TÜV NORD INTEGRA bvba Certification in agriculture and food Statiestraat 164 2600 Berchem – Antwerp Belgium Phone: + 32 3 287 37 60 Fax: +32 3 287 37 61 www.tuv-nord-integra.com [email protected]

RSPO P&C Surveillance assessment PUBLIC SUMMARY REPORT

New Britain Palm Oil Limited – Poliamba Limited

Date of assessment: 30/11/2015 to 04/12/2015 Number of ASA: (1 to 4): ASA - 04

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Contents

1 Scope ...... 4 1.1 Organizational information/Contact person ...... 4 1.2 Certification details ...... 4 1.3 Identity of certification unit ...... 4 1.4 Production volume ...... 6 1.5 Description of fruit supply base ...... 6 1.6 Date of planting and cycle ...... 11 1.6.1 Planting program for each plantation ...... 11 1.6.2 Replanting program for each estate ...... 12 1.7 Progress against time-bound plan by parent company ...... 12 1.8 Progress of associated smallholders or outgrowers towards compliance with relevant standards ...... 13 2 Assessment process ...... 13 2.1 Certification body ...... 13 2.2 Qualifications of the assessment team ...... 14 2.2.1 Qualification of the lead auditor: Cheong, Chun Yuen (Robert) ...... 14 2.2.2 Assessment team members ...... 14 2.3 Assessment methodology ...... 17 2.3.1 General overview ...... 17 2.3.2 Calculation of the Number of Production Units (N) to Sample for the Mill ...... 17 2.3.3 Assessment program ...... 18 2.4 Stakeholder consultation ...... 20 2.4.1 Summary ...... 20 2.4.2 List of contacted stakeholders ...... 21 3 Partial certification ...... 24 3.1 General ...... 24 3.2 Requirements for time-bound plan ...... 24 3.3 Requirements for uncertified management units and/or holdings ...... 25 4 Assessment findings ...... 27 4.1 Findings by RSPO Principle and sample of the Criteria ...... 27 4.2 Noteworthy positive components and identified non conformances ...... 173 4.2.1 Details of noteworthy positive components ...... 173 4.2.2 Status of non-conformities previously identified...... 173 4.2.3 Detail of Non Conformities identified during this audit ...... 174 4.3 Issues raised by stakeholders ...... 175 5 RSPO Supply Chain Certification...... 177 5.1 Findings by criteria ...... 177 5.2 Noteworthy positive components and identified non conformances ...... 179

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5.2.1 Details of noteworthy positive components ...... 179 5.2.2 Detail of non-conformity ...... 179 6 Certified organization’s acknowledgement of internal responsibility ...... 179 6.1 Date of next surveillance visit ...... 179 6.2 Date of closing non-conformities...... 180 6.3 Formal sign-off of assessment findings ...... 180 Abbreviations: ...... 181

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1.1 Organizational information/Contact person

Principle Contact Person Ipiso Junior

Business address District, Province,

Name New Britain Palm Oil Limited – Poliamba Limited

Office Number +675 984 2079

Mobile Telephone Number +675 79811695

Fax +675 984 2081

E-mail address [email protected]

Web site www.nbpol.com.pg

1.2 Certification details

RSPO membership number: 1_0016_04_000_00

Parent company as applicable: New Britain Palm Oil Limited

Certificate number: 78814

Date of previous assessment 08/09/2014 to 12/09/2014

Date of issue certificate 19/03/2012

Date of expiry certificate 18/03/2017

1.3 Identity of certification unit New Britain Palm Oil Limited (NBPOL) is a plantation organisation with operations in 5 provinces in Papua New Guinea and one operation in the Solomon Islands. NBPOL is operating 11 mills, one refinery and 5 bulking terminals in Papua New Guinea and 1 mill and bulking terminal in the Solomon Islands. Poliamba Limited (POL) consists of 1 oil mill Poliamba Oil Mill with a supply base of 5 internally owned estates and 1,756 Village Oil Palms (VOP) associated smallholders as per table below. The audit of the mill, estates and smallholders was conducted according to the RSPO P&C Generic Version 2013 and PNG National Interpretation Guideline 2015 and RSPO SCC version 2014 The methodology for collection of objective evidence included physical site inspections, observation of tasks and processes, interviews of staff, workers and their families, review of documentation and monitoring data. Checklists and questionnaires were used to guide the collection of information. The comments made by external stakeholders were also taken into account in the assessment. During this surveillance audit, applying the RSPO sampling formula of square root number of estates / smallholders x 0.8, minimum 2 estates and 34 smallholders have to be selected. Finally, the selected estates are West Coast, Madak and 43 smallholder members from North, South and West area.

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. The mill and supply bases are listed in below tables.

Name of Mill Location of mill Coordinates

Poliamba Oil Mill Kavieng District, E151o16’35”; S02o 52’29”

Name of Plantation Location GPS Position (Lat-Long)

Kara Kavieng District, New Ireland Province S 02°42'23''- S 02°48’39.6” E 151°01’42”- E 151°11’5.9

Nalik Kavieng District, New Ireland Province S 02°52'14''- S02°55’57” E 151°12'54''- E 151°25'47''

West Coast Kavieng District, New Ireland Province S 02°48'49.4''- S 02°58'56'' E151°1'9.1''- E 151°17'34.7''

Noatsi Kavieng District, New Ireland Province S 02°57'38''- S 03°06'35'' E151°27'23''- E 151°42'19''

Madak , New Ireland Province S 03°08'35''- S 03°15'35'' E 151°45'21''- E 152°02'28''

Name of Scheme Location GPS Position (Lat-Long) Smallholders

Kavieng District , New Ireland S 02°41'2.7816''- S 02°52'48.0612'' North Province E150°57'0.4104''- E 150°15'24.6708''

Kavieng & Namatanai District New S 02°52'.16.3092''- S 03°11'17.7864'' South Ireland Province E 151°17'10.9356''- E 151°50'8.1132''

Kavieng District. New Ireland S 02°48'34''- S 02°59'56'' West Province E 151°01'42''- E 151°20'43''

See Figure 1-1 Map below showing the mill and the supply bases.

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1.4 Production volume

Certified volume for the past Actual annual volumes** Projected volume for the next year * 12 months*** (Mar 2015 to Feb 2016) (Mar 2016 to Feb 2017)

FB CPO PK FFB CPO PK FFB CPO PK

Own 21,272.86 5,844.43 Own Estates: 19,417.44 5,449.83 Own 17,892.12 4,877.26 Estates: Estates: 77,239.09 82,779.69 63,897.83 Associated Associated Smallholders: Associated smallholders: Smallholders 22,889.56 24,681.12 24,458.33

*of certified products since date of last reporting period **from current reporting period *** project reporting period

The reduction in FFB production from owned estates for the period Mar 2016 to February 2017 was due to replanting.

1.5 Description of fruit supply base The supply bases for the Poliamba oil mill of the Poliamba Ltd, New Ireland Province are as below table:

Name of Plantation Area (Ha) FFB Production (ton/year) Total* Planted** (Mar 2015 to Feb 2016)

Kara 1,032.10 865.41 1,992.03

Nalik 2,666.75 1,846.61 13,046.77

West Coast 749.84 455.43 9,376.09

Noatsi 2,064.10 1,489.63 26,948.89

Madak 1,517.11 946.7 25,875.31

Total FFB supplied to the mill (Plantations) 77,239.09 Name of associated Area (Ha) FFB Production (ton/year) smallholders Total Planted (Mar 2015 to Feb 2016)

North 1,000.09 1,000.09 9,473.57

South 1,092.58 1,092.58 9,791.06

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West 511.4 511.4 3,624.93

Total FFB supplied to the mills (Smallholders) 22,889.56 Total FFB supplied to the mills (Plantations + 100,128.56 Smallholders) *includes productive and non-productive area (infrastructures, conservation, HCV, community use, set aside area etc.) ** immature + Mature Area

Above data were based on production from March 2015 to February 2016. Based on this surveillance audit the projected quantity of CPO and PK to be certified for period March 2016 to February 2017 is 17,892.12 and 4,877.26 metric tons respectively.

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Figure 1-1 Geographical Map of Papua New Guinea

Map of New Ireland Province, PNG

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Figure 1-2 Map of mill and supply base

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1.6 Date of planting and cycle

1.6.1 Planting program for each plantation

Year Kara Nalik West Coast Noatsi Madak POL

Year 1989 439.92 439.92 Year 1990 252.94 483.21 736.15 Year 1991 301.90 254.96 556.86 Year 1992 Year 1993 Year 1994 13.98 114.35 128.33 Year 1995 24.70 24.7 Year 1996 Year 1997 43.51 94.4 84.37 87.44 309.71 Year 1998 162.74 79.94 242.68 Year 1999 50.45 626.29 676.74 Year 2000 59.13 59.13 Year 2001 Year 2002 Year 2003 Year 2004 Year 2005 Year 2006 Year 2007 Year 2008 Year 2009 Year 2010 Year 2011 217.36 217.36 Year 2012 242.49 446.13 688.62 Year 2013 395.20 395.20 Total Mature 249.49 1,355.14 455.43 1489.63 932.72 4,475 Year 2013 - Y3 Year 2014 - Y2 298.25 211.65

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Year 2015 - Y1 324.67 279.82 13.98 Total Immature 622.92 291.47 0 0 13.98 1,128.37 TOTAL OIL 865.41 1846.61 455.43 1489.63 946.70 5603.78 PALM

1.6.2 Replanting program for each estate

Year of Planted area (ha) in each estates Total area to be replanting replanted (ha) Kara Nalik West Coast Noatsi Madak 2015 324.67 279.82 205.09 809.58

2016 986.98 986.98

2017 43.51 396.30 144.13 583.94

2018 153.43 153.43

2019 236.11 236.11

TOTAL 324.67 323.33 396.30 1489.54 236.11 2,770.04

1.7 Progress against time-bound plan by parent company a. Time-bound plan for mill(s)

The NBPOL group has 6 operation locations, of which 5 are in Papua New Guinea namely West New Britain (WNB), Higaturu Oil Palm (HOP), Poliamba Limited (POL), Ramu Agri-Industries Limited (RAIL) and Milne Bay Estates (MBE) and 1 in the Solomon Islands namely Guadalcanal Plains Palm Oil Ltd (GPPOL). The table below shown the certification achieved by the respective sites. In this aspect, all operating sites within NBPOL plan in both PNG and Solomon Islands have now been certified to RSPO P & C and RSPO SCCS. The village oil palm (VOP) smallholders in New Ireland Province all have been included in the certification in 2013. Therefore, the time-bound plan is not applicable.

Time-bound for Name of Mill(s) Location Certified year certification

West New Britain: Kimbe, West New Britain, Papua September 2008 N/A New Guinea Mosa Palm Oil Mill, Kumbango Palm Oil Mill, Numundo Palm Oil Mill, Kapiura Palm Oil Mill and Waraston Palm Oil Mill Higaturu Oil Palms: Popondetta, Oro Bay Province, January 2013 N/A Papua New Guinea Sangara Palm Oil Mill, Sumbiripa Palm Oil Mill and Mamba Palm Oil Mill Poliamba Limited: Poliamba Palm Kavieng, New Ireland Province, February 2012 N/A

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Oil Mill Papua New Guinea.

Milne Bay Estates: Hagita Palm Oil Alotau, Milne Bay Province, Papua February 2013 N/A Mill New Guinea Ramu Agricultural Industries Ltd: Gusap Downs, Lae, Morobe July 2010 N/A Gusap Palm Oil Mill Province, Papua New Guinea Guadalcanal Plains Palm Oil Ltd Guadalcanal Plains, Guadalcanal March 2011 N/A (GPPOL): Tetere Palm Oil Mill Province, Solomon Islands b. Time-bound plan for plantation(s) and smallholders All plantations and smallholders are certified and the below table is not applicable

Name of plantations / Time-bound for Locations smallholders certification

See above table 1.5 North, South & West area NA

1.8 Progress of associated smallholders or outgrowers towards compliance with relevant standards (should be in accordance to the 3 year implementation plan). NBPOL, Poliamba Limited (POL) is in collaboration with 1,756 Village Oil Palm (VOP) smallholders that was developed on customary land. The VOPs were developed independently of the company. The individual VOP manage all aspects of their small holdings of oil palm including harvesting. The smallholders supply approximately 23% of the total tonnage of FFBs processed by the Poliamba oil mill. All the smallholders at New Ireland Province are RSPO certified. NBPOL- POL operates a Smallholder Affairs Department (SHA) that is dedicated to support the smallholders who supply FFBs to the company’s mill. NBPOL has a defined list of smallholders and has agreed to collect the smallholder fruits. The smallholders land was mapped and NBPOL is continuing to assist in the verification of their rights to the land. NBPOL SHA works with the Oil Palm Industry Council (OPIC) on the development of smallholders. The development process involves the physical inspection of the blocks and interview of each smallholder to assess their understanding of sustainable practices and conformance with the relevant RSPO P&Cs. The surveys, development and inspections are on-going process by the OPIC officers with POL smallholders’ affairs office to hold continuous comprehensive discussions with the smallholders on RSPO P&C implementation in maintaining the certification. All smallholders have been certified within the 3 year time-bound plan from the initial certification. Therefore, the 3 years implementation is not applicable.

2 Assessment process

2.1 Certification body TÜV NORD INTEGRA is a certification and inspection body which operates in agriculture and the food and feed processing industry. TÜV NORD INTEGRA is member of the internationally operating German inspection and certification organisation TÜV NORD.

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TÜV NORD INTEGRA is accredited by ASI for RSPO P&C and RSPO SCC.

2.2 Qualifications of the assessment team

2.2.1 Qualification of the lead auditor: Cheong, Chun Yuen (Robert)

Requirement Qualifications

A minimum of post high school (post-secondary Graduate in Business Administration. school) training in either agriculture/forestry, RSPO P&C, SCC & ISCC EU / PLUS Lead auditor; environmental science or social sciences; Authorised ISCC EU / PLUS GHG & Land use change auditor; MSPO Lead Auditor. Senior assessor for carbon credits

At least 5 years professional experience in area RSPO P&C, SCC & ISCC EU / PLUS Lead auditor; of work relevant to the assessment (e.g., palm Authorised ISCC EU / PLUS GHG & Land use change oil management; agriculture/forestry; ecology; auditor; MSPO Lead Auditor. Senior assessor for carbon social science); credits. 10 years in carbon credits, 3 years in ISCC and 2 years in MSPO auditing. Training in the practical application of the RSPO Successful completion of the RSPO P&C Lead Assessor criteria, and RSPO certification systems; Course (organised by Wild Asia, Kuala Lumpur, Malaysia : 24-28 November 2014) Successful completion of the RSPO SCC Auditor Course (Organised by David Ogg & Partners, Kuala Lumpur, Malaysia : 26-27 January 2015) Successfully completion of an ISO 9000:19011 Attended ISO 14001 in 2005 & 2007 and ISO 9001 in 1994, lead assessors course; 2006 & 2015 auditor course. MSPO Auditor course in 2014 A supervised period of training in practical 3 years as ISCC Lead auditor for ISCC EU & PLUS, Land assessment against the RSPO criteria or similar use change, GHG assessor; sustainability standards, with a minimum of 15 2 years as MSPO Lead Auditor; days assessment experience and at least 3 assessments at different organisations. 10 years as Senior assessor for carbon credits.

2.2.2 Assessment team members Requirement Assessor Qualification Compliance

Field working experience in the palm Cheong, Chun Yuen 3 years as ISCC Lead auditor for Yes oil sector, or demonstrable (Robert) ISCC EU & PLUS, Land use equivalent. change & GHG assessor; 2 years as MSPO Lead Auditor; 10 years as Senior assessor for carbon credits. Primas, Kapi MA Honours in Development Yes Studies; M Applied Sc in

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Agriculture and Rural Development; Graduate Diploma in Systems Agriculture; Diploma in High School Teaching (Agriculture and Commerce): Certificate in Tropical Agriculture; Agriculture Extension Officer with the Community Affairs Department of Chevron Niugini Limited in Papua New Guinea: Provided technical advice obtained from researchers to farmers regarding best management practices for agriculture activities such as coffee, oil palm, vegetables, small livestock on fertilisers application, chemical application, harvesting, weed control, biological pest management, etc. Encouraged farmers to reduce usage of chemicals and fertilisers for sustainability; Rural Development Technician (RDT) with the Department of Agriculture and Livestock in Mendi District, Southern Highlands Province: Provided technical advice obtained from researchers to farmers regarding best management practices for agriculture activities such as coffee, oil palm, vegetables, small livestock on fertilisers application, chemical application, harvesting, weed control, biological pest management, etc. Encouraged farmers to reduce usage of chemicals and fertilisers for sustainability; PNG Auditor with PT. BSI Group Indonesia and Singapore based Auditors auditing Hargy Oil Palm Limited in Bialla, West New Britain Province. Assisted the BSI Auditors and Team Leader on small holders audit relating to topics on smallholders planting practices in PNG such as planting, fertilising program and

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harvesting practices in translating English to Tok Pisin for the Auditor and the smallholders during the smallholders visits Good Agricultural Practices (GAP), Cheong, Chun Yuen 3 years as ISCC Lead auditor for Yes and Integrated Pest Management (Robert) ISCC EU & PLUS, Land use (IPM), pesticide and fertilizer use. change & GHG assessor; 2 years as MSPO Lead Auditor; 10 years as Senior assessor for carbon credits. Primas, Kapi University of Western Sydney Yes Hawkesbury in New South Wales, Australia: Master of Applied Science (course work) with major studies in Agriculture and Rural Development: 1999. University of Western Sydney Hawkesbury in New South Wales, Australia: Graduate Diploma in Systems Agriculture: 1998. University of Papua New Guinea, Goroka Teachers College: Diploma in High School Teaching (Agriculture and Commerce): 1989 – 1990. Sepik Agriculture College: Certificate in Tropical Agriculture: 1985 – 1986. Health and safety auditing on the Cheong, Chun Yuen Carbon Credits / ISCC / MSPO Yes farm and in processing facilities, for (Robert) audits example OHSAS 18001 or Occupational, Health & Safety Sivathasan Punnyan OHSAS 18001:2007 audit Assurance System. experience in various manufacturing and service industries Worker welfare issues and social Cheong, Chun Yuen Attended Basic SA 8000 & GRI 4 Yes auditing experience, for example (Robert) training + qualified as ISCC / with SA8000 or related social or MSPO sustainability auditor ethical accountability codes. Primas, Kapi Community Liaison Officer with the Community Affairs Department of Chevron Texaco Niugini Limited in Papua New Guinea: October 2001 – December 2002. Assisted Project area communities with community development projects

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such as communities meetings, social issues, requests from communities, supervised village officers, contact point for company; Senior Field Researcher with Booyong Forest Science on Social Impact Assessment (SIA): Supervised Field Researchers on research work comprising of field interviews and observations in New Ireland, PNG. Environmental and ecological Cheong, Chun Yuen Authorised ISCC / MSPO / Yes auditing, for example experience (Robert) Carbon Credits sustainability with organic agriculture, ISO 14001 auditor or Environmental Management Leong Sak Kuan Authorised lead auditor for QMS Systems (EMS). ISO 9001 & EMS ISO 14001 with experience in various manufacturing and service industries Sivathasan Punnyan Authorised lead auditor EMS ISO 14001 and QMS ISO9001 with experience in various manufacturing and service industries

Fluency in the main languages Cheong, Chun Yuen English Yes relevant to the location where the (Robert) specific assessment is taking place, including the languages of any Leong, Sak Kuan English potentially affected parties such as Sivathasan Punnyan English local communities. Primas Kapi English + Tok Pisin

2.3 Assessment methodology

2.3.1 General overview The assessment was carried out following the TÜV NORD Integra RSPO P&C Certification Procedure. During the assessment the assessors used the RSPO standard as endorsed for the country in which the assessment took place and recorded their findings.

2.3.2 Calculation of the Number of Production Units (N) to Sample for the Mill N = 0.8√Y, where “Y” is the number of units, with the result always to be rounded “up” to the next whole integer. Where only a sample of the supply base is assessed, units not previously assessed, or assessed earlier in the certification program, are to be preferred over those more recently assessed. For the Mill, how many units form the production base? Owned estates (Y) N = 0.8√Y Smallholders (Z) N = 0.8√Z 5 2 1,756 34

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Explanation as to the selection of estates sampled: The owned estates are randomly selected. The number of owned estates assessed was 2 .The selected estates were not audited during the last surveillance audit. The number of smallholders selected was 43 from North, South and West areas.

2.3.3 Assessment program The audit schedule is as below. Table 2-1 Audit Schedule

Focus/ Date/ Time1) Standard Auditor Subject Site Requirement/ (Initials) Chapter DAY 1: Monday

(30/11/2015 Opening Meeting at Poliamba Limited Main RC, SP, 7:30-to 7:45am Office @ Lakurumau - Nalik Estate Area LSK, PK

7:45 to 9:00am 1, 2, 3 Financial Viability, Land Office RC

General Documentation - Main Sustainability 7:45 to 12:00am 1, 2, 4, 5, 6, 8 Files for all RSPO Indicators, Previous Audit LSK Report Workshop, Central Stores, Landfill

General Documentation - Main Sustainability 7:45 to 9:00am 1,2,4,5,6 SP, PK Files for all RSPO Indicators

RC, SP, 9:00 to 12:00noon 1, 6 Stakeholder Consultation at Lakurumau area PK

12:00 to 1:00pm Lunch

Poliamba Oil Mill and Kernel Crusher Plant 1, 2, 3, 4, 5, 6, 1:00 to 5:00pm Operations, Documentation & SCC, Bulking RC, LSK 8 Jetty, Laboratory

General Documentation - Main Sustainability 1:00 to 5:00pm 1 to 8 SP, PK Files for all RSPO Indicators, Internal Audits

RC, SP, 5:00 to 5:30pm Reporting and day wrap up LSK, PK DAY 2: Tuesday

(01/12/2015)

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West Coast Estate - Field Operations, site 7:30 to 12:00noon 1, 2, 4, 5, 6, 8 documentation, chemical shed, workshop, RC, LSK clinic, landfill, accommodation.

7:30 to 12:00noon 1, 2, 4, 5, 6 Smallholders West Coast SP, PK

12:00 to 13:00 Lunch

1:00 to 2:30pm 1, 6 Stakeholder meeting at West Coast Area SP, PK

3:00 to 5:00pm 4, 5, 6, 7 Smallholders Affairs Office SP, PK

General Documentation - Main Sustainability 1:30 to 5:00pm 1 to 8 RC, LSK Files for all RSPO Indicators RC, 5.00 to 5.30pm Reporting and day wrap up LSK, SP, PK DAY 3: Wednesday

(02/12/2015)

7:00 to 12:00noon 1, 2, 4, 5, 6 Smallholders at Noatsi Area SP, PK

7:00 to 12:00noon 1, 6 Stakeholders Meeting in Kavieng RC, LSK

12:00 to 1:00pm Lunch

Documentation NPP, SEIA, HCV, PalmGHG, 1:30 to 5:00pm 1, 2. 5, 7 RC, LSK Agronomist, Field Operation Department,

1:00 to 3:00pm 1, 6 Stakeholders Meeting at Noatsi Area SP, PK

3:30 to 5:00pm 1, 4, 5, 6 HR, Training, Smallholders Internal Audit SP, PK

RC, LSK, 5:00 to 5:30pm Reporting and day wrap up SP, PK DAY 4: Thursday

(03/12/2015) Madak Estate – Field Operations, site 1, 2, 4, 5, 6, 7, 7:00 – 12:00noon documentation, chemical shed, workshop, RC, LSK 8 clinic, landfill, accommodation.

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7:00 to 12:00noon 1, 2, 4, 5, 6 Smallholders South Madak Area SP, PK

12:00 to1:00pm Lunch

1:00 to 3:00pm 1, 6 Stakeholders meeting at Madak Area SP, PK

1:00 to 3.00pm 7 Newly planted area RC

Environment, OSHA, Environment / Operation 1:00 to 5:00pm 1, 2, 4, 5, Permits, Legal Register, Waste / Water LSK Management Plans

3:00 to 5:00pm 6, 8 SIA, Continuous Improvement Plan SP, PK

3:30 to 5:00pm 4, 5 Medical Records, HR, Grievance Complaint RC

RC, SP, 5:00 to 5:30pm Reporting and day wrap up LSK, PK DAY 5: Friday

(04/12/2015) Final review of sustainability and operation RC. SP, 7:30 to 11:00am 1 to 8 documents LSK, PK

RC. SP, 11:00 to 12:00noon Auditors time LSK, PK RC. SP, 12:00 to 1:00pm Lunch LSK, PK RC, SP, 1:00 to 2:00pm Discussion with Sustainability Team and GM LSK, PK RC, SP, 2:00 to 3:00pm Reporting & Closing Meeting LSK, PK RC, SP, 3:00pm End of onsite LSK, PK

2.4 Stakeholder consultation

2.4.1 Summary The stakeholder meeting notifications were sent on 15/10/2015 giving notice of the meeting that will be held at various locations due to the stakeholders are located at different areas due the distance from one location to another is approximately 70 to 150km.

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The stakeholders consultations were held at following areas: 1. Nalik Estate, Lakurumau Training Center on 30/11/2015 Topic of Discussion: a) Support from Poliamba Limited to the local communities; b) Housing for workers; c) Shops and banking facility organised by POL; d) Smallholders issues; e) Smell and flies from mulching of EFB; 2. West Cost Estate on 01/12/2015 Topic of Discussion: a) Main obstacles faced by workers; 3. Kavieng town at stakeholders offices on 02/12/2015 Topic of Discussion: a) Wildlife Conservation Society: - Support from POL on their activities; - Any wildlife management area at POL location; b) Boi Village Chief: - POL support to the local communities; - Smallholders issues; c) Provincial Land and Physical Planning - Type of land POL has leased; - New development by POL; 4. Noatsi Estate on 02/12/2015 Topic of Discussion: a) Main obstacles faced by workers b) Madek estate on 03/12/2015 Topic of Discussion: a) Main obstacles faced by workers The invitation letters were sent to organisations and workers representatives and those present at the meeting as table below.

2.4.2 List of contacted stakeholders Public consultation meeting was held at respective locations near to the stakeholders. Below is the list of stakeholders who were attending the meeting at the various locations. (refer

Table 2-2 List of stakeholders s)

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Table 2-2 List of stakeholders Nalik Estate, Lakurumau Training Center on 30/11/2015

No Name of organisation Name of Person

1. Woman in Oil Palm Christine Vanes

2. Fissoa Village Smallholder Farmer Gerald Gee

3. Panamana Village Smallholder Farmer Gerson Rabana

4. Panamana Village Smallholder farmer Jane Nodai

5. Nalik Estate Representative Peter Pombi

6. OPIC Field Manager, Panamana Village Robroy Unini

7. Women in Oil Palm Rose Elias

8. Ward 10 Tikana, Munawai Village Wesley Kate

9. Nalik TSD Sprayer Abel Karapo

West Coast Estate on 01/12/2015

No Name of organisation Name of Person

1. West Coast Estate – Agrochemical Sprayer Gipson Yanlik

2. West Coast Estate – Site Safety Officer Jeffrey Carol

Kavieng Town on 02/12/2015

No Name of organisation Name of Person

1. Provincial Land & Physical Planning Christine Gurumang

2. Wildlife Conservation Society, New Ireland Province Annisah Sapul

3. Boi Village Chief Demas M Kavavu

Noatsi Estate on 02/12/2015

No Name of organisation Name of Person

1. Walters Farmers Association Philip Langu

2. Noatsi Estate- Agrochemical Sprayer Jerry Pinu,

3. Noaotsi Estate – Site Safety Officer Dicksie Meaka

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Madak Estate on 03/12/2015

No Name of organisation Name of Person

1. Madak Estate – Site Safety Officer / Village Warden Joel Guiness

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3 Partial certification

3.1 General Organizations that have a majority holding* in and / or management control of more than one autonomous company growing oil palm will be permitted to certify individual management units and/or subsidiary companies only if all the following are complied with the requirements mentioned below. *Majority shareholding: the largest shareholding. Where the largest shareholdings are equal (e.g. 50/50) this applies to the organisation that has management control

Requirement Finding/ Compliance

The parent organization or one of its majority owned All 6 operational sites of NBPOL are already RSPO and / or managed subsidiaries is member of RSPO. P&C certified (see 1.7 Time Bound plan). Therefore, this section is not applicable.

For groups with complex management structures the N/A following are required: (a) A statement of the ultimate controlling shareholders and directors in the managing agency company/companies. (b) Ditto in respect of each of the operating groups. (c) Application for membership by the top asset owning company/companies. (d) Application for membership by the managing agency company/companies

If one of the above mentioned requirements is non-compliant, this leads to a major non-conformity. The following requirements about a time bound plan (3.2) and requirements for uncertified management units and/ or holdings (3.3) are applicable if the registered RSPO member is the holding company or one of its subsidiaries and if one or more of these units are currently not yet RSPO P&C certified.

3.2 Requirements for time-bound plan

Requirement Finding/ Compliance

A challenging time-bound plan for certifying all its As all 6 operational sites of NBPOL are already RSPO relevant entities (Relevant entities – including both the business P&C certified (see 1.7 Time Bound plan). Therefore, units and parent company(ies) commitment to RSPO, membership this section is not applicable. status and involvement with palm oil for each subsidiary) is available. The time-bound plan should contain a list of subsidiaries, estates and mills.

The time bound plan is appropriate (in particular, the time N/A scale is sufficiently challenging, taking into account circumstances around each entity), taking into account comments received from stakeholders following the public consultation process.

What is the progress of this plan since the last audit? N/A

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(if the last audit was done by another CB, the time- bound plan shall be accepted at the moment of first acceptance and only check continued appropriateness shall be checked).

Are there any revision to the time-bound plan or to the N/A circumstances of the company e.g. due to acquisitions/disposals, emergence/re-emergence of land disputes and/or labour conflicts?

If the previous question was answered with yes, the N/A plan shall be reviewed for whether it is still appropriate, such that changes to the time-bound plan are permitted only where the organisation can demonstrate that they are justified. The requirements will also apply to any newly acquired subsidiary from the moment that the company is legally registered with the local notary or chamber of commerce (or equivalent).

When there are isolated lapses in implementation of the time-bound plan, a minor non-compliance is raised. When there is evidence of a systematic failure to proceed with implementation of the plan, a major non-compliance is raised.

3.3 Requirements for uncertified management units and/or holdings

Requirement Finding/ Compliance

No replacement of primary forest or any area identified There are no uncertified management units in the as containing High Conservation Values (HCVs) or NBPOL group. All these requirements are covered by required to maintain or enhance HCVs in accordance the respective RSPO P&C certificates. with RSPO criterion 7.3. Any new plantings since January 1st 2010 must comply with the RSPO New Plantings Procedure.

