Roundtable on Sustainable Palm Oil Surveillance Audit Report Report No: ASA11_14007 Recertification against RSPO Generic Principle and Criteria 15 November 2013 and RSPO SCCS November 2014

Name of client Bakrie Sumatera Plantation Area Sumut 1 and Palm Oil Mill Kisaran

Head Office: Jl. Ir. H. Juanda, Kisaran, Asahan District, North Sumatera Province, Indonesia 21202

Date of Audit: May 16th to 20 th , 2016

Wahyu (RSPO Lead Auditor)

Certification decision by: Abdul Qohar (Director PT TUV Rheinland Indonesia)

Certification Body: PT TUV Rheinland Indonesia Menara Karya 10 th Floor Jl H.R. Rasuna Said Block X-5 Kav. 1-2 Jakarta 12950 – Indonesia Telp +62 21 579 44 579 Fax +62 21 579 44 579 www.tuv.com TABLE OF CONTENTS

1.0 SCOPE OF CERTIFICATION ASSESSMENT ...... 3 1.1 National Interpretation / Standard Used ...... 3 1.2 Scope of Assessment ...... 3 1.3 Certification Details ...... 3 1.4 Location and Maps ...... 4 1.5 Organisational Information / Contact Person ...... 6 1.6 Description of Supply Base ...... 7 1.7 Actual production volumes and project outputs...... 7 1.8 Dates of Plantings and Replanting Cycles ...... 8 1.9 Area of Plantation (Total, Planted and Mature) ...... 8 1.10 Progress Against Time Bound Plan ...... 9 1.11 Progress of associated smallholders or outgrowers towards RSPO compliance ...... 9 1.12 Approximate Tonnages Certified ...... 10 2.0 ASSESSMENT PROCESS ...... 11 2.1 Certification Body ...... 11 2.2 Qualifications of Lead Assessor and Assessment Team ...... 11 2.3 Assesment Methodology & Agenda ...... 12 3.0 ASSESSMENT FINDINGS ...... 14 3.1 Summary of Findings pertaining to RSPO Principles & Criteria...... 14 3.2 Status of Previously Identified Non-conformities ...... 41 3.3 Identified Non-conformances against RSPO P&C Requirements, Corrective Actions Taken and Auditors Conclusions...... 47 3.4 Description of Supply Chain Management System ...... 49 3.5 Status of Previously Identified Non-conformities ...... 51 3.6 Identified non-conformance against RSPO SCCS requirements, Corrective Actions Taken and Auditors Conclusions...... 51 3.7 Noteworthy Positive Components ...... 52 3.9 Issues Raised by Stakeholders and Findings Pertaining to Issues...... 52 4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY ...... 52 4.1 Date of Next Surveillance Visit ...... 52 4.2 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client ...... 52 APPENDICES ...... 53 Appendix 1(a): Details of Revised Certificate ...... 53 Appendix 3: List of Abbreviations ...... 55 Appendix 4: List of Stakeholders Interviewed and Contacted ...... 56 Appendix 5: Observations and Opportunities for Improvement ...... 56

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1.0 SCOPE OF CERTIFICATION ASSESSMENT

1.1 National Interpretation / Standard Used The operations of the palm oil mill(s) and its supply base of FFB were assessed against the RSPO Gener- ic Principe and Criteria 15 November 2013 and RSPO SCCS November 2014

1.2 Scope of Assessment This surveillance I assessment was carried out on 1 (one) mill and 5 (five) estates (Tanah Raja estate, Kuala Piasa estate, Gurach Batu estate, Serbangan estate, and Sei Baleh estate) under PT Bakrie Su- matera Plantation by Bakrie Sumatera Plantation Group. The date of re-certification of this unit was April 13 – 16,, 2015.

1.3 1st Surveillance Details The details of RSPO 1st surveillance assessment of PT Bakrie Sumatera Area Sumut 1 - Kisaran Mill are as per table below:

Table 1: Certification details of PT Bakrie Sumatera Plantation Area Sumut 1

RSPO Membership no.: 1-0036-07-000-00

RSPO Certificate no.: 824 502 14007

Date of first RSPO certificate & va- Issued: June 14, 2010 & validity: 2010-06-14 to 2015-06-13 lidity:

Date of certification audit: May 25 to 29, 2010 Date of previous re-certification au- April 13-16, 2015 dit: Date of revised RSPO certificate & Revised: November 03, 2015 & validity: 2015-06-14 to validity (if applicable): 2020-06-13

CPO tonnages claimed: 34,989 PK tonnages claimed: 6,846

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1.4 Location and Maps

PT BSP Area Sumut 1

Figure 1: Location of PT Bakrie Sumatera Plantation Area Sumut 1 in North Sumatera, Indonesia

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KIsaran Palm Oil

Figure 2 : Map of PT Bakrie Sumatera Plantation Area Sumut 1 – Kisaran Mill

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Table 2: GPS locations for all estates and mills included in annual surveillance assessment

GPS locations Name of mill / Location estates Latitude Longtitude

Jl. Ir. H. Juanda, Kisaran 21202, Asahan Main office 02º59’04.6” 099º38’12.1” Regency, North Sumatera Indonesia

Sei Baleh Village, Sei Baleh District, Batu Palm Oil Mill 03º02’26.7” 099º34’53.2” Bara Regency, North Sumatra Province.

Sei Renggas Village, Kisaran Barat Dis- Tanah Raja trict, Asahan Regency, North Sumatra 02º57’50.0” 099º35’57.7” Province.

Gerak Tani Village, Meranti District, Asa- Gurach Batu 3°20’45.0” 99° 58’23.4” han Regency, North Sumatra Province.

Tinggi Raja Village, Tinggi Raja District, Kuala Piasa Asahan Regency, North Sumatra Prov- 02º54’04.2” 099º34’00.2” ince. Rawang Lama Village, Panca Arga Dis- Serbangan trict, Asahan Regency, North Sumatra 03º01’29.8” 099º39’30.3” Province.

Sei Baleh Village, District Sei Baleh, Batu Sei Baleh 03º04’12.1” 099º35’11.0” Bara Regency, North Sumatra Province.

1.5 Organizational Information / Contact Person Contacts details of the company are as follows: Company Name: PT Bakrie Sumatera Plantation Tbk Kisaran Unit Jl. Ir. H. Juanda, Kisaran 21202, Asahan Regency, North Sumatera Address: Province, Indonesia Sei Baleh Village, Sei Baleh District, Batu Bara Regency Contact Person: Mr. Andi Wahyudin Telephone: +62-623- 41434, +62-623-348614; Fax: +62-623-41066 Email: [email protected] 1. HGU (Land use certificate) No. 66.HGU/DA/85/B/151 with area of 18,556.01 Ha, valid from 13 November 1996 for 25 years. 2. HGU No. 020.HGU/1991 with area of 2,714 Ha valid from 7 De- cember 1991 until 31 December 2020. 3. HGU No. 026/HGU/BPN/1999 with area of 952 ha valid since 19 March 1999 for 35 years. Legal Permit * 4. Government directives: BKPM Decision Letter No. 257/T/Pertanian/Industri/1989 and BKPM Decision Letter 5. No. 1293/T/Industri/2008 regarding Capital Investment within the State (‘Penanaman Modal Dalam Negeri’). HGU Area includes Aek Salabat estate that has not included in certifi- cation scope )

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1.6 Description of Supply Base

Table 3: FFB Supply Information for Kisaran Palm Oil Mill for period year 2015 & year 2016

FFB supplied Tonnes* FFB supplied Tonnes** FFB Contributors Tonnes % Tonnes % Company owned estates:

- Serbangan Estate 27,207.450 10.94 8,218.880 12.73

- Sei Baleh Estate 36,832.950 14.81 9,090.660 14.08 - Gurach Batu Estate 13,236.540 5.32 3,419.250 5.30 - Tanah Raja Estate 33,822.470 13.60 8,654.590 13.41 - Kuala Piasa Estate 30,411.600 12.23 8,157.790 12.64

Sub Total owned state 141,511.010 56.90 37,541.170 58.16 Other company’s area (Aek Sal- 14,542.450 5.85 4,440.180 6.88 abat & Seed Garden) Outgrowers 92,690.689 37.26 22,572.251 34.97

TOTAL 248,744.149 100 64,553.601 100

Note: *) Data from January to December 2015 **) Data from January to April 2016

1.7 Actual production volumes and project outputs.

Table 4: Total CPO and PK production from Kisaran Palm Oil Mill for period of January-December 2015 and projected production for year 2016

Amount (MT) Item CPO PK Certified tonnages claimed (stated on previous certificate) 34,989.670 6,845.805 Certified tonnages sold (2015) 3,303.012 - Certified tonnages purchased (2015) - - Actual Production* 53,089.054 10,755.707 Actual certified product production** 32,533.381 6,481.204 Projection FFB production in 2016*** Projection FFB certified only 132,975.623 Extraction Rate (%) 23.50 4.5 Projected output for year 2016 31,249.271 5,983.903

* Data from January to December 2015, consisting of material from certified and non-certified FFB ** Data from January to December 2015, material from certified FFB only *** Budget production for 2016 for certified FFB, CPO and PK only

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1.8 Dates of Plantings and Replanting Cycles The company follows a replanting cycle of 25 years. Information on the dates of plantings is as per the ta- ble below.

Table 5: Age and year of plantings of company estate supplying to Kisaran Palm Oil Mill

Oil palm planted area at each estate (ha) Age & Year of Total Plantings Serban Sei Gurah Tanah Kuala Salabat Planted gan Baleh Batu Raja Piasa Aek 2011 – 2016 (0 – 5) 469 139 184 132 123 - 1,047 - 2006 – 2010 (6 – 10) 612 636 422 922 - 2,592

2001 – 2005 (11 – 15) 146 472 - 589 122 3 1,332

1996 – 2000 (16 – 20) 150 194 132 196 1,497 - 2,169 < 1995 ( > 21 ) 461 799 249 111 502 6 2,128 TOTAL 1,838 2,240 987 1,950 2,244 9 9,268

Table 6: Planned and actual oil palm replanting activities and conversion from rubber plantation to oil palm plantation year 2013 to 2016 PT Bakrie Sumatera Plantation Tbk Kisaran Unit*

Total Planned Actual Replanted Area Actual Total Re- Year Replanting planted Area Up Serba Sei Gurah Tanah Kuala Area (ha) to Year 2016 (ha)* ngan Baleh Batu Raja Piasa 2013 359 235 13 56 - 55 359 2014 702 368 59 101 - 174 702 2015 329 76 - 253 - - 329 2016 403 46 84 - 55 218 403 Total 1,793 725 156 410 55 447 1,793 * Based on planted realization 2016 (January – April 2016)

1.9 Area of Plantation (Total, Planted and Mature) Table 7: Oil Palm Planted Area Summary, FFB Production and Average yield/ha for PT Bakrie Su- matera Plantation Tbk Kisaran Unit Oil Palm FFB Total area Mature Immature Nursery Average Estate Name Planted Production* (Ha) area (ha) Area (ha) and L/C yield/ ha* Area (Ha) (tonnes)

Serbangan 1,838 1,838 1,470 368 - 27,199 18.6

Sei Baleh 2,240 2,240 2,181 59 - 36,832 16.9

Gurach Batu 987 987 886 101 - 13,236 14.9

Tanah Raja 1,950 1,950 1,950 - - 33,811 17.3

Kuala Piasa 2,244 2,244 2,121 123 - 30,422 14.3

TOTAL 9,259 9,259 8,582 651 - 141,502 16.4 Note * Data from January to December 2015

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Table 8: Land use data for PT Bakrie Sumatera Plantation Tbk Kisaran Unit*

Oil HCV/ To- Rubber Land used for other purposes (ha) Palm Potential tal Planted Estate Name Planted HCV Road, rivers area Area Nurse- Other Area areas Building and rail- (ha) (ha) ry Purposes (ha) (ha) ways Serbangan 3,391 1,422 1,838 44.20 56 74 - 1

Sei Baleh 3,955 1,588 2,240 131.66 53 69 - 5

Gurach Batu 3,562 2,474 987 66.48 43 50 - 8

Tanah Raja 4,152 1,845 1,950 45.73 169 144 - 46

Kuala Piasa 2,764 450 2,244 343.17 22 35 - 13

TOTAL 17,824 7,779 9,259 642.01 343 370 - 66

1.10 Progress Against Time Bound Plan

Table 9: Time Bound Plan of the Other Management Units

Time bound plan Name of Holding Location Remarks for certification Kisaran, North Su- Re-certified on November BSP Kisaran 2009 matera 03, 2015 Agrowiyana Jambi 2010 June 2013 Pasaman, West Su- Waiting for RSPO Board Bakrie Pasaman Plantation 2011 matera Approval - Keluar dari timebond Graha Dura Leidong Prima North Sumatera 2016 per 2015 Keluar dari timebond per 2013 karena kepemilikan Indogreen Kalteng 2016 BSP di Indogreen minoritas

1.11 Compliance to Rules for Partial Certification Compliance of the uncertified management units of Bakrie Sumatera Plantation against the rules for par- tial certification according to RSPO Certification System clause 4.2.4 was assessed by submission self assessment report. A summary of findings is as stated below.

Partial Certification Requirements Audit Findings (a) The parent organization or one of its majority owned PT Bakrie Sumatera Plantation Kisaran is and / or managed subsidiaries is a member of RSPO. RSPO member with membership number 2-0017-05-000-00. (b-d) A challenging time-bound plan for certifying all its PT Bakrie Sumatera Plantation Tbk has relevant entities is submitted to the Certification Body revised the time bond plan as determined (CB) during the first certification audit. The time-bound on the table above. The revision due to in- plan should contain a list of subsidiaries, estates and ternal economic reason, so several com- mills. panies under PT Bakrie Sumatera Planta- tion Tbk, delayed for certification process- Any revision to the time-bound plan or to the circum- es. stances of the company shall cause the plan to be re-

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viewed. For whether it is still appropriate, such that changes to the time-bound plan are permitted only where the organization can demonstrate that they are justified (e) No replacement of primary forest or any area identified According to the audit result and man- as containing High Conservation Values (HCVs) or re- agement interview verification there is no quired to maintain or enhance HCVs in accordance with replacement of primary forest or any area RSPO criterion 7.3. Any new plantings since January 1 st as containing High Conservation Values 2010 must comply with the RSPO New Plantings Proce- dure (f) Land conflicts, if any, are being resolved through a mu- According to the audit result, management tually agreed process, e.g. RSPO Grievance procedure or review verification and stakeholder com- Dispute Settlement Facility, in accordance with RSPO cri- munication, the company has a good rela- teria 6.4, 7.5 and 7.6. tionship with all of stakeholder and there is no land conflict has identified. (g) Labor disputes, if any, are being resolved through a According to the audit result and workers mutually agreed process, in accordance with RSPO crite- interview on PT Bakrie Sumatera Planta- rion 6.3. tion, there is no labor disputes in the com- pany (h) Legal non-compliance, if any, are being resolved in All of others management has RSPO been accordance with the legal requirements, with reference to certified and waiting for approval from RSPO criteria 2.1 and 2.2. RSPO Board.

1.12 Progress of associated smallholders or out growers towards RSPO compliance There is no smallholder scheme in PT BSP SUMUT Unit 1 that supplies to Kisaran Palm Oil Mill. Addi- tional FFB is supplied from independent out growers.

1.13 Approximate Tonnages Certified The approximate tonnages certified should be the same as per the 1 st revision of the certificate, which is as follows: - Crude Palm Oil (CPO) : 34,989 MT - Palm Kernel (PK) : 6,846 MT

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2.0 ASSESSMENT PROCESS 2.1 Certification Body PT TUV Rheinland Indonesia is member of Group TÜV Rheinland Group, a global leader in independent testing and assessment services. The TÜV Rheinland Group was established in 1872 with offices located in over 490 locations in 62 countries on all five continents. TUV Rheinland Indonesia offers certification for a wide range of management systems according to established international standards including ISPO, ISCC, Ecohotel, SNI, CE Mark, ISO 9001, ISO 14001, OHSAS 18001, SA 8000, as well as CDM Valida- tions and Verifications. TUV Rheinland Indonesia office is located in Menara Karya Menara Karya 10 th Floor Jl H.R. Rasuna Said Block X-5 Kav. 1-2 Jakarta 12950 – Indonesia phone (+62 21) 579 44 579 and Fax (+62 21) 579 44 579, www.tuv.com .

2.2 Qualifications of Lead Assessor and Assessment Team Wahyu is the lead auditor for this surveiillance audit. There is no assessment team members of this sur- veillance audit that were part of the same assessment team for the previous audit. There for the assess- ment team members during the 1 st surveillance audit are as per the table below:

Name Position Qualifications / Experience

Education: Bachelor degree of Mechnical Engineering - University of Indo- nesia and Magister of Manufacturing - Pancasila University

Trainings attended: ISO 9001 and ISO 14001 IRCA Lead Auditor Training, Training of ISO 28000, TOT of Maritime Security, ISO 22000, and OHSAS 18001, SVLK Lead Auditor Training, COC – LEI Lead Auditor Training, VLO & RIL Training, ISPO Lead Auditor Training, and RSPO Lead Auditor Train- Lead Wahyu ing. Auditor

Working experience: Arround 8 (eight) years as technician and engineer at manufacturing industries, 3 (three) years as QHSE Head at independent surveyor and inspection services company , 3 (three) years as QHSE Con- sulant, and 6 (six) years as auditor of ISO 9001, ISO 14001, OHSAS 18001, SVLK, COC – LEI, SVLK for Industry, ISPO and RSPO

Education: Bachelor of Forestry, Faculty of Forestry, Bogor A gricultural University

Trainings attended: Awareness training of ISO 9001, 14001 and 18001, inhouse training of ISO 19011 and ISPO, Training of Assesor for Sustainability Natural Forest Management (SFM) by The Indone- sian Ecolabel institute (2008), Training of Auditor for Sustainability Forest Management By center for Educational and Training of For- Ade estry, Department of Forestry (2010), Examination of competency for Auditor Sudiana auditor of Sustainability Forest Management by Personal Certifica- tion Body - Rhino (2014), Training of Auditor For ISPO (2016) by ISPO Comission.

