Roundtable on Sustainable Palm Oil Public Summary Report Report no. : RSPO P&C – 17062 – ASA-03 Anual Surveillance Assessment ASA-03 against the: INA-NI, NG-NI, Generic, 2018 RSPO Principles & Criteria MY-NI, 2019 GH-NI, RSPO Supply Chain Certification Standard, 2014 (Rev. June 2017) Group Certification of FFB Production 2016 Rev.2018 RSPO Principle and Criteria Certification System, June 2017 RSPO Supply Chain Certification System, June 2017

Audit can be partially performed: Remote Audit On-site Audit

PT Rea Kaltim Plantation – Cakra Palm Oil Mill and Supply Based

Kelekat village, Muai village, Kembang Janggut village Kembang Janggut sub-district, Kutai Kartanegara district East Province, Indonesia

Date of assessment : Remote Audit : 29 – 30 Apr 2020 On-site Audit : 12 – 16 Aug 2020

Report prepared by: Muhammad Fundy C Kurniawan (RSPO Lead Auditor)

Certification decision by: I Nyoman Susila (Director of TUV Rheinland Indonesia)

Certification Body: PT TUV Rheinland Indonesia Menara Karya, 10th Floor Jl. H.R. Rasuna Said Block X-5 Kav.1-2 12950, Indonesia Tel: +62 21 57944579 Fax: +62 21 57944575 www.tuv.com/id

Accreditatation number: ASI-ACC-061 & 18 June 2019

TABLE OF CONTENTS

1.0 Scope of 3rd Surveillance Assessment ...... 3 2.0. Description of Certification Unit ...... 3 2.1 Location ...... 3 2.2. Maps ...... 5 2.3. Supply Base Composition ...... 9 2.4 Area of Plantation (Total, Planted and Mature) ...... 10 2.5 Dates of Plantings and Replanting Cycles ...... 10 2.6 Volume of CPO and PK recommended for Certification ...... 11 2.7 Data & Information relate of employment & social issues ...... 11 2.8 Organisational Information / Contact Person ...... 13 3.0 Assessment process ...... 13 3.1 Qualifications of Lead Assessor and Assessment Team ...... 13 3.2. Assessment Agenda ...... 14 3.3 Assessment Methodology ...... 16 4.0 Stakeholder Consultation and Stakeholders Contacted ...... 17 5.0 Compliance to Other RSPO Requirement ...... 17 5.1. Time Bound Plan for Other Management Units ...... 17 5.2. Compliance to Rules for Partial Certification ...... 18 5.3. Compliance to other RSPO Procedure ...... 22 5.4. Compliance to RSPO Guidance on GHG calculation ...... 22 5.5 Plan for certification of associated smallholders ...... 24 6.0 ASSESSMENT FINDINGS ...... 25 6.1 Summary of Findings ...... 25 6.2. Compliance to RSPO Role of Market Communications & Claims: ...... 74 6.3. Compliance to Book & Claim requirement: ...... 74 7.0 Status of Previously Identified Non-Conformities ...... 75 8.0 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions ...... 79 9.0 Noteworthy Positive Components and Potential for Improvement ...... 85 10.0 Issues Raised by Stakeholders and Findings Pertaining to Issues ...... 85 11.0 Certification Decision ...... 85 11.1 Recommendation for Certification ...... 85 11.2 Date of Certificate Issued and Scope of Certificate ...... 85 11.3 Date of Next Surveillance Visit ...... 85 12.0 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client ...... 86 APPENDICES ...... 87 Appendix 1: Details of Certificate ...... 87 Appendix 2: 3rd Surveillance Audit Plan – Remote audit...... 89 Appendix 3: List of Abbreviations ...... 97 Appendix 4: Other Achievement s and Certificatio Helds ...... 98 Appendix 5: List of Stakeholders Interviewed and Contacted ...... 99 Appendix 6: Organization’s land History and information about all previous users of the land ...... 101

RSPO 3rd Surveillance Assessment Report PT Rea Kaltim Plantation – Cakra Palm Oil Mill Kutai Kartanegara district, Province, Indonesia

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1.0 Scope of 3rd Surveillance Assessment

The 3rd surveillance assessment was carried out on one (1) and four (4) under Cakra palm oil mill owned by PT Rea Kaltim Plantation. The operations of the palm oil mill(s) and its supply base of FFB were assessed against the RSPO Principle and Criteria, Generic 2018, selected Supply Chain Model according to company’s FFB supply base is MB.

Name of Certification Body PT TUV Rheinland Indonesia

Name of Lead Auditor Muhammad Fundy C Kurniawan

Name of Auditor(s) Panggading Nainggolan, Budi Setyawan, Doni

RSPO Membership 1-0045-07-000-00

Name of RSPO Member R.E.A. Holdings Plc

Name of Certification Unit PT Rea Kaltim Plantation – Cakra Palm Oil Mill

RSPO plamtrace number RSPO_1000000512 Kelekat village, Muai village, Kembang Janggut village, Kembang Janggut sub- Address district, Kutai Kartanegara district, East Kalimantan province, Indonesia Mill Capacity 60 ton FFB per hours

Supply Chain Model MB

Assessment Type 3rd Surveillance – Remote audit

Audit date 29 – 30 Apr 2020

Certificate number 824 502 17062

Certificate end date (dd/mm/yy) 30-07-2022

Start date License (dd/mm/yy) 15-08-2019

End date License (dd/mm/yy) 30-10-2020

Standard used RSPO P&C Generic 2018

2.0. Description of Certification Unit

2.1 Location

Table 1: GPS locations for all estates and mills included in 3rd surveillance assessment

GPS locations Name of mill/estate Location Latitude (N) Longitude (E) Cakra oil mill Kelekat Village, Kembang Janggut Sub District, Kutai Kar- 0 15’ 55.2” N 116 15’ 59.1” E tanegara District, East Kaliman- tan Province Lestari estate Long Beleh Modang Village, Kembang Janggut Sub District, 0 23’ 17.8” N 116 10’ 55.1” E Kutai Kartanegara District, East Kalimantan Province

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Cakra estate Muai Village, Kembang Janggut Sub District, Kutai Kartanegara 0 17’ 07.6” N 116 15’ 55.1” E District, East Kalimantan Prov- ince Damai estate Kelekat Village, Kembang Janggut Sub District, Kutai Kar- 0 14’ 57.6” N 116 10’ 36.2” E tanegara District, East Kaliman- tan Province Berkat estate Kembang Janggut Village, Kem- bang Janggut Sub District, Kutai 0 13’ 11.3” N 116 22’ 22.1” E Kartanegara District, East Kali- mantan Province Kedaron Estate* Senyiur Village, Muara Ancalong Sub District, Kutai Timur District, 0° 27' 48.85'' N 116° 24' 20.27'' E East Kalimantan Province Note: *) Kedaron estate is under PT Kutai Mitra Sejati was extension scope, and already audit on 28 Oct – 1 Nov 2019.

Is there scheme/associate smallholder on table above? Yes No If yes, please filling in table below:

Name of scheme/associate SH Number of SH members Plasma Etam Bersatu Not applicable

Note: This scheme smallholder is fully operated by company. Due to the RSPO Compensation Panel process is yet finish, the Plasma Etam Bersatu yet able to including on certification process.

MS-0034725-17.1 Rev.0 2.2. Maps

Figure 1. Location map of Rea Kaltim Plantation

RSPO 3rd Surveillance Assessment Report PT Rea Kaltim Plantation – Cakra Palm Oil Mill Kutai Kartanegara district, East Kalimantan Province, Indonesia

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Lestari estate

Cakra estate

Berkat estate

Damai estate

Figure 2. Estate distribution of Cakra Oil Mill supply based

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Figure 3. Location map of Rea Kaltim Plantation – Kutai Mitra Sejahtera

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Figure 4. Block design map of Rea Kaltim Plantation – Kutai Mitra Sejahtera – Kedaron Estate

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2.3. Supply Base Composition

Table 2: FFB Supply Base Composition for Cakra Oil Mill within Audit Date Period 27 Apr 2019 – 11 Aug 2020 (update until on-site audit)

Processed Conversion rates (%) Production Supply based FFB % OER KER CPO PK Certified sourced under supply based Lestari 1302.66 0.25 0.242 0.0495 315.24 64.48 Cakra 112232.28 21.83 0.242 0.0495 27160.21 5555.49 Berkat 152644.07 29.70 0.242 0.0495 36939.86 7555.88 Damai 60404.02 11.75 0.242 0.0495 14617.77 2989.99 KMS Kedaron 117512.46 22.86 0.242 0.0495 28438.01 5816.86 Total certified receipt 444095.49 86.41 0.242 0.0495 107471.10 21982.72 Non-certified sourced Rea Kaltim Plantation – Estae Tepian 317.13 0.06 0.242 0.0495 76.74 15.69 Satria 0 0 0.242 0.0495 0 0 CDM/Long Mesangat 2002.04 0.38 0.242 0.0495 484.49 99.10 Sub total 2319.17 0.45 0.242 0.0495 561.23 114.79 Scheme smallholder Etam Bersatu 6316.86 1.22 0.242 0.0495 1528.68 312.68 Kahad Bersatu 46.88 0.00 0.242 0.0495 11.34 2.32 Senyiur Indah 3912.72 0.76 0.242 0.0495 946.87 193.67 Terusan Jaya 28.46 0.00 0.242 0.0495 6.88 1.40 Sub total 10304.92 2.00 0.242 0.0495 2493.79 510.09 Independent Smallholder Penoon 60.68 0.01 0.242 0.0495 14.68 3.00 Modang Bersatu 174.1 0.03 0.242 0.0495 42.13 8.61 Belayan Sejahtera 51246.5 9.97 0.242 0.0495 12401.65 2536.70 Tunas Harapan 53.34 0.01 0.242 0.0495 12.90 2.64 Karya Makmur 55.42 0.01 0.242 0.0495 13.41 2.74 Gotong Royong 275.66 0.05 0.242 0.0495 66.70 13.64 Bintang Surya 6.35 0.00 0.242 0.0495 1.53 0.31 Binawana Sejahtera 69.16 0.01 0.242 0.0495 16.73 3.42 Etam Sejahtera 3685.34 0.71 0.242 0.0495 891.85 182.42 Rimba Jaya Mulia Sawit 3.29 0.00 0.242 0.0495 0.79 0.16 Dwi Karya 171.24 0.03 0.242 0.0495 41.44 8.47 Sub total 55801.08 10.85 0.242 0.0495 13503.86 2762.15 Outgrowers Era Cipta Mandiri 991.14 0.19 0.242 0.0495 239.85 49.06 Pinang Berjaya 100.72 0.01 0.242 0.0495 24.37 4.98 Sumber Makmur PDN 186.65 0.03 0.242 0.0495 45.16 9.23 Sentekan Permai 47.45 0.00 0.242 0.0495 11.48 2.34 PT Sawit Sukses Sejahtera 40.59 0.00 0.242 0.0495 9.82 2.00 Sub total 1366.55 0.26 0.242 0.0495 330.70 67.64 Sub total Non-Certified 69791.72 13.58 0.242 0.0495 16889.59 3454.69 Total Certified + Non-Certified 513887.21 113.31 0.242 0.0495 124360.70 25437.41

Table 3: CPO and PK production and sold period within audit date period and projection for 2020 Amount (mt) Remarks FFB CPO PK From Estate 443856.00 From Independent Small- Certified 0 holder (ISH) 106525.44 22192.80 tonnage From Scheme or Assosiate (previous license) 0 SH/Outgrower Volume Extension - 1040.60 - Actual Production within audit date period 27 Apr 2019 – 11 Aug 2020 Actual OER and KER (%) n.a 24.20 4.95 Total production 513887.21 124360.70 25437.41 RSPO 3rd Surveillance Assessment Report PT Rea Kaltim Plantation – Cakra Palm Oil Mill Kutai Kartanegara district, East Kalimantan Province, Indonesia

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Amount (mt) Remarks FFB CPO PK Total non-certified production 69791.72 16889.59 3454.69 Total certified production 444095/49 107471.10 21982.73 Previous Current Previous Current Actual Sold until audit date period 27 Apr 2019 – 11 Aug 2020 License*) License**) License*) License**) Actual sold volume under RSPO scheme n.a 3948.00 8246.38 0 7654.86 Actual sold volume under ISCC scheme n.a n.a 49505.60 n.a n.a Actual sold conventional n.a n.a 30545.70 47889.74 9795.43 Credits sold (audit date period) n.a 0 0 5951.00 0 New Projected Production for 2020 (remote) OER and KER projection (%) n.a 24.00% 5.00% Total production 419915 103179.60 21495.75 Total non-certified production 81735.00 19616.40 4086.75 From Estate 348180.00 83563.20 17409.00 Total From Independent Small- certified produc- 0 0 0 holder (ISH) tion (RSPO From Scheme or Assosiate Scheme) 0 0 0 SH/Outgrower Note: *) previous license 31-10-2018 to 14-08-2019; **) current license 15-08-2019 to 31-10-2020

2.4 Area of Plantation (Total, Planted and Mature)

Table 4: Oil Palm Planted Area Summary, FFB Production and Average yield/ha for Rea Kaltim Plantation – Cakra Oil Mill within audit period 27 Apr 2019 – 11 Aug 2020 (update until remote audit)

Oil Palm Immature FFB Mature Total area Planted (Non- Production* Average Estate name (Production) (ha) area production) (tonnes) yield/ ha area (ha) (ha) area (ha) Berkat 7471.70 4490.00 4490.00 0 152644.07 33.99 Cakra 5491.00 4676.00 4676.00 0 112232.28 24.00 Lestari *) 4520.80 3818.80 3818.80 0 1302.66 0.34 Damai 3517.00 2129.00 2129.00 0 60404.02 28.37 Kedaron **) 7321.15 3831.44 3789.31 42.13 117512.46 31.02 Total 21000.50 18945.24 18903.11 42.13 444095.49 23.49 Note: *) FFB produced from Lestari estate delivered to Perdana oil mill; **) Kedaron estate is under PT Kutai Mitra Sejati was extension scope, and already audit on 28 Oct – 1 Nov 2019.

2.5 Dates of Plantings and Replanting Cycles

The company follows a replanting cycle of 25 years. Information on the dates of plantings are as per the table be- low:

Table 5: Age and year of plantings of company estate supplying to Cakra Oil Mill within audit date period 27 Apr 2019 – 11 Aug 2020 (update until remote audit)

Year of Oil palm planted per estate (ha) plantings Berkat Cakra Lestari Damai Kedaron 1994 0 0 193.40 0 0 1995 0 0 874.40 0 0 1996 0 0 1016.00 0 0 1997 0 0 1097.00 0 0 1998 0 612.00 638.00 0 0 2000 0 874.00 0 0 0 2004 0 3190.00 0 0 0 2005 0 0 0 1290.00 0 2006 2347.00 0 0 716.00 0 2007 2143.00 0 0 0 0 2011 0 0 0 123.00 0 2012 0 0 0 0 1903.40 2013 0 0 0 0 1806.44

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Year of Oil palm planted per estate (ha) plantings Berkat Cakra Lestari Damai Kedaron 2014 0 0 0 0 79.47 2017 0 0 0 0 42.13 Total 4490.00 4676.00 3818.80 2129.00 3831.44 Note: Total area 89.1 ha consist of Cakra 16.42 ha and Berkat 72.68 ha, are excluded from certification scope area due to planting outside the land use rights (HGU).

Table 6: Land use data for Rea Kaltim Plantation – Cakra Oil Mill within audit period 27 Apr 2019 – 28 Apr 2020

Land used for other purposes (ha) HCV/ Oil Palm Local Gov- Total Potential ernment of- Estate name Planted Cleared area (ha) HCV areas* fice, Road, Nursery Other Land Area (ha) Area (ha) Housing, Drain, POM Berkat 7471.70 4490.00 2702.09 279.61 0 0 0 Cakra 5491.00 4676.00 609.17 180.83 0 0 0 Lestari 4520.80 3818.80 228.97 473.03 0 0 0 Damai 3517.00 2129.00 912.15 475.85 0 0 0 Kedaron 7321.15 3831.44 2027.39 409.32 0 0 229.10 Total 28321.65 18945.24 6479.77 1818.64 0 0 229.10 Note: *) HCV areas inside of estate/plantation areas;

Table 7: Planned and actual oil palm replanting activities for Rea Kaltim Plantation – Cakra Oil Mill

Total planned Total planned replanting area for each estate (ha) Actual Year replanting Replanted area (ha) Lestari Cakra Berkat Damai Kedaron (ha) 2022 416.00 0.00 0.00 0.00 0.00 0.00 0.00 2023 1,956.00 978.00 0.00 0.00 0.00 0.00 0.00 2024 2,044.00 1,022.00 0.00 0.00 0.00 0.00 0.00 2025 2,000.00 1,000.00 0.00 0.00 0.00 0.00 0.00 2026 1,250.00 818,00 0.00 0.00 0.00 0.00 0.00

2.6 Volume of CPO and PK recommended for Certification

The approximate tonnages certified, based projection of production for company owned estates for year 2020 are as follows:

Information 2020 (remote) MT 2021 (onsite) MT FFB : 348180.00 491670 CPO : 83563.20 118000.80 PK : 17409.00 24583.50 OER : 24.00% 24.00% KER : 5.00% 5.00%

2.7 Data & Information relate of employment & social issues

Table 8: Distribution of manpower (person) each estates/divisions & POM within audit date period 27 Apr 2019 until 11 Aug 2020 (update until remote audit)

MRP* DRP* PKWT/Contract* PHL/Casual* Contractor* Total Estate/Mill M** F** M** F** M** F** M** F** M** F** (person) Lestari estate 65 11 353 102 46 18 - - - - 595

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MRP* DRP* PKWT/Contract* PHL/Casual* Contractor* Total Estate/Mill M** F** M** F** M** F** M** F** M** F** (person) Cakra estate 94 16 404 129 59 23 - - - - 725 Berkat estate 100 13 458 156 51 29 - - 31 - 838 Damai estate 56 5 185 52 38 15 - - - - 351 Kedaron estate 83 7 380 126 55 59 - - - - 710 Cakra POM 112 6 51 6 5 2 - - 29 - 211 Total 510 58 1831 571 254 146 - - 69 - 3430 Note: *) MRP: Monthly Rated Permanent; DRP: Daily Rated Permanent; Contract worker or temporary worker or PKWT (Perjanjian Kerja Waktu Tertentu = Certain Period Employement Contract) especially in Indonesia; Casual worker or daily worker or PHL (Pekerja Harian Lepas = daily/casual worker) especially in Indonesia; contractor/outsourcing worker (from employment outsourcing or employment service provider/agency for Indonesia) or worker from other/thrid parties who do work that belong to the employer ; **) M = Male & F = Female.

Table 9: Detail of manpower per department within period Apr 2019 – Mar 2020

Month Estate/POM Total Apr May Jun Jul Aug Sep Oct Nov Dec Jan Fen Mar Lestari Estate Harvesting 3446 288 301 286 307 292 295 289 285 288 280 259 276 Spraying 435 44 44 41 40 36 34 31 32 38 34 32 29 Manuring 510 60 60 56 52 40 39 38 37 30 35 34 29 Other 4307 438 437 410 387 348 345 333 328 334 330 324 293 Total 8698 830 842 793 786 716 713 691 682 690 679 649 627 Cakra Estate Harvesting 3891 368 358 360 353 343 330 309 303 291 289 294 293 Spraying 696 47 60 68 68 67 67 65 59 49 49 49 43 Manuring 573 43 48 57 57 55 55 54 51 41 41 43 29 Other 32 32 32 32 32 32 32 32 32 32 32 32 32 Total 5192 490 498 510 510 497 484 460 445 413 411 418 397 Damai Estate Harvesting 1779 159 154 154 161 157 153 141 140 140 136 144 140 Spraying 454 37 37 47 35 32 43 33 37 37 38 39 39 Manuring 560 49 64 53 70 69 37 37 37 37 36 31 40 Other 2102 238 220 184 152 165 137 176 176 168 171 158 157 Total 4895 438 475 438 418 423 370 387 390 382 381 372 376 Berkat Estate Harvesting 3737 320 323 329 321 316 311 306 304 303 300 300 304 Spraying 527 55 54 50 44 41 39 41 39 39 36 36 53 Manuring 725 75 73 80 64 58 51 55 56 56 54 52 51 Other 4868 441 44 433 422 411 398 386 392 387 388 389 386 Total 9857 891 894 892 851 826 799 788 791 785 778 768 794 Kedaron Estate Harvesting 3512 317 316 303 290 285 297 289 286 284 281 285 279 Spraying 1377 151 149 144 141 137 139 89 89 88 87 82 81 Manuring 1172 128 126 124 121 118 120 76 77 75 72 68 67 Other 3384 263 264 257 243 233 229 328 322 317 315 308 305 Total 9445 860 855 828 795 773 785 782 774 764 755 743 732 Cakra POM Processing 660 57 57 57 57 57 57 54 54 55 55 50 50 Security 54 4 4 4 4 4 4 4 4 4 4 7 7 Workshop 311 25 25 25 25 25 25 27 27 26 26 28 27 Other 1167 98 98 97 95 97 97 97 96 98 98 98 98 Total 2192 184 184 813 181 183 183 182 181 183 183 183 182

Table 10: Detail of contractor activity within period Apr 2019 – Mar 2020

Sexual Total No. Company Name Scope of activities M F (person) Berkat Estate 1 Yohanes Suwaji 4 4 FFB transport 2 Jon Wels Makmur Rajagukguk 2 2 FFB transport 3 Tasrif 3 3 FFB transport 4 PT Herita Anugrah Sukses Mandiri 4 4 FFB transport 5 M. Ardiansyah 1 1 FFB transport 6 Andarias Palajukan 1 1 FFB transport 7 PT Sapta Jaya Lintas 11 11 FFB transport

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8 Ranti Diana 5 5 FFB transport Total 31 31 Kedaron estate 9 KSU Senyiur Indah 63 63 FFB transport 10 Zainal Arifin 6 6 FFB transport 11 PT. Sejahtera Arta Jaya 30 30 FFB transport 12 Goni 6 6 FFB transport 13 Wartono 9 9 FFB transport 14 PT. Agung Belayan Makmur 12 12 FFB transport 15 Abd. Rahman 12 12 FFB transport 16 Umar Abdul Kadir 6 10 16 EFB application Total 144 10 154 Cakra POM 17 PT. Besteel Lestarindo 10 10 Boiler maintainance 18 PT. BCI 19 19 POM consultant Total 29 29

2.8 Organisational Information / Contact Person

Contacts details of the company are as follows:

Company Name PT Rea Kaltim Plantation – Cakra Palm Oil Mill and supply based

RSPO Membership no. 1-0045-07-000-00 on behalf R.E.A Holdings, Plc since date on 10 November 2007

Address Head office : Palm Tower 9th floor, Balikpapan Super Block Plantation & POM : Kembang Janggut sub-district, Kutai Kartanegara district, East Kalimantan Province, Indonesia Contact Person Peter David Bayliss

Telephone & Fax +628115849471

Email [email protected]

3.0 Assessment process

3.1 Qualifications of Lead Assessor and Assessment Team

Name Position Qualifications / Experience

Muhamad Fundy Lead Auditor Education: Master Degree in Natural Reseource and Environmental Man- C Kurniawan agement, Bogor Agriculture University Trainings attended: Environmental Impact Assessment (EIA), Ecological Risk Assessment (ERA), Internal Quality Audit Training for Quality Man- agement System, IRQA-QMS ISO 9001:2000, IRQA-EMS 14001, High Conservation Value (HCV), RSPO Lead Auditor Course, ISPO Auditor Course, SCCS Auditor, ISCC plantation audit, ISCC Auditor and LVV Audi- tor for GHG Management ISO 14063 and 14064, ISO SNI 37001, ISCC GHG Auditor and CORSIA Verificator (Carbon Offsetting Reduction Scheme for Internal National Aviation). Working experience: Experienced in Environmental Impact Assessment (EIA Assessment), Environmental Health Safety Senior Officer (EHS- Senior Officer) in Wilmar International Plantation, Internal Auditor for Wil- mar International Plantation, and Auditor for Rountable on Sustainable Palm Oil (RSPO), Indonesian Sustainable Palm Oil (ISPO), International Sustainability Carbon Certification (ISCC), ISCC GHG Verificator, GHG Verifier for ISO 14063 and CORSIA verificator in PT TUV Rheinland Indo- nesia since June 2012 – present.

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Panggading Auditor Education: Bachelor of Social, Social Science and Political Institute, Ja- Nainggolan karta. Trainings attended: RSPO in house training by Mutu Agung Lestari, ISPO training by ISPO Comission and QHSE Awareness QHSE (management system review dan integrated management system concept ISO 9001, 14001, OHSAS, RSPO P&C and RSPO SCCS Training. Working experience: National Comission for Children Protection (Komisi Nasional Perlindungan Anak) – Public Relation and Staff Education pro- gram – Common Ground Indonesia, Reporter on “Global Informasi Bermu- tu”, Producer on Netwave Multimedia, Producer on “Satu Visi Perkasa Produksi”, Project Supervisor on Surya Solusi Informasi and Auditor for ISPO & RSPO Budi Setyawan Auditor Education: Bachelors Degree in Forestry - Bogor Agriculture University, Indonesia. Trainings attended: Indonesian Sustainable Palm Oil (ISPO) Lead Audi- tor Course by ISPO Commision; Quality Management System (QMS) Au- ditor/Lead Auditor by IRCA (ISO 9001:2008); Environmental Management Systems Auditor/Lead Auditor Conversion Training by IRCA (ISO 14001:2004); Calculation of Green House Gas at Palm Oil Plantation by ISPO Commision; SVLK Auditor Training by Ministry of Forestry; CoC Au- ditor by LEI; PUB and Café training by ministry of tourism; HCV Training; RSPO P&C and SCCS Training; AWS Training, CORSIA Training. Work experience: Staff Planning & Analysis in PT Bakti Sukses Mandiri; PT Mutu Hijau Indonesia as Technical Manager (2015-2016); HR and fi- nance manager (2014-2015); Auditor in PT Mutu Hijau Indonesia (2010- 2016), and Auditor in PT TUV Rheinland Indonesia (2016-present). Doni Auditor Education: Master in Rural Sociology, Graduate School of Bogor Agricul- tural University completed in 2005. Trainings Attended: GIS Training, Auditor Training of Indonesian Sus- tainable Palm Oil (ISPO), Training of Participatory Mapping, Training of Doc-ument Preparation HCV and SIA, Auditor Training of Sustainable Pro- duction Forest Management (SFM), RSPO P&C Training, Training and Up- Grading of SFM, Training of Mentoring technique for the Rural Farmers, Conflict Resolution Training and Journalism Training. Work Experience: Frequently conducted certification audits of RSPO and ISPO for Palm plantation, the certification audit of SFM (Sustainable Pro- duction Forest Management) for HPH and HTI, worked as a consultant for the National Development Planning Agency, Min-istry of Environment and Forestry, Indonesian People Bank (BRI), Ministry of Rural Development (KPDT) and the Ministry of Public Works, Director General of Cipta Karya, JICA and UN-HABITAT and UNDP, HCVF document drafting team for the company of HTI, HPH and constituent team for documents of HCV / SIA for oil palm plantations. Since March 2016 till now, work at PT. TUV Rhein- land Indonesia.

3.2. Assessment Agenda

Location/ Main Date Main activities sites Remote audit 29 Apr 2020 Remote audit Opening meeting Document verification: previous NCR verification, information and public avail- ability, communication and consultation, commitment to ethical conduct, legal compliance to applicable law and regulations, standard operating procedure, system for managing human resources, human rights, complaints and griev- ances, third party contractors, SEIA and plans, training, pay and working con- ditions, freedom of associations, no child labour, no harassement, no forced or trafficked labour, third party FFB legal sourced, long term plan and economic availability, continuous improvement and reporting, supply chain, occupational health and safety plan, peat, pollution and GHG’s, HCV and HCS, effective in- tegrated pest management, pesticide use, waste management, soil health fer-

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tility, soil conservation (erosion and degradation), soil survey and topographic information, water quality and quantity and energy used. 30 Apr 2020 Remote audit Document verification: previous NCR verification, information and public avail- ability, communication and consultation, commitment to ethical conduct, legal compliance to applicable law and regulations, standard operating procedure, system for managing human resources, human rights, complaints and griev- ances, third party contractors, SEIA and plans, training, pay and working con- ditions, freedom of associations, no child labour, no harassement, no forced or trafficked labour, third party FFB legal sourced, long term plan and economic availability, continuous improvement and reporting, supply chain, occupational health and safety plan, peat, pollution and GHG’s, HCV and HCS, effective in- tegrated pest management, pesticide use, waste management, soil health fer- tility, soil conservation (erosion and degradation), soil survey and topographic information, water quality and quantity and energy used. Closing meeting On-site audit 12 Aug 2020 Kedaron estate Document and on-site verification previous NCR verification, information and public availability, communication and consultation, commitment to ethical conduct, legal compliance to applica- ble law and regulations, standard operating procedure, system for managing human resources, human rights, complaints and grievances, third party con- tractors, SEIA and plans, training, pay and working conditions, freedom of as- sociations, no child labour, no harassement, no forced or trafficked labour, third party FFB legal sourced, long term plan and economic availability, con- tinuous improvement and reporting, supply chain, occupational health and safety plan, peat, pollution and GHG’s, HCV and HCS, effective integrated pest management, pesticide use, waste management, soil health fertility, soil conservation (erosion and degradation), soil survey and topographic infor- mation, water quality and quantity and energy used. 13 Aug 2020 Berkat estate Document and on-site verification previous NCR verification, information and public availability, communication and consultation, commitment to ethical conduct, legal compliance to applica- ble law and regulations, standard operating procedure, system for managing human resources, human rights, complaints and grievances, third party con- tractors, SEIA and plans, training, pay and working conditions, freedom of as- sociations, no child labour, no harassement, no forced or trafficked labour, third party FFB legal sourced, long term plan and economic availability, con- tinuous improvement and reporting, supply chain, occupational health and safety plan, peat, pollution and GHG’s, HCV and HCS, effective integrated pest management, pesticide use, waste management, soil health fertility, soil conservation (erosion and degradation), soil survey and topographic infor- mation, water quality and quantity and energy used. 14 Aug 2020 Damai estate Document and on-site verification previous NCR verification, information and public availability, communication and consultation, commitment to ethical conduct, legal compliance to applica- ble law and regulations, standard operating procedure, system for managing human resources, human rights, complaints and grievances, third party con- tractors, SEIA and plans, training, pay and working conditions, freedom of as- sociations, no child labour, no harassement, no forced or trafficked labour, third party FFB legal sourced, long term plan and economic availability, con- tinuous improvement and reporting, supply chain, occupational health and safety plan, peat, pollution and GHG’s, HCV and HCS, effective integrated pest management, pesticide use, waste management, soil health fertility, soil conservation (erosion and degradation), soil survey and topographic infor- mation, water quality and quantity and energy used. 15 Aug 2020 Cakra estate Document and on-site verification Cakra oil mill previous NCR verification, information and public availability, communication and consultation, commitment to ethical conduct, legal compliance to applica- ble law and regulations, standard operating procedure, system for managing human resources, human rights, complaints and grievances, third party con- tractors, SEIA and plans, training, pay and working conditions, freedom of as- sociations, no child labour, no harassement, no forced or trafficked labour, third party FFB legal sourced, long term plan and economic availability, con- tinuous improvement and reporting, supply chain, occupational health and

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safety plan, peat, pollution and GHG’s, HCV and HCS, effective integrated pest management, pesticide use, waste management, soil health fertility, soil conservation (erosion and degradation), soil survey and topographic infor- mation, water quality and quantity and energy used. Closing meeting

Agenda for Verification of Closure of Major Non-conformities (if necessary)

Date Location / Main sites Auditor Main activities

No onsite major verification conducted during remote audit. No onsite major verification conducted to verify major non-conformity due to there is no systemic major non- conformity as required by RSPO certification system and TUV Rheiland Indonesia Procedure.

3.3 Assessment Methodology

The 3rd surveillance assessment was conducted betwen 29 – 30 Apr 2020 for remote audit and 12 – 15 Aug 2020 for on-site verification audit as per the assessment program above (section 3.2). The assessment was carried out in accordance with PT TUV Rheinland Indonesia’s RSPO audit procedure as well as the RSPO Certification Sys- tems document. During assessment, the qualified TUV Rheinland assessors used the RSPO standard as en- dorsed for the country in which the assessment took place and recorded their findings. Due to the location and proximity of the estates, combined with common management systems, it was possible to carry out both field and document assessments of all estates and the mill within the time frame without compromising the integrity of the assessment in anyway. Based on information in section 1 above, total estate as supply based is five (5). As required by the RSPO Certifi- cation, total estate taken for sampling is four (4), refer to 0.8√y x (z), where (y) is number of estate; and (z) is risk level. The risk level for this estate is low due to the estate is relatively homogenous, geographilcally as well as so- cioeconomically and no replanting activities. Refer to that explanation, the sampling taken for this audit were 0.8√5 x (1) = 1.7. The result is lower than ≤ 4, total sampling taken must be 4 (minimum sampling taken) required by RSPO. During audit five (5) estates (Kedaron, Cakra, Berkat Lestari and Damai) and one (1) mill were visited and the as- sessment team carried out field and document assessments of compliance to all the RSPO principles and criteria. Common systems were identified and specific evidence was recorded for individual estates. Interviews were con- ducted at all estates and the mill.

Coronavirus outbreak Based on circular letter date on 24 March 2020 from RSPO secretariat that surveillance / recertification audit can be partially performed through a combination of remote and on-site audits as follow:  The surveillance audit was conducted through remote audit date on 29 – 30 Apr 2020 and on-site audit date on 12 – 15 Aug 2020 as per the assessment program above.  The assessment was carried out in accordance with PT TUV Rheinland Indonesia’s RSPO audit procedure as well as the RSPO Certification Systems document and circular letter date on 24 March 2020 from RSPO secretariat. During assessment, the qualified TUV Rheinland assessors used the RSPO standard as en- dorsed for the country in which the assessment took place and recorded their findings.  Based on information in section 1 that total of estate [5]. It is more than four estates so sampling is required. The sampling design shall include every mill and minimum sample of [5] estates ((0.8√ [5] (the number of estates)) x [1] (the multiplier defined by the risk assessment). If the result of calculation is lower than 4 so roundup be 4). Risk level is [1], due to the estate is relatively homogenous, geographilcally as well as soci- oeconomically and no replanting activities.  During remote audit, reviewing compliance against the RSPO P&C requirements as attached in annex 1 of circular letter date on 24 March 2020, through the review of appropriate documented evidence and if need- ed the interview of audit team to interviewer through video conference.  During remote audit, if non-conformity not available so lead auditor submitting remote audit report to tech- nical reviewer and technical review will issued review result immediately. If any non-critical NC raised in re-

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mote audit so evidence of correction will be verifying next ASA but the plan of correction and corrective ac- tion shll be reviewed and accepted by auditor team. Whereas, if any critical NC raised in remote audit so : o Shall be closed within 90 days after closing meeting for carry out remote audit in minimum of 10 days before end date of license (for ASA) or end date validity of certificate (for recertification audit) or o Shall be closed < 90 days after closing meeting or 10 days before end date of license for extension of first period of 3 months (for ASA) which remote audit will be carried out after end date of license. o For those actions need to be verified on-site, can combine together with later on-site audit.  License can be extended for an additional period of 3 months (for extension of first period of 3 months) if critical NC shall be closed and the remote audit report shall be finalized and review result has issued.  During on-site audit, [will be complete after oniste audit is conducted] estates/associated smallholders (i.e [will be complete after oniste audit is conducted]) and [will be complete after oniste audit is conducted] mill were visited and the assessment team carried out field and document assessments of compliance to all the relevant remaining RSPO principles and criteria requirements. Common systems were identified and specif- ic evidence was recorded for individual estates. Interviews were conducted at all estates and the mill.  On-site audit shall be performed before the end of the 6 months extension or whenever the travel re- strictions are lifted by the relevant authority. However, for exceptional cases where on-site audit is not pos- sible during this 6 month extension, the CB is required to inform the RSPO secretariat for further decision.  Once the on-site audit has been successfully completed, the audit team shall update its initial remote audit report to include the on-site process and ensure that the final report fully complies with all RSPO P&C certi- fication system requirement including the peer review of the recertification audit report.

4.0 Stakeholder Consultation and Stakeholders Contacted

The stakeholder consultation involved both external and internal stakeholders. External stakeholders notified to make comments on the surveillance assessment by placing an invitation to comment on the RSPO website. Stakeholders included those immediately linked with the operation of the company such employees, outgrowers, the local government, NGO’s, trade and labour unions and local communities. Stakeholder consultation visited to stakeholder’s location and interviews. Meetings with stakeholders held to seek their views on the performance of the company with respect to the sustainability practices outlined in the RSPO Principles & Criteria, and to com- ment on aspects where improvements could made. Meetings with local communities held at their respective premises within and near the company’s area. In all the interviews and meeting, the objectives of the RSPO and the purpose of the assessment was clarified at the outset followed by an evaluation of the relationship between the stakeholders and the company before discussion proceeded to obtain the stakeholders feedback on the company’s compliance to different aspects of the RSPO Principles & Criteria. Although several stakeholders were not familiar with RSPO but they agreed with its objective and expressed their willingness to collaborate in the promotion of sustainable palm oil in East Kalimantan Province. In all interviews and meeting, the assess- ment team did not restrict discussion of both the positive and negative aspects of operations conducted by PT Rea Kaltim Plantation. The interview with employee and related stakeholder held during the audit was extensive and productive, with an attendance is 84 person. This followed by site inspections, including visits to the local communities, interviews with land claimants and contractors, and inspections of worker amenities and infrastruc- ture. The list of stakeholders that attended the stakeholder consultation meeting or stakeholders interviewed dur- ing the assessment is included as Appendix 6.

5.0 Compliance to Other RSPO Requirement

5.1. Time Bound Plan for Other Management Units

The time frame laid out below is considered to be both challenging and realistic. The audit team is satisfied that the company conforms to the RSPO requirements for partial certification as laid out in Clause 4.5 of the RSPO Certification Systems document (year 2017).

Tabel 8: Time Bound Plan of R.E.A Holdings Plc

Time bound Name of Company Name of POM Name of Estate Location plan for Status certification PT Sasana Yudha Bhakti Perdana POM Tepian Kutai Kar- 2020 Excluded from the tanegara scope of the certified

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Time bound Name of Company Name of POM Name of Estate Location plan for Status certification district, East unit (Perdana POM) Kalimantan due to the findings of province the RaCP and will be certified after the compensation plan has been approved by the RSPO. PT Sasana Yudha Bhakti Satria POM Satria Kutai Kar- 2020 Waiting liability com- tanegara pensation to RSPO district, East Kalimantan province PT Cipta Davia Mandiri Another mill ex- Long Mesangat, Kutai Timur 2022 Will be audit as out- cluding REA Kelinjau, district, East grower scheme and af- group Tamaring Kalimantan ter the compensation province plan has been ap- proved by RSPO PT Kartanegara Kumala Another mill ex- Kartanegara Ku- Kutai Timur 2025 Will be audit as out- Sakti cluding REA mala Sakti district, East grower scheme group Kalimantan province PT Prasetia Utama Perdana POM Prasetia Utama Kutai Kar- 2025 Will be audit part of tanegara Perdana POM supply district, East based (extension Kalimantan scope) province PT Persada Bangun Jaya Perdana POM Persada Bangun Kutai Kar- 2025 Will be audit part of Site Kembang Janggut Jaya tanegara Perdana POM supply district, East based (extension Kalimantan scope) province PT Persada Bangun Jaya Satria POM Persada Bangun Kutai Kar- 2025 Will be audit part of Sa- Site Tabang Jaya tanegara tria POM supply based district, East (extension scope) Kalimantan province Plasma Kahad Bersatu Perdana POM Plasma Kahad Kutai Kar- 2020 Waiting liability com- Bersatu tanegara pensation process from district, East RSPO and will be au- Kalimantan dited as part of Per- province dana POM Plasma Etam Bersatu Perdana POM, Plasma Etam Kutai Kar- 2020 Waiting liability com- Cakra POM Bersatu tanegara pensation process from district, East RSPO and will be au- Kalimantan dited as part of Cakra province POM Plasma Bangun Sari Satria POM Plasma Bangun Kutai Kar- 2023 Will be audit after three Sari tanegara (3) years Satria POM district, East certified Kalimantan province Plasma Anugerah Se- Satria POM Plasma Anugerah Kutai Kar- 2023 Will be audit after three jahtera Sejahtera tanegara (3) years Satria POM district, East certified Kalimantan province Plasma Pekalai Murip Satria POM Plasma Pekalai Kutai Kar- 2023 Will be audit after three Murip tanegara (3) years Satria POM district, East certified Kalimantan province

5.2. Compliance to Rules for Partial Certification

Compliance of the uncertified management units of Rea Kaltim Plantations against the rules for partial certifica- tion according to RSPO Certification System clause 4.5 was assessed by desk study as well as web check on

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Page 19 of 121 relevant complaints; verification to company’s parent company, a positive assurance statement based upon company’s self assessment completed with sufficient evidence against each requirement; consultation with tar- geted stakeholders including consultation with the relevant NGO’s, and or further stakeholder consultation and or field inspection considering the risk assessment result of any non compliance with the requirements. A summary of findings is as stated below:

Partial Certification Requirements Audit Findings 4.5.2 The parent organization or one of its ma- PT REA KALTIM is subsidiary under R.E.A Holdings Plc and R.E.A jority owned and / or managed subsidiaries is Holdings Plc is RSPO member with RSPO member number 1- a member of RSPO. 0045-07-000-00 since on 10 November 2007. 4.5.3 A challenging time-bound plan for certify- R.E.A Holding Plc have revision of time-bound plan to achieve ing all its relevant entities is submitted to the RSPO certification for all relevant entities referring to the time Certification Body (CB) during the first certifi- bound plan table (Table 8 above). cation audit. The time-bound plan should con- There are management unit revision of time bound plan with some tain a list of subsidiaries, estates and mills. reasons as below : Any revision to the time-bound plan or to the  Satria estate (PT Sasana Yudha Bhakti): LUCA has approved by circumstances of the company shall cause the RSPO in year 2019. plan to be reviewed. for whether it is still ap-  Kedaron estate (PT Kutai Mitra Sejahtera): based on overlay of propriate, such that changes to the time-bound map between map of land use right and map of forest areas is plan are permitted only where the organisation the location of Kedaron estate inside of forest areas so that au- can demonstrate that they are justified ditee still in-process compliance to regulation.  Kartanegara Kumala Sakti estate (PT Kartanegara Kumala Sak- ti): the company has not been land clearing so that the company will be conducting NPP assessment before land clearing activi- ties.  Prasetia Utama (PT Prasetia Utama): It has taken over by PT Sasana Yudha Bhakti from other company (Bakrie Sumatera Plantation Group) on 18 September 2017. Majority of PT Pra- setia Utama areas has claimed by communities so that the company has carried out re-inventory activities in order the land compensation process. The current condition that 3,265 ha has re-inventoried and the company will be paying compensation land of 309 ha in the near future.  Smallholder of Kahad Bersatu : cooperative of committee and company has not been deal regarding cost from implementation of RSPO certification process and benefit received by the coop- erative Moreover that there are entities remove from table 8 above be- cause :  PT Putra Bongan Jaya: it has sold to other company. Whereas, LUCA has approved by RSPO secretariat year 2017  Smallholder of Terusan Jaya Mandiri: there is dispute regarding one of clause in agreement of developing community plantation so that the plantation has operated by cooperative and/or coop- erative members and FFBs production has sold to other POMs under R.E.A Group. Record of the handling of dispute resolu- tion process has available but both parties has disagreed until audit. 4.5.4 (a). No replacement of primary forest or Based on self-assessment report from auditee that uncertified any area identified as containing High Conser- management units has conducted HCV assessment such as : vation Values (HCVs) or required to maintain  PT Sasana Yudha Bhakti (Satria estate & Tepian estate): HCV or enhance HCVs in accordance with RSPO assessment was conducted by Stephan Wulffraat - WWF Indo- criterion 7.3 (it has changed be Criterion nesia in July 2008. 7.12 in P&C 2018). Any new plantings since  PT Kutai Mitra Sejahtera (Kedaron estate): HCV assessment January 1st 2010 must comply with the RSPO was conducted by The Malaysian Environment Consultants New Plantings Procedure*. For each new (MEC) between August 2010 and May 2011. planting development, compliance with the  PT Cipta Davia Mandiri (Long Mesangat estate, Kelinjau estate NPP shall be verified by an RSPO accredited & Tamaring estate): HCV assessment was conducted by The CB. Malaysian Environment Consultants (MEC) on August 2014.  PT Kartanegara Kumala Sakti (Kartanegara Kumala Sakti es- *Any new plantings since this period must be tate): HCV assessment has conducted by Remark Asia on Oc- reported to TUV Rheinland to conduct verifica- tober 2017. HCV report still review process by HCV-RN. tion of compliance to the New Planting Proce-  PT Prasetia Utama: HCV assessment has conducted on year

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Partial Certification Requirements Audit Findings dure 2014 and it has updated and reviewed by PT Gagas Dinamiga Aksenta on July 2018.  PT Persada Bangun Jaya (Site of Kembang Janggut & Tabang): HCV assessment has conducted by Malaysian Environment Consultant (MEC) on year 2013.  Cooperative of Kahad Bersatu: HCV assessment has conducted by PT Gagas Dinamiga Aksenta on October 2018.  Cooperative of Etam Bersatu: HCV assessment has conducted by PT Gagas Dinamiga Aksenta on October 2018.  Cooperative of Pekalai Murip & Anugerah Sejahtera: HCV as- sessment was conducted by Stephan Wulffraat - WWF Indone- sia in July 2008.  Cooperative of Bangun Sari: HCV assessment was conducted in July 2008. Some management units has carried out land clearing activities since November 2005 without preceded by HCV identifica- tion/assessment. Based on RaCP tracker (per January 2019) that some management units under R.E.A Holding Plc explained as below :  4 management units has submitted LUCA but LUCA of 1 man- agement unit still in-process revision to new LUCA template so that the status in RaCP tracker as management unit with poten- tial liability.  1 management units with potential liability is certified manage- ment units.  LUCA of 1 management unit has passed and need concept note (uncertified management unit)  1 management unit is LUCA review ongoing (certified manage- ment unit)  1 management unit has submitted compensation plan (uncerti- fied management unit) Following up one of resolution from 35th BHCVWG meeting year 2017 are pushing certified management unit to submit annex 7 & 8 (compensation concept note & compensation plan) to RSPO com- pensation panel in annual surveillance audit by each certification body according time frame which has decided in meeting. The progress of the passed LUCA and/or the concept note approval can be saw in indicator 7.3. Information of LUCA for some uncertified management units as follow as : 1. PT Sasana Yudha Bhakti (Satria estate): LUCA has got ap- proval from RSPO in Year 2019 and in-process to develop concept note because any liability. 2. PT Citra Davia Mandiri: based on email dated on 14 February 2018 that concept note was endorsed by the compensation panel and organization has submitted compensation plan to RSPO compensation. 3. PT Prasetia Utama: organization has not been land celaring activities because organization has conducted land inventory in July 2018 with total of areas 3,265 ha and will conducting land compensation for 309 ha. Therefore, your LUCA will not be processing by the compensation desk because your LUCA is actually meant for NPP purpose. 4. PT Kartanegara Kumala Sakti : the organization has not been conducting land clearing and still in-process preparation NPP verification where HCV report still reviewed by HCV-RN 5. PT Kutai Mitra Sejahtera (Kedaron estate): organization has conducted HCV assessment before land clearing activities so that LUCA has verified by CB in NPP verification. NPP report has notified on RSPO website dated on 6 March 2012 6. PT Persada Bangun Jaya (Site Tabang & Kembang Jnaggut): PT PBJ (both sites) has carried out NPP verification. NPP re- port on behalf PT PBJ – Site Kembang Janggut has notified

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Partial Certification Requirements Audit Findings on RSPO website dated on 14 July 2014 whereas NPP verifi- cation on behalf PT PBJ – Site Tabang has carried out but it was discontinued because still in-process solving dispute re- garding overlap with permit of mining areas. Based on infor- mation above that LUCA document was available for both sites. 7. Cooperative of Kahad Bersatu & Etam Bersatu: LUCA report still in finalize by consultant. 8. Cooperative of Pekalai Murip & Anugerah Sejahtera : location of cooperative of Pekalai Murip & Anugerah Sejahtera inside of land use right (HGU) on behalf Satria estate (PT SYB) so that LUCA has got approval from RSPO in Year 2019 and in- process to develop concept note because any liability. 9. Cooperative of Bangun Sari: still in-process develop of disclo- sure report and will submitting report to RSPO so on. 4.5.4 (b). Land conflicts, if any, are being re- The organization has carried out land compensation process activ- solved through a mutually agreed process, ities as shown in the list of person/party which has received land such as the RSPO Complaints System or Dis- compensation payment, record of land compensation payment & pute Settlement Facility, in accordance with agreement of handover land, minute of meeting regarding land RSPO criteria 2.2, 6.4, 7.5 and 7.6 (it has compensation process and map of land compensation or inventory changed be Criterion 4.8, 4.7 and 4.5 in land on behalf uncertified management unit. P&C 2018). In general, all REA uncertified management units have got non- significant land conflict issue with community and are being re- solved through a mutually agreed process in accordance with Land Compensation and Village Claims Standard Operating Procedure. This SOP applies to all plantation subsidiary companies within REA Kaltim Plantations Group. The SOP is subject for any further updates and modification relevant to the needs. Organization has provided some evidences regarding cultivating land solving by one of communities inside of organization’s land use right (HGU) areas as samples such as : 1. Personil (live in RT 10 – Kelinjau Village) which cultivated Block 206 A, 206 B and 222 A in PT CDM areas and solving process from June 2016 to March 2017. 2. Personil (live in RT 006 – Muara Bengkal Ilir Village) which cul- tivated Block 38C, 38D and 52D in PT CDM areas and solving process on August 2017. 3. Personil (live in Muara Bengkal Ilir Village) which cultivated Block 52D and 53A in PT CDM areas and solving process on August 2017. 4. Notary deed no. 21 dated on 23 July 2011 regarding agree- ment between Senyiur and PT Kutai Mitra Sejahtera. Content of agreement is land compensation process (include of amount of land compensation per hectare), develop of small- holder areas and guarantee from the head of village that areas which has been compensated will not cultivated by the owner and other parties. 5. Documentation of the solving process through legal/law chan- nels (May 2018) for claim of land in block 37C, 37D & 51D – PT CDM by Mr Harani and friends 6. Agreement between PT CDM and KSU Balai Indah Mandiri dated on 21 May 2018 regarding overlap of location permit ar- eas PT CDM with land ownership of KSU Balai Indah Mandiri 7. Documentation of land dispute solving with mining company (PT Tiwa Abadi). 4.5.4 (c). Labour disputes, if any, are being re- Based on self-assessment against uncertified management units solved through a mutually agreed process, in that no significant labour issues has found under the uncertified accordance with RSPO criterion 6.3. (it has management units. changed be Criterion 4.2 in P&C 2018) Some evidences has provided by organizations which has operat- ed regarding labour issue such as :  Organization have policy of human right (no. 002/BOD_REA/P/II/2015) include of Whistleblowing policy  Manual of human resource section V.5.4

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Partial Certification Requirements Audit Findings  Bipartite cooperation institute (LKS Bipartite)  Record of labour dispute solving as sample in PT SYB (Satria estate & POM). Whereas, other management units has not been labour dispute cases 4.5.4 (d) Legal non-compliance, if any, are be- Uncertified management units have the list of laws & regulations or ing resolved in accordance with the legal re- law register relate of plantation, environment and OSH issue. The quirements, with reference to RSPO criteria result of evaluation law and regulation with implementation by 2.1.(it has changed be Criterion 4.2 in P&C company was available. 2018) Based on self-assessment report that some of R.E.A Holding Plc’s uncertified management units (include of their scheme smallhold- er) have not complied with certain legal requirements, i.e. :  There are indication that part of PT KMS’s areas has overlap with forest areas in East & (Minister of For- estry decree no. SK.718/Menhut-II/2014 dated on 29 August 2014)  There are indication that part of cooperative of Kahad Bersatu & Etam Bersatu’s areas has overlap with forest areas (spatial plan of East Kalimantan Province)  2 operators in sterilizer station (Satria POM) have not opera- tion permit relate of OSH  3 casual workers in PT CDM areas (division of 3) has worked more 21 days sequent (July to September 2018)  RKPPLP document has not available in PT PU  There are not been implemented law & regulation relate of la- bour, OSH, plantation issues, etc in scheme smallholder areas and PT CDM areas. At time of this audit, the company was still making efforts to close these legal non-compliances. Whereas, evidence of compliance to law and regulation such as :  Revision of company act on behalf PT Kutai Mitra Sejahtera (no.25 dated on 11 October 2018), PT PBJ (Site Kembang Janggut) (no.39 dated on 15 June 2017) & PT PU (no. 27 dat- ed on 11 October 2018) and has informed to government,  Location permit,  Land use right (HGU),  Environmental document and/or permit,  Business plantation permit,  Land ownership for scheme smallholder areas, etc. Uncertified management units has carried out monitor of pillar boundary regularly except PT PBJ (Site Tabang & Kembang Janggut), PT PU & PT KKS because has not been got land use right (HGU) and scheme smallholder because all boundary stones has not been demarcated.

