Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM 7/3/20 2 59 PM

Rapid Response Report 29

Rapid Response Thu 7/2/2020 4:25 PM To: [email protected] Cc: [email protected] ; [email protected] ; Phil Aikman ; Asha Sharma

(jj 1 attachments (1 MB) RR Report 29 2020 final vers a.pdf;

Dear Michelle -

Today, we are releasing Mighty Earth's Rapid Response report 29. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia. The following are new cases of deforestation and/or peatland development (in order of appearance in report 29) with known supply chain links. They are listed by Group, if known, then by concession name. Parna Raya: PT Mitra Andalan Sejahtera Rimbunan Hijau: PJP Pelita Lundu Plantation Sdn Bhd

The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 29) with known supply chain links: Capitol Group: PT Medco Papua Hijau Selaras Widya Corporation: PT Mulia Inti Perkasa Rimbunan Hijau: Poh Zhen Sdn Bhd

The report also includes 4 new cases and 22 repeat cases of deforestation and/or peatland development that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because. For the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports. Mighty Earth expects that traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their ‘no buy’ lists. Please confirm this action will be taken.

Please see attached a copy of the Rapid Response report for full information, including GPS coordinates, satellite imagery showing recent deforestation and peat development, and what we know regarding supply chain links and company ownership. The supply chain links, which are based on mill disclosures and recent export data, are: Parna Raya appears to sell (directly or indirectly) to AAK, Bunge, and Fuji Oil. Rimbunan Hijau appears to sell (directly or indirectly) to AAK, ADM, BLD, Bunge, , Felda IFFCO, Fuji Oil, IOI, KLK, , , and Wilmar. Capitol Group appears to sell (directly or indirectly) to AAK, ADM, Bunge, Cargill, Fuji Oil, Neste, Olam, Sime Darby, and Wilmar. Widya Corporation appears to sell (directly or indirectly) to AAK, Astra, Bunge, Cargill, Fuji Oil,

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Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM 7/3/20 2 59 PM

Olam, Sime Darby, and Wilmar.

As mentioned in the cover email with Rapid Response report 13 and subsequent emails, Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. How palm oil traders and biofuel companies address such grievances will be assessed as part of our Rapid Response Trader Tracking’ grievance performance system.

Please provide us with an update on your engagement, or if your grievance tracker has been updated recently on these cases, let us know so we can review. We ask for your reply no later than July 16, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond.

Thanks, and stay safe! Asha

ASHA SHARMA I DIRECTOR I miahtvearth.org [email protected] Follow us: Facebook I Twitter

The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies ’ work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.

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Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM 7/3/20 3 00 PM

Rapid Response Report 29

Rapid Response Thu 7/2/2020 4:34 PM To: [email protected] [email protected]> Cc: [email protected] ; [email protected] ; [email protected] ; Phil Aikman ; Asha Sharma

(jjj 1 attachments (1 MB) RR Report 29 2020 final vers a.pdf;

Dear Laura -

Today, we are releasing Mighty Earth's Rapid Response report 29. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia. The following are new cases of deforestation and/or peatland development (in order of appearance in report 29) with known supply chain links. They are listed by Group, if known, then by concession name. Parna Raya: PT Mitra Andalan Sejahtera Rimbunan Hijau: PJP Pelita Lundu Plantation Sdn Bhd

The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 29) with known supply chain links: Capitol Group: PT Medco Papua Hijau Selaras Widya Corporation: PT Mulia Inti Perkasa Rimbunan Hijau: Poh Zhen Sdn Bhd

The report also includes 4 new cases and 22 repeat cases of deforestation and/or peatland development that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because. For the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports. Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their ‘no buy’ lists. Please confirm this action will be taken.

