SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Rountable on Sustainable Palm Oil Annual Surveillance Assessment Report

PT. Sumber Indah Perkasa – Sungai Buaya Mill , ,

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

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

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

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List of Contents Page

A Scope of the Certification Assessment...... 4 A.1. National Interpretation Used ...... 4 A.2. Assessment Type (Estate and Mill) ...... 4 A.3. Location Map ...... 4 A.3.1. Data of the mill, certified tonnages (CPO, PK, FFB), and certified area ...... 5 A.4. Description of Supply Base...... 5 A.4.1. General Description ...... 5 A.4.2. Location of Supply Base ...... 5 A.4.3. Statistic of Supply Base ...... 6 A.5. Organizational Information and Contact Person ...... 7 A.5.1 Audit against the Rules for Partial Certification ...... 7 A.6. Date Certificate Issued and Scope of Certificate ...... 10 B. Assessment Process ...... 11 B.1. Certification Body ...... 11 B.2. Qualifications of the Assessment Team ...... 12 B.2.1. Qualifications of the Lead Assessor and Assessment Team ...... 12 B.3. Assessment Methodology ...... 13 B.3.1. General Overview ...... 13 B.4. Assessment Finding ...... 18 B.4.1. Summary of How Stakeholder Consultation was Organized...... 18 B.4.2. RSPO Supply Chain Checklist ...... 42 B.4.3. Status of Previously Minor Finding & Observation ...... 45 B.4.4. Stakeholder Consultation ...... 49 B.5. Date of Next Surveillance Visit ...... 50 C. Certified Organization’s Acknowledgement of Internal Responsibility ...... 51 C.1. Formal Sign-Off of the Assesssment Findings ...... 51 C.2. Statement by the Certifier Body on Behalf of PT. Sucofindo SBU-SICS ...... 52 Appendix 1 List of Abbreviation ...... 53 Appendix 2 Map ...... 55

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

A. 2. Assessment Type (Estate and Mill) Certification Unit : PT. Sumber Indah Perkasa – Sungai Buaya Mill located at Mesuji Timur, – Lampung, INDONESIA

A.3. Location map Please see Appendix 1 : the details of estate maps of 1. Overlay Map of Sungai Buaya Estate (SBYE), Gedung Aji Lama (GALA) Estate and Mesuji (MSJA) Estate, 2.Map of Rivers, 3.HCV , 4.Topography, 5. Planting Year Sumatera Island - Indonesia

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A. 3. 1. Data of the mill, certified tonnages (CPO, PK, FFB), and certified area Name Of Mill Sungai Buaya Mill PT. Sumber Indah Perkasa Location Address Desa Talang Batu, Kecamatan Mesuji Timur, Kabupaten Mesuji – Lampung GPS Reference Latitude : 4o07’ 43.00” S Longitude : 105o26’ 19.82” E Capacity 60 MT/Hour Actual Production (2014) CPO : 56,444.32 mt ; PK : 13,096.67 mt FFB : 255,932.87 mt Certified tonnages claimed CPO : 56,444.32 mt ; PK : 13,096.67 mt FFB : 255,932.87 mt Certified Area (based on IUP) 15,273.70 ha Planted Area 14,993.40 ha Certified tonnages sold *) CPO : 0 mt ; PK : 0 mt Certified tonnages purchased CPO : 0 mt ; PK : 0 mt Note *) So far, CPO is sold under ISCC Scheme

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A.4. Description of Supply Base A. 4. 1. General description

PT. Sumber Indah Perkasa operates 2 palm oil mills under PT Sumber Indah Perkasa, named PT Sumber Indah Perkasa - Sungai Buaya Mill (SBYM) and PT Sumber Indah Perkasa – Sungai Merah mill (SMRM). The raw material/ FFB for PT. Sumber Indah Perkasa - Sungai Buaya Mill is supplied from : 1. Sungai Buaya Estate (SBYE)- own estate, 2. KKPA Gedung Aji Lama (GALA) Estate - smallholder 3. KKPA Mesuji (MSJA) Estate - smallholder.

Total supplied FFB from these three (3) estates are 256,011.252 MT.

All estates are operated under one management of PT. Sumber Indah Perkasa. All estates located in Lampung, INDONESIA. PT. Sumber Indah Perkasa is a member of RSPO and they are implementing a program to achieve RSPO Certified Palm Oil for all its production. There is no plan to expand the land holding and therefore Principles 7 is not applicable to this assessment.

A. 4. 2. Location of the supply base GPS No. Estate Name Location Latitude Longitude 1 Sungai Buaya Estate Desa Talang Batu, (SBYE) Kecamatan Mesuji 4o09’44.86” S 105o26’09.23”E Timur, Kabupaten Mesuji – Lampung 2 KKPA Gedung Aji Lama Desa Paduan Rajawali, (GALA) Estate– Plasma Kecamatan Meraksa Aji, 4o 17’23.84” S 105o 25’54.68”E Kabupaten Tulang Bawang – Lampung 3 KKPA Mesuji (MSJA) Desa Brabasan, Estate– Plasma Kecamatan Tanjung 3o 58’40.74” S 105o 20’50.75” E Raya, Kabupaten Mesuji – Lampung

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A. 4. 3. Statistic of supply base Estate Planting Age/ Estimated Estimated No. Planted Area Name Year Planting Year FFB/Year CPO/Year 1 Sungai 1991 24 513.14 8,168.128 1,801.39 Buaya Estate 1992 23 2,720.94 48,930.098 10,790.89 (SBYE) 1993 22 1,118.24 17,392.164 3,835.83 1994 21 402.54 5,961.910 1,314.82 2000 15 30.66 520.710 114.84 SUB TOTAL 4,785.52 80,973.01 17,857.77 2 KKPA 1995 20 250.00 4,662.280 1,028.88 Gedung Aji Lama 1996 19 2,833.00 24,146.090 5,328.58 (GALA) 1997 18 1,313.00 21,798.520 4,810.51 Estate – Plasma 1998 17 606,00 8,334.680 1,839.30 SUB TOTAL 5,002 58,941.570 13,007.27 3 KKPA 1995 20 149.75 3,156.570 695.96 Mesuji (MSJA) 1996 19 2,631.25 59,017.080 13,011.99 Estate – 1997 18 1,891.88 42,373.320 9,342.40 Plasma 1998 17 533.00 11,470.230 2,528.94 SUB TOTAL 116,017.20 25,579.29 TOTAL 255,932.87 56,444.32

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A. 5. Organizational Information and Contact Person

PT. SUMBER INDAH PERKASA – Sungai Buaya Mill 1 Company Name (SBYM) 2 Personal Contact Ismu Zulfikar 3 Vice Management Humala Sinaga Sinarmas Land Plaza Menara 2 Lantai 30, Jalan M. H. 4 Company Address Thamrin No. 51, Jakarta, Indonesia 5 Company Status PMDN 7 Phone/ Fax 021 50338899 8 E-mail [email protected] 9 Website www.smart-tbk.com 10 RSPO membership number 1-0096-11-000-00

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

1. Assessment agenda

Date Location Agenda 16 Maret 2015 PT. Sumber Indah Perkasa During ASA I to verify legal documents, - Sungai Buaya Mill HCV, Labor Union and land conflict Kec. Mesuji Timur within the GAR group Kabupaten Mesuji Lampung Indonesia 2. Audit Team Findings in Correlation to the Rules Partial Certifications a. The Organization is a member of RSPO PT. Sumber Indah Perkasa has confirmed membership of the RSPO with no. 1-0096- 11-000-00 b. A Time Bound Plan for achieving certification within relevant entities ~

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

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Estimate Name of No Supply Base Company Location time of Mill Certification 1 Sungai Sungai Buaya PT. Sumber Lampung 2013 Buaya Mill Estate Indah Perkasa Certified Gedung Aji Lama KKPA Mesuji KKPA 2 Sungai Sungai Merah PT. Sumber Lampung 2013 Merah Mill Estate Indah Perkasa Certified Gedung Aji Baru KKPA Gedung Aji Lama KKPA 3 Pangkalan Sawit Mas Estate PT. Sawit Mas South 2014 Panji Mill Sejahtera 2nd stage audit 4 Bumi Sawit Bumi Sawit Estate PT. Bumi Sawit South 2014 Mill Permai Sumatra Progress final report 5 Muara Muara Kandis PT. Djuanda South 2014 Kandis Mill Muara Tawas Sawit Lestari Sumatra 2nd stage audit Pandawa KKPA Pandawa Plasma 6 Sungai Sungai Rungau PT. Sumber Central 2013 Rungau Estate Indah Perkasa Kalimantan Certified Mill Sungai Seruyan Estate Terawan Estate Tangar Estate Bukit Tiga Estate 7 Bukit Perak Bukit Perak PT. Bumi Permai Bangka 2014 Mill Bukit Permata Lestari Belitung 2nd stage audit 8 Tanjung Tanjung Kembiri PT. Foresta Bangka 2013 Kembiri Estate Lestari Dwikarya Belitung Certified Mill Tanjung Rusa 9 Sungai Sungai Kupang PT. Sinar South 2015 Kupang Estate Kencana Inti Kalimantan Mill Sungai Kupang Perkasa 10 Kasuari Cendrawasih PT. Sinar Papua 2015 Mill Nuri Estate Kencana Inti Rajawali Estate Perkasa Mambruk Estate 11 Senakin Senakin Estate PT. Purimas South 2015

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Mill Sasmita Kalimantan 12 Pekawai Kayung Estate PT. Agrolestari West 2014 Mill Pekawai Estate Mandiri Kalimantan Stage 1 audit Sungai Kelik Nanga Tayap Kayung Kemitraan 13 Kenanga Kencana Estate PT. Kencana West 2014 Mill Cendana Estate Graha Permai Kalimantan Progress final Kenanga Estate report Cempaka Estate Kencana Kenanga 14 Tanggar Manuhing Estate PT. Tapian Central 2015 Mill Kajuji Estate Nadenggan Kalimantan Stage 1 audit Sulin Estate Nahiyang Estate Katayang Estate Sungai Nusa Sako Estate Sungai Ayawan Estate 15 Perdana Perdana Estate PT. Binasawit Central 2015 Mill Lenggana Estate Abadi Pratama Kalimantan 1st stage audit Semandau Estate Muara Dua Estate 16 Kuayan Mentaya Estate PT. Agrokarya Central 2015 Mill Kuayan Estate Prima Lestari Kalimantan 1st stage audit Bukit Santuhai Estate Tajur Beras Seranau Estate Sapiri Estate 17 Belian Mill Gaharu Estate PT. Paramitra West 2015 Muara Tawang Internusa Kalimantan Estate Pratama Belian Estate Tengkawang Kapuas Hulu

The company has made the self declaration for partial certification rule and signed by management. The self declaration stated as belows (a-d) :

a. Significant Conflicts The company has the SOP for Conflict Land Resolution refers to RSPO criteria 6.4, 7.5

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and 7.6. All the conflicts so far has been resolved with mutual agreement. GAR also registered as member of RSPO Dispute Settlement Facility Advisory Group as a representative of grower. Supporting document is DSF RSPO member as a grower dated 22 April 2013. During the ASA I based on information and document forwarded by auditee there was no conflict regarding land in 2013-2015. b. No replacement of primary forest and or area with HCV’s since November 2005 or year 2007 (National Interpretation) PT. SMART Tbk, has been appointed to manage all companies under GAR Group. PT SMART Tbk has conducted Historical HCV Assessment (HHA) in collaboration with Faculty of Forestry, Institut Pertanian Bogor (IPB) April 2011. Historical HCV Assessment (HHA) Report has been submitted to RSPO on May 2011. As a follow up from the Historical HCV Assessment (HHA) Report, GAR has been proposed HCV Remediation Plan to RSPO. Revision of HCV Remediation Plan is on going process/ discussion with RSPO Biodiversity and HCV Working Group (BHCV WG). Supporting documents is Historical HCV Assessment (HHA) report. Company has submitted to RSPO regarding the latest development on 04 September 2014 by email to RSPO compensation c. No labor disputes that are not being resolved through an agreed The company has the SOP and mechanism to resolve dispute with union labor with mutually agreement. During the ASA I based on information and document forwarded by auditee there was no labor dispute in 2013-2015. d. No evidence of non-compliance with law in any of the non-certified holdings The company has comply with the applicable law and regulation refers to RSPO criteria 2.1.which stated no evidence of non-compliance with the applicable regulation. Supporting documents are copies of SK AMDAL, SK HGU, IUP, IMB.