5.3. Compliance to other RSPO Procedure

RSPO NPP Yes RSPO Compensation and Remediation procedure Email from RSPO dated in 21 Oct 2019, based on dis- closure, the company have reported no-complaint land clearing after Nov 2005 without prior HCV assessment for Damai dan Berkat Estate Areal Subject to sanction -

5.4. Compliance to RSPO Guidance on GHG calculation for period 2019

During the audit, the audit team verify and confirm that i. The RSPO PalmGHG Calculator used Version 4.1 Accurate data has been put into the RSPO PalmGHG Calculator Yes

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Net GHG Emission Figure (tCO2e/tCPO) 0.35

Summary Emissions Product tonCO2/t Product CPO 0.35 PK 0.35

Production t/yr FFB processed 401307.16 CPO produced 96769.85

Description Unit Value Oil palm planted on mineral soil Ha 26412.10 Oil palm planted on peat Ha 0 Conservation area (forested) Ha 11611.29 Conservation area (non-forested) Ha 0 Total planted area Ha 26412.10 FFB production per hectarage Ha 23.47 OER % 24.12 KER % 4.74

Description tCO2 tonCO2/t FFB Emission sources POME 2031.92 0.01 Fuel consumption 3548.93 0.01 Grid electricity utilization 0 0 Credits Export of excess electricity to housing & Grid -8384.33 -0.02 Sale of PKS 0 0 Sale of EFB 0 0 Total -2803.49 -0.01

Palm oil mill effluent (POME) treatment

Divert to compost 0 Divert to anaerobic digestion 100

Palm oil mill effluent (POME) to Anaerobic Digestion:

Divert to anaerobic pond 0 Divert to methane capture (flaring) 9 Divert to methane capture (electricity) 91

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Summary of Field Emissions and Sinks Own Crop Group 3rd party Emission tCO2e tCO2e/ha tCO2e/tFFB tCO2e tCO2e/ha tCO2e/tFFB tCO2e tCO2e/ha tCO2e/tFFB Emission sources Land Conversion 199527.72 9.81 0.56 1578.89 0.26 0.58 0 0 0

CO2 Emission from Fertilizer 12952.59 0.64 0.04 115.47 0.02 0.04 0 0 0

N2O Emissions from peat 0 0 0 0 0 0 0 0 0

N2O Emissions from fertilizer 10160.00 0.50 0.03 109.14 0.02 0.04 0 0 0 Fuel consumption 4841.28 0.24 0.01 61.35 0.01 0.02 0 0 0 Peat Oxidation 0 0 0 0 0 0 0 0 Sinks Crop Sequestration -138757.47 -6.38 -0.39 -1098.00 -0.18 -0.40 0 0 0 Sequestration in Conservation area -55506.70 -2.73 -0.16 -58.93 -0.01 -0.02 0 0 0 Total 33217.44 1.83 0.09 707.91 0.12 0.26 9066.82 0 45334.10

5.5 Plan for certification of associated smallholders

As seen from data in Table 3, the mill received 1.21 % supply of FFB from smallholders, of which Etam Bersatu scheme smallholder of these are small- holders associated with the mill. The mill has developed a plan for certification of associated smallholders, where will audit in the third (3) years after certification, but due to RaCP process yet finished by RSPO Compensation panel, the company still waiting the process is done, while still educate the scheme smallholder regarding RSPO requirements. This will be check during on-site visit. The plan still in 2020 (this year).

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6.0 ASSESSMENT FINDINGS

6.1 Summary of Findings

The following is an audit findings made for the indicator listed in the RSPO Principles & Criteria Generic 2018 Note:  YYYY : Generic 2018  R : Remote Audit; O : On-site Audit; R & O : Remote & On-site Audit;

CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS Principle 1: Behave Ethically and Transparently 1.1 The unit of certification provides adequate information to relevant stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languanges and forms to allow for efffective participation in decision making.

R 1.1.1 (C) Management documents that are specified in the RSPO P&C are made publicly available

a. How are the management documents listed in (b) below made publicly available? Remote audit result b. Are the management documents related to the environmental, social and legal issues below made publicly available The company has provide the list of documents which is publicly available as stated on BPO Transparency and Yes : Information Submission, No. REA.BPO.LGL.TPI, i.e. : No - Results of FPIC processes; - Vision and mission of the company N.A - SEIAs; - Company policy. - Human Rights policies including policy on protection of human rights defenders (HRDs)/whistleblowers; - Regular reports to the department. NCR No : - - Social programmes avoding or mitigating negative social impact; - Company SOP - Social programmes advancing livelihoods; - Report of K3 activities, environmental, social and employment. (HCV, AMDAL, RKL-RPL, CSR, SIA, legisla- - Figures of gender distribution within all workers categorised by management, administrative staff and workers tive evaluation list). (both permanent casual workers, piece rate workers); - A summary of public certification and management systems: - Partnership programmes for independent smallholders, education and health in the communities (where appli- And documents that can be accessed with the approval of the President Director such as: cable) - Company licensing documents (company deed, location permit, HGU, IUP) c. Are the following management documents (but not necessarily limited to) made available upon request : - Report on financial audit results - Land titles/user rights (Criterion 4.4) - All types of maps and technical data - Occupational health and safety plans (Criterion 3.6) - Plans and impact assessments relating to environmental and social impacts (Criterion 3.4) - HCV & HCS documentation (Criterion 7.12) - Pollution prevention and reduction plans (Criterion 7.10) - Details of complaints and grievances (Criterion 4.2) - Negotiation procedures (Criterion 4.6) - Continuous improvement plans (Criterion 3.2) - Human Rights Policy (Criterion 4.1) O 1.1.2 Information is provided in appropriate languages and accessible to relevant stakeholders

a. Are the documentation including information provided to stakeholder and communication with stakeholder done in Onsite verification result appropriate languages? There is evidence that company provides adequate information on (environmental, social and/or legal) issues relevant Yes b. Are stakeholders aware of the type of information available and how to get access to the information? to RSPO Criteria to relevant stakeholders for effective participation in decision making. Also company has conduct No c. How and where is the information disseminated? dissemination mechanism to communicate with stakeholders, company policy , land conflict procdure, FPIC procedure N.A d. From the audit evidences, what type of information is provided to the stakeholders? and periodic report to stakeholder on April 15, 2020 (Province, district government and agency) and April 20-21,2020 (local leader, communitties etc) for Kutai Mitra Sejahtera socialization conducted at 19-20 December 2019 at Muara NCR No : RSPO03239 Ancalong Sub District. Company also has send the periodic report to such P2K3 report, annual labour report, man- agement-monitoring environment report, plantation report and much others, however based on document review com- pany has not send the periodic land use report to land agency. It raised non conformity to this condition.

R 1.1.3 (C) Records of requests for information and responses are maintained

a. Are records of requests for information and responses maintained? Please indicate the type of records reviewed Remote audit result b. Does the company have an SOP to ensure constructive response to stakeholders? Company Procedure for Transparency and Information Submission (REA.BPO.LGL.TPI) by adding information on Yes c. Is there a clear time frame for response to request for information? types and / or documents that can be accessed by the public referring to the RSPO standard (Sustainability Depart- No d. Who is the personnel in charge (PIC) for receiving and responding to request? ment). Time frame 14 days. PIC Smallholder and comdev Assistant. N.A Example record: 2 Letter from the Provincial Plantation Agency of East Kalimantan dated January 08, 2020 regarding requests for CPO NCR No : - and FFB production data processed by mill, and response from management by submitting production data for CPO and FFB production for the period 2018-019 to East Kalimantan Plantation Agency on January 16, 2020.

R 1.1.4 (C) Consultation and communication procedures are documented, disclosed, implemented, made available, and explained to all relevant stakeholders by a nominated management official

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. Is there SOP being developed by the unit of certification for consultation and communication between the company Remote audit result and all relevant stakeholders? Company Procedure for Transparency and Information Submission as mentioned above also company has appoint- Yes b. Has the SOP been communicated to the relevant stakeholders and understood by these parties? If yes, how was it ed the personel to handle external communication is Smallholder and comdev Assistant (new assignment).The pro- No done? cedure has been disseminate to external parties also carried out by the PIC appointed by company on April 15, 2020 N.A c. Who in the company is appointed to be responsible for communication and consultation with the relevant stakehold- (Province, district government and agency) and April 20-21,2020 (local leader, communitties etc) ers? NCR No : - d. Is the position made official with clear and proper job description? e. Are the relevant stakeholders aware of and know how to contact the person in charge? f. Are the relevant stakeholders aware of the established SOP? Please interview the relevant stakeholders? g. Are there records of actions taken in response to input from stakeholders?

R 1.1.5 There is a current list of contact and details of stakeholders and their nominated representatives

a. Is there a list of contact and details of stakeholders and their nominated representatives? Remote audit result b. What details are included in the list? Units have list all relevant stakeholder such local leaders, union, suppliers, contractors, and govenment agencies etc, Yes c. When the list was last updated? which upate on January 2020. No d. Are the listed contacts exist? Auditor to verify by contacting the listed stakeholders randomly N.A

NCR No : -

1.2 The unit of certification commits to ethical conduct in all business operations and transactions

R & O 1.2.1 A policy for ethical conduct is in place and implemented in all business operations and transactions, including recruitment and contracts

a. Is there a written policy committing to a code of ethical conduct and integrity in all operations and transactions, in- Remote audit result cluding recruitment and contracts? The company has a written policy committing to a code of ethical conduct and integrity in all operations and Yes b. Does the policy include as a minimum : transactions, as stated on document of “Business Ethics Policy” No. 001/BOD_REA/P/II/2015 dated on March 01 No - A respect for fair conduct of business? 2015. The policy has communicated and distributed to all levels of the workforce and operations. N.A - A prohibition of all forms of corruption, bribery and fraudulent use of funds and resources? - A proper disclosure of information in accordance with applicable regulations and accepted industry practices? Onsite verification result NCR No : - Interview result with workers found that they never saw any ethical conduct violation among workers and/or with man- agers.

R & O 1.2.2 A system is in place to monitor compliance and the implementation of the policy and overall ethical business practice

a. What is the mechanism in place to monitor the compliance and implementation of the policy and overall ethical Remote audit result business practice? Company has Whistleblowing system mechanism to ensure the operation comply with ethical business policy and Yes b. Has the mechanism been effectively implemented? well implemented. Until surveillance audit, there was no existing record related ethical business allegation. No N.A Onsite verification result Based on verification and workers interview no violence against to the code of ethical business practice. The compa- NCR No : - ny also have concern on this through internal audit and enforcement of discipline. Principle 2 : Operate legally and respect rights - Implement legal requirements as the basic principles of operation in any jurisdiction

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

R & O 2.1.1 (C) The unit of certification complies with applicable legal requirements

a. Is the complete list of legal requirements available? Remote audit result b. When was the list updated? Based on document verification the company mill and estate able to show the record compliance to applicable law and Yes c. Is there evidence of compliance to the applicable legal requirements? regulations. Sampling of the compliance such as: No - Valid license of temporary storage of hazardous waste (TPS LB3) of Cakra POM, No. 660.1/117/BLHD-I/2016, N.A dated May 24, 2016, and valid until 5 (five) years since issuance. - Valid license of temporary storage of hazardous waste (TPS LB3) of Cakra Estate, No. 660.1/277/BLHD-I/2016, NCR No : - dated December 30, 2016, and valid until 5 (five) years since issuance. - Valid license of temporary storage of hazardous waste (TPS LB3) of Berkat Estate, No. 660.1/274/BLHD-1/2016, dated December 30, 2016 and valid 5 (five) year since issuance. - Valid license of temporary storage of hazardous waste (TPS LB3) of Damai Estate, No. 660.1/273/BLHD-1/2016, dated December 30, 2016 and valid 5 (five) year since issuance. - Valid license of temporary storage of hazardous waste (TPS LB3) of Lestari Estate, No. 660.1/270/BLHD- 1/2016, dated December 30, 2016 and valid 5 (five) year since issuance. - Report of implementation of RKL & RPL for period Semester 1 and 2 year of 2019.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS - River Water Utilization Permit based on the Decree of the Minister of Public Works Number: 326 / KPTS / M / 2012 concerning Permits to Use Water Resources from the Belayan River (Intake II) to PT Rea Kaltim Planta- tions dated October 19, 2012. - Permission for plantation activities for factories (renewal and upgrading) document No.525.26/005/IUP- P/BID.I/XII/2015/BP2T regarding Upgrading Capacity of Cakra POM, issued by Head of Kutai Kartanegara Dis- trict. This permit explained about Cakra POM upgrading capacity from 60 tonne FFB/hours become 90 tonne FFB/hours. Issued at Tenggarong on December 2, 2015. - Company has facilitated and freedom to form of Labour union SP Kahutindo (Act No. 21 year 2000 Labour Un- ion). - Implementation of local minimum wages for 2018 (Governor Decree No. 561/K.824/2017 regarding minimum wages for East Kutai, East Kalimantan.

Onsite verification result Based on verification audit, interview with workers, no violation against to applicable law and regulations. The check- ing focused on workers welfare, occupational health and safety, wages and others permit must complete follow by company. O 2.1.2 A documented system for ensuring legal compliance is in place. This system has a means to track changes to the law and also includes listing and evidence of legal due diligence of all contracted third parties, recruitment agencies, service providers and labour contractors. a. Is there a documented system which includes the following? Onsite verification result - Personnel in charge to identify the legal requirements and ensure compliance; To ensure the legal compliance, company conduct internal audit at all units (certification scope) which conduct twice a Yes - Comprehensive list of international, national, sub-national and provincial laws which details the requirements of year. Last internal audit conducted at 13-15 January 2020, with result several nonconfomitty, mostly related safety and No specific to the mill and estate operations. administration aspect. N.A - Relevant sections within the law that is identified and linked to activities within the unit of certification. b. How legal compliance is verifed and assessed? NCR No : - c. Is there a documented methodology (e.g.: personnel in charge (PIC), source of info, frequency of update) for track- ing changes and communication of changes to relevant sections of the legislation?

O 2.1.3 Legal or authorised boundaries are clearly demarcated and visibly maintained, and there is no planting beyond these legal or authorised boundaries

a. Is there a map showing location of boundary markers? Onsite verification result b. Is there physical presence of boundary markers? Company able to evidence the maps of HGU pillars of each estates , monitoring already conducted on April 2020 Yes c. How the company does maintained its boundary markers? and the pilars are in good conditions as seen site observation – pilar No. 57-58 at Div 08 Block 47 D Berkat Estate No Note to auditor: Ground verification of boundary markers using GPS should be conducted. Priority should be on bounda- and pilar No 16-17 at Div I Block 04 D. However, based on field observation Berkat estate unit has not installed and N.A ries with other estates, community areas, protected area and rivers monitored boundry pillars No. 56-96. It raised minor non confomity to this condition. d. Any planting beyond these legal or authorised boundaries? How was this verified? NCR No : RSPO03241

2.2 All contractors providing operational services and supplying labour, and Fresh Fruit Bunch (FFB) suppliers, comply with legal requirements.

R 2.2.1 A list of contracted parties is maintained

a. Is each of the site maintained a list of contracted parties? Remote audit result b. Is the list included the following : The company has a list of contractors or partners. Contractor or partner information that is, the company's name, Yes i. Contractor providing operational services to the site? owner, address, type of business and legality. The results of checks during audits, contractors or partners adhere to No ii. Labour including the following : national regulations, for example wages, problem guarantees, work agreements with workers, wage documentation. N.A - Temporary employment However, there are types of jobs that are outsourced to other companies, but evidence cannot be shown that the out- - Short-term contracts; renewable contract sourcing activities have been reported to the relevant agencies. This condition raised as nonconformity under NCR NCR No : RSPO03120 - Fixed-term, project, task-based contracts or casual work No.RSPO03120. iii. FFB suppliers

R & O 2.2.2 All contracts, including those for FFB supply, contain specific clauses on meeting applicable legal requirements, and this can be demonstrated by the third party.

a. Are there contractual agreements between the Company and the third party listed in 2.2.1? Remote audit result b. Is the agreement requires the third party to comply with applicable legal requirements and to provide evidence of its All contractors have a work agreement with the company. The contents of the agreement are the rights and obliga- Yes compliance? tions of both parties based on the results of the agreement and partly refers to national regulations. For example: Let- No c. How does the organization ensure that compliance is met by third party? ter of Work Agreement between PT Rea Kaltim Plantattions and Azizi Muhgofar No. 014/SPK/LES/I/2020, time of ex- N.A ecution of work on 1 January 2020-30 June 2020. To ensure that the contractor or partner meets the specified requirements. The company has a Supplier or Contractor NCR No : RSPO 03121 Performance Evaluation Procedure. REA.BPO.PRO.EKS issued May 25 2016 and Contractor Safety Management NCR No : RSPO 03242 Procedure No. REA.BPO.HSE.MKK published September 25, 2016. However, in its operations the company cooperates with the contractor, but it cannot yet be proven that the contractor has fulfilled the applicable legal obligations, for example BPJS Health and Employment membership for its workers,

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS salary slips, SPK between the contractor and its workers, contractor agreement has not been registered by the con- tractor with District Manpower Office Kutai Kartanegara. This condition raise as nonconformity under NCR No.RSPO 03121.

Onsite verification result The company has shown the results of the contractor evaluation based on the REA.BPO.HSE.MKK Procedure, but this evaluation has not been effective, because there are still workers who are transporting and loading FFB contrac- tors in Division V, Block 7B, in Kedaron Estate working without using Personal Protective Equipment (PPE) and all the legality of the contractor and the implementation of workers' rights has not been shown (salary slip, BPJS member- ship, work contract, PPE submission and list of workers). This condition raise as nonconformity under NCR RSPO 03242.

R 2.2.3 All contracts, including those for FFB supply, contain clauses disallowing child, forced and trafficked labour. Where young workers are employed, the contracts include a clause for their protection

a. Are the contractual agreements between the Company and the third party listed in 2.2.1 contain clauses disallowing Remote audit result child, forced and trafficked labour to be employed by the third party, and where young workers are employed, the The contractual agreement between the company and a third party already contains a clause that prohibits children, Yes contracts include a clause for their protection? forced and trafficked workers from being employed by third parties and the contract includes a clause for their protec- No b. How the company does ensures that the third party comply with the above requirements? tion. N.A The way the company ensures that third parties comply with the requirements above is to apply a Supplier or Contrac- tor Performance Evaluation Procedure. REA.BPO.PRO.EKS issued May 25 2016 and Contractor Safety Management NCR No : - Procedure No. REA.BPO.HSE.MKK published September 25, 2016.

2.3 All FFB supplies from outside the unit of certification are from legal sources.

R 2.3.1 (C) For all directly sourced FFB, the mill requires : - Information on geo-location of FFB origins - Proof of the ownership status or the right/claim to the land by the grower/ smallholder - Where applicable, valid planting/ operating/ trading license, or is part of a cooperative which allows the buying and selling of FFB

a. Has the mill maintained a list of directly and indirectly sourced FFB suppliers? Remote audit result b. Has the mill identified the geo-locations of FFB origins of its FFB suppliers? The Cakra POM has record of list third party FFB sourced from the 3rd surveillance audit date period 27 Apr 2019 until Yes c. How the mill does tracked the geo-locations? 28 Apr 2020. There are two (2) types of FFB thirdparty supplir wheres the first one is indirect suppliers and the second No d. Has the mill obtained the proof of the ownership status or the right/claim to the land of their FFB suppliers? is direct suppliers. Total of indirect supplier was Koperasi Plasma Etam Bersatu, and the indirect was consist of 27 N.A e. Where applicable, has the suppliers provided the mill of their valid planting/ operating/ trading license, or is part of a suppliers. List of suppliers data complete with information such as Land_ID; Status; Land owner; Land Certificate cooperative which allows the buying and selling of FFB? Number; Name of Cooperative (Koperasi); Address; Land location; Year of Planting; Total areas (ha); and X, Y coor- NCR No : - dinate. Within the date period above, total FFB thirdparty supplied to the Cakra oil mill was 51815.36 MT consist of two (scheme smallholder); ten (10) independent smallholders and four (4) outgrowers. Complete information regarding this matter served in Table 2 above.

O 2.3.2 For all indirectly sourced FFB, the unit of certification obtains from the collection centres, agents or other intermediaries, the evidence as listed in Indicator 2.3.1 PROCEDURAL NOTE : For Implementation Procedure for 2.3.2 refer to Annex 4 a. Is there evidence that the mill is complying with indicator 2.3.1 above? Onsite verification result b. Is there any smallholders identified as supplier to the mill? Refer to production record above in Table 2, showed there 13.58% of raw material non-certified FFB supplied to the Yes c. If yes to (b), are the the requirements in indicator 2.3.1 been met? mill from scheme smallholders, independent smallholder and outgrowers. For independent smallholder, the mill has No d. If no to (b), has the mill established a timeline to fulfill the requirements? contract agreement for FFB thirdparty. Within the audit date period 27 Apr 2019 – 11 Aug 2020, total FFB non-certified N.A e. Is the timeline meeting the requirements of Annex 4 of P&C 2018, i.e. for existing certified mill, 3 years from 15 supplied to the mill was 69791.72 MT. Contract agreement sampled was taken for Belayan Sejahtera and Etam Se- November 2018, and for newly certified mill, 3 years from the Initial Certification jahtera as FFB thirdparty who the biggest supplier within audit date period. The contract agreement number was: NCR No : 1. Contract agreement no. 006/PJB-TBS/PPMD-REA/II/2020 dated on 6 Jun 2020 between Cakra oil mill and Koperasi Perkebunan Belayan Sejahtera. 2. Contract agreement no. 007/PJB-TBS/PPMD-REA/II/2020 dated on 6 Jun 2020 2020 between Cakra oil mill and Koperasi Perkebunan Etam Sejahtera. For scheme smallholder under Cakra oil mill i.e.: Etam Bersatu, during the 3ASA the company yet include the the sceheme smallholder to the certification scope due to the RaCP process still in under RSPO review and waiting for environmental permission from authority. This is already communicate to the RSPO, explained in CR 7.12.1 below. Principle 3 : Optimise productivity, efficiency, positive impacts and resilience

3.1 There is an implemented management plan for the unit of certification that aims to achieve longterm economic and financial viability

R & O 3.1.1 (C) A business or management plan (minimum three years) is documented that includes, where applicable, a jointly developed business case for Scheme Smallholders

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. Is there a documented business or management plan with a minimum planning period of 3 years? Remote audit result b. Is the business or management plan contain : The Cakra oil mill and estate has established business/long-terms management plan from 2018 until 2025. Infor- Yes i. Attention to quality of planting materials? mation on this document coverage but not limited to hectares planted area, FFB projection production for owned es- No ii. Crop projection = Fresh Fruit Bunches (FFB) yield trends? tate and smallholders, FFB projection suppliy to the Cakra mill, CPO and PK projection, OER and KER projection, for- N.A iii. Mill extraction rates = Oil Extraction Rate (OER) and Kernal Extraction Rate (KER) trends? cast pricess for FFB and palm product, potential income, others financial indicators (general charges capitalised) and iv. Cost of production = cost per tonne of Crude Palm Oil (CPO) trends? so on. This management plan has approved by the Top Management of R.E.A. HOLDINGS. NCR No : - v. Forecast prices? vi. Financial indicators? Onsite verification result c. Is the business or management plan approved by the top management? Based on-site verification all estate under Cakra oil mill has established long-terms management plant for 2018 until d. For smallholder schemes, has the scheme management provided their members with information on business or 2025, also for FFB budget production for 2020 and 2021. The FFB budget production was per year and per division. management plan and its progress? For long-terms management plan the FFB projection, extraction rate for CPO and PK, cost production, forcast prices and others financial indicators was in place. This management plan is approved by top management due to develop by top management it self. The management plan for scheme smallholder of Etam Bersatu also included on that doc- ument. R 3.1.2 An annual replanting programme projected for a minimum of five years with yearly review, is available.

a. Is there a documented annual replanting programme projected for a minimum of five years? Remote audit result b. Is the progress of implementation monitored and recorded? From all the estate supply based (Cakra, Lestari, Berkat and Damai), only Lestari estate has plan for replanting. Plan Yes c. Is there evidence of a yearly review of the replanting programme? for replanting per year is presented below: No Lestari Cakra Berkat Damai Actual N.A Total replanting Year Estate Estate Estate Estate Replanting plan (ha) (ha) (ha) (ha) (ha) (ha) NCR No : - 2022 416 0 0 0 0 0 2023 1956 978 0 0 0 0 2024 2044 1022 0 0 0 0 2025 2000 1000 0 0 0 0 2026 1250 818 0 0 0 0

R & O 3.1.3 The unit of certification holds management reviews at planned intervals appropriate to the scale and nature of the activities undertaken.

a. Has the unit of certification conducted management review at planned intervals? Remote audit result b. Has the agenda included the following minimum items: The Cakra oil mill and estate supply based has conducted the management review periodically. The last update man- Yes i. Results of internal audits? agement review conducted on 13 Feb 2020 attended by 54 participants for all unit department in mill and estate. The No ii. Customer feedback? management review agenda discussed but not limited to internal audit result; status of preventif and corrective actions N.A iii. Process performance and product conformity? from external audit result; follow-up actions from previous management review result; changes that could affect the iv. Status of preventive and corrective actions? management system; and recommendations for improvement. The management review also complete with outcome NCR No : - v. Follow-up actions from management reviews? of management review, where the outcome was focusing on performance of each department, three monthly periodic vi. Changes that could affect the management system? monitoring on the problem addressed, procedure, company policy and system requirements. The minutes of man- vii. Recommendations for improvement? agement review meeting able to show by the company. c. When was the management review conducted? d. Is there minutes of meeting? Onsite verification result e. What are the outcome of the review? Based on-site verification all the estate under Cakra oil mill able to show the management review report. Interviewed f. Are the actions been implemented? with the estate manager and oil mill manager, the management review report was in place, no complaint from cus- tomer regarding product, the internal audit was performed by internal company auditor, and the non-conformity report from internal audit still in progress for correction and corrective action. 3.2 The unit of certification regularly monitors and reviews their economic, social and environmental performance and develops and implements action plans that allow demonstrable continuous improvement in key operations.

R & O 3.2.1 (C) The action plan for continuous improvement is implemented, based on consideration of the main social and environmental impacts and opportunities of the unit of certification.

a. Are there action plans for continual improvement for the following: Remote audit result i. Optimising the yield of the supply base. The continuous improvement implementation in the company (mill and estate) could showed from the implementation Yes ii. Reduction in use of pesticides (Criterion 7.2) of internal audit to identify whether the level of compliance is meet with the company standard and able to answer or No iii. Environmental impacts (Criteria 3.4, 7.6 and 7.7) able to show the progress of continuos improvement required by RSPO. Some of sampling as contoinuos improve- N.A iv. Waste reduction (Criterion 7.3) ment against to RSPO requirement as follow information below: v. Pollution and greenhouse gas (GHG) emissions (Criterion 7.10) 1. Optimising the yield off supply based; for this section all the estate Cakra mill supply based has high yield of pro- NCR No : - vi. Impacts on communities, workers and smallholders (Principle 6) duction performace; vii. Integrated management of HCV-HCS, peatland and other conservation areas (Criteria 7.7 and 7.12) 2. Redution of pesticide used; the estate supply base implemented the EFB mulching and land application as fertiliz- b. Are the action plans included the PIC for implementation and monitoring? er substitution to control and minimize the chemical fertilizers input. This will more explain in CR7.2. c. Are records of implementation of the action plan available? 3. Environmental impact; on this section the company mill and estate has the environmental impact assessment d. What are the examples and evidence of continual improvements that have been implemented? document approved by authority. As implementation, the mill and estate required to carry out management and monitoring twice a year and report to the authority per semester. Implementation of this report completely explain in CR3.4; CR7.6 and CR7.7. 4. Waste reduction; the mill and estate has waste management for organic waste and hazardous waste. Complete information on this matter served in CR7.3 5. Pollution and greenhouse gas (GHG); the mill and estate has identify the significant emission for GHG, and calcu- late using the RSPO GHG Calculation Version 4 to estimate the GHG emission. The GHG mitigation plan for sig- nificant GHG emission soruce able to showed and implemented. Complete explanation served in CR7.10 6. Impacts of communities, workers and smallholders; the mill and estate has collaboration program to increase the communities livelihood through the smallholder scheme program and receipt the communities FFB in the mill. While workers the company is commit to provide the workers all workers rights as required by regulation. Explana- tion on this served in principle 6. MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS 7. For the HCV, the company able to showed record of HCV monitoring and management implementation record. The RTE species are monitored well. Complete explanation on this served in CR7.7 and 7.12. The action plas of the continuous improvement was in internal audit result such as correction and corrective action for each non-conformity raised against to RSPO requirements. The record per explanantion above served in the related criteria.

Onsite verification result Based on-site verification in the HCV area of Kedaron estate, found the HCV area located set-aside with block no. 29A division 05 and 22A division 06, the signboard of HCV installed and clear inform the HCV status and HCV type with good condition. While for Berkat estate HCV area in block no. 005A division 01, block no. 013B division 02 and block no. 023 B divi- sion 05, based ground checking the HCV condition is maintained with clear demarcation between planted area and concervation area. The HCV signboard installed in the mainroad to inform very person that was HCV area and is not allowed to carry out any activity will damage the HCV area. R 3.2.2 As part of the monitoring and continuous improvement process, annual reports are submitted to the RSPO Secretariat using the RSPO metrics template.

a. Is the RSPO metrics template filled and completed accordingly? Remote audit result b. Who is responsible to fill the template? Is not applicable until further information from RSPO regarding metrics template. Yes c. Is the data traceable to the source of information? No N.A

NCR No : -

3.3 Operating procedures are appropriately documented, consistently implemented and monitored.

R 3.3.1 (C) Standard Operating Procedures (SOPs) for the unit of certification are in place.

a. Are the SOPs for mills and plantation documented? Remote audit result: b. Are the SOPs appropriate and adequately cover all estate and mill processes and activities? Provide examples of The mill and estates has Standard Operating Procedures (SOPs) that covers all aspects of oil palm planting and Yes SOPs established in the estate and mill management. The SOPs cover all estate operations such as Nursery Practice, Land Clearing, Preparation and No c. Are the SOPs dated and approved by the management? Planting, Soil Conservation and Terracing, Road Con-struction and Maintenance, Establishment and Maintenance of N.A d. Is a copy of the latest version of the SOP available on site and is it documented in an appropriate language? Legume Covers, Planting Density and Planting Technique, Palm Replacement During Immaturity and Supplying, Up- e. Are the SOPs made available at the appropriate location accessible by the workers? keep of Immature Oil Palms, Upkeep of Mature Oil Palms, Pests & Diseases, Manuring, EFB Application, Harvesting, NCR No : - f. Is there evidence that SOPs are implemented and understood by workers? Bunch Census and Palm Thinning. The Oil Mill has SOPs covering all mill operations such as FFB Grading, Sterilization Station, Press Station, Threshing Station, Oil Room, Kernel Plant, Laboratory, CPO & PK Despatch, Engine Room, Boiler Room, Electrical, Workshop as well as Raw and Boiler Water Treatment Plant.

O 3.3.2 A mechanism to check consistent implementation of procedures is in place.

a. What are the mechanisms established to check consistent implementation of procedures in the unit of certification? Onsite verification result b. Are the mechanisms implemented? In order to ensure consistent implementation of the SOPs among all levels of the workforce in the field. The following Yes mechanisms are periodic monitoring, inspection and internal audit to checking the implementation of the procedure. No Records of monitoring and any actions taken has maintained and available that seen on Report of Internal Audit. N.A

NCR No : -

R & O 3.3.3 Records of monitoring and any actions taken are maintained and available.

a. Are the following records maintained? Remote audit result: i. Measurements or results of internal control and monitoring activities In order to ensure consistent implementation of the SOPs among all levels of the workforce in the field. The following Yes ii. Records of corrective actions and improvement undertaken mechanisms are periodic monitoring, inspection and internal audit to checking the implementation of the procedure. No Records of monitoring and any actions taken has maintained and available that seen on Report of Internal Audit N.A conducted onJuly 10 , 2019. NCR No : - Onsite verification result Based on verification result interview with harvester and sprayer workers they able to mention how to work based on procedure requirements, what is allow and not allow during harvesting and spraying activity. The workers also men- tioned if prior to work, the morning briefing is conducted by division assistant to inform the workers what is the activity today, PPE checking, target and the company policy. 3.4 A comprehensive Social and Environmental Impact Assessment (SEIA) is undertaken prior to new plantings or operation, and a social and environmental management and monitoring plan is implemented and regularly updated in ongoing operations.

R & O 3.4.1 (C) In new plantings or operations including mills, an independent SEIA, undertaken through a participatory methodology involving the affected stakeholders and including the impacts of any smallholder/outgrower scheme, is documented.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. Is there any new plantings or operations, or expanding existing ones by the company? If yes, what is the size of the Remote audit result new development i.e. new planting area or operation or expansion? Within 3rd surveillance, no revision regarding EIA documents of the company. The EIA document assessment con- Yes b. Has an independent social and environmental impact assessment (SEIA) been documented for the new plantings or ducted by external consultant, and approved by Environmental Local Official Government of Kutai Kartanegara with No operations (i.e. existing planting)? approval no. 660.1/289/B.I.1/BLHD/VI/2011, issued dat on 13 Jun 2011, then renew due to impact assessment of re- N.A c. Are the impact assessments prepared by accredited independent experts? planting activity will start in 2022. This renewal of EIA documents approved by Environmental Local Official Govern- d. Are all environmental and social impact (positive and negative) adequately identified? ment of Kutai Kartanegara with approval no. P-660.2/077/DPMPTSP/IV.3/IL-AMDAL/11/2018, issued date on 1 Nov NCR No : - e. Is the SEIA undertaken based on the scope of operation 2018. The SIA assessment already information assessment from all activity in the company, from land clearing until f. Is the SEIA undertaken in a participatory manner, including the relevant affected stakeholders? production and transportation product. The environmental paramaters such as biological, physics and chemical is as- g. Is the SEIA assessment include and as a minimum : sessed. All the envrionmental potential impact build in metrics of environmental managemen and monitoring effort and i. Assessment of the impacts of all major planned activities, including land clearing, planting, replanting, pesticide periodically reported to local official government. and fertiliser use, mill operations, roads, drainage and irrigation systems and other infrastructure The company has SIA document assessment, conducted on May 2020 by internal. The SIA development process and ii. Assessment of the impacts on HCVs, biodiversity and RTE species, including beyond concession boundaries findings has documented and reported in the SIA document. Then, SIA document also covered all potential impacts and any measures for the conservation and/or enhancement of these factor, such as: iii. Assessment of potential effects on adjacent natural ecosystems of planned developments, including whether  Increased public educations around the company development or expansion will increase pressure on nearby natural ecosystems  The gap qualified labor needs iv. Identification of watercourses and wetlands and assessment of potential effects on hydrology and land subsid-  Migration of people into the company around area. ence of planned developments. Measures should be planned and implemented to maintain the quantity, quality  Changes livelihoods and access to water and land resources  Changes income v. Baseline soil surveys and topographic information, including the identification of steep terrain, marginal and  Financial institutions both formal and non-formal, including banks and cooperatives. fragile soils, areas prone to erosion, degradation, subsidence, and flooding  Social capital vi. Analysis of type of land to be used (forest, degraded forest, peatlands, cleared land, etc.)  Improved rural infrastructure vii. Assessment of land ownership and user rights viii. Assessment of current land use patterns  Health ix. Assessment of impacts on people’s amenity  Workplace safety x. Assess impacts on employment, employment opportunities or from changes of employment terms (including  Access and rights Welfare of workers/labour and women, children and vulnerable group in SIA document)  Economic livelihood xi. A cost-benefit analysis on social aspects  Traditional or customary rights owned by the local community xii. Assessment of potential social impacts on surrounding communities of a plantation, including an analysis of  Contributions to the local development. potential effects on livelihoods, and differential effects on women versus men, ethnic communities, and migrant There were evidences checked that impact assessment has been involved the affected parties/communities such as versus long-term residents and Contribution to the local development, including improvement of human re- landowners, and the people residing in villages around the company concession area. Based on information from the sources, local and customary communities public and SIA document, that participatory assessment carried out by using method of FGD with affected parties re- xiii. Assessment of salient risk of human rights violations lated. The FGD process done on 16-22 April 2020. xiv. Assessment of the impacts on all dimensions of food and water security including the right to adequate food, The assessment includes details of positive and negative social effects that may be caused by plantations and mills and monitoring food and water security for affected communities and documents participation of affected parties and local communities. During the assessment the company conduct- xv. Assessment of activities which may impact air quality or generate significant GHG emissions ed several consultation and communication with relevant stakeholders. All records of communication and public con- h. Are there schemed smallholders/outgrowers involved? sultation are available and Properly documented incorporated in the report. i. Are they considered and involved in the whole process of the SEIA? In the SIA document, positive and negative impacts of oil palm plantations and POM have been identified, including j. What are the main impacts affecting these smallholders/outgrowers? those of smallholders. k. Is the assessment involved consultation with the affected parties? Who are the affected parties? l. What are the main findings of the assessment? Onsite verification result m. Are the findings of the SEIA found any negative impacts? If yes, is there a management and monitoring plan devel- Based on verification both of documents above (EIA and SIA) available in place and accessisble, provided in local oped to mitigate the negative impacts? language (Bahasa). R 3.4.2 For the unit of certification, a SEIA is available and social and environmental management and monitoring plans have been developed with participation of affected stakeholders.

a. Is the SEIA management and monitoring plan developed with participation of affected stakeholders Remote audit result b. Is the above plan implemented? The SIA Action Plans for avoidance or mitigation of negative impacts and promotion of the positive ones as well as Yes c. Is there any documented record to outline the plan on mitigation, implementation and monitoring according to the monitoring of impacts, has been developed in consultation with the affected parties, stated in the document of SIA as No SEIA report? a matrix. There are any recommendations on the preparation Social Management Plan as social impact mitigation N.A plan. PT Rea Kaltim has had a Social Management Plan to avoid or mitigate negative impacts and positive promotion, and monitoring the impacts. Company also has Social management plan for 2020 and 2021. NCR No : - The review and plan identified for monitoring plan is based on participatory discussion with community representatives during SIA meeting 2020.

R & O 3.4.3 (C) The social and environmental management and monitoring plan is implemented, reviewed and updated regularly in a participatory way.

a. Is the review of the management and monitoring plan conducted regularly? How frequent was the review? Remote audit result b. Was the review done internally or externally? The SIA Action Plans for avoidance or mitigation of negative impacts and promotion of the positive ones as well as Yes c. Is the plan updated as necessary (i.e. in cases where the review has concluded that changes should be made to monitoring of impacts, has been developed in consultation with the affected parties, stated in the document of SIA as No current practices)? a matrix. There are any recommendations on the preparation Social Management Plan as social impact mitigation N.A d. Is there evidence that the review has been done in a participatory way? plan. PT Rea Kaltim has had a Social Management Plan to avoid or mitigate negative impacts and positive promotion, e. When the last was reviewed done? and monitoring the impacts. Company also has Social management plan for 2020 and 2021. NCR No : - f. Was the process recorded/documented? The review and plan identified for monitoring plan is based on participatory discussion with community representatives during SIA meeting 2020.

Onsite verification result The SIA Action Plans for avoidance or mitigation of negative impacts and promotion of the positive ones as well as monitoring of impacts, has been developed in consultation with the affected parties, stated in the document of SIA as a matrix. There are any recommendations on the preparation Social Management Plan as social impact mitigation plan. PT Rea Kaltim has had a Social Management Plan to avoid or mitigate negative impacts and positive promotion, and monitoring the impacts. Company also has Social management plan for 2020 and 2021. The review and plan identified for monitoring plan is based on participatory discussion with community representatives during SIA meeting 2020.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS 3.5 A system for managing human resources is in place

R 3.5.1 Employment procedures for recruitment, selection, hiring, promotion, retirement and termination are documented and made available to the workers and their representatives.

a. Are there SOPs for recruitment, selection, hiring, promotion, retirement and termination of workers established? Remote audit result: Please indicate the SOPs reference number Company has procedures regarding human resource aspects , eg : Yes b. Is the company explicitly stated the indiscriminatory policy during the recruitment selection, hiring and promotion - SOP recruitment and selection no.REA.BPO.HRD.RnS No process? - HR Manual Organization Development Chapter II (section 2.6 Promotion and Deloyment) N.A c. Are the SOPs communicated in appropriate languages and made available to the workers and their representa- - HR Manual indusrial Relation and Personel Administration Chapter V (section 5.6 Termiantion and Pension) tives? Information of employment arrangements and employment status per unit department served in table 8, section 2.7. NCR No : - d. What types of employment arrangements are there in the company? (E.g. contractual, outsourced, apprenticeships, direct hires, piecemeal basis, etc.)

O 3.5.2 Employment procedures are implemented and records are maintained

a. Are the employment procedures implemented? Onsite verification result b. Are records of implementation of the procedures been maintained? Company able to demonstrate the HR procedures impelementation for example: promotion on behalf Syahrul office Yes clerk (Damai) from KHT to monthly worker, Fadli estate mechanic (Berkat). All records kept in estates office. No N.A

NCR No : -

3.6 An occupational health and safety (H&S) plan is documented, effectively communicated and implemented.

R 3.6.1 (C) All operations are risk assessed to identify H&S issues. Mitigation plans and procedures are documented and implemented.

a. Is there a health and safety policy in place? Remote audit result b. Is there any SOP to conduct risk assessments of all its operations? Please indicate the reference number. Within the 3rd sruveillance audit date period, no revision regarding occupational health and safety of this company Yes c. Are risk assessments conducted for all company's operations, processes and activities where health and safety is (mill and estate). The OHS policy document was No.004/BOD_REA/P/II/2015 signoff by Board of Directors on 1 No an issue March 2015. The OSH Policy cover about compliance against to the OSH law and regulation, integration OSH system N.A d. Is there documented mitigation plan for the identified issues in the risk assessments? with company procedure, preventing and recording accidents, training and awareness, no drugs and alcohol, personal e. Is the risks assessment and the actions plan reviewed when accidents occurred to prevent further recurrence? protective equipment, emergency preparedness and response. The OSH Policy was written in Bahasa. NCR No : - f. Are accidents recorded? The company also has established procedure for risk identification and assessment for mill and estate, document g. Are all precautions attached to products properly observed and applied to the workers? No.REA.BPO.SHE.IBP Rev.01, issued on 25 May 2017. No revision on this procedure during 3rd surveillance audit. h. Are the workers aware of the risks associated with their work activities? While for risk identification and assessment (HIRADC – Hazard Identification Risk Assessment Determining Control) i. Is there plan included targets for improving occupational health and safety? was in place for mill and estate. This document update periodically or is needed refer to the accident or incident hap- pened in the mill and estate. The last update on this document was in Jan 2020. All the activity already coverage in this document. The HIRADC document consist of type of activity, potential risk, accident risk, risk control, applicable regulation relevant, initial risk assessment, determining control, risk assessment and follow-up action. The Cakra mill and estate has record all of accident for 2019 and 2020 until date of audit. This accident record complete with as- sessment of frequency rate and saverity rate. O 3.6.2 (C) The effectiveness of the H&S plan to address health and safety risks to people is monitored.

a. What are the evidences of implementation of the H&S plan? Onsite verification result b. Is the effectiveness of the health and safety plan monitored? The Kedaron estate has record of OHS plan for 2019 and 2020. The OHS work plan consist of type of activity, timeline Yes c. Is the health and safety plan made publicly available? per month, achievement target, and remarks. Based on evaluation OHS work implementation for 2019, the estate No d. Is there an action taken if targets are not achieved? showed all the work plan program is achieved. N.A e. Has the company identified the responsible person/persons to implement and monitor the H&S plan? f. Is adequate and appropriate protective equipment available to all workers at the place of work to cover all potentially The Kedaron estate has responsible person who dealing with OHS implementation. This person was qualified person NCR No : - hazardous operations, such as pesticide application, machine operations, and land preparation, harvesting, etc? based on OHS specialist certificate issued by Directorate General of Labour Inspection Development and Occupation- al Safety and Health, Ministry of Manpoer of The Republic of Indonesia, No.Reg. 68656/PK3/AJ/64/2019/P0 and No.Reg. 68650/PK3/AJ/64/2019/P0 issued date on 10 May 2019, valid until 10 May 2022. Based on-site verification to the division 03, block no. 3B (harvesting); division 03, block no. 1E (enricher), division 05, block no. 23G (sprayer – manual weeding), during interviwed and direct verification all workers able to explained re- garding PPE’s type they need, the PPE’s able to replace any time, and they worked with used complete PPE’s. Fur- thermore, the estate able to showed record of PPE”s distribution for 2019 to all workers example for sprayer workers in division V and division III.

