorak.

Conclusion: conform

4.3.4 Subsidence of peat soils shall be minimised and monitored. A documented water and ground cover management programme shall be in place. Major

The company has no peat areas, it is based on the identification type of land. The company has mineral soil types. Conclusion: N/A

4.3.5 Drainability assessments shall be required prior to replanting on peat to determine the long-term viability of the necessary drainage for oil palm Minor growing.

The company has no peat areas, it is based on the identification type of land. The company has mineral soil types Conclusion: N/A

4.3.6 A management strategy shall be in place for other fragile and problem soils (e.g. sandy, low organic matter, acid sulphate soils). Minor

The Company has a strategy for the fragile and problem soils, such as the company use empty bunch applications to add nutrients in the sandy soil. Generally, PT Brahma Binabakti has mineral soil type so it does not need a lot of treatment to improve the structure of the soil. Conclusion: conform

4.4 Practices maintain the quality and availability of surface and groundwater.

4.4.1 An implemented water management plan shall be in place.

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with reference to the Permenkes 416/1990 for clean water. The results of test showed that result for all parameters meet requirement quality standards. Therefore, the previous observation can be closed. In 2016, total water consumption for process activities about 112,470 M3 and total boiler water usage 281,688 M3. The amount of water usage as much as 394,158 M3. Total FFB processed until the end of December as many as 287,937 tons. The water usage ratio is 1:37. This value is still far from the target of 1:20, but decreased from 2015 at 1:42. Aside from the water surface, the water needs for office activities drawn from underground water for POM in the two points of underground water. With the permission of the Head of Department of Energy and Mineral Resources Muaro District No. 05 of 2014 and No. 08 of 2014 dated March 28, 2014 with a validity period of 3 years. The allowable discharge were 50 liters/sec for each. Whereas, taking underground water licensing for estate’s office needs with number 06/2014 is the same discharge of 50 liters/sec. PT BBB groundwater source map with scale of 1: 100.000 with the number of groundwater uptake points as much as 7 (seven) has been available. Groundwater uptake permits from the seven are already available from related agencies. Decision of the Head of Department of Investment and Integrated One-Stop Services of Jambi Province concerning GRANTING LICENSE OF LAND WATER OPERATION TO PT BRAHMA BINABAKTI dated January 26th , 2017 and valid for 3 (three) years has been available. Therefore the previous major can be closed. Monthly Water Pollution Reports Period February 2017 to Head of ESDM Department of Muaro Jambi based on Permit no. 5/2014 and No. 8/2014 with withdrawal amount 8475 m3 and 2971 m3 dated March 4th , 2017 - at POM locations already available. Monthly Water Pollution Reports Period February 2017 to Head of ESDM Department of Kab. Muaro Jambi based on Permit no. 20, 21, 22, 23 with a total of 280 m3, 140 m3, 140 m3 and 1680 m3 dated March 6th, 2017 - at the estate and POM is available. Groundwater uptake permits and water quality results for 7 (seven) groundwater sources identified in PKS and estate, but for water sources in afdeling E and A are still in the identification stage for permit handling. This has been raised as observation.

Conclusion: Observation No.2

4.4.2 Protection of water courses and wetlands, including maintaining and

Major restoring appropriate riparian and other buffer zones (refer to national best practice and national guidelines) shall be demonstrated. In the current surveillance audit the auditor verifies the corrective actions made by the company in the form of signboard installation for maintenance of riparian and trees planting (Pulai, Jambu

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biji, and Karet) along riparian of Sekawan river. During field visits it is found that the sign board has been installed and trees planted in good condition. The company already has a monitoring program to ensure that the embedded trees can grow well. Adequate corrective action has been made and non-conformity can be closed.

PT. Brahma Binabakti has the river map for Own and Pemayung Estate. The rivers that crosses the own estate area according to the river map and based on identification of HCV in 2013 are Putat river (width 1,5 – 3 m), Anak Mendahara river (width 2 – 4 m), and rivers that crosses the Pemayung estate are Danau Bangko river (width 10 – 15 m) and Batanghari river (width 250 – 400 m). In the HCV identification report, assessor set the width of riparin river as follows: - 20 meters each side of the Suak Putat river along 3.472 m - 20 meters each side of the Anak Mendahara river along 4.192 m - 50 meters each side of the Danau Bangko river - 50 meters each side of the Batanghari river

In the previous audit found major non-conformity about recommendation from HCV assessor which set the width of riparian for Suak Putat and Mendahara river are 20 m. The recommendation has get approval from Badan Lingkungan Hidup of Muaro Jambi written in letter No: 660.4/36/BLH.3/2016 dated 4 April 2016. However, during field visit to Block D-12 (Afd. E) Auditor found that the company has set the riparian with the width 50 m from the river (marks with yellow paint around the palm oil trees). This is consistent with the interviews results with sprayers stating that trees with yellow paint was banned for a given chemical treatment.

PT. Brahma make efforts to protect water bodies and the riparian with : 1. Test the water quality of the river to determine the chemical pollution that enter the river water. 2. Establish limited treatment zones without fertilizer and agrochemical applications for border that had already planted. Adequate corrective action has been made and non-conformity can be closed. Conclusion: Conform

4.4.3 Appropriate treatment of mill effluent to required levels and regular monitoring of discharge quality, especially Biochemical Oxygen Demand Minor (BOD), shall be in compliance with national regulations (Criteria 2.1 and 5.6).

Decree of One Stop Agency Muaro Jambi Sub decree No. 07 / Kep.KaBPTSP / VI / 2016 dated June 23, 2016 on the extension of Wastewater Utilization Permit PT. BBB POM with an area of 300 Ha and license valid for 5 (five) years. Obligations related to the license : - Monitoring the quality of waste water (coordinates S 1 21 00.7 103 19 29.2) with parameters of pH (daily), BOD, COD, oils / fats, Pb, Cu, Zn, and Cd - Monitoring of groundwater quality (5 points: 3 land applications, 2 control wells) with the

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parameters of BOD, COD, pH, NO3, NH3-N, Cd, Cu, Pb, Zn, Cl, SO2 every 6 (six) months - Monitoring of land (6 layers: 0-120 cm) conduct every 1 (one) year The Company reports on the monitoring activities to the BLH Muaro Sub district. Conclusion: Conform

4.4.4 Mill water use per tonne of Fresh Fruit Bunches (FFB) (see Criterion 5.6) shall be monitored. Minor

In 2016, total water consumption for process activities 112,470 M3 and total special boiler water usage 281,688 M3. The amount of water usage as much as 394,158 M3. Total FFB processed until the end of December 2016 as many as 287,937 tons. It found that the water usage ratio is 1:37. This value is still far from the target of 1:20, but decreased from 2015 at 1:42. Conclusion: conform

4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management Techniques

4.5.1 Implementation of Integrated Pest Management (IPM) plans shall be monitored. Major The Company has Guideline Technical Agronomy in which there are SOP Pest and Plant Disease Control such as pest control of Worm Eater Leaf (UPDKS) 041 / PT / VI / 2014, pest control rats 042 / PT / XII / 2014 and pest control beetle horn 045 / PT / VI / 2014. The Company also has early warning system (EWS) through regular pests monitoring every month such as fire caterpillar, bags caterpillar and ganoderma. Conclusion: conform

4.5.2 Training of those involved in IPM implementation shall be demonstrated.

Minor Company had census worker for each Division, coordinated by the foreman of each Division. The company also had census worker that has been appointed as EWS team. Company has conducted EWS Training to the team in the form of Agronomy Technical Training on May 21, 2016 and introduction of pests and diseases of oil palm plantations training and also early detection activities in preventing pests and palm plant diseases on February 26, 2016. The company also conduct planting host plants enemies such as Turnera subulata, Antigonon leptopus and Cassia sp. During 2016, the company has been planting Turnera subulata and Antigonon as much as 2,589.98 Ha also Casia Plant 40.8 Ha. Conclusion: conform

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4.6 Pesticides are used in a way that do not endanger health or the environment.

4.6.1 Justification of all pesticides used shall be demonstrated. The use of selective products that are specific to the target pest, weed or disease and Major which have minimal effect on non-target species shall be used where available.

The Company already has a list of pesticides used based on the identification of each pests and plant diseases. The Company has a list of chemicals used by the WHO classification, i.e: 1. Herbicide  Metaprima 20 WDG (Methyl metsulfuron), classificationU  Starlon 665 EC (Triklopir), classificationII  Prima up 480 AS (Isopropilamina gliphosat), classification III 2. Insecticide  Acephate (Asefat), classification II The Company had a census for each Division and coordinated by the foreman in each division. The Company had census workers that have been appointed as EWS team. The Company already conducted training of IPM Control on May 21, 2016.

Conclusion: conform

4.6.2 Records of pesticides use (including active ingredients used and their LD50, area treated, amount of active ingredients applied per ha and number of Major applications) shall be provided.

The Company has a list of chemicals used by the WHO classification, i.e: a. Herbicide  Metaprima 20 WDG (Methyl metsulfuron), classificationU  Starlon 665 EC (Triklopir), classificationII  Prima up 480 AS (Isopropilamina gliphosat), classification III b. Insecticide  Acephate (Asefat), classification II The Company has a record of chemicals using, for example in 2016, the company has applied Prima Up (isopropyl glyphosate) of 3,496.17 L for 4,352.09 Ha planted, Metaprima (Methyl metsulfuron) of 236 kg. Conclusion: conform

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4.6.3 Any use of pesticides shall be minimised as part of a plan, and in accordance with Integrated Pest Management (IPM) plans. There shall be no prophylactic Major use of pesticides, except in specific situations identified in national Best Practice guidelines. The Company has Guideline Technical Agronomy in which there are SOP Pest and Plant Disease Control such as pest control of Worm Eater Leaf (UPDKS) 041 / PT / VI / 2014, pest control rats 042 / PT / XII / 2014 and pest control beetle horn 045 / PT / VI / 2014. The Company also has early warning system (EWS) through regular pests monitoring every month such as fire caterpillar, bags caterpillar and ganoderma. Conclusion: conform

4.6.4 Pesticides that are categorised as World Health Organisation Class 1A or 1B, or that are listed by the Stockholm or Rotterdam Conventions, and paraquat, Minor are not used, except in specific situations identified in national Best Practice guidelines. The use of such pesticides shall be minimised and eliminated as part of a plan, and shall only be used in exceptional circumstances.

The Company already has document for monitoring toxicity of pesticide on Pesticide Monitoring Units that monitored in January 2016. The Company has conducted spraying training for staff, foremen and employees working as a sprayer. Company has a policy to discontinue the using paraquat which is recorded in an MI (Internal Memo) No. 001/TAP/MIN-EST-HO/II/2013 concerning Paraquat Herbicide Booking Termination dated 22 February 2013. Company has stopped using Paraquat since March 2013. Conclusion: conform

4.6.5 Pesticides shall only be handled, used or applied by persons who have completed the necessary training and shall always be applied in accordance Major with the product label. Appropriate safety and application equipment shall be provided and used. All precautions attached to the products shall be properly observed, applied, and understood by workers (see Criterion 4.7). Pesticide Handling was included in SOP K3L TAP/SOP/120-SHE/0001 Section Handling Agronomy Environment. Pesticides are always applied in accordance with the product label. There are MSDS for pesticides used readily available for easy reference. The company has monitored PPE spray and recorded in the spray monitoring book in each Afdeling. Based on employee’s data, there were 51 people worked with pesticides. The company has had technical guidelines spraying jobs such as technical guidelines spray circle. At site visit to afdeling C block C17, spraying workers have used full PPE during work time. The workers use PPE (glassess, aprons, glooves, boots and masks). The workers have received training handling and application of pesticides. If the PPE is damaged/broken while working, then the worker must report to the foreman for replacement PPE immediately.

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Conclusion: Conform

4.6.6 Storage of all pesticides shall be according to recognised best practices. All pesticide containers shall be properly disposed off and not used for other purposes (see Criterion 5.3). Major Pesticide Handling was included in SOP K3L TAP/SOP/120-SHE/0001 Section Handling Agronomy Environment. Based on observations in the central warehouse, herbicide container waste was stored in a warehouse of hazardous waste. Storage of hazardous and hazardous waste are arranged in TAP / SOP / 120-SHE / 0001 CHAPTER VI.3 Conclusion: conform

4.6.7 Application of pesticides shall be by proven methods that minimise risk and impacts. Minor

The company has had technical guidelines spraying jobs such as technical guidelines spray circle, path and TPH; spot spraying. Implementation pesticides application is described in SOP K3L TAP/SOP/120-SHE/0001 regarding the handling of agrochemicals. The Company has conducted socialization to the sprayer. The socialization was conducted in Cambodgien A on February, 16th 2016. During a visit to the field, spraying workers already apply pesticides according to applicable SOP. Conclusion: conform

4.6.8 Pesticides shall be applied aerially only where there is documented justification. Communities shall be informed of impending aerial pesticide Major applications with all relevant information within reasonable time prior to application.

