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SAVONNERIE TROPICALE HUILERIE MELVILLE TOAMASINA,

Auditor Name: Ingrid Ayub Audit Date : December 6-9 th., 2016

MQ III IBD Revisão 30.04.2013 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_En - Relatório RSPO P & C

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CONTENTS

1. Scope of the Certification Audit 1.1 Normative references 1.2 Company and Contact Details 1.3 RSPO Membership Details 1.4 Audit type 1.5 Location of the Palm Oil Mill 1.6 Palm Oil Mill Output and Approximate Tonnages Certified 1.7 General Description of Supply Base 1.7.1 Location of the Supply Base 1.7.2 Statistics of the Supply Base and Estimated Tonnes of FFB/year 1.7.3 Biodiversity (Conservation & HCV Area for the respective Supply Bases) 1.7.4 Total Certified Area 1.7.5 Calculation of the Number of Production Units (N) to Sample for the Mill 1.7.6 Calculation of the number of subcontractors to be sampled 1.8 Progress of associated Smallholders or Out-growers towards compliance 1.9 Location Map for this Certification Unit

2. Partial Certification 2.1 Management Organization 2.2 Time-bound plan 2.3 Progress made on the time-bound plan 2.4 Non-conformities

3. Audit Process 3.1 IBD - The Certification Body 3.2 Audit Team 3.3 Audit Methodology 3.3.1 Audit Agenda 3.3.2 List of stakeholders consulted prior to and during the audit. 3.3.3 Outline of how stakeholder consultation was managed. 3.3.4 Issues that arose during stakeholder consultation and company responses.

4. Audit Findings 4.1 Summary of findings 4.2 Non conformity register 4.2.1 Verification of previous assessment non-compliances 4.2.2 New non-compliances raised at this audit 4.2.3 Observations 4.3 Lead Auditor Recommendations for the RSPO Principles & Criteria certification. 4.4 Comments for next audit.

5. Formal signing of audit findings 5.1 Acknowledgment of internal responsibility by the Client 5.2 Signing by the Lead Auditor.

6. Major non-compliances follow-up actions

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1. SCOPE OF THE CERTIFICATION AUDIT 1.1 Normative references The Palm Oil Mill and the supply base was audited against the following documents: RSPO International Principles and Criteria (April, 2013 version) National Interpretation (approved version XX/20XX) RSPO Supply Chain Certification (November, 2014 version) New Planting Procedures (November, 2015 version) RSPO Rules on Market Communications and Claims (June, 2015 version) 1.2 Company and Contact Details Company name SAVONNERIE TROPICALE HUILERIE MELVILLE Villa Nirina, parcelled 32/12 Tanamakoa. Toamasina, Madagascar. Business address

Scope Production of palm oil and palm kernel. Products Palm Oil and Palm Kernel. Contact person Ramaroson Danick Telephone +261342098175 E-mail [email protected] Web site www.savonnerie-tropicale.mg Other certifications held Organic 1.3 RSPO Membership Details RSPO membership number 1-0149-14-000-00 Parent company as Does not apply applicable 1.4 Audit type Date of previous audit December 7-10, 2016 Date of this audit December 6 -9, 2016 Main or ASA (1 to 4) ASA 2 Date of next surveillance January or February 2018. The mill does not operate from july to mid audit December each year 1.5 Location of the Palm Oil Mill Palm Oil Mill (POM) Mill Capacity GPS Reference Location Address Name MT/Hour Longitude Latitude Huilerie Melville Melville (Commune Fanandrana) 5 S: E: 18°14.006 049° 17.542 1.6 Palm Oil Mill Output and Approximate Tonnages Certified The 12 month output is the average over any 12 month period and the actual production for the 12 months from the date of certification will be included in the annual summary. These figures exclude any output product from non-certified suppliers. For the 12 month period ending July 2016 the mill received [5.502] mt of FFB.  The estimate for the last 12 months is applicable to Annual Surveillance Audits and is the Projection for the next 12 months from the previous audit.  The actual production for the last 12 months is the audited quantity since the last audit.  The projection for the next 12 months is given by the company. FFB received and processed by the mill for the 12 months prior to Mt RSPO Certified 5.502 this audit: FFB: Mt Conventional 0.00 FFB: Estimate for last 12 Months (MT) Actual Production for last 12 months Projection for next 12 Months (MT) [State of IP or MB] (ASA audits). (MT) [IP] [IP] CPO PK CPO PK CPO PK

860 497 1.060 575,9 1.220 650 Notes: The mill only operates from mid December to July of the next year due to crop seasonality. 1.7 General Description of Supply Base All FFB entering the mill comes from the own company certified plantation comprising of 1.226,53 ha of planted oil palms. The supply base for the mill is conformed by 5 farms/areas/zones located at two communes: Fanandrana commune (areas/farms I and II) and Amboditandroho commune (areas/farms III, IV and IV). The farms are adjacent as could be seen on the map placed on section 1.9 of this report.

The current and only mill owned by Savonnerie Tropicale S.A., the palm oil plantation and land on conservation were legally acquired by the company in 1997 when named as the only awardee of the Somapalm Agroindustrial Complex, even though Savonnerie Tropicale S.A. has been operating in the land since 1991. The Somapalm Agroindustrial Complex was previously owned by the Madagascar government and the palm oil plantation was established in the 1960 s. Approximately 1100 ha were planted prior to 1995 having palms with ages from 20 to 40 years old. A replanting program started in 2011. The

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Doc_2_2_30_1_3_En production yield in 2015 was 3. 4 mt /ha.

Within the boundaries of the Savonnerie Tropicale S.A. property there are 56 villages and 2000 inhabitants. Most of the workers at the mill and plantation are residents of the villages settled within the property. Besides the palm oil plantation and villages there are 780 ha under conservation and 227,06 ha that were identified as HCV 6 in 2014.

During the year 2016, some managerial changes occurred at Savonnerie Tropicale Huilerie Melville, a person to be in charge of health and safety issues was contracted, a new department for sustainable development was established and Gaetan ETANCELIN , former development manager ,was raised to the manager position. On the other side, the responsible person on human resources resigned the position on may 2016 and the vacancy has not been filled and the former mill manager left the position in june. Consequently, some disorganization at the human resources department was detected during the audit.

A major change is expected for the coming years, regarding the supply base, as Savonnerie Tropicale Huilerie Melville is working on a project to develop new plantings areas by smallholder that will be group on a cooperative in 2018. The first plantings are targeted for the end of 2017 and the project is co-financed by GIZ (german cooperation). In that context, externally grown fruit is expected to come into the mill by 2019.

1.7.1 Location of the Supply Base Oil Palm Plantation (OPP) GPS Reference Location Address Name Longitude Latitude Area I and II Commune Fanandrana 18°23.357’S 49°29.257’E Area III, IV and V Note: For this report the words área, farm and zone are equivalent. Commune Amboditandroho 18°16'22.51"S 49°20'33.50"E 1.7.2 Statistics of the Supply Base and Estimated Tonnes of FFB produced per year Name Area of Oil Palm (Ha) Estimated Planting Cycle Total Production Tonnes Years (Years) FFB/Yr Area 1 299,34 299,34 1.410 1969-1990 40 Area 2 296,50 270,00 1.294 1969-2012 40 Area 3 260,45 243,96 962 1971-2013 40 Area 4 176,70 131,90 1.382 1970-2012 40 Area 5 193,54 142,12 1.288 1970-2013 40 TOTAL 1.226,53 1.087,32 6.336 - - 1.7.3 Biodiversity (Total Conservation & HCV Area for the respective Supply Bases) Oil Palm Plantation Biodiversity.(Total Conservation & HCV Area) Hectares. Name Conservation HCV Comments Savonnerie Tropicale S.A. /Ivondro Palm Oil 780,00 227,06 The HCV area corresponds to 227,06 ha of Plantation. State. Madagascar (Vavazahana sand HCV 6 that includes sacred sites, sacred and Anjavidy) mountains, cementeries and plantation forest as determined by the High Conservation Value Inicial Assessment done in January 2014. Mahalanga forest, was identified as a HCV 6. The 780 ha on conservation corresponds to Vavazahana sand and Anjavidy area. TOTAL 780,00 227,06 -

1.7.4 Total Certified Area (Total Certified Area corresponds to the sum of total Area of Oil Palm 2233,59 and the total Conservation Area) 1.7.5 Calculation of the Number of Production Units (N) to Sample for the Mill N = 0.8√Y, where “Y” is the number of units, with the result always to be rounded “up” to the next whole integer. Where only a sample of the supply base is assessed, units not previously assessed, or assessed earlier in the certification program, are to be preferred over those more recently assessed. For the Mill, how many units make up the production base? Owned estates (Y) N = 0.8√Y Smallholders (Z) N = 0.8√Z 5 0.8√5=1.78 Eq. 2 0 0 Explanation as to the selection of estates sampled There are two areas / farms at the Fanandrana commune (areas I and II) and three areas / farms at the Amboditandroho commune (areas III, IV and V). At least one area/farm on each commune was selected to be visited during the current audit, MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 3 de 38

Doc_2_2_30_1_3_En and areas / farms not visited during the ASA 1 audit were selected to be visited during the current ASA 2 audit. Between the preselected areas/farms, the final areas/farms to be visited were selected taking into consideration the activities carried on during the visit day (areas / farms and sites in which more activities were carried out were selected). As a result the area/farm I was selected for the Fanandrana commune and the area / farm III was selected for the Amboditandroho commune. The areas/farms visited during the past ASA 1 audit were farms II and IV.

The table below shows the oil palm plantations that were included in this audit, with the operations reviewed in the field, the number of sample sites within the plantation and the number of worker interviews. Comments are added as applicable. Oil palm plantation. Operation No of No of Comments. sample Intervie sites ws Area/farm I Cleaning of drainages, abattage 2 8 Full use of PPE was (erradication of palms) and observed, replanting availability of Area/farm III Harvesting and collection of fallen 3 15 drinking water and fruit latrines with water and soap was verified on the field. Strong focus on labour law and health and safety issues during interviews. 1.7.6 Calculation of the Number of Sub Contractors to be sampled. N = 0.8√Y, where “Y” is the number of contractors, with the result always to be rounded “up” to the next whole integer. Where only a sample of the sub-contractors not previously assessed, or assessed earlier in the certification program, are to be preferred over those more recently assessed. The table below shows the number of approved sub-contractors who may be contracted to be directly employed in the work of the certification unit. The number of sub-contractors actually contracted at the time of the audit is used to calculate the sample. Number of sub-contractors. Mill and workshops Farms Approved: 4 Approved: 0 On site during audit: Y 0 On site during audit: N/A Y Number to audit: = 0 Number to audit: = N/A 0.8√Y 0.8√Y Names Activity Audit Names Activity Audit ed ed Mr Ettiene Transportation of NO N/A N/A N/A CPO to the port (usually once a month) Materauto S.A. Mechanical NO N/A N/A N/A service to electricity generator Mr Barijaona. Quality Chain of Custody NO N/A N/A N/A service. Cabinet Maritime d and security of Expertise et de Surveillance. CPO loading to ships (once a month Groupe ADONIS. Company YES N/A N/A N/A Environnement S.A. engaged in the collection, treatment and recycling of industrial waste in Madagascar, island and Reunion island Explanation as to the selection of sub-contractors sampled:

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Eventhough no sub contractors were present at the company during the audit, the local office of Groupe ADONIS was visited and the regional director was interviewed. The Groupe ADONIS office is located less than 8 km from Huilerie Melville and provides treatment to part of the mill waste. Environmental permits and other legal requirements (Ex: payment to the CNAPS) were reviewed and found to be in order. 1.8 Progress of associated Smallholders or Out-growers towards Compliance with relevant Standards - should be in accordance to the 3 year implementation plan N/A. The totality of FFB processed come from the Savonnerie Tropicale Huilerie Melville own farms. 1.9 Location Map for this Certification Unit Note: Individual maps of the group members are available from the co-operatives but it is not practical to reproduce them here. Each area of oil palm is individually managed as an integral part of a farm holding and the adjacent crops are all agricultural.