The Berkat estate hasresponsible person regarding OHS implementation was appointed based on certificate decree issued by Directorate General of Labour Inspection Development and Occupational Safety and Health, Ministry of Manpoer of The Republic of Indonesia, No.Reg. 68647/PK3/AJ/64/2019/P0 and No.Reg. 68647/PK3/AJ/64/2019/P0 issued date on 10 May 2019, valid until 10 May 2022. The H&S management plan developed by the responsible per- son and OHS Committee. The H&S management plant already complete with information such as risk assessment evaluation, PPE’s monitoring stocks, knowledge training needs, shortbrief and skilss development, OHS inspection, emergency preparedness, first aid, and others. Based on-site verification to the division division 04, block no. 31A (en- richer) and division 01, block no. 7B (sprayer), during interviwed and direct verification all workers able to explained regarding PPE’s type they need, the PPE’s able to replace any time, and they worked with used complete PPE’s. Fur-

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS thermore, the estate able to showed record of PPE”s distribution for 2019 to all workers example for sprayer workers in division IV and division 01.

For Damai estate, the H&S plan was in place for 2019 and 2020. The H&S plan consist of information such as type of activity, timeline per month, target, and date of activity, achievement and remarks. The H&S plan coverage and but not limited to periodically meeting, risk assessment evaluation, PPE’s monitoring stocks, knowledge training needs, shortbrief and skilss development, OHS inspection, emergency preparedness, first aid and so on. Damai estate has assigned responsible person who handle OHS implementation. This person already have competency and approved by Directorate General of Labour Inspection Development and Occupational Safety and Health, Ministry of Manpoer of The Republic of Indonesia, based on No. Reg. 68651/PK3/AJ/64/2019/P0, valid until 10 May 2022. Based on-site verification to the division 03, block no. 15BC (sprayer) during interviwed and direct verification all work- ers able to explained regarding PPE’s type they need, the PPE’s able to replace any time, and they worked with used complete PPE’s.

Cakra estate The responsible person already have competency and approved by Directorate General of Labour Inspection Devel- opment and Occupational Safety and Health, Ministry of Manpoer of The Republic of Indonesia, based on No. Reg. 42038/PK3/AJ/64/2017/P0, valid until 22 Aug 2020.

Cakra oil mill The responsible person already have competency and approved by Directorate General of Labour Inspection Devel- opment and Occupational Safety and Health, Ministry of Manpoer of The Republic of Indonesia, based on No. Reg. 68649/PK3/AJ/64/2019/P0, valid until 10 May 2022, issued date 10 May 2019.

3.7 All staff, workers, Scheme smallholders, outgrowers and contract workers are appropriately trained.

R & O 3.7.1 (C) A documented programme that provides training is in place, which is accessible to all staff, workers, Scheme Smallholders and outgrowers, taking into account gender-specific needs, and which covers applicable aspects of the RSPO P&C, in a form they un- derstand, and which includes assessments of training. a. Is the company maintained a list of staff, workers, scheme smallholders, outgrowers and contract workers whom Remote and Oniste audit result training must be provided to? The company has a list of staff, workers, smallholders and contract workers who must be trained. The employees are Yes b. Is there a formal training programme in place that covers all aspects of the RSPO Principles and Criteria that in- planned in the 2020 training program. The training program includes the assessment of training needs, the implemen- No cludes : tation of training internally and externally. N.A i. Regular assessment of training needs of all staff, workers, smallholders and contract workers; The program has covered all aspects of RSPO principles and criteria such as training on OHS, HCV, pesticide han- ii. Training for workers on scheme smallholder and ourgrower plots; dling and management, environmental pollution prevention training and SCCS training, productivity and best man- NCR No : - iii. Documentation of all the training assessment needs, formal training conducted and the list of participants at- agement practice, relevant SOPs etc. Before creating a training program, the HR department and representatives of tending these formal training the plantations and factories compile identification of training needs. c. Who is responsible for the development of training programme, scheduling and the conduct of training? d. Are the training for workers cover, at minimum, the following: i. the health and environmental risks of pesticide exposure; ii. recognition of acute and long-term exposure symptoms including the most vulnerable groups (e.g. young work- ers, pregnant women); iii. ways to minimise exposure to workers and their families; iv. International and national instruments or regulations that protect workers’ health; v. Productivity and best management practice; vi. relevant SOPs e. Are all workers involved in the operation appropriately trained in safe working practices f. Are the training provided in a form understood by the workers? g. Are there assessment of training for the workers? Note to auditor : To interview staff, workers, smallholders and contract workers to verify that the implementation of the training programme and the effectiveness of the training R & O 3.7.2 Records of training are maintained, where appropriate on an individual basis.

a. Are documentation of all the training assessment needs, formal training conducted and the list of participants at- Remote and Oniste audit result tending these formal training been maintained? There is also some partial memorandum of personnel apointment list for training. Every employee, smallholders and Yes b. Are training records maintained for each employee, where appropriate? contrack workers has a track record of training that has been attended both internally and externally. There is also No documented form of training evaluation 2019. Realization of training program 2019 and 2020 participate by employee N.A and contractor. All documentation of implementation of training was maintained by Human Resources Departement include of certificate, list of participant and assessment after training. NCR No : -

O 3.7.3 Appropriate training is provided for personnel carrying out the tasks critical to the effective implementation of the Supply Chain Certification Standard (SCCS). Training is specific and relevant to the task(s) performed.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. Are there specific personnel carrying out tasks for effective implementation of the supply chain? Onsite verification result b. Are the job descriptions for each of the personnel identifed above defined and communicated? The mill has appointed person who responsible for implementation SCCS requirement. This person was qualified Yes c. Are there evidence that specific training was provided and relevant to the task performed? (trained) by internal who has RSPO trained. The last RSPO SCCS socialization carried out March 2020 attended by No d. When was the last training on SC conducted and to whom? 10 participants from all department unit. The socialization material was in place. Based on interviewed with the re- N.A e. Through interviews with the relevant personnel involved in the SC, are the persons knowledgeable and competent in sponsible person, he able to demonstrated the RSPO SCCS requirements. The decree letter regarding appointment implementing the supply chain procedures? responsible person clear mentioned responsibility of person incharge. NCR No : -

3.8 Supply chain requirements for mills R 3.8.1 (C) A mill is deemed to be Identity Preserved (IP) if the FFB used by the mill are sourced from plantation/ estates that are certified against the RSPO Principles and Criteria (RSPO P&C), or against the Group Certification scheme. Certification for CPO mills is nec- essary to verify the volumes and sources of certified FFB entering the mill, the implementation of any processing controls (for example, if physical separation is used), and volume sales of RSPO certified products. If a mill process certified and uncertified FFB without physically separating them, then only Module E is applicable. Note : Definition Identity Preserved Mill a. Are all FFBs sourced from certified estates within the unit of certification? Remote and On-site audit result b. Are there FFBs from other certified estates (not within the certified unit)? If yes, how do you confirm that the supply- The Cakra oil mill has record of FB certified sourced within the audit date period 27 Apr 2019 until 11 Aug 2020 (up- Yes ing estates are certified? date from remote + on-site) data audit. The Cakra mill also receipt FFB certified from others certified estate under Rea No c. How do you confirm that the mill only process certified FFB? Kaltim Plantation subsidiary also but not within certified unit. Information regarding FFB certified receipt within audit N.A d. Are there any FFB processed from non-certified sources? date period, as follow information below: e. Is the mill assure that certified PO is kept separate from non-certified PO and PO from other certified mills, including Estate name Quantity (MT) Percentage (%) NCR No : - during transport and storage? Lestari 1302.66 0.25 Cakra 112232.28 21.83 Berkat 152644.07 29.7 Damai 60404.02 11.75 KMS Kedaron 117512.46 22.86 Total 444095.49 86.39 The Cakra oil mill also receipt non-certiifed FFB from others estate which is not certified yet under Rea Kaltim Planta- tion subsidiary and from scheme smallholder, independent smallholder and outgrower. Details explanation regarding FFB receipt and process whethere certified and non-certified presented in Table 2 above. Due to Cakra oil mill implemented mass balance model (MB) for supply chain, the separation between certified and non-certified raw material handling is not applicable. The mill used mass balance report to control the volume of certi- fied and non-certified. R 3.8.2 (C) A mill is deemed to be MB if the mill process FFB from both RSPO certified & uncertified plantations/estates. A mill may be taking delivery of FFB from uncertified growers, in addition to those from its own and 3rd party certified supply base. In that scenario, the mill can claim only the volume of oil palm products produced from processing of the certified FFB as MB. Note : Definition Mass Balance Mill a. Are the certified and non-certified FFB been monitored? Remote audit result b. How is the monitoring of incoming certified and non-certified FFB been conducted? The Cakra oil mill is monitored between certified and non-certified raw material FFB from mass balance report per dai- Yes ly of FFB incoming or receipt by mill. Record of FFB supplier between certified and non-certified clear mentioned in the No FFB production record receipt by mill. N.A

NCR No : -

R 3.8.3 (C) The estimated tonnage of CPO and PK products that could potentially be produced by the certified mill shall be recorded by the certification body (CB) in the public summary of the P&C certification report. This figure represents the total volume of certified oil palm product (CPO and PK) that the certified mill is allowed to deliver in a year. The actual tonnage produced shall then be recorded in each subsequent annual surveillance report. Note : Explanation (Volume and Product Integrity) a. Has the projected certified volume for CPO and PK been appropriately determined by the mill? Remote audit result b. What was the basis for determining certified volume? The Cakra mill has projected of FFB receipt, CPO and PK production refer to budget plan (business management) for Yes c. For previous license volume, how was the actual production volume as compared to certified volume? the next year, refer to previous year production records as determining basis to company estimate the certified volume No production. The projected certified volume in 2019 for previous license (31-10-2018 until 14-08-2019) presented be- N.A low: Product name Amount (MT) NCR No : - FFB : 443856 CPO : 106525.44 PK : 22192.80 Then, compare with the actual production for previous year refer to mass balance report, was: Product name Amount (MT) FFB : 41563.43 CPO : 10014.41 PK : 11181.45 Refer to production above, the actual production for certified product does not exceed the volume stated in the certifi- cate. R & O 3.8.4 (C) The mill shall also meet all registration and reporting requirements for the appropriate supply chain through the RSPO IT platform Note : Explanation (Volume and Product Integrity)

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. What is all transactions has registered through RSPO IT platform for the appropriate supply chain? Remote audit result b. What is all transactions has reported through RSPO IT platform for the appropriate supply chain? The Cakra oil mill conducted transaction for certified product CSPO and CSPK through the RSPO Platform, and all the Yes transaction for has been registered in palm trace. As served in the section 3.8.3 above all transaction for previous li- No cense already complete with transaction ID number as evidence if the transaction registered in the palm trace. Other N.A evidence, the shipping announcement for all transaction whether previous license or current license (audit date period) also able showed by the mill. NCR No : -

Onsite verification result Based on-site document verification, all document regarding transaction for certified RSPO product registered in the RSPO IT Platform and able to verify and accessible.

R 3.8.5 (C) The mill shall have written procedures and/or work instructions equivalent to ensure the implementation of all elements of the applicable supply chain model specified. This shall include at minimum the following :  Complete and up to date procedures covering the implementation of all the elements of the supply chain model requirements.  Complete and up to date records and reports that demonstrate compliance with the supply chain model requirements (including training records)  Identification of the role 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 mill’s procedures for the imple- mentation of this standard  The mill shall have documented procedures for receiving and processing certified and non-certified FFBs including ensuring no contamination in the IP mill Note : Documented Procedure a. Are the following procedures established? : Remote audit result i. Receiving and processing of certified and non-certified FFB? The Cakra oil mill has established procedure regarding handling certified incoming raw material FFB and delivery of Yes ii. SOPs as required under the SCC requirements? certified product (CPO). Some of procedure such as: No iii. Training procedure? 1. Supply chain mechanism and traceability of sustainable product, document no.REA.BPO.SUS.MRP, issued N.A b. Are the procedures complete to cover the supply chain requirements? date on 25 May 2016, revision no.06, revised date on 07 Apr 2018, and effective date on 7 Apr 2018. This c. Has the organization identified relevant person(s) responsible for the implementation of the RSPO SC? procedure has established information regarding traceability, handling incoming raw material, communica- NCR No : - d. Are the roles, responsibility and authority been defined and are the personnel aware of their roles? tion and claim, handling out going product, retentation time for any document and records, and mass bal- e. Where the procedures are kept and are they accessible by the personnel involved in the SC implementation? ance. f. Are the personnel involved in the SC implementation knowledgeable and able to demonstrate awareness of the or- 2. Sustainability internal audit, document no.REA.BPO.SUS.IAS, issued date on 25 Oct 2016, revision no.04, ganization's procedures? revision date 10 Jan 2019, effective date on 10 Jan 2019. 3. Management review, document no.REA.BPO.SUS.RTM, issued date on 25 May 2016, revision no.01, revi- sion date 01 Mar 2019, effective date on 1 Mar 2019. 4. Discprapancy control/handling non-conformity, document no.REA.BPO.ENG.ICC, issued date on 25 May 2016, revision date no.-, and effective date on 25 Jun 2016. 5. Palm oil mill operation, document no.REA.BPO.ENG.PMO, issued date on 25 Aug 2017, revision date no.-, effective date on25 Sep 2017. On this procedure, also explained regarding conversion ratios (OER and KER) rate. The mill assigned person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements. As stated on procedure document No. REA.BPO.SUS.MRP, issued date on 25 May 2016, revision no.06, revised date on 07 Apr 2018, and effective date on 7 Apr 2018 regarding Supply Chain Mechanism and Traceability of Sustainable Product (RSPO and ISCC), on section 4 (Responsibilities). On this section explained clearly every person incharge regarding RSPO SCCS implementation in Cakra POM, since Mill Manager, Mill Office Administrator, Mill Assistant, Production Clerk, Dispatch Officer, Wighing Operator, Transport Department, Bulking Station, and so oon. If refer company procedure, all person in each working station they have re- sponsibiliy regarding to ensure and implemented the RSPO SCCS implementation. The important person who have authorized is Mill Manager refer to company procedure, section 4.2.1. As observed during audit, the management representative has able to demonstrate awareness of the organization’s procedures for the implementation of this standard. This responsible person already get supply chain training, where the training done by internal delivered by Sustainability Manager who has knowledge and qualified for RSPO SCC. Then, the training for all responsible person in the facility done on 18 Apr 2019 attended by 18 participants from all unit production department. R 3.8.6 (C)  The mill shall have a written procedure to conduct annual internal audit to determine whether the mill : a. Conforms to the requirements in the RSPO Supply Chain Certification Requirement for mills and the RSPO Role on Market Communications and Claims. b. Effectively implements and maintains the standard requirements within its organisation  Any non-conformities found as part of the internal audit shall be issued & required corrective action. The outcomes of the internal audits and all actions taken to correct non- conformities shall be subject to management review at least annually. The mill shall maintain the internal audit records and reports Note : Internal Audit a. Is there SOP for conducting internal audit? How regular is the internal audit? Remote audit result b. Has the internal audit assessed the organization conformance to the requirements in the RSPO Supply Chain Certi- As mentioned above, the internal audit procedure already in place. The procedure required in section 6.1.1 page 10 of Yes fication Standard and the RSPO Market Communications and Claims Documents? procedure, the internal audit carry out twice a year to check effectivity and efficiency of implementation for sustainabil- No c. When the internal audit was conducted and was the internal audit done by competent auditor(s)? tity scheme, quality management system and environmental management system. The last internal audit for semester N.A d. Are there non-conformities raised? If yes, has it been responded in a timely manner? II year 2019 conducted on 10 Jul 2019, with two (2) non-conformities were found. For this non-conformance, the facili- e. Are the outcomes of the internal audit and corrective actions of the non-conformities been reviewed in the manage- ty has follow up action to close the non-conformity. Record of CAR’s and evidence submitted also statement result is- NCR No : - ment review? sued by internal auditor regarding CAR’s submitted is available. The form of correction/corrective action provided in f. Are all the audit records and reports been maintained? form (REA.BPO.SUS.IAS-8/1-1/25-07-2016. This form is noncnformity report form with description is nonconformity g. Did the internal audit show that the organization effectively implements and maintains the standard requirements status, location found, standard references, auditee name, auditor name, nonconformity, root cause, correction and within its organization? corrective action, review/response of correction/corrective action taken, and approval. The result of this internal audit already became one of discussion agenda in the management review. From the summary of internal audit result, the internal auditor summarized is the facility has effort enough to maintain implementation of RSPO SCC requirements. R 3.8.7 (C) i. The mill shall verify and document the tonnage and sources of certified and the tonnage of non-certified FFBs received

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS ii. The mill shall inform the CB immediately if there is a projected overproduction of certified tonnage iii. The mill shall have a mechanism in place for handling non-conforming FFB and/or documents Note : Purchasing/Good In a. Is the mill conduct verification and document the tonnage and sources of certified and the tonnage of non-certified Remote audit result FFBs received? The Cakra oil mill has record of incoming raw material certified and non-certified. The Cakra oil mill has identified the Yes b. Where is it recorded? certified source, and non-certiifed source (please see table 2) in first section above. On that table, the facility has sep- No c. Is there overproduction? If yes, did the mill inform the CB? arate the certified and non-certified source. The certified source estate came from internal supply based i.e.: Berkat, N.A d. What is the mechanism in place for handling of non-conforming products? Cakra, Lestari, Damai and Kedaron estate. While non-certified came from uncertified unit under Rea Kaltim, scheme smallholder, and outgrowers. NCR No : - All incoming raw material whether certified and non-certified is recorded on the mass balance report excel sheet per date, per month and per year. Refer to 3.8.3 above, no overproduction found in the facility. The mill has procedure for handling non-conforming oil palm products and/or documents, i.e.: in company procedure document No.REA.BPO.ENG.ICC, issue date May 25, 2016, effective date on June 25, 2016, regarding discrapancy control in section 6.2 for control of discrapancy in recording of certified and noncertified raw material and product.

R 3.8.8 (C) The supplying mill shall ensure that the following minimum information for RSPO certified products is made available in document form. The Information shall be complete and can be presented either on a single document or across a range of documents issued for RSPO certified oil palm products (for example, delivery notes, shipping documents and specification documentation) :  The name and address of the buyer :  The name and address of the seller;  The loading or shipment / delivery date;  The date on which the documents were issued;  RSPO Supply chain certificate number;  A description of the product, including the applicable supply chain model (Identity Preserved or Mass Balance or the approved abbreviations);  The quantity of the products delivered;  Any related transport documentation;  A unique identification number; Note : Sales and goods out a. Is there any document accompanying the certified oil palm products delivery? Remote and On-site audit result b. On which document/documents does the mill put the supply chain model and the SCC certificate number? The Cakra oil mill has record of outgoing certified product to the certified buyer. Within the audit date period 27 Apr Yes c. Do all documents sampled meet the requirements of this clause? Verify the documents 2019 until 11 Aug 2020 (update from remote + on-site) data audit, total certified product sold was 3850 MT of CSPO No and 2845.52 MT of CSPK. All the transaction registered in the palm trace, as record below: N.A Transaction Product Transaction ID Date CSPO CSPK NCR No : - Remote audit TR-6b1b14be-91c1 07/04/2020 - 842.3 TR-231cc58d-1b90 10/02/2020 1450.17 - TR-d70b3b59-f278 22/11/2019 1800.31 - TR-d926a61b-7a51 17/09/2019 - 1114.89 TR-292f2dfe-a3b9 15/08/2019 - 888.33 TR-465ab785-ebd9 05/04/2020 600.06 - Total - 3850.54 2845.52 On-site audit TR-7e0f9541-4715 13/06/2020 1499.72 - TR-e37edc6b-8a51 13/05/2020 1448.06 - TR-108ad5fe-c05d 13/05/2020 1448.06 - TR-85a3432a-02e6 31/07/2020 - 1132.1 TR-dc2f714b-5848 31/05/2020 - 1067.1 TR-c23486fa-87d4 30/04/2020 - 1550.25 TR-09548cb2-1bc0 30/06/2020 - 1059.89 Total 4395.84 4809.34 Some example of transaction for certified sold already comply with RSPO SCC requirements, as sampling below: Document name Information Contract no. S-011/CPO/03/19 Contract date 12 Nov 2019 Buyer PT Karya Indah Alam Sejahtera Seller PT Rea Kaltim Plantations – Cakra Oil Mill Product name CSPO Amount (MT) 1800.31 RSPO SCC model MB Delivery order no. DO/CPO-098/11/2019 Delivery order date 12 Nov 2019 B/L no. 071/PGB/SMD/XI-19 B/L date 15 Nov 2019 Port of loading FOB Sei Meriam Port of discharge Gresik Transaction ID number TR-d70b3b59-f278 Transaction date 22 Nov 2019

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS Refer to information table above, the RSPO SCC minimum requirements regarding information document specification already comply.

R 3.8.9 (C) i. The mill shall not outsource its milling activities. In cases where the mill outsources activities to independent third parties (e.g. subcontractors for storage, transport or other outsourced activities), the mill holding certificate shall ensure that the independent third party com- plies with the requirements of this RSPO Supply Chain Certification. Note : Outsourcing Activities a. Are there outsourced activities to independent third parties? Please list down the outsourced activities Remote audit result b. Is there agreement in place with the third party service providers? Refer to the document verification, the facility used outsourced activities for CPO and CPKO transport from facility to Yes c. Is the agreement included the requirement that the independent third party complies with the requirements of the the jetty. The information if the outsourced activity presented below: No RSPO Supply Chain Certification Standard? Contact person and N.A No. Contractor name Document contract no. Type of activity d. Are there outsourced facilities that were deemed risky and visited? Address Bumdes Jaya Perdana village, 004/SPK/CTS/II/2020 Transporting of NCR No : - Makmur Abadi Kembang Janggut CPO/CPKO subdistrict, Kutai Kartanegara district, East Kalimantan province. Bumdes Tuana Se- Tuana Tuha village, 014/SPK/CTS/II/2020 Transporting of jahtera Kenohan subdistrict, CPO/CPKO Kutai Kartanegara district, East Kali- mantan province. Bumdes Kembang Kembang Janggut 016/SPK/CTS/II/2020 Transporting of Etam Jaya village, Kembang CPO/CPKO Janggut subdistrict, Kutai Kartanegara district, East Kali- mantan province. Bumdes Citra Pulau Pinang vil- 020/SPK/CTS/II/2020 Transporting of Pinang lage, Kembang CPO/CPKO Janggut subdistrict, Kutai Kartanegara district, East Kali- mantan province. Bumdes Pelangi Muai village, Kem- 022/SPK/CTS/II/2020 Transporting of Muai Bersatu bang Janggut sub- CPO/CPKO district, Kutai Kar- tanegara district, East Kalimantan province. PT Rastra Kreasi Jl. Stadion, No.22, 018/SPK/CTS/II/2020 Transporting of Buana RT 13, Loa Ipuh, CPO/CPKO Tenggarong, Kutai Kartanegara district, East Kalimantan province. The contract document available and able to show during the audit process. Based on contract document verification, the contract already informed the outsourced company will allow the CB carry out verification during the audit time to check and ensure the RSPO SCC implementation. Due to the MB model applied by the facility, and the outsourced activity is transportation only, the risk level is low, and no need to carry out verification.

R 3.8.9 (C) ii. The mill shall ensure the following : a. The mill has legal ownership of all input material to be included in outsourced processes; b. The mill has an agreement or contract covering the outsourced process with each contractor through a signed and enforceable agreement with the contractor. The onus is on the mill to ensure that certification bodies (CBs) has access to the outsourcing contractor or op- eration if an audit is deemed necessary; c. The mill has a documented control system with explicit procedures for the outsourced process which is communicated to the relevant contractor; d. The mill shall furthermore ensure (e.g. through contractual arrangements) that independent third parties engaged provide relevant access for duly accredited CBs to their respective operations, systems, and all information, when this is announced in advance; Note : Outsourcing Activities a. Is the agreement signed with independent third party legally enforceable? Remote audit result b. Is the legal ownership of the materials included in outsourced processes clearly defined in the agreement? As explain above, the contract document (agreement document) already in place, able to show during the audit pro- Yes c. Are these companies RSPO certified? If not, do they have to be verified? cess. The agreement document signoff by both of two parties (facility and contractor). The contract document infor- No d. Is there SOP for outsourced process been established and communicated to the relevant contractor? mation stated the outsource activity is for transportation only from facility storage tank to jetty. The facility also carried N.A e. Is there mechanism to ensure that outsourced activities are in compliance to RSPO SC requirements and facility’s out training/socialization to increase the contractor awareness regarding RSPO SCC requirements. The last socializa- Standard Operating Procedure (SOP)? tion conducted on 21 Jan 2020 attended by 12 participants from all contractor. The training material was SOP for con- NCR No : - f. Has the third party contractor maintained records and available to the CB during the audit? Is this requirement in- tractor, RSPO SCC requirements of MB, traceability product OHS. cluded in the agreement?

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS R 3.8.10 (C) The mill shall record the names and contact details of all contractors used for the physical handling of RSPO certified oil palm products Note : Outsourcing Activities a. Is there a list of contractors (used for the processing or physical handling of certified oil palm products) with names Remote audit result and contact details? Please refer to table above. Yes b. When the list was last updated? No N.A

NCR No : -

R & O 3.8.11 (C) The mill shall inform its CB in advance prior to conduct of its next audit of the names and contact details of any new contractor used for the physical handling of RSPO certified oil palm products Note : Outsourcing Activities a. Are there new contractors appointed by the company for the processing or physical handling of RSPO certified oil Remote audit result palm products? If yes, is the list of contractor been updated? The facility has mechanism to inform CB if any new contractor used. Based on document audit, no new contractor Yes b. Is there agreement in place? used by facility. The mechanism will inform the CB via email if any new contractors. List of contractor used please re- No fer to table above. N.A

Onsite verification result NCR No : - During onsite verification no new contractors in the organization.

R & O 3.8.12 (C) i. The mill shall maintain accurate, complete, up-to-date and accessible records and reports covering all aspects of this RSPO Supply Chain Certification Standard requirements Note : Record Keeping a. Is there accurate, complete, up-to-date and accessible records and reports covering all aspects of these RSPO Remote audit result Supply Chain Certification requirements? Based on document verification, the Cakra oil mill has established procedure regarding retention time document for Yes b. Who are responsible for maintaining the records? RSPO SCCS document no.REA.BPO.SUS.MRP, issued date on 25 May 2016, revision no.06, revised date on 07 Apr No 2018, and effective date on 7 Apr 2018, stated the retention time for RSPO SCC documentation will keep within two N.A (2) years. Based on audit, all the documentation since the incoming raw material handling until dispatch process in- cluding certified and non-certified product available and able to show during audit document verification. NCR No : -

Onsite verification result During onsite verification all the documents and records regarding RSPO SCC implementation is available and acces- sible in place, and maintained well. The document controler are responsible person to update and keep the all relevant documents and records.

R & O 3.8.12 (C) ii. Retention times for all records and reports shall be a minimum of two (2) years and shall comply with legal and regulatory requirements and be able to confirm the certified status of raw materials or products held in stock The organisation shall be able to provide the estimate volume of palm oil / palm kernel oil content (separate categories) in the RSPO certified oil palm product and keep an up to date record of the volume purchased (input) and claimed (output) over a period of twelve (12) months Note : Record Keeping Note for auditor : Records for the previous license period and the new license period needs to be verified a. What is the retention period, and is it complying with the legal and regulatory requirements? Remote audit result b. Are there records showing the FFB input and the products produce and sold by the mill available? The time retention for record keeping is two (2) years as mentioned above. Yes c. Is the organization able to confirm the certified status of raw materials or products in stock? Check PalmTrace & No Accounting system of certified products Onsite verification result N.A The organization able to confirm and show the certified raw materials and products in palm trace system. All transac- tion are registered into palm trace. NCR No : -

R & O 3.8.12 (C) iii. For IP module, the mill shall record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO and PK on a real-time basis iv. For MB module, the mill : a) shall record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO and PK on a real-time basis and / or three-monthly basis b) All volumes of certified CPO & PK that are delivered are deducted from the material accounting system according to conversion ratios stated by RSPO c) The mill can only deliver Mass Balance sales from a positive stock. Positive stock can include product ordered for delivery within three (3) months. However, a mill is allowed to sell short. (i.e.: product can be sold before it is in stock.) Note : D.5.1 & E.5.1 a. Remote audit result  For IP mill, has the record of certified FFB receipts and process, and CSPO and CSPK produced and sold The Cakra oil mill applied MB model, with three monthly basis evaluation. This is confiremed based on mass balance Yes been established on a real-time basis? report verification for 2019 and 2020 (until audit date period) the three monthly basis evaluation already carried out by No  For MB mill, what accounting system that is applied? facility. No minus stock per end of three month found per March 2020. N.A b. Are the delivered volume of CSPO and CSPK in accordance with the approved conversion ratios by RSPO c. If not, what are the ratios? Onsite verification result NCR No : - d. Does the mill sell short? The organization did not carried out the sell short. The three monthly basis of mass balance evaluation are imple- e. If yes, have they balanced the account within a period of three months? mented, and based on mass balance report verification no negative of certified product stock in the end of three monthly basis. The mill manager is required the production clerk to carried out an update per monthly to check and ensure the stock of certified raw material and products. R 3.8.13 (C) OER & KER shall be applied to provide a reliable estimate of the amount of certified CPO & PK from the associated inputs. Mill shall determine and set their own extraction rates which shall be based upon past experience, documented and applied consistently. Note : Conversion Factors

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. What was the conversion rate used for the estimation of certified volume of CSPO and CSPK? Remote audit result b. Is the conversion rate applied provide a reliable estimate for the amount of certified output available from the asso- The Cakra oil mill is applied actual extraction ratios for conversion rate as mentioned in the Palm oil mill operation, Yes ciated inputs? document no.REA.BPO.ENG.PMO, issued date on 25 Aug 2017, revision date no.-, and effective date on25 Sep No c. Is the conversion ratio periodical reviewed? 2017. On this procedure, also explained regarding conversion ratios (OER and KER) rate be measured based on la- N.A boratory test. Within the audit date period 27 Apr 2019 – 28 Apr 2020, the actual conversion rate for certified and non-certified as NCR No : - follow information below: Conversion ratios Product (MT) Total FFB processed (MT) (%) OER KER CPO PK 415956.66 24.20 4.95 100661.51 20589.85

Conversion ratios Product (MT) Total FFB processed (MT) (%) OER KER CPO PK 444095.49 24.20 4.95 107471.10 21982.73 Note: update until 8/11/2020 (on-site audit date)

R 3.8.14 (C) Extraction rates shall be updated periodically to ensure accuracy againt actual performance or industry average if appropriate. Note : Conversion Factors a. Was the conversion rate following the actual performance or industry average? Remote audit result Yes, please refer to information above. Yes No N.A

NCR No : -

R & O 3.8.15 (C) For IP module, The mill shall assure and verify through documented procedures and record keeping that the RSPO certified oil palm product is kept separated from non- certified oil palm product including during transport and storage to strive for 100% separation. Note : Processing a. For IP mill, is there SOP for managing the certified oil palm products separated from non-certified oil palm product Remote audit result including during transporation and storage (to strive for 100% separation)? The Cakra oil mill is applied MB model. Not applicable. Yes b. Are there documented procedures established to ensure no contamination during transport and storage for its No RSPO certified oil palm product from non-certified materials? Onsite verification result N.A

NCR No :

R & O 3.8.16 (C) i. Shipping Announcement in the RSPO IT platform shall be carried out by the mill when RSPO Certified product are sold as certified to refineries, chrusher & traders not more than three months after dispatch with the dispatch with the dispatch date being the Bill of Lading or the dispatch document date ii. Remove: RSPO certified volumes sold under different scheme or as conventional, or in case of underproduction, loss or damage shall be removed in the RSPO IT Platform. Note : Registration of Transaction a. Is the shipping announcement carried out in accordance with the internal SOP requirements? Remote and On-site audit result b. Is the confirmation from the buyer conducted in the RSPO IT Platform? The Cakra oil mill registered all transaction in the RSPO IT Platform (palmtrace). Per transaction ID, the shipping an- Yes c. Is tracing conducted at least annually? nouncement able to download and showed to the auditor during audit process. Total transaction recorded was: No d. Is volume sold under other scheme or conventional being remove from the certified volume? Transaction Product N.A Transaction ID Date CSPO CSPK Remote audit NCR No : - TR-6b1b14be-91c1 07/04/2020 - 842.3 TR-231cc58d-1b90 10/02/2020 1450.17 - TR-d70b3b59-f278 22/11/2019 1800.31 - TR-d926a61b-7a51 17/09/2019 - 1114.89 TR-292f2dfe-a3b9 15/08/2019 - 888.33 TR-465ab785-ebd9 05/04/2020 600.06 - Total - 3850.54 2845.52 On-site audit TR-7e0f9541-4715 13/06/2020 1499.72 - TR-e37edc6b-8a51 13/05/2020 1448.06 - TR-108ad5fe-c05d 13/05/2020 1448.06 - TR-85a3432a-02e6 31/07/2020 - 1132.1 TR-dc2f714b-5848 31/05/2020 - 1067.1 TR-c23486fa-87d4 30/04/2020 - 1550.25 TR-09548cb2-1bc0 30/06/2020 - 1059.89 Total 4395.84 4809.34 No conventional sold from facility. The facility has separated the raw material certified and product (FFB, CPO and PK) in the mass balance table per sustainability scheme applied in the facility (RSPO and ISCC). While for product CPO sold under ISCC was removed from RSPO palm trace.

Onsite verification result

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS Until the date of on-site audit 8/11/2020 no transaction for RSPO certified product in palm trace.

R & O 3.8.17 (C) The mill shall only make claims regarding the production of RSPO certified oil that are in compliance with the RSPO Rules on Market Communications and Claims. Note : Claims a. Is the mill making claims? If yes, has the claim following the RSPO Rules on Market Communications and Claims Remote audit result The facility Cakra oil mill has established procedure regarding supply chain mechanism and traceability of sustainable Yes product, document no.REA.BPO.SUS.MRP, issued date on 25 May 2016, revision no.06, revised date on 07 Apr No 2018, and effective date on 7 Apr 2018. This procedure has established information regarding traceability, handling in- N.A coming raw material, communication and claim, handling out going product, retentation time for any document and records, mass balance and communication and claims. The facility did not made any claims. The facility only made NCR No : - business communication, consumer communication and corporate communication through informed in the contract sales information regarding RSPO certificate number and RSPO SCC model applied.

Onsite verification result Based on-site verification the organization did not make any claims on their certified product sold.

Principle 4 : Respect Community and Human Right and Deliver Benefits

4.1 The unit of certification respects human rights, which includes respecting the rights of Human Rights Defenders R & O 4.1.1 (C) A policy to respect human rights, including prohibiting retaliation against Human Rights Defenders (HRD), is documented and communicated to all levels of the workforce, operations, supply chain and local communities and prohibits intimidation and harass- ment by the unit of certification and contracted services, including contracted security forces a. Is there a written policy or commitment made by the senior management on Human Rights including prohibiting re- Remote audit result taliation against Human Rights Defenders (HRD) or a stand alone policy to protect HRD? Decree No. 002 / BOD-REA / P / II / 2015 on Human Rights Policy REA Kaltim Group recognize their obligation to Yes b. Is the policy included the prohibition of intimidation and harassment by the unit of certification and contracted ser- respect and support human rights are internationally recognized include a clause regarding the protection of human No vices, including contracted security forces? rights defenders. It stated in the Bill of Human Rights and the ILO convention on principles and Rights at work. N.A c. How was the policy communicated to all levels of the workforce, operations, supply chain and local communities? In this policy, the management appreciate and support human rights such as: When was the last communication conducted? 1. Enforce its policy not to employ anyone underage. NCR No : d. What evidence is available to demonstrate that all levels of workforce, supply chain and local communities been in- 2. No forced or trafficked labour formed of the above? 3. No harassment, including harassment based on age, disability, ethnicity, gender, marital status, political e. Based on interview with the workers, supply chain and local communities who have been communicated, are they persuasion, race, religion or sexual orientation. aware of the policy? 4. No violence, the REA groups does not condone the use of violence by security personnel and will not use mercenaries and para militaries in its operations. 5. Freedom of association, respects the right of employees and contract workers to form or join trade unions and bargain collectively. 6. Equal opportunities 7. Protection of reproductive rights 8. Pay and conditions in line with regulations 9. FPIC, REA Group will respect the right of local communities to withhold consent to oil palm cultivation on land to which they have legal, customary or user rights. 10. Respect for land use rights 11. Conflict resolution

Onsite verification result Based on interview with workers, no indidcation if the company violation of the human rights. The company very commit on the human rights of the workers. O 4.1.2 The unit of certification does not instigate violence or use any form of harassment, including the use of mercenaries and paramilitaries in their operations a. Is there mercenaries and paramilitaries use in the operations of the company? If yes, what is the scope of their Onsite verification result work? Company does not using mercernaries and paramiliters for handling any conflict. Currently because covid 19 auditor Yes b. Does the interviews with the relevant stakeholders (workers and local communities) or online search reveal use of can not conduct direct communication interview with local communities and based on online search there is no conflict No violence by/in the unit of certification? issue at all estates. As interview eith sprayers at Cakra estate Block 64 B Div 03, for resolve conflict management us- N.A c. If there are reported cases or interviews reveal used of violence by/in the unit of certification, please verify with ing persuasive approach as priority. relevent stakeholders. NCR No : -

4.2 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all affected parties. O 4.2.1 (C) The mutually agreed system, open to all affected parties, resolves disputes in an effective, timely and appropriate manner, ensuring anonymity of complainants, HRD, community spokespersons and whistleblowers, where requested, without risk of reprisal or intimidation and follows the RSPO policy on respect for HRD

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. Is there a system in place to deal with complaints and grievances for all affected parties? Onsite verification result b. Does the system allow for the complainant to agree on the process of the grievance mechanism? The system, open to all affected parties, to resolve disputes in an effective, timely and appropriate manner, ensuring Yes c. Does the system allow for the protection of the anonymity of the complainant if requested? anonymity of complainants and whistleblowers, where requested has been established as recorded on documents No d. How is a complaint or grievance investigated, addressed and resolved? bellow: N.A e. Is the system effective to ensure complaints or grievances are addressed or resolved in an effective, timely and ap- 1. SOP No. REA.EP.002 , July 22nd 2005. In point 6.3.3 Communication with other external stakeholders, propriate manner? mentioned: NCR No : - f. Is there a non-retaliation or non-reprisal policy that protects complainants or whistle-blowers? - Anyone who receives a complaint or a request for environmental information from (internal-external) g. Does the complainant know that his/her anonymity will be protected if requested? interested parties should forward it to the General Affairs manager. h. Where a resolution is not found mutually, is there a process for complaints to be brought to the next level e.g. RSPO - GA Staff section records all complaints and requests for information in the list of communications from Complaints System? (internal-external) interested parties. 2. Company also has procedure document no.REA.BPO.DVA.PKE issued on July 01, 2015 about handling grievence for external. This procedure also explained about conflict resolution with involve the affected par- ties for participatory mapping and allow for mediators if they are deemed unresolved. 3. Human Rights Policy No. 002/BOD_REA/P/II/2015. This policy giving guarantees the confidentiality / anonymity following the reporting as well as external and internal complaints handling. REA Group will protect the anonymity of complaints, whistleblowers and individuals who chose to assist the company in enforcing its policies and management has chosen the officer responsible for handling complaints from outsiders Smallholder and comdev Assistant. R 4.2.2 Procedures are in place to ensure that the system is understood by the affected parties, including by illiterate parties. a. Are there procedures to ensure the above system is understood by the affected parties, including the illiterate par- Remote audit result: ties? The procedure is understood by affected parties, it can be proved by example below related complaint from stake- Yes b. How the system was made known and communicated to all parties including Illiterate parties? When was the last holder (local community). This procedure already disseminated to stakeholders on April 20-21,2020 (local leader, No communication been carried out? communitties etc) for Pulau Pinang and Bukit Lawang community village and etc. N.A c. Is there evidence that the system is known/understood by all parties including the illiterate parties? NCR No : -

R & O 4.2.3 The unit of certification keeps parties to a grievance informed of its progress, including against agreed timeframe and the outcome is available and communicated to relevant stakeholders. a. Is the complaints or grievance resolution process documented? Remote and Onsite audit result: b. Does the grievance mechanism requires the company to keep parties informed of its progress against an agreed Company has record of incoming letter response from stakeholder. Incoming mail from internal and external was Yes timeframe? accepted by central office by PT Rea Kaltim Plantations in General Affair (GA), then it was distributed by relevant No c. Is the progress of the resolution process been informed to the parties to a grievance? party, as seen on example below : N.A d. Are outcomes or decisions communicated to the parties? Complaint on behalf Rasmi Supardi (Permanent-Harvester) on February 01, 2020 regarding currently he has not receive BPJS card and in kind benefitfrom company such riceallowance for wife children, respon from management NCR No : - inform to HR regarding new employee and its allowance for BPJS and permanent employee benefits.

R & O 4.2.4 The conflict resolution mechanism includes the option of access to independent legal and technical advice, the ability for complainants to choose individuals or groups to support them and/or act as observers, as well as the option of a third-party mediator. Note: Auditor need to interview with the grievance parties to determine the process. a. Does the conflict mechanism include the option of access to independent legal and technical advice, the the ability Remote and Onsite audit result: for complainants to choose individuals or groups to support them and/or act as observers, as well as the option of a The system, open to all affected parties, to resolve disputes in an effective, timely and appropriate manner, ensuring Yes third-party mediator? anonymity of complainants and whistleblowers, where requested has been established as recorded on documents No b. Has there been a case of the above occurred? If yes, what is the outcome? bellow: N.A 1. SOP No. REA.EP.002 , July 22nd 2005. In point 6.3.3 Communication with other external stakeholders, mentioned: NCR No : - Anyone who receives a complaint or a request for environmental information from (internal-external) interested parties should forward it to the General Affairs manager. - GA Staff section records all complaints and requests for information in the list of communications from (internal- external) interested parties. 2. Company also has procedure document no. REA.BPO.DVA.PKE issued on July 01, 2015 about handling grievence for external. This procedure also explained about conflict resolution with involve the affected parties for participatory mapping and allow for mediators if they are deemed unresolved. 3. Human Rights Policy No. 002/BOD_REA/P/II/2015. This policy giving guarantees the confidentiality / anonymity following the reporting as well as external and internal complaints handling. REA Group will protect the anonymity of complaints, whistleblowers and individuals who chose to assist the company in enforcing its policies and management has chosen the officer responsible for handling complaints from outsiders Smallholder and comdev Assistant. 4.3 The unit of certification contributes to local sustainable development as agreed by local communities.

O 4.3.1 Contributions to community development that are based on the results of consultation with local communities are demonstrated. a. Have the local development needs been identified in consultation with local communities? Onsite verification result b. Are there any contributions made to the local development? If yes, are they in accordance with what have been The management of PT Rea Kaltim has strong commitment to contribute to community development and documented Yes agreed during the consultation? in Quality, Safety and Health Environmental, for Sustainable Policy. The Social Impact Assessment Report was No issued. The activities planned were varied, such as socialization of shareholders program for the locals, aids for local N.A teachers, free medical treatment for the locals, making a well for locals, etc. several records related contribution to local development, such as: NCR No : - - Donation for the construction of a water canal for integrated farming at Senyiur Village on 29 July 2019. MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS - Donation for the construction of PUSKESMAS/Medical Centre in Muara Ancalong Sub District, on 22 August 2019.

4.4 Use of the land for oil palm does not diminish the legal, customary or user rights of other users without their free, prior and informed consent. R 4.4.1 (C) Documents showing legal ownership or lease, or authorised use of customary land authorised by customary landowners through a Free, Prior and Informed Consent (FPIC) process. Documents related to the history of land tenure and the actual legal or cus- tomary use of the land are available. a. Are there documents showing legal ownership or lease of the land available? (e.g. land titles, lease documents) Remote audit result: b. Is there legitimate claim from the stakeholders? The Cakra POM and their supply based have demonstrated legal ownership of their land by having legal land titles to Yes c. Has the claim been identified and assessed through the FPIC process? the land in form of land use right (Hak Guna Usaha). Some land use rights was covered Cakra POM and their supply No d. Are there documents showing history of land tenure available? (e.g. legal documents showing land status change, based i.e : N.A SIA and EIA reports, HCV assessment reports) 1. Land use right (HGU) certificate No.01 dated 10 January 1998 with basic of registration is decision letter e. Who was the previous land owner of the unit of certification? from head of National Land Agency No.154/HGU/BPN/97 dated 30 December 1997 valid for 30 years (until NCR No : RSPO03243 9 January 2028) for areas of 12,924 ha located in Kelekat village, Kembang Janggut Sub District, Kutai Dis- trict. Measurement letter No. 18/98 come from cadastral map No.019/1997 dated on 16 June 1997. Decision letter from the head of National Land Agency (BPN) No.154/HGU/BPN/97 has been available. 2. Land use right (HGU) certificate No.02 dated 26 August 1999 with basic of registration is decision letter from head of National Land Agency No.48/HGU/BPN/99 dated 3 June 1999 valid for 30 years (until 24 August 2029) for areas of 3,408 ha located in Long Bleh Halok village, Kembang Janggut Sub District, Kutai District. Measurement letter No. 01/99 (NIB: 16.03.18.07.00002) come from cadastral map No.31/1997 dated De- cember 1997. Decision letter from the head of National Land Agency (BPN) No.48/HGU/BPN/99 has been available. 3. Land use right (HGU) certificate No.03 dated 6 September 1995 with basic of registration is decision letter from head of National Land Agency No.47/HGU/BPN/95 dated 27 July 1995 valid for 30 years (until 31 De- cember 2025) for areas of 4,552 ha located in Long Beleh village, Kembang Janggut Sub District, Kutai Dis- trict. Measurement letter No. 2640/95 come from cadastral map No.30/1994 dated 19 October 1994. Deci- sion letter from the head of National Land Agency (BPN) No.47/HGU/BPN/95 has been available. All the legal use rights document is available in place and could accessible. Information the land use rights for Kedaron estate presented below: Total area Estate Decree No. Certificate No. Validation (ha/m) Kedaron 6/HGU/BPN RI/2011 145;Desa Senyiur 1,459.20 Ha 19 February 2046 146;Desa Senyiur 847.47 Ha 19 February 2046 147;Desa Senyiur 5,014.48 Ha 19 February 2046 It has been available documentation of compensation, process and outcome of any negotiated agreements with evi- dence of the involvement of the affected party through the FPIC process. Records of land disputes and settlement processes as follows: Identity cultivators, land area under cultivation, a notice that the land acquisition team PT REA Kaltim plantation will do the acquisition cultivated land. However, based on the field observation, it was identified that the company had planted outside the HGU certificate map at Block 47 D Berkat Estate and Block 25 C-52 B-C Cakra Estate, HGU No. 177 and 178 in 1998.It raised non conformity to this condition. The previous land ownership record served in the appendix 6 below. O 4.4.2 Copies of documents evidencing agreement-making processes and negotiated agreements detailing the FPIC process are available and include : a) Evidence that a plan has been developed through consultation and discussion in good faith with all affected groups in the communities, with particular assurance that vulnerable, minorities’ and gender groups are consulted, and that information has been provided to all af- fected groups, including information on the steps that are taken to involve them in decision making b) Evidence that the unit of certification has respected communities’ decisions to give or withhold their consent to the operation at the time that these decisions were taken c) Evidence that the legal, economic, environmental and social implications of 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 unit of certification’s title, concession or lease on the land a. Are copies of negotiated agreements with affected parties available? Onsite verification result b. Is there evidence that the agreement was established through a proper FPIC process? Record of land compensation records from 1995- 2016 about 9507,12 Ha. An example compensation records for AM, Yes c. Does the agreement contain the following : who has land of 0.60 Ha located in field No.14CD. The record consist of receipt of payment (with signoff from No i. An action plan developed through consultation with all affected parties, is inclusive and evidence that members compensated man); minutes of land compensation payments dated on 04 August 2011 complete with signoff and N.A of affected parties are well informed and involved in the decision making process witnesses present, map of compensated location . ii. Evidence of options to give or withhold consent for development PT. KMS able to evidences the records of compensation at HGU area for personal owwners about 156.94 ha, also NCR No : - iii. Evidence that members of the affected communities understand and accept the implication involved in permit- company able to show compensation plan yar 2020 for 15 land owners about 117.04 Ha and meeting record with af- ting/rejecting oil palm development on their land (E.g.: legal Status, social, environmental, economic) fected parties without coercion as evidence. iv. Evidence that the negotiated agreement was entered voluntarily without coercion by all parties v. Evidence that adequate time was given for customary decision making and iterative negotiations vi. Clause which states that the negotiated agreement is legally binding R 4.4.3 (C) Maps of an appropriate scale showing the extent of recognised legal, customary or user rights are developed through participatory mapping involving affected parties (including neighbouring communities where applicable, and relevant authorities). Note to auditor : Actual ground verification showing the accuracy of the dispute map should be conducted a. Is there a map of the extent of legal, customary or user rights? Is this map of appropriate scale? Remote audit result: b. Was the map produced through participatory mapping involving affected parties (including neighbouring communi- Company able to demonstrate the maps showing the location of stakeholder areas inside company areas, the broad Yes ties where applicable, and relevant authorities)? legal rights, customary right or the right to use the recognized parties. No c. Are the maps accepted by the relevant communities? The company has shown evidences such as: N.A 1. Map of claimers identification location in four (4) estate with scale 1:35,000 whereas the “red colour” as claimers identification. The map also informed name of claimers. NCR No :

MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS 2. Record of participatory mapping with claimers together. The company has evidences 9 minutes of participatory mapping records completed with information of involved of claim-ers in participatory mapping process, with evidenced in signoff from claimers.