There are no pesticide applied aerially. Conclusion: N/A

4.6.9 Maintenance of employee and associated smallholder knowledge and skills on pesticide handling shall be demonstrated, including provision of Minor appropriate information materials (see Criterion 4.8). The company has had a training program on site (mill and estate). The training is reported monthly. The training that have been implemented include training for officers spraying, fertilizing, safety for transportation, socialization of use PPE, fire extinguisher Training for farmers has been carried out between the months of October to December 2016 include harvesting, fertilizing, maintenance, weed control, OHS and HCV conservation. One of the internal trainings in December 2016 was the SHE and P2K3 Training. The company conducted report flowchart crash training in October 2016. Conclusion: conform Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 42of 124

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4.6.10 Proper disposal of waste material, according to procedures that are fully understood by workers and managers shall be demonstrated (see Criterion Minor 5.3). The company has set SOP regarding proper disposal of waste material in the Manual of Environment and OHS No. TAP/SOP/220-SHE/0001 Chapter VI Hazardous Waste Management. There are training provided to workers and managers on proper waste disposal. The company has cooperated with PT Primanru Jaya as carrier and collector hazardous waste based on contract No. 142 / MOU-KIS / II / 2016. The company utilize waste water for land application. There was report of waste water utilization during 2016 and had been reported to the relevant agencies on January 11, 2017. Conclusion: conform

4.6.11 Specific annual medical surveillance for pesticide operators, and documented action to treat related health conditions, shall be demonstrated. Major

Based on the workers database on March 2017, there were 51 people worked with pesticides. Pesticide operators get specific medical examination regularly twice a year. Specific medical examination (cholinesterase) 2016 has been carried out on April 27th until May 03, 2016 and October 28rd until November 09, 2016. Report of medical examination PT BBB from February 2016 to January 2017 has been reported to The Labor Service on March 4, 2017. In 2017 the company has arranged schedule for this medical examination on April and October 2017. Implementation of medical examination be conducted by third party that is Laboratory Prodia from Jambi. During audit surveillance II on 13-17 March 2017, team auditor visited afdeling H block G5-G5A, Afdeling D block D12, and Afdeling C block C7. Based on report of medical examination February 2016 until January 2017 and interview with workers in the field, not all of pesticide operators have been tested for cholinesterase twice as required by regulation of Permenaker 3/1986 as in the name of Mrs Nely in afdeling B, and Mr Rasik in afdeling G. This raised as Major Nonconformity No.6. The company clarified that this incident was due to the assistant and the foreman employing non-spray workers on behalf of Nely (Afdeling B) to do the spray work so that the employee had not received a cholinesterase examination. In addition, the Employee on behalf of Rasik is an employee appointed as a spray team one month after the implementation period of medical examination.

Conclusion: Major NCR No.6

4.6.12 No work with pesticides shall be undertaken by pregnant or breast-feeding women. Major

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The company has a policy to not employ pregnant and lactating/breast-feeding women for spraying activity, as stated in IK-12 / B-OIL / 2014 point 4. There are list of female workers handling pesticides. It is advised that company to be more persistent in conducting pregnancy test to all female workers who work with chemicals. The company has a system to identify pregnant and breast feeding women with test pack pregnant every month. Sample for monitoring in February 2017, pregnant test was conducted in 21-28 Februari 2017. There are evidence showing that pregnant and breast-feeding women are not allowed to handle pesticide for example on behalf of Mrs Suseni. Conclusion: Conform

4.7 An occupational health and safety plan is documented, effectively communicated and implemented

4.7.1 A health and safety policy shall be in place. A health and safety plan covering all activities shall be documented and implemented, and its effectiveness Major monitored.

The Company has established integrated policy with Environment, Safety and Occupational Health corporately and signed by the Director of PT. Brahma Binabakti, on February 5th, 2013. It was written in an appropriate language. Workers aware of and understand the policy. The LK3 policy already contained a commitment to improve environmental performance and K3, communicate policies and procedures to all employees and stakeholders, obey laws, identify and assess, and control all the risks and perform continuous improvement to prevent workplace accidents and occupational diseases. The company had target and safety plan in 2017. Strategic objective about safe and healthy working environment SHE index 80 (Green). Conclusion: conform

4.7.2 All operations where health and safety is an issue shall be risk assessed, and procedures and actions shall be documented and implemented to address Major the identified issues. All precautions attached to products shall be properly observed and applied to the workers. The Company has established procedures to conduct assessment of operational risks that could threaten the safety and health, i.e. SOP of Identification and Evaluation of Environmental Aspects and OHS under Section III.1 (TAP / SOP / 120-SHE / 0001). List of OHS and environmental impact identification was established set in 2014. It was a list of environmental and OHS impact assessment from all of OHS activity. Risk assessment have been conducted for all operations where health and safety is in issue such as mill process, warehouse, workshop and clinic. The Company already made procedures (SOPs) and work instructions (WI) related to jobs were at risk to safety and health. Some of them are: potential physical and health hazards and the environment arising from the use of chemicals in the workplace.

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The Company has made safety procedures and precautions, i.e. SOP of chemical hazard communication. The company has monitored and measured work environment in accordance with Permenaker no. 13 in 2011, covering a threshold value factor of physics, chemistry, and biology in each work area. An assesment of work environmentwas conducted on Oct, 7 2017 including noise, vibration, lighting, ISBB (Indeks Suhu Bola Basah), and dust.

The company has conducted special medical examination including spirometry, audiometry, and cholinesterase. Spirometry examination was conducted on April 27, 2016 to 24 workers from various work units. The results of spirometry examination declared that there are 9 people workers get light restriction and another workers was normal. Audiometric examination was conducted on April 27, 2016 against a genset operator. The resut of examination are normal. While cholinesterase examination was conducted twice a year ie on 3 May and 27 April 2017 for the first semester, October 28 and November 9, 2016 for the second semester. The company has equipment requiring licenses for operrator such as Boilers, Skidsteer loaders, Wheel Loaders, Static cranes, and hoisting cranes. Currently, the company already has 5 licensed operators Conclusion : Conform

4.7.3 All workers involved in the operation shall be adequately trained in safe working practices (see Criterion 4.8). Adequate and appropriate protective Major equipment shall be available to all workers at the place of work to cover all potentially hazardous operations, such as pesticide application, machine operations, and land preparation, harvesting and, if it is used, burning.

The company has set a competency matrix for every function. Identification of training has referred to the competency gaps and proposals of each section. Procedure of employee training has included the evaluation of the effectiveness of training. The Company has established a training program related to the environment, safety and health, and RSPO in 2016. The company has been providing personal protective equipment for their employees. Regarding PPE, It is found non-conformity that no specification according to the standard of each PPE applied to each type of work. Based on sampling, it is founds apron in warehouse afdeling H that made very thin and can not be sure workers are protected from contamination of pesticide material. This is raised as Major nonconformity.

The Company clarifies that this nonconformity is due to different PPE specifications at PT BBB. The Company did not yet made work instructions related to the standardization of Personal Protective Equipment at PT BBB in every process. As for the findings of PPE apron because there is no standardization of Personal Protective Equipment as a reference in the purchase of apron.

Conclusion: Major NCR No.3

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4.7.4 The responsible person/persons shall be identified. There shall be records of regular meetings between the responsible person/s and workers. Concerns Major of all parties about health, safety and welfare shall be discussed at these meetings, and any issues raised shall be recorded. The company already set up a committee which will be responsible for Occupational Health and Safety (K3) problems. In March 2017, the company undertook renewal P2K3 team headed by Mr. Parlinggoman and Secretary Ms. Irena Astra. Secretary General AK3 had got training and had received a letter of appointment from the Ministry of Labor per July 25, 2016. The P2K3 is submitted for approval by the Jambi provincial labor offices. Company apply for approval on March 02, 2017. Application is accepted by Manpower Agency Jambi province on March 3, 2017.

P2K3 committee conduct meetings every month. Samples taken by auditor are meeting in January 2017. All progress in January 2017 has been implemented by Company. P2K3 conduct report activities for 3 months. Reporting samples taken are third and fourth quarter 2016. Evidence of Reporting such as acceptance of the report with signature and staple of Jambi Provincy

Conclusion: conform

4.7.5 Accident and emergency procedures shall exist and instructions shall be clearly understood by all workers. Accident procedures shall be available in Minor the appropriate language of the workforce. Assigned operatives trained in First Aid should be present in both field and other operations, and first aid equipment shall be available at worksites. Records of all accidents shall be kept and periodically reviewed.

The Company has established some procedures and work instructions related work accidents and emergencies. Procedures and work instructions applies to all units under PT. BBB. Here are some procedures (SOPs) and work instructions (IK) that has been made: Incident Investigation SOP, SOP First Aid, Emergency Response Plan SOP, SOP Medical Services, and Medical Flow chart. The Procedure available in the appropriate language of the workforce. The Company has P3K officers about 9 people. P3K officer has got training 5 - 7 September 2016 and got the license from the Ministry of Labor. P3K training for supervisors was implemented on July 26, 2016. The training was attended by the entire harvesting foreman, but there is no documented evidence of training followed by a whole foreman, for example foreman of afdeling H. This has been issued as observation no.4. Emergency Plan All units already has first aider who have been trained on September 05-06 2017, which was attended by 9 people and conducted by the Manpower agency..

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First aid (P3K) box is already provided in each division or unit such as class A box that is in accordance with the Permenaker no. 15 in 2008. As for field foreman, they have provided a bag of P3K class A. In addition there are other facilities to support the emergency response preparedness such as 1 ambulance and the facilities and there is a paramedic who accompanied the patient. The Company already has a health clinic, where there are license of DHO Muaro with no. 441/09 / SIKP / DHO / 2016. Company’s doctor have designation as Hyperkes doctors from the Ministry of Labor (Permenaker no. 01 of 1976). Doctors have training hyperkers 17 to 21 October 2016. The doctor has got the designation of manpower agency kep.34 / BINWASK3-PNK3 / KK / II / 2017 per February 27, 2017.

The Company is already calculating the frequency rate (FR) and the severity rate (SR) from the scene of the accident were carried out during 2016. The calculation refers to the provision in Ministerial Regulation No. 03 / MEN / 1998, and already counting lost working days (Lost Time Accident). Calculation results are recorded in Form SR / FR Monthly. The guides and Procedure of filling FR Format – SR was also availabe. Emergency response equipments in estate were sufficient in locations such as a water tank.

The location during visited to see implementation of the second surveillance audit on 13 to 17 March 2017 was section H block G5-G5A, Afdeling D block D12, and Afdeling C block C7.

Conclusion: Observation No.4

4.7.6 All workers shall be provided with medical care, and covered by accident insurance. Minor

The Company has not paid the premiums of health insurance (BPJS kesehatan), retirement insurance and pensions for daily casual worker as seen in their paycheck month of December 2105 and January 2016 Conclusion: Conform

4.7.7 Occupational injuries shall be recorded using Lost Time Accident (LTA) metrics. Minor

During the year 2016 up to now there was no occupational accident in factories as well as in the estate. It is advised to provide the sheet for routine checks on the ambulance readines. The company has been cooperating with the nearest referral hospital (Hospital Ahmad Rifin Muaro Jambi). The Company has calculated the frequency rate (FR) and the severity rate (SR) from the accident during 2016. The calculation refers to the provision in Ministerial Regulation No. 03 / MEN / 1998, and already counting Lost Time Accident. Calculation results are recorded in the sheet of SR / FR Monthly. There was guides Procedure Charging FR Format – SR. The company has calculated occupational injuries using Lost Time Accident (LTA) Metrics based on SK Dirjen Pembinaan Hub. Industri & Pengawasan Ketenagakerjaan NoKep 84/BW/1998. Total Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 47of 124

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of workingtime on January 2017 for all workers are 116,294. Conclusion: Conform

4.8 All staff, workers, smallholders and contractors are appropriately trained.

4.8.1 A formal training programme shall be in place that covers all aspects of the RSPO Principles and Criteria, and that includes regular assessments of Major training needs and documentation of the programme.

The company has a training program on site. The training is reported monthly. The training that have been implemented include training for officers spraying, fertilizing, safety for transportation, socialization of use PPE, fire extinguisher. Training for farmers has been carried out between the months of October to December 2015 include harvesting, fertilizing, maintenance, weed control, OHS and HCV conservation. The Company has set a standard job descriptions and competency on the functions and positions respectively. Standards of competency have been defined in a matrix of competencies in order to get a gap for every function. Identification of training besides referring to the competence gap, the company also received a proposal from each division for the required training. Then the company created a training program. Internal training is set an Internal memo No. MI / HC / II / 2016/007. In the procedure of the provisions on employee training has accommodated assessment of effective training results by the direct supervisor for 6 months (the form is available). To accommodate the training needs for the employees, the company already established training programs related to the environment, K3, ISPO and RSPO in 2016. One internal training in 2016 is SHE training and P2K3, and the flowchart accident report conducted in October 2016. One example of the external training in 2016 is P3K training which was held on 5 to 7 September 2016 from the Ministry of Labor. Related training in estate, it was training about pesticides and P3K on July 6, 2016 carried by the company doctor. Conclusion: conform

4.8.2 Records of training for each employee shall be maintained.

Minor

One of internal training in 2016 are SHE training and P2K3, Flowchart accident reports conducted in October 2016. One example of the external training in 2016 is P3K training which was held on 5 to 7 September 2016 from the Ministry of Labor. Related training in estate, one of them related to pesticides and P3K on July 6, 2016 by the company’s doctor. Company keep documentation of training and the evaluation. Conclusion: conform

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5 ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY

5.1 Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative

impacts and promote the positive ones are made, implemented and monitored, to demonstrate

5.1.1 An environmental impact assessment (EIA) shall be documented.

Major EIA documents (AMDAL & RKL RPL) for palm oil activity covering area of + - 6400 hectares in Subdistrict Pemayung, District Batanghari Jambi province (Kuap Village, Senaning, Lubuk Ruso, Teluk Ketapang, Ture, Pulau Betung, Lopakaur, Selat, Olak Rambahan, Pulau Raman and Kaos).