Please see attached a copy of the Rapid Response report for full information, including GPS coordinates, satellite imagery showing recent deforestation and peat development, and what we know regarding supply chain links and company ownership. The supply chain links, which are based on mill disclosures and recent export data, are: Parna Raya appears to sell (directly or indirectly) to AAK, Bunge, and Fuji Oil. Rimbunan Hijau appears to sell (directly or indirectly) to AAK, ADM, BLD, Bunge, Cargill, Felda IFFCO, Fuji Oil, IOI, KLK, Neste, Sime Darby, and Wilmar. Capitol Group appears to sell (directly or indirectly) to AAK, ADM, Bunge, Cargill, Fuji Oil, Neste, Olam, Sime Darby, and Wilmar.

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Widya Corporation appears to sell (directly or indirectly) to AAK, Astra, Bunge, Cargill, Fuji Oil, Olam, Sime Darby, and Wilmar.

As mentioned in the cover email with Rapid Response report 13 and subsequent emails, Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. How palm oil traders and biofuel companies address such grievances will be assessed as part of our Rapid Response Trader Tracking’ grievance performance system.

Please provide us with an update on your engagement, or if your grievance tracker has been updated recently on these cases, let us know so we can review. We ask for your reply no later than July 16, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond.

Thanks, and stay safe! Asha

ASHA SHARMA I DIRECTOR I miahtvearth.org [email protected] Follow us: cacebook I Twitter

The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’ work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.

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Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM 7/3/20 3 01 PM

Rapid Response Report 29

Rapid Response Thu 7/2/2020 4:37 PM To: nasuha [email protected] cnasuha [email protected]> Cc: gifty [email protected] ; nick [email protected] cnick martell- [email protected]>; Phil Aikman ; Asha Sharma

(jj 1 attachments (1 MB) RR Report 29 2020 final vers a.pdf;

Dear Nasuha -

Today, we are releasing Mighty Earth's Rapid Response report 29. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia. The following are new cases of deforestation and/or peatland development (in order of appearance in report 29) with known supply chain links. They are listed by Group, if known, then by concession name. Parna Raya: PT Mitra Andalan Sejahtera Rimbunan Hijau: PJP Pelita Lundu Plantation Sdn Bhd

The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 29) with known supply chain links: Capitol Group: PT Medco Papua Hijau Selaras Widya Corporation: PT Mulia Inti Perkasa Rimbunan Hijau: Poh Zhen Sdn Bhd

The report also includes 4 new cases and 22 repeat cases of deforestation and/or peatland development that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because. For the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports. Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their ‘no buy’ lists. Please confirm this action will be taken.

Please see attached a copy of the Rapid Response report for full information, including GPS coordinates, satellite imagery showing recent deforestation and peat development, and what we know regarding supply chain links and company ownership. The supply chain links, which are based on mill disclosures and recent export data, are: Parna Raya appears to sell (directly or indirectly) to AAK, Bunge, and Fuji Oil. Rimbunan Hijau appears to sell (directly or indirectly) to AAK, ADM, BLD, Bunge, Cargill, Felda IFFCO, Fuji Oil, IOI, KLK, Neste, Sime Darby, and Wilmar. Capitol Group appears to sell (directly or indirectly) to AAK, ADM, Bunge, Cargill, Fuji Oil, Neste, Olam, Sime Darby, and Wilmar. Widya Corporation appears to sell (directly or indirectly) to AAK, Astra, Bunge, Cargill, Fuji Oil,

https //out oo off ce com/ma / nbox/ d/AAQ AD yYz 4NDcyLTgw...QtNDB MSIhYTV LTM4ZWQwZ zN czNQAQAOEMMBaLXdNAuyybpMnGf78%3D Page 1 of 2

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Olam, Sime Darby, and Wilmar.

As mentioned in the cover email with Rapid Response report 13 and subsequent emails, Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. How palm oil traders and biofuel companies address such grievances will be assessed as part of our Rapid Response Trader Tracking’ grievance performance system.

Please provide us with an update on your engagement, or if your grievance tracker has been updated recently on these cases, let us know so we can review. We ask for your reply no later than July 16, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond.