O 4.4.4 All relevant information is available in appropriate forms and languages, including assessments of impacts, proposed benefit sharing, and legal arrangements a. Is there evidence that all the information (maps, agreement, records, impact assessment, and benefit sharing and Onsite verification result legal arrangements) is available in appropriate forms and languages, understood and accessible to affected parties? Companies able to evidence records of meetings with landowners for land acquisition for oil palm cultivation along with Yes an attached map of land to be compensated., example : record of ground checking and measurement of land which No claimed by villagers “USH” about 0.04 Ha at Damai Estate on July 29, 2019. N.A

NCR No :

O 4.4.5 (C) Evidence is available to show that communities are represented through institutions or representatives of their own choosing, including by legal counsel if they so choose. a. Who is the representative of the community in the negotiation process? Onsite verification result b. Is the representative aappointed by the community? In the negotiation process the community generally appoints a village head as a representative in the negotiation pro- Yes c. Is the record of appointment to represent the community available and shared with the affected parties? cess for land acquisition in the company's HGU or conduct personal represent, mostly for negotiations process con- No ducted by the land owners. N.A

NCR No :

O 4.4.6 There is evidence that implementation of agreements negotiated through FPIC is annually reviewed in consultation with affected parties. Note to auditor : interviews with affected parties to be conducted to verify the occurrence of the process a. Is there evidence that the implementation of agreements negotiated through FPIC is annually reviewed in consulta- Onsite verification result tion with affected parties? Company does not conducting the annual review for FPIC and agreement for compensation, because all negotiation Yes b. When the reviewed was conducted? has beeb agreed and stil waiting for payment process by company. No N.A

NCR No :

4.5 No new plantings are established on local peoples’ land where it can be demonstrated that there are legal, customary or user rights, without their FPIC. This is dealt with through a documented system that enables these and other stakeholders to express their views through their own representative institutions. O 4.5.1 (C) Documents showing identification and assessment of demonstrable legal, customary and user rights are available. a. What are the documents showing identification of legal, customary and user rights? Onsite verification result b. Does the SEIA include the identification and assessment of legal, customary and user rights of the area? The company has SEIA document assessment, known as AMDAL. Checking into these documents found that the so- Yes cial aspects only cover external impacts such as business and work opportunities for local community. Interview with No company management found that management officers has conducted special Social impact assessments in October N.A 2019. NCR No :

O 4.5.2 (C) FPIC is obtained for all oil palm development through a comprehensive process, including in particular, full respect for their legal and customary rights to the territories, lands and resources via local communities’ own representative institutions, with all the rele- vant information and documents made available, with option of resourced access to independent advice through a documented, long-term and two-way process of consultation and negotiation. a. Is comprehensive FPIC process carried out for all oil palm development including in particular, full respect for their Onsite verification result legal and customary rights to the territories, lands and resources via local communities’ own representative institu- The company provide adequate evidence that affected local peoples understand they have the right to say ‘no’ to op- Yes tions? erations planned on their lands before and during initial discussions, during the stage information gathering and asso- No b. What evidences are available to support (a)? ciated consultations, during negotiations, and up until an agreement with the grower/miller is signed and ratified by N.A these local peoples. Company has showed land acquisition records, and each record has completed with maps (which acknowledged by previous land owners, representatives and witnesses), such as evidence below: NCR No : 1. List of Previous land Owner inside PT KMS HGU that has been receiving compensation 2011-2012, consist of 24 persons (groups), total 156.94 ha. The list developed and signed by Formature Team (Abd Rasyid and Sholehudin). 2. Land Compensation Calculation agreement, consist of Land compensation for 7321 Ha, @IDR 500.000/Ha; 3. Example of Land compensation records on behalf IDM, area 5.9 Ha at Block 32 BD dated December 4, 2019 Kedaron Estate. O 4.5.3 Evidence is available that affected local peoples understand they have the right to say ‘no’ to operations planned on their lands before and during initial discussions, during the stage of information gathering and associated consultations, during negotiations, and up until an agreement with the unit of certification is signed and ratified by these local peoples. Negotiated agreements should be non-coercive and entered into voluntarily and carried out prior to new operations. a. Has it been communicated to the community that they have the right to say 'no' to the proposed development at all Onsite verification result stages, up until the agreement with company is signed? What evidence was sighted? The company provie adequate evidence that affected local peoples understand they have the right to say ‘no’ to oper- Yes b. Is there evidence to demonstrate that the consent/agreement has been given prior to new operations? ations planned on their lands before and during initial discussions, during the stage information gathering and associ- No c. Is the negotiated agreements made without coercion and entered into voluntarily and carried out prior to new opera- ated consultations, during negotiations, and up until an agreement with the grower/miller is signed and ratified by N.A tions? If yes, what documents to support this? these local peoples. Company has showed land acquisition records, and each record has completed with maps (which acknowledged by previous land owners, representatives and witnesses), such as evidence below: NCR No : 1. List of Previous land Owner inside PT KMS HGU that has been receiving compensation 2011-2012, consist of 24 persons (groups), total 156.94 ha. The list developed and signed by Formature Team (Abd Rasyid and Sholehudin). 2. Land Compensation Calculation agreement, consist of Land compensation for 7321 Ha, @IDR 500.000/Ha; 3. Example of Land compensation records on behalf IDM, area 5.9 Ha at Block 32 BD dated December 4, 2019 Kedaron Estate. MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS O 4.5.4 To ensure local food and water security, as part of the FPIC process, participatory SEIA and participatory land-use planning with local peoples, the full range of food and water provisioning options are considered. There is transparency of the land allocation pro- cess. a. Has the company conducted a participatory SEIA and participatory land-use planning with local peoples prior to new Onsite verification result planting? During the FPIC process, the local community able to provide their daily needs. They did not need the land allocation Yes b. During the process, has the impact on food and water security for local people, full range of food and water provi- for food crops and water provisioning as substitute. No sioning options identified, discussed and agreed with the local people? N.A c. Are there any measures proposed for implementation in b, and are these documented? d. Is there transparency of the land allocation process? NCR No :

O 4.5.5 Evidence is available that the affected communities and rights holders have had the option to access to information and advice that is independent of the project proponent, concerning the legal, economic, environmental and social implications of the proposed op- erations on their lands. a. What are the records to show that the community and rights holders have freedom to access information and inde- Onsite verification result pendent advisor(s) concerning the legal, economic, environmental and social implications of the proposed opera- Company able to evidences that FPIC or acquisition process not using coercion and communitties free to appointed Yes tions on their lands? the spokesman or representatives such Village Head or represent themselves (land owners) during negotiation pro- No cess. N.A

NCR No :

O 4.5.6 Evidence is available that the communities (or their representatives) gave consent to the initial planning phases of the operations prior to the issuance of a new concession or land title to the operator. a. Did the communities (or their representatives) give consent to the initial planning phases of the operations prior to Onsite verification result the new issuance of a concession or land title? The company provie adequate evidence that affected local peoples understand they have the right to say ‘no’ to oper- Yes b. What evidences were sighted for (a) above? ations planned on their lands before and during initial discussions, during the stage information gathering and associ- No ated consultations, during negotiations, and up until an agreement with the grower/miller is signed and ratified by N.A these local peoples. Company has showed land acquisition records, and each record has completed with maps (which acknowledged by previous land owners, representatives and witnesses), such as evidence below: NCR No : 1. List of Previous land Owner inside PT KMS HGU that has been receiving compensation 2011-2012, consist of 24 persons (groups), total 156.94 ha. The list developed and signed by Formature Team (Abd Rasyid and Sholehudin). 2. Land Compensation Calculation agreement, consist of Land compensation for 7321 Ha, @IDR 500.000/Ha; 3. Example of Land compensation records: a) Declaration Letter as Land User; b) Land Measurements Reports; c) Land Measurement and compensation calculation notes; d) Declaration of Land User Rights Submission to PT KMS; e) Compassion Payment Notes etc. O 4.5.7 New lands will not be acquired for plantations and mills after 15 November 2018 as a result of recent (2005 or later) expropriations in the national interest without consent (eminent domain), except in cases of smallholders benefitting from agrarian reform or anti- drug programmes. a. Is there any new land acquired after 15/11/2018 for plantations and mills? Onsite verification result b. Have the local communities consented and/or compensated prior to acquisition of the land? Company has conducted the FPIC process for new planting area. There is example for land compensation records on Yes behalf IDM, area 5.9 Ha at Block 32 BD dated December 4, 2019 Kedaron Estate. Land owners was accepted the No compensation price and there was no reclaimers again on that land. N.A

NCR No :

O 4.5.8 (C) New lands are not acquired in areas inhabited by communities in voluntary isolation. Note to auditor : There should be direct verification of above with the local communities a. Is there any community in voluntary isolation being identified? Onsite verification result b. Is there any new land aquired in area with communities in voluntary isolation? During onsite audit, there is no new land acquired in areas inhabited by communities in voluntary isolation. Auditor Yes conducted field at visit to new acquried area, and there is no local community settlement. During covid -19 auditor can No not interview local community and not available while contact by phone. N.A

NCR No :

4.6 Any negotiations concerning compensation for loss of legal, customary or user rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institu- tions. O 4.6.1 (C) A mutually agreed procedure for identifying legal, customary or user rights, and a procedure for identifying people entitled to compensation, is in place. Note to auditor : There should be direct verification of above with the affected parties a. Is there documented system in place for identifying legal, customary or user rights, and a procedure for identifying Onsite verification result people entitled to compensation? The company hold SOP “Land Acquisition Oil Palm Plantations” No. SOP Rev. 0, July 1st 2009. But, this SOP does Yes b. Is the documented system agreed by the affected parties? not specifically address issue of indigenous peoples, local communities and other stakeholders to express their views No through their own representative institutions during negotiation for compensations. A newly prepared draft of SOP, N.A No. REA.BPO.DCA.NLC Issue No. 01, dated February 3rd 2020—which is comply with the above requirement. NCR No :

O 4.6.2 (C) A mutually agreed procedure for calculating and distributing fair and gender-equal compensation (monetary or otherwise) is established and implemented, monitored and evaluated in a participatory way, and corrective actions taken as a result of this evalua- tion. a. Does the company have a documented system in place to calculate and distribute fair and gender-equal compensa- Onsite verification result tion (monetary or otherwise)? Company has SOP Oil Palm Plantation Land Acquisition No. Rev 0 of 2009, SOP was prepared from the process of Yes b. Is the documented system agreed by the affected parties socialization, identification of land ownership, land inventory, land measurement, land mapping, creation of land ad- No c. Does the system include participative monitoring and evaluation with the affected parties and the corrective action ministration, land payment and archiving of documents of land acquisition. N.A was taken into consideration? Related to aspects of gender rights, land rights both migrant communities and indigenous peoples are cover by Na- tional Law (UU Pokok Agraria No. 5/1960) as legal considerations in procedure and it stated in Companies Human NCR No : Right Policy. Procedure on land compensation is in place and it details the Free Prior Informed Consent (FPIC) process. The pro- MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS cess of handling Land Claim is documented with maps together with negotiation letter and with the amount agreed (Proses Penanganan Klaim Lahan). Company has SOP of Land Acquisition showing flow chart to make a negotiation to resolve any land conflict. All persons involved have received compensation agreed upon signing the agreement with the company. Company has procedure to develop of responsible new palm plantation No. REA.BPO.SUS.NDA on May 25, 2016. The purpose of procedure is to ensure any new land was acquired by Rea Kaltim Group, developed in responsible way in accordance with sustainable standard of company commitment. In this procedure, it was explained that land acquisition through land acquisition procedure published on July 1, 2009 and procedure of Free Prior Informed Con- sent (FPIC). O 4.6.3 Evidence is available that equal opportunities are provided to both men and women to hold land titles for small holdings. a. What are the evidence that demonstrates equal opportunities were provided to both men and woman to hold land ti- Onsite verification result tles for smallholdings? The company paid the compensation to the land owner or the claimants irrespective of the gender. Both sexes are of Yes equal opportunity should they have a legitimate claim to the land. Review to the record of land compensation, for ex- No ample at 2014 the company compensate a piece of land (4.23 Ha) belong to SNH (women land owner). Although N.A some women were spotted in the record however, their number were very small due to local custom. NCR No :

O 4.6.4 The process and outcomes of any negotiated agreements, compensation and payments are documented, with evidence of the participation of affected parties, and made publicly available to them. a. Is the process and outcome of any compensation claims documented and made publicly available to the affected Onsite verification result parties? The company provide adequate evidence that affected local peoples understand they have the right to say ‘no’ to op- Yes b. What evidence was sighted for (a) above and was it done with the participation of affected parties? erations planned on their lands before and during initial discussions, during the stage information gathering and asso- No ciated consultations, during negotiations, and up until an agreement with the grower/miller is signed and ratified by N.A these local peoples. Company has showed land acquisition records, and each record has completed with maps. As example: Land compensation record of Edy Suparwin at block 6 BCD (8.1 Ha) on June 15, 2020. NCR No :

4.7 Where it can be demonstrated that local peoples have legal, customary or user rights, they are compensated for any agreed land acquisitions and relinquishment of rights, subject to their FPIC and negotiated agreements.

O 4.7.1 (C) A mutually agreed procedure for identifying people entitled to compensation is in place. a. Does the company have a documented system or procedure in place to identify people and/or community groups Onsite verification result entitled to compensation? Company has SOP Oil Palm Plantation Land Acquisition No. Rev 0 of 2009, SOP was prepared from the process of Yes b. Is the procedure agreed by the affected parties? socialization, identification of land ownership, land inventory, land measurement, land mapping, creation of land ad- No ministration, land payment and archiving of documents of land acquisition. N.A

NCR No :

O 4.7.2 (C) A mutually agreed procedure for calculating and distributing fair compensation (monetary or otherwise) is in place and documented and made available to affected parties. Note to auditor : There should be direct verification of above with the affected parties a. Does the company has documented system to calculate and distribute fair compensation? Onsite verification result b. Is the documented system agreed by the affected parties and made available to them? A procedure for identifying legal, customary or user rights, and a procedure for identifying people entitled to compen- Yes sation as well as for calculating and distributing fair compensation (monetary or otherwise) has established, docu- No mented as SOP Oil Palm Plantation Land Acquisition Rev. 0 dated July 01, 2009. The purpose of document is to pro- N.A vide guidance on managing any dispute encountered by PT REA Kaltim or its subsidiary (including PT KMS) with any third parties claiming interests on the land, gathering of information and documents such land titles and development NCR No : plans, appointment of land surveyors and legal practitioners and consultation with land authorities in negotiation pro- cess. O 4.7.3 Communities that have lost access and rights to land for plantation expansion are given opportunities to benefit from plantation development. a. Does the company provide communities that have lost access and rights to land for plantation expansion opportuni- Onsite verification result ties to benefit from plantation development? The company provie adequate evidence that affected local peoples understand they have the right to say ‘no’ to oper- Yes b. What are the evidences to an above? ations planned on their lands before and during initial discussions, during the stage information gathering and associ- No ated consultations, during negotiations, and up until an agreement with the grower/miller is signed and ratified by N.A these local peoples. Company has showed land acquisition records, and each record has completed with maps (which acknowledged by previous land owners, representatives and witnesses), such as evidence below: NCR No : 1. List of Previous land Owner inside PT KMS HGU that has been receiving compensation, consist of 20 per- sons (groups), total 101,8 ha. The list developed and signed by Formature Team (Abd Rasyid and Shole- hudin). 2. List of Previous land Owner inside PT KMS HGU that has been receiving compensation, as the result of CV NBJ, consist of 24 persons (group representative), total 182,81 ha. 4.8 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. O 4.8.1 Where there are or have been disputes, proof of legal acquisition of title and evidence that mutually agreed compensation has been made to all people who held legal, customary, or user rights at the time of acquisition is available and provided to parties to a dis- pute, and that any compensation was accepted following a documented process of FPIC. Note to auditor :  Due diligence should be conducted on the management to provide evidence that there has been no historical or current land dispute  There should be direct verification of above with the affected parties a. Are there, or have there been any land disputes? Onsite verification result b. If there are or have been disputes, are there : Land disputes cases inside PT Rea Kaltim Cakra supply base has happened and some of them has been meet the Yes i. Documents to proof legal acquisition? resolution in 2018. Records regarding the meeting, negotiation process and compensation payment process with No ii. Records of FPIC process including resolution of the dispute? impacted parties has showed during surveillance, such as Record of land compensation process for Mr. Abdullah, who N.A c. If there has been acquisition involving compensation, are there : has land of 1.85 Ha located in field No.14 CD. The record consist of receipt of payment (with signoff from MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS i. Records that fair compensation has been provided and accepted by parties involved? compensated man); minutes of land compensation payments dated on 5 August 2011 complete with sign off and NCR No : ii. Records that all affected parties are consulted and represented? witnesses present, map of compensated location. The document also complete with letter statement of rights release iii. Documents of negotiations/discussion available? from first land owner to the company. This record compensation process came from Cakra estate. While for other estate in Berkat and Central complex the company also submitted the record with similar record but diferent name. An acceptable conflict resolution processes can demonstrate as seen on evidence of implemented were accepted by the parties involved, as seen on documents below: 1. Agreement ACT, No. Notary Silvanus DN, July 23rd 2011, between Senyiur Village with PT KMS. The agree- ment regarding Palm Oil Plantation Plan on area decreed by SK HGU No. 6/HGU/BPN-RI/2011, February 18th 2011. Points of agreement are: a) community’s Plant Compensation inside HGU area; b) CSR activities for Community. 2. Meeting Note, June 5th 2017, between PT KMS with Community Leaders of Senyiur, regarding Grievances Submission according to Ignorance of District Head Decree. The meeting attended by 6 community leaders and 6 KMS managers. O 4.8.2 (C) Land conflict is not present in the area of the unit of certification. Where land conflict exists, acceptable conflict resolution processes (see Criteria 4.2 and 4.6) are implemented and accepted by the parties involved. In the case of newly acquired plantations, the unit of certification addresses any unresolved conflict through appropriate conflict resolution mechanisms. a. Does the company have cases of land conflict? (i.e. preventing the company from operating normally) Onsite verification result b. If the company has cases of conflict, are records of the following available? Based on document checked, found that there is an agreement between communities with company during the HGU Yes i. Status of land conflict establishment process. The company has shown evidences such as: No ii. SOP/ mechanism for conflict resolution 1. Map of claimers identification location in four (4) estate with scale 1:35,000 whereas the “red colour” as claimers N.A iii. Implementation of SOP/mechanism identification. The map also informed name of claimers. iv. Acceptance of the procedures by all parties 2. Record of participatory mapping with claimers together. The company submitted 8 minutes of participatory NCR No : v. Records of conflict resolution mapping records completed with information of involved of claim-ers in participatory mapping process, with evidenced in signoff from claimers.

O 4.8.3 Where there is evidence of acquisition through dispossession or forced abandonment of customary and user rights prior to the current operations and there remain parties with demonstrable customary and land use rights, these claims will be settled using the rele- vant requirements (Indicators 4.4.2, 4.4.3 and 4.4.4). a. Is there evidence that the land has been acquired through dispossession or forced abandonment of customary and Onsite verification result user rights prior to the current operations? The company provide adequate evidence that affected local peoples understand they have the right to say ‘no’ to op- Yes b. Are there any parties who can establish legitimate rights on the land? erations planned on their lands before and during initial discussions, during the stage information gathering and asso- No c. If so, are the requirements in 4.4.2, 4.4.3 and 4.4.4 been met? ciated consultations, during negotiations, and up until an agreement with the grower/miller is signed and ratified by N.A these local peoples. Company has showed land acquisition records, and each record has completed with maps. As example: Land compensation record of Edy Suparwin at block 6 BCD (8.1 Ha) on June 15, 2020. NCR No :

O 4.8.4 For any conflict or dispute over the land, the extent of the disputed area is mapped out in a participatory way with involvement of affected parties (including neighbouring communities where applicable). Note to auditor : Actual ground verification showing the accuracy of the dispute map should be conducted a. Is there an SOP for participatory mapping of disputed area? Onsite verification result b. Is the disputed area mapped? Company has procdures to handle conflict and disputes : Yes c. Is there documented evidence of involvement and acceptance by the affected parties? (a) SOP participatory mapping “Prosedur Penangangan Konflik Lahan SOP No. 01 REA.BPO.DCA.PKL dated No- No vember 01st 2019, effective on December 1st 2019. N.A (b) The company has prepared maps of “encroachment” areas for every estate. The maps were prepared by TSPS Department, with the participation of the affected parties. For example, Perdana Encroachment Map dated Au- NCR No : gust 30th 2019 No. 151/SMD-MAP/SHP/VIII/2009 identified 7,45 ha that been encroach by 19 farmers. A partici- patory maps with the “landowners” representative was done in August 22nd 2019. As for the newly disputed area of block 13 Perdana Estate, by Sainuddinsyah, the company has prepared map No. 079/SMD-MAP/SHP/III/2020. Record held on file “Pemetaan Partisipatif Areal Berkonflik”. Principle 5 : Support Smallholder Inclusion

5.1 The unit of certification deals fairly and transparently with all smallholders (Independent and Scheme) and other local businesses.

R 5.1.1 Current and previous period prices paid for FFB are publicly available and accessible by smallholders a. Is there any information on current and previous price paid for FFB available during the audit? Remote audit result Note : Recommended good practice to maintain for 12 months of previous Current and past prices paid for Fresh Fruit Bunches (FFB) has publicly available. As seen on the Mill area. The Yes b. Has the mill made available the information (current and previous prices) to the smallholders? If yes, how was it company has FFB prices documents of East Kutai District, established by the local government / Department of Plan- No done? tation for Januari, February and March 2020. The pricing mechanism agreed upon in accordance with the decision of N.A c. Are the smallholders aware of such information is available? the team determine the price at its monthly meeting Disbun/Plantation Agency. Below the list of FFB prices applies for the 3 months: NCR No : - Year 2020 Age of No January February March Plant Rp/Kg Rp/Kg Rp/Kg 1 3 1,576.30 1,559.29 1,404.84 2 4 1,684.23 1.665,60 1,500,90 3 5 1.691.59 1,673.28 1,507.57 4 6 1,709.12 1,690.72 1,523.23 5 7 1,718.97 1,700.53 1,532.02 6 8 1,732.23 1,713.59 1,543.82 7 9 1,766.45 1,768.45 1,574.41 8 > 10 1,787.39 1.768,45 1,593.07 Smallholders knows the price of the FFB. Smallholderslearned about the price of FFB from an information board in front of the factory. The company also socializes TBS prices through WhatsApp social media.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS O 5.1.2 (C) Evidence is available that the unit of certification regularly explains the FFB pricing to smallholders a. What evidence is available to show that the mill has regularly explained the FFB pricing to smallholder? Onsite verification result b. What was the mechanicm used to explain the FFB pricing to smallholders? In Kedaron Estate there is plasma, but the organization has not yet been formed, the Calon Petani Plasma (CPP) al- Yes c. How often is the mechanism being implemented? ready exists and the draft partnership agreement has been discussed in Senyiur Village. No In Berkat Estate there is plasma. Koperasi Plasma Etam Sejahtera, Kembang Janggut Village, Kembang Janggut Dis- N.A trict, Kutai Kartanegara District, Legal Entity No. 309 / BH / XX-5 / III / 2016 dated March 30, 2016, 623 members, planting year 2017, area 119.65 ha, not yet producing or producing. Cooperation Agreement between PT Rea Kaltim NCR No : Plantations and Koperasi Plasma Etam Sejahtera regarding Development of Plasma Oil Palm Estates, Number: 023 / SPK / REA-JKT / XI / 2016, Friday date November 25, 2016. In Cakra Estate there are plasma. Koperasi Etam Bersatu, 227 members, 565.65 ha area, 2010 and 2011. Amend- ment I of Partnership Agreement In Development of Palm Oil Plants No. 001 / REKAP-KOPBUN-PEB / PK / I / 2009 dated 15 November 2017. In Kebun Damai there is no partnership for developing oil palm plantations (plasma). The company has provided sufficient evidence that FFB pricing, and pricing mechanisms as explained in the 5.1.1 above.

O 5.1.3 (C) Fair pricing, including premium pricing, when applicable, is agreed with smallholders in the supply base and documented a. How is the price of FFB determined? Onsite verification result b. Was the price equal to or above the prices established by the government or government endorsed initiatives? The company has FFB purchase procedure. FFB supply for Cakra POM from plasma farmers (Smallholder & Sceme Yes c. In the case of FFB price is not fix by the government, what is mechanism used to determe the price? smallholeder). Based on document review and interviewed with management and FFB suppliers that no complaint on No d. Has the price been agreed with the smallholders in the supply base? Please interview smallholders involved FFB pricing. N.A e. Is there any documented agreement between the company and the smallholders on the fair pricing? f. Was there any complaints on FFB pricing? If yes, how was the complaint handled and what was the solution? NCR No :

O 5.1.4 (C) Evidence is available that all parties, including women and independent representative organisations assisting smallholders where requested, are involved in decision-making processes and understand the contracts. These include those involving finance, loans/credits, and repayments through FFB price reductions for replanting and or other support mechanisms where applicable a. Is there list of all parties including women and independent representative organizations assisting SH available in Onsite verification result the company? If yes, when was it updated? The company provide sufficient evidence that all parties understand the contractual agreements they enter into, and Yes b. Has the parties in the list involved in decision-making processes and understand the contracts? If yes, how was the that contracts are fair, legal and transparent. REA Kaltim has partnership contract with local smallholder (PPMD No process carried out? Scheme and Swadaya) , such as: a) Era Cipta Mandiri; b) Belayan Sejahtera; c) Dwi karya; d) Etam Sejahtera; e) N.A c. Is the contracts include any FFB price reduction due to repayment for replanting, or other support mechanisms Modang Bersatu; f) Tunas Harapan. All smallholder cooperative agreed as FFB supplier for Cakra Mill and the defin- where applicable? ing on FFB price according to Disbun price. Contract was stamped and signed by both parties. Evidence FFB pay- NCR No : ment receipt on February 2020. This evidence showed that the payment conduct timely manner.

R & O 5.1.5 Contracts are fair, legal and transparent and have an agreed timeframe a. Is there a contractual agreement between the miller and smallholders or their appointed representative? Remote and Onsite audit result b. Do all parties understand the contractual agreements they have entered into? The company provide sufficient evidence that all parties understand the contractual agreements they enter into, and Yes c. Are all contractual agreements fair, legal and transparent and have an agreed timeframe? that contracts are fair, legal and transparent. REA Kaltim has partnership contract with local smallholder (PPMD No d. Who keeps the contractual agreements? Please check the agreement with the smallholders Scheme and Swadaya) , such as: a) Era Cipta Mandiri; b) Belayan Sejahtera; c) Dwi karya; d) Etam Sejahtera; e) N.A Modang Bersatu; f) Tunas Harapan. All smallholder cooperative agreed as FFB supplier for Cakra Mill and the defining on FFB price according to Disbun price. Contract was stamped and signed by both parties. Evidence FFB payment NCR No : - receipt on February 2020. This evidence showed that the payment conduct timely manner.

R 5.1.6 (C) Agreed payments are made in a timely manner and receipts specifying price, weight, deductions and amount paid are given a. How are payments made to the smallholders or their appointed representative? Remote audit result b. What is the mode of recording/documenting transactions between millers with smallholders and/or their appointed Payment of TBS once a month. Payment is in accordance with the number of TBS scales and the applicable price. Yes representative? Both parties understand and agree with the agreement and signature on the seal, also company conducted monthly No c. Are the receipts dated, specified the price, weight, deductions and amount to be paid? payments according to the agreed time in the term. There is no complaint related FFB payment. N.A d. Have agreed payments been made in a timely manner as agreed in the contract? NCR No : -

R 5.1.7 Weighing equipment is verified by an independent third party on a regular basis (this can be government) a. Is there evidence that the weighing equipment been calibrated or verified by third party? If yes, when was it last Remote audit result conducted and who performed the calibration/verification? Weigh bridge inspection No.510.63/315/Disperindag/Metrologi/XII/2019 by the Legal Metrology UPT of Kutai Kar- Yes b. How regular is the calibration/verification been conducted? tanegara District, validity period November 27, 2020. Inspections are conducted once a year. No N.A

NCR No : -

O 5.1.8 The unit of certification supports Independent Smallholders with certification, where applicable, ensuring mutual agreements between the unit of certification and the smallholders on who runs the internal control system (ICS), who holds the certificates, and who holds and sells the certified material a. Is the units of certification supports the ISH with certification, where applicable? If yes, what is their rol Onsite verification result b. Is there an agreement between the unit of certification and the ISH group to go for certification? If yes, when was it The certification unit supports independent smallholders to enter RSPO certification. There is already an agreement Yes signed? between the certification unit and the independent smallholders. The agreement letter has explained about ICS, hold- No c. Has the agreement defined the roles of the unit of certification e.g. who runs the ICS, holds the certificates, and who ing certificates and the certification system. N.A holds and sell the certified material? NCR No : - MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS

R 5.1.9 (C) The unit of certification has a grievance mechanism for smallholders and all grievances raised are dealt with in a timely manner a. Is there a mechanism to deal with complaints and grievances from smallholders and all affected parties? Remote audit result b. Is the existence of the system been made known and communicated to all parties? If yes, how was it done? The system, open to all affected parties, to resolve disputes in an effective, timely and appropriate manner, ensuring Yes c. Are there any grievances reported and are they dealt in a timely manner? anonymity of complainants and whistleblowers, where requested has been established as recorded on documents bel- No low: N.A 1. SOP No. REA.EP.002, 22 July 2005. In point 6.3.3 Communication with other external stakeholders, mentioned: a. Anyone who receives a complaint or a request for environmental information from (internal-external) inter- NCR No : - ested parties should forward it to the General Affairs manager. b. GA Staff section records all complaints and requests for information in the list of communications from (in- ternal-external) interested parties. 2. Human Rights Policy No. 002/BOD_REA/P/II/2015. This policy giving guarantees the confidentiality / anonymity following the reporting as well as external and internal complaints handling. REA Group will protect the anonymity of complaints, whistleblowers and individuals who chose to assist the company in enforcing its policies and man- agement has chosen the officer responsible for handling complaints from outsiders is a public relations officer / DVA. The company has created signboards and communication flowchart to stakeholders. The company has also social- ized the above procedures to all levels of workers, for example March 1, 2019. 5.2 The unit of certification supports improved livelihoods of smallholders and their inclusion in sustainable palm oil value chains

O 5.2.1 The unit of certification consults with interested smallholders (irrespective of type) including women or other partners in their supply base to assess their needs for support to improve their livelihoods and their interest in RSPO certification a. Is there a list of all smallholders including women and other partners in their supply base? Onsite verification result b. Has the unit of certification consults with the above stakeholders to assess their needs for support to improve their It has been verified that there are 3rd party (scheme smallholder) FFB received by the Mill. The mill has record the or- Yes livelihoods and their interest in RSPO certification? If yes, when and where was the consultation carried out? igins of all third-party sourced Fresh Fruit Bunches (FFB). The company has daily and summary record of volume and No c. Is there minutes of meeting available and minuted the need to support? origins of third-party FFB received. N.A d. Has there been any action taken to follow up on the issues highlighted in the consultation? Company has consults with the above stakeholders to assess their needs for support to improve their livelihoods with CSR programs The Company has participated in the development of community around the estate through education, NCR No : - health, infrastructure, productive business, sports, art, culture and religious activities. The company has several rec- ords related to the local development contribution, based on the results of the consultation. O 5.2.2 The unit of certification develops and implements livelihood improvement programmes, including at least capacity building to enhance productivity, quality, organisational and managerial competencies, and specific elements of RSPO certification (including the RSPO Standard for Independent Smallholder) PROCEDURAL NOTE: The RSPO is currently developing a separate standard for Independent Smallholders. a. Is there any programmes developed by the unit of certification to enhance productivity, quality, organisational and Onsite verification result managerial competencies, and specific elements of RSPO certification (including the RSPO Standard for Independ- The company has programs to improve productivity, quality, organizational and managerial competence and training Yes ent Smallholder)? on the RSPO certification system, for example on March, 2020. The company also encourages farmers to do the best No b. What are the content of the programmes? agricultural practices. N.A c. Has the programmes been implemente (example via RSPO SH Trainer Acedamy)? When was the last programme held? NCR No : - d. Are there efforts been made to improve the farming practices of smallholders? e. Where there are smallholders, have efforts and/or resources been allocated to improve smallholder productivity? O 5.2.3 Where applicable, the unit of certification provides support to smallholders to promote legality of FFB production a. Where applicable, is there any programmes to support smallholders to promote legality of FFB production? Onsite verification result b. What are the supports provided? The company also encourages FFB suppliers to have plantation legality in accordance with national regulations. The Yes company has programs to improve productivity, quality, organizational and managerial competence and training on No the RSPO certification system, for example on March, 2020. The company also encourages farmers to do the best ag- N.A ricultural practices. NCR No : -

O 5.2.4 (C) Evidence exists that the unit of certification trains Scheme Smallholders on pesticide handling a. Is there scheme smallholders in the unit of certification? Onsite verification result b. Is there evidence that the unit of certificaiton trains the Scheme Smallholders on pesticides handling? The company also encourages FFB suppliers to have plantation legality in accordance with national regulations. The Yes c. When was the training provided and how many participated? company has programs to improve productivity, quality, organizational and managerial competence and training on No the RSPO certification system, for example on June 20, 2020. The company also encourages farmers to do the best N.A agricultural practices. NCR No : -

O 5.2.5 The unit of certification regularly reviews and publicly reports on the progress of the smallholder support programme a. Has the unit of certification reviews the progress of the smallholder support programmes? Onsite verification result b. When was the last review done? The certification unit reviews and reports the progress of the farmer support program to management. The company Yes c. Was the progress of the support programmes reported and made publicly available? How regular was it done? also encourages FFB suppliers to have plantation legality in accordance with national regulations. The company has No programs to improve productivity, quality, organizational and managerial competence and training on the RSPO certi- N.A fication system, for example on March, 2020. The company also encourages farmers to do the best agricultural prac- tices. NCR No : -

Principle 6 : Respect Workers Rights and Conditions

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS 6.1 Any form of discrimination is prohibited R 6.1.1 (C) publicly available non-discrimination and equal opportunity policy is implemented in such a way to prevent discrimination based on ethnic origin, caste, national origin, religion, disability, gender, sexual orientation, gender identity, union membership, political af- filiation or age a. Is there a company policy on non-discrimination and equal opportunities? Does it at least cover the items mentioned Remote audit result in the criteria (6.1.1)? Policy for equal opportunities policy is available in Human Rights Policy based on Decree of The Board of Directors, Yes b. Is the policy publicly available to the relevant stakeholders? No. 002/BOD_REA/P/II/2015, signed by Mark Parry, President Director, REA Group dated 1 March 2015. It stipulates No c. Is there evidence that the policy has been implemented? that the REA Group actively promotes diversity in the workplace and does not tolerate discrimination based on differ- N.A ences in age, disability, ethnicity, gender, marital status, political persuasion, race, religion or sexual orientation in re- cruitment, dismissal or promotion. NCR No : - The Equal Opportunity Policy is clearly displayed in the office and on the notice boards around the estates and mill. The policy has been socialized to stakeholders, for example on April 13, 2020.

O 6.1.2 (C) Evidence is provided that workers and groups including local communities, women, and migrant workers have not been discriminated against. Evidence includes migrant workers' non-payment of recruitment fees a. What evidence is available to support that workers and groups including local communities, women, and migrant Onsite verification result workers have not been discriminated against? Evidence may include job advertisement, job description, appraisal, Evidence of equal treatment in working opportunities for workers could be seen on worker list whichshows that all Yes and/or information obtained via interviews with relevant stackholders workers come from different race, nation, gender and religion. Based on interview and field observation it was found No b. For migrant workers, is there evidence that the workers are not paying recruitment fees during the recruitment pro- that there was no discrimination to the worker regarding to this opportunity. N.A cess? Please check the contract between employer and agency, and contract betweeen worker and agency Interview result with workers found that there is no indication of gender, race, religion and/or favouritism based dis- c. For migrant workers, is there evidence that they are not paying anything that a local worker is not required to pay, crimination. There is no complaints regarding discrimination were received from all workers interviewed. Pay and ben- NCR No : - unless mandated by the law? efits received and there was no evidence of discrimination during recruitment. Workers are usually made known is d. Are there complaints against the company on issues relating to discrimination? If yes, what actios have been tak- based on skill, qualities, capabilities and medical fitness, while vacancy notices for higher positions do not contain any en? discriminatory elements. Based on the results of interviews with HRD, it was found that there were no migrant workers.

R & O 6.1.3 The unit of certification demonstrates that recruitment selection, hiring, access to training and promotion are based on skills, capabilities, qualities and medical fitness necessary for the jobs available a. Are the company’s employees recruited and promoted based on skills, capabilities, qualities, and medical fitness Remote audit result necessary for the job? Based on interviews with HRD, it was stated that employee recruitment and promotion were based on skills, capabilitis Yes b. What are the evidences to show this compliance? and qualitites. Promotion of the appointment of workers is based on the results of the assessment with the require- No ments of skills, capability, qualitites and discipline. N.A

Onsite verification result NCR No : - Unit of certification recruit employee based on the needs and skills in accordance with available job specifications, provide training as needed and carry out medical checkups for employee at least once a year. Promotion is also given to employee based on an assessment system developed by the company.

O 6.1.4 Pregnancy testing is not conducted as a discriminatory measure and is only permissible when it is legally mandated. Alternative equivalent employment is offered for pregnant women a. Is the unit of certification conducting pregnancy test? Was it required under the law? Onsite verification result b. Is pregnancy testing conducted as a discriminatory measure? Pregnancy test for woman employess fertilizers and spraying are conducted every 1 months, and ensure that preg- Yes c. Does the company provide alternative equivalent employment for pregnant woman? nant/breastfeeding women should not carry out work related to chemicals (agrochemical), and based on the two SOPs No (SOP Circle and path spraying and Fertilization), pregnant employee will be moved to other places that are not at risk N.A for her pregnancy. For female workers dealing with chemicals, the company conducts a pregnancy test. Pregnant women workers are NCR No : - given other equal work. According to the Regulation of the Minister of Manpower of the Republic of Indonesia No. 3 / MEN / 1986 concerning safety and health requirements at work that manage pesticides, pregnant or nursing women should not manage pesticides. R & O 6.1.5 (C) A gender committee is in place specifically to raise awareness, identify and address issues of concern, as well as opportunities and improvements for women a. Has the company formed a Gender Committee to raise awareness, identify and address issues of concern, as well Remote and Onsite audit result as opportunities and improvements for women? Company has established Gender Committee in order to maintain the compliance to the policy and act as specific Yes b. Is there a list of the members sitting in the committee? complaint handling. Female employees have been briefed on what constitutes as sexual harassment/violence, and re- No c. When was the last gender committee meeting held? productive rights who to report such cases to, maternity benefits entitled to them, and requirement that women work- N.A d. Who attended and what issues were discussed? ing with chemicals should inform the company if they are pregnant so they are allocated to other work. e. Is there any records of discussion? Estate and POM already have an organization of gender committee and its members. The management of the gender NCR No : - f. Were issues highlighted in the meeting resolved? committee and its members are employees of the company. The gender committee also con-ducts meetings, for ex- ample: On March 5, 2019, the socialization of the prevention and treatment of sexual harassment at the meeting room of, permanent employee participants and contractor employees. R & O 6.1.6 There is evidence of equal pay for the same work scope a. Is there a wage structure for each level work? Remote and Onsite audit result b. Is there a pay condition for each job scope? The company has a wage structure and scale contained in wage policy in 2020. All male and female employees have Yes c. Is there any evidence that employees for the same work scope of all genders are being paid equally? equal wages. Pay and conditions for employees are documented in Company Regulations/Peraturan Perusahaan/PP No 2018-2020. The unit of certification provide the same salary for workers in the same scope of work, both men and N.A women. NCR No : -

6.2 Pay and conditions for staff and workers and for contract workers always meet at least legal or industry minimum standards and are sufficient to provide decent living wages (DLW)

R 6.2.1 (C) Applicable labour laws, union and/or other collective agreements and documentation of pay and conditions are available to the workers in national languages and explained to them in language they understand

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. Are there Labour laws, union and/or other collective agreements detailing payments and other conditions, made Remote audit result available in the languages understood by the workers or explained to them by a management official? Pay and conditions for employers are documented. Pay slips are provided to workers as confirmed from worker inter- Yes b. What types of employment arrangements are there in the company? (E.g. contractual, outsourced, apprenticeships, views. Pay slips for field workers show breakdown for all work done allowances received, deductions, number of days No direct hires, piecemeal basis, etc.) worked and overtime hours performed. Company’s commitment in order to comply minimum wage as seen on sam- N.A c. Is there documentation of pay and conditions for each employee? ple evidences below: d. Do the workers understood the pay documentation and the conditions? a. Governor Decree No. 561/K.636/2019, dated 5 December 2019, regarding minimum wage of Kutai Kartanegara NCR No : - District 2020. The minimum wage applied is IDR. 3,179,673, start at 1 January 2020. b. Directors Board of PT Rea Kaltim Decree No. REAKAP: PD-EST/887/XII/2019, dated 27 December 2019, re- garding Appointment of Minimum Wage for Permanent Daily Worker (KHT) and Non-Permanent Daily Worker (KHL) of PT Rea Kaltim. Points on this decree are: a) Minimum wage of KHT and KHL appointed is IDR. 3,179,673; b) the daily rate for KHL is IDR. 127,186.92. Practically, since 2018, PT REA Kaltim has not employ Daily Non-Permanent Worker (KHL). The lowest grade of em- ployment is Daily Permanent Worker (KHT). Below Examples of Pay Slips of March 2020 showed compliance to min- imum wage regulation: a. Moh. Alfandy, KHT, Cakra POM, basic salary IDR. 3.179.673. b. M. Agus S, KHT, Cakra POM, basic salary IDR. 3.179.673. c. Ardiansyah, KHT, Berkat Estate, basic salary IDR. 3.235.280. d. Donatus PK, KHT, Berkat Estate, basic salary IDR. 3.570.372. The company has a document listing the employee wages for the month of March 2020, and the wages of employees are paid above the average of the provisions of the provincial government of East Kalimantan Province. Company has a Company Regulations/Peraturan Perusahaan/PP 2018-2020. PP has been approved by the East Ka- limantan Province Office of Power and Transmigration with Decree No. 560/2492/ B.PHI & JAMSOSTEK / 2018 dated August 14, 2018. PP have included: facilities and assistance to the labour union, recruitment, remuneration, daily working hours, exemption from the obligation to work, health care, social security and workers' welfare, health and safety, order and discipline, complaints and settlement, termination of employment. PP has been socialized to all lev- els of estate workers and POM. R & O 6.2.2 (C) Employment contracts and related documents detailing payments and conditions of employment (e.g. regular working hours, deductions, overtime, sick leave, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc. in compliance with national legal requirements) and payroll documents give accurate information on compensation for all work performed, including work done by family members a. Is the pay and conditions of employment clearly detailed in the employment or service contracts? (E.g. working Remote and Onsite audit result hours, deductions, overtime, sick leaves, holiday entitlement, maternity leave, reasons for dismissal, period of no- Company has a Company Regulations/Peraturan Perusahaan/PP 2018-2020. PP has been approved by the East Ka- Yes tice, etc.) limantan Province Office of Power and Transmigration with Decree No. 560/2492/ B.PHI & JAMSOSTEK / 2018 dated No b. Is the contract prepared in languages understood by the workers, explained to workers by management officials, August 14, 2018. PP have included: facilities and assistance to the labour union, recruitment, remuneration, daily N.A and signed by both the authorised signatory of the company and employee? working hours, exemption from the obligation to work, health care, social security and workers' welfare, health and c. Does the pay and conditions provided in labour laws, union agreements or direct contracts of employment comply safety, order and discipline, complaints and settlement, termination of employment. PP has been socialized to all lev- NCR No : - with : els of estate workers and POM.  The decent living wage as provided in the National Interpretation for the country; or  The local legal requirements in meeting the minimum wage; or  The industry minimum standard for a similar position or work responsibilities d. Does the payroll documents give accurate information on compensation for all work performed, including work done by family members? e. Is the pay received by the employee consistent with the terms of the contract and the law f. Through interviews with workers, are there any issues raised by the workers regarding the payment and conditions which does not meet the terms of contract of employment? R 6.2.3 (C) There is evidence of legal compliance for regular working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice and other legal labour requirements a. Are the regular working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for Remote audit result dismissal and period of notice in accordance with the legal and other labour requirments? Company has a Company Regulations/Peraturan Perusahaan/PP 2018-2020. PP has been approved by the East Ka- Yes b. What evidences available in the company to support the legal compliance on the above issues? limantan Province Office of Power and Transmigration with Decree No. 560/2492/ B.PHI & JAMSOSTEK / 2018 dated No August 14, 2018. PP have included: facilities and assistance to the labour union, recruitment, remuneration, daily N.A working hours, exemption from the obligation to work, health care, social security and workers' welfare, health and safety, order and discipline, complaints and settlement, termination of employment. PP has been socialized to all lev- NCR No : - els of estate workers and POM.