Legalization of the environmental documents already available on the Jambi Governor Decree No. 37 / Kep.Gub / BPMD-PPT / 2013 dated 4 April 2013 on Environmental Feasibility Palm Oil Partnership covering an area of 6400 hectares by PT Brahma Binabakti in Subdistrict Pemayung, District Batanghari in Jambi Province.

The Head of Regional Investment Board and Integrated Licensing Services Jambi No. 296 / Kep.Ka.BPMD-PPT.4 / X / 2016 is available dated October 10, 2016 about Environmental Permit Activity Palm Oil Partnership Covering an area of + - 6400 hectares in Subdistrict Pemayung, District Batanghari in Jambi Province.

EIA documents covering activities such as:

 Pre-Construction (licensing, socialization, land acquisition, establishment of cooperatives,

 Construction (employment, procurement of heavy equipment and materials, plantation infrastructure development, structuring and development of conservation areas, land preparation, seeding, terracing, procurement and utilization of water, oil palm planting, maintenance of immature plants)

 Operations (employment, generating plant maintenance, harvesting, waste management, CSR)

 Post-Operation (termination of the partnership, the release of labor, land release)

Land acquisition is 40% of location permits on an area of 6400 Ha and reduced residential land and flood areas, about 2360 ha.

Environmental monitoring matrix operation phase:

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 microclimate - temperature changes, humidity, rainy days, rainfall, irradiation, wind direction, wind speed - once a year - agricultural lands

 Air quality - Ambient air and dust (SO2, CO, CO2, NO2, H2S, NH3 and other gases) – once a year - the area of oil palm plantations - PP 41/1999

 Water quality surface - TSS, TDS, NH3, NO3-N, NO2-N, H2S, SO4, P, E. Coli, Coliform, AAS, BOD, COD – once a year - the Batang Hari River, Danau Bangko River - PP 82/2001

 Groundwater quality - TDS, turbidity, odor and taste, CaCO3, Na, Fe, NH3-N, NO3-N, NO2-N, H2S, SO4, E. Coli, Coliform – once a year - about wells population - Permenkes 416/1990

 Soil fertility and soil texture - organic matter content, soil pH, N, P, K, Ca, Mg – once a year - plantations and riparian

 Soil erosion - rain erosivitas index, erodibility, land and length factor - once a year - plantations and riparian

 Water discharge - once a year - plantations and riparian

 Sedimentation - once a year - plantations and riparian

 Diversity of wildlife and natural predators

 Changes plant intruder organism

 employment and business opportunities

 Household income

 Institutional cooperation

 Attitudes and perceptions

 Social conflict

 Transfer of science and technology

 Disease patterns

 Environmental Health

 Behavioral Health

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 Means and health infrastructure

 Changes traffic and road conditions

Conclusion : Conform 5.1.2 Where the identification of impacts requires changes in current practices, in order to mitigate negative effects, a timetable for change shall be developed Minor and implemented within a comprehensive management plan. The management plan shall identify the responsible person/persons.

Revised Recommendation Letter of Matrix RPL DELH Palm Oil Activity and Palm Oil Processing Plant No. 660.4 / 095 / BLH.3 / II / 2016 dated February 23, 2016 from BLH Muaro Jambi to increase the scope of environmental monitoring activities of land application of environmental hygiene and sanitation was available in place. Conclusion: Conform

5.1.3 This plan shall incorporate a monitoring protocol, adaptive to operational changes, which shall be implemented to monitor the effectiveness of the Minor mitigation measures. The plan shall be reviewed as a minimum every two years to reflect the results of monitoring and where there are operational changes that may have positive and negative environmental impacts. There are monitoring reports on RKL RPL from second half of 2016 for POM activities and oil palm plantations in the village of Suko Awin Jaya, District Sekernan, Muaro Jambi. The test results of environmental monitoring carried out include:

- Domestic Wastewater – Labling, Jambi - Upper of Sekawan River - Labling, Jambi - Lower of Sekawan River - Labling, Jambi - Monitoring wells 1, 2, 3 and control wells 1, 2 - Labling, Jambi - Upstream and downstream of Putat River, Mendahara River and Kaos River – Labling, Jambi - The soil quality (soil intact on water bag 0-30, 30-60 cm) - Unilab Perdana - The soil quality (soil intact on water bag and tree 0-30, 30-60 cm) - Labling, Jambi - The soil quality (soil intact in control land 0-30, 30-60 cm) - Labling, Jambi - The soil quality (soil disturbed in water bag 0-20 cm, 20-40, 40-60, 60-80, 80-100, 100-120) - Labling, Jambi - The soil quality (soil disturbed in water bag with trees 0-20 cm, 20-40, 40-60, 60-80, 80-100, 100-120) - Labling, Jambi

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- The soil quality (soil disturbed in the control area of 0-20 cm, 20-40, 40-60, 60-80, 80-100, 100-120) - Labling, Jambi - Air quality - ambient, odor - public housing - Labling, Jambi - Air quality - emissions - central generator Perkins, genset afdeling E Changfa, - Labling, Jambi - Air quality - ambient, the odor - a large office area, housing employees - Labling, Jambi - The air quality emissions - flue boiler No. 1, No. 2, generator No. 1, No. 2 - Labling, Jambi All parameters of the test results for the environmental monitoring are compliance with environmental quality standards.

Conclusion : Conform

5.2 The status of rare, threatened or endangered species and high conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and operations managed to best ensure that they are maintained and/or enhanched

5.2.1 Information shall be collated in a High Conservation Value (HCV) assessment that includes both the planted area itself and relevant wider landscape-level considerations (such as wildlife corridors). Major

Inti (Own estate) HCV assessment for inti conducted on May 2013 with team that lead by Ahmad Faisal Siregar, S.Hut, M.Si. HCV identification result stated that there is only one type of HCV, i.e Anak Mendahara river and Suak Putat river (HCV 4.1) with total wide 30,66 ha. Pemayung HCV assessment for Pemayung estate conducted in April 2016 by a team lead by Dr. Ir. Nyoto Santoso, MS (ALS 14 013 MS) .The scope of the assessment is the Location Permit PT Brahma Binabakti Pemayung estate covering an area of 6,000 ha. The results of the HCV identification mentions there are three types of HCV, ie HCV-1 (Lutung Simpai-Presbytis melalophos and Buaya Senyulong-Tomistoma schlegelii), HCV-4 (riparian of Bangko and Batanghari river), and HCV 6 (Pematang Saung Temple) with a total area of 442, 75 Ha. PT. Brahma Binabakti have a map of new licenses moratorium in which includes information about location of peat area, protected areas / sanctuary / nature protection, and primary forest located around the location of the Pemayung estate. From the map it can be seen that the location of the Pemayung estate does not overlap with the protected areas as mentioned above.

Conclusion: conform

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5.2.2 Where rare, threatened or endangered (RTE) species, or HCVs, are present or are affected by plantation or mill operations, appropriate measures that are Major expected to maintain and/or enhance them shall be implemented through a management plan.

Inti Based on the identification of HCV assessment, in the inti estate of PT. Brahma Binabakti there are no fauna in the category of RTE according to the IUCN Red List. However discovered species protected under PP 7 In 1999, ie Kucing hutan, Elang tikus, burung Raja Udang Meninting, Burung Madu Belukar, Burung Madu Sriganti, and Ular sanca. Pemayung Estate Based on the identification of HCV assessment, in the inti estate of PT. Brahma Binabakti there are no fauna in the category of RTE according to the IUCN Red List. It were Lutung Simpai (Presbytis melalophos) dan Buaya Senyulong (Tomistoma schlegelii). To conserve the fauna of PT. Brahma Binabakti. The Company conducted the efforts : - Carry out socialization to employees and the public to not catch and kill animals in the area of PT. Brahma Binabakti and smallholders. Socialization conduct by installing signboard, conduct direct socialization to the public. - Perform enrichment of trees on the riparian which are often seen presence of animals - To monitor the presence of wildlife populations periodically and report to the Badan Lingkungan Hidup. - Provide sanctions to workers who violate related regulations wildlife. However, the company need to standardize the checklist that is used for monitoring wildlife that includes a checklist of the threat of poaching. This has been issued as observation no.1. Conclusion: Observation No.1

5.2.3 There shall be a programme to regularly educate the workforce about the status of these RTE species, and appropriate disciplinary measures shall be Minor instigated in accordance with company rules and national law if any individual working for the company is found to capture, harm, collect or kill these species.

HCV socialization to KUD has been done as is done in KUD Akso Dano on 21 September 2016 by the Eko Bayu (Assistant CSR). Things that has been delivered in socialization are: - the protection of high conservation value areas - protection of of riparian - prohibition to hunt animals

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- Prevent river to be pollute due to the plantation activity. HCV also been socialized in Pemayung Estate on 20-21 January 2017 by Mrs Irena Ginting . It was delivered was the presence of HCV in the estate area and its efforts to maintain the sustainability. Conclusion: conform

5.2.4 Where a management plan has been created there shall be ongoing

Minor monitoring: The status of HCV and RTE species that are affected by plantation or mill operations shall be documented and reported; Outcomes of monitoring shall be fed back into the management plan.

 There is a master plan for the monitoring and management of HCV area PT. Brahma Binabakti (Own and Pemayung Estate) year period from 2017 to 2021 that were made based on recommendations from the assessment team HCV.  There were reports of monitoring the presence of wildlife in the area HCV PT. Brahma Binabakti (Own and Pemayung) are reported every 6 months to BLHD Muaro Jambi. Sampling of the Minutes of the document submission for HCVA management No: 122 584 / BBB / SKR-SUS-SK / I / 2017 dated January 10, 2017 Conclusion: Conform

5.2.5 Where HCV set-asides with existing rights of local communities have been identified, there shall be evidence of a negotiated agreement that optimally Minor safeguards both the HCVs and these rights.

Based on the own estate and Pemayung estate HCV identificatio, none of the HCV location are intersect with usage rights of local communities so that there is no agreement with the local community Conclusion: conform

5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner

5.3.1 All waste products and sources of pollution shall be identified and documented. Major

Estimates of Fiber Fuel Usage

Month Usage (ton) Feb 2016 1693

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Mar 1461 Apr 1454 Mei 1369 Jun 1448 Jul 1410 Agust 2272 Sept 2982 Okt 3223 Nov 3232 Des 3096 Jan 2017 2903

Shells

Month Usage (ton) Feb 2016 615 Mar 293 Apr 140 Mei 127 Jun 222 Jul 407 Agust 1192 Sept 2560 Okt 2850 Nov 2447 Des 2111 Jan 2017 1384

Boiler Ash

Month Usage (ton) Feb 2016 216 Mar 167 Apr 199 Mei 185 Jun 205 Jul 217 Agust 321 Sept 429 Okt 482 Nov 474 Des 448 Jan 2017 406

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Month Usage (ton) Feb 2016 216 Mar 167 Apr 199 Mei 185 Jun 205 Jul 217 Agust 321 Sept 429 Okt 482 Nov 474 Des 448 Jan 2017 406

Empty Bunch

Month Usage (ton) Feb 2016 3266 Mar 2667 Apr 3065 Mei 2726 Jun 2693 Jul 3079 Agust No data Sept No data Okt No data Nov 6603 Des 7587 Jan 2017 6733

Conclusion: conform

5.3.2 All chemicals and their containers shall be disposed of responsibly.

Major The Decree of the Head of One Stop Integrated Services Muaro Jambi No. 04 / Kep.Ka.BPTSP / III / 2015 dated March 25, 2015 about Hazardous Waste Management Permit for temporary storage activity PT BBB valid for five (5) years with the coordinates location at S 01 20 50.6 and E 103 19 34.1.

Temporary storage of hazardous waste derived from activities of Estate and POM in the Sekernan District and Estate in the Pemayung District. Hazardous waste that allowed to be stored: used oil, used oil filters, used cloth waste, used gloves, hazardous contaminated packaging, used fluorescent lamp, used batteries and medical waste with the time savings that

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allowed for 365 days.

Hazardouse waste storage report for the period of October, November and December 2016 were available and reported to the related institutions.

The cooperation agreement of hazardous waste transport and destruction with PT Kenali Indah Sejahtera No. 53/MOU-KIS/II/2017 dated February 20, 2017 was available in place.