Working experience: Consultant and Trainer of : Quality Management System (ISO 9001), Environment Management System (ISO 14001), Safety Management System (SMK3/ OHSAS 18001), ISPO (Indone- sian Sustainable Palm Oil), Consultant and Trainer in PT FOCUS (2008-2016); Auditor of: Sustainability Forest Management (SFM) for Plantation and Natural Forest (2010-now), Auditor in PT Forestcitra

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Page 12 of 56 Sejahtera (2008-2016); Auditor of SFM, RSPO and ISPO, Auditor in PT TUV Rheinland Indonesia (2016-now). Education : Bachelor of Agriculture, Bogor Agricultural Institute

Trainings attended : - Indonesian Sustainable Palm Oil (ISPO) Auditor Training, - Sustainable Forest Management (Bogor, 2013).

M. Nurul Working Experience : Auditor Anwar Trainer for community development and entrepreneurship projects and moti- vator for micro business entrepreneurship program since 1999, experience as expert of micro business development (1995-2006), team leader of com- munity development program (2006-2012), program manager of corporate social rensponsibility in PT Aneka Tambang (2012) and PT Timah (2013), ISPO Auditor since 2014, SFM Auditor since 2013, Agriculture Expert for ANDAL and AMDAL since 2008

2.3 Assessment Methodology & Agenda The surveillance assessment was conducted on May 16 to 20, 2016 as per the assessment program be- low. The assessment was carried out in accordance with TUV Rheinland Indonesia RSPO audit proce- dure as well as the RSPO Certification Systems document. During assessment, the qualified TUV Rhein- land assessors used the RSPO standard as endorsed for the country in which the assessment took place and recorded their findings. Due to the location and proximity of the estates, combined with common management systems, it was possible to carry out both field and document assessments of all estates and the mill within the time frame without compromising the integrity of the assessment in anyway. All 5 estates and 1 mill were visited and the assessment team carried out field and document assess- ments of compliance to all the RSPO principles and criteria. Common systems were identified and specific evidence was recorded for individual estates. Interviews were conducted at all estates and the mill. The certification assessment agenda is as explained below.

2.4 Stakeholder Consultation Process and Result The stakeholder consultation involved both external and internal stakeholders. External stakeholders were notified to make comments on the certification assessment by placing an invitation to comment on the RSPO website. Stakeholders included those immediately linked with the operation of the company such employees, out growers, the local government, NGO’s, trade and labor unions and local communities. Stakeholder consultation took place in the form of meetings in their respective premises. Meetings with stakeholders were held to seek their views on the performance of the company with respect to the sus- tainability practices outlined in the RSPO Principles & Criteria, and to comment on aspects where im- provements could be made. Meetings with local communities were held at their respective premises within and near the company’s area. Letters inviting and appointment for individual stakeholders to the stake- holder consultation meeting were prepared and sent to the individual stakeholders, while electronic mail and telephone calls were made to arrange the meetings. In all the interviews and meeting, the objectives of the RSPO and the purpose of the assessment was clarified at the outset followed by an evaluation of the relationship between the stakeholders and the com- pany before discussion proceeded to obtain the stakeholders feedback on the company’s compliance to different aspects of the RSPO Principles & Criteria. Although several stakeholders were not familiar with RSPO but they agreed with its objective and expressed their willingness to collaborate in the promotion of sustainable palm oil in North Sumatera province. In all interviews and meeting, the assessment team did not restrict discussion of both the positive and negative aspects of operations conducted by PT Bakrie Sumatera Plantation Kisaran Unit estates and mill. The stakeholder consultation meeting held with stakeholders during the audit was extensive and produc- tive. This was followed by site inspections, including visits to the local communities, interviews with stake- holder and contractors, and inspections of worker amenities and infrastructure. All stakeholder issues

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Page 13 of 56 raised were recorded and forwarded to the management for their written response, and this is summarized in Section 3.9.The list of stakeholders that attended the stakeholder consultation visiting and stakeholders interviewed during the assessment is included as Appendix 4. The 1 st Surevillance Audit Agenda Location/ Date Main Activities Main S ites 1st day, May 16 , 201 6 14.00 – 14.30 Main Office - Opening Meeting - Verification of previous audit findings - Verifiction of document related to information transparency and ethical conducts, compliance toregulations including land use 14.30 – 17.00 Main Office right, commitment to long term economic and financial viability, estate’s and mills’s best practices, environmental responsibility, social rsponsibility, and commitment to continual improvement. 17.00 - …. - End of 1 st day audit nd 2 day , May 17, 2016 - Verification of grower best practices implementation, i.e.: ma- nuring records, harvesting records, chemical/pesticides applica- tion records, maintenance records, soil fertility and water man- Main office, agement records, erosion control records, HCV management 08.00 – 12.00 Sei Baleh records, spraying records, IPM, road maintenance records, train- & & Tanah Raja ing records, OHS implementation related records, 14.00 – 17.00 Estates - Observation to riparian zones, HCV areas, harvesting best prac- ticess, implementation of erosion control, implementation of wa- ter courses conservation, OHS implementations - Verification of labour documents and social related documents 17.00 - …. - End of 2nd day audit 3rd day, May 18, 2016 Public Consultation to: - Environment Office of Asahan District - Labor Office of Asahan District Visiting to - Forestry and Agriculture Office of Asahan District Stakeholder 08.00 – 12.00 - Environment Office of Batu Bara District (governmental - Labor Office of Batu Bara District agencies) - Forestry and Agriculture Office of Batu Bara District - Workers Union of PT BSP tbk Unit Kisaran - Employee Cooperative of PT BSP tbk Unit Kisaran Kuala Piasa & - Verification of grower best practices implementation, i.e.: ma- Gurach Batu nuring records, harvesting records, chemical/pesticides applica- Estates & tion records, maintenance records, soil fertility and water man- 14.00 – 18.00 Stakeholder agement records, erosion control records, HCV management rec- Visiting (worker ords, spraying records, IPM, road maintenance records, training union, FFB records, OHS implementation related records supplier, - Stakeholders interview 18.00 - …. - End of 3rd day audit 4th day, May 1 9, 2016 - Verification of grower best practices implementation, i.e.: manur- ing records, harvesting records, chemical/pesticides application records, maintenance records, soil fertility and water management records, erosion control records, HCV management records, Kuala Piasa, spraying records, IPM, road maintenance records, training rec- Gurach Batu, & 08.00 – 12.00 & ords, OHS implementation related records Serbangan 14.00 – 17.00 - Observation to riparian zones, HCV areas, harvesting best prac- Estates & Asa- ticess, implementation of erosion control, implementation of wa- han Mill ter courses conservation, OHS implementations. - Veriication of mill best practices implementation, i.e.: OHS relat- ed records, hazardous waste records, GHG matter, efficiency of energy usage, POME, supply chain,

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Location/ Date Main Activities Main Sites 5th day, May 20, 2016

08.00 – 09.30 Main office - Conformation assessment results - Closing meeting preparation (auditor team discussion & report 09.30 – 10.00 Main office preparation) 10.00 – 10.30 Main office - Closing meeting st 10.30 - ….. 1 Surveillance Audit end 10.30 - ….. Auditor team back to Jakarta

3.0 ASSESSMENT FINDINGS 3.1 Summary of Findings pertaining to RSPO Principles & Criteria During this surveillance audit, tim auditor was found 8 (eight) nonconformities were assigned which is 5 (five) major nonconformities indicators and 3 (three) minor nonconformities indicators and 8 (eight) obser- vations or opportunities for improvement were identified. Further explanation of the non-conformities raised and corrective actions taken by the company are provided in Section 3.2. The observations & op- portunities for improvement are listed in Appendix 5. The following is a summary of findings made for the criteria listed in the RSPO Generic Principles & Crite- ria November 2013 and RSPO-SCCS November 2014.

Principle 1: Commitment to transparency

Criterion 1.1: Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages & forms to allow for effective participation in decision making. Findings: The company has maintained a list of stakeholders that consisting of people around the company, non- governmental organization, entreprizes/suppliers, government of villages, sub-district and district. Eval- uation of the list of stakeholders will be conducted if any changes of stakeholders. There is evidence that the stakeholder verification was performed as documented in the list and office phone num- ber/private stakeholders. There is evidence that the company has provided information in appropriate form and language to rele- vant stakeholders, such as report to labor agency regularly every year. The company has defined accessible informations by public, i.e: the company's history, basic values, vision, mission, strategies, sustainability, human resources, workers information, map the location, summary of the company's performance, organizational structure, financial performance, CSR, OHS matters, environment issues, waste, awards and certifications. Otherwise, there are informations can not accesed directly by public, but reported to relevant authorized ageny, i.e.: environmental management and monitoring plan, hazardous waste activities, production plan, and etc. The company also has defined confidential information and can not be accessed by pub- lic such as marketing strategy, assessment of employee performance, business development strategy, and etc. HR and area Division Head was assigned by the company for providing and receiving informations to stakeholders. Based on interviews with stakeholders, evidenced that the stakeholders has known on how to get the information needed from the the company The organization has established mechanism for communication and consultation with stakeholders,

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including to handling information requisition and how to response. The mechanism has documented in ` procedure of Participation and Consultation Communication SOP internal – external, document no. BMH -03, Rev. 5, dated 25 April 2015. The procedure was decscribed detailed mechanism and also defined HR Area Head Division to ensure that the mechanism implemented appropriately. Obs noted: However, the procedure has no defined clearly time frame for the response(s) information’s requisition. The company has maintain records of information’s requests from stakeholders as documented in a Log Book requests for Information (incoming mail) and Log Books of Providing Information (outgoing mail). There is evidence that the company was response and feedback information requested by stake- holders in a timely.

Compliance status: Compliance with observation Observation No. OBS 2016 01 of 08 The procedure no. BMH -03, Rev. 5, dated April 25, 2015 has no defined clearly time frame for the re- sponse(s) information’s requisition.

Criterion 1.2: Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environ- mental or social outcomes. Findings: There is evidence that the company was providing document regarding the information of company's history and development of the company's activities both legality, production activities, management of environment, social activities, financial reports and others, are available on the company's annual re- port. The document is also planning provides monitoring and reporting monitoring results. All docu- ments are available to the public.

Compliance status: Full Compliance

Criterion 1.3: Growers and millers commit to ethical conduct in all business operations and transactions Findings: The company has established a policy namely “Kebijakan Sustainable Palm Oil Area 1 (Sumut 1)” doc- ument no. Doc. B-MSM/01, Lampiran 18.1b. The policy was signed by company’s President Director dated May 06, 2013. In the policy was decribeb commitment of the organization to ethical conduct in all their operation. There is sufficient evidence that the policy has communicated and understood by all personnel within the company.

Compliance status: Full Compliance

Principle 2: Compliance with applicable laws and regulations Criterion 2.1: There is compliance with all applicable local, national and ratified internation- al laws and regulations. Findings: The organization has maintain their list of applicable law and regulation and other requirement, and evaluated regularly according to the company procedure. The organization also has a mechanism to ensure that all law and regulation implemented in all aspect in mill and plantation. There are procedures for Identification of law and Regulation and others Requirement number BMH-01 Rev 06 Issued on November 23, 2014. That procedure mentioned “selection and identification process of law and regulation and others requirement through contact the regarding institution, email, letter and/or searching in the internet”. Law and regulation is related with RSPO, ISPO, Safety and Health, Environmental and Human Resource. The company maintained and updated a list of applicable legal and other requirements, that consist of environmental field, OHS Fields, RSPO & ISPO related. There is evidence that the organization has

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evaluated the compliance of their estates to these legal requirements according to their company pro- cedures as documented in their SOPs. The last updated was conducted at May 13, 2016. Some of compliance evidence, as below: - Hazardous waste permit for temporary store number 660.1/0464/LH/2014, time period in 180 days for all type of hazardous waste produced by the company. Issued by Ministry of Environ- mental. - Land application permit number 660/235 /BLH/IV/2015 Issued date April 24, 2015 valid for 3 years and still valid during the audit. Total land application based on permit is 120 Ha in Sei Baleh Estate. Issued by Environmental Agency of Batubara Regency. - Report of Inspection of Weight Bridge, No. 510.3/720/MT.RP/15-TU, dated October 2015, valid until October 2016. - Record of reporting of hazardous waste activities for periods January – Maret 2016, dated April 13, 2016 to Minister of Environmental, to Governor of North Sumatera province, Environment Agency of Asahan Districk, and head of Pusat Pengelolaan Lingkungan Hidup Regional Sumatera at Pek- anbaru. - Letter head no. 215/HRD/IX/2015, dated September 04, 2015, regarding reporting of implementa- tion of RKL/RPL Semester I year 2015, to head of environment agency of Batubara District; envi- ronment agency of Sumatera Utara province; and Regent of Batubara; Receipt slip and receiving mark has available. - Letter head no. 114/HRD/IV/2016, tanggal April 28, 2016, Regarding reporting of implementation of RKL/RPL Semester II year 2015, to head of environment agency of Batubara District; environment agency of Sumatera Utara province; and Regent of Batubara; Receipt slip and receiving mark has available.

Compliance Status: Full Compliance

2.2 The right to use the land is demonstrated, and is not legitimately contested by local people who can demonstrate that they have legal, customary or user rights Findings: The company has valid licensed from National Land Agency number 66/HGU/DA/85/B/51 about change of name of HGU and Extension of HGU Rights, with HGU Number 1/Kisaran Timur, Terus Tengah, and Tinggi Raja about ± 18,922 Ha in Kisaran, Buntu Pane District, Asahan Regency, North Sumatra Province, with extension of HGU rights is 25 years. Issued at Jakarta on November 13, 1996. This HGU rights completely with Land Certificate Number 2/HGU/ Desa Kisaran Timur, about land area 18,517.76 Ha, issued at Kisaran, dated on May 1, 1997, valid until April 30, 2022. All of documents are legal ownership of BSP Kisaran co. limited. During this 1st surveilence audit, there is no change licensed form National land agency and completed. The company maintained all document of legal ownership and has a legal map showing location of boundary markers (HGU Map). Based on the results of field verification, there is physical evidence such limits exist boundary markers of HGU). There is evidence that check boundary markers every once a year. Example at Kuala Piasa Estate, there is report of checking stone on consession, date January 6, 2016, and Sei Baleh Estate, there is report of checking stone on consession, date January 12, 2016. However, the company has not Procedure for boundary demarcation and maintenance consecion bor- der stone, its condition, auditor raise an observation. During this 1st surveilence audit, there is no smallholder in company’s area. During in 1 st surveilence audit, there is no land dispute in company’s area and member of the sur- roundings community. The last conflict was between the company and Tinggi Raja community (Tinggi Raja sub district, Asahan district) which had been resolved and the result was accepted by both par- ties. During in 1 st surveilence audit, there is no land dispute in company’s area and member of the sur- roundings community. The last conflict was between the company and Tinggi Raja community (Tinggi

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Raja sub district, Asahan district) which had been resolved and the result was accepted by both parties During in 1 st surveilence audit, there is no land dispute in company’s area and member of the sur- roundings community. The last conflict was between the company and Tinggi Raja community (Tinggi Raja sub district, Asahan district) which had been resolved and the result was accepted by both par- ties.

Compliance Status: Compliance with Observtion OBS No. 2016 – 02 0f 08: 2.2.2 - The company has not defined procedure related monitoring and maintenance of consecion border stone. 2.3 Use of the land for oil palm does not diminish the legal, customary or user rights of other us- ers without their free, prior and informed consent. Findings: There is evidence that the Social Impact Assessment document preparation be participatory without coercion through focus group discussions with affected communities. There are no maps of indigenous communities because in the area of PT BSP there is no customary rights community . The company’s Palm Oil Plantation was built by the Dutch since 1911, thus the documents related to public land com- pensation is not available anymore. Based on interviews with people around the PTBSP note that there is no public denial of the existence of oil palm plantations. The Society helped with the plantation companies, especially in terms of employment. Evidence of the agreement is no longer available given the document storage period has exceeded 30 years so it has been destroyed. Evidence of the agreement is no longer available given the document storage period has exceeded 30 years so it has been destroyed.

Compliance : Full Compliance

Principle 3: Commitment to long-term economic and financial viability

Criterion 3.1: There is an implemented management plan that aims to achieve longterm econom- ic and financial viability Findings: The organization has a documented management plan as documented in the document Budget 2016 and Strategic Plan 2017 – 2020 (including achievement data for 2014 and 2015 and 2016 estimation). The document was included, i.e.: - Operational Data Palm (Hectare planted; Yield/Ha; Field Production; FFB Put Into Process; Extrac- tion Rate; Factory Production; Mill Utilization; Sales Volume; - Field Cost (Ha Mature; Field Production; Field Cost – Amount; Field Cost per Ha; Field Cost per ton; - Processing Cost (Factory Production; Processing Cost Amount; Processing Cost per Kg - Purchase Cost (Raw Mat’l and Finished Goods/Trading Purchase - Cost of Goods Solds (Sales Volume, Production Cost, FFB Purchase, Processing Cost; Total Cost of Manufactured, and etc) - Capital Expenditure (Plantations and Non Plantations) - Statements of Income (Revenue, COGS, Gross Profit; Operating Expenses, Operating Profit, EBITDA, Income Before Tax, Net Income and etc) - Balance Sheet, that showing financial indicators – profitability forecast The company has defined replanting plan for year 2016 - 2020, as mentioned at Letter No. 25/GM- Smt.1/IV/2016, dated April 19, 2016, Regarding Replanting Program 2016 until 2020. Based on the letter replanting rogram for year 2016 till 2020 as table below:

Estate 2016 2017 2018 2019 2020

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Serbangan 34,00 ha 56,00 ha Sei Baleh 57,00 ha 86,00 ha Gurach Batu 253,00 ha 98,00 ha Tanah Raja 47,00 ha 64,00 ha Kwala Piasa 59,00 ha 57,00 ha 69,00 ha Total 0 57,00 ha 393,00 ha 275,00 ha 155,00 ha The company will review its replanting program every year according condition and company’s capabil- ity.