Land conflicts, if any, are being resolved through a N/A mutually agreed process, e.g. RSPO Grievance procedure or Dispute Settlement Facility, in accordance with RSPO criteria 6.4, 7.5. and 7.6.

Labour disputes, if any, are being resolved through a N/A mutually agreed process, in accordance with RSPO criterion 6.3.

Legal non-compliance, if any, are they being resolved N/A in accordance with the legal requirements, with reference to RSPO criteria 2.1 and 2.2.

Assessment of above mentioned requirements is based on the following approach: Positive assurance statement, which is based upon self-assessment (i.e. internal audit) by the organisation. This would require evidence of the self-assessment against each requirement. Targeted stakeholder consultation may be carried out by the certification body. If this has already been conducted by a certification body, other certification bodies may request the summary report through the organisation. If necessary, the certification body may decide on further stakeholder consultation or field inspection, assessing the risk of any non- compliance with the requirements.

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For the requirements mentioned in the section, the approach to defining major and minor non-compliance can be applied from the relevant national interpretation. For example, if a non-compliance against a ‘major indicator’ in a non-certified holding/management unit is identified, the current certification assessment cannot proceed to a successful conclusion until that is addressed. Failure to address any of the requirements may lead to certification suspension(s) (consistent with the RSPO Certification Systems document rules on non-compliance).

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4 Assessment findings

4.1 Findings by RSPO Principle and sample of the Criteria The assessment team conducted a thorough assessment of each principle and some example criteria. Over the 5 years’ period of the certificate cycle, there will be 4 annual surveillance audits in which different criteria will be assessed. Evidences were sought for conformity with the RSPO NI of both systems and their implementation. The summary of the assessment can be seen below, where the “Findings/Comments” column reflects the findings in accordance with each criteria and indicator or evidences that were, and when non conformity was found, a summary of the non-conformity can be found in 4.2.2.

NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Principle 1: Commitment To Transparency a. Does the company maintain a list of 1.1 Growers and millers provide 1.1.1 There shall be evidence that X POL has a stakeholder register adequate information to relevant growers and millers provide stakeholders? (E.g. listed by established for year 2015 with the stakeholders on environmental, adequate information on category and stakeholders listed stakeholders listed by categories. social and legal issues relevant to (environmental, social and/or legal) should be site specific) RSPO Criteria, in appropriate issues relevant to RSPO Criteria to The stakeholders list established is languages and forms to allow for relevant stakeholders for effective listed by category. effective participation in decision participation in decision making. Example: Local authorities, local making. Specific Guidance: NGO, suppliers, communities, workers, etc For 1.1.1: Evidence should be provided b. What is the frequency of updating X The stakeholder register is updated on that information is received in appropriate the stakeholder list? form(s) and language(s) by relevant an annual basis. stakeholders. Information will include Last update was 30/08/2015 information on the RSPO mechanisms c. Is there evidence of stakeholder X There are records of stakeholder for stakeholder involvement, including verification? information on their rights and communication available at respective responsibilities. sites. Most recent meeting conducted 12/11/2015 with smallholders d. What type of information is X The information provided is per the list provided? (E.g. Environmental, of publicly available documents social and legal) Information is provided to both internal and external stakeholders and includes social, environmental and economic issues.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min e. What is the frequency and level of X Publicly available documents for access to this information? viewing and upon request are available all year round and displayed at notice boards at respective operating sites. f. How and where is the information X Information is grouped into two disseminated? categories. Documents available for viewing are displayed at all notice boards whilst documents available upon request are maintained at the Sustainability Department. and can only be accessed upon approval by top management g. Who is responsible for providing & X Information is updated by respective updating information? departments and approved by the GM. h. Is there an SOP available to X POL has established SOP 002 describe the process (of information Request for Information, revision 004 sharing/dissemination)? dated 12/11/2015 to handle reception and dissemination of information. i. Are stakeholders aware of the type X Stakeholders are made aware of of information available and the these information and procedures procedures for accessing the through awareness, meetings and information? notices. List of publicly available documents are displayed on notice boards. a. Does the company have an SOP to 1.1.2 (M) Records of requests for X Request for Information SOP 002 information and responses shall be ensure constructive response to revision 004 dated 12/11/2015 to maintained. stakeholders? handle reception and dissemination of information. Guidance: b. Who is the personnel in charge X The GM is the overall person in Growers and millers should have a (PIC)? charge to approve dissemination of Standard Operating Procedure (SOP) to information as defined by the respond constructively to stakeholders, communications procedures.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min including a specific timeframe to respond c. Does the SOP cover the elements X SOP includes elements under 1.1.1 to requests for information. Growers and under 1.1.1? millers should respond constructively and promptly to requests for information from d. Is there a clear time frame for stakeholders. X In the SOP, time frame is stated. response to request for information? Growers and millers should ensure that Example: Within 5 days for request of sufficient objective evidence exists to information. demonstrate that the response is timely e. Are records of requests for and appropriate. X Internal and External Request information and responses Register. See Criterion 1.2 for requirements maintained? relating to publicly available Internal request are addressed by documentation. respective HODs and where it requires GM’s approval then it is sent See Criterion 6.2 on consultation. to GM. All external request sent to GM See Criterion 4.1 on SOPs. for approval and records maintained in GMs Office in the Stakeholder Communication Register. See scanned copy 1. Stakeholder Request Book. So far there are no external requests for company’s documentation during the current year. f. Are responses to requests for X So far there are no external requests information timely and appropriate? for company’s documentation during the current year. a. How are the management 1.2 Management documents are publicly 1.2.1 (M) Publicly available documents X POL list of publicly available available, except where this is shall include, but are not documents listed in (c) below made documents is a public document itself

prevented by commercial necessarily limited to: publicly available? which lists the documents for public confidentiality or where disclosure of  Land titles/user rights (Criterion viewing that are also displayed information would result in negative 2.2); publicly and documents available environmental or social outcomes.  Occupational health and safety upon request which are provided upon approval by the GM plans (Criterion 4.7); b. Where are the documents placed?  Plans and impact assessments X Public documents for viewing are relating to environmental and displayed at notice boards at all POL operating sites whilst documents for social impacts (Criteria 5.1, request are available at Sustainability Int rspo pc cld clr sum e - v01 – 23/9/2015 p. 29/ 181 NBPOL – POL 30/11/2015 to 04/12/2015

NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min 6.1, 7.1 and 7.8); or respective departments and are  HCV documentation (Criteria released upon approval by GM. 5.2 and 7.3); c. Is the information provided  Pollution prevention and The information provided is adequate reduction plans (Criterion 5.6); adequate? Note: At minimum, an information summary of the  Details of complaints and document listed below should be grievances (Criterion 6.3); made available.  Negotiation procedures  Land titles/user rights (Criterion (Criterion 6.4); X Available upon request through the 2.2)  Continual improvement plans POL Sustainability Department upon (Criterion 8.1); approval by the GM  Public summary of certification -Legal boundaries ,land use, X Available upon request through the assessment report; classification, total area, grant POL Sustainability Department upon  Human Rights Policy (Criterion title, permit validity , NCR rights, approval by the GM  Occupational health and safety 6.13). X Available upon request through the plans (Criterion 4.7); POL Sustainability Department upon Guidance: approval by the GM This concerns management documents -risk assessment and mitigation X Available upon request through the relating to environmental, social and ,emergency response plan, POL Sustainability Department upon legal issues that are relevant to training, accident records approval by the GM compliance with RSPO Criteria.  Plans and impact assessments Management documents will include X Available upon request through the relating to environmental and POL Sustainability Department upon monitoring reports. social impacts (Criteria 5.1, 6.1, approval by the GM The auditors will comment on the 7.1 and 7.8); adequacy of each of the documents listed in the public summary of the -main social and environmental X Available upon request through the assessment report. impacts and mitigation measures POL Sustainability Department upon approval by the GM Examples of commercially confidential  HCV documentation (Criteria 5.2 X Available upon request through the information include financial data such as and 7.3); costs and income, and details relating to POL Sustainability Department upon customers and/or suppliers. Data that approval by the GM affects personal privacy should also be -identification on HCV areas, maps, X Available upon request through the confidential. management and monitoring HCV POL Sustainability Department upon approval by the GM

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Pollution prevention and reduction Ongoing disputes (within or outside of a X Available upon request through the legal mechanism) can be considered as plans (Criterion 5.6); POL Sustainability Department upon confidential information where disclosure approval by the GM could result in potential negative outcomes for all parties involved. -identification of pollutants, X Included in the program through the However, affected stakeholders and management and reduction continuous improvement plan those seeking resolution to conflict measures established version 04 last reviewed should have access to relevant on 06/11/2015 information. Available upon request through the Examples of information where POL Sustainability Department upon disclosure could result in potential approval by the GM  Details of complaints and negative environmental or social X Complaint and grievances record outcomes include information on sites of grievances (Criterion 6.3); books are established at all operating rare species where disclosure could sties. increase the risk of hunting or capture for trade, or sacred sites which a community Available upon request through the wishes to maintain as private. POL Sustainability Department upon approval by the GM Growers and millers should ensure that sufficient objective evidence exists to -nature of complaints, parties X Details in the record books include demonstrate that the level of measuring involved, status of case nature of complaints, parties involved and monitoring of the management plan, and status of case. and information, is appropriate and made Available upon request through the available. POL Sustainability Department upon approval by the GM  Negotiation procedures (Criterion X POL has established Conflict 6.4); Resolution Procedure LAN003 address issues arising over landownership between company and locals; FPIC Procedure LAN004 and MG 21 Mini Estates Guidelines for any land dealings between the Company and Land owners. Available upon request through the POL Sustainability Department upon

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min approval by the GM

- SOP, consultative, neutral, Pol has established Communication inclusiveness, timeframe, X and Consultative Procedure SUS009 responsibility that encourage free and effective communication between the company and the stakeholders. Available upon request through the POL Sustainability Department upon approval by the GM Continual improvement plans (Criterion X POL has established continuous 8.1) improvement plan and reviewed annually by the respective HODs of all the operating sites. Last review was on 06/11/2015 Available upon request through the POL Sustainability Department upon approval by the GM - for all elements under 8.1, X Included in the plan

 Public summary of certification X Available upon request through the assessment report; HOP Sustainability Department.

- follow RSPO format X Adopt RSPO format

 Human Rights Policy (Criterion X Human Right Policy was last reviewed 6.13). on June 2011.

- policy statement should comply to X In compliance to requirements of 6.13 the requirements of 6.13

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min d. Do the management documents X Relevant documents contain contain monitoring plans and monitoring plans and reports reports? Example: OSH Plan; IPM Available upon request through the POL Sustainability Department upon approval by the GM e. Are all monitoring reports publicly X Available upon request through the available? POL Sustainability Department. Upon approval by the GM a. Is there a written policy committing 1.31 Growers and millers commit to 1.3.1 There shall be a written policy X POL maintains the NBPOL Business ethical conduct in all business committing to a code of ethical to a code of ethical conduct and Ethics Policy last revised in June 2011

operations and transactions. conduct and integrity in all integrity in all operations and operations and transactions, which transactions? Whistleblower policy which prohibits shall be documented and all forms of improper conduct and communicated to all levels of the proper methods for information workforce and operations. disclosure. b. Does the policy include as a

Guidance: minimum:

All levels of the operations will include  A respect for fair conduct of contracted third parties (e.g. those X Included in policy business? involved in security).  A prohibition of all forms of The policy should include as a minimum: X Included in policy  A respect for fair conduct of corruption, bribery and business; fraudulent use of funds and  A prohibition of all forms of resources?

1 New Criteria - Growers and millers commit to ethical conduct in all business operations and transactions.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min corruption, bribery and  A proper disclosure of X Included in policy fraudulent use of funds and information in accordance with resources; applicable regulations and  A proper disclosure of accepted industry practices? information in accordance with c. Is the policy documented and applicable regulations and X POL Business Ethics Policy & communicated to all levels of the accepted industry practices. Whistleblower Policies are workforce and operations, including documented. The policy should be set within the contracted third parties? How is it The policies are communicated framework of the UN Convention Against communicated? Corruption, in particular Article 12. through training / awareness, musters, notice boards, meetings and toolbox talk. Records of policy communication are available at all sites. d. Are the documentation and X Policies communicated to the communication done in the workforce & community are done appropriate languages? using English and local Pidgin languages Note to auditor: The workforce should Onsite interviews are conducted in be interviewed to determine level of both English and Tok Pisin for both understanding of policy workers and smallholders.

Principle 2: Compliance With Applicable Laws and Regulations a. Is the complete list of legal 2.1 There is compliance with all 2.1.1 (M) Evidence of compliance with X POL has in place a license & permits applicable local, national and ratified relevant legal requirements shall be requirements available? (Refer to register which captures all applicable international laws and regulations. available. relevant NIs or LIs for list of legal local and national legal requirements. requirements) Guidance: List of laws and acts applicable to oil palm industry in PNG and other Implementing all legal requirements is an requirements are available at essential baseline requirement for all Sustainability Department. growers whatever their location or size. Relevant legislation includes, but is not Example: limited to: regulations governing land tenure and land-use rights, labour, Environmental permit no. EP-L2B (155) dated 26/07/1991, expiry

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min agricultural practices (e.g. chemical use), 31/12/2053 for water extraction, environment (e.g. wildlife laws, pollution, wastewater discharge and water environmental management and forestry quality. laws), storage, transportation and processing practices. It also includes laws made pursuant to a country’s obligations under international laws or b. Does the company have copies of X POL has available copies of all conventions (e.g. the Convention on the legal requirements? Biological Diversity (CBD), ILO core applicable national and international Conventions, UN Guiding Principles on legal and other requirements. Business and Human Rights). Copies of all applicable licenses & Furthermore, where countries have permits are renewed annually. provisions to respect customary law, these will be taken into account. All related operating permits are available on records and at work sites. Key international laws and conventions are set out in Annex 1 Note to auditor: A due diligence on the company/area or management unit on Contradictions and inconsistencies legal compliance should be conducted should be identified and solutions prior to field audit. Any non-compliance suggested. should be verified during the field audit. Relevant legislation includes, but is not limited to: regulations governing land tenure and land-use rights, labour, agricultural practices (e.g. chemical use), environment (e.g. wildlife laws, pollution, environmental management and forestry laws), storage, transportation and processing practices. It also includes laws made pursuant to a country’s obligations under international laws or conventions (e.g. the Convention on Biological Diversity (CBD), ILO core Conventions and UN Guiding Principles on Business and Human Rights.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Is there a document system which 2.1.2 A documented system, which X POL has established a document for includes written information on legal includes the following? Identification, Access and Evaluation requirements, shall be maintained. to Legal & Other Requirements. b. Personnel in charge to manage X The Sustainability Manager as the responsible person for all legal requirements. c. Set of legal documents X The document contains a list of all applicable national and international legal requirements. d. Comprehensive list of international, X List of all applicable national and national, sub-national and provincial international laws are listed in the POL laws which details the requirements legal compliance document named of specific to the mill and estate above. operations. e. Relevant sections within the law X POL has developed sets of legal that is identified and linked to compliance checklists to link to activities applicable activities pertaining to the operations. f. Are the documents available to all X POL Sustainability Department is levels of management? responsible for all legal aspects of the POL operations and relevant legal documents are kept at the Sustainability Department as well as other departments. All legal documents are available to all levels of management upon request. a. Is an internal audit for legal 2.1.3 A mechanism for ensuring X POL Sustainability Department compliance shall be implemented. compliance conducted annually and conducts quarterly RSPO internal documented? audits which include the scope of legal compliance. POL is also inspected annually by relevant regulatory bodies. Internal audit conducted quarterly by

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min sustainability department, latest on 29/10/2015. Operation sites covered are mill, estates, clinics, workshop and human resources. Sustainability internal audit report maintained. a. Is there a documented methodology 2.1.4 A system for tracking any changes X POL defines the method, PIC, source in the law shall be implemented. (e.g.: personnel in charge (PIC), of information, frequency of update source of info, frequency of update) and responsible persons. Specific Guidance: for tracking changes and For 2.1.4: The systems used for tracking communication of changes to any changes in laws and regulations relevant sections of the legislation? should be appropriate to the scale of the organisation. a. Are there documents showing legal 2.2 The right to use the land is 2.2.1 (M) Documents showing legal X Available with POL Lands Office demonstrated, and is not legitimately ownership or lease, history of land ownership or lease of the land contested by local people who can tenure and the actual legal use of available? (e.g. land titles, lease State leased title issued by government and sub-lease agreement demonstrate that they have legal, the land shall be available. documents) customary or user rights. with individual owners b. Are there documents showing X Available with POL Lands Office history of land tenure available? (e.g. legal documents showing land State leased title issued by status change, SIA and EIA reports, government and sub-lease agreement with individual owners HCV assessment reports) c. Are there documents showing the X Available with POL Lands Office actual legal use of the land available?

d. Are the documents complete? X Complete documents available with POL Lands Office a. Is there a legal map showing 2.2.2 Legal boundaries shall be clearly X Maps include boundary markers. demarcated and visibly location of boundary markers?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min maintained. b. Is there physical presence of X Sighted during onsite inspection for Specific Guidance: boundary markers? both smallholders and internal leased estates. For 2.2.2: Plantation operations should cease on land planted beyond the legally c. Is there an SOP for boundary X Boundary demarcation and determined area and there should be demarcation and maintenance? specific plans in place to address such maintenance SOP No. LAN001 issues for associated smallholders. Note to auditor: Ground verification of revision 001 last reviewed on boundary markers using GPS should be 12/11/2015 for the purpose to ensure conducted. Priority should be on land boundaries are clearly boundaries with other estates, demarcated with boundary markers, community areas, protected area and well maintained and visible at all times rivers In the case of Associated Smallholders: X In each smallholders approval form a. Are there documents showing that (SAF), block name, block size, the boundaries of associated location (village) with GPS reading are smallholders have been recorded recorded and verified by the mill?

In the case of Associated Smallholders: X In the SAF, any disputes will be b. In case of boundary breach, is resolved by the tribe or clan through there proof of a mitigation plan the tradition tribal land dispute being implemented? resolution plan (2008) for settlement.

a. Are there, or have there been any 2.2.3 Where there are or have been X There is a land dispute at Lakuruamau disputes, additional proof of legal land disputes? Portion 18. The lands officer was acquisition of title and evidence Note to auditor: Due diligence should be interviewed and documents were that fair compensation has been conducted on the management to checked. made to previous owners and provide evidence that there has been no Reference: Lakurumau Dispute occupants shall be available, and historical or current land dispute that these have been accepted Portion 18 Documents reviewed. with free, prior and informed . consent (FPIC). b. If there are or have been disputes,

are there:

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min - Documents to proof legal X Available at POL lands office acquisition?

- Records of FPIC process? X POL has established FPIC SOP No. LAN004 revision 001 last reviewed date 12/11/2015. Example: Confirmation as land ownership c. If there has been acquisition

involving compensation, are there:

- Records that Fair X Available at POL lands office compensation has been provided and accepted by Signed sub-leased agreement parties involved? - Records that all affected X Available at POL lands office parties are consulted and represented? Confirmation letter from land owner and invitation to conduct survey. - Documents of X Available at POL lands office negotiations/discussion available? Sighted confirmation letter for land ownership and invitation for Note to auditor: There should be direct preliminary survey of land. verification of above with the affected parties a. Does the company have cases of 2.2.4 (M) There shall be an absence of X There is a land dispute at Lakuruamau significant land conflict, unless significant land conflict? (i.e. Portion 18. The lands officer was requirements for acceptable preventing the company from interviewed and documents were conflict resolution processes (see operating normally) checked. Criteria 6.3 and 6.4) are implemented and accepted by the Reference: Lakurumau Dispute parties involved. Portion 18 Documents reviewed. .

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. If the company has cases of Guidance conflict, are records of the following Where there is a conflict on the condition available? of land use as per land title, growers - Status of conflict should show evidence that necessary X Awaiting written approval from the action has been taken to resolve the Government Surveyor to confirm that conflict with relevant parties. the disputed area is within the company leased area and advising A mechanism should be in place to the disputing party of the resolution at resolve any conflict (Criteria 6.3 and the time of onsite audit. 6.4). - SOP/ mechanism for conflict X POL has established Conflict Where operations overlap with other resolution Resolution SOP No. LAN003 revision rights holders, companies should resolve 001 last reviewed on 12/11/2015 the issue with the appropriate - Implementation of authorities, consistent with Criteria 6.3 X SOPs are communicated to internal and 6.4. SOP/mechanism and external stakeholders and can be verified through training and signed sub-leased agreement. - Acceptance of the procedures X SOPs are communicated to internal by all parties and external stakeholders and can be verified by physical observations of employees following the procedures. - Records of conflict resolution X Avaialble at land officer office.. a. Is there an SOP for participatory 2.2.5 For any conflict or dispute over the X POL has established SOP No. land, the extent of the disputed mapping of disputed area? LAN005 revision 001 last reviewed on area shall be mapped out in a 12/11/2015 for participatory mapping participatory way with involvement of disputed area. of affected parties (including b. Is a dispute map available? neighbouring communities where X POL will have maps made available if applicable). there is any land dispute.

c. Is there documented evidence of X POL has established SOP No. involvement and acceptance by the LAN005 revision 001 last reviewed on affected parties? 12/11/2015 for participatory mapping of disputed area. Note to auditor: Actual ground

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min verification showing the accuracy of the dispute map should be conducted POL has one disputed area (Lakuruamau Portion 18) about 0.03ha garden encroachment by a local. Site verification by Government Surveyor with the Company and Disputing Parties confirmed that the area is inside the Company leased area. The area is not planted and awaiting written approval from the Government Surveyor to confirm that the disputed area is within the company leased area and advising the disputing party of the resolution. Reference: Lakurumau Dispute Portion 18 Documents provided a. Does the company have a policy to 2.2.6 (M) To avoid escalation of conflict, X POL does not instigate violence. there shall be no evidence that circumvent instigated violence to palm oil operations have instigated maintain peace and order in current POL has established Policy Statement violence in maintaining peace and and planned operations? Against Instigating Violence that order in their current and planned discourages violence and promotes operations. peace and order in current operation. b. Is there any evidence of: Specific Guidance: - The use of confrontation and For 2.2.6: Company policy should X No evidence observed and interview prohibit the use of mercenaries and para- intimidation by the company to of smallholders and stakeholders militaries in their operations. Company maintain peace and order? during consultation. policy should prohibit extra-judicial intimidation and harassment by - Use of para-militaries and X No evidence observed and interview contracted security forces (see Criterion mercenaries in the plantation? 6.13). of smallholders and stakeholders during consultation.

a. Does the company have an SOP on 2.3 Use of the land for oil palm does not 2.3.1 (M) Maps of an appropriate scale X POL has established FPIC SOP No. diminish the legal, customary or user showing the extent of recognised FPIC? LAN004 revision 001 last reviewed

rights of other users without their legal, customary or user rights date 12/11/2015.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min free, prior and informed consent. (Criteria 2.2, 7.5 and 7.6) shall be b. Is there evidence that the X Available at POL Lands Office developed through participatory identification of legal, customary or mapping involving affected parties user rights has been done through (including neighbouring FPIC process? communities where applicable, and relevant authorities). c. Is there evidence that the FPIC Guidance: X FPIC meetings and consultations process has been implemented in conducted with all interested All indicators will apply to current accordance to the company SOP? communities / land owned by operations, but there are exceptions for Where is this evidence recorded? individuals prior to them agreeing to long-established plantations which may (E.g.: Documents, Minutes of give-up land for new development. not have records dating back to the time of the decision making, in particular for meeting, Records, Agreements, Records of FPIC meetings and compliance with Indicators 2.3.1 and Maps etc.) consultations held on file at POL land 2.3.2. office. d. Is there a map of the extent of legal, Where there are legal or customary X Maps are available at Land Office with rights over land, the grower should customary or user rights? Is this scale of at least 1: 20,000 demonstrate that these rights are map of appropriate scale (1: understood and are not being threatened 10,000)? or reduced. This Criterion should be e. Was the map produced through considered in conjunction with Criteria X Maps produced through participation 6.4, 7.5 and 7.6. Where customary rights participatory mapping with of all parties areas are unclear these should be reference to SIA and HCV established through participatory assessment? mapping exercises involving affected f. Does the map have a title, legend, parties (including neighbouring X Map includes title, legend, scale and source, scale and projections/geo communities and local authorities). projections. reference? This Criterion allows for sales and g. Are the maps accepted by the negotiated agreements to compensate X Yes by all parties. other users for lost benefits and/or relevant communities? relinquished rights. Negotiated agreements should be non-coercive and entered into voluntarily, carried out prior to new investments or operations, and based on an open sharing of all relevant information. The representation of communities should be transparent and in open communication with other

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min community members. Adequate time should be given for customary decision making and iterative negotiations allowed for, where requested. Negotiated agreements should be binding on all parties and enforceable in the courts. Establishing certainty in land negotiations is of long-term benefit for all parties. Companies should be especially careful where they are offered lands acquired from the State by its invoking the national interest (also known as ‘eminent domain’). Growers and millers should refer to the RSPO approved FPIC guidance (‘FPIC and the RSPO: A Guide for Companies’, October 2008) a. Are copies of negotiated 2.3.2 Copies of negotiated agreements X Available at POL Lands Office detailing the process of free, prior agreements with affected parties

and informed consent (FPIC) available? Example Agreement between POL (Criteria 2.2, 7.5 and 7.6) shall be and Catholic Mission Kavieng available and shall include: Property Trust b. Is there evidence that the a) Evidence that a plan has been X Proper FPIC process is conducted for agreement is prepared through sub-leased land. developed through consultation proper FPIC process? and discussion with all affected Example Agreement between POL groups in the communities, and and Catholic Mission Kavieng that information has been provided Property Trust to all affected groups, including c. Does the agreement contain the

information on the steps that shall following: be taken to involve them in decision making;

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min - An action plan developed b) Evidence that the company has X Included in FPIC process and respected communities’ decisions through consultation with available at POL land Office to give or withhold their consent to affected parties, is inclusive and the operation at the time that this evidence that members of decision was taken; affected parties are well c) Evidence that the legal, informed and involved in the economic, environmental and decision making process social implications for permitting - Evidence of options to give or X Sighted and available at POL land operations on their land have been withhold consent for office. understood and accepted by development affected communities, including the - Evidence that members of the implications for the legal status of X Agreement sighted and available at their land at the expiry of the affected communities POL land office. company’s title, concession or understand and accept the lease on the land. implication involved in permitting/rejecting oil palm development on their land (E.g.: legal status, social, environmental, economic) - Evidence that the negotiated X Sighted agreement available at POL agreement was entered land office. voluntarily without coercion by all parties

- Evidence that adequate time X Available at POL land office through was given for customary FPIC process. decision making and iterative negotiations

- Clause which states that the X Available at POL land office through negotiated agreement is legally FPIC process. binding Example Agreement between POL and Catholic Mission Kavieng Property Trust

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Is there evidence that all the 2.3.3 All relevant information shall be X Available at POL land office. available in appropriate forms and information (maps, agreement, languages, including assessments records, impact assessment, benefit Example Agreement between POL of impacts, proposed benefit sharing and legal arrangements) is and Catholic Mission Kavieng Property Trust sharing, and legal arrangements. available in appropriate forms and languages, understood and accessible to affected parties? Note to auditor: this should be cross checked to a sample of the affected parties a. Who is the representative of the 2.3.4 (M) Evidence shall be available to X Land owner community in the negotiation show that communities are represented through institutions or process? representatives of their own b. Is the representative accepted by X The head of the Catholic Mission choosing, including legal counsel. the community? Kavieng Property Trust is the Specific Guidance: appointed representative c. Is the record of appointment to For 2.3.4: Evidence should be available X Available at POL land office. from the companies, communities or represent the community available other relevant stakeholders. and shared with other parties?

Principle 3: Commitment to Long-term Economic and Financial Viability a. Does the company have a 3.1 There is an implemented 3.1.1 (M) A business or management X POL has established a 5years management plan that aims to plan (minimum three years) shall documented business or business plan from 2015 to 2020

achieve long-term economic and be documented that includes, management plan with a minimum financial viability. where appropriate, a business planning period of 3 years? case for scheme smallholders. b. Does it include the following:

Specific Guidance: - Land area statement (planting  For 3.1.1: The business or X Refer POL field acreage statement, years, non-planted areas, i.e. management plan should contain: estates maps, smallholders blocks HCV, conservation areas,  Attention to quality of planting maps fragile soils, enclaves) with materials; updated location maps. Maps  Crop projection = Fresh Fruit should have title, legend, Bunches (FFB) yield trends; source, scale and

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Mill extraction rates = Oil projections/geo referenced Extraction Rate (OER) trends;  Cost of Production = cost per tonne of Crude Palm Oil (CPO) - Plan for management of trends; X Included in 5 years business plan  Forecast prices; scheme smallholders (where appropriate)  Financial indicators. - Quality of planting materials  Suggested calculation: trends in X Included in 5 years business plan 3-year running mean over the last decade (FFB trends may - Crop projection = Fresh Fruit X Included in 5 years business plan. need to allow for low yield Bunches (FFB) yield trends during major replanting (Confidential information not programmes). disclosed) - Mill extraction rates = Oil X Included in 5 years business plan. Extraction Rate (OER) trends (Confidential information not Guidance: disclosed)  Whilst it is recognised that long- - Cost of Production = cost per term profitability is also affected by X Included in 5 years business plan. tonne of Crude Palm Oil factors outside their direct control, (CPO) trends (Confidential information not top management should be able to disclosed) demonstrate attention to economic - Forecast prices X Included in 5 years business plan. and financial viability through long-

term management planning. There (Confidential information not should be longer term planning for disclosed) - Financial indicators – plantations on peat, particularly in X Included in 5 years business plan. regards to subsidence and flooding profitability forecast issues (see Indicator 4.3.5). (income vs cost) (Confidential information not disclosed)  Consideration of smallholders should be inherent in all - Projected expansion management planning where X Included in 5 years business plan for (area, mill capacity, any expansion. applicable (see also Criteria 6.10 infrastructure, social and 6.11). For scheme amenities) (Confidential information not disclosed)

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min smallholders the content will vary - General strategy and X Included in 5 years business plan for from that suggested (refer to allocation for any allocation. RSPO Guidance on Scheme environmental and social Smallholders, July 2009). management (refer to P5, (Confidential information not disclosed)  Growers should have a system to P6 and P8) improve practices in line with new c. Is this management document X Continuous review on monthly basis information and techniques. For subjected to an annual review? and annually during budget period. smallholder schemes, the scheme d. For plantations on peat, is there a management should be expected X No peat land sighted in POL through to provide their members with long term viability plan – e.g. document and map review. information on significant flooding, drainability assessments improvements. and subsidence issues? (see 4.3.5) e. Does the grower have a system to This Criterion is not applicable to X POL has adopted the Management improve practices in line with new Guidelines MG01A New Development independent smallholders (refer to information and techniques? RSPO Guidance for Independent Practices Issue 5 dated July 2014 for Smallholders under Group new information and techniques - Has the personnel in charge Certification, June 2010) X POL General Manager is the PIC (PIC) been identified?