The Ministry of LHK Decree No. 06.7.04 2015 dated April 30, 2015 which is valid for 5 years on Hazardous Waste Management Permit for Hazardous Waste Collection for PT KIS was available in place. There was Recommendation of hazardous waste transportation for PT KIS based on Decree of KemenLHK No. S-279 / PSLB3-VPLB3 / 2015 dated July 30, 2015 for truck No. Pol. BH 9149 AR, BH 8905 XU. Permits are available specifically for dangerous goods transporting from Ministry of Transportation No. SK.3681 / AJ.309 / DJPD / 2016 / 150710881BB-0001. The Decree of the BLH Head of Jambi No. 68 of 2014 concerning the environmental permit collection and transport activities of hazardous material by PT KIS dated October 14, 2014 was available.

Conclusion: conform

5.3.3 A waste management and disposal plan to avoid or reduce pollution shall be documented and implemented. Minor Documentation of Spraying Work Instruction No. IK-12 / BB-SAWIT / 2014 is available. In the Work Instruction, it is determined that after spraying, used PPE is cleaned in the apron loose area and discharged to the waste container for PPE leaching. Waste water PPE that has been collected in the waste container is reused to be applied to the field. The clean the sprayer tools after spraying in the spray washer.

Amount of Implementation of waste water from PPE application as follows:

Period Total Applied (liter)

March 2016 280

April 2016 60

May 2016 500

June 2016 860

July 2016 560

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August 2016 460

September 2016 440

October 2016 680

November 2016 300

December 2016 340

January 2017 900

February 2017 560

Observations at the field have been conducted at afdeling G and rinsehouses which have secondary detention and control of the output water from rinsehouses with a waterproof storage tub. The remaining water of PPE washing in the bath is reused for on-site applications. The Company shall ensure that domestic waste management is governed by the applicable regulations (Regulation 81/2012). At the time of the visit to the office afdeling H, domestic solid waste is still mixed between organic and non organic waste. This has been raised as observation. Conclusion : Observation No.5

5.4 Efficiency of fossil fuel use and the use of renewable energy is optimized

5.4.1 A plan for improving efficiency of the use of fossil fuels and to optimise renewable energy shall be in place and monitored. Minor The company has the Program Plan for Solid and Liquid Waste, Water Conservation Program Plan (Power House, Laboratories) and Emission Control Plan with Maintenance Plan in the year 2017.

The company has recorded the use of solar boiler efficiency for shells and fiber yearly.

Conclusion : Conform

5.5 Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN guidelines or other regional best practice.

5.5.1 There shall be no land preparation by burning, other than in specific situations as identified in the ‘Guidelines for the Implementation of the Major ASEAN Policy on Zero Burning’ 2003, or comparable guidelines in other

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regions.

The company has the principle SOP land clearing without burning (zero burning) contained in Agronomy Procedure revision 1 with the copy number: TAP-PR / AGR / OP-001 / V09-1. Conclusion : Conform

5.5.2 Where fire has been used for preparing land for replanting, there shall be

Minor evidence of prior approval of the controlled burning as specified in ‘Guidelines for the Implementation of the ASEAN Policy on Zero Burning’ 2003, or comparable guidelines in other regions.

The Company does not conduct land clearing without burning. The company opened its land using uprooted system before conducted stacking with the heavy equipment (excavators and bulldozers) as set in SOP No. 009 / PT / II / 2014. Conclusion : Conform

5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented, and monitored.

5.6.1 An assessment of all polluting activities shall be conducted, including gaseous emissions, particulate/soot emissions and effluent (see Criterion 4.4 Major Company has established Greenhouse Gas Emission Reduction procedures (No. TAP/SOP/120-HCV/004) which contains the identification and reduction of greenhouse gases. Company has conducted identification and inventory of GHG emission based on data from 2016. Sources of GHG emission come from land clearing, FFB transportation from estate to mill, fertilizer and pesticide application, genset and POME.

Total emissions in 2016 from estate operational was -9,140.73 tCO2e and total emissions in 2016 from mill was 37,470 tCO2.

Conclusion: conform

5.6.2 Significant pollutant and greenhouse gas (GHG) emissions shall be identified, and plans to reduce or minimize them implemented Major Company has established SOP of GHG Mitigation as stated on internal memo MI- 003/MD/SUST/XI/2012, dated November 12th, 2012 regarding to minimize GHG emission from estate and POM.

Company has conducted identification and inventory of GHG emission based on data from 2016. Sources of GHG emission come from land clearing, FFB transportation from estate to mill,

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fertilizer and pesticide application, genset and POME.

Total emissions in 2016 from estate operational was -9,140.73 tCO2e and total emissions in 2016 from mill was 37,470 tCO2.

Conclusion: conform

5.6.3 A monitoring system shall be in place, with regular reporting on progress for these significant pollutants and emissions from estate and mill operations, Minor using appropriate tools. The liquid waste generated from FFB processing in mill was used as land application through the process in POME. Waste water management report in 4th quarter of 2016 has been submitted to related agency related to the obligations of the permit.

Conclusion: conform

6 RESPONSIBLE CONSIDERATION OF EMPLOYEES AND OF INDIVIDUALS AND COMMUNITIES AFFECTED BY GROWERS AND MILLS

6.1 Aspects of estate and mill management that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement

6.1.1 A social impact assessment (SIA) including records of meetings shall be documented. Major

The Company has reviewed the CSR program conducted every year. Changes to the program based on the reassessment results conducted internally per 2 year period. Conclusion: conform

6.1.2 There shall be evidence that the assessment has been done with theparticipation of affected parties. Major The company keeps a schedule of meetings with the surrounding community on a regular basis as well as with government representatives in the regions. The results of the meeting are notated and compiled into CSR plans for the following year.

Conclusion: conform

6.1.3 Plans for avoidance or mitigation of negative impacts and promotion of thepositive ones, and monitoring of impacts identified, shall be developed Major inconsultation with the affected parties, documented and timetabled, Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 60of 124

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includingresponsibilities for implementation. The Company has conducted a review to mitigate the negative impacts of the company's presence on the surrounding community. So far the demand of the surrounding community is the need for clean water in the dry season and the help of water spraying on the road to avoid dust in the dry season.

Conclusion: Conform

6.1.4 The plans shall be reviewed as a minimum once every two years and updated asnecessary, in those cases where the review has concluded that changes Minor shouldbe made to current practices. There shall be evidence that the review includesthe participation of affected parties.

The company has reviewed the company's CSR plan. The last review was conducted for the period 2015-2016. The company has conducted socialization related to SOP of communication where the company has given explanation related to the mechanism of providing information response to the proportional submitted by the community. Conclusion: conform

6.1.5 Particular attention shall be paid to the impacts of smallholder schemes (wherethe plantation includes such a scheme). Minor The Company has a partnership with plasma 1 and 2 under the Akso Dano Cooperative. The company provides technical training and regular meetings. The cooperative confirms that the company has provided technical guidance even though the cooperation pattern is only in the form of sales of FFB to the company.

Conclusion : conform

6.2 There are open and transparent methods for communication and consultation between growers and/or mills, local communities and other affected or interested parties

6.2.1 Consultation and communication procedures shall be documented.

Major The Company has Stakeholders Complaint Receiving and Resolution SOP (No. 106899/TAP/PRO-CSR-HO/VI/13)

Conclusion: Conform

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6.2.2 A management official responsible for these issues shall be nominated.

Minor Company already has a documented mechanism for land dispute resolution. This is contained in the internal memo (MI) Stakeholder Complaint Handling in the Site (Estate & Mill) No. MI- 005/MD/SUST/X/2012. Also, Stakeholders Complaint Receiving and Resolution SOP (No. 106899/TAP/PRO-CSR-HO/VI/13) has been established which is provided with a flowchart starting from the identification process to the production of minutes, and put into force on 13 June 2013. The scope includes: complaints from stakeholders, complaints on a contract, and land dispute resolution. List of stakeholders already exists in the company area, including: religious leaders, customary leaders, village chiefs, members of plasma, cooperatives, local police, contractors, suppliers, and related agencies complete with names& addresses. The list of Stakeholders made is as per 2013.

Conclusion : Conform

6.2.3 A list of stakeholders, records of all communication, including confirmation of receipt and that efforts are made to ensure understanding by affected Minor parties, and records of actions taken in response to input from stakeholders, shall be maintained.

There were complaints from members of the plasma farmer groups which are recorded in the form: 106181/TAP/PRO-CSR-HO/VI/13, document No. 002, on 5 August 2014. One of the members of Asoka Farmer Group filed a complaint that he wanted to quit from his plasma group i.e. Asoka 1 A and move to the group of Asoka 1 B. The results of interview with the information source show that the problem has been dealt with by the company immediately and the case is resolved properly. The complaint status in the form has been closed and resolved. Conclusion: conform

6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties

6.3.1 The system, open to all affected parties, shall resolve disputes in an effective,timely and appropriate manner, ensuring anonymity of complainants Major andwhistle-blowers, where requested. Companies own SOP reception and handling of complaints (Doc No. 106 899 / TAP / PRO- CSR-HO / XI / 16.

Found discrepancy ie:

1. SOP is not yet set up a mechanism where workers make a complaint or a complaint to

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another supervisor or senior.

2. SOP is not set up on socialization and complaints that are confidential and how to protect against the relevant person.

3. SOP is not set up a complaint to the RSPO Complaint system, if the problem can not be resolved by the two parties.

This has been issued as Major NCR No. 10 Conclusion: Major NCR No.10

6.3.2 Documentation of both the process by which a dispute was resolved and the outcome shall be available. Major

Grievances and complaint submitted was filed in sheet no. TAP / FO / SIA-0003. In general, complaints and complaints submitted through the immediate supervisor, suggestion boxes and unions. Suggestions were submitted via the suggestion box. which was monitored weekly. During 2015 there were no complaints submitted via suggestion box In the certification report, there was an observation raised stated that the union did not record complaints submitted via it. At the ASA I, company has recorded, among other complaints regarding the provision of school buses for children who attend afternoon course (February 2016), concerning sports facilities (May 2015). Complaints records recorded in a complaint form no. TAP / FO / SIA-0003. In general, complaints are submitted through the immediate supervisor, suggestion boxes and unions. For suggestions submitted via the suggestion box is monitored every week. During 2015 there were no complaints submitted via the suggestion box. In the certification report, there was observation that the union did not record complaints. At the time of audit surveillance 1, the company has recorded complaints regarding the provision of school buses for children who attend afternoon course (February 2016) and concerning sports facilities (May 2015) Conclusion: conform

6.4 Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stake holders to express their views through their own representative institutions

6.4.1 A procedure for identifying legal, customary or user rights, and a procedure

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for identifying people entitled to compensation, shall be in place. Major The existence of indigenous peoples and customary land is not found. However the Company already has a documented land dispute resolution mechanisms. This was stated in an internal memo (MI) Redress Stakeholders in the Site (Estate & Mill) No. MI-005 / MD / Sust / X / 2012. In addition, there was an SOP of Acceptance and Settlement of Complaint From Stakeholders (No. 106 899 / TAP / PRO-CSR-HO / VI / 13) which is equipped with a flowchart which starts from the identification process to preparing BA. The scope includes: complaints from the stakeholders, complaints contract, until the settlement of land disputes.

Conclusion: conform

6.4.2 A procedure for calculating and distributing fair compensation (monetary orotherwise) shall be established and implemented, monitored and evaluated Minor in aparticipatory way, and corrective actions taken as a result of this evaluation. Thisprocedure shall take into account: gender differences in the power to claimrights, ownership and access to land; differences of transmigrants and longestablishedcommunities; and differences in ethnic groups’ proof of legal versuscommunal ownership of land. Company already has a documented land dispute resolution mechanism. This was stated in an internal memo (MI) Redress Stakeholders in the Site (Estate & Mill) No. MI-005 / MD / Sust / X / 2012. In addition, there was an SOP of Acceptance and Settlement of Complaint From Stakeholders (No. 106 899 / TAP / PRO-CSR-HO / VI / 13) which is equipped with a flowchart which starts from the identification process to preparing BA. The scope includes: complaints from the stakeholders, complaints contract, until the settlement of land disputes.

Conclusion: Conform

6.4.3 The process and outcome of any negotiated agreements and compensation claims shall be documented, with evidence of the participation of affected Major parties, and made publicly available.

There is documentation of compensation to Mr. Pajrin in Afd E, Block E1 PT. Brahma Binabakti such as Minutes of Measurement Result of Land No. 01 / BBBS / 1/2014, and approval document from Mr. Pajrin as the landlord. The agreement on release of land of Mr. Pajrin been witnesses by Mr. Parjin, the Board of Directors and Chief of Desa Jaya Suko Awin (Hidayah).

Conclusion: conform

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6.5.1 Documentation of pay and conditions shall be available.

Major

The Company has set wages in accordance with the provisions issued by the government of Jambi Province. The minimum wage quantity after divided in 25 working days hence the daily wage amount is Rp. 82.500, - / day. The company has changed the status of casual laborer and raised it to permanent day laborer. Conclusion: conform

6.5.2 Labour laws, union agreements or direct contracts of employment detailing payments and conditions of employment (e.g. working hours, deductions, Major overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc.) shall be available in the languages understood by the workers or explained carefully to them by a management official. The company has kept the previous working agreement of permanent workers that has been working since the PT. Sakernan, and has made new working agreement with them, as an example NIK 21/2121/0808/145, AN. NIK 21/2121/0709/278.

