SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

RSPO Assessment Report PUBLIC SUMMARY

PT. Sumber Indah Perkasa – Sungai Buaya Mill , ,

This public summary 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: Tuti Suryani Sirait (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. Location Address of the Mill and Approximate Tonnages Certified

(CPO and PK5 )...... 5

A.4. Description of Supply Base ...... 5

A.4.1. General Description ...... 5

A.4.2. Location of Supply Base ...... 6

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 ...... 8

A.6. Date Certificate Issued and Scope of Certificate ...... 12

B. Assessment Process ...... 13

B.1. Certification Body...... 13

B.2. Qualifications of the Assessment Team ...... 13

B.2.1. Qualifications of the Lead Assessor and Assessment Team ...... 13

B.3. Assessment Methodology...... 14

B.3.1. General Overview ...... 14

B.4. Stakeholder Consultation...... 18

B.4.1. Summary of How Stakeholder Consultation was Organized ...... 18

B.5. Date of Next Surveillance Visit...... 21

C. Assessment Findings...... 22

C.1. Lead Assessor’s Summary and Recommendation for Certification ...... 22

C.2. Summary of the Findings by Criteria ...... 23

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D. Certified Organization’s Acknowledgement of Internal Responsibility...... 53

D.1. Formal Sign-Off the Assessment Findings ...... 53

D.2. Statement by the Certifier Body on Behalf of PT. Sucofindo SBU-SICS...... 54

List of Abbreviation ...... 55

Attachment 1 - Map ...... 57

Attachment 2 - NCR ...... 67

Appendix ...... 79

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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, RSPO Certification Systems and RSPO Suply Chain Certification Systems.

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

Annual Output (mt) No Name of Mill Location Address GPS Reference CPO PK 1. Sungai Buaya Mill Desa Talang Batu, Latitude: PT. Sumber Kecamatan Mesuji o 4 07’ 43.00” LS Indah Perkasa Timur, Kabupaten 66.926,18 16.420,64 Mesuji – Lampung Longitude: 105o26’ 19.82” BT

Note : This data (Annual output) exclude from non-certified suppliers) 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 the 1.

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Sungai Buaya Estate (SBYE)-own estate, 2. KKPA Gedung Aji Lama (GALA) Estate - smallholder and 3. KKPA Mesuji (MSJA) Estate - smallholder. Totally supplied FFB from these three (3) estates are 300,561,69 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 Timur, o o 4 09’ 44.86” 105 26’ 09.23” Kabupaten Mesuji – Lampung

2 KKPA Gedung Aji Lama Desa Paduan Rajawali, (GALA) Estate– Plasma Kecamatan Meraksa Aji, o o 4 17’ 23.84” 105 25’ 54.68” Kabupaten Tulang Bawang – Lampung

3 KKPA Mesuji (MSJA) Desa Brabasan, Estate– Plasma Kecamatan Tanjung Raya, o o 3 58’ 40.74” 105 20’ 50.75” Kabupaten Mesuji – Lampung

A. 4. 3. Statistic of supply base No. Estate Planting Area/Planting Age/Planting Estimated Estimated Name Year Year Year FFB/Year CPO/Year 1 Sungai 1991 513,14 22 11.625,545 2.565,87 Buaya Estate 1992 2.720,94 21 67.169,083 14.824,88 (SBYE) 1993 1.118,24 20 22.702,698 5.010,71

1994 402,54 19 7.448,399 1.643,94

2000 30,66 13 705,555 155,72

2 KKPA 1995 250,00 18 6.930,170 1.510,23 Gedung Aji Lama 1996 2.833,00 17 78.414,670 17.088,21 (GALA) 1997 1.313,00 16 34.927,270 7.611,39

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Estate - 1998 606,00 15 15.561,800 3.391,25 Plasma

3 KKPA 1995 149,75 18 3.337,980 736,90 Mesuji (MSJA) 1996 2.631,25 17 62.722,060 13.846,72 Estate - 1997 1.891,88 16 47.275,360 10.436,66 Plasma 1998 533,00 15 12.488,510 2.757,00

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

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

1. Introduction The audit team has visited Head office at Sinarmas Land Plaza, Tower 2, 30th Floor, Jalan M. H. Thamrin No. 51, Jakarta, Indonesia dated 13 September 2013, to find out the compliance with the rules for partial certification standard in the whole group of Golden Agri Resources, Ltd. (GAR Group). There are 17 mills and 61 estates (including plasma) within this group. This is the first company in group to be certified by PT Sucofindo, SBU SICS for RSPO certification. The team found that the company conforms with the RSPO requirements for partial certification as stated in the final RSPO certification Systems documents, June 2007, section 4.2.4. Progress and any issue will be verified and reported in subsequent surveillance visits.