- How is the information updated? X As and when new techniques required or information available. - Is there a documented SOP X Included in the Management which requires monitoring and Guidelines MG01A New Development updating information to improve Practices Issue 5 dated July 2014 practices? - Is new information x Morning muster call briefing for communicated to workers and workers in estate, toolbox for mill scheme smallholders (where workers and fieldtrips for smallholders. appropriate)? How is it communicated? a. Is there an annual replanting 3.1.2 An annual replanting programme X POL has established a 10 years projected for a minimum of five programme projected for a programmed from 2015 to 2025 years (but longer where necessary minimum of five years?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min to reflect the management of b. Has it been documented? fragile soils, see Criterion 4.3), with X Refer above yearly review, shall be available. c. Is the progress of implementation X Refer above documented?

d. How does the programme take into X By means for document review of the consideration fragile soils such as maps, there were no peat lands in peat? Is there a longer projection POL period (see C4.3)? e. Is there evidence of a yearly review X Annual review in cooperation with of the replanting programme? annual financial budget

Principle 4: Use of Appropriate Best Practices by Growers and Millers a. Have the SOPs for mills and 4.1 Operating procedures are 4.1.1 (M) Standard Operating X POL has established documented appropriately documented, Procedures (SOPs) for estates and plantation been documented? SOPs available for plantations and consistently implemented and mills shall be documented. mills. monitored. Specific Guidance: SOPs sighted for mill (horizontal sterilizer, tippler / thresher, digester / For 4.1.1 and 4.1.4: SOP and press / screen, etc.) and plantation documentation for mills should include (field handbooks for nursery, relevant supply chain requirements (see immature and mature oil palm) RSPO Supply Chain Certification b. Does the SOP cover key processes, Standard, Nov 2011). X POL adopts the Field handbook for harvesting, transportation, mature and immature oil palm covers manuring, IPM, GAP, Supply Chain topics like harvesting, delivery, requirements for the mill, etc.? weeding, manuring, pest control, etc. Additional SOPs are available for key operations areas up to shipment. c. Is a copy of the SOP available on X SOPs are available and displayed at site and is it documented in an notice boards at respective sites and appropriate language? are documented in English and Pidgin.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Copies kept at main office accessible by employees. SOPs maintained for Leaf & Rachis sampling (SOP no. FIL003), boundary demarcation (SOP no.LAN001) and Field handbook for mature oil palm, 2nd edition 1999. Control of pests in oil palm; trunk injection procedures – technical note 9 by OPRA (oil palm research association) d. Is there evidence that SOPs are X SOPs are communicated to implemented and understood by employees and can be verified by workers? physical observations of employees following the procedures. SOP training conducted Example Chemical Handling on 10/09/2015 e. Are the SOPs appropriate and X The SOPs appropriate and adequately adequately cover all estate and mill cover the estates and mill processes. processes and activities? All the relevant records available at the Mill and estates. f. How are the SOPs made available X SOPs are displayed at worksites and at the point of use? are communicated through trainings / awareness, toolbox talk and morning musters. SOPs located at the operating offices and are accessible by operation personnel. a. Is there a master list of all SOPs? 4.1.2 A mechanism to check consistent X POL has established the master list of implementation of procedures shall all the SOPs in the database and be in place. managed by the Sustainability Department and some of the SOP Guidance: managed by the Mill and estates office.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Mechanisms to check implementations POL mill, master list of SOPs for could include documentation Engineering department updated in management systems and internal Jan 2015 and Sustainability control procedures. department updated on 12/11/2015. b. How does the company keep track X The company keep tracks through of revisions? revision history table on each SOP and records of last and next review dates. The master SOP register is maintained and held by Sustainability department. c. Is there mechanism for:

- Translation of SOP into work X SOPs are available in English and instructions in appropriate Pidgin versions. languages? - Records of training for all levels? X Records of training/awareness, toolbox talk and morning muster conducted on SOP’s are available at respective sites Example RSPO P&C Training on 13/01/2015 - Internal control (e.g. audit and X POL Sustainability Department review, field inspection) conducts quarterly RSPO internal procedure in place to monitor audits in a year as well as monthly consistent implementation of inspections. SOPs? Example: internal audit record dated 13/10/2015 for Luburua, Maramakas, Fileba, Lugagun, Madina and Fissoa divisions. Audit conducted at Poliamba mill on 15/10/2015.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min - Trained and competent X POL personnel are trained and personnel assigned to carry out competent to conduct internal internal control activities? management systems audits. Records of auditor training are available. Winnie Kale (admin officer) auditing for estates and Ipiso (sustainability manager) for mill. Training attendance record sighted for training on Auditing & report writing by Ipiso, Naomi, Theresa and Winnie dated 20/07/2015. - Implementation audits to be X RSPO internal audits are conducted carried out regularly covering quarterly in a year. As well as monthly implementation of all the inspections. SOPs? Internal audit covered processes like documentation, legal compliance, training, safety & health, chemicals, PCD, etc ( mill ) and grievances, incidents & accidents, first aid, training, chemicals, housing conditions, etc. (estates). - Procedure to address non- X POL has established Internal Audit compliance and corrective SOP, SUS008, rev.01, 12/11/2015 to action for continuous identifying nonconformity, corrective improvement? and preventative action. Records of non-conformance and corrective actions are available. a. Have the records been maintained 4.1.3 Records of monitoring and any actions taken shall be maintained on the following? and available, as appropriate. - Measurements or results of X POL maintains records of all internal control and monitoring monitoring activities including audits activities (refer 4.1.2) and inspections. Records are available at Sustainability Department

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min and at respective sites. Poliamba – Environmental permit no. EP-L2B (155) dated 26/07/1991 expiry 31/12/2053 for water extraction, wastewater discharge and water quality. Quarterly monitoring of water and effluent quality by SGS lab. Latest report no.PG02428 dated 05/11/2015 for 14 water sources/bore holes on E Coli, total coliform, turbidity and TSS. E.Coli readings for Lamerika (5), Kameriba (58), Bolegila (3) and Fissoa (28). Specification is zero.Total coliform readings for Lamerika (50), Kameriba(70), Bolegila (6) and Fissoa (76). Spec is <3 per 100 ml. - Records of corrective actions x POL Sustainability Department and improvement undertaken maintains a master register and records of all non-conformities and corrective and preventative actions taken (NC & CAR are located in separate file). Each respective site maintains records. Records of the corrective action and improvement have been complied. a. Is there an SOP for third-party FFB 4.1.4 (M) The mill shall record the origins X The 3rd party suppliers are the of all third-party sourced Fresh sourcing? smallholders included in the Fruit Bunches (FFB). certification. POL has established Smallholder Supply Chain Process on November 2015, Issue no: 2. The SOP covers harvesting, collection and delivery.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. Is there a list of approved third-party X Master list of all smallholders as third FFB suppliers? party smallholders are available with OPIC and POL Smallholder Affairs Department. Smallholders located at North, South and West spread over several villages. c. Is there proof of observed X SOPs are consistently implemented implementation of SOP?

d. Is there daily and summary records X The weighbridge records volume and of volume and origins of third-party sources of FFB which are then FFB received? presented in the daily mill production report. Daily Mill production report e. Have these records been verified X Records can be verified according to against the available document? the SOPs for smallholders established. Record was verified against the docket, daily mill production report and the payslip for the smallholders.. a. Are there SOPs for Good 4.2 Practices maintain soil fertility at, or 4.2.1 There shall be evidence that good X POL adopted the Field Handbook on where possible improve soil fertility agriculture practices, as contained Agricultural Practices in managing Oil palm Series Volume 1 to 3. to, a level that ensures optimal and in Standard Operating Procedures soil fertility? Volume 1 covers Nursery. Volume 2 sustained yield. (SOPs), are followed to manage covers Immature and volume 3 soil fertility to a level that ensures covers Mature Oil Palm as Good optimal and sustained yield, where agricultural practices possible. The SOP captures good agricultural Guidance: practices which includes a nutrient recycling strategy on EFB and Long-term fertility depends on decanter cake returned to field as maintaining the structure, organic matter manure

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min content, nutrient status and b. Is there evidence that the SOPs microbiological health of the soil. Nutrient X The SOP is consistently implemented. have been implemented and There are monthly OMP records of efficiency should take account of the age monitored? of plantations and soil conditions. field application for all inorganic and organic fertilizers available at Field TSD and Sustainability department. SOP Briefing Memo dated 20/10/2015 for SOP training on 24 & 26/10/2015 a. Is records of fertiliser inputs 4.2.2 Records of fertiliser inputs shall be X There are available records of OMP maintained. maintained? agronomic dashboard reports which can be linked to fertilizer program. West Coast estate - Stock cards maintained for fertilizers – urea, sodium borate and MOP. Madak estate – Fertilizer inventory recorded in Weekly returns for fertilizers ending 21/11/2015. Fertilizer application program has been established for year 2015. Example: Kara: Block - AA0010, Fert. Name: TSP-2015. Month of fertilizer: May, July and September. Total amount: 3,450 MT. West Coast: Block - AC0020, Fert. Name: Urea. Month of fertilizer: Feb and Sept. Total amount: 8,000MT. Nalik: Block – AB0050, Fert. Name: KCL. Month of fertilizer: April, Sept and Oct. Total amount: 4,150MT. Smallholders do not apply fertilisers. b. Is there records to proof that the X There are available records of OMP fertiliser program is linked to the agronomic dashboard reports which agronomic report? can be linked to fertilizer program

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Fertiliser inputs for each plantation were based on the recommendation and application program from the Technical Service Department. c. Is there records of fertilizer usage X Records of fertilizer input per tonne of per tonne of FFB production (>in FFB produced are available in the Summary Table, specific types of monthly OMP agronomic dashboard fertilizers)? reports. Fertilisers used are recorded and monitored by each estate. Records includes type of fertiliser applied, block numbers of areas and amount applied. Example:- Madak – Fert. Name: AN. October 2015. (0.52 kg/palm), YTD (1.67 kg/palm), Fert. Name: KCL (1.37 kg/palm), Fert.name: Urea October 2015 (0.02 kg/palm), YTD (2.22 kg/palm) (0.00992t/tFFB) West Coast – Fert.name: AN. YTD (0.92 kg/palm), Fert.name: KCL. October 2015 (0.81 kg/palm), YTD (2.03g/palm). Fert.name: Urea. YTD (1.84 kg/palm) (0.00772t/tFFB) Daily manuring based on the programme and recommendation for year 2015 and actual applied is recorded in the operation management system. Example:- OMP Fertilizer Application year 2015 for all the areas a. Is there SOPs for tissue and soil 4.2.3 There shall be evidence of periodic X SOPs on Oil Palm Sampling and Leaf tissue and soil sampling to monitor sampling? & Rachis Sampling are established for

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min changes in nutrient status. soil and tissue sampling tests.

b. Is there evidence of implementation x There are evidences of of the SOPs, including availability of implementation with records available records? at POL Field TSD. c. Is there records of tissue and soil X There are available records for soil analysis? and tissue sampling at the POL Field TSD and copies at Sustainability Department. Soil and Foliar tests were conducted by the Applied Agricultural Resources Sdn. Bhd in Malaysia. Dated 02/06/2015. Test conducted annually. d. Is the results of the study X Results from soil and tissue sampling incorporated into the fertilizer are incorporated into the main fertilizer program? program. Fertiliser Recommendations established for year 2015 are based on year 2014 foliar leaf tests results. a. Is there a nutrient recycling strategy 4.2.4 A nutrient recycling strategy shall X POL adopts the Mature Field Hand be in place, and may include use in place? Book Vol. 3 pages 29-33 which covers of Empty Fruit Bunches (EFB), nutrient recycling strategy. Palm Oil Mill Effluent (POME), and palm residues after replanting. POL has established SOP Field-SOP- 06 Guidance: Manuring which covers a nutrient The nutrient recycling strategy should recycling strategy for EFB and palm include any use of biomass for by- kernel decanter cake. products or energy production. Nutrient recycling is in place for the Nalik and Kara estates b. Does the strategy include the

following?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Clear objectives and time-bound X POL has no time bound plans since it targets is a continuous process. Palm residues and EFBs are applied during replanting and at young palms. This could be observed during field visits for internal managed estates. Smallholders applied fronds.  Inventory of

- EFB X Captured in OMP summary report where the EFBs are sent. Field application at Nalik and Kara estates as these 2 estates are near to the mill. Records available at filed management office. - POME X POME records are available with mill and captured in monthly KPI monitoring report. - Fibre X No fibre applied to the fields. Combusted in mill boiler for steam generation. - Boiler ash X No boiler ash applied to fields. Records available at mill. - Kernel shell X No kernel shells applied to field. Combusted in mill boiler for steam generation. - Palm residues from replanting X Palm residues during replanting. This could be observed during field visits of owned estates.  Biomass recycling program X EFBs and fronds are applied in fields

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min of both owned and smallholders.

 Implementation and monitoring X Captured in mills residues summary records and OMP records are available with Note to auditor: Ground verification the POL Field Department. required EFBs are applied to plantations nearer to the oil mill. Records are available for the quantities of EFBs applied to the fields. Example: Kara estate: 1,287tons year to date, 2015. Nalik estate: 1,208 tons year to date, 2015 EFBs are applied to the fields manually by the workers. a. Is there soil maps showing 4.3 Practices minimise and control 4.3.1 (M) Maps of any fragile soils shall X There are no fragile soil in all POL erosion and degradation of soils. be available. presence of fragile soils and estates and smallholders. problem soils (refer to 4.3.6)? Soil Maps are available with the POL Field Department. Estate maps of Madak and Noatsi estates were reviewed. b. Are maps georeferenced and of X Maps geo reference to scale of at appropriate scale (1:50,000)? least 1:20,000

a. Is there a management strategy in 4.3.2 A management strategy shall be in X POL adopted the Field Handbook place for plantings on slopes place for plantings on slopes? volume 3 for soil erosion and risk above a certain limit (this needs to management which defines be soil and climate specific). requirements for planting on slopes.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. Does the management strategy Guidance: include the following? Techniques that minimise soil erosion are well known and should be adopted, - Identification of steep areas not where appropriate. These should include X POL adopted the Field Handbook practices such as ground cover suitable for planting volume 3 for soil erosion and risk management, biomass recycling, management which defines terracing, and natural regeneration or requirements for planting on slopes restoration instead of replanting. and PNG logging code of practice defines slopes over 25 degrees as not suitable for planting. - Policy of planting on slopes X Above procedure contains requirements for planting on slopes.

- SOPs to minimise soil erosion X The Field Handbook contains based on local soil and climate information for erosion control conditions, e.g. ground cover practices, these includes, cover management, biomass cropping and buffer zone recycling, terracing, and natural establishment. regeneration or restoration instead of replanting c. Is there proof of records of field X POL field department conducts inspection on SOP implementation? regular field inspection to ensure consistent implementation of field standards. There are records of field inspections available at the POL Field department and copies at Sustainability department a. Is there a road maintenance 4.3.3 A road maintenance programme X POL has established a road shall be in place. programme in place with supporting maintenance plan for 2014-2015 budget and resources? updated on 03/01/2015. Example areas covers: Kara (road + drain) West coast (road + drains)

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Nalik (road + drains) Noatsi (road + drains) Madak (road +drains) The road maintenance programme was supported with the budget and resources. b. Is there road maintenance records? x POL has established fortnightly emergency roads maintenance established. Road maintenance completed for several road such as: Nalik – Luburua, road upgraded. Completed on March 2015. Maramakas, road upgrading. Completed on March 2015. Kara – Baia, road upgraded on April 2015. Other roads maintenance still in progress. a. Is there an SOP to provide 4.3.4 (M) Subsidence of peat soils shall x POL does not have any peat soils in be minimised and monitored. A guidance on subsidence the areas of its operations. documented water and ground management? cover management programme b. Does the SOP make reference to shall be in place. x POL does not have any peat soils in the RSPO BMPs on peat? the areas of its operations. Guidance: c. How is subsidence being x POL does not have any peat soils in Plantations on peat should be managed monitored? at least to the standard set out in the the areas of its operations. ‘RSPO Manual on Best Management d. Are there records of subsidence Practices (BMPs) for existing oil palm x POL does not have any peat soils in cultivation on peat’, June 2012 monitoring? the areas of its operations. (especially water management, fire

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min avoidance, fertiliser use, subsidence and e. How is subsidence being vegetation cover). x POL does not have any peat soils in minimised? the areas of its operations. Specific Guidance: f. Is there a water management x There is no drainability assessment of For 4.3.4: For existing plantings on peat, programme and evidence of the water table should be maintained at peat as POL does not have any peat an average of 50cm (between 40 - 60cm) implementation? soils in the areas of its operations below ground surface measured with For existing plantings on peat, the groundwater piezometer readings, or an water table should be maintained at average of 60cm (between 50 - 70cm) an average of 50cm (between 40 - below ground surface as measured in 60cm) below ground surface water collection drains, through a measured with groundwater network of appropriate water control piezometer readings, or an average structures e.g. weirs, sandbags, etc. in fields, and watergates at the discharge of 60cm (between 50 - 70cm) below points of main drains (Criteria 4.4 and ground surface as measured in 7.4). water collection drains, through a network of appropriate water control structures e.g. weirs, sandbags, etc. in fields, and watergates at the discharge points of main drains (Criteria 4.4 and 7.4). g. Is there a ground cover x There is no drainability assessment of management programme and is peat as POL does not have any peat there evidence of implementation? soils in the areas of its operations a. Was a drainability assessment 4.3.5 Drainability assessments shall be x There is no drainability assessment of required prior to replanting on peat conducted before replanting on peat as POL does not have any peat to determine the long-term viability peat? soils in the areas of its operations of the necessary drainage for oil b. Was a flood risk map provided as a palm growing. x There is no drainability assessment of result of the drainability peat as POL does not have any peat Specific Guidance: assessment? soils in the areas of its operations

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min c. If the drainability assessment shows For 4.3.5: Where drainability x There is no drainability assessment of assessments have identified areas that an area is unsuitable for peat as POL does not have any peat unsuitable for oil palm replanting, plans replanting, are there alternative soils in the areas of its operations should be in place for appropriate plans in place for rehabilitation and rehabilitation or alternative use of such alternative use in accordance to the areas. If the assessment indicates high RSPO BMPs? risk of serious flooding and/or salt water intrusion within two crop cycles, growers and planters should consider ceasing replanting and implementing rehabilitation. a. Is there a management strategy in 4.3.6 A management strategy shall be in x POL adopted the Field Handbook place for other fragile and problem place for other fragile and problem volume 3 to manage strategy planting soils (e.g. sandy, low organic soils? fragile and problem soil. matter, acid sulphate soils). However, there are no known fragile or problem soils at POL. b. Does the management strategy x Refer above handbook include SOPs for the management of other fragile and problem soils? c. Is inspection and implementation x There are no known fragile or problem records available? soils at POL. Therefore no records are available. Most of the smallholder blocks in POL areas are flat land. This could be observed during field visits Smallholders interviewed during field visits understood soil erosion and ways to mitigate impacts from soil erosion. a. Is there a water management plan 4.4 Practices maintain the quality and 4.4.1 An implemented water x POL has established a Water availability of surface and ground management plan shall be in in place for mill and plantation with management plan, issue 3, revision 2 water. place. identified actions? last reviews on 19/10/2015 that captures all sources of water within its

Specific Guidance: operating areas.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min For 4.4.1: The water management plan Example: will: Monitoring of volume of water  Take account of the efficiency of extracted and water quality, good use and renewability of sources; irrigation practice to minimize rainfall  Ensure that the use and run-off, etc. management of water by the b. Does the plan include the following?

operation does not result in adverse impacts on other users within the catchment area,  Identification of water sources x The water management plan captures including local communities and all sources of water within its customary water users; operating areas.  Aim to ensure local Example; Extraction of ground water communities, workers and their from bores. families have access to  Efficient use of water adequate, clean water for x The plan contains water usage at drinking, cooking, bathing and estates, mill, nursery and community domestic water use criteria to ensure cleaning purposes; efficient use of water.  Avoid contamination of surface  Renewability of water source and ground water through run- x The plan takes into consideration the renewability of all water resources. off of soil, nutrients or chemicals, or as a result of  Impacts on catchment area and x POL Water Management Plan defines inadequate disposal of waste local stakeholders regular monitoring of water sources as including Palm Oil Mill Effluent well as rivers / creeks located within (POME). the company operations area. No threats since water extraction is based on approved water permit Guidance: issued by Department of Growers and millers should address the Environmental & Conservation effects of their use of water and the  Access of clean drinking water x POL sustainability department effects of their activities on local water all year round for stakeholders conducts monthly drinking water resources. sampling and further analysed by accredited laboratories to ensure quality sources of drinking water. Corrective actions are taken then to

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min improve quality. Piped clean water available all year round to the workers and staff quarters.  Avoidance of surface and x POL ensures as much as possible to ground water contamination comply with all legal requirements to ensure there is no contamination of surface and ground water. POL has established buffer zones in its existing and new developments. c. Have the identified actions in the x Identified actions are implemented as plan been implemented? necessary as possible to meet the objectives of the Water Management Plan. a. Is there a map identifying water 4.4.2 (M) Protection of water courses and x Maps are available for all water wetlands, including maintaining courses and wetlands? courses and wetlands within and and restoring appropriate riparian around the POL operations areas. and other buffer zones (refer to national best practice and national Maps are available at Field guidelines) shall be demonstrated. department. b. Are the water courses and wetlands Specific Guidance: x All water courses within POL protected? operations areas are protected under For 4.4.2: Refer to the ‘RSPO Manual law (logging code of Practice) as well On Best Management Practices (BMP) as POL environmental and buffer for management and rehabilitation of zone policies. natural vegetation associated with oil palm cultivation on peat’, July 2012. Buffer zones demarcation SOP dated 19/11/2015 established to maintain and managed any buffer zones. c. Are the riparian and buffer zones x All riparian and buffer zones are maintained and restored in existing maintained throughout POL new and plantation and replanting areas? existing estates. Riparian and buffer zones at existing planting are maintained and replanting area increases according to PNG

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min logging Act requirements.

d. Is there SOP for riparian and buffer x POL has established Buffer zones zone protection? demarcation SOP dated 19/11/2015 to maintain and manage any water course and wetlands. POL maintains all legal and RSPO requirements for establishment of riparian and buffer zones. e. Has the SOP been implemented? x Buffer zones regularly inspected as per SOP. Records of buffer zone inspections maintained at Sustainability Department. a. Is the mill effluent treatment process 4.4.3 Appropriate treatment of mill x POL established POME treatment in place? effluent to required levels and SOP no. POM16, issue 1, Nov 2015 regular monitoring of discharge includes monitoring of ponds for quality, especially Biochemical overflow, blockage, seepage, bund Oxygen Demand (BOD), shall be subsidence. Maintain minimum in compliance with national 600mm freeboard in ponds for regulations (Criteria 2.1 and 5.6). rainwater. Skim cooling pond oil and feed effluent into each anaerobic pond. Monitoring of pH value. Final pond BOD discharge controlled at 100 ppm. b. Is there a process in place for x POL established Weekly effluent checking and monitoring water discharge wastewater analysis for discharge quality, particularly BOD? alkalinity, pH, SS, oil & grease, temp and BOD. Sighted Environmental control record dated Nov 18-23 for pond 4 and reed bed (dry). Latest result from reed bed dated

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min 18/08/2015 to 23/08/2015 showed pH 7.9, SS 1296, oil & grease 6.7, temp 28 and BOD 14, complying to spec. Palm oil effluent discharge report no. PG02436 from SGS dated 29/10/2015 for BOD 180 (spec <100), TSS 270 and oil & grease 5.7 c. Is the water discharge quality in x BOD 100, pH 5-9, TS 1500, SS 500, compliance with national oil & grease 50. regulations? Sighted SGS report no. PG02436 dated 29/10/2015 where BOD is recorded at 80. d. Does the mill have a license for x Environmental permit issued to oil treatment, discharge or land palm mill indicating compliance to application of mill effluent, and is discharge volume, BOD, pH, TSS, oil the mill in compliant with the & grease requirements. requirements of the license? Sighted Environmental Permit no. EP- L2B 1550 for POL dated 26/07/1991 expiry on 31/12/2053. a. Are there procedures to measure 4.4.4 Mill water use per tonne of Fresh x There are documented records Fruit Bunches (FFB) (see Criterion mill water usage, and are the available at POL mill for measurement 5.6) shall be monitored. procedures implemented? and monitoring of mill water usage. b. Are there records of mill water use X Monthly mill resource efficiency per tonne of Fresh Fruit Bunches reports DMPR are available for mill (FFB)? water use per tonne of FFB produced. Example: Month of Oct: 1.05 t/tFBB. YTD 1.09 t/tFFB. a. Is there a documented IPM plan? 4.5 Pests, diseases, weeds and invasive 4.5.1 (M) Implementation of Integrated x POL has established a documented introduced species are effectively Pest Management (IPM) plans IPM plan version 4.0 updated on

managed using appropriate shall be monitored. 10/01/2015

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Integrated Pest Management b. Does the IPM plan include the Guidance: techniques. following? Growers should apply recognised IPM  Identification of potential pests techniques, incorporating cultural, x The IPM plan identifies different pest biological, mechanical and physical and thresholds and weeds associated with oil palm methods to minimise the use of plantations. chemicals. Current pest within POL plantations Native species should be used in and its smallholders is Ganoderma, biological control where possible. Sexava (locust) and stick insects.  What are the techniques used x Techniques stated in the plan include; (cultural, biological, mechanical mechanical, physical, biological and and physical methods)? chemical control techniques. POL uses a physical control measure to remove the palm to reduce the spread of Ganoderma. There are no chemical controls for Ganoderma. For Sexava census is conducted before chemically treated. A biological method has been established using a biological agent to control Sexava and sitck insects. The biological control agents stichotrema (parasite) was released in the estates that will control Sexava.  What are the native species x Native species of biological pest used as part of the biological control were breed at Dami and control method? populated at POL for release to the affected areas.  Does it help in reducing the use x POL advocates the judicious use of of chemicals over a period of certain pesticides. time?  Prophylactic use of pesticides x No prophylactic use of pesticides

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Minimization of pesticide use x POL IPM considers the prudent use of pesticides where possible.  Review on the plans to suit the x The IPM plan is reviewed annually to present condition such as suit current situations. replanting? c. Is there an SOP to implement the x The IPM includes procedures for plan and monitor its effectiveness? implementation of the IPM. d. Is there record of pest occurrence x There are records of Ganoderma and control? ,Sexava and stick inserts occurrence and control measures available at POL Field TSD a. Is there record of training provided 4.5.2 Training of those involved in IPM x There are records of training are implementation shall be to those involved in the sighted and available at Field TSD. demonstrated. implementation of IPM? Sighted Chemical Treatement training for Sexava conducted on 09/01/2015 a. Does the organization have a policy 4.6 Pesticides are used in ways that do 4.6.1 (M) Justification of all pesticides x OHS policy and Safe use of chemicals not endanger health or the used shall be demonstrated. The on safe use of chemicals? has been established and revised on environment. use of selective products that are 01/10/2015 approved by General specific to the target pest, weed or Manager disease and which have minimal b. Does the organization have SOPs x POL has established Integrated Pest effect on non-target species shall for use of selective products that be used where available. Management Plan and implemented. are specific to target pests, weeds, Revised on 10/01/2015 that covered Specific Guidance: or diseases and which have minimal the specific on the use of effect on non-target species? Agrochemicals, weed control, nursery For 4.6.1: Measures to avoid the inspection, fungal disease, disease development of resistance (such as management and methods of disease pesticide rotations) should be applied. control. The justification should consider less i. Measures to avoid the harmful alternatives and IPM. x Pesticide rotation is practiced in the development of resistance (such plantations. Pesticide is applied as per Guidance: as pesticide rotation) should be set pesticide application program applied. maintained at respective estates

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min ii. Is there a list of all pesticide with The RSPO has identified some examples x List of all pesticides with target of alternatives to pesticide use, which target species and justification of species was stated in the Integrated include those listed in the ‘Research use? Pest Management Plan project on Integrated Weed Management Strategies for Oil Palm; CABI, April Example:-Glyphosate 450, Ally, Basta, 2011’. Bufos 135, Canyon 20 WG, Grasskill 450, Tecto Flowable SC, and Due to problems in the accuracy of Adjuvant. measurement, monitoring of pesticide iii. The justification should consider toxicity is not applicable to independent x POL currently uses less harmful less harmful alternatives and pesticides. Paraquat has been phased smallholders (refer to ‘Guidance for IPM. Independent Smallholders under Group out in 2012 for use in all estates. Certification’, June 2010). c. Is there evidence of implementation x Evidence of implementation can be of SOP on the ground? verified against Field OMP report on pesticide application. Records of OMP pesticide application are available with Field Department a. Does the company have a pesticide 4.6.2 (M) Records of pesticides use x All POL estates have a pesticide (including active ingredients used application program? application program for year 2015. and their LD50, area treated, amount of active ingredients Verified records in OMP system applied per ha and number of No use of pesticides by the applications) shall be provided. smallholders. b. Is record of pesticides use x OMP reports on pesticide application available? are available at Field Department Recorded in pesticide stock control records, received, issued and balance. Madad estate – Chemical stock and usage record for glyphosate abd Li700 surfactant. c. Do the records detail the active x OMP pesticide application reports ingredients used and their LD50, captures active ingredients, LD50, area treated, amount of active area treated, and active ingredient per

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min ingredients applied per ha and hectare. number of applications? Example: Spray area 1,702.2 ha, Glyphosate AI 45%, LD50 – 5000, 4 applications for year 2015 a. Does the company have an IPM 4.6.3 (M) Any use of pesticides shall be x POL has established an IPM plan minimised as part of a plan, and in plan? which is implemented. Revised on accordance with Integrated Pest 10/01/2015, it covered specific Management (IPM) plans. There information on the use of shall be no prophylactic use of Agrochemicals, weed control, nursery pesticides, except in specific inspection, fungal disease, disease situations identified in national Best management and methods of disease Practice guidelines. control b. Has that plan been implemented? Specific guidance for 4.6.3: x The plan has been implemented to Justification of the use of such pesticides control the pest Ganoderma, Sexava will be included in the public summary and stick insects. report. Records are available with Field TSD OPRA provided the replanting guidelines to minimize risk from Ganoderma. Survey has been carried out by the Technical Service team on the Ganoderma, Sexava and stick insects. c. Is the effectiveness of the IPM plan x There are SOPs available for the monitored? implementation of the IPM. SOP for IPM are available with Field TSD and estates. POL Annual Continuous Improvement Plan monitors IPM programme. d. Are there records showing that the x There are records available for the use of pesticides have been use of physical controls to eradicate minimised in accordance with the spread of Ganoderma, Sexva and Integrated Pest Management (IPM) stick insects. plan? Records are available with Field TSD

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Record in Chemical Stock spreadsheet by each estate. e. Has there been prophylactic use of x POL advocates the judicious use of pesticides? If so, justification must certain pesticides in accordance with be provided in accordance to best practices. No prophylactic use of National Best Practices. pesticides has been observed. a. Does the company have a complete 4.6.4 Pesticides that are categorised as x POL has in place a WHO chemical World Health Organisation Class listing of WHO class 1A, class 1B, listing of WHO class 1A, class 1B and 1A or 1B, or that are listed by the and Stockholm or Rotterdam Stockholm or Rotterdam Conventions Stockholm or Rotterdam Conventions pesticide? pesticide Conventions, and paraquat, are not used, except in specific No use of one of these pesticides, situations identified in national Best including paraquat. Practice guidelines. The use of Stocks records verified. such pesticides shall be minimised b. Is there a policy, procedure or x POL has in place an IPM plan which and eliminated as part of a plan, management plan committing to and shall only be used in focuses on the prudent use of minimise and eliminate use of these exceptional circumstances. pesticides. pesticides and paraquat? Paraquat has been phased out in 2012 for use in all estates. Awareness poster of the Pied Coucal (Mukmuk) bird which feeds on the Sexava pest. Implementation of biological control using parasitic wasps which lay their eggs into the sexava eggs and ultimately control the pest c. Are there records of minimisation of x There are trends for pesticide used in pesticides and paraquat use? POL available to verify pesticide usage. Yearly records on usage of methamidophos shown continual reduction of usage from 2010 (2433 lit ) to 2014 (1113 lit) and 2015 (663 lit.).