O 6.2.4 (C) The unit of certification provides adequate housing, sanitation facilities, water supplies, medical, educational and welfare amenities to national standards or above, where no such public facilities are available or accessible. National laws, or in their absence the ILO Guidance on Workers’ Housing Recommendation No. 115, are used. In the case of acquisitions of non-certified units, a plan is developed detailing the upgrade of infrastructure. A reasonable time (5 years) is allowed to upgrade the infrastructure a. Has the unit of certification provided the basic necessities such as that listed below to national standards or above, Onsite verification result where no such public facilities are available or accessible? Company (Estate and Mill) is not at a remote area. There are grocery stalls selling daily need was found in every em- Yes  adequate housing; placement with a normal/affordable price. Company also provide workers facilities like housing, sports, health care, No  sanitation facilities; mosque, football field and school bus ect. For household need, traditional market near by the company area around 5 N.A  adequate electricity; km from workers housing. Moreover, there is employee’s cooperative (koperasi karyawan) company which has provid-  access to medical services; ed some comsumption items for household need too (type of cooperative is consumption bussiness activities), shop NCR No : RSPO 03244  access to children education near emplasment areas was available and peddler visiting emplasment every day too.  welfare amenities However, based on the results of interviews with workers in Blocks 3B, 1E, and field observations to Division III hous- b. Through interviews with workers, are there any complaints on the above? ing estates, it was found that: The number of toilets is not sufficient to meet the needs of employees living in the hous- c. Has the company acquired new non-certified units? If yes, is there a plan developed to maintain or upgrade the in- ing. Clean water for drinking and bathing, washing and toilet (MCK) is not yet available adequately. This condition frastructure within 5 years? raise as nonconformity under NCR RSPO 03244.

O 6.2.5 The unit of certification makes efforts to improve workers' access to adequate, sufficient and affordable food a. What are the efforts made by the unit of certification to monitor and improve workers’ access to adequate, sufficient Onsite verification result and affordable food? Company (Estate and Mill) is not at a remote area. There are grocery stalls selling daily need was found in every em- Yes placement with a normal/affordable price. Company also provide workers facilities like housing, sports, health care, No MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS mosque, football field, school bus, clean water ect. All employee facilities provided by the company are in good condi- N.A tion and used by employees and their families. For household need, traditional mar-ket near by the company area around 5 km from workers housing. Moreover, there is employee’s cooperative (koperasi karyawan) company which NCR No : - has provided some comsumption items for household need too (type of cooperative is consumption bussiness activi- ties), shop near emplasment areas was available and peddler visiting emplasment every day too. R & O 6.2.6 A DLW is paid to all workers, including those on piece rate/quotas, for whom the calculation is based on achievable quotas during regular work hours.

PROCEDURAL NOTE: The RSPO Labour Task Force will prepare guidance on the DLW implementation, including details on how to calculate a DLW, expected for 2019. The RSPO Secretariat will endeavour to carry out DLW country benchmarks for palm oil producing countries in which RSPO members operate and for which no Global Living Wage Coalition (GLWC) benchmarks exist a. Is there an RSPO endorsed living wage country benchmark available? Remote audit result b. For countries with available benchmark Worker pay and conditions implemented were based on Decree of the Regent of Kutaikartanegara No. 1/REK- Yes Does the prevailing wage meet the GLWC Living wage standard? BUP/HK/2019 regarding concerning district minimum wages in 2020, IDR. 3.179.673. In addition to the basic salary, No If the prevailing wage does not meet the GLWC standard, Is there an implementation plan with specific targets and employees also receive electricity subsidies, water subsidies, rice subsidies, school education subsidies for employ- N.A phase implementation plan including : ees' children. - Updated assessment on prevailing wages and in-kind benefits NCR No : - - There is annual progress on the implementation of living wages Onsite verification result - Where a minimum wage, based on equivalent of baskets of goods, is stipulated in Collective Bargaining Agree- Worker pay and conditions implemented were based on Decree of the Regent of Kutaikartanegara No. 1/REK- ments (CBAs), this should be used as the foundation for the gradual implementation of the living wage payment BUP/HK/2019 regarding concerning district minimum wages in 2020, IDR. 3.179.673. In addition to wages in ac- - The unit of certification may to choose to implement the living wage payment in specific section as a pilot project; cordance with applicable regulations, the company also provides facilities that support the welfare of work, includ- the pilot will then be evaluated and adapted before eventual scale up of the living wage implementation. ing: c. For countries without available Benchmark Decent Living Wage For countries where no living wage standard is established, until such time that an RSPO endorsed benchmark for No. IN-KIND Benefit Per Month (Rp) the country is in place, national minimum wages shall be paid to all workers. In addition to the payment of minimum 1. Rice 150,000 wages, the Unit of Certification (UoC) shall conduct an assessment of the prevailing wages and in-kind benefits pro- vided to workers in the Unit of Certification aligned with the RSPO Guidance for Implementing a Decent Living 2. Housing 500,000 Wage 3. Electrical 200,000 Once the benchmark is available, this procedural note is no longer applicable. UoC shall have implementation plan with specific targets, and phased implementation process including : 4. Water 100,000 - Updated assessment on prevailing wages and in-kind benefits 5. Education 573,510 - There is annual progress on the implementation of living wages 6. Healthcare 319,217 - Where a minimum wage, based on equivalent of baskets of goods, is stipulated in Collective Bargaining Agree- ments (CBAs), this should be used as the foundation for the gradual implementation of the living wage payment 7. Creche facility 637,878 - The UoC may to choose to implement the living wage payment in specific section as a pilot project; the pilot will Total 2,480,605 then be evaluated and adapted before eventual scale up of the living wage implementation Basic Salary 3,179,673 Grand Total 5,660,278

O 6.2.7 Permanent, full-time employment is used for all core work performed by the unit of certification. Casual, temporary and day labour is limited to jobs that are temporary or seasonal a. Has the company identified what are the core work activities in the unit of certification? Onsite verification result b. Are all the core work activities performed by permanent, full-time employed workers? Categories of workers in the company: Yes c. Are there casual, temporary and day labour been employed? If yes, what is the scope of employment?  MRP (Monthly Rated Permanent) No  DRP (Daily Rated Permanent) N.A  Contract worker or temporary worker or PKWT (Perjanjian Kerja Waktu Tertentu/Certain Period Employem- ent Contract). NCR No : -  Contractor/outsourcing worker (from employment outsourcing) 6.3 The unit of certification respects the rights of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of in- dependent and free association and bargaining for all such personnel R 6.3.1 (C) A published statement recognising freedom of association and right to collective bargaining in national languages is available and is explained to all workers in languages that they understand, and is demonstrably implemented a. Has the company published a statement in local language or language understood to all workers recognising their Remote audit result rights to freedom of association and collective bargaining? The company has a Policy on Freedom of Association as seen on Policy in Human Rights Policy based on Decree of Yes b. What evidence to show that the above statement has been explained to all workers in languanges that they under- The Board of Directors, No. 002/BOD_REA/P/II/2015, amended April 2020. The policy has been publish in all public No stand? What are the evidences to support this? area, such as meeting room, loading ramp, sport hall and housing area. A workers union has been established, it is N.A c. Are the employees including migrant, transmigrant and contract workers given an avenue to negotiate with the em- called “Serikat Pekerja KAHUTINDO”. Registration approval from local Labor Office East Kutai. It was sight letter of ployer on the terms of their contract? registration No. 003/DPC F-SPK/SK/IV/2016. NCR No : -

O 6.3.2 Minutes of meetings between the unit of certification with trade unions or workers representatives, who are freely elected, are documented in national languages and made available upon request a. Are there documented minutes of meetings between the company and main trade unions or workers representa- Onsite verification result tives? All workers allowed joining any worker associations and/or labor union that existed Surround Company working area. Yes b. When was the last meeting held? Company has also developed LKS bipartite as required by National Law, and has been registered to District level No c. Are the minutes made readily available to employees upon request? Government Agency of Workforce and Transmigration. Evidences showed during surveillance confirmed that Labor N.A union and LKS Bipartite has effectively worked as facility of worker’s aspirations. Documentation of the discussion of the problems of employees, ie: NCR No : - - On July 10, 2019 at the office of company socialization about regulations and safety in traffic delivered. - On Sepetmber 8, 2019 a meeting (workers and management) to improve work productivity, provide wrking tools for FFB transport workers. O 6.3.3 Management does not interfere with the formation or operation of registered unions/ labour organisations or associations, or other freely elected representatives for all workers including migrant and contract workers

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. How do you confirm that the management does not interfere with the formation or operation of registered unions/ la- Onsite verification result bour organisations or associations, or other freely elected representatives for all workers including migrant and con- Based on interview result with Labor Union board confirmed that no interventions from company during boards for- Yes tract workers? mation. All process has conducted with compliance to Labor Union code of conducts (AD/ART). Boards of Labor Un- No ion and LKS Bipartite registered to Workforce agency. N.A

NCR No : -

6.4 Children are not employed or exploited

R 6.4.1 A formal policy for the protection of children, including prohibition of child labour and remediation is in place, and included into service contracts and supplier agreements a. Has the unit of certification established a formal policy for the protection of children including prohibition of child la- Remote audit result bour and remediation? The company has a Child Labor Policy as seen on Policy for minimum age requirement policy is available in Human Yes b. Are the requirements (i.e. prohibition of child labour and remediation) included into service contracts and supplier Rights Policy based on Decree of The Board of Directors, No. 002/BOD_REA/P/II/2015, amended April 2020. Re- No agreements? quirement to hire workers only 18 years and above. In every letter of employment agreement with all contractors writ- N.A c. Has the unit of certification communicated the policy to their supplier and contractors? ten that the contractor is prohibited from employing children under the age of 18 years. Masterlists of workers from the mill and estates, including dates of birth and date of hiring of all workers was checked, NCR No : - and sampled workers were cross checked against personal identification records. Personal files checked during sur- veillance such as, Alfian (Male), Laode (Male), Nuraeini (Female), and Uswatun (Female). All workers recruited when their age above 18 years old. This Policy has been communicated to all level worker trough general meeting, specific communication event and Morning Call Meeting. Master lists of workers from the mill, and estates and Outsourcing Company, including dates of birth and date of hiring of all workers was checked, and sampled workers were cross checked against personal identi- fication records. It was found not any worker under 18 years old.

R 6.4.2 (C) There is evidence that minimum age requirements are met. Personnel files show that all workers are above the national minimum age or above company policy minimum age, whichever is higher. There is a documented age screening verification procedure a. Is the minimum working age for workers clearly defined in the company’s recruitment policy? If yes, is the minimum Remote audit result age not less than stated under national regulations? The company has a Child Labor Policy as seen on Policy for minimum age requirement policy is available in Human Yes b. Are workers employed above the minimum school leaving age of the country or who are at least 15 years of age? Rights Policy based on Decree of The Board of Directors, No. 002/BOD_REA/P/II/2015, amended April 2020. Re- No c. Does ground verification and review of personnel files show evidence of employment of workers below the minimum quirement to hire workers only 18 years and above. In every letter of employment agreement with all contractors writ- N.A working age? ten that the contractor is prohibited from employing children under the age of 18 years. This Policy has been communicated to all level worker trough general meeting, specific communication event and NCR No : - Morning Call Meeting. Master lists of workers from the mill, and estates and Outsourcing Company, including dates of birth and date of hiring of all workers was checked, and sampled workers were cross checked against personal identi- fication records. It was found not any worker under 18 years old.

O 6.4.3 (C) Young persons may be employed only for non-hazardous work, with protective restrictions in place for that work a. Has the company employes workers above 15 and below 18 years old? Onsite verification result b. Where are young workers assigned to work? There are no workers over the age of 15 and under 18 (see indiator 6.4.2 above for detail). Yes c. Is the work classified as hazardous or non-hazardous? No N.A

NCR No : -

O 6.4.4 The unit of certification demonstrates communication about its ‘no child labour’ policy and the negative effects of child labour, and promotes child protection to supervisors and other key staff, smallholders, FFB suppliers and communities where workers live a. What evidence is available to demonstrate that the unit of certification has communicated to its supervisors and Onsite verification result other key staff, smallholders, FFB suppliers and communities where workers live about its ‘no child labour’ policy The prohibition on employing children has been regularly socialized by the unit of certification. The policy has been Yes and the negative effects of child labour, and promotes child protection? socialized to the contractor on 6 March 2020, to all levels of employees on 5 March 2020. No b. When was the communication last held and to whom? N.A

NCR No : -

6.5 There is no harassment or abuse in the workplace, and reproductive rights are protected

R 6.5.1 (C) A policy to prevent sexual and all other forms of harassment and violence is implemented and communicated to all levels of the workforce a. Does the company has a policy to prohibit any form of sexual and all other forms of harassment and violence? Remote audit result b. Has this policy been implemented and communicated clearly to all levels of the workforce? The company established a policy to prevent sexual and all other forms of harassment and Policy to prevent sexual Yes c. Is there any case of sexual and all other forms of harassment and violence being reported? If yes, what actions and all other forms of harassment and violence is available in Human Rights Policy based on Decree of The Board of No have been taken? Directors, No. 002/BOD_REA/P/II/2015, amended April 2020. It stipulates that all employees have the right to work in N.A environment that is free from harassment of any kind, including harassment based on age, disability, ethnicity, gender, marital status, political persuasion, race, religion or sexual orientation. The policy has been socialized to the contractor NCR No : - on 6 March 2020, to all levels of employees on 5 March 2020. Up to the time of the assessment there is no complaints related to sexual harassment, violence, or violation of reproductive rights.

R 6.5.2 (C) A policy to protect the reproductive rights of all, especially of women, is implemented and communicated to all levels of the workforce a. Is there a policy to protect the reproductive rights of all, especially of women? Remote audit result b. Has this policy been implemented and communicated clearly to all levels of the workforce? The company established a policy to prevent sexual and all other forms of harassment and Policy to prevent sexual Yes and all other forms of harassment and violence is available in Human Rights Policy based on Decree of The Board of No

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS Directors, No. 002/BOD_REA/P/II/2015, amended April 2020. It stipulates that all employees have the right to work in N.A environment that is free from harassment of any kind, including harassment based on age, disability, ethnicity, gender, marital status, political persuasion, race, religion or sexual orientation. The policy has been socialized to the contractor NCR No : - on 6 March 2020, to all levels of employees on 5 March 2020. Interview with HRD, known that CH has dis-seminated and implemented the policy related to prevent sexual and other form of harassment and violence, as well as to protect reproductive rights. Pregnant and lactating women are prohibit- ed to work related to agrochemicals. Up to the time of the assessment there is no complaints related to sexual har- assment, violence, or violation of reproductive rights. O 6.5.3 Management has assessed the needs of new mothers, in consultation with the new mothers, and actions are taken to address the needs that have been identified a. Has the management assessed the needs of new mothers? How was the needs assessed? Onsite verification result b. When was the needs assessed and has the needs been documented for follow-up? Based on interview with workers and document review (Minutes of Assessment of New Mothers (FGD), the unit of cer- Yes c. Are actions been taken to address the needs that have been identified? tification has conducted an assessment of new mothers working at company to identify and know the basic needs of No d. Has the company provided adequate space and paid breaks to enable new mothers with infants 24 months or mothers after giving birth and make ac-tions to meet those needs. The results of the assessment and follow-up can be N.A younger to breastfeed or express and store breastmilk with privacy? seen in detail on the official document. NCR No : -

O 6.5.4 Grievance mechanism, which respects anonymity and protects complainants where requested, is established, implemented and communicated to all levels of the workforce a. Does the company have a mechanism to handle employment grievances, that respects anonymity and protects Onsite verification result complainants where requested? Internal complaints and grievances procedure are stated in the Company Regulations/Peraturan Perusahaan/PP Yes b. Does the mechanism provide a way for workers to report a grievance against a supervisor to someone other than 2018-2020. Company also has policy to protect identity reporter as mentioned in policy reporter Violation Company. No that supervisor? Grievances and complaints of internal stakeholders could also submit to Labor Union and dis-cussed in LKS Bipartite N.A c. Is the mechanism documented, implemented and communicated clearly to all levels of the workforce? meetings. Mill and Estate has shown evidances regarding meeting note of LKS Bipartite. Both, companyand labor un- d. Has the company identified personnel who will be responsible to receive and manage complaints received from the ion have Complaint feedback logbook where com-plaints are recorded and filed was revewed. Mill and estates has al- NCR No : - workforce? so has records of worker com-plaints/grievances and it’s responses regarding housing facilities maintenance. 6.6 No forms of forced or trafficked labour are used R & O 6.6.1 (C) All work is voluntary and following are prohibited : • Retention of identity documents or passports • Payment of recruitment fees • Contract substitution • Involuntary overtime • Lack of freedom of workers to resign • Penalty for termination of employment • Debt bondage • Withholding of wages a. Are all migrant workers legally recruited? Remote audit result b. Are migrant workers asked to sign a contract upon arriving in the receiving country? If yes, is that contract identical The company has policy related to force labour, with document No. 002/BOD_REA/P/II/2015, amended April 2020 Yes to the one signed in the country of origin? about human rights policy. This policy in Section 2 mentioned the commitment do not any force labour and trafficked No c. Have workers entered into employment voluntarily and freely, without the threat of a penalty, and have freedom to labour. There is no Migrant worker existing in company, however some managerial personnel level (Director) are from N.A terminate employment without penalty given reasonable notice as per agreement? other country such Great Britain. d. Are workers given a copy of their employment contracts? If yes, is the contract identical to the one signed at the In carrying out its operations the company does not exploit fellow humans and the community including forced and NCR No : - time of recruitment? bound labor, does not hold workers' identity documents, does not collect recruitment fees, may not be transferred con- e. Is there evidence of contract substitution occurring? tract, free to stop working, there is no alternative to terminating employment, bondage practices and wage retention. f. Who keeps the workers passports or identity documents? g. If the document is kept by the company for safekeeping purpose, where is it kept and was it voluntarily done? Does Onsite verification result the company returned to the workers upon request? Results of search on the list of workers in August 2020, it was noted that no trafficked labor found. The company em- h. What are the penalties imposed if the workers were terminated or fired before their contract expires? ploys a permanent worker and a daily worker. Employment contract agreement between the companies with workers i. Confirm with workers on the following whether the following occurs : is in bahasa, and it found easily understood by workers. - Any involuntary overtime? Based on the human resources department, interviews with workers found that company has hold worker credentials - Debt bondage? original prints such as ID, Marital Leter, Family Card and/or Formal Education Certificate. Company ony keep copies - withholding of wages? of ID and Family Card of workers as part of insurance requirements. No indication found regarding force labor in - Lack of freedom to resign? Company’sworking areas. - Payment of recruitment fees? j. What is the process if a worker wants to terminate their employment before their contract expires? Is the process in accordance witht the employment contract? R & O 6.6.2 (C) Where temporary or migrant workers are employed, a specific labour policy and procedures are established and implemented a. What is the company’s policy and procedures for temporary or migrant workers? Remote audit result b. Does the special labour policy include : The company has policy related to force labour, with document No. 002/BOD_REA/P/II/2015, amended April 2020 Yes - Statement of the non-discriminatory practices? about human rights policy. This policy in Section 2 mentioned the commitment do not any force labour and trafficked No - No contract substitution? labour. There is no Migrant worker existing in company, however some managerial personnel level (Director) are from N.A - Post-arrival orientation programme with emphasis on language, safety, labour laws, cultural practices, etc? other country such Great Britain. - The provision of decent living conditions? In carrying out its operations the company does not exploit fellow humans and the community including forced and NCR No : - c. Have the policies and procedures been implemented? bound labor, does not hold workers' identity documents, does not collect recruitment fees, may not be transferred con- tract, free to stop working, there is no alternative to terminating employment, bondage practices and wage retention.

Onsite verification result Results of search on the list of workers in August 2020, it was noted that no trafficked labor found. The company em- ploys a permanent worker and a daily worker. Employment contract agreement between the companies with workers is in bahasa, and it found easily understood by workers. Based on the human resources department, interviews with workers found that company has hold worker credentials MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS original prints such as ID, Marital Leter, Family Card and/or Formal Education Certificate. Company ony keep copies of ID and Family Card of workers as part of insurance requirements. No indication found regarding force labor in Company’sworking areas.

6.7 The unit of certification ensures that the working environment under its control is safe and without undue risk to health R & O 6.7.1 (C) The responsible person(s) for H&S is identified. There are records of regular meetings between the responsible person(s) and workers. Concerns of all parties about health, safety and welfare are discussed at these meetings, and any issues raised are rec- orded Note: Auditors to interview those who attended the meeting to confirm the meeting was held and that issues were raised. a. Who has been appointed as the responsible person(s) for H&S in the unit of certification? Remote audit result b. Are meetings between the responsible persons and workers conducted on a regular basis, or as required by law, if The company mill and estate has record of person who incharge in the OHS implementation, as follow information be- Yes any? When was the last meeting carried out? low: No c. Are minutes of meeting recording attendees and issues discussed available? 1. Cakra oil mill; based on decree of Labor and Transmigration Official Local Government of Kalimantan Timur prov- N.A d. Are concerns of all parties about health, safety and welfare discussed at these meetings? ince, number KEP.566/1787/P2K3/PPK/DTKT/2018, regarding approval of OHS Committee in Cakra oil mill. This e. Are actions taken on the issues raised? decree issued on 28 May 2018, valid as long as no revision of person in Cakra oil mill. NCR No : RSPO03122 2. Cakra estate; based on decree of Labor and Transmigration Official Local Government of Kalimantan Timur prov- ince, number KEP.566/1785.b/P2K3/PPK/DTKT/2018, regarding approval of OHS Committee in Cakra oil mill. This decree issued on 28 May 2018, valid as long as no revision of person in Cakra oil mill. 3. Berkat estate; based on decree of Labor and Transmigration Official Local Government of Kalimantan Timur prov- ince, number KEP.566/1787.b/P2K3/PPK/DTKT/2018, regarding approval of OHS Committee in Cakra oil mill. This decree issued on 28 May 2018, valid as long as no revision of person in Cakra oil mill. 4. Lestari estate; based on decree of Labor and Transmigration Official Local Government of Kalimantan Timur prov- ince, number KEP.566/1786.b/P2K3/PPK/DTKT/2018, regarding approval of OHS Committee in Cakra oil mill. This decree issued on 28 May 2018, valid as long as no revision of person in Cakra oil mill. 5. Damai estate; based on decree of Labor and Transmigration Official Local Government of Kalimantan Timur prov- ince, number KEP.566/1790.A/P2K3/PPK/DTKT/2018, regarding approval of OHS Committee in Cakra oil mill. This decree issued on 28 May 2018, valid as long as no revision of person in Cakra oil mill. Due to revision of person incharge (estate personal rotation) the company submit request letter to the Labor and Transmigration Official Local Government of Kalimantan Timur province regarding revision of OHS Committee based letter no.RKP.ES-459/III/2020 dated on 20 Mar 2020. This request letter receipt by authorities on 16 Apr 2020 proven by official authorities stamp and signoff. Furthermore, person in charge (certified person) who responsible in the OHS implementation, also recorded in the company based on: 1. Cakra oil mill; OHS License card No.Reg.68649/PK3/AJ/64/2019/P0, valid until 10 May 2022 2. Cakra estate; OHS License card No.Reg.42308/PK3/AJ/64/2017/P0, valid until 22 Aug 2020 3. Berkat estate; OHS License card No.Reg.68658/PK3/AJ/64/2019/P0, valid until 10 May 2022 4. Lestari estate; OHS License card No.Reg.68659/PK3/AJ/64/2019/P0, valid until 10 May 2022 5. Damai estate; OHS License card No.Reg.68651/PK3/AJ/64/2019/P0, valid until 10 May 2022 Company mill and estate has record of OHS periodically meeting, the meeting carried out monthly, sampling taken: 1. Cakra oil mill; minutes of meeting dated on 29 Jan 2020 2. Cakra estate; minutes of meeting dated on 28 Feb 2020, attended by 10 participants, but not attended by estate mananeger, and responsible person OHS Specialist (AK3 Umum). 3. Damai estate; minutes of meeting dated on 20 Mar 2020, attended by 7 participants, but not attended by estate mananeger, and responsible person OHS Specialist (AK3 Umum). 4. Berkat estate; minutes of meeting dated on 24 Jan 2020, attended by 34 participants, but not attended by estate mananeger, and responsible person OHS Specialist (AK3 Umum). 5. Lestari estate; minuted of meeting dated on 28 Feb 2020, attended by 21 participants, but not attended by estate mananeger, and responsible person OHS Specialist (AK3 Umum). Thus condition above raised as non-conformity NCR No.RSPO03122.

Onsite verification result Refer to the request letter above (during remote audit) regarding revision of OHS Committee, the final OHS Commit- tee already in place based on decree from Labour Official Government of East Kalimantan no. 566/1193/P2K3/DTKT/2020, issued on 11 Jun 2020, , valid as long as no revision person who stated in OHS Commit- tee organizational structure. Based on verification, all person stated in the OHS Committee organization structure still exist in the PT Rea Kaltim Plantation. This OHS Committee is coverage all of unit member under PT Rea Kaltim Plan- tation.

The Kedaron estate has responsible person who dealing with OHS implementation. This person was qualified person based on OHS specialist certificate issued by Directorate General of Labour Inspection Development and Occupation- al Safety and Health, Ministry of Manpoer of The Republic of Indonesia, No.Reg. 68656/PK3/AJ/64/2019/P0 and No.Reg. 68650/PK3/AJ/64/2019/P0 issued date on 10 May 2019, valid until 10 May 2022. Based on-site verificarion the OHS Committee has conducted the periodically meeting in a month. The last meeting record on April, May, and June 2020 showed the meeting agenda discussed regarding accident and incident happened, accident evaluation, PPE’s monitoring, and other issues regarding OHS implementation. The meeting complete with summary and rec- ommendation for next improvement. Meeting was attended by 18 participants as stated OHS Committee member. Every issues raised during OSH periodically meeting, the action taken was in place by the OSH specialist. The OHS Committee in Kedaron also was in place, based on decree from Labour Offical Government of East Kali- mantan, no. 566.194/P2K3/DTKT/2020, issued on 11 Jun 2020, valid as long as no revision person who stated in OHS Committee organizational structure. Based on verification, all person stated in the OHS Committee organization structure still in Kedaron estate.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS Then for the Berkat estate, responsible person regarding OHS implementation was appointed based on certificate de- cree issued by Directorate General of Labour Inspection Development and Occupational Safety and Health, Ministry of Manpoer of The Republic of Indonesia, No.Reg. 68647/PK3/AJ/64/2019/P0 and No.Reg. 68647/PK3/AJ/64/2019/P0 issued date on 10 May 2019, valid until 10 May 2022. Based on meeting record on January and February 2020 showed the meeting agenda discussed regarding accident and incident happened, accident evaluation, PPE’s moni- toring, and other issues regarding OHS implementation. The meeting complete with summary and recommendation for next improvement. Meeting was attended by 39 participants on January and 28 participants on February as stated OHS Committee member. Every issues raised during OSH periodically meeting, the action taken was in place by the OSH specialist.

For Damai estate, responsible person who handle OHS implementation already have competency and approved by Directorate General of Labour Inspection Development and Occupational Safety and Health, Ministry of Manpoer of The Republic of Indonesia, based on No. Reg. 68651/PK3/AJ/64/2019/P0, valid until 10 May 2022. The estate also has OHS Committee under control of OHS Central Committee. This estate OHS committee has conducted the regula- ry meeting where the meeting conducted in mothly and reported per quartertly to the Labour Official Government of East Kalimantan province. The OHS Committee record meeting was in place and accessable during the audit. Exam- ple for OHS meeting in fourth quarter in 2019 (Oct, Nov and Dec) the meeting conducted on 30 Dec 2019 attended by 21 participants; 20 Nov 2019 attended by 21 participants, and 1 Nov 2019 (for October period) attended by 12 partici- pants. Minutes of meeting for the meeting contained was accident evaluation record, OHS performance, accident and incident trend, PPE’s commitment, workers welfare. Every issue raised as meeting discussed agenda, the result and recommendation was in place.

Furthermore for Cakra estate the responsible person already have competency and approved by Directorate General of Labour Inspection Development and Occupational Safety and Health, Ministry of Manpoer of The Republic of Indo- nesia, based on No. Reg. 42038/PK3/AJ/64/2017/P0, valid until 22 Aug 2020. The estate also has OHS Committee under control of OHS Central Committee. This estate OHS committee has conducted the regulary meeting where the meeting conducted in mothly and reported per quartertly to the Labour Official Government of East Kalimantan prov- ince. The OHS Committee record meeting was in place and accessable during the audit. Example for OHS meeting in first quarter of 2020 (Jan, Feb and Mar) the meeting conducted on 31 Jan 2020; 28 Feb 2020 and 30 Mar 2020, with meeting agenda discussion was OHS issue, workers welfare, recommendation of improvement and responsible per- son. The meeting attended by 31 participants in Jan, 10 participants in Feb and Mar 2020.

OHS Committee of Cakra oil mill has carried out the periodically meeting to discuss the OHS performacen trend in oil mill. The meeting is carried out monthly and reported per three monthly to the authority. Sampling taken meeting in monthly was on 2nd quarter (Apr, May and Jun) 2020. Meeting conducted on 29 Apr 2020 attended by 16 participants; 27 May 2020 attended by 14 participants and 27 Jun 2020 attended by 15 participants. All the OHS committee mem- ber attended on that meeting. The minutes of meeting record for that three month above the containt discussed was OHS trend issues, OHS perforamce, accident and incident record, workers welfare, and others. The OHS brief also dessiminated to contractors conducted on 17 Apr 2020 attended by 60 participants form CPO transporter contractors. OHS brief also deliver to internal workers in peridocially manner, where the last activitiy was on 21 Feb 2020 attended by all mill workers department. Next, on 4 March 2020 the similar activity also conducted and attended by 75 partici- pants.

R & O 6.7.2 Accident and emergency procedures are in place and instructions are clearly understood by all workers. Accident procedures are available in the appropriate language of the workforce. Assigned operatives trained in first aid are present in both field and other op- erations, and first aid equipment is available at worksites. Records of all accidents are kept and periodically reviewed a. Are there SOPs for handling of accidents and emergency? Remote audit result b. Are the accident procedures available in appropriate language of the workforce? The company (mill and estate) has established procedure for accident reporting and investigations, document Yes c. Are the SOPs cover all major potential emergencies, such as, but not limited to fire, chemical spillage, and potential no.REA.BPO.HSE.PIK, issued date on 25 Sep 2016. This procedure required that accident investigations shoud carry No natural disasters specific for the region, e.g. earthquakes, volcanoes, etc.? out at least within 8 hours after accident and should resolved within no later that 48 hours. Then, for emergency pre- N.A d. Are accidents investigated and action taken to prevent recurrence? paredness the procedure also in place, with document no.REA.BPO.HSE.STD, issued date on 25 Sep 2016. This pro- e. Are accident reported to the local authority in accordance with local legal requirements cedure required the emergency response must be carry out every six month or every once a year or if any specific NCR No : - f. Are the instructions on emergency procedures clearly understood by all workers? condition. The emergency type dfined by procedure was hazardous contamination, hydrocarbon contamination, natu- g. Are assigned operators trained in First Aid present in both field and other operations? ral disaster, and others. h. Is there records of training of the first aiders? When was the last training conducted? The company has record of investigation accident for 2019 and 2020. Records of accident also was in place and able i. Is first aid equipment available at worksites? Is the equipment available during conduct of field manual work? to show during the audit process. The records also presented the accident statistically records for all estate, and peri- j. Are first aid kits adequately stocked and regularly checked in accordance with legal requirements? odically discussed in the OHS Committee monthly meeting and reported to the local authority per three months. The k. Are records of all accidents kept and periodically reviewed? When was the last review carried out? responsible person for first aid (P3K) already trained by company, where the last training conducted on 24 Mar 2020 attended by 25 participants, 27 Mar 2020 attended by 18 participants, 30 Mar 2020 attended by 25 participants, and 17 Mar 2020 attended by 16 participants. Where the first aid simulation conducted on 12 Mar 2020 attended by 14 participants. The estate has first aid licensed operator, with registration no.566/046/III/PPL/DTK/2018, valid until 01 Jan 2021, issued by Labour and Transmigration Authority Local Government of East Kalimantan.

Onsite verification result Kedaron estate has qualified person for first aid in work place, based on certificate issued date on 30 Jan 2018, issued by Directorate General of Labour Inspections and Occuaptional Safety and Health Development, Ministry of Manpower of The Republic of Indonesia. The last first aid traning conducted on 24 Oct 2019 attended by 18 participants from harvester and sprayer foreman, with trainier from paramedic registered as first aid licensed.

In Berkat estate, the accident record was in place, and became one of OHS meeting agenda discussion in monthly. The accident also investigated by responsible to check and trace the rootcouse of the accident. For person incharge in first aid, the company assigned paramedic who responsible and deliver knowledge regarding first aid to all foreman in the field. The first aid training record conducted on 18 Mar 2020 attended by 39 participants with trainer came from MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS company doctor.

For Damai estate, the accident record was in place, and became one of OHS meeting agenda discussion in monthly. The accident record was in place and already as one of OHS meeting agende in monthly. The accident also investi- gated by responsible to check and trace the rootcouse of the accident. For person incharge in first aid, the company assigned paramedic who responsible and deliver knowledge regarding first aid to all foreman in the field. The first aid training record conducted on 17 Mar 2020 attended by 16 participants with trainer came from company doctor.

While for Cakra estate, the accident record was in place, and became one of OHS meeting agenda discussion in monthly. The accident record was in place and already as one of OHS meeting agende in monthly. The accident also investigated by responsible to check and trace the rootcouse of the accident. For person incharge in first aid, the company assigned paramedic who responsible and deliver knowledge regarding first aid to all foreman in the field. The first aid training record conducted on 12 Mar 2020 attended by 34 participants with trainer came from company doctor.

Cakra Oil mill has record of OHS implementation such as OHS brief to all thirdparty contractors to increase the OHS awareness from

O 6.7.3 (C) Workers use appropriate personal protective equipment (PPE), which is provided free of charge to all workers at the place of work to cover all potentially hazardous operations, such as pesticide application, machine operations, land preparation, and harvest- ing. Sanitation facilities for those applying pesticides are available, so that workers can change out of PPE, wash and put on their personal clothing a. Are all the workers provided with PPE as identified in the risk assessment carried out? Onsite verification result b. Is adequate and appropriate PPE available to all workers at the place of work to cover all potentially hazardous op- The company has established procedure regarding personal protective equipment (PPE), document no. Yes erations, such as pesticide application, machine operations, land preparation, and harvesting? REA.BPO.HSE.APD, issued date on 25 Aug 2016; rev 01, revision date 18 May 2018; effective date on 25 Sep 2016. No c. Is the PPE provided to workers free of charge and replaced when damage? This procedure explained clearly regarding lifetime for every tipe of PPE’s. Record of PPE’s distribution to all workers N.A d. Does the organization maintain a list of PPE distribution? in all division was in place, example in division 05, districubution of protective clothes, rubber glove, chemical mask to e. Are all workers involved in the operation appropriately trained in safe working practices and trained in the use of the the 9 (nine) sprayer works on 1 Feb 2020. NCR No : - PPE? Based on-site to the Kedaron estate, verification in division 03, block no. 3B (harvesting); division 03, block no. 1E (en- f. Are workers observed to be wearing appropriate PPE at the worksite? richer), division 05, block no. 23G (sprayer – manual weeding), during interviwed and direct verification all workers g. Are Safety Data Sheet (SDS) for pesticides used readily available for easy reference? able to explained regarding PPE’s type they need, the PPE’s able to replace any time, and they worked with used h. Are there sanitation facilities available for workers handling pesticides to change out of PPE, wash and put on their complete PPE’s. Then, based on chemical warehouse verification, the SDS for all chemical/plant protection type was personal clothing? in place in local language (Bahasa). During interview, the sprayer workers in block no. 23G division 05 they able to i. How is the wastewater from the sanitation facilities handled to avoid land or water pollution? mentioned the negative effect of the plant protection used if exposure to their body. O 6.7.4 All workers are provided with medical care and covered by accident insurance. Costs incurred from workr elated incidents leading to injury or sickness are covered in accordance with national law or by the unit of certification where national law does not offer pro- tection a. Is there evidence that all workers are provided with medical care and covered by accident insurance by the compa- Onsite verification result ny? During interview in Kedaron estate, location block same as stated above (6.7.3) all workers said they already include Yes b. For accidents that have occurred, is there evidence that the affected workers received appropriate medical treat- in the medical care (national health insurance) BPJS Kesehatan. Records of health insureance registration card num- No ment, and was able to claim and receive compensation under the insurance policy (if relevant) ber and paid of insurance was in place. The paid document record content was registration number of workers, name, N.A c. Is there evidence that the insurance policies are valid? family member include, number (IDR) paid by company. d. Was there evidence that cost incurred from workrelated incidents leading to injury or sickness are covered in ac- Also for Cakra estate, the record of medical care insurance (BPJS Kesehatan) registration membership and payment NCR No : - cordance with national law or by the unit of certification where national law does not offer protection? paid document was in place. The medical care coverage all off family member (until third children). R & O 6.7.5 Occupational injuries are recorded using Lost Time Accident (LTA) metrics a. Is there a system in place to record the LTA? Onsite verification result b. Are the records been monitored and regularly reviewed? The LTA was recorded by estate for year 2019. For Kedaron, Berkat, Damai, Cakra estate and Cakra oil mill, the LTA Yes c. Who records the LTA? Was he/she been trained? data has been reported to the Labour Official Government of East Kalimantan. The responsible who recorded the LTA No d. When was the last reviewed on LTA been carried out? was OHS Specialist of Berkat estate. The LTA reviewed in monthly during OHS periodically meeting. N.A

NCR No : -

Principle 7 : Protect, Conserve and Enhance Ecosystems and the Environment

7.1 IPM plans are implemented and monitored to ensure effective pestcontrol

R & O 7.1.1 (C) IPM plans are implemented and monitored to ensure effective pest control a. Is there a documented IPM plan? Remote and Onsite audit result b. Does the IPM plan include among others the following? a. The company has a document IPM plan 2020 and IPM plan monthly. Yes - Identification of potential pests and thresholds b. This document explain about date plan, activity (Census, insecticide control, upkeep beneficial plant), block, No - The techniques used (cultural, biological, mechanical and physical methods)? chemical used, manual method, amount worker, etc. N.A - The native species used as part of the biological control method? c. Company has established procedure document no.REA.EST.OPP.IPM, Issue No.1, Issue date on 1 Jul 2018, - help in reducing the use of chemicals over a period of time? Rev00, Effective date on 1 Aug 2018 regarding Integrated Pest and Diseases Management. The procedure con- NCR No : - - Prophylactic use of pesticides tain about preventive program through beneficial plant breeding, planting and care of beneficial plant, breeding of - Minimization of pesticide use Owl and maintain the existence of natural enemies and predators. - Review on the plans to suit the present condition such as replanting? d. There is record of pest occurrence and control, example at block B10a, rat pest control with result moderate. The c. Is there an SOP to implement the plan and monitor its effectiveness? company has controlled using rancumin chemicals d. Is there records of pest occurrence and control? e. No e. Is there any sign of fire use for pest control? f. There is record of pest occurrence and control, example: f. Is there any sign of rat pest dropping in the area? 1. Block 057C division 1 cakra estate, caterpillar (Darna trima) control with result moderate. The estate g. Is there training conducted on IPM? has controlled take a cocoon 2. Cakra estate: block 27C, date 27 February 2020, and rat pest control with result zero 3. Berkat estate: block 16A, date 28 February 2020, and rat pest control with result zero 4. Damai estate: block 18C, date 11 April 2020, and rat pest control with result zero MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS g. There is training conducted of IPM: 1. Lestari estate on 6 March 2019 with 23 participants 2. Cakra estate 21 February 2019 with 23 participants 3. Damai estate 12 April 2019 with 10 participants 4. Berkat estate 15 April 2019 with 24 participants 5. Kedaron estate 4 march 2019 with 31 participants R 7.1.2 Species referenced in the Global Invasive Species Database and CABI.org are not to be used in managed areas, unless plans to prevent and monitor their spread are implemented a. Is the company personnel aware of the Global Invasive Species and CABI.org? Remote audit result b. Are the listed species not used in the area? If in used, are the plans to prevent and monitor their spread implement- Not applicable Yes ed? No c. Is there monitoring been carried out? N.A

NCR No : -

O 7.1.3 There is no use of fire for pest control unless in exceptional circumstances, i.e. where no other effective methods exist, and with ap prior approval of government authorities. [For NI to define process] a. Is there SOP for pest control established? If yes, is the procedure included the handling of pest during normal and Onsite verification Result exceptional situation? Company has established procedure document no.REA.EST.OPP.IPM, Issue No.1, Issue date on 1 Jul 2018, Rev00, Yes b. Is the procedure specified fire is not used for pest control, unless it is permitted by authorities? Effective date on 1 Aug 2018 regarding Integrated Pest and Diseases Management. The procedure contain about pre- No ventive program through beneficial plant breeding, planting and care of beneficial plant, breeding of Owl and maintain N.A the existence of natural enemies and predators. This procedure included the handling of pest during normal and ex- ceptional situation situation (example, no use of fire for pest control unless in exceptional circumstances). NCR No : -

7.2 Pesticides are used in ways that do not endanger health of workers, families, communities or the environment

R & O 7.2.1 (C) Justification of all pesticides used is demonstrated. Selective products and application methods that are specific to the targetpest, weed or disease are prioritised a. Is the justification of all pesticides used been demonstrated? Remote and Onsite audit result b. Is there SOP for use of selective products that are specific to target pests, weeds, or diseases and which have min- a. Considering the nature of company’s condition and target pest, weed or disease, and following recommendation Yes imal effect on non-target species? Is the procedure included the following : from List of Pesticide in company used, the company use some listed pesticide as determine on document List No  Measures to avoid the development of resistance (such as pesticide rotation) are identified and applied, where of pesticides Stock in the main warehouse each estate where all of pesticides used has been well demonstrated N.A possible b. The company has procedure of pest and disease no. No. REA.EST.OPP.IPM, Issue No.1, Issue date on 1 Jul  List of all pesticide with target species and justification of the use 2018, Rev00, Effective date on 1 Aug 2018. This procedure states that use of selective products that are specif- NCR No : -  Consideration of using less harmful alternatives ic to target pests, weeds, or diseases and which have minimal effect on non-target species. c. Is there evidence of implementation of SOP on the ground? c. The procedure has been implemented, example census pest and disease every day and UPDTKS. O 7.2.2 (C) Records of pesticides use (including active ingredients used and their LD50, area treated, amount of activeingredients appliedper ha and number of applications) are provided a. Is there a pesticide application program? On-site verification result b. Are records of pesticides use available? a. The company has a pesticide application program year 2019 Yes c. Do the records detail the active ingredients used and their LD50, area treated, amount of active ingredients applied b. Records of pesticides use (including active ingredients used and their LD50, area treated, amount of active in- No per ha and number of applications? gredients applied per ha and number of applications) is provided on Agrochemical and pesticides Toxicity Moni- N.A toring for Year 2019 as show on Herbicide and Pesticide Toxicity estimation from January to December 2019 monitoring program in company NCR No : - c. The company has record detail the active ingredients used and their LD50, area treated, amount of active ingre- dients applied per ha TOTAL Pestisida 2018 2019 Amiphosate (L) 53,239.63 53,490.50 Amiron 20 Wg (Kg) 2.68 - Amfas (L) - 634.60 Chepate (Kg) 171.00 1,546.00 Kenrene (L) 265.10 - Basta (L) 392.11 408.96 Agristik (L) - 394.90 Klerat (kg) - 15.00 Mantene 75 SP (Kg) 732.80 831.30 Run UP 486 SL (L) - - Sidarat (Kg) - 135.00 Trendy 20 WP (Kg) - 283.55 Weedrol 866 SL (L) 973.07 9.00 Winson 20 WG (Kg) - 52.40

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS Kenlly 20 WG (Kg) - 382.02 Alkylaril Poliglikol Eter (Ltr) - 130.06 Metil Metsulfuron 20% (Kg) - 117.88 Trap 20 WP (Kg) - 0.89 Inteam 150 SL (Ltr) - 93.00 Xilaw (Kg) - 2.00 Amonium Glufosinat (Kg) - 17.00 Fluroksipir Meptil Ester 288 G/L (Kg) - - Garlon (Ton) - 14.00 Becano 500 SC (Kg) - 3.82 Triklopir (Ltr) - 44.00 Total 57794.385 60624.88

Quantity Quantity / ha Estate Ingredient Unit 2018 2019 2018 2019

IPA Glyphosate liter 29,653.08 27,329.40 0.391 0.357 Methil Metsulfuron kg 341.56 543.68 0.006 0.007

Lestari Ammonium Glufosinat liter 625.30 64.74 0.127 0.014 Indaziflam liter 6.24 0.006

Alkilaril poliglikol eter liter 907.03 639.54 0.022 0.013

IPA Glyphosate liter 28,527.20 28,266.40 0.537 0.456 Methil Metsulfuron kg 249.64 290.75 0.022 0.018 Ammonium Glufosinat liter 1,173.50 0.413 Cakra Triklopir liter 379.00 0.035

2.4 D Dimetil amine liter 27.00 0.022

Asefat liter 5.00 2.500

IPA Glyphosate liter 13,898.00 9,459.15 0.605 0.321 Indaziflam kg 0.42 0.001

Ammonium Glufosinat liter 185.50 247.50 0.195 0.035

Damai Methil Metsulfuron liter 226.32 289.42 0.012 0.009 Asefat liter 940.44 1.340

Alkilaril poliglikol eter liter 379.20 509.77 0.025 0.016

Brodifakum kg 113.50 2.052

IPA Glyphosate liter 16,094.40 21,150.00 0.370 0.354 Methil Metsulfuron kg 292.70 356.00 0.009 0.009 Ammonium Glufosinat liter 668.00 0.076

Berkat Indaziflam liter 4.00 0.001

Triklopir liter 116.00 0.009

Asefat kg 2,581.00 1.833

Alkilaril poliglikol eter liter 56.00 368.00 0.064 0.010

Kedaron IPA Glyphosate liter 62,494.76 62,405.95 0.978 0.726

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS Methil Metsulfuron kg 1,470.28 1,119.22 0.031 0.015 Fluroksipir MHE liter 342.00 0.090

2.4 D Dimetil amine liter

Brodifakum kg 452.00 0.159

O 7.2.3 (C) Any use of pesticides is minimised as part of a plan, eliminated where possible, in accordance with IPM plans a. Is there evidence of IPM plan being implemented? Onsite verification result b. Are there records showing that the use of pesticides have been minimised, eliminated where possible, in accord- The company shows that any use of pesticides has minimised as part of a plan, and in accordance with Integrated Yes ance with Integrated Pest Management (IPM) plan? Pest Management (IPM) plans. There was not found prophylactic use of pesticides. No N.A

NCR No : -

O 7.2.4 There is no prophylactic use of pesticides, unless in exceptional circumstances, as identified in national best practice guidelines a. Has there been prophylactic use of pesticides? If so, any justification provided? Onsite verification result b. Is justification provided in accordance to national best practices guidance? There was not found prophylactic use of pesticides Yes No N.A

NCR No : -

R & O 7.2.5 Pesticides that are categorised as World Health Organisation Class 1A or 1B, or that are listed by the Stockholm or Rotterdam Conventions, and paraquat, are not used,unless inexceptional circumstances,as validated by a due diligence process, or when author- ised by government authorities for pest outbreaks. The due diligence refers to : a) Judgment of the threat and verify why this is a major threat b) Why there is no other alternative which can be used c) Which process was applied to verify why there is no other less hazardous alternative d) What is the process to limit the negative impacts of the application 7.2.5 e) Estimation of the timescale of the application and steps taken to limit application to the specific outbreak. a. Is there a policy, procedure or management plan committing to minimise and eliminate use of these pesticides and Remote and On-site audit result paraquat? a. Any use of pesticides has minimised as part of a plan (based on environment and conservation Policy 003 Yes b. Is the pesticides used in the company been cross checked with the WHO class 1A, class 1B, and Stockholm or Rot- /BOD_REA/ P/ II / 2015, as amended April 2020. No terdam Conventions pesticide? b. Stock identification for the chemical, which include in the list of WHO chemical class 1A, or 1B, Stockholm con- N.A c. Does physical verification of inventory in the chemical store match with the inventory records? vention and Rotterdam convention has been identified. Based on document review, during year 2019 and 2020, d. Are there records of minimisation of pesticides and paraquat use? the company used Gliphosate and metyl metsulfuron herbicides. Its ingredients are not categorized as WHO NCR No : - e. Where there is the use of the above pesticides or paraquat, has justification in line with national best practice guide- Class 1A or 1B and not listed on the Stockholm or Rotterdam convention. lines been documented? c. Based on verification of inventory in the chemical store match with the inventory records, example stock report monthly per 30 November 2019 d. Any use of pesticides has minimised as part of a plan, and in accordance with Integrated as seen on Application of Fertilizers and Pesticides use Planning 2019. Records of pesticides use including active ingredients used and their LD50, area treated, amount of active ingredients applied per ha and number of applications is provided i.e. round up which consist of Isopropil Amina Gliposat as request to apply as herbicide in estate. e. Based on Records of pesticides use year 2019 and 2020 not used paraquat and pesticides used Isopropil Ami- na Gliposat and and metyl metsulfuron.