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2. PARTIAL CERTIFICATION The rules for partial certification allow organizations that have a majority holding in and / or management control of more than one autonomous company growing oil palm to certify individual management units and / or subsidiary companies subject to certain rules. 2.1 Management Organization Item Criteria (Yes/No Description (if applicable) N/A. There is only one mill owned by Savonnerie Is the operation conducting a partial 2.1.1 NO Tropicale S.A. The RSPO membership is under certification? Savonnerie Tropicale S.A. There is only one mill owned by Savonnerie Is any company of the group, member of 2.2.2 N/A Tropicale S.A. The RSPO membership is under the RSPO? Which one? Savonnerie Tropicale S.A. Is there a clear relationship between the There is only one mill owned by Savonnerie companies, where one company has the 2.2.3 N/A Tropicale S.A. The RSPO membership is under majority ownership or the management control of others? Savonnerie Tropicale S.A. There is only one mill owned by Savonnerie Is there a clear and achievable time- 2.2.4 N/A Tropicale S.A. The RSPO membership is under bound plan prepared and in place? Savonnerie Tropicale S.A. There is only one mill owned by Savonnerie 2.2.5 Does the plan include all subsidiaries? N/A Tropicale S.A. The RSPO membership is under Savonnerie Tropicale S.A. 2.2 Time-bound plan Description: N/A

Initial (mention sites and years proposed for the certification): N/A

Alterations: N/A

Justifications: N/A

Acquisitions: N/A

2.3 Progress made on the time-bound plan

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Please report upon adherence or deviation: N/A

2.4 Non-compliances on the partial certification rules N/A 3. AUDIT PROCESS 3.1 IBD - The Certification Body IBD takes pride in being the largest certifier in Latin America and the only Brazilian certifier of organic products with accreditation through IFOAM (international market), ISO Guide 65 (European market regulation CE 889/07), Demeter (international market), USDA/NOP (North-American market), COR (Canadian market) and INMETRO/MAPA (Brazilian market), making its certificate global.

Located in Botucatu-SP, Brazil, IBD has been in operation since 1992. Initially focused exclusively on the certification of organic product, after 2004, IBD began including certification services in the social-environmental area through the EcoSocial, Integra, RSPO and UEBT (Union for Ethical BioTrade) programs. Today, IBD certifies over 5,000 producers, covering an area of approximately 520 thousand hectares in cultivation and 3 million hectares under wild harvest management, throughout 16 countries.

For more information regarding IBD Certificações, access www.ibd.com.br. RSPO Membership No: 8-0090-08- 000-00. RSPO accredited by ASI on November 4th, 2014, worldwide (accreditation code RSPO-ACC-020).

3.2 Audit Team Lead auditor Ingrid Ayub Audit team Regis solofonirina and Kraidi Awossi 3.3 Audit Methodology 3.3.1 Audit Agenda Date Time Location Program Auditor(s) 06/12/ 9:005 Mill and farms office Opening meeting I.A., R.S., K.A. 2016 a.m. Observation visit to the mill following the process flow from weighing bridge until the 9:30 expedition area. The mill was under cleaning 06/12/ a.m.- and last minute repairs as it was not operating Mill I.A., R.S., K.A. 2016 12:00 since mid july and on December 7 th it was m. going to be restarted. Visit to the newly build and not inaugurated mills efluent treatment ponds Documental review (initiation): R.S. (principles 1 and 6 and 06/12/ 1:p.m.- criterion 2.2) Mill and farms office I.A., R.S., K.A. 2016 5 p.m. I.A. (principles 2, 3, 5, 7 and 8 plus SCC) K.A. (principle 4)

Field visit to the plantations and conservation areas. Interviews to workers. Meeting with stakeholders and visit to some local institutions in the visited areas. 8:00 07/12/ a.m.- R.S. : from 11:15 to 2:45 Individual meeting Areas/Farms I and III I.A., R.S., K.A. 2016 3:00 with communities who lend lands inside the P.M. Savonnerie Tropicale property on the villages of Nosimbero and Analandrafia and Interview of the traditional leader of Analandrafia: sacred sites, land lending, collaboration of the “Tangalamena” with the company 07/12/ 3:00- 5:00 Mill and farms office Continuation of documentary review. I.A., R.S., K.A. 2016 p.m. Interviews with key stakeholders : deputy 8:30 mayors, president of municipality council, a.m.- director of MRF school, Tamatave 3:15 Different locations nearby or University students, Savonnerie Tropicale 08/12/ p.m._ within Savonnerie Tropicale gender committee member and others. R.S. _____ 2016 Huilery Melville land ______3:15-

5:00 From 3:15 -5:00 p.m. : Documentary p.m. review

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8/12/ 8:00 – Mainly documentary review with short 5:00 Mill and mill and farm office visits to specific areas to verify aspects I.A., K.A. 2016 p.m. on ground. All three auditors were mainly reviewing documentation but performed some 8:30 different activities in between: 09/12/20 a.m.- Mill and farm office / Farm I Interview with Groupe ADONIS I.A., R.S., K.A. 2:00 / Groupe ADONIS office 16 Environnement S.A. regional director at p.m. Groupe ADONIS office (I.A.) Visit to Farm I (K.A.) 09/12/ 2:00- 3:00 Mill and farms office Preparation on the closing meeting I.A., R.S., K.A 2016 p.m. 3:00- 09/12/2 4:00 Mill and farms office Closing meeting I.A., R.S., K.A. 016 p.m. 3.3.2 List of stakeholders consulted prior to and during the audit. Name Category COMMUNITY MEMBERS MISY and his wife (TOANDRO Hélène Resident at Nosimbero, inside Melville proprerty Resident at parcel 23rd Analandrafia, head of family living in LUCIEN Savonnerie Tropicale property Traditional leader of Analandrafia (one of the villages inside BOTO Robert the Savonnerie Tropicale property OLIVIER Mahasoa community resident . ZAFIMALO Rémi 1st Deputy Mayor of Fanandrana Commune SOLO Emmanuel 2nd Deputy Mayor of Fanandrana Commune President of the Municipality Council of Fanandrana IEFATRA Daniel Commune ORGANIZATION REPRESENTATIVES (other than community organizations CNaPS employees on inspection during the first audit day at Nomenjanahary Izella Elmilson Edwigia Id 800 578 Savonnerie Tropicale, Huilerie de Melville

CNaPS employees on inspection during the first audit day at Mbahizafisambo Hortensia Alice Gabrielle Id 670 967 Savonnerie Tropicale, Huilerie de Melville

RAZAFIMAHEFA Georges Aimé, Personnel delegate from syndicate SEMPIMITO (Sendikan’ny Id 3251 Mpiasa Mivondrona eto Toamasina) ANDRIANA Andriamalazaray Coordinatrice Regional Croix Rouge Malagasy LELAKA Roella Etudiant ISSED, Université de Tamatave Directeur of MFR (Maison Familiale Rurale)/Agricultural HASA Noelson Victor Training Chef de Service Regional de l Ecologie de la Direction Mario Rakotovoany Régionale de l Environnement, de la Ecologie et des Forets Roderic MAHASOA Madagascar Fauna and Flora Group (herpetologist) SAVONNERIE TROPICALE FIELD WORKERS AND SOME MILL WORKERS Code 3095 Security Guard. Male Code 1843 Loose/fallen fruit collector. E- 14 section. Female Code 5504 Loose /fallen fruit collector E- 14 section. Female Code 1840 Loose /fallen fruit collector E- 14 section. Female Code 1219 Loose /fallen fruit collector E- 14 section. Female Code 1833 Chef D Equipe. E- 14 section, male Code 1161 Harvester. E- 14 section. Male Code 1077 Harvester. E-14 section. Male Code 3508 Chef d Equipe. Section C-1 Code 1164 Harvester. Section C-2. Male Code 1030 Harvester. Section C-2. Male Code 1763 Harvester. Section C-2. Male Code 3514 Harvester. Section C-2. Male Code 1998 Harvester. Section C-2. Male Code 3537 Harvester. Male Code 3330 FFB Réceptionniste. Scale at mill. Female Code 3323 FFB Réceptionniste. Scale at mill.Female Code 5354 Agent abattage (destruction of old palms. Male Code 5563 Nursery and replanting worker.Male Code 5428 Nursery and replanting worker. Male

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Chief of civil works. Road maintaining and drainage Code 3551 channels. Male. Code 3352 Gender Committee.Female Code 3451 Chef de Zone (agricultural production. Male Code 3340 Chef de Zone (agricultural production). Male Code 3543 Hygiene and Safety at Work Committee. Female Code 3502 Chef de Zone. Security department. Male Code 3335 Chef logistique (agricultural production) Code 3103 Laboratory chef (oil quality) Environment. Laboratory worker in charge of the functioning Code 3566 of the new effluents treatment plant MANAGERIAL AND ADMINISTRATIVE WORKERS RAKOTOMAMONJY Randrianina Elise Code 3580 Human Resources Responsible ( Direction Assistant RAMAROSON Danick Operations director ETANCILLIN Gaëtan Administrative Director SOANIRINA Léa Brigitte Social relations Code 6008 ODETTE Nattacha Technical Control Department (environment) RABE Flavian Head of the Technical Control Department ANDRRIAMANALINARIVO Solofohery Head of the Research and Development Department JOAQUIN Head of Services in Civil Engineering RATSIMBAZAGY Lovamanantsoa Health and Safety Responsible SEA ANDRO Honorine Head of the Plant Protection section. George AIMÉ Mill responsible (Chef d Usine) BARIARISON Florentina Secretary RANDRIAMAMPIANINA Charlie Chef Observateur (chief observer at field and scale) SERVICE PROVIDERS ZO RABETTRANO / Directeur Regional. Groupe ADONIS Collection, treatment and recycling of industrial waste in Environnement S.A. Madagascar, Mauritius island and Reunion island 3.3.3 Outline of how stakeholders consultation was managed. Community members The community members including the traditional leaders, deputy majors and municipality president were interviewed in their communities of residence by the auditor in charge of principles 1 and 6 and criterion 2.2. The traditional leaders and residents were interviewed individually as other community members were interviewed on group.

Organization Representatives CNaPS employees, Croix Rouge Malagasy (Red Cross) personnel, Tamatave University students, Direction Régionale de l Environnement, de la Ecologie et des Forets and Madagascar Fauna and Flora Group personnel were all interviewed at the Savonnerie Tropicale Huilerie Melville property taking advantage of their presence when they were performing different tasks, inspections or research and interviews were performed by individual auditors. The director of the Maison Familiale Rurale training school was interviewed by the three auditors when he attended the requested appointment at the mill /farm office. The syndicate delegate, a mill worker, was interviewed at the mill.

Savonnerie Tropicale Huilerie Melville Field Workers and Some Mill Workers The personnel listed above was interviewed from December 6 to December 9, some of them every day, some of them just some days. They were interviewed by one to three auditors during the audit term and several aspects regarding Huilerie Melville operation were addressed.

Managerial and Administrative Workers The managerial and administrative personnel was interviewed from December 6 to December 9, some of them every day, some of them just some days. They were interviewed by one to three auditors during the audit term and several aspects regarding Huilerie Melville operation were addressed.