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min d. Where there is the use of the above x All chemicals used in POL are in pesticides or paraquat, has accordance with national best justification in line with national best practices. practice guidelines been Pest infestation recommendation documented? (PestRec) dated 30/06/2015 from PNGOPRA for Rangalis division for trunk injection of 87 ha, endorsed by Dr. Mark Ero. e. Does physical verification of x Records of all chemical storage can inventory in the chemical store be verified with master chemical agree back to the inventory register maintained at the POL Central records? Field Stores. Stocks records verified through visual inspection Inventory record as of 01/12/2015 shows 1000 lit but physical stock is only 960 lit. 40 lit written off due to leakages. Justification for stock adjustment dated 02/10/2015, approved by Anita (financial controller). a. Is there SOP for 4.6.5 (M) Pesticides shall only be x POL has established Chemical mixing handled, used or applied by chemicals/pesticides handling? SOP no. FIL008, rev.001, 12/11/2015 persons who have completed the and Chemical application, SOP no. necessary training and shall FIL009, rev.001, 23/11/2015. always be applied in accordance b. Is there a training plan and training with the product label. Appropriate x All POL estates have in-house training records for workers who apply or programs for pesticide handlers and safety and application equipment handle pesticides? shall be provided and used. All applicators. precautions attached to the Records are available at respective products shall be properly estates; observed, applied, and understood by workers (see Criterion 4.7). Example:  Chemical spraying / handling dated 09/09/2015

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Chemical usage, container disposal, chemical application and mixing dated 28/11/2015. c. Is there evidence that training has x All trainings are conducted in English been conducted in an appropriate and local Pidgin languages. language understood by the workers? Example:  Chemical spraying / handling dated 09/09/2015 Chemical usage, container disposal, chemical application and mixing dated 28/11/2015. d. Are pesticides handled, used or x Chemical handlers and applicators in applied only by persons who have POL estates have gone through completed the necessary training? necessary training. Records of training are maintained at respective sites.  West coast estate: Training record for Tien Malik (chemical mixer) for chemical spraying/handling on 09/09/2015  Chemical usage, container disposal, chemical application and mixing on 28/11/2015.  Madak estate: Training records for Jowas and Topias (chemical mixer) on chemical handlers training dated 09/09//2015. e. Are the workers involved in x Understanding of work instructions chemical handling or application and associated OHS & environmental able to demonstrate understanding risks can be verified through physical of the hazards and risks related to observation of employees in field and chemicals used when interviewed? through interviews  West coast estate: Training record for

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Tien Malik (chemical mixer) for chemical spraying/handling on 09/09/2015  Chemical usage, container disposal, chemical application and mixing on 28/11/2015. f. Are pesticides always applied in x All pesticides are applied in accordance with the product label? accordance with IPM which is written in accordance to best practices. There are up to date MSDS available at all sites which store and use pesticides Sighted product label for glyphosate, Li700 and metalsulfron. g. Are MSDS for pesticides used x Pesticide MSDS are stored at the readily available for easy reference? point of storage and usage at all POL estates. Sighted MSDS for glyphosate, Li700 and metalsulfron. h. Is appropriate safety and application x Appropriate safety equipment & PPE equipment provided and used? are issued to workers involved with pesticides. Records of PPE issue are available at respective estates. Example: PPE provided: Gumboots, rubber gloves, safety goggles and face mask. Verified chemical mixing worker with gumboots, rubber gloves, goggles and face mask. i. Is PPE used appropriate according x PPE used are issued as per risk to recommendations in any risk involved. assessments done? According to MSDS and product label:

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Chemical mixing SOP no. FIL008, rev.001, 12/11/2015 and Chemical application, SOP no. FIL009, rev.001, 23/11/2015. j. Is appropriate PPE provided and x Appropriate safety equipment & PPE used, and can it be easily replaced are issued to employees involved with if damaged? pesticides. PPE is also replaced upon wear & tear. Records of PPE issue are available at respective estates. Interview of field workers. k. Does the management checked the x Daily PPE checks are done during workers usage of appropriate morning musters. Records of PPE PPEs? checks are available at respective estates. Field supervisors conduct the inspections when there are spraying activities. Quarterly checked by sustainability team. a. Has the SOP for pesticide storage 4.6.6 (M) Storage of all pesticides shall x POL ensures storage of all pesticides been documented and be according to recognised best is in accordance with best practices. practices. All pesticide containers implemented? shall be properly disposed off and Procurement and stores SOP no. not used for other purposes (see FIN001, rev.001, 19/11/2015. Criterion 5.3). Verified that pesticides are stored Specific guidance for 4.6.6: separately from general goods in Recognised best practice includes: bunded sheds. b. Are all pesticides stored according Storage of all pesticides as prescribed in x All pesticides stored according to the FAO International Code of Conduct to recognised best practices? recognised best practices. on the distribution and use of pesticides and its guidelines, and supplemented by Powders above liquids sighted during stores inspection.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min relevant industry guidelines in support of the International Code (see Annex 1). Pesticide stores are fenced and with signage. Spill kit maintained. Inventory records maintained c. Is there evidence that empty x All pesticide storage in POL is pesticide containers are properly according best management stored and disposed off and not practices. used for other purposes? All empty containers are stored in a chemical shed. Damaged empty containers are disposed in the chemical pit landfill. Example: Madak estate – Waste treatment and disposal options register which indicated daily disposal of chemical containers to Lakurumau landfill. d. Is there evidence observed in the x Empty pesticide containers are not field that pesticide containers are used for other purposes and reuse as indiscriminately disposed (in dump pesticide pre-mix containers. site) or used for other purposes, Damaged containers are punched and .e.g. as waste containers, flower cut before disposed at landfill sites pots? Physical inspections at and workers housing, no evidence found empty and damaged containers are used for any purpose.. a. Is there work instruction for 4.6.7 Application of pesticides shall be x POL has established Chemical by proven methods that minimise pesticide application? application, SOP no. FIL009, risk and impacts. 12/11/2015 and Chemical application, SOP no.FIL009, rev.1, 23/11/2015 b. Is there training provided on work x Training is regularly conducted on instruction including risk and SOP’s which include associated risks impacts of pesticide applications? and impacts. Records of pesticide trainings are Int rspo pc cld clr sum e - v01 – 23/9/2015 p. 76/ 181 NBPOL – POL 30/11/2015 to 04/12/2015

NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min available at respective estate. Example: Madak estate SOP training on 05/11/2015 a. Has aerial spray been applied? If 4.6.8 (M) Pesticides shall be applied x POL operations do not apply aerially only where there is yes, is there documented pesticides aerially. documented justification. justification? Communities shall be informed of b. Is the impact and risk associated x POL operations do not apply impending aerial pesticide with aerial application documented applications with all relevant pesticides aerially. and made available? information within reasonable time prior to application. c. Are the identified affected x POL operations do not apply communities informed of impending pesticides aerially. aerial pesticide applications with all relevant information within reasonable time prior to application? a. Has the company provided 4.6.9 Maintenance of employee and x Smallholder Affair office established associated smallholder knowledge information materials on pesticide training plan to the smallholders and skills on pesticide handling handling to all employees and growers for year 2015. Training was shall be demonstrated, including associated smallholders (if any) carried out to the smallholders provision of appropriate (see Criterion 4.8)? growers on regular basis.. information materials (see Criterion 4.8). Training was conducted throughout a year. Example:- Training topic – Fertilizer, Harvesting & Upkeep, Pest & Disease, Roadside clearing and RSPO (Include FFB price formula, Pesticides handling and zero burning). It was sighted and confirmed during the visit and interviewed the smallholders growers

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. Is there evidence of periodic training x Training / awareness, toolbox talk, (in appropriate language) of morning musters on pesticide employees and associated handling is conducted regularly at all smallholders on pesticide handling? POL estates. Note: Interview with workers and Records are maintained at respective smallholders on their knowledge and plantations. skills in pesticides handling. Workers were interviewed during on site. All POL smallholders do not use pesticides. a. Is there an SOP for proper disposal 4.6.10 Proper disposal of waste material, x POL has established Waste according to procedures that are of waste material? management plan, revision 2, issue 3 fully understood by workers and updated on 19/10/2015 and Container managers shall be demonstrated disposal SOP no. FIL002, Clinic waste (see Criterion 5.3). incineration SOP no.HRA002.. b. Is there training provided to workers x There are trainings conducted on and managers on proper waste proper waste management and disposal? disposal practices at POL. Records of communication on waste management are maintained at respective sites. Waste Disposal SOP training on 19/10/2015 at Madak estate c. Is there evidence of implementation x All waste are disposed in accordance of proper ways for waste disposal with POL Waste Management Plan by the company? and can be verified through the POL waste disposal register for the main POL landfill site maintained by Sustainability and physical observation of waste management practices. Waste disposal at the landfill was recorded by the Sustainability

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min department. Waste disposal at the landfill was recorded by the individual estates. Example Madak estate on 26/10/2015 disposed 58 fertiliser bags and 3 empty damaged containers. a. Is there an updated list of pesticide 4.6.11 (M) Specific annual medical x POL has in place an updated list of all surveillance for pesticide operators? pesticide handlers engaged at all its operators, and documented action estates and TSD office. to treat related health conditions, shall be demonstrated. Respective estates have in place list of pesticide handlers. Pesticides operators register at the estates and TSD office was verified b. Is there record of annual medical x POL conducts 12 monthly medical surveillance of pesticide operators? screening of pesticide handlers and 6 months medical screening for Class IB pesticide handlers. All pesticides operators are issued a Green Card as prove they are medically fit for the work. Records are maintained at respective estates, clinics, TSD office and copies at Sustainability Department Medical surveillance for pesticides handling operators was verified. c. Is there medical and treatment x Pesticide handlers who are screened record of all pesticide operators? and recommended for further treatment or are proven to be medically unfit are transferred to other section or duties. All pesticides operators are issued a Green Card as prove they are medically fit for the work.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Records of corrective actions acted upon recommendations from medical screening are available at respective estates, HR department and copies at Sustainability Department. Medical examination records were verified. Example medical fitness conducted on 04/04/2015 a. Is there a policy statement 4.6.12 (M) No work with pesticides shall x POL has established Pregnant and be undertaken by pregnant or preventing pregnant and breast- Breast Feeding Women Policy and breast-feeding women. feeding women from handling Nursing Mothers Policy updated on pesticides? 29/11/2015 signed by General Manager for no work with Pesticide for pregnant and breast-feeding woman which prohibits the handling of pesticide by pregnant & breast feeding women. b. Is there a list of female workers x POL has endeavoured its efforts to handling pesticides available? prevent female as pesticide operators. The list of pesticide handlers maintained by HR and estates to filters out female as sprayers. Workers register at estates and human resources department were verified. c. Does the company have a system x POL has established Pregnant and to identify pregnant and breast- Breast Feeding Mothers Policy and feeding women? procedure HRA003 which encourages working females to come forward for pregnancy test if they feel that they are pregnant. POL conducts periodic pregnancy tests and monthly tests for breast

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min feeding women. Records at clinic were verified.

d. Is there evidence showing that x Records of women transferred due to pregnant and breast-feeding women pregnancy or child birth are are not allowed to handle maintained at respective estates and pesticides? HR office. Transfer records to other duties as specified by the medical officer if any detected case. a. Is there a health and safety policy in 4.7 An occupational health and safety 4.7.1 (M) A health and safety policy shall x POL has established OHS policy plan is documented, effectively be in place. A health and safety place? updated on 01/20/2015 signed by communicated and implemented. plan covering all activities shall be General Manager. documented and implemented,  Is it written in an appropriate and its effectiveness monitored. x The OHS Policy was written in dual language? language, English and Pidgin. Guidance:  Has the policy been approved x Policy approved by POL General Growers and millers should ensure that by an authorized personnel and the workplace, machinery, equipment, Manager dated? transport and processes under their  Does the policy cover mitigation control are safe and without undue risk to x OHS policy stipulates mitigation for health. Growers and millers should of risks to workers health and appropriate management systems to ensure that the chemical, physical and safety at all workplace activities? identify and control risks involved at all biological substances and agents under workplace activities. their control are without undue risk to  Are the workers aware of and health when appropriate measures are x OHS Policy is a publicly available understand the policy? taken. All indicators apply to all workers document and displayed at notice regardless of status. boards at all POL locations. The health and safety plan should also Regularly policy communication is reflect guidance in ILO Convention 184 conducted at respective sites with (see Annex 1). documented records. b. Is there a health and safety plan in x POL has established Health and place? Safety plan version 03 updated on 06/10/2015

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Does the plan include targets for x POL OHS Plan clearly defines its improving occupational health objectives in improving OHS in its and safety? operations and included in annual continuous improvement plan version 5 updated 06/11/2015  Does the plan reflect guidance x POL OHS plan does reflect guidance provided in the ILO Convention provided by the ILO Convention 184 in 184 (see Annex 1)? carrying risk assessments, provision of training, PPE, risk assessment, handling and storage c. Is there evidence of implementation x Evidence of implementation can be of the plan? verified against POL overall OHS performance. Records of safety performance are available with Sustainability Department. Example: Poliamba mill: Emergency response fire drill operation conducted on 06./11/2015. Records of drill attendance list and photos sighted. d. Is the effectiveness of the health x Evidence of implementation can be and safety plan monitored? verified against HOP’s overall OHS performance. Records of safety performance are available with Sustainability Department. Latest OHS committee meeting on 23/09/2015. e. Is the health and safety plan made x The OHS Plan is a public document publicly available? upon request and approval by General Manager and is available at all POL

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min sites.

f. Is there an action plan if targets are x Action plan for improvements in POL not achieved? overall OHS performance is recommended through annual management review meetings. Records of management review are available. Latest OHS committee meeting on 23/09/2015. a. Have risk assessments been 4.7.2 (M) All operations where health and X Risk assessments have been safety is an issue shall be risk conducted for all operations where undertaken at POL to cover all assessed, and procedures and health and safety is an issue? activities of its operations. actions shall be documented and implemented to address the Workplace risk assessment conducted identified issues. All precautions for central stores, construction, attached to products shall be medical clinic, plantations, vehicle properly observed and applied to workshop and mill, dated 05/10/2015. the workers. Criteria – severity x probability. Score > 15 considered extreme risk. One extreme risk identified – palm nail injury from harvesting and pruning. Controls – training, PPE. b. Does the risk assessment cover all x The risk assessment covers all key the organization’s processes and operations areas of POL. activities? Risk assessment covers estates, mills, VWS & transport, construction and smaller units as clinics, stores c. If any accidents had occurred, were x POL risk assessments are reviewed these included in the risk annually to capture occurrences not assessments with action plans to identified and are identified as prevent further recurrence? recommended controls which are then managed by individual sites.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min d. Have the procedures and action x POL risk assessments are reviewed plans been documented and annually to capture occurrences not implemented to address the identified and are identified as identified issues? recommended controls which are then managed by individual sites. Incidents reports with additional training and briefing provided to workers and staff. Example; Safety training to workers on 22/09/2015 Major accidents included in action plans for risk assessment. OHS meeting dated 23/09/2015 to review action plans e. Have all precautions attached to x All precautions including MSDS are products been properly observed regularly communicated to the and applied to the workers? workforce as well as made available at appropriate locations for access by workers. Records of precautions/MSDS communication are maintained at respective sites Product label and MSDS training provided to workers. a. Are all workers involved in the 4.7.3 (M) All workers involved in the x Employees are regularly trained on operation shall be adequately operation appropriately trained in safe working procedures throughout trained in safe working practices safe working practices (see HOP sites. Records of trainings (see Criterion 4.8). Adequate and Criterion 4.8)? conducted on safe working appropriate protective equipment procedures are maintained at shall be available to all workers at respective site. the place of work to cover all potentially hazardous operations, Chemical safety training record dated 29/11/2015.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min such as pesticide application, b. Are OSH training programs and machine operations, and land x POL sites have developed in-house training records available and training programs and are conducted preparation, harvesting and, if it is conducted by qualified persons? used, burning. by managers, DM / line managers and site Sustainability / OHS representatives who have undergone basis OH&S training. Safety training conducted by trained personnel Example Harvesting training conducted on 22/07/2015 at West Coast Estate.  Does the organization maintain x All POL employees are issued a list of PPE distribution? appropriate PPE to suit specific work conditions. Spare PPE is currently recommended to be available at high risk areas such chemical storage areas. Issuance of PPEs and equipment recorded in Stock record card - gumboots, overalls, harvest poles, knives & raincoats. West coast estate: Tools & PPE issue records for gumboots dated 23/09/2015 to 60+ workers. c. Is adequate and appropriate x Workers are provided with suitable protective equipment available to PPEs for each operation activities: all workers at the place of work to cover all potentially hazardous Example: operations, such as pesticide Sprayer is provided with gloves, application, machine operations, apron, face mask. and land preparation, harvesting Chemical mixer provided with gloves, and, if it is used, burning? eye shield, face mask and apron. Workers carrying hot work at mill are

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min provided with safety helmet, gloves, face shield, eye shield when performing welding.

d. Is PPE provided to workers and x All POL employees are issued PPE to replaced when damaged suit work conditions and are replaced on wear-tear basis or prolonged use such as masks for pesticide sprayer Example: Replacement of gloves and apron records sighted.  Does the organization x All POL sites maintain a PPE issue maintain a list of PPE register which keeps track of PPE distribution? issued to individual workers. Example: Issuance of PPEs and equipment recorded in Stock record card - gumboots, overalls, harvest poles, knives and raincoat. e. Are workers observed wearing x It can be verified through physical appropriate PPE observation of POL workers are wearing appropriate PPE. Example: All workers and visitors entering the mills must put on safety helmets, eye wear and ear plugs entering noise area. a. Has the company identified the 4.7.4 (M) The responsible x The Sustainability manager is in responsible person/persons to person/persons shall be identified. charge of overall OHS There shall be records of regular implement OSH? implementation. Implementation of the meetings between the responsible OHS policy is delegated to a person/s and workers. Concerns of Sustainability Officer. all parties about health, safety and There are nominated site OHS

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min welfare shall be discussed at these responsible persons and safety meetings, and any issues raised wardens for respective sites to carry shall be recorded. out implementation at site level. Each site has an OHS committee to address identified issues. b. Are meetings between the x Monthly site OHS committee meetings responsible persons and workers are conducted. conducted on a regular basis, or as required by law, if any? Records of OHS meetings are maintained at respective sites and copies at Sustainability. West coast estate: OHS committee meeting conducted on monthly basis. Sighted minutes dated 18/11/2015 and 14/10/2015. Review of accidents, reporting system, inspection findings, training, policy & procedures, any other business. Attendance list included. Poliamba mill: OHS committee meeting every quarterly. Latest on 23/09/2015. Madak estate: OHS meeting agenda dated 10/11/2015 and 31/10/2015 sighted c. Are minutes of meeting recording x Records of monthly OHS meetings attendees and issues discussed minutes containing attendance list and available? discussed issues are maintained at respective sites with copies at Sustainability. Poliamba mill: Minutes and attendance recorded dated 23/09/2015

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min d. Are concerns of all parties about x Site OHS committees are made up health, safety and welfare randomly selected employees who discussed at these meetings? present concerns on behalf of all parties. Note to Auditor: Interviews with workers reflect compliance to a-d above. Review of previous meetings, accident & injury, site inspections, safety issues, update during OHS audits. a. Are there SOPs for accidents and 4.7.5 Accident and emergency x POL has established an Emergency procedures shall exist and emergencies? Response Procedure SOP no. 28, instructions shall be clearly updated in October 2015. understood by all workers. Accident procedures shall be Ambulance SOP no. HRA001, available in the appropriate 12/11/2015.  Do these cover all major language of the workforce. x POL ERP covers major potential Assigned operatives trained in First potential emergencies, such as, emergencies. Regular emergency Aid should be present in both field but not limited to fire, chemical drills are conducted at POL sites on and other operations, and first aid spillage, and potential natural different emergency situations to test equipment shall be available at disasters specific for the region, ERP. worksites. Records of all accidents e.g. earthquakes, volcanoes, shall be kept and periodically Records of emergency drills are etc.? reviewed. maintained at respective sites  Are accidents investigated and x Accident investigation is carried out to action taken to prevent identify causes in order to allow recurrence? improvements to be made in controls. POL SHEQ001 incident form no. IR484 dated 21/102015 for injury to right leg by sharp frond. Form no. 479 dated 12/10/2015 for injury to leg due to grass knife. Correctives actions taken, recorded and verified  Are accident records provided to x Only major accidents and the local authority in accordance emergencies are reported to local with local legal requirements, if authority. any? POL did not have any major fatality

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min accidents occured for the past 12 months..

 Available in the appropriate x POL sites conduct regular emergency language of the workforce? drills to test and familiarise SOP with all workforce. The ERP is communicated to employees in English and local Pidgin language. b. Are the instructions on emergency x Records of emergency drill evaluation procedures clearly understood by all are done after each drill to workers? continuously improve workers understanding of ERP. Fire drill at Madak estate conducted on 21/03/2015 c. Are assigned operators trained in X POL facilitates regular First Aid First Aid present in both field and training for assigned employees at all other operations? POL sites. There are records of First Aid certificates available at Sustainability. Example First Aider training conducted by PNG Red Cross on 29/04/2015 d. Is there records of training of the x Sustainability maintains a master list first aiders? of all current First Aiders and copies of training certificates. Example First Aider training conducted by PNG Red Cross on 29/04/2015 e. Is first aid equipment available at Min NC1 First aid kits are available at estates worksites? Is the equipment offices, mill office, HQ office and available during conduct of field workshops. However not available at manual work? the field work areas.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Min NC 1: During the field visits at West Coast and Madak estates, first aid kits were not made available at chemical spraying, chemical mixing area and harvesting work locations to handle emergency in the event of an injury and/or accident f. Are first aid kits adequately stocked x First Aid kits are regularly inspected and regularly checked in and stocked in accordance with local accordance with local legal regulations. requirements? First aid kit content records are maintained. g. Are records of all accidents kept x Records of accidents / incidents are and periodically reviewed for maintained at respective sites and are continuous improvement? reviewed during monthly OHS committee meetings. Sustainability department conducts monthly reports which capture incident / accident review Monthly review in OHS meetings. Reviewed quarterly in OHS committee meeting. Latest on 23/09/2015 minutes recorded. a. Is there evidence that all workers 4.7.6 All workers shall be provided with x All POL employees are provided with are provided with medical care medical care, and covered by free medical care and are covered by accident insurance. (refer to Criterion 6.5.3), and an insurance policy which is governed covered by accident insurance by under local regulations (Workers the company? For contract workers, Compensation Act 1978 & the contract between the company Employment Act 1978) and the contractor shall be in Sighted QBE Insurance for workers compliance. compensation for period 31/12/2014 to 31/12/2015

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. For accidents that have occurred, is x There are records available with there evidence that the affected Finance on employees who have workers received appropriate claimed and received compensation. medical treatment, and was able to Madak estate, Kamariba division, claim and receive compensation Sambes Gibson received under the insurance policy (if compensation for 10 days due to relevant)? injury. Madak estate – Sighted Poliamba clinic attendance form dated 03/12/2015 for patient treatment for mild pain, malaria, fever, etc. c. Is there evidence that the insurance x Sighted QBE Insurance for workers policies are valid? compensation for period 31/12/2014 to 31/12/2015

a. Are occupational injuries recorded 4.7.7 Occupational injuries shall be x POL records all industrial injuries recorded using Lost Time Accident using Lost Time Accident (LTA) using the LTA metrics. Records of (LTA) metrics. metrics? LTA formula and trends for all POL sites are maintained at Sustainability Specific Guidance for 4.7.7: The department. National Interpretation will define the metrics for LTA. For countries where POL analysis of incidents / accidents there are no national interpretations, the data on number of employees, lot time growers will determine their own metrics. cases, lost work days, lost time cases rate, lost work day rate, severity rate and fatality from 2011 – 2015. Poliamba mill: Data for Oct indicated 2015 employees, 20 lost time cases, 44 lost workdays, 11.2% lost time cases rate, 24.8% lost work day rate, severity rating of 2 and zero fatality. a. Does the company maintain a list of 4.8 All staff, workers, smallholders and 4.8.1 (M) A formal training programme x POL Training Department maintains a contract workers are appropriately shall be in place that covers all staff, workers, smallholders and list of employees from all departments trained. aspects of the RSPO Principles contract workers whom training whom training must be conducted to. and Criteria, and that includes must be provided to? This list is collected from in-house

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min regular assessments of training training needs from respective needs and documentation of the departments/sites. programme. Smallholder Affair office established Guidance: training plan to the smallholders for year 2015. Training was carried out to Workers should be adequately trained the smallholders on regular basis. on: the health and environmental risks of pesticide exposure; recognition of acute Trainings are conducted throughout and long-term exposure symptoms the year. Example: Training topic – including the most vulnerable groups Fertilizer, Harvesting & Upkeep, Pest (e.g. young workers, pregnant women); & Disease, Roadside clearing and ways to minimise exposure to workers RSPO (Include FFB price formula and and their families; and international and zero burning). national instruments or regulations that protect workers’ health. It was sighted and confirmed during the visit and interviewed the The training programme should include smallholders.

productivity and best management nd practice, and be appropriate to the scale Madak: 2 Week January 2015: of the organisation. Attended by Katedan, Lavatbura, Lambuso dated on 20/01/2015. Training should be given to all staff and Attendant list available.

workers by growers and millers to enable st them to fulfil their jobs and Noatsi 1 week June 2015: Attended responsibilities in accordance with by Kama & Kafkaf dated on documented procedures, and in 23/06/2015. Attendant list available. compliance with the requirements of West coast 4th Week August 2015: these Principles, Criteria, Indicators and Attended by Lavolai dated on Guidance. 27/07/2015 . Attendant list available. b. Is there a formal training Contract workers should be selected for X POL Training Department is their ability to fulfil their jobs and programme in place that covers all responsible for developing a master responsibilities in accordance with aspects of the RSPO Principles training program for all workers whom documented procedures, and in and Criteria? Does the formal require training. compliance with the requirements of the training program include: RSPO Principles, Criteria, Indicators and A formal training program is Guidance. developed once training needs are collected from each respective Growers and millers should demonstrate departments/sites. training activities for schemes The formal training program will cover

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min smallholders who provide Fresh Fruit all aspects of RSPO. Bunches (FFB) on a contracted basis. RSPO P&C 2013 & PNG NI 2015 Workers on smallholder plots also need training conducted on 27/10/2015 & adequate training and skills, and this can 28/10/2015 be achieved through extension activities  Regular assessment of training of growers or millers that purchase fruit x Annual training programme needs of all staff, workers, established for Jan to Dec 2015 from them, by smallholders’ smallholders and contract organisations, or through collaboration covering Safety, Field and Technical & workers; with other institutions and organisations Engineering.  Training for workers on (refer to ‘Guidance for Independent x The training was carried out for the Smallholders under Group Certification’, smallholder plots; smallholders at the field. Attendance June 2010, and ‘Guidance on Scheme of the smallholders was recorded. Smallholders’, July 2009)  Documentation of all the For individual smallholder operations, x POL keeps training records of all in- training records should not be required training assessment needs, house and external trainings for their workers, but anyone working on formal training conducted and conducted. Training assessments are the farm should be adequately trained for the list of participants attending done out in the field through the job they are doing (refer to ‘Guidance these formal training; observations of work performance. for Independent Smallholders under Group Certification’, June 2010, and Records of trainings are available at ‘Guidance on Scheme Smallholders’, the POL Training Departments and July 2009). copies at Sustainability department. The formal training on the RSPO P&C was conducted and recorded in the attendance sheet. Example: Training conducted on the RSPO P&C, FFB pricing formula, grievance and other training to smallholders Madak: 2nd Week January 2015: Attended by Katedan, Lavatbura, Lambuso dated on 20/01/2015. Attendant list available. Noatsi 1st week June 2015: Attended by Kama & Kafkaf dated on 23/06/2015. Attendant list available.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min West coast 4th Week August 2015: Attended by Lavolai dated on 27/07/2015 . Attendant list available.

