Bogotá, December 4th 2015

Mr. RAVIN KRHISNAN Complaints Coordinator Roundtable on Sustainable Palm Oil

Dear Mr Ravin,

In the following pages you will find Extractora La Gloria and Hacienda La Gloria response to the complaint presented by Asocol, Asocadar and three Colombian politicians.

In accordance to our transparency policy, we answered each allegation in detail, providing all the documents to support our statements. However, if you need any further details or information, please do not hesitate to contact us. Our priority is to clarify this issue.

Best Regards,

Extractora La Gloria Team

A. Description of the name, address and location, and nature of the company being complained about.

The information of Extractora La Gloria presented in the complaint is not correct. Extractora La Gloria is a simplified stock company registered in the Chamber of Commerce of (not in ), and its domicile is at kilometer 5.5 of the road that from the township of La Mata conducts to the municipality of La Gloria, according to the certificate of incumbency attached. SEE ANNEX 1 B. Description of the action taken by me/us to try to settle the issues (please provide details based on chronological event). Extractora La Gloria responds to each one of the points presented: 1. The former Hacienda Bellacruz- today Hacienda La Gloria- occupies 9,000 hectares in the municipalities of La Gloria, and , in southern . Many of the palm oil crops processed by the La Extractora La Gloria plant are located in this area, formed out of several lots registered between the 1930s and 1970s. The Marulanda Ramírez family consolidated La Hacienda, first on behalf of ALBERTO MARULANDA GRILLO and CECILIA RAMIREZ DE MARULANDA, and later on behalf of the company M.R. INVERSIONES LTDA, today M.R. DE INVERSIONES S.AS (ownership history and no-lien certificate No. 196-10389).

Hacienda La Gloria is a premise legally different and independent from the so called Hacienda Bellacruz. Hacienda Bellacruz was a 9,000-hectares premise identified with land registration number 196-1038. The shareholders of the company Grupo Agroindustrial Hacienda La Gloria purchased an area of 5,830 hectares of those 9,000 hectares, duly identified with a land registration number different and independent from the one of Hacienda Bellacruz. In addition, 2,500 hectares were purchased in the province of Bolívar. The addition of these two, 5,830 plus 2,500 hectares is what is now known as Hacienda La Gloria. Consequently, today’s Hacienda La Gloria is different from Hacienda Bellacruz, which private property is duly certified by competent authorities.

SEE ANNEX 2

2. Due to irregularities in Hacienda Bellacruz’s ownership and transfer history, the Inspector General of began a clarification process for the property with Incora1 (today Incoder).2 In 1994, the process was completed, declaring that the Hacienda contained seven lots with 1,500 hectares of fallow land (Resolution 1551 of 1994). According to Colombian law (Law 160 of 1994), the Constitution dictates that fallow lands must be used to guarantee poor rural populations’ (small rural farmers, indigenous and Afro-descendant peoples) access to the land.

In 1990, the INCORA (currently INCODER) initiated a process called “Clarificación de títulos desde el punto de vista de la propiedad” (Clarification of titles from the point of view of the ownership) on Hacienda Bellacruz premises, which ended with the issue of Resolution No. 1551, dated April, 20, 1994.

However, this Resolution has no legal effect since, by means of Resolution 0334 dated February 19, 2015 the INCODER decided to resolve the loss of legal validity of that Resolution (Resolution 1551) leaving it with no effect. Therefore, the private nature of former Hacienda Bellacruz is confirmed, and so of the 5,830 hectares part of Hacienda La Gloria. SEE ANNEX 3

3. Since 1986, farmers have occupied and customarily owned part of said fallow land, which is comprised of 13 rural districts or administrative units.

The are no barrens at Hacienda La Gloria according to the certificate of actual sale, which shows the chain of transfers of titles of private property according to Colombian legislation. Also, it is clarified that the premises know nowadays as Hacienda La Gloria, from 2008, have only been occupied by Grupo Agroindustrial Hacienda La Gloria S.A. Sucursal Colombia and the people authorized by it.