2. Assessment agenda (partial Certification Audit)

Date Location Agenda 13 September Head Office - Jakarta Meeting with sustainable team to verify 2013 legal documents, HCV, Labor Union and land conflict within the GAR group

3. 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

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

Gedung Aji Lama KKPA

Mesuji KKPA

2 Sungai Sungai Merah PT. Sumber Lampung 2013 Merah Mill Estate Indah Perkasa

Gedung Aji Baru KKPA

Gedung Aji Lama KKPA PT. Sawit Mas 3 Pangkalan Sawit Mas Estate South 2014 Sejahtera Panji Mill

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PT. Bumi Sawit 4 Bumi Sawit Bumi Sawit Estate South 2014 Permai Mill Sumatra PT. Djuanda 5 Muara Muara Kandis South 2014 Sawit Lestari Kandis Mill Sumatra Muara Tawas

Pandawa KKPA

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

Tangar Estate Bukit Tiga Estate PT. Bumi Permai 7 Bukit Perk Bukit Perak Bangka 2014 Lestari Mill Belitung Bukit Permata PT. Foresta 8 Tanjung Tanjung Kembiri Bangka 2013 Lestari Dwikarya Kembiri Mill Estate Belitung

Tanjung Rusa PT. Sinar 9 Sungai Sungai Kupang South 2015 Kencana Inti Kupang Mill Estate Kalimantan Perkasa Sungai Kupang PT. Sinar 10 Kasuari Mill Cendrawasih Papua 2014 Kencana Inti Nuri Estate Perkasa

Rajawali Estate

Mambruk Estate PT. Purimas 11 Senakin Senakin Estate South 2014 Sasmita Mill Kalimantan PT. Agrolestari 12 Pekawai Kayung Estate West 2014 Mandiri Mill Kalimantan Pekawai Estate

Sungai Kelik

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

Kenanga Estate

Cempaka Estate

Kencana

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

Sulin Estate

Nahiyang Estate

Katayang Estate

Sungai Nusa

Sako Estate

Sungai Ayawan Estate PT. Binasawit 15 Perdana Perdana Estate Central 2015 Abadi Pratama Mill Kalimantan Lenggana Estate

Semandau Estate

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

Bukit Santuhai Estate

Tajur Beras

Seranau Estate Sapiri Estate PT. Paramitra 17 Belian Mill Gaharu Estate West 2015 Internusa Kalimantan Muara Tawang

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Estate Pratama

Belian Estate

Tengkawang

Kapuas Hulu

Team has been verified documents during partial certification audit. The companyhas conducted Gap analysis to the whole group compare to P & C RSPO requirement. The Gap Analysis conducted by BSI Certification Body. Randomly, the team checked the content of reports to ensure the fulfillment of partial certification. From the sampling report, the team found that not all report has the conclusion for the fulfillment regards to partial certification requirement. The company has made the self declaration for partial certification rule and signed by management. The self declaration stated as belows (a-d) :

a. Significant Conflicts The company has the SOP for Conflict Land Resolution refers to RSPO criteria 6.4, 7.5 and 7.6. All the conflicts so far has been resolved with mutual agreement. GAR also registered as member of RSPO Dispute Settlement Facility Advisory Group as a representative of grower. Supporting document is DSF RSPO member as a grower dated 22 April 2013. 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. 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. The latest resolution dispute document handled as evidence is dispute between workers (Hanadi) with PT. Foresta Lestari Dwikarya for terminated employment. The worker has been assumed to be resigned as he has absent for 8 (eight) days in a month. The supporting document is available such as chronology of resolution Industrial Relation between worker and PT. Foresta Lestari Dwikarya, copy of legal verdict caseIndustrial Relations No. 08/G/2012/PHI. PN PKP from court of Industrial Relations at Court of District Pangkalpinang. Collective agreement PT. FLD with Mr. Hanadi No. 07/EM-pb/IV/2013 completed with the sign of each party. 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.

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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

Issued by PT SUCOFINDO, SBU SICS

Address GrahaSucofindo, SBU SICS. Jl Raya PasarMingguKav 34 Jakarta 13640

Telephone /Fax Tel.: +62-21-7983666 / Fax.: +62-21-7987015 Email [email protected]

Website www.sucofindo.co.id

Scope : Mill PT. Sumber Indah Perkasa - Sungai 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 : 66.926,18 MT and PK : 16.420,64 MT

Certification Registration Code SICS-00003

Type of Certification Single site Certifier Triyan Aidilfitri

Signed

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

B. 2. Qualifications of the Assessment Team

B. 2. 1. Qualifications of the Lead Assessor and Assessment Team Tuti Suryani Sirait (Lead Auditor) : Graduated from Institute Agriculture in Bogor (IPB), 1991 She has more than 10 years audit experiences in auditing HACCP, GMP, ISO 9001:2008, ISO 22000:2005, ISPO and RSPO. She has successfully completion training RSPO by Komisi RSPO, Jakarta, SCC Standard Training by David Ogg & Partner – Jakarta, ISPO Lead Auditor Training by Komisi ISPO, Jakarta, Lead Auditor Training of ISO 9000/19011 organized by SICS – Sucofindo, ISO 22000 : 2005 FSMS Auditor / Lead Auditor by Moody International, Singapore; Lead Assessor for Food Safety Management System (HACCP&GMP) by QAS Sydney, Australia and Social Lead Auditor Training (SA 8000) from Social International Audit (SIA), Turkey. She is actively participated in RSPO meeting to discuss RSPO P & C and also as a trainer in ISPO Lead auditor training.