Company has conducted socialization that people who are not tied the employment with the company is not allowed to work at the company's location. Based on interview with housewives, harvesters and supervisors, it is known that the wives of employees still allowed to assist the harvester picks fruit and harvesters also use labor from outside (helper) to collect the fruit during peak harvest. Workers have 40 hours of work per week. If the employee is absent, then the salary will be deducted as much as Rp. 82,500 per day (1 HK). The Company grants leave permits and permits not to enter work without deducting wages as required by Law 13/2003. Conclusion: Conform

6.5.3 Growers and millers shall provide adequate housing, water supplies, medical, educational and welfare amenities to national standards or above, where no Minor such public facilities are available or accessible. At the ASA 1, In 2015 there was no examination of well water and now (2016), company was just delivered samples of well water of Afdelling E, H, B and C on 29 February 2016 to BLHD laboratory of Jambi Province. This has been issued as major nonconformity. The Company has conducted corrective action by doing laboratory test to all drilling wells. Results of clean water quality at location of water uptake from UPTB Regional Environmental Laboratory of Jambi Province:

1. Drilling well 1 - LHU no. 129 / LHU / L2JBI / II / 17 - February 02, 2017

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2. Drilling well 2 - LHU no. 129 / LHU / L2JBI / II / 17 - February 02, 2017

3. Drilling well 3 - LHU no. 277 / LHU / L2JBI / III / 2016 - March 16, 2016

4. Water source afdeling E - LHU no. 211 / LHU / L2JBI / III / 16 - March 1, 2016

5. Well water afdeling H - LHU No. 211 / LHU / L2JBI / III / 16 - March 1, 2016

6. Drilling well afdeling D - LHU no. 1215 / LHU / L2JBI / X / 16 - October 25, 2016

7. Water source afdeling A - LHU no. 1215 / LHU / L2JBI / X / 16 - October 25, 2016

8. Well water afdeling B - LHU No. 204 / LHU / L2JBI / II / 16 - February 29, 2016

9. Well water afdeling C - LHU No. 204 / LHU / L2JBI / II / 16 - February 29, 2016

Testing based on Permenkes 492 / 2010. The Corrective actions have been considered adequate so the finding can be closed. The company provides home facilities with 2 rooms for married workers, transportation assistance such as school bus from site to the nearest school location and daycare. During the visit to daycare in Block H, found 5 children with age between 1.6 months to 5 years. Parents prepare children's food from home for breakfast and lunch, there is no food aid from the company. The company should provide bus transportation for children who attend school outside the location of the estate because children in elementary and junior high school must ride motorcycle from Block H to Sengeti Village every day. The company provides electricity every morning at 4-6 am and 6-11 pm. Workers' wives propose empowerment of mothers by providing training in workshops to supplement family financial input. Conclusion: Conform

6.5.4 Growers and millers shall make demonstrable efforts to monitor and improve workers’ access to adequate, sufficient and affordable food. Minor

The company provides cooperatives that are in afdeling 6 to meet the family's basic needs. The Company provides clean water from both drilled wells and water derived from processing at the Mill.

Conclusion: conform

6.6 The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of

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association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel

6.6.1 A published statement in local languages recognising freedom of association shall be available. Major Freedom to form the unions is set in the period of 2015-2017 PP Preamble paragraph 2, act 1, which state:

"The company respects human rights, recognize and provide opportunities to every employee with the same rights and be given the opportunity to progress in the work and association without RESTRICTIONS and discrimination or because of differences in ethnicity, religion, race and groups (SARA)".

Conclusion: conform

6.6.2 Minutes of meetings with main trade unions or workers representatives shall be documented. Minor

The Company already has two units of labour union organizations for unit of Estate and Mill 1. Labour union Estate – (IPB3) Management consists of: Chairman (Komando Tarigan), Secretary (Edison Efendi), Treasurer (Junaidi Abdulah), and the Representative Afdeling (as many as 13 officials) for the period 2016- 2018. Management set at the date of August 15, 2015 by the Social Service Muaro Jambi No. 560.6 / 351 / Sosnakertrans. Until now union labour has members 358 people. Union Labour PT Brahma Binabakti which address in Suko Awin Jaya village, Sekernan subdistrict, includes unit: Division of Oil Palm Plantation, Plantation Rubber Division, and the Division of MCC. Unions Labour (IPB3) do bipartite meeting at the date of January 16, 2017 with the agenda of the wage scale discuss the Year 2017. These meeting was attended by the entire board and chief representative of each Afdeling. 2. Labour Union Mill All Indonesian Workers Union has been established by the Decree of the Board of Trade Unions Federation of Agricutural and Plantation Area ofJambi, No. 12/PD.F.SPPPSPSI/JB/V/2013 dated May 17th, 2013. A letter explain the decision on the confirmation Substitution Composition and Personnel Management Work Unit Agriculture and Plantation Workers Union of PT. Brahma Binabakti period 2013-2018. Management consist of: Chairperson (Saiful Hambali), Vice Chairman & Secretary (SM. Silalahi), Deputy Secretary (Bonar Manalu), and Tresurer (Mispan). Records of meetings between the company and the union or the unions internal recorded in the function of the Secretariat. There is evidence of meeting records related to the activities of Trade Unions, among others:

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Labour Unions do Bipartir monthly meetings between company with labour mill on Monday, February 8, 2017 At 2:00 p.m. to 15:00 pm Meeting room located at PT BBB. The agenda discussed was about the poor quality of rice originating from the manufacturer and are already resolved rice producers with better quality. Conclusion: conform

6.7 Children are not employed or exploited.

6.7.1 There shall be documentary evidence that minimum age requirements are met. Major

The Company already has a policy that specifies the age requirements of workers with at least a minimum age of 18 years and prohibits child labor from working and helps parents work in the estates. Results of data tracking and interviews of workers, wives and children in residential settlements all confirmed the prohibition of child labor. Sanctions will be given to workers who are known to help their parents work in the estates. Conclusion: conform

6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited

6.8.1 A publicly available equal opportunities policy including identification of relevant/affected groups in the local environment shall be documented. Major

The Company already has a discriminatory policy stipulated in company regulations and SOP recruitment. From company data, workers come from various ethnic tribes such as Java, Sundanese, Malay and Batak. Conclusion: conform

6.8.2 Evidence shall be provided that employees and groups including local communities, women, and migrant workers have not been discriminated Major against.

The results of interviews with workers, they confirm no racial treatment of the company. Conclusion: conform

6.8.3 It shall be demonstrated that recruitment selection, hiring and promotion are based on skills, capabilities, qualities, and medical fitness necessary for the Minor jobs available.

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interviews, there was no difference in the treatment of women and men and the company data showed that the majority of workers were men. Conclusion: conform

6.9 There is no harassment or abuse in the work place, and reproductive rights are protected

6.9.1 A policy to prevent sexual and all other forms of harassment and violence shall be implemented and communicated to all levels of the workforce. Major

The company already has policies relating to sexual harassment (sexual abuse) that have been listed in the company regulations.

During audit, it was found unconformity such as : 1) There was no evidence of training on gender and all workers' committees related to sexual harassment. During an interview for sprayers group which all of they are women, they have no understanding related to the sexual abuse, 2) Not found training materials related to sexual harassment No contacts that found can be reach of and ensure it confidentiality. During the interview, the workers are not aware about this provisions. This has been raised as Major Nonconformity. Conclusion: Major NCR No.11

6.9.2 A policy to protect the reproductive rights of all, especially of women, shallbe implemented and communicated to all levels of the workforce. Major

The company already has a policy related to the prohibition of doing work that is at risk to pregnant and lactating mothers. The group of women workers is prohibited from working in the fertilizing, spraying and warehouse of toxic chemicals.

The company makes regulations on a group of female workers by performing a pregnancy test using a monthly pregnancy test pack conducted at a clinic by a company doctor. Conclusion: conform

6.9.3 A specific grievance mechanism which respects anonymity and protectscomplainants where requested shall be established, implemented, Minor andcommunicated to all levels of the workforce.

The company does not have a confidential complaint mechanism. This is already subject to the findings of criterion 6.9.1

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Conclusion: Conform

6.10 Growers and mills deal fairly and transparently with smallholders and other local businesses.

6.10.1 Current and past prices paid for Fresh Fruit Bunches (FFB) shall be publiclyavailable. Minor The company with Akso Dano Cooperative has an agreement to determine the price of the fruit in accordance with the provisions of the local Disbun. Payment to cooperatives has been running smoothly. Conclusion: conform

6.10.2 Evidence shall be available that growers/millers have explained FFB pricing,and pricing mechanisms for FFB and inputs/services shall be Major documented (wherethese are under the control of the mill or plantation).

The company already has an agreement with the cooperative related to the method of sorting and granting penalties on the fruits derived from the plasma. The penalties were awarded for very raw and raw fruits of 1.5%, very mature fruits of 1.25% and long stalks of 1%. The company is already willing to provide empty, ash and solid bunches to the plasma farmers to be used as fertilizer on plasma land. Conclusion: conform

6.10.3 Evidence shall be available that all parties understand the contractual agreements they enter into, and that contracts are fair, legal and transparent. Minor

The company already has SPK with Ako Dano Cooperative and all FFB suppliers. In each SPK already include terms and terms of payment, sorting method and integrity agreement. Each party has signed and has a copy of the SPK.

Conclusion: Conform

6.10.4 Agreed payments shall be made in a timely manner.

Minor

In the SPK already set payment period. For outside suppliers, the company specifies the payment given 7 days after the invoice is received. For payments to cooperatives, payments are made once a month. Conclusion: conform

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6.11 Growers and millers contribute to local sustainable development wherever appropriate

6.11.1 Contributions to local development that are based on the results of consultation with local communities shall be demonstrated.

Minor

The realization of the local recruiting for mechanic trainee was available in place. The job vacancies are communicated to the parties to the villages around the estate. From 17 candidates selected employees, there were 10 persons approved as employee and three of them were people from Sekernan District.

The composition of the workforce in December 2016 are 1) the Jambi Local Employees - 210 people and 2) Outside Jambi Employees - 528 people.

There are official letters of honorarium payment of elementary school’s tools about four (4) people with a total of 3.28 million per month. There are five (5) employees as employees of the company and was assigned to be a teacher in schools around the estate.

Record of oil purchases for school bus operations belonging to the village of Suko Awin Jaya for the period September 2016 until December 2016, was availabele in place. The financial support was about 3 million per month.

The official letter of repair social facilities and public facilities in the village of Tanjung was available in place. The financial support was about Rp. 8.5 million (February 9, 2016), 36.032 million (May 30, 2016), 7.41 million (November 25, 2016), 6.518 million (May 30, 2016).

Evidence report on the implementation of training to FFB farmers around the estate on October 25, 2016 was available in place. It is followed by 4 people with the material of the fire caterpillar pests.

Conclusion: conform

6.11.2 Where there are scheme smallholders, there shall be evidence that efforts and/or resources have been allocated to improve smallholder productivity. Minor

The Company has made efforts to improve farming practices to the plasma that supplies FFB to mill PT Brahma Binabakti. The undertaking is in the form of Agronomy Training and Integrated

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Pest Management in February 2017.

Conclusion: conform

6.12 No form of forced or trafficked labour are used

6.12.1 There shall be evidence that no forms of forced or trafficked labour are used.

Major

On the list of companies, workers come from the tribes of Java, Sundanese, Malay and Batak. There are no workers coming from outside Indonesia. Conclusion: conform

6.12.2 Where applicable, it shall be demonstrated that no contract substitution has occurred. Minor

Based on interviews with workers, no workers were forced to work in other areas, all worked out according to the agreement and listed in the contract. Conclusion : conform

6.12.3 Where temporary or migrant workers are employed, a special labour policy and procedures shall be established and implemented. Major

There are no migrant workers and / or temporary workers in the company. Conclusion : conform

6.13 Growers and millers respect human rights.

6.13.1 A policy to respect human rights shall be documented and communicatedto all levels of the workforce and operations (see Criteria 1.2 and 2.1). Major

Policies related to human rights are contained in Company Regulations and socialized regularly on every morning muster Conclusion: conform

7 RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS

The Company has a new plantation sites under scheme smallholder management with ratio company and plasma: 40%: 60%.

The company conducted planting in 2011. The company already has a Location Permit No. 66 of 2014 of 6000 Ha and Plantation Business License Number 640 of 2013 for an area of 3500 Ha. Land that has

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been planted was 641.44 ha (227.78 ha for company and 413.66 Ha for plasma). An area of 97.69 hectares which will be cleared in 2016, is located in the Sub district of Pemayung. There are nonconformities in which the company has not done: a. HCV Assesment b. SIA Assesment c. NPP Procedure

During ASA2, the company has not conducted NPP yet, therefore the status of the company become suspended per date March 31, 2017.