4. Colombia has experienced more than 60 years of armed conflict, exacerbated by the actions of paramilitary groups. A number of paramilitary groups were active in Cesar, including the Self- Defense Forces of Santander and Southern Cesar (Autodefensas de Santander y Sur de Cesar), which began operations in Pelaya in 1996 with support from CARLOS ARTURO MARULANDA, son of ALBERTO MARULANDA GRILLO and CECILIA RAMIREZ DE MARULANDA, according to the ruling convicting JUAN FRANCISCO PRADA MÁRQUEZ, his former commander.

The South of the province of Cesar is one of the areas with more history of violence in the country. Violent events by the guerillas, para-military, and criminal bands have been documented. On the date of the purchase of these premises, and after a due diligence process, it was found that there was no decision at all against the Marulanda family.

It is important to clarify that Grupo Agroindustrial Hacienda La Gloria and Extractora La Gloria have no commercial or personal relationship with the Marulanda Ramírez.

5. Hacienda Bellacruz, the Company that is the subject of this complaint, has been at the center of multiple human rights violations. Beginning February 14, 1996, paramilitary groups with support from the military and the police, insulted the area´s occupants, burned their houses and destroyed their crops, forcibly displacing an estimated 480 families. The paramilitary groups assassinated peasant leaders Jaime Laguna, Eduardo Donado and brother Eliseo and Eder Narváez Corrales. According to affidavits there are mass graves on the state. Domestic judicial authorities and international human rights bodies have verified these claims. Despite warnings from the Inter-American Commission on Human Rights in 1999, impunity prevails.

The facts referred to in the 1996 complaint when Hacienda La Gloria purchased 5,830 hectares of land, duly entitled and with no pending or legal problems, in 2008. The shareholders knew that this was a region affected by the armed conflict like almost all the lands in Colombia, but selected this area because it was geographically fit for the cultivation of palm, and because it generates opportunities in a region where there were no opportunities.

If at any time the previous owners committed any irregularities in the lands part of La Gloria today, the justice should condemn them, and Grupo Agroindustrial Hacienda La Gloria would be the first one to support that the claims that some people have made on these topics should be clarified. But we cannot condemn an entire area due to the fact that the conflict has occurred there and hinder that new opportunities for formal development may come.

SEE ANNEX 4 6. On October 7, 2010, MR Inversiones transferred the title of Hacienda La Gloria to Fiduciaria Cafetera S.A, which then formed the Fideicomiso Dolce Vista. Since 2008, the defunct Panamanian company La Dolce Vista Inc owned more than 45% of Sociedad MR Inversiones’ shares, through La Dolce Vista Sucursal Colombia.

The premise Hacienda La Gloria was in charge by MR DE INVERSIONES S.A.S. (the company that owns the premise) to Grupo Agroindustrial Hacienda La Gloria S.A. for economic exploitation through an agricultural project for the cultivation of palm. In order to obtain the necessary resources for the financing of the project and making the investments in new palm crops, Grupo Agroindustrial Hacienda La Gloria S.A. Sucursal Colombia requested a loan from Banco Davivienda in 2010. As collateral of this loan, Davivienda required to constitute a guaranty irrevocable commercial trust. To this end, MR DE INVERSIONES S.A.S. had to transfer the premise Hacienda La Gloria to Fiduciaria DAVIVIENDA. Grupo Agroindustrial Hacienda La Gloria S.A. owns 100% of the shares of the company MR DE INVERSIONES S.A.S. since 2008.

SEE ANNEX 5

7. La Extractora La Gloria was established in 2010 to develop, produce, commercialize, profit from and carry out agro-industrial activities.

Correct, Extractora La Gloria is a company legally incorporated and existent according to the laws of the Republic of Colombia, incorporated by means of private document dated February 3, 2010, and registered with the Chamber of Commerce of Bogota on February 8, 2010, which main purpose is the production of raw palm oil, palm kernel oil, or palm kernel cake. It is currently registered with the Chamber of Commerce of Aguachica.