A.6. Date Certificate Issued and Scope of Certificate Name of Client PT SUMBER INDAH PERKASA – Sungai Buaya Mill Client Number RSPO 00003 Certificate Number RSPO 00003 Certification Decision Date May, 2nd 2014 Issued by PT SUCOFINDO, SBU SICS Address Graha Sucofindo, SBU SICS. Jl Raya Pasar Minggu Kav 34 Jakarta 13640 Telephone /Fax Tel.: +62-21-7983666 / Fax.: +62-21-7987015 Email [email protected] Website www.sucofindo.co.id

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Scope : Mill PT. Sumber Indah Perkasa - Sungai Buaya Mill (SBYM) Estate 1. Sungai Buaya Estate (SBYE) 2. Mesuji Estate (MSJA) 3. Gedung Aji Lama Estate (GALA) Projected mass balance CPO & PK CPO : 56,444.32 MT and PK : 13,096.67 MT Certification Registration Code SICS-00003 Type of Certification Single site Certifier Triyan Aidilfitri Signed

B. Assessment Process B. 1. Certification Body SUCOFINDO SUCOFINDO ICS INTERNATIONAL CERTIFICATION SERVICES (SUCOFINDO ICS), which was formed in 1994, is one of the strategic business unit that provides certification services for leading companies. Sucofindo Certification by International Certification Services is recognized nationally and international.Quality Management System Certification by SUCOFINDO ICS has obtained accreditation from National Accreditation Committee (KAN-Indonesia). Lead Auditors and Auditors of SUCOFINDO ICS are trained professionals in the field of international standards, auditing and management systems and are registered in the IRCA (International Register of Certified Auditors) and IEMA (Institute of Environmental Management & Assessment), UK. SUCOFINDO ICS certification process is supported by experts at PT. SUCOFINDO who understand the industry sectors and services in Indonesia. SUCOFINDO ICS Operational is supported by a network of branch and representative offices of PT. SUCOFINDO spread in 45 cities across Indonesia. The services provided by International Certification Services Sucofindo are: . Quality Management System Certification . Environmental Management System

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. ISO 22000 :2005 . OHSAS 18000 Certification . Hazard Analytical Critical and Control Point (HACCP) Certification . Good Manufacturing Practice (GMP) Audit . Product Certification . Sustainable Forest Management Certification . Products Organic Food Certification . RSPO certification . ISPO Certification . Certification of Integrated Management System Certification (SMT) . Training

B. 2. Qualifications of the Assessment Team

B. 2. 1. Qualifications of the Lead Assessor and Assessment Team The assessment team members of this surveillance audit are as per the table below. Among them only Ganjar who were part of the assessment team of the previous audit (certification audit) Nuzwardy Sjahwil : He graduated from Institutee Agriculture of Bogor (IPB). He has more than 5 years audit experiences in OSHAS and SMK3. He has successfully completion from Lead auditor for SMK3, Lead Auditor for OHSAS and Lead Auditor for ISO 9001. He has successfully completion training Lead Auditor RSPO by Proforest, Lead Auditor Training by Komisi ISPO, Jakarta, and Supply Chain Training. RSPO GHG, RSPO Supply Chain Certification System. Ronald E Butar-Butar (Auditor) S1 graduated from Catholic University Faculty of Agriculture. Work Experience (Best Practice Estates) in oil palm estates for 6 years. He has successfully completion Lead Auditor Training ISPO by Komisi ISPO. He has completion In House Training RSPO for 4 days. Hidayat Pramudiyanto (Auditor): He graduated from University of Diponegoro, Semarang He has the training AMDAL A at Universityy of Gadjah Mada Yogyakarta, April 1994, AMDAL B at University of Diponegoro, Semarang, October 1998, Monitoring of environment quality and waste, IRCA Environmental Management Systems Auditor / Lead Auditor Course, Ganjar Gumelar (Auditor): He graduated from University of Gadjah Mada (UGM), Forestry Faculty, majoring in Forest Management, Yogyakarta. He has completed the training such as Indonesian Sustainable Palm Oil (ISPO) auditor training, Komisi ISPO – Ministry of Agriculture & Komisi Akreditasi Nasional (KAN), Bogor (West Java) & Pangkalan Bun (Kalimantan), Indonesia, 2013 ;ISO 9001 : 2000 Quality Management Sucofindo ICS FRM 14.05 12 of 70

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Systems (QMS) Auditor/Lead Auditor Training Course (IRCA),PT. SUCOFINDO (Persero), Jakarta, Indonesia, 2013 ; Awareness Hazard Analysis Critical Control Point (HACCP), PT. SUCOFINDO (Persero), Jakarta, Indonesia, 2013 ; Life Cycle AssessmentWorkshop Oil Palm Plantation and Oil Palm Milling, Life Cycle Sustainability Assessment Lab &State Minister for The Environment, Jakarta, Indonesia, 2013 ; Assessor Training High Conservation Value Forest – HCVF, Tropenbos International Indonesia Program, The Nature Conservancy (TNC), WWF Indonesia & Institut Pertanian STIPER (INSTIPER) Yogyakarta, Yogyakarta, Indonesia (2011).

B.3. Assessment Methodology B. 3. 1. General Overview The assessment was carryingout in conformity with the SBU SICS RSPO manual and procedures for auditor and certifier. The assessment was conducted by qualified auditors and referred to RSPO standard as endorsed for the Indonesia National interpretation. Partial certification audit conducted during ASA I to check compliance with Final RSPO Certification System for partial certification. The opening and closing meeting was conducted at the office of Sungai Buaya Estate and then continue in Mill’s and estate’s offices. Stakeholders meeting was conducted once, during ASA.

Date/Time Functions / areas / Department / activities to be audited (include related requirements) 16 Maret 2015 Day 1st Audit 05:40 Departure from Jakarta – Lampung 14.00 Departure to Regional Office Sungai Buaya Estate 18:00 Arrived at site 17.00 End of the day 1 17 Maret 2015 Day 2nd Audit 08.00 Location: Sungai Buaya Estate (Division II blok 14-15) Opening Meeting Document audit  Check completeness of previous NCR minor and observation  RSPO - SCCS  Partial Certification  Land conflict and compensation

 Check completeness of previous NCR minor and observation  Prevention of land fire  Check completeness of previous NCR minor and observation  Licensing and legality  Check completeness of previous NCR minor and observation  HCV 12.00 Break  Estate and mill management Sucofindo ICS FRM 14.05 13 of 70

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 Information provision  Social responsibility  Empowerment of local/indigenous people  Development of local businesses  Continous improvement  FFB processing  Worker welfare (2.1, 4.8, 6.5)  Child labour (2.1, 6.7, 6.8)  Meeting with Union  Sexual harrasment (6.9)  Ethical conduct  Humant right  Occupational health and safety and legal requirement regarding heath and safety  Water conservation  Environmental monitoring  AMDAL, UKL, UPL  GHG mitigation  Utilization of hazardous waste  Renewable energy  Legality  Community plantation  New Planting  Seeding management  Cultivation at mineral land  Cultivation at peat land  Manuring  Pest management  Harvesting  HCV  Erosion control  Biodiversisty 12:00 Break 14:00 Estate Sungai Merah  Land conflict and compensation  Worker welfare  Child labour  Policy of prohibiton of mercenary  HCV  Erosion control  Biodiversisty  Water conservation

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 Environmental monitoring  AMDAL, UKL, UPL  GHG Mitigation  Utilization of hazardous waste  Renewable energy  Occupational health and safety and legal requirement regarding health and safety  Legality  Community plantation  Land clearing  Seeding  Plantation at mineral soil  Plantation at peat soil  Best practice at estate  Pest management program : listed pesticide  Harvesting  High conservation value  Erosion control  Biodiversisty  Water conservation  Environmental monitoring  AMDAL, UKL, UPL  GHG Mitigation and renewable energy  Utilization of hazardous waste  Occupational health and safety and legal requirement regarding health and safety  Legality  Community plantation Field visit planning 18.00 End of day 1 Wednesday, Day 3 18/03/15 07.30 Estate visit Sungai Buaya Block 1  OSH, Worker welfare, housing facility, bathing facility for pesticide handler  High Conservation Value and Best Practice Estate  Sexual harassment Block 2  OSH, Worker welfare, housing facility, bathing facility for pesticide handler  High Conservation Value and Best Practice Estate  Visiting BPN Pole

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 Sexual harassment 10:00 Visit to GAL KKPA  1.2 Kebun Masyarakat (6.1, 6.10) 12:00 Break 13:00 Visit to Mesuji KKPA 1.2 Kebun Masyarakat (6.1, 6.10) Location: Mill Sungai Buaya  OSH  Environmental monitoring  AMDAL, UKL, UPL  Emergency preparadness  GHG mitigation  Hazardous waste utilization Sungai Buaya Mill  FFB Processing  RSPO Supply Chain  Worker welfare  TBS receiving from plasma dan out grower (6.10) 18:00 End of audit day 3 Thursday, Day 4 19/03/15 Sungai Merah Estate 07:30 Block .. (to be discussed)  OSH, Worker welfare, housing facility, bathing facility for pesticide handler  High Conservation Value and Best Practice Estate  Visiting BPN Pole  Sexual harassment Visit to GABA KKPA  Community plantation 10:00  Social (Meeting with stakeholders : managed small holder and leader of local community ) 12:00 Break Location: Sungai Merah Mill  OSH  Environmental monitoring  AMDAL, UKL, UPL  Emergency preparadness  GHG mitigation  Hazardous waste utilization  Worker welfare  FFB Processing 15:00  RSPO Supply Chain

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 TBS receiving from plasma dan out grower (6.10) 16:00 End of audit day 4 Friday, Day 5 20/03/15 09:00 Closing Meeting 11:00 End of audit 11:30 Road trip to 18:35 Flight to Jakarta Scope : 2 mills and 5 estates Number of assessor participating: 4 auditors Number of days spent for the assessment on site : 4 days Total number of mandays used for the assessment on site :16 days

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B.4 Assessment Findings B.4.1 Summary of the Findings by Criteria 1 COMMITMENT TO TRANSPARENCY 1.1 Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages & forms to allow for effective participation in decision making. Company has established SOP of Comunication and Consultation (SOP/SMART/UMUM/SADV/1/004). List of information is in place that is accessible to relevant stakeholders, which is different between mill, main estate and plasma estate. Estate Manager is responsible for providing stakeholders with relevant information particularly information relating to social aspect. Every information request and the respective response are recorded at log book, while every information release to relevant stake holder is recorded in “Buku komunikasi” (communication book). Written recorded Information is routine infomation to related institution which need to be submitted on regular basis. The sample or regular information i.e report to insurance company (Jamsostek), extension of vehicle permit and reguler inspection of operational vehicle. Based on sample taken regarding, the Information request have been responded accordingly. The sample i.e cement request from Kampung Sidoharjo on 26 Februari 2015, were responded by delivering cements amounting 97 bags. Reguest cash to fund the celebration of Indonesian Independ day from Desa Sungai Cambai has been responded by funding those celebration amounting to Rp. 500,000. The records of information requests and responses are kept with retention time of 10 years. Status: Conform 1.2 Management documents are publicly available except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes Company as explained in 1.1 SOP of Communication and Consultation. It is Estate manager who responsible to release information to related stake holder, especially ones related to social aspect. Company has identified publicly information dan classsified ones. Confidential documents are documents outside the list of information to Stakeholder, such as commercial data and data causing negative impacts that are accessible only upon management’s approval, e.g. conflict data. In general, data may be accessed /asked by relevant stakeholders as long as relevant. In addition there are data that can be given only to relevant agencies, for example production data is given to the Regency and Provincial Plantation Service. Publicly information/documents are as follow  Land legality which detailed further at 2.2  Enviromental document as described at 5.1.  Labour document which detailed further at 6.5  Occupational safety and health document as described further at 4.7