During ASA 2, it was found that there is a monitoring report on the implementation of RKL RPL (Environmental Documents) of second semester of 2016 for oil palm plantation activities in Kec. Pemayung, Batanghari District, but not yet include environmental monitoring results such as air quality aspects, surface water quality, ground water quality, and so on.

It can not be ascertained that hazardouse waste produced in Pemayung 1 and 2 estates has been stored and managed in accordance with the requirements of TPS B3 waste. 04 / Kep.Ka.BPTSP / III / 2015. This has raised as major nonconformity as below.

License for Land Acquisition and Utilization Permit. 123495 / BBB / SPM-CSR-SK / II / 17 dated 27 February 2017 for new permit application for 2 (two) well units in Pemayung 1 (S 01 32 24.61 E 103 21.4 16) and Pemayung 2 (S 01 33 32.69 E 103 18 46.59) was available.

A Final Report on the Study of Carbon and GHG Emissions Reserves at PT BBB Area in Batanghari District conducted by the Faculty of Forestry IPB. Based on the results of the report obtained the study as follows:

The land cover of partnership land of PT BBB resulting from image interpretation taken on July 3, 2015 with path 125 row 061. The interpretation result is 8 (eight) land cover that is oil palm (AGRI), regeneration forest, open land, PL, water body, Land clearing, shrubs and housing. PT. Kirana Sekernan has a location permit covering 6,200 ha in Pemayung District, Batang Hari and issued by the Regent of Batang Hari with decision No. 147 of 2008. In 2009 PT. Brahma Binabakti acquired PT. Kirana Sekernan through the Deed of Amendment No. 67 dated December 17, 2009.

Location permits issued by the Head of One Stop Integrated Services Batang Hari No. 08 of 2011 for PT. Brahma Binabakti with an area 6,400 hectares in the same location as the previous location permit on behalf of PT. Kirana Sekernan. The permit is the basis of land clearing by PT. Brahma Binabakti. The results of verification of the recapitulation LC PT. Brahma Binabakti - Pemayung obtained the following information:

- LC = 588.27 ha

- Re-steking = 384.76 ha

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- IMAS = 169.72 ha

At the opening of the land PT. Brahma Binabakti has not identified HCV. Identification of HCV conducted in April 2016. To determine the coefficient of vegetation that have been opened without HCV assessment PT. Brahma Binabakti reviewing Land Use Changes Analysis August 2016. However there are still some things that have not been appropriate, namely:

1. There is a difference of information regarding areal extents that have been opened by the company between documents Land Use Change Analysis and recapitulation LC, re-stacking, and IMAS PT. Brahma Binabakti-Pemayung. Changes in Land Use Analysis area opened by the company from January 1, 2010 is 472.91 ha. While the LC recapitulation, the extent was opened by the company covering an area of 588.27 ha. There are differences of land has been opened covering 115.36 ha which have not been identified in the Land Use Changes Analysis.

2. Based on field trips to the Pemayung Estate and verification of documents LC recapitulation, re-stacking, and IMAS PT. Brahma Binabakti-Pemayung and Batang Hari Regency Decree No. 147 of 2008 on the Permit Area PT. Kirana Sekerna obtained the data and information that the range of 2008 to 2010, there were clearings (LC) in the location permit area. However, information on the amount of land cleared in the span of years was not mentioned in the review Land Use Changes Analysis.

3. PT. Brahma Binabakti not send Disclosure regarding clearings without HCV study to RSPO in accordance with the "Remmediation and Compensation Procedure related to land clearance without prior HCV assessment" page 10, point 3.1 first paragraph.

4. The Company has not been able to show the data that provides information about starting and completion dates clearing (LC) for Pemayung Estate. This has been raised as Major finding NCR No. 8

Conclusion : Major NCR No.8

8 COMMITMENT TO CONTINUOUS IMPROVEMENT IN KEY AREAS OF ACTIVITY

8.1 Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations

8.1.1 The action plan for continual improvement shall be implemented, based on a consideration of the main social and environmental impacts and Major opportunities of the grower/mill, and shall include a range of Indicators covered by these Principles and Criteria. Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 74of 124

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As a minimum, these shall include, but are not necessarily be limited to: • Reduction in use of pesticides(Criterion 4.6); • Environmental impacts (Criteria 4.3, 5.1 and 5.2); • Waste reduction (Criterion 5.3); • Pollution and greenhouse gas (GHG) emissions (Criteria 5.6 and 7.8);  Social impacts (Criterion 6.1); • Optimising the yield of the supply base.

The Company has conducted monitoring to the implementation of RSPO in the form of internal audit, which was conducted on December 2016. Conclusion : conform

C.2.2 RSPO Supply Chain Checklist – Module E : CPO Mill Mass Balance Modul PT. Brahma Binabakti – Brahma Binabakti Mill E.3 Documented procedure E.3.1 The site shall have written procedures and/or work instructions to ensure the implementation of all the elements specified in these requirements. This shall include at minimum the following: a) Complete and up to date procedures covering the implementation of all the elements in these requirements; There was SOP of the tracking of FFB, CPO and PK models Mass Balance TAP / SOP / 120- DCC / 0002 rev. 00. The procedure stipulated that the supply chain system applied by the company was the mass balance. The procedure set that the mill received FFB from own estate, smallholdings, as well as out growers. There was also SOP to calculate and record certified FFB, CPO and PK in the procedure of TAP / SOP / 10-DCC / 003

Conclusion : conform b) The name of the person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements. This person shall be able to demonstrate awareness of the site procedures for the implementation of this standard. There was internal decree no. 827 / HR-HRO / IX / 2014 concerning the appointment of traceability officer dated 01 September 2014. The personnel who was designated as traceability officer was Mill Manager Yopie Risnandar

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Conclusion : conform

E.3.2 The site shall have documented procedures for receiving and processing certified and non- certified FFBs. RSPO SOP of tracking of FFB, CPO and PK models Mass Balance TAP / SOP / 120-DCC / 0002 set that the supply chain system applied by company was mass balance. The procedure set that the mill received FFB from own estate, smallholdings, as well as out growers. The record showed that the : - Total actual certified FFB, CPO, and PK in year 2016 as follows: CPO: 15,655.00 MT, PK : 3,787.00 MT, FFB : 71,469.00 MT. OER : 21.90 and KER 5.30 - Total projected cerified FFB, CPO, and PK in year 2017 as follows: FFB : 81,200.00 , CPO : 17,864.00 MT, PK : 4,303.00 MT OER : 22.00 and KER 5.30

Conclusion : conform E.4 Purchasing and goods in

E.4.1 The site shall verify and document the volumes of certified and non-certified FFBs received.

Procedure SOP RSPO tracking of FFB, CPO and PK models Mass Balance TAP / SOP / 120- DCC / 0002 set that the supply chain system adopted by the Company is the mass balance. On the E model CPO Mill Mass Balance, the plant receives FFB from their own estates, smallholdings, as well as out growers. FFB from the certified estates (own garden) were identified using the manual stamp stated "certified". Conclusion : conform E.4.2 The site shall inform the CB immediately if there is a projected overproduction of certified tonnage. The organization has set up in the procedure of RSPO SOP regarding tracking of FFB, CPO and PK models Mass Balance TAP / SOP / 120-DCC / 0002. The SOP has set up . In case of overproduction (projected overproduction), as set in the point IV.19, the mill manager will inform the Production Control for follow-up to the certification body. So far, there is no reporting to CB regarding projected overproduction of certified Tonnase. Conclusion : conform

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E.5 Record keeping

E.5.1 a) The site shall record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO and PK on a three-monthly basis.

In 2016 the company has recorded the FFB reception both for certified ones and non-certified ones and balanced its sheet every 3 months. Data show that total product from plasma and grower as follows: FFB : 282,758.00 MT CPO : 55,743.00 MT PK : 14,569.00 MT Total product (certified and non certified) as follows FFB : 282,758.00 MT CPO : 55,743.00 MT PK : 14,569.00 MT Conclusion : conform b) All volumes of palm oil and palm kernel oil that are delivered are deducted from the material accounting system according to conversion ratios stated by RSPO.

The company has delivered both from certified and non-certified ones. The data base system has set up the balance of certified and non-certified product accordingly.

Conclusion : conform c) The site can only deliver Mass Balance sales from a positive stock. Positive stock can include product ordered for delivery within three months. However, a site is allowed to sell short.(ie product can be sold before it is in stock.)

Mill is allowed to deliver the product before it is in stock as set in the procedure TAP/SOP/120- DCC/002 point IV.15

Conclusion : conform E.5.2 In cases where a mill outsources activities to an independent (not owned by the same organization) palm kernel crush, the crush still falls under the responsibility of the mill and Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 77of 124

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does not need to be separately certified. The mill has to ensure that the crush is covered through a signed and enforceable agreement. There was neither outsourced process nor activities to the third parties Conclusion : conform

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D.2. Statement by the Certifier Body on Behalf of PT. Sucofindo SBU-SICS

We, the undersigned declare that the information and conclusions included in this report have been prepared in accordance with rule and standard of RSPO, P&C, and that the certification decision has been based upon this information.

Verified and Reviewed by:

Name Nuzwardy Sjahwil

Position SLA / LA / Auditor

Signature

Date June 16, 2017

Approval:

Name Triyan M. Aidilfitri

Position HSE Audit and Certification Department Head

Signature

Date June 16, 2017

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APPENDIX - 1

List of Abbreviation

BBB Brahma Bina Bakti CPO Crude Palm Oil CSR Corporate Social Responsibility DOE Department of Environment EFB Empty Fruit Bunch EIA Environment Impact Assessment FFB Fresh Fruit Bunch FSMS Food Safety Management System GMP Good Manufacturing Practice GPS Global Positioning System HACCP Hazard Analysis and Critical Control Point HCV High Conservation Value HCVF High Conservation ValueForest HGU Hak Guna Usaha IEMA Institute of Environmental Management and Assessment IPM Integrated Pest Management IRCA International Register of Certified Auditor ISCC International Supply Chain Certification MOU Memorandum of Understanding MSDS Material Safety Data Sheet NA Not Applicable NC Non Conformity NCR Non Conformity Register OSH Occupational Safety and Health OSHAS Occupational Safety and Health Assessment Scheme P&C Principle and Criteria PK Palm Kernel PKO Palm Kernel Oil

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POM Palm Oil Mill POME Palm Oil Mill Effluent

PPE Personal Protective Equipment RSPO Roundtable on Sustainable Palm Oil RSPO NI Roundtable on Sustainable Palm Oil National Interpretation

SA8000 Social Accountability 8000 SIA Social Impact Assessment SIO Surat Izin Operator

SOP Standard Operating Procedure UKL Upaya Pengelolaan Lingkungan UPL Upaya Pemantauan Lingkungan

WWTP Waste Water Treatment Plant WHO World Health Organization

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APPENDIX - 2

MAP

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APPENDIX- 3

Status of Non-Conformities

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Previous Non Conformity Register ANNUAL SURVEILLANCE ASSESMENT (ASA) I

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No Claus Root Cause Corrective Action & Audit Team . Category e Std Auditor Description Investigation* Evidence* Review (1) (2) (3) (4) (5) (6) (7) (8) (9) 1 Minor 2.1.3 RS The Company has not Open PO HDY evaluate the compliance with laws and regulations regularly. By sampling, it was found that compliance with Ministry of Public Work and Public Housing RegulationNo. 37 / PRT / M / 2015 on approval of use of water and / or water sources, dated July 24, 2015 has not been evaluated. 2 Observation 2.1.1 RS HDY The Company has permit Open PO retrieval of the river water that is not valid. Currently the company is working on the arrangements of license renewal decision of Sekawan river based on the receipt document dated March 11, 2015 from Sumatra BWS VI. 3 Major 4.4.2 RS HDY The Company has not made There has been no Perform maintenance Observation, PO an effort for maintaining the activity to maintain efforts by planting trees the water source of Sekawan the water of implementatio River where the water was Sekawan River n will be seen used by the company on the next ASA

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4 Major 4.4.1 RS HDY The company could not show There was no water Arranging permit from the Observation, PO the surface water uptage uptakes permit relevant agencies. The the realization permits for the entire estate. license for the use process that has been will be seen in By sampling, there was no of groundwater in done were SPPL permit, the next ASA SIPA permit for groundwater Afdeling conducting further water wells in section H. test for licensing at the Department of Energy and Mineral Resources 5 Major 4.4.2 RS TSS/NR Based on the results of field There are There is a Letter of Observation, PO visit to Afdeling E field in the recommendations Approval from the the realization D6 block, and the provisions for HCV assessor will be seen in Environment Agency set forth in the company's which determined the next ASA internal memo PT TAP the riparian zone 20 Muaro Jambi No: 660.4 / number MI-004 / MD / Sust / m wide left and 36 / BLH.3 / 2016 dated 4 XI / 2012 dated 12 November right of the river, April 2016 on the approval 2012 regarding conservation of the results identification of riparian of river and water Reservoir Water of HCV conducted by team of Faculty of Company based on Forestry, Bogor recommendations from the Agricultural Institute HCV assessor has set a riparian zone as wide as 20- meters from the river side or the same distance with space between 2 palm trunks as HCV4. This is not in accordance with applicable laws and regulations (including PP No. 38 of 2012 on the River)

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6 Observation 4.4.1 RS HDY Laboratory analysis result of OPEN PO the well for clean watershould be appropriatewith Permenkes no. 416 and equipped with testing of E Coli’s parameters

7 Minor 5.3.3 RS HDY In section H of pesticide Open PO management in rinse house on its use has not been found contaimen secondary and effluent control at rinse housetanks 8 Observation 4.7.3 RS HDY Fire training is necessary to Open PO ensure the realization of level A, B C and P3K also its implementation in accordance with the scheduling agenda in 2016. The company data indicated that there was no training in 2015.