8. La Extractora La Gloria SAS, Frigorífico La Gloria SAS and MR Inversiones SAS6 make up the GRUPO AGROINDUSTRIAL HACIENDA LA GLORIA S.A. SUCURSAL COLOMBIA, known until 2011 as LA DOLCE VISTA SUCURSAL COLOMBIA. The parent company of GRUPO AGROINDUSTRIAL HACIENDA LA GLORIA SUCURSAL COLOMBIA is GRUPO AGROINDUSTRIAL HACIENDA LA GLORIA, registered in Panama. Their shareholders are Tigris Energy (75%), whose partners are Strategic Venture and Sinergy- through a “special purpose vehicle known as Fundación HJDK” registered in Panama-; Bio Palm Corp (13.57%) and Estrategic Venture (11.43%). Despite the fact that companies within the group share registered offices and legal representatives, the business group’s existence has not been declared under Colombian corporate and tax law (see figure).7

Grupo Agroindustrial Hacienda La Gloria S.A. Sucursal Colombia is a branch of a foreign company incorporated according to the laws of Panama, incorporated in Colombia by means of public deed No. 370 dated February 25, 2009 granted by Notary Office 43 of Bogota, and domiciled in Bogota, as registered in the Certificate of the Chamber of Commerce.

In turn, Grupo Agroindustrial Hacienda La Gloria S.A. is the sole shareholder of the following Colombian companies: MR DE INVERSIONES S.A.S., FRIFORÍFICO LA GLORIA S.A.S., and EXTRACTORA LA GLORIA S.A.S.

MR DE INVERSIONES S.A.S. and FRIGORÍFICO LA GLORIA S.A.S. are inactive companies, since they do not exert their corporate purpose. They currently have only some trust rights on some of the land. Grupo Agroindustrial Hacienda La Gloria S.A. Sucursal Colombia is in charge of the crop of palm oil. On the other hand, EXTRACTORA LA GLORIA S.A.S. is the owner of the premise where the extractor plant is, which was declared special and permanent agro-industrial free trade area (zona franca permanente especial agroindustrial), and the corporate purpose is the production of raw palm oil.

All these companies pay taxes accordingly, or those they are obligated to, according to valid legislation and the place where they are domiciled.

9. Due to the lack of information provided by GRUPO AGROINDUSTRIAL HACIENDA LA GLORIA; the fact that many of the companies that make it up are registered in countries like Panama and the Cayman Islands, which are or have been on the OECD’s list of tax havens and/or off-shore jurisdictions; and the existence of financial vehicles like Fundación HJDK; it is not possible to identify all the partners and investors and the origin of the capital that supports EXTRACTORA LA GLORIA SAS’ legal activities.

The capital of Extractora La Gloria S.A.S. comes from Grupo Agroindustrial Hacienda La Gloria S.A. Sucursal Colombia, which is the sole shareholder of the company Extractora La Gloria S.A.S. The corporate structure is the one determined in the previous paragraph. The structure of Grupo Agroindustrial Hacienda La Gloria and of Extractora La Gloria is absolutely transparent, and has been revealed in several occasions to public and private entities, such as: National Tax and Customs Office (Dirección de Impuestos y Aduanas Nacionales - DIAN), Ministry of Commerce, and banks, among other.

The main shareholder of Fundación HJDK is Mr. Germán Efromovich, president of the group Synergy.

10. LA DOLCE VISTA, today GRUPO AGROINDUSTRIAL HACIENDA LA GLORIA SA, did not exercise due diligence when it acquired the former Hacienda Bellacruz in 2010. It did not research the property history, including the ownership history and no-lien certificate, identified with registration folio number 196-1038, which included Incora’s 1994 resolution declaring the existence of fallow land within the estate (see ownership history and no-lien certificate).8 In that matter, Incoder concluded that: “(…) FIDEICOMISO DOLCE VISTA only needed to carefully read registration folio number 196-1038 to know that annotation 22 referenced Resolution No. 1551 from April 20, 1994, through which the General Management of Incora declared the following lots fallow: LOS BAJOS, CAÑO NEGRO, SAN SIMÓN, VENECIA, POTOSI, MARIA ISIDRA y SAN MIGUEL” (see Incoder document).