Service providers 1 of 4 approved service providers was interviewed during the present audit eventhough none of the four were present at the company during the audit time. The service provider Groupe ADONIS Environnement S.A .representative was interviewed at the service provider office located just 5 minutes driving from the Savonnerie Tropicale Huilerie Melville office. Only one auditor attended to the appointement.

The opinion of interviewed stakeholders regarding different RSPO criteria and indicators addressing environmental, social and economic issues as well as contracts, labour law, payments and permits was collected.

3.3.4 Issues that arose during stakeholder consultation and company responses.

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Subject raised Company response and Audit team findings proposed action to be taken. Community members Good communication and Good communication and respectful manifested that there is good respectful relationships between relationships between the company communication and respectful the company and communities was and communities was confirmed by the relationship between the confirmed by the company audit team. company and communities. representatives. The company personnel indicated that the requirements to become permanent workers are explained Harvest workers does not know It was not possible to go deeper into every year during the annual the mechanism or requirements this issue, with human resources meeting where workers, to comply to become permanent personnel, during this audit. It is administrative workers and workers instead of remaining as recommended to follow up this issue in managers attends, but they are temporary workers. going to work on the issue to the RSPO ASA 3 audit. ensure everybody understands the mechanism.

4. AUDIT FINDINGS 4.1 Summary of findings. Principle 1: Commitment to Transparency. Criterion 1.1: Oil Palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO criteria, in appropriate languages and forms to allow for effective participation decision making. Summary of the findings for 1.1: Findings: Comments: Compliance Savonnerie Tropicale S.A. provides sufficient and There is notebook based systems which connect YES appropriate information regarding environmental, closely the Savonnerie Tropicale to theirs social and legal aspects of its operation to stakeholders. Indeed, at least, 05 different stakeholders in order for them to participate on notebooks are used to inform and capture decision making about aspects that affects or information from stakeholders: the “cahier des interest them. visiteurs”(visitors notebook) in the main gate There are records of request of information and its where all visitors are recorded and write the respective answers. reasons of visit and the types of information or data needed, and four(04) others notebooks recording all complains and information from the four (04)key stakeholders as the municipality(communes), the chief of Fokontany(the lower administrative level in Madagascar) and its chiefs of zone (administrative level under the Fokontany on the city/village) and the traditional leaders(called “Tangalamena”). Examples: _ on February 24th, 2016, two zebus belonging to the traditional leader Mr. Velolamba are reported by the security guard seen inside the replanting area in parcel E6(replanting area is forbidden for zebus) and this respected old man recognized his fault and wrote his excuses linked to this incident in the “tangalamena” notebook. _ on July 14th, 2016, the deputy Mayor of Amboditandroroho commune wrote in the commune notebook the municipality thanks to Melville Savonnerie Tropicale for giving them supports in providing 02 prizes, 01 soccer ball and 04 boxes of perfumed soap for the Malagasy Independence Day (June 26th) and submitted their request of the society barge to transport the heavy equipment needed to rehabilitate the municipality soccer field. Criterion 1.2: Management documents are publicly available except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes. Summary of the findings for 1.2: Findings: Comments: Compliance

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Through written request by the interested person, The interested person or stakeholders can access YES the company provides or allows the consultation of to the documents by two ways: in the company such documents. office, through a written request by the interested person, the company provides or allows the consultation of such documents but the notebooks recording the interactions between the company and the third parties (commune, chiefs of Fokontany, chiefs of “carrreau”, “traditional leaders,…) are publicly available all the times. Available documents for consultations includes, between others, legal documents showing ownership, OSHA risks assessment, reports of health and safety Committee, Environmental and social impacts assessments(EIA,SIA), High Conservation Values assessment, pollution prevention and reduction plan, public summary of certification assessment reports(ECOCERT,BIOSUISSE,RSPO), negotiation procedure, actions plan improvement, written procedure for complaints and grievances, program D for investment 2014- 2017, Human Rights Policy,… In the Savonnerie Tropicale office, the authorisation to provide the documents relies on the Administrative Manager. Criterion 1.3 Growers and millers commit to ethical conduct in all business operations and transactions. Summary of the findings for 1.3: Findings: Comments: Compliance The Savonnerie Tropicale S.A. has a written code of The Ethical Code appeals to respect human dignity, YES ethics and integrity “Code D”Ethiquet et D” environment respect, rituals and cultural respect, Integrité” written in french and malagasy and act in conformity with biologic agriculture, work displayed at the entrance of the plantation and mill with transparency in every company activity. office. This Code of ethics applies to all personnel of Savonnerie Tropicale and its contractors from the The Savonnerie Tropicale S.A. also is a signatee of highest to bottom levels; it is visible through the the Engagement D Integrité de Professionnels du Savonnerie Tropicale infrastructure and is well Secteur Industriel that focus against corruption. known by interviewed employees. Signed in 26/06/2012.

Principle 2: Compliance with applicable laws and regulations. Criterion 2.1: There is compliance with all applicable local, national and ratified international laws and regulations Summary of the findings for 2.1: Findings: Comments: Compliance Savonnerie Tropicale S.A., in general, complies with All employees (permanent and temporary) are YES / NO the relevant Malagasy legislation as it was evidence affiliated to the CNaPS and the payment to CNaPS through interviews, documental review, and is up to date. observation. Certification : Situation Fiscale –Annee 2016. N. 2000005166. Savonnerie Tropicale S.A. N0 A mechanism for ensuring compliance with the law is 0058831 / DGI-C. Up to date. implemented as well as a system for tracking Multirisques Dommages (multi risk insurance). changes on the law. Periode de validité de l”avenant : 01/01/2016 – 31/12/2017. Facture N. 0076/DAA-2016. However, two specific situations do not comply with the Malagasy law and a non conformity was raised against criterion 2.1.1 : 1- The higher content of oils and fats downstream the Ivondro river compared with upstream waters from the discharging POME point (related with criterion 4.4.3 and 5.6.1.).are out of accepted parameters. Corrective actions were already presented as a 6 compartment lagoons was build and will MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 11 de 38

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be inaugurated on december 10 th. 2016. Oils are going to be removed manually from the 1 st and 2 nd. compartments as indicated in pertinent procedures. 2- The minimum wage was not updated according to the government decret N. 2016-232 from april 5 th. 2016 resulting in salaries been lower from what the law establishes (related with criterion 6.5.1). Criterion 2.2: The right to use the land can be demonstrated and is not legitimately contested by local communities with demonstrable rights Summary of the findings for 2.2: Findings: Comments: Compliance Legal ownership of the land was demonstrated The current and only mill owned by Savonnerie YES through public deeds. Tropicale S.A., the palm oil plantation and the conservation land were acquired by the company During field visits legal boundaries were found in 1997 when named as the only awardee of the demarcated and interviews done to workers and SOMAPALM industrial complex (Savonnerie community members evidenced that there are no Tropicale has been operating in the land since land conflicts. 1991). The SOMAPALM Agro-industrial Complex was previously owned by the Madagascar There are mechanisms for the resolution of conflicts. government. Through visual observation, it was verified that the legal boundaries are demarcated and visibly maintained. Within the boundaries of the Savonnerie Tropicale, there are 56 villages with more than 2000 inhabitants who are allowed to do agriculture (in the free land not used by the company) and to graze zebus (the inhabitants cannot graze zébus into a replanting area to avoid destroying nursery ). Now, some of these people are in their third generation or more in the area.

The company is acquired by Savonnerie Tropicale S.A. since 1991 from Malagasy government through the privatization process and there was no official opposition from pretended owners of the land until 2016. Criterion 2.3: Use of land for oil palm does not diminish the legal or customary rights of other users without their free, prior and informed consent. Summary of the findings for 2.3: Findings: Comments: Compliance Customary rights are respected by the company. The customary rights came with the land YES acquisition in the 1990′s. There are maps There are maps identifying sacred and customary identifying sacred sites and customary rights. It rights. was observed that the sacred sites are identified on the field with signs, and through interviews to There is a good communication system between the community members it was confirmed that sacred company and the political and traditional leaders of sites and customary rights are respected by the each of the settled communities within the company company. property boundaries. The sacred sites were identified and demarcated by the company many years ago and reconfirmed There are no negotiated agréements for free, prior as High Conservation Value 6 by an initial and informed consent as the land was purchased assessment of High Conservation Values carried from de government as an ongoing company. out by Savonnerie Tropicale S.A. in 2014 in consultation with the local people.

There has been oil palms in the land since 1966 and sugar cane was cultivated in the land since the mid eighteen hundreds to the nineteen sixties.

The communication system between the company and the political and traditional leaders of the communities is based on notebooks where every communication is written in malagasy. There are MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 12 de 38

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notebooks for the communication with majors, chef carreaueus, fokontany and tangalamena, each of them are authorithies that representes the community members.

Principle 3: Commitment to long-term economic and financial viability. Criterion 3.1: There is an implemented management plan that aims to achieve long-term economic and financial viability. Summary of the findings for 3.1: Findings: Comments: Compliance The company has an updated Business Plan The Programme D′Investissement 2017-2020 Usine YES (Programme D′Investissement 2017-2020 Usine D′Extraction D′Huile Brute list the activities to D′Extraction D′Huile Brute). The business plan is perform during each year. Most of the activities updated every year. listed relates with the improvement of the mill performance and mill capacity through the There are no scheme smallholders at the moment replacement and acquisition of equipment. There is but the plan is to include the scheme in 2017. an annual budget that summarizes the investment to be made each year. Regarding the plantation, there is budget to semi mechanize harvest and maintenance There is a plantation renewal program that pretends to renovate 1000 ha in 5 years (2016-2020) at a rate of 200 ha /year.

Principle 4: Use of appropriate best practices by growers and mills. Criterion 4.1 Operating procedures are appropriately documented and consistently implemented and monitored. Summary of the findings for 4.1: Findings: Comments: Compliance Standard Operating Procedures (SOPs) for farms and The checks on the coherent implementation of the YES mill are documented. procedures are carried out at 3 levels. At the level of the administrative direction and management of There is a mechanism in place to check consistent the operation of the oil mill. The second level of implementation of procedures. control is the department heads and the 3rd level the security department. Activity reports are Records of activities performed and monitoring are produced daily by each of the activities carried out maintained and available. are available at each level.

The mill only receives and processes the Savonnerie Tropicale S.A. own fresh fruit bunches. Criterion 4.2: Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield Summary of the findings for 4.2: Findings: Comments: Compliance Good agricultural practices as the application of The Laboratory of Pedology of Antananarivo YES /OBS empty fruit bunches (EFB), the use of green "FOFIFA" perform the soil analyses. And based on manures and the use of guano to manage soil the results the fertilization plan is developed. fertility, are followed by the company. Fertilization uses greens as Purerias and Glyricidia

Records of fertilizer inputs are maintained. (legumes), compost from mill waste (EFB, fiber, POME muds) and vermicomposting (in the There are soil analysis performed and results experimental phase). The quantities of compost are the base to implement corrective actions. brought are quantified. Records are available and plot yields are estimated (2 to 4 tons per hectare per year). Observation: 4.2.3. Eventhough Savonnerie Tropicale S.A. perform soil analysis in young plant lots or parcelles (0-4 years), the farms does not perform soil analysis in older palms in a regular basis, just when problems are apparent. Criterion 4.3: Practices minimise and control erosion and degradation of soils. Summary of the findings for 4.3: Findings: Comments: Compliance Soil maps available. There are no peat soils within The company has maps of all cultivated plots. YES/OBS

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Doc_2_2_30_1_3_En the palm oil plantation but there are within the Soil slopes are very low or there are no slopes. Savonnerie Tropicale property. SOPs to minimize soil erosion are based on soil conditions and local climate, eg soil cover There is a strategy on place to plant oil palms only on management, biomass recycling, earth-moving, flat áreas. and natural regeneration or restoration instead of replanting. A road maintenance program is implemented. All peat soils are identified. A SOP is in place to provide guidance on management of peatland No signs of erosion observed at visited plantations subsidence. areas. All peaty soils or shallow soils or wet or flooded soils identified and mapped. There are strategies to manage low organic matter An assessment of the possibilities of drainage is soils. carried out before replanting on the peat soils. The plot maps showing areas at risk of flooding as a result of drainage assessment are produced.