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WarsidSumarlin (Auditor) He graduated from Institute Agriculture of Bogor (IPB) majoring Economic and Social. 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 RSPO by Komisi RSPO, Jakarta, ISPO Lead Auditor Training by Komisi ISPO, Jakarta. Rizky Qomaruzaman (Auditor) Lead Auditor SMK3 since year 1997 till now. Lead Auditor OHSAS 18001 since year 2000. Auditor ISO 14001 since 2002. Premises visited: many various industries, petrochemical, oil & gas, EPC, general contractor, Palm Oil Plantation and Mill, chemical, pulp & paper, coal mining, cement industries, and so on. Attended Green Company Training year 2008, He has successfully completion from ISPO lead auditor course year 2013, attended RSPO lead auditor Course at KL year 2013, attended environmental seminar (Environmental Audit) from Environmental Ministry Republic Of Indonesia year 2013. Yusuf Mu’arif (Auditor) He has graduated from Bogor Agriculture University (IPB Bogor) since March 1988. He has more than 10 years audit experiences in auditing (internal and external audit) of Australian Quarantine Scheme and Ministry of Agriculture of RI, ISPO, OHSAS and SMK3. He has successfully completion training of ISPO Lead Auditor Training by Komisi ISPO, Internal Auditor SMK3 from Ministry of Manpower and Transmigration RI that held by SICS – Sucofindo. Kind of audit scope such as various industries, petrochemical, general contractor, plantation of palm oil, chemical, electrical generator project, telecommunication etc. Ganjar Gumelar (Auditor): He graduated from University ofGadjahMada (UGM), Forestry Faculty, majoring in Forest Management, Yogyakarta. He has completed the training such as Indonesian Sustainable Palm Oil (ISPO) auditor training, Komisi ISPO – Ministry of Agriculture & Komisi Akreditasi Nasional (KAN), Bogor (West Java) & Pangkalan Bun (Kalimantan), Indonesia, 2013 ;ISO 9001 : 2000 Quality Management Systems (QMS) Auditor/Lead Auditor Training Course (IRCA),PT. SUCOFINDO (Persero), Jakarta, Indonesia, 2013 ; Awareness Hazard Analysis Critical Control Point (HACCP), PT. SUCOFINDO (Persero), Jakarta, Indonesia, 2013 ; Life Cycle AssessmentWorkshop Oil Palm Plantation and Oil Palm Milling, Life Cycle Sustainability Assessment Lab &State Minister for The Environment, Jakarta, Indonesia, 2013 ; Assessor Training High Conservation Value Forest – HCVF, Tropenbos International Indonesia Program, The Nature Conservancy (TNC), WWF Indonesia & Institut Pertanian STIPER (INSTIPER) Yogyakarta, Yogyakarta, Indonesia (2011).

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

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was held during Preliminary Audit and secondly Certification Audit. At the opening meeting, the team audit confirm to conduct the audit at : Regional Office at Tulang Bawang - Lampung, include  Documentation review for transparencies  CSR plan and policy  Internal Audit program & Management Review Meeting  Land ownership and compensation mechanism At estate, include :  Worker interviews :OSH. Sexual, religious, racial harassment. Payment scheme, contracts. Child labor. First aid. Awareness.  Chemical stores : Storage. MSDS leaflets. Herbicide mixing areas. PPE. Ventilation. Security.  Field inspections: Fertilizing operations. SOP’s., Herbicide application program. Harvesting sites and efficiency. Soil maps. Land preparation. Ground cover. IPM. First aiders and boxes. Soil erosion.  HCV’s:Identification. Management plans. Environmental Impact Assessments  Riparian zones:Width. Current and future management, monitoring system  Water management:Water courses. Water monitoring.  Road maintenance:Program and progress of road improvement.  Social amenities:Social Impact Assessments.  Workshops:Oil traps. Safe working environment. PPE.Diesel tanks. Environmental waste management.  Line sites:Interviews with householders. Inspection of water discharge points. Water improvement plans. Waste disposal.  Local communities. Contributions made. Employment opportunities. Social impacts. Complaints procedures, Transparency. At Mill include :  Mill and workshop inspections.  Documentation.  Worker interviews. SOP’s. Safe working environment. Gen sets. Walk ways. Signs. EFB. POME treatment. Emissions. Mass balance. Diesel tanks. PPE. Fire extinguishers. First aiders and boxes. Fuel and water usage.  OSH. Training. Management structure. First aiders.  Full document review. Completion of the checklist. Review and documentation of evidence. All aspects of RSPO P&C’s applicable.  Worker interviews. OSH. Sexual, religious, racial harassment. Payment scheme, contracts, union labor  Supply Chain Certification System from receiving until finish products (CPO and PK).

Actual Audit Programme

Phase I : Preliminary Audit Date/Time Functions / areas / Department / activities to be audited (include related requirements) 10 June 2013 Day 1st Audit 12.35 Departure from Jakarta – Lampung