In 2008, a due diligence process was carried out with a well-known law firm and a reputed forensic investigation firm, where documents related to the premises and shareholders were studied, and which concluded the legality of the right of private property that approved the purchase of the companies which own them. Consequently, current shareholders of these companies are good-faith owners and have all the titles and documents that credit the private property on those premises, where the agro-industrial project is developed today.

In addition, all financial entities that support the project have carried out studies on the titles of the premises as requirement of the loan. Also, the Colombian government has deeply studied the company and goods before granting the status of permanent free trade area to Extractora La Gloria. It is important to clarify that Resolution 1551 was not registered in the main page registry (196- 1038), and this is certified by the Superintendence Office of Notary and Registry (Superintendencia de Notariado y Registro).

11. The year that LA DOLCE VISTA acquired the property, Incoder began recovering unduly occupied fallow lands. During this process, it determined that of the Hacienda’s 1,500 hectares declared fallow in 1994, 1,200 remained within the property (Resolution 0481 of 2013). In 2015, Incoder modified this decision (Resolution 334), annulling the clarification process for the property. In October 2015, Incoder restarted the property clarification process (Auto 179, October 26, 2015).9 Administrative inconsistencies within the State’s land agency do not exempt companies from demonstrating “legal ownership” of the land.

As mentioned previously, Hacienda La Gloria is private property. Regarding the order for the re- initiation of the process for the clarification of titles from the point of view of the ownership, the company will be ready to face this new process with the absolute certainty of the inexistence of barrens within Hacienda La Gloria. 12. The Colombian state, in compliance with its international duties to recognise the rights of victims of forced uprooting, committed itself to provide comprehensive care and reparations (Laws 387 of 1997 and 1448 of 2011). Land restitution to victims of dispossession or forced abandonment is a state obligation. Companies have a responsibility to contribute to the process within the framework of the UN Business and Human Rights standards. Farmers at the Hacienda Bellacruz requested that the Land Restitution Unit return and formalize their ownership of the land from which they had been violently expelled. These farmers had not been able to return to their land due to the State’s inconsistencies and the palm oil plantations built by Extractora La Gloria and their investors.

Extractora La Gloria and Hacienda La Gloria are good-faith owners, have all titles and documents that credit the private property on the premises where they develop the corporate purpose today. In 2008, a due diligence process was carried out where the documents related to the premises were studied, which concluded the legality of the tight of private property that approved the purchase of them. Therefore, there are no reasons for a conflict in that sense.

In any case, these companies are respectful of the laws and decisions of the State, so they are willing to submit any documentation required in the modality of inverted burden of evidence proposed by the government in the project for the restitution of land.

13. For the reasons mentioned, the palm plantation and extraction mil were not built with the free prior and informed consent of the claimant farmers, the main party affected. In addition, the Business Group failed to create spaces for dialogue and negotiation, even though it is a known fact that farmers have demanded rights over Hacienda La Gloria’s plots since 1990.

According to national regulations, since it is private property, the free, previous, and informed consent only applies to indigenous communities and ethnical groups found in the limits of the company. The company has the certificates of the Ministry of Internal Affairs that certify that there are no protected communities in the premises of HLG. In addition, we have the map of consuetudinary rights identified, as well as the proceeding for their identification, having it clear that in no case was there a consuetudinary right for the use of land, since it has always been private property, as registered in the certificated of actual sale. However, in November 2011, the year previous to the launching of the extracting company (Extractora), the company called for a dialogue round table and work with local authorities and leaders for the socialization of the project, and to respond the inquiries the community may have.