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The records of information requests and responses are kept with retention time of 10 years. Based on data of information record, during 2014 there was no information request form stakeholder regarding the above publicly information. Status: Conform 1.3 Grower and millers commit to ethical conduct in all business operation and transaction Company already as written police to ethical conduct in GAR Social and Community Engagement which stated its commitment to actively and constructively engaging with all GAR's stakeholders, including communities, government, customers, and civil society at the local, national and international levels. Status: Conform 2 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS 2.1 There is compliance with all applicable local, national and ratified international laws and regulations. Company has made periodic evaluation of all regulations which is regulated through SOP/SPO/SMART/LH/03 (Legal and Other Requirements rev 01), which is evaluated per semester. Central office’s Sustainability division performs evaluation and the results are communicated to the units (estates and mills), which in turn will select those regulations relevant to them. The complainces to law and regulation are further detailed as follow;: 1. Occupation safety and health at 4.7 2. Labour and manpower at 6.5 3. Union at 6.6 4. Land tenure and legality 6.6 Water used for activities in the palm oil mill and surrounding housing of SBYM was supplied from Sungai Buaya, however the company did not have permits those source of water from the relevant authorities. This has been made as Major non-conformity . Based on letter no. 520/342/ii.07/2015 from Badan Penanaman Modal dan Pelayanan Perizinan terpadu (Board of Integrated of Investation and Pemit Services), the permit to use survace water are still in progress. Therefore the status of this finding is downgrading as minor non conformity. Status: Minor Non Conformity No. 8 2.2 The right to use the land is demonstrated, and is not legitimately contested by local people who can demonstrate that they have legal, customary or user rights Right over the land Based on report of environmental impact analisis of PT. SIP, the location of this plantation are in according to Master Plan of Lampung Province no. 05 2001, where this location are set as production development area. 1. Company has made an overlay map (plantation and forest area) based on Situation map of HGU no. 32 year 1993 and no. 2 year 2000 as well as map of forestry area and water area of of Lampung Province, at scale of 1:250.000. This overlay map has already had coordinat data. Due to the map issued by BPN has not been furnished with the coordinat data, company made its own coordinat in it.

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Company already has a letter from Forestry Department, Regional Office of Lampung Province no. 1052/Kanwil-6/TGH 134/90 dated 16 July 1990 stating that the area managed by PT Sumber Indah Perkasa, which is located to the East and bordering with permanent production forest of Sungai Buaya Reg.45, is not overlapping with the forest area. Site permit Company has been granted location permit based Governor decree no. C/202/DA/HK /1989 amounting to 9000 Ha on behalf of PT. Sumber Indah Permai. This permit then revised to be 9522,11 Ha by Governor decree no. C/309/BPH/HK/1990. Company previous name is PT Sumber Indah Permai and then changes name to become PT Sumber Indah Perkasa. Change in the company name has been notarized by a Notary Deed dated 20 September 1990 (Benny Kristianto and associate) and secured in the Decree of the Minister of Justice no. C2-5826 HT.01.01.Th90./HK/1990. Plantation Business Permit Company already posseses plantation business permit (IUP) no. 956/Menhutbun-VII/2000 dated 8 Agustus 2000 for 1 mill with capacity 30 ton FFB/jam and a landmass of 9046,63 Ha. Company increase processing capacity by 60 ton FFB/hour for one line thus the mill capacity increase to 120 ton FFB/hour. The increase of capacity has been approved by Ministry of Investation (BKPM) no. 46/II/PMDN1998 dated 01 July 1998 regarding the approval to increase the capacity to 120 ton FFB/hour and letter from the Board of Investment and Regional Integrated Permit Service with No. 800/200/BID.V/II.06/2013 dated 1 July 2013 for the management of mills with a capacity of 120 ton FFB/hour and secured by letter No 800/200/BID.V/II.06/2013 on 01 Juli 2013 issued by provincial investment body (BKPM). SK HGU for PT SIP Company has HGU certificate from BPN no. 1/HGU/BPN/93 dated 30 January 1993 for area amounting to 9.522.11 ha dated 30 Januari 1993. In line with SK BPN No. 1/HGU/BPN/93 area granted to PT SUMBER INDAH PERKASA Bandar Lampung covered Desa Sungai Sidang, Sungai Cambai, Talang Gunung, Kecamatan Mesuji, dan Desa Gedung Aji. Desa Gedung Meneng, Kecamatan Manggala, Kabupaten Lampung Utara Propinsi Lampung. - HGU certificate consist of : Sungai Buaya Estate (SBYE) This HGU issued by Kabupaten Lampung Utara no. 08.04.15.01.2.00014 dated 21 Juli 1993 for amounting to 5.058,82 ha for SBYE which valid until 31 Desember 2027. Maintenance of BPN poles The company has established SOP “Prosedur pemeliharaan patok” No. SOP/SMART/CERS- EHSP/SADV/I/004 for maintaining land poles. Company has maintained the land poles, i.e land pole HGU no.10 dan 12 . The company has established SOP for maintaining HGU poles dan conducted monitoring and maintenance to those poles. It is advised that in the monitoring check list to be inputed the coordinate data of those poles. HGB Company has obtained HGB for mill No. 62 (NIB 08.06.02.17.2.00062) with area 58,20 Ha, located at Desa Sidomukti, Kecamatan Manggala Kabupaten Tulang Bawang. This HGB issued by beurau of land affair (Kantor Pertanahan) Kabupaten Tulang Bawang at 25 March 2000.

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Pemit to build ( IMB) Company has obtain several permit to build for building in the estate as follow :  IMB No. 503/600/201-14/II/IMB/2001 issue on 14 Februari 2001 for housing complex and several social facility and general facility building.  IMB No. 503/600/VII/IMB/2000 issue on 17 July for housing complex, office, worshop and warehouses. Conflict Company has documented the conflict management in SOP “Penanganan Konflik Sosial” (SOP/SMART/SENSES-CSRD/SADV/I/2) and land right compensation “in prosedur ganti rugi lahan/tanah” SOP/NP/SMART/VII/D&L002. This procedure also include the compensation for the lost of customary right over the land as stated in point 6.2 Based on the information collected form (local village cooperative) KUD and revelant stakeholder from teh surrounding village, there were no conflict over the land since 2010. Based on SIA report isued by company itself there were no customary right identified. The land for the estate has been cleared in the beginning of 1990 before RSPO, therefore there is no data whether the mechanism of FPIC was practiced during that time. During this surveillance audit there were no paramilitary force or military force observed in the estate. Status: Observation No. 1 2.3 Use of land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent. Based on the information collected form (local village cooperative) KUD and revelant stakeholder from the surrounding village, there were no conflict over the land as well as land accuisiton since 2010. Based on SIA report isued by company itself there were no customary right identified therefore in the map No. Reg: 948/214/PMNP/VI/12 scale 1 : 250,000, no customary land showed. As has been previously described at point 2.2 there were no new land accuisiton since 2010. Status: Conform 3 COMMITMENT TO LONG-TERM ECONOMIC AND FINANCIAL VIABILITY 3.1 There is an implemented management plan that aims to achieve long-term economic and financial viability Company has made long term and short term financial and operational planning. The long term ones has been made for operational/financial planning up to 2020. This document explain that the first replanting will commence at 2017 until 2020 covers 5 estate which covered area as much as 23,443.87 ha. Status: Conform 4 USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS 4.1 Operating procedures are appropriately documented and consistently implemented and monitored

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Company has documented estate and mill operation with detail as follows: Estate Land clearing procedure is documented in SOP Pedoman Teknis Persiapan Lahan (Technical guidance for land preparation) issued on 1st July 2010 and Pedoman Teknis Penanaman Kelapa Sawit (technical guidance for Palm oil Plantation/MCAR) which is detailed in several work instruction. MCAR technical guidance encompased as well for SOP for land clearing (SOP/SMART/MCAR/IV/TA-PLB) prohibit land preparation using open fire (zero burning). Also available SOP for harvesting as documented in procedure no. SOP/SMART/ MCAR/XIII/TA- PNN which rever to SOP dan WI of Teknis Budidaya Tanaman Kelapa Sawit (cultivation technique for Palm oil) Smart Agribusiness and Food. This procedure also explains the harvesting preparation, the desired criteria for FFB. Harvesting has been conducted properly and so has with the arrangement of FFB at collecting point. It is advised to repair the FFB collecting point to maintain th quality of FFB at collecting point. Mill Company has documented SOP of Palm Oil Processing in (SOP-PENGOLAHAN/Review MCMD/1/2013). This SOP covers processing from FFB reception until CPO storage, and the SOP for operating and maintenance of utility. There are list measuring equipment in the laboraty as well as calibration planning for each of them. Calibration is conducted internally for research office and also validation of equipment and personal competency for the personnel in the laboratory. This company has weight bridge which has been legally calibrated every six month by Badan metrologi (beurau of weights and measurements). The quality of CPO area monitored per hour and recorded in the logsheet. The parameter which is regularly monitored i.e FFA, moisture content, impurity and DOBI (degree of bleachability index). The totall FFB received by SBYM during 2014 was 259,067.33 tonnes and total CPO produced is 57,118.52 tonnes, kernel as much as 13,096.67 tonnes. The extraction rate were 22,00% (OER) and 5.00% (KER) respectivelly. All FFB received were certified ones which originated form its own estate and full managed small holder. The appropriate supply chain was IP (identity preserved). Status: Observation No. 2 4.2 Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield Company has implement leaf analysis and the respective result was documented in Internal memorandum ef. 254/DAUN/LAB-SMARTRI/VI/2014 on 20 Juni 2014 and 292/DAUN/LAB- SMARTRI/VI/2014 on 29 June 2014. The result analysis taken from 40 LSU (leave sampling unit) for parameter N, P, K, Mg, Ca, B, Cl, Rutin, Fe, CL. Based on the result of soil analysis and leave analysis, the recommendation for fertilzation the dossage was : KA, 1,16%, N 2,48%, P 0,150%, K 0,76%, Mg 0,26%, Ca 0,73%, B 19 ppm, Cl 0,67%. Sungai Buaya Estate (SBYE) Company has record of utilizaiton of every kind of fertilizer and herbicide until Desember 2014 based on the dosage recommended by Smartri (Smart Research Institute) for a landmass of 4.785,52 Ha. The ulitilization of every kind of fertizer and herbice are as follow:

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1. Urea : 621.871 Kg. 2. DAP : 278.396 Kg. 3. MKP : 9.355 Kg. 4. Kieserite Granular : 486.844 Kg. 5. TSP : 57.934 Kg. 6. MOP : 1.574.065 Kg. 7. Kies. Powder : 66.500 Kg. 8. Kaptan : 170.100 Kg. 9. CuSO4 : 14.189 Kg. 10. ZnSO4 : 8.512 Kg. Mesuji (MSJA) KKPA Company has implement leaf analysis and the respective result was documented in Internal memorandum ref. 255/DAUN/LAB-SMARTRI/VI/2014 on 20 Juni 2014. The result perihal analysis taken from 24 LSU (leave sampling unit) for parameter N, P, K, Mg, Ca, B, Cl, Rutin, Fe, CL. Based on the result of soil analysis and leave analysis at Block GAVA V1 B19, the recommendation for fertilzation in 2014 the dossage were : KA, 1,20%, N 2,22%, P 0,146%, K 0,83%, Mg 0,26%, Ca 0,65%, B 20 ppm, Cl 0,67%. Based on the result of soil analysis and leave analysis at Block MSJA 11 B11, the recommendation for fertilzation in 2014 the dossage were : KA, 1,22%, N 2,41%, P 0,145%, K 0,88%, Mg 0,31%, Ca 0,37%, B 14 ppm, Cl 0,60%. Gedung Aji Lama (GALA) KKPA Company has implement leaf analysis and the respective result documented in Internal memorandum ref. 256/DAUN/LAB-SMARTRI/VI/2014 on 20 Juni 2014. The result perihal analysis taken from 24 LSU (leave sampling unit) for parameter N, P, K, Mg, Ca, B, Cl, Rutin, Fe, CL. Palm oil mill effluent (POME) is also utilized as land application. The company already obtain lisence to use POME as land application from local environmental authority B/342/ 1.02/ HK / MSJ / 2014 on 6 Oktober 2014, valid until 3 years. The POME at SBYM is applicated to fertilize 355.53 ha at 14 blokcs of estate from F14 - F18, G10-15 and H12-14, located at Desa Talang Batu, kecamatan Mesuji, Kabupaten Mesuji. The volume of the POME to land application during January 2015 was 20.651 m3 Status: Conform 4.3 Practices minimize and control erosion and degradation of soils. Company has commitment to minimize dan control the erosion and prevent the degradation soil quality by making topographical map and river map in every unit of its estate. The slope of at area og SBYE, GALA and MSJA is classified into two classes i.e flat land which slope between 0 – 8%, and wavy land which slope between 8 – 15%. The land was dominated by flat ones. The estimation of danger or erotion rate (TBE) at SBYE, GALA and MSJA based on slope and kind of soil are classified as low until medium. According Kpeterss no. 32 1990 and PP NO. 26 2008, the plantation acitivy is enabled in the area with slope less than 40%. The erotion control and preservation of land quality was documented in SOP Pengelolaan dan Pemantauan Nilai Konservasi Tinggi (Management and monitoring of high conservation value area)