Thanks, and stay safe! Asha

ASHA SHARMA I DIRECTOR I miahtvearth.org [email protected] Follow us: Facebook I Twitter

The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies ’ work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.

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Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received Received

/ *

July Report by by

NSD/FARA NSD/FARA

2020

29 RAPID Palm

Registration Registration

Unit Unit Oil

RESPONSE 07/03/2020 07/03/2020

Report

3:17:43 3:17:43 MIGHTY

PM PM V

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EARTH Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM

Table of Contents Cases identified using Sentinel imagery

Indonesian Companies

New Cases Parna Raya Group: PT Mitra Andalan Sejahtera 4

Unresolved Cases Capitol Group: PT Medco Papua Hijau Selaras 6 Widya Corporation: PT Mulia Inti Perkasa 8

Sarawak Companies

New Cases Rimbunan Hijau: PJP Pelita Lundu Plantation Sdn Bhd 10 Unresolved Cases Rimbunan Hijau: Poh Zhen Sdn Bhd 12

Additional cases identified using filtered GLAD alerts

New Cases - Unknown Supply Chain Links

Kayu Lapis Indonesia: PT Inti Kebun Lestari Block I 14 PT Az-Zhara Plantation: PTTaringin Perkasa 14 First Borneo Group: PT Borneo International Anugerah 14 Ciptana Group: PT Cipta Papua Plantation Block A 14

Repeat Cases - Known Supply Chain Links

Mulia Sawit Group: PT Persada Era Agro Kencana 15 NPC Resources Bhd: PT Sumber Alam Selaras 15 Samling Group: PTTunas Borneo Plantations 15 Shin Yang Group / Sarawak Oil Palms Bhd: Shin Yang LPF 0018 15

Repeat Cases - Unknown Supply Chain Links

Unknown Group: PT Menthobi Mitra Lestari (formerly owned by PT Bakrie Sumatra Plantations Tbk 1 <5 First Borneo Group: PT Wahana Hamparan Hijau 15 JSK International Co Ltd (Korea): PT Future Agropia Indonesia 16 Korompisfamily: PT Berau Karetindo Lestari 16 Salim/IndoGunta: PT Rimbun Sawit Papua 15 Salim/IndoGunta: PT Rimbun Sawit Papua 16 Starmas Sentosa Mandiri: PT Agrindo Sukses Sejahtera 16 Alas Kusuma Group: PT Kusuma Alas Sari 16 Unknown Group: PT Triomas Forestry Department Indonesia 16

wYN) MIGHTY EARTH 2

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Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases - Unknown Supply Chain Links (continued) Salim/IndoGunta: PT Rimbun Sawit Papua 16 Unknown Group: PT Artanusa Agrindo 16 JKS International Co Ltd (Korea): PT Future Agropia Indonesia 16 Hangzhou Jinjiang Group: PT Putra Sari Lestari 16 Unknown Group: PT Sentosa Kalimantan Jaya 16 Bukit Berlian Plantation Group: PT Ginang Fohu Plantation 17 Bukit Berlian Plantation Group: PT Ginang Fohu Plantation 17 Venture Resources Pte. Ltd: PT Sanggam Harapan Sejahtera 17 Kwantas Corporation Bhd: Miracle Harvest Sdn Bhd 17

Supply chain information: Supply chain information included in Rapid Response reports is based on the latest public versions of mill disclosures, recent export data and grievance logs. Mighty Earth encourages companies to send updated versions of mill disclosures as soon as they become available and to share any decision to suspend relations with a given group/company listed in those mill disclosures; please send to [email protected].