SEE ANNEX 6, ANNEX 7, ANNEX 8, AND ANNEX 9

14. The municipalities where Extractora La Gloria operates are considered within the so-called high-risk zones, due to the presence of armed groups, the State’s institutional weakness, corrupt practices, and high levels of poverty and vulnerability. In 2012, a self-proclaimed “anti- restitution army” formed but was denounced as an illegal armed group that has threatened members of ASOCOL. Leaders of the association have reported threats from the private surveillance and security company “Seguridad Velez” which provides security services to the business group of which Extractora La Gloria is a part.

The influence area of Hacienda and Extractora La Gloria is, with no doubt, one of the most affected areas in the country. The company, as neighbor of the region, has been in charge of denouncing any irregular fact it may witness, and channeling this information so that competent national authorities investigate and act according to protocols.

The company “Seguridad Vélez LTA.” is a security company legally incorporated in Colombia, and has not threatened any member of the community of the mentioned associations ever. Seguridad Vélez provides private security services in the perimeter of the property. There is a clause of security and human rights in its agreement, which states:

“Security and Human Rights”. The Contractor’s proceedings and policies must be consistent with human rights and International Humanitarian Law. The Contractor’s staff must be duly trained to comply with these proceedings and policies. The Contractor will be responsible of the training of its staff on human rights.

The Contractor guaranties and agrees to comply with the following provisions regarding the activities of the Agreement herein:

The Contractor and affiliates, as well as relevant representatives, shareholders, directors, delegates, employees, and any other person or entity acting on behalf of any of them, must:

 Respect and comply with human rights and International Humanitarian Law, and refrain from hiring any person convicted for the violation to human rights and International Humanitarian Law  Services on the Agreement herein must be provided according to applicable laws and consistently with all applicable laws, and consistently with human rights and International Humanitarian Law  Regarding the agreements related to the provision of security services, the Contractor’s entire staff assigned to the Agreement must have receive training in human rights, before the initiation of service, and receive periodical re-training during the validity of the Agreement herein, at least every (12) months.  The Contractor shall inform its staff of the need of reporting violations to human rights and International Humanitarian Law, and shall keep the Contacting Party informed on those reports in the event of occurrence.”

It is important to mention that, after three decades of poverty and violence, nowadays there is an agro-industrial project that amounts USD$125 million dollars, which generates around 1,000 dignified jobs, which have re-activated the local economy. Hacienda La Gloria has led social development programs regarding topics of housing, health, and education that have helped around 40,000 individuals, have formed productive alliances with more than 90 farmer families that own their own land, and have successfully produced and created environmentally sustainable crops, as well as an important offer of exportable products.

SEE ANNEX 10

15. On June 30 2015, facing delays in the fallow land recovery process and the lack of a state response to their petitions, approximately 180 families decided to voluntary return without institutional accompaniment, to the plots in La Hacienda Bellacruz –today La Gloria- which Incora had declares fallow in the 1990s. The following day, the police and private armed staff subjected these families to a violent process of eviction. A person that the farmers have identified as a non-demobilized paramilitary was also present.

On June 30, 2015 a group of people invaded the premises of Grupo Agroindustrial Hacienda La Gloria. The invasion to private property, in Colombia, is considered a “de facto” situation and is ranked illegal. Grupo Agroindustrial Hacienda La Gloria submitted the documents that credit the ownership of those premises to competent authorities, and denounced the illegal act.

The National Police of Colombia and the Major of the Municipality of La Gloria, acting as competent authorities, proceeded with a pacific eviction along with the Municipal Inspector, Secretary of Family, and other entities that intervened to guaranty the integrity of invaders. The official report of the National Police evidences that it was an eviction that followed all protocols of law.

In addition, the community of Simaña, a township close to the place of the invasion denounced, with several authorities, that these invaders came with weapons, and irrupting the tranquility of inhabitants, causing fear among the community.

SEE ANNEX 11 AND ANNEX 12

16. The business group of which Extractora La Gloria is a part has not publicly denounced these aggressions against the claimants’ human rights. On the contrary, Germán Efromovich, stockholder of the business group asserted in the press that the murder of the farmers claiming rights to the land was not his problem. The group also began legal action against the protection measures granted by the Constitutional court to the safeguard the integrity of the number of claimants to the fallow land, displacement victims that had formed ASOCOL an ASOCADAR. The decision was substantiated by the existence of a possible threat or impact on the right to life, the right to this process and to the land.