9 Minor 5.1.2 RS HDY The documentation DELH Open PO showed that all activities of the mill has not been identified aspects such as the impact of land application activities and sanitation activities that produce domestic waste.

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10 minor 5.1.3 RS HDY Monitoring of domestic waste Open PO in accordance with LH Decree no. 112 of 2003 has not been made by the company 11 observation 5.3.3 RS HDY The Company should ensure Open PO the implementation and documentation of the entire program and long-term targets in order to reduce domestic solid waste, reduction of emissions and a reduction in water use. The efforts should be monitored and measured. 12 Observation 4.7.5 RS HDY Emergency response Open PO equipment such as water tanks in the estate section H was not adequate and standby at the site.

13 Minor 4.7.6 RS NS Not all labor followthe social the company already set Observation,. PO security programs as the regulation stating that The provided in Regulation 84 in all employees will be implementatio 2013. Casual workers only registered to full packet of n of regulation receive protection in the form BPJS ketenagakerjaan will be of work accident insurance and BPJS kesehatan checked (JKK) anddeath benefit during the next (JKM) and does not include ASA Retirement Security (JHT), pensions and health Insurance (data in the form of casual worker paycheck ID No. 21/2121/0812/759, and 21/2121/0812/757 month of December 2105 and January Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 92of 124

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2016

14 Observation 6.5.2 RS NS The company should make Open PO a new worker agreement for permanent workers who have been working since the PT. Sakernan, From the results of the documents, there was long-time permanent worker that have not been renewed its agreement as an example NIK21/2121/0808/145 and NIK 21/2121/0709/278. 15 observation 6.3.1 RS NS The grievance procedure Open PO SOP (AP-MPR / HRD-GM / 063-0113-0, 01/18/2013) should add article / item concerning custody secret of the complainant identity. 16 MINOR 6.5.3 RS NS Clean water supply for labor Open PO can not be ensured the continuance. In interviews with the occupants in Afdelling A, theiy were lack of water during the dry season and have to buy water for cooking / drinking. For the need of a shower / wash , they were using the river near the housing and can not be ascertained that the water is the category of clean water.

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17 Observation 4.6.12 RS NS Open It is advised that company to PO be more persistent in conducting pregnancy test to all female workers who work with chemicals. Female worker in afdelling A, G, H have not been examined for pregnancy.

18 Observation 6.9.3 RS NS The instruction of complaints Open PO of sexual harassment IK-01 / BBB / 2014., There should be an instruction to maintain the anonymity of the reporter or reported from unauthorized parties.

19 Observation 4.6.5 RS NS Mandor / Foreman should Open PO carry a spare of easily damaged PPE such as rubber gloves. From the field observations, there were sprayers that use rubber gloves that had been torn and the workers did not replace it because the worker did not bring the spare. 20 Observation 4.6.5 RS NS Company should re-evaluate Open PO the use of anti-pollution fabric mask for the sprayers because in fabric mask is not mentioned that it can filter out chemicals C3H8NO5P / Phosphomethyl glicin) (IPA) and metsulfuron

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methyl. That materials is used for weed control. 21 Observation 6.5.2 RS NS Company should conduct Open PO socialization that people who are not tied the employment with the company is not allowed to work at the company's location. Based on interview with housewives, harvesters and supervisors, it is known that the wives of employees still allowed to assist the harvester picks fruit and harvesters also use labor from outside (helper) to collect the fruit during peak harvest. 22 Minor 1.1.1 RS TSS Related with the provision of Open PO information to stakeholders, the relevant SOP and assurance in the field has not been stated: a. Frequency stakeholders updated list. b. There has been no appointment letter from the company to the personnel responsible for providing information c. There has been no determination of the type / level of information provided to stakeholders. d. There has been no SOP governing the dissemination / sharing of such information. Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 95of 124

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23 Observation 1.1.2 RS TSS Related the provision of a Open PO response to the stakeholders, it should be : a. Ensuring the officer who gave the answer, because in the SOP item 4.3.3 there are some responsiblepersonnelsbut from Job description it is only Assistant CSR. b. There was still confused of information over when providing information. SOP point 4.5 stated that the administration approved the information provided within a maximum of 5 working days. For the types of information that are not approved will be given an answer within a maximum of two working days. In points 4.8.4 declare any incoming mail requires a response no later than 14 working days. 24 observation 1.2.1 RS TSS a. list of information that can Open PO be accessed in public (SOP No. 106 181 / TAP / PRO- CSR-HO / VI / 13) has not complete yet as required under RSPO standards such as the concession, Complaints & Grivience Procedure, Negotiation Procedure, Continues improvement, Public Summary of the Certification

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audit report, and Human Rights Policy. b. Company do not have a website so the stakeholders can not have access to information related to PT. BBB. c. The Company has not disseminate type of relevantinformation and can be accessed by all relevant partiesto the stakeholders. 25 Observation 2.3.2 RS TSS Related the compensation Open PO against Mr. Pajrin located in section E Block E1.3, a. Preferably in the procedure include the requirement to map-making that comes with the title, legend, scale and coordinate points. b. In the official-making letter of measurement has not completed the signature of the village officials. c. At the time the process of compensation, official letter was not available. 26 observation 2.3.3 RS TSS There was a relinquishment Open PO of rights letter between the company and claim maker; Mr. Pajrin dated February 11, 2014. The relinquishment of rights agreement was made in 3 pieces. The legality should be determined because there are no initials

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on each of the sheet and also signatures of the witnesses made in a separate page. 27 Minor 6.10.3 RS TSS The Company already has Open PO SPK with KUD Akso Dano (SPK No. 116 509 / BBB / PER-SK / V / 15) and the Supplier of FFB. Under these agreements, it has not contain penalties of agreement / cutting for trash and not appropriate pieces (for KUD). For supplier, it should be no garbage, but in its implementation there are cutting of pieces of 30-80 kg. it is also not in accordance with related IK (Acceptance Smallholder Fruit and Outside Fruit). At the ascertainment in the field, both the chairman and the secretary KUD were not understand the mechanisms in cutting FFB accordance to provision of Disbun and FFB supplier does not understand the cutting mechanism of garbage.

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28 observation 6.1.3 RS TSS Related to the SIA, should be Open PO ascertained: a. Ensuring relevant agenda has been realized or not in the plan and the realization of CSR b. Make sure their efforts to improve the welfare of communities (Community Development)

29 Major 7 RS TSS The Company has a new The area is a Corrective actions have To be followed PO plantation sites under partnership of land. been made up with NPP scheme smallholder In the areas of the 1. Assessment of HCV process management with ratio partnership, there is 2. Assessment SIA company and plasma: 40%: a sharing are for 60%. main estate and For FFB that were not plasma estate that included in the criteria of The company conducted supporting certified FFB (Non CSPO) planting in 2011. The assessment for company already has a certification has not Location Permit No. 66 of been conducted 2014 of 6000 Ha and Plantation Business License Number 640 of 2013 for an area of 3500 Ha. Land that has been planted was 641.44 ha (227.78 ha for company and 413.66 Ha for plasma). An area of 97.69 hectares which will be cleared in 2016, is located in the Sub district of Pemayung. There are nonconformities in which the company has not done:

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a. HCV Assesment b. SIA Assesment c. NPP Procedure

30 Observation 2.2.5 RS TSS Map making land in conflict Open PO should be equipped with coordinate data and a scale of 1: 10000, a) At the completion of compensation to Mr. Fajrin, the map does not include the scale and point coordinates. b. In SOP No. 002 / TAP / PRO-CSP-HO / IV / 10 field measurements need to be equipped with a scale. 31 minor Partial RS TSS Timebound: Open certific PO a. Company does not have a ation detailed plan related to the proposed Certification Plasma 1, 2 and 3. b. When assurance to the KUD, Information was obtained that socialization / training is merely the best practices and has not related to the preparatory activities of Plasma Certification.

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32 Major 2.1.1 RS RB There are areas of the There were no Create reports about Observation PO plantation located in the information description of the map to forest area with an area of regarding planting the area of 785 Ha 785 hectares (No. SK.727 / area in the location Menhut-II / 2012). of Forest Area At the time of construction PT Bina Bakti Brahma refered to the Spatial Plan map of Jambi province in 1993 which states that an area of 785 hectares located in the area of other uses. By 2012 there is a decision of the Minister of Forestry of Indonesia No.SK 727 / Menhut-II / 2012 regarding zonation changes from non-forest to forest areas which resulted the area of PT BBB covering 785 Ha changed from other uses area into forest area. In order to follow up the changes of the status of the area, the company has filed the changes of forest land designation under Regulation No.104 Year 2015 on February 25, 2016 Date with the letter number: 118 875 / BBB / SKR-RO1 / II / 16.

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33 Major 2.2.1 RS RB There are areas of plasma There is a plasma Arranging activity plan Observation PO that has been planted which within the regarding plasma land located in the concession. It concession area of within the concession is uncertain where the land PT BBB is, and this is because the The company will apply company has not been able for an extension of the to show a map of the location concession area and of the land (Block) and its exclude plasma inside the range. concession, considering the period of validity of the concession PT BBB will expire in 2020. The Company will apply for the extension of the concession in the year 2017 and in the proposal, the company will reduce the area of the concession with the plasma one. This was will be confirmed on the next audit. 34 Observation 2.2.1 RS RB The Company has not had Open PO the concession for an area of 6000 hectares (planted area = 641.44 ha and 97.69 ha LC) located in District Pemayung. Currently The location permit(No. 66 of 2014)and the Business License Plantation- Cultivation (Number 640 of 2013) is on process.

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35 Major 6.5.3 RS NS In 2015 there was no The Company has The Company has been Observation, (previous PO examination of well water not conducted conducted sampling and the audit was and now (2016), company testing of water the result of test in consistency minor) was just delivered samples of samples in Afdeling Afdeling B,C,E and H will be well water of Afdelling E, H, in accordance with were available. checked in the B and C on 29 February Permenkes 416 next ASA 2016 to BLHD laboratory of 1990, and its Well water of afdelling E Jambi Province results were not and H has beent available for examined on 01 March Afdeling B, C, E 2016 and H

Non Conformity Register ANNUAL SURVEILLANCE ASSESMENT (ASA) II

Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) 1 Obs 5.2.2 2 SSW PT Brahma Binabakti Next Checklist is - Make a checklist Open, the have engaged in Surveillance available but not that covers the implementation activities for the Audit yet covered the types of wildlife will be checked preservation of wildlife types of hunting hunting activities in the next ASA that exists in plantation activities - Provide training to area. However, PIC who will companies need to conduct monitoring standardize the checklist that is used for monitoring wildlife that includes a checklist on the presence or

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) absence of poaching activity.