Mighty Earth is now including biofuel companies in the supply chain tables of Rapid Response reports, as these companies have both direct and indirect trading relationships with groups highlighted in these reports and should be filing grievances on these cases. These biofuel companies are listed in the "Traders and Biofuel Companies" tables. S~a\ l/vA) MIGHTY EARTH

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New Case

Group: Parna Raya PT Mitra Andalan Sejahtera Concession location: (0.083410, 109.287645)

Deforestation and/or peat development

Peat Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) July 9, 2019 - June 9, Report 29 12 2020 Satellite imagery (see below) shows that between July 9, 2019 and June 9, 2020 a total of 12 hectares of forest was cleared in the PT Mitra Andalan Sejahtera concession. (Imagery: Contains modified Copernicus Sentinel data 2020)

Supply Chain Information

Biofuel Company/Group Trader Compan Consumer Brand

PT Mitra Andalan General Mills, Hershey, PepsiCo, AAK, Bunge, Fuji Oil Sejahtera RB

General Mills, Hershey, PepsiCo, Parna Raya AAK, Bunge, Fuji Oil RB

Ownership Information

PT Mitra Andalan Sejahtera is part of the Parna Raya Group.1

1. Parna Raya website, www.parnaraya.co.id/pro.php?i=perkebunan

MIGHTY EARTH 4

Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM

Mapping analysis

PT Mitra Andalan ... IX II Safahtwar i Miffa Vietnam | K Philippin

Malaysia j* ** . *» .• . • * S'' Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (0.055243, 109.328935) Date: July 9, 2019 Date: June 9, 2020

MIGHTY EARTH

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Unresolved Case

Group: Capitol Group PT Medco Papua Hijau Selaras Concession location: (-0.809675,133.825946)

Deforestation and/or peat development

Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) January 11,2020 - Report 25 221 397 February 24, 2020 February 17, 2020 Report 26 40 (GLAD) March 16, 2020 March 16, 2020 Report 27 35 (GLAD) April 15, 2020 April 21,2020-May Report 28 31 (GLAD) 21,2020 February 24, 2020 Report 29 286 69 June 18, 2020 Satellite imagery (see below) shows that between February 24, 2020 and June 18, 2020 a total of 286 hectares of forest was cleared and 69 hectares were prepared for clearing (stacking lines) in the PT Medco Papua Hijau Selaras concession. (Imagery: Contains modified Copernicus Sentinel data 2020)

Supply Chain Information

Biofuel Company/Group Trader Compan Consumer Brand

Avon, Colgate-Palmolive, AAK, ADM, Bunge, FrieslandCampesina, General Mills, PT Medco Papua Hijau Fuji Oil, Olam, Sime Hershey, Johnson&Johnson, Selaras Darby, Wilmar Kellogg, Mars, Mondelez, Nestle, PepsiCo, PZ Cussons, RB

Avon, Colgate-Palmolive, Danone, AAK, ADM, Bunge, FrieslandCampesina, General Mills, Capitol Group Fuji Oil, Neste, Olam, Hershey, Johnson&Johnson, Sime Darby, Wilmar Kellogg, Mars, Mondelez, Nestle, PepsiCo, PZ Cussons, RB

MIGHTY EARTH 6

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Ownership Information

Formerly owned by Medco Agro, PT Medco Papua Hijau Selaras is now part of the Capitol Group.2 The company is majority owned by PT Yabes Perkebunan Sawit,3 which is wholly owned by Jimmy Widjaja and Raisa Widjaja, the a son and granddaughter of Eka Tjipta Widjaja (deceased) -- the founder of the Sinar Mas Group. The Sinar Mas Group includes GAR and Asia Pulp & Paper (APP), which both have NDPE policies.

Mapping analysis

LC PT Medco Papua Hi- a Philippines

onesia Papua Nev Guinea

Alert Imagery (before and after satellite images)

Clearance location: (-0.812069, 133.818092) Date: February 24, 2020 Date: June 18, 2020 S A

Jh

-

2. Capitol Group website, http://thecapitolgroups.com 3. Notary Acts for PT Medcopapua Hijau Selaras and PT Yabes Perkebunan Sawit MIGHTY EARTH 7

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Unresolved Case

Group: Widya Corporation PT Mulia Inti Perkasa Concession location: (2.274158, 116.918204)