R & O 7.2.6 (C) Pesticides are only handled, used or applied by persons who have completed the necessary training and are always applied inaccordance with the product label. All precautions attached to the products are properly observed, applied, and understood by work- ers (see Criterion 3.6). Personnel applying pesticides must show evidence of regular updates on the knowledge about the activity they carry out a. Is there SOP for chemicals/pesticides handling? Remote and On-site audit result b. Is there a training plan and training records for workers who apply or handle pesticides? a. There is procedure for chemical/pesticides handling: Yes c. Is there evidence that training has been conducted and understood by the workers? Application of pesticides has proven methods that minimise risk and impacts as seen on documented proce- No d. Are pesticides handled, used or applied only by persons who have completed the necessary training? dures below: N.A e. Are the workers involved in chemical handling or application able to demonstrate understanding of the hazards and  Materials handling, document no. REA.EP.004, dated 22 July 2015. risks related to chemicals used when interviewed?  Working instruction of Storage of Herbicide, document no. WI.REA.BPO.MED.EST.PYH, dated 1 De- NCR No : - f. Are pesticides always applied in accordance with the product label? cember 2015. g. Are Safety Data Sheet (SDS) for pesticides used readily available for easy reference?  Working instruction of Measure and Mixing of Herbicides, document no. WI.REA.BPO.MED.EST.PPH, h. Is appropriate safety and application equipment provided and used? dated 1 December 2015. i. Is PPE used appropriate according to recommendations in any risk assessments done?  Working instruction of Spraying, document no. WI.REA.BPO.MED.EST.PYT, dated 1 December 2015. j. Is appropriate PPE provided and used, and can the PPE be easily replaced if damage? b. Training of those involved in chemicals/pesticides handling has demonstrated as stated on document of Attend- ance list in 7 & 12 March 2018 with 46 participants. The company also refreshment training every month for ma- nuring and spraying worker. c. Based on result evaluation training with spraying worker, they understood about chemical/pesticides handling d. Training of those involved in chemicals/pesticides handling has demonstrated as stated on document of Attend- ance list in 10-15 February 2020 with 149 participants. The company also refreshment training every month for manuring and spraying worker. e. Training of those involved in chemicals/pesticides handling has demonstrated as stated on document of Attend- ance list in 10-15 February 2020 with 149 participants. The company also refreshment training every month for MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS manuring and spraying worker f. Considering the nature of company’s condition and target pest, weed or disease, and following recommendation from List of Pesticide in company used. The company use some listed pesticide as determine on document List of pesticides Stock in the main warehouse company where all of pesticides used has been well demonstrated. The list of pesticide has been approved as seen on the Decree of Head of Manpower & Transmigration Agency of Kutai Kartanegara District, No.090/0587/PPK/DTKT/2019 dated 20 March 2019 and valid until 20 March 2020. The use of selective products that can prove have minimal effect on non-target species shall be used where available g. Safety Data Sheet (SDS) for pesticides used readily available for easy reference. The socialization of MSDS on 10-15 february 2020 with 149 participants h. Available minutes of PPE handover to chemical employees: - Berkat estate: Heni Kuswati on 2019 & 2020 for Apron, carbon masks, gloves, helmets, and safety shoes - Cakra estate: Suleman on 2019 for Apron, carbon masks, gloves, helmets, and safety shoes - Damai estate: Yustin on 14/3/2020 for Apron, gloves, and spectacles i. Based on procedure of PPE (REA.BPO.HSE.APD, issue date 25 Augustus 2016, effective date 25 September 2016) stated that PPE used appropriate according to recommendations in any risk assessments j. Based on procedure of PPE (REA.BPO.HSE.APD, issue date 25 Augustus 2016, effective date 25 September 2016) stated that the PPE be easily replaced if damage. O 7.2.7 (C) Storage of all pesticides is in accordance with recognised best practices Note to auditor : refer to the safety data sheet on storage and disposal a. Is the storage of all pesticides followed the recognised practices? Remote and On-site audit result Storage of all pesticides were according to recognised best practices. All pesticide containers has properly disposed of Yes and not used for other purposes. All containers ex pesticides was disposed to third party which has licenses to No transport and further disposed. N.A The company has a mechanism in the storage of pesticides contained in working instruction of Storage of Herbicide, document no. WI.REA.BPO.MED.EST.PYH, dated 1 December 2015. Application of pesticides has proven methods NCR No : - that minimise risk and impacts. O 7.2.8 All pesticide containers are properly disposed of and/or handled responsibly if used for other purposes a. Is the storage of all pesticides followed the recognised practices? Onsite verification result b. Is there evidence that empty pesticide containers are properly stored and disposed off and not used for other pur- The unit of certification have a documented procedure on how to handling hazardous waste (empty container ex pesti- Yes poses? cides), i.e SOP “Pengelolaan limbah”, document no. REA.BPO.EMS.WSM, date 14 March 2020. All of hazardous No c. Is there evidence observed in the field that pesticide containers are indiscriminately disposed (in dump site) or used waste (including empty container ex-pesticides) stored on temporary hazardous waste store (TPS LB3). Then, the N.A for other purposes, .e.g. as waste containers, flower pots? waste disposed off to third party who has licenses for further processes. Based on field during this surveillance audit, all the plant protection container are handling well, with rinse prior to dis- NCR No : - posal to the hazardous waste. There is no re-used activity for plant protection continer. R & O 7.2.9 (C) Aerial spraying of pesticides is prohibited, unless in exceptional circumstances where no other viable alternatives are available.This requires prior government authority approval. All relevant information is provided to affected local communities at least 48 hours prior to application of aerial spraying a. Has aerial spray been applied? If yes, is there documented justification and approval by the government authority? Remote audit result b. Is the impact and risk associated with aerial application documented and made available? The company did not applied aerially spraying. Yes c. Are the identified affected communities informed of impending aerial pesticide applications and are the information No given at least 48 hours prior to application of aerial spraying? Onsite verification result N.A d. What are the information given to local communities and how was it communicated? NCR No : -

O 7.2.10 (C) Specific annual medical surveillance for pesticide operators, and documented action to treat related health conditions, is demonstrated a. Is there an updated list of pesticide operators Onsite verification result b. Is there records of annual medical surveillance of pesticide operators? The unit of certification has been provided specific annual medical surveiance for their workers who handling pesti- Yes c. Is there evidence of documented action taken to treat related health condition? cides every 6 (six) month. Records of surveillane are available. For example: the surveillance, employee number who No d. Are there any trends of workers being absent due to incident related to pesticide usage? attended for specific medical surveillance as follow: N.A e. - Total employee Kedaron estate: 103 workers consist of 92 female and 11 male. - Total employee Berkat estate: 42 workers consist of 29 female and 13 male. NCR No : - - Total employee Cakra estate: 50 workers consist of 41 female and 9 male - Total employee Damai estate: 48 workers consist of 11 female and 3 male All of spraying workers, mandora, and store staff who handing pesticides has done specific medical test and the result of workers are normal on 25-29 September 2019. There is worker with result above threshold an Arli at Damai estate. This worker has moved to another working (selective manual), there is evidence of rotation working document. Semester I 2020 still progress for specific medical test. Why still progress because there is pandemic covid-19. O 7.2.11 (C) No work with pesticides is undertaken by persons under the age of 18, pregnant or breast feeding women or other people that have medical restrictions and they are offered alternative equivalent work a. Is there a policy/SOP preventing persons under the age of 18, pregnant and breast-feeding women from handling Onsite verification result pesticides? The company has a policy no. 002/BOD_REA/P/II/2015 date 9 April 2020 regarding prohibition of pregnant and Yes b. Is there a lists of female workers handling pesticides? breastfeeding women work with chemical (pesticides). Based on-site interview with pesticides spraying workers, the No c. What is the mechanism established to identify pregnant and breast-feeding women? workers already aware about this and no female worker being pregnant and breast-feeding. The company has imple- N.A d. Is there evidence showing person under the age of 18, pregnant and breast-feeding women are not allowed to han- mented a mechanism to identify pregnant and breastfeeding women. If any pregnant or breastfeeding women, she is dle pesticides? going too offered to other work. NCR No : - Persons under 18 ages are not allowed to work within the unit of certification and no found workers under the age 18 years old during this surveillance audit. 7.3 Waste is reduced, recycled, reused and disposed of in an environmentally and socially responsible manner

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. Is the list of waste products produced identified? Remote audit result b. Is the waste management plan available? The company has an identification of waste source for mill and estate such as generator, fertilizing, workshop, chemi- Yes c. Is the plan included management and operation prescriptions for reduction, recycling, reusing of the waste? cal store, spraying, office, emplacement, harvesting, clinic, FFB transportation. The company has a waste manage- No d. Is there evidence of implementation of the plan? ment plan related reduction, recycling, reusing and disposal to third party that have a license. The company has a rec- N.A ord of disposal waste. The company has been handling related domestic waste properly. The company has equipped the waste bin including organic waste and anorganic waste. The company conduct transporting of domestic waste NCR No : twice a week. O 7.3.2 Proper disposal of waste material, according to procedures that are fully understood by workers and managers, is demonstrated a. Is there an SOP for proper disposal of waste material? Onsite verification result b. Is there training provided to workers and managers on proper waste disposal? The company has a documented procedure for proper disposal of waste i.e.: “SOP Pengelolaan limbah”, document Yes c. Is there evidence of implementation of proper ways for waste disposal by the company? no. REA.BPO.EMS.WSM, date 14 March 2020. All of hazardous waste are temporary stored on temporary storage of No hazardous waste as required by regulation. The temporary storage has valid license that issued by authority agency, N.A i.e. 1. Kedaron estate has Temporary Hazardouse Waste Storage (TPSLB3) which has permit issued by Environment NCR No : Agency of Kutai Timur District No 660/K.806/2017 date issued November 9, 2017 valid for 5 years. 2. Cakra estate: License of temporary storage of hazardous waste of Cakra Estate, No. 660.1/277/BLHD-I/2016, dated 30 December 2016, valid for next 5 (five) years since issuance 3. Damai estate: License of temporary storage of hazardous waste of Damai Estate, No. 660.1/273/BLHD-1/2016, dated 30 December 2016, valid for next 5 (five) year since issuance 4. Berkat estate: License of temporary storage of hazardous waste of Berkat Estate, No. 660.1/274/BLHD-1/2016, dated 30 December 2016, valid for next 5 (five) year since issuance 5. Lestari estate: License of temporary storage of hazardous waste of Lestari Estate, No. 660.1/270/BLHD-1/2016, dated 30 December 2016, valid for next 5 (five) year since issuance 6. Cakra POM: License of temporary storage of hazardous waste of Cakra POM, No. 660.1/117/BLHD-I/2016, dat- ed 24 May 2016, valid for next 5 (five) years since issuance

Kedaron estate: Kedaron estate disposed all hazardouse waste to approved vendor namely PT Ilham Jaya Bersama which has licence valid for 5 years started from January 3, 2017 as decree letter No 503/002/LINGK/DPMTSP/I/2017 and PT Karunia Lumasindo Pratama which has licence valid for 1 years started from 1 July 2019 as decree letter No 003/SPK/KMS- BPN/V/2019 (there are amandement for this agreement for extend 6 month). Cakra, Berkat, and Damai estate: All estate disposed all hazardouse waste to approved vendor namely PT Ilham Jaya Bersama which has licence valid for 1 years started from 1 July 2019 as decree letter No 008/SPK/REA-BPP/V/2019 and PT Karunia Lumasindo Pratama which has licence valid for 1 years started from 1 July 2019 as decree letter No 006/SPK/REA-BPN/V/2019 (there are amandement for this agreement for extend 6 month).

Records of hazardous waste are maintained suh as logbook of hazardous waste, minute of hazardous waste hando- ver, manifest of hazardous waste, and etc. The unit of certification has reported their activities about waste to the au- thority agencies regularly every 3 (three) month. Herewith records of report for period year of 2020: - Periods January to March 2020: dated April 10, 2019. The report has been submitted to: 1) head of environmen- tal agency of Kutai Timur Dstrict; 2) head of environmental agency of Kalimantan Timur province; 3) head of ecoregion center of Kalimantan at Balikpapan; and 4) ministry of environmental and forestry at Jakarta. – Kedaron estate - Periods April to June 2020, dated 12/8/2020. The report has been submitted to: 1) head of environmental agen- cy of Kutai Timur Dstrict; 2) head of environmental agency of Kalimantan Timur province; 3) head of ecoregion center of Kalimantan at Balikpapan; and 4) ministry of environmental and forestry at Jakarta. – Kedaron estate O 7.3.3 The unit of certification does not use open fire for waste disposal a. Is there evidence that waste has not been disposed off using open fire? Onsite verification result Based on field visit during this surveillance, there is evidence that the waste (hazardous waste and domestic waste Yes has disposed off in accordance relevant regulations and best practices. The unit of certification has not using open No fire. N.A

NCR No :

7.4 Practice maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimsl and sustianed yield

R & O 7.4.1 Good agriculture practices, as contained in SOPs, are followed to manage soil fertility to optimise yield and minimise environmental impacts

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. Are there SOPs for Good Agricultural Practices included managing soil fertility to optimise yield and minimise envi- Remote and On-site audit result ronmental impacts? a. The company has established procedure/work instruction for maintain soil fertility; such as: SOP for Manuring Yes b. Is there evidence that the SOPs have been implemented and monitored? No. REA.EST.OPP.MNR, issue No. 01, dated on 1 July 2018 No c. Is there any comparison made from the previous year with regard to the implementation of GAP? If yes, was the in- b. Actual fertilizer applications recorded monthly and compared against fertilizer recommendations in the monthly N.A formation used to optimise yield and minimise the environmental impact? estate manager’s report with summary of reconciliation of fertilizer application schedule. Fertilizer application schedule and records for each field is available and maintained at the respective estate offices NCR No : - c. The company has comparison made from the previous year with regard to the implementation of GAP in docu- ment management review. Table fertilizer use in first semester in 2020 (Jan – Jul) Berkat Kedaron Estate Cakra Damai estate estate Urea Kg 121,400.00 270,990 107,000 600,400 RP Kg 617,730.00 502,190 532,850 717,850 MOP Kg 6,046.40 - - 112,800 Kieserite Kg 482,544.40 409,500 92,200 298,905 Borate Kg 18,300.40 - 19,060 35,510 Hi-key kg - 333,580 - -

R 7.4.2 Periodic tissue and soil sampling is carried out to monitor and manage changes in soil fertility and plant health a. Are there records of tissue and soil analysis? Remote audit result b. How regular is this been done and when was the last analysis done? a. There are record of soil analysis and tissue analysis year 2019 by Socfindo. Yes Note to auditor : to compare the analysis against the previous year b. Foliar sampling conducted on an annual basis and its results and corresponding fertilizer recommendations are No c. Are the results of the analysis incorporated into the fertilizer program? contained in the soil analysis result. The leaf nutrient assessment to determine the levels of nitrogen, phospho- N.A rus, potassium, calcium, magnesium and boron in the palms was conducted. Soil analysis also conducted five year. The company has record of soil analysis that conduct on year 2019. NCR No : - c. Decision on fertilizer usage is taken based on Oil Palm Manuring Recommendation Report of year 2020, which was established according to annual leaf tissue sample analysis result. The recommendation is applicable for each block of Estate. Soil analysis have also been conducted in 2019 and this manuring recommendation have also considered the soil analysis result. R & O 7.4.3 A nutrient recycling strategy is in place, which includes the recycling of Empty Fruit Bunches (EFB), Palm Oil MillEffluent(POME),palm residues and optimal use of inorganic fertilisers a. Is there a nutrient recycling strategy in place? Remote and On-site audit result b. Is the strategy included the recycling of EFB, POME, palm residues and optimal use of inorganic fertilisers? a. There is a nutrient recycling with usage EFB. For nutrient recycling strategy. Yes c. Are there records of application? b-c The company has record of EFB application i.e.: No Berkat estate: during 2019 from January until December 2019 as large as 854.7 ha with total EFB as much as N.A 33,830 ton and year 2020 from January until July 2020 as large as 517.40 ha with total EFB as much as 23.927 ton NCR No : - Cakra estate: during 2019 from January until December 2019 as large as 429.71 ha with total EFB as much as 17,044.63 ton and year 2020 from January until June 2020 as large as 492.99 ha with total EFB as much as 19,804.04 ton Kedaron estate: during 2019 from January until December 2019 as large as 445.60 ha with total EFB as much as 12,859.82 ton and year 2020 from January until July 2020 as large as 98.51 ha with total EFB as much as 3,804.41 ton Damai estate: during 2019 from January until December 2019 as large as 602.21 ha with total EFB as much as 24,391.64 ton and year 2020 from January until July 2020 as large as 220.86 ha with total EFB as much as 9,001 ton. O 7.4.4 Records of fertiliser inputs are maintained Palm Oil Mill Effluent (POME), palm residues and optimal use of inorganic fertilisers a. Are records of fertiliser inputs maintained? Onsite verification result b. Is the fertiliser program linked to the agronomic report? If not are there any justification? Practices that maintain or enhance soil fertility to ensure sustained yield are contained in SOP for Manuring No. Yes c. Are there records of fertilizer usage per tonne of FFB production being monitored (in Summary Table, specific types REA.EST.OPP.MNR, issue No. 01, dated on 1 July 2018. No of fertilizers)? Actual fertilizer applications are recorded monthly and compared against fertilizer recommendations in the monthly N.A estate manager’s report with summary of reconciliation of fertilizer application schedule in the progress report. Ferti- lizer application schedule and records for each field is available and maintained at the respective estate offices. Sam- NCR No : - pled records for year (please inform the time/date/location) showed that fertilizer application is done according to the Expert recommendation ecord of fertilizer inputs maintained, e.g.: Table fertilizer use period January - July 2020

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS Berkat Kedaron Estate Cakra Damai estate estate Urea Kg 121,400.00 270,990 107,000 600,400 RP Kg 617,730.00 502,190 532,850 717,850 MOP Kg 6,046.40 - - 112,800 Kieserite Kg 482,544.40 409,500 92,200 298,905 Borate Kg 18,300.40 - 19,060 35,510 Hi-key kg - 333,580 - -

7.5 Practices minimise and control erosion and degradation of soils

R 7.5.1 (C) Maps identifying marginal and fragile soils, including steep terrain, are available a. Are there maps identifying marginal and fragile soils, including steep terrain and peat soils? Remote audit result During 3rd surveillance audit period, there is no revision regarding soil type information on the company concession Yes area. Based on soil map analysis issued by Param Agriculture Soil Surveys in Oct 2010 soil type of REA Kaltim Plan- No tation concession area consist of hapludults dystrudepts, endoaquepts haplohemist, endoaquepts, undisamments N.A hapludox, and hapludults kandiudults. This is also confirmed in the HCV assessment regarding soil type in Rea Kaltim Plantation concession area, issued on December 2015. NCR No : - The slope conditions of all supply based estate are located in undulating until hilly area but not more than 38%. Sam- ple taken in Cakra estate found the slope condition was: Slope class (%) Total (Ha) Undulating (4-12) 1,196.80 Rolling (12-24) 1,998.30 Hilly (24-38) 1,353.60 Steep (38-50) 42.40 Flat (0-4) 200.20 Total 4,791.30 Similar condition also present in Damai, Lestari and Berkat estate, map of slope for all estate available in place. O 7.5.2 There is no extensive replanting of oil palm on steep terrain a. Is there evidence of replanting on steep terrain (i.e. more than 25 degrees) greater than 25 ha within the replanting Onsite verification result area? The company has SOP for Soil Erossion, Terrain Conservation and Terrace Making No. REA.EST.OPP.CON, issue Yes b. If yes, when was the replanting done and what is the total replanting area at above 25 degrees? No. 04, dated on 1 July 2018 which explained slope classification such as flat (0-4,8° or 0-8,3%), undulating (4,8-8,1° No or 8,3-14,3%), hilly (steep)( 8,1-14° or 14,3-25%) dan very steep (> 14° or > 25%). N.A The SOP has explained about management strategy for terrain such as: Flat: LCC planting NCR No : Rolling: conservation terrace 2.5 m mechanically follow land contour. Steep: terrace, horse tread. Very steep: no oil palm planting. Based on terrain map of Kedaron estate that slope 0 – 12 degree, flat until rolling. No steep area and no peat soil The slope conditions of all supply based estate are located in undulating until hilly area but not more than 38%. Sam- ple taken in Cakra estate found the slope condition was: Slope class (%) Total (Ha) Undulating (4-12) 1,196.80 Rolling (12-24) 1,998.30 Hilly (24-38) 1,353.60 Steep (38-50) 42.40 Flat (0-4) 200.20 Total 4,791.30 Similar condition also present in Damai, and Berkat estate, map of slope for all estate available in place O 7.5.3 There is no new planting of oil palm on steep terrain a. Is there new plantings on steep terrain? Onsite verification result No new planting during audit. Yes No N.A

NCR No :

7.6 Soil surveys and topographic information are used for site planning in the establishmenet of new plantings, and the results are incorporated into plans and operations

R 7.6.1 (C) To demonstrate the long-term suitability of land for palm oil cultivation, soil maps or soil surveys identifying marginal and fragile soils, including steep terrain, are taken into account in plans and operations a. Has the unit for certification submitted NPP to RSPO? If no, how does the unit conducted its soil maps or soil sur- Remote audit result veys identifying the marginal and fragile soil, including the steep terrain? a. During surveillance audit no new planting activity conducted. During 3rd surveillance audit period, there is no revi- Yes b. Are the soil maps or soil surveys taken into account in plans and operations of the estates to ensure long term suit- sion regarding soil type information on the company concession area. Based on soil map analysis issued by No ability of land for palm oil cultivation? Param Agriculture Soil Surveys in Oct 2010 soil type of REA Kaltim Plantation concession area consist of hap- N.A c. Are the maps used to identify areas that are inappropriate for planting? ludults dystrudepts, endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kan-

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS d. Are there any new planting on unsuitable area as identify in the soil map? diudults. This is also confirmed in the HCV assessment regarding soil type in Rea Kaltim Plantation concession NCR No : - area, issued on December 2015. The slope conditions of all supply based estate are located in undulating until hilly area but not more than 38%. Sample taken in Cakra estate found the slope condition was: Slope class (%) Total (Ha) Undulating (4-12) 1,196.80 Rolling (12-24) 1,998.30 Hilly (24-38) 1,353.60 Steep (38-50) 42.40 Flat (0-4) 200.20 Total 4,791.30 Similar condition also present in Damai, Lestari and Berkat estate, map of slope for all estate available in place. b. The company have soil map with scale 1:50,000. As seen on the map, soil type of REA Kaltim Plantation conces- sion area consist of hapludults dystrudepts, endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kandiudults. This is also confirmed in the HCV assessment regarding soil type in Rea Kaltim Plan- tation concession area, issued on December 2015. Then, based on slope area it known that the slope conditions of all supply based estate are located in undulating until hilly area but not more than 38%. c. No marginal and fragile soils within Estate and smallholders areas. d. No new planting on unsuitable area. O 7.6.2 Extensive planting on marginal and fragile soils,is avoided, or, if necessary, done in accordance with the soil management plan for best practices a. Is there evidence of planting on marginal and fragile soils? Onsite verification result b. If yes in (a) above, how extensive is the area planted and was it done in accordance with the soil management plan During surveillance audit no new planting activity conducted. During 3rd surveillance audit period, there is no revision Yes for best practices? regarding soil type information on the company concession area. Based on soil map analysis issued by Param Agri- No c. Is the plan implemented? culture Soil Surveys in Oct 2010 soil type of REA Kaltim Plantation concession area consist of hapludults dystrudepts, N.A endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kandiudults. This is also confirmed in the HCV assessment regarding soil type in Rea Kaltim Plantation concession area, issued on December 2015. No NCR No : fragile soil and other problem soils at Damai, Berkat Lestari and Cakra estate.

The slope conditions of all supply based estate are located in undulating until hilly area but not more than 38%. Sam- ple taken in Cakra estate found the slope condition was: Slope class (%) Total (Ha) Undulating (4-12) 1,196.80 Rolling (12-24) 1,998.30 Hilly (24-38) 1,353.60 Steep (38-50) 42.40 Flat (0-4) 200.20 Total 4,791.30

Similar condition also present in Damai, Lestari and Berkat estate, map of slope for all estate available in place. Kedaron estate has soil map and terrain map with scale 1:55,000. Based on soil map that soil type is Tropudults Dys- tropepts 2,656.83 Ha and Tropudults Tropaquepts 4,664.32 Ha. No fragile soil and other problem soils. Based on ter- rain map that slope 0 – 12 degree, flat until rolling. No steep area and no peat soil. O 7.6.3 Soil surveys and topographic information guide the planning of drainage and irrigation systems,roads and other infrastructure a. Are the areas where planting was carried out require drainage or irrigation? Onsite verification result b. If yes, is there topographic information and soil surveys to guide the planning of drainage and irrigation system? There is a road maintenance programme that is rigorously adhered to. The road maintenance programme covers the Yes c. Is the topographic information and best practices taken into consideration during the development of roads and in- distribution of gravel stones, grading and compacting and levelling of estate roads, construction and maintenance of No frastructure? bridges as well as construction of silt pits especially near slopes to allow for water run-off into the pits and prevent ero- N.A sion of access roads. NCR No : Road maintenance program 2019 – 2020 available in place. Program and realization of road maintenance in 2019 as follow: Kedaron estate: Main road: 104,152 m period January –Juli 2020 Collection road: 174,785 m period January –Juli 2020 Berkat estate: Main road: 42,720 m period January –August 2020 Collection road: 58,750 m period January – August 2020 Damai estate Collection road: 412 m period January – August 2020 Cakra estate: Collection road: 46,980 m period January – August 2020

7.7 No new planting on peat, regardless of depth after 15 November 2018 and all peatlands are managed responsibly

R & O 7.7.1 (C) There is no new planting on peat regardless of depth after 15 November 2018 in existing and new development areas a. Is there peat in the unit of certification? If yes, please refer to RSPO Peat Audit Guidance for P&C 2018 Remote audit result Based on soil map analysis, no peat soil present in all estate. The soil type in all estate was hapludults dystrudepts, Yes endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kandiudults. No new planting hap- No pen in all estate. This criteria is not applicable. N.A MS-0034725-17.1 Rev.0

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Onsite verification result NCR No : - N/A

R & O 7.7.2 Areas of peat within the managed areas are inventoried, documented and reported (effective from 15 November 2018) to RSPO Secretariat. PROCEDURAL NOTE : Maps and other documentation of peat soils are provided, prepared and shared in line with RSPO Peatland Working Group (PLWG) audit guidance (see Procedural Note for 7.7.5 below) Refer to RSPO Peat Audit Guidance for P&C 2018 Remote audit result Based on soil map analysis, no peat soil present in all estate. The soil type in all estate was hapludults dystrudepts, Yes endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kandiudults. No new planting hap- No pen in all estate. This criteria is not applicable. N.A

Onsite verification result NCR No : - N/A

R & O 7.7.3 (C) Subsidence of peat is monitored, documented and minimised Refer to RSPO Peat Audit Guidance for P&C 2018 Remote audit result Based on soil map analysis, no peat soil present in all estate. The soil type in all estate was hapludults dystrudepts, Yes endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kandiudults. No new planting hap- No pen in all estate. This criteria is not applicable. N.A

Onsite verification result NCR No : - N/A

R 7.7.4 (C) A documented water and ground cover management programme is in place Refer to RSPO Peat Audit Guidance for P&C 2018 Remote audit result Based on soil map analysis, no peat soil present in all estate. The soil type in all estate was hapludults dystrudepts, Yes endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kandiudults. No new planting hap- No pen in all estate. This criteria is not applicable. N.A

Onsite verification result NCR No : - N/A

R & O 7.7.5 (C) For plantations planted on peat, drainability assessments are conducted following the RSPO Drainability Assessment Procedure, or other RSPO recognised methods, at least five years prior to replanting. The assessment result is used to set the time frame for future replanting, as well as for phasing out of oil palm cultivation at least 40 years, or two cycles, whichever is greater, before reaching the natural gravity drainability limit for peat. When oil palm is phased out, it is replaced with crops suitable for a higher water table (paludiculture) or rehabilitated with natural vegetation. PROCEDURAL NOTE: Full details of the RSPO Drainability Assessment Guidelines and related concepts and detailed actions are in the manual currently being fine-tuned/tested by PLWG. A final version should be approved by PLWG in January 2019 and will include additional guidance on the steps to be followed after the decision not to replant as well as implications for other stakeholders, smallholders, local communities and the unit of certification. It is recommended that a further twelve-month methodology trial period is proposed for all related management units (i.e. those with plantations on peat) to utilise the methodology and provide feedback to the PLWG to enable further refinement of procedure as appropriate before January 2020. Units of certification have the option to defer replanting till after the availability of the revised guidelines. Additional guidance on alternative crops and rehabilitation of natural vegetation will be provided by PLWG. PROCEDURAL NOTE: PLWG and the Smallholder Interim Group (SHIG) will collaboratively develop guidance for Independent Smallholders [cross links to SHIG and GHG issues] Refer to RSPO Peat Audit Guidance for P&C 2018 Remote audit result Based on soil map analysis, no peat soil present in all estate. The soil type in all estate was hapludults dystrudepts, Yes endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kandiudults. No new planting hap- No pen in all estate. This criteria is not applicable. N.A

Onsite verification result NCR No : - N/A

O 7.7.6 (C) All existing plantings on peat are managed according to the‘RSPO Manual on Best Management Practices (BMPs) for existing oil palm cultivation on peat’, version2 (2018) and associated audit guidance. Refer to RSPO Peat Audit Guidance for P&C 2018 Remote audit result Based on soil map analysis, no peat soil present in all estate. The soil type in all estate was hapludults dystrudepts, Yes endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kandiudults. No new planting hap- No pen in all estate. This criteria is not applicable. N.A

Onsite verification result NCR No : - N/A

O 7.7.7 (C) All areas of unplanted and set-aside peatlands in the managed area (regardless of depth) are protected as “peatland conservation areas”; new drainage, road building and power lines by the unit of certification on peat soils is prohibited; peatlands are managed in accordance with the ‘RSPO BMPs for Management and Rehabilitation of Natural Vegetation Associated with Oil Palm Cultivation on Peat’, version2 (2018) and associated audit guidance. Refer to RSPO Peat Audit Guidance for P&C 2018 Remote audit result Based on soil map analysis, no peat soil present in all estate. The soil type in all estate was hapludults dystrudepts, Yes endoaquepts haplohemist, endoaquepts, undisamments hapludox, and hapludults kandiudults. No new planting hap- No pen in all estate. This criteria is not applicable. N.A

Onsite verification result NCR No : - N/A

7.8 Practices maintain the quality and availability of surface and groundwater

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS R & O 7.8.1 (C) A water management plan is in place and implemented to promote more efficient use and continued availability of watersources and to avoid negative impacts on other users in the catchment. The plan addresses the following : a. The unit of certification does not restrict access to clean water or contribute to pollution of water used by communities. b. Workers have adequate access to clean water a. Is there a water management plan for mill and the estates? Remote and On-site audit result b. Is the plan includes the following? Estate has program water management plan to protect the water sourced in the estate. This management plan has Yes - Identification of water sources implemented by evidence record of water springs management. Kind of activity conducted by estates such as demar- No - Efficient use of water cation, fencing, and enrichment with vegetation of the water source area. N.A - Renewability of water source The company has not planned any replanting activities. The oldest planting is 2006. The company follows a replanting - Impacts on catchment area and local stakeholders cycle of 25 years. NCR No : - Access of clean drinking water all year round for workers The company carries out management to prevent water quality degradation in the water, i.e: - Avoidance of surface and ground water contamination  use fertilizers and pesticides in accordance with the specified dose, so as not to cause envi-ronmental pollu- c. Are the identified actions in the plan implemented? tion d. Is the company contribute to local communities programmes to protect, maintain and improve water sources?  Spraying on time, on the right dose and on target.  Fertilizing on time, on the right dose and on target  Provide water sources in each division for spraying activities  Application of fertilizing and spraying in accordance with procedures so as to reduce pollu-tion in water bod- ies.  Using pesticides that are easily biodegradable and environmentally friendly.

The company have map of watercourses and wetlands, SOP for riparian, and buffer zone protection. Records of im- plementation water management plan and water courses protettion are available, report of surface water quality anal- ysis and etc. Sources water has been used by worker from surface and ground water. The company has record used water year 2019 i.e: Kedaron estate: 13,160 m3 Berkat estate: 67,860 m3 Damai estate:110,355 m3 Cakra estate: 107,310 m3

The company has record of surface water of quality measurement result, surface water analysis by external laboratory (PT Unilab Perdana) who has approval and accredication from National Accreditation Committee, example: - Certificate Result No.5258/BPPI/BRSSd.1/STU/09/2019 for semester II 2019 (surface water). Based on meas- urement result the paramaters is below the standard. (Berkat estate) - Certificate Result No.LHP.KHT.1903.0713 for March 2020 (surface water – senyiur river)). Based on measure- ment result the paramaters is below the standard. (Kedaron estate) - The company have contributed to local communities programmes to protect, maintain and improve water sources by implement, monitor and evaluate the management plan and monitoring of HCV for 2019 for such as natural water courses and riparian along the location of PT Rea Kaltim. O 7.8.2 (C) Water courses and wetlands are protected, including maintaining and restoring appropriate riparian and other buffer zones in line with ‘RSPO Manual on BMPs for the management and rehabilitation of riparian reserves’ (April 2017). a. Is there a map identifying water courses and wetlands? Onsite verification result b. Are the water courses and wetlands protected in accordance with the RSPO Manual on BMPs for the management The company have map of watercourses and wetlands, SOP for riparian, and buffer zone protection. Records of im- Yes and rehabilitation of riparian reserves? plementation water management plan and water courses protettion are available, report of surface water quality analy- No c. Are the riparian and buffer zones maintained and restored in existing plantation and replanting areas? sis and etc. N.A d. Is there SOP for riparian and buffer zone protection? If yes, has it been implemented? NCR No :

R 7.8.3 Mill effluent is treated to be in compliance with national regulations. Discharge quality of mill effluent, especially Biochemical Oxygen Demand (BOD), is regularly monitored. a. Is the mill effluent treatment process in place? Remote audit result b. Is there a process in place for checking and monitoring water discharge quality, particularly BOD? a. The company has mill effluent treatment facility (IPAL) until land application. POM has mill effluent treatment Yes c. Is the effluent discharge quality in compliance with national regulations? facility (IPAL) consisted of 6 ponds. Flow chart as follow: mill effluent  biogas and fat pit or direct to cooling No d. Does the mill has the necessary license or permits from the authority for treatment, discharge or land application of pond  primary anaerobic 1 pond (pond 1)  primary anaerobic 2 pond (pond 2)  aerobic pond (pond 3)  N.A mill effluent? aerobic pond (pond 4)  land application. b. Appropriate treatment of mill effluent to required levels and regular monitoring of discharge quality, especially NCR No : - Biochemical Oxygen Demand (BOD) by environmental laboratory (Mutu certification international) accredited by KAN, has been in compliance with national regulations e.g.: January 2020, BOD was 314; February 2020, BOD was 1003; and March 2020, BOD was 613. c. Yes, see indicator above. d. POM has conducted land application of mill effluent. Land application permit No. 660.1/014/B.II.4/Bpdld/X/2008 dated on 17 October 2008 issued by Bupati Kutai Kartanegara and every year a review is conducted. R 7.8.4 Mill water use per tonne of FFB is monitored and recorded. a. Is there a plan to monitor and measure the mill water usage? If yes, is the plan been implemented? Remote audit result b. Are there records of mill water use per tonne of Fresh Fruit Bunches (FFB)? a. Yes. There is a plan to monitor and measure the mill water usage and implemented. See table below about wa- Yes ter usage 2019. No b. Mill water use per tonne of Fresh Fruit Bunches (FFB) has been monitored as seen on records of mill report. N.A c. Yes. There is a plan to monitor and measure the mill water usage and implemented. See table below about wa- ter usage 2019. NCR No : - d. Mill water use per tonne of Fresh Fruit Bunches (FFB) has been monitored as seen on records of mill report.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS Parameter TOTAL TBs Olah Ton 400,969

Inlet m3 445,278

Proses+Boiler m3 399,321

Domestik m3 45,957

Air/ Ton TBS m3/ton 1.11

7.9 Efficiency of fossil fuel use and the use of renewal energy is optimised

R & O 7.9.1 A plan for improving efficiency of the use of fosil fuels and to optimise renewable energy is in place, monitored and reported. a. Is there a plan for improving efficiency of the use of fossil fuels and to optimise renewable energy? Remote and On-site audit result b. Is the plan included the monitoring of the following? a. The company has implemented effort to improving efficiency of the use of fossil fuels and to optimize renewable Yes - Renewable energy use/tCPO or palm product; energy among others by utilized solid waste (shell and fiber) as fuels replaced fossil fuels. A plan for improving No - Direct fossil fuel use/tCPO or tFFB; efficiency of the use of fossil fuel has been implemented and monitored regularly. Based on the Emission Re- N.A - Estimated fuel use by on-site contract workers and transport and machinery operations; port 2019 that company has GHG emission reduction strategy included minimise fuel consumption. For year - Electricity use in operations. 2019 total fuel used 628,576 liter. NCR No : - c. Has the plan been implemented and monitored? b. For b until c d. Is there a plan for the mill to build a biogas plant? 2019 2020 SOLAR ltr 628,576 62,541

BENSIN ltr 5,380 1,537

Solar/Ton TBS 1.57 0.71

Bensin/Ton TBS 0.01 0.02

Bahan Bakar Boiler 2019 2020

Fiber Ton 41,654.84 9,208.10

Shell Ton 22,454.26 -

Fiber/Ton TBS 0.10 0.10

Shell/Ton TBS 0.06 -

Electricity use: 2019

Pemakaian listrik bersumber dari Biogass (kWH) Unit Keterangan

Operasional Emplasement Dijual ke PLN

2019 7,256,466.36 5,476,811.66 4,884,578.00 10,361,389.66 2020 1,325,761.89 1,310,383.30 1,511,664.00 2,822,047.30

Table use Premium and solar year 2019 and 2020 (until June) Year Berkat Kedaron Damai Cakra Premium 2019 14,100 8,003 15,419 2020 6,314 2,974 2,336 Diesel fuel 2019 401,207 149,364 177,835 2020 186,845 84,567 181,905

d. Based on Emission Report 2019 that company has Biogas.

7.10 Plans to reduce pollution and emissions, including greenhouse gases (GHG), are developed, implemented and monitored and new developments are designed to minimise GHG emissions

R 7.10.1 (C) GHG emissions are identified and assessed for the unit of certification. Plans to reduce or minimise them are implemented, monitored through the Palm GHG calculator and publicly reported.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS a. Are all sources of GHG emissions identified? Remote audit result b. Is the GHG emissions for the unit of certification calculated using the latest version of RSPO Palm GHG calculator? Within the 3rd surveillance period, no revision or changes the company procedure regarding inventarization, estima- Yes c. Are there plans to reduce or minimise the GHG emissions? Is this publicly reported? tion of greenhouse gas, where the document was No.REA.BPO.SUS.GRK, issued date on 25 Jul 2016, effective date No d. Are the plans being implemented? Was there any changes? Is it justified? on 25 Aug 2016, Rev.0. The company already calculate the GHG emission from all activity (emission source) present N.A e. Is there a system in place to monitor emission of greenhouse gases from estate (plantation) and mill operations? in the mill and estate. The estimation was use RSPO GHG calculator template version 4. Complete information re- f. Is there regular reporting of the monitoring outcomes? garding result of GHG emission presented in section 5.4 above. NCR No : - To reduce the GHG significant emission source, the company develop GHG mitigation management plan for previous year and current year (2020) refer to GHG previous calculation to check whether the GHG emission is increase or de- crease and to evaluate the program developed is effective. This GHG mitigation management plan implementation is reported periodically per annum to the management and also reported to the RSPO by RSPO public summary report. R 7.10.2 (C) Starting 2014, the carbon stock of the proposed development area and major potential sources of emissions that may result directly from the development are estimated and a plan to minimise them prepared and implemented (following the RSPO GHG As- sessment Procedure for New Development). a. Has the unit of certification identified and estimated carbon stock of the proposed development area? Remote audit result b. If yes, what are the potential major sources of emissions that may result directly from the development? The Cakra oil mill and its supplied base did not carry out new planting. This criteria is not applicable. Yes c. Is there a plan to minimise the emissions? If yes, is the plan following the RSPO GHG Assessment Procedure for No New Development N.A d. Is the plan implemnted and monitored? NCR No :

R & O 7.10.3 (C) Other significant pollutants are identified and plans to reduce or minimise them implemented and monitored. a. Is there a documented list of all significant pollutants from the estate and mill operations? Remote audit result b. Are there plans to reduce or minimise the identified pollutants? The company mill and estate has record and list of significant pollutants. Based on company identification, the signifi- Yes c. Is there a system in place to monitor the pollutants? cant pollutants is came from transport activity, palm oil mill processing and effluent pond. The company has program No to mitigate this matter, through maintain the engine of transport unit periodically, using of renewable energy from bio- N.A mass (shell and fiber) in boiler and convert the COD and BOD into methane gas through methane capture as source of green energy. NCR No : -

Onsite verification result Based on-site verification the company both mill and estate has identified the significant pollutanst from the estates and mill operation. To reduce the significant pollutants the company conducted the periodically monitoring to evaluate the emission from the mills and estate operation is still comply with regulations or exceeds from the limit as required. This analysis carried out by external consultant and reported periodically twice a year to the environmental authority. In the other hand, to reduce the GHG emission, the mills already install methane capture to trap the methane gas and convert to energy. 7.11 Fire is not used for preparing land and is prevented in the managed area

O 7.11.1 (C) Land for new planting or replanting is not prepared by burning. a. Does the company has a zero burning policy or any statement on zero burning? Onsite verification result b. Has the policy been implemented throughout the operations? Estate does not conduct open burning for land clearing, This is in accordance to the Zero Burn Method under the sec- Yes c. Is there any new planting or replanting takes place? If yes, how was the land prepared? tion on Land Clearing, Preparation and Planting e.g.: The company has a zero burning policy under Responsible De- No velopment Policy No. 005/BOD_REA/P/II/2015 dated on 1 March 2015 where zero burning under number 3 reduction N.A of GHG emission. The company alos has SOP for land preparation which mentions zero burning under SOP for Land Clearing No. REA.EST.OPP.LCR, issue No. 01, dated on 1 July 2018. NCR No : - Based on land clearing records in 2012, 2013, 2014 and 2017 that company used mechanic for land clearing such as chipping etc. There were no open burning sighted in any of the new planting areas, landfills as well as workers and staff quarters during the field visits. The company has conducted zero burning socialization, i.e.: - kedaron estate on 13 November 2019 by Sustainability and attended by management and workers - Berkat estate on 3 August 2020 by Sustainability and attended by management and workers (230 participant). O 7.11.2 The unit of certification establishes fire prevention and control measures for the areas directly managed by the unit of certification. a. What is the mechanism/system established for fire prevention and contral measures for areas directly managed by Onsite verification result the unit of certification? The company has a mechanism/system established for fire prevention and contral measures for areas directly man- Yes b. Is there adequate fire control equipment? aged as stated in procedure mitigation, management of forest and land fires. The company has fire control equipment No c. What are the equipment available and how are equipment maintained to ensure that they are functioning well at all for each estates and mill. Some the equipment was available at estate e.g. water tank, fire control truck, some type of N.A time? water Pump, water hose of various sizes, Helmet etc. Beside that all estate have fire monitoring tower (menara api). d. Has fire drill been conducted? If yes, when was it last carried out? The company has conducted monitoring fire equipment every month as presented in form of equipment monitoring. NCR No : - e. Are the relevant workers aware of the actions to be taken in case of fire occurrence? Base on the record, all equipments are good condition. During field verification at fire equipment wharehouse, there are equipments available and good condition.

The Company has conducted fire drill regularly at estates and mill such as : On 13 November 2019 attended by 23 participant (with stakeholders) All simulation for fire handling has attended by workers and emergency respond team. Base on interview with workers and emergency team, they understood mechanism actions to be taken in case of fire occurrence. O 7.11.3 The unit of certification engages with adjacent stakeholders on fire prevention and control measures. a. Has the company made engagement with adjacent stakeholders on fire prevention and control measures? Onsite verification result b. What type of engagement is agreed? The company has made engagement with adjacent stakeholders on fire prevention and control measures such as in- Yes stalled signboard about burning prohibited, example: No - 22 January 2020 - coordination with stakeholders, including the community, plantation service, fire service, N.A etc (50 people) MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS - Fire simulations were conducted on 13 November 2019 with 23 participants. NCR No : -

7.12 Land clearing does not cause deforestation or damage any area required to protect or enhance HighConservation Values (HCVs) or High Carbon Stock (HCS) forest. HCVs and HCS forests in the managed area are identified and protected or enhanced R 7.12.1 (C) Land clearing since November 2005 has not damaged primary forest or any area required to protect or enhance HCVs. Land clearing since 15 November 2018 has not damaged HCVs or HCS forests. A historic Land Use Change Analysis (LUCA) is conduct- ed prior to any new land clearing, in accordance with the RSPO LUCA guidance document. Note to Auditor : Refer to Interpretation of Indicator 7.12.2 and Annex 5 a. Since November 2005, have any new plantings replaced primary forest, or any area required to maintain or enhance Within 3rd surveillance audit date period, similar with previous audit report, found new planting after Nov 2005 inside one or more High Conservation Values (HCVs)? If yes, was an adequate HCV assessment carried out prior to clear- the company concession area in Berkat and Damai estate, with information served below: Yes ing the land. 1. Berkat estate: No b. Has the unit of certification submitted the Disclosure form and LUCA to RSPO? 1. YoP 2006 total planted 2,347 ha N.A c. Does the disclosure form reported any land liability? 2. Yop 2007 total planted 2,143 ha d. Since 15 November 2018, have any new plantings been done? If yes, was a HCV-HCSA assessment conducted 2. Damai estate: NCR No : - and passed through the HCVRN ALS quality review process prior to any land clearing. 1. YoP 2005 total planted 1,290 ha e. Where HCVs & HCS forests have been identified on the land that is intended for new plantings, have new plantings 2. Yop 2006 total planted 716 ha been planned and managed to best ensure the HCVs & HCS forest identified are maintained and/or enhanced. 3. YoP 2010 total planted 123 ha The HCV assessment performed by WWF on Sep 2009, then on December 2015 the company also performed delin- eation assessment of the HCV area based on HCV assessment done by WWF. The estate above has conduct LUC Assessment, whereas the assessment done on June 2016 by Research Center for Biodiversity and Tropical Forest Rehabilitation, Faculty of Forestry, Bogor Agriculture University (external consult- ant). This LUC assessment started from May 2005 until August 1, 2009 before HCV assessment conducted by WWF on September 2009. If refer to LUC assessment document (Section IV – Conclusion and Recommendation) stated “could be concussed there is not liability for company although compensation and remediation”. This statement re- ported to the RSPO by email. Until 3rd surveillance period the update process on this matter is: Date Progress Evidences Remarks 29 June 2018 PT REAKAP has been sent the Email from PT Based on the results of LUCA disclosure and LUCA report to REAKAP to com- surveillance audit of the RSPO. pensation panel. Cakra POM and Supply based in May 2018. 4 July 2018 RSPO have received the LUCA dis- Email from RSPO At the time it was an in- closure & LUCA report of PT to PT REAKAP. ternal transition period REAKAP and need a clarification re- so that there was inter- garding period between first LC and rupted communication HCV assessment where PT REA to the RSPO. Kaltim has stated that the first cle- reance was on March 2005 and the HCV assessment conducted on 9 September 2009. 17 January 2019 PT REAKAP requested confirmation Email from PT To update the progress, of progress disclosed LUCA. REAKAP to RSPO the company took the initiative to ask RSPO. 18 January 2019 The RSPO informed that they have Email from RSPO Responsed by the response on 4 July 2018 asking fro to PT REAKAP company by explana- clarification from Pak Purwantoro. tion in the coloum be- However, they gave clarification: (1) low. the documentation send is incom- plete because the LUCA submission has to follow the Annex 3 to Annex 4 of the RaCP documentation submis- sion; (2) the LUCA report send does not follow the template and there are no raw image files to process. 18 January 2019 PT REAKAP give a verification that Email from PT LUCA field assessment LUCA was conducted in 2016 before REAKAP to RSPO conducted on 15-26 applies of LUCA templates and February 2019, and standards. have processing to fi- nalize the LUCA report with consultant. 15-26 February Re-LUCA field assessment wad con- LUCA report of PT - 2019 ducted by PT Gagas Dinamika REA Kaltim Plan- Aksenta. tations. 27 February – 12 Finalize the LUCA report with the LUCA report of PT - April 2019 Aksenta. REA Kaltim Plan- tations. 16 April 2019 Submitted the LUCA report and Email from PT No response from LUCA disclosure to RSPO. REAKAP to RSPO RSPO. 23 April 2019 Reminder the update of LUCA dis- Email from PT No response from closed to RSPO based on previous REAKAP to RSPO RSPO. email. 25 April 2019 Reminder the update of LUCA dis- Email from PT No response from closed to RSPO based on previous REAKAP to RSPO RSPO.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS email. 10 May 2019 Reminder the update of LUCA dis- Email from PT No response from closed to RSPO based on previous REAKAP to RSPO RSPO. email. 21 Jun 2019 Reminder the update of LUCA dis- Email from PT No response from closed to RSPO based on previous REAKAP to RSPO RSPO. email. 24 Jul 2019 Reminder the update of LUCA dis- Email from PT No response from closed to RSPO based on previous REAKAP to RSPO RSPO. email. 11 Sep 2019 Reminder the update of LUCA dis- Email from PT No response from closed to RSPO based on previous REAKAP to RSPO RSPO. email. 12 Sep 2019 RSPO reply the company email re- Email from RSPO - garding “the RSPO informed if they to PT REAKAP will re-check the REA’s disclosure. 26 Oct 2019 Reminder the update of LUCA dis- Email from PT No response from closed to RSPO based on previous REAKAP to RSPO RSPO. email (12 Sep 2019) 12 Nov 2019 Reminder the update of LUCA dis- Email from PT No response from closed to RSPO based on previous REAKAP to RSPO RSPO. email (26 Oct 2019) 25 Nov 2019 Feedback from RSPO regarding the Email from RSPO - result of LUCA review submission is to PT REAKAP still need clarifications 26 Dec 2019 Feedback clarification required sent Email from PT - to RSPO REAKAP to RSPO 30 Dec 2019 Feedback from RSPO and said if the Email from RSPO - company clarification has been share to PT REAKAP to reviewer. 15 Jan 2020 Reminder to RSPO regarding LUCA Email from PT - final review refer to previous email on REAKAP to RSPO 30 Dec 2019 19 Jan 2020 Feedback from RSPO and said the Email from RSPO - LUCA review is finalize with the re- to PT REAKAP viewer 28 Jan 2020 LUCA review result has been receipt Email from RSPO - from RSPO and still needs clarifica- to PT REAKAP tion. 02 Aug 2020 The company send the clarification Email from PT Waiting response from report to the RSPO refer to the LUCA REAKAP to RSPO. review report V2 on 28 Jan 2020 RSPO.