Compliance status : Full Compliance

Principle 4: Use of appropriate best practices by growers and millers Criterion 4.1: Operating procedures are appropriately documented and consistently im- plemented and monitored. Findings: The company has established documented procedures for all Mill’s and Estates operation. There is sufficient evidence that the procedures are maintain and communicated to relevant sections and personnel. There is evidence that the procedures are available at point of uses. The SOPs for all estates are maintained on file and includes SOPs for all main estates activities procedures from seeding (nursery), land preparation, maintenance, harvesting to land clearing. The organization also has defined, maintained and implemented SOP for mill’s operation. The SOPs for mill include receiving of FFB, sorting, and processes such as sterilizing station, di- gester, pressing station, clarification station, kernel silo, CPO storage, PK and PKO and dispatch to storage tank. It was observed that work instructions are displayed at machines throughout the mill area and mill workshop, al SOPs was presented in Indonesian language. Total number of SOP / WI listed on the “Document Master List” is 142 SOP/IK. Some of SOP/work instruction are listed as follow: - BMEOP-WI-24 revision 02 dated 15-07-2015 Regarding FFB Shortage at Loading Ramp - BMEOP-WI-36 Rev01 Date Issued on May 03, 2013 about guidelines for EFB operator, ex- plained about PPE’s for EFB operator, dosage, application procedures. - BMO-WI-01, Rev.01, Issued date September 30, 2011, Concerning Penanggulangan Kecel- akaan Kerja pada Proses Pengolahan Kelapa Sawit - BMO-WI-02, Rev.01, Issued date September 30, 2011, Concerning Penanggulangan Kecel- akaan Kerja pada Proses Workshop Mekanik dan Elektrik - BMO-WI-03, Rev.01, Issued date September 30, 2011, Concerning Loading Ramp Processes - BMO-WI-04, Rev.01, Issued date September 30, 2011, Concerning Lori Management - BMO-WI-05 Rev.01, Issued date September 30, 2011, Concerning Sterilizer Processes - BMO-WI-06, Rev.01, Issued date September 30, 2011, Concerning Indexer Processes - BMO-WI-07, Rev.01, Issued date September 30, 2011, Concerning Tippler Processes - BMO-WI-08, Rev.01, Issued date September 30, 2011, Concerning Thresher Processes - BMO-WI-09, Rev.01, Issued date September 30, 2011, Concerning Empty Bunch Processes - BMO-WI-10, Rev.02, Issued date January 28, 2016, Concerning Digester Processes - BMO-WI-11, Rev.01, Issued date March 26, 2011, Concerning Screw Press Processes - BMO-WI-12, Rev.01, Issued date September 30, 2011, Concerning Dilution Water Processes - BMO-WI-13, Rev.01, Issued date September 30, 2011, Concerning Sand Trap Processes - BMO-WI-14, Rev.01, Issued date September 30, 2011, Concerning Vibrating Screen Pro- cesses - BMO-WI-15, Rev.01, Issued date September 30, 2011, Concerning Crude Oil Tank Processes - BMO-WI-16, Rev.01, Issued date September 30, 2011, Concerning Continuous Setting Tank (CST) Processes - BMO-WI-17, Rev.02, Issued date January 25, 2016, Concerning Wet Oil Tank and Sludge Tank Processes - BMO-WI-18, Rev.01, Issued date September 30, 2011, Concerning Oil Purifier Processes - BMO -WI -19, Rev.02, Issued date March 10, 2014, Concerning vacuum Dryer Processes

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Page 19 of 56 - BMO-WI-20, Rev.01, Issued date September 30 2011, Concerning Sand Cyclone Processes - BMO-WI-21, Rev.02, Issued date January 25, 2016, Concerning Buffer Tank Processes - BMO-WI-23, Rev.02, Issued date January 25, 2016, Concerning Brush Stainer Processes - BMO-WI-31, Rev.03, Issued date January 25, 2016, Concerning Kernel Silo Dryer Processes - BMO-WI-32, Rev.02, Issued date November 04, 2013, Concerning Boiler Operation - BMO-WI-39, Rev.01, Issued date March 13, 2010, Concerning Weight Bridge Operation - BMO-WI-40, Rev.05, Issued date March 18, 2013, Concerning Sortation Operation - Etc.

SOP’s socialization processes was conducted by “Placed SOP at Point of use” and verbally com- municated to related operator. There is no formal training records regarding the Mill’s SOP during this 1 st surveillance. The organization has established mechanism to check consistent implementation of procedures shall be in place, that is “Procedure of Internal Audit, Doc. No. BMA-05, Rev. 05, dated November 27, 2014). There is evidence that the organization has conducted internal audit that was cover Mill & all es- tates. The internal audit was cover standards ISO 9001:2008, ISO 14001:2004, OHS based on Government Regulation of Republic of Indonesia No. PP.50 Year 2012), Indonesian Sustainable Palm Oil (ISPO), and RSPO. The internal audit was on November 09-12, 2015 and November 16- 20, 2015. Internal audit was performed by trained and competent personnel, consist of 21 (twenty one) persons of assignment auditors and 8 (eight) in trainee auditors. The organization has established procedures to address non-compliance and corrective action for continuous improvement, that are: - Procedure of Nonconformity, BMA-07, Rev.03, dated July 09, 2011 - Procedure of Corrective Action, BMA-08, Rev.02, dated June 05, 2014 - Procedure of Preventive Action, BMA-09, Rev.02, dated December 05, 2011

There is records of corrective action and improvement undertaken to follow up internal audit find- ings, for example “Permintaan Tidakan Perbaikan Audit”, Form No. BMA-FR-28, dated December 01, 2015

The organization has establish an SOP for third-party FFB sourcing, namely Instruksi Kerja Pelaksanaan Sortasi, Doc. No. BMO-WI-040, Rev.05, Issued dated March 18, 2013. There is list of approved third-party FFB suppliers. they are Piun Brahmana and Franky Liwijaya. There is legal agreement between the organization and the FFB Supplier. Records of daily and summary vol- ume and origins of third-party FFB received are available and maintained.

Compliance status: Compliance with observation OBS No. 2016 – 03 of 08: Working Instruction available at Sterilizer Station has no identity, the condi- tion potentially mis-use of instruction.

Criterion 4.2: Practices maintain soil fertility at, or where possible improve soil fertility to, a lev- el that ensures optimal and sustained yield Findings: The company has procedure for Good Agricultural Practices in managing soil fertility through the ferti- lizing activity, Empty Fruit Bunch (EFB) application and land application, they are: 1. Work instruction number BMEOP-WI-18 Rev 02 dated on July 15, 2013 about fertilizing application in the field. When the fertilizing application is based on fertilizer recommendation, depend on year of planting, fertilizer type, and method. 2. Work instruction number BMEOP-WI-36 Rev 02 dated on April 6, 2015 about EFB application. On the procedure mentioned, “EFB application applied on the field with dosage ± 450 kg or 60 ton/tree/ha, for sandy area, EFB application dosage is 700 – 900 kg/tree”. 3. Work instruction number BMEOP-WI-37 Rev 00 dated on May 3, 2013 about land application. The procedure explained about dosage land application, when yearly dosage is 750 m3 (based on

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management recommendation). The company has conducted fertilizing application according procedure for maintenance soil fertility and maintains records of fertilizing inputs in repeat usage of fertilizer. Tanah Raja Estate and Sei baleh Esate has record of fertilizing application in 2016. When the record showed, fertilizing activities is still not comply with target because the financial problem of the company. And then the company is seek- ing alternative way through EFB application. The company conduct leaf sampling periodically according work instruction for tissue sampling, Im- plementation of sampling leaf, BMEOP-WI-17, Rev: 02, issued date July 15, 2013. There is record that implementation of leaf sampling including location and number of tissue sampling in 2015. Example Sei Baleh Estate: there is 35 Number of LSU with 1.884 Ha . Sample of leaf have submitted to Research and Development centre of Asian Agri for process tissue analysis. The records of tissue analysis is available base on result of tissue analysis by Research and Devel- opment centre of Asian Agri, Number ref: 271/RD/EXT/L/OKT/15, Issued dated October 10, 2015. Base on result of the tissue analysis, there is recommendation of fertilizer Dosis by PT Nusa Pusaka Kencana analytical & QC Laboratories in 2015. During the 1st surveilence audit, t he company cannot show records of the last soil analysis for all estate. Therefore there is no record of soil analysis for all estate. Its condition, raised as non con- formity (RSPO 00494). Meanwhile, the company has not procedure for soil sampling. The company has a nutrient recycling strategy including EFB application and POME. Records of EFB and POME application are available and maintain very well for year 2015 and until April 2016., such as: 1. Sei Baleh Esate/mill : a. Report of EFB Transport, 2015: January-December 2015, was applied 4.067.711 kg of EFB into 183 Hectare; Report of Progress EFB transport, until April 2016, was applied 1.800.410 Kg of EFB into 45 Hectares. b. Data of POME implementation of LA : ° April 2016: 242 hour of working pump, POME applied 13.794 M3 ° March 2016: 293 hour of working pump, POME applied 16,701 M3 ° February 2016: 248 hour of working pump, POME applied 14. 136 M3 ° January 2016 : 574 hour of working pump, POME applied 34.440 M3 ° January until December, 2015, 7.356 hour of working pumping, POME applied 425.151 M3 2. Tanah Raja: EstateReport of EFB Transport, 2015:, January-December 2015, was applied 16.372.510 kg of EFB into 1.133 Hectares. Report of Progress EFB transport, until April 2016, was applied 1.964.900 Kg of EFB into 152 Hectares.

Compliance Status: Non Compliance NCR RSPO 00494 (Minor Non Conformity). There is no records of soil analysis for all estates

Criterion 4.3: Practices minimise and control erosion and degradation of soils

Findings: During in 1 st Surveilence audit, there is no change of data or map about the fragile soil in the company. The company has a map of the land for Sei Baleh Estate, Serbangan Estate, Tanah Raja Estate, Gu- rah Batu Estate; Kuala Piasa Estate shows mainly alluvial soil type. Maps of soil types for all estates are available at the main office. The maps show that there are no marginal soils within the estate area and most of the estate land consists of alluvial soils and podsoils . The company has work instructions for planting on slopes are documented and describes methods to

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reduce soil erosion on slopes through the use of ‘tapak kuda’ (horseshoe) methods. In Kuala Piasa Estate, there is a small area of high slope (>30%), where this area was classified as a potential HCV 4 area base on HCV Assesment Document. The company has working plan and realization of road maintenance year 2016, Form No. BME-FR- 06 Rev 01. For example in Sei Baleh Estate Division 2 has done road maintenance activities such as Main road maintenance (4.847 meter), collecting road maintenance (2.253 meter) and unkeep road (closing hole). There are no peat soils or fragile or problem soils located within the estates

Compliance Status: Full Compliance

Criterion 4.4: Practices maintain the quality and availability of surface and ground water.

Finding: The organization has establish a water management plan for mill and plantation with identified actions, as demonstrated at organization’s environmental license, i.e: DELH. The water management plan was included following items identification of water sources, efficient use of water, renewability of water source, impacts on catchment area and local stakeholders, access of clean drinking water all year round for stakeholders, avoidance of surface and ground water contamination. The identified water sources are Asahan River and Ground Water. In otherhand the sources of impacts are domestic and plantations activities at upstream of Asahan River and POME that applied for Land Application. The organization has a license for utilizing surface water from authority agency of local government, i.e.: Decree of Head of Integrated Services Agency (Kepala Badan Pelayanan Terpadu) Province of Sumatera Utara, No. 610/127/BPPTSU/2/12.1/XI/2014, dated November 06, 2014, regarding Awarding License of Pengambilan and Pemanfaatan Air Permukaan. The license valid 3 (three) year since is- sued. The organization also has License for land application of mill effluent, based on Decree of Regent of Batu Bara District, Decree No. 660/235, dated April 24, 2015, concerning Awarding License POME Uti- lization for Land Application. The license valid 3 (tree) year since issuance. There is obligation for the license’s holder, i.e.: - Areal applied 120 ha, in Sei Balai Sub District, Batu Bara District, Sumatera Utara Province. - Reported to Regent of Batu Bara District, cq.: Head of Environmental Agency of Batu Bara District, Head of Environmental Agency Sumatera Utara Province, and Minister of Environmental, according to results of : 1. POME monitoring each 6 (six) months 2. Ground Water Quality monitoring each 6 (six) months 3. Soil monitoring 1 (one) time per year The actions for protect water contamination and pollution was identified and the monitoring program has been defined associated with HCV Programme. There is evidence that the action plan and moni- toring program to protect water sources and to ensure that the quality of water still meet requirements (based on local and national government regulations) has been implemented. The organization has mill effluent treatment process in place, where a process for checking and moni- toring water discharge quality (especially BOD) are available. Threis is evidence that water discharge quality in compliance with national regulations. Thre is evidence that the organization monitoring their BOD from the waste water periodically every month, some documents of monitoring results were reviewed and found that the results still meet re- quiremens. The organization has maintain records of mill water use per tonne of Fresh Fruit Bunches (FFB), for year of 2015, water use for Mill was 399,930 M3, whereas during year 2015, the mill was processed 248,744.149 MT of FFB, so Mill water use per tonne year of 2015 was 1,61 M3 per tonne TBS.

Compliance status: Full compliance

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Criterion 4.5: Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management techniques

Findings: The company has procedure related to Integrated Pest Management (IPM) in the estate, such as: 1. BMEOP-WI-15 Rev 02 dated July 15, 2013 about Caterpillar and Bagworm controlling, when con- trolling such as: - Using beneficial plant (Turnera subulata and Antigonon leptopus) - Hand picking - Biologycal insecticide based on census level - Path spraying and fogging 2. BMEOP-WI-14 Rev 02 dated July 15, 2013 about Pest Integrated Management System for rat, thirataba, and oryctes. For rat level attack, when level attack < 5% in one area, controlled by Ro- denticides on palm oil tree. If the level attack more than >5% in one area, controlled by Rodenti- cides in every tree palm oil. While the oryctes attack controlled by hand picking and using the oryctes trap (orycnet) in every tree palm oil. BMEOP-WI-28 Rev 02 dated April 6, 2015 about Caterpillar and Bagworm census. Procedure men- tioned the census conducted in every week in every field has been attacked, and every month for every filed attacked yet. The company has IPM plan and implemented, example in Sei Baleh Estate, there is record of census Caterpillar and Bagworm on January 2016. No attacking pest above threshold, so that the control effort has not been made. All estate has been done conducted census/EWS for Genoderma every 6 month. Based on record of Genoderma monitoring July – December 2015 period, example in Tanah Raja Division I, for 3 (three) field number P96101, P04101, and P04102, with all area is 285 Ha, with total tree is 40.821 trees, it was indicated high level attack is 48 trees. And for Division II and IV there is no attack. Until now, es- tate has effort to control Genoderma through the mapping of genoderma location attack, and for cutting for dead tree after that dried under sun. Implement IPM programme by using benefical plant, i.e: plant turnera subulata, and antigodon lepto- sus , at near main road. The company already conduct training provided to those in the implementation of Integrated Pest Man- agement (IPM) namely Training of IPM for foreman, date on May 25, 2015 with followed 32 person and also Sosialization of IPM training for foreman, on date May 28, 2015.

Compliance Status: Full Compliance

Criterion 4.6: Pesticides are used in ways that do not endanger health or the environment. Findings: The company has a policy on safe use of chemicals which are contain ISPO dan RSPO Sustainability policy. For pesticide application, the company uses only approved and registered Agrochemicals per- mitted by local regulations and use of pesticides are documented. Recommendation for approved and registered agrocemichal permitted No. 1595/IV-DTK/2015, from In these recommendations only lists 45 types of pesticides used. However, the recommendation for approved and registered agrocemichal permitted is expiry on date April 13, 2016. So that auditor raise at Non conformity (NCR Major Indicator) (RSPO 00495). The company uses pesticide for managing pest and weed in the area. All estate use pesticide accord- ing recommendation and registered agrochemical permitted.

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There is evidence that use of pesticide maintained, including detail the active ingredients used and their LD50, area treated, amount of active ingredients applied per ha and number of applications. Data of pesticide usage in 2016 : 1. Tanah raja estate: Report of Chemical Usage Until April 2016, Bio Up (Iso propil amina glifosat) : 490 gr/ltr, applied for 1.444 ha of areal,: 241,66 liters; LD50 oral : >5000 mg , Cyro24 WG (metil metsulfuron) : 20 %, applied for 1.444 ha of areal, : 36,97 Kg, LD50 : >5000 mg : Bravoxone (para- quat diklorida), 276 gr/ltr, applied for 35 ha of areal, 8.7 ltr, LD50 oral : 725,24 mg. 2. Sei Baleh Estate: Report of Chemical Usage Until Maret 2016, Bio Up (Iso propil amina glifosat) : 490 gr/ltr, applied for 533 ha of areal; 196,01 Ltr; LD50 Oral : >5000 mg, Cyro 24 WG (metil met- sulfuron) : 20 %, applied for 1.168 ha of area : 3.167,98 Kg, LD50 oral : >5000 mg ; Sidamin (2-4 Dimetil amina) , : 865 gr/ltr, applied for 216 ha of areal : 7 Ltr. 3. Kuala Piasa Estate: Report of Chemical Usage Until Maret 2016, Bio Up (Iso propil amina glifosat) : 490 gr/ltr, applied for 569,8 ha of areal; 314,4 liters. , LD50 oral : >5000 mg The company has program to manage their oil palm from pests, diseases and invasive organism in 2016 and implemented. Based on their work instruction number BMEOP-WI-22 Rev 01, in the page 2, state that the census will be conducted in every 1 week in the every field for global census. And if any invasive in high categorized, the company conducted the effective census, with the categorized there is 4 head of bagworm per midrib, and 8 head of nettle caterpillar per midrib, the census will be conduct 1 – 2 per week with 5 – 6 tree/Ha. After that, the mortality census will be conducted if needed after the insecticide spraying with the aim is to ensure the mortality rate and effectiveness of the IPM program This activity is accordance to Work Instruction about control of bagworm and nettle caterpiller withdocument number BMEOP-WI-23 Rev 01 in page 2, state about managing step for bag worm and caterpiller, with the step is: 1. Hand picking 2. Biological steps with integrated pest management use the beneficial plant i.e. Turnera subulata, and Antigonon leptopus 3. Chemical steps with spraying based on global and effective map of invasived censused use insectiside, i.e. Bactospine, Dipel WP, Thuricide HP, Florbac with the dosage about 300 – 800 gr/ 400 litter water per Ha. Spraying methode also have 3 steps, first is spraying on the leaf, especially the underside of the leaves, second is spraying with mist blower, applied in the arround of the tree, and the third is fogging. This methode is a last alternative if the hand picking and biological steps can not handling the pest invasive. No attacking pest above threshold limit in 2016, so that the control effort has not been made. The company has a policy on safe use of chemicals which are contain ISPO dan RSPO Sustainability policy on article 11 e.i: “use of agricultural chemicals (agrochemicals) which is registered and permitted by the competent agency”. Based on record of chemical used on Tanah Raja Estate 2016 (until April), the company still used par- aquat (Bravoxone). Bravoxone is a pesticide which registered and permitted by the authority competent agency. The company has done In House training Use of Pesticides Limited on September 25 th , 2014 in coop- eration with the Fertilizer and Pesticide Control Commission of North Sumatra province, evidenced by record attendance and certificate of completion of training participants. Storage of pesticides including the disposal of used pesticide containers in accordance with the rele- vant regulations. The Company categorizes used pesticide containers as a Hazardous Waste (LB3). During 1 st surveilence, there is evidence that pesticide contaniners have stored at temporarily store hazardous waste. The company has valid licenced to temporarily store hazardous waste (Head of Ba- tubara Regency Decree No. 660/235/BLH/IV/2015 Issued date April 24, 2015). There is record of pesticide contaniners in log book and form sheets Hazardous waste storage. Base on record of form sheets Hazardous waste storage on April 2016, amount of pesticide contaniners is

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0.052 ton. The company has work instruction for pesticide application namely BMEOP-WI-09. Rev. 02, issued on dated July 15, 2013, sub chapter .4.3.2 about maintenance for mature and immature oil palm through spraying chemish. There is evidence that the company has conduct socialization pesticide application through spraying chemist on date April 9, 2015. There is no Pesticides applied aerially, there is no smallholder scheme, proper disposal of waste material, according to procedures that are fully understood by workers and managers demonstrated during audit. The company already conduct sosialization about knowledge and skills on pesticide handling shall be demonstrated, including provision of appropriate information materials. Example In Sei Baleh estate, Division 1, socialization for pesticide handling conduct on date January 7, 2015. The socialization in- clude about personnel protective equipment (PPE). During this 1st surveillance audit at PT BSP KIs- aran, there is no chemical-spraying activities. The Company has a Hazardous waste Management Procedure No. BMA-18 dated May 12, 2014, as a guide in the management of Hazardous waste generated by the entire Department of PT BSP Tbk area 1 North Sumaetra 1 Kisaran.