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No. SOP/SAMART/BCOS-EHSD/SADV/I/002 and in the collection of SOP/WI Sustainable Palm Oil, 2014, WI to monitor erotion No. F/SMART/BCOS-EHSD/SADV/002/004 dan SOP Management and monitoring of water resources No. SOP/SAMART/BCOS-EHSD/SADV/I/004. The rule of land and water conservation in SBYE, GALA and MSJA has been done by planting cover crop Mucuna and making ditches. There are records erotion measurement conducted on Division at Block G-16 on 6 March 2015. The acivity covered : - Terresan - Pit pond - LCC planting - Weeding management - Midribh arrangement - Empty bunch application Sungai Buaya Estate (SBYE) Company has record regarding planting in the peat land i.e Year 1992 : 100,88 Ha Year 1993 : 347,13 Ha Year 1994 : 320,63 Ha with mineral soil amounting to 768,64 Ha. Gedung Aji Lama (GALA) KKPA and Mesuji (MSJA) KKPA have no peat land. Status: Conform 4.4 Practices maintain the quality and availability of surface and groundwater. In an effort to maintain the quality of groundwater and surface water, the Company has the SOP Management and Monitoring of Water Resources no. No. SOP/SAMART/BCOS-EHSD/SADV/I/004 contained in set of SOP – WI Sustainable Palm Oil, 2014. In the implementation the company has spared the riparian at a distance of 50 meters from the edge of the river. The river banks were planted with bamboo plants to prevent erosion. Socialization has been made to employees and the community / farmers around the estate through sign board in the form of prohibition on the use of the river, such fishing, burning, and cultivation. According to the record of water usage at Mill per ton FFB in January 2015 is 1.1 m3 of water. The usage water for the domestic requirement is 2000 m3 / month, thus a mill capacity of 60 tonnes of FFB per hour, the total usage of river water is 14,984 m3 / month. Estate Water demand for estate operational purposes in each section (housing, offices and washing equipment PPE pesticides) is supplied by under ground water wells (wells drilled) that exist on each section of estate. Water which is used for housing needs around SBYE, has been analysed and meets the requirements according to Permenkes no. 416 – 1990. Company has obtain pemit to use depth water (SIPA) from Mesuji District Government Office of Energy & Mining, number: 540/06 / SPKTS-SIPA / III.14 / MSJ / IV / 2013, permits the wellbore

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depth of ± 100 m, covering 3 consists Mesuji point and 1 at sidang Gunung Tiga at April 7, 2013. At the office estate of SBYE and the nearby housing complex water is supplied from depth drilled well. This water has been analized and the result was still met to Permenkes 416/1990. Monitoring of well water in accordance with water quality standards based Permenkes no. 416 of 1990 has been carried out by the Health Polytechnic Tanjung Karang, has included factors such as Coliform microbiology. Should certainly all parameters are measured in accordance with the regulations mentioned above. Thih has been made as an Observation no. 11. However during the surveillance audit in SBYE in section V, VI and IV, there were drilled wells which doesnt have-related licenses, water analysis, and water usage and this has been raised as a minor non- conformity.

Mill Water used for activities in the palm oil mill and surrounding housing of SBYM was supplied from Sungai Buaya, however the company did not have permits those source of water from the relevant authorities. This has been made as Major non-conformity on criterion 2.1. The company has made corrective action which then finding is down graded as minor non conformtity as explained in 2.1. The water from the Sungai Buaya was collected in a reservoir. This water is then processed through a series of treatment before usage for processing and activities in Palm Oil Mill. Palm oil mill monitored water quality independently. The company carries out monitoring of the water in every stage of treatments on a daily basis to ensure that the water used in production processes meet the requirements. The monitoring of the quality of water from Sungai Buaya, was conducted by external laboratories in accordance with Goverment Regulation no. 82 2001 class II. The efficiency of water usage for processing in SBYM in January 2015 of was 1.1 m3 per tonne of FFB. The Company has conducted monitoring of BOD from the POME as described in 5.6 Status: Minor non-conformity No. 10 ; Observation No. 11 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management Techniques To control pests and plant diseases, the Company has developed procedures to control pests and plant diseases as documented in SOP - Technical Work Instruttion of palm oil Cultivation, Smart Agribusiness and Food and SOP Plant Pests and Diseases Control (SOP / SMART / MCAR / VII / hands HPT, 09.01.2012). Some important pests and diseases of productive crops are : 1. kumbang tanduk 2. Tirathaba ruvivena and Tirathaba mundela 3. Silkworm Palm Leaf Eater 4. Ulat Kantong 5. Mice 6. Ganoderm 7. Hog

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The company has OPT personnels i.e pest census personnel. Every division is provided 3 OPT personnel. There was training UPDKS census on 29 September 2011, furnished with evidence of: photographs, attendance list. Instructor for this training is Section Research region. The material for is documented in training Module for Integrated Pest Management (IPM). Sungai Buaya Estate (SBYE) The company already has a team of pest observers and census. The company has done Integrated Pest Management Training, Soil and Leaf Sampling Unit Sampling Unit held on January 31, 2015 which was attended by 20 participants. There are evaluation, attendance and training materials. At SBYE there is one team of sprayer @ 24 people. These sprayer personnel has been trained by local agriculture Lampung 18/10/2011 to SBYE. There was training about related SOP and WI. This training conducted on 27 April 2013 which is attended by 64 participant At the SBYE, the census of rat during 2012-2013, was conducted quarterly, census of UPDKS (Silkworm Palm Leaf Eater), was conducted every month during 2009- 2013. Maintenance of Biological Control agent plant, is conducted every month, includes: Turnera subulata, Antigonon sp. and Nephrolephis biesserata. There was map showing plan and realization maintenance Biological Control agent plant such as Turnera sp. and Antigonon sp. and realization There are records census of rat attacks, pest management of oil palm leaf eaters (UPDKS), census Gupon of owl / Tyto Alba and records maintenance of host plants for caterpillars predator, kutib pupa, light trap. Samples taken at the census rat attacks on SBYE in of October 2014 at Division VI there was rat attacks of 4.13%. The rate of rat attack was still below the critical threshold of 5%. Thus the rat attacks on plantationof SBYE, catagized as Light (below the critical threshold). There was no worm attack a fire in the garden area Sungai Buaya Estate (SBYE). Gedung Aji Lama (GALA) KKPA There are records census of rat attacks, pest management of oil palm leaf eaters (UPDKS), census Gupon of owl / Tyto Alba and records maintenance of host plants for caterpillars predator, kutib pupa, light trap. Samples taken at the census rat attacks showed the rat attacks at the rate of 4.13%, The rate of rat attack was still below the critical threshold of 5%. Thus the rat attacks on plantationof GALA, catagized as Light (below the critical threshold). Mesuji (MSJA) KKPA The company already set pest and desease team in this full managed small holder estate. Training for the team has been conducted on 28 January 2015 which attended by 34 Participat, complete with evaluation result, attendant list and training modules. There are records census of rat attacks, pest management of oil palm leaf eaters (UPDKS), census Gupon of owl / Tyto Alba and records maintenance of host plants for caterpillars predator, kutib pupa, light trap. Samples taken at the census rat attacks on Mesuji Estate in October 2014 at Division III showed that rat attacks of at the rate of 3,40%, Thus te rate the rat attacks on this estate, catagorized as Light (below the critical threshold). There was no worm attack a fire in the estate area of Sungai Buaya (SBYE). Company has a list of pesticide both sinthetic and natural ones such as Rolixon, Gromoxone, Roll up and natural insecticide Cordiceps. The company already has a records of the types of fertilizers and herbicides used until in December 2014 according to the dose recommendation of Smartri (Smart Research Institute) for an area of 4785.52 hectares, of which at GALA KKPA use Sucofindo ICS FRM 14.05 26 of 70

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1. Glifosate : 2.244,85 Liter 2. Paraquat : 131,73 Liter At Mesuji (MSJA) KKPA the usage of Paraquat was 489,27 Liter. The company has done the planting of beneficial plant almost evenly across all the estate of PT. SIP. Planting of beneficial plant is done so that the whole block has a plant that serves as the host of biological enemies of plant pests and diseases. Sungai Buaya Estate (SBYE), Gedung Aji Lama (GALA) KKPA dan Mesuji (MSJA) KKPA has a program and a realization of maintenance and planting host plants Turnera subulata and Antigonon leptopus 2015. Status: Conform 4.6 Pesticides are used in a way that do not endanger health or the environment. The Company already has a list of agricultural pesticides used. This list refer to recommendations by the Pesticide Commission of the Republic of Indonesia, i.e Erkafuron 20 WG with the active ingredient of metal metsufuron 20%, Rolixone 276 SL with the active ingredient Paraquat dichloride 276 g / l, Roll Up 480 SL with the active ingredient glyphosate isopropyl amine 480 g / l with manufacturer PT. Chemical Rolimex Nusamas and Starane 290 EC with the active ingredient Fluroxypyt methyl heptyl ester 290 g / l with manufacturer PT. Dow Agroscinces Indonesia. The company also has reduced the use of paraquat active ingredients herbicide. Based on the record in 2014, there were reduction to the use paraquat based herbicide. There was a Memorandum of central leadership to the entire estate of a reduction in the use of paraquat. There is a letter of agreement between the company and suppliers of herbicides, PT. Chemical Rolimex Nusamas no. 011 / RKN - FER / PER / V / 2014 to deliver the used packaging to producers. There was evidence over the handover jerry can of 20 liters Rolixone, Roll Up, Erkafuron of SBYE, SMRE, GALA, MSJA to occurred PT. Chemical Rolimex Nusamas on June 7, 2014. The company has the SOP associated with Pesticides Waste Handling. Rolymex accept packaging ex pesticides in the form jerry can and plastic bottles. Non rolymex ex pesticide packaging were collected in a special warehouse after appropriate treatment according to WI of Ex Washing and Cleaning Pesticides and Fertilizers Sacks, SIP-SBYEIK / 19, Revision No: 00 dated March 1, 2012. The Company already has a list of synthetic and natural pesticide to weeds and caterpillars include synthetic herbicides Rolixon, Gramoxone, rollup and natural insecticides Cordyceps to control caterpillars fire. However, the company should reduce the use herbicide with active ingredients paraquat (limited pesticide), and subtitute it with a herbicide which quite either effectvie to control weed or safe for operators in the long term. There are records of results of medical examinations of cholineterase and spirometry for pesticide handlers to 102 people were conducted on 4 - March 5, 2015 by the Center for Occupational Health and Safety Department of Manpower and Transmigration Lampung Province. However, periodic health checks to Cholinesterase and Spirometry has not been done consistently every 6 months in accordance with the procedures and regulations of Decree no. 03, 1986 (see explanation in 4.7) and this has been raised as a minor finding in 4.7 Status: Conform 4.7 An occupational health and safety plan is documented, effectively communicated and