Observation: For certain plots the pipes are not suitable for the efficient drainage of water. They do not often have secondary pipelines. Criterion 4.4: Practices maintain the quality and availability of surface and ground water. Summary of the findings for 4.4: Findings: Comments: Compliance Water management plan available for mill and Rivers and wetlands are mapped. YES farms. The main river is the Ivondro rivers. Water analysis POME quality exam results within legal accepted are carried out upstream and downstream to parameters but the upstream and downstream assess the level of pollution from oil mill Ivondro river water difference regarding oil and fats discharges. values (after discharging POME), is out of accepted Buffer zones are maintained near the watercourse. parameters (non conformity placed on criteria 2.1.1). Waste-scrubbing plants such as vetiver are planted on the banks and edges of the main drains to also A procedure for the protection of banks and buffer prevent erosion. zones is implemented and communicated to A procedure for the protection of banks and buffer workers. zones is implemented and communicated to workers. Despite the above, No irrigation done at the plantations. Irrigation is Ivondro river flow affected by rains and cyclonic used only at the nursery but collected rainfall water periods cause river channel changes preventing is used. the establishment of riparian zones in some areas.

0.44 m3 of water / tonne of FFB processed. Criterion 4.5: Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate integrated Pest Management (IPM) techniques Summary of the findings for 4.5: Findings: Comments: Compliance There is no use of synthetic pesticides in Savonnerie A documented integrated pest management plan YES Tropical S.A. operation. The operation is organic is in place : certified. • Identification of potential pests and nuisance thresholds. No use of herbicides to control weeds. Manual • Biological control on the basis of the use of weeding is performed. plants with repellent properties of enemies.

Trap placement and manual collection to capture Recordings on monitoring and control of pests are disease transmitting insects and the use of available. bioproducts is practice. Thus for the oil mill Melville, the head of department Replantation has the following tools: IPM training to the IPM team was performed in - Information sheets on the development cycles of 27/02/2016 and 05/03/2016. pests (Oryctes Rhinoceros) other insect pests (locusts, ants, caterpillars etc.). - Records identification and collection of larvae, - Protocols of biological struggles, - Implementation of eradication or corrective action - Use of larvae for consumption.

Criterion 4.6: Agrochemicals are used in such a way that does not endanger health or the

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Doc_2_2_30_1_3_En environment. There is no prophylactic use, and where agrochemicals are used that are categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented. Summary of the findings for 4.6: Findings: Comments: Compliance There is no use of agrochemicals in the whole Synthetic pesticides are not utilize as the N/A operation. production is entirely organic. The operation is certified organic by Ecocert International. Certificate N. MG-2013-70658-Z_06356-2008 The use of pesticides is formally prohibited according to the procedures of the company.

Criterion 4.7: An occupational health and safety plan is documented, effectively communicated and implemented Summary of the findings for 4.7: Findings: Comments: Compliance The company has a health and safety policy in place, Risk assessment covers all processes and activities YES /NO known by the staff. of the organization. The precautions or A health and safety plan is also in place. It includes instructions to be taken to control risks are defined objectives to improve health and safety at work, it and communicated to the workers. Unannounced reflects the guidance provided in ILO Convention 184 . checks are made by security officers to observe Risk assessments have been conducted for all compliance with the safety instructions. operations and all workers involved in plant or plantation operations receive health and safety Adequate and appropriate protective equipment is training related to their work. made available to all workers at the workplace to cover all potentially hazardous operations such as

machine operations and land preparation, PPE is provided to workers and replaced when harvesting and boiler operation, castration of damaged. seedlings, weeding, etc.

All works accidents are recorded including those Meetings between managers and workers are conducted on a regular basis to discuss health and resulting in loss of time according to company- safety issues. specific parameters (accident rests are decided by the mill nurse depending on the severity of the There is emergency procedures in case of accident accident). Registration reports are available. Thus and clear and comprehensible instructions available from September 2015 to August 2016 the factory for the workers. totaled 148 days of work stoppage due to

accidents. All workers (permanent and contract workers) receive medical care (see Criterion 6.5.3), and all are covered by accident insurance). The factory has a Observations: nursing infirmary that takes care of all workers in However, some workers do not always follow case of illness or occupational accident. It is even instructions. For example, during the visits of the open to local communities. plantations it was observed the inappropriate attachment of the poles after stopping harvest, First-aid kits are available at all stations, however, and lifting a bunch of more than 45 kg by a single they are not sufficiently equipped reason why the worker. non conformity 001/2015 remained open..

Criterion 4.8: All staff, workers, smallholders and contractors are appropriately trained Summary of the findings for 4.8: Findings: Comments: Compliance There is a training program, documented and Training programs on the general activities of the YES implemented, that covers the RSPO principles company and the implementation of the RSPO and criteria. program are implemented annually.

Evaluation of the knowledge of participants on the training topics is performed

There are up to date training records. Principle 5: Environmental responsibility and conservation of natural resources and biodiversity.

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Criterion 5.1: Aspects of plantation and mill management that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement Summary of the findings for 5.1: Findings: Comments: Compliance An Environmental Impact Assessment is The EIA was made by the governmental YES documented and it was approved by the institution as it was the first company Ministry of Environment on 05/09/2006 requiring this kind of study in Madagascar. It (Certificat de Conformite Environnemental). was a pilot project in Madagascar with the Savonnerie Tropicale Unite de Production There is a Plan of Environmental Management Melville –Ivondro MISE EN CONFORMITE as a which is part of the EIA and is strictly followed result. After this report the Certificat de by the company to monitor and mitigate Conformite Environnemental was issued in potential negative impacts. The responsible September 2006. person for the compliance of the plan is Etancelin Gaetan, Head of Research and The EIA, between others, includes section II. Development for Savonnerie Tropicale Huilerie Description of the activities, III Description of Melville. the environment, IV Analyses of Impacts, V There are daily monitoring protocols in place to Plan of Environmental Management. It monitor the effectiveness of the mitigation includes a List of Annexes, List of Tables, List measures. of Figures, Abreviations used. Between the potential detected environmental impacts there is the pollution of water, generation of waste and pollution of air.

The EIA on table 12, presents the monitoring protocol: Monitoring program establishes the parameters that should be measured and includes the quality of POME effluents (parameters pH, temp, huiles et graisses turbidity, BOD and COD), quantity of solid waste generated (quantity of solid waste generated and deposited at the composting site), quality of combustion gases (color of gaseous emissions / smokes). Note: the method established to evaluate the gaseous emissions is through visual method (observation of the colors of smoke).

Documents reviewed: Effluent and upstream and downstream river physico chemical exams with sample taken 03/06/2015 and results delivered the 17/06/2015. Analysis done by Laboratoire D” Analyse de Controle de la Qualite de les Aliments et des Eaux. All of the results are within the accepted parameters indicating no impact on stream. Results signed by the responsible of the LAB: RAKOTOARIVONY EMMA. Normative document: Valeur prescrite dans le decret N. 2003/464 du 15/04/03 portant classification des eauxs de surface et réglementation des rejects d “effluents liquids.

Cahier de Charges Environnementales. Daily record of inputs, products, solid and liquid waste (quantity of fuel used, quantity of water used, quantity of effluents produced, weight of EFB produced, weight of EFB reused, weight of fiber send to the field as fertilizer, quantity of fiber used in the boiler). Criterion 5.2: The status of rare, threatened or endangered species and high conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations. Summary of the findings for 5.2:

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Findings: Comments: Compliance An Assessment of High Conservation Value was An Assessment of High Conservation Value of YES performed in 2014. As a result, only HCV 6 was Ivondro Palm Oil Plantation, Atsinanana State. identified on the area. Madagascar was made in 2014. Responsible person ETANCELIN GAETAN. Head of research and No RTE species have been identified on the Development 21/01/2014. The HCV assessment Savonnerie Tropical Huilerie Melville area. Despite includes : Accronyms, Acknowledgment, the above, the personell receives induction about to Definition, Executive Summary (introduction, respect wildlife in general and to not capture, harm, objectives, approach, HCV assessment team. The collect or kill any species regardless it is an RTE Concession Area, Assesment Methodology, species or not. Findings, Summary HCV, Conclusion, Reference. Appendix 1: record of Stakeholder consultation. Signs are placed within the area and security staff is Appendix 2: Fauna Survey Data. Appendix 3: Flora present to prevent the theft of fruit and illegal Survey Data. Figures from 1 to 18. Total of pages hunting, fishing or capture of species. 115 plus figures. The HCV study included HCV 1, HCV 2, HCV3, HCV4, HCV 5 and HCV 6. As a result, only HCV 6 was identified on the area.

The area have been cleared for agriculture purposes in the past 200 years impacting the integrity of the forest vegetation notable of hosting a rich biodiversity of flora and fauna. Only 5 species of reptiles and 5 species of birds were identified within the property boundaries. No RTE species were idientified. Criterion 5.3: Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner. Summary of the findings for 5.3: Findings: Comments: Compliance There is an Environmental Impact Assessment that YES/NO Waste products and sources of pollution are idientifies waste products and sources of pollution. identified. There is a waste management plan that explains A waste management plan is documented and the collection of waste products, reclycling and partially implemented. composting. There is monitoring of waste with detailed records. There is proper management of organic waste. There There is another document that establishes the is recycling of waste as Empty Fruit Bunches (EFB) destiny of waste produced on the mill. Ex: Systeme are use as a source of organic matter at plantations de gestion des ordures D “ Usine. Dechets Melville. and fiber of fruit, after oil extraction, is use as a Contains the type of residues by class and explains source of energy for the boiler. the destination of each residue: recyclables as Other recyclable waste is not properly managed as Empty Fruit Bunches and fruit fiber goes to the paper, cardboard and plastics are send to the composting area or directly to the plantation as municipal landfill. (Non compliance 002/2015 non recyclables goes to the commune trash against 5.3.3 was raised to major). deposit on a Savonnerie Tropicale Huile Melville truck). There are agreements with accredited waste collection companies to collect used oils and Despite the above, it was found, through maintenance waste as oil, diesel and air filters and documental review and interviews, that other specialized residues. recyclables as paper, cardboard and plastic, during 2016, have been send to the municipality landfill . Monitoring of polluting activities includes the registration of the amount of generated waste.

The company is committed to organic agriculture. There are no chemical container to dispose.

Criterion 5.4: Efficiency of energy use and use of renewable energy is maximised. Summary of the findings for 5.4: Findings: Comments: Compliance All energy used is monitored. The fuel use in the boiler is the fruit fiber and the YES shells of palm kernel. There is no other fuel used A plan to optimize the use of renewable energy is in in the boiler. The rest of the fruit fiber goes directly place. to compost or directly to the plantations.