 Does the training for workers

cover, at minimum, to the following:

o The health and x Trainings conducted at POL covers all environmental risks of aspects of RSPO which includes the pesticide exposure; risks of pesticide exposure Awareness training of safe chemical handling, mixing and application procedures and the hazards associated with chemical handling on 09/09/2015/ to 10/1092015 to pesticides operators Smallholder Affair office established training plan to the smallholders for year 2015. Training was carried out to the smallholder’s growers on regular basis. Training was conducted throughout a year. Example Training topic – Fertilizer, Harvesting & Upkeep, Pest & Disease, Roadside clearing and RSPO (Include FFB price formula). o recognition of acute and x Included in above training long-term exposure symptoms including the most vulnerable groups (e.g. young workers, pregnant women);

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min o ways to minimise exposure x Included in above training to workers and their families;

o International and national x Included in above training instruments or regulations that protect workers’ health; and o Productivity and best x POL keeps training records of all in- management practice. house and external trainings Note to auditor: To interview staff, conducted. Training assessments are workers, smallholders and contract done out in the field through workers to verify that the training has observations of work performance. been conducted effectively. Training for smallholders was conducted throughout the year. Example Training topic – Fertilizer, Harvesting & Upkeep, Pest & Disease, Roadside clearing and RSPO (Include FFB price formula). Interviewed of staff, workers and smallholders during field visits. 4.8.2 Records of training for each a. Are training records maintained for Min NC 2 Records of in house trainings employee shall be maintained. each employee? conducted at POL are maintained at respective site. POL training department keeps master records of all in-house and external trainings conducted at HOP. Poliambi mill Training records verified for Emmanuel and Joe ( lab tech) on pond samples analysis dated 06/10/2015 Min NC 2: Madak estate:

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min During document review, it was found the training records for the harvester and loose fruit pickers at Madak estate are not available Principle 5: Environmental Responsibility and Conservation of Natural Resources and Biodiversity a. Has an EIA been conducted Aspects of plantation and mill 5.1.1 (M) An environmental impact x POL has established Environmental 5.1 management, including replanting, assessment (EIA) shall be according to the scope of aspect impact register last updated on that have environmental impacts are documented. operation covering at minimum 10/10/2015. identified, and plans to mitigate the the following: Guidance negative impacts and promote the Aspects include methane gas positive ones are made, emission, chemical spraying, fuel The EIA should cover the following spillage, fire, etc. Significant aspects implemented and monitored, to activities, where they are undertaken: demonstrate continual improvement. were assessed and mitigation controls  Building new roads, processing mills were implemented. or other infrastructure;  Building new roads,  Putting in drainage or irrigation x Included in register for any new processing mills or other development of activities. systems; infrastructure;  Replanting and/or expansion of  Putting in drainage or planting areas; x Plantation development, groundwater irrigation systems;  Management of mill effluents depletion, surface water depletion are (Criterion 4.4); addressed  Clearing of remaining natural  Replanting and/or expansion vegetation; x Plantation development is addressed.  Management of pests and diseased of planting areas; palms by controlled burning (Criteria  Management of mill effluents x POME treatment is addressed. 5.5 and 7.7). (Criterion 4.4);  Clearing of remaining natural Impact assessment can be a non- x Land clearing is addressed. restrictive format e.g. ISO 14001 EMS vegetation; and/or EIA report incorporating elements  Management of pests and spelt out in this Criterion and raised x Integrated pest management is through stakeholder consultation. disease palms by controlled addressed. burning (Criteria 5.5 and 7.7).

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. Has the EIA been conducted and Environmental impacts should be x Covers all aspects of the operations identified on soil and water resources documented according to local according to any local requirements (Criteria 4.3 and 4.4), air quality, requirements? where applicable. greenhouse gases (Criterion 5.6), biodiversity and ecosystems, and c. Does the assessment include x Assessment was conducted with people’s amenity (Criterion 6.1), both on consultation with relevant and off-site. internal stakeholders, eg. mill and stakeholders to identify impacts plantation managers, supervisors and Stakeholder consultation has a key role and to develop any mitigation process owners. in identifying environmental impacts. The measures? inclusion of consultation should result in improved processes to identify impacts and to develop any required mitigation measures. For smallholder schemes, the scheme management has the responsibility to undertake impact assessment and to plan and operate in accordance with the results (refer to ‘Guidance for Independent Smallholders under Group Certification’, June 2010, and ‘Guidance on Scheme Smallholders’, July 2009). a. Is there an environmental 5.1.2 Where the identification of impacts x POL has established Environmental requires changes in current management plan in place? monitoring & management program practices, in order to mitigate version 4 updated on 20/02/ 2015, negative effects, a timetable for b. Is the environmental management

change shall be developed and plan documented to include the implemented within a following: comprehensive management plan.  Identification of responsible The management plan shall x Sustainability manager for identify the responsible person(s); conservation of traditional land use person/persons. areas, field manager for improved training on safe handling and correct disposal of chemicals, etc.  Potential impacts from current x Loss of biodiversity from plantation practices; development, change vegetation balance from groundwater depletion,

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min vegetation in streams from pruning and harvesting, etc.

 Measures to mitigate negative x Measures recorded in Existing impacts; Controls - observe SOPs and NPP, continual monitoring and compliance, supervision & training.  Timetable for change (where x Included in plan and changes as and changes in current practices when required during the monthly are required). review. c. Has the environmental x POL established the KPIs to monitor management plan been the EMMP. implemented? a. Does the plan incorporate a 5.1.3 This plan shall incorporate a x Monitoring established for soil erosion, monitoring protocol, adaptive to monitoring protocol? herbicides, insecticides and fertilizer operational changes, which shall application, chemical storage & be implemented to monitor the handling, bulk fuel storage and effectiveness of the mitigation handling, vehicle workshop, boiler measures. The plan shall be emission, solid organic waste, scrap reviewed as a minimum every two metal & packaging materials, POME, years to reflect the results of etc. monitoring and where there are b. Is the monitoring protocol adaptive x Monitoring protocol will be adjusted operational changes that may have to operational changes? positive and negative accordingly by sustainability environmental impacts. department whenever there are any operational changes. c. Is the monitoring protocol x KPIs monitoring system established to implemented to monitor the monitoring program such as pesticide effectiveness of the mitigation spraying, fertilizer application, waste measures? disposal / discharge, smoke emission from boiler, etc. Sighted – daily smoke density report, water / wastewater analysis, etc.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min d. Is the plan reviewed at a minimum x Plan is reviewed annually by every two years to reflect the results sustainability manager. Last review on of monitoring and where there are 20/02/2015. operational changes that may have positive and negative environmental impacts? a. Has a High Conservation Value 5.2 The status of rare, threatened or 5.2.1 (M) Information shall be collated in x POL has carried HCV assessment for endangered species and other High a High Conservation Value (HCV) (HCV) assessment been conducted existing estates conducted on 17 to Conservation Value habitats, if any, assessment that includes both the and cover the following: 30/04/2011 by A.J.F.M. Dekker that exist in the plantation or that planted area itself and relevant could be affected by plantation or mill wider landscape-level For new areas, Full High Conservation management, shall be identified and considerations (such as wildlife Value Assessment for Proposed operations managed to best ensure corridors). Lamawan and Lamendauen divisions, that they are maintained and/or Namatani District, New Ireland enhanced. Specific Guidance: Province dated 23/10/2013. This information will cover: A summary report of social and environmental impact assessment • Presence of protected areas that dated 18/09/2013. could be significantly affected by the  Presence of protected areas that grower or miller; x IUCN and legal protection status is could be significantly affected by same, no changes. Most species are • Conservation status (e.g. IUCN the grower or miller; categorised as Endangered species. status), legal protection, population status and habitat requirements of However, there is no presence of RTE rare, threatened, or endangered ecosystems identified within POL (RTE) species that could be areas significantly affected by the grower or  Conservation status (e.g. IUCN miller; x There is no presence of RTE status), legal protection, ecosystems identified within POL • Identification of HCV habitats, such population status and habitat areas reported in the HCV as rare and threatened ecosystems, requirements of rare, assessment for existing and new that could be significantly affected by threatened, or endangered areas. the grower or miller; (RTE) species that could be Guidance: significantly affected by the grower or miller.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Identification of HCV habitats, This information gathering should include x Critical temporal use, water checking available biological records and such as rare and threatened catchment, erosion control, and local consultation with relevant government ecosystems, that could be community needs. departments, research institutes and significantly affected by the interested NGOs if appropriate. grower or miller; Depending on the biodiversity values that b. Was the HCV assessment x Guy Williams was RSPO assessor at are present, and the level of available performed by a qualified HCV information, some additional field survey the time of conducting new work may be required. assessor? development assessment. Wherever HCV benefits can be realised A.J.F.M. Dekker was a recognised outside of the management unit, HCV assessor at the time of collaboration and cooperation between conducting the assessment for other growers, governments and existing estates. organisations should be considered. c. Was the HCV assessment x Consultation with relevant performed in consultation with stakeholders, leaseholders, NGOs, relevant stakeholders? government officers conducted on 05/08/2012 with leaseholders in Kavieng, provincial government officers. Consultation neighbouring ward committees in Luburua village and local NGOs in Fangalava village conducted on 06/08/2013 d. Does the HCV assessment include x Biological data consulted for checking of available biological background information and data. records?

e. Does the HCV assessment include x All areas in the broader POL estates both the planted area itself and are covered. relevant wider landscape-level considerations (such as wildlife This includes POL managed estates alongside the smallholder palm oil corridors)? blocks surrounding the formal estate. Areas of intact forest as well as other ecological types (agricultural land, forest, grasslands) adjacent to the

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min POL estate areas were also assessed. Endemic plant and animal species resident in limited geographical ranges and a biologically rich marine environment dominated by fringing coral reefs, closely inter-linked to a range of shoreline habitats including sandy beaches, estuaries, sea-grass beds, mangroves and rocky shores. Assessment on Lamendauen division which covers 225 ha and was a discontinued coconut plantation on state leased land. No primary forests or HCVs or fragile / peat soils in the area. f. Was the HCV assessment x The HCV assessment is conducted performed in accordance to the voluntary on existing planted areas in latest methodology available at accordance to methodology of 5 main global and national level? HCV indicators. g. Are identified HCVs mapped? x Yes. Included in report

a. Are HCVs and/or RTEs present? 5.2.2 (M) Where rare, threatened or x No HCV or RTE identified in the report endangered (RTE) species, or HCVs, are present or are affected b. If HCVs and/or RTEs are present, by plantation or mill operations, x POL established a HCV management has a management plan containing plan dated June 2015 to monitor any appropriate measures that are appropriate measures that are expected to maintain and/or RTEs if exists in the estates and expected to maintain and/or enhance them shall be surrounding areas. implemented through a enhance them been prepared? The management plan. measures should include the following:

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Ensuring that any legal Specific Guidance: x Comply with Fauna (Protection and requirements relating to the Control) (Amendment) Conservation These measures will include: protection of the species or Act 2014. • Ensuring that any legal requirements habitat are met; relating to the protection of the  Avoiding damage to and species or habitat are met; x POL has established Buffer deterioration of HCV habitats • Avoiding damage to and Management Plan guideline version 0 such as by ensuring that HCV deterioration of HCV habitats such as dated 29/04/2011. areas are connected, corridors by ensuring that HCV areas are Buffer zones are established along are conserved, and buffer zones connected, corridors are conserved, streams and creeks within estates around HCV areas are created; and buffer zones around HCV areas areas are created; Signboards put up at respective main • Controlling any illegal or tributary locations and identified as inappropriate hunting, fishing or buffer zone areas collecting activities, and developing  Controlling any illegal or x Warnings and memos sent out. responsible measures to resolve inappropriate hunting, fishing or Warnings issued to employees human-wildlife conflicts (e.g. collecting activities, and making gardens along buffer zones. incursions by elephants). developing responsible Ongoing monitoring conducted by measures to resolve human- respective plantation management to wildlife conflicts (e.g. incursions ensure no employee is creeping into by elephants). the area for hunting or gardening. c. Are the measures contained in the x Monitoring and mitigation measures management plan actively included in the plan and implemented. implemented to maintain and/or enhance HCV values? Sighted quarter internal audits from Madak estate last conducted on 16/10/2015 that includes buffer zones and any reserves areas. d. Are the HCV values and the x Regular site monitoring and presence of RTEs periodically inspections of buffer zones and monitored? reserves areas by sustainability team Buffer Zones inspection conducted during the quarterly audits. Latest records sighted 16/10/2015

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min e. Are the field inspections conducted x Quarterly audit conducted by regularly to ensure implementation Sustainability team. of mitigation plan (especially along areas bordering natural area)? Latest records sighted 16/10/2015 a. Does the company have policies or 5.2.3 There shall be a programme to x POL established a HCV management regularly educate the workforce rules to protect RTE species? plan dated June 2015 to monitor any about the status of these RTE RTEs if exists in the estates and species, and appropriate surrounding areas. disciplinary measures shall be instigated in accordance with POL has a Forest Policy established company rules and national law if POL has a Buffer Management Plan any individual working for the guideline version 0 dated 29/04/2011 company is found to capture, b. Is there a programme to regularly harm, collect or kill these species. x Regular awareness in all POL villages educate the workforce about the including nearby communities, status of the RTE species? schools and smallholder.

c. Is there evidence or action taken to x Quarterly audit conducted by implement the rules and programs? Sustainability team. E.g. Inspections conducted to check no traps/snares put up within or Latest records sighted 16/10/2015 nearby areas. d. Have appropriate disciplinary x No incidents recorded so far. measures been imposed in accordance with company rules and national law, should any individual working for the company is found to have captured, harmed, collected or killed any RTE species? a. Does the management plan contain 5.2.4 Where a management plan has x Quarterly audit conducted by been created there shall be ongoing monitoring of status of HCV Sustainability team. ongoing monitoring: and RTE species that are affected by plantation or mill operations? Latest records sighted 16/10/2015

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  The status of HCV and RTE b. Is the status documented and x Included in report species that are affected by reported? plantation or mill operations shall be documented and c. Are the outcomes of monitoring fed reported; x Included in report back into the management plan?  Outcomes of monitoring shall be fed back into the management plan. a. Is there HCV set-asides with 5.2.5 Where HCV set-asides with x POL has established HCV existing rights of local communities existing rights of local communities? Management Plan. have been identified, there shall be evidence of a negotiated POL recognizes the importance of agreement that optimally these HCVs within New Ireland safeguards both the HCVs and Province area and do not limit or these rights. interfere with traditional land use. Specific Guidance: Areas of HCV importance identified are mostly along the boundaries with For 5.2.5: If a negotiated agreement the local communities where it is cannot be reached, there should be mostly in their land. They all the rights evidence of sustained efforts to achieve access and use the site. such an agreement. These could include b. Who are the affected communities? third party arbitration (see Criteria 2.3, x Communities living in areas adjacent 6.3 and 6.4). to and nearby to the POL area. Note: Most HCVs 3, 4 and 5 identified in the map under HCV Management Plan Operators need to consider a variety of are in the customary areas sharing land management and tenure options to boundaries with POL. secure HCV management areas in ways c. Is the identified HCV areas x Maps provided in the HCV that also secure local peoples’ rights and mapped? livelihoods. Some areas are best Management Plan allocated to community management and secured through customary or legal tenures, in other cases co-management

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min options can be considered. Where d. Is there evidence of stakeholder communities are asked to relinquish x No new developments on customary consultation and negotiated lands. Only one new development at rights so that HCVs can be maintained or agreement, in accordance to FPIC enhanced by the companies or State Lamawan that is on state land. Land principles, with local community to agencies, then great care needs to be title owned by one person and taken to ensure that communities retain optimally safeguard both the HCVs subleased to company. access to adequate land and resources and rights of local communities? FPIC process was conducted. to secure their basic needs; all such e. If a negotiated agreement cannot be x NA relinquishment of rights must be reached, is there evidence of subjected to their free, prior, and sustained efforts to achieve an informed consent (see Criteria 2.2 and 2.3). agreement? Refer to specific guidance for 5.2.5. a. Is there a registry/list of waste 5.3 Waste is reduced, recycled, re-used 5.3.1 (M) All waste products and sources x POL established a summary table of and disposed of in an of pollution shall be identified and products produced? all waste and management options, environmentally and socially documented. app.1 in the Waste Management Plan, responsible manner. issue 2 last updated in Jan 2015.

b. Is there a registry/list of pollution x Sources and types of wastes sources? generating activities listed in section 4 of Waste Management Plan, Example: land clearing, road construction, plantation establishment, maintenance and harvesting, residential compounds, construction & medical waste, vehicle workshop, milling activities, etc. a. Is there an inventory of chemicals 5.3.2 (M) All chemicals and their x Poliamba mill: Inventory records containers shall be disposed of and their containers that are used maintained in Pronto system. Stock responsibly. and kept on site? cards recently implemented. West coast estate: Pesticide stock cards for Li700 surfactant, tri-ester, metalsulfuran and glyphosate.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. How are chemicals and their x Chemicals stored in 20 lit plastic containers stored and disposed off? containers. If unusable, they will be Is it in accordance to best triple rinsed and punctured before practices? (as prescribed by disposal at chemical pit. manufacturers’ labels, local requirement, national or international best practice) c. Are collection and disposal records x Waste disposal register for fertilizer of chemicals and their containers bags and chemical containers. maintained? Sighted record dated 04/09/2015 for 1 empty container, verified by Winnie (sustainability admin officer). a. Is there a documented waste 5.3.3 A waste management and disposal x Waste management plan, issue 2, Jan plan to avoid or reduce pollution management and disposal plan to 2015. shall be documented and avoid or reduce pollution? implemented. b. Does the waste management and  Environment risk register dated x Guidance: disposal plan, at minimum, include 25/10/2015 measures for: The waste management and disposal Waste disposal register. plan should include measures for:  Identifying and monitoring x Summary table of all waste and Identifying and monitoring sources • sources of waste and pollution? management options. Environmental of waste and pollution. monitoring & management program – • Improving the efficiency of resource activity, issue, impact, method, utilisation and recycling potential frequency and responsibility for wastes as nutrients or converting hazardous waste, mill effluent, solid them into value-added products waste, etc  Improving the efficiency of (e.g. through animal feeding x EFB are applied to the field as organic programmes). resource utilisation and recycling fertilizers. • Appropriate management and potential of wastes as nutrients disposal of hazardous chemicals or converting them into value- and their containers. Surplus added products (e.g. through chemical containers should be animal feeding programmes)?  Appropriate management and reused, recycled or disposed of in x Containers adequately labelled to an environmentally and socially disposal of hazardous chemicals indicate content, triple rinsed, reused and their containers? when old punctured and disposed into

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min responsible way using best chemical waste pit at landfill site. available practices (e.g. returned to the vendor or cleaned using a triple rinse method), such that there is no  Reduction, re-use and recycle of risk of contamination of water x Reuse of fertilizer bags and chemical waste? containers, waste oil for tree stump sources or risk to human health. poisoning, EFB / mill waste used as The disposal instructions on the fertilizers. manufacturers’ labels should be c. Is there evidence that the plan has adhered to. x Sighted – empty fruit bunches placed been implemented? at plantations for mulching at nearby estates to mill. d. Is there evidence that waste has not Use of open fire for waste disposal x POL has established a Zero Burning been disposed off using open fire? should be avoided. Statement dated 28/11/2015 signed by the General Manager. No evidence that open fire has been carried out. a. Is there a plan for improving 5.4 Efficiency of fossil fuel use and the 5.4.1 A plan for improving efficiency of x POL has monthly servicing of use of renewable energy is the use of fossil fuels and to efficiency of the use of fossil fuels company fleets and gensets to

optimised. optimise renewable energy shall and to optimise renewable energy? maintain and improve fuel combustion be in place and monitored. efficiency, installation of automatic back pressure control to improve Guidance: steam use efficiency for power Renewable energy use per tonne of generation (June 2016), training & Crude Palm Oil (CPO) or palm product in awareness on energy usage saving at the mill should be monitored. homes / office / clinic and shops. b. Has the plan been implemented and Direct fossil fuel use per tonne of CPO or x Monthly usage of diesel and is it monitored? Fresh Fruit Bunches (FFB) should be renewable energy. monitored. c. Does the monitoring system

Energy efficiency should be taken into encompass the following : account in the construction or upgrading of all operations.  Renewable energy use/tCPO or x Poliamba mill: 19.7 kwh/tFFB for Oct Growers and millers should assess the palm product; 2015, YTD 18 kwh/tFFB. direct energy use of their operations,

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min including fuel and electricity, and energy  Direct fossil fuel use/tCPO or x Poliamba mill: 2.39 lit/tFFB for Oct efficiency of their operations. This should tFFB; include estimation of fuel use by on-site 2015, YTD 2.5. contract workers, including all transport  Estimated fuel use by on-site and machinery operations. x All contractors are inducted at site contract workers and transport upon commencement of services. As The feasibility of collecting and using and machinery operations; part of this the contractor is inducted biogas should be studied if possible. into the company’s policies and requirements, including the management and usage of fuel. GHG emissions included in Palm GHG.  Electricity use in operations. x Electricity use is monitored at all operations as a function of diesel consumption reported by operations. GHG emissions included in Palm GHG. d. Was energy efficiency taken into x No upgrading which affects energy account during the construction or efficiency for the past year upgrading of all operations? e. Has studies on the feasibility of x No at the moment and may be collecting and using biogas been considered when any upgrading of carried out? mill. a. Does the company have a zero 5.5 Use of fire for preparing land or 5.5.1 (M) There shall be no land x Zero burning statement dated replanting is avoided, except in preparation by burning, other than burning policy or any statement on 28/11/15 signed by General Manager. specific situations as identified in the in specific situations as identified in zero burning? ASEAN guidelines or other regional the ‘Guidelines for the best practice. Implementation of the ASEAN b. Does the company have SOPs for x Use of fire for new planting or Policy on Zero Burning’ 2003, or land preparation which mentions replanting for land clearing strictly not comparable guidelines in other zero burning? allowed, as stated in zero burn policy. regions. c. Was land prepared using the burn Guidance: x No indication during onsite inspection method? If yes, was it based on the Fire should be used only where an of new planting and replanting area. specific situations identified in the assessment has demonstrated that it is the most effective and least ‘Guidelines for the Implementation of the ASEAN Policy on Zero

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min environmentally damaging option for Burning’ 2003, or comparable minimising the risk of severe pest and guidelines in other regions? disease outbreaks, and exceptional levels of caution should be required for use of fire on peat. This should be d. Has the policy been implemented subject to regulatory provisions under x Via induction programme and posted respective national environmental throughout the operations? at signboards. legislation.

Extension/training programmes for e. Is there training programmes for associated smallholders may be x Training on RSPO principles & criteria associated smallholders on zero necessary. (including zero burning) to burning where appropriate? smallholders of Lakarumau village dated 13/01/2015, Pinnikidu village on 19/01/2015, Lambuso village dated 19/012015, etc. Smallholder Affair office established training plan to the smallholders growers for year 2015. Training was carried out to the smallholders growers on regular basis.. Training was conducted throughout a year. Example Training topic: Fertilizer, Harvesting & Upkeep, Pest & Disease, Roadside clearing and RSPO (Include FFB price formula and zero burning). Madak estate on 20/01/2015. Attendant list available. Noatsi Estate on 23/06/2015. Attendant list available. West coast estate on 27/07/2015 . Attendant list available.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Where fire has been used for 5.5.2 Where fire has been used for x Zero burning statement dated preparing land for replanting, there preparing land for replanting, is 28/11/15 signed by General Manager. shall be evidence of prior approval there evidence of prior approval of of the controlled burning as the controlled burning as specified No fired used for preparing of land for specified in ‘Guidelines for the in ‘Guidelines for the replanting. Implementation of the ASEAN Implementation of the ASEAN Policy on Zero Burning’ 2003, or Policy on Zero Burning’ 2003, or comparable guidelines in other comparable guidelines in other regions. regions? b. What was the justification for using x NA fire?

5.6 Preamble Growers and millers commit to reporting on operational greenhouse gas emissions. However, it is recognised that these significant emissions cannot be monitored completely or measured accurately with current knowledge and methodology. It is also recognised that it is not always feasible or practical to reduce or minimise these emissions. Growers and millers commit to an implementation period until the end of December 2016 for promoting best practices in reporting to the RSPO, and thereafter to public reporting. Growers and millers make this commitment with the support of all other stakeholder groups of the RSPO. a. Has an assessment of all polluting 5.6 Plans to reduce pollution and 5.6.1 (M) An assessment of all polluting x POL established an aspects and emissions, including greenhouse activities shall be conducted, activities been conducted including impact register updated on gases, are developed, implemented including gaseous emissions, gaseous emissions, particulate/soot 10/10/2015 and monitored. particulate/soot emissions and emissions and effluent (see Assessment on polluted water run-off, effluent (see Criterion 4.4). Criterion 4.4)? exhaust from gen-set and boiler, Guidance: effluent discharge, boiler ash

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min emission, GHG emission from air-con Where practically feasible, operations servicing, emission from vehicles should follow best management practices to measure and reduce emissions. Advice on this is available from the RSPO. b. Is there a documented list of all x Environment risk register dated identified polluting activities 10/10/2015

a. Is there a documented list of all 5.6.2 (M) Significant pollutants and x Environment risk register dated greenhouse gas (GHG) emissions identified significant pollutants and 1010/2015 shall be identified, and plans to GHG emissions? reduce or minimise them b. Are there plans to reduce or x POL established the continuous implemented. minimise the identified pollutants improvement plan revision 5 updated Specific Guidance: and GHG emissions? on 06/11/2015 to monitor on the reduction of GHG emissions and For 5.6.2: Plans will include objectives, identified the pollutants. targets and timelines. These should be c. Do the plans include objectives, responsive to context and any changes x Plans implemented by respective should be justified. targets and timelines for reduction departments are on-going basis as that are responsive to context? defined in the CIP. For 5.6.2 and 5.6.3: The treatment d. Are the plans being implemented? methodology for POME will be recorded. x Plans implemented by respective Was there any changes? Is it departments are on-going basis as justified? defined in the CIP. No changes due to financial constraint. e. Is the treatment methodology for x SOP for POME maintained by Mill POME recorded? (refer to C 4.4.3) including results of regular monitoring. POME treatment, SOP no. POM14, issue 1 last updated in January 2015.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Is there a system in place to monitor 5.6.3 A monitoring system shall be in x Emissions from mill monitored through place, with regular reporting on progress emission of pollutants including DMPR, internal audits/inspections. for these significant pollutants and greenhouse gases from estate Field through site inspections audits. emissions from estate and mill (plantation) and mill operations? operations, using appropriate tools. Poliamba mill daily monitoring of smoke density. Specific Guidance: Sighted smoke density results for Oct For 5.6.3 (GHG): For the implementation 2015. Result average 4%. Target - < period until December 31st 2016, an 20% where smoke density exceeds RSPO-endorsed modified version of Ringelmann 2 (40%). PalmGHG which only includes emissions b. Is there regular reporting of the from operations (including land use x There is ongoing reporting to monitoring outcomes? How often management through regular reports practices) can be used as a monitoring and to whom is reporting done? tool. and monthly sustainability reports. Annually to CEPA through the For 5.6.3: In addition, during the Environmental Performance Report. implementation period, growers will start to assess, monitor and report emissions Monthly data compiled and submitted arising from changes in carbon stocks to sustainability manager. Annual within their operations, using the land environmental performance report use in November 2005 as the baseline. prepared. The implementation period for Indicator Sighted report for 2014 dated 5.6.3 is the same implementation period 09/03/2015 where smoke density for Criterion 7.8. result is average at 18%. c. Is the monitoring and reporting During the implementation period, x Monitoring tools include site reporting on GHG will be to a relevant conducted using appropriate tools? inspections as well as regular internal RSPO working group (composed of all What tool is being used to assess, audits. Mill smoke emissions membership categories) which will use monitor and report on GHG monitored using smoke density the information reported to review and emissions? monitor. Reporting of GHG is using fine tune the tools, emission factors and the GHG calculator toolkit methodologies, and provide additional Please refer to specific guidance for guidance for the process. Public GHG requirements Poliamba mill sighted smoke density reporting is desirable, but remains meter and analyzer transmitter used voluntary until the end of the for smoke emission from boiler. implementation period. During the implementation period the RSPO working group will seek to continually improve PalmGHG,

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min recognising the challenges associated with measuring GHG and carbon stock. PalmGHG or RSPO-endorsed equivalent will be used to assess, monitor and report GHG emissions. Parties seeking to use an alternative to PalmGHG will have to demonstrate its equivalence to the RSPO for endorsement.

Principle 6: Responsible Consideration of Employees and of Individuals and Communities Affected by Growers and Millers a. Has an SIA been conducted? When 6.1 Aspects of plantation and mill 6.1.1 (M) A social impact assessment x SIA was conducted for the current management that have social (SIA) including records of meetings was the last SIA conducted? operations on 27/09/2011 by Booyong impacts, including replanting, are shall be documented. Forest Science (a SIA consulting identified in a participatory way, and company). Guidance: plans to mitigate the negative b. Is the process in conducting the SIA impacts and promote the positive Identification of social impacts should be x The SIA report includes the ones are made, implemented and carried out by the grower with the and the findings documented? methodology and process of the SIA monitored, to demonstrate continual participation of affected parties, including as well as a discussion of the findings improvement. women and migrant workers as for RSPO criteria. appropriate to the situation. The involvement of independent experts c. Does the SIA cover all of the

should be sought where this is potential impact factors, including: considered necessary to ensure that all impacts (both positive and negative) are identified. Participation in this context means that  Access and use rights; x Land use rights and land affected parties are able to express their compensation are included in the SIA views through their own representative report. institutions, or freely chosen spokespersons, during the identification

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min of impacts, reviewing findings and plans  Economic livelihoods (e.g. paid for mitigation, and monitoring the x Payment and working conditions are employment) and working included in the SIA report. success of implemented plans. conditions; Potential social impacts may result from activities such as: building new roads,  Subsistence activities; processing mills or other infrastructure; x Subsistence activities are addressed replanting with different crops or in the report. expansion of planting area; disposal of mill effluents; clearing of remaining natural vegetation; changes in employee numbers or employment terms;  Cultural and religious values; smallholder schemes. x POL has established SIA monitoring plan dated 25/10/2015 version 4 Plantation and mill management may including internal assessment of the have social impacts (positive or negative) cultural and religious values affected on factors such as: by the operations on the communities  Access and use rights; living around the operation sites  Economic livelihoods (e.g. paid  Health and education facilities x Health and education facilities are employment) and working addressed in report conditions;  Subsistence activities;  Cultural and religious values;  Other community values,  Health and education facilities; x The community values are addressed resulting from changes such as  Other community values, in the report improved transport resulting from changes such as /communication or arrival of improved transport substantial migrant labour force. /communication or arrival of substantial migrant labour force.