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13.00 Departure to Regional Office Sungai Buaya Estate 13.00 Break 15.00 Opening Meeting at Regional Office (All Team) 17.00 End of the day 1 11 June 2013 Day 2nd Audit 08.00 Location: Sungai Buaya Estate (Division II blok 14-15) Environment Aspects : Water Management (water courses, water monitoring); Environment waste management, Environmental Impacts, Chemical store (RQ) HCV Aspect :HGU and Land Status Estates confirmation, Riparian Zone , HCV Confirmation (RQ) Plantation Aspects : Herbicide Application Programme, Integrated Pest management ); Harvesting Site, Fertilizing Operations, Land Preparation and Assessment (WS) 12.00 Break Sungai Buaya Mill & Sungai Merah Mill (All Team ) 14.00 Document Review of Environmental, HCV, Social and Best Practices Aspects 17.00 End of the day 2 12 June 2013 Day 3rd Audit 08.00 Sungai Buaya Mill & Sungai Merah Mill (All Team) Environment Aspect, Biodiversity, & HCV (RQ) OSHAS/SMK3, Worker Welfare, Training, & Best Practices (WS) Social, Legality, Management & SCC System (TSS) 17.00 End of the day 3 13 June 2013 Day 4th Gedung Aji Baru Estate (blok B 13) 08.00 Document Review of Environmental, HCV, Social and Best Practices Aspects (TSS, WS, RQ) 12.00 Break 14.00 Environment Aspects : Water Management (water courses, water monitoring); Environment waste management, Environmental Impacts, Chemical store (RQ) HCV Aspect :HGU and Land Status Estates confirmation, Riparian Zone , HCV Confirmation (RQ) Plantation Aspects : Herbicide Application Programme, Integrated Pest management ); Harvesting Site, Fertilizing Operations, Land Preparation and Assessment (WS) 17.00 End of the day 4 14 June 2013 Day 5th Audit 08.00 Reporting 12.00 Break 15.00 Closing Meeting 19.00 Departure from Lampung to Jakarta Scope : 2 mills and 5 estates Number of assessor participating: 3 auditors Number of days spent for the assessment on site : 15 days Total number of person days used for the assessment on site :15 days

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Phase II : Certification Audit

Date/Time Functions / areas / Department / activities to be audited (include related requirements) 15 Jul’13 1st Day 12.35 Departure from Jakarta – Lampung 13.00 Departure to Regional Office Sungai Buaya Estate 13.00 Break 14.30 Opening Meeting Arrangements Schedule Auditor vs auditees Arrangements location (estate and stakeholders) to be visited 16.30 End of audit day 1 16 Jul’13 2nd Day 07.30 Location : Office Documents Audit : Review previous findings (All Team) 12.00 Break 14.00 Location : Sungai Buaya Mill (SBYM) Best Practices & Environment Aspect (RQ) Worker Welfare, Training, Management (WS & TTS) OSHAS/SMK3 (YM) Social & Legality (TSS & GGU) 16.30 End of audit 17 Jul’13 3 rd Day 09.00 Location : Mesuji KKPA (MSJA) Environment Aspects:Water management (Water courses, water monitoring); Environment waste management, Environmental Impacts; Chemicals store. (RQ) HCV Aspect: HGU and Land Status Estates confirmation, Riparian Zone, HCV Confirmation. (GGU & YM) Plantation Aspects: Herbicide Application Programme, Integrated Pest management); Harvesting Site, Fertilizing Operations, Land Preparation and Assessment. (GGU & YM) Social Aspects: Meeting Stakeholders, Kepala Desa and Confirmation of Local Contribution /CSR. (TSS) Worker Welfare:Housing, Clinic, Labor Union, Koperasi, Worker welfare. (WS) Location : Gedung Aji Lama KKPA (GALA) Social Aspects : Meeting Stakeholders, Kepala Desa and Confirmation of Local Contribution /CSR. (TSS) 16.30 End of audit 18 Jul’13 4th Day 07.30 Location : Sungai Merah Estate (SMRE) Environment Aspects:Water management (Water courses, water monitoring); Environment waste management, Environmental Impacts; Chemicals store.

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(RQ) HCV Aspect: HGU and Land Status Estates confirmation, Riparian Zone, HCV Confirmation. (GGU) Plantation Aspects: Herbicide Application Programme, Integrated Pest management); Harvesting Site, Fertilizing Operations, Land Preparation and Assessment. (YM) Social Aspects: Meeting Stakeholders, Kepala Desa and Confirmation of Local Contribution /CSR. (TSS) Worker Welfare:Housing, Clinic, Labor Union, Worker Welfare. (WS) 12.00 Break 14.00 Location : Sungai Merah Mill (SMRM) Best Practices & Environment Aspect. (RQ, YM & GGU) Worker Welfare, Training, Management (WS) OSHAS/SMK3 (WS & YM) Social Legality, & SCC System (TSS) 16.30 End of audit 19 Jul’13 5th Day 07.30 Reporting (All Team) 12.00 Break 14.00 Closing Meeting (All Team) 17.00 Back to Lampung 22.00 Arrive at Lampung 20 Jul’13 6th Day 06.50 Back to Jakarta

Scope : 2 mills and 5 estates Number of assessor participating: 5 auditors + 1 Witness Ministry of Agriculture, totally 6 person Number of days spent for the assessment on site:30 days Total number of person days used for the assessment on site : 25 days B. 4. Stakeholder Consultation B. 4. 1. Summary of How Stakeholder Consultation was Organized

Stakeholders Consultation and Company Responses Issue Company Responses Assessor Findings

Sungai Buaya Mill (SBYM) Company has the SOP, - Conform stated contractor should obey FFB Contractor : Mr. Dalmadi for safety standard and relevant government The employee of contractor has regulation. been paid as per government standard for minimum salary per province.

The contract agreement has contained the requirement for

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safety.