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implemented The Company has established policies of Occupational Health Safety and Hygiene PT. SIP - Region Lampung, dated 2/9/2011. Policy signed by the chief executive. OHS Policy socialization was conducted through training, meetings, morning circle, and on display at workplaces. The Company already had OHS Manual complete with procedures, and forms, which are enforced as of July 1, 2010. At present, most of the documentation has been revised. The Company has established safety committee (P2K3) that has been endorsed by Decree No. 560/8 / III.04 / MSJ / P2K3 / III / 2013. date. 22/10/2013. by Disnakertrans Mesuji. Secretary of the a / n. Doni Saputra (General safety and health expert). The company already includes employees in the social security insurance program (Jamsostek). The policy to include employees in Jamsotek program, stated at PP chapter III, Article 14-17 and PKB Chapter IX Article 26 - 28. For casual workers and contracted harvesters (PKWT), has been included in BPJS health and as well as reimbursement of hospitalization for the workers themselves, as stated in rights and Obligations treaty article first party (article 6). There is a letter from the Social Security Employment (BPJS) Lampung II no. B. / 140/032 014 dated March 3, 2014 stating that the company based on Law no. 24 In 2011, PP 84 on the Implementation of the Social Security program is implemented BPJS. This letter explained all program of JHT (pension scheme, accident insurance (JKK ) and death insurance (JKM) should be included in large company based on PERPRES no. 109 of 2013. Partial participation to only granted for construction services, therefore BPJS Employment Insurane could not accept partial participation for JKK and JKM scheme started in March 2014. Due this letter the company are not allowed to register its contract and casual worker for partial program (accident insurance and death insurance) instead of full program (included pensione scheme). In SBYE, based on payment receipt March 4, 2015 via BNI Tanjung Karang for the payment for premium Social Security Employment for the period February 2015 for JKK, JKM and JHT program, for 445 employees. While the rest of labour of 668 have not been registered because BPJS Lampung II which stated that BPJS could not accept the registration for partial progam.. For labour who has not been registered in that insurance scheme, the risk will be bear by the company itself, however this mechanism has not been approved by the local Manpower Authority. This has been raised as Minor non-conformity no. 5. Related to with health examination, the Company issued a Labor Health Examination Policy Region Lampung, approved by the regional controller, and the controller Production on tgl.1 / 6/2011. This examination covered medical examination prior to employment, periodic, and special examination. The medical examination for chemical handlers such as sprayers, warehouse and laboratory personnel, has been conducted. There were records of results of medical examinations to 102 people were conducted on 4 – 5 March 5 2015 for pesticide handlers with pesticide levels in the blood examination (Cholinesterase & spirometri) by the Center for Occupational Health and Safety Department of Manpower and Transmigration Lampung Province. However, periodic health checks to Cholinesterase and Spirometry has not been conducted consistently every 6 months in accordance with the procedures and regulations of Decree no. 03 in 1986. This has been raised as Minor non-conformity no. 07. Audiometry examination has been conducted to as many as 43 labours who are exposed to noisy environment on 4 to 5 March 2015. The result showed there are 10 people have problems with hearing.

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The recommendation from doctor has not been followed up. This has been raised as Minor non- conformity no. 07. The company has established procedure of hazard identification, risk assesment and detemination control/HIRADC (no. SOP / SMK3 / SMART / LH-02, rev.01). The document of HIRADC already covered activities both in Estate and Mill. The emergency preparadness both in Mill and Estate has been documented in SOP Penanganan Keadaan Darurat (SOP/SMK3/SMART/LH-09) (1) Fire (housing dan land) (2) Hazardous substance/waste spillage (3) Earth quake (4) Poisoning. (5) Riot These procedures took effect since July 1, 2010. The socialization has been done to the entire workforce by sticking the procedure in strategic places, such as: Estate offices, division offices, Mill office, workshop, and parking area in the form of banners or billboards. The Company has established the Emergency Response Team and the related training and drill has been conducted to ensure the readiness of the team to handly emergency situation. The Team consists of the Chairman, Vice Chairman, General Support, Administrator, Secretary, Team Fire (Poison Fire, Hydrant, sand, wet burlap, Galah hook), Evacuation Team, Security Team, liaison team, Team remover team, and health team. To cope with emergency situation Company has provided emergency equipment such as : (1). 30 pieces fire extinguisher at 30 locations; (2). 5 units hydrant pillars and box with 5 pieces of equipment (hoses, nozle, lock valve) in five strategic locations: an office and lab, St. Boiler, St. Nut & Kernel, and St. Thresher, and St. Dispatch Oil. (3). jute sand shovel equipped and gaff hooks in 3 locations (office, st. Loading ramp, and st. Nut & Kernel); and (4) eye washer and shower in 3 locations (lab, warehouse CaCO3, LB-3, and WTP). The company also has made Evacuation Maps and Map Fire Prone equipped with an image of points extinguisher, hydrant, eye washer / shower, direction arrows evacuation routes, and 2 areas of meeting points. The things to be consider that the infrastructure for fire prevention and control in the estate be owned were not still in accordance with the guidelines for fire control in the estate issued by of the Directorate General of Plantation of the Ministry of Agriculture. Attention should be paid at mil, that the mill did not have firefighter personnel which have qualification according to Kepmenaker No. 186/MEN/1999. Based on this ministral regulation the company should provide 1 personnel for class A, 1 personnel for class B, 5 pesonnel for class C dan 12 personnel for firefighter class D. The Company has made various efforts related to land fire prevention and suppression. Records of such activities were stored properly. - In SBYE, simulated fires emergency was conducted at, date. 11/11/2014. There are scenarios, evaluation, photographs and attendance. - The company has provided a list of lists no.telpon both internally and externally including to the police station, local army, health centers, local fire squad. - - In the Sungai Buaya Estate (SBYE) there are fire patrol activities conducted by Tim Security Sucofindo ICS FRM 14.05 29 of 70

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Patrol to monitor HCV and land fires. This activity is recorded in Book Patrol per 2 weeks. - The company made firebreaks for every division in areas adjacent to the surrounding community estate, and or area with vulnerable to fire. There are map of Fire Prone Area (SBYE). Signed by by the Assistant Division, known by the Secretary P2K3, and approved by the Chairman of the P2K3. This map was upadated in the beginning of year included in the Agronomy Program. Routine inspections of emergency response equipment, such as: fire extinguisher, hydrant, and gunny sand is conducted routinely ranging from 2 weekly, and monthly. This activity is carried out by members of emergency team, or SPO Officer, or secretary P2K3. Fire prevention report was submitted to to local Manpower authority every 3 months, alongwith P2K3 quarterly reports. The reports contains among others: security patrol, monitoring equipment, the month when there is a simulation or training will be attached. Other recordings related to the accident, are: (1) Summary of Accident Report Monthly (FP 03 / SMK3-SOP-10), and (4). SR count recapitulation and FRR (FP 04 / SMK3-SOP-10). Status: Minor nonconformity no. 5 and 7 4.8 All staff, workers, smallholders and contractors are appropriately trained. The Company has established an annual training program. Training was made based on the SOP Human Resources Development Training includes: preparation, implementation, and evaluation. There is a TNA are set by the Regional Training Center Coordinator (RTCC) and the results in the form of training Needs Identification Matrix (FL / Estate / TRAD / 10). The annual training program is formulated and established by each unit meanwhile the records of training for sustainability aspect was done by SPO Officer. The Company requires contractors who do business with it to be trained and fulfill their obligations to revelan legislation. To communicate, the company has conducted socialization to contractors regarding their obligation to register its workforce on social security, provision of personal protective equipment for their workers, for transporting FFB required to have drivers who have obtained the appropriate driving license. Status: Conform 5 ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY 5.1 Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate The Company has had EIA document, Revised EIA Oil Palm and Palm Oil Processing into CPO PT Sumber Indah Perkasa was for area of 9254 ha and 2 POM with a capacity of 60 ton TBS / hour. EIA documents incorporate aspects of environmental impact assessments, physical, biological, social culture, flora and fauna, the local economy. The company carries out compulsary environmental monitoring through RKL and RPL. The results of RKL and RPL is reported every six months to BLH Tulang Bawang and Mesuji, BLH Lampung and Jakarta KLH. The frequency of the report was not in accordance with the approved EIA document. The documents states the report has to be made and submitted every 3 months, and this finding is raised in observation no. 12. At the moment there are no expansion of the estate or increasing plant Sucofindo ICS FRM 14.05 30 of 70

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capacity, so there is no revision of EIA. Status: Observation No. 12 5.2 The status of rare, threatened or endangered species and high conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and operations managed to best ensure that they are maintained and/or enhanched PT. Sumber Indah Perkasa has had SOP of Protection of Flora and Fauna in the plantation environment as stipulated in the SOP Identification and Management of HCV / HCV, Number: SOP / NP / SMART / IV / LH 001 effective date June 1, 2010 No. Revision 01. Based on Information on the EIA document before planting, there were flora identified as commercial crops such as meranti. EIA documents are currently identifying flora and fauna after the plantation of palm oil mills, such as shrubs, for the reptile fauna such as crocodiles, snakes spoon, rats, porcupines, wild boar, leopard roots, and more, Initial secondary forest land. EIA documents contained no information about the flora and fauna while still secondary forest. Information flora and fauna are described in detail in Document Presentation of Environmental Information (PIL) Oil Palm Plantation Project PT. Sumber Indah Perkasa Mesuji sub-district and District Menggala, prepared by PT. Noble Consultant with ratification on August 12, 1991. Division/Block/ HCV Area Field Identification Result Location of Type (Ha) Findings Sungai Buaya Estate There is area of river border or riparian ecosystem of Sungai Tapak Sungai Buaya and Sungai Tapak which functions to river border 1.1 ; 4.1 47.30 support local protected areas, water sources and flood control. There are protected animal species: Sungai Buaya 1. Elang Hitam (Ictinaetus malayensis) river border and 2. Cangak Abu (Ardea sumatrana) inside the 1.2 - 3. Cangak Merah (Ardea purpurea) plantation 4. Suku Alcedinidae (Raja Udang Biru, Cekakak Belukar, Cekakak Sungai and Pekakak Emas) Mesuji KKPA There is area of river border or riparian ecosystem of Lake Dasiem 1.1 ; 1.3 Sungai Buaya and Sungai Tapak which functions to 5.42 ; 4.1 support local protected areas. Endangered/protected species in the list of Mesuji (MSJA) Government Regulation No. 7/1999 (Protected) and KKPAEstate and IUCN LC ver 3 (2010), include : surrounding areas 1. Raja Udang Biru (Alcedo coerulescens) 1.2 2. Cekakak Belukar (Halycon smyrnensis) - 3. Blekok Sawah (Ardeola speciosa) 4. Kuntul Kerbau (Bubulcus ibis) 5. Raja Udang (Alcedo meninting) 6. Cangak Laut (Ardea purpurea) Sucofindo ICS FRM 14.05 31 of 70

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7. Cangak Merah (Ardea sumatrana) 8. Elang Tikus (Elanus caeruleus) 9. Cekakak Sungai (Todirhamphus chloris) 10. Macan Akar (Felis bengalensis) There is old cemetery Old Cemetery 6 - Blok B-11 Gedung Aji Lama KKPA Endangered/protected species in the list of Gedung Aji Lama Government Regulation No. 7/1999 (Protected) and (GALA) KKPA IUCN LC ver 3 (2010), include: Estate and 1. Raja Udang Biru (Alcedo coerulescens) surrounding areas 2. Cekakak Belukar (Halycon smyrnensis) 3. Blekok Sawah (Ardeola speciosa) 4. Kuntul Kerbau (Bubulcus ibis) 5. Raja Udang (Alcedo meninting) 1.2 6. Cangak Laut (Ardea purpurea) - 7. Cangak Merah (Ardea sumatrana) 8. Elang Tikus (Elanus caeruleus) 9. Pekakak Emas (Pelargopsis capensis) 10. Cekakak Sungai (Todirhamphus chloris) 11. Macan Akar (Felis bengalensis) 12. Tupai Tanah (Lariscus insignis) 13. Buaya Muara (Crocodylus porosus) 14. Biawak (Varanus sp) There are cemeteries: GALA unit area: 1. Bangunrejo Old Cemetery - Block A-19 2. Rejomulyo Public Cemetery - BlockB-26 3. Karyamakmur Public Cemetery - BlockC-41 6 - 4. Pasar Batang Public Cemetery - BlockC-06 5. Bangunrejo Public Cemetery - BlockD-12 6. Panca Tunggal Jaya Public Cemetery - BlockA-29 7. Infant Cemetery - BlockA-59