The review can be done (once every two years) internally or externally.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Does the assessment involve 6.1.2 (M) There shall be evidence that x The communities where the estates the assessment has been done consultation with the affected are located were invited to the with the participation of affected parties? Who are the affected stakeholders’ consultations. parties. parties? Example smallholders, workers, contractors, transporters, labour officer, land owners, local authorities, schools, communities members, etc., b. Is there record of how the x Stakeholders consultation includes the participatory assessment has been feedback from respective conducted? Were the affected stakeholders listed in the report. parties able to express their views through their own representative institutions, or freely chosen spokespersons, during the identification of impacts, review of findings and planning for mitigation? a. Is there any documented record to 6.1.3 (M) Plans for avoidance or x POL has established a social mitigation of negative impacts and outline the plan on mitigation, improvement plan revision 0 dated promotion of the positive ones, and implementation and monitoring 29/04/11 and latest updated version 5 monitoring of impacts identified, according to the SIA report? on 25/10/2015 shall be developed in consultation with the affected parties, The action plan is for year 2013 to documented and timetabled, 2016 b. Have plans for avoidance or including responsibilities for x Impacts are monitored through our implementation. mitigation of negative impacts and internal audits, inspections and site promotion of the positive ones, and visits. monitoring of impacts been Mitigation plans are stated within the developed? Social Improvement Plan c. Have these plans been X Scheduled completion dates are documented, with clear timetables? included within the Social Is the timeline reasonable? Improvement Plan. Timetables or schedules are dependent on budgets.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min d. Have the persons responsible for x Persons responsible for each action implementation of the plans been plan have been identified and stated identified? within the plan. a. Is the plan reviewed every two 6.1.4 The plans shall be reviewed as a x The social improvement plan was last minimum once every two years years? reviewed on 29/10/2015 as revision 5. and updated as necessary, in Revision history is stated in the plan. those cases where the review has b. Has the plan been updated as concluded that changes should be x Updated as and when to the status necessary (i.e. in cases where the and progress of the plans since the made to current practices. There review has concluded that changes shall be evidence that the review document was made on 29/04/2011. should be made to current includes the participation of affected parties. practices)? c. Have the changes to the plan been x Updated as and when to the status implemented? and progress of the plans since the document was made on 29/04/2011. d. Is there evidence that the review x Meeting records available. has been done with the participation of the affected parties? Latest meeting dated 17/10/2015. e. Has the process been recorded / x Meeting records available. documented? Latest meeting dated 17/10/2015 a. Are there schemed smallholders 6.1.5 Particular attention shall be paid to x Smallholders were considered and the impacts of smallholder involved? involved in the SIA process. schemes (where the plantation b. Have they been considered and includes such a scheme). x Smallholders schemes were consulted involved in the whole process of the and interviewed as part of the SIA. SIA? They are included in the SIA report. c. What are the main impacts affecting x Main impacts affecting smallholders these smallholders? include: FFB price, distribution of income between husband and wife. a. Does the company maintain a list of 6.2 There are open and transparent 6.2.1 (M) Consultation and x POL maintains a stakeholders methods for communication and communication procedures shall local communities and other register. consultation between growers and/or be documented. affected or interested parties? millers, local communities and other POL Lands Office keeps a list of affected or interested parties. interested landowner groups.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Guidance: Smallholders Affairs Department maintains a list of all smallholders Decisions that the growers or mills are involved with the company. planning to make should be made clear, so that local communities and other interested parties understand the b. Is there SOP being developed by purpose of the communication and/or x POL has established a communication consultation. the company for communication policy for communicating with internal and consultation between the Communication and consultation and external parties dated 01/20/2015 mechanisms should be designed in company and the local communities signed by the General Manager. collaboration with local communities and and other affected or interested other affected or interested parties. parties? These should consider the use of c. Is the FPIC approach incorporated x POL has established FPIC SOP appropriate existing local mechanisms in the SOP for communication and and languages. Consideration should be revision 001 last reviewed on consultation with the local given to the existence/formation of a 12/11/2015. communities and other affected or multi-stakeholder forum. The FPIC approach has been used to interested parties? Communications should take into communicate and consult with account differential access to information landowners. by women as compared to men, village leaders as compared to day labourers, Records of FPIC awareness and new versus established community communication are available groups, and different ethnic groups. d. Has the SOP been developed x SOP developed includes input for both together with the local communities Consideration should be given to internal and external stakeholders. involving third parties, such as and other affected or interested disinterested community groups, NGOs, parties using appropriate existing or government (or a combination of local mechanisms and in languages these), to facilitate smallholder schemes understood by these parties? and communities, and others as e. Has the SOP been socialized with x See above appropriate, in these communications. the local communities and other affected or interested parties taking Example: Smallholders meeting with into account the differential access OPIC on 15/11/2015 to information by women as compared to men, village leaders as compared to day labourers, new versus established community

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min groups, and different ethnic groups?

f. Have interviews with affected x Stakeholders consultations were parties been carried out to verify conducted during the audit to verify on that the SOPs are effective? the SOP effectiveness. Workers and communities were interviewed during onsite visits. a. Who in the company is appointed to 6.2.2 A management official responsible x POL sustainability & lands office is for these issues shall be be responsible for communication responsible for communication and nominated. and consultation with the affected consultation with indigenous peoples parties? particularly in regards to land matters. POL Smallholders Affairs Department are responsible for communication and consultation with smallholders. b. Has the position been made official x Sustainability department are with clear and proper job responsible in communicating and description? consulting with affected parties. c. Have the affected parties been x Affected parties and their made aware and have access to the representatives are aware and have person in charge? access to the person in charge of consulting and communicating with them. Sustainability Manager participates in field visits to inform the communities of the access. a. Is the following maintained? 6.2.3 A list of stakeholders, records of all communication, including

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min confirmation of receipt and that  List of stakeholders (local efforts are made to ensure x POL maintains a stakeholder register communities and other affected last updated on 30/08/2015 understanding by affected parties, or interested parties etc.); and records of actions taken in  Records of all communication, response to input from x Records of communication with stakeholders, shall be maintained. including confirmation of receipt stakeholders are available in file. or endorsement; Each respective POL estates keep records of communication with stakeholders.  Evidence that efforts have been x Communication records with made to ensure understanding stakeholders are kept in file. by affected parties; For Landowner communication records refer to FPIC document.  Record of actions taken in x Each respective POL operating sites response to input from has records of actions taken in stakeholders. response to input taken from stakeholders. a. Is there a system in place to deal 6.3 There is a mutually agreed and 6.3.1 (M) The system, open to all x POL has established a grievance / with complaints and grievances for documented system for dealing with affected parties, shall resolve complaint procedure dated complaints and grievances, which is disputes in an effective, timely and all affected parties? 01/10/2015 signed by the General implemented and accepted by all appropriate manner, ensuring Manager affected parties. anonymity of complainants and b. Who in the company is responsible whistle-blowers, where requested. x The Master Register for complaints to receive complaints and and grievances is kept and updated Specific Guidance: grievances? within the Sustainability Department. For 6.3.1: The system should aim to Each department / site has their own reduce the risks of reprisal. grievance register available Guidance: Sighted complaint and grievance record book at HR department See also to Criterion 1.2. c. Is the existence of the system been x POL grievance procedure is displayed Dispute resolution mechanisms should made known and communicated to on notice boards at all operating sites. be established through open and all parties? It also communicated at each consensual agreements with relevant respective sites through morning affected parties. musters and tool box talks.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Complaints should be dealt with by Sighted training records smallholders mechanisms such as Joint Consultative on the RSPO P& C covers on the Committees (JCC), with gender complaint and grievance. representation as necessary. Grievances d. Is there evidence that the system is may be internal (employees) or external. x Interview of workers, staff and understood by all parties? smallholders and found they For scheme and independent understood the grievance SOP. smallholders, refer to ‘Guidance for Independent Smallholders under Group Smallholder Affair office established Certification’, June 2010, and ‘Guidance training plan to the smallholders for on Scheme Smallholders’, July 2009. year 2015. Where a resolution is not found mutually, Training was carried out to the complaints can be brought to the smallholders on regular basis. attention of the RSPO Complaints e. Is training provided to the workers System. x The procedure is communicated at on the procedures/systems? each POL sites and records Refer to helpful texts for guidance, such maintained as the Human Rights Commission (HRC) endorsed ‘Guiding Principles on SOP training conducted on Business and Human Rights: 16/01/2015 f. Is the system effective to ensure Implementing the UN "Protect, Respect x The procedure is communicated at and Remedy" Framework’, 2011. that complaints or grievances are each POL sites and records addressed or resolved in an maintained effective, timely and appropriate West coast estate: Grievances will be manner? reported using the SHEQ001 incident report. Latest report no. 031 dated 27/10/2015 for domestic rubbish everywhere. Report no. 029 dated 18/08/2015 for employees without PPE (gumboots). Corrective actions taken and recorded. g. Does the mechanism or procedure x Each site has a Sustainability provide a way for workers to report Representative who is responsible for a grievance against a supervisor to registering grievances within their

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min someone other than the supervisor? department or operating site. Complainants who wish to report a grievance against their supervisor can report to the Sustainability Representative or they can report directly to the HR department or Sustainability Department. h. How is a complaint or grievance x If the grievances can be resolved at investigated, addressed and the site at which it was reported, then resolved? Are complaints dealt with it is resolved at that level. However, if by mechanisms such as JCC? the grievance requires resolution at management level or another department, it is forwarded to the relevant department to resolve. The investigation office carries out investigations where needed. i. Is there a non-retaliation or non- x POL adopted the group corporate reprisal policy that protects whistleblower policy which protects complainants or whistle-blowers? complainants. j. Is the privacy of parties protected? x Refer Whistleblower Policy

k. Where a resolution is not found x Where a complaint is not mutually mutually, is there a process for resolved, the complainant can seek complaints to be brought to the further assistance with local RSPO Complaints System? authorities and to RSPO complaint system. a. Is the complaint or grievance 6.3.2 (M) Documentation of both the x POL has a complaints and grievance process by which a dispute was resolution process documented? register with records of the grievances resolved and the outcome shall be and evidence of decisions made. available. The register was reviewed during onsite audits of estates, mills, smallholders’ affairs office, HR department and sustainability

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min department.

b. Are outcomes or decisions reported x Decisions made are reported back to to the parties? the parties through formal letters or verbal notification to the complainants. c. Who has access to the x Records of resolution is kept with the documentation of the process Department in which the grievance and/or outcomes? was resolved (usually the HR department) and copies given to the Sustainability department and the site / department who registered the complaint. a. Are procedures for identifying legal, 6.4 Any negotiations concerning 6.4.1 (M) A procedure for identifying x POL adopted the Management compensation for loss of legal, legal, customary or user rights, and customary or user rights in place? guideline 21 revision September 2012

customary or user rights are dealt a procedure for identifying people (MG21). Identification of legal, with through a documented system entitled to compensation, shall be customary or user rights are done that enables indigenous peoples, in place. through identification of genealogy local communities and other and family trees of land groups. These stakeholders to express their views Guidance: processes are government processes through their own representative This criterion should be considered in outlined in the Incorporated Land institutions. conjunction with Criteria 2.2 and 2.3, and Groups Guidelines. the associated Guidance. b. Are procedures for identifying x MG21 and Incorporated Land Groups people entitled to compensation in Guidelines revised edition September place? 2012. c. Are those procedures jointly x Procedures for identifying legal, developed, agreed and accepted by customary and user rights are done in local communities? consultation with indigenous people/ local communities. a. Has a procedure for calculating and 6.4.2 A procedure for calculating and x POL adopts MG21 for any distributing fair compensation distributing fair compensation compensation payment. However, (monetary or otherwise) shall be (monetary or otherwise) been there are no ILGs in POL. POL has established and implemented, established and implemented? only leases directly leased from the monitored and evaluated in a state and 4 subleases where state

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min participatory way, and corrective tittles owned by individuals. actions taken as a result of this evaluation. This procedure shall take into account: gender b. Are the procedures jointly differences in the power to claim x The compensation scheme is well rights, ownership and access to developed, agreed, accepted and understood and accepted by affected land; differences of transmigrants clearly understood by affected parties and long-established communities; parties? and differences in ethnic groups’ c. Is the procedure monitored and x POL adopts MG21 for any proof of legal versus communal evaluated in a participatory way? ownership of land. compensation payment. However, Have corrective actions been taken there are no ILGs in POL. POL has Specific Guidance: as a result of this evaluation? only leases directly leased from the For 6.4.2: Companies should make best state and 4 subleases where state efforts to ensure that equal opportunities tittles owned by individuals. d. Does this procedure take into have been provided to both female and male heads of households to hold land account the following: titles in smallholder schemes.  Gender differences in the power x Customary land in PNG is either to claim rights; owned by male or female based on different societies or clans. Ownership and access to land is based on local traditional clan systems.  Ownership and access to land x Customary land in PNG is generally owned by the women. Ownership and access to land is based on local traditional clan customers.  Differences of transmigrants and x PNG government provide land long-established communities; settlement scheme for transmigrants and customary land for natives. However there are no LSS schemes established in New Ireland Province based on the interview with the local provincial President.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Differences in ethnic groups’ x The land right issued by the land proof of legal versus communal office is proof of legal ownership by ownership of land. ethnic group. e. Where there are schemed x There are no scheme smallholders at smallholders, is there effort to POL operating sites. ensure equal opportunity has been provided to Therefore not applicable.

a. Is the process and outcome of 6.4.3 (M) The process and outcome of x Copies of negotiated agreements and any negotiated agreements and negotiated agreements and compensations claims are available compensation claims shall be compensation claims documented? with the POL lands office. documented, with evidence of the participation of affected parties, Sighted agreement signed. b. Does this documentation include and made publicly available. x Land mediation records are available evidence of the participation of with the POL lands office. affected parties? Is there any approval/signed by effected parties? c. Was consent obtained from all x Documents are publicly available parties to make the documents upon request if consent is obtained publicly available? from all affected parties. a. What types of employment 6.5 Pay and conditions for employees 6.5.1 (M) Documentation of pay and x Expatriate Staff, Contractors, and for contract workers always meet conditions shall be available. arrangements are there in the Seasonal l / casual workers, National

at least legal or industry minimum company? (E.g. contractual, Executive Staff, Junior Staff, General standards and are sufficient to outsourced, apprenticeships, direct workers, Apprentice / cadets Staff. provide decent living wages. hires, piecemeal basis, etc.) Information on employment arrangements are available with the Human Resources Department. b. Is there documentation of pay and x Records are available with Finance conditions for each employee? and Human Resources Departments. Pay slip was sighted.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min c. Is there a definition for living wage x Minimum wage is determined by in the country? If not, how was the Department of Labour and Industrial decision on wage for employees Relations.. and contract workers made? POL has obtained approved decision from the Department of Labour and Industrial Relations for a minimum hourly rate of K2.50/hour for 44 hours week cash that excludes benefits such as medical, housing and electricity. The minimum wage of K2.50/hr is well above the 2nd phase of mandated reduced cash wage of K1/68/hour as required by Clause 6 of the Minimum Wage Determination. Based on review of the pay slip and the table of wage for each scale of workers , it was evident the worker’s wage is above the minimum wages of K1.68/hr. a. Is the pay and conditions of 6.5.2 (M) Labour laws, union agreements x A General policies and regulations or direct contracts of employment employment clearly detailed in the handbook that covers the recruitment detailing payments and conditions employment or service contracts? of non-executives and workers. In the of employment (e.g. working hours, (E.g. working hours, deductions, handbook it has listed down the terms deductions, overtime, sickness, overtime, sickness, holiday and conditions in hiring. holiday entitlement, maternity entitlement, maternity leave, The workers minimum wage is K2.50 leave, reasons for dismissal, reasons for dismissal, period of period of notice, etc.) shall be per hour for 44 hours week which notice, etc.) available in the languages excludes allowances. understood by the workers or The benefits provided to the workers explained carefully to them by a are housing, free water, electricity, management official. medical, paid sick leave, children education, workers insurance compensation, etc. This can be verified through contractual agreement records

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min available at the HR department.

b. Is the contract prepared in x Records of employee contracts and languages understood by the inductions are available with the HR workers, explained carefully to department workers by management officials, In both Pidgin and English fully and signed by both the authorised understood by workers and signed by signatory of the company and both parties employee? c. Does the pay and conditions

provided in labour laws, union agreements or direct contracts of employment comply with:  The decent living wage as x The workers minimum wage is K2.50 provided in the National per hour for a 44 hour week excluding Interpretation for the country; or allowances. The benefits provided to the workers are free housing, water, electricity, medical, paid sick leave, children education, workers insurance compensation, etc.  The local legal requirements in x The minimum cash wage approved by meeting the minimum wage; or the Department of Labour and Industrial Relations is K1.68/hr for 44 hours per week.  The industry minimum standard x The minimum living wages for workers for a similar position or work in PNG according to Department of responsibilities. Labour and Industrial Relations is K3.20/hour for 44 hours week that includes basic and benefits such as medical, housing and electricity. Based on review of the pay slip, it was

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min shown the worker’s wage is above the minimum wages of K3.20/hr. With the additional benefits amounting to K2.18 is added to the minimum wage of K2.50, the wage will be K4.68 which is higher than K3.20/hour for 44 hours week. d. Is the pay received by the employee x According the PNG labour law, all consistent with the terms of the workers shall be paid fortnightly. contract and the law (relates to P2)? Workers confirmed they received wages every fortnight. Evident records have been verified at HR department. e. Have there been any cases x No records of complaints and recorded of breach by the company, grievances regarding pay conditions or complaint made by employees during document review at HR against the company on unjust pay department and conditions? No evidence of complaints during interview of workers a. Have growers and millers provided 6.5.3 Growers and millers shall provide x Employee benefits include housing, adequate housing, water supplies, adequate housing and other basic free electricity and water supply, and medical, educational and welfare necessities such as that listed free health care facilities. Education amenities to national standards or below to national standards or facilities are also located within or above, where no such public above, where no such public nearby POL villages. This was verified facilities are available or facilities are available or with the HR Department. accessible. accessible?  adequate housing; x Workers and staff are provided with housing at each work site. Housing was inspected.  adequate electricity; x Electricity is provided

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  clean water supplies (availability x Provide all year round of clear water all year round);

 medical services (distance to x A clinic is available to provide medical health care facility i.e. clinic, services. hospital); Serious injury or serious illness will be referred to main clinic at the head office clinic.  children education (distance to x Free education is provided to workers school and schooling children up to grade 6. attendance (%) of children under 12)  welfare amenities. x Free transport to town, village market, sports facilities.

a. Have growers and millers made 6.5.4 Growers and millers shall make x Village market is setup at the workers demonstrable efforts to monitor demonstrable efforts to monitor and housing compound. and improve workers’ access to improve workers’ access to adequate, sufficient and affordable adequate, sufficient and affordable Assigned locations within the estates as vegetable gardens. food. food? Visited a convenient store setup at Lakuramau division during site visits. a. Has the company published a 6.6 The employer respects the rights of 6.6.1 (M) A published statement in local x POL has established Employee Rights all personnel to form and join trade languages recognising freedom of statement in local languages & Equal Employment Opportunity unions of their choice and to bargain association shall be available. recognising the rights of employees (EEO) Policy revised on 01/10/2015 collectively. Where the right to to freedom of association? includes a statement the right of all Guidance: freedom of association and collective personnel to form and join trade bargaining are restricted under law, The right of employees, including migrant unions of their choice and to bargain the employer facilitates parallel collectively.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min means of independent and free and transmigrant workers and contract b. Are the employees, including association and bargaining for all workers, to form associations and x All employees are allowed to form migrant and transmigrant workers associations provided is restricted such personnel. bargain collectively with their employer and contract workers, allowed to should be respected, in accordance with under any law. form associations and bargain Conventions 87 and 98 of the However, there is no workers union collectively with their employer? International Labour Organisation (ILO). formed at POL. c. Was the outcome, if any, from the Labour laws and union agreements, or in x The company established regular their absence direct contracts of collective bargaining process meetings and support union activities. employment detailing payments and between the company and the other conditions, should be available in association respected, implemented The latest union meeting held between management and union was the languages understood by the and adopted in full or partially by the n 10/10/2015 & 11/10/2015 to re- workers or explained carefully to them by company? a management official. activate the union. d. Are there Labour laws and union x Payments of wages are made in agreements, or in their absence English fully understood by the direct contracts of employment workers. detailing payments and other conditions, made available in the languages understood by the workers or explained carefully to them by a management official? a. Are there documented minutes of 6.6.2 Minutes of meetings with main x The latest union meeting held trade unions or workers meetings between the company and between management and union was representatives shall be main trade unions or workers n 10/10/2015 & 11/10/2015 to re- documented. representatives? activate the union. b. Are the minutes made readily x Refer above (a) available to employees upon request?

a. Is the minimum working age for 6.7 Children are not employed or 6.7.1 (M) There shall be documentary x Minimum age is 16 years. Working exploited. evidence that minimum age workers together with working hours hours 5.30am to 2.30pm daily This is

requirements are met. clearly defined in the company’s included in employment handbook. recruitment policy? Guidance:

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. Are workers employed above the Growers and millers should clearly define x All workers employed are above the the minimum working age, together with minimum school leaving age of the age of 18 years working hours. Only workers above the country or who are at least 15 years minimum school leaving age in the of age? country or who are at least 15 years old may be employed. The minimum age of c. Is there evidence that the nature of workers will not be less than stated under x No workers are employed under the national regulations. Any hazardous work work for workers under 18 is in age of 18 years. should not be done by those under 18, accordance with International as per International Labour Organisation Labour Organisation (ILO) Review of workers employment records (ILO) Convention 138. Convention 138? d. Does ground verification show Please refer to ‘Guidance for x Workers employment records last Independent Smallholders under Group evidence of employment of workers update on October 2015 Certification’, June 2010, and ‘Guidance below the minimum working age? on Scheme Smallholders’, July 2009for additional guidance on family farms. a. Is there a company policy on non- 6.8 Any form of discrimination based on 6.8.1 (M) A publicly available equal x Employee Rights & Equal Opportunity race, caste, national origin, religion, opportunities policy including discrimination and equal Policy last review October 2015

disability, gender, sexual orientation, identification of relevant/affected opportunities? Does it at least cover signed by General Manager union membership, political groups in the local environment the items mentioned in the criteria affiliation, or age, is prohibited. shall be documented. (6.8)? b. Is the policy made publicly available Guidance: x The Equal Employment Opportunity for the relevant stakeholders? Examples of compliance can be Policy is a publicly available appropriate documentation (e.g. job document. It is also displayed on advertisements, job descriptions, notice boards at all POL sites. appraisals, etc.), and/or information c. Is there evidence that the policy has x POL employs both male and female obtained via interviews with relevant been implemented? stakeholders such as affected groups workers, expatriates and locals. which may include women, local This was verified with recruitment communities, foreign workers, and records at the Human Resources migrant workers, etc. Department. Notwithstanding national legislation and regulation, medical conditions should not be used in a discriminatory way. The grievance procedures detailed in

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Criterion 6.3 apply. Positive discrimination to provide employment and benefits to specific communities is acceptable as part of negotiated agreements.

a. Is there evidence that employees 6.8.2 (M) Evidence shall be provided that x Workers are interviewed and and groups including local employees and groups including stakeholders consultation meeting local communities, women, and communities, women, and migrant was held and could confirm no migrant workers have not been workers have not been discrimination against women and discriminated against. discriminated against? local communities by the company. b. Are the employees and groups x By means of workers interview and including local communities, local communities, the company has women, and migrant workers happy treated the workers and communities with the way the company is fairly. treating them? Request from communities are generally provided. c. Are there complaints against the x By means of interviewing workers and company on issues relating to staff and from the stakeholders discrimination? consultation, the company has not breached the Employee Rights & Equal Opportunity Policy established d. What is the nature of complaints x The grievance compliant book was employees and groups including reviewed and no evidences of local communities, women, and complaint against the company being migrant workers have lodged lodged. against the company, if any? a. Does the company keep and 6.8.3 It shall be demonstrated that x At the main clinic and HR department. recruitment selection, hiring and maintain a record of their promotion are based on skills, employees’ work credentials and POL HR Department keeps the files of capabilities, qualities, and medical medical history? all its employees which include credentials and medical history.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min fitness necessary for the jobs b. Does the company explicitly state available. x Recruitment procedures and records the indiscriminatory policy during are available with the HR Department. the recruitment selection, hiring and promotion process? Included in induction form. POL Employee Rights & Equal Employment Opportunities Policy includes discrimination based on any grounds in recruitment, dismissal or promotion is strictly banned. c. Is the company’s indiscriminatory x As and when required. The latest policy reviewed regularly? revision was on 01/10/2015 d. Are the company’s employees x Recruitment procedures and records recruited and promoted based on are available with the HR Department. skills, capabilities, qualities, and medical fitness necessary for the Where job opportunities arises, local are promoted. job? How is this evidenced? POL General Manager Mr. Roland Soupa is the 1st local appointed as General Manager. a. Does the company have the policy 6.9 There is no harassment or abuse in 6.9.1 (M) A policy to prevent sexual and x POL has established sexual the work place, and reproductive all other forms of harassment and to prohibit any form of sexual and all harassment policy last revised on

rights are protected. violence shall be implemented and other forms of harassment and 01/20/2015 signed by the General communicated to all levels of the violence? Manager. workforce. Policy includes any forms of violence Specific Guidance: b. Has this policy been documented, x The policy is explained to the staff, implemented and communicated For 6.9.1 and 6.9.2: These policies workers and dependents during should include education for women and clearly to all levels of the workforce? sexual harassment awareness awareness of the workforce. There campaign and publicly available at should be programmes provided for notice boards in all work sites. particular issues faced by women, such c. Is there a clear protocol for the as violence and sexual harassment in the x POL has established a grievance company to deal/handle such procedure last revised on 01/10/2015 workplace. A gender committee issues/complaints received from the specifically to address areas of concern in which complainants can follow to workforce? report such case.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min to women will be used to comply with this d. Is there a list of awareness Criterion. This committee, which should x An awareness program for Domestic programs or training provided to the Violence and Sexual Harassment was include representatives from all areas of workforce in relation to these work, will consider matters such as: carried out in January at company issues? training on women’s rights; counselling villages this year. for women affected by violence; child Report on this awareness is available care facilities to be provided by the in file. growers and millers; women to be allowed to breastfeed up to nine months During induction of workers and before resuming chemical spraying or regular trainings and toolbox talk. e. Has the company formed a Gender usage tasks; and women to be given x POL has established a Gender specific break times to enable effective Committee to address areas of Committee that include the list of breastfeeding. concern to women? Is there a list of member and TOR Guidance: the members sitting in the committee? What are the Terms of There should be a clear policy developed Reference of the committee? Does in consultation with employees, contract it include the handling of issues workers and other relevant stakeholders, and the policy should be publicly such as:  training on women’s rights; available. Progress in implementing the x During induction and toolbox briefing policy should be regularly monitored, and the results of monitoring activities should  counselling for women affected be recorded. x POL HR and Sustainability office by violence; provides counselling. Notwithstanding national legislation and  child care facilities to be regulation, reproductive rights are x POL does not has childcare facilities, respected. provided by the growers and however, has a number of schools millers; within its premises beginning from elementary..  women to be allowed to x POL has established Pregnant and breastfeed up to nine months Breast Feeding Mothers Policy dated before resuming chemical 29/11/2015 signed by the General spraying or usage tasks; and Manager that does not allow breastfeeding women to work with pesticides or fertilizer.  women to be given specific x POL has established a Nursing break times to enable effective Mothers Policy dated 29/11/2015 breastfeeding. signed by General Manager that

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min women to be given specific break times to enable effective breastfeeding.

f. Is the policy regularly reviewed? x As and when required. Last reviewed in 29/11/2015

a. Is there a policy to protect the 6.9.2 (M) A policy to protect the x Refer Pregnant and Breast Feeding reproductive rights of all, especially reproductive rights of all, especially Mothers Policy of women, shall be implemented of women? and communicated to all levels of the workforce. b. Has this policy been documented, x Yes, it is communicated through Specific Guidance: implemented and communicated morning musters and displayed at the clearly to all levels of the workforce? For 6.9.2: see Indicator 4.6.12. main public notice boards. Guidance: c. How is this policy communicated to x During morning musters and Notwithstanding national legislation and all levels of the workforce? displayed on the notice boards regulation, reproductive rights are respected. a. Does the company have a 6.9.3 A specific grievance mechanism x POL has established a Whistleblower which respects anonymity and mechanism to handle employment Policy which commits protecting the protects complainants where grievances, that respects anonymity identity of genuine whistleblowers. requested shall be established, and protects complainants where implemented, and communicated requested? to all levels of the workforce. b. Does the mechanism provide a way x The policy states, if a whistleblower for workers to report a grievance finds his/her immediate manager or against a supervisor to someone supervisor to be involved with other than that supervisor? improper conduct, they are to report to the company secretary. c. Is the mechanism documented, x The policy is documented and implemented and communicated communicated to all levels of the clearly to all levels of the workforce? workforce. Records of communication are kept

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min with each respective POL operating sites. d. Has the company identified x The Whistleblower Policy identifies the personnel who will be responsible to NBPOL company secretary as the receive and manage complaints personnel responsible to receive and received from the workforce? manage such complaints. e. Has the company received any x If any harassment or abuse should reports or complaints of harassment occur, complaints are addressed by or abuse? How was it addressed or the POL HR Department through its resolved? disciplinary policy and procedure. f. Is the policy reviewed regularly? x Reviewed annually by Sustainability Department and GM a. How is the price of FFB 6.10 Growers and millers deal fairly and 6.10.1 Current and past prices paid for x The FFB price formula has been given transparently with smallholders and Fresh Fruit Bunches (FFB) shall be determined? to all the smallholders. other local businesses. publicly available. Payslip will be the references against Guidance: the FFB price formula. b. Is current and past prices paid for Transactions with smallholders should x The FFB price formula has been consider issues such as the role of Fresh Fruit Bunches (FFB) publicly explained to the smallholders by middle men, transport and storage of available? How? conducting field training for all the FFB, quality and grading. The need to areas. Training was conducted recycle the nutrients in FFB (see throughout a year. Criterion 4.2) should also be considered; where it is not practicable to recycle Example: wastes to smallholders, compensation for Training topic – Fertilizer, Harvesting the value of the nutrients exported can & Upkeep, Pest & Disease, Roadside be made through the FFB price. clearing and RSPO (Include FFB price Smallholders should have access to the formula). grievance procedure under Criterion 6.3 Madak training on 20/01/2015 if they consider that they are not Attendance list verified receiving a fair price for FFB, whether or not middle men are involved. Noatsi training on 23/05/2015. Attendance list verified The need for a fair and transparent West coast training on 27/07/2015.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min pricing mechanism is particularly Attendance list verified important for outgrowers who are contractually obliged to sell all FFB to a particular mill. If mills require smallholders to change c. Was there any complaints on FFB practices to meet the RSPO Principles x No complaint on FFB pricing formula and Criteria, consideration should be pricing? given to the costs of such changes, and d. How was the complaint handled? the possibility of advance payments for x Continuous financial training to FFB can be considered. smallholders jointly with OPIC. Training conducted on 09/08/2015, 16/10/2015 e. What was the solution? x Continuous briefing to smallholders and provide financial training to them. a. What is the mode of 6.10.2 (M) Evidence shall be available x Transactions are documented through that growers/millers have recording/documenting transactions pay slips. Smallholders pay summary explained FFB pricing, and pricing between millers with middlemen reports are also available with the mechanisms for FFB and and/or smallholders? POL Smallholders Dept. inputs/services shall be b. Is there evidence that documented (where these are x FFB pricing mechanism under the control of the mill or growers/millers have explained FFB communication records are available. plantation). pricing and pricing mechanisms for FFB? The FFB price formula has been explained to the smallholders by conducting field training for all the division. Example: Training price formula at Training Centre on 09/08/2015 &16/10/2015 Attendance list verified.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min c. Are there any inputs/services x Transport that will influence the FFB rendered by the millers to pricing smallholders/middle men? Are these inputs/services having any influence to the pricing and pricing mechanisms for FFB? d. Have inputs/services been x A Memorandum of Understanding is documented (where these are signed between the smallholder and under the control of the mill or POL. plantation)? Available in the respective smallholders files. e. Where it is not practicable to x POL pays only for FFBs. The waste smallholders to recycle waste (i.e. (EFB) is POL responsibility to EFB), is there compensation for the manage. It does not affect FFB value of the nutrients of EFB given pricing. to the smallholders? Is this Not practical to recycle EFB to translated into the pricing factors of smallholders. The price of FFB FFB? includes under and over ripe fruits. No deduction for usage of EFBs and under or over ripe fruits. a. Is there a contractual agreement 6.10.3 Evidence shall be available that x Contract agreements are between all parties understand the between the miller and POL and smallholders. contractual agreements they enter smallholders/ middle men? into, and that contracts are fair, These are available with the POL legal and transparent. Smallholders Affairs Department. MoU between smallholders and POL sighted b. Do all parties understand the x Mutually agreed between POL and contractual agreements they have smallholders. entered into? Contracts are signed after an agreement between both parties c. Are all contractual agreements fair, x All POL contracts are fair, legal and legal and transparent? done in consultation with the