The payment methods has been agreed by each party

The contractor has been trained for safety matter

Sungai Buaya Estate (SBYE) The head of Sub-district The head of Sub-district Meraksa Aji is new in his Meraksa Aji has been Head of Sub-district Meraksa Aji position. Therefore, the assigned for 6 month in the (Bpk Sukerdi) information received could be Sub-District. The information not from representative given is sopposed to be There is complains from growers growers. valid. The Company should that company charge for ensure cooperative’s efforts production, transport and to socialize aspects that methods was not clearly defined become a factor in price cutting related to costs imposed to plasma members for maintenance and transportation costs. Proof that all parties understand the contract agreement they entered to, and that the contracts are fair, legal and transparent. – Observation

KKPA GALA Estate Company has the SOP for Conform Religion Leader : Mr. KH Information Request and Muhidin Response. All information Head of Village : Mr. Suraji requests should be responded for maximum 1 - Confirmed no land conflict month. - The request information always replied by company - There is company charity for Islamic school

The company will conduct KKPA MSJA Estate socialization for grading Observation. Head of village Mesuji : Mr. system at mill and also to Azhar Hidayatullah introduce the types of rare and endangered flora and - Access to village is shorter as fauna surrounding village. people have the shortcut via Sucofindo ICS FRM 14.05 19 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

estate. - Company provides scholarship to the local community. - No socialization yet to local community to maintain rare and endangered flora & fauna - Local empowerment by employ local people and contractor for FFB transporter - The company has conducted CSR program such as missal medication, glass aid, and bazaar. - The grading system at mill is not clearly to the growers - There are an indigenous people (Nenggala ethnic) but the location is about +/- 60 km from nearest estate. Labor Union Company has the policy to Conform allow the worker to form the Union Leader : Mr. Sopuan union labor. The evidence is circulating letter from CEO-2 - Confirm that no child labor No. 094/CEO2/SE/12/2010 employed dated 14/12.2011. Only one - Salary minimum for workers (1) labor union registered in have been complied the company. - Regular Meeting has been conducted with supporting facility by management Cooperation Krida Sejahtera The company will set up the Minor no. 01 program to ensure all Head of Cooperation : Mr. Miseri representative growers and AJ Aminanto staff will be adequate socialize for sexual - The plasma member is totally harassment issue. 17.062 member from 36 villages - There is not yet socialization conducted regarding sexual harassment to the growers. - The grading methods have been clearly defined and there are two (2) staffs present at the mill every day as a witness during grading process. - There is no conflict land

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among growers and company. - Payment from company conducted twice per month and the payment time is always on time

B. 5. Date of Next Surveillance Visit One (1) year after date of certification

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C. Assessment Findings C. 1. Lead Assessor’s Summary and Recommendation for Certification The audit is conducted jointly Roundtable on Sustainable Palm Oil (RSPO) Certification Scheme and Indonesian Sustainable Palm Oil (ISPO) Certification Scheme. There are 2 (two) mills and 5 (five) estates has been audited at the same time during preliminary (June, 10th-14th 2013) and certification audit (July, 15th-19th 2013). Some of the issues between ISPO and RSPO are mainly same such as commitment to transparency, compliance with applicable laws and regulations, commitment to long-term economic and financial viability, environmental requirements, social aspects, best practices of estates and mill and continuous improvement. The significant differences which is only for RSPO requirements such as term of findings, HCV’s issue, SIA, sexual harassment requirement, specific requirements of contractor (should be meet with manpower regulation and well trained), and NPP requirement. The audit conducted twice i.e. preliminary audit and certification audit. The scope of the audit for this unit is a mill (SBYM) and three (3) estates. Two (2) of the three (3) estates are smallholder schemes (KKPA Gedung Aji Lama (GALA) Estate and KKPA Mesuji (MSJA) Estate) and the own estate is Sungai Buaya Estate (SBYE). The Mill and estates has been visited during preliminary and certification audit (no sampling). The management (Mill and estate) showed the commitment to the implementation of the principles and criteria of the RSPO NI-INA. The assessment has been carried out through field visit to head office, mill and estate. The public announcement for certification has published on RSPO website prior 30 days from the audit certification to give the opportunity to stakeholders for comments and feedback. There is no a grievance or complaints received from the stakeholders during 30 days of public consultation period. Team auditors also conducted separate meeting with village head, local community, union labor team, and government official representatives. There is some clarification received regarding the HCV issue, conflict land, Socialization of Rare and endangered flora and fauna, transparancies, charity, etc. There is 1 NCR minor and 10 Observations issued during certification audit. There is commitment of management to make corrective action and for continuous improvement. There is also improved plan for social and environmental area. The audit team found that PT Sumber Indah Perkasa (Sungai Buaya Mill (SBYM), Sungai Buaya Estate (SBYE),KKPA Gedung Aji Lama (GALA) Estate, KKPA Mesuji (MSJA) Estate are complying against RSPO P & C approved for Indonesia. Therefore the recommendation of the Lead Auditor that Certificate of RSPO is awarded to PT Sumber Indah Perkasa – Sungai Buaya Mill and its estates.

