SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

RSPO Assessment Report Annual Surveillance Assessment Report

PT. Sumber Indah Perkasa – Sungai Merah Mill, ,

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

Prepared by: Nuzwardy Sjahwil (Lead Assessor) Certification decision made by :Triyan Aidilfiitri

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

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List of Contents Page

A Scope of the Certification Assessment ...... 3 A.1. National Interpretation Used ...... 3 A.2. Assessment Type (Estate and Mill) ...... 3 A.3. Location Map ...... 3 A.3.1. Location Address of the Mill and Approximate Tonnages Certified (CPO and Mill ) ...... 6 A.4. Description of Supply Base ...... 6 A.4.1. General Description ...... 6 A.4.2. Location of Supply Base ...... 7 A.4.3. Statistic of Supply Base...... 7 A.5. Organizational Information and Contact Person ...... 8 A.5.1 Audit Against the Rules for Partial Certification ...... 9 A.6. Date Certificate Issued and Scope of Certificate ...... 13 B. Assessment Process...... 14 B.1. Certification Body ...... 14 B.2. Qualifications of the Assessment Team ...... 14 B.2.1. Qualifications of the Lead Assessor and Assessment Team ...... 14 B.3. Assessment Methodology...... 15 B.3.1. General Overview ...... 15 C. Assessment Findings ...... 20 C.1. Summary of the Findings by Criteria ...... 20 C.2. Supply Chain Modul E : CPO Mill Mass Balance ...... 46 C.3. Status of Previous Non-conformities ……………………………………………...50 C.4. Issues Raised by Stakeholders……………………………………………………..54 D. Certified Organization’s Acknowledgement of Internal Responsibility ...... 55 D.1. Formal Sign-Off the Assessment Findings ...... 55 D.2. Statement by the Certifier Body on Behalf of PT. Sucofindo SBU-SICS ...... 56 D.3. Date of Next Surveillance Visit………………………………………………… 56 List of Abbreviation ...... 57 Attachment 1 - MAP ...... 59 Attachment 2 - NCR ...... 64

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A. Scope of the Certification Assessment A. 1. National Interpretation Used The management of the Palm Oil Mill(s) and associated suppliers of Fresh Fruit Bunches (FFB) were assessed for compliance against the International RSPO criteria as interpreted and endorsed for Indonesia 2008, RSPO Principle and Criteria 2013 Generic and RSPO Certification Systems and RSPO Suply Chain Certification Systems 2014

A. 2. Assessment Type (Estate and Mill) Certification Unit : PT. Sumber Indah Perkasa – Sungai Merah Mill located at Gedung Aji Baru, Tulang Bawang Regency – Lampung, INDONESIA

A.3. Location map Please see Appendix 1 : the details of estate maps of 1.Overlay Map of Sungai Merah Estate (SMRE) and KKPA Gedung Aji Baru (GABA) Estate, 2.Map of Rivers, 3. HCV, 4.Topography

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Sumatera Island - Indonesia

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

1 Name of Mill Sungai Merah Mill PT. Sumber Indah Perkasa

2 Location address Desa Sidomukti Batu, Kecamatan Gedung Aji Baru, Kabupaten Tulang Bawang - Lampung

3 GPS Reference Latitude: 4o 13’ 06.40” LS

Longitude: 105o 35’ 19.57” BT

4 Actual Production (2014)*) CPO : 39,221.62 PK : 9,179.98

FFB : 185,828.10

5 Certified tonnage claimed**) CPO : 36,829.10 PK : 8,617.01

FFB : 174,510.87

6 Certified area 8,551.76 Ha

7 Planted area 8,450.47 Ha

8 Certified Tonnages Sold *) CPO : 0 mt ; PK : 0 mt

9 Certified tonnages purchased CPO : 0 mt ; PK : 0 mt

Note : *) This data (Annual output) include data from non-certified suppliers **) So far, CPO is sold under ISCC scheme A.4. Description of Supply Base A. 4. 1. General description

PT. Sumber Indah Perkasa operates 2 palm oil mills under PT Sumber Indah Perkasa, named PT Sumber Indah Perkasa - Sungai Buaya Mill (SBYM) and PT Sumber Indah Perkasa – Sungai Merah Mill (SMRM). The raw material/FFB for PT Sumber Indah Perkasa - Sungai Merah Mill (SMRM) is supplied from 1. Sungai Merah Estate (SMRE), and 2. KKPA Gedung Aji Baru (GABA) Estate - Smallholder.

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Totally supplied FFB from these two (2) estates are 174,510.87 MT. There are outgrowers supplied for 11,317.23 MT and totally Mill operates for 185,828.10 Mt FFB from all suppliers and estates. All estates are operated under one management of PT. Sumber Indah Perkasa. All estates located in Lampung, INDONESIA. PT. Sumber Indah Perkasa is a member of RSPO and they are implementing a program to achieve RSPO Certified Palm Oil for all its production. There is no plan to expand the land holding and therefore Principles 7 is not applicable to this assessment.

3. Location of the supply base GPS No. Estate Name Location Latitude Longitude

1 Sungai Merah Estate Desa Sidang Gunung Tiga, Kecamatan Rawa 4o 12’ 00.73” 105o 38’ 05.14” Jitu Utara, Kabupaten Mesuji – Lampung

2 Gedung Aji Baru KKPA Desa Sidoharjo, Kecamatan Penawartama, 4o 09’ 44.86” 105o 26’ 09.23” Kabupaten Tulang Bawang – Lampung

4. Statistic of supply base

No. Estate Planting Area/Planting Age/Planting Estimated Estimated Name Year Year Year FFB/Year CPO/Year

1 Sungai 1991 503,03 24 11,234.572 2,374.22 Merah 1992 513,19 23 9,716.506 2,053.40 Estate 1993 1,230.45 22 19.595,832 4.141.32

1994 834.23 21 13,537.612 2,860.93

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1996 452.91 19 9,426.375 1,992.09

2000 266.41 15 4,093.055 864.99

2001 19.95 14 401.906 84.99

2004 124.55 11 2,707.992 572.28

2 Gedung 1995 3.115,25 20 71,612.140 15,099.03 Aji Baru 1996 605,00 19 14,266.920 3,008.10 KKPA 1997 377,00 18 8,900.770 1,876.68

1998 71,00 17 1,839.210 387.79

1999 337,50 16 7,177.980 1,513.44

A. 5. Organizational Information and Contact Person

PT. SUMBER INDAH PERKASA – Sungai Merah Mill 1 Company Name (SMRM)

2 Personal Contact Ismu Zulfikar

3 Vice Management Humala Sinaga

Sinarmas Land Plaza Menara 2 Lantai 30, Jalan M. H. 4 Company Address Thamrin No. 51, Jakarta, Indonesia

5 Company Status PMDN

7 Phone/ Fax 021 50338899

8 E-mail [email protected]

9 Website www.smart-tbk.com

10 RSPO membership number 1-0096-11-000-00

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A. 5. 1. Audit Again the Rules for Partial Certification

1. Assessment agenda (partial Certification Audit)

Date Location Agenda

16 Maret 2015 PT. Sumber Indah Perkasa During ASA I to verify legal documents, HCV, Labor Union and land conflict - Sungai Buaya Mill within the GAR group Kec. Mesuji Timur Kabupaten Mesuji Lampung Indonesia

2. Audit Team Findings in Correlation to the Rules Partial Certifications a. The Organization is a member of RSPO PT Kresna Duta Agroindo has confirmed membership of the RSPO with no. 1- 0096-11-000-00 b. A Time Bound Plan for achieving certification within relevant entities ~

Time bound The progress of time bound below was based on the explanation of Div. Head Sustainability no. 030/EL/SMART-RSPO CB/II/2015 on 10 February 2015 and memorandum from Division Head Sustainability no. 104/IL-HP/STDV-PD/II/2015 to President Director 18 February 2015

Estimate Name of No Supply Base Company Location time of Mill Certification

1 Sungai Sungai Buaya PT. Sumber Lampung 2013 Buaya Mill Estate Indah Perkasa Certified Gedung Aji Lama KKPA

Mesuji KKPA

2 Sungai Sungai Merah PT. Sumber Lampung 2013 Merah Mill Estate Indah Perkasa Certified Gedung Aji Baru KKPA

Gedung Aji Lama KKPA PT. Sawit Mas 3 Pangkalan Sawit Mas Estate South Sejahtera

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Panji Mill Progress Final Report PT. Bumi Sawit 4 Bumi Sawit Bumi Sawit Estate South 2014 Permai Mill Sumatra Progress final report PT. Djuanda 5 Muara Muara Kandis South Certified 2015 Sawit Lestari Kandis Mill Sumatra Muara Tawas

Pandawa KKPA

Pandawa Plasma PT. Sumber 6 Sungai Sungai Rungau Central 2013 Indah Perkasa Rungau Mill Estate Kalimantan Certified Sungai Seruyan Estate

Terawan Estate

Tangar Estate

Bukit Tiga Estate PT. Bumi Permai 7 Bukit Perak Bukit Perak Bangka 2014 Lestari Mill Belitung nd Bukit Permata 2 stage audit, awaiting audit report PT. Foresta 8 Tanjung Tanjung Kembiri Bangka 2013 Lestari Dwikarya Kembiri Mill Estate Belitung Certified Tanjung Rusa PT. Sinar 9 Sungai Sungai Kupang South 2nd stage Kencana Inti Kupang Mill Estate Kalimantan audit on May Perkasa 2015 Sungai Kupang

PT. Sinar 10 Kasuari Mill Cendrawasih Papua 1st audit on Kencana Inti January 2015 Nuri Estate Perkasa

Rajawali Estate

Mambruk Estate PT. Purimas 11 Senakin Senakin Estate South 2014 Sasmita

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Mill Kalimantan berdasarkan data time bound GAR diubah menjadi 2015 PT. Agrolestari 12 Pekawai Kayung Estate West 2014 Mandiri Mill Kalimantan Pekawai Estate Stage 1 audit

Sungai Kelik

Nanga Tayap

Kayung Kemitraan PT. Kencana 13 Kenanga Kencana Estate West 2014 Graha Permai Mill Kalimantan Cendana Estate Progress final report Kenanga Estate

Cempaka Estate

Kencana

Kenanga PT. Tapian 14 Tanggar Manuhing Estate Central 2015 Nadenggan Mill Kalimantan Kajuji Estate Stage 1 audit

Sulin Estate

Nahiyang Estate

Katayang Estate

Sungai Nusa

Sako Estate

Sungai Ayawan Estate PT. Binasawit 15 Perdana Perdana Estate Central 2015 Abadi Pratama Mill Kalimantan st Lenggana Estate 1 stage audit

Semandau Estate

Muara Dua Estate PT. Agrokarya 16 Kuayan Mill Mentaya Estate Central 2015

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Prima Lestari Kalimantan st Kuayan Estate 1 stage audit

Bukit Santuhai Estate

Tajur Beras

Seranau Estate

Sapiri Estate PT. Paramitra 17 Belian Mill Gaharu Estate West 1st stage audit Internusa Kalimantan Muara Tawang Pratama Estate

Belian Estate

Tengkawang

Kapuas Hulu

The company has made the self declaration for partial certification rule and signed by management. The self declaration stated as belows (a-d) : a. Significant Conflicts The company has the SOP for Conflict Land Resolution refers to RSPO criteria 6.4, 7.5 and 7.6. All the conflicts so far has been resolved with mutual agreement. GAR also registered as member of RSPO Dispute Settlement Facility Advisory Group as a representative of grower. Supporting document is DSF RSPO member as a grower dated 22 April 2013. During the ASA I based on information and document forwarded by auditee there was no conflict regarding land in 2013-2015. b. No replacement of primary forest and or area with HCV’s since November 2005 or year 2007 (National Interpretation) PT. SMART Tbk, has been appointed to manage all companies under GAR Group. PT SMART Tbk has conducted Historical HCV Assessment (HHA) in collaboration with Faculty of Forestry, Institut Pertanian Bogor (IPB) April 2011. Historical HCV Assessment (HHA) Report has been submitted to RSPO on May 2011. As a follow up from the Historical HCV Assessment (HHA) Report, GAR has been proposed HCV Remediation Plan to RSPO. Revision of HCV Remediation Plan is on going process/ discussion with RSPO Biodiversity and HCV Working Group (BHCV WG). Supporting documents is Historical HCV Assessment (HHA) report. Company has submitted to RSPO regarding the latest development on 04 September 2014 by email to RSPO compensation c. No labor disputes that are not being resolved through an agreed The company has the SOP and mechanism to resolve dispute with union labor with mutually agreement. During the ASA I based on information and document forwarded by auditee there was no labor dispute in 2013-2015.

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The company has comply with the applicable law and regulation refers to RSPO criteria 2.1.which stated no evidence of non-compliance with the applicable regulation. Supporting documents are copies of SK AMDAL, SK HGU, IUP, IMB.