The company should conduct examination health for pestiicide operator periodically. However during 1st surveilence audit, there is no evidence that examination health for pesticide operator in 2015 and 2016. Based on this condition, auditor raised a non comformity ( RSPO 00496). In Document “Perjanjian Kerja Bersama 2012-2017”, there is article that the company is prohibited from employing no pregnant or breast-feeding women. The company have a system to identify pregnant and breast-feeding women through examination women at clinic office once every six months. Base on report of examination women on May 2016, there is no pregnant or breast-feeding women that han- dling pesticide including pesticide operator.

Compliance Status: Not Compliance NCR RSPO 00495 (Major Non conformity) The pesticides recommendation letter of the organization has been expired on April 13, 2016.

NCR RSPO 00496 (Major Non conformity). There is no evidence that examination health for pesticide operator in 2015 and 2016 was performed.

Criterion 4.7: An occupational health and safety plan is documented, effectively communicated and implemented.

Findings: The organization has been established health and safety policy that has written in Bahasa Indonesia and was approved by an authorized personnel (Director of the Company) and dated November 02, 2011. The policy was cover commitment of organization’s top management to comply to all reletad le- gal and other requirements including OHS’s field, mitigation of risks to workers health and safety at all workplace activities. There is evidence that the policy has been socialization to all personnel at all lev- els and functions within organization. The organization has established health and safety plan, includ- ing targets for improving occupational health and safety. An example, Document Planning Mutu, Ling- kungan, Keselamatan dan Kesehatan Kerja (Form No. BMA-FR-06, Rev.2) for period January – De- cember 2016. There evidence that the organization has been implemented the plan, for example document of Laporan Hasil Review / Evaluasi Quality Objective Mutu, Lingkungan Keselamatan dan Kesehatan Kerja (Form No. BMA-FR-07), for period January – December 2015. Based on the document, the tar- get for Zero Lost Time Accident (LTI) has not achieved. During year of 2015 the LTI was 2,00. Since

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the target are not achieved, the organization has been taken actions needed.

The organization has been conducted risk assessments all operations where health and safety is an issue and was cover all the organization’s processes and activities within Palm Oil Mill and Estate op- erations. There is evidence, risk assessment was reviewed and action plan to prevent further recur- rence, since accidents had occurred. The procedures and action plans been documented and imple- mented to address the identified issues such as: - Procedure of Identifikasi, Penilaian, dan Pengendalian Aspek-Dampak Lingkungan serta Bahay – Resiko Keselamatan dan Kesehatan Kerja (K3), Doc. No. BMA-01; Rev. 05, dated October 2013. - Procedure of Pelaporan and Penyelidikan Insiden, Document No. BMH-05, Rev.02, dated Novem- ber 05, 2014. - Procedure of Persiapan dan Tanggap Darurat, Document No. BMA-11, Rev.05, dated October 24, 2012. - All work instruction for all activities within the organization.

The organization has defined standard of minimum competency of each functions including on OHS Matters. And also has defined Rencana Kebutuhan Pelatihan (similar with Training Need Analysis) for each employee. There is evidence that OSH training programs and training records available and con- ducted by qualified person. The records of training were reviewed, such as Implemented training for 2015, at Mill, was founds that the workers involved in the operation was trained in safe working practic- es. As addition, mill’s operator was relevant licensed of OHS from Minister of Manpower. Based on the fields observation and Mill tour, found that adequate and appropriate protective equip- ment available to workers at the of work to cover potentially hazardous operations, such as, machine operations, harvesting and, Mill effluent worker, and etc. There is evidence tht the organization was provide appropriate PPE to workers and replaced when damaged. The records of PPE distribution are available, as follow: - PPE’s receipt note for January 2016, was distributed ear plug, masker, and glove to operator of Process-A, 22 persons - PPE’s receipt note for January 2016, was distributed ear plug, masker, and glove to operator of Process-B, 22 persons; and March 2016 was distributed ear plug to 22 persons - PPE’s receipt note for January 2016, was distributed ear plug, masker, and glove to operator of UP- KEEP, 9 persons - PPE’s receipt note for January 2016, was distributed glove to all security, 15 persons - PPE’s receipt note for January 2016, was distributed masker and glove to operator of Sortation, 10 persons - PPE’s receipt note for February 2016, masker to operator of warehouse 2 persons - PPE’s receipt note for January 2016, was distributed masker and glove to operator of Laboratory, 6 persons - PPE’s receipt note for January 2016, masker and glove to operator of Maintenance, 16 persons and March 2016, Ear Plug, 16 persons

Based on dokumen no. BMEOP-WI-23, Rev. 02, dated July 15, 2013, mentioned that mandatory PPE for Harvester is Safety Shoes only. This case raised as Nonconformity (RSPO 00497) , because is not in accordance poential hazard identified for harvester, for example struck by FFB and etc. The organization has assigned a committee who responsible to implement OHS, namely Panitia Pem- bina Keselamatan dan Kesehatan Kerja (P2K3) according to national regulation, i.e: Regulation of Min- ister of Manpower No. Per-04/MEN/1997. The committee has approved by Head of Manpower Agen- cy, Batu Bara District, Decree No. 566/1459/06/SK-P2K3/DTK-BB/2015, dated June 25, 2015. The committee consist of Pembina (General Manager of Sumut-1), Chairman (Area Manager), Vice Chair- man (HR Manager Area Sumut-1), Secretary (OHS General Expert ), Vice Secretary I (OHS General Expert ), Vice Secretary II (OHS General Expert ), and Members. There is also Decree No. 4509/IV- DTK/2014, dated October 16, 2014, regarding Approval of P2K3, issued by Head of Manpower Agency,

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Asahan District. Meetings between the responsible persons and workers conducted on a regular basis, as required by regulation that is Regulation of Minister of Manpower No. Per-04/MEN/1997. Some of meeting docu- ment were reviewed, for example : - Attendance List and Meeting Minute of P2K3LM, dated April 29, 2016. - Attendance List and Meeting Minute of P2K3LM, dated October 02, 2015 - Attendance List and Meeting Minute of P2K3LM, dated August 25, 2015 There is evidenced that the meeting was attended by all parties and concerns discussed about safety, health and environmental.

The organization has established SOPs for accidents and emergencies, which cover all major potential emergencies, such as fire, chemical spillage, flood, earthquakes, demonstration, riot, and explosion. The SOP is namely Prosedur Persiapan dan Tanggap Darurat, Doc. No.BMA-11, Rev.05, dated Octo- ber 24, 2012. The organization has maintain records of accident investigation and action taken to pre- vent recurrence. For example : - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date April 30, 2016 - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date April 12, 2016 - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date March 16, 2016; - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date March 11, 2016 - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date February 22, 2016 - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date February 26, 2016 - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date February 09, 2016 - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date February 29, 2016 - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date January 22, 2016 - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date March 18, 2016 - Report of Incident Investigation (form no. BMH-FR-12, Rev.01), report date March 09, 2015

There is evidence that accident records has provided to the local authority (Manpower Agency of Asa- han and Batu Bara Districts, province of Sumatera Utara) regularly every 3 (three) months in accord- ance with legal requirements. For example: Report of P2K3 for period January – March 2016. And Letter No. 2965/HRD-IR/X/2015, dated October 2015, Regarding Report of Accident, to Head of Man- power Agencies of Batu Bara and Asahan Districs.

The organization has established a procedure for handling emergency situations, that is Procedure of Emergency Preparation and Response (Persiapan dan Tanggap Darurat), Document No. BMA-11, Rev.05, dated October 24, 2012. The procedure was available in the Bahasa Indonesia, therefore the instructions on emergency procedures easy and clearly understood by workers. In other hand, the or- ganization has effort to make first aid equipment available at worksites, however, based on observation to workplace, some of first aid equipment not complete yet, example POM’s workshop. However, the organization has not assigned operators trained in First Aid present in both field and other operations, as required by the Pernaker No. 15 /2008. There is evidence that the organization has no regularly checked first aid kits for adequately stocked. There is evidence that first aid equipments available dur- ing conduct of field manual work, for example based on observation to harvesting activities at Sei Baleh Estate. The organization has maintained records of all accidents kept and periodically reviewed for continuous improvement. However an NCR was raised due to the company has no first aid officer as required by national regula- tion (Permenakertrans No. 15 year 2008) (RSPO 00498) There is evidence that all workers are provided with medical care (BPJS Ketenagakerjaan), and cov- ered by accident insurance by the company. For accidents that have occurred, there is evidence that the affected workers received appropriate medical treatment, and was able to claim and receive com- pensation under the insurance policy. For example, victim’s name M. Rosul Sinaga (Loading Ramp operator), accident date October 01, 2015 . And also there is evidence that the insurance policies are still valid, i.e:BPJS Cards of Mega Khairani Nasution and Supri. The organization has maintained an

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occupational injuries recorded using Lost Time Accident (LTA) metrics.

Compliance status: Non Compliance NCR RSPO 00497 (Major non-conformity) Based on dokumen no. BMEOP-WI-23, Rev. 02, dated July 15, 2013, mentioned that mandatory PPE for Harvester is Safety Shoes only. This case raised as Nonconformity, because not in accordance po- tential hazard identified for harvester, for example struck by FFB and etc.

NCR RSPO 00498 (Minor non-conformity) There is no First Aid Officer as required by the national requlation (Permenakertrans No. 15 Tahun 2008)

Criterion 4.8: All staff, workers, smallholders and contractors are appropriately trained.

Finding: There is sufficient evidence that all Sei Baleh POM Operators has trained, including mandatory training by regulation, e.g.: Dcocument of “Rencana Kebutuhan, Pelaksanaan Pelatihan” Year 2016, the organ- ization has established training program for 1 (one) year ahead. The training program including type of training and budget needed. The training program includesd OHS, Hazrdous Waste, POM’s Process- es, Trouble Shooting, Maintenance and etc. There is sufficient evidence that training records of all em- ployee maintained appropriately.

Surveillance Findings: Full Compliance

Principle 5: Environmental responsibility and conservation of natural resources and bio- diversity Criterion 5.1: Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and pro- mote the positive ones are made, implemented and monitored, to demonstrate continuous improvement.

Findings: The company has a Document Environmental Evaluation (DELH) for palm oil plantation and palm oil mill PT BSP, located in Asahan District and Batu Bara District, North Sumatera in 2011. The document was approved in accordance Decree of the Head of Environment Agency (BLH) Province North Su- matera No. 1512.D / BLH-SU / BTL-A 2011dated October 3, 2011 about Plan Activity for Palm oil tree development, which covering 9.243 ha of palm oil tree and processing Unit Capacity 45 tons FFB / hour. The document was contain identification of environmental aspect and impact assessment & con- trol, and covered all company’s operational including building new roads, mills processing, infrastruc- tures (housing, office, etc), drainage system, mill effluent, chemical handling, estate’s operational, pest and pesticide, and etc. Environmental Management Plan and Emvironmental Monitoring Plan (mostly known as UKL-UPL Document) was explained how to manage and monitoring significant impacts in order to prevent envi- ronment pollutions and ensure comply with applicable and relevant regulations. There is evidence that the company has conducted monitoring in accordance with applicable regulations regularly. Some of monitoring and testing of environmental quality has performed by independent laboratory and the re- sults was reported to authorized competent body (as explained in P&C 2.1)

Compliance status: Full Compliance

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Criterion 5.2: The status of rare, threatened or endangered species and other High Conserva- tion Value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and operations managed to best ensure that they are main- tained and/or enhanced Findings: The company has identified HCV on their HGU, through the HCV assessment conducted on March 2009. Based on HCV assessment has identified 3 type of HCV i.e.: - HCV 1.2; 1.3 in Danau Teratai as habitat or endangered species. - HCV 4.1 in Danau Teratai as a flood control - HCV 6 local people cemetery Based on species identification in the HCV report of assesment, there is no RTE species available in the company area, only classified into IUCN and Sites Appendix II, i.e.: - Dicurus hottentotus - Spilornis cheela - Monticola solitaries - Gallus varius - Paradoxurus hermaphroditus - Naja sumatrana - Halcyon pileata - Haliastur indus The company has evidence to manage their HCV through the working program, evidenced by: 1. Implementation schedule of HCV management on Afdeling 2 with the type of activity is maintaning the signboard, keep the vegetation in along of riparian zone, maintaning the boundry markers. 2. Implementation schedule of HCV management on Afdeling 4, with the type of activity is maintaning the signboard, keep the vegetation in along of riparian zone, maintaning the boundry markers espe- cially for HCV 6. 3. The company has done the installation of signboard in all HCV identification evidenced by the work program of signboard installation and photograph of the signboard installation process

During this 1st surrveilence audit, there is signboard in HCV 4.1 Area at Kuala Piasa Estate The company also established the company regulation about prohibition of catching, hunting, illegal logging; all of species include flora and fauna in the company area. Company also installed signboard in the estate area as a warning to reminder every one in the company area that is not allowed to disturb the HCV area. The company has conducted monitoring to ensure the species and HCV area condition are protected and maintain very well. Records of flora and fauna monitoring are available for December 2015 exam- ple in Kuala Piasa on report of HCV monitoring. The Company already conducted dissemination to the public to be equally committed to preserve and maintain the HCV area. Example : Tanah Raja estate conduct dissemination HCV area to community Dadi Mulyo Village on January 04, 2015.

Compliance Status: Full Compliance

Criterion 5.3: Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner Finding: The organization has records of registry/list of waste products produced and pollution sources, as pre- sented on “Identifikasi Sumber Limbah” document. The list of waste products at POM as follow: - Emision waste (Boiler and Genset) - Solid waste a. Production: empty fruit bunch, fibre, shell and boiler ash)

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b. Electrical: electrical panel and lamp ball) c. Maintenance: used metal, and etc) - Liquid waste: POME (washing water: vibrating screen, rotary brush strainer, floor, hydrocyclone, oil purifier; and sludge separator) - Hazardous waste: (used oil; Battery, Expired Chemical, Container ex Chemical, Used Gloves, and etc) There is an inventory of chemicals and their containers that are used and kept on site. The chemical and their containers stored and disposed off to Licensed Collector in accordance to local and national requirements. There is evidence that collection and disposal records of chemicals and their containers maintained, for example: - Despatch Slip No. 41/POM/16, dated May 14, 2016, was transfer from Kisaran POM to CWB, as follow: 375 sheet of Goni Chemical, 63 pcs of ex chemical container, 120 liter of used oil ex Gen- set and Loader, 1 pc of accu ex Car, and 9 pcs of filter ex genset and loader. - Waste Logbook of POM.

The organization has a documented waste management and disposal plan to avoid or reduce pollution, as documented on: - IK Pengelolaan Limbah Cair, Document No. BMO-WI-140; Rev.0, dated October 05, 2012, This WI has purposed to manage Liquid Waste for land application. - IK Pengelolaan Limbah B3 Padat, Document No. BMO-WI-117, Rev. 03, dated March 18, 2014. This WI has purosed to manage Hazardous Solid Waste - IK Pengelolaan Limbah B3 Cair, document No. BMO-WI-116, Rev. 02, dated March 18, 2014. This WI has purosed to manage Hazardous Liquid Waste. The WI and waste management and disposal plan, include: - measures for identifying and monitoring sources of waste and pollution, - improving the efficiency of resource utilisation and recycling potential of wastes as nutrients or converting them into value-added products (e.g. as fertilizer, and etc). - Appropriate management and disposal of hazardous chemicals and their containers - Reduction, re-use and recycle of waste There is evidence that the plan has been implemented, for example, fibre and shell was replaced fuel usage for Genset. There is evidence that waste has not been disposed off using open fire. Based on records of Data Usage Fibred and Shell, during year of 2015, shell has using for Genset was 11,319.40 tonne.

Compliance status : Full Compliance

Criterion 5.4: Efficiency of fossil fuel use and the use of renewable energy is optimized.

Finding: The company (especially Sei Baleh Palm Oil Mill) has used fiber and shell as sources of renewable en- ergy (shells and fibres), i.e. to produce steam from the mill turbine/boiler. In year 2015 (January – De- cember), total shell usage is 11,319.40 tonnes and total fiber usage is 26,411.93 tonnes. The fossil fuel used is diesel oil, the monitoring result stated that in year 2015, the company used 66,729.50 tonne or 0,03% (diesel oil/tonne of FFB). The company has procedure for Green House Gases Identification and Mitigation number BMA-17 Rev 00 dated on April 12, 2013.

Compliance status: Full Compliance Criterion 5.5: Use of fire for waste disposal and for preparing land for replanting is avoided ex- cept in specific situations, as identified in the ASEAN Guidance or other regional best practice.

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Findings: The company has estblished a zero burning policy signed by top management and fire has not been used for preparing land for replanting so assessment document not available. There is evidence that during field visit that there is no fire using for replanting or any other purposes.