Hacienda La Gloria has denounced any irregularity it has found in the area with competent authorities, and condemns any action that violates people’s integrity and life.

Thanks to the work of the communities, the company has an excellent relationship with communities of the area of influence. Also, the quality of employment offered, added to good conditions, make that we can count with the support of workers. The Constitutional Court has clarified that this type of facts are illegal, and by means of document A-441 of 2015 it has condemned the legal representatives and members of farmers’ associations ASOCOL and ASOCADAR to refrain from performing any conduct that implies an irregular entry to the premises of Hacienda La Gloria.

SEE ANNEX 13

17. Inside Hacienda La Gloria sits the Forest Reserve Buffer Zone of the upper Caño Alonso River basin,14 declared as such on January 29, 1987. According to farmers’ complaints as well as reports from Corpocesar (regional environmental authority) and the Ministry of Environment, there is no environmental baseline or Environmental Management Plan for the forestry reserve, as required by environmental regulations. The lack of such instruments does not exempt EXTRACTORA LA GLORIA from its responsibility to prevent, mitigate and repair the environmental impact of its business operations. The palm facilities have affected the reserve zone’s buffer area15 and have caused forest cover to decrease from 445 to 77 hectares. In February 2014, the Comptroller for Environmental Affairs began an investigation to determine the environmental impact of the palm monoculture on the Forest Reserve Buffer Zone of the upper Caño Alonso River basin and monitor compliance with environmental obligations in the area affected by Hacienda La Gloria. The area’s inhabitants have also warned about the decline in the Caño Aloso riverbeds and the drying up of the Singararé, El Carmen and Simaña streams, sources of water for human and agricultural consumption.

Hacienda La Gloria has respected the areas for amortization, and actively contributes with the care and recovery of the Forrestal Reserve of High-Basin of Caño Alonso (Reserva Forestal de la Cuenca Alta de Caño Alonso). It is currently executing a protective, compensatory re-forestation plan (in approximately 600 hectares) inside the reserve, and other areas thereof establishing corridors for biological connectivity of the area with other areas of environmental interest existing in the area, and cooperating, this manner, with the improvement plan of it, established by the corporation.

Denunciations submitted by third parties have never prospered because HACIENDA LA GLORIA and EXTRACTORA LA GLORIA have always complied with valid environmental regulations and have all required permits.

SEE ANNEX 14

Unfulfilled and/or violated principles

In addition to voluntary initiatives in favor of the environmental, human rights, labor stability, and transparency, Hacienda and Extractora La Gloria started to work 2 years ago to align all processes to RSPO standards. In 2014, the first pre-auditing with Control Union was done, evidencing a 70% progress of verification means. The companies have worked non-stop to achieve 100% adjustment to these principles and criteria, finally achieving the certification in 2016.

Following, the status of the company in each of the principles mentioned in the complaint is showed:

Principle 1.1 The commercial information of Extractora La Gloria and Hacienda La Gloria lies in the certificates of the Chamber of Commerce. These documents are public and anyone can access them.

The structure of the company previously provided has been submitted each time an interested party (such as a bank or authority) has requested it.

Both companies have a communication and consultation, and PQRS proceeding to facilitate the disclosure and reception of information.

SEE ANNEX 1 AND ANNEX 15

Principle 2.1

Hacienda La Gloria has the forest benefit and use permits issued by Corpocesar, which is the autonomous body that regulates environmental legislation in the region.

There is a legal matrix where all applicable rules are evidenced, and there is a mechanism for the relevant follow up process.

SEE ANNEX 14

Principle 2.2

Hacienda and Extractora La Gloria have the documents that prove the legal ownership of land, as well as the clear delimitation. These same documents show the legal purchase of land, without affecting any consuetudinary or use right.

Likewise, the company has made important contribution to the community and worked in protecting consuetudinary rights of the inhabitants of the region.