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A.6. Date Certificate Issued and Scope of Certificate Name of Client PT SUMBER INDAH PERKASA Client Number RSPO 00004 Certificate Number RSPO 00004 Certification Decision Date 02 May 2014 Issued by PT SUCOFINDO, SBU SICS Address GrahaSucofindo, SBU SICS. Jl Raya PasarMingguKav 34 Jakarta 13640 Telephone /Fax Tel.: +62-21-7983666 / Fax.: +62-21-7987015 Email [email protected] Website www.sucofindo.co.id Scope : Mill PT. Sumber Indah Perkasa - Sungai Merah Mill (SMRM) Estate 1. Sungai Merah Estate (SMRE) 2. Gedung Aji Baru Estate (GABA) Projected mass balance CPO & PK CPO : 36,829.10 MT and PK : 8,617.01 MT Certification Registration Code SICS-00004 Type of Certification Single site Certifier Triyan Aidilfitri Signed

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B. Assessment Process

B. 1. Certification Body SUCOFINDO SUCOFINDO ICS INTERNATIONAL CERTIFICATION SERVICES (SUCOFINDO ICS), which was formed in 1994, is one of the strategic business unit that provides certification services for leading companies.SucofindoCertification by International Certification Services is recognized nationally and international.Quality Management System Certification by SUCOFINDO ICS has obtained accreditation from National Accreditation Committee (KAN- Indonesia). Lead Auditors and Auditors of SUCOFINDO ICS are trained professionals in the field of international standards, auditing and management systems and are registered in the IRCA (International Register of Certified Auditors) and IEMA (Institute of Environmental Management & Assessment), UK. SUCOFINDO ICS certification process is supported by experts at PT. SUCOFINDO who understand the industry sectors and services in Indonesia. SUCOFINDO ICS Operational is supported by a network of branch and representative offices of PT. SUCOFINDO spread in 45 cities across Indonesia. The services provided by International Certification Services Sucofindo are: . Quality Management System Certification . Environmental Management System . ISO 22000 :2005 . OHSAS 18000 Certification . Hazard Analytical Critical and Control Point (HACCP) Certification . Good Manufacturing Practice (GMP) Audit . Product Certification . Sustainable Forest Management Certification . Products Organic Food Certification . RSPO certification . ISPO Certification . Certification of Integrated Management System Certification (SMT) . Training

B. 2. Qualifications of the Assessment Team

B. 2. 1. Qualifications of the Lead Assessor and Assessment Team

The assessment team members of this surveillance audit are as per the table below. Among them only Ganjar who were part of the assessment team of the previous audit (certification audit) : Nuzwardy Sjahwil (Lead Auditor In Evaluation) : He graduated from Institutee Agriculture of Bogor (IPB). He has more than 5 years audit experiences in OSHAS and SMK3. He has successfully completion from Lead auditor for SMK3, Lead Auditor for OHSAS and Lead Auditor for ISO 9001. He has successfully completion training Lead Auditor RSPO by Proforest, Lead Auditor Training by Komisi ISPO, Jakarta, and Supply Chain Training.

Ronald E Butar-Butar (Auditor)

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

Hidayat Pramudiyanto (Auditor): He graduated from University of Diponegoro, Semarang He has the training AMDAL A at Universityy of Gadjah Mada Yogyakarta, April 1994, AMDAL B at University of Diponegoro, Semarang, October 1998, Monitoring of environment quality and waste, IRCA Environmental Management Systems Auditor / Lead Auditor Course,

Ganjar Gumelar (Auditor):

He graduated from University ofGadjahMada (UGM), Forestry Faculty, majoring in Forest Management, Yogyakarta. He has completed the training such as Indonesian Sustainable Palm Oil (ISPO) auditor training, Komisi ISPO – Ministry of Agriculture & Komisi Akreditasi Nasional (KAN), Bogor (West Java) & Pangkalan Bun (Kalimantan), Indonesia, 2013 ;ISO 9001 : 2000 Quality Management Systems (QMS) Auditor/Lead Auditor Training Course (IRCA),PT. SUCOFINDO (Persero), Jakarta, Indonesia, 2013 ; Awareness Hazard Analysis Critical Control Point (HACCP), PT. SUCOFINDO (Persero), Jakarta, Indonesia, 2013 ; Life Cycle AssessmentWorkshop Oil Palm Plantation and Oil Palm Milling, Life Cycle Sustainability Assessment Lab &State Minister for The Environment, Jakarta, Indonesia, 2013 ; Assessor Training High Conservation Value Forest – HCVF, Tropenbos International Indonesia Program, The Nature Conservancy (TNC), WWF Indonesia & Institut Pertanian STIPER (INSTIPER) Yogyakarta, Yogyakarta, Indonesia (2011). B.3. Assessment Methodology B. 3. 1. General Overview

The assessment was carryingout in conformity with the SBU SICS RSPO manual and procedures for auditor and certifier. The assessment was conducted by qualified auditors and referred to RSPO standard as endorsed for the Indonesia National interpretation. Partial certification audit conducted during ASA I to check compliance with Final RSPO Certification System for partial certification.

The opening and closing meeting was conducted at the office of Sungai Buaya Estate and then continue in Mill’s and estate’s offices. Stakeholders meeting was conducted once, during ASA.

Date/Time Functions / areas / Department / activities to be audited (include related requirements) 16 Maret 2015 Day 1st Audit 05:40 Departure from Jakarta – Lampung 14.00 Departure to Regional Office Sungai Buaya Estate 18:00 Arrived at site 17.00 End of the day 1 17 Maret 2015 Day 2nd Audit 08.00 Location: Sungai Buaya Estate (Division II blok 14-15)

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Opening Meeting

Document audit  Check completeness of previous NCR minor and observation  RSPO - SCCS  Partial Certification  Land conflict and compensation

 Check completeness of previous NCR minor and observation  Prevention of land fire

 Check completeness of previous NCR minor and observation  Licensing and legality

 Check completeness of previous NCR minor and observation  HCV 12.00 Break  Estate and mill management  Information provision  Social responsibility  Empowerment of local/indigenous people  Development of local businesses  Continous improvement  FFB processing

 Worker welfare (2.1, 4.8, 6.5)  Child labour (2.1, 6.7, 6.8)  Meeting with Union  Sexual harrasment (6.9)  Ethical conduct  Humant right  Occupational health and safety and legal requirement regarding heath and safety

 Water conservation  Environmental monitoring  AMDAL, UKL, UPL  GHG mitigation

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 Utilization of hazardous waste  Renewable energy

 Legality  Community plantation

 New Planting  Seeding management  Cultivation at mineral land  Cultivation at peat land  Manuring  Pest management  Harvesting  HCV  Erosion control  Biodiversisty 12:00 Break 14:00 Estate Sungai Merah  Land conflict and compensation  Worker welfare  Child labour  Policy of prohibiton of mercenary

 HCV  Erosion control  Biodiversisty

 Water conservation  Environmental monitoring  AMDAL, UKL, UPL  GHG Mitigation  Utilization of hazardous waste  Renewable energy  Occupational health and safety and legal requirement regarding health and safety

 Legality  Community plantation

 Land clearing

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 Seeding  Plantation at mineral soil  Plantation at peat soil  Best practice at estate  Pest management program : listed pesticide  Harvesting  High conservation value  Erosion control  Biodiversisty

 Water conservation  Environmental monitoring  AMDAL, UKL, UPL  GHG Mitigation and renewable energy  Utilization of hazardous waste

 Occupational health and safety and legal requirement regarding health and safety

 Legality  Community plantation

Field visit planning

18.00 End of day 1 Wednesday, Day 3 18/03/15

07.30 Estate visit Sungai Buaya

Block 1  OSH, Worker welfare, housing facility, bathing facility for pesticide handler  High Conservation Value and Best Practice Estate  Sexual harassment

Block 2  OSH, Worker welfare, housing facility, bathing facility for pesticide handler  High Conservation Value and Best Practice Estate

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 Visiting BPN Pole  Sexual harassment 10:00 Visit to GAL KKPA  1.2 Kebun Masyarakat (6.1, 6.10)

12:00 Break

13:00 Visit to Mesuji KKPA 1.2 Kebun Masyarakat (6.1, 6.10)

Location: Mill Sungai Buaya  OSH  Environmental monitoring  AMDAL, UKL, UPL  Emergency preparadness  GHG mitigation  Hazardous waste utilization

Sungai Buaya Mill  FFB Processing  RSPO Supply Chain  Worker welfare  TBS receiving from plasma dan out grower (6.10) 18:00 End of audit day 3

Thursday, Day 4 19/03/15

Sungai Merah Estate

07:30 Block .. (to be discussed)  OSH, Worker welfare, housing facility, bathing facility for pesticide handler  High Conservation Value and Best Practice Estate  Visiting BPN Pole  Sexual harassment

Visit to GABA KKPA  Community plantation

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10:00  Social (Meeting with stakeholders : managed small holder and leader of local community )

12:00 Break

Location: Sungai Merah Mill  OSH  Environmental monitoring  AMDAL, UKL, UPL  Emergency preparadness  GHG mitigation  Hazardous waste utilization

 Worker welfare  FFB Processing

15:00  RSPO Supply Chain  TBS receiving from plasma dan out grower (6.10) 16:00 End of audit day 4

Friday, Day 5 20/03/15

09:00 Closing Meeting

11:00 End of audit

11:30 Road trip to

18:35 Flight to Jakarta Scope : 2 mills and 5 estates Number of assessor participating: 4 auditors Number of days spent for the assessment on site : 4 days Total number of mandays used for the assessment on site :16 days

C ASSESMENT FINDINGS C.1 SUMMARY OF THE FINDINGS BY CRITERIA 1 Commitment To Transparency

1.1 Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages & forms to allow for effective participation in decision making. Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 21of 73

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Company has established SOP of Comunication and Consultation (SOP/SMART/UMUM/SADV/1/004). List of information is in place that is accessible to relevant stakeholders, which is different between mill, main estate and plasma estate. Estate Manager is responsible for providing stakeholders with relevant information particularly information relating to social aspect. Every information request and the respective response are recorded at log book, while every information release to relevant stake holder is recorded in “Buku komunikasi” (communication book) Written recorded Information is routine infomation to related institution which need to be submitted on regular basis. The sample or regular information i.e report to insurance company (Jamsostek), extension of vehicle permit and reguler inspection of operational vehicle Based on examination results recorded in the log book of Communication and Consultation of stakeholders, there are request that have been addressed such as from Kribandi of Sidomekar regarding motor grader heavy equipment received on 13/01/2015 and responded on January 15, 2015. Company replied by letter no. 27 / SIP-SMRE / 0 / V / 2014 which stated that it could not fullfill the request. Requests for assistance cement of Masjid Al-Hikmah received on 8 September 2015, has been responded to by the company on 20 November 2015 by the giving 25 sacks of cement. From the examination results proved that the company has provided information on a regular basis, among others, to the Manpower Authority of Mesuji and Investation Coordination Board. The records of information requests and responses are kept with retention time of 10 years 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 Company as explained in 1.1 SOP of Response to Request and Information. It is Estate manager who responsible to release information to related stake holder, especially ones related to social aspect. Company has identified publicly information dan classsified ones. Confidential documents are documents outside the list of information to Stakeholder, such as commercial data and data causing negative impacts that are accessible only upon management’s approval, e.g. conflict data. In general, data may be accessed /asked by relevant stakeholders as long as relevant. In addition there are data that can be given only to relevant agencies, for example production data is given to the Regency and Provincial Plantation Service.

Publicly information/documents are as follow  Land legality which detailed further at 2.2  Enviromental document as described at 5.1.  Labour document which detailed further at 6.5  Occupational safety and health document as described further at 4.7

The records of information requests and responses are kept with retention time of 10 years. Based on data of information record, during 2014 there was no information request form stakeholder regarding the above publicly information.

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2 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

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

Company has made periodic evaluation of all regulations which is regulated through SOP/SPO/SMART/LH/03 (Legal and Other Requirements rev 01), which is evaluated per semester. Central office’s Sustainability division performs evaluation and the results are communicated to the units (estates and mills), which in turn will select those regulations relevant to them. The complainces to law and regulation are further detailed as follow;: 1. Occupation safety and health at 4.7 2. Labour and manpower at 6.5 3. Union at 6.6 4. Land tenure and legality 6.6 Status : minor non conformity

2.2 The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights

Right over the land Based on report of environmental impact analisis of PT. SIP, the location of this plantation are in according to Master Plan of Lampung Province no. 05 2001, where this location are set as production development area. 1. Company has made an overlay map (plantation and forest area) based on Situation map of HGU no. 32 year 1993 and no. 2 year 2000 as well as map of forestry area and water area of of Lampung Province, at scale of 1:250.000. This overlay map has already had coordinat data. Due to the map issued by BPN has not been furnished with the coordinat data, company made its own coordinat in it. HGU map issued by BPN on 1990 was not furnished with the coordinat data therefore the company conducting overlaid mapping to find the coordinat data of the map The compalny had already overlaid map based on situation map of HGU no. 2 2000 and map of forest and waters area of Province of Lampung with scale 1.250.000 year 2000 Company already has a letter from Forestry Department, Regional Office of Lampung Province no. 1052/Kanwil-6/TGH 134/90 dated 16 July 1990 stating that the area managed by PT Sumber Indah Perkasa, which is located to the East and bordering with permanent production forest of Sungai Buaya Reg.45, is not overlapping with the forest area. Site permit Company has been granted location permit based Governor decree no. C/202/DA/HK /1989 amounting to 9000 Ha on behalf of PT. Sumber Indah Permai. This permit then revised to be 9522,11 Ha by Governor decree no. C/309/BPH/HK/1990. Company previous name is PT Sumber Indah Permai and then changes name to become PT Sumber Indah Perkasa. Change in the company name has been notarized by a Notary Deed dated 20 September 1990 (Benny Kristianto and associate) and secured in the Decree of the Minister of Justice no. C2-5826 HT.01.01.Th90./HK/1990. Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 23of 73

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Plantation Business Permit (IUP) Company already posseses plantation business permit (IUP) no. 956/Menhutbun-VII/2000 dated 8 Agustus 2000 for 1 mill with capacity 30 ton FFB/jam for plantation area of 9046,63 Ha. Company increase processing capacity by 60 ton FFB/hour for one line thus the mill capacity increase to 120 ton FFB/hour. The increase of capacity has been approved by Ministry of Investation (BKPM) no. 46/II/PMDN1998 dated 01 July 1998 regarding the approval to increase the capacity to 120 ton FFB/hour and letter from the Board of Investment and Regional Integrated Permit Service with No. 800/200/BID.V/II.06/2013 dated 1 July 2013 for the management of mills with a capacity of 120 ton FFB/hour and secured by letter No 800/200/BID.V/II.06/2013 on 01 Juli 2013 issued by provincial investment body (BKPM).