Compliance status : Full Compliance

Criterion 5.6: Plans to reduce pollution and emissions, including greenhouse gases, are devel- oped, implemented and monitored. Findings: All estates and mill have identified all sources of waste from their activities, including spraying, manur- ing, warehouse, office, pest management etc. when making Identification of Environmental Aspects and Impacts 2015 and 2016. Base on identification pollutan and GHG emission, the company already establish significant pollutan and GHG emission. Example : List of source identification and mitigation of emissions of greenhouse gases in 2016. The company has plan to reduce or minimise the identification pollutan and GHG emission. Data of the plan : 1. Reduce GHG from 21.87t CO2/t CPO be 0.85 tCO2/t PO. 2. Reduce GHG from 21.87 t CO2/lt PK be 10.85 t CO2t/ PK The company has established GHG emission Value with RSPO calculating methode. Total field emis- sions Own Crop = 842104.35 tCO2. The company has been periodically report the enviromental management and monitoring (RKL/RPL) every 6 month, evidenced by: 1. Report of environmental management and monitoring (RKL/RPL) number 215/HRD/IX/2015 ad- dressed to Head of Environmental Bodies of Batabara Regency on September, 2015 for periode of January until Juni, 2015, the content of the report was include example : a. Report of result waste water analyzed from pond number 5 and 6 with the result number Nomor sertifikat 826-2/A/BINA/II/2015, date of testing on march 25– until April 30, 2015 with the pap- ramater analyzed is pH, BOD, COD, Oil and Grease, Pb, Cu, Cd and Zn accordance to Decree of Ministry of Environmental Number 28 and 29/2003. b. Report of result waste water analyzed from pond number 5 and 6 with the result number 840- 1/A//BINA/IV/2015, date of testing on March 26 – until April 1, 2015 with the paramater analyzed is pH, BOD, COD, Oil and Grease, Pb, Cu, Cd and Zn accordance to Decree of Ministry of Envi- ronmental Number 28 and 29/2003 c. Report of result waste water analyzed from pond number 5 and 6 with the result number 841-1/ A//BINA/IV/2015, date of testing on April 22 –26, 2015 with the papramater analyzed is pH, BOD, COD, Oil and Grease, Pb, Cu, Cd and Zn accordance to Decree of Ministry of Environmental Number 28 and 29/2003. Overall, the company have done the periodically monitoring every month to waste water in pond number 5 and 6, accordance to permit of land application. d. Report of emission test, evidenced by result of emission test number 841-1/ UE//BINA/IV/2015,with the identification sample from boiler, genset 1 and 2 and also ambient air from the palm oil mill and housing, with the testing date April 24-30, 2015, with the paramater is SO2, NO2, H2S, NH3, Particulate, Opacity, HF, HCL, Cl2 with the result is under than standard e. Report of fresh water evidence by result of fresh water test number 192/III/2015, date of testing on February 24 until March 17, 2015, accordance to Decree Ministry of Health Number 416/MenKes/Per/IX/1990 with the water sample is from housing, and the testing date January 20 until February 9, 2015, with the interpretation the result of physics and chemical for all paramters is under than standart f. Report of soil analysis for land application in the flat bad, between flat bad and the land control with the certificate result number is 624/0.1/Sert/VI/2012, with the testing date May 3 until June 13, 2012, accordance to Decree Ministry of Environmental Number 28 and 29/2003

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2. Report of environmental management and monitoring with number 114/HRD/IV/2016, addresed to Head of Environmental Bodies Batubara Regency on date April 28, 2016 for periode of July until De- cember 2015.

Compliance status: Full compliance

Principle 6: Responsible Consideration of Employees and of Individuals and Communities Af- fected by Growers and Millers Criterion 6.1: Aspects of plantation and mill management that have social impacts, including re- planting, 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 continual im- provement. Findings: The companies PT BSP has had SIA document created in 2011 by a team of quality safety and envi- ronment. SIA making process and the findings have been documented and reported in the document SIA. The SIA has covered all the potential impacts of factors ,i.e : - Increased public education around - The gap qualified labor needs - Migration of people into wilayahdi around PT.BSP - Insufficient resources of agricultural land and plantation - Change livelihoods - Changes in income - Financial Institutions, both formal and non -formal, including banks and cooperatives - Social capital - Improved rural infrastructure (roads, transport, communications, religious facilities, sports facilities, etc) - Health - Workplace safety There is an impact assessment involving the affected communities. The communities affected are the land owners and the people residing in villages around the site of PT. BSP. There is information from the public and based on the SIA document, that participatory assessment carried out by the method of Focus Group Discussion with affected communities. The SIA document contained recommendations on the preparation of the Social Management Plan as social impact mitigation plan. The Company has had a Social Management Plan 2016 which aims to avoid or mitigate negative impacts and positive promotion, and monitoring the impacts. There are reports of environmental management and monitoring plan (including social activities) as a form of review activities carried out once every 6 months. The report examined is RKL / RPL second half of 2014 and report KL / RPL semester II 2015. Review carried out independently by PT.BSP as a form of evaluation of the activities carried out. Review has been documented in the form of RKL / RPL reports every 6 months was reported also to the environmental agency. There manegement Plan for Social activities 2016. There is no group of farmers who cooperate in the activities of the company, but there are people who settled at the company site. The surrounding communities have been involved in the preparation of the SIA as a resource of information. The main impact for the community is to increase employment

Compliance Status: Full Compliance

Criterion 6.2: There are open and transparent methods for communication and consultation be- tween growers and/or millers, local communities and other affected or interested parties. Findings: The company owns and maintains a list of local stakeholders (communities) around the company (list of stakeholders see 6.2.3). The company has the SOP communication andconsultation between the

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company and the local community and those affected by other interested namely SOP Communication Participation and Consultation Internal and External No. BMH -03 rev 5, dated April 25, 2015. The procedure aims to regulate the mechanism of communication, participation and consultation of the problems that occur and to ensure that any problems that exist are processed and followed up with cor- rective action or troubleshooting for continuous improvement. SOP established by considering the interests of local communities, where they can apply for assistance for the activities of micro enterprise development and socio-cultural activities. The SOP drafted in the Indonesian language that is understood by the local community. SOP has been prepared by taking into account women's interests and public interests are marginal, without any discrimination. Based on interviewed, evidenced that the public understand the mecha- nisms of communication with the company. The company's CSR program is no discrimination of gen- der, religion , race etc. The Company has appointed PIC Communications, i.e: HR and area Head Division and staf are: Yusri Helmy name Saros and Ismi Bebi Lestari Harahap (Industrial Relations and Legal). Job description of PIC Communication are : - Communicate with stakeholders - To coordinate with operating unit leaders and the regional coordinator of CSR - Ensure a harmonious relationship with the community - To identify and anticipate every obstacle in CSR activities - Prepare and submit report The Society has to understand PIC designated the company as evidenced by the incoming mail that can be immediately addressed by the Company . There stakeholder document are : government stake- holders village, sub-district and district, stakeholder NGOs and stakeholders of the company part- ners/suppliers

List of Goverment Stakeholder No. Pemerintahan Asahan Pemerintahan Batubara 1 Bupati Asahan Bupati Batubara 2 Badan Pertanahan Badan Pertanahan 3 Pengadilan Negeri Pengadilan Negeri 4 Kejaksaan Negeri Kejaksaan Negeri 5 Dinas Tenaga Kerja Dinas Tenaga Kerja dan Catatan Sipil 6 Kantor Lingkungan Hidup Kantor Lingkungan Hidup 7 Badan Perizinan Badan Perizinan 8 Dinas Kehutanan dan Perkebunan Dinas Kehutanan dan Perkebunan 9 Koperindag. PM Koperindag PM 10 PT. KAI PT. KAI 11 PT. JAMSOSTEK PT. JAMSOSTEK 12 Pengadilan PHI Pengadilan PHI 13 Polres Asahan Polres Batubara 14 Polsek Asahan Polsek Batubara 15 Camat Camat 16 Kelurahan/Kepala Desa Kelurahan/Kepala Desa 17 Departemen Agama Departemen Agama

List of NGOs Stakeholder No. Nama LSM/Organisasi Alamat 1 SPSI PT.BSP Tbk PT.BSP Tbk 2 SBSI PT.BSP Tbk PT.BSP Tbk 3 WASPADA KA.BIRO KISARAN 4 ANALISA KA.BIRO KISARAN 5 SINAR INDONESIA BARU KA.BIRO KISARAN 6 METRO ASAHAN KA.BIRO KISARAN 7 ASAHAN POS KA.BIRO KISARAN 8 MEDAN BISNIS KA.BIRO KISARAN 9 METRO 24 KA.BIRO KISARAN 10 BATAK POS KA.BIRO KISARAN 11 LSM MARTABAT BP.MANDOGE DESA BUNTU PANE

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12 LSM WASPADA GREEN CLUB KISARAN TIMUR 13 GARHI JL. MARA RUSLI – MUTIARA List of Company partner/ Suplier Stakeholder No. Nama Perusahaan Alamat 1 Toko Expo Jl. Imam Bonjol No.284 – Kisaran 2 Pohon Bangunan Jl. Imam Bonjol No.355 - Kisaran 3 Balige Baru Jl. Cokroaminoto No.16 – Kisaran 4 Pertamina Jl. Cokroaminoto – Kisaran 5 PT. Melakim Inti Perkasa Jl. Gatot Subroto No.150 - Medan 6 PT. Gersik Cipta Perkasa Jl. Glugur By Pass No.31-32 – Medan 7 PD. Kencana Agung Jl. Malaka No.41A – Medan 8 Kisaran Optical Jl. Sutomo No.36 – Kisaran 9 Toko Plastik Jl. Diponegoro No.12 – Kisaran 10 PT. Tri Agung Jaya Jl. A. Malik No.66 – Medan 11 Mestika Karunia Utama Jl. Kol.Sugono No.30C – Medan 12 Maroke Tetap Jaya Jl. Thamrin No.67A-B – Medan 13 Toko Sinar Bakti Jl. Imam Bonjol No.343 – Kisaran 14 PT. Altrak 1978 Jl. D.I.Panjaitan No.179 – Medan 15 Kilang Padi Niaga Jl. Pedagangan Km 14 – Bangun 16 PT. Trakindo Utama Jl. Tg.Morawa Km 9 – Medan 17 PT. Asia International (Auto 2000) Jl. S.M.Raja No.8 – Medan 18 PD. Sumber Jaya Jl. Malaka No.41A – Medan 19 PT. Pertani Jl. Pane Belakang No.25 – P.Siantar 20 PT. Tri Suar Agung Jl. A. Malik No.66 – Medan 21 Masyarakat Pratama Anindita Gun.Palimpus No.16H – Medan 22 PT. Logikreasi Utama Jl. Putri Hijau No.12 – Medan 23 Rolimex Corporation Jl. Kol.Sugono No.2C – Medan 24 Sumatra Berlian Motor Jl. Raya Medan Tg. Morawa Km 7 25 Kopkar PT.BSP Kantor Direksi Kisaran 26 Surya Sumatra Indah Sejahtera Jl. Letkol Martinus Lubis No.40 – Medan 27 Wesfalie Indonesia Jl. Alfalah No.5C – Medan 28 PT. Capella Jl. Gatot Subroto No.21 – Medan 29 Sepaka Akti Jl. Raden Saleh No.46 – Medan 30 Pola Raya Jaya Sakti Jl. Sutomo No.325 – Medan 31 Imam Citra Logamindo Jl. Gandhi No.69 – Medan 32 Atrisco Asbastos Cement Industri Jl. K.L.Yos Sudarso Km 75 - Medan 33 Sinar Sentosa Abadi Sejahtera Jl. Rontan Baru 8C – Medan 34 PT. Almindo Jl. K.L.Yos Sudarso No.100 – Medan 35 UD. Lestari Jl. Nias No.9 – Pematang Siantar 36 Wirakreasi Gemanugraha Jl. Thamrin NO.1D – Medan 37 UD. Kuat Jl. Cokroaminoto No.37 – Pematang Siantar 38 Nirmala Delima Makmur Jl. Jl. Veteran No.24 – Medan 39 Putra Arezda Purnama Jl. Sisingamangaraja Km 10 – Medan 40 Chemifin Jaya Utama Jl. Bungur Besar No.37 AB – Medan 41 Kisaran Sari Indah Jl. Agus Salim No.22 – Kisaran 42 UD. Hemas Jl. Mahkamah No.54B - Medan 43 CV. Restu Jl. Dr. Sutomo No.24 – Kisaran 44 Indo Dachin Persisi Utama Jl. Brigjen Katamso Km 7 – Medan 45 UD. Berkembang Jl. Imam Bonjol No.324 – Kisaran 46 Buana Internusa Jl. Bandung No.19 – Medan 47 PT. Separatech Indonesia Jl. SM Raja Km 10 – Medan 48 CV Sinar Asia Jl. Nipah No.11 – Padang 49 Tani Makmur Jl. Cipto No.29 – Kisaran 50 PT. Multi Mas Chamindo Jl. F.Tobing No.26 – Medan 51 PT. Curah Niaga International Jl. Dr. Saharja No.52 – Jakarta 52 PT. Kogelaha Indonesia Jl. Krakatau No.68 – Medan

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53 PT. Susanto S.Abadi Jaya Jl. Veteran No.96/142 – Medan 54 PT. Bina Multi Instrumindo Jl. Grya Riatur Indah – Medan 55 PT. Sentral Inti Gas Jl. Wahidin No.183 – Medan 56 Usaha Anwar Jl. Budi Utomo No.269 – Kisaran 57 CV. Cipta Karya Bersama Jl. Tanjung No.165 – Medan 58 Citra Jaya Jl. Dr. Arifin No.20 – Medan 59 PT. Perdana Agro Mandiri Jl. Prof.H.M.Yamin SH No.117 – Medan 60 CV. Prima Jl. Mahkamah No.37 – Medan 61 CV. Laris Jaya Jl. Prof.H.M. Yamin SH II No.7C – Medan 62 PT. Tulus Marisi Jl. Perniagaan No.48 - Medan 63 PD. Perseda Indonusa Jl. Taut No.77 – Medan 64 PT. Meroke Tetap Jaya Jl. Thamrin No.67 – Medan 65 PT. Swasti Tunggal Mandiri Jl. Pukat V No.38 – Medan 66 Arya Tama Kreasi Jl. Lembu No.1 – Medan 67 CV. Tri Jaya M.P. Jl. Cemara No.176 – Medan 68 PT. Putra Otto Mandiri Jl. Mayang No. 25A - Kisaran 69 PT. Sumnico Jl. Darussalam – Medan 70 CV. Global Group Jl. Imam Bonjol - Kisaran

Recording confirmation correspondence is documented in the log book / letter entry – exit Incoming mail : On March 29, 2016 3 / 52 / IV / 2016 / Ditbinmas of Directors Binmas North Sumatra Police on Bill- board Installation in order to socialize the maintenance of social order. PT BSP recorded evidence of action in response to input from stakeholders as well disimpam outgoing mail in a log book. On April 04,2016 to the Director Binmas North Sumatra Police on Billboard Installation in order to socialize the maintenance of social order

Compliance Status: Full Compliance

Criterion 6.3: There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all affected parties. Findings: There is a mechanism for handling complaints and grievances of all parties affected, namely: SOP Par- ticipation and Consultation Communication Internal and External No. BMH -03 rev 5, dated April 25, 2015. Receiving Complaints Procedures Stakeholders and Resolving Disputes Doc.No RSPO-02, Rev.1 dated April 14, 2011. There PIC which is responsible for the complaint that the PR department by appointing PIC Communi- cation: HR Area Head Division and Staff HR Legal. The SOP system has been disseminated to stake- holders. The system is conceived and run properly: - There are complaints that payment of annual salary increases should not apply since January 2016, but until the end of February has not been implemented. - Further the company through bipartit meetings on March 21, 2016 endorsed the actual payment of the difference in the increase year by the end of March 2016. The Company has not yet provided a policy that guarantees security protection for whistleblowers. This conditions raised as a nonconformance ( RSPO 00499) If there is no agreement in the settlement of disputes will be resolved through bipartite meetings with the help of the union and if there is no agreement it will be resolved through the courts There is documentation of employee complaints, e.g: - Date 04/07/2015 ; complaint about the down-payment in 2015, which was followed up by a meet- ing with LKS Bipartit and has been completed by the company in April 2015 - dated 12.30.2015 complaints about changes harvester working hours, followed by EMC meetings to explain the schedule changes harvester.

Compliance Status: Non Compliance NCR RSPO 00499 (Major non-conformity) The company has not yet provided a policy that guarantee security protection for whistleblowers.

Criterion 6.4: Any negotiations concerning compensation for loss of legal, customary or user

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rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative in- stitutions Findings: There is a procedure identifying the parties entitled to receive compensation Document No. RSPO - 01 dated 11 april 2011 revision 1. The procedures that guarantee the implementation of the identification of the parties entitled to receive compensation for damages crops, plants and buildings to obtain the concession for the company. Identification team formed jointly between the company and government districts, village and community leaders. Thus these mechanisms can be accepted by the affected communities. However, the company does not have specific procedures for identifying the law, the rights of indigenous and local communities. This condition raised as a nonconformance ( RSPO 00500 ).

The Company has procedures to identify the parties entitled to receive compensation Doc.No. RSPO - 01 rev 01, dated 14, April 2011. The procedure was disseminated and accepted by the recipient impact. The procedure will be evaluated when there are changes in government regulations related to the compensation value set by the government. The procedure gives the same rights to the recipient of the impact regardless of gender, ethnicity, and religion.

Documentation relating to the compensation and land acquisition for HGU PT BSP was not available given the document has exceeded the shelf life of over 30 years.

Compliance Status: Non Conformance NCR RSPO 00500. (Major non-conformity) The company does not have specific procedures for identifying the law, the rights of indigenous and lo- cal communities.

Criterion 6.5: Pay and conditions for employees and for contract workers always meet at least legal or industry minimum standards and are sufficient to provide decent living wages Findings: This type of arrangement wages by : 1. Agreement with Sumatera Utara Workers Union BKPPS Forum of for 2016 have been agreed on March 21, 2016, are : - BHL Harvesters and tappers (Day off): Rp 2.040.450,-/month - PKWT (Specific Time Employment Agreement) contract labor: Rp 2.142. 470,-/ month - SKU (Daily fixed) : wage setting by BKS PPS (Sumatera Plantations Company Cooperation Agency ) for 2016 amounted to Rp 2,178,625,-/ month - HIP (daily monthly): low of Rp 2,267,985,- / month highs 3,346,822 / month - Staff (Management): determination of salary based on performance

2. Governor Decree No. 188.44 / 200 / Kpts / 2016th of Asahan Regency Sectoral Minimum Wage in 2016 amounted to Rp 2.142.470,-per month.