Deforestation and/or peat development

Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) May 11,2018-July Report 6 30 19, 2018 April 6, 2019-May 8 Report 15 119 46 2019 April 19 2019-May Report 16 119 (GLAD) 18, 2019 August 15, 2019 - Report 20 71 (GLAD) September 1 5, 201 9 September 16, 2019 Report 21 31 (GLAD) - October 15, 2019 October 15, 2019 - Report 22 186 (GLAD) November 14, 2019 November 15, 2019 Report 23 74 (GLAD) December 6 ,2019 December 15 2019 Report 24 151 (GLAD) January 15, 2020 August 13, 2018 - Report 25 1304 January 21,2020 February 17, 2020 - Report 26 23 (GLAD) March 16, 2020 March 16, 2020- Report 27 134 (GLAD) April 15, 2020 April 21,2020-May Report 28 50 (GLAD) 21,2020 March 16, 2020 Report 29 17 June 4, 2020 Satellite imagery (see below) shows that between March 16, 2020 and June 4, 2020 a total of 17 hectares of forest was cleared in the PT f /lulia Inti Perkasa concession. (Imagery: Contains modified Copernicus Sentinel data 2020)

MIGHTY EARTH 8

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Supply Chain Information

Biofuel Company/Group Trader Compan Consumer Brand

Cargill, Fuji Oil, Olam, PT Mulia Inti Perkasa Sime Darby

Avon, Danone, AAK, Astra, Bunge, FrieslandCampesina, General Mills, Widya Corporation Cargill, Fuji Oil, Olam, Hershey, Johnson&Johnson, Sime Darby, Wilmar Kellogg, Mars, Nestle, P&G, PepsiCo, PZ Cussons, RB,

Ownership Information

PT Mulia Inti Perkasa is part of the Widya Corporation.4

Mapping analysis

^ (bum. Vietnam Philippines

alaysia

Indonesia 0

Alert Imagery (before and after satellite images)

Clearance location: (2.274158,116.918204)

Date: March 16, 2020 Date: June 4, 2020

\ T r

4. See Rapid Response report 6 for ownership details

MIGHTY EARTH 9

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New Case

Group: Rimbunan Hijau PJP Pelita Lundu Plantation Sdn Bhd Concession location: (1.520403, 109.828348)

Deforestation and/or peat development

Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) Feb 11,2020-May Report 29 6, 2020 Satellite imagery (see below) shows that between February 11,2020 and May 6, 2020 a total of 4 hectares of forest was cleared in the PJP Pelita Lundu Plantation Sdn Bhd concession. (Imagery: Contains modified Copernicus Sentinel data 2020)

Supply Chain Information

Biofuel Company/Group Trader Compan Consumer Brand

PJP Pelita Lundu Plantation Sdn Bhd

AAK, ADM, BLD, Avon, Colgate-Palmolive, FrieslandCampesina, General Mills, Bunge, Cargill, Felda Hershey, ISF, Johnson&Johnson, Rimbunan Hijau IFFCO, Fuji Oil, IOI, Kellogg, Mars, Nestle, P&G, KLK, Neste, Sime PepsiCo, PZ Cussons, RB, Unilever, Darby, Wilmar Upfield, Vandemoortele

Ownership Information

PJP Pelita Lundu Plantation Sdn Bhd is part of the Rimbunan Hijau Group.f 5

5. Rimbunan Hijau website, www.rsb.com.my/our_milestones.html

MIGHTY EARTH 10

Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM

Mapping analysis f V. Vietnam Philippine

Malaysia

Indonesia &

Alert Imagery (before and after satellite images)

Clearance location: (1.520403, 109.828348) Date: February 11,2020 Date: May 6, 2020

*

MIGHTY EARTH 11

Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM

Unresolved Case

Group: Rimbunan Hijau Poh Zhen Sdn Bhd Concession location: (2.676323, 111.346419)