SK HGU for PT SIP Company has HGU certificate from BPN no. 1/HGU/BPN/93 dated 30 January 1993 for area amounting to 9.522.11 ha dated 30 Januari 1993. In line with SK BPN No. 1/HGU/BPN/93 area granted to PT SUMBER INDAH PERKASA Bandar Lampung covered Desa Sungai Sidang, Sungai Cambai, Talang Gunung, Kecamatan Mesuji, dan Desa Gedung Aji. Desa Gedung Meneng, Kecamatan Manggala, Kabupaten Lampung Utara Propinsi Lampung. . HGU certificate consist of :

 HGU issued by Kabupaten Lampung Utara No. 08.04.2.00037 for area of 2.088,13 Ha at 26 November 1996 for SMRE which valid until 31 Desember 2027.

 HGU issued by Kabupaten Lampung Utara No. 08.04.2.00038 for area of 1.899,68 Ha at 26 November 1996 for SMRE which valid until 31 Desember 2027.  HGU issued by Kabupaten Tulang Bawang No. 08.06.02.17.2.00062 for area of 58.20 Ha at 21 July 1999 for SMRM which valid until 2029.

Maintenance of BPN poles The company has established SOP “Prosedur pemeliharaan patok” No. SOP/SMART/CERS- EHSP/SADV/I/004 for maintaining land poles. Company has maintained the land poles, i.e land pole HGU no.10 dan 12 . It is advised that company ensure that all the land pole is still in the coordinat according to HGU. HGB Company has obtained HGB for mill No. 62 (NIB 08.06.02.17.2.00062) with area 58,20 Ha, located at Desa Sidomukti, Kecamatan Manggala Kabupaten Tulang Bawang. This HGB issued by beurau of land affair (Kantor Pertanahan) Kabupaten Tulang Bawang at 25 March 2000. Pemit to build ( IMB) Company has obtain several permit to build for building in the estate as follow :  IMB No. 503/600/2016/III/IMB/2000 issue on 30 Maret 1999 for housing complex and several social facility and general facility building.  IMB No. 503/600/XI/IMB/1999 issue on 01 November 1999 for housing complex, office, Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 24of 73

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worshop and warehouses. Conflict Company has documented the conflict management in SOP “Penanganan Konflik Sosial” (SOP/SMART/SENSES-CSRD/SADV/I/2) and land right compensation “in prosedur ganti rugi lahan/tanah” SOP/NP/SMART/VII/D&L002. This procedure also include the compensation for the lost of customary right over the land as stated in point 6.2 Based on the information collected form (local village cooperative) KUD and revelant stakeholder from teh surrounding village, there were no conflict over the land since 2010. Based on SIA report isued by company itself there were no customary right identified. The land for the estate has been cleared in the beginning of 1990 before RSPO, therefore there is no data whether the mechanism of FPIC was practiced during that time. During this surveillance audit there were no paramilitary force or military force observed in the estate.

2.3 Use of land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent. Based on the company’s data and the information from the KUD and other parties around the village contacted, there have been no disputes since 2010 in the company surrounding areas and no land acquisition after 2010. As for the ulayat (communal) rights, the SIA report 2012 did not report any existence of ulayat rights so that the land map of PT. Sumber Indah Perkasa No. Reg: 948/214/PMNP/VI/12 with the scale of 1 : 250,000 does not identify any ulayat land. As for the compensation as addressed in 2.2, there has not been any new land acquisition since 2010. Status: Conform

3 COMMITMENT TO LONG-TERM ECONOMIC AND FINANCIAL VIABILITY

3.1 There is an implemented management plan that aims to achieve long-term economic and financial viability The company already has in place the short- and long-term plans that are contained in the company’s management plan. The long-term plan in the form of PT. SIP replanting plan has been drawn up until 2020. Replanting will start in 2017 up to 2020 covering 5 plantations with a total area of 23,443.87 Ha. Status: Conform

4 USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS

4.1 Operating procedures are appropriately documented and consistently implemented and monitored The company already documents the estate and mill management system with the following details: Plantation The process of land clearing refers to the Land Preparation Technical Guidelines (Oil Palm), Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 25of 73

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which is a collection of SOPs and WIs relating to the preparation of new planting issued 1/7/2010 and the Oil Palm Planting Technical Guidelines (MCAR), which refers to the collection of SOPs - WIs of Oil Palm Cultivation Techniques, Smart Agribusiness and Food, issued 01/09/2012. In the MCAR there is the New Land Clearing SOP (SOP/SMART/MCAR/IV/TA-PLB), rev.0, issued 1/9/2012. The SOP’s General Overview section states that the purpose of the SOP is to prepare the clearing of a new land for oil palm planting with the principle of zero burning. SOP on harvesting is available with Document No. SOP/SMART/ MCAR/XIII/TA-PNN Rev. 00, which refers to the collection of SOPs - WIs of Oil Palm Cultivation Techniques, Smart Agribusiness and Food, issued 01/09/2012. The harvesting SOP details the TPH Construction and Maintenance, the Preparation of Harvesting Workers and the Preparation of harvesting Tools and Equipment. It also details the FFB Accepting Criteria. Mill The company has in place the processing SOP (SOP-PENGOLAHAN/Review MCMD/1/2013). The document is in the form of SOPs, starting from FFB Reception, Sterilization, Thresher, Press Station, Clarification Station, Nut Kernel Station, Boiler & engine room, Water treatment, Final effluent up to Tank cleaning. The laboratory already has a WI for palm oil analysis. List of measuring equipment used in the laboratory is already available such as analytical scale. The scale calibration is performed internally using standard weights and there is a regular inspection from the research office on equipment validation, test methods and personnel competence. The company’s 60,000 kg capacity weighing bridge is already calibrated regularly every 6 months by the Metrology Agency. The last calibration will be valid until November 2015. The CPO quality is monitored on an hourly basis and recorded in the production oil analysis log sheet and inspected daily. ALB, water content, impurity content and DOBI are the specification of the processed product. Throughout 2014 the SMRM received FFB from its own estate and GABA Plasma totaled 174,510.87 (ISCC certified), 11,317.23 ton (uncertified) from outgrowers. The CPO produced was: 36,829.10 ton (ISCC certified), 2,392.52 ton (uncertified) with the total extraction rate (total OER) of 21.054%. Palm kernel it produced was: 8,617.01 ton (ISCC certified), and 562.97 ton (uncertified), with the total kernel extraction rate (KER) of 4.913%. Because the SMRM receives uncertified FFB the supply chain model it uses is MB (mass balance).

Status: observation

Practices maintain soil fertility at, or where possible improve soil fertility to, a 4.2 level that ensures optimal and sustained yield Maintenance activities are recorded in: - Log Book of Group Leader Activity (BKM)-day basis - Log Book of Work Outcome (BHK) – quantity basis. - For Nucleus Estate, the data of BKM and BHK is entered into the Checkroll program (SAP), while for Smallholder the BKM data is summarized into the Plant Maintenance Report. The company maintains the records of Planned and Realized Fertilization, and the record of fertilization implementation activities is available, which is evidenced by the Work Outcome Inspection Report. Sungai Merah Estate (SMRE)

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There is the memorandum of Laboratory Analysis Result ref. 201/TANAH/AL/ANLZ/11/11 dated 22 November 2011 regarding the result of Soil Sample Analysis of the SMRE’s Soil Sampling Unit (SSU) totaled 54 samples with request for Routine non-texture analysis of +Cu, Zn, Fe, Mn, B. The Method of Analysis applied was ICP-OES, except for C.Org, H-Al Tkr (titrimetry), N, N- KTK (colorimetric), and pH. There is the result of Soil Sample Analysis carried out by SMART Research Institute-Analytical Laboratory. There is the memorandum of Laboratory Analysis Results ref. 299/DAUN/LAB- SMARTRI/VI/2014 dated 30 June 2014 and 284/DAUN/LAB-SMARTRI/VI/2014 dated 28 June 2014 concerning the Results of Leaf Sample Analysis of the SMRE’s Leaf Sampling Unit (LSU) totaled 49 samples with request for N, P, K, Mg, Ca, B, Cl, Routine, Fe, CL analysis. Based on the results of soil and leaf analysis the fertilizer recommendation year 2014 was issued, for instance the Block SMREVI I50 Division 6 had the following fertilizer dosage: KA, 1.46%, N 2.57%, P 0.164%, K 1.12%, Mg 0.27%, Ca 0.51%, B 18 ppm, Cl 0.58%. At the time of the surveillance audit visit on 19/03/2015 the Block G36 and G37 Division III was undertaking chemical activities in the form of spraying the palm circle and harvesting path. The spraying team comprised a group leader and 8 spraying workers. Chemicals applied were Glifosat with 55 cc per 15 liters of water dosage. Based on the interviews with the spraying workers they generally understood how to spray correctly according to the procedure specified by the company. Gedung Aji Baru (GABA) KKPA There is the memorandum of Laboratory Analysis Results ref. 255/DAUN/LAB- SMARTRI/VI/2014 dated 20 June 2014 concerning the Results of Leaf Sample Analysis of the GABA’s Leaf Sampling Unit (LSU) totaled 24 samples with request for N, P, K, Mg, Ca, B, Cl, Routine, Fe, CL analysis. Based on the results of soil and leaf analysis the fertilizer recommendation year 2014 was issued, for instance the Block GABA V 1 B19 had the following fertilizer dosage: KA, 1.20%, N 2.22%, P 0.146%, K 0.83%, Mg 0.26%, Ca 0.65%, B 20 ppm, Cl 0.67%. Based on the results of soil and leaf analysis the fertilizer recommendation year 2014 was issued, for instance the Block MSJA11 B1 had the following fertilizer dosage: KA, 1.22%, N 2.41%, P 0.145%, K 0.88%, Mg 0.31%, Ca 0.37%, B 14 ppm, Cl 0.60%. Status: Conform 4.3 Practices minimize and control erosion and degradation of soils. The company has made the efforts to minimize and control the erosion and a reduction in the quality of soil and for this purpose it already has the Topographic Map and Riparian Map in each plantation unit of PT. Sumber Indah Perkasa. The slope conditions within the area of Sungai Merah based on land map unit have 3 (three) classifications i.e. 0-8% (flat), 8-15% (rolling) and 15-25% (wavy), the dominant slope classification is flat. The potential erosion hazard level (TBE) within the area of SMRE by slope classification and soil type is predicted to have the TBE class from moderate to very heavy. According to Keppres No. 32/1990 and PP No. 26/2008, cultivation activities remain possible at the slope of less than 40%. The erosion control and soil quality maintenance procedures are documented in the SOP of High Conservation Value Management and Monitoring No. SOP/SAMART/BCOS-EHSD/SADV/I/002, which is contained in the Collection of SOP-WI Sustainable Palm Oil, 2014, the Work Instruction of Erosion Measurement No. F/SMART/BCOS-EHSD/SADV/002/004 and the SOP of Water Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 27of 73

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Resource Management and Monitoring No. SOP/SAMART/BCOS-EHSD/SADV/I/004, which is contained in the Collection of SOP-WI Sustainable Palm Oil, 2014. The conservation practices that have been implemented by the SMRE unit management are the creation of silt pits and horse shoe shaping in the area with high erosion potentials. There is the record of Erosion Measurement which was carried out on the palm circle, live inter- row (path) and dead inter-row areas on 10 December 2014 in the Block C-12 Division 1 SMRE with the measurement results of 0 mm. According to Permen LH No. 07/2006 with the Critical Threshold (PP 150/200) of 9-12 mm/10 years the results of erosion measurement are still below the critical threshold. The Sungai Merah Estate has the Data of Turnera subulata and Antigonon leptopus Maintenance Year 2014. As a sample the maintenance of Turnera subulata and Antigonon leptopus was conducted in December covering the total area of 2,0005.43 Ha.