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The boiler relies entirely on fruit fiber and palm There are two electricity generators for the kernel shells. operation. There is no electricity provided by cable. The biggest electricity generator works Through proper maintenance of electricity from 8 a.m. to 2 p.m. everyday that there is work generators operated by diesel, the efficiency of fuel on the mill. The mill works some days from is guaranteed. Monday to Saturday depending on the fruit availability. The mill uses 1.2 tons of fiber / mt of oil produced.

The mill uses 4.2 litres of diesel /mt of FFB processed. Criterion 5.5: Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN guidelines or other regional best practice Summary of the findings for 5.5: Findings: Comments: Compliance Fire is not permitted at any agricultural or waste The use of fire is forbidden within the property YES disposal activity at Savonnerie Tropicale S.A. limits.

Fire is not used for the preparation of land or any other use on field operations. The use of fire is prohibited within the property for those who work and /or live within the area owned by the company.

The company lend out land to resident villagers. The process includes a written request by the villager, followed by an inspection of the requested site by the Savonnerie Tropicale S.A. personnel. After reviewing the site and confirming that everything is fine, the permit is given (written) under certain conditions established by the plantation, within them, no use of agrochemicals and no use of fire.

Evidence:

Visit to the production areas of Zone I and III (E 14 replanted area and C 2)

Criterion 5.6: Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and monitored. Summary of the findings for 5.6: Findings: Comments: Compliance Pollutants and sources of GHG has been identified: The CAHIER DE CHARGES ENVIRONNEMENTALES YES/NO -Mill effluents for the year 2015 and 2016 has numbered sheets -Boiler emissions and the seal of FITSARANA Tribunal de 1 er -Waste Instance TAMATAVE (signed by Le President on -Fuels 28/08/2015). The notebook has all parameters that has to be recorded by the company each day Plans to reduce pollutants and GHG are documented and week, according to the environmental and implemented. management plan established on the EIA Page 56 corresponds to 01/01/2016 to 03/01/2016 Periodic monitoring of pollutants and sources of and page 100 corresponds to October 3 rd to 9 th., GHG is done. POME analysis are performed by 2016. It includes inputs, products and waste: accredited ISO 17025 laboratories. liquids, solids and gaseous. On the gaseous parameters, regarding the smokes of the mill Boiler emissions are daily monitored through color chimney, includes the quantity of fuel (m3), boiler of smoke, as required by the EIA. working hours, quality of smoke to be recorded based on color of smoke. For the chimney smokes MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 18 de 38

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A non compliance regarding differential values the color indicators are NI : noire, B= blanche, I= outside legal parameters between upstream water incolore, V= Variable, G= grise. and downstream water oils and fats was Example: july 2016, 4 days were incolored and 2 established against criterion 2.1.1 . days were grey colored. The totality of days worked in july were 2. Non conformity against criterion 5.6.3.: Eventhough there are records of volumes of waste The effluent parameters are recorded on a daily per type going out, there are no analysis on basis and external exams are done every 6 progress of this estate and mil pollutant neither months). measures for its reduction. Effluent Physico- chemical quality analysis were performed to the POME in december 2015 and may 2016 and results dated January 20 th. 2016 (analyse N. 79/2015) and may 18 th. 2016 (analyse N. 70/16/CNRE/D4). The results were within the acepted legal parameters with exception of the pH for the may 2016 analysis which shows a pH value of 5.64 when the accepted values are between 6 and 9.

There are also for the same dates, analysis of the water of the Ivondro river upstream and lowstream. The results of the may 2016 analysis shows that the water downstream is 19.20 mg/l when the upstream water has a value of 3.73 mg/l of oils and fats. That fact seems to show that the waters drained into the river by the mill are altering the river oil and fats contents. Decret n.0 2003/464 du 15/04/03 important classifications des eaux de surface et reglementation des rejets d effluents liquids.

Le Centre National de Recherches Industrielle et technologique – CNRIT- BP 6294

To solve the fat and oil contents of the POME effluents, a 6 compartment lagoon has been build but has not started operation yet due that the mill has been stopped since july 14 th 2016.

Principle 6: Responsible consideration of employees and of individuals and communities affected by growers and mills. Criterion 6.1: Aspects of plantation and mill management that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement Summary of the findings for 6.1: Findings: Comments: Compliance The non conformity established against criterion A SIA (Social Impact Assessment) issued on April YES / NO 6.1.1 and 6.1.2 during the RSPO ASA 1 audit were 14th, 2016 including records of meetings is closed by the auditee through a corrective action documented. This document is done, after the send to the CB on april 15 th. 2016. A SIA (Social finding of the “non-compliance 003/2015” during Impact Assessment) issued on April 14th, 2016 the last surveillance audit on December 2015. This including records of meetings is documented SIA has 65 pages with 11 tables and 35 figures. SIA must take into consideration others potentials The SIA has been done with the participation of social risks: thefts and/or intrusions, conflicts affected parties. about the irrigation channel maintenance which A non conformity against criterion 6.1.3 jointly used both by the Huilerie de Melville and remains open as the SIA does not include the communities (ricefields, others agriculture plans. issues,…) lending the land, impacts of the restriction of communities concerning the zebus There is no smallholders scheme in the grazing toward the increase of the replanting area, operation. demography increase inside the property,

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The Social Impact Assessment has been done with the participation of affected parties such as internal personnel (DAD, DIREX, Environmental Department, Gender Committee, Health & Safety,…) and the external stakeholders as the Mayor, the traditional leaders (called “Tangalamena”) and the local communities. Observation: The period to review the SIA is not mentioned on the document.

Criterion 6.2: There are open and transparent methods for communication and consultation between growers and/or mills, local communities and other affected or interested parties Summary of the findings for 6.2: Findings: Comments: Compliance The existence of documented procedures for The company has an update list of its YES communication and consultation was verified. stakeholders. Documented records on proper formats of the Records of request of information, respective information requests and the approval by the answers and follow up actions are updated and company representative to deliver the needed available. documents, to organize the meetings and tours of the mill and the farms are available. Mrs. Danick RAMAROSON, Administrative Records of request of information, respective manager is responsible for the coordination of answers and follow- up actions are updated and consultation and communication with local available. communities and other affected or interested Reports of meetings with community members parties. (list of attendants) that include the comments and The existence of a stakeholder directory was agreed measures to follow-up are available. verified, it is managed by the administrative Indeed, there are notebooks for each commune on manager. which every communication and interactions are documented. Every three months, regularly, the Documented records on proper formats of the company employees are sent to collect all these request for information and the approval by information and communications from the representatives of the company's to delivery commune. 04 notebooks are recording every event the documents and to organize meetings and tours of the mill and farm were available. and communication from the keys stakeholders: traditional leaders, Communes Reports of meetings with community memebers (Amboditandroroho and Fanandrana), Chiefs of (list of assistance) that includes the comments Fokontany and chiefs of carreau (zones). made and agreed measures to follow, are As evidence, on February 2nd , 2016, in the available. traditional leaders notebook, the “Tangalamena” VELOLAMBA of the village of Antseranampe has written to request calendar, raincoat and informed the company about the road area destroyed by pigs to be maintained. A request to graze zebus in parcel E1 & E18 where palm nurseries are already big enough is written by the Mahatsara chief of Fokontany and has been submitted to Huilerie of Melville. For security matter, the local authorities inform and communicate to Savonnerie Tropicale Manager without delay.

Criterion 6.3: There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties Summary of the findings for 6.3:

Findings: Comments: Compliance There is a documented and implemented There is a procedure establishing that complaints YES system for dealing with complaints and and grievances arrive in a written way: registered, grievances, accepted by all parties. investigated and solution taken (process takes 7 days). Prompt resolution of problems was verified The system comprises notebooks managed by Savonnerie Tropicale S.A. personnel and through notebooks review. If necessary, in some communes were grievances, complaints, and occasions, the involvement of the complainant for requests are documented in a continuos basis research is requested by the company and/or the and resolutions and agreements are also local authorities. Different notebooks where

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Doc_2_2_30_1_3_En documented. complaints, grievances and requests are documented and are Complaints and suggestions should be track managed by the Savonnerie Tropicale and the key and solve in a maximum of 7 days. stakeholders. Above the 04 notebooks seen on P &

Prompt resolution of problems was verified C criteria 6.2.3., another notebook called “Cahier through notebooks review. pour la traçabilité des sensibilisations suivant les anomalies sur parcelles” is used by the villagers to capture all the fields problems and to propose solution; every area has its own notebook. Example: on February 24th 2016, Mr. VELOLAMBA is reported on “Tangalamena” notebook by the security guard that he has put his 02 zébus to graze in replanting parcel E6 and recommended to meet the Manager of the company to solve the issue. He presented his excuses, according to the communities rules” (zebus must be put to “fourrière” and paid taxes to the municipality) , to the company Manager and resolved the problem with friendly way.

Criterion 6.4: Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stake holders to express their views through their own representative institutions Summary of the findings for 6.4: Findings: Comments: Compliance There are customary rights by villagers at The company performed studies/consultations in YES Savonnerie Tropical land. participatory processes to determine the existence of legal customary rights users. The two most There is no planting on communal land important items taken into consideration are the

There is a map where all the sacred sites are sacred sites and the use of agriculture land for indicated /located. these communities inside the Savonnerie Tropicale property., There is no procedure for calculation There is no compensation required as the and distributing compensation as there is no sacred sites are respected and there is free planting on communal land. access to them. The Melville plantation company allows communities to use their lands for livelihoods and to graze zebus with agreed conditions: no fire use, no deforestation, no zebus into the replanting area. Above, the communities can freely access to the identified sacred sites belonging to them which are mapped as HCV 6. Criterion 6.5: Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages. Summary of the findings for 6.5: Findings: Comments: Compliance Savonnerie Tropicale S.A. complies with labour Documentation of pay and conditions are available YES law regarding payment of extra hours at a in HR Department. At the HR office, there is a See criterion different rate, affiliation to CnaPS and paid folder for each employee, containing several 2.1.1 vacations, between others and maintain documents, such as contract employment, letter of adequate information on pay and conditions for their workers. Despite the above, it was found worker confirmation of hiring for permanent, copy that minimum wages were not updated of monthly payslip, trainings already done during according to the Decret n° 2016- 232 related the career period, test done to verify skills, to the minimum salary in Madagascar issued in competencies and characteristics/behaviours, Antananarivo on April 5th, 2016 , at least on trying notification letter, maternity rights some workers. A non conformity against documents for women employees(maternity leave criterion 2.1.1 was established regarding the request, …),.… fact that some workers are receiving less than The company maintains adequate documents of the minimum wage due to the worng / not updated value of the minimum wage been used pay and conditions added to contracts for their by the human resources responsibles. workers, temporary, seasoning or permanents. In order to facilitate the identification of worker typology status, the folders of the workers are

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Payment details are summarized in the payroll differently coloured: blue for permanent delivered to each worker and the receipt is employees and each department has its special signed by the worker. colour for the temporary and/or seasoning workers. Workers are affiliated to the CNaPS, CMS (medical care) and the company has a medical Workers are affiliated to CNaPS (“Caisse Nationale center with a doctor and a nurse working from de Prévoyance Sociale”)or CMS(Centre Médico- Monday to Saturday that provides medical care Sanitaire) and the company has a medical center to workers and their families. on site(Huilerie de Melville is located more than 25 km from the Tamatave town) managed by a doctor No housing provided by the company. and a nurse working from Monday to Saturday morning that provide a medical care for the The company provides potable water at the workers and their families. working sites. The contracts are written in Malagasy or French The company lend 350 ha of land per year to according to the employee.. villagers for agricultural purposes. No housing is provided to workers by the company because most of the workers are living around the palm plantation; the other part of the employees living in Tamatave town are transported by the company bus freely going to work and returning back home. On sites, for every zone, a shelter was constructed to be use by workers. Savonnerie Tropicale daily demonstrates and gives to all personal an adequate and sufficient foods, in the office and on sites, freely. The cafeteria of Savonnerie Tropicale gives freely foods to workers during the working days Criterion 6.6: The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel Summary of the findings for 6.6: Findings: Comments: Compliance There is a policy that recognizes freedom of There is policy that recognizes freedom of YES association for workers. association for workers called “Politique des droits desHommes, item 4:” La société s’engage à la There are two syndicates that representes liberté d’association syndicale et au droit de se workers at Savonnerie Tropicale. réunir”. On Malagasy Labour law 2003- 044 issued

on July 28th 2004(Official Journal n° 2956 of There are minutes of the meetings between the February 21st 2005), the item 136 on Title V Des company and the workers representatives. relations professionnelles, Chapter I Des organisations des travailleurs et des employeurs: “L’exercice du droit syndical est reconnu dans le respect des droits et des libertés garanties par la constitution”. That’s why there are many syndicates inside the company: SEMPIMITO (Sendikan’ny Mpiasa Mivondrona eto Toamasina) and SEKRIMA (Sendika Kristianina Malagasy).