Deforestation and/or peat development

Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) March 12, 2019-July Report 17 40 7, 2019 July 15, 2019- Report 19 7 (GLAD) Auqust 15, 2019 August 15, 2019 - Report 20 31 (GLAD) September 1 5, 201 9 February 17, 2020 - Report 26 8 (GLAD) March 16, 2020 March 16, 2020- Report 27 7 (GLAD) Apnl 15, 2020 July 31,2019-May Report 29 66 54 26, 2020 Satellite imagery (see below) shows that between July 31,2019 and May 26, 2020 a total of 66 hectares of peat was developed and 54 hectares were prepared for clearing (stacking lines) in the Poh Zhen Sdn Bhd concession. (Imagery: Contains modified Copernicus Sentinel data 2020)

Supply Chain Information

Biofuel Company/Group Trader Compan Consumer Brand

ADM, BLD, KLK, Sime Poh Zhen Sdn Bhd Darby

AAK, ADM, Astra, BLD Avon, Colgate-Palmolive, FrieslandCampesina, General Mills, Bunge, Cargill, Felda Hershey, ISF, Johnson&Johnson, Rimbunan Hijau IFFCO, Fuji Oil, IOI, Kellogg, Mars, Nestle, P&G, KLK, Neste, Sime PepsiCo, PZ Cussons, RB, Unilever, Darby, Wilmar Upfield, Vandemoortele

MIGHTY EARTH 12

Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM

Ownership Information

Poh Zhen Sdn Bhd is a wholly owned subsidiary of Jaya Tiasa Bhd, part of the Rimbunan Hijau Group.6

Mapping analysis

iurma) Vietnam Philippine:

Malaysia < At J Indonesia u , a

• 4 ' V v -U,:

Alert Imagery (before and after satellite images)

Clearance location: (2.684481, 111.339182) Date: July 31,2019 Date: May 26, 2020

6. Company profile from Companies Commission Malaysia

MIGHTY EARTH 13

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Additional cases identified using screened GLAD alerts

The following cases have been identified through screened GLAD alerts (see methodology below). As these cases are either repeat cases from previous Rapid Response reports or where Mighty Earth did not determine any supply chain links for these concessions/groups, no satellite image analysis was conducted for these cases to save resources.

Mighty Earth expects that palm oil traders and biofuel companies conduct their own satellite image analysis of these cases and, if confirmed to be deforestation/peatland development, conduct due diligence to determine if they are exposed to associated companies/groups.

Methodology: For Indonesia, GLAD alerts are screened using the Indonesia Ministry of Forestry and the Environment land cover dataset for 2017 which classifies existing palm oil plantations and primary and secondary forest. Hence, only GLAD alerts in primary and secondary forest according to that dataset are included.

For Malaysia, GLAD alerts are screened to exclude known plantation areas using the Global Forest Watch (GFW) plantations dataset. This automatically eliminates the most common false positives, i.e. the replanting of palm that existed prior to the year 2000.

New Cases - Unknown Supply Chain Links

Area covered by Concession license area Group/ownership screened GLAD Time period alerts (ha)

Kayu Lapis May 15, 2020- PT Inti Kebun Lestari Block I 10 Indonesia June 14, 2020

PT Az-Zhara May 15, 2020- PTTaringin Perkasa Plantation June 14, 2020

May 15, 2020- PT Borneo International Anugerah First Borneo Group June 14, 2020

May 15, 2020- PT Cipta Papua Plantation Block A Ciptana Group June 14, 2020

MIGHTY EARTH

Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM

Repeat Cases - Known Supply Chain Links

Rapid Area covered Response Concession license by screened „ Group/ownership Time period reports GLAD a erts r related to each case* Reports 9,10, 11, 12, 15, 16, PT Persada Era Agro May 15, 2020- Mulia Sawit Group 10 17, 18, 19, 20, Kencana June 14, 2020 22, 23, 24, 25, 27, 28______

May 15, 2020- Reports 23, 25, PT Sumber Alam Selaras NPC Resources Bhd June 14, 2020 26, 27

PT Tunas Borneo May 15, 2020- Reports 18, 27, Samling Group Plantations June 14, 2020 28

Reports 15, 18, Shin Yang Group / May 15, 2020- Shin Yang LPF 0018 10 19, 20,21,25, Sarawak Oil Palms Bhd June 14, 2020 26,27

*Rapid Response reports available on Mighty Earth's Rapid Response website page, linked here.