The company already has an estate map showing the location of high conservation value / protected areas. Identification of HCV has been carried out on SBYE (sungai buaya) (4 ° 5 '- 4 ° 17' S and 105 ° 26 '- 105 ° 39' E). To monitor the state of HCV that has been identified, The company officer has been appointed SPO officer. As an effort to preserve and protect the HCV that has been identified, the Company has put up signs of endangered animals in strategic places in the form of images of endangered animals which are identified in the area of PT. Indahperkasa source. There are maps of conservation areas scattered throughout the estate unit PT. Indahperkasa source. Sungai Buaya Estate (SBYE) There were records of dissemination about policies of the company for the protection of rare and

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endangered flora and fauna on January 14, 2015 held at SBYE with speaker SPO Officer, attended by 59 employees of PT. SIP SBYE. Mesuji (MSJA) KKPA There were records of dissemination about company policies regarding the protection of rare and endangered flora and fauna on 13 September 2014 with a speaker housed in MSJA SPO Officer attended by 19 employees and stakeholders PT. SIP MSJA. During the visit at Surveillance audit on 18.03.2015 in Block E16 in the estate of Mesuji KKPA, it was found a river border region or riparian ecosystems that support local protected areas. Conservation was maintained. Status: Conform 5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner The Company has established SOP Waste Management, SOP / SMART / LEMS - EHSD / SADV / I / 002, revision: 00 includes plant waste: solid, liquid, gas (including hazardous waste). Socialization of hazardous waste has been conducted to the entire estate and personnel who fequently contacted with hazarodus waste such as sprayers and responsible person in the divisions. The Company also uses liquid and solid wastes, while the details of the use of liquid and solid wastes described in 4.2. There are available List of hazardous waste Source which already obtain permission, i.e used oil, oil filters, fluorescent lamp, used batteries, cotton waste, and contaminated rugs. All the hazardous waste in temporary storage of hazardous waste was still on the storage time. The company obtain the permit to store hazardous waste from Mesuji district and Tulang Bawang. The company has obtain Permit to temporary store Hazardous Wastes and Toxic (LB3) PT Sumber Indah Perkasa Unit SBYE, SBYM based Regent Mesuji Decision No. B / 464 / I.02 / HK / MSJ / 2012. All hazardous waste originating from both estate and mill, was collected at hazardous waste temporary storage (TPS B3). There are records of quantity and types of incoming and outgoing waste. Hazardous waste temporary storage (TPS B3) was already complied with the provisions of regulations BAPEDAL Decision no. 01 1995. Packaging of hazardous waste scatered at estate location while the ones in the plant is collected in one hazardous waste temporary storage and is readily available on-site bins B3 MCC. The company already has a way to clean up spills using rags, if rather a lot by using a rubber mop, broom, and dust pan / dustpan (drain), and contaminated rags. Hazardous waste manifest recordings already available and adequate according to the specification of each hazardous waste. There is agreement between the company and suppliers manufacturer of herbicides, PT. Chemical Rolimex Nusamas with no. 011 / RKN - FER / PER / V / 2014 about re-sending used herbicide packaging to producers. Evidence on June 7, 2014 there were handover of used jerican 20 liters Rolixone, Roll Up, Erkafuron of SBYA, SMRE, GALA, MSJA to PT. Chemical Rolimex Nusamas. Waste management is recorded in the manifest of balance sheet of hazardous waste. Hazardous Waste Manifest is submitted every three months to Regent Tulang Bawang, BLH Lampung Province, and KLH Jakarta. Status: Conform

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5.4 Efficiency of fossil fuel use and the use of renewable energy is optimized The Company has documented Waste Management practice at SOP, SOP / SMART / LEMS - EHSD / SADV / I / 002, which covers: solid, liquid, gas, hazardous waste including technical instructions for waste utilization. The companty utilize shell and fiber as substitution of fossil fuels. On January 2015 the usage of shell and fiber was 587.54 tonnes and 1233.79 tonnes respectively, to process 9870.30 tons FFB. The total energy used / ton CPO is 1.27154 million kcal. Status: Conform 5.5 Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN guidelines or other regional best practice. The land clearing process refers to the Technical Guidelines for Preparation of Land (Plant Palm Oil) which is a set of SOPs and related Wi land preparation (new planting). Published in 07/01/2010 as well as the Technical Guidelines on Oil Palm Cultivation (MCAR), which refers to the set of SOP - Technical IK Oil Palm Cultivation, Smart Agribusiness and Food, publication date of 01/09/2012. In MCAR, there is SOP Opening New Land (SOP / SMART / MCAR / IV / TA-PLB), Rev. 0, published 01/09/2012. On the General Explanation of this SOP, mentioned that the purpose of the SOP is to prepare for the opening of new land for oil palm cultivation using the principle of non-burning (zero burning). Based on data from 2014, there are no new land clearing and replanting so there is no record of the use of fire. The Company has documented procedures in handling fires - Emergency Management SOP (SOP / SMK3 / SMART / LH-09), which is applicable in the Estate and Mill. The details regarding the procedures and records of land fire management criteria outlined in 4.7. Facilities and infrastructure of fire prevention and control of land owned by the estate to adapted the fire control guidelines of land issued by Directorate General of Plantation of the Ministry of Agriculture. Status: Observation No. 9 5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented, and monitored. The organization has RKL and RPL which covers environmental impact to the quality of rivers and drilled wells, ambient air, noise, air quality. RKL and RPL reported to BLH Tulang Bawang and Mesuji every 6 months starting in 2012, and there Receipt submission of documents RKP and the RPL. The company has conducted the measurement of vibration, odor and noise by the Government of South Sumatra Province Environment Agency UPTB Environment Laboratory. The company controlling vibration nuisance, odor, and noise through work instructions for jobs in Mill. The work instruction has included work in the high noise area such as in the power generation room.. The noise impacted to the area beyond factory boundary and to the employee housing complex and community, has been controlled using trees. These trees was also used to control pungent odor and dust as described RKL and RPL report bi annually. The company has the SOP Calculation of Greenhouse Gas Emissions,i.e SOP / SMART / CERs - EHSD / SADV / I / 003. At SBYM the use of shells and fiber as substitute of fuel in January 2015 was

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amounting to 587.54 tonnes and 1233.79 tonnes respectively. FFB was processed was 9870.30 tons. and total energy used to produce 1 ton CPO is 1.27154 million kcal. Greenhouse gas mitigation program of PT. SIP Region Lampung ie substituting diesel fuel with renewable energy (shell and fiber) for process in Palm Oil Mill. Company also supervise the use of diesel for operational activities in the estate, socialize the habit to turn off the truck vehicle when queued into the plant, monitoring kwh per ton of product using renewable and non-renewable energy, fertilizer application for operational activities in accordance with the recommendations from Corporate for maintaining and improving soil fertility (the use of fertilizers by type, land application and application Pome bunch empty , IPM (integrated pest management) methods undertaken to control plant pests organism by the use of environmentally friendly pesticides. Palm oil mill at SBYM has four pools of liquid waste and in SMRM have 8 pools of liquid waste. Daily internal monitoring in SMRM and SBYM internal covered parameters which include pH, Alkalinity, and VFA. The rate of flow of liquid waste directly discharged from Palm Oil Mill and for land application was measured and recorded on daily basis at 8 and hours of the completion of the pump operation at 16.00. Status: Conform 6 RESPONSIBLE CONSIDERATION OF EMPLOYEES AND OF INDIVIDUALS AND COMMUNITIES AFFECTED BY GROWERS AND MILLS 6.1 Aspects of estate and mill management that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement The Company has had EIA document, Revised EIA Oil Palm and Palm Oil Processing into CPO PT Sumber Indah Perkasa with an area of 9254 ha and 2 Palm oi mill with a capacity of 60 ton TBS / hour. EIA documents incorporate aspects of environmental impact assessments, physical, biological, social culture, flora and fauna, the local economy. Companies already doing internally Social Impact Assessment in 2012 to surrounding Sungai Buaya and the Sungai Merah. From the results of the SIA identified there are 14 villages around PT SIP which socially affected by the operation of farm and factory. SIA reports included in the main area of the estate is 9102.2 ha and plasma of approximately 15,000 hectares. The company already has a list of stakeholders all units. The number of members of KUD is 17 254 households. Things that that become a negative perception of society are social envy, decreasing land for agriculture, air pollution caused by smoke and the smell of POME, as well as a decrease in the level of health due to the increase population of flies. The Company has been doing Social Impact Assessment for the company and the surrounding area. From the results of the study, the majority of the people residing in and around the concession area of PT SIP is a Java descendant and Lampung tribe. Social Impact Assessment identified the existence of indigenous Mesuji who reside outside the location of smallholdings with a radius of 20 Km from the outer estate. The indigenous people are located in the riverside Cambai. Review of SIA has been carried out within 2 years. There are reports of social impact management monitoring during May 2012 – 2014. This review has involved stakeholders include Tri Redjomulyo village head and village head of Batu ampar which affected by plantation and mill activities. Sucofindo ICS FRM 14.05 35 of 70

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The company submitted the report monitoring every 6 months to BLH Mesuji District (SBYM), BLH Tulang Bawang (SMRM), BLH Lampung Province, and KLH Jakarta. Auditor has published some observation regarding to the FFB management from plasma, as follows: 1. At FFB grading process of plasma (managed small holder) should also be signed by representatives from plasma KUD who witnessed the grading process to ensure that the results of the grading by the company actually has been approved by representatives of KUD plasma. 2. Cooperative has learned that to FFB on smallholdings that getting penalty is for unripe FFB, midripe FFB and empty bunch. To be more clear and legally binding, the penalty should be stated in written agreement. Status: Conform 6.2 There are open and transparent methods for communication and consultation between growers and/or mills, local communities and other affected or interested parties Company as explained in 1.1 SOP of Response to Request and Information. It is Estate manager who responsible to release information to related stake holder, especially ones related to social aspect. Company has identified publicly information dan classsified ones. Confidential documents are documents outside the list of information to Stakeholder, such as commercial data and data causing negative impacts that are accessible only upon management’s approval, e.g. conflict data. In general, data may be accessed /asked by relevant stakeholders as long as relevant. In addition there are data that can be given only to relevant agencies, for example production data is given to the Regency and Provincial Plantation Service. Publicly information/documents are as follow  Land legality which detailed further at 2.2  Enviromental document as described at 5.1.  Labour document which detailed further at 6.5  Occupational safety and health document as described further at 4.7 The records of information requests and responses are kept with retention time of 10 years. Based on data of information record, during 2014 there was no information request form stakeholder regarding the above publicly information. Status: Conform 6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties The Company has established policy related to employee complaints, i.e:  (1). At PKB Article 26 Settlement of complaints, and  (2). SOP Handling Complaints and dissatisfaction (No. SOP / NP / SMART / XII / MCAR / 001, Date of issue 07.01.2010). Complaints and dissatisfaction recorded in the log book.  Sources of these complaints come from internal and external Records of complaints of workers, have been stored and acted upon. There are complaints Internal Books, which includes: date, place, name, contact details, the problem (s), Registration, response (date, action, status, PIC), and the target completion.