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min concerned party.

d. Who keeps the contractual x POL keeps the contract agreements agreements? copies are provided and kept with smallholders. a. How are all payments made to the 6.10.4 Agreed payments shall be made x Payments are made through their in a timely manner. smallholders/middle men? nominated bank accounts. Payment to smallholders has been made through the bank and issuing cheque for those doesn’t have bank account. The payment will be paid fortnightly. b. What is the mode of recording / x Transactions are recorded through documenting transactions between payment summary reports. millers with middlemen and/or smallholders? The smallholders will receive payslip from the smallholder office. Finance department managed all the payment made to smallholders. c. Have agreed payments been made x Payments are done in a timely in a timely manner? manner. The payments paid to smallholders are fortnightly. a. Have the local development needs 6.11 Growers and millers contribute to 6.11.1 Contributions to local x Written request from local local sustainable development where development that are based on the and priorities been identified in communities were handled by the appropriate. results of consultation with local consultation with local General Manager directly. communities shall be communities? (refer also to C 6.2) demonstrated. Sighted records kept by General Manager on request for water supplies Guidance: by communities hereby to Lakurumau division.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. What are the contributions made to Contributions to local development x POL maintains all roads and bridges should be based on the results of local development? Are they in within and around its operations. consultation with local communities. See accordance with the results of also Criterion 6.2. Such consultation consultation? Free health care is available to should be based on the principles of surrounding communities at POL transparency, openness and clinics. participation, and should encourage Surrounding communities have communities to identify their own access to schools within the POL priorities and needs, including the estates. different needs of men and women. c. Are there efforts to improve or x POL prioritises employment of Where candidates for employment are of maximise employment opportunities indigenous people. equal merit, preference should always be at the company for local given to members of local communities. communities? Example local employed as HODs: Positive discrimination should not be Sustainability Manager, Human recognised as conflicting with Criterion Resource Manager and TSD 6.8. Manager. Efforts should be made to identify independent smallholders in the supply base. Where sourcing of fruit is from identified independent smallholders, efforts should be made to contribute to the improvement of their farming practices. a. Is there a complete registry of 6.11.2 Where there are scheme x POL Smallholders Affairs Department smallholders, there shall be independent smallholders in the maintains a complete list of all evidence that efforts and/or supply base? smallholders. resources have been allocated to b. Have efforts been made to improve improve smallholder productivity. x Training is conducted by OPIC and the farming practices of POL Smallholders Affairs Department independent smallholders? to improve smallholders farming practices. Fertilisers are issued to smallholders by POL to improve production c. Where there are schemed x POL has a rehabilitation scheme smallholders, have efforts and/or where smallholders blocks are resources been allocated to

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min improve smallholder productivity? rehabilitated to a more productive state and then given back to the block holder to manage. Sighted Local Planning Committee meeting organised by OPIC on 25/11/2015. a. What is the company’s policy on 6.12 No forms of forced or trafficked 6.12.1 (M) There shall be evidence that x  POL established Recruitment General forced or trafficked labour? labour are used. no forms of forced or trafficked Statement 2015 signed by GM labour are used. strongly prohibited forced or trafficked

labour. Specific Guidance: (Forced labour refers to situations in b. How does the company define x POL defines forced labour as serious which persons are coerced to work For 6.12.1: Workers should enter into forced or trafficked labour? violation of human rights can be of through the use of violence or employment voluntarily and freely, such nature as forced employment of intimidation, or by more subtle without the threat of a penalty, and under age children, ill treatment of means such as accumulated debt, should have the freedom to terminate workers and underpaying them, retention of identity papers or threats employment without penalty given abuse and harassment of workers in of denunciation to immigration reasonable notice or as per agreement. the worked, sexual slavery in the work authorities) Guidance place. c. What is the process of recruiting Migrant workers should be legalised, and x There are no immigrant workers. All foreign/ migrant workers directly a separate employment agreement workers are PNG citizens. should be drawn up to meet immigration and/or through licenced outsourcing By means of document review, no requirements for foreign workers and agencies/ labour suppliers? foreign labours were recruited for international standards. Any deductions estates and mills operations. made should not jeopardise a decent d. Who is the person responsible for living wage. x No foreign labour. Therefore not selecting/ screening labour applicable. Passports should only be voluntarily suppliers/ outsourcing agents? surrendered. e. Do the foreign workers have to pay There should be evidence of due x No foreign labour. Therefore not diligence in applying this to all sub- a fee to the employment recruitment applicable contract workers and suppliers. agency or labour suppliers in the National guidance should be used on workers’ countries of origin? If yes, contract substitution. does it jeopardise decent living wage?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min f. Are there restrictions on workers x No restrictions. from leaving the mill or estate or their housing facilities outside Workers and staff were interviewed. working hours? g. What is the process if a worker x No foreign labour. Therefore not wants to terminate their applicable employment before their contract expires? In this case, who pays for the return transportation? h. What are the penalties imposed if x No foreign labour. Therefore not the workers were terminated or fired applicable before their contract expires?

i. Who keeps the workers passports x No foreign labour. Therefore not or identity documents? applicable

j. If workers do not keep their x No foreign labour. Therefore not passports or identity documents, is applicable this legally allowed?

k. What is the process for workers’ to x No foreign labour. Therefore not hand over their passports or identity applicable documents to the company?

l. Do workers have unrestricted x No foreign labour. Therefore not access to their passports or identity applicable documents? Describe how workers are able to access their documents a. Is there evidence of contract 6.12.2 Where applicable, it shall be x POL has a proven track record of demonstrated that no contract substitution occurring? practicing no contract substitutions. substitution has occurred. Workers were provided with a copy of signed contract. Workers were interviewed.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. Are foreign workers asked to sign a x No foreign labour. Therefore not contract upon arriving in the applicable receiving country? If yes, is that contract identical to the one signed in the country of origin? c. Are workers given a copy of their x All employees are given copies of employment contracts? If yes, is the their employment which are identical contract identical to the one signed to the one signed during the time of at the time of recruitment? employment. This can be verified with the POL HR Department. a. What is the company’s policy and 6.12.3 (M) Where temporary or migrant x POL established Company workers are employed, a special procedures for temporary or Regulations Handbook 1st issue dated labour policy and procedures shall foreign/migrant workers? February 2015 states temporary or be established and implemented. casual employment. Specific Guidance: Does the special labour policy include: For 6.12.3: The special labour policy  Statement of the non- should include: x Included in POL Employee Rights & discriminatory practices? Equal Employment Opportunities  Statement of the non- Policy discriminatory practices;  No contract substitution?  No contract substitution; x Verified labour contract with no substitution.  Post-arrival orientation programme to focus especially  Post-arrival orientation x Induction program conducted for all on language, safety, labour programme with emphasis on newly hired workers or staff in both laws, cultural practices etc.; language, safety, labour laws, Pidgin and English.  Decent living conditions to be cultural practices etc.? provided.  The provision of decent living x Most of contract labour stays at their conditions? houses in the villages. b. Have the policies and procedures x Placed at notice boards and made been implemented? available upon request.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Is there a company policy on human 6.13 Growers and millers respect human 6.13.1 (M) A policy to respect human x Human Rights policy has been rights. rights shall be documented and rights? established and was last reviewed in communicated to all levels of the June 2011. The human rights policy workforce and operations (see has been published on the Website. Criteria 1.2 and 2.1). The Human Rights policy covers; Guidance: Free, prior and informed consent, Right to health, Rights for workers. See also Criterion 6.3. b. How is this communicated to all x Communicated at each POL operating All levels of operations will include employees, including outsourced sites through morning musters and contracted third parties (e.g. those workers, customers and suppliers? tool box talks. Records are maintained involved in security). If by training, how often is the at each respective site. Note: training conducted? Displayed publicly at notice boards at From the UN Guiding Principles on all operating sites. Workers and staff Business and Human Rights: inductions, suppliers and customers were brief upon entering work “The responsibility of business premises. enterprises to respect human rights c. Who has the task of communicating refers to internationally recognised x All POL Policies are communicated the policy internally and externally? human rights – understood, at a within each respective POL estate by minimum, as those expressed in the OHS / Sustainability Representatives, International Bill of Human Rights and supervisors and village wardens. the principles concerning fundamental Policies are distributed by rights set out in the International Labour Sustainability Department. Organization’s Declaration on Fundamental Principles and Rights at d. Does the company have any Work” (“The corporate responsibility to x POL does not have any case of outstanding cases of human rights human rights violation. respect human rights” in Guiding violations? Principles on Business and Human No evidence sighted during document Rights). review and interview of workers and The RSPO WG on Human Rights will staff. provide a mechanism to identify, prevent, mitigate and address human rights issues and impacts. The resulting Guidance will identify the relevant issues on human rights to all RSPO Members. Principle 7: Responsible Development of New Plantings

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Is there any new plantings or 7.1 A comprehensive and participatory 7.1.1 (M) An independent social and x Under POL expansion program there independent social and environmental impact assessment operations, or expanding existing is new mini-estate being developed. environmental impact assessment is (SEIA), undertaken through a ones by the company? What is the undertaken prior to establishing new participatory methodology size of the new planting area? The most recent approved new plantings or operations, or expanding including the relevant affected planting by RSPO on 06/05/ 2014 was existing ones, and the results stakeholders, shall be for Lamawan division with plantable incorporated into planning, documented. ha of 66.66ha management and operations. b. Has an independent social and Guidance: x Independent SEIA were conducted by environmental impact assessment an assessor Mr. Narua Lovel for new See also Criteria 5.1 and 6.1. (SEIA) been documented for the development at Lamawan division new plantings? The terms of reference should be defined Reported dated 18/09/2013 is and impact assessment should be available at Sustainability Department. carried out by accredited independent c. Are the impact assessments experts, in order to ensure an objective x Mr. Narua Lovai – is a recognised prepared by accredited independent independent SEIA consultant process. Both should not be done by the experts? same body. A participatory methodology including external stakeholder groups is d. Are all environmental and social x All impacts associated with the new essential to the identification of impacts, impacts adequately identified? particularly social impacts. Stakeholders developed division are adequately such as local communities, government identified. e. Is the SEIA undertaken based on departments and NGOs should be x Yes involved through the use of interviews the scope of operation? and meetings, and by reviewing findings f. Is the SEIA undertaken in a and plans for mitigation. x Relevant stakeholders were participatory manner, including the consulted. It is recognised that oil palm relevant affected stakeholders? development can cause both positive g. Does the SEIA assessment include and negative impacts. These developments can lead to some and as a minimum: indirect/secondary impacts which are not • Assessment of the impacts of all under the control of individual growers x Impacts as a result of the mini-estate and millers. To this end, growers and major planned activities, development have been captured in millers should seek to identify the including planting, mill the report. indirect/secondary impacts within the operations, roads and other SEIA, and where possible work with infrastructure?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min partners to explore mechanisms to • Assessment, including x Stakeholder consultations for the mitigate the negative indirect impacts stakeholder consultation, of High and enhance the positive impacts. Lamawan division were conducted Conservation Values (see during the SEIA study. Criterion 7.3) that could be negatively affected? The potential impacts of all major • Assessment of potential proposed activities should be assessed x Assessment done and potential in a participatory way prior to effects on adjacent natural effects on adjacent ecosystems taken development. The assessment should ecosystems of planned into consideration. include, in no order of preference and as developments, including Captured in the rapid HCV a minimum: whether development or • Assessment of the impacts of all assessment report conducted by Mr. expansion will increase Guy Williams dated 23/10/2013 major planned activities, including pressure on nearby natural planting, mill operations, roads and ecosystems? other infrastructure; • Identification of • Assessment, including stakeholder x Identified in the rapid HCV watercourses and wetlands Assessment report consultation, of High Conservation and assessment of Values (see Criterion 7.3) that could potential effects on be negatively affected; hydrology and land • Assessment of potential effects on subsidence of planned adjacent natural ecosystems of developments. Measures planned developments, including should be planned and whether development or expansion implemented to maintain will increase pressure on nearby the quantity, quality and natural ecosystems; access to water and land • Identification of watercourses and resources? wetlands and assessment of • Baseline soil surveys and x Baseline soil surveys to be potential effects on hydrology and topographic information, land subsidence of planned undertaken by TSD department including the identification of including providing topographic developments. Measures should be steep slopes, marginal and information. planned and implemented to fragile soils, areas prone to At the moment POL only developing maintain the quantity, quality and erosion, degradation, access to water and land resources; mini-estate at disused old coconut subsidence, and flooding? plantations.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min • Baseline soil surveys and • Analysis of type of land to be x Lamawan division is a disused topographic information, including used (forest, degraded forest, unproductive coconut plantation as the identification of steep slopes, cleared land)? reported in the HCV assessment and marginal and fragile soils, areas SEIA reports. prone to erosion, degradation, • Analysis of land ownership and subsidence, and flooding; x The new development undertaken is user rights? • Analysis of type of land to be used on local peoples land (traditional) (forest, degraded forest, cleared which are customary owned and leased to POL land); • Analysis of current land use • Analysis of land ownership and user x Refer to SEIA report. rights; patterns? • Analysis of current land use patterns; The land for proposed development is a disused old coconut plantation. • Assessment of potential social impacts on surrounding communities • Assessment of potential social of a plantation, including an analysis x Locals will be hired to work on the impacts on surrounding mini-estate with income to sustain of potential effects on livelihoods, communities of a plantation, family and for other use. and differential effects on women including an analysis of versus men, ethnic communities, and potential effects on livelihoods, migrant versus long-term residents; and differential effects on • Identification of activities which may women versus men, ethnic generate significant GHG emissions. communities, and migrant versus long-term residents? Plans and field operations should be • Identification of activities which developed and implemented to x Disused old coconut plantations that is incorporate the results of the may generate significant GHG no longer productive. assessment. One potential outcome of emissions? the assessment process is that the Since it is an old unproductive coconut development may not proceed because plantation, GHG emissions will be low of the magnitude of potential impacts. since the land use change is not from a forest or grassland. For smallholder schemes, the scheme h. What were the main findings of the management should address this x Identified in the SEIA assessment Criterion. For individual smallholders, this assessment? report. Criterion does not apply. Example:

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Where there is no National Interpretation, More opportunities for contractual for land areas greater than 500ha, a full support by local entrepreneurs; independent assessment will be required. For land areas less than 500ha, More employment opportunities and an internal assessment using selected therefore more regular wage earners components of SEIA and HCV and more income into the local assessments can be used. Where such economy; internal assessments identify significant Improved access to customary land in environmentally or socially sensitive the interior for subsistence gardening, areas or issues, an independent cash cropping including VOPs and assessment will be undertaken. extraction of traditionally useful forest products; The nearby villagers acknowledge the ownership of the plantation land and welcome the planting of oil palm. i. Were secondary impacts of oil palm x Reported in the in SEIA assessment development identified in the SEIA? reports. Example: Issue raised by stakeholder Villagers contemplating VOPs and other cash crops as a result of improved access to land behind the plantation ought to consider food security and increased dependency on imported processed food; Assessor comment: This is entirely up to individuals and families that want to engage in cash cropping. Most people accept that too much processed food is not good for their health and they are making provision for local garden food. These can be either bought from the revenue they earn or grown in their food

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min gardens. One local NGO known as Roots for Change is actively promoting organic farming as an alternative to traditional shifting cultivation. The objective is to reduce the rate of clearance of forest areas for new food gardens. a. Does the findings of the SEIA 7.1.2 Appropriate management planning x No negative impacts were uncovered and operational procedures shall uncover any negative impacts? If during the SEIA assessment. be developed and implemented to yes, has a management plan and avoid or mitigate identified operational procedures been POL has established a management and mitigation plan. potential negative impacts. developed to mitigate the negative impacts? b. Has the management plan and x The management plan is operational procedures been implemented. implemented? Existing estate operation procedure applied. a. Are any outgrowers involved in the 7.1.3 Where the development includes x No smallholders or out growers an outgrower scheme, the impacts new plantings? involved in new plantings. of the scheme and the implications b. Has management prepared a plan of the way it is managed shall be x No plan for smallholders because for the outgrower scheme? given particular attention. smallholders are not involved in new plantings c. Does the SEIA include an x .Not applicable since not smallholders assessment of impacts and the involved. implications of the way the outgrower scheme is managed? a. Are soil suitability/survey maps for 7.2 Soil surveys and topographic 7.2.1 (M) Soil suitability maps or soil x Soil surveys / suitability maps for new information are used for site planning surveys adequate to establish the the planted areas available or in developments available on file and in the establishment of new long-term suitability of land for oil place? also held by TSD. plantings, and the results are palm cultivation shall be available  Is the map adequate to x Maps indicate different soil types incorporated into plans and and taken into account in plans establish the long-term operations. and operations. within the new development plus suitability of land for oil palm existing plantations. Guidance: cultivation?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min  Are the soil suitability maps or These activities can be linked to the x All maps are appropriate and indicate Social and Environmental Impact soil surveys appropriate to the the different soil types available and Assessment (SEIA) (see Criterion 7.1) scale of operation? they are suitable for oil palm but need not be done by independent plantations. experts.  Does the soil suitability maps or x Soil suitability survey maps only Soil suitability maps or soil surveys soil surveys include information include information on soil types, should be appropriate to the scale of on soil types, topography, and topography and hydrology. operation and should include information hydrology, rooting depth, on soil types, topography, hydrology, moisture availability, stoniness rooting depth, moisture availability, and fertility? stoniness and fertility to ensure long-term  Do the soil suitability maps or sustainability of the development. Soils x Soil fertility results are used to requiring appropriate practices should be soil surveys identify soils determine the type of fertilizer to apply identified (see Criteria 4.3 and 7.4). This requiring appropriate practices? at each site according to the soil type information should be used to plan of the site planting programmes, etc. Measures b. Are there any areas located within should be planned to minimise erosion x All areas within the plantation the plantation perimeters that are perimeters are suitable for long term through appropriate use of heavy considered unsuitable for long-term machinery, terracing on slopes, oil palm cultivation oil palm cultivation? appropriate road construction, rapid  Are such areas delineated in establishment of cover, protection of x There are areas identified in the SEIA riverbanks, etc. Areas located within the the plans? and HCV assessment unsuitable for plantation perimeters that are considered oil palm cultivation unsuitable for long-term oil palm  Are there areas set aside for cultivation will be delineated in plans and x Area identified as HCV areas are set included in operations for conservation or conservation? aside for conservation. rehabilitation as appropriate (see  Or are there plans for Criterion 7.4). x Area identified as HCV areas are set rehabilitation as appropriate? Assessing soil suitability is also important aside for conservation. for smallholders, particularly where there are significant numbers operating in a c. Does the company plan to particular location. Information should be x There are no independent suppliers at purchase Fresh Fruit Bunches the moment. collected on soil suitability by companies (FFB) from potential developments planning to purchase Fresh Fruit of independent suppliers in a Bunches (FFB) from potential particular location?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min developments of independent d. If yes, the following information

smallholders in a particular location. should be obtained: Companies should assess this information and provide information to independent smallholders on soil  Is information on soil suitability x Not Applicable suitability, and/or in conjunction with collected and assessed? relevant government/public institutions and other organisations (including  Has the company provided x Not applicable NGOs) provide information in order to information on soil suitability to assist independent smallholders to grow the independent smallholders in oil palm sustainably. order to assist them to grow oil palm sustainably? a. Does the area where plantings are 7.2.2 Topographic information adequate x Some minor drainages done along to guide the planning of drainage done require drainage or irrigation? roadsides and other low laying areas and irrigation systems, roads and to drain out access water. other infrastructure shall be available and taken into account in POL plantations does not require plans and operations. irrigation system b. If yes, is there adequate x Topographic maps are available and topographic information to guide kept at TSD section the planning of drainage and irrigation systems? c. Is the topographic information and x Topographic information are important best practices taken into for roads and drainage constructions consideration during the development of roads and infrastructure? a. Since November 2005, have any 7.3 New plantings since November 2005 7.3.1 (M) There shall be evidence that x POL developed at disused old have not replaced primary forest or no new plantings have replaced new plantings replaced primary coconut plantations. any area required to maintain or primary forest, or any area required forest, or any area required to enhance one or more High to maintain or enhance one or maintain or enhance one or more This could be verified in the SEIA and HCV assessment report. Conservation Values. more High Conservation Values High Conservation Values (HCVs)? (HCVs), since November 2005. If yes, was an adequate HCV New plantings shall be planned and assessment carried out prior to the managed to best ensure the HCVs clearing of the land?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min identified are maintained and/or b. Where HCVs have been identified enhanced (see Criterion 5.2). x Areas identified as HCV areas are on the land that is intended for new identified and conserved. Specific Guidance: plantings, have new plantings been planned and managed to best Buffer zones are and will be For 7.3.1: Evidence should include established along streams, creeks and ensure the HCVs identified are historical remote sensing imagery which near to coast as per the PNG Logging demonstrates that there has been no maintained and/or enhanced (see Code of Practice. conversion of primary forest or any area Criterion 5.2)? required to maintain or enhance one or Map of HCV area within proposed more HCV. Satellite or aerial mini-estate held with Sustainability photographs, land use maps and Department as well as TSD. c. Are there finalised HCV maps and vegetation maps should be used to x The map has identified unplantable inform the HCV assessment. areas endorsed/signed off by area coverage in ha, endorsed and management showing type of HCV Where land has been cleared since signed off by the management. and area coverage (ha)? November 2005, and without a prior and adequate HCV assessment, it will be excluded from the RSPO certification programme until an adequate HCV compensation plan has been developed and accepted by the RSPO. d. Has the company comply with NPP Guidance: x Yes notification for current new procedures? i.e. NPP documents planting at Lamawan division was This Criterion applies to forests and other was submitted and put for public submitted to RSPO on 07/04/2014. vegetation types. This applies notification. irrespective of any changes in land ownership or farm management that have taken place since November 2005. HCVs may be identified in restricted areas of a landholding, and in such

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min cases new plantings can be planned to e. Is CB verification of NPP x Current new plantings were verified by allow the HCVs to be maintained or documents include field enhanced. BSI auditor on 03/02/2014 prior to verification? If not, field verification ASA02 by means of document review. The HCV assessment process requires of HCV is required during . appropriate training and expertise, and certification audit. will include consultation with local communities, particularly for identifying social HCVs. HCV assessments should be conducted according to the National Interpretation of the HCV criteria or f. Where land has been cleared since x No new developments were according to the Global HCV Toolkit if a November 2005, and without a National Interpretation is not available undertaken on areas cleared since prior and adequate HCV (see Definitions). 2005. assessment, is there evidence that POL development was on disused old Developments should actively seek to an adequate HCV compensation coconut plantation. utilise previously cleared and/or plan for the affected area has been degraded land on mineral soil. Plantation developed and accepted by the development should not put indirect pressure on forests through the use of all RSPO? available agricultural land in an area. Where landscape level HCV maps have been developed, these should be taken into account in project planning, whether or not such maps form part of government land use plans. In case of small areas located either in hydrologically sensitive landscapes or in HCV areas where conversion can jeopardise large areas or species, an independent assessment will be required. HCV areas can be very small. Once established, new developments should comply with Criterion 5.2.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Is the prepared HCV assessment 7.3.2 (M) A comprehensive HCV x HCV assessment is comprehensive assessment, including stakeholder comprehensive? Was the and takes in consideration all aspects consultation, shall be conducted assessment prepared in of biodiversity conservation as well as prior to any conversion or new consultation with the affected RTE species and ecosystems. planting. This shall include a land stakeholders prior to any There was wider consultation use change analysis to determine conversion or new planting? changes to the vegetation since undertaken with local landowners, November 2005. This analysis shall communities and local authorities. be used, with proxies, to indicate Minutes and consultation records changes to HCV status. maintained on file. b. Do the HCV assessments include x The developed area is a disused land use change analysis to coconut plantation. determine changes to the vegetation since November 2005? The SEIA finding that no HCVs including primary forests, fragile soils (This analysis shall be used, with and peat soils occur in the project proxies, to indicate changes to area HCV status) a. Are the dates of land preparation 7.3.3 Dates of land preparation and x Record for land preparation and and commencement recorded? commencement shall be recorded. commencement is included in the Plantation Planning and Management Report for Lamawan Division Land preparation commenced in October 2014 and planting started in June 2015 a. Has the company developed an 7.3.4 (M) An action plan shall be x Identified HCV areas incorporated in developed that describes action plan that describes the Plantation Planning and operational actions consequent to operational actions consequent to Management Report the findings of the HCV the findings of the HCV assessment, and that references assessment? the grower’s relevant operational b. Does the action plan reference the procedures (see Criterion 5.2). x Current field management handbook grower’s relevant operational is applied as the operating procedure. procedures (see Criterion 5.2)?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Have areas required by affected 7.3.5 Areas required by affected x Consultations/interviews were communities to meet their basic communities to meet their basic undertaken including site inspections needs, taking into account potential needs, taking into account potential of the proposed new developments positive and negative changes in positive and negative changes in with landowners and wider livelihood resulting from proposed livelihood resulting from proposed communities. Areas identified as operations, shall be identified in operations, been identified in being HCVs and those areas consultation with the communities consultation with the communities? considered important for sustaining and incorporated into HCV local peoples livelihoods’ were assessments and management identified and will be preserved. plans (see Criterion 5.2). b. Have these areas been x Identified HCV areas incorporated into Specific Guidance: incorporated into HCV assessment and Management Plan assessments and management For 7.3.5: The management plan will be plans (see Criterion 5.2)? adaptive to changes in HCV 5 and 6. Decisions will be made in consultation with the affected communities. a. Are there maps identifying marginal 7.4 Extensive planting on steep terrain, 7.4.1 Maps identifying marginal and x Maps indicate different soil types and/or marginal and fragile soils, fragile soils, including excessive and fragile soils, including within all new developments plus including peat, is avoided. gradients and peat soils, shall be excessive gradients and peat soils? existing plantations held on file. available and used to identify b. If peat is present, does the map x No peat land identified areas to be avoided. show the extent, nature, and depth Guidance: of peat? c. Are the maps used to identify areas This activity should be integrated with the x No peat land identified in the maps. social and environmental impact that are inappropriate for planting? assessment (SEIA) required by Criterion 7.1. d. Have the maps been incorporated x There are no peat soils identified Planting on extensive areas of peat soils for use in the social and therefore no SEIA assessment and other fragile soils should be avoided environmental impact assessment required (see Criterion 4.3). Adverse impacts may (SEIA)? include hydrological risks or significantly e. Is there evidence that planting on x Planting on swampy areas has been increased risks (e.g. fire risk) in areas extensive areas of peat soils and outside the plantation (see Criterion 5.5). avoided other fragile soils have been avoided?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Are there plans to protect planted 7.4.2 (M) Where limited planting on x There are no plantings on peat and fragile and marginal soils, including areas on fragile and marginal soils, fragile soils therefore no plan peat, is proposed, plans shall be including peat from adverse developed. developed and implemented to impacts? protect them without incurring b. Does the plan take into

adverse impacts. consideration specific control and NI thresholds, including:  Slope limits; x POL does not develop slopes and hilly areas >25 degrees.  List of soil types that need to be x There are no peat soils within all POL avoided, especially peat soil; new developments therefore no list created.  Proportion of plantation areas x There are no peat soils within all POL that can include marginal / new developments therefore no list fragile soil. created c. Has the plan been implemented? x There are no peat soils within all POL new developments therefore no plans implemented. a. Does the new planting area include 7.5 No new plantings are established on 7.5.1 (M) Evidence shall be available that x All new developments are planned local peoples’ land where it can be affected local peoples understand ‘local people’s land’? and undertaken on local people land

demonstrated that there are legal, they have the right to say ‘no’ to through the mini-estate sub-lease customary or user rights, without operations planned on their lands scheme. their free, prior and informed before and during initial b. If yes, has the community given consent. This is dealt with through a discussions, during the stage of x POL followed the RSPO NPP their consent? documented system that enables information gathering and procedure to acquire land. FPIC these and other stakeholders to associated consultations, during meetings and consultations conducted express their views through their own negotiations, and up until an with all interested communities / land representative institutions. agreement with the grower/miller is owner clans prior to them agreeing to signed and ratified by these local give-up land for new development. peoples. Records of FPIC meetings and consultations held on file.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min c. Is there evidence to demonstrate Refer also to criteria 2.2, 2.3, 6.2, 6.4 x Records of consent agreement held and 7.6 for Indicators and Guidance on that the consent/agreement has on file at Sustainability Department compliance. been given? and with Lands Section. Guidance: This activity should be integrated with the Social and Environmental Impact d. Has the community been given the Assessment (SEIA) required by Criterion x Communities made aware of negative 7.1. opportunity to say ‘no’ to the and positive impacts of oil palm and proposed development? given every opportunity to say 'yes' or Where new plantings are considered to 'no' to oil palm development on their be acceptable, management plans and land. operations should maintain sacred sites. Agreements with indigenous peoples, e. Are the principles of the FPIC x POL under RSPO NPP procedure local communities and other process followed? followed all the FPIC process. stakeholders should be made without coercion or other undue influence (see Guidance for Criterion 2.3). Relevant stakeholders include those affected by or concerned with the new plantings. Free, prior and informed consent (FPIC) is a guiding principle and should be applied to all RSPO members throughout the supply chain. Refer to RSPO approved FPIC guidance (‘FPIC and the RSPO; A Guide for Companies’, October 2008). Customary and user rights will be demonstrated through participatory user mapping as part of the FPIC process. a. Does the SEIA include the 7.6 Where it can be demonstrated that 7.6.1 (M) Documented identification and x SEIA identifies all relevant landowners identification and assessment of local peoples have legal, customary assessment of demonstrable legal, of each of the new development

or user rights, they are compensated customary and user rights shall be legal, customary and user rights of areas. for any agreed land acquisitions and available. the area?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min relinquishment of rights, subject to b. Does the company have SOPs to their free, prior and informed consent Specific Guidance: x MG 21 Land Acquisition describes all identify and assess any legal, the processes involved for land and negotiated agreements. For 7.6.1: This activity shall be customary and user rights of the acquisition. Copy held with integrated with the social and local peoples? Sustainability Dept. environmental impact assessment (SEIA) c. Is there any known notification from required by Criterion 7.1. x Land proposed for new development the stakeholders claiming to have Guidance: is customary land held by local legal, customary and/or user rights people. Refer to Criteria 2.2, 2.3 and 6.4 and on the land for the new planting associated Guidance. area? d. Has the claim been identified and This requirement includes indigenous x Land is identified through individual peoples (see Annex 1). assess according to the landowners. The whole process is protocol/SOP? Does the process Refer to RSPO approved FPIC guidance transparent and gives every right to (‘FPIC and the RSPO; A Guide for follow and respect the FPIC the individual landowners Companies’, October 2008) principles? e. Has the process of identification x Identification and Assessments of land and assessment been done through participation of all recorded/documented and made member of the land. publicly available? Records held with POL land office and only made available to concerned parties. a. Does the company have a system 7.6.2 (M) A system for identifying people x Through the negotiation process with entitled to compensation shall be in in place to identify people and/or individual landowners. place. community groups entitled to compensation? b. Is the system documented? x Fully documented and records with POL lands office c. Does the system follow and respect x FPIC is included. the FPIC principles?

a. Does the company have a system 7.6.3 (M) A system for calculating and x Contained in land use agreements distributing fair compensation in place to calculate and distribute signed with land owners (monetary or otherwise) shall be in fair compensation (monetary or place. otherwise)?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. Is the system documented and x Only made available to concerned publicly made available? parties only and not public.

c. Does the system follow and respect x Yes the FPIC principles?

a. Does the company provide 7.6.4 Communities that have lost access x Locals given employment and rights to land for plantation communities that have lost access opportunities, local contracts on mini- expansion shall be given and rights to land for plantation estates opportunities to benefit from expansion opportunities to benefit plantation development. from plantation development?

a. Is the process and outcome of any 7.6.5 The process and outcome of any x Only made available to concerned compensation claims shall be compensation claims documented parties only and not public. documented and made publicly and made publicly available? available.

a. Is there record to show that the 7.6.6. Evidence shall be available that x Both SEIA and HCV rapid assessment the affected communities and community and rights holders have are made available publicly at RSPO rights holders have access to freedom to access information and website. information and advice, that is independent advisor(s) concerning independent of the project the legal, economic, environmental proponent, concerning the legal, and social implications of the economic, environmental and proposed operations on their social implications of the proposed lands? operations on their lands. Specific Guidance: b. Is there evidence to show that the For 7.6.6: Growers and millers will x POL has records of all dealings with company has sought the local people from initial FPIC, through confirm that the communities (or their community and the right holders’ representatives) gave consent to the individual landowners and attainment consent to the initial planning initial planning phases of the operations of land title. prior to the new issuance of a concession phases of the operations prior to or land title to the operator. the new issuance of a concession or land title?