Sungai Merah Estate (SMRE) For planting there is peat land being planted in the SMRE i.e. the land with depth of < 3m totaled 831.83 Ha with planting year 1991, 1992, 1993, 1994, 1996, 2000, and 2004 and the land with depth of > 3m totaled 440.43 Ha with planting year 1993, 1994, 1996, 2000 and 2004. The water management has been implemented which refers to the Work Instruction IK/SMART/MCAR/III/TABDT/06- IK Peat Land Planting Rev.00 dated 26 March 2012. There is the record of piezometer monitoring for SMRE division 5. Gedung Aji Baru (GABA) KKPA, there is no peat land area. Status: Conform

4.4 Practices maintain the quality and availability of surface and groundwater. In the effort to maintain the quality of groundwater and surface water, the Company has the SOP of Water Resource Management and Monitoring No. SOP/SAMART/BCOS-EHSD/SADV/I/004 which is contained in the Collection of SOP-WI Sustainable Palm Oil, 2014. The dissemination of information to the employees and communities/farmers around the estate is in the form of warning boards of prohibition to use the river such as no fishing, no burning, and no cultivating. The riparian buffer zone protection is implemented by clearing the areas within a distance of 50 meter from the river’s edge from palm trees and by planting the river’s edge with bamboo species to prevent erosion. The dissemination of information to the employees and communities/farmers around the estate is in the form of warning boards of prohibition to use the river such as no fishing, no burning, and no cultivating. Water requirement in January 2015 was 1.25 m3 per 1 ton FFB for mill, 2876 m3/month for domestic use. With the mill capacity of 60 tons per hour, then the total use of river water would be 15,239 m3/month. Water use efficiency for the SMRM’s processing in January 2015 was 1.25 m3 per ton FFB.

Estate Water requirement for the SMRE’s estate operation in the pondok 3 where residential, office and pesticide PPE cleaning activities occur is sourced from groundwater wells (bore wells).

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SIPA permit from the Mining and Energy Office of Government is already held with no. 540/06/SPKTS-SIPA/III.14/MSJ/IV/2013, ± 100 m deep bore well permit, covering the following 3 well points: 1 point at Mesuji estate, 1 point at Sungai Buaya estate and 1 point at Sidang Gunung Tiga, 7 April 2013. At the SMRE’s pondokan 3 the bore well water is pumped from the well up into the reservoir tanks and then distributed through a piping system to the office and housing. Laboratory analysis of the bore well water has been conducted against the clean water standards of Permenkes no. 416/1990. The record of water consumption in December 2014 was 2,259.90 m3 / month. The other three SMRE’s bore wells at pondok 1, 2 and 4 have not been identified in terms of their permit, analysis results, and water requirement.

Mill The source of water utilized for palm oil mill and housing activities is from Sungai Merah. However, the permit of extraction and utilization of this river water from relevant authorities is not yet available. Up to this time, the company extracts water by pumping it into a reservoir with capacity according to a total of 2 pumps. Prior to use for production process and domestic needs the water is treated with the following process: Collection ponds, Clarifier Tanks, Sedimentation Tanks, Sand Filter, Treated Water Tanks, and Demin water specific for Boiler. Water utilized for the needs of housing around the SBYE is already monitored through a laboratory analysis and conforms to the requirements of Permenkes no. 416 of 1990 for clean water. The palm oil mill is also conducting water quality monitoring independently. The company performs daily monitoring of water at the water treatment plant to ensure that water it uses in its production process meets the requirements. The measurement of water quality is carried out on water at each stage including raw water, sand filter water, condensate water, deaerator water, and boiler water according to the boiler water quality norms. But for the monitoring of water from the Sungai Merah the cooperation has been made with an external laboratory which runs a monitoring program based on the designation of water bodies according to Government Regulation no. 82/2001 class II. Water requirement in January 2015 was 1.25 m3 per 1 ton FFB for mill, 2876 m3/month for domestic use. With the mill capacity of 60 tones per hour, then the total use of river water would be 15,239 m3/month. Water use efficiency for the SMRM’s processing in January 2015 was 1.25 m3 per ton FFB. The company has conducted the monitoring of the mill’s effluent BOD as addressed in 5.6.

Status: Conform 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated To control pests and plant disease the company already has the procedure of pest and plant disease control which refers to SOP – WI Oil Palm Cultivation Techniques, Smart Agribusiness and Food and the SOP of Pest and Plant Disease Control (SOP/SMART/MCAR/VII/TA-HPT, 1/9/2012). Several important pests and diseases on Productive Plants are:

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1. Kumbang tanduk 2. Tirathaba ruvivena and Tirathaba mundela (Penggerek tandan buah) 3. UPDKS control 4. Ulat Kantong 5. Rats 6. Ganoderma control 7. Boar control Sungai Merah Estate (SMRE) The company already has a Pest Observer team/EWS in the form of the Sungai Merah Estate (SMRE) Census Team. The company has conducted Training in Integrated Pest Control, Soil Sampling Unit and Leaf Sampling Unit which was carried out on 24 January 2015, attended by 22 participants including the team from Gedung Aji Baru (GABA) KKPA Estate and attached with training evaluation results, attendance list and materials. Records are available on rat attack census, Oil Palm Leaf Eating Caterpillar (UPDKS) pest management and Gupon/Tyto Alba census. Samples were taken on rat attacks in the Sungai Merah Estate (SMRE) area and a rat attack of 2.44% was found; this remains below the rat attack critical threshold of 5%. Thus the rat attacks in the Sungai Merah Estate (SMRE) area is categorized as Minor (below the critical threshold). The forms of rat attack census and UPDKS census should specify the attack categories with reference to the existing procedures. Observation. Gedung Aji Baru (GABA) KKPA Records are available on rat attack census, Oil Palm Leaf Eating Caterpillar (UPDKS) pest management, Gupon/Tyto Alba census and the methods of planting host plants for ulat api, kutib pupa, light trap predators. Samples were taken on rat attacks in the Gedung Aji Baru (GABA) KKPA estate area and a rat attack of 1.30% was found; this remains below the rat attack critical threshold of 5%. Thus the rat attacks in the Gedung Aji Baru (GABA) KKPA estate area is categorized as Minor (below the critical threshold). The company already plants the beneficial plant in almost all estate areas of PT. Sumber Indahperkasa. The beneficial plant is planted so that all blocks will have plants that serve as a host to the biological enemy of the pests and plant disease. Sungai Merah Estate (SMRE) has Data of Turnera subulata dan Antigonon leptopus Cultivation Year 2014; as a sample the Turnera subulata and Antigonon leptopus Cultivation was conducted in December covering the total area of 2.0005,43 Ha. Status: Observation

4.6 Agrochemicals are used in a way that does not endanger health or the environment. There is no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. 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 The company already has a list of agrochemicals it uses that refers to the recommendation by the Pesticide Commission of the Republic of Indonesia i.e. Erkafuron 20 WG with active substance of metal metsufuron 20 %, Rolixone 276 SL with active substance of Paraquat dichloride 276 g/l, Roll Up 480 SL with active substance of Isopropil amina glifosat 480 g/l with producers of PT. Rolimex Kimia Nusamas and Starane 290 EC with active substance of Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 30of 73

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Fluroxypyt metyl heptyl ester 290 g /l with producers of PT. Dow Agroscinces Indonesia. The company also already reduces the use of herbicide with an active substance of paraquat (restricted pesticide); this is evidenced by the record of its decreasing use in year 2014. There is a Memorandum from the central management to all estates on the reduction of paraquat use. There is a cooperation agreement between the company and the herbicide supplier producer i.e. PT. Rolimex Kimia Nusamas no. 011 / RKN – FER / PER / V / 2014 on submission of used herbicide packaging to the producer. The evidence is that on 7 June 2014 there was a handover of 20 liter Rolixone, Roll Up, Erkafuron jerrycan from SBYA, SMRE, and GABA to PT. Rolimex Kimia Nusamas. The company has SOPs relating to Pesticide Waste Handling. Rolymex receives used pesticide packaging of plastic jerrycans and bottles, while non-Rolymex is collected in a dedicated warehouse after handling in accordance with Used Pesticide Packaging and Fertilizer Sack Washing and Cleaning WI, SIP-SBYEIK/19, Revision No.:00 authorization date on 1 March 2012. The company already has a list of agrochemicals it uses that refers to the recommendation from the Pesticide Commission of the Republic of Indonesia i.e. Erkafuron 20 WG with active substance of metal metsufuron 20 %, Rolixone 276 SL with active substance of Paraquat dichloride 276 g/l, Roll Up 480 SL with active substance of Isopropil amina glifosat 480 g/l with producers of PT. Rolimex Kimia Nusamas and Starane 290 EC with active substance of Fluroxypyt metyl heptyl ester 290 g /l with producers of PT. Dow Agroscinces Indonesia. The company also already reduces the use of herbicide with an active substance of paraquat (restricted pesticide); this is evidenced by the record of its decreasing use in year 2014. There is a Memorandum from the central management to all estates on the reduction of paraquat use. Records are available on the results of health examination of the pesticide handling workers with the examination of pesticide level in blood (Cholinesterase) and Spirometry to a total of 102 personnel which was conducted on 4 – 5 March 2015 by the Center for Occupational Safety and Health, the Manpower and Transmigration Office of Lampung Province. However, the routine health examination of Cholinesterase and Spirometry is not yet consistently implemented once every 6 months in accordance with the procedure and the regulation of Kepmenaker no. 03/1986. (See the explanation in 4.7). Status: Conform 4.7 An occupational health and safety plan is documented, effectively communicated and implemented The company has stipulated the Occupational Safety Health and Hygiene policy of PT. SIP – Region Lampung, dated 2/9/2011. The policy was signed by the president director. The policy aims at continuously seeking to minimize hazards that may cause work accident resulting in injury, work-related disease, property damages, fire and explosion, as well as production process disruption and environmental pollution. The safety policy dissemination has been carried out in classes, training, meetings, morning briefings, morning circles, and displayed in the workplace. The company already has and establishes the SMK3 safety management system documentation including Safety Manual, SOP/Procedures, and forms, which was made effective as of 1 July 2010. At present, most of the documentation is already revised. Mill : The P2K3 safety committee has been approved by the Decree No. 560/12/HIPK/II.12/P2K3/III/2015 dated 11/2/2015, of Kadisosnakertran of Tulang Bawang

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Regency. The secretary is in the name of M. Ali Mukhtar (General Safety Expert). Estate : The P2K3 safety committee with the Decree no. 560/12/P2K3/III.05 / MSJ /2015 of the Head of Manpower and Transmigration Office of Mesuji Regency. The secretary is in the name of Indra Kurniawan as safety expert who has obtained the appointment with the Decree No. Kep.4118/M/DJPPK/I/2013. The safety committee already holds monthly regular meetings. The meeting minutes has included meeting topic, meeting outcome, completion timeframe (starting, completion), and PIC. The company has included its employees from day laborer (BHL), PKWT to SKU employee level in the Jamsostek Program. The Program’s packages vary with the employee status. The BHLs will be included only after they have been working for consecutively 3 months for their status has then been higher to become the SKU-Harian (SKU-H). The employees of SKU-H and PKWT status will be included in ½ Program Package or for JKK and JKM only, while those employees with the status of SKU-Bulanan (SKU-B) and SKU up to the staff will have a full package program or JKK, JKM, JHT, and JPK. The list of the Jamsostek participants is stored and recorded in the manpower database, and each has the Jamsostek participant card (KPJ) number. However, the PKWT status does not have this KPJ number. The Jamsostek Insurance does not give the.KPJ number for the reason of their non-permanent employee status. There is a letter from BPJS Ketenagakerjaan Lampung II no. B./140/032014 dated 03 March 2014 informing that the company is based on Law no. 24 Year 2011, PP 84 2013 regarding the 9th amendment of PP no. 14 1993 Jamsostek Program Implementation for which the BPJS only runs the JHT, JKK and JKM and the presidential regulation no. 109 of 2013 regarding the classification of participation in the social security program that for large companies and with continuous nature of work, the JKK and JKM are only given for construction companies, so that in that letter the BPJS Ketenagakerjaan cannot accept the participation for just JKK and JKM starting from March 2014. Based on the receipt of payment on Jamsostek Ketenagakerjaan for the period of January 2015 for the package JKK, JKM and JHT a total of 511 employees has their Jamsostek paid on 06 February 2015 via the Bank BNI of Tanjung Karang branch, while a total of 339 employees has not been registered, on the other hand the company does not have the mechanism of independent insurance relating to work accident and fatality as approved by the local manpower office.

With respect to health examination, the company has issued the Policy of Region Lampung Manpower Health Examination, approved by the Regional Controler, and the Production Controler, on 1/6/2011, which contains prior to work, periodic, and special examination. The hazardous material handlers such as spraying workers, hazardous waste personnel, chemical warehouse and laboratory personnel have their cholinesterase aspect examined. Likewise the workers in the noisy area have had their audiometry measured. Records are available on the results of health examination of the pesticide handling workers with the examination of pesticide level in blood (Cholinesterase) and Spirometry to a total of 102 workers which was conducted on 4 – 5 March 2015 by the Center for Occupational Safety and Health, the Manpower and Transmigration Office of Lampung Province. However, the routine health examination of Cholinesterase and Spirometry is not yet consistently implemented once every 6 months in accordance with the procedure and the regulation of Kepmenaker no. 03/1986.