While RaCP process for scheme smallholder full operated of Plasma Etam Bersatu, the progress was: Date Progress Evidences Remarks 27 Oct 2019 First submission LUCA report to the Email from PT - RSPO REAKAP to RSPO 11 Nov 2019 Feedback from RSPO concerning on Email from RSPO Company internal tim need sme supporting documents tpo to PT REAKAP has follow-up and will- complete the LUCA disclosure complete the docu- ments as requested. 02 Aug 2020 The company completed the docu- Email from PT Company expectation ments and send to the RSPO based REAKAP to RSPO the environmental per- on previous email on 11 Nov 2019 mission (UKL-UPL) will complete in the end of 2020.

Additional Note: All the email correspondence with RSPO regarding RaCP process above, able to show by the com- pany during the audit process.

No new planting performed since 15 Nov 2018 until onsite verification is conducted. The company proposed new land clearing after 15 Nov 2018 through the LURI verification (will explain in the next criteria).

R & O 7.12.2 (C) HCVs, HCS forests and other conservation areas are identified as follows : a) For existing plantations with an HCV assessment conducted by an RSPO-approved assessor and no new land clearing after 15 November 2018, the current HCV assessment of those plantations remains valid. b) Any new land clearing (in existing plantations or new plantings) after 15 November 2018 is preceded by an HCV-HCS assessment, using the HCSA Toolkit and the HCV-HCSA Assessment Manual. This will include stakeholder consultation and take into account wid- er landscape-level considerations. PROCEDURAL NOTE for 7.12.2: For details of transitional measures, refer to Annex 5: RSPO transition from HCV assessments to HCV-HCS Aassessments. R & O a) For existing plantations with an HCV assessment conducted by an RSPO-approved assessor and no new land clear- Remote audit result ing after 15 November 2018, the current HCV assessment of those plantations remains valid. Within the 3rd surveillance audit date period, no revision of the HCV assessment. The HCV assessment performed by Yes a. Is there any land clearing after 15 November 2018? If yes, go to 7.12.2b) WWF on Sep 2009, then on December 2015 the company also performed delineation assessment of the HCV area No MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS b. Who conduted the HCV assessment? based on HCV assessment done by WWF conducted by external consultant from Bogor Agriculture University, Facul- N.A c. Is the HCV assessment covers the following : ty of Forestry on Dec 2015. The HCV assessment coverage a whole areas of Rea Kaltim Plantation including for Cak- - Presence of protected areas that could be significantly affected by the grower or miller; ra, Berkat, Damai and Lestari estate. NCR No : - - Conservation status (e.g. IUCN status), legal protection, population status and habitat requirements of rare, threat- Based on HCV delineation assessment, found species categorized as RTE which consist of 5 types including in list of ened, or endangered (RTE) species that could be significantly affected by the grower or miller. appendix II CITES, 10 types include in IUCN Red List, 2 types with CR/critically endangered, 5 types of - Identification of HCV habitats, such as rare and threatened ecosystems, that could be significantly affected by the EN/endangered, 2 types of VU/vulnerable, and 1 type of LR/low risk. Complete information flora and fauna categorized grower or miller; as RTE and location served in HCV delineation assessment. d. Was the HCV assessment performed in consultation with relevant stakeholders? The HCV delineation assessment performed by qualified HCV assessor and licensed by ALS, i.e.: ALS register num- e. Does the HCV assessment include checking of available biological records? ber ALS14013MS and ALS15028SA. f. Does the HCV assessment include both the planted area itself and relevant wider landscape-level considerations The HCV delineation assessment performed thorugh the stakeholder consultations, with follow the information below: (such as wildlife corridors)? 1. December 18, 2015 in REA meeting room attendees by 15 person from internal company g. Was the HCV assessment performed in accordance to the latest methodology available at global and national level? 2. December 19, 2015 in Desa Long Lalang attendees by 6 person from villagers h. For existing plantation going for certification after 15 November 2018, are the applicable requirements in Annex 5 3. December 21, 2015 in Desa Kembang Janggut attendees by 6 person from local government only fullfilled? 4. December 21, 2015 in Desa Kelekat attendees by 5 person from local government only 5. December 19, 2015 in Desa Bukit Layang attendees by 5 person from local government only 6. December 21, 2015 in Desa Pulau Pinang attendees by 3 person from local government only 7. December 19, 2015 in Desa Long Bleh Haloq attendees by 3 person from local government only 8. December 19, 2015 in Desa Muai attendees by 3 person from local government only That stakeholder consultations is attendees by local government only without local community. This HCV delineation assessment was assessed all REA Kaltim plantation concession area as stated above and also as identified possible corridors. This HCV delineation assessment performed with HCV National Toolkits, and map of HCV location area inside of company concession area available in place. This Cakra oil mill and its supplied based is existing oil palm plantation with certified management unit status.

Onsite verification result During onsite verification the HCV assessment report able to showed and verify that all the process of HCV assess- ment is completely as requested by RSPO requirements. This document of HCV assessment is similar with previous audit, no revision, and the company are agree with the HCV assessmet result and already carried out delineation and demarcation on the ground. R & O b) Any new land clearing (in existing plantations or new plantings) after 15 November 2018 is preceded by an HCV- Remote audit result HCS assessment, using the HCSA Toolkit and the HCV-HCSA Assessment Manual. This will include stakeholder con- No new land clearing after 15 Nov 2018 in all estate of Cakra oil mill supply based. Yes sultation and take into account wider landscape-level considerations. No a. Is there land clearing after 15 November 2018? Onsite verification result N.A b. If Yes to (a), does it fall into any of the scenarios in Annex 5 and the 'RSPO Interpretation of Annex 5 & indcator During onsite verification, the Cakra palm oil mill supply base is proposed plan for new land clearing inside the certi- 7.12.2'document? fied management unit. Refer to interpretation of indicator 7.12.5 and annex 5, RSPO document approved by RSPO NCR No : - c. If Yes to (b), are the applicable requirements for the scenario in Annex 5 fullfilled? Board of Governors on 12 Jun 2019, the estate is follow the flowchart and scenarios 4.1 Existing Certified Plantations. d. If No to (b), was a HCV-HCSA assessment conducted prior to any land clearing? All estate proposed the new land clearing already carried out LURI assessment, with summary of LURI assessment e. Is the HCV-HCSA assessment passed the ALS quality control? How was this confirmed? for new land clearing proposed area as presented on table below: f. Was the HCV-HCSA assessment conducted in consultation with stakeholders and take into account wider land- Low Risk Risk Area scape-level considerations? Estate Land Cover Area ( Ha) ( Ha ) Young Regeneration Forest ( R1 ) 46.89 Shrub ( R2 ) 22.86 Kedaron Estate – Bareland (LR1 ) 3.96 PT Kutai Mitra Sejahtera Bush ( LR3 ) 249.75 Palm Small Holder ( LR4 ) 45.45 Sub Total 69.75 299.16 Shrub ( R2 ) 21.42 Cakra Estate - PT REA Bush ( LR3 ) 13.84 Kaltim Plantations Palm Small Holder ( LR4 ) 2.21 Sub Total 21.42 16.05 Shrub ( R2 ) 14.84 Damai Estate - PT REA Bareland (LR1 ) 15.85 Kaltim Plantations Bush ( LR3 ) 63.94 Palm Small Holder ( LR4 ) 20.39 Sub Total 14.84 100.18 Berkat Estate - PT REA Bareland ( LR1 ) 12.24 Kaltim Plantations Infrastructure ( LR5 ) 10.02 Sub Total 0 22.26 Total 106.01 437.65 For the Risk Area the company commit will not open or clearing that area. This is based on Top Management com- mitement on internal memo no. IM.PD-045/VIII/2020, issued date on 13 Aug 2020 from President Director. This letter mentioned the company will not open every area with “No Go Area and Risk Area” category after 15 Nov 2018. The area will proposed for new land clearing is Low Risk Area only. For on the ground implementation, to ensure the No Go Area and Risk Area is protected the demarcation and delineation will be conducted through provide buffer +/- 5 meters if the Low Risk Area will open is set-aside with the No Go Area of Risk Area as well as for river buffer zone the demarcation will refer to national regulations.

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS All the LURI assessment report has verified and the ground checking also conducted for sampling area, which the sampling area taken as presented on table below: Coordinate Estate Land Cover Hectare Long (DMS) Lat (DMS) E 116⁰25'087" N 0⁰29'970" Shrub 2.43 E 116⁰24'872" N 0⁰29'700" Young Regeneration Forest 11.43 Kedaron Estate - E 116⁰24'315" N 0⁰29'738" Bush 42.84 PT Kutai Mitra Sejahtera E 116⁰26'588" N 0⁰24'793" Bareland 2.7 E 116⁰26'238" N 0⁰24'713" Palm ( Small Holder ) 0.27 E 116⁰26'045" N 0⁰24'412" Bush 35.01 Total (Hectares) 94.68

Coordinate Estate Land Cover Hectare Long (DMS) Lat (DMS) E 0024926 N 0424512 Shrub 1.88 Damai Estate - E 0026114 N 0424764 Young Regeneration Forest 2.87 PT REA Kaltim Planatations E 0028315 N 0420299 Bush 2.18 E 0029453 N 0420247 Bareland 1.35 Total (Hectares) 8.28

Coordinate Estate Land Cover Hectare Long (DMS) Lat (DMS) E 116⁰10'36.6" N 0⁰19'59.4" Bush 22.34 E 116⁰11'07.9" N 0⁰19'37.6" Bush 22.84 Lestari Estate - E 116⁰11'11.1" N 0⁰19'48.2" Smallholder 5.23 PT REA Kaltim E 116⁰13'20.2" N 0⁰21'04.9" Bareland 3.95 Plantations E 116⁰11'10.1" N 0⁰20'07.0" Smallholder 3.36 E 116⁰10'39.5" N 0⁰19'57.7" Smallholder 5.38 E 116⁰10'49.5" N 0⁰19'54.9" Shrub 24.49 Total (Hectares) 87.60

Coordinate Estate Land Cover Hectare Long (DMS) Lat (DMS) Cakra Estate - E 116⁰14'48.34" N 0⁰18'19.45" Bush 13.84 PT REA Kaltim E 116⁰14'43.62" N 0⁰18'10.60" Shrub 21.42 Plantations E 116⁰14'29.68" N 0⁰18'06.40" Palm ( SmallHolder) 1.61 Total (Hectares) 36.87

Coordinate Estate Land Cover Hectare Long (DMS) Lat (DMS) Berkat Estate - PT REA E 116⁰23'36.95" N 0⁰16'47.99" Bareland 3.33 Kaltim Plantations E 116⁰22'20.28" N 0⁰13'12.91" Infrastructure 10.02 Total (Hectares) 13.35

As explain in the CR 7.12.2 (a), the HCV assessment report of the company has performed by qualified HCV assessor and licensed by ALS, i.e.: ALS register number ALS14013MS and ALS15028SA, and conducted refer to the HCV toolkits, with involving of public stakeholders consultation.

O 7.12.3 (C) In High Forest Cover Landscapes (HFCLs) within HFCCs, a specific procedure will apply for legacy cases and development by indigenous peoples and local communities with legal or customary rights, taking into consideration regional and national multi- stakeholder processes. Until this procedure is developed and endorsed, 7.12.2 applies. PROCEDURAL NOTE for 7.12.3: There should be demonstrable benefits to the local community; clear recognition of legal and customary lands based on participatory land use planning; development should be proportional to the needs of the local community; with a balance between conservation and development. This procedure will also cover planting on previous or abandoned agricultural land / plantations. All other P&C requirements apply, including FPIC and HCV requirements. This checklist will be provided once the procedure by the "No Deforestation Joint Steering Group" is finalised. Onsite verification result This section is not applicable. Please refer to explanantion in CR7.12.2 above. Yes No N.A

NCR No : -

R & O 7.12.4 (C) Where HCVs, HCS forests after 15 November 2018, peatland and other conservation areas have been identified, they are protected and/or enhanced. An integrated management plan to protect and/or enhance HCVs, HCS forests, peatland and other conser- vation areas is developed, implemented and adapted where necessary, and contains monitoring requirements. The integrated management plan is reviewed at least once every five years. The integrated management plan is developed in consultation with relevant stakeholders and includes the directly managed area and any relevant wider landscape level considerations (where these are identified). a. Has the unit of certification identified the HCV, HCS, peatland and other conservation areas? This is applicable for Remote audit result both existing and new planting areas. This section is not applicable. Please refer to explanation in CR7.7.1 until CR7.7.5 above Yes b. Where (a) have been identified on the land that is intended for new plantings, have new plantings been planned and No managed to ensure the identified HCVs are maintained and/or enhanced. Onsite verification result N.A MS-0034725-17.1 Rev.0

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CR CHECKLIST RESULTS OF VERIFICATION COMPLAINCE STATUS c. Is there an integrated management plan to protect and/or enhance HCVs, HCS forests, peatland and other conser- This section is not applicable. Please refer to explanation in CR7.7.1 until CR7.7.5 above vation areas developed, implemented and adapted where necessary? Is the plan contains monitoring requirements? NCR No : d. Is the integrated management plan developed in consultation with relevant stakeholders and includes the directly managed area and any relevant wider landscape level considerations (where these are identified)? e. Is the plan reviewed by the unit of certification? When the last was reviewed conducted? O 7.12.5 Where rights of local communities have been identified in HCV areas, HCS forest after 15 November 2018, peatland and other conservation areas, there is no reduction of these rights without evidence of a negotiated agreement, obtained through FPIC, encour- aging their involvement in the maintenance and management of these conservation areas. a. Are there rights of local community’s identifed in HCV areas, HCS forest after 15 November 2018, peatland and Onsite verification result other conservation areas? As explained in CR7.12. (a), the HCV assessment was performed involving the communities. The HCV assessment Yes b. Who are the affected communities? report complete with HCV identification map, communities affected during HCV 5 assessment, and other. No peatland No c. Is the identified areas mapped? found in Cakra palm oil mill supply based. N.A d. Is there evidence of stakeholder consultation and negotiated agreement, in accordance to FPIC principles, with local community to optimally safeguard both the HCVs and rights of local communities? NCR No : e. If a negotiated agreement cannot be reached, is there evidence of sustained efforts to achieve an agreement? R & O 7.12.6 All rare, threatened or endangered (RTE) species are protected, whether or not they are identified in an HCV assessment. A programme to regularly educate the workforce about the status of RTE species is in place. Appropriate disciplinary measures are taken and documented in accordance with company rules and national law if any individual working for the company is found to capture, harm, collect, trade, possess or kill these species. a. Is there a policy or rules to protect RTE species? Remote audit result b. Is there a programme to regularly educate the workforce about the status of the RTE species? When was the pro- Within 3rd surveillance audit date period, no revision of the RTE protection policy. The company very commit to pro- Yes gramme carried out? tect the HCV area including RTE species present on the company concession area. This policy signoff by top man- No c. Is there evidence or action taken to implement the rules and programs? E.g. Inspections conducted to check no agement. N.A traps/snares put up within or nearby areas. d. Are there appropriate disciplinary measures imposed in accordance with company rules and national law, should Onsite verification result NCR No : any individual working for the company is found to have captured, harmed, collected or killed any RTE species? Based on interview with the HCV Officer who carry out monitoring the HCV area, the RTE species are monitored. Record of species including RTE and non RTE species was in place and able to show and the species monitoring the company used camera trap. Based on RTE species monitoring there are decreese of the species is happened in the estate HCV area. This due to community activity which opened the HCV area. The company carried out approchment with the community, to educate them periodically. Some HCV area already back again to the company and the com- pany carried out re-enrichment in that HCV area. O 7.12.7 The status of HCVs, HCS forests after 15 November 2018, other natural ecosystems, peatland conservation areas and RTE species is monitored. Outcomes of this monitoring are fed back into the management plan. a. Is the management plan contained ongoing monitoring of status of HCV, HCS, other natural ecosystems, peatland Onsite verification result conservation areas and RTE species? The management plan for management and monitoring HCV was in place, but this management plan did not develop Yes b. Is the status documented and reported? based on RTE species monitoring result feedback evaluation. This is condition raised as nonconformity. No c. Are the outcomes of monitoring fed back into the management plan? N.A

NCR No : RSPO03246

R 7.12.8 (C) Where there has been land clearing without prior HCV assessment since November 2005, or without prior HCV-HCSA assessment since 15 November 2018, the Remediation and Compensation Procedure (RaCP) applies. a. Is there land cleared since November 2005 without prior HCV assessment? Remote audit result b. Is there land cleared since 15 November 2018 without prior HCV-HCSA assessment? No new land clearing after 15 Nov 2018 in all estate of Cakra oil mill supply based. Yes c. If (a) or (b) above applies, has the unit of certification undergone the RaCP process? No d. If (c) applies, is there evidence that compensation plan for the affected area has been approved by the RSPO? N.A Note to auditor: Certificate shall not be issued until the Compensation Plan is approved. Onsite verification result As explain in CR 7.12.2 (a) above, no new land clearing after 15 Nov 2018 by the company. NCR No : -

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6.2. Compliance to RSPO Role of Market Communications & Claims:

Chapter is applicable by client : Yes No

If yes, what is type of communication applied by client? General Corporate Communication (off product claim) Business to Business Communication Business to Consumer Communication

Following the above selected communication method, please describe compliaces to company compliance to RSPO role of market communications and claims section 4 / 5 / 6: Please refer to 3.8.17 (SCCS checklist)

If the company using the RSPO trademark, this applied on: This section is not applicable (N/A) The company website or digital platform Business cards The company / product promotional use (leaflet, brochure, banner, etc) Document/report: N/A

The company demonstrate that: The company hold a trademark license from the RSPO Yes No Approval for off/on product trademark and/or label used recieved Yes No

If yes, please explain the approval of off/on product trademark and/or label from RSPO: Not applicable

6.3. Compliance to Book & Claim requirement:

Chapter is applicable by client : Yes No

If yes, please complete information require in appendix 7.

If not, please delete appendix 7

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7.0 Status of Previously Identified Non-Conformities

Auditee Response NCR Evidence Observed / NCR Ref Verification Result Status No. raised Correction Corrective Action

4.1.1 NCR There is indication of inconsistently • Re-socialization the Ensure the commitment of 1. Based onsite major verification and Closed RSPO related implementation the proce- procedure (ReaCon) management related cor- document verification, the dissemina- 02497 dure No.REA.BPO.CON.PGK is- • Ensure the accuntability rective action of evaluation tion/socialization of procedure sued No.01, issued date 25 January of each department re- result of effectiveness the no.REA.BPO.CON.PGK issued No.01, 2017, revision 0, effective date 25 lated responsibility of implementation of policy issued date 25 January 2017, revision February 2017 regarding disrupts implementation the pol- and procedure especially if 0, effective date 25 February 2017 al- conservation areas for example in icy and procedure there is inconsistently will ready conducted on 8 May 2019 and at- section 4.1, 4.3 and 4.4 about re- be educating in accord- tended by 17 participants from estate sponsibility of estate manager, DVA ance with company regu- manager, HR assisstant, support de- and SECO related disturbance in lation partment (SH, Comdev, SECO, the HCV area located in Block 47C LCC/DVA manager, surveyor and map- and 47D Division III of Berkat estate. ping department). 2. Revised the encroachment legend map of Berkat estate related to name of landowner/claimers and the status. 3. Minute of ground check about en- croachments areas in HCV areas each landowners/claimers. It has signed by each landowners/claimers too except Mr Rofinus M & Mr Suryadi because they are not summoned individually. 4. Auditee has done meeting with land- owners/claimers about all encroach- ment areas has land compensation paid to head of village or representative of community and it is inside of land use right (HGU) on behalf company. 5.2.2 NCR Based on field verification Block 47 Review and evaluation the • Conduct periodic evalu- Based on document verification and onsite Closed RSPO C and 47 D Division VIII of Berkat handling program of HCV ation of effectiveness major verification, the company conducted 02498 Estate found HCV area has been encroachment where the the HCV management ground check based on minute of ground distrurb and planting palm oil trees handling and encroach- plan as a corrective of check about encroachments areas in HCV where the HCV area indicated as ment mitigation conduct relevant variable that areas each landowners/claimers. It has habitat of RTE species. This case by participation of all re- has been set so there is signed by each landowners/claimers too does not accordance with HCV lated stakeholder so there feedback of effective except : management plan that has been is integrated and compre- correction o Mr Rofinus M & Mr Suryadi be- stated in the HCV document and in- hensive management pro- • The management en- cause they are not summoned in- dicator of RSPO to protect the habi- gram sure and encourage the dividually, tat of RTE species from disturb that control to accountability o Mr Syahlani/Toh because he has

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Auditee Response NCR Evidence Observed / NCR Ref Verification Result Status No. raised Correction Corrective Action

cause the habitat of RTE species of each department re- managed of land since year 2002 disturbing. lated responsibility to and there was planned compen- implementation the sation land by company year 2003 handling and en- but it did not done, croachment mitigation o Mr Nut, Mr Kadir & Mr Zulkifli no program reason, o Mr Matius & Mr Agus Wardani beause they are requesting to be met with the first owner who sold tha land, o Mrs Rahma because she request- ing to solving process with gath- ered all landowners/claimers and facilitated by the head of village, o Mr Warsito because land has pur- chased from other person and he is not understand that it is on land use right (HGU) on behalf the company, o Mr M. Ardiansyah because he has been cultivated since long time ago before the company got land use right (HGU) Based on major onsite verification through interview with landowners/claimers (Mr Yusran, Mr Bardi, Mr Suhaeli, Mr Markus & Mr Suryadi) & field visit in block 47C & 47D and company management that :  Mr Markus, Suryadi, Bardi & Suhaeli has bought land from other persons (other community or family) and other commodity plant was available  They are not understand that it is on land use right (HGU) on behalf com- pany and as HCV areas because no signed as boundary stone and no pole of HCV areas in block 47C & 47D. The result of field visit that pole of HCV areas was available in other position inside of block 47C & 47D

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Auditee Response NCR Evidence Observed / NCR Ref Verification Result Status No. raised Correction Corrective Action

but in fifth encroachment areas was not available  Mr Suryadi & Markus has informed that there is one of stone near our lands so that they understood that the boundaries of the company’s area only reached the location it and their estates/lands were not in the land use right (HGU) areas. The result of field visit that there is one of stone but it have not information like is boundary stone from National Land Agency (BPN).  They hope that they still cultivate land it because they get land with buy pro- cess from other parties  The company has provided that they has paid land compensation amount of 7,218.92 ha in Berkat estate with detail of information such as : o Year 2006 : Mr Hasan Sanusi has received land compensation pay- ment for land amount of 5,000 ha o Year 2007 : Mr Hasan Sanusi & Mr Safransyah has received land compensation payment for land amount of 2,190 ha o Year 2009 : Mr Indra Wahyudi, Mr Akil & Mr Mashudi has received land compensation payment for land amount of 23.20 ha o Year 2011 : Mr Syahlani has re- ceived land compensation pay- ment for land amount of 5.72 ha o Year 2013: Mr Aslan, Mr Asan, Mr Safransyah & Mr Arwadi has re- ceived land compensation pay- ment. o Notary deed no. 3 & 4 dated on 01 May 2006 & 02 May 2006 by nota-

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Auditee Response NCR Evidence Observed / NCR Ref Verification Result Status No. raised Correction Corrective Action

ry of Bakhtiar, SH regarding land compensation agreement be- tween PT REA Kaltim Plantation and cultivating community in Kembang Janggut Village. It is follow up from minute of agree- ment dated on 17 April 2006. In- formation from minute of agree- ment that the company has paid compensation for land acquisition for the purpose of forest conserva- tion amount of 2,000 ha. It has signed by both parties (the com- pany and village representative team (8 persons) and it has acknowledged by head of sub dis- trict and head of village). o Minute of payment and payment note dated on 9 March 2007 o Map of the location of Berkat es- tate operation where it has wit- nessed by village representative team, acknowledge by head of vil- lage and approved by head of sub district. 5.2.2 NCR The company does not implemented • Acceleration of finish- Conduct monitoring and Based on document check verification, the Closed RSPO the time bound plan related small- ing the Land Use periodic evaluation of pro- LUCA still in process review by the RSPO. 02499 holder that including into the scope Change Analysis gress the implementation Then, the smallholder EIA document still in of certification where this is has (LUCA) and submit to program to ensure the progress under adivce technically consider- been 2nd surveillance audit RSPO and get the fi- feedback and corrective ation from Estate and Animal Husbandry nal statement about action so the certification Local Authority of Kutai Kartanegara, prior FCL program conduct on-time the permission of EIA is issued by the relat- • Create the develop- in accordance with time ed authority. This advice technically consid- ment program of certi- bound plan eration document no.521/697/ADV- fication in accordance DISTANAK/VI/2020 issued date on 18 Jun with time bound plan 2020. The company revised the timebound that has been set plan due to the EIA document still on pro- cess.

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8.0 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions

A total of 3 nonconformances were identified during remote audit on 3rd surveillance assessment. These consisted of 1 major non-conformities and 2 minor non- conformities. For the major non-conformances, the company has taken the necessary corrective action to close these non-conformances within 90 days from completion of the assessment time (closing meeting), and this was verified by the audit team through checks of documents submitted by the company. For the minor non-conformances, the company has taken corrective action against these as well, and for those which could not be verified as closed through document checks, the closure of these minor non-conformities will be assessed during the next surveillance audit. A summary of all identified non-conformances, corrective actions taken and auditor conclusions is as explained below:

8. 1. Major non-conformities

Auditee Response Date of NCR Verification of Corretion/ closure Ref Evidence Observed / NCR raised No.RSPO Correction Corrective Action Corrective action Auditor/ Conclution

Remote audit 6.7.1 03122 Based on OHS periodically meet- 1. Revise the OHS 1. The periodically moni- The company submit evidence to closed the 02-07-2020 ing records in Cakra estate 28 committee and sub- toring and evaluation correction follow the information below: Closed Feb 2020; Damai estate 20 Mar mit the new revision will be implemented 1. The new OHS Committee approved by 2020; Lestari estate 28 Feb 2020 to the local authority, regarding implemen- local authority was decree letter show in the attendant list record where in the new tation of the new OHS no.566/1193/P2K3/DTKT/2020, issued the estate manager and OHS OHS Committee or- Committee work in- date on 11 Jun 2020. Valid as long as specialist (OHS Committee sec- ganization, the cen- structions (WI). no revision person (name recorded on retary) is not attended the meet- tralize model will be 2. The Safety Commit- license). ing. applied, then the tee in the estate is ac- 2. The new WI document OHS Committee will tive and reporting pe- no.WI.REA.HSE.P2K3, date of issued be able in central on- riodically to the Cen- on 01 Jun 2020, with new responsibility ly on behalf PT Rea tral OHS Committee. per position in the new OHS Committee Kaltim Plantations, 3. The Central OHS and time management for reporting, while in the estate Committee will eval- and periodically meeting. field the safety com- ute in the Safety The corrective action implementation will be mittee will be organ- Committee in the es- verified during on-site verification. ize to carry out the tate in perodically. function control and evaluation of OHS implementation to all activities in the field, and reported periodi- cally to the OHS Committee in central. 2. Revise the OHS Committee work in- MS-0034725-17.1 Rev.0

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Auditee Response Date of NCR Verification of Corretion/ closure Ref Evidence Observed / NCR raised No.RSPO Correction Corrective Action Corrective action Auditor/ Conclution

structions (WI) due to revision of OHS Committee organiza- tional structure and responsibility, with the new WI docu- ment no.WI.REA.HSE.P2K 3, date of issued on 01 Jun 2020. On-site audit 2.1.1 03240 Based on interview with spraying 1. The company is- 1. Re-evaluate again The company submit the evidence: 30-09-2020 workers in division 03 Damai es- sued internal the evalution of 1. Internal memo letter no. IM.HR- Closed tate and division 01 Berkat es- memo regarding law and regula- 051/IX/2020, issued date 08 Sep tate, they work with chemicals time scheduling for tions compliance 2020 regarding working hours for (spraying activity) is more than 5 spraying workers especialy in OHS chemical/spraying workers. The (five) hours. This is not comply based on that reg- implementation. letter signoff by Head of Human with regulations of Ministry of ulation. 2. Accommodate the Resource Department. Manpower n. 03/1986. 2. All estate should fiver hours (5) per 2. Dissemination information of be deliver this in- day or 30 hours working hours for chemical formation to all per week working workers (spraying) for Berkat es- spraying workers for spraying activi- tate and Cakra estate, conduct- and must be im- ty and mentioned ed on 29 Sep 2020, informed the plemented. thus in the compa- all chemical workers is not allow ny procedure. work for more than 5 hours per day or 30 hours per week. At- tended by all chemical workers and division assisstant. 3. Dissemination information of working hours for chemical workers (spraying) for Damai es- tate and Lestari estate, conduct- ed on 11 Sep 2020, informed the all chemical workers is not allow work for more than 5 hours per day or 30 hours per week. At- tended by all chemical workers and division assisstant. 4.1.1 03243 Based on-site verification found 1. Overlay the plant- Carry out monitoring The company submit the evidence: 30-09-2020 planting activity is outside the ing map with land and re-evaluate the 1. Minutes of meeting identification Closed MS-0034725-17.1 Rev.0

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Auditee Response Date of NCR Verification of Corretion/ closure Ref Evidence Observed / NCR raised No.RSPO Correction Corrective Action Corrective action Auditor/ Conclution

company land use rights (HGU), use rights map planting area as well as planted area outside the land which area was Block D47 Ber- (HGU) in Cakra planting map to ensure use rights (HGU) conducted on kat estate; Block C25; 52 B-C in and Berkat estate. no more planting activi- 07 Oct 2020 for Berkat estate, Cakra estate. 2. Exclude the plant- ty carried out outside with the final result total area ing area if proven the land use rights planted outside the land use that area planted (HGU), and develop rights (HGU) was 72.68 ha, con- outside the land commnunication with sist of Block 52A; 52B; 52C and use rights (HGU), the relevant official 52D. Signoff by estate manager. and all the FFB government (authority). 2. Minutes of meeting identification produce from that planted area outside the land area not claim as use rights (HGU) conducted on certfied raw mate- 28 Sep 2020 for Cakra estate, rial FFB. with the final result total area planted outside the land use rights (HGU) was 16.42 ha, con- sist of Block 100A, 101A and 101B. Signoff by estate manag- er, Sr. EC North and HoEA. 3. Letter of statement of scope au- dit area for RSPO in Cakra oil mill supply base, no. RKP.ES- 1272/X/2020, issued date 08 Oct 2020 by Company Management Representative, where informed to the CB there are some area with total 89.1 ha planted area outised the land use rights (HGU) is remove from the RSPO scope audit area and not claim as RSPO certified including for the furit produce from that area. 4. Mass balance report for 2020 show the FFB incoming from Block as mentioned above categrozied as non-certified. 6.2.4 03244 Based on interview with workers 1. The company shall The program will be in- The company submit the evidence: 30-09-2020 in Block 3B and 1E, and housing develop details clude / part of 2021 1. Housing area repair program Closed area verification in Division III of program to provide budget program as ev- from oct 2020 until Mar 2021, in- Kedaron estate, found: the toilets with idence commitment for formed the location name for 1. The number of toilet measurable time continuous improve- housing repair i.e.: Pondok 26, was not enough for indicator, and ap- ment from company to Pondok 12 Bulukumba, Pondok MS-0034725-17.1 Rev.0

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Auditee Response Date of NCR Verification of Corretion/ closure Ref Evidence Observed / NCR raised No.RSPO Correction Corrective Action Corrective action Auditor/ Conclution

housing area, where proved by top fulfill the housing facili- 33, Pondok sawmill, Pondok 38, only 5 toilets is able to management. ties for all workers. Pondok 48, Pondok Lompaq, used for 95 person 2. Carry out housing Pondok 40 and Pondok Seki- who living in that hous- repair and added taran Kantor. The program was ing area. new facilties for including for housing, toilets and 2. The clean water quanti- housing area such clear water source. The measur- ty was also not as sanitation area able time table clearly on the enough. and clean water program. The program already source. apporoved by Sr. Estate Con- troler CDM, KMS & South. 2. The photograph of water source installation. The company install the water tank with capacity 1000 M3 for each housing area. 7.2.7 03245 Based on-site visit verification ot 1. Carry out evalua- 1. Carried out review 1. Revised the procedure no. 30-09-2020 chemical werehouse, found: tion analysis of the on the K3L Aspect REA.BPO.EMS.K3LP regarding Closed 1. Obsolete of plant pro- plant protection procedure espe- OHS and Environmental for pes- tection (Amiphosate) and issued the in- cially on the pesti- ticides handling, Rev.01, issued still kept in. ternal memo rec- cide handling date 17 Sep 2020, effective date 2. The air circulation of ommendation to management, and 25 Sep 2020. The revision was chemical werehouse handling the obso- monitor the life- on section 4.1.5 handing the ob- was not good, due to let plant protection. time of stored solote pesticides. the odors of chemical 2. Carry out risk iden- plant protection. 2. Minutes of plant protection in- smelled to the washing tification of wash- 2. Monitoring and spection conducted on 04 Sep room for sprayer. ing room which evaluate the follow 2020 with the result recommen- set-aside with the up action of risk dation is remove the obsolote chemical were- assessment result plant protection not later than 2 house. and recommenda- months after this recommenda- tion as feedback tion is issued. for management 3. Dissemination information of effectivity. HIRADC to all spraying workers concerning on washing house located set-aside with chemical werehouse, conducted on 17 Sep 2020. 4. Renovation photograph of chem- ical werehouse with provide more air circulation.

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It is recommended by the lead auditor to award the system of the company with a certificate pursuant to the above-mentioned RSPO standards after eliminating the non-conformities rated as “major”.

8.2. Minor non-conformities

Auditee Response Date of NCR Verification of Corretion/ closure Ref Evidence Observed / NCR raised No.RSPO Correction Corrective Action Corrective action Auditor/ Conclution

Remote audit 2.2.1 03120 Found some activity is outsourc- Create letter to report Consistent carry out Correction and corrective action is ap- 30-04-2021 ing activity such as FFB trans- regarding outsourced reporting to the authori- proved. The implementation will be check Closed portation, EFB transportation. activity for all contrac- ty for all contractor ac- during onsite verification. But, no evidence able to show by tor to the local authori- tivity if any new con- the company if all the contractor ty. tractor. workers and the contract already reported to the authority (Labour Regulation, Act.19 Year 2020, Article 5). 2.2.2 03121 Related to the NCR No.03120 Carry out education Contractor evaluation Correction and corrective action is ap- 30-04-2021 above, the company did not able and awareness pro- will be performed peri- proved. The implementation will be check Closed to show evaluation record if the gram to all related con- odically to ensure the during onsite verification. contractor they used already tractors company re- contractor able to show compply to applicable law and garding compliance to the commitment to regulations related to social applicable law and comply with applicable worker and health insurance regulations. law and regulations. (BPJSTK and BPJSKES), pay- ment slip, agreement document between contractor with the workers and others. On-site audit 1.1.2 03239 The company did not able to Reporting the land use Re-evaluation the iden- Correction and corrective action is ap- 15-08-2021 show evidence of the periodically rights actual used for tification mechanism of proved. The implementation will be check Closed reporting of land use rights period 2019 to the land applicable law and reg- during onsite verification. (HGU) to the Land Official Gov- authority. ulations. ernment (BPN) for period 2019. 2.1.3 03241 Berkat estate did not install the Re-evaluate the Revise the procedure Correction and corrective action is ap- 15-08-2021 boundary pillars no. 56 – 96. boundary pillars moni- of installation and mon- proved. The implementation will be check Closed toring and mainte- itoring of boundary pil- during onsite verification. nance, and install the lars with review the missing boundary pil- boundary pillars in- lars. spections. MS-0034725-17.1 Rev.0

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Auditee Response Date of NCR Verification of Corretion/ closure Ref Evidence Observed / NCR raised No.RSPO Correction Corrective Action Corrective action Auditor/ Conclution

2.2.2 03242 Found the outsourcing actitivity Identify and evaluate Create applicable law Correction and corrective action is ap- 15-08-2021 for FFB transport in Block 7B, di- all of contractor com- and regulations com- proved. The implementation will be check Closed vision V of Kedaron estate was pany to ensure the pliance program with during onsite verification. not used complete PPE during contractor company al- clear timely manner, on duty, and did not able to show so comply with national and target to achiev. the if the cotractor company al- regulations. ready comply to national regula- tions. 7.12.7 03246 The HCV management and mon- Revise the HCV man- Result of HCV man- Correction and corrective action is ap- 15-08-2021 itoring plan 2019 and 2020 was agement and monitor- agement and monitor- proved. The implementation will be check Closed build but not refer to the RTE ing plan for 2021 with ing implementation will during onsite verification. species monitoring result. baseline is RTE spe- be as feedback for the cies monitoring result. next HCV management and monitoring plan.

It is recommended by the lead auditor to award the system of the company a certificate pursuant to the above-mentioned RSPO standards. The non-conformities identified shall be audited again in line with the timeframe during the next surveillance audit

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9.0 Noteworthy Positive Components and Potential for Improvement

9.1. Positive Observation:

No. Ref. Positive Comments

- - -

9.2. Potential for Improvement:

No. Ref. Potential for improvement

- - -

10.0 Issues Raised by Stakeholders and Findings Pertaining to Issues

10.1 Issues Raised during Stakeholder Consultation Meeting

No. Issues Raised Management Response Auditor Verification

- - - -

10.2 Issues Raised during Stakeholder Interviews On-site

No. Issues Raised Audit Verification

- - -

11.0 Certification Decision

11.1 Recommendation for Certification

PT Rea Kaltim Plantation – Cakra Palm Oil Mill and Supply Based has established and maintains an effective system to ensure compliance with the RSPO principles and criteria. The audit team has confirmed through the remote audit process that the company’s practices complies with, adequately maintains and implements the re- quirements of RSPO Principles and Criteria Generic 2018. PT TUV Rheinland Indonesia recommends that PT Rea Kaltim Plantation – Cakra Oil Mill and Supply Based be maintain as a producer of RSPO Certified Sustaina- ble Palm Oil, prior onsite verification is conducted.

11.2 Date of Certificate Issued and Scope of Certificate

The scope of the certificate covers production of palm oil from PT Rea Kaltim Plantation – Cakra Palm Oil Mill and its supply base, which includes [details of supply base]. The date of certificate issued is [Date of certificate to be included upon certification decision and issuance of certificate]. Further details of the certificate are as per Appendix 1.

11.3 Date of Next Surveillance Visit

The next surveillance visit is planned for April 2021

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12.0 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client

It is acknowledged that the assessment visit was carried out as described in this report and we accept the as- sessment findings and report content.