SEE ANNEX 2, ANNEX 4, AND ANNEX 7

Principle 2.3 Since it is private property, the free, previous, and informed consent only applies when there are indigenous communities and ethnical groups protected living in the premises. The company has the certificates of the Ministry of Internal Affairs showing that there is no presence of these groups within the limits of Hacienda La Gloria. In addition, a map of consuetudinary rights identified was prepared along with the community, showing that in no event there was a right of use of land since it has always been private property, as registered in the certificates of actual sale.

SEE ANNEX 2 AND ANNEX 7

Principle 4.4 Hacienda La Gloria acts as protector of Reserva de Caño Alonso. This XXX-hectare territory has not been affected; on the contrary, we have worked on protection and recuperation. The Environmental Autonomous Corporation of Cesar (Corporación Autónoma Ambiental del Cesar), which is the environmental authority has made several control and follow up visits, always certifying the correct management of the reserve.

The company has a program for saving and the efficient use of water that shows the commitment with the correct use of natural resources.

It is important to mention that Extractora La Gloria is ranked as Clean Development Mechanism (CDM) by the UNFCCC, thanks to the ZWAB system (Zero Waste Aereated Bunker) that allows an extraction process with zero contaminant residues.

SEE ANNEX 14, ANNEX 18, AND ANNEX 17

Principle 5.2

There is evidence that there are no plantations within the reserve; on the contrary, the company is recuperating the reserve affected by local communities previous to the arrival of the company to the area.

There is an AVC study by a RSPO-authorized biologist that proves that the company has not affected any AVC; on the contrary, the recuperation of the reserve and corridors key for the protection of species is included in the management plan.

ANNEX 14 AND ANNEX 19

Principle 6.4

The company has a proceeding to identify consuetudinary rights and people with compensation right; however, it was established that there are no consuetudinary rights or legal rights for the use of land within consuetudinary rights, since the purchase of land was finally sold, and this is legally demonstrated as private property.

The company has a PQRS system implemented where all claims of the community are answered. However, when we talk about legal processes with the State, where communities are not involved, management is applicable to the nature of the process. There is a negotiation process with the communities for cases within the community.

ANNEX 2 AND ANNEX 8

Principle 6.1.3

The company has a comprehensive policy with respect to human rights. In addition, several initiatives included in Progress Communications of the Global Agreement (Comunicaciones de Progreso del Pacto Global) show the legitimate preoccupation of Extractora and Hacienda La Gloria for the wellbeing and protection of employees and communities.

SEE ANNEX 4 AND ANNEX 21

C: Other persons contacted by us in the attempt to settle the issues

Hacienda La Gloria and Extractora La Gloria are respectful of public institutions. For that reason, it has gone forward to local, regional, and national authorities so they certify and solve any kind of disagreement. Shareholders and collaborators abide by and will abide by any decision taken with respect to the operation.

D: Any other relevant facts and/or materials to support the complaint

Annex 1: Certificate of Incumbency - ELG Annex 2: Certificate of Actual Sale - Hacienda La Gloria – 196-39010 Annex 3: Resolution 0334 dated February 19, 2015 Annex 4: Copies COPs Annex 5: Auditor’s Certificate Annex 6: Certificates of the Ministry of Internal Affairs on the non-existence of protected communities within the limits of the premises Annex 7: Map of Consuetudinary Rights Annex 8: Proceeding for Consuetudinary Rights Annex 9: Minutes, firms, and pictures of the meetings for the socialization of the project of the extractor company Annex 10: Letters sent to police stations and the Major Annex 11: Minutes of the police on the eviction performed Annex 12: Communication of Inhabitants of Simaña Annex 13: Document A-441 of 2015 Annex 14: Corpocesar Reports and Certification Annex 15: Proceeding for communication and consultation, and PQRS Annex 16: Forest Benefit and Use Permits Annex 17: Program for saving and the efficient use of water Annex 18: CDM Document Form Annex 19: AVC study Annex 20: Proceeding for the negotiation with communities Annex 21: Human Rights Policy