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The audiometry check has been made to a total of 43 workers for those exposed to noise which was carried out on 4 – 5 March 2015. Out of 43 workers exposed to noise, 10 have problems with their hearing. The doctor’s recommendation was already available and further medical check up has been conducted to 08 of 10 person on 16 April 2015. The result of medical check showed there was a worker having reduction of hearing problem at 7000 hz. The Procedure for Hazard Source Identification, Risk Assessment and Control (ISBPR) (no. SOP/SMK3/SMART/LH-02, rev.01) is already in place. The company has undertaken the ISBPPR covering the entire Estate and Mill. The results of ISBPPR are recorded in the form Risk Analysis (FP 02/SMK3-SOP-02) and the Form Follow Up to Risk Analysis (FP 03/SMK3-SOP- 02). The reference for preparation is the ASNZ method. The ISBPR preparation for Estate includes: maintenance (fertilizers, sprays, inter-rows, OPT, paths), harvesting, maintenance of emplacement, warehouse (all), workshop (all machinery), clinic, main office, washing facility for fertilizer equipment and sacks (spraying worker bathing). For Mill it already covers the whole process, which includes: transportation, security, weighing, FFB grading, loading ramp, transfer carriage, sterilizer, tippler, tresher, press, clarifier, boiler, kernel, enginering, effluent, worshop, warehouse, hazardous material warehouse, diesel fuel tanks, lab, office, CPO dispatch, machinery unit installation, fire extinguisher, and vehicle traffic. The ISBPPR is reviewed annually in order to see the effectiveness of risk control that has been implemented previously. When considered necessary, additional control will be added until the low level of risk (low, L) is achieved. This activity is carried out together by the operation officials and the safety committee Secretary and the safety committee Chairman. The Emergency Response SOP (SOP/SMK3/SMART/LH-09), applicable to Estate and Mill. The technical guidelines on dealing with emergency situations in the form of Emergency Response Flow Diagram which is contained in the form FP 02/SMK3-SOP-10 according to the situation are: (1) Fire (residentials and land) (2) Hazardous Substance Spill Handling (3) Earthquake (4) Chemical Poisoning through Mouth. (5) Riots These procedures have been made effective since 1 July 2010. Information dissemination has been made to all workers by means of posting the procedures in strategic locations, such as the Estate office, the Division office, the Mill office, workshop, and parking area in the form of a banner or billboard. The company has been established the Emergency Response Team by appointing its personnel. The capability to prevent and deal with fire is created by providing training as follows: - Mill: In the KTD Equipment Checklist it is recorded to have: (1). 35 Lighweight Fire Extinguishers (APAR) at 35 locations; (2). 4 units of pillar hydrant and 4 boxes with associated equipment (hose and nozzle) at 4 strategic locations: St. Sterilizer, St. Boiler, St. Kernel, and St. Clarifier; (3). Sand bags accompanied with spades at 4 locations; and (4) eye washers and showers at 5 locations (lab, CaCO3 warehouse, LB-3, oil warehouse, and WTP). The company also has created the Evacuation Map and the Fire Sensitive Map which are accompanied with pictorial points of APAR, hydrant, eye washer/shower, evacuation direction arrows, and 2 assembly points. They should better be added with information on emergency phone numbers that can be contacted during an emergency.

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- Estate: In the Lightweight Extinguisher (APAR) Summary Check report the company has (1). 33 APARs at 30 locations throughout the Estate area which include the central office, fertilizer warehouse, diesel fuel, oil, sparepart, hazardous waste warehouse, the division office, mess, staff house. (2). 1 unit of water tank, 1 portable water pump accompanied with hose and nozzle/gun. The company already performs the routine inspection of APARs and hydrants whose results are recorded using the form APAR dan Hydrant Monitoring and carried out on a monthly basis. This activity is carried out by the workshop foreman, verified by the workshop assistant, and acknowledged by the Mill Manager. In dealing with emergency situations the company has formed the Mill Emergency Response Team (KTD): In the KTD Equipment Checklist it is recorded to have: (1). 35 Lightweight Fire Extinguishers (APAR) at 35 locations; (2). 4 units of pillar hydrant and 4 boxes with associated equipment (hose and nozzle) at 4 strategic locations: St. Sterilizer, St. Boiler, St. Kernel, and St. Clarifier; (3). Sand bags accompanied with spades at 4 locations; and (4) eye washers and showers at 5 locations (lab, CaCO3 warehouse, LB-3, oil warehouse, and WTP). The company also has made the Evacuation Map and the Fire Sensitive Map which are accompanied with pictorial points of APAR, hydrant, eye washer/shower, evacuation direction arrow, and 2 assembly points. They should be added with information on emergency phone numbers that can be contacted during an emergency. Estate: In the Lightweight Extinguisher (APAR) Summary Check report the company has (1). 33 APARs at 30 locations throughout the Estate area which include the central office, fertilizer warehouse, diesel fuel, oil, sparepart, hazardous waste warehouse, the division office, mess, staff house. (2). 1 unit of water tank, 1 portable water pump accompanied with hose and nozzle/gun. The company already performs the routine inspection of APARs and hydrants whose results are recorded using the form APAR dan Hydrant Monitoring and carried out on a monthly basis. Evidences of implementation are available for December 2012 and January 2013. This activity is carried out by the workshop foreman, verified by the workshop assistant, and acknowledged by the Mill Manager. Attention should be drawn to the mandatory facilities and infrastructure for land and estate fire control that are not yet consistent with the land and estate fire control guidelines from the Directorate General of Estate, the Ministry of Agriculture. In dealing with emergency situations the company has formed the Emergency Response Team (TTD) as follows: The Organizational Structure of Emergency Response and Preparedness has been set for each Unit, i.e. SMRE, and SMRM. The KTD structure is prepared by the P2K3 Secretary and approved/authorized by the P2K3 Chairman (the Unit Manager). In general, the structure is composed of the Team Chairman, Vice Chairman, General Affairs, Executive Chairman, Secretary, Fire Fighting Squad (Fire Extinguisher, Hydrant, Sand, Wet Gunnysack, Plaster Hook), Evacuation Squad, Security Squad, Contacting Squad, Eliminating Squad, and Medical Squad. Note that, for mill area, the company should have fire mitigation officer according to the provisions of Kepmenaker No. 186/MEN/1999. Based on Attachment 1 and 3 a mill is classified as vegetable oil plant and categorized to have the potential fire of Moderate III. For a mill with above 100 workers it must have the following fire mitigation personnel: 1 officer of class A, 1 officer of class B, 5 officers of class C, and 12 officers of class D. The company currently does

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not have personnel with such qualification. - List of phone number is available both internal and external including sectoral police, military office, community health center, and fire brigade. - Fire patrol activities by the Security Team to monitor HCV and land fire are recorded in Patrol Log Book every 2 weeks. - Creation of fire break in the area bordered with the community plantations and or potentially to catch fire at each division – Unit. There is Division Fire Sensitive Map, prepared by the Division Assistant, acknowledged by the P2K3 Secretary, and approved by the P2K3 Chairman, prepared annually at the beginning of year and belongs to the Agronomic Program. . Routine inspection of emergency response equipment such as APARs, hydrants, and sand bags from biweekly to monthly. This activity is carried out by the TTD member, or SPO Officer, or the P2K3 secretary. Fire prevention reporting to the Social Manpower and Transmigration Office is carried out quarterly at the same time as the P2K3’s quarterly report, among others: security patrol, TTD equipment monitoring. If during the reported months simulations or training occurs they will be incorporated in the report. Other accident related records are (1) Summary Monthly Accident Report (FP 03/SMK3-SOP- 10), and (4). Summary SR and FRR Counts (FP 04/SMK3-SOP-10).

Status: Conform 4.8 All staff, workers, smallholders and contractors are appropriately trained. The company already establishes training program which is prepared annually. The training activities are based on the HRD Training SOP that include: preparation, implementation, and evaluation. There is TNA which is set by the Regional Training Center Coordinator (RTCC) and the outcome is in the form of Training Needs Identification Matrix (FL/Estate/TRAD/10). The annual training program is prepared and determined by respective Unit and the training record for sustainability aspect is maintained by the SPO Officer, while for general aspect is maintained by the KTU of respective Unit. The company already requires the partnering Contractors to be trained and to fulfill their obligations in compliance with laws and regulations. To communicate these requirements the company has carried out dissemination activities to its contractors regarding their obligation to register their workers in the Jamsostek, to provide personal protection equipment for their own workers, and to provide drivers who have obtained appropriate driving license to transport FFB. Status: Conform 5 ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY

5.1 Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate The company already has the ANDAL document which is the document owned by PT. SIP, the revised AMDAL Oil Palm Plantation and Oil Palm Processing into CPO of PT Sumber Indah Perkasa covering a total area of 9,254 Ha and 2 POMs with a capacity of 60 ton TBS/Hour. The ANDAL document contains the environmental impact analysis of physical, biological, socio

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cultural, flora and fauna, and community economic aspects. The company performs measurements through RKL and RPL. The results of RKL and RPL are reported every 6 months to the BLH of the Regencies of Tulang Bawang and Mesuji, the BLH of Lampung Province, and the KLH Jakarta. However, the RKL and RPL reporting of every 6 months is not consistent with that in the AMDAL document approved by the BPLHD of Lampung Province of every 3 months. During the audit there was not an increase in the area of the estate or an increase in the capacity of the mill, so that there was no AMDAL revision. Status: Observation

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 PT. Sumber Indah Perkasa already has the SOP to protect Flora and Fauna in the estate environment which is contained in the HCV/NKT Identification and Management SOP, No.: SOP/NP/SMART/IV/LH 001. Information in the ANDAL document shows that the flora identified prior to planting was a commercial tree type such as meranti wood. There is flora and fauna identification before planting. The ANDAL document also identified flora and fauna after the oil palm estate and palm oil mill had been established such as oil palm trees and shrubs for flora and such as crocodiles, cobras, rats, porcupines, boars, tigers, etc for fauna. The baseline condition of land was a secondary forest. The ANDAL document does not provide information on flora and fauna under this condition. Flora and fauna information is detailed in the Environmental Information Presentation Document (PIL) of the Oil Palm Estate Project of PT. Sumber Indah Perkasa, Mesuji District and District, , which was prepared by PT. Mulia Consultant with approval on 12 August 1991. Data of flora and fauna prior to planting which is contained in the Environmental Information Presentation Document (PIL) of the Oil Palm Estate Project of PT. Sumber Indah Perkasa, Mesuji District and Menggala District, North Lampung Regency, prepared by PT. Mulia Consultant consists of: Vegetation Cover (Base Vegetation), which includes : - Alang – alang (Imperata cylindrical) - Rumput Bendera (Eleucine indica) - Putri Malu (Mimosa invisia) - Pakis (Alsophila sp) - Rumput Merdeka (Paspalum sp) Tree Species, which includes: - Pala Hutan (Myristica sp) - Beringin Hutan (Ficus benyamina) - Karet (Hevea brasiensis) - Bambu (Bambusa sp) - Pule (Gudrania sp) Aquatic Flora around the project location of PT. Sumber Indah Perkasa, which includes:

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- Ganggang Hijau (Chlorophyta) - Enceng Gondok (Eichornia grassipes) - Palam (Corypha sp) - Teratai Putih (Nelumbium sp) - Pakis Air (Ceratopteris sp) - Lumut (Bryophyta) Data of species diversity of terrestrial fauna in the project location of PT. Sumber Indah Perkasa at the condition prior to planting includes: Aves - Manyar (Ploceus manyar) - Tekukur (Streptopelia sp) - Jalak (Strurnus contra) - Emprit (Lanchura sp) - Cucak Rowo (Pycmonotus sp) - Elang (Bustantur sp) Mammals - Gajah (Elephan sp) - Kijang (Cervis timorensis) - Babi (Sus vitatus) - Beruang (Urus sp) Reptilia - Ular Piton (Phyton sp) - Kadal (Mobvia multifaciata) - Ular Sawah (Phyton molurus) - Jenis Insekta - Kupu-kupu (Papilio sp) - Capung (Gomphus sp) - Kumbang (Aryetes sp) List of fauna after planting is contained in the Final Report of Identification and Analysis of Areas with High Conservation Value at each unit.