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Regarding land disputes included in the SOP Management of Social Conflict (SOP / SMART / SENSES-CSRD / SADV / I / 2 and there are procedures for compensation of land / soil SOP / NP / SMART / VII / D and L002. The procedure of compensation of land / soil already incorporated the customary right, as listed in point 6.2. Status: Conform 6.4 Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stake holders to express their views through their own representative institutions Concerning the identification and calculation of compensation for the land described in detail in the description 6.3. So far companies, cooperatives and stakeholder around the village who was contacted informed that there is no dispute in since the year 2010 in the region around the company and there is no tenure after 2010. Status: Conform 6.5 Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages Regarding the wages in 2015, the company refers to the Lampung Governor Decree, No. G / 892 / III.05 / HK / 2015, the Minimum Wage of District (UMK) of Tulang Bawang year 2105. Rp. 1.5885 million, -, 1/01/2015. This provision has been socialized by decree No. 034 / CEO 2 / HR PSM 2/01/2015 regarding daily wage casual workers (BHL) PT. SIP-Lampung. The minimum wage was then adjusted accordingly to become Rp. 63 540, / day. This decision applies from the date of 01.01.2015. There are Circular letter no. PSM / II / 012 / I / 2015 for the job harvester (loose fruit picker) paid by volume (quantity) in the amount of Rp 1,932 per bucket. If the harvest is low, although the quantity of picking does not reach the base manday, then on the loose fruit picker was entitled to low crop premium provided minimum 6 hectares area have been harvested. The target area for harvesting minimal 6 Ha is still in range of average capability of loose fruit pickers. Based on interviews with loose fruits picker encountered in the field or in the housing, the highest that can be harvested area reached 13 wicket only (1 ha approximately equivalent to 2 wicket, so about 6 ha). Low harvest premium payments are paid on the next payroll period (a period approximately equal to 14 days). At SBY estate, sample taken from the payment record of casual worker. The data showed that the respective worker during the low crop season (26 February to 10 March 2015) was paid daily according to minimum wage of 2014. SBYE has submitted obligatory report on workforce on February 2, 2015. There were 341 CPUH/BHL (casual worker), 210 contracted labor. Permanent daily paid worker (CPUH) 284 people. There have been a contract of casual worker no. 001 / SBYE / PKH / I / 2015. Contract with daily volume based contracted labor in SBYE has not been yet reported to local manpower authority in accordance with ministrial Decree no. 100 / MEN / 2004, article 13. This has been raised as minon non-conformity no. 6. The Company has made corrective action, agreements of daily volume based contracted workers (BHB) will be registered separately from the other contracted

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workers. This non conformity can be closed accordingly. Related to the payroll system, the Company has a policy set out in:  Agreement Article 16 Wage System  SK on Monthly Labor Wage Scale (SKU-B) PT. SIP - Lampung, which starts from A1 to Gol Gol G-8.  SK similar to SKU-H.  List Policies F (Remuneration) ranging from F-001-00 HR s / d F 039, Working equipment such as “egrek” is provided by the company. However the remaining working equipmentt such as pole for egrek and angkong (trolley) should be provided by harvesters themselves with discounted price from the company. It is suggested that The company provide all the equipment work for workers who work at the company. The Company provides welfare facilities and infrastructures scattered in each unit (either real or mill), as the table below. List of Facilities Available in PT. Sumber Indah Perkasa unit Sungai Buaya and KKPA.

No. Facilities Sat Location Total SB GAL MSJ SBY SM YE A A M RM 1. Housing for staf Unit 31 12 11 10 2. Housisng for Unit 226 20 119 employees 3. Masjid Unit 4 1 1 1 4. Church Unit - 1 5. Kindergarden Unit 1 6. Elementary School Unit 1 7. Rumpin Unit 1 8. Clinics (MSJA) Unit 1 1 1 9. Employee hall Unit 4 10. Day care Unit 4 11. Cooperative Unit 1 1 12. Foot ball field Unit 3 1 1 1 13. badminton court Unit 1 1 1 1 14. Volley ball court Unit 1 1 2 15. Tennis court Unit 1

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16. School bus Unit 1 1 Totall

The Company has contracts with its contractors. These contracts requir all contractors subject to compliance with labor laws and related regulations, as shown in the example where the contract No. SPK: 001-GABA / SPK-I / I / 2015-Transports TBS dated 27/01/2015 Status: Conform 6.6 The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel The Company currently has one Union. Policies concerning the permissibility to establish unions contained in the Circular Letter of the CEO-2 concerning Freedom of Association Workers Organisation / Labour. There is one union for all units and Mill Estate. Union has been registered as Branch Board SK Federation of Unions of Agricultural and Plantation SPSI Kab Bone Onions No. 15 / PD.F.SPSI / LPG / X / 2013, date. 10.27.2013 on Ratification of Management of Work Unit SP.PP SPSI PT. SIP Bhakti Period 2013-2016 and has had a book Collective Labour Agreement (CLA) with the corresponding registration number SK Manpower chief of Lampung Province No. 79 / PKB / HI / III / 2015 which is valid until November 2015. In addition to unions, has also been formed Bipartite Cooperation Institution (LKS) in each Unit. Union has conducted meeting in 2014 at 4, 20 March, June, October and December. Among other issues discussed regarding the minimum wage, health insurance, overtime, premiums. Status: Conform 6.7 Children are not employed or exploited. Provision of minimum age of labor is set in:  PKB (collective labour agreement) article 7 of the recruitment of new workers verse 4, that a minimum of 18 years.  Company regulation chapter II, Article 5, paragraph 2 that prospective employees are at least 18 years old.  Circular of the HR Director to all Unit Head, No. 002 / SE-HRDV / 03/09, date 31.03.2009, concerning Minimum Age, according to UU no. 13, Article 68, concerning the prohibition of employment of children, the minimum age of recruitment is 18 years. Employees data in each unit held under KTU Personnel, also included age of employee when first recruited. Based on the results of the employment data, there were no employee who were first recruited the age of 18 years. Status: Conform 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, Sucofindo ICS FRM 14.05 39 of 70

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gender, sexual orientation, union membership, political affiliation, or age, is prohibited The Company provides equal opportunity to everyone to be accepted to work in the Company. In the document: (1). HR Policy No. A-001-00, the applicable date of 01/09/2005 issued by the Managing Director of Strategic, item 2, stated that the organization is in principle employs individual who has competency in accordance with the requirement of office regardless of their ethnicity, race, and religion. On Procurement Policy Employment: Recruitment and Selection Conditions Outside Jakarta (no. HR A-006-00, dated 09/01/2005, provides that the procurement of labor does not require the tribe, gender, or religious beliefs. Status: Conform 6.9 There is no harassment or abuse in the work place, and reproductive rights are protected The Company has established policies related to the prevention of sexual harassment that is documented in the letter endaran No. 003 / CeO2-SE / 01/2011, dated 10/01/2011. Policy protection for women's reproductive rights have been included among others: Company Rules Chapter IV, paragraph 25 regarding maternity leave and miscarriages.  Memorandum No. 001 / Memo / VPA PSM2 / 04/2011 regarding the prohibition of pregnant and lactating women as sprayers.  The circular No. 095 / CeO2-SE / 12/2010 regarding menstruation leave. Complaints related to sexual harassment is delivered according to the procedures as explained in the description 6.3. Status: Conform 6.10 Growers and mills deal fairly and transparently with smallholders and other local businesses. Data of the price of FFB based on the Minutes Purchase Price Rate of FFB issued by local agriculture authority on March 6, 2015 were: CPO Price Rp. 7.388,68/kg Palm kernel Rp. 5.335,00/kg FFB origin : FFB Price per kg Palm oil 3 years old 1.193,69 Palm oil 4 years old 1.299,18 Palm oil 5 years old 1.340,75 Palm oil 6 years old 1.386,96 Palm oil 7 years old 1.428.16 Palm oil 8 years old 1.483,49 Palm oil 9 years old 1.526,74

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Palm oil over 10 years old 1.534,17

Data from the results of grading was recorded by grading officers and signed by the company, among others, by the grading officials and factory managers. How ever for transparency purpose the grading results for FFB from plasma should also be signed by representatives KUD who witnessed the grading process. This means to ensure that the results of the grading by the company right has been approved by representatives of KUD plasma. Based on information from administrators and representatives KUD (village cooperative) as well as from representative of KUD plasma at loading ramp (a fruit reception area) that penalty only apply to the sampled truck, the remaining (unsampled) trucks were not get a discount. The company already has Guidelines for Grading of FFB as documented in work instruction No. PT SIP-SBYM / IK / 04-1. This WI contains sorting criteria and determination pinalty of FFB that is not according to specifications. The Company has established a system of grading and determination of penalty is in conformity with the conditions set by Local Agriculture Authority. For FFB from smallholdings that getting penalty is for raw FFB, mid ripe FFB and EFB, but there is no written agreement regarding the penalty provisions. Status: Conform 6.11 Growers and millers contribute to local sustainable development wherever appropriate The Company has made CSR program per each unit and to the community in the plasma estate and its own estate. In 2014 there were of CSR activities in the social sector, infrastructure, religion and the environment with a budget of Rp. 155,631,030.00 and the realization of Rp. 23,328,482, - Assistance included the construction of riool as many as 28 units on December 7, 2014. Status: Conform 6.12 No form of forced or trafficked labour are used During the ASA I, it was observed there are no traficked labour used and forced labor. All workers had Indonesian citizenship. From the results of the examination of the labor contract for harvesters, there are no contracts subtitution. Status: Conform 6.13 Growers and millers respect human rights. The Company has a written commitment to respect human rights in the document GAR social and community engagement policy. Status: Conform 7 RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS N / A There are no new plantation development in the period 2013 to the current audit. 8 COMMITMENT TO CONTINUOUS IMPROVEMENT IN KEY AREAS OF

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ACTIVITY 8.1 Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations The company has monitored the reduction in the use of chemicals, which details can be seen in 4.6, aspects and impact on the environment which details can be seen in 5.1, waste reduction which details can be seen at 5.3, pollution and emissions, which details can be seen at 5.6, and the social impact which detail can be seen at 6.1. The Company has conducted an internal audit of the RSPO in 3 to 8 November 2014. The audit team made two separate reports using each criteria in the guidelines. Nonconformities found during internal audit, has been addressed adequately with the respective corrective actions. Status: Conform

B.4.2 RSPO SUPPLY CHAIN CHECKLIST – MODULE D : MILL IDENTITY PRESERVED

PT. SIP Sungai Buaya Mill is producing crude palm oil (CPO) and palm kernel (PK), the the audit time did not make transaction in the RSPO E-Trace System, because company currently sell their product without claiming it as certified sustainable palm oil (CSPO) or certified sustainable palm kernel (CSPK). All CPO produced from this Mill are sold as International Sustainability Carbon Certification (ISCC) . The following is a description of the company’s supply chain management system according to the RSPO SCCS 2014 requirements, including status of compliance of the company and their outsourced third parties to RSPO SCCS requirements :

D.3 Documented procedures

D.3.1 a) The company has documented procedures required in SCCS in “SOP Identifikasi dan Kemamputelusuran Produk Bersertifikat” (identifcation and tracebility of certified products) SOP/SMART/CERS-EHSD/SADV/I/001, it covers all model from SG and MB, it is suggested that this procedure be revised to cover IP since actually SBYM only received FFB from certified estate (own estate and full managed small holder /KKPA). b) The company on January 2014 by letter 005/FM-SBYM/I/2014 has appointed KTU as traceability Officer who has overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements. TO has been trained about SCCS on November 3, 2014.

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D.3.2

The Company has developed documented procedure for receiving of certified FFB. The documented procedures i.e “SOP Identifikasi dan Kemamputelusuran Produk Bersertifikat” (identifcation and tracebility of certified products) SOP/SMART/CERS- EHSD/SADV/I/001 dan SOP Pelaporan prosedur Bersertifkat SOP/SMART/CERS- EHSD/SADV/I/003. It is advised that the SOP of traceability of certified product (SOP/SMART/CERS- EHSD/SADV/I/001) to be revised to include the IP product since in actual SBYM mill only receives FFB from certified estates. This has been published as an Observation no. 3

D.4 Purchasing and goods in

D.4.1

The FFB in SBYM are supplied only from its own estate (SBYE) and small holder that fully managed by the company. Both of supply bases has been certified, however The company has prepared and set up procedure and database system to separate certified and non certified from receiving FFB until delivery to the buyer

D.4.2

The company has a mechanism to inform the certification body (CB) immediately if there is a projected overproduction as seen in “SOP Identifikasi dan Kemamputelusuran Produk Bersertifikat” (identifcation and tracebility of certified products) SOP/SMART/CERS- EHSD/SADV/I/001

D.5 Record Keeping

The sustained palm oil scheme that company apply are RSPO SCCS and ISCC. The company has centralized computerized sistem to prevent mix up between these scheme.

Record of the implementation of SCCS are “surat pengantar buah”(delivery letter of FFB), “nota timbang buah” (FFB weigh receipt), Bukti Timbang CPO (CPO weight receipt), CPO delivery Order, daily mill report, monthly report, 3 monthly report and annual report.

The Mill records tonnages received at the weighbridge and these are reported daily to head office. There are Daily Mill Report, Monthly Mill Report, three monthly report and annual report.

Three monthly Mill Report that was sampled during the audit : period of Oktober – Desember 2014 showed there was 65,522,980 kgs of FFB Processed, CPO produced 14.333.250 kg (OER 21,88%) and PK 3.740.130 kgs (KER 5,71%)

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Yearly Mill Report for 2014 total FFB received 255,932.87 ton, CPO produced : 56,444.32 ton (OER 22,00%), PK produced 13,096.67 ton (KER 5,00%) (certified).