There are minutes of the meetings between the company and the workers representatives shown during the audit. In several occasions, the personnel representatives request of meeting is submitted to the Director for acceptation. The agenda and requests of the meetings are written and documented in a book called “Cahier de révendication des délegués de personnel”in Melville Criterion 6.7: Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programmes. Children are not exposed to hazardous working conditions. Summary of the findings for 6.7: Findings: Comments: Compliance Savonnerie Tropicale S.A. has established a The minimum age requirement on Savonnerie YES policy of No child labor. MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 22 de 38

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Tropicale recruitment is 21 years old. Through the No childs were observed at the palm oil interviews done with HR Department and the plantation eventhough the collection of fallen representative of personnel (RAZAFIMAHEFA fruit is done by women. Georges Aimé, Id 3251), they testified this

minimum age for work in the company. Savonnerie Tropicale S.A. has established a policy of no children labours. It is already included in the Human Rights Policy. Criterion 6.8: Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited. Summary of the findings for 6.8: Findings: Comments: Compliance There is a comprehensive human rights policy with a There is a specific no discrimination policy, written YES non-discrimination statement. in French and Malagasy languages, displayed at the wall of the Human Resources office where all There is a specific no discrimination policy (in french employees can see and read. On item 2, the and malagasy) displayed at the wall of the human company establishes the commitment to avoid any resources office where all employees can see it. kind of discrimination by age, race, sex, ethnic, origin, nationality, religion, health conditions, Through interviews, it was established that there is marital status, sexual orientation and political & no discrimination at Savonnerie Tropicale S.A. philosophic opinions. There are no migrant employees in Savonnerie There are procedures for the recruitment of Tropicale. Yes, there are many employees from permanent and non permanente workers, written in different ethnics of Madagascar but there are french and malagasy, and displayed on the external treated equally since Tamatave is always a town of wall of the human resourses office. many ethnics or mixing people. As evidence, one member of Gender Committee Aplicants for a new job will be selected taking into interviewed during the audit, Miss Felicie, Id 3352, account skills, capabilities, qualities and medical monitor, testified that there is neither fitness to perform the Jobs available. discrimination against women nor against the handicapped personnel at Savonnerie Tropicale Promotion is based on capabilties and skills shown S.A.. during work. There are procedures for permanents and temporary/seasoning recruitment, written in French and Malagasy languages, and displayed on the Human Resources (HR) office board. New job applicants are selected in taking account skills, competencies, qualifications or backgrounds and medical fitness to perform the jobs available. Applicants related with the job are selected and called for an interview where confirmation of fulfilment of the requirements position is performed. The candidates’ selection is based on job skills, abilities, capabilities, qualifications and fitness for work. Employees’ promotion depends on capabilities, skills during the works period

Observation: harvest workers does not know the mechanism or requirements to comply to become permanent workers instead of remaining as temporary workers. Criterion 6.9: A policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied. Summary of the findings for 6.9: Findings: Comments: Compliance Zero tolerance to sexual harassment is Zero tolerance against sexual harassment or abuse YES contemplated on Savonnerie Tropicale S.A. in the work place is shown through the Human Human Rights Police (item 3). Rights Policy, item 3. This Policy is communicated to all levels of the workforce by HR Department in There is a policy to protect reproductive rights, which is supported by a gender committee. The displaying it on the HR communication office policy is communicated to all levels of the board, with French and malagasy versions.

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Doc_2_2_30_1_3_En workforce. Testified through interviews with women working with the company in different Services/Departments and the Gender Committee There are several documented and members, there is a Policy to protect reproductive implemented grievance mechanisms. rights

Grievance mechanisms includes grievance notebooks placed by The National Office of Environment (is social and environmental) in the communes. As workers are villagers they can easily place they complaints through this way.

There are notebooks available at the entrance of the mill where complaints can be set. There is a written procedure that describes the flow of the complaints and establishes that in 7 days the compliants should be analyzed and decisions taken.

Workers interviewed at the office and on the fields said that they can complaint to HR Department, their chief of zone or supervisor, through personnel delegates and the Gender of Committee(TATA Jean Paul, Id 1833, Climber chief, FAKAHITA Jean Maurel, Id 3551, Section chief of civil works, RAKOTOMAMONJY Randrianina Elise, HR Department interim,Id 3580,...)

Criterion 6.10: Growers and mills deal fairly and transparently with smallholders and other local businesses. Summary of the findings for 6.10: Findings: Comments: Compliance All FFB coming into the mill comes from the There is no smallholder scheme. YES Savonnerie Tropicale S.A. own plantations. Four services providers are contracted by the company: Quality service. Cabinet Maritime d There are not external FFB providers. Expertise et de Surveillance. (chain of custody and

Three service providers are contracted by the security loading at ships.), electrical generators company. Terms and conditions of the service (MATERAUTO), Groupe ADONIS (waste tratment) are very clear and agreed payments are made and Transportation Etienne (CPO transportation in a timely manner. from Huilerie de Melville to Port). Terms and conditions of the service are very clear and agreed payments are made in a timely manner.

Criterion 6.11: Growers and mills contribute to local sustainable development wherever appropriate. Summary of the findings for 6.11: Findings: Comments: Compliance Through documental review and interviews with The administrative manager is responsible for the YES stakeholders it was evidenced that the communication with the community members company contributes to local sustainable development. Savonnerie Tropicale S.A. is the first social partner

The contributions responds to the needs, of the two regional surrounding communes: request and demands of local communities. Amboditandroroho and Fanandrana. On meeting the two deputy Mayors (ZAFIMALO Remi, 1st -All field and mill workers are from the villages Mayor Deputy, SOLO Emmanuel, 2ND Mayor settled within the property boundaries or Deputy) and the president of the Municipality neighbouring villages. Council of Fanandrana ( IEFATRA Daniel) during -Provides land and building materials for the audit time, December 8th, 2016, they noticed schools and churches. that many collaborations are made between the -Collaboration with materials and wokforce on the construction of the Basic Health Center of parties: MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 24 de 38

Doc_2_2_30_1_3_En two communities. _ logistic supports to MFR professional agriculture -Supports community members through the training for regional youths by giving freely the Medical Center Mahasoa. Called Social Actions land property “Riche en eau SOMAPALM “during (realisation actions sociales). Donations for 15 years which size is 140 m2(“Convention de mise consultation with specialist, transportation, house repair and others. a disposition” signed on Antananarivo May 22th -Lending of 350 ha of land a year to community 2015 and fuel for transportation. memebers for the planting of rice, taro, _ independence day supports to the two mandioc, leaves, bananas, eggplants, zuchines. communes _ traditional leaders grants _ payment for the communes participation of the secondary school construction of Fanandrana

(beneficiaries supports) and lending tractors for

the transportation of sand (2016).

There is no scheme smallholder. Until now, there is no smallholders working with the Savonnerie Tropicale . The project to cultivate palm oil outside the company boundaries/property is just start the feasibility study (financed by Savonnerie Tropicale) and will be progressively implemented. Criterion 6.12: No forms of forced or trafficked labour are used. Summary of the findings for 6.12: Findings: Comments: Compliance The company Human Rights Policy (Police sur le It was found through interviews and direct YES Respect des Drioit des Hommes) establishes observation in the operation of Savonnery that the company is against forced labour (item Tropicale Huilerie Melville that no forms of 1). forced labor or labor trafficking are practiced. All the workers are contracted directly by the company and there are clear and well known procedures to recruit / hire personnel. Each employee has a signed contract that establishes the working and payment conditions.

Savonnerie Tropical Huilerie Melville does not contract migrants workers. There are specific policies and procedures for the recruitment of temporary workers. Criterion 6.13: Growers and millers respect human rights. Summary of the findings for 6.13: Findings: Comments: Compliance A policy to respect human rights is documented The Human Rights Policy (Police sur le YES and communicated to all levels of the workforce Respect des Drioit des Hommes) contains 6 and operations main items: no forced labour, no children at work, no discrimination, freedom of association, preserve the relation mother/enfant, no sexual or any kind of harassment and to favour the insertion of handicapped workers. It was found through interviews and direct observation that the company respects human rights Principle 7: Responsible development of new plantings. Criterion 7.1: A comprehensive and participatory social and environmental impact assessment is undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management and operations Summary of the findings for 7.1: Findings: Comments: Compliance No new plantings since 2005. Savonnerie Tropicale S.A. manages 1200 N/A ha of Organic Palm oil and has no plans for expansion neither the establishment of new plantations within the own property boundaries. Informed by management personnel. The plantation was established in the 1960′s and there are no new plantings since 2005 Criterion 7.2: Soil surveys and topographic information are used for site planning in the establishment of new plantings, and the results are incorporated into plans and MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 25 de 38

Doc_2_2_30_1_3_En operations Summary of the findings for 7.2: Findings: Comments: Compliance No new plantings since 2005. Savonnerie Tropicale S.A. manages 1200 N/A ha of Organic Palm oil and has no plans for expansion neither the establishment of new plantations within the own property boundaries. Informed by management personnel. The plantation was established in the 1960′s and there are no new plantings since 2005 Criterion 7.3: New plantings since November 2005 have not replaced primary forest or any area containing one or more high Conservation Values Summary of the findings for 7.3: Findings: Comments: Compliance No new plantings since 2005. Savonnerie Tropicale S.A. manages 1200 ha of N/A Organic Palm oil and has no plans for expansion neither the establishment of new plantations within the own property boundaries. Informed by management personnel. The plantation was established in the 1960′s and there are no new plantings since 2005 Criterion 7.4: Extensive plantings on steep terrain, and/or on marginal and fragile soils, are avoided. Summary of the findings for 7.4: Findings: Comments: Compliance No new plantings since 2005. Savonnerie Tropicale S.A. manages 1200 ha of N/A Organic Palm oil and has no plans for expansion neither the establishment of new plantations within the own property boundaries. Informed by management personnel. The plantation was established in the 1960′s and there are no new plantings since 2005 Criterion 7.5: No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their own representative institutions Summary of the findings for 7.5: Findings: Comments: Compliance No new plantings since 2005. Savonnerie Tropicale S.A. manages 1200 ha of N/A Organic Palm oil and has no plans for expansion neither the establishment of new plantations within the own property boundaries. Informed by management personnel. The plantation was established in the 1960′s and there are no new plantings since 2005 Criterion 7.6: Local people are compensated for any agreed land acquisitions and relinquishment of rights, subject to their free, prior and informed consent and negotiated agreements. Summary of the findings for 7.6: Findings: Comments: Compliance No new plantings since 2005. Savonnerie Tropicale S.A. manages 1200 ha of N/A Organic Palm oil and has no plans for expansion neither the establishment of new plantations within the own property boundaries. Informed by management personnel. The plantation was established in the 1960′s and there are no new plantings since 2005 Criterion 7.7: Use of fire in the preparation of new plantings is avoided other than in specific situations as identified in the ASEAN guidelines or other regional best practices Summary of the findings for 7.7: Findings: Comments: Compliance MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 26 de 38

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No new plantings since 2005. Savonnerie Tropicale S.A. manages 1200 ha of N/A Organic Palm oil and has no plans for expansion neither the establishment of new plantations within the own property boundaries. Informed by management personnel. The plantation was established in the 1960′s and there are no new plantings since 2005 Criterion 7.8: New plantation developments are designed to minimise net greenhouse gas emissions. Summary of the findings for 7.8: Findings: Comments: Compliance No new plantings since 2005. Savonnerie Tropicale S.A. manages 1200 ha of N/A Organic Palm oil and has no plans for expansion neither the establishment of new plantations within the own property boundaries. Informed by management personnel. The plantation was established in the 1960′s and there are no new plantings since 2005. Principle 8: Commitment to continual improvement in key areas of activity. Criterion 8.1: Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continual improvement in key operations Summary of the findings for 8.1: Findings: Comments: Compliance There is a documented Action Plan for There is a documented Action Plan for YES Improvement which is bound with the Programe Improvement which is bound with the Programe for Investment (2016/2017). for Investment (2016/2017).