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min c. Did the communities (or their x FPIC conducted from initial start of representatives) give consent to the NPP process through to attainment of initial planning phases of the individual landowners and then land operations prior to the new titles issuance of a concession or land title? a. Is there evidence of land 7.7 No use of fire in the preparation of 7.7.1 (M) There shall be no land x POL does not undertake land new plantings other than in specific preparation by burning, other than preparation by burning? preparations through burning. situations, as identified in the ASEAN in specific situations, as identified (The auditors shall conduct site Zero burning statement is established. guidelines or other regional best in the ‘Guidelines for the verification of the newly planted site practice. Implementation of the ASEAN which will include interviews with Policy on Zero Burning’ 2003, or workers). comparable guidelines in other regions. b. Was land prepared using the burn Guidance: x POL does not undertake land method due to reasons or specific preparations through burning. Fire should be used only where an situations, as identified in the assessment has demonstrated that it is ‘Guidelines for the Implementation Refer zero burn statement established the most effective and least of the ASEAN Policy on Zero environmentally damaging option for Burnings’ 2003, or comparable minimising the risk of severe pest and disease outbreaks, and exceptional guidelines in other regions? levels of caution are required for use of fire on peat. This should be subject to c. If the burn method has been used regulatory provisions under respective x POL does not undertake land for land preparation, has the national environmental legislation. preparations through burning. Extension/training programmes for company complied with the smallholders may be necessary. requirements of ‘Guidelines for the Refer zero burn statement established Implementation of the ASEAN

Policy on Zero Burning’ 2003, or comparable guidelines in other regions? d. Is document showing proper x POL does not undertake land justification for such activity preparations through burning. available? Refer zero burn statement established

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. In exceptional cases where fire has 7.7.2 In exceptional cases where fire has x POL does not undertake land to be used for preparing land for to be used for preparing land for preparations through burning. planting, there shall be evidence of planting, is there evidence of prior prior approval of the controlled approval of the controlled burning Refer zero burn statement established burning as specified in ‘Guidelines as specified in ‘Guidelines for the for the Implementation of the Implementation of the ASEAN ASEAN Policy on Zero Burning’ Policy on Zero Burning’ 2003, or 2003, or comparable guidelines in comparable guidelines in other other regions. regions? b. Was the activity incorporated in the x POL does not undertake land Specific Guidance: SEIA report? preparations through burning. For 7.7.2: This activity shall be Therefore not applicable in SEIA integrated with the social and Refer zero burn statement established environmental impact assessment (SEIA) c. What were the mitigation required by Criterion 7.1. x POL does not undertake land measures? Was it implemented? preparations through burning. Refer zero burn statement established 7.82 Preamble It is noted that oil palm and all other agricultural crops emit and sequester greenhouse gases (GHG). There has already been significant progress by the oil palm sector, especially in relation to reducing GHG emissions relating to operations. Acknowledging both the importance of GHGs, and the current difficulties of determining emissions, the following new Criterion is introduced to demonstrate RSPO’s commitment to establishing a credible basis for the Principles and Criteria on GHGs. Growers and millers commit to reporting on projected GHG emissions associated with new developments. However, it is

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min recognised that these emissions cannot be projected with accuracy with current knowledge and methodology. Growers and millers commit to plan development in such a way to minimise net GHG emissions towards a goal of low carbon development (noting the recommendations agreed by consensus of the RSPO GHG WG2). Growers and millers commit to an implementation period for promoting best practices in reporting to the RSPO, and after December 31st 2016 to public reporting. Growers and millers make these commitments with the support of all other stakeholder groups of the RSPO.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Is there an assessment conducted 7.83 New plantation developments are 7.8.1 (M) The carbon stock of the x POL has planned carbon stock designed to minimise net proposed development area and to identify and estimate the carbon assessment for proposed new greenhouse gas emissions. major potential sources of stock in the proposed development development sites at Masi and Lokono emissions that may result directly area and major potential sources of where assessments are planned to from the development shall be emissions that may result directly commence in 2nd half of 2016. identified and estimated. from the development? Specific Guidance: For 7.8.1: GHG identification and estimates can be integrated into existing processes such as HCV and soil assessments. The RSPO carbon assessment tool for new plantings will be available to identify and estimate the carbon stocks. It is acknowledged that there are other tools and methodologies currently in use; the RSPO working group will not exclude these, and will include these in the review process.

3 New Criteria - New plantation developments are designed to minimize net greenhouse gas emissions.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min b. What are the tools and The RSPO PalmGHG tool or an RSPO- x Appropriate HCS toolkits will be endorsed equivalent will be used to methodologies used to identify and deployed identify and estimate the estimate future GHG emissions from new estimate the carbon stock and carbon stock and potential sources of developments using, amongst others, the potential sources of emission? emission at proposed new data from the RSPO carbon assessment development area. tool for new plantings. Parties seeking to use an alternative tool for new plantings will have to demonstrate its equivalence to the RSPO for endorsement. Guidance This Criterion covers plantations, mill operations, roads and other infrastructure. It is recognised that there may be significant changes between the planned and final development area, hence the assessment may need to be updated before the time of implementation.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min c. Has the results of the carbon stock Public reporting is desirable, but remains x Currently no carbon stock assessment voluntary until the end of the assessment been submitted and implementation period. reported to RSPO according to RSPO procedures and timeline? During the implementation period until December 31st 2016 (as specified in Criterion 5.6), reporting on GHG will be to a relevant RSPO working group (composed of all membership categories) which will use the information reported to review and fine tune the tools, emission factors and methodologies, and provide additional guidance on the process. During the implementation period the RSPO working group will seek to further develop and continually improve the RSPO carbon assessment tool for new plantings, recognising the challenges associated with estimating carbon stocks and projecting GHG emissions from new developments. Thereafter growers and millers will ensure that new plantation developments are designed to minimise net GHG emissions and commit to reporting publicly on this. Once established, new developments should report on-going operational, land use and land use change emissions under Criterion 5.6.

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min a. Is there a plan to minimise net 7.8.2 There shall be a plan to minimise x Appropriate plan will be established to net GHG emissions which takes GHG emissions from new minimise net GHG emissions from into account avoidance of land development? new development at proposed new areas with high carbon stocks development areas of Masi and and/or sequestration options. Lokono during 2nd half 2016. Specific Guidance: For 7.8.2: Growers are strongly encouraged to establish new plantings on mineral soils, in low carbon stock areas, and cultivated areas, which the b. Does this plan take into account x Current newly developed area does current users are willing to develop into avoidance of land areas with high not has a high carbon stocks since it oil palm. Millers are encouraged to adopt carbon stocks, sequestration is disused old coconut plantation. low-emission management practices options and low-emission (e.g. better management of palm oil mill management practices? effluent (POME), efficient boilers etc.) in new developments. Growers and millers should plan to implement RSPO best management practices for the minimisation of emissions during the development of new plantations. Principle 8: Commitment To Continual Improvement In Key Areas of Activity. a. Is there an action plan for continual 8.1 Growers and millers regularly 8.1.1 (M) The action plan for continual x Continual improvement plan was monitor and review their activities, improvement shall be improvement? updated on 06/11/2015, version 4. and develop and implement action implemented, based on a plans that allow demonstrable consideration of the main social The continual improvement plan continual improvement in key and environmental impacts and covered the keys area such as: operations. opportunities of the grower/mill, 1. Agrochemical use and shall include a range of 2. Environment Indicators covered by these 3. Waste Reduction Principles and Criteria. 4. Pollution Emissions and Energy As a minimum, these shall include, Use Efficiency but are not necessarily be limited 5. Social Impacts to: 6. Health & Safety • Reduction in use of 7. Legal and Standard

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min pesticides(Criterion 4.6); Compliance and transparency. • Environmental impacts Continual Improvement Plan: (Criteria 4.3, 5.1 and 5.2); • Waste reduction (Criterion 1.Agrochemical use 5.3); - Improve sprayer training to reduce • Pollution and greenhouse spraying of non-target areas. Current gas (GHG) emissions status: On going. (Criteria 5.6 and 7.8); - Improve training on handling and • Social impacts (Criterion disposal of chemicals to field 6.1); employees. Current status: on going. • Optimising the yield of the Time frame: 2014-2016. supply base. - Spray reduction plan. Current status: 100% completed. 2. Environment Guidance: - Education of staff on the need to reduce burning and to ensure rubbish Growers should have a system to is segregated and correctly in landfill improve practices in line with new sites. Current status: On-going. Time information and techniques, and a frame: 2014-2016. mechanism for disseminating this information throughout the workforce. For - Improve waste management in smallholders, there should be systematic compounds and work sites. Current guidance and training for continual status: On-going. The training was improvement. done for the workers. Pending for dependents.

- Minimizing pollution of surface water and buffer damage along the surface edges. Current status: 100% Done for year 2015 and will continue for year 2016. 3. Waste Reduction - Scrap metal piles used for recycling or given to contractors. Current status: On-going. Scrap metal contractor engaged and picked up the scrap Int rspo pc cld clr sum e - v01 – 23/9/2015 p. 166/ 181 NBPOL – POL 30/11/2015 to 04/12/2015

NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min metal in year 2014. - Recycling of empty chemical containers for mixing chemical for spraying. Current status: On- going. New empty containers are being used for mixing chemical. Only old and broken containers are being triple rinsed and disposed in the chemical land fill. 4. Pollution Emissions and Energy Use Efficiency - Expand the capacity of palm oil effluent treatment ponds to improve effluent treatment and prevent overflow and leaks. Current status: On-going. Work has commenced in Mid Nov. 2013 to commence using the 2 CTP ponds in alternate with the current anaerobic ponds to ensure that they are desilted when necessary. Boiler ash is used to maintain the walls of the ponds. Currently the extra pond is in use by pumping effluent. - Illegal burning in compounds, landfills and plantation areas. Current status: On-going. Awareness being done in fire affected area. Illegal burning in landfall and plantation field had been as issues during dry season. 5. Social Impacts -Improve medical facilities for all employees. Current status: New clinic has been built at Nalik estate. - Additional labour housing with 7

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min centralised housing compounds at Poliamba. Current status: On-going. Work has commenced in Jan 2014. 16 DLQs (Duplex Labour quarters) completed at Nalik Estate in 2014. 8 DLQs at Kara estate under construction. 6. Health & Safety - Contractor awareness and compliance to company safety requirement. Current status: On- going. Contractor awareness on PPE compliance done on 05.11.15. Those contractors that do not observe the instructions will be penalised. - Review workers injury at work pay so that the worker is not paid under sick pay if injured at work. Current status: On-going by Jan 2016. Poliamba has taken the necessary steps to improve the method on sick pay and accident pay respectively. 7. Legal and Standard Compliance and transparency. - Refresher training for boiler attendants. Current status: By June 2016. Boiler attendant training included in the 2016 training budget. - Pressure vessels not tagged and properly identified. Current status: The mill team tagged and identified all the pressure vessels. b. Describe the main components of x The main components on the the plan. Continual improvement plan were the objectives, target, time frame, action

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min and area of the implementation.

c. Has the action plan been x Action plan has been implemented implemented? and completed. Example:- - Spray reduction plan. Current status: 100% completed. - Minimizing pollution of surface water and buffer damage along the surface edges. Current status: 100% Done for year 2015 and will continue for year 2016. -Improve medical facilities for all employees. Current status: New clinic has been built at Nalik estate. - Pressure vessels not tagged and properly identified. Current status: The mill team tagged and identified all the pressure vessels. d. Provide examples of continual x Refer to 8.1 c improvements that have been implemented. e. Are history records available to x The history on the action plan based develop the action plan? on the environmental aspects and impacts, SEIA and HCV reports. f. Are records of implementation of x Implementation of the action plan has the action plan available? been recorded. Refer to Example:- 1. Recycling of empty chemical containers for mixing chemical for spraying. Current status: On- going. New empty containers are being used for mixing chemical. Only old and

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min broken containers are being triple rinsed and deposed in the chemical land fill. 2. Expand the capacity of palm oil effluent treatment ponds to improve effluent treatment and prevent overflow and leaks. Current status: On-going. Work has commenced in Mid Nov. 2013 to commence using the 2 CTP ponds in alternate with the current anaerobic ponds to ensure that they are desilted when necessary. Boiler ash is used to maintain the walls of the ponds. Currently the extra pond is in use by pumping effluent. 3. Contractor awareness and compliance to company safety requirement. Current status: On- going. Contractor awareness on PPE compliance done on 05/11/2015. Those contractors that do not observe the instructions will be penalised. 4. Review workers injury at work pay so that the worker is not paid under sick pay if injured at work. Current status: On-going by Jan 2016. Poliamba has taken the necessary steps to improve the method on sick pay and accident pay respectively g. Does the action plan include

strategies for:

• Reduction in use of pesticides x A list was established for the (Criterion 4.6)? Is IPM widely minimising the use of certain implemented? pesticides such as methamidophos

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min

• Environmental impacts (Criteria x Significant environmental impacts 4.3, 5.1 and 5.2)? identified in the environmental aspects and impacts register (2015) has been incorporated in the continuous improvement plan. • Waste reduction (Criterion 5.3)? x Reduction in waste is achieved in accordance with Poliamba Waste Management Plan dated Jan 2015., ussie no: 2. • Pollution and greenhouse gas x Included. Pollution and emissions are (GHG) emissions (Criteria 5.6 identified in the Environmental and 7.8)? Aspects as an ongoing process • Social impacts (Criterion 6.1)? x Social impacts identified through a Social Impact Assessment are incorporated into the Continuous Improvement Plan. • Optimising the yield of the x Poliamba plantations are constantly supply base? monitored for optimised field standards in line with the RSPO P&C Poliamba smallholder affair department and OPIC have undertaken and in progress in training of all smallholder growers on the RSPO P&C to improve production. Do growers have a system to improve x Smallholder Affair office established practices in line with new information training plan to the smallholders and techniques, and a mechanism for growers for year 2015. Training was disseminating this information carried out to the smallholders throughout the workforce? growers on regular basis.. Training was conducted throughout a year. Example:- Training topic –

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NO. CRITERION INDICATOR CHECKLIST Score: x/ Comments Maj/Min Fertilizer, Harvesting & Upkeep, Pest & Disease, Roadside clearing and RSPO (Include FFB price formula). There was no new information and techniques provided by the OPIC and Poliamba NBPOL at the moment.

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4.2 Noteworthy positive components and identified non conformances

4.2.1 Details of noteworthy positive components 1. Full cooperation of auditees at visited sites 2. Documentation are made available for review and assessment 3. Smallholders are cooperative during field visits 4. Workers and operators could demonstrate the work competency.

4.2.2 Status of non-conformities previously identified. This section gives an overview of actions taken to close out non-conformities raised during the previous audit. If a minor non-conformity raised at the last audit, is not closed out, then this will be raised to a Major non- conformity and the company is given 60 days to close this out. No major nor minor non-conformities were raised during the previous ASA audit. Observations raised during the last audit are as follows and have been addressed appropriately. OBS 1: RSPO P & C, Generic Standard 2013 – Indicator 5.1.1 POL Aspects and Impacts Register dated 15th January, 2015 by the Sustainability Dept and related personnel. Aspects identified were categorized into positive and negative and covers activity, its related environmental aspect and impact, location, department, operational controls, whether the aspect has related legal requirements and calculation on (consequences, probability, severity). Significant and non-significant environmental aspect has been identified & relevant operational controls has been established and communicated was verified on site. Among the main activities covered were land clearing, mill yard run-off, boiler operation and steam use, chemical storage & use and POME (Palm Oil Mill Effluent) Treatment. The aspect and impacts register is reviewed on annual basis or where there is significant change on the activities. This indicates in the general that the EIA was conducted accordingly as per principle 5.1.1. However related constructions activities which are construed as not directly related to mill and plantations management were not clearly indicated since similar aspect and impact for example soil and water contamination has been identified. Evidence – Poliamba environment aspect impact register dated 10/10/2015 which has been revised to include construction activities like new construction site for waste generation, road construction / upgrading, solid waste disposal, etc OBS 2: RSPO P & C, Generic Standard 2013 – Indicator 5.6.3 Environment Permit; Environment Act 2000; Permit Number: WD-L2B (249); Date of Issue: 26th July 1991, Date of Amendment: 2nd June, 2010 was reviewed and generally referenced to Environmental Code of Practice for Papua New Guinea Oil Palm Processing Industry, DEC 1997 for mill operations. The new code of practice i.e. Environmental Code of Practice for Papua New Guinea Oil Palm Processing Industry, DEC 2013 which indicates that required quarterly noise readings are to be taken at each nominated location and recorded along with time of taking the reading and mill operational status and plan indicating the sampling direction whereby it needs to be verified when it is compulsory to comply (year of implementation).

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Current steps taken were noise mapping, ear-plugs provided and observed worn in high noise areas. In addition monitoring of smoke density must not exceed Ringelmann 2 (40%) for more than 20% of the operating hours of any boiler including transient start-up and shut-down periods which were evident with records shown. Evidence – The new Environmental Code of Practice is dated 1st July 2013 and not Dec 2013. Under clause 1.3 for Adoption, existing facilities, if unchanged in throughput or cumulative capacity increase of less than 50%, must achieve compliance within ten years of publication of the Code of Practice with the exception of compliance with the requirement of clause 4.1 Site Considerations. Since Poliamba falls into this category, no compliance is required until 2023.

4.2.3 Detail of Non Conformities identified during this audit This section gives an overview of the non-conformities raised during this audit.

AUDIT OUTCOME

Nil MAJOR Non-Conformities

2 MINOR Non-Conformities

Non Conformity Number <1>

RSPO – Criterion: 4.7.5 Location West Coast and Madak estates Description of Finding/Objective Evidence: During the field visits at West Coast and Madak estates, first aid kits were not made available at chemical spraying, chemical mixing area and harvesting work locations to handle emergency in the event of an injury and/or accident

Classification Major Minor Deadline for Corrective action Before Next ASA implementation

Review of corrective action

Closed: Yes No The implementation of the corrective action will be counter checked during the annual surveillance audit. Cheong, Chun Yuen (Robert) Punnyan, Sivathasan, Leong, Sak Kuan, Date

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Non Conformity Number <2>

RSPO – Criterion: 4.8.2 Location Madak Estate Description of Finding/Objective Evidence: During document review, it was found the training records for the harvester and loose fruit pickers at Madak estate are not available Classification Major Minor Deadline for Corrective action Before Next ASA implementation

Review of corrective action

Closed: Yes No The implementation of the corrective action will be counter checked during the annual surveillance audit. Cheong, Chun Yuen (Robert) Punnyan, Sivathasan, Leong, Sak Kuan, Date

4.3 Issues raised by stakeholders Stakeholder meeting was held at various locations on each day during the audit. The subjects raised and responded by the company will be reviewed at the next annual surveillance assessment. Subsequent annual surveillance audit reports will include any subjects raised during the period of certification and during the annual surveillance audit. Stakeholders at Lakurumau consultation: a) Request POL to provide clean water and electricity to communities situated near to Lakurumau, Nalik Estate; b) Request to improve housing; c) Improve road connected to smallholders. d) Reduce smell and flies from EFB mulching; Auditors Observation: a) GM and sustainability department confirmed that POL is providing water and electricity as requested by communities nearby to Lakurumau area. The management has to obtain approval before they can carry out such request. b) POL GM confirmed housing budget has been approved and this will take time to complete the workers housing since the previous owner did not provide proper housing to workers;

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c) The auditors have visited the shops and banking facility during onsite and could confirm communities and workers could buy food and carry out banking activities. POL has established communities’ needs to support local business at the work areas. d) OPIC officer explained that the local government has commenced with the road maintenance within the District; e) The field services department has been informed and will review the mulching locations to reduce complaints on smell and flies. Stakeholders at West Coast Estate, Noatsi Estate and Madak Estate: a) Housing, water and transport to school; Auditors Observation: a) Similar to Lakurumau area, the housing improvement program has been approved and takes time to complete according to the GM; b) Access water to clean water is made available with the change of the company owners after NBPOL took over the company. This takes time and financial approval from the company Board. The sustainability team conducts monthly water quality tests to ensure clean water available at the workers housing area. c) POL management is organising transport to ferry workers’ children to schools; Stakeholders at Kavieng town: a) Wildlife Conservation Society: POL has been supportive to WCS activities for wildlife studies in other locations of New Ireland Province. There were no wildlife management areas at current POL plantation locations. Most of the wildlife management areas are marine wildlife located in small islands of the province. b) Boi Village Chief: The presence of POL is the key organisation in New Ireland Province that supports the local economy. Without POL, the economy in New Ireland Province would be badly affected; Smallholders benefited very much with POL presence. c) Provincial Land and Physical Planning POL plantations are state leased with some sub-leased from individual owners. All leased lands are registered with the provincial land office with proper transfer of titles; POL is developing in discontinued old coconut plantations belonging to individuals or churches. There is no new state land leased by POL; Any land disputes (if any) will be managed and handled by the provincial land officers; Auditors Observations: From the interviews with the Boi Village Chief, POL has contributed much to New Ireland Province economy. The audit team has further interviewed the owner of Nusa Lik Island resort and could confirm POL is the key economy contributor to New Ireland Province with the oil palm generates a large part of the province income. As confirmed by the Provincial Land office, POL operates on state leased land and sub leased of old discontinued coconut plantations. From the input of WCS, no WMA around the current plantations operated by POL.

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5 RSPO Supply Chain Certification The palm mill mentioned in the scope of the audit was audited against the requirements of the following:  RSPO Supply Chain Certification Systems. November 2014.  RSPO Supply Chain Certification Standard. November 2014. Supply chain model for which the mill applies: Identity preserved

Mass Balance

5.1 Findings by criteria Poliamba Mill CRITERION SCORE COMMENT Module D – Identity preserved D.1. Definition D.1.1 A mill is deemed to be Identity Preserved (IP) if Conform The model applied for the FFB used by the mill are sourced from its own recertification is IP Module D. supply base certified to the RSPO Principles and Poliamba mill process all FFBs Criteria (RSPO P&C). Certification for CPO mills is supplied by owned estates and necessary to verify the volumes and sources of certified VOPs smallholders. FFB entering the mill, the implementation of any processing controls (for example, if physical separation The FFBs supplied are RSPO is used), and volume sales of RSPO certified products. certified. There are no delivery of A mill may be taking delivery of FFB from uncertified non-certified FFBs. growers, in addition to those from its own certified land base. If a mill processes certified and uncertified FFB without physically separating the material then only Module E is applicable. D.2 Explanation D.2.1 The estimated tonnage of CPO and PK products Conform Estimated tonnage of CPO (Mar that could potentially be produced by the certified mill 2016 – Feb 2017) : 17,892.12 must be recorded by the certification body (CB) in the public summary of the P&C certification report. This Estimated tonnage of PK (Mar figure represents the total volume of certified palm oil 2016 – Feb 2017) : 4,877.16 product (CPO and PK) that the certified mill is allowed to deliver in a year. The actual tonnage produced shall then be recorded in each subsequent annual surveillance report.

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D.2.2 The mill must also meet all registration and Conform The mill is under the NBPOL – reporting requirements for the appropriate supply chain POL e-Trace, RSPO IT platform through the RSPO supply chain managing organization for the trading of the CSPO and (RSPO IT platform or book and claim). in compliance of the registration and reporting requirements. D.3 Documented procedures D.3.1 The site shall have written procedures and/or work instructions to ensure the implementation of all the elements specified in these requirements. This shall include at minimum the following: a) Complete and up to date procedures covering the Conform Poliamba Palm Oil Mill has implementation of all the elements in these established operating procedures requirements covering all elements of the requirements Example: Supply Chain Management System Guidelines Issue 4 dated November 2015 b) The role of the person having overall responsibility for Conform Mr. Henry Gapi is the appointed and authority over the implementation of these acting mill manager who has the requirements and compliance with all applicable overall responsibility and requirements. This person shall be able to demonstrate authority in operating the oil mill awareness of the site’s procedures for the to meet RSPO SCC compliance implementation of this standard. for CSPO and PK.

D.3.2 The site shall have documented procedures for Conform Poliamba Palm Oil Mill standard receiving and processing certified and non-certified operating manual includes FFBs. receiving and processing certified FFBs from the owned estates and VOPs smallholders. D.4 Purchasing and goods in D.4.1 The site shall verify and document the tonnage Conform All certified FFBs sources and and sources of certified and the tonnage of non-certified tonnage are fully traceable on a FFBs received. daily, weekly, monthly and annual accumulated value. All data are updated daily and kept in the computer server.

D.4.2 The site shall inform the CB immediately if there is Conform System to deal with the a projected overproduction of certified tonnage. overproduction case and mechanism to inform CB is available D.5 Record keeping

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D.5.1 The site shall record and balance all receipts of Conform Records of receiving certified RSPO certified FFB and deliveries of RSPO certified FFB are well been kept and CPO and PK on a three-monthly basis. maintained. Weight of certified FFB from each estate and sales documents of certified CPO can be retrieved easily for traceability cross-checking D.6. Processing D.6.1.The site shall assure and verify through Conform Records of receiving certified documented procedures and record keeping that the FFB are well been kept and RSPO certified palm oil is kept segregated from non- maintained. certified material including during transport and storage. Weight of certified FFB from each estate and sales documents of certified CPO can be retrieved easily for traceability cross-checking D.6.2 The objective is for 100 % segregated material to Conform The objective of 100% IP be reached. material is fully achieved as there is no processing of non-certified FFBs.

5.2 Noteworthy positive components and identified non conformances

5.2.1 Details of noteworthy positive components 1. Documentation are well established and documented 2. Shipping documents of invoices, test results, delivery notes, bills of lading are fully traceable, etc to each contract. 3. Auditees are supportive and cooperative.

5.2.2 Detail of non-conformity AUDIT OUTCOME

0 MAJOR Non-Conformities

6 Certified organization’s acknowledgement of internal responsibility

6.1 Date of next surveillance visit The next surveillance audit is scheduled within 9 – 10 months from certification date.

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6.2 Date of closing non-conformities

All major NCs closed by NA

All minor NCs to be closed by Next surveillance assessment

6.3 Formal sign-off of assessment findings Name of Client: New Britain Palm Oil Limited – Poliamba Limited Client number: 46117

Scope (unit of certification and supply base): 1 mill and supply bases from owned estates and VOPs smallholders. Production area (ha): 8,207.85 Certified area (ha): 10,633.97 Annual volume FFB: 88,356.16 mt Certified volume CPO: 17,892.12 mt Certified volume PK: 4,877.16 mt Type of certification: Production of CPO and PK Certificate number: 78814 Certification Decision Date: 9/04/2016 Issued by TÜV NORD Integra Address Statiestraat 164, 2600 Berchem, Antwerp, Belgium Telephone +32 3 287 37 60 Fax +32 3 287 37 61 Email [email protected] Website www.tuv-nord-integra.com Certifier (contact person) Gerrit De Weerdt Signature:

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Abbreviations: BOD Biological Oxygen Demand CLAU Clan Land Usage Agreement COP Code of Practice ERP Emergency Respond Plan PCD Pollution Control Device HCS High Carbon Stock HOP Higaturu Oil Palms ILG Incorporated Land Group ILO International Labour Organisation LG Land Group LLB Lease-leased back LSS Leased Settlement Scheme MG Management Guidelines OMP Oil Palm Management Program OPIC Oil Palm Industry Cooperation OPRA Oil Palm research Association POL Poliamba Ltd SAF Smallholders Approval Form SS Suspended Solids TDS Total Dissolve Solids TS Total Solids TSD Technical Services Department TSS Total Suspended Solids VOP Village Oil Palm VWS Vehicle Workshop WMA Wildlife Management Area WMP Waste Management Plan YTD Year-to-date

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