Division/Block/ Type of Area Field Identification Results HCV Location of (Ha) Findings Sungai Merah Estate (SMRE) Protected species: (Block D20-D23; 1. Elang Hitam (Ictinaetus malayensis) E20-E23; B26- B29; C26-C30; 1.2 2. Elang Tikus (Elanus caeruleus) - D26-D30; E30) 3. Cangak Abu (Ardea sumatrana) and surrounding 4. Raja Udang (Alcedo meninting) areas

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Protected species: Pidada River 1. Buaya Muara (Crocodytus porosus) - 2. Kuntul Kerbau (Bubulus ibis)

KKPA Gedung Aji Baru (GABA) Estate – Plasma There are river border areas of Putuk river and Putuk River 17,42 1.1 ; 4.1 Camp river that serve to support the protected area, Camp River source of water and flood control. 10,06 Endangered species (almost extinct) as listed in the Gedung Aji Baru Government Regulation No. 7/1999 (Protected) and (GABA) KKPA IUCN LC ver 3 (2010), including: Estate, Division 6 1. Raja Udang Biru (Alcedo coerulescens) Peringgan and Pidada River 2. Cekakak Belukar (Halycon smyrnensis)

3. Blekok Sawah (Ardeola speciosa) 1.2 4. Kuntul Kerbau (Bubulcus ibis) - 5. Raja Udang (Alcedo meninting) 6. Cangak Laut (Ardea purpurea) 7. Cangak Merah (Ardea sumatrana) 8. Pekakak Emas (Pelargopsis capensis) 9. Cekakak Sungai (Todirhamphus chloris) 10. Macan Akar (Felis bengalensis) The company already has estate maps identifying locations of high conservation value/protection area. HCV identification was conducted in the oil palm plantation area of SMRE unit (4°5’ - 4°17’ S and 105°26’ - 105°39’ E). The area of PT. Sumber Indah Perkasa – Sungai Merah is 4,046.01 Ha with the planting year of 1991, 1992, 1993, 1994, 1996, 2000, 2001 and 2004. GABA has a total area of 5,005.25 Ha with the planting year of 1995, 1996, 1997, 1998 and 1999. To monitor the identified HCV the company has appointed the SPO officer. The company has posted rare fauna dissemination boards in strategic locations showing the images of rare animals that have been identified in the area of PT. Sumber Indahperkasa. A map is available on the location of conservation area warning boards which spread across the estate unit of PT. Sumber Indahperkasa. However, the existing number of warning boards is still very limited. The number of warning boards should be increased to be posted in other strategic locations. Sungai Merah Estate (SMRE) There is a record of dissemination of the policy on the protection of rare and endangered flora and fauna, which held on 3 February 2015 at the SMRE with the SPO Officer as a speaker and attended by 112 employees of PT. SIP SMRE, accompanied with photo documentation, dissemination materials and attendee list. Gedung Aji Baru (GABA) KKPA There is a record of dissemination of the policy on the protection of rare and endangered flora and fauna, which held on 19 January 2015 at the GABA with the SPO Officer as a speaker and

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attended by 58 employees of PT. SIP GABA, accompanied with photo documentation, dissemination materials and attendee list. Status: observation

5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner The company has established the Waste Management SOP, SOP / SMART / LEMS – EHSD / SADV / I / 002, revision: 00 covering mill waste: solid, liquid, gas (including hazardous waste). Hazardous waste information dissemination has been sufficient, and also carried out to all estates & personnel involved in hazardous waste handling such as spraying workers & person responsible in the division and they already know how to prevent spills when pouring pesticide from a jerry can into the spray container. The company also utilizes liquid and solid waste which is detailed in 4.2. List of Identified Source of Hazardous Waste permitted is already available i.e. used oil, used oil filters, TL lamps, used battery, and contaminated rags. All these hazardous waste in the TPS LB3 are still within their storage period limit. The company obtained hazardous waste storage permit from the regencies of Mesuji and Tulang Bawang. The organization has obtained Hazardous and Toxic Waste Temporary Storage Permit of PT Sumber Indah Perkasa Unit Sungai Merah and Sungai Buaya based on the Decree of the Regent of Mesuji No. B/464/I.02/HK/MSJ/2012. All hazardous waste originating from each unit is collected in the TPS of hazardous waste and having their quantity and type coming in and going out recorded to be managed by third parties. The TPS of hazardous waste for temporary collection and storage of hazardous waste already meets the storage requirements according to the regulatory provisions of Bapedal Decree no. 01 of 1995. Hazardous material packagings across the estate and mill locations are already collected in the TPS LB3 and hazardous waste bins are already provided in the mill and estate. The company already has the method to clean up spills using rags, and in the case of considerable quantity using a rubber mop, sapu lidi broom, and wooden pan, and the contaminated rags are disposed of into the hazardous waste bin. Records of hazardous waste manifest are already available, and sufficient according to hazardous waste type. There is a cooperation agreement between the company and the herbicide supplier producer i.e. PT. Rolimex Kimia Nusamas no. 011 / RKN – FER / PER / V / 2014 on submission of used herbicide packaging to the producer. The evidence is that on 7 June 2014 there was a handover of 20 liter Rolixone, Roll Up, Erkafuron jerry can from SBYA, SMRE, and GABA to PT. Rolimex Kimia Nusamas. The report of waste management in the form of hazardous waste balance & hazardous waste manifest is already submitted periodically every three months to the Regent of Tulang Bawang, the BLH of Lampung Province, and the KLH Jakarta. Status: Conform 5.4 Efficiency of energy use and use of renewable energy is maximized The company already has the Waste Management SOP, SOP / SMART / LEMS – EHSD / SADV / I / 002, revision: 00 covering the mill waste: solid, liquid, gas, and hazardous waste, including technical guidelines on the utilization of waste, both solid waste i.e. the utilization of shell, fiber, empty fruit bunches and liquid waste for land application.

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The use of shell and fiber at SBYM as substitute fuel in January 2015 was 587.54 ton and 1,233.79 ton, respectively, with the processed FFB of 9,870.30 ton. Total energy used per ton CPO was 1,271.540 KKAL. Status: Conform

5.5 Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN guidelines or other regional best practice. The process of land clearing refers to the Land Preparation Technical Guidelines (Oil Palm), which is a collection of SOPs and WIs relating to the preparation of new planting issued 1/7/2010 and the Oil Palm Planting Technical Guidelines (MCAR), which refers to the collection of SOPs - WIs of Oil Palm Cultivation Techniques, Smart Agribusiness and Food, issued 01/09/2012. In the MCAR there is the New Land Clearing SOP (SOP/SMART/MCAR/IV/TA-PLB), rev.0, issued 1/9/2012. The SOP’s General Overview section states that the purpose of the SOP is to prepare the clearing of a new land for oil palm planting with the principle of zero burning. Based on data of year 2014 there was no new land clearing or replanting so that there is no record on the use of fire. The company already documents the Procedure of land fire handling in the Emergency Handling SOP (SOP/SMK3/SMART/LH-09), which applies to Estate and Mill. The procedure and records of land fire handling are detailed in the criteria 4.7. Status: Observation

5.6 Plans to reduce pollution andemissions, including greenhouse gases, are developed, implemented, and monitored. The organization has RKL and RPL covering the environmental impacts on the river and bore well water quality, ambient air, noise, and air quality. RKL and RPL are reported to the BLH of Tulang Bawang and Mesuji Regencies every 6 months starting in 2012, and the receipt of RKL and RPL document submission is available. The organization already implements the measurements of vibration, odor and noise levels carried out by the Government of South Sumatera Province, Environmental Agency, UPTB Environmental Laboratory. The organization controls the vibration, odor, and noise nuisance through work instructions for the nuisance at Mill, for example noise, the work instruction of the genset work already incorporates controls using a silencer in the genset room and personal hearing protection (ear plug and ear muff). Relating to noise beyond the mill perimeter and in the employee/community residential area there is information on its control in the RKL and RPL report every six months, such as the control using trees to suppress odor, noise, and dust. The PKS SMRM liquid waste is processed through pond 1 up to pond 6 with a capacity of 10,000/m3 and feed time of 1 hour. The measurement of effluent discharge rate is currently only on the effluent directly leaving from the mill into the Land Application with a flow meter taking a daily record from 8 in the morning until the pump stops operating at 16.00. The use of empty fruit bunches at SMRE in January 2015 was 21,763 tons with the land application area of 382.89 hectares. The targeted area for empty fruit bunch application for 2

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years was 668 hectares. In the year 2012 it was 63,634 tons of EFB, on 1,155.74 hectares of land, with the target of 672 hectares of land and 49,915 tons of EFB. The greenhouse gas mitigation program of PT. SIP Region Lampung is to substitute diesel fuel with renewable energy (shell and fiber) in the CPO production process, exercise control on the use of diesel fuel for the estate and mill operational activities, disseminate information on turning off the FFB truck’s engine while waiting in queue to enter the mill, monitor the kwh per ton of product at mill originating in renewable and non-renewable energy, apply the fertilizer for the estate operational activities according to the SMART recommendation efficiently and effectively, record the efforts to maintain and improve soil fertility (the application of fertilizer according to type, Pome land application and empty fruit bunch application, the PHT method to control plant damaging organisms, and the use of environmentally friendly pesticide). Status: Conform

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

6.1 Aspects of estate and mill management that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement The company already has the documents of ANDAL, Revised AMDAL Oil Palm Plantation and Oil Palm Processing into CPO of PT Sumber Indah Perkasa with a total area of 9,254 Ha and 2 PKS with a capacity of 60 ton TBS/Hour. The ANDAL Document covers the environmental impact analysis of physical, biological, socio cultural, flora and fauna, and community economic aspects. The company has conducted Sosial Impact Assesment internally in 2012 for Sungai Buaya and Sungai Merah. The SIA has identified that there were 14 villages around the PT SIP affected by the social impact of the estate and mill operations. The SIA report states that the size of core plantation was 9,102.2 Ha and smallholders approximately 15,000 Ha. The company already has the list of stakeholders for all units. The total number of KUD members is 17,254 households. Things that become the negative community perception include social envy, reduced agricultural land, air pollution from the mill smoke and waste odor, and degraded level of health due to fly population. The issue of flies according to the company investigation is not caused by the application of empty fruit bunches, since the distance of the empty bunches to the community location is about 1 km and according to the opinion of company’s references (Azwar year 1990), the remotest distance a fly will travel is 1 km. The company has conducted Sosial Impact Assesment for the company and its surrounding areas. According to the study the majority of people living in and around the HGU area of PT SIP are Javanese and Lampung ethnics. Based on the results of Sosial Impact Assesment the company has identified the existence of indigenous people of Mesuji living outside the location of smallholder estate at a radius of 20 Km from the outermost plantation. This indigenous community is located at the banks of Cambai river. A review has been made within the time period of 2 years. There is a report of social impact management for the period of May 2012 – 2014 involving the stakeholders including the chief of Tri Redjomulyo village and the chief of Batu Ampar village affected by the company activities.

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The company reported the results of measurement every 6 months to the BLH of Mesuji Regency (SBYM), the BLH of Tulang Bawang Regency (SMRM), the BLH of Lampung Province, and the KLH Jakarta, with the evidence of submission receipt. Status: Observation

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

Company as explained in 1.1 SOP of Comunication and Consultation (SOP/SMART/UMUM/SADV/1/004).. It is Estate manager who responsible to release information to related stake holder, especially ones related to social aspect. Company has identified publicly information dan classsified ones. Confidential documents are documents outside the list of information to Stakeholder, such as commercial data and data causing negative impacts that are accessible only upon management’s approval, e.g. conflict data. In general, data may be accessed /asked by relevant stakeholders as long as relevant. In addition there are data that can be given only to relevant agencies, for example production data is given to the Regency and Provincial Plantation Service.

Publicly information/documents are as follow  Land legality which detailed further at 2.2  Enviromental document as described at 5.1.  Labour document which detailed further at 6.5  Occupational safety and health document as described further at 4.7

The records of information requests and responses are kept with retention time of 10 years. Based on data of information record, during 2014 there was no information request form stakeholder regarding the above publicly information.