Between the improvement actions are the Between the improvement actions are the following: following: - New Planting area: smallholders GIZ co - New Planting area: smallholders with GIZ co financing. (2017-2022). An EIES will be done by financing. (2017-2022). An EIES will be done an independent team (proforest, WWF, by an independent team (Proforest, WWF, Conservation International) for the smallholders Conservation International) for the new plantation. A cooperative will be function in 2018.First planting target for 2017 after EIES. smallholders new plantation. A cooperative - An independent study will be will be function in 2018 .First planting target implemented to see conformity with ISO 14001. for 2017 after EIES. - ISO 14 001 is a target for the end of - An independent study will be implemented to 2018. see conformity with ISO 14001. - Buy a new boiler from Malaysia (june - ISO 14 001 is a target for the end of 2018. 2017). - Buy a new boiler from Malaysia (june 2017). - Continuing the sensitization on the correct use of PPE. - Continuing the sensitization on the correct - Training to workers will focus on french use of PPE. language, fertilization and first aid care. Hire of - Training to workers will focus on french a training chief. language, fertilization and first aid care. Hire - The company will integrate COMBO of a training chief. project: compensation, mitigation, POME - The company will integrate COMBO project: recycling in partnership with CNRIT. - Several improvements on the compensation, mitigation, POME recycling in infrastructure and equipment of the mill partnership with CNRIT. (modernization of the palm oil production line). - Several improvements on the infrastructure and equipment of the mill (modernization of Indicators: the palm oil production line). - There is no use of pesticides (the plantation is organic certified)

4.3. Specific management when planting on peat , no oil palm planting on slopes, road maintenance program in place and kudzu soil coverage and organic matter applied (EFB and palm oil leaves) on low organic matter soils. 5.1. Visual daily monitoring of chimney smoke and laboratory analysis of the quality of mill

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effluents. Weekly monitoring of waste produced and disposed. 5.2. Advanced conversation with Conservation International NGO to perform an advance RTE species study in the area. Currently there are no RTE species identified in the area.

Waste reduction. There is daily and weekly monitoring of waste, depending on the type of waste. Currently, the cardboard, paper and plastic is not recycled. There are advanced conversations with a local association to send the cardboard, paper and plastic for recycling in 2017.

Good equipment maintenance program in place.

Continuous communication with political and traditional community leaders as well as with individuals of the communities settle within the property boundaries though the notebooks systems (see indicator 6.1.1)

Yield production in 2016: 3. 4 mt /ha. RSPO Supply Chain Certification Supply Chain Module D – Identity Preserved / E - Mass Balance Findings: Comments: Compliance Description All FFB entering the mill comes from the own There is control of the quantity of CPO and PKO YES/ NO company certified farms. The supply base is produced every day, which is then summarized conformed by 5 farms located at two on a weekly and monthly basis. communes: Fanandrana commune (areas farms I and II) and Amboditandroho The company has estimated the production of commune (areas/farms III, IV and IV). The CPO and PKO for the next twelve months, as farms are adjacent as could be seen on the follows: map placed on section 1.9 of this report. All FFB are processed in the only mill located in For the season, the following amount of FFB Fanandrana. has came into the mill: 5 502 mt

During the last season (nov 2015- july 2016) the The current capacity of the mill is of 5 MT/hr and it production reached was: works 8 hours a day. The configuration of the mill is for 10 MT /hr putting 1 extra press and 1 extra CPO = 1 060 metric tons (IP) boiler. Because of the potential capacity of the mill, PK = 575.9 metric tons (IP) Savonnerie Tropicale Huilerie Melville is working PKO = 45.5 metric Tons (IP) with some NGO s to promote the planting of palm oil by local farmers that can deliver FFB to the mill. OER was 19.26 for the nov 2015 to july 2016 season.

The last fruit processed was processed in july 2016 due to the crop stationallity in Madagascar. The harvesting has been delayed and has not started in late november as usual due to several factors , between them, the delay in rains and the repairs that has been made in the mill (currently working on repairs).

Expected for the 2017 season: An amount of 6 335 mt of FFB coming into the mill CPO= 1 220 metric tons (IP) PK = 650 metric tons (IP) PKO = 50 metric tons (IP).

The increase in production is due to an increase of the OER and also to some lots of replanted palms coming into production . The climatologic conditions has been favorable also. Documented Procedures MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 28 de 38

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Standard Operating Procedures (SOPs) for the mill Harry Ancelly who was in charge of the mill left the YES are documented. company in june 2016 and his position has not been replaced, at the moment the Chief de Service There is a mechanism in place to check consistent (RAZAFIMAHEFA Georges Aimé N. 3251) is in charge implementation of procedures. of the mill and demonstrate understanding of the procedures and implementation of the standard. Records of activities and monitoring are maintained and are available. There is a procedure for the activities carried out at the plant "Procedure D'Usinage, 12/13", containing schematic flow diagram and description of the activities (sterilization, pressing, centrifugation, etc.) and descriptive manufacturing process of CPO and PKO.

Work instructions: Quality Manual. Activities performed by the laboratory (Ex.: Procedure for the analysis of oil acidity).

Records:

Productivity records were reviewed: Example. Juillet 2016. Notebook for Zone II. Semaine du 04 au 09 juillet. The records are kept at a notebook and indicates the following: date of entrance, 04 N. of ticket, 1683 (coming from the field) entry hour, 14:35 departure hour, 14:50 Zone the fruit is coming from, II Tractor ID, JD6 Lots, 31=11, 35=21, 34=21 DF, 41/41 NR,53/53 PR 1159/1159 PM, 22,64 PB, 7000 (gross weight) PV, 5800 (only truck) PNAT 1200, (FFB weight) TJ, 1200 Accumulated volume: 1 151 010 kg

Purchasing and goods in The company only processes the FFB produced on There is a weighting scale at the entrance of the mill YES their own certified supply base. No FFB is where all FFB coming in are weighted and the origin purchased to third parties. recorded. As only the own company certified FFB comes in, the number of the Zone/ Area and parcel Overproduction has not occurred yet but the is recorded. company will notify the certification body There has not been overproduction yet. The average immediately is there is a projected overproduction. of FFB produced per hectare per year is of 3.4 mt. Record keeping There are daily records of FFB received and .The site keeps daily records of certified FFB YES processed. entering the mill and certified CPO and PKO produced. Every month a production balance report Daily records of CPO and PKO produced. is generated and it contemplates the amount of FFB received and CPO produced and sold and PKO Updated sales records of CPO. The totality of the produced and dispatched to the soap factory. production of CPO is sold to a unique cliente in The balance is kept actualized through the Fiche de Switzerland. Stock. The Fiche de Stock for tanks 1 and 2 for CPO were reviewed as same as the Palm Kernel Oil in The totality of the production of PKO is send to the VRAC (55 gal barrels). The Fiche has the following Savonnerie Tropicale S.A. soap factory in columns: Date, Type, ENTRY (Quantity), EXIT Antananarivo. (Quantity) and STOCK (Quantity). The fiches has daily records according to the production days.

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Example: fiche de Stock for CPO Tank N.1. Starting date : may 20 th 2015: Entry: 6 175 kg; Stock 16 064 may 20 th. 2016: Entry: 253 kg; Stock 16 317 May 21 st. 2016: Entry: 9 150; Stock 25 467 kg. May 22 nd. 2016: Entry: 5 923:; Stock 31 390 kg May 22. 2015:Exit : 22 050 kg; Stock 9 390 kg.

Ending date: July 12 ve. 2016: Entry: 1 398 kg; Stock : 114 863 Nov 03rd. 2016: Exit: 4 625; Stock: 109 863 kg …. Other exists Nov. 25 th. 2016: 3 885 kg; Stock: 34 198 kg. Observation: the CPO production stopped in july 2016 and was restarted December 8 th due to fruit seasonality in Madagascar. The palm kernel oil production is maintained throughout the year.

Same type of records are kept for the Palm Kernel Oil . Example: Dec. 1st. 2016: Entry: 253 kg; Exit: 185 kg; Stock: 150 kg Dec. 2nd. 2016: Entry: 315 kg; Exit: 370 kg; Stock: 95 kg Dec 3 rd. 2016: Entry: 214 kg; Exit:185 kg; Stock: 124 kg. Processing 100 % of the produced CPO and PKO is RSPO IP Only certified FFB are received at the mill and only YES certified as the FFB source is 100 % RSPO certified. certified IP CPO and IP PKO is produced at the mill. Only certified IP CPO and IP PKO are storage and transported by the company. The mill has two tanks with a capacity of three tonnes each for the storage of RSPO certified IP CPO. The certified PKO is stored in 55 gallons tanks as well as the palm oil that does not reach the acidity required to be exported. RSPO Rules on Market Communications and Claims Claims & Trademark use There is a RSPO Trademark License for Savonnerie There is use of the RSPO trademark in YES Tropicale S.A. License number : RSPO-1106333. communication materials displayed at the mill/farm Issue 31 march 2015. Computer generated, require office surroundings which complies with the RSPO no signatory from RSPO. rules of communications and claims.

4.2 Non conformity registers. This section gives an over view of new or revised non-conformities raised during this assessment and of action taken to close out non-conformities raised during the previous assessments. Major non-conformities raised during a main assessment will prevent the certification body from making a positive certification decision for the concerned units/products. The NC number is comprised of 2 parts to include the year in which the NC is raised as well as a sequential number.

4.2.1 Verification of previous assessment non-compliances Non-compliance 001-2015 Date raised 07/12/2015 Minor. Minor not upgraded to major because detected issues on the 2015 Major or Minor audit were addressed but other aspects were found on the 2016 audit. Remains open with new issues. 4.7.5 . Non conformity text: The company has procedures related with the Reference of standard prevention and attention of accidents and emergencies as the presence of fire extinguishers in key areas of the mill and offices, maps and evacuation routes and MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 30 de 38

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the presence of a first aid kits in the dock of the Ivondro river. However, the company does not have a specific procedures for evacuation under the presence of natural emergencies or accidents and no first aid kits were available at the site of work (plantation). Full Partial There is emergency procedures in case of accident and clear and comprehensible instructions available for the workers. Records of all accidents are kept daily. However, accidents are not periodically examined. The causes of accidents are not determined in order to take measures to prevent the recurrence of accidents. For evidence the accidents present the following data: AT Injuries 2015 Jan-Sep: 64 Correction at this audit AT Injuries 2016 Jan-Sep: 74 Burns 2015: 3 Burns 2016: 10 Increase in TA over 13.51%.