D.6 Processing

D.6.1

The CPO and PK produced by company was stored in tanks and warehouse. There was no possiblity of comingling with non certified products since the all the FFB supplied to the company was certified ones. However the trucking/transportation and storage in the bulking terminal is not managed by the company which is out of this scope and boundaries of this certification

Document available Delivery Order, completed with a. Name and buyer address (contract) b. Report of CPO Shipping dates c. Product description was CPO quality d. Quantity of product (ton) e. Transport documentation, sounding report, acceptance report of CPO Documents are safety kept by the logistic staff, up to ASA I there was no sales using RSPO scheme.

D.6.2

The realization of 100% segregation of RSPO certified CPO and PK cannot be checked, since there was no demand for RSPO certified ones. The realization of segregation has made only for ISSC certified product

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B. 4. 1. Non Conformity Register

B. 4. 3.2 Status of Previously Minor Finding and Observation

Audit Corrective Action & Team No. Category Clause Std Auditor Description Root Cause Investigation* Evidence* Review (1) (2) (3) (4) (5) (6) (7) (8) (9) 1 Minor 6.9 1 WS The implementation of sexual Sexual harassment To completed the Closed harassment socialization to socialization has been documentation of sexual employees is limited compared conducted to the workers, harassment socialization. to the number of workers. Data but the documentation was Evidence : showed : cannot be showed at the Documentation of sexual -In GALA Unit, the number of time of audit. harassment socialization is workers has been socialized to available at SPO secretariat. 23 safety team and 29 staff’s wives and male workers. For BHL and PKWT personnel are63 out of 872 workers (only 7.2 %). -In MSJA Unit, no evidence is found that the socialization has been made to BHL/BHB workers; it is only to 13 staff’s wives and female workers.

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2 Obs 4.6 1 YSF Company has used herbicide The company still apply The management has issued Closed registered in Pesticide restricted pesticide i.e. memo to reduce the paraquat Commission of the Republic of paraquat. No. 002/MEMO-VPA Indonesia but the use of PSM2/04/2011. The restricted pesticide should be restricted pesticide will be reduced gradually and monitored yearly to see the substituted by a more trend of paraquat reduced. environmentally friendly Evidence : herbicide and safer to field Graphic of restricted operators. pesticide use year 2011-2013 showed the reduce of paraquat used. 3 Obs 4.7 1 YSF Two units of Light Fire The personnel checked the The Head of P2K3 retraining Closed Extinguisher in diesel fuel fire extinguisher the personal who responsible warehouse and KKPA GALA inaccurately. to check the fire extinguisher. warehouse should be inspected To ensure the monitore result more carefully to ensure the of fire extinguisher meet with content and pressure of the the actual condition. extinguisher so that they can be Evidence : used during the emergency. Letter of reminder from Head of P2K3 to secretary with the subject of the fire extinguisher monitoring system. 4 Obs 4.7 1 YSF Company has undertaken The workers with exposure To conduct identification the Closed workers health examination to chemical material hazard workers with risks of covering cholinesterase and were not checked for chemical exposure and audiometry but for those spirometry. gradually will conduct working with risks of chemical spirometry checking. exposure should be added with Evidence : spirometry examination to 1. List of worker who needs ensure their lung health. to be checked for spirometry. 2. Medical check program for spirometry.

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5 Obs 2.3 1 TSS/GG Organization has made a map The company has the Map will be adjusted to be Closed U but the map should have a different scale for all maps. scale 1 : 100.000 sufficient scale, at least 1 : Evidence : 100.000 in accordance with Map with the scale 1:100.000 Decree of the Ministry of Forestry No. 48/menhut- II/2004. 6 Obs 5.2 1 TSS/GG Organization had SOP on HCV KKPA GALA Estate has no HCV monitoring and patrol Closed U Management, it specifies that data for monitoring HCV will be conducted every 2 monitoring or patrol is carried for July 2013. weeks. out every two weeks but in Evidence : GALA the last monitoring is on HCV Monitoring and patrol 24 June 2013. is available. 7 Obs 5.2 1 TSS/GG Organization has performed There is no column for PIC Completed the form with edit Closed U monitoring and contained in and Action Plan at Form PIC and Action Plan. HCV Monitoring Report, but it HCV Monitoring. Column. should establish Person in Evidence : Charge (PIC) and due date of Revision of Form HCV the recommendation specified Monitoring. in the HCV monitoring report to see the follow up and progress of such recommendation. 8 Obs 4.7 1 WS Company already complete The simulation of fire To fulfill the number of fire Closed with the provisions of Decree fighting has conducted but fighter to meet with the of the Ministry of Manpower the number of the fire Kepmenaker No. 186 Tahun No. 186/1999 related to the fighter was not meet with 1999. number of fire mitigation the government regulation Evidence : personnel in mill area. But it (Kepmenaker No. 186 Documentation of fire fighter only trained 20 personnel for Tahun 1999). training. both mills (it should be 12 personnel for each mill). It should ensure to gradually conduct training to cover the remainder in class D, C, B and A.

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9 Obs 4.8 1 WS In GALA, two SPKs are found During tender process, the In every MoU, the safety Closed not expresivvely specifying the requirement of safety aspect standard should be stated provisions of PPE mandatory has been informed to the mandatory. use. They are SPK No. contractor, but when the Evidence : 027/GALA/JKTO/04/2013 – MoU issued there is no The revision of MoU. Box Culvert, and SPK No. safety requirement stated. KUD-KS/GALA/SPKL- L/January-12-/010-FFB Transportation &Loading.

10 Obs 8.1 1 TSS Companyshould develop a Yearly CSR Program has The company will re- Closed specific method to evaluate the been setup for each unit, but identification the existing effectiveness of CSR program not yet covered the culture indigenous people. If there is done as input to future program program. For the strategic then the company will setup improvement. planning year 2014-2018 the CSR to develop and has addressed the vision and maintain the culture of mission to develop and indigenous people. maintain the culture of local Evidence : people. Revise CSR Program. 11 Obs 6.10 1 TSS Company should ensure The company has conducted The company will conduct Closed cooperative’s efforts to the socialization to the monthly meeting and to socialize aspects that become a cooperation staff and socialized the factor in price factor in price cutting related to coordinator staff, regarding cutting related to costs costs imposed to plasma the factor in price cutting imposed to plasma members members for maintenance and related to costs imposed to for maintenance and transportation costs. Proof that plasma members for transportation costs. all parties understand the maintenance and Evidence : contract agreement they entered transportation costs. But the The documentation of to, and that the contracts are socialization was not meeting schedule between fair, legal and transparent. sufficient some of the company and cooperation is members were found well available. not understand for the subject.

B. 4. 3.2 Non Conformities and Observation

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Root Cause Corrective Action & Audit Team No. Category Clause Std Auditor Description Investigation* Evidence* Review 1 Observation 2.2 RSPO RB The company has established SOP for maintaining HGU poles dan conducted monitoring and maintenance to those poles. It is advised that in the monitoring check list to be inputed the coordinate data of those poles 2 Observation 4.1 RSPO RB Harvesting has been conducted properly and so has with the arrangement of FFB at collecting point. It is advised to repair the FFB collecting point to maintain th quality of FFB at collecting point. 3 Observation SCCS NS It is advised that the SOP of traceability of certified product (SOP/SMART/CERS- EHSD/SADV/I/001) to be revised to include the IP product since in actual SBYM mill only receives FFB from certified estates 4 Minor 6.5 RSPO NS In the SBYE the report of daily Employment Corrective Action : Closed, adequate volume based contracted workers Agreements on Agreements of daily evidence (BHB) has not been submitted to daily volume volume based local manpower authority in based contracted contracted workers accordance with Ministrial Decree workers (BHB) will be no. 100 / MEN / 2004 Article 13 (BHB)already registered separately registered / from the other reported to the contracted workers. Manpower Tulang Bawang but the Evidence : registration was Agreement of submitted with the Employment daily registration joined volume based by contracted contracted workers

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worker (BHB) already reported to local Manpower Authority of Tulang Bawang. 5 Minor 4.7 RSPO NS At SBYE there were 668 people and at SMRE 399 people until March 2014 which has been registered Social Security and JKM JKK program, but since April 2014 the premium can not be paid due to a letter from the Employment BPJS Lampung II which stated that BPJS could not accept the registration for partial progam. 6 Observation 6.1 RSPO NS At FFB grading process of plasma (managed small holder) should also be signed by representatives from plasma KUD who witnessed the grading process to ensure that the results of the grading by the company actually has been approved by representatives of KUD plasma. Cooperative has learned that to FFB on smallholdings that getting penalty is for unripe FFB, midripe FFB and empty bunch. To be more clear and legally binding, the penalty should be stated in written agreement.

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7 Minor 4.7 RSPO HDY Periodic health surveillance for Cholinesterase and Spirometry has not been done consistently every 6 months in accordance with the procedures and regulations of Decree no. 03 in 1986.

An environmental assessment work An environmental Corrective Action : Closed done on the MCC SBYM and assessment has not SMRM not include Dust and been carried out Measurement of WBGT as Permenaker no. 13 in work which working environment 2011 includes dust and for dust and WBGT WBGT. will be held in conjunction with other environmental monitoring.

Evidence : Dust and WBGT measurement results on SBYM and SMRM Target Date : 11 April 2015 Doctor's recommendations on the results of audiometric measurements that have been done in 2013, found seveal employees experienced problems with hearing. However until the next measurement in March 2015, no action has been taken.

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8 Major 2.1 RSPO HDY Permission for the retrieval and Based on letter no. Status of finding utilization of river water of Sungai 520/342/ii.07/2015 down graded as Buaya and Sungai Merah used for from Badan minor. In the the process in the POM has not been Penanaman Modal dan next ASA will obtained. Pelayanan Perizinan be checked again terpadu, the permit to use survace water are still in progress 9 Observasi 5.5 RSPO HDY Facilities and infrastructure of fire prevention and control of land owned by the estate to adapted the fire control guidelines of land issued by Directorate General of Plantation of the Ministry of Agriculture.

10 NC 4.4 RSPO HDY From 11units of Corrective Action : Open, waiting Minor The company has already received drilled (SBYE 4, Mendokumentasikan for the license permission to drill wells 3 points: 1 SMRE 4, GALA hasil uji kualitas air. for 8 remaining point SBYE, 1 point for Mesuji and 2, MSJA 1), only 3 wells 1 point for SMRE. But has not done license has been Evidence : hasil Identification of underground water found that three analisa air tersebut di wells else and analysis of water, units (SBYE 1, masing-masing unit. discharge water use SMRE, 1 and MSJA1) while Target Date : 10 remaining license April 2015 has not been found

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11 Observasi 4.4 RSPO HDY Monitoring of well water in accordance with water quality standards based Permenkes no. 416 of 1990 has been carried out by the Health Polytechnic Tanjung Karang, has included factors such as Coliform microbiology. Should certainly all parameters are measured in accordance with the regulations mentioned above.

12 Observasi 5.1 RSPO HDY RKL RPL reporting has been conducted every six months, however, that the reporting is done every 3 months according to the EIA document of BPLHDs Lampung Province.

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B.4.4 Stakeholder Consultation

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

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B. 5. Date of Next Surveillance Visit One (1) year after date of 2015 surveillance audit

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

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

Verified and Reviewed by:

Name Tuti S. Sirait

Position SLA / LA / Auditor

Signature

Date August, 25th 2015

Approval:

Name Triyan Aidilfitri

Position HSE Audit and Certification Department Head

Signature

Date August, 25th 2015

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APPENDIX 1 LIST OF ABBREVIATION

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

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

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APPENDIX 2 MAP

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1.1. Overlay Map of Sungai Buaya Estate, Gedung Aji Lama Estate and Mesuji Estate

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1.2. Map of Rivers

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1.3. Map of HCV Sungai Buaya Estate

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1.4. Map of HCV Gedung Aji Lama Estate

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1.5. Map of HCV Mesuji Estate

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1.6. Map of Topography

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1.7. Map of Planting Year Sungai Buaya Estate

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1.8. Map of Planting Year Gedung Aji Lama Estate

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1.9. Map of Planting Year Mesuji Estate

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