Signed :

Tuti Suryani Sirait Date : September 16, 2013

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C. 2. Summary of the Findings by Criteria 1 COMMITMENT TO TRANSPARENCY

1.1 Palm oil 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 Response to Request and Information (SOP/SPO/SMART/LH-01). 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. In the Mesuji Plasma Estate, the person in charge of social aspect was appointed by the management through the letter of appointment no 016/RC-LAMPUNG/01/2012 that the MSJA Manager is responsible for social aspects and communication with stakeholders. All communication is recorded in the communication book for all stakeholders (internal and external). The majority of requests found in the list of stakeholder request are clean water supply request from the Community of Brabasan Village. Sampling is conducted on the Letter of request from Brabasan Village Manpower and Transmigration Service asking for labor and grass cutting equipment assistance, dated 12 Feb 2013 under the name of Drs. Rozali. Company has responded by providing assistance on 23 Feb 2013 evidenced by the minutes of hand-over of 1 unit of grass cutting equipment along with the operator. All forms of request for information are filed in a folder and indexed according to the date of incoming letter. For GALA Plasma Estate, personnel responsible for communication with stakeholders are the GALA Manager who is established with management decision letter no. 12/SK-RC- Lampung/IV/2013. Any requests for information are recorded in log book. Recorded information requests comprise routine reports to government agencies in need. Communication and Consultation are recorded in a separate log book. In general, most request letter is asking for assistance of road repairs and surfacing from surrounding communities. Sampling was conducted on the letter of request from the Paduan Rajawali Village Chief dated 8 November 2012 containing a request for heavy equipment assistance. Company had followed it up on 26 November 2012 by conducting road repairs using Grader in Paduan Rajawali Village, Meraksa Aji District -Tulang Bawang and evidence of completion had been documented in the form of Minutes. The records of information requests and responses are kept with retention time of 10 years. Compliance status: Full Compliance

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 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.

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Compliance status: Full Compliance

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. Sampling of Mesuji Estate, personnel responsible for ensuring compliance with regulations related to ‘sustainable palm oil’ is under the responsibility of Sustainable Palm Oil Officer stipulated in decision letter no. 03/EM-MSJA/VI/2013. Company sorts regulation list according to the aspect s: environmental aspect, estate aspect, permit aspect, employment and occupational safety and health (OSH) aspect. Evidence of evaluation of the most recent regulations such as PP no 27/2012 relating to environmental permit has conformed. Other sampling of evidence of compliance with regulations has conformed such as company has conducted reporting routinely to relevant agencies, for example routine report to Jamsostek (worker’s social security). Company previously has operating permit of one (1) mill for the capacity of 30 ton/hour. At the time of preliminary audit, a nonconformity was found in which the company had two (2) Milswith a capacity of 60 ton/hour each, totalled 120 ton/hour. At the time of certification audit, the company had been following it up by processing the IUP for Mills of 120 ton FFB/hour capacity. The company already has a 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. Compliance status : Full Compliance 2.2 The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights 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. Company has a Decree of Governor No. C/202/DA/HK /1989 on Land /Site permit and land use totaling 9,000 Haunder the name of PT Sumber Indah Permai. After that, there are site permit changes no. C/309/BPH/HK/1990 to become 9,522.11 Ha. 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. Company already has a certificate of HGU from BPN with no. 1/HGU/BPN/93 totaling 9,522.11 Ha dated 30 January 1993. Company already has a certificate of HGU that consists of : HGU issued by the Regency of North Lampung with no. 08.04.15.01.2.00014 dated 21 July 1993

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totaling 5,058.82 Ha for the location of SBYE and SBYM. All HGUs will expire in 2027. Company already has IMB no. 642/245/650/600/1995 totaling 5,995.4 M2 for PKS SBYM. Compliance status: Full Compliance 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. Company is a takeover from earlier company in 1990. Company states that during the period from 1990 until the time of the audit there was no purchasing of land. There is SOP of Land Conflict Settlement (SOP/SPO/SMRT/LH-04). So far the company and KUD inform that there was no dispute during the period from 2010 to the present time in the area around company site. It is said in the SOP to prioritize deliberation over legal action. At the time of audit the Location Map of PT. Sumber Indah Perkasa No. Reg: 948/214/PMNP/VI/12 with the scale of 1 : 250,000 were showed. The map should have a sufficient scale of minimum 1 : 100,000 in accordance with Decree of the Ministry of Forestry No. 48/menhut-II/2004. Compliance status : Observation no. 5 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 PT SIP long term replanting program up to 2020 has been established. The replanting plan will commence in 2017 up to 2020 covering 5 estates with a total area of 23,443.87 Ha. For plantations under the SBYE Estate, including MSJA and GALA, replanting area is determined as follows : - 2017 (planting year (TT) 1991) is 513.14 ha ; - 2018 (TT.1992) is 2,720 ha ; and - 2019 (TT.1993) is 1,118 ha ; Company has financial statement that has been audited by the public accountant office of Tanubrata Sutanto Fahmi & Rekan, in 2011. Tax report data for 2012 was not available yet but there is a statement letter dated 16 April 2013 issued by the public accountant office that it is under audit completion process. Compliance status : Full Compliance

4 USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS

4.1 Operating procedures are appropriately documented and consistently implemented and monitored - SOP and WI related to new planting, issued 1/7/2010. - SOP on New Land Opening (SOP/SMART/MCAR/IV/TA-PLB), rev.0, issued 1/9/2012. Point 2.2.6 Preparation regulates on: terracing and horseshoe shaping (tapak kuda).