There is a document employee's salary, for example, pay slips, as an example : Isturanto ID 1329P month of April 2016 : - Basic salary : Rp. 2.142.470,- - Accident insurance : Rp 12.298,- - Total salary : Rp 2,154,768,-

Evidence shows that the salary slip PT BSP (idr 2,154,768,-) has given salary to employees with a value greater than the minimum wage prescribed by the Governor (idr 2.142.470,-) nor the minimum wage agreed by the Workers Union BKPPS Forum (idr 2.040.450,-)

There is a definition of wages which have been agreed in accordance with Law No. 13 of 2003 on Manpower. The entire records of the wages of employees have been documented by the company in Finance.

The employment contract clearly indicate the basic salaries and working conditions of the facilities,

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such as working hours, benefits, cuts in wages, overtime, sick leave entitlements and maternity leave, reasons for termination, notice periods, etc. The employment contract prepared in the Indonesian lan- guage understood by the workers, signed by both parties, ie the company and its employees. Salary and conditions provided in accordance in labor laws, union agreements or direct contracts of employ- ment in accordance with the minimum wage in accordance with the decree of the Governor of North Sumatera. Based on the verification results to the workers there is no violation by the company PT BSP linked to remuneration of employees. PT. BSP both plantations and factories have been providing adequate housing and other basic needs national standard. Based on the verification of the workers , it is known that the PT BSP provides ac- cess to the food needs of the form: 1. The benefit of rice per month provided that: worker 15 kg / month; wives 9 kg / month; Child maksimum 3 child ) @ 7,5kg / month 2. Duty trip : The payment of food allowance and trip services amounted to Rp 50,000 per day 3. Payment of insurance BPJS Desember 2015 : Rp 411.210.279,- 4. Payment of insurance BPJS Januari 2016 : Rp 411.066.121,-

The facilities provided by PT. BSP is :

Total Infrastructure Location Worker Total unit Poly- House Mosque Mushola Church Others Sport clinic Head Office 142 1 - - 3 4 - 150 Bunut Fact ory 390 1 2 2 1 4 1 401 POM 105 1 - - 2 3 1 112 RSIK 110 1 - - 1 1 - 113 Serbangan 424 5 3 - 7 2 1 442 S. Baleh Est 250 4 1 - 3 2 1 261 G. Batu Est 199 6 - - 2 2 1 210 T. Raja Est 414 7 - - 7 2 1 431 K. Piasa Est 190 3 - - 2 2 1 198 A. Salabat Est 203 10 - 2 - 2 1 218

Compliance Status: Full Compliance

Criterion 6.6: The employer respects the rights of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel Findings: PT. BSP has a firm policy in the Indonesian language that recognizes the rights of employees to free- dom of association. Employees have a union SPSI (All Indonesia Workers Union) and the SBSI (All- Indonesia Workers Union) to all workers including migrants and contract workers. Unions are associa- tions of workers to negotiate with the company. The union SPSI PT SBI members about 3200 workers and SBSI PT SBI members about 300 workers. Tabel of Documentation of the discussion of the problems of employees

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No Date Topic Follow up Solution 1 24/01/2015 Harvest Sunday and HRD Coordination Harvest Sunday and Holidays handed over Holidays Meeting with SP/SB to Third Parties 2 27/01/2015 Salary Increase Decision 2015 Salary Dissemination to all employees Agreement 2015 Increase 3 27/05/2015 Final Bonus 2014 Coordination Meeting Bonus Final Agreement Granting of 2014 HRD With SP / SB 4 04/07/2015 Lebaran Bonus Provision Provision Coordination yet an agreement Bonus 2015 . Coordinationmeeeting only between the SP / SB then it will continue the discussion at the next meeting . 5 03/09/2015 Salary In August Coordination Meeting Socialization salary payment in August 2015 2015 between SP / SB with HRD.

The results of the negotiations in the form of PKB is endorsed by the company and union workers. PKB period 2015-2017. The agreement contains the rights, obligations and working conditions, safety, wel- fare, leave, termination of employment, etc. Ratification PKB No.KEP 88/PHIJSK-PKKAD/ PKB/VI/2015 concerning the Registration Agreement BKS-PPS with the PP. FSP.PP-SPSI period 2015 - 2017 by contested of Industrial Relations Labor and Social Security. The agreement refers to the Law No. 13 of 2003 on Labor and has been disseminated to the workers, it is evident that workers know the contents of the CLA. Board SPSI PT BSP period 2016 – 2021 was available. Meeting between the union and the company have been documented. Documents available for the worker and stored by the Unions and HRD PT BSP.

Status Compliance: Full Compliance

Criterion 6.7: Children are not employed or exploited Findings: There are rules about the minimum age of workers at PT . BSP ie at least 18 years old by Memo HR Area Head No. 783/HRD/V/2011 dated May 9, 2011. The company have total worker: 1.167 people , comprising : Staff : 77 people, Non staf : 1.090 people, Male employees : 991 ( 84.92 % ), Female employees : 176 ( 15.08 %). Based on the verification of documents and interviews with workers proved that PT BSP does not em- ploy workers younger than the minimum age. Based on the verification of documents, most young worker is : Edy Surya (ID 20 527) employees posi- tions harvest, was born on 21 April 1995 and began working 1 Januair 2015 (age 19 years)

Compliance Status: Full Compliance

Criterion 6.8: Any form of discrimination based on race, caste, national origin, religion, disabil- ity, gender, sexual orientation, union membership, political affiliation, or age, is prohibited Findings: PT BSP has had a policy was no discrimination in employment, which is set in: 1. Human Rights Policy article 4. "We enforce all the people who worked at PT BSP fairly and without discrimination on differences in ideology, ethnicity, color skin, religion, gender, sexual orientation, national origin, age, disability or more status social". 2. Sustainable Palm Oil Policy, Article 17 "Every worker has an equal opportunity to obtain employ- ment without discrimination and the right to equal treatment without discrimination from employers Information policy is open to the public are accessible to all interested stakeholders.Policies posted on the board companies. The policies have been implemented proven employees of PT BSP came from various regions of both local and surrounding areas . Job Vacancies postings through the mass media, job fairs, and announcements in the surrounding villages, as well as through a job fair in collaboration with universities in Medan. For example Job fair with the College of Chemical Industry Medan in Feb- ruary 2016.

SOP Selection acceptance of new employees Document No. BMH - 07 rev 01 dated February 2, 2013 : every worker has an equal opportunity to obtain employment without discrimination, applicants are

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required a minimum of 18 years of age. Vacancy information through : a letter of notification to Country across departments, advertising in mass media, through labor recruitment agencies, internet, etc. There is no gender discrimination in the recruitme nt of employees at PT BSP, proved there are female employees from the lowest level up to the management level is Marketing Manager (Windi Juliani Ulfa) and Assistant Estate Officer Data (Dian Carolina ID 2006080087). Female employees feel happy to the treatment of companies that do not distinguish gender status within the company. Based on interviews of employees, there is no gen- der discrimination issues. There is a history of employee health records presented in the clinic per month. The results of lab anal- ysis : No18A / LHU - LK / BK3 - MDN / I / 2016 ; noise intensity analysis results revealed that the noise level in the mill is still within the threshold. Audiometry examination dated January 14, 2016 against 15 employees of Mill there are 7 people who indicated experiencing reduced hearing due to the working environment.Spirometry exam dated January 14, 2016 against 15 employees of Mill there are 5 people who indicated experiencing Ristriksi Light (RR). Colenestrase examination for employees associated with the chemical / agrochemical planned for the third week in May 2016 by letter No. 130 / HRD / V / 2016 of HR Head to the Central Area and Safety Hiperkes North Sumatra Province. The Company explicitly states indiscriminatory policy for recruitment selection, appointment and pro- motion process. There are policies indiscriminatory. There Evaluation of Employee Performance As- sessment annually and used as the basis for promotion of employees. This performance assessment provides an assessment of the commitment and technical competence and non technical competency

Compliance Status: Full Compliance

Criterion 6.9: There is no harassment or abuse in the work place, and reproductive rights are protected. Findings: There is a sexual harassment policy; - Human Rights Policy, article 1 "we conduct business in a manner respecting the rights and dignity of all people in accordance with the legal requirements " - Oil SustainablePlam Policy, section 5 "Preventing sexual harassment and violence" The policy has been documented, implemented and communicated and disseminated to all working women through the socialization of women's rights and domestic violence on 26 March, 2014.

There are mechanisms and clear rules for companies to handle / deal with issues such as / complaints received from labor. However the company has no decree of Gender Committee, including structure at each unit respective- ly and job description and working program.

There is a Gender Committee as a means for workers to facilitate the fulfillment of basic rights of wom- en. Chairman of the committee Gender: Suriana ; Vice Chairman: Dian Carolina Secretary: Erlina Ef- fendi Lubis ; Members: ISMI Bebi, Nurimah siregar, Restu, Sulfiah, Siti Aminah, Masdiana . However Not yet available commite gender program.

The comite gender not available yet awareness programs or training provided tolabor in relation to sexual harassment.

There is a policy of protection of women's reproductive rights . The policy also contained in: - PKB article VIII, such as : menstruation , pregnancy , childbirth and breastfeeding - PKB Article XV include: workers are required to use safety equipment or personal protective equipment; The medical examination colenestrase per 6 months for employees dealing with chem- icals / agrochemicals; antenatal care for women workers related chemicals.

Implementation of a medical examination had been conducted through Medical Chek Up (MCU) which was held on January 14, 2016 to 15 employees Mill.

Colenestrase examination for employees associated with the chemical / agrochemical planned for the third week in May 2016 by letter No. 130 / HRD / V / 2016 of HR Head to the Central area and Safety Hiperkes North Sumatra Province . The Company has a mechanism to deal with complaints of work, that respects and protects the anonymity of complainants.

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Compliance Status: Non Compliance NCR RSPO 00501 (Major non-conformity) The company has has not issued an official decree on the establishment of the Gender Committee. , in- cluding structure at each unit respectively and job description and working program.

Criterion 6.10: Growers and millers deal fairly and transparently with smallholders and other lo- cal businesses Findings: Pricing FFB by Marketing Division with the basis (18.5 % yield , pricing is done every week : - On May 17, 2016 TBS price : Rp 1.670,- per kg - On May 9, 2016 FFB price : Rp 1.700,- per kg - On May 3, 2016 FFB price : Rp 1.710,- per kg Payments to suplayer FFB : twice a week (Mondays and Thursdays). There were no complaints from the public related to the price of FFB purchased by Mill . There are 2 suppliers TBS namely: Franki Li- wijaya and Piun Brahmana. FFB transaction documents payments to farmers through the Bank. Th e payment evidence available, such as : - Through Bank Mandiri to Fanky Liliwijaya dated May 2, 2016 amount Rp. 620. 474. 498 , - Through Bank Mandiri to Fanky Liliwijaya dated May 2, 2016 amount Rp 790.735.435 , - Contract suppliers TBS : - Purchase Agreement TBS a / n Nador Darojad Iwa Brahmin No. 20 / BSP - P & C / PCH - Nador / I / 2016 , a minimum quantity of 100 tonnes / day for 6 months periode until 31 Juli 2016 - Purchase Agreement TBS a / n Franky Liliwijaya No. 190 / BSP - P & C / PCH - Franky / I / 2016 , a minimum quantity of 100 tonnes / day for 6 months, periode until 31 Juli 2016

Supplier PIUN BRAHMANA

Date Netto (kg) Price/Kg Amount Tax: PPH 22 Total 28/05/16 141.690 1,770 251.042.000 1.255.210 249.786.790 29/05/16 126.489 1,750 223.950.420 1.119.752 222.830.668 30/05/16 174.813 1,750 310.663.400 1.553.317 309.110.083 Total 442992 - 785.655.820 785.655.820 781.727.541

Supplier FRANKY

Date Netto (kg) Price/Kg Amount (Rp) Tax: PPH 22 Total 28/05/16 97,257 1,770 172,144,890 860,724 171,284,166 29/05/16 132,155 1,770 234,035,900 1,170,180 232,865,720 30/05/16 118,785 1,770 210,249,450 1,051,247 209,198,203 Total 348,197 - 616,430,240 616,430,240 613,348,089

There is evidence that the MCC has been explained for FFB via the information board in Mill. FFB price has been calculated by the value of palm oil waste. Employment contracts made available in a transparent, fair legal and there is no pressure. All parties have signed an agreement. Contract con- ducted in a fair and transparent. The Agreement made between the Mill Manager anda supplier, the agreement document is : - Purchase Agreement FFB a / n Nador Darojad Iwa Brahmin No. 20 / BSP - P & C / PCH - Nador / I / 2016 , a minimum quantity of 100 tonnes / day for 6 months, period until 31 Juli 2016 - Purchase Agreement FFB a / n Franky Liliwijaya No. 190 / BSP - P & C / PCH - Franky / I / 2016, a minimum quantity of 100 tonnes / day for 6 months, period until 31 Juli 2016. Payments to suppliers to do twice a week (Mondays and Thursdays) Records of transactions between suppliers with POM in the form of the number of shipments FFB every day. Payment was agreed and implemented According to the agreement.

Compliance Status: Full Compliance

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Criterion 6.11: Growers and millers contribute to local sustainable development where appro- priate Findings: Identification of community needs has been carried out by PT BSP , as can be seen in the SIA report. PT BSP has contributed to regional development in the field of infrastructure development, education, religious social assistance, health and natural disaster relief. Assistance in education is the provision of auxiliary fees elementary school teachers in the villages around the company, educational scholar- ships for outstanding students, the school football in the estate Bunut. PT BSP contributes to employment in Asahan district , based on the explanation of the Department of Labor at least PT BSP has absorbed 15 % of the workforce in Asahan district . Companies do not co- operate with farmers (scheme smallholders) to produce CPO

Compliance Status: Full Compliance

Criterion 6.12: No forms of forced or trafficked labour are used. Findings: The company has particularly a policy on the prohibition of forced labor. Recruitment of foreign work- ers conducted by the Jakarta headquarters with reference to laobor regulations in Indonesia. The Company does not hold workers' passports or identity as collateral work. The company has only a copy of the identity documents of workers. There are labor outsourcing, through cooperative work in the field of office cleaning and yard. Based on document tracking and verification in proved that : - There is no evidence of the replacement of employment contracts of employees - All workers have had a copy of the employment contract

There are two types of migrant workers, migrant workers internal and international migrants. Internal migrant workers are those workers who migrate within the country. Examples of the most common and easily understood is urbanization and transmigration. That international migrants are individuals who migrate abroad for work purposes.

Associated with internal migrant workers who mostly come from NTT and Java, the company does not discriminate in employment opportunities, wages, housing, health care, there is no change of the contract, the opportunity to worship and others.

Bakri PT Sumatera Plantation, committed to providing opportunities equal access to employment, through the following business : 1. The Company provides equal opportunities to workers to find employment and a decent income, 2. The company puts all workers in accordance with the expertise, capabilities and other job requirements, and in accordance with operational needs of employees. Thus this policy is made, to be a concern and responsibility all parties on the implementation of this policy.

Compliance Status: Full Compliance

Criterion 6.13: Growers and millers respect human rights Findings: PT BSP has had a policy on human rights , which have been disseminated to all employees by the public relations department . Policy information is also posted on the information board at the PT. BSP. There is sufficient evidence that never happened human rights violations in PT BSP during year 2015 and 2016 (until date of audit)

Compliance Status: Full Compliance

Principle 7: Responsible development of new plantings

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Findings: During the last one year there is no new planting in the company PT BSP Kisaran . All existing area is the area under the company’s existing HGU (cultivation Right), which is all previously planted and no planting in HCV area. The company is only carrying out expansion of their oil plam plantation inside ex- isting HGU area from rubber plantation converson area but since issued a letter No. 27/HBU/III/2011 dated on March 21, 2011 that no further conversion activities from rubber to oil palm.

Compliance status : Not Applicable

Principle 8: Commitment to continuous improvement in key areas of activity Findings: The company has commitment to continuous improvement by defined mechanism to improve practices. including mechanism for disseminating information to all workers. The mechanism are: - Procedure of “Tinjauan Manajemen” document no. BMA – 06, Rev. 05, dated July 15, 2011 - Procedure of “Internal Audit” document no. BMA – 05, Rev. 04, dated Noember 27, 2014 - Procedure of “Ketidaksesuaian””, document no. BMA – 07, rev. 03, dated July 09, 2011 - Procedure of “Tindakan Perbaikan”, document no. BMA – 08, rev. 02, dated June 05, 2014 - Procedure of “Tindakan Pencegahan”, document no. BMA – 09, rev. 02, dated December 05, 2011 - Procedure of “Pengendalian Dokumen”, document no.BMA – 03, rev. 04, dated October 25, 2013 - Procedure of “Pengendalian Rekaman”, document no BMA – 04, revi. 03, dated Nopember 27, 2014.