MIGHTY EARTH 15

Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM

Repeat Cases - Unknown Supply Chain Links

Rapid Area covered Response by screened Concession license area Group/ownership Time period reports GLAD alerts related to (ha) each case*

Unknown Group (PT MMLformerly owned May 15, 2020- Reports 16, 17, PT Menthobi Mitra Lestari 137 by PT Bakrie Sumatra June 14, 2020 20, 22, 27 Plantations Tbk)_____

May 15, 2020- Reports 17, 18, PTWahana Hamparan Hijau First Borneo Group 103 June 14, 2020 19

PT Future Agropia JSK International Co May 15, 2020- Reports 17, 20, 71 Indonesia Ltd (Korea) June 14, 2020 27

Reports 2, 6, 9, May 15, 2020- PT Berau Karetindo Lestari Korompis family 45 15, 16, 19,20, June 14, 2020 21,22, 27, 28 Reports 3, 10, May 15, 2020- 13, 14, 16, 17, PT Rimbun Sawit Papua Salim/IndoGunta 42 June 14, 2020 18, 20, 23,25, 26, 28 Reports 3, 10, May 15, 2020- 13, 14, 16, 17, PT Rimbun Sawit Papua Salim/IndoGunta 38 June 14, 2020 18, 20, 23, 25, 26, 28

PT Agrindo Sukses Starmas Sentosa May 15, 2020- Reports 8, 16, 23 Sejahtera Mandiri June 14, 2020 22, 26, 27, 28

May 15, 2020- Reports 7, 17, PT Kusuma Alam Sari Alas Kusuma Group 15 June 14, 2020 23, 26, 28

PTTriomas Forestry May 15, 2020- Reports 17, 22, Unknown Group 15 Development Indonesia June 14, 2020 23, 24, 27 Reports 3, 10, May 15, 2020- 13, 14, 16, 17, PT Rimbun Sawit Papua Salim/IndoGunta 13 June 14, 2020 18, 20, 23, 25, 26, 28______

May 15, 2020- Reports 18, 19, PT Artanusa Agrindo Unknown Group 11 June 14, 2020 21,28

PT Future Agropia JSK International Co May 15, 2020- Reports 17, 20, 10 Indonesia Ltd (Korea) June 14, 2020 27

Hangzhou Jinjiang May 15, 2020- Reports 22 and PT Putra Sari Lestari Group June 14, 2020 23

May 15,2020- Reports 21 and PT Sentosa Kalimantan Jaya Unknown Group June 14, 2020 23

'Rapid Response reports available on Mighty Earth's Rapid Response website page, linked here.

MIGHTY EARTH 1

Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM

Repeat Cases - Unknown Supply Chain Links

Rapid Area covered Response by screened Concession license area Group/ownership Time period reports GLAD alerts related to (ha) each case*

Bukit Berlian Plantation May 15, 2020- Reports 17, 23, PT Ginang Fohu Plantation Group June 14, 2020 28

Bukit Berlian Plantation May 15, 2020- Reports 17, 23, PT Ginang Fohu Plantation Group June 14, 2020 28

PT Sanggam Harapan Venture Resources May 15, 2020- Reports 8, 22, 24 Sejahtera Pte. Ltd June 14, 2020

Kwantas Corporation May 15, 2020- Reports 20 and Miracle Harvest Sdn Bhd Bhd June 14, 2020 21

*Rapid Response reports available on Mighty Earth's Rapid Response website page, linked here.

MIGHTY EARTH 17

Received by NSD/FARA Registration Unit 07/03/2020 3:17:43 PM