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- There is IK /SMARTR/MCAR/TA-PPA/01 on Drainage - Records of nursery maintenance are not available since there is no longer nursery activity. - SOP/SMART/MCAR/V/TA-TNM, 1/9/2012. SOP on Planting - There is IK/SMART/MCAR/V/TA-TNM/01- Lining Flat to Wavy Area and also guidance (table) from Plant Density in Flat Area. - In SOP and orWIthe plant density is set at 136/ha. In general, the company already has SOP on Land Preparation Technical Guidelines (Palm Oil) that constitutes a collection of SOP and WI related associated with new planting. issued 1/7/2010. SOP on New Land Opening (SOP/SMART/MCAR/IV/TA-PLB), rev.0, issued 1/9/2012.Point 2.2.6 Preparation regulates on: terracing and horseshoe shaping (tapak kuda). Also, there is IK /SMARTR/MCAR/TA-PPA/01 on Drainage system. There are SOP on Nursery Bed (SOP/SMART/MCAR/III/TA-BBT, rev.00,1/9/2012) and IK/SMART/MCAR/III/TA-BBT/06, Seedling Acceptance and Planting. But both do not regulate the use of certified seedlings yet at the time of audit stage I. Nevertheless, at the audit stage II the company had issued a Memorandum from VPA PSM2 (D. Sivasanker) No. 001/MEMO-VPA PSM 2/07/2013 dated 1 July 2013 on the use of certified seedlings as evidence of commitment to the established SOP and WI (conform). There is Form of Oil Palm Seedling Selection (FORM/III/TA-BBT/06-Seedling Acceptance and Planting /01 Selection. IK/SMART/MCAR/III/TA-BBT/08-PN Selection, starting from selection at 2 months old and at transplanting, counting abnormal seedlings (criteria exists), and documenting/recording/reporting all reject seedlings. Figure 1. Types of Reject Seedlings. Recorded in the form of Pre Nursery Oil Palm Seedling Selection Sheet (FORM/III/TA-BBT/08-Seleksi PN/01, rev.00, rejection is classified into: RL, C, TS, CM, TS, etc. There is no data on planting plan and realization since there is no longer planting activity in all estate areas of Sungai Buaya Estate (SBYE), KKPA Mesuji (MSJA) Estate, KKPA Gedung Aji Lama (GALA) Estate. At the time of audit stage I there was no SOP on planting on a peat land. However, at the time of audit stage II verification was made on Work Instruction IK/SMART/MCAR/III/TABDT/06- IK on Planting on a Peat Land Rev.00 dated 26 March 2012 for the above three (3) estate areas. Compliance status : Full Compliance 4.2 Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield Sop on Maintaining Unproductive Plants SOP/SMART/MCAR/X/TA-PTB Work Instruction on Plant Census IK/SMART/MCAR/X/TA-PTB/01-Plant Census Work Instruction on Insertion IK/SMART/MCAR/X/TA-PTB/02-Insertion Work Instruction on Measuring Plant IK/SMART/MCAR/X/TA-PTB/03-Measuring Plant Growth Growth Work Instruction on Constructing And IK/SMART/MCAR/XI/TA-PMP/04-Constructing And Installing Harvest Ladders Installing Harvest Ladders Work Instruction on Maintaining IK/SMART/XII/TA-PTM/01-Maintaining weeded circle, Weeded Circle, Harvest Path, Control harvest path, control path and collection path

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Path and Collection Path Sop on Harvest Preparation SOP/SMART/MCAR/IX/TA-PMP Work Instruction on Developing IK/SAMRT/MCAR/XI/TA-PMP/01 - Developing Pollinating Weevil Pollinating Weevil Work Instruction on Castration IK/SAMRT/MCAR/XI/TA-PMP/02- Castration Work Instruction on Sanitation IK/SAMRT/MCAR/XI/TA-PMP/03-Sanitation Work Instruction on Constructing And IK/SAMRT/MCAR/XI/TA-PMP/04-Constructing And Installing Harvest Ladders Installing Harvest Ladders Work Instruction on Maintaining IK/SMART/MCAR/XII/TA-PTP/01-Maintaining weeded Weeded Circle, Harvest Path, Control circle, harvest path, control path and collection path Path and Collection Path Sop On Maintaining Productive Plants SOP/SMART/MCAR/XII/TA-PTM Work Instruction on Tree Census IK/SMART/MCAR/X/TA-PTB/01-Tree Census Work Instruction on Maintaining IK/SMART/MCAR/XII/TA-PTP/01- Maintaining Weeded Circle, Harvest Path, Control Weeded Circle, Harvest Path, Control Path and Path and Collection Path Collection Path Sop on Maintaining Space Between SOP/SMART/MCAR/VIII/TA-PGM Palm Rows Sop on Weeding SOP/SMART/MCAR/VIII/TA-PGM Sop on Maintaining Roads, Drains and SOP on New Land Opening Bridges SOP/SMART/MCAR/IV/TA-PLB Sop on Pest and Disease Control SOP/SMART/MCAR/VII/TA-HPT Work Instruction on Pruning and IK/SMART/MCAR/XII/TA-PTM/02-Pruning and Stacking of Fronds Stacking of Fronds Sop on Fertilizing SOP/SMART/MCAR/IX/TA-PPK Sop on Harvesting SOP/SMART/MCAR/XIII/TA-PNN Attachment to Work Instruction on Ripe LAMP/XIII/TA-PNN/01- Ripe Fruit Criteria in MILL Fruit Criteria in Mill Work Instruction on Harvest IK/SMART/MCAR/XIII/TA-PNN/01-Harvest Sop on Loading and Transporting FFB SOP/SMART/MCAR/XIV/TA-PPT Work Instruction on Loading FFB SOP/SMART/MCAR/XIV/TA-PPT/01-Loading FFB Work Instruction on Transporting FFB SOP/SMART/MCAR/XIV/TA-PPT/02- Transporting FFB Work Instruction on Installing Nets and SOP/SMART/MCAR/XIV/TA-PPT/03-Installing nets Seals and seals