The company has established program and action plan annually. Effectiveness of program and action plan monitored and evaluated through internal audit and management review meeting at regular basis. In other hand, the company also has established objectives of quality, health and safety. There is evi- dence that the mechanism of continual improved has implemented, i.e: - Social Affairs in 2016 and 2017 - Internal audit related to compliance with RSPO standards that have been carried out in February 2016

Compliance status : Full compliance

3.2 Status of Previous Identified Non-conformities During previous audit (re-certification assessment), a total of 12 (twelve) nonconformance’s against the RSPO Generic Principles & Criteria November 15 th , 2013 were identified. These consisted of 8 (Eight) major non-conformities and 4 (four) minor non-conformities. The company is given a timeframe to close all major non-conformities within 60 days and at time of first submission of this re- port to the RSPO. For all the non-conformances, the company has provided their planned corrective action against these. A summary of all identified non-conformances, corrective actions taken and auditor conclu- sions is as below :

Criterion 1.2.1 Publicly available documents shall include, but are not necessarily limited to: • Land titles/user rights (Criterion 2.2); • Occupational health and safety plans (Criterion 4.7); • Plans and impact assessments relating to environmental and social impacts (Criteria 5.1, 6.1, 7.1 and 7.8); • HCV documentation (Criteria 5.2 and 7.3); • Pollution prevention and reduction plans (Criterion 5.6); • Details of complaints and grievances (Criterion 6.3); • Negotiation procedures (Criterion 6.4);

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• Continual improvement plans (Criterion 8.1); • Public summary of certification assessment report; • Human Rights Policy (Criterion 6.13). Non-conformance RSPO 2015- 1 of 12 (Major non-conformity) : "Communication Procedures, Participation and Consultation Internal-External". (BMH-03, rev.04) sev- eral types of documents required RSPO standard is not presented to the stakeholders, which include: a. Documents related to the legality of land (HGU). b. Plans and environmental and social impact assessment c. HCV documents d. Pollution prevention and abatement plan e. Detailed process complaints f. the negotiation procedure g. Human Rights Policy Correction : - Company revised the procedure to ensure those document contained in - To brief to related parties inside company to be understood Corrective action: - Company revised the procedure to ensure those document contained in - To update SOP periodically and brief to related parties inside company to be understood Verification result: - Company has revised the procedure to ensure those document contained in - Evidence of briefing to related parties inside company available Auditor conclussion : Closed

Criterion 2.1.1 Evidence of compliance with relevant legal requirements shall be available Non-conformance RSPO 2015- 2 of 12 (Major non-conformity) : 1. There is no record LB3 shipping container types of used chemicals in 2014 were found in Kuala Pi- asa estate. (Based on BMW Form-FR-23). 2. In year 2014, there were recorded delivery of Hazardous Waste such as used chemical containers from CWB to Kuala Piasa Estate which is reused as container of diesel, premium, MEDITRAN and loose fruits. Also in year 2015, the CWB also sent the same Hazardous Waste to Kuala Piasa es- tate. (Based on BMW Form-FR-23). Correction : 1. Hazardous officer colleting all the hazardous waste (chemical container) from all estate before de- liver to the Bunut Central Werehouse. 2. Delivered all the hazardous waste to Bunut Central Werehouse. 3. Not allowed the reuse activity from hazardous waste again as a mentioned in company procedure BMA-18 Corrective action: 1. Carry out the procedure of BMA-18, that the maximum of hazardouse waste stored in the estate on- ly 7 days and after that shall be delivere to the Bunut Central Werehouse as licensed stored. 2. Carry out the procedure of BMA-18, that the chemical container is not allowed for reuse activities for others

Verification result: The company was delivered all of hazardous waste (chemical container) to the Bunut Central Wer e- house with evidenced form BW-FR-04 Number 359847 from Kuala Piasa Estate dated on April 20, 2015 and was receipt by the Bunut Central Werehouse. Auditor’s conclu sion : Closed Criterion 4.6.2 Records of pesticides use (including active ingredients used and their LD50, area treated, amount of active ingredients applied per ha and number of applications) shall be provided Non-conformance RSPO 2015- 3 of 12 (Major non-conformity) : No records of pesticide use, including active ingredients used and LD50 of the active ingredient, the ta r- geted area, the amount of active ingredient applied per ha and number of applications, durng visit at Sei Baleh Real Estate & Serbangan Correction: Prepare report of Agrochemical use. Corrective action: Provide use of Agrochemical monthly reports with the new form. Verification result:

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The company has prepared monthly report of agrochemicaluse with new form, and company provide guidance for calculation quantity of it. Auditor’s conclussion : Closed 4.6.7 Application of pesticides shall be by proven methods that minimize risk and impacts. Non-conformance RSPO 2015- 4 of 12 (Minor non-conformity) : Application of pesticides is done in the block that is being harvested, in P05101, although there is a warning sign not to enter the area during visit at Kuala Piasa estate Correction: Company has provided harvesting program integrated with spraying program. Company provide monthly report program and the annual harvesting plan that avoids harvesting and spraying conducted at the same time and place. Corrective action: Company creating spraying program and the annual harvesting plan that avoids harvesting and spraying conducted in the same field at same time. Auditor’s conclusion: Evidence of immediate action taken was accepted. Effectiveness of implemen- tation to verified at next surveillance audit This surveillance verification result: The company has work instruction for pesticide application namely BMEOP-WI-09. Rev. 02, issued on date July 15, 2013, sub chapter .4.3.2 about maintenance for mature and immature oil palm through spraying chemist. There is evidence that the company has conduct socialization pesticide application through spraying chemist on date April 9, 2015. During observation to Kuala Piasa, Tanah Raja and Sei Baleh Estate, there is no found that pesticides application has conducted together with other activities, e.g.: harvesting. Auditor conclusion: The corrective actions has been implemented effectively. 4.6.11 Specific annual medical surveillance for pesticide operators, and documented action to treat related health conditions, shall be demonstrated.

Non-conformance RSPO 2015- 5 of 12 (Major non-conformity) : From the results of the semi analyzer Spectrophotometer rayto on behalf Saldan, foreman spraying Sei Baleh Estate, suffering from liver and kidney function Disorders (laboratory analysis No. 89 J / LHU-KES / BK3-MDN / XI / 2014 dated September 22, 2014). There is no recording the follow-up of the results of laboratory analyst for an employee Saldan. Correction: Sent the employee to Kartini Hospital to have subsequent examination results. Corrective action: Following up on any medical examination results by sending employees detected got Occupational ilness to Kartini General Hospital. If the result is positive for Occupational ilness, there will be job rotation. Verification result: There is a letter explain that company transferred the employee to a job that is not related to chemicals. BSP provide monthly report program and advance for subsequent examination. Auditor conclussion : Closed 4.7.3 All workers involved in the operation shall be adequately trained in safe working practices (see Criterion 4.8). Adequate and appropriate protective equipment shall be available to all workers at the place of work to cover all potentially hazardous operations, such as pesticide ap- plication, machine operations, and land preparation, harvesting and, if it is used, burning. Non-conformance RSPO 2015- 6 of 12 (Major non-conformity) : No evidence of training / socialization / briefing related k3 Harvest under / around electrical lines during the year 2014/2015 in Kuala Piasa Division I, although no fatal accidents in the process. Correction: Training or dissemination of safety Harvesting has been conducted Corrective action: Company makes Training Need Analysis annual to identify all training should be i m- plemented and followed by all employees. Verification result: Evidence of dissemination available suc h as attendant list and trainig material as well. Auditor conclussion : Closed 5.1.2 Where the identification of impacts requires changes in current practices, in order to miti- gate negative effects, a timetable for change shall be developed and implemented within a com- prehensive management plan. The management plan shall identify the responsible per- son/persons.

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Non-conformance RSPO 2015- 7 of 12 (Minor non-conformity) : Company has not completed the Environmental Management Plan Reports Semester II in 2014, so it is not available proof of delivery of the report to the Associated Institutions Correction: Company send Environmental Management Reports Semester II to government Corrective action: Company will ensure to send Environmental Management Reports on time each semester. Auditor conclusion: Evidence of immediate action taken was accepted. Effectiveness of implementa- tion to verified at next surveillance audit.

This surveillance verification result: There is evidence the organization has reported theirs Environmental Plan to auhority agencies, suc as: - Semester I year of 2015 : Letter head no. 215/HRD/IX/2015, dated September 04, 2015, regard- ing reporting of implementation of RKL/RPL Semester I year 2015, to head of environment agen- cy of Batubara District; environment agency of Sumatera Utara province; and Regent of Batuba- ra; Receipt slip and receiving mark has available. - Semester II year of 2015: Letter head no. 114/HRD/IV/2016, dated April 28, 2016, Regarding re- porting of implementation of RKL/RPL Semester II year 2015, to head of environment agency of Batubara District; environment agency of Sumatera Utara province; and Regent of Batubara; Re- ceipt slip and receiving mark has available. Auditor conclusion: Closed

5.2.5 Where HCV set-asides with existing rights of local communities have been identified; there shall be evidence of a negotiated agreement that optimally safeguards both the HCVs and these rights. Non-conformance RSPO 2015- 8 of 12 (Minor non-conformity) : Not available records of implementation of HCV dissemination to the public to be equally committed to preserve and maintain the HCV area especially directly adjacent to the community during sampling at Kuala Piasa Estate Correction: The company has created letter No.76/KP/04/2015 addressed to all Head of District (Kepala Desa) about HCV brief for local communities. Corrective action: Develop yearly program for HCV brief for every local communities adjacent with HCV area. Corrective action: Creating an annual work program to the public in the form of socialization HCV around the estate. Auditor conclusion: Evidence of immediate action taken was accepted. Effectiveness of implementa- tion to verified at next surveillance audit

This surveillance verification result: The company has conducted monitoring to ensure the species and HCV area condition are protected and maintain very well. Records of flora and fauna monitoring are available for December 2015 exam- ple in Kuala Piasa on report of HCV monitoring. The Company already conducted dissemination to the public to be equally committed to preserve and maintain the HCV area. Example : Tanah Raja estate conduct dissemination HCV area to community Dadi Mulyo Village on January 04, 2015 Auditor conclusion: Closed

5.6.2 Significant pollutants and greenhouse gas (GHG) emissions shall be identified, and plans to reduce or minimize them implemented. Non-conformance RSPO 2015- 9 of 12 (Major non-conformity) : The Company has identified the source of GHG emissions in the garden and plant and has cal culated the value of the emissions produced and make the program work for mitigation and reduction of the GHG emissions. However, the work program was made not based on the GHG calculation results that have been made, and no available targets to be achieved in the program. Correction: The company has calculated the GHG calculation with the RSPO GHG calculation tools

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and develops the work program to minimize or reduce the significant GHG emission. Corrective action: Create the GHG calculation in every year and develop the program Verification result: The company submit the evidence of GHG management program to reduce and minimize the significant pollutant, through the first is emission and GHG source identification from all a c- tivities, and GHG mitigation program has include the target for next year, example from the fossil used in 2014 about 76.526 liter with emission is 335.8 t CO2e/year, and in the 2015 the company will decrease the fossil fuel in to 72.700 liter with GHG emission decrease will 272.2 t CO2e/year. Auditor conclussion : Closed 5.6.3 A monitoring system shall be in place, with regular reporting on progress for these signifi- cant pollutants and emissions from estate and mill operations, using appropriate tools. Non-conformance RSPO 2015- 10 of 12 (Minor non-conformity) : Not available recording the realization of mitigation and reduction of GHG emissions are guided by the GHG program that has been created. Correction: The company has submitted correction GHG record which is done by the company, i.e.: record of fossil fuel, energy efficiency, reforestation in along of riparian zone, and others”. In green col- or marked. Corrective action: The company will continue to record all of activity related the GHG emission mini- mize or reduce in every year. Auditor conclussion: Evidence of immediate action taken was accepted. Effectiveness of implemen- tation to verified at next surveillance audit.

This surveillance verification result: There is evidence that the organization has maintain records of mitig ation and reduction of GHG. Base on identification pollutan and GHG emission, the company already establish significant pollutant and GHG emission. Example: List of source identification and mitigation of emissions of greenhouse gases in 2016. The company has plan to reduce or minimise the identification pollutan and GHG emission. Data of the plan : 1. Reduce GHG from 21.87t CO2/t CPO be 0.85 tco2/t CPO. 2. Reduce GHG from 21.87 t CO2/lt PK be 10.85 t co2t/ PK Auditor conclusion: Closed

6.5.1 Documentation of pay and conditions shall be available. Non-conformance RSPO 2015- 11 of 12(Major non-conformity) : Evidence regarding payment for employees showed during recertification audit showed that company’s contractor (BSP Kisaran Worker Cooperation) employees have paid under minimum wage, especially for upkeep worker. Based on “Worker Payment List: Upkeep March 01 – 31 2015”, the upkeep worker only paid for IDR 5.857 per hour, it’s below local minimum wage (IDR 9.699 per hour). Correction: Working system for upkeep worker no longer based on working hour allocation but base on a contract system. By this contract system, worker could leave the working area after their respon- sibilities/obligations as assigned by BSP Cooperation has been done. Corrective action: Develop new agreement with BSP Cooperation regarding upkeep worker supplies, and conduct reviews on Casual Contractor wages annually. Verification Result: Evidence of immediate action has shown, such as: a. Working Agreement between BSP Worker Cooperation with in-permanent worker (upkeep), 5 sam- ples. Article 4 emphasize that the working agreement is targeted working agreement. There is no clause mentions about obligation to attend in timely manner. b. Worker Payment List: Upkeep April 01 – 30 2015, issued by the company, shows that all upkeep workers has received and signed their payments record. There are 27 upkeep workers, and accept- ed IDR 830.250,00 each. Auditor conclusion: Closed Evidence of immediate action taken was accepted. Effectiveness of implementation to verified at next surveillance audit

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6.5.2 Labour laws, union agreements or direct contracts of employment detailing payments and conditions of employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc.) shall be available in the languages understood by the workers or explained carefully to them by a management official. Non-conformance RSPO 2015- 12 of 12 (Major non-conformity) : 1. Casual Workers and contracted worker not have direct contracts with Kopkar. 2. Facility medical benefits (BPJS) is not given to the casual workers for upkeep 3. The contract between the BSP with Kopkar did not specify the obligations of the contractor to com- ply with labor regulations, especially related minimum prevailing wage. 4. The evaluation procedure available partner does not mention the clauses of compliance with labor regulations as one of indicator evaluated. The relevant labor regulations are: minimum wage, social security, and promotion in the status of casual into become Contracted worker. Correction: 1. Already made a contract of employment between the worker and Kopkar PT BSP. 2. Employment contract between BSPdan Kopkar yet made a complete 3. Already paid to BPJS for employees Kopkar PTBSP 4. Revised procedure of Partner Selection and Evaluation BMP-02 and BMP- & Kopkar Corrective action: 1. Always make the employment contract between the worker and Kopkar PT BSP 2. Involve BPJS for all labor Kopkar PT BSP eligible. 3. Reviewing the contents of the contract of employment every year. 4. Creating employment contract every year between BSP and Kopkar. Reviewing each procedure in accordance with the requirements of the applicable legislation Verification result: Company has provide evidences such as: 1. As the follow up of NCR, BSP has order The BSP Worker Cooperation Management to develop contract between Cooperation and its worker. The order has been implemented by the cooperation. There are five samples of Cooperation Working Contract Agreement with workers showed as evi- dences (Working Agreement Document number 143, 144,145, 146 and 147). 2. As the follow up of NCR, BSP has order The BSP Worker Cooperation Management to involve all of workers as BPJS member. This order has been implemented by the Cooperation. There are ev- idences shows such as: - A Letter from BPJS Office, April 2015, regarding Cooperation Workers BPJS invoices. - List of monthly invoice from BPJS for Cooperation workers and their families. - BPJS payment records on Mandiri Bank, April 7 th 2015 for Cooperation workers. 3. BSP shows evidences that Working Contract regarding worker supplies has been revised. The re- vised document is “Working Contract Agreement Number: 025/BSP/UP KEEP HO/V/2015”. Article 5 of this agreement mentions about the obligations of the contractor to comply with all labor regula- tions, especially related minimum wage. 4. BSP shows evidence that they already has been revised their procedure regarding partner selection and evaluation: a. Procedure Document No. BMP – 02 regarding Partner Selection Procedure has been revised and published in May 12 th 2015. Subjects that been revised are: - Additional in term and definition - Clause revision regarding OHSA and Manpower - Form revision of vendor selection (BMP-FR-01) b. Procedure Document No. BMP – 04 regarding Partner Evaluation Procedure has been revised and published in May 9 th 2015. Subjects that been revised are: - Additional in term and definition

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- Clause revision regarding OHSA and Manpower - Form revision of vendor selection (BMP-FR-01) Auditor conclusion : Closed

3.3 Identified Non-conformances against RSPO P&C Requirements, Corrective Actions Taken and Au- ditors Conclusions

During this 1st surveillance assessment, total of 8 (eight) nonconformance’s against the RSPO Generic Principles & Criteria November 15 th , 2013 were identified. These consisted of 5 (five) major non- conformities and 3 (three) minor non-conformities. The company is given a timeframe to close all major non-conformities within 60 days and at time of first submission of this report to the RSPO For all the non-conformances, the company has provided their planned corrective action against these. A summary of all identified non-conformances, corrective actions taken and auditor conclusions is as below:

Criterion 4.2.3: There shall be evidence of periodic tissue and soil sampling to monitor change in nutrient status Non-conformance RSPO RSPO 00494 (Minor non-conformity): There is no records of soil analysis for all estates. Correction: The company has send sampling of soil for test analisis for all estate to PPKS Laboratory at June 28, 2016. Corrective action: The company established program to ensure that soil test will performed periodiclly Auditor Conclusions: Closed Date of closure: June 28, 2016 Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of implemen- tation to verified at next surveillance audit.

Criterion 4.6.1: Justification of all pesticides used shall be demonstrated. The use of selective products that are specific to the target pest, weed or disease and which have minimal effect on non-target species shall be used where available. Non-conformance RSPO RSPO 00495 (Major non-conformity): The pesticides recommendation letter of the organization has expired on April 13, 2016 Correction: The organization has submitted a letter to get a recommendation Use of Pesticides to the related institutions and the letter of recommendation has been can be from labor office, Asahan Dis- trict. Corrective action: Conduct periodic monitoring to ensure validity of recommendation letter. Verification result: The organization has attached an Recommendation Letter No. 2287/IV-DTK/2016 dataed May 24, 2016. The recommendation was issued by Labor Agency of District Asahan and valid until 1 (one) year since issuance. Date of Closure : June 03, 2016 Auditor conclussion : Closed

Criterion 4.6.11: Specific annual medical surveillance for pesticide operators, and documented to treat relatedto health condition, shall be demonstrated Non-conformance RSPO 00496 (Major non-conformity): There is no evidence that examination health for pesticide operator in 2015 and 2016 was performed. Correction: The company has performed medical surveillance for estate’s agrochemical operators. Corrective action: The company defined a Medical Surveillance Program, including yearly routine medical surveillance. Verification result: There is document Result of Medical Check Up/ ”Hasil Pemeriksaan Kesehatan PTBakrie Sumatera Plantation Tahun 2016 ”. The document reported on June 2016. The report has published by Balai Keselamatan dan Kesehatan Kerja Medan, Dirjen Pembinaan Pengawasan Ketanagakerjaan dan Keselamatan dan Kesehatan Kerja, Kementerian Ketenagakerjaan RI. The document has contained result of laboratory analysis of Spirometry and Cholinesterase for spray- ing operators at all estates. Date of Closure : June 11, 2016

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Auditor conclussion : Closed

Criterion 4.7.3: All workers involve in the operation shall be adequately trained in safe working practices. Adequate and appropriate protective equipment shall be available to all workers at the place of work to cover all potentially hazardous operations, such as pesticides applications, machines operations, and land preparation, harvesting, and if it is used, burning Non-conformance RSPO RSPO 00497 (Major non-conformity): Based on dokumen no. BMEOP- WI-23, Rev. 02, dated July 15, 2013, mentioned that mandatory PPE for Harvester is Safety Shoes on- ly. This case raised as Nonconformity, because not in accordance poential hazard identified for har- vester, for example struck by FFB and etc. Correction: The company has revised their IK and PPE Standard for Harvester. Corrective action: Reviewed hazard identification, risk assessment and control (HIRAC) to control all unacceptable/untolerable risk identified. Verification result: Document No. BMEOP-WI-22, Revision 04, dated June 15, 2016, Title “Aturan/perintah Kerja yang harus Diktahui Pemanen Dalam Pelaksanaan Panen Buah Kelapa Sawit di Lapangan”. On this revision, PPE Standar should be applied by harvester are safety shoes, gloves, safety googes, and safety helmet. Date of Closure: June 22, 2016 Auditor conclussion : Closed

Criterion 4.7.5 Accident and emergency procedures shall exist and instructions shall be clearly understood by all workers. Accident procedures shall be available in the appropriate language of the workforce. Assigned operatives trained in First Aid should be present in both field and other operations, and first aid equipment shall be available at worksites. Records of all acci- dents shall be kept and periodically reviewed. Non-conformance RSPO 00498 (Minor non-conformity): There is no First Aid Officer as required by the national requlation (Permenakertrans No. 15 Tahun 2008) . Correction: Completed First Aid Licenses and First Aid Guidance Book to Labor Agency and Fiiling First Aid Box including Bincard Controller. Corrective action: Follow the Certified First Aider Traning and perform monitoring of First Aid Box pe- riodically. Auditor Conclusions: Closed Date of closure: June 25, 2016 Auditor conclussion: Evidence of immediate action taken was accepted. Effectiveness of implemen- tation to verified at next surveillance audit .