2 Obs 4.4.1 2 PS The Company has Next There is no Coordinate with the Open, the provide groundwater Surveillance available water “Pekerjaan Umum” implementation intake permits and water Audit source office regarding the will be checked quality test results for identification in location of water in the next ASA seven (7) groundwater Afdeling A and sources in Afdeling A sources identified in the E, so no permit and E. mill and estates, but for has been made water resources in yet section E and A are still in the stage of identification to obtaining a permit. 3 Major 4.7.3 2 AGT Associated with the 17 May 2017 The Company Create work The corrective provision of PPE it is already has instructions related to action has found a discrepancy that technical Standardization of complied and the specification on guidelines for Personal Protective adequate so every PPE applicable to Personal Equipment at PT that the finding any type of work not Protective BBB match with the standard. Equipment but can be closed By sampling it is found not yet equipped Make purchases of that apron in section H with the apron in accordance warehouse made from standard of with the thin material and can not each type of specifications on be sure the workers are PPE work instructions protected from pesticide Standardization contamination. Personal Protective The existence of Equipment at PT Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 104of 124

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) thin apron BBB because there is no Attach a completed standardization HIRA of Personal Protective Evidence: Equipment as 1. Work Instruction reference in related to Apron purchase standardization of Personal Protective HIRA has not Equipment PT BBB been fully 2. Purchase apron as identified per predefined standardization 3. HIRA Estate dan Mill 4 Obs 4.7.5 2 AGT The company has Next First aid training Company conducted Open, already conducted first Surveillance has not been first aid training for Effectiveness of aid training to estate Audit conducted by estate foreman by implementation foreman on July 26, Officers who trainers who have will be seen in 2016, but the trainer dr. have attended attended the first the next audit Zukri Nasution has not training on stage of occupational been proven have occupational safety and health followed training for first safety and (K3) training in aid in the workplace. health (K3) in workplace accidents the field of first aid in workplace accidents

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) 5 Obs 5.3.3 2 AGT Next The company the company Open, Surveillance has provided conducted corective Effectiveness of Audit organic and action i.e the implementation Companies must ensure organic waste company provide will be seen in the domestic waste bins but the organic and the next audit management is manage amount is not inorganic waste bins. by regulations (PP enough The company 81/2012). During a visit conducted to the office section H, Employees still socialization the domestic solid waste is do not have a separation of organic still mixed between high awareness and inorganic waste organic and non- in waste sorting to employees on a organic. regularly. 6 Major 4.6.11 2 AGT Based on sprayers list 17 May 2017 the assistant • Made a policy to The corrective and a list of employees and the foreman avoid employing action has which checked in 2016, employing non- employees (non complied and there are sprayers that spray workers spray) for spraying adequate so have not received the on behalf of • The company that the finding examination Nely (Afdeling conducted special (cholinerasterase) such B) to do the medical examination can be closed as: Nely-Afdeling B, and spray work so (Cholinestrase) for Rasik-Afdeling G. that the two spray officers on employee had behalf of Mrs Nely not received a Afdeling B and Mr cholinesterase Rasik Afdeling G examination. Made requirement the Employee for operator pesticide (Mr Rasik) is an

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) employee • The Company has appointed as a established Internal spray team one Memo No. 02 / month after the SUST-BBB / IV / implementation 2017. The memo period of describes that the medical assistant avoid examination. employing employees (non Requirements to spray) for spraying be a spray team and the medical if workers from examination another function (cholinesterase) are not yet requirement for the available spray worker twice a year. Internal Memo is set since April 13, 2017. • Internal memo has been socialized to every assistant on May 03, 2017 which is proven with attendance list. • The company has conducted medical examination (cholinesterase) to employees behalf of

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) Mrs Neli and Mr Rasik.

requirement and structure operators pesticide

7 Major 2.2 2 RB There are planted area 17 May 2017 Based on the Coordinate with the The corrective for 785 ha which planted letter of Bupati Ministry of Living and action has in Forest Area (based Batang Hari No. Forestry related to complied and on Forestry Minister 525.26 / 4146 / the process of adequate so Decree No. 727/2012). Date dated application for that the finding This is not in September 1, changes in the accordance with 1994, Jo. designated forest can be closed Government Regulation Batang Hari area. Any progress Number 104 of 2015 Bupati's letter document activity will no. 525.26 / be reported 5946 / Pemda dated November Evidence: 5, 1994 stated Progress of forest that it was given release of PT BBB to planting an oil area palm plantation covering an area of ± 25,000 Ha in the Area of Dry Cultivation, but in 2012 issued Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 108of 124

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) Minister of Forestry Decree No. RI. SK, 727 / Menhut-II / 2012 concerning the change of allotment of forest area to non forest area and change of function of forest area so that there is plant area which is in forest location. The request for a change of status has been made in accordance with Government Regulation No. 104 of 2015, but it has not been completed yet because it will take a long time to change the status of the

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) region..

8 Major 7 2 SSW PT. Brahma Binabakti 17 May 2017 There is a 1) Revised the LUCA The corrective , PS, already conduct studies discrepancy in report by including action has TSS of Land Use Change the results of the land clearing complied and Analysis (LUCA) in LUCA study: conducted in the adequate so August 2016. However 1)Differences in period 2008 to 2010 that the finding there are still some data on the size so that the difference things that have not of land in LUCA of planting area of can be closed been conform, ie: documents with 115.36 ha has been 1) From the verification data on clearing included in the scope of Land Use Change of land owned of LUCA Analysis report and by the company, recapitulation of land because the 2) Data on land clearing and re-stacking area of land clearing conducted in PT. Brahma Binabakti- clearing the period 2008-2010 Pemayung, can be conducted has been traced by known that there is under the the Consultant using different information control of PT Landsat Image and about area that has Kirana incorporated into the been cleared. In LUCA Sekernan has LUCA Report PT report stated the not been BBB Pemayung company cleared area calculated for 472,91 ha since 1 3) The Company has Januari 2010. But in the compiled a timeplan recapitulation of land 2) The inclusion of compliance with clearing, the company of information the LUCA Review cleared 588,27 ha. regarding land and submitted it to

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) There is 115,36 ha of clearing by PT the RSPO cleared area that not yet Kirana Compensation been identified in LUCA Sekernan which Panel, as the NPP report. process on the is the 2) Based on site visit, embedded land is verification on responsibility of not required recapitulation of land PT Brahma (evidence of clearing/re-stacking PT. Binabakti for communication with Brahma Binabakti- land clearing the RSPO Pemayung and period from compensation panel Batanghari Regent 2008-2010 has been sent via Decision No. 147 of email) because LUCA 2008 on the Location Permit PT. Kirana study was 4) The Company has Sekernan obtained data originally based sent a liability and information that in on land clearing disclosure template the range of year 2008 map owned by to the RSPO to 2010, there were PT BBB Compensation Panel clearings (LC) in the Pemayung as a condition in area of the location fulfilling the LUCA permit. However, 3) PT. Brahma review process information on the amount of land cleared Binabakti has no 5) The Company has in that range of years plans for new submitted was not mentioned in plantings in the documentary the Land Use Changes Pemayung area evidence of the Analysis report. commencement date 3) PT. Binabakti Brahma 4) PT Brahma and completion of is a member of TAP Binabakti has the land clearing to

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) Group, where TAP has not sent a CB been a member of the disclosure of RSPO in 2007, under land clearing 6) Conduct the provisions of NPP environmental testing conducted item 1.3 mentioned that in accordance with land clearing after 1 Jan without HCV RKL-RPL documents 2010 is subjected to assessment to in BBB Pemayung; NPP requirement. RSPO because 4) PT Brahma Binabakti the company 7) Identify and had not submit assumes PT manage groundwater Disclosure regarding BBB Pemayung utilization permit and clearings without HCV make time plan of is a plasma Assessmen to RSPO permit arrangement (RaCP related to LC plantation of PT without prior HCV Brahma 8) Conducting LB3 Assessment item 3.3.1) Binabakti, thus TPS permission and 5) The Company not entering GA13- time plan for able to show the data 6g RSPO completion of LB3 that provides information Resolution on TPS permit about starting and "Resolution to completion dates of clearing (LC) for Review and Pemayung estate Amendment Of 6) There are monitoring The Updated reports on RKL RPL NPP Process As second half of 2016 for Applied To the activities of oil palm Smallholders ", plantations in the Pemayung district, so that the entire NPP Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 112of 124

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) Batang regency. process However, the report including the does not already include LUCA is environmental postponed first monitoring results as aspects of air quality, until there is surface water quality, further review of groundwater quality, and the resolution so on. 7) Groundwater intake 5) The at the site of Pemayung Company has 1 and 2 are still in the not been able to process of obtaining a provide data license from relevant starting and agencies. 8) It is uncertain completion of hazardous waste land clearing for produced in the the Pemayung Pemayung estate 1 and estate because 2 are stored and the managed in accordance documentation / with the requirements in the permit No. 04/ archives of land Kep.Ka.BPTSP / III / clearing have 2015 held. been stored and archived in Jakarta

6) No

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) identification of parameters for the overall environmental test and PT BBB-Pemayung environmental monitoring time plan has been carried out

7) There is no identification of groundwater retrieval at the location of Pemayung 1st and 2nd and there is no time plan for obtaining permits from the relevant agencies

8) Available

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) TPS B3 waste in Pemayung, but the permit has not been obtained and not yet available time plan completion permit TPS LB3

9 Obs 1.1.1 2 TSS In SOP / SUPP / II / Next There is no Revise the SOP by Open, the 2017/001 dated Surveillance provision entering the implementation February 20, 2017 Audit concerning the complaint will be checked Revision 02 related complaint mechanism clause in the next ASA Reception and Handling submitted by via e-mail of Requests for stakeholders to Information have set the companies sent frequency of updating via company the list of stakeholders email conducted every 6 months. Companies should make provisions related to complaints submitted by stakeholders emailed to the company.

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) 10 Major 6.2.1 2 TSS Companies own SOP 17 May 2017 1. SOP 1. Revise the The corrective reception and handling Employee mechanism of action has of complaints (Doc No. Complaints direct complaint complied and 106 899 / TAP / PRO- No. SOP / submission to adequate so CSR-HO / XI / 16). SUPP / XT / superiors and / or that the finding Found discrepancy ie: 1) SOP is not yet set up 2016/009 is other supervisors can be closed a mechanism where available. In workers make a the SOP has 2. Setting up complaint or a complaint been set important phone to another supervisor or complaint numbers disite for senior. submission the delivery of 2) SOP is not set on can be done information socialization and through 3 complaints that are mechanisms: 3. Adding clauses confidential and how to 1. Through related to the protect against the relevant person. direct superior delivery 3) SOP is not set up a 2. Through mechanism to the complaint to the RSPO the Feedback RSPO complaint Complaint system, if the Box system problem can not be 3. Through resolved by the two Bipartit. Evidence: parties. However SOP 1. SOP Employee has not been Complaints referring to No.SOP / SUPP / what is xt / 2016/009 required in the general 2. Memo Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 116of 124

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) checklist of P No.124027lTAP / & C RSPO Ml N-HRD-HO / IV 2013 which is / 1 7 the delivery of complaint 3. Work Instruction directly to Mechanisms another Submission of superior or external and above it. internal stakeholder 2. SOP complaints to the Employee RSPO Complain Complaints Panel No.SOP / SUPP / xt / 4. Minutes of 2016/009 has complaints related covered about to the complaint maintaining panel complaints confidentiality panel RSPO and protection against complainants. This SOP is revised from the previous SOP NO. TAP- PR / HRD-GN Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 117of 124

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) / 063-0113-0. Date 18 January 2013. which in Audit surveillance PT. The first BBB has become an audit finding on 29 February - 04 March 2016. In the new SOP the point of maintaining confidentiality has been included in the Flow of the Submission of Stage 1 Employee Complaints at Point 6 3. SOP Employee Complaints are Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 118of 124

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) available No.SOP / SUPP / xt / 2016/009. In the SOP has been set complaint submission can be done through 3 mechanisms: 1. Through direct superior 2. Through the Feedback Box 3. Through LKS Bipartit However SOP has not been referring to what is required in the general checklist of P & C RSPO 2013 which is about Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 119of 124

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Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) complaint to RSPO Complaint System when problems can not be solved by both parties

11 Major 6.9.1 2 TSS The company already 17 May 2017 1.PT. Brahma 1. Making memos The corrective has policies relating to Binabakti does related to the action has sexual harassment not yet have implementation of complied and (sexual abuse) that have policies and socialization of adequate so been listed in the programs to sexual harassment, that the finding company regulations. Found discrepancy ie: engage in to be more can be closed 1) There was no socialization scheduled in the evidence of training on related to implementation of gender and all workers' sexual its socialization. committees related to harassment to Conduct sexual harassment. workers. socialization on During an interview for gender committees sprayers group which all 2. The Gender and all workers of they are women, they Committee related to sexual have no understanding Executive has harassment as well related to the sexual abuse, no knowledge / as make 2) Not found training understanding socialization materials related to on aspects of programs Sexual sexual harassment sexual harassment to

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SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) 3) No contacts that harassment. employees found can be reach of Gender and ensure it committees do 2. a. Provide confidentiality. During not yet have training materials the interview, the competencies and training workers are not aware about this provisions related to exercises from aspects of competent parties sexual to gender harassment. committee No adequate members training material on 2. b. Make sexual requirements as a harassment is member of the available and gender committee there is no and conduct a requirement of Trainer of Training ompetency as (TOT) to workers a member of from previous the gender Gender Committee committee members who have been trained 3. For procedural / 3. Provide personal technical contacts that can guidelines for be contacted reporting Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 121of 124

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) gender Evidence: inequality has 1. Memo been made socialization of available, but it sexual harassment does not and requirement to include be member of personal gender committee contacts that 2. Minutes of can be training contacted in implementation to the guidelines. gender committees and workers from the police and the Manpower Office 3. News of training events to all employees in each afdeling 4. Training materials from police related to sexual harassment 5. Training materials from Disnaker 6. Personal contacts that can Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 122of 124

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Non Conformity / Observation Report

No Category Clause Std Audi Description Deadline Root Cause Corrective Action & Audit Team tor of Investigation Evidence and Date* Review and Corrective and Date* Date Action (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) be contacted in the event of sexual harassment

12 Major - RSPO SSW PT Brahma Binabakti 17 May 2017 Time bound Review and revise The corrective Certfic has made time-bound already plasma timebound of action has ation plan for certification of available but not PT Brahma Binabakti complied and Syste plasma from the year covering the adequate so m: 2018 to 2020. In this whole plasma Evidence: that the finding Timeb year (2017) it already (made partially) 1. Time line plasma ound contained the certification can be closed plan socialization of the RSPO certification process to plasma 1. However, time-bound plan should be ensured completed with a period of 3 years after the PT. Brahma Binabakti certified so that a time- bound plan that has been made insufficient.

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SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

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