Status : conformity 6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties The company already has the policy relating to employee grievances, i.e.: (1). Article 26 of the CLA Grievance Resolution, and (2). Complaint and Grievance Handling SOP (No. SOP/NP/SMART/XII/MCAR/001, date issued 1/7/2010). The complaint and grievance is recorded in a log book. The information of complaint is sourced internally and externally. The records of employee complaints and grievances are already maintained and followed up. There is Internal Grievance Log Book in place containing: date, place, name, contact details, problems, registration, response (date, action, status, PIC), and completion timeframe. Issues of land dispute belong to the Social Conflict Handling SOP (SOP/SMART/SENSES- CSRD/SADV/I/2) and there is the procedur of land compensation (SOP/NP/SMART/VII/D&L002). The compensation procedure already covers the ulayat right, as in point 6.2. Status: Conformity

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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 The identification and calculation of land compensation is detailed in 6.3. So far, the company, KUD and other parties around the village contacted inform that there has been no dispute since 2010 in the company surrounding area and no land acquisition occurred after 2010. The SIA report 2012 does not report the existence of ulayat right. Status: Conformity

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 Relating to wages year 2015, the company refers to Decree of the Governor of Lampung, No G/892/III.05/HK/2015 regarding Tulang Bawang Regency Minimum Wage Stipulation (UMK) Year 2105 of Rp. 1.588.500,-, valid as of 1/01/2015. This stipulation has been disseminated according to Decree No. 034/CEO 2/HR PSM 2/01/2015 regarding Day Laborer (BHL) Wage of PT. SIP-Lampung, in consideration of the above Governor Decree, to decide that: first, to raise the day laborer (BHL) wage to become Rp. 63.540,/day. This decision has been effective since 1/1/2015. There is Circular Letter PSM/II/012/I/2015 for the harvesting workers (loose fruit pickers) who is paid on a quantity basis i.e. Rp 1,932 per bucket. During the low crop season although the quantity of fruit picked does not achieve the HK base the loose fruit pickers will be given low crop reward if the plantation area harvested is 6 Ha. The standard of plantation area in which the loose fruit is to be picked still matches the reasonable ability of the fruit pickers. According to interviews with the fruit pickers both in the field and in the residential area, the largest area that they can harvest is 13 inter-rows only (1 ha approximately equals to 2 inter-rows, thus about 6 Ha). The payment of low crop reward will be made in the next pay period (one period more or less equals to 14 days). In the SMRE Estate based on sampling of 2 quantity day laborers on the reward payment (harvest and low crop) for the period of 26 February – 10 March 2014 they have been paid the daily pay in accordance with the minimum wage year 2014. The SMRM reported the mandatory manpower reporting on 10 June 2014. There were 642 CPUH (BHL). Based on sampling of day laborer contracts there have been the written agreement and has been known by the Head of HI and Control Section of the Mesuji Regency. With respect to wage system the company already has the policy which is contained in: (1) CLA Article 16 Wage System (2) Decree regarding Monthly Laborer Wage Scale (SKU-B) of PT. SIP – Lampung, starting from Class A1 to Class G-8. (3) The same Decree for SKU-H. (4) List of Policy F (Remuneration) starting from SDM F-001-00 to F 039. The harvesting worker’s equipment such as sickles is supplied by the company, but the pole and wheelbarrow are purchased by the harvesting workers with a subsidy from the company. The company should be better to supply all working equipment to its workers. Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 43of 73

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The company provides welfare amenities that spread across each unit (both estate and mill), as shown in the table below: List of Welfare Amenities Available in PT. Sumber Indah Perkasa of Sungai Merah and KKPA units. No. Type of Building Unit Location Total SBYE SMR GABA GALA MSJ SBY SMR E *) A M M 1. Staff housing Unit 13 12 11 10 2. Employee Housing Unit 201 20 119 3. Mosque Unit 4 1 1 1 4. Church Unit 1 5. Pre School Unit 6. Elementary School Unit 7. Rumpin Unit 8. Clinic – Posyandu (MSJA) Unit 1 1 1 9. Employee Rest Unit 6 10. Child Care Facility Unit 2 11. Cooperative Unit 1 12. Soccer Field Unit 3 1 1 1 13. Badminton Court Unit 4 1 1 1 14. Volley Court Unit 4 1 2 15. Tennis Court Unit 1 16. School Bus Unit 1 1 Total

Note: *) GABA shares the amenities with SBYE since both sites are closely located. The company has required its contractors to have complied with manpower regulations as shown in the sample contract No. SPK: SIP-SMRE/SPKL-L/Jan-2015/004-Angkut TBS dated 02/01/2015 that has included the requirements for PPE, Driver License, Truck Registration, and the minimum wage and jamsostek implementation. Status: Observation

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 The company already has a Trade Union. The policy that allows the formation of a trade union is contained in the Circular Letter from CEO-2 regarding Laborer/Worker’s Freedom of Association.

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It is the only Trade Union that covers all Units both Estate and Mill. The Union has been registered as stipulated in the Decree of the Branch Board of the Federation of Agricultural and Plantation Workers Union SPSI of Tulang Bawang Regency No. 15/PD.F.SPSI/LPG/X/2013, dated 27/10/2013 regarding the Approval of Work Unit Officials of SP.PP SPSI PT. SIP for the Period of 2013-2016 and already has the Collective Labor Agreement (CLA) with the registration number according to Decree of the Head of Manpower Office of Lampung Province No. 79/CLA/HI/III/2015 which is valid until November 2015. In addition to the Trade Union, the Bipartite Cooperation Body (LKS) has also been set up at each Unit. The worker’s union conducted meetings in 2014 on 4, 20 March, June, October and December. Issues discussed are among others minimum wage, health insurance, overtime pay, and premium. Status: Conform 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 The provisions on worker’s age are regulated in:  CLA Article 7 regarding recruitment of new employees; the paragraph 4 says they must be a minimum of 18 years of age.  PP chapter II Labor Relations, Article 5, paragraph 2 says the candidate employee must be a minimum of 18 years old. The Circular Letter from HR Director to all Unit Heads, No. 002/SE-HRDV/03/09, dated 31/3/2009 regarding the Minimum Age Requirement, swehubu. Law No. 13, article 68, regarding child labor prohibition, thus the minimum recruitment age is 18 years old. Data of employees of each Unit is maintained by the Personnel Department under KTU in the form of (1) SKU Employee Data (NO, NIK, name, gender, religion, No. KPJ, NPWP, place of birth (area of origin), address, ethnicity, date of birth, work starting date, age when working, job/position, marital status, wage. Based on labor data verification no worker is found to be under 18 years old. Status: Conform 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited The company gives equal opportunities to every person to be recruited to work with the company. The document: (1). HR Policy No. A-001-00, effective date 1/9/2005 issued by the Managing Director Strategic, point 2, says that the Organization in principle employs any individual with the competency according to position requirements regardless of ethnicity, race, and religion”. (2). Manpower Procurement Policy: the Provision of Recruitment and Selection Outside Jakarta (no. SDM A-006-00, dated 1/9/2005, regulates that manpower procurement does not favor for particular ethnicity, race, gender and religion. Status: Conform 6.9 A policy to prevent sexual harassment and other forms of violence against women and to protect the reproductive rights is developed and applied

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The company already has the policy related to prevention of sexual harassment which is documented in the circular letter No. 003/CEO2-SE/01/2011, dated 10/01/2011. The protection of woman reproductive rights has been incorporated including: - Company Regulation chapter IV, paragraph 25 regarding pregnancy and miscarriage leaves. - Memorandum No. 001/Memo/VPA PSM2/04/2011 regarding prohibition to employ pregnant and breastfeeding women as a chemical spraying worker. - Circular letter No. 095/CEO2-SE/12/2010 regarding menstrual leave. Complaint related to sexual harassment is submitted according the procedure as addressed in 6.3. Status: Conform 6.10 Growers and mills deal fairly and transparently with smallholders and other local businesses. During the audit the data of FFB price based on the Oil Palm FFB Purchasing Price Stipulation Letter by the Plantation Office of Lampung Province stipulated on 06 March 2015 is: CPO Price Rp. 7.388,68/kg Palm Kernel Rp. 5.335,00/kg FFB FFB Price 3 years old 1,193.69 4 years old 1,299.18 5 years old 1,340.75 6 years old 1,386.96 7 years old 1,428.16 8 years old 1,483.49 9 years old 1,526.74 Age > 10 years 1,534.17 The company already has FFB Grading Guidelines and FFB Grading WI No. PT SIP- SBYM/IK/04-1. It contains the criteria for sorting and the determination of penalty for out-of- specification fruit. The company has established the grading system and the penalty determination has already been consistent with the provisions stipulated by the Plantation Office. FFB from smallholders that is subject to a penalty is the immature FFB, less mature FFB and empty bunches, however there is no written agreement on such penalty. Data of grading results has been recorded by the grading officer and signed by the company among others by the grading officer and factory manager, however the grading results for the FFB from smallholders should also be signed by the smallholder KUD representative witnessing the grading process in order to ensure that the result of grading by the company is completely agreed by the smallholder KUD representative. Based on the information from the KUD management and the smallholder KUD representative in the fruit reception site the fruit from the smallholder being cut is those contained in the sampled trucks, while the unsampled trucks are considered not to be subjected to such cutting. Status: Conform 6.11 Growers and millers contribute to local sustainable development wherever appropriate The company has developed the CSR program for each unit for the community within the

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smallholder and nucleus estate environment. In 2014 the SMRE estate already had the CSR activity plan with a budget of Rp. 180,528,603.00 and had been realized amounting to Rp. 72,796,248.00. This realization included grader assistance for the repair of Wono Agung Village road on 18 May 2014, building material assistance for the construction of the Mosque Sidang Gunung Tiga on 31 October 2014, and cheap price oil operation on 18 and 20 July 2014. Status: Conform 7 RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS

7.1 A comprehensive and participatory independent 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 There was no new land acquisition 8 COMMITMENT TO CONTINUOUS IMPROVEMENT IN KEY AREAS OF ACTIVITY

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

The company has conducted monitoring on a reduction in the use of chemicals as can be seen in 4.6, environmental aspects and impacts in 5.1, waste minimization in 5.3, pollution and emission in 5.6, and social impacts in 6.1. The company has conducted the RSPO internal audit on 03 – 08 November 2014. The audit team developed 2 separated reports using each of the criteria in the guideline. Non conformity that existed had its sufficient corrective action made. Status: Conform

C.2 RSPO SUPPLY CHAIN MODUL E – CPO MILL : MASS BALANCE

PT. Sumber Indah Perkasa – Sungai Merah Mill (SMRM) is implemented the supply chain system procedures as required in RSPO certification. The company has set the supply chain system categorized as Mass Balance scheme.

E3. Documented Procedures E.3.1 a) Complete and up to date procedures covering the implementation of all the elements in these requirements.

Records/Evidence:

There is procedure SOP Identifikasi dan kemampuan-telusuran (SOP Identification and Traceability) Traceability) SOP/SMART/CERS-

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EHSD/SADV/I/001

b) The name of the person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements. This person shall be able to demonstrate awareness of the facilities procedures for the implementation of this standard.

Records/Evidence:

Management Representative related to RSPO-SCCS implementation

Traceability officer related to RSPO-SCCS implementation SMRM decree no. 010/PC-SMRM/III/2013

Document controller – SPO Offider related to RSPO-SCCS Implementation, decree : 005/FM-SMRM/III/2013

E.3.2 The facility shall have documented procedures for receiving and processing certified and non-certified FFBs. Records/Evidence:

 SOP identifikasi dan kemampuan-telusuran (SOP Identification and traceability) PT SIP-SMRM/SOP/01  Surat Pengantar Buah (Fruit Delivery Letter) (SMRE & GABA) with ‘’Mass Balance’’ mark SMRM: Form Rekap Penerimaan TBS Per Unit (FFB Receiving Resume Form each Unit)

E.4 Purchasing and goods in E4.1 The facility shall verify and the document the volumes of certified and non-certified FFBs received. Records/Evidence:  There is procedure SOP Identifikasi dan kemampuan-telusuran (SOP Identification and traceability PT SIP-SMRM/SOP/01  There is a database system called Weightbridge Computerized Program which has been designed to separate certified and non-certified incoming FFB from own estate, Scheme small holders and independent small holders with the specific code in database. 

E.4.2 The facility shall inform the CB immediately if there is a projected overproduction.

Records/Evidence:

The company has a mechanism to inform the certification body (CB) immediately if there is a projected overproduction as seen in “SOP Identifikasi dan

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Kemamputelusuran Produk Bersertifikat” (identifcation and tracebility of certified products) SOP/SMART/CERS-EHSD/SADV/I/001

E.5 Record keeping E.5.1 a) The site shall record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO and PK on a three-monthly basis

evidence :

At the time of audit there were no RSPO product stored and recorded. However the company has the monthly, three-monthly, and annual report which contain record and balance all receipts of RSPO certified FFB and deliveries of ISCC certified CPO and PK.

(SMRM Mass Balance Monthly Report, SMRM Mass Balance Three-Monthly Report, and SMRM Mass Balance Annual Report)

b) All volumes of palm oil and palm kernel oil that are delivered are deducted from the material accounting system according to conversion ratios stated by RSPO.

Evidence :

There is a database system called Weightbridge Computerized Program which has been designed to align and integrate from the material accounting system according to conversion ratios stated by RSPO. The supporting data such as:

Massa Balance Report ; Daily, Monthly, Three-Monthly, and Annually CPO Production Report

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

Sell short has been discussed in procedure “SOP Pelaporan prosedur Bersertifkat SOP/SMART/CERS-EHSD/SADV/I/003”

E.5.2 In cases where a mill outsources activities to an independent (not owned by the same organization) palm kernel crush, the crush still falls under the responsibility of the mill and does not need to be separately certified. The mill has to ensure that the crush is covered through a signed and enforceable agreement.

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Evidence

There were no outsourced activities

.

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C.3 Status Of Non Conformity Previously Identified

Non Conformity / Observation Report Organization No. Audit Standard. Audit Date : 19-07-2013 (TSS, RQ, GGU, YSF, WS, ) RSPO 00003 No. 02 (1) RSPO (Certification) ATL / Auditor : RSPO 00004 Organization Rep. :

Audit Claus Corrective Action & Team No. Category e Std Auditor Description Root Cause Investigation* Evidence* Review (1) (2) (3) (4) (5) (6) (7) (8) (9) 1 Minor 6.9 1 WS The implementation of sexual Sexual harassment To completed the Closed harassment socialization to socialization has been documentation of sexual employees is limited compared conducted to the workers, harassment socialization. to the number of workers. Data but the documentation was Evidence : showed : cannot be showed at the Documentation of sexual -In GABA Unit, the number of time of audit. harassment socialization is workers has been socialized to available at SPO secretariat. 30 workers. For BHL and PKWT personnel are30 out of 276 workers (only 10.9 %).