Criterion 6.3.1: The system, open to all affected parties, shall resolve disputes in an effective, timely and appropriate manner, ensuring anonymity of complainants and whistle-blowers, where requested Non-conformance RSPO 00499 (Major non-conformity): The company has not yet provided a poli- cy that guarantee security protection for whistleblowers Correction : The company has established a Policy of Whistle Blower Corrective action: The company will ensure that all RSPO Requirements will be fulfilled Verification result: The company has provided draft document of “Kebijakan dan Panduan Umum Sistem Pelaporan dan Penanganan Tindak Pelanggaran”, document no. SPPTP – 01, revision 00. The document was contain guarantee protection for whistleblowers. Date of Closure: June 27,2916 Auditor conclussion : Closed

Criterion 6.4.1: A procedure for identifying legal, customary or user rights, and a pro- cedure for identifying people entitled to compensation, shall be in place .

Non-conformance RSPO 00500 (Major non-conformity): The company does not have specific pro- cedures for identifying the law, the rights of indigenous and local communities Correction: The company has established procedure of “Identifikasi Hak Legal, Hak Masyarakat Adat & Masyarakat Setempat”, document no. BMH-06, Revision 00, dated June 13, 2016. Corrective action: The company will ensure that all P&C RSPO and requirements. Verification result: The company has provided copy of procedure as mentioned above.

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Date of Closure: June 13 Auditor conclussion : Closed

Criterion 6.9.1: A policy to prevent sexual and all other forms of harassment and violence shall be implemented and communicated to all levels of the workforce Non-conformance RSPO 00501 (Major non-conformity): The company has no decree of Gender Committee, including structure at each unit respectively and job description and working program Correction : The company has defined organization structure of Gender Committee, including job de- scription and their program Corrective action: The effectiveness of Gender Committee will be evaluated periodically. Verification result: The company has provided a document of Decree of General Manager No. 01/GM-Sumut 1/VI/2016, dated June 17, 2016. Ther decree was contained decision/assignment of or- ganizatioan structure of Gender Committee and their job descriptions respectively and a programme of 2016 Date of Closure: June 17, 2016 Auditor conclussion : Closed

3.4 Description of Supply Chain Management System

E.1. Definition Findings: Kisaran mill is Palm Oil Mills owned by PT Bakrie Sumatera Plantation Tbk Kisaran unit, that is located in Kisaran, Asahan District, North Sumatra. Kisaran Palm Oil Mill was established in 2007, based on the government directives from the Capital Investment Coordination Board (BKPM), i.e. ‘Keputusan BKPM No. 257/T/Pertanian/Industry/1989’ and ‘Keputusan BKPM No. 1293/T/Industri/2008’. Currently Kisaran Mill receives FFB supply from 5 estates owned by PT Bakrie Sumatera Plantation Tbk- Kisaran Unit (Tanah Raja Estate, Gurach Batu Estate, Kuala Piasa Estate, Serbangan Estate and Sei Baleh Estate) and other company’s area (Seed Garden, BARI and Aek Salabat). Since company increase their production capacity following their approved production capacity (full capacity) and Kisaran mill receive supplies of FFB from independent out growers or other suppliers. The organization (Kisaran Mill) implemented the RSPO-SCCS Mass Balance model. This SCCS model allowed to mixing of certified and uncertified product but shall be control by the Mass Balance record to ensure the quantity of certified product, and only certified product could be claim by the organization as certified palm oil product. The organization has identified the volume of certified and uncertified FFB supplied to the mill. Based on record of Mass Balance showed the amount of FFB certified and uncerti- fied, when the certified FFB is come from own estate (Tanah Raja Estate, Gurah Batu Estate, Kuala Pi- asa Estate, Serbangan Estate and Sei Baleh Estate). And for uncertified FFB is come from out- side/outgrower and sister company such as (Seed Garden, BARI and Aek Salabat Estate) and others. In 2015 from January until December, Kisaran Mill received certified FFB is approximately 141,511.01 tonnes of FFB or 56.86 % from the FFB received total in once year. And for uncertified FFB is approxi- mately 107,350.31 tonne or 43.14 %. Then, in 2016 from January until May (during the 1st Surveillance audit) certified FFB received by Kisaran Mill about 42,851.04 tonne or 58.15% and for uncertified FFB about 30,842.13 tonne or 41.58%. Kisaran Mill just produced Crude Palm Oil and Palm Kernel. Mass balance record also showed the certified product. In 2015 from January until December CPO cer- tified product is about 32,541.04 tonne or 61.30%, and uncertified CPO is about 20,548.14 tonne or 38.70%. In 2016 from January until May CPO certified product is about 9,465.83 tonne or 61.50%, and uncertified CPO is about 5,924.71 tonne or 38.50%. While for the PK certified in 2015 is about 6,484.26 tonne or 60,17% and PK uncertified is about 4,291.444 tonne or 39.83%.

Compliance status : Full Compliance

E.2. Explanation

Findings: Estimated of tonnage CPO and PK products has been recorded in to the public summary of the P&C certification report.

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Kisaran Mill registered in RSPO IT Platform (e-Trace) with the RSPO member ID RSPO_PO1000000184.

Compliance status: Full Compliance

E.3. Documented procedures

Findings: The organization (Kisaran Mill) has recorded and documentation owned procedures and work instruc- tions to ensure the implementation of RSPO SCCS Mass Balance. That procedures such as: - FFB incoming procedure, BMO-03, Rev.06 date issued January 15, 2016. In the procedure ex- plained about the receiving of certified and uncertified FFB. - Certified Palm Oil & Palm Kernel Storage Procedure, with document number BMO-04, Rev. 02, is- sued date July 09, 2011 - Certified Palm Oil & Plam Kernel Delivery Procedure, with document number BMO-05, Rev.06, is- sued date January 15, 2016. - Poduction Losses Analysis, Document No. BMO-09, Rev. 05, issued date October 25, 2014 - Reporting of Information of Projected of FFB, CPO and PK Procedure, Document No. BMO-19, Rev. 01 issued date October 25, 2014 - Procedure of Input Data to e-Trace Application/UTZ, Doc. No. BMO-20, Rev.01, Issued Date Octo- ber 25, 2014. - Procedure of CPO Receiving, Document No. BMO-21, Issued date January 15, 2016. - Flowchart of Costumer Complaint Handling procedure, with document number BM-FC-02 Rev03 date issued July 09, 2011 - Flowchart for product sales and purchase contract, with document number BMO-FC-06 Rev03 date issued 09 July 2011

The last refreshment SCCS training for person who implemented RSPO SCCS MB, on June 13, 2014 with evidenced is attendant list and also certificate, the training was attended by 15 persons. The organization also was conducted internal training for SCCS by Bpk Efdi Ruzaly (PT BSP Ja- karta). The training was attended by 5 (five) persons (Miswar Efendi, Suryo Muliono, Mega Khai- rani, A.Y. Putri, and Maskud).

Compliance Status: Full Compliance

E4. Purchasing and good in

Findings: Kisaran mill has been recorded volume of FFB’s certified and uncertified in mass balance record. Based on field observation in weight bridge activity, person in weighbridge understood the different of certified and uncertified incoming FFB through the mass balance stamp in weighing slip and delivery FFB slip. In delivery FFB slip showed the RSPO SCCS model, origin/estate, field number, unit transport number and others. In 2015, FFB certified received in Kisaran Mill is about 141,511.010 tonnes of FFB or 56.86% from the FFB received total in once year. Until 1st surveillnce audit, there is no overproduction of certified palm product or FFB, but if the over- production will happen, the mill has mechanism to inform to the certification body through the mill pro- cedure.

Compliance status: Full Compliance

E.5. Record keeping

Findings: The Mill has maintained records and balance all receipts of RSPO certified FFB and non-certified

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Page 51 of 56 FFB, an also RSPO certified CPO and Palm Kernel (PK). Based on the Mill’s records, during year of 2015, shown data as follow: - Total FFB received: 248,861.360 tonne - Certified FFB received: 141,511.010 tonne (56.86%) - Non-certified FFB received: 107,350.309 tonne (43.14%) - Certified CPO produced: 32,541.04 tonne (61.30%) - Non Certified CPO produced: 20,548.14 tonne (38.70%) - Certified PK produced: 6,484.26 tonne (60.17%) - Non-certified PK produced:4,291.44 tonne (39.83%) - Certified CPO delivered/sold: 623.69 tonne - Certified PK delivered: 3,303.01 tonne - Stock of certified CPO : 31,917.35 tonne - Stock of certified PK : 3,230.25 tonne

Based on the above data, evidenced that until December 2015, palm oil products (CPO & PK) still in positive quantity. There is evidence that mass balance records was evaluated every 3 (three) month regularly. The Mill also was demonstrated that the mass balance records has been sup- ported by relevant documents, e.g:: - Slip Timbang (Weighing Slip) dated May 17, 2016, Ticket No. 150947, Vehicle BK 8507VE; Product: CPO; Deliver to PT Multimas Nabati Asahan; 1 st Weighing 14,220 kg; 2 nd Weighing 46,200 kg; Netto 1: 31,980 kg; Adjustment 0.00%; Netto 2 : 31,980 kg; - Official Report of CPO/PK Loading, dated May 17, 2016 - Official Report of Seal Attachment, dated May 17, 2016 - Vehicle Checklist Record - Document of Nota Pengiriman No. 021826, dated May 17, 2016.

Compliance status: Full Compliance

3.5 Status of Previously Identified Non-conformities During the Re-certification audit, there was 1 nonconformance against the RSPO-SCCS. The company is given a time frame to close those non-conformities within 60 days and at time of first submission of this report to the RSPO.

NCR SCCS 2015 - 01 of 01: Kisaran POM through Parts Trading has been selling Certified PK to PT MNA based on recordings of DO 24 / MO / PK-POM / 15 dated March 15, 2015, but sales are not recorded in the RSPO E-trace sys- tem

Correction Action: Already registering for PK. on RSPOEtrace, because there is no delivery we affirm it in a letter issued by GM North Sumatra 1

Corrective Action: Will be recorded to the RSPO E-Trace System Certified PK every sale.

Date of closure: June 03, 2013

Verification result: There is a memo from GM to marketing and SCCS representative to register PK sales also to record all PK sales into RSPO E-Trace in the future.

Auditor Conclusions: Closed

3.6 Description of Supply Chain Management System Identified non-conformance against RSPO SCCS

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requirements, Corrective Actions Taken and Auditors Conclusions

Not applicable, since there is no non-conformance found during 1 st surveillance audit

3.7 Noteworthy Positive Components

Criterion 2.1. There is compliance with all applicable local, national and ratified international laws and regulations. Findings: The company has achieved gold class health and safety awarded from The Ministry of Labour.

3.9 Issues Raised by Stakeholders and Findings Pertaining to Issues Below do stakeholders interviewed on-site raise a summary of issues

Management Re- No. Issues Raised Audit Verification sponse Based on visiting result to some au- The company has thority agencies both of Batubara and good communica- Asahan District, such as: Environ- tion with gover- mental agencies, Labor Agencies, mental authority and Forestry and Plantation Agen- agencies 1 cies, there is no significanty issue raised.

The company has fulfil all their obliga- tion as required by legal and other regulations applied.

4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY

4.1 Date of Next Surveillance Visit

The next surveillance visit is planned for April 2017.

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

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

Signed on behalf of PT Bakrie Sumatera Signed on behalf of TUV Rheinland Indonesia

…………………………………………. ……………………………. Andi Wahyudin Wahyu RSPO Management Representative Lead Auditor Date: September 10, 2016 Date: September 09, 2016

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APPENDICES Appendix 1(a): Details of Revised Certificate

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Page 55 of 56 Appendix 3: List of Abbreviations

AMDAL Analisis Dampak Lingkungan & Sosial (Social & Environmental Impacts Assessment) BLH Badan Lingkungan Hidup (Environmental Agency) CPO Crude Palm Oil CWB Central Warehouse Bunut DELH Dokumen Evaluasi Lingkungan Hidup (Environment Evaluation Document) EIA Environmental Impact Assessment ERTs Endangered, Rare & Threatened species ESH Environmental Safety & Health EBITDA Earn Before Interest, Tax, Depreciation and Amortization. FFB Fresh Fruit Bunches EFB Empty Fruit Bunches HCV High Conservation Value IPM Integrated Pest Management Kopkar Koperasi Karyawan (Employee Cooperatives) LTA Lost Time Accident MSDS Material Safety Data Sheets NGO Non-Government Organization OSH Occupational Safety & Health P&C Principles & Criteria PK Palm Kernel PKO Palm Kernel Oil PKWT Perjanjian Kerja Waktu Tertentu (Employment Agreement Specified Time) POME Palm Oil Mill Effluent PPE Personal Protective Equipment PT BSP PT Bakrie Sumatera Plantations (Company name) RKL Rencana Pengelolaan Lingkungan (Environmental Management Plan) RPL Rencana Pemantauan Lingkungan (Environmental Monitoring Plan) SCCS Supply Chain Certification System SEL Studi Evaluasi Lingkungan (Environment Evaluation Study) SIA Social Impact Assessment SOP Standard Operating Procedure UKL Upaya Pengelolaan Lingkungan (Environmental Management Efforts) UPL Upaya Pengelolaan Lingkungan (Environmental Management Efforts)

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Page 56 of 56 Appendix 4: List of Stakeholders Interviewed and Contacted Name of No. Institution – Address Stakeholder Stakeholders Interviewed On-Site 1. Andi Wahyudin Management Representative/QHSE Departement 2 Sugiartono Manager Serbangan Estate 3. Djuarno Manager Tanah Raja Estate 4. Sumantri Human Resources Area Head 5. Bahrum Nawar Siregar Finance Manager 6. Miswar Effendi Hasibuan Palm Mill Manager 7. Mega Khairani Palm Laboratorium Officer 8. Subarna KopKar BSP 9. Adni Said Manager Gurach Batu Estate 10. A. Yakafemi Manager Kuala Piasa Estate 11. Rudi Irwansyah Sei Baleh Estate 12. Randang Astono Procurement & Contract Officer 13. M. Husni Mubaraq Centra Warehouse Bunut 14. Helmi Yusri Saros Human Resource Officer 13. Suriana Human Resource Officer 14. Ismi Bebi Harahap Human Resource Officer 15. Hartati Mustika Bestari QHSE Officer

Appendix 5: Observations and Opportunities for Improvement

No. Observations / Opportunities for Improvement Criteria Terdapat SOP Komunikasi dan konsultasi dengan stakeholder, namun SOP 1 tersebut tidak dilengkapi dengan kerangka waktu yang jelas untuk memberikan 1.1.2 respon/tanggapan atas permintaan informasi. Perusahaan belum memiliki SOP terkait pemantauan dan pemeiliharaan Patok 2 Batas Konsesi (HGU) 2.2.2

Harus dipastikan bahwa seluruh referensi kerja (prosedur/instruksi ker- ja/gambar/flowchart dan lain-lain) yang ada ditempat kerja adalah yang masih ber- 3 4.1.2 laku (terbaru). Contoh kasus, IK yang terdapat pada proses sterilizer tidak ada identitasnya (nomor, revisi, tanggal). Belum tersedia ketentuan yang mengatur tentang larangan wanita hamil dan me- 4 nyusui bekerja pada bagian yang terkait dengan bahan kimia. 4.6.12 Sosialisasi Kebijakan K3 harus ditingkatkan, misalnya dengan menempatkan pernyataan kebijakan K3 terbaru pada semua karyawan. Contoh kasus Kebijakan 5 K3 yang ada di Workshop PKS bukan yang terbaru (tanggal 10 Januari 2011). 4.7.1 Sedangkan perusahaan sudah memiliki Kebijakan K3 yang ditandatangani tanggal 2 November 2011. - Implementasi pengendalian proses produksi harus ditingkatkan misalnya pen- gendalian parameter proses produksi. Contoh kasus pada proses sterilizer, menggunakan kertas blank pada alat pemantau tekanan dan pada pressure gauge tidak terdapat tanda tekanan maksimum (disyaratkan pada akte izin penggunaan sterilizer) 6 4.7.2 - Tangki bahan bakar solar harus diberi tanda/symbol yang sesuai dengan jenis bahayaanya secara jelas. Contoh kasus, tangki solar d area PKS hanya mem- iliki tanda/symbol jenis bahaya hanya pada satu sisi. - Sebaiknya tempat pengambilan sampel limbah cair di IPAL lebih memper- hatikan keselamatan pekerja. 7 Flow meter pegaliran limbah cair untuk Land Aplikasi agar difungsikan. 4.4.3 8 Sampah domestik di depan pagar PKS Kisaran agar di kendalikan 5.3.3

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