There is no TBM maintenance because the youngest is the planting year 2000 - TM maintenance includes: (1) Tree census, (2) Maintenance of weeded circle, harvest path, control path, and collection path (3) Maintenance of space between palm rows (4) Weeding (5) Road and bridge maintenance (6) Pest and Disease Control Sucofindo ICS FRM 14.05 27 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

(7) Pruning and Stacking of Fronds Maintenance activities are recorded in: - Foreman Activity Log (BKM) – daily - Work Outcome Log (BHK) – wholesale. - For main estate, the content of BKM and BHK is inputted into Check roll program (SAP), while for Plasma, the BKM is summarized in the Report of Plant Maintenance. Compliance status: Full Compliance

4.3 Practices minimize and control erosion and degradation of soils Company has protected river border area by clearing free from oil palms with clearance space of 50 meter from river edge, and the river banks are planted with bamboo and fertifer grass to prevent erosion. The document is SOP of PT. SIP-GALA/SOP/34 Revision 00 dated 1 March 2012. The details of rivers location and condition are described in Criteria 5.2 (HCV). Compliance status: Full Compliance 4.4 Practices maintain the quality and availability of surface and groundwater. Revised ANDAL Document of AMDAL of Oil Palm Plantation and Oil Palm Processing into CPO, sources of water from Sungai Buaya and Sungai Merah. There are 3 drilled wells. The depth of drilled wells are 10-15 meter Company already has SIPA permit from the Government of Mesuji Regency, the Mining and Energy Department, No : 540/06/SPKTS-SIPA/III.14/MSJ/IV/2013, ± 100 m depth drilled well permit, covering Mesuji Estate and Sungai Buaya Estate, 7 April 2013 Water needs for Mill 1 ton TBS are 1.5 m3 of water, for domestic needs are 100 m3/day, so with mill with a capacity of 60 ton TBS per hour, the total use of river water is 2,800 m3/day. The efficiency of water use for processing in the SBYM in 2013 from January to April is 0.712 m3 per ton TBS. The efficiency of water use for processing in the SBYM in 2012 from January to December is 0.905 m3 ton TBS, where the target of 1.5 m3 per ton TBS has been achieved. Areas at Buaya River and Tapa River have been planted with bamboo to prevent erosion. The results of surface water measurement can be found in RKL and RPL that cover Sungai Buaya, Sungai Merah mill, and 4 resident wells. Organization has measured the quality of clean water in the resident wells with 4 resident well sampling points. The results of clean water quality measurement of resident well number 3 is below the BML = 50 for coliform biological factor, for pH the resident well number 1 and 4 are below the BML = 6.5 - 9 Company has measured the SBYM liquid waste, with results is appropriate with the requirements of KepMenLH No. 29 of 2003. Routine measurement is conducted every 6 months according to the activity in the RKL and RPL that conduct measurement and reporting every 6 months to BLH of Mesuji Regency, BLH of Lampung Province, and KLH Jakarta (SBYM), and to BLH of , BLH of Lampung Province, and KLH Jakarta. Organization conducted environmental measurement during the period of Semester I of 2013 that covers surface water and groundwater. For the SBYM area it covers Tapa River. The regulatory references are the Regulation of the Governor of South Sumatera No. 16/2005

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(Attachment I). The measurement results do not exceed the Environmental Quality Standard requirements yet. The results will be reported to the government in accordance with RKL and RPL requirements. On 1 May 2013, the organization conducted the measurement of Tulang Bawang river upstream and Tulang Bawang river downstream in Gedung Aji Lama KKPA, executed by SMART Research. The results of river water analysis, SMARTRI-Form-PSM-27-01, revision: 00. Measurement results are in accordance with BML. On 20 May 2013 the organization conducted measurement of surface water quality in the area of MSJA and GABA, by Environmental Laboratory, Environmental Body, the Government of South Sumatera Province. This body also has obtained KAN accreditation as an environmental testing laboratory. The measuring standards are the Governor Regulation No. 16/2005. Compliance status: Full Compliance 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated The company has the SOP on Plant Disease and Pest Control (SOP/SMART/MCAR/VII/TA- HPT, 1/9/2012) The data found for IPM program at SBYE, KKPA Mesuji and KKPA GALA:

(1) rat census 2012-2013, carried out quarterly,

(2) UPDKS (Oil Palm Leaf Eating Caterpillar), monthly since 2009-2013.

(3) Maintenance of Bio controls Plants (APH), 2009 – 2013, monthly, covering: Turnera subulata, Antigonon sp. and Nephrolephis biesserata.

(4) Census officer, there are 3 personnel for each division (SBYE) – there is caterpillar census implementation. The officer has been trained and supporting data such as photographs, attendee list, trainer from Regional Research Unit, Integrated Pest Control Training Module.

(5) Sprayers, for SBYE there are 2 groups @24 personnel. For GABA there are 1 group @10 personnel. There is evidence of