For first-aid kits they are available at all stations. However, they are not sufficiently equipped: only strips and plaster. According to the Malagasy Red Cross the minimum requirements includes Betadine, gloves, compress, chisel or clip, band, alcohol. Not Corrected

4.2.1. Verification of previous assessment non-compliances Non compliance 002/2015 Date raised 10/12/2015 Major or Minor Minor upgraded to major (not closed during 2016) 5.3.3. Non conformity text: There is a documented waste management plan and disposal plan that considers recycling of mill waste. Empty Fruit Bunches (EFB) and fruit fiber are used as fertilizers in the plantation and fruit fiber is used as fuel for the boiler. There is proper separation of other type of waste Reference of standard as paper, cardboard and plastic are managed in different color bags but there is not an appropriate disposal of this waste due that paper, cardboard and plastic goes to different opencast holes in the grounds of the property. Currently, there is no a waste management plan that includes the recycling of paper, cardboard and plastic. Full January 12 ve. 2017. On January 12 ve 2017 Savonnerie Tropicale S.A. has send to the CB a copy of a contract signed with Group ADONIS Environnement S.A. on January 9 th. 2017. The contract is signed by both parts and establishes that Groupe ADONIS Environnement S.A. will be in charge of collecting and treating the waste generated by Savonnerie Tropicale Huilerie Melville Operation. The contract contains 12 articles explaining, between others, the following issues: Article 1: contract of collection, transport, valorization or elimination of solid and Correction at this audit liquid waste generated by Savonnerie Tropicale uilerie Melville by Groupe ADONIS Environnement S.A. The article includes the list of items to be collected including hidrocarburates, oil filters, air filters, use oils, batteries, contaminated soil, medical waste and other dangerous waste as well as plastic, cardboard and paper. Article2: Groupe ADONIS Environnement will follow the Madagascar law when offering the service. Article 3 defines the color of bags to be use by waste type. Article 4 explains the conditions of the collection including weighting. Article 5 establishes the type of documents that will be generated for

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the service. Article 6 defines the required minimum weight to send a truck. Article 7 indicates the cost of collection and treatment per kilogram of every kind of waste. Article 8 explains the treatment to be done to every kind of waste. Article 9 explains that the cost of treatment will be reviewed one month before the present contract ends. Article 10 defines the contract validity period which starts January 9 th 2017 and finishes January 8 th 2018. Article 11 indicates that representatives of both parts should sign every delivery. Article 12 indicates that Savonnerie Tropicale S.A. will pay in 30 days after receiving the bill. Article 13 establshes the price of gasoil on the date the contract was signed. Due to the above, the non conformity was closed in full. Records will be reviewed during the RSPO ASA 3. Partial Not corrected

4.2.1. Verification of previous assessment non-compliances Non compliance 003-2015 Date raised 10/12/2015 Major or Minor Major 6.1.1 Non conformity text: Eventhough a continuous assessment and monitoring of problems / potential problems/ between the company and the community members and request to the company is done by the company Reference of standard and the inputs are analyzed and solve in an immediate way (as manifested by both parts), there has been no identification of negative and positive social impacts (SIA) beside the environmental impacts that the mill may cause. Full The non conformity established against criterion 6.1.1 during the RSPO ASA 1 audit was closed by the auditee through a corrective action send to the CB on april 15 th. 2016. The following text was written during the ASA 2 audit: A SIA (Social Impact Assessment) issued on April 14th, 2016 including records of meetings is documented. This document is done, after the finding of the “non-compliance 003/2015” during the last surveillance audit on December 2015. This SIA has 65 pages with 11 tables and 35 figures. SIA must take into Correction at this audit consideration others potentials social risks: thefts and/or intrusions, conflicts about the irrigation channel maintenance which jointly used both by the Huilerie de Melville and the communities (ricefields, others agriculture issues,…) lending the land, impacts of the restriction of communities concerning the zebus grazing toward the increase of the replanting area, demography increase inside the property and others.

Partial Not corrected

4.2.1. Verification of previous assessment non-compliances Non compliance 003-2015 Date raised 10/12/2016 Major or Minor Major 6.1.2 Non conformity text: As a Social Impact Assessment was not made there was Reference of standard no participation of affected parties on a Social Impact Assessment.. Full The non conformity established against criterion 6.1.2 during Correction at this audit the RSPO ASA 1 audit was closed by the auditee through a corrective action send to the CB on April 15 th. 2016. MQ III IBD Revisão 26.09.2016 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 32 de 38

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The following text was written during the ASA 2 audit:

As seen on page 55 to 63, the Social Impact Assessment has been done with the participation of affected parties such as internal personnel (DAD, DIREX, Environmental Department, Gender Committee, Health & Safety,…) and the external stakeholders as the Mayor, the traditional leaders (called “Tangalamena”) and the local communities.

Partial Not corrected

4.2.1. Verification of previous assessment non-compliances Non compliance 003-2015 Date raised 10/12/2015 Major or Minor Major 6.1.3 Non conformity text: As there is no identification of negative and positive social Reference of standard impacts there are no documented plans for mitigating the negative ones and improving the positive ones. Full 03/02/2017 The company presented a proper Social Impact Management Correction at this audit Plan. Partial Not corrected

4.2.2 New non-compliances raised at this audit NC number 001-2016 Date raised 07/12/2016 Major or Minor Major Reference of standard 2.1.1 Standard requirement Evidence of compliance with relevant legal requirements shall be available.

a- Results of semestral water quality analysis to the Ivondro river waters before and after discharging the POME, specifically the difference in oil and fats content values between the upstream water and downstream water at the Ivondro river, is out of accepted limits. See indicator 4.4.3 and 5.6.1 for more details. Decret n.0 2003/464 du 15/04/03 important classifications des eaux de surface et reglementation des rejets d effluents liquids b- The government Decret n° 2016- 232 related to the minimum wage in Madagascar issued in Antananarivo on April 5th, 2016 was not implemented. Indeed, the minimum wage for agriculture salary is Ar.730,30/hour, equal to a monthly salary of Ar. 146 060, based on Evidence of non-compliance 200h/month of working time(M1-1A as professional category). During the audit, it was seen when verifying a seasonal worker pay for the period of November 9th to November 15th, 2016,Mrs SOANIRINA LIliane, Id 1843, job title as “Rond & epandage de rafles”, it is noticed that the salary rate used by the HR responsible is lower than the one that the recent law has recommended. Instead of using Ar.4868,66 per day(equivalent of 730,30/hour) on the 2016- 232 government decret, the HR calculates the pay from the worker contract rate which was Ar. 4176,00/day or Ar.522,00/hour. Workers, or at least some workers are not receiving at least the minimum wage established by law. See indicator 6.5.1.

19/02/2017 Date of closing: a) Corrective actions were presented during the ASA 2 audit regarding non compliance related with criteria 4.4.3 and 5.6.1. The mill has

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followed recommendations from two documents: a diagnostic analysis performed to the mill effluents treatment system and a thesis project specifically designed to solve the effluents oil and fat contents at Savonnerie Tropicale Huilerie Melville. Between the followed measures was the construction of a 6 compartment lagoon to treat the effluents , which considers the manual extraction of oils and fats at the first and second ponds. Unfortunately, the lagoon was not working during the audit time as it has not been inaugurated yet. The mill only operates from mid December to mid july each year due to fruit / harvest seasonality. b) The company have made retroactive payments covering the difference between what was paid to Mrs SOANIRINA Liliane and what was due for Government Decree 2016-232. Although it should be checked next year if this situation is still happening.

4.2.2 New non-compliances raised at this audit NC number 002-2016 Date raised 9/12/2016 Major or Minor Minor Reference of standard 5.6.3 A monitoring system shall be in place, with regular reporting on progress for these Standard requirement significant pollutants and emissions from estate and mill operations, using appropriate tools. Eventhough there are records of volumes of waste per type going out, there are no Evidence of non-compliance analysis on progress of this estate and mil pollutant (if the volume has been reduced or not) and measures for its reduction. Date of closing:

4.2.3 Observations Date raised 8/12/2016 4.2.3. Eventhough Savonnerie Tropicale S.A. perform soil analysis in young plant lots or parcelles (0-4 years), the farms does not perform soil analysis in older palms in a regular basis, just when problems are apparent.

Observations Date raised 8/12/2016 4.3.5. There is a drainage plan in place but it was evidenced that some lots are not efficiently drained ( there is lack of secondary drainage channels). There was evidence of swampy areas on the plantation.

Observations 7/12/2016 Date raised

4.7.2.

Risk assessments have been conducted for all operations where health and safety is a health and safety risk. Risk assessment covers all processes and activities of the organization. The precautions or instructions to be taken to control risks are defined and communicated to the workers. However, some workers do not follow instructions. For example, during the visits of the plantations the inappropriate attachment of the poles after stopping the harvest and single workers carrying bunches which appears to be over 45 kg were observed.

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4.2.3 Observations Date raised 6.1.4. The period to review the SIA is not mentioned on the document.

4.3 Lead Auditor Recommendations for the RSPO Principles & Criteria certification.

Grant/ Renewal/ Extension* Maintenance* Suspension Refuse / Withdrawal

Certificate

Justification for the Maintenance after proper closing of 3 major non conformities. Recommendation

* Grant / Renewal / Extension / Maintenance, in the case of open Minor nonconformities, assumes that the nonconformities will be cleared as agreed OBS: The final decision whether the company will be granted with the RSPO P&C certification or not, shall rely upon the certification body, after reviewing the audit documentation and taking in account the lead auditor’s recommendation.

4.4 Comments for next audit. To perform the audit in the month of January, when the mill is operating. Due to seasonality, the mill stops operation in mid july and starts in mid December each year. To check the correct operation of the effluents treatment lagoon as it was not inaugurated yet during the ASA 2 audit. To check if more seasoning workers are paid according to Government Decree 2016-232.

5. FORMAL SIGNING OF AUDIT FINDINGS 5.1 Acknowledgment of internal responsibility by the Client. I the undersigned, being the most senior relevant management representative of the operation seeking or holding certification, agree with the contents and audit findings as presented in this document .

I also confirm:

 Acceptance of liability in execution of the instructions given.  That this company was made aware that the findings of the audit team are tentative; pending review and decision making by the duly designated representatives of IBD.  That during the closing meeting all agenda items were covered by the lead auditor. Name RAMAROSOM Danick

Position Operating Manager

Signature See attached PDF (ASA 2 AUDIT FINDINGS). Please consider the correct signing date as December 9 th. 2016 instead of December 8th. 2016

5.2 Signing by the Lead Auditor. I the undersigned, being the lead auditor, confirm that this report is an accurate record of the findings and of the closing meeting. I further confirm that the summary of the findings as presented are a true representation of the actual findings of the audit team. Name Ingrid Ayub Position Lead Auditor Signature

Date December 9 th. 2016

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6. Major non-compliances follow-up actions (exclusive use of IBD decision maker) Verification of effectiveness by:

Follow-up on-site audit: On-site review and evaluation of the introduction, implementation and effectiveness of non- compliance(s) correction and corresponding corrective actions.

Desktop audit: Document assessment of root cause analysis and evidence of corrections and corrective actions submitted to the certification body.

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