2 Observation 4.6 1 YSF Company has used herbicide The company still apply The management has issued Closed registered in Pesticide restricted pesticide i.e. memo to reduce the paraquat Commission of the Republic of paraquat. No. 002/MEMO-VPA Indonesia but the use of PSM2/04/2011. The restricted pesticide should be restricted pesticide will be reduced gradually and monitored yearly to see the substituted by a more trend of paraquat reduced. environmentally friendly Evidence : herbicide and safer to field Graphic of restrictedpesticide

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operators. use year 2011-2013 showed the reduce of paraquat used. 3 Observation 4.7 1 YSF Company has undertaken The workers with exposure To conduct identification the Closed workers health examination to chemical material hazard workers with risks of covering cholinesterase and were not checked for chemical exposure and audiometry but for those spirometry. gradually will conduct working with risks of chemical spirometry checking. exposure should be added with Evidence : spirometry examination to 1. List of worker who ensure their lung health. needs to be checked for spirometry. 2. Medical check program for spirometry. 4 Observation 2.3 1 TSS/GG Organization has made a map The company has the Map will be adjusted to be Closed U but the map should have a different scale for all maps. scale 1 : 100.000 sufficient scale, at least 1: Evidence : 100.000 in accordance with Map with the scale 1:100.000 Decree of the Ministry of Forestry No. 48/menhut- II/2004. 5 Observasi 5.2 1 TSS/GG Organization has performed There is no column for PIC Completed the form with edit Closed U monitoring and contained in and Action Plan at Form PIC and Action Plan. HCV Monitoring Report, but it HCV Monitoring. Column. should establish Person in Evidence : Charge (PIC) and due date of Revision of Form HCV the recommendation specified Monitoring. in the HCV monitoring report to see the follow up and progress of such recommendation.

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6 Observation 4.7 1 WS Company already complete The simulation of fire To fulfill the number of fire Closed with the provisions of Decree fighting has conducted but fighter to meet with the of the Ministry of Manpower the number of the fire Kepmenaker No. 186 Tahun No. 186/1999 related to the fighter was not meet with 1999. number of fire mitigation the government regulation Evidence : personnel in mill area. But it (Kepmenaker No. 186 Documentation of fire fighter only trained 20 personnel for Tahun 1999). training. both mills (it should be 12 personnel for each mill). It should ensure to gradually conduct training to cover the remainder in class D, C, B and A. 7 Observation 8.1 1 TSS Companyshould develop a Yearly CSR Program has The company will re- Closed specific method to evaluate the been setup for each unit, but identification the existing effectiveness of CSR program not yet covered the culture indigenous people. If there is done as input to future program program. For the strategic then the company will setup improvement. planning year 2014-2018 the CSR to develop and has addressed the vision and maintain the culture of mission to develop and indigenous people. maintain the culture of local Evidence : people. Revise CSR Program. 8 Observasi 6.10 1 TSS Company should ensure The company has conducted The company will conduct Closed cooperative’s efforts to the socialization to the monthly meeting and to socialize aspects that become a cooperation staff and socialized the factor in price factor in price cutting related to coordinator staff, regarding cutting related to costs costs imposed to plasma the factor in price cutting imposed to plasma members members for maintenance and related to costs imposed to for maintenance and transportation costs. Proof that plasma members for transportation costs. all parties understand the maintenance and Evidence : contract agreement they entered transportation costs. But the The documentation of to, and that the contracts are socialization was not meeting schedule between fair, legal and transparent. sufficient some of the company and cooperation is members were found well available. not understand for the subject.

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9 Observation 1.1 1 TSS It is advised that company Obs ensures responses to any information request as required by related SOP where responses are to be given within 1 month at the latest. Sampling II, no records are found on request for assistance applied by Ibu Nurhayati on 18 May 2013 i.e. application for educational and playing equipment assistance for TK Dharma Batu Ampar.

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C.3 Isues Raised by Stake Holders Consultation

Issue Assessor comment Labor Union No comment there was no other Union Leader : Mr. Sopuan dependable sources data to confirm - No Issue raised the information raised by Labor Union. Cooperation Krida Sejahtera The company agree to make written Vice head : Samsudin agreement regarding the grading Secretary : Bukhori methods and penalty Treasury : Sujoko Regarding poor road infrastructure - The grading methods have been clearly defined there is no further comment, since and there are two (2) staffs present at the mill there was no data about the location every day as a witness during grading process. where the damaged taken place, the However there was no written agreement severity of the damage. regarding the grading - Poor road infrastructure, resulting in increased transport costs. According to the information of damage occurred in the government / public

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D. Certified Organization’s Acknowledgement of Internal Responsibility D.1. Formal Sign-Off of the Assessment Findings I the undersigned, being the legal representative of the inspected company, agree with the contents of this report and accept the liability in execution of the instructions given in the report.

Name Ismu Zulfikar Position Head of Environment and CSR Coordination Signature

Date

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

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

Verified and Reviewed by:

Name Warsid Sumarlin

Position SLA / LA / Auditor

Signature

Date August, 26th 2015

Approval:

Name Triyan Aidilfitri

Position HSE Audit and Certification Department Head

Signature

Date August, 26th 2015

B. 4. Date of Next Surveillance Visit One (1) year after date of 2015 surveillance audit

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List of Abbreviation

AMDAL Analisa Mengenai Dampak Lingkungan (Environment Impact Study Report) ANDAL Analisa Dampak Lingkungan (Environment Impact Analysis Report) BOD Biological Oxygen Demand BPN Badan Pertanahan Nasional (National Land Agency) COD Chemical Oxygen Demand CPO Crude Palm Oil CSR Corporate Social Responsibility DOE Department of Environment EFB Empty Fruit Bunch EIA Environment Impact Assessment FFA Free Fatty Acid(s) FFB Fresh Fruit Bunch FSMS Food Safety Management System GMP Good Manufacturing Practice GABA Gedung Aji Baru Estate GALA Gedung Aji Lama Estate GPS Global Positioning System Ha Hectare(s) HACCP Hazard Analysis and Critical Control Point HCV High Conservation Value HCVF High Conservation Value Forest HGU Hak Guna Usaha (Land Use Title) HSE Health Safety Environment IEMA Institute of Environmental Management and Assessment IPB Institut Pertanian Bogor IRCA International Register of Certified Auditor JAMSOSTEK Jaminan Sosial Tenaga Kerja (Labor Social Insurance) K3 Keselamatan dan Kesehatan Kerja (Occupational Safety and Health) KAN Komite Akreditasi Nasional (The Indonesian Accreditation Committee) KKPA Kredit Kepada Koperasi Primer KLH Kementerian Lingkungan Hidup (Ministry of Environment) KTU Kepala Tata Usaha (Administration Head) LCC Legume Cover Crop LSM Lembaga Swadaya Masyarakat (NGO(s)) MOU Memorandum of Understanding MSDS Material Safety Data Sheet MSJA Mesuji Estate NA Not Applicable NC Non Conformity NCR Non Conformity Register

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OER Oil Extraction Rate OSH Occupational Safety and Health OSHAS Occupational Safety and Health Assessment Scheme P&C Principle and Criteria PHT Pengendalian Hama Terpadu ( Integrated Pest Management/IPM) PK Palm Kernel PKO Palm Kernel Oil POM Palm Oil Mill POME Palm Oil Mill Effluent PPE Personal Protective Equipment RSPO Roundtable on Sustainable Palm Oil RSPO NI Roundtable on Sustainable Palm Oil National Interpretation RKL-RPL Rencana Kelola Lingkungan dan Rencana Pemantauan Lingkungan (Environment Management Plan – Environment Monitoring Plan) SA8000 Social Accountability 8000 SIA Social Impact Assessment SIO Surat Izin Operator SOP Standard Operating Procedure SIP Sumber Indah Perkasa SBYM Sungai Buaya Mill SBYE Sungai Buaya Estate SMK3 Sistem Manajemen – Keselamatan dan Kesehatan Kerja (Management System of Occupational Safety and Health) SMRM Sungai Merah Mill SMRE Sungai Merah Estate TTD Tim Tanggap Darurat (Emergency Response and Preparedness) UKL Upaya Pengelolaan Lingkungan (Environmental Management Efforts) UPL Upaya Pemantauan Lingkungan (Environmental Monitoring Efforts) WWTP Waste Water Treatment Plant WHO World Health Organization

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ATTACHMENT-1 MAP

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1.1. Overlay Map of Sungai Merah Estate (SMRE) and KKPA Gedung Aji Baru (GABA) Estate

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1.2. Map of Rivers

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1.3. Map of HCV Gedung Aji Baru Estate

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1.4. Map of Topography

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1.5. Map of Planting Year Sungai Merah Estate (SMRE)

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1.6. Map of Planting Year Gedung Aji Baru (GABA) Estate

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ATTACHMENT-2 Non Conformity & Observation Report

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NCR and Observation finding during ASA 1

Non Conformity / Observation Report 20-03-2015 (TSS, RB, GGU, NS, ) Audit Organization No. Standard. Audit Date : RSPO 00003 No. 03 (1) RSPO (Certification) ATL / Auditor : RSPO 00004 Organization Rep. :

Audit Corrective Action & Team No. Category Clause Std Auditor Description Root Cause Investigation* Evidence* Review (1) (2) (3) (4) (5) (6) (7) (8) (9) 1 Observation 2.1 3 RB The company already has 4 SOP for HGU Poles maintenance procedures and the company also has conducted monitoring on HGU poles. It is advised that the monitoring check lists include column coordinate to ensure the appropriate coordinates 2 Observasi 4.1 3 RB Harvesting been conducted 4 correctly as well as the preparation of fruit at fruit collection place (TPH). The company should make improvements to the TPH

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which are destroyed to maintain the quality of FFB. 3 Observasi 4.5 4 GGU Preferably in the rat attack census form and UPDKS census should mention offensive category refers to available procedures (SMRE)

4 Observasi 5.2 4 GGU It is advised that in Sungai Merah Estate to have a record of dissemination policies regarding the protection of flora and fauna of rare and endangered to stakeholders around the estate.

7 NC 4.7 3 NS At SMRE there are 399 Minor 4 people who until March 2014 had included the Social Security program JKK and JKM, but since April 2014 can not be paid the fee due to the letter from Employment BPJS Lampung II, which stated it no longer accept the membership to partial program JKK & JKM (only) while the company has not had a mechanism to self bear work-related accidents and deaths that

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have been approved by the local Manpower Office.

8 Observation 6.1 3 NS In the grading process of 4 plasma FFB should also be signed by representatives from cooperative plasma who witnessed the grading process to ensure that the results of the grading by the company actually has been approved by representatives of plasma cooperative. Cooperative has learned that to FFB from plasma estate that getting penalty is for unripe FFB, under ripe FFB and empty bunch. In order to be more clear and legally binding, the penalty provisions should be put into the written agreement 9 NC 4.7 3 HDY Periodic health checks for MINOR 4 Cholinesterase and Spirometry has not been done consistently every 6 months in accordance with the procedures and regulations of Decree no. 03 in 1986. A working environmental A working environmental Corrective Action : Closed monitoring which was monitoring which has not Measurement of working conducted on the Mill of been carried out did not environment for dust and SMRM had not include Dust include parameter of dust WBGT will be held in and WBGT as Permenaker and WBGT. conjunction with other

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no. 13 in 2011 environmental monitoring.

Evidence : Dust and WBGT measurement results on SBYM and SMRM Target Date : 11 April 2015 Based on audiometric measurement results that have been done in 2013, there were employees who have problems with hearing. However the action to conduct the remediation as per doctor recommendations was not conducted until March 2015 10 NC 2.1 3 HDY Licensing of water extraction Based on letter no. Status Major 4 and utilization of the Sungai 520/342/ii.07/2015 from of Merah to the POM has not Badan Penanaman Modal finding been conducted dan Pelayanan Perizinan down terpadu, the permit to use graded survace water are still in as minor progress 11 Observasi 5.5 3 HDY Facilities and infrastructure 4 of fire prevention and control of land and gardens that must be owned by the garden are advised to adapt the fire control guidelines for land and estate of the Directorate General of Plantation of the Ministry of Agriculture. 12 NC 2.1 3 HDY The company is already From 7 deep wells, there Corrective Action : Open Minor 4 doing licensing for 2 points were only 2 wells which Documenting the results of

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of deep wells, i.e: 1 point for has been found those water quality testing. Mesuji and 1 point for license. 1 for SMRE and SMRE. But has not done 1 for MSJA Evidence : the results of Identification of the other the water analysis in each deep wells related licenses, unit. analysis of water, discharge water use Target Date : 10 April 2015 14 Observasi 6.5 3 HDY Monitoring of well water 4 according to permenkes 416 1990 has been conducted by Politeknik Kesehatan Tanjung Karang. The item has included microbiological parameter such as Coliform, but not included E. Coli. It advised in the next monitoring, all the microbiological parameters included.

15 Observasi 5.1 3 HDY Reporting of the 4 implementation of RKL and RPL was reported bi annually while the AMDAL document from Lampung Province, requires the company to report every 3 months.

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