Signed on behalf PT Rea Kaltim Plantation – Cakra Signed on behalf PT TUV Rheinland Indonesia Palm Oil Mill

Winetou Budi Satria Muhammad Fundy C Kurniawan Sustainability Manager Lead Auditor Date: Oct 2020 Date: Oct 2020

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APPENDICES

Appendix 1: Details of Certificate

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Appendix 2: 3rd Surveillance Audit Plan – Remote audit

Organizational Unit and Procedure - Element - Date / Time (1) Auditor / Abbrev. Interviewee Processes Standard Chapter Monday, 27 Apr 2020 08.00 – 09.00 ICT test Cakra POM MK, BS, PN, DN Management Rep- ICT Test by Webex resentatives Wednesday, 29 Apr 2020 08.00 – 08.30  Opening meeting MK, BS, PN, DN Management  Penyampaian permintaan Representa- dokumen tives 08.30 – 12.00 Document verification: PN Management Prosperity: - Previous NCR verification Representa- 1.1.1; 1.1.3; 1.1.4; 1.1.5 - Information and public availa- tives 1.2.1; 1.2.2 bility 2.1.1 - Communication and consulta- 3.3.1; 3.3.3 tion 3.5.1 - Commitment to ethical con- duct People: - Legal compliance to applica- 4.1.1 ble law and regulations 4.2.2; 4.2.3; 4.2.4 - Standard Operating Proce- 4.4.1; 4.4.3 dures. - System for managing human resources - Human rights - Complaints and grievances 08.30 – 12.00 Document check regarding: DN Management Prosperity: - Previous NCR verification Representa- 2.2.1; 2.2.2; 2.2.3 - Third party contractors legal tives 3.4.1; 3.4.2; 3.4.3 - SEIA and plans 3.7.1; 3.7.2 - Training - Pay and working conditions People: - Freedom of associations 5.1.1; 5.1.5; 5.1.6; 5.1.7; - No child labor 5.1.9 - No harassment 6.1.1; 6.1.3; 6.1.5; 6.1.6 - No forced or trafficked labor 6.2.1; 6.2.2; 6.2.3; 6.2.6 6.3.1 6.4.1; 6.4.2 6.5.1; 6.5.2 6.6.1; 6.6.2 6.7.1; 6.7.2; 6.7.3 08.30 – 12.00 Document check regarding: MK Management Prosperity: - Previous NCR verification Representa- 2.3.1 - Third party FFB legal sourced tives 3.1.1; 3.1.2; 3.1.3 - Long term plan and economic 3.2.1; 3.2.2 availability 3.6.1 - Continuous improvement and reporting Supply chain certification - SCCS System: - Occupational health and safe- General requirements ty plan Module E (mass balance) - Peat 3.8.1 – 3.8.17 - Pollution and GHG’s - HCV and HCS Planet: 7.7.1; 7.7.2; 7.7.3; 7.7.4; 7.7.5 7.10.1; 7.10.2; 7.10.3 7.12.1; 7.12.2; 7.12.3; 7.12.4; 7.12.6; 7.12.18 08.30 – 12.00 Document check regarding: BS Management Planet: - Previous NCR verification Representa- 7.1.1; 7.1.2 - Effective integrated pest tives 7.2.1; 7.2.5; 7.2.6; 7.2.9 management 7.3.1 - Pesticide use 7.4.1; 7.4.2; 7.4.3 - Waste management 7.5.1 - Soil health fertility 7.6.1 - Soil conservation (erosion and 7.7.1; 7.7.2; 7.7.3; 7.7.4; degradation) 7.7.5 - Soil survey and topographic 7.8.1; 7.8.3; 7.8.4

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Organizational Unit and Procedure - Element - Date / Time (1) Auditor / Abbrev. Interviewee Processes Standard Chapter information 7.9.1 - Water quality and quantity 7.12 - Energy use 12.00 – 13.30 Break All auditor - - 13.35 – 16.30 Continue the document verifica- All auditor Management Please refer above. tion Representa- tives Thursday, 30 Apr 2020 08.30 – 12.00 Document verification: PN Management Prosperity: - Previous NCR verification Representa- 1.1.1; 1.1.3; 1.1.4; 1.1.5 - Information and public availa- tives 1.2.1; 1.2.2 bility 2.1.1 - Communication and consulta- 3.3.1; 3.3.3 tion 3.5.1 - Commitment to ethical con- duct People: - Legal compliance to applica- 4.1.1 ble law and regulations 4.2.2; 4.2.3; 4.2.4 - Standard Operating Proce- 4.4.1; 4.4.3 dures. - System for managing human resources - Human rights - Complaints and grievances 08.30 – 12.00 Document check regarding: DN Management Prosperity: - Previous NCR verification Representa- 2.2.1; 2.2.2; 2.2.3 - Third party contractors legal tives 3.4.1; 3.4.2; 3.4.3 - SEIA and plans 3.7.1; 3.7.2 - Training - Pay and working conditions People: - Freedom of associations 5.1.1; 5.1.5; 5.1.6; 5.1.7; - No child labor 5.1.9 - No harassment 6.1.1; 6.1.3; 6.1.5; 6.1.6 - No forced or trafficked labor 6.2.1; 6.2.2; 6.2.3; 6.2.6 6.3.1 6.4.1; 6.4.2 6.5.1; 6.5.2 6.6.1; 6.6.2 6.7.1; 6.7.2; 6.7.2 08.30 – 12.00 Document check regarding: MK Management Prosperity: - Previous NCR verification Representa- 2.3.1 - Third party FFB legal sourced tives 3.1.1; 3.1.2; 3.1.3 - Long term plan and economic 3.2.1; 3.2.2 availability 3.6.1 - Continuous improvement and reporting Supply chain certification - SCCS System: - Occupational health and safe- General requirements ty plan Module E (mass balance) - Peat 3.8.1 – 3.8.17 - Pollution and GHG’s - HCV and HCS Planet: 7.7.1; 7.7.2; 7.7.3; 7.7.4; 7.7.5 7.10.1; 7.10.2; 7.10.3 7.12.1; 7.12.2; 7.12.3; 7.12.4; 7.12.6; 7.12.18 08.30 – 12.00 Document check regarding: BS Management Planet: - Previous NCR verification Representa- 7.1.1; 7.1.2 - Effective integrated pest tives 7.2.1; 7.2.5; 7.2.6; 7.2.9 management 7.3.1 - Pesticide use 7.4.1; 7.4.2; 7.4.3 - Waste management 7.5.1 - Soil health fertility 7.6.1 - Soil conservation (erosion and 7.7.1; 7.7.2; 7.7.3; 7.7.4; degradation) 7.7.5 - Soil survey and topographic 7.8.1; 7.8.3; 7.8.4 information 7.9.1

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Organizational Unit and Procedure - Element - Date / Time (1) Auditor / Abbrev. Interviewee Processes Standard Chapter - Water quality and quantity 7.12 - Energy use 12.00 – 13.30 Break All auditor - - 13.35 – 15.45 Continue the document verifica- All auditor Management Please refer above. tion Representa- tives 15.45 – 16.00 Preparation for closing meeting All auditor - - 16.00 – 16.30 Closing meeting All auditor Management Representa- tives Finished

Audit plan for On-site audit

Organizational Unit and Process- Procedure - Element - Date / Time (1) Auditor / Abbrev. Interviewee es Standard Chapter Monday 10 Aug 2020 08.00 – ………. Waiting for PCR test MK, BS, PN, DN Tuesday 11 Aug 2020 04.55 – 08.05 Travelling (flight) CGK to BPN MK, BS, PN, - GA560 DN Wednesday 12 Aug 2020 08.00 – 08.30  Opening meeting All auditor Management  Auditor introducing Representa- tives 08.00 – 12.00 Document and on-site verification: PN Management Prosperity: Kedaron estate - Previous NCR verification Representa- 1.1.2 - Information and public availa- tives 1.2.1; 1.2.2 bility 2.1.1; 2.1.2; 2.1.3 - Communication and consulta- 3.3.2; 3.3.3; tion 3.5.2 - Commitment to ethical conduct - Legal compliance to applicable People: law and regulations 4.1.1; 4.1.2 - Standard Operating Proce- 4.2.1; 4.2.3; 4.2.4 dures. 4.3.1 - System for managing human 4.4.2; 4.4.4; 4.4.5; 4.4.6 resources 4.5.1; 4.5.2; 4.5.3; 4.5.4; - Human rights 4.5.5; 4.5.6; 4.5.7; 4.5.8 - Complaints and grievances 4.6.1; 4.6.2; 4.6.3; 4.6.4 4.7.1; 4.7.2; 4.7.3 4.8.1; 4.8.2; 4.8.3; 4.8.4

08.00 – 12.00 Document and on-site verification: DN Management Prosperity: Kedaron estate - Previous NCR verification Representa- 2.2.2 - Third party contractors legal tives 3.4.1; 3.4.3 - SEIA and plans 3.7.1; 3.7.2; 3.7.3 - Improved livelihoods of small- holders People: - Training 5.1.2; 5.1.3; 5.1.4; 5.1.5; - Pay and working conditions 5.1.8 - Freedom of associations 5.2.1; 5.2.2; 5.2.3; 5.2.4; - No child labor 5.2.5 - No harassment 6.1.2; 6.1.3; 6.1.4; 6.1.5; - No forced or trafficked labor 6.1.6 6.2.2; 6.2.4; 6.2.5; 6.2.6; 6.2.7 6.3.2; 6.3.3 6.4.3; 6.4.4 6.5.3; 6.5.4 6.6.1; 6.6.2 6.7.1; 6.7.2; 6.7.3; 6.7.4; 6.7.5 08.00 – 12.00 Document and on-site verification: MK Management Prosperity: Kedaron estate - Previous NCR verification Representa- 2.3.2 - Third party FFB legal sourced tives 3.1.1; 3.1.3 - Long term plan and economic 3.2.1

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Organizational Unit and Process- Procedure - Element - Date / Time (1) Auditor / Abbrev. Interviewee es Standard Chapter availability 3.6.2 - Continuous improvement and reporting Supply chain certification - SCCS System: - Occupational health and safety General requirements plan Module E (mass balance) - Peat 3.8.4; 3.8.11; 3.8.12; 3.8.15; - Pollution and GHG’s 3.8.16; 3.8.17 - HCV and HCS Planet: 7.7.1; 7.7.2; 7.7.3; 7.7.4; 7.7.5 7.10.3 7.12.2; 7.12.3; 7.12.4; 7.12.5; 7.12.6; 7.1.2.7 08.00 – 12.00 Document and on-site verification: BS Management Planet: Kedaron estate - Previous NCR verification Representa- 7.1.1; 7.1.3 - Effective integrated pest man- tives 7.2.1; 7.2.2; 7.2.3; 7.2.4; agement 7.2.5; 7.2.6; 7.2.7; 7.2.8; - Pesticide use 7.2.9; 7.2.10; 7.2.11 - Waste management 7.3.2; 7.3.3 - Soil health fertility 7.4.1; 7.4.3; 7.4.4 - Soil conservation (erosion and 7.5.2; 7.5.3 degradation) 7.6.2; 7.6.3 - Soil survey and topographic in- 7.7.1; 7.7.2; 7.7.3; 7.7.5; formation 7.7.6; 7.7.7 - Water quality and quantity 7.8.1; 7.8.2 - Energy use 7.9.1 - Zero burning activity 7.11.1; 7.11.2; 7.11.3 12.00 – 13.30 Break All auditor - - 13.35 – 18.00 Continue the document verifica- All auditor Management Please refer above. tion Representa- tives 08.00 – 18.00 LURI Verification for Kedaron Es- NQ, MK Management RSPO P&C 7.12.2 Annex 5 tate (document and on-site veri- Representa- fication) tives Thursday 13 Aug 2020 08.00 – 12.00 Document and on-site verification: PN Management Prosperity: Berkat Esate - Previous NCR verification Representa- 1.1.2 - Information and public availa- tives 1.2.1; 1.2.2 bility 2.1.1; 2.1.2; 2.1.3 - Communication and consulta- 3.3.2; 3.3.3; tion 3.5.2 - Commitment to ethical conduct - Legal compliance to applicable People: law and regulations 4.1.1; 4.1.2 - Standard Operating Proce- 4.2.1; 4.2.3; 4.2.4 dures. 4.3.1 - System for managing human 4.4.2; 4.4.4; 4.4.5; 4.4.6 resources 4.5.1; 4.5.2; 4.5.3; 4.5.4; - Human rights 4.5.5; 4.5.6; 4.5.7; 4.5.8 - Complaints and grievances 4.6.1; 4.6.2; 4.6.3; 4.6.4 4.7.1; 4.7.2; 4.7.3 4.8.1; 4.8.2; 4.8.3; 4.8.4

08.00 – 12.00 Document and on-site verification: DN Management Prosperity: Berkat Esate - Previous NCR verification Representa- 2.2.2 - Third party contractors legal tives 3.4.1; 3.4.3 - SEIA and plans 3.7.1; 3.7.2; 3.7.3 - Improved livelihoods of small- holders People: - Training 5.1.2; 5.1.3; 5.1.4; 5.1.5; - Pay and working conditions 5.1.8 - Freedom of associations 5.2.1; 5.2.2; 5.2.3; 5.2.4; - No child labor 5.2.5 - No harassment 6.1.2; 6.1.3; 6.1.4; 6.1.5; - No forced or trafficked labor 6.1.6 6.2.2; 6.2.4; 6.2.5; 6.2.6;

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Organizational Unit and Process- Procedure - Element - Date / Time (1) Auditor / Abbrev. Interviewee es Standard Chapter 6.2.7 6.3.2; 6.3.3 6.4.3; 6.4.4 6.5.3; 6.5.4 6.6.1; 6.6.2 6.7.1; 6.7.2; 6.7.3; 6.7.4; 6.7.5 08.00 – 12.00 Document and on-site verification: MK Management Prosperity: Berkat Esate - Previous NCR verification Representa- 2.3.2 - Third party FFB legal sourced tives 3.1.1; 3.1.3 - Long term plan and economic 3.2.1 availability 3.6.2 - Continuous improvement and reporting Supply chain certification - SCCS System: - Occupational health and safety General requirements plan Module E (mass balance) - Peat 3.8.4; 3.8.11; 3.8.12; 3.8.15; - Pollution and GHG’s 3.8.16; 3.8.17 - HCV and HCS Planet: 7.7.1; 7.7.2; 7.7.3; 7.7.4; 7.7.5 7.10.3 7.12.2; 7.12.3; 7.12.4; 7.12.5; 7.12.6; 7.1.2.7 08.00 – 12.00 Document and on-site verification: BS Management Planet: Berkat Esate - Previous NCR verification Representa- 7.1.1; 7.1.3 - Effective integrated pest man- tives 7.2.1; 7.2.2; 7.2.3; 7.2.4; agement 7.2.5; 7.2.6; 7.2.7; 7.2.8; - Pesticide use 7.2.9; 7.2.10; 7.2.11 - Waste management 7.3.2; 7.3.3 - Soil health fertility 7.4.1; 7.4.3; 7.4.4 - Soil conservation (erosion and 7.5.2; 7.5.3 degradation) 7.6.2; 7.6.3 - Soil survey and topographic in- 7.7.1; 7.7.2; 7.7.3; 7.7.5; formation 7.7.6; 7.7.7 - Water quality and quantity 7.8.1; 7.8.2 - Energy use 7.9.1 - Zero burning activity 7.11.1; 7.11.2; 7.11.3 12.00 – 13.30 Break All auditor - - 13.30 – 18.00 Continue the document verifica- All auditor Management Please refer above. tion Representa- tives 08.00 – 18.00 LURI Verification for Berkat and NQ, MK Management RSPO P&C 7.12.2 Annex 5 Damai Estate (document and on- Representa- site verification) tives Friday 14 Aug 2020 08.00 – 12.00 On-site verification: PN Management Prosperity: Damai estate - Previous NCR verification Representa- 1.1.2 - Information and public availa- tives 1.2.1; 1.2.2 bility 2.1.1; 2.1.2; 2.1.3 - Communication and consulta- 3.3.2; 3.3.3; tion 3.5.2 - Commitment to ethical conduct - Legal compliance to applicable People: law and regulations 4.1.1; 4.1.2 - Standard Operating Proce- 4.2.1; 4.2.3; 4.2.4 dures. 4.3.1 - System for managing human 4.4.2; 4.4.4; 4.4.5; 4.4.6 resources 4.5.1; 4.5.2; 4.5.3; 4.5.4; - Human rights 4.5.5; 4.5.6; 4.5.7; 4.5.8 - Complaints and grievances 4.6.1; 4.6.2; 4.6.3; 4.6.4 4.7.1; 4.7.2; 4.7.3 4.8.1; 4.8.2; 4.8.3; 4.8.4

08.00 – 12.00 Document and on-site verification: DN Management Prosperity: Damai estate - Previous NCR verification Representa- 2.2.2

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Organizational Unit and Process- Procedure - Element - Date / Time (1) Auditor / Abbrev. Interviewee es Standard Chapter - Third party contractors legal tives 3.4.1; 3.4.3 - SEIA and plans 3.7.1; 3.7.2; 3.7.3 - Improved livelihoods of small- holders People: - Training 5.1.2; 5.1.3; 5.1.4; 5.1.5; - Pay and working conditions 5.1.8 - Freedom of associations 5.2.1; 5.2.2; 5.2.3; 5.2.4; - No child labor 5.2.5 - No harassment 6.1.2; 6.1.3; 6.1.4; 6.1.5; - No forced or trafficked labor 6.1.6 6.2.2; 6.2.4; 6.2.5; 6.2.6; 6.2.7 6.3.2; 6.3.3 6.4.3; 6.4.4 6.5.3; 6.5.4 6.6.1; 6.6.2 6.7.1; 6.7.2; 6.7.3; 6.7.4; 6.7.5 08.00 – 12.00 Document and on-site verification: MK Management Prosperity: Damai estate - Previous NCR verification Representa- 2.3.2 - Third party FFB legal sourced tives 3.1.1; 3.1.3 - Long term plan and economic 3.2.1 availability 3.6.2 - Continuous improvement and reporting Supply chain certification - SCCS System: - Occupational health and safety General requirements plan Module E (mass balance) - Peat 3.8.4; 3.8.11; 3.8.12; 3.8.15; - Pollution and GHG’s 3.8.16; 3.8.17 - HCV and HCS Planet: 7.7.1; 7.7.2; 7.7.3; 7.7.4; 7.7.5 7.10.3 7.12.2; 7.12.3; 7.12.4; 7.12.5; 7.12.6; 7.1.2.7 08.00 – 12.00 Document and on-site verification: BS Management Planet: Damai estate - Previous NCR verification Representa- 7.1.1; 7.1.3 - Effective integrated pest man- tives 7.2.1; 7.2.2; 7.2.3; 7.2.4; agement 7.2.5; 7.2.6; 7.2.7; 7.2.8; - Pesticide use 7.2.9; 7.2.10; 7.2.11 - Waste management 7.3.2; 7.3.3 - Soil health fertility 7.4.1; 7.4.3; 7.4.4 - Soil conservation (erosion and 7.5.2; 7.5.3 degradation) 7.6.2; 7.6.3 - Soil survey and topographic in- 7.7.1; 7.7.2; 7.7.3; 7.7.5; formation 7.7.6; 7.7.7 - Water quality and quantity 7.8.1; 7.8.2 - Energy use 7.9.1 - Zero burning activity 7.11.1; 7.11.2; 7.11.3 12.00 – 13.30 Break All auditor - Continue on-site verification 13.35 – 18.00 Continue the document verifica- All auditor Management Please refer above. tion Representa- tives 08.00 – 18.00 LURI Verification for Cakra and NQ, MK Management RSPO P&C 7.12.2 Annex 5 Lestari Estate (document and Representa- on-site verification) tives Saturday 15 Aug 2020 08.00 – 12.00 Document and on-site verification: PN Management Prosperity: Cakra estate - Previous NCR verification Representa- 1.1.2 - Information and public availa- tives 1.2.1; 1.2.2 bility 2.1.1; 2.1.2; 2.1.3 - Communication and consulta- 3.3.2; 3.3.3; tion 3.5.2 - Commitment to ethical conduct - Legal compliance to applicable People: law and regulations 4.1.1; 4.1.2

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Organizational Unit and Process- Procedure - Element - Date / Time (1) Auditor / Abbrev. Interviewee es Standard Chapter - Standard Operating Proce- 4.2.1; 4.2.3; 4.2.4 dures. 4.3.1 - System for managing human 4.4.2; 4.4.4; 4.4.5; 4.4.6 resources 4.5.1; 4.5.2; 4.5.3; 4.5.4; - Human rights 4.5.5; 4.5.6; 4.5.7; 4.5.8 - Complaints and grievances 4.6.1; 4.6.2; 4.6.3; 4.6.4 4.7.1; 4.7.2; 4.7.3 4.8.1; 4.8.2; 4.8.3; 4.8.4

08.00 – 12.00 Document and on-site verification: DN Management Prosperity: Cakra estate - Previous NCR verification Representa- 2.2.2 - Third party contractors legal tives 3.4.1; 3.4.3 - SEIA and plans 3.7.1; 3.7.2; 3.7.3 - Improved livelihoods of small- holders People: - Training 5.1.2; 5.1.3; 5.1.4; 5.1.5; - Pay and working conditions 5.1.8 - Freedom of associations 5.2.1; 5.2.2; 5.2.3; 5.2.4; - No child labor 5.2.5 - No harassment 6.1.2; 6.1.3; 6.1.4; 6.1.5; - No forced or trafficked labor 6.1.6 6.2.2; 6.2.4; 6.2.5; 6.2.6; 6.2.7 6.3.2; 6.3.3 6.4.3; 6.4.4 6.5.3; 6.5.4 6.6.1; 6.6.2 6.7.1; 6.7.2; 6.7.3; 6.7.4; 6.7.5 08.00 – 12.00 Document and on-site verification: MK Management Prosperity: Cakra estate - Previous NCR verification Representa- 2.3.2 - Third party FFB legal sourced tives 3.1.1; 3.1.3 - Long term plan and economic 3.2.1 availability 3.6.2 - Continuous improvement and reporting Supply chain certification - SCCS System: - Occupational health and safety General requirements plan Module E (mass balance) - Peat 3.8.4; 3.8.11; 3.8.12; 3.8.15; - Pollution and GHG’s 3.8.16; 3.8.17 - HCV and HCS Planet: 7.7.1; 7.7.2; 7.7.3; 7.7.4; 7.7.5 7.10.3 7.12.2; 7.12.3; 7.12.4; 7.12.5; 7.12.6; 7.1.2.7 08.00 – 12.00 Document and on-site verification: BS Management Planet: Cakra estate - Previous NCR verification Representa- 7.1.1; 7.1.3 - Effective integrated pest man- tives 7.2.1; 7.2.2; 7.2.3; 7.2.4; agement 7.2.5; 7.2.6; 7.2.7; 7.2.8; - Pesticide use 7.2.9; 7.2.10; 7.2.11 - Waste management 7.3.2; 7.3.3 - Soil health fertility 7.4.1; 7.4.3; 7.4.4 - Soil conservation (erosion and 7.5.2; 7.5.3 degradation) 7.6.2; 7.6.3 - Soil survey and topographic in- 7.7.1; 7.7.2; 7.7.3; 7.7.5; formation 7.7.6; 7.7.7 - Water quality and quantity 7.8.1; 7.8.2 - Energy use 7.9.1 - Zero burning activity 7.11.1; 7.11.2; 7.11.3 12.00 – 13.00 Break All auditor Management Representa- - tives 13.30 – 15.30 Cakra Oil mill – onsite and doc- All auditor Management Please refer to criteria Cakra oil mill ument verification Representa- above. tives 08.00 – 15.30 LURI Verification for Perdana NQ, MK Management RSPO P&C 7.12.2 Annex 5

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Organizational Unit and Process- Procedure - Element - Date / Time (1) Auditor / Abbrev. Interviewee es Standard Chapter and Sentekan Estate (document Representa- and on-site verification) tives 15.30 – 16.00 Preparation for closing meeting All auditor - - 16.00 – 17.30 Closing meeting All auditor Management Representa- tives 18.00 – …….. Travelling to Balikpapan and All auditor overnight in Balikpapan if possi- - - ble Sunday 16 Aug 2020 13.05 – 14.20 Travelling (flight) BPN to CGK All auditor - GA567 Finished

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Appendix 3: List of Abbreviations

AMDAL Analisis Dampak Lingkungan & Sosial (Social & Environmental Impacts Assessment) CPO Crude Palm Oil EIA Environmental Impact Assessment ERTs Endangered, Rare & Threatened species ESH Environmental Safety & Health FFB Fresh Fruit Bunches EFB Empty Fruit Bunches HCV High Conservation Value IPM Integrated Pest Management LTA Lost Time Accident MSDS Material Safety Data Sheets NGO Non-Government Organization NPP New Planting Procedure OSH Occupational Safety & Health PKO Palm Kernel Oil POME Palm Oil Mill Effluent PPE Personal Protective Equipment RKL Rencana Pengelolaan Lingkungan (Environmental Management Plan) RPL Rencana Pemantauan Lingkungan (Environmental Monitoring Plan) SIA Social Impact Assessment SOP Standard Operating Procedure UKL Upaya Pengelolaan Lingkungan (Environmental Management Efforts) UPL Upaya Pemantauan Lingkungan (Environmental Monitoring Efforts)

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Appendix 4: Other Achievement s and Certificatio Helds

Certification Name of mill / Certification Standard / Date Body / estate Award achieved Achieved Awarder - - - -

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Appendix 5: List of Stakeholders Interviewed and Contacted

No. Name of Stakeholder Institution / Position Remarks Stakeholders Interviewed during Public Consultation Meeting 1 Stakeholders Interviewed Remote 1 Ramdan Harvester Div III Perdana Estate 2 Mansur Foreman Div III Perdana Estate 3 Taslim Contractor (EFB Application) Pedana Etsate 4 Yani Safitri Sprayer/EFB application Sentekan 5 Anto Payung Harvester Sentekan Estate 6 Rupang Foreman Sentekan Estate 7 Rodiyah Upkeep Sentekan Estate (PKWT) 8 Elisabeth Upkeep Sentekan Estate (PKWT) 9 Musniarthi Upkeep Sentekan Estate (PKWT) 10 Sumiati Upkeep Sentekan Estate (PKWT) 11 Suryani Abdullah Upkeep Sentekan Estate (PKWT) 12 Ahmad Habibi Sustainability Staff 13 Winetou Budi Satria Sustainability Manager Stakeholders Interviewed On-site 1 Ahmad Habibi Sustainability Certification Manager 2 Winetou Budi Satria Sustainability Manager 3 Soso Harvesters, Division III, Block 3B, Kedaron Estate 4 Febianus Udin Harvesters, Division III, Block 3B, Kedaron Estate 5 Asar Harvesters, Division III, Block 3B, Kedaron Estate 6 Agustinus Harvesters, Division III, Block 3B, Kedaron Estate 7 Helmi Juit Maintenance, Division III, Block iE, Kedaron Estate 8 Shinta Maintenance, Division III, Block iE, Kedaron Estate 9 Aluadi Maintenance, Division III, Block iE, Kedaron Estate 10 Sudarmi Maintenance, Division III, Block iE, Kedaron Estate 11 Yupita Mendung Maintenance, Division III, Block iE, Kedaron Estate 12 Deltian M Maintenance, Division III, Block iE, Kedaron Estate 13 Potoulia Maintenance, Division III, Block iE, Kedaron Estate 14 Pilomena Siman Maintenance, Division III, Block iE, Kedaron Estate 15 Wati Maintenance, Division III, Block iE, Kedaron Estate 16 Kornila M Maintenance, Division III, Block iE, Kedaron Estate 17 Yulia Jerahu Maintenance, Division III, Block iE, Kedaron Estate 18 Asmiati Sprayers, Div. 2, Block IIA, Berkat Estate 19 Mahdin Sprayers, Div. 2, Block IIA, Berkat Estate 20 Maryam Sprayers, Div. 2, Block IIA, Berkat Estate 21 Miti Sprayers, Div. 2, Block IIA, Berkat Estate 22 Surisah Sprayers, Div. 2, Block IIA, Berkat Estate 23 Apiah Sprayers, Div. 2, Block IIA, Berkat Estate 24 Saidah Sprayers, Div. 2, Block IIA, Berkat Estate 25 Suryati Sprayers, Div. 2, Block IIA, Berkat Estate 26 Partati Sprayers, Div. 3, Block 15BC, Damai Estate 27 Riswan Sprayers, Div. 3, Block 15BC, Damai Estate 28 Siti Aminah Sprayers, Div. 3, Block 15BC, Damai Estate 29 Maria Sprayer worker (Kedaron estate) 30 Maria Ima Sprayer worker (Kedaron estate) 31 Margaretha Sprayer worker (Kedaron estate) 32 Maria Afra Sprayer worker (Kedaron estate) 33 Martina Sprayer worker (Kedaron estate) 34 Tutiana Maria Sprayer worker (Kedaron estate) 35 Estin Sprayer worker (Kedaron estate) 36 Aidin Sprayer worker (Berkat estate) 37 Aziz Sprayer worker (Berkat estate) 38 Rafi Sprayer worker (Berkat estate) 39 Nuraini Sprayer worker (Berkat estate) 40 Heni K Sprayer worker (Berkat estate) 41 Sapriani Sprayer worker (Berkat estate) 42 Sudaria Sprayer worker (Berkat estate) 43 Rosdiana Sprayer worker (Berkat estate).,

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44 Ayulin Sprayer worker (Berkat estate) 45 Siswanto Sprayer worker (Damai estate) 46 Hadira Sprayer worker (Damai estate) 47 Yustin Sprayer worker (Damai estate) 48 Cece Sprayer worker (Damai estate) 49 Helin siska Sprayer worker (Damai estate) 50 Ribka Sprayer worker (Damai estate) 51 Roy Sprayer worker (Damai estate) 52 Ramdan Harvester Div III Perdana Estate 53 Mansur Foreman Div III Perdana Estate 54 Taslim Contractor (EFB Application) Pedana Etsate 55 Yani Safitri Sprayer/EFB application Sentekan 56 Anto Payung Harvester Sentekan Estate 57 Rupang Foreman Sentekan Estate 58 Rodiyah Upkeep Sentekan Estate (PKWT) 59 Elisabeth Upkeep Sentekan Estate (PKWT) 60 Musniarthi Upkeep Sentekan Estate (PKWT) 61 Sumiati Upkeep Sentekan Estate (PKWT) 62 Suryani Abdullah Upkeep Sentekan Estate (PKWT)

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Appendix 6: Organization’s land History and information about all previous users of the land

Total of land compensation: 9507.12 ha Total of entity: 841 unit so minimum of the quantity of sample each audit is 0.8 x √841 Unit = 23.2 Unit

Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) Damai estate 1 Kelekat Vilage Piman 3.70 2006 2 Kelekat Vilage Cudil 0.41 2007 3 Kelekat Vilage Wisiu 0.30 2007 4 Kelekat Vilage Iceh 0.30 2007 5 Kelekat Vilage Duin 5.40 2008 6 Kelekat Vilage Louis 6.30 2008 7 Kelekat Vilage Duin 4.80 2008 8 Kelekat Vilage Wiin SH 16.90 2008 9 Kelekat Vilage Ardil 14.90 2008 10 Kelekat Vilage Andreas Lung 15.01 2008 11 Kelekat Vilage Misransyah/Imis 6.10 2008 12 Kelekat Vilage Gek/Ruskin 39.20 2008 13 Kelekat Vilage Sika 6.80 2008 14 Kelekat Vilage Idiu 7.90 2008 15 Kelekat Vilage Iman 17.40 2008 16 Kelekat Vilage Yustian 7.50 2008 17 Kelekat Vilage Tani 12.60 2008 18 Kelekat Vilage Ngenget 4.80 2008 19 Kelekat Vilage Antonie Marchellino 8.60 2009 20 Kelekat Vilage Joyok 21 Kelekat Vilage Aliansyah (Len) 22 Kelekat Vilage Ali Lejiu 6.60 2009 23 Kelekat Vilage Edo Christian 24.00 2009 24 Kelekat Vilage Laupeg 23.30 2009 25 Kelekat Vilage Ari Danuri 15.30 2010 26 Kelekat Vilage Antonie Marchellino 25.93 2010 27 Kelekat Vilage Sutan 17.10 2010 28 Kelekat Vilage Marta 33.10 2010 29 Kelekat Vilage Witim 9.60 2010 30 Kelekat Vilage Idol 11.56 2010 31 Kelekat Vilage Ardil 21.10 2010 32 Kelekat Vilage Laboh 24.30 2011 33 Kelekat Vilage Haniah 11.20 2011 34 Kelekat Vilage Ali Lejiu 10.00 2011 35 Kelekat Vilage Dalmasius,SH 36 Kelekat Vilage Dalmasius,SH 37 Kelekat Vilage Ismail 18.90 2011 38 Kelekat Vilage Sumarno 40.40 2011 39 Kelekat Vilage Dalmasius,SH 40 Kelekat Vilage Dalmasius,SH

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 41 Kelekat Vilage Dalmasius,SH 42 Kelekat Vilage Ibau 2.40 2011 43 Kelekat Vilage Ibau 6.50 2011 44 Kelekat Vilage Bakran 5.20 2011 45 Kelekat Vilage Bakran 11.00 2011 46 Kelekat Vilage Nisen 1.50 2011 47 Kelekat Vilage Nisen 9.40 2011 48 Kelekat Vilage Hambiyah 15.40 2011 49 Kelekat Vilage Wisiu 3.80 2011 50 Kelekat Vilage Wisiu 0.90 2011 51 Kelekat Vilage Wisiu 0.60 2011 52 Kelekat Vilage Wisiu 4.70 2011 53 Kelekat Vilage Ardil 18.50 2011 54 Kelekat Vilage Ardil 2.10 2011 55 Kelekat Vilage Wahyudin 15.30 2011 56 Kelekat Vilage Wahyudin 3.20 2011 57 Kelekat Vilage Ibau 2.50 2013 58 Kelekat Vilage Asen 2.30 2013 59 Kelekat Vilage Petrus Amran 57.00 2013 60 Kelekat Vilage Petrus Amran 4.70 2013 61 Kelekat Vilage Petrus Amran 22.00 2013 62 Kelekat Vilage Vinah 10.20 2013 63 Kelekat Vilage Vinah 2.50 2013 64 Kelekat Vilage Rudi 139.00 2013 65 Kelekat Vilage Piwil 20.90 2013 66 Kelekat Vilage Burhan 21.00 2013 67 Kelekat Vilage Wahyudin 3.60 2013 68 Kelekat Vilage Umi 5.60 2013 69 Kelekat Vilage Umi 0.20 2013 70 Kelekat Vilage Umi 7.50 2013 71 Kelekat Vilage Umi 2.30 2013 72 Kelekat Vilage Umi 1.20 2013 73 Kelekat Vilage Ali Lejiau 13.60 2013 74 Kelekat Vilage Tendos 1.60 2013 75 Kelekat Vilage Salehudin 3.40 2013 76 Kelekat Vilage Salehudin 7.50 2013 77 Kelekat Vilage Jimransyah 8.40 2013 78 Kelekat Vilage Ahen 66.90 2013 79 Kelekat Vilage Ahen 61.40 2013 80 Kelekat Vilage Ahen 12.00 2013 81 Kelekat Vilage Sirajuddin 0.70 2013

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 82 Kelekat Vilage Kipung 8.91 2013 83 Kelekat Vilage Kipung 8.91 2013 84 Kelekat Vilage Kipung 2.80 2013 85 Kelekat Vilage Kipung 1.10 2013 86 Kelekat Vilage Wancen 6.20 2013 87 Kelekat Vilage Wancen 1.40 2013

Berkat Estate 1 Kembang Janggut village Hasan Sanusi 2,000.00 2006 2 Kembang Janggut village Hasan Sanusi 3,000.00 2006 3 Kembang Janggut village M.Elyas Effendi 4 Kembang Janggut village Syabaruddin S 5 Kembang Janggut village Syahruddin 6 Kembang Janggut village Borhan Hs 7 Kembang Janggut village Alala 8 Kembang Janggut village Musliansyah 9 Kembang Janggut village Ramli 10 Kembang Janggut village Mirhansyah 11 Kembang Janggut village Asma 12 Kembang Janggut village Awang Ardiansyah 13 Berkat village Hasan Sanusi 14 Berkat village Hasan Sanusi 15 Kembang Janggut village Hasan Sanusi 2,000.00 2007 16 Kembang Janggut village Hasan Sanusi 17 Kembang Janggut village Hasan Sanusi 190.00 2007 18 Kembang Janggut village Indra Wahyudi 4.40 2009 19 Kembang Janggut village Akil 3.80 2009 20 Kembang Janggut village Mashudi 15.00 2009 21 Kembang Janggut village Intuk 22 Kembang Janggut village Bahriansyah/bahri 23 Kembang Janggut village Ling 24 Kembang Janggut village Padliansyah/padli 25 Kembang Janggut village Wandi Wahyudi/Ndut 26 Kembang Janggut village Iyus Yunus/Yus 27 Kembang Janggut village Sumarno/Marno 28 Kembang Janggut village Robiansyah/Robi 29 Kembang Janggut village Jumri.Jum 30 Kembang Janggut village Dona 31 Kembang Janggut village Syahlani 5.70 2011 Aslan,Asan,S,Safransyah, dan 32 Kembang Janggut village - 2013 Arwad

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc)

Cakra estate 1 Bukit Layang village Sepiman 1 2.00 2000 2 Bukit Layang village Sepiman 2 1.50 2000 3 Bukit Layang village Male 2.00 2000 4 Bukit Layang village Lukas Judi 2.00 2000 5 Muai village Kamranuddin,Pulus,Idris 413.50 2003 6 Joyo lukito 7 M.Hariyanto Abd 8 Budi Wijayanto 9 Romelan 10 Mustaqim 11 Nursalim 12 Kalamullah 13 Munjianto 14 Eko Hadi Susilo 15 Norman H. Setiawan 16 Fatimah 17 Ayu PS 18 Iin Komar 19 Zamal zam zam 20 Paulus Lejap 21 Aser 22 Januri 23 Thamrin 24 Norman 25 Rustam 26 Ardiansyah Adi 27 La Una 28 Alfian 29 Bahtiar 30 Husfiadi 31 Bay La Ode Hasyim 32 Abdullah Ahap 33 Eddy 34 Wendi 35 Itok 36 Cipen 37 Aan 38 Sarni 39 Aidin

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 40 Otoh 41 Hetolar 42 Yun 43 Arifin 44 La Mili 45 La Komena 46 Cakol 47 La Esso 48 Unni AR 49 Abar 50 Jamhur 51 Kol 52 Suhur 53 Syahnan 54 Ucap 55 Jahran 56 La Dehe 57 Yon 58 Lebok 59 Idin 60 Agus H 61 Musli 62 Rizal 63 Jamir Hamdani 64 Padli 65 Pitria 66 Misran 67 H. Bustani 68 Juriadi 69 Mardiah 70 Rapinus 71 Petrus Payung 72 Abdurahman 73 Riyanto 74 Jumri 75 Sugiyanto 76 Agus Ara 77 Lambang 78 Sari 79 M.Madoi 80 Ismail Pandalo

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 81 Saleh 82 Sandiri 83 Ersam 84 Ahmad Same 85 Boro 86 Yunus Pulung 87 Yajup 88 Bara 89 Karnadi 90 Mulyadi 91 Paulus Lejap B 92 Arnadi Umu 93 Irus 94 Kamarudin uding 95 Cutut 96 Ciko/Ismail 97 Syaripudin 98 Affandi 99 Usuf Cinun 100 Arsuni 101 Japar Japek 102 Kuas 103 Asmiran Mira 104 Aspar Apoi 105 Acang 106 Ulus 107 Nanang 108 Sadri Teten 109 Dyahrudin Beleo 110 Jahri Empek 111 Sudaslan 112 La Ali/Kadier 113 Halidi 114 Bok 115 Japri 116 Besen 117 Ko'An 118 Hadi 119 Pudin 120 Wahiduk 121 Ahmad Same

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 122 Kacum 123 Ridu Udin 124 Piter 125 Syahrul 126 Kaseng 127 Kiding 128 Hidayat 129 Asan Sahar 130 Sopiyan 131 Ahmadsyah 132 Abdul Hamid 133 drs Bahaudin 134 Ali Anew 135 Bahar 136 Hani 137 Amransyah Taom 138 Lahuddin Kenek 139 Mashan Genu 140 141 Ishak Razak 142 Kamaruddin T 143 Norman 144 Japek 145 ardan 146 Bustani Bew 147 Coton 148 Nami 149 Jamal 150 Yusran/Yus 151 U ni Kol 152 Juhri/Ijuh 153 Nance 154 Suni Icol 155 Mol 156 Abar 157 Usuf Cinun 158 Dak 159 M.Nasri.R 160 Hassan 161 Astan/Kuas 162 Askar/Akoy

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 163 Mudin Suni 164 Sudir Arjan 165 Rahman Jonet 166 Saidi/Tetew 167 Tob Pik 168 Jahri/Empek 169 Jepang Siah 170 Jamran/Muh 171 Kengkeng 172 Ardian Sudin 173 Saini Tuk 174 Kidding 175 Sadri KTC 176 177 Boy 178 Ipul 179 Suhur 180 Uni Kal 181 Yusran 182 Kenek 183 Piter 184 Kacum 185 Sin/Keluarga 186 M.Nasri.B 187 Suni 188 Hadri 189 Ponidi 2004 190 Lakumena 191 Muai Village Geng 192 Kelekat village Cukfrianto I 193 Cukfrianto II 194 Birhan 195 Syahminan 196 Jamli I 197 Jamli II 5.00 2004 198 Kewang I 199 Kewang II 200 Beng 201 Setak/iwan 202 Jui/Rinca 203 Akil

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 204 Ardiansyah 205 Muliansyah 206 Cila I 207 Cila II 208 Asen 209 Abdul Fatah/Ilham 210 Lesen 211 Mayon 212 Ilham 213 Wisiu 214 Lasarus EN 215 Muai village Halidi 13.30 2005 216 Lambang 53.00 217 Kelekat village Cawal SE 218 Arbiansyah Utun S.Sos 219 Cawal SE 220 Abniansyah Utun 221 Muhidi 222 Arisandy 223 Ali Mustopa 224 Akun 225 Alim Iswandi 226 Antonius 227 Akhmat Tang 228 Alexander 229 Ajus 230 Alpian 231 Ahen 232 Boby 233 Cila 234 Cuk 235 Cuing 236 Diot 237 Duin 238 Diut 239 Dilok 240 Dogak 241 Diman Mot 242 Darsono 243 Depi Ibus 244 Dumoi/Dimoi

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 245 Darham Duat 246 Enda 247 Ady Sopian 248 Hasnan 249 Hamrin 250 Tani 251 Heri Turit 252 Hot 253 Ipsyah 254 Imransyah 255 Iyan (Duri) 256 Ineng 257 Ibau 258 Idol 259 Jusen 260 Jui 261 Jepen 262 Kationg 263 Kuyam 264 Kasip 265 Kipung 266 Lot 267 Lejiu 268 Martiani 269 Mardi Jalung 270 Mincong 271 Mulyansyah 272 Mobi 273 Man 274 Murin 275 Masir/Maser 276 Mahmud Ismail 277 Muhtar OT 278 Nyupin 279 Puat/Pijat 280 Redianus 281 Siiu 282 Siong 283 Saucai 284 Sumidi/Semidi 285 Suntek

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 286 Sangkem 287 Sem 288 Seradin 289 Seradi 290 Samsudin 291 Sipan 292 Setak 293 Tangkai 294 Toni 295 Urhansyah 296 Uyuk 297 Ubok 298 Usman Alan 299 Wiin SH 300 Wanjah 301 Witar 302 Wincue 303 Witim 304 Wasun 305 Sipan 306 Johan 307 Yusak 308 Yulman 309 Yusensyah 310 Lauis/Lanis 311 Kina 312 Akhmadi 313 Akhwa 314 Ali Robina 315 Abian 316 Ajiu 317 Piman 318 Alim 319 Adial 320 Amat 321 Anisal 322 Apet Nego 323 Adian 324 Biran 325 Bandi 326 Cinau

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 327 Akil 328 Disap 329 Embung 330 Empiyong 331 Ging 332 Ipul 333 Iti 334 Iwan 335 Iyan 336 Ibah 337 Jandis 338 Judi/Jusen 339 Jutek 340 Jenny/Ren 341 Jayan 342 Jejer 343 karsah 344 Kew 345 Lahady/Enjung 346 Lado 347 Murdin 348 Mew 349 Malian 350 Muhadi 351 Ngenget 352 Naih 353 Naelnaelpis 354 Oyek 355 Onih 356 Onek 357 Paimin 358 Pisah 359 Rudin 360 Runah 361 Reli/Yik 362 Sanji/Sanyik 363 Saw 364 Seperni 365 Surik 366 Siti Hajar 367 Seniu Tendos

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 368 Tigar 369 Timan 370 Widi 371 Wita 372 Wisa 373 Wanding 374 Yani 375 Youche 376 Yumi 377 Yunusli 378 Bukit Layang village Jene 379 Loa Lempung village Ateng 380 Caca 381 Matias 382 Muin 383 Tukuk 384 Plus 385 Idiu 386 Beson 387 Kibin 388 Banciu 389 Siman 390 Jeliman 391 Yustian 392 Siwin 393 Pir 394 Kelekat village Jepun 395 Loa Lempung village Bagong 396 Kelekat village Cinal 397 Nyanti 398 Elham 399 Abd Patah 400 Enjung 401 Sukanto/Suhanto 402 Suming/Sunding 403 Napoi/Pai 404 Nudin 405 Bahu 406 Bacok 407 Cugat 408 Lowis

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 409 Piep/Wengkon 410 Sirajudin/Sira 411 Yurin 412 H.Ngoweng 413 Hadri 414 Nyonya 415 Wanih 416 Juung/Junug 417 Mayon 418 Tinggi 419 Cayut 420 Butun 421 Nisen 422 Kumer/Kuner 423 Piwil 424 Cudil 425 Into 426 Cawal 427 Edo Crystian 428 Kiwong 429 Muhammat 430 Rahmat 431 Wajar/Wajir 432 Sutan 433 Asen Lepek 434 Are Danuri 435 Kihok 436 Iceh 437 Liseh 438 Porot 439 Rudi 440 Rusli 441 Ardiansyah 442 Heri Nunung 443 Junal 444 Jamli 445 Marta 446 Mauni/Laboh 447 Nipoi/Nipon 448 Raciu 449 Siko/Sika

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 450 Wahyudin 451 En 452 Sudih 453 Sungkin 454 Imansyah 455 Mursidi 456 Sien 457 Darman 458 Wisiu 459 Hin 460 Jimransyah 461 Arnodus Lulu 462 Zainudin 463 Aliansyah/Len 464 Muliadi/Len 465 Iyan/Len 466 Susi/Len 467 Diman 468 Beng 469 Dik 470 Haniah 471 Nalianah 472 Orin 473 Sundih(L/Pulut) 474 Midiansyah/yan 475 Nyunison 476 Muai village Sahrul 477 Ohong 478 Rinto 479 Andik 480 Senah 481 Sela 482 Tompek 483 Rosi D 484 Asran 485 Empek 486 Peng 487 Ta 488 Au 489 Tika 490 Apon

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 491 Ateu 492 Rindo 493 Dilah 494 Totoi 495 Safii/Ulus 496 Andri/Ojek 497 Hendra 498 Sabarudin 499 Sutik 500 Ak 501 Idul 502 bahar 503 Akok 504 Salmah 505 Dian 506 Peng 507 Sri 508 Herman 509 Diot 510 Jehri 511 Jehri 512 Suhur 4.00 513 Zaini 6.00 514 Mulyanto 6.00 515 Sulik 10.00 516 Jafri/Ainah 2.00 517 Run 2.00 518 Koan 2.00 519 Besen/Animah 2.00 520 Senang 0.63 521 Supiman 522 Muin 523 Jukman 524 Deka 525 Jukman/Rina 526 Sitoi 527 Jujan 528 Ardani/Ateng 529 Ali 5.00 530 Besen 4.00 531 Thamrin 4.50

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 532 Sulis 17.00 533 Herman 7.00 534 Hambau village Jasri 16.00 2007 535 Sabran 536 Idil 537 Halidi 538 Okon 539 Ibur 540 Canew 541 Pendi 542 Heri 543 Ajeni 544 Aminudin 545 Herdi 546 Yatman 547 Kusrin 548 Irwan 549 Padil 550 Rizki 551 Muai village Halidi 13.30 552 La'Ali 4.80 553 Kalisi 1.20 554 Kelekat village Jumriansyah Kape 1.10 555 Muai village Kaliansyah,Polmi,Piwan 19.10 2008 556 Imransyah 24.20 557 Antonius Riong 7.994 558 Abd.Mutalib 4.00 2009 559 Suhendro/Bagong 5.10 560 Kelekat village Matias Lahang 6.60 2010 561 Bukit Layang village Irwan B 2.80 562 Kelekat village Naftali Mering 1.20 563 Muai village Abdullah/Adul 1.85 2011 564 Apon/Nila 2.10 565 Bian 1.10 566 Elia/Amt Yong 1.65 567 Masitah/Cini(Alm) 2.50 568 Jonansyah/En 1.40 569 Sainah/Ene 1.70 570 Hendrik 0.70 571 Rusli 1.30 572 Safrudin 4.75

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 573 Rahmad 1.20 574 Samsi/Pikol 1.90 575 Oma Sukma/Oma 2.00 576 Ardiansyah/Ohong/Ubay 3.10 577 Norhan 1.50 578 Hanafi/Nafi 1.90 579 Abdul Mutalib/ 0.60 580 Syahrial/Yusup 6.00 581 Sahril/Syahril 1.10 582 Salahudin 6.00 583 Samsudin/Adin 1.90 584 M.Jais 8.40 585 Sufianto 2.00 586 Sujin/Sunjin 4.00 587 Ubay 3.10 588 Janiah/Ujang/Njang 2.15 589 Ardi/Adi 1.70 590 Arbani/Bani 2.60 591 Bukran 1.00 592 Leo Cahyo/Cahyo 6.50 593 Cakul 3.80 594 Rusli C./Celoy 1.90 595 Frans Nur Dani/Dani 2.50 596 Dhani 1.60 597 Darman Landi/Landi 4.70 598 Rafii 2.00 599 Ahmad Rifai/Rifai 2.00 600 M.Rodi 2.50 601 Rukayah 2.00 602 Tohriyadi 2.40 Umar Bin Nadus Boro/Umar 2.00 603 Nadus 604 Abd. Rahman 1.90 605 Affandi 2.10 606 Hatmah 1.70 607 Ahmad/Umuk 2.13 608 Arifin/Laharuni 1.90 609 Aser/Jon Aser 3.40 610 Bahar Nor/Nor Aini 1.90 611 HJ.Mulyati/Barak (Alm) 3.40 612 Darmansyah/Toh Pik 5.70

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 613 Bahauddin 1.70 614 Murdiansyah 6.50 615 Gembira 9.40 616 Saripudin/Guru Udin/Udin 1.00 617 Hadi 2.00 618 Irus/Ria 2.00 619 Itok 2.00 620 A.Rafandy/Januri 2.90 621 Rianto/Jerapah 2.00 622 Joyo Lukito 2.00 623 Juri/Wandan 1.90 624 Kalut Ulana 5.90 625 Kiding 2.00 626 La Dehe 2.90 627 M.Hariyanto Abd. 16.60 628 Mujianto 2.00 629 Muslihuddin/Musli 1.90 630 Mustaqim 2.00 631 Nanang Fauzi 1.70 632 Otoh A 2.20 633 Paulus A/Lejab 2.00 634 Paulus B/Paulus Lejab 1.80 635 Samsuri/Payung 2.00 636 Syaifuddin/Pudin 2.00 637 Saini Tuk 2.00 638 Salok 7.30 639 Sugianto 2.10 640 Syahrudin/Beleu 2.00 641 Fatmawati/Uci Lan 1.20 642 Yusuf/Usup Cinun/Yusuf 2.00 643 Yun(Alm)/Aida 1.90 644 Agus Martinus Arah/Agus Ara 1.80 645 Muai village Hepni 5.50 2013 646 Abar 1.00 647 Mohamad Thamrin 2.00 648 Ainah 2.00 649 Ani 2.00 650 Asrani/kuas 4.30 651 Majau 2.50 652 Maya Lestari 1.30 653 Norhan 1.55

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 654 Sabran 2.50 655 Sabran 3.90 656 Saiful 7.40 657 Salok 1.64 658 Sanariah 5.00 659 Sopian 2.50 660 Umar Bin Nadus Boro 5.00 661 Baharuddin 2.50 662 Ali A 0.29 663 Yusni 2.50 664 Syahruddin Jaya 4.20 665 Norma 2.40 666 Muksin 9.20 667 Hamsani 2.00 668 Puji Hartono 2.70 669 Ridwan 1.00 670 Muai village Diryono 2.80 2014 671 Wahyudin 1.00 Wahidu (Ahli Waris 2.50 672 Alm.Arbain) 673 Iwan Ridwan 2.60 674 Ali Husni 1.70 675 Mukransyah 4.15 676 Sanariah 4.23 677 Hatmah 7.23 678 Muai village Umar Nadus Boro 5.29 2016 679 Cakul 4.96

Lestari estate 1 Longseng vilage MAJ - 1995 2 Mr. Jefferies 3 Tining/Mashur 1999 4 Jastan 5 Lukman/Bit 6 Nain 7 Asran Long Beleh village 8 Syahruddin 9 Aini 10 Pahrul/Yul 11 Anang Taher 12 Rusli

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Year of Verification Previous land owner (person Location (estate name and Total areas Year of land released and their No name / group name / tradition- Remarks or the result of interview Plan Actual or village/sub-village name) (ha) evidences al group name / etc) 13 Syainuddin 14 Kadir/Sabri 15 Arpan 16 Mahjur 17 Ilik/Armiansyah 18 Sukran 19 Ardiansyah 20 Bram 21 Nusi 22 Muhadir 23 Miter 24 Rustam 25 Cuwol/Johari 26 Masrani 27 Husni 28 Abdul Muis 29 Muhlis 30 Murdani 31 Darlani 32 Hekmi 33 Maskur 34 Subhi 35 Badrun 36 Hairul 37 Halid 38 Yunus/Idris 39 Dulgani/Sawal 40 Ahmad 41 Abdul Manan 42 Maceo 43 Abdul kadir 44 Syaiful Anwar 45 Ahmad/Neo 46 Abdul Rahman 47 Asmuransyah 48 Long Beleh village Hadri Jepang - 2000 49 Long Beleh Haloq village H. Joni Kerbau 10.50 2003 50 51 52 Long Beleh Modang village Hanafi 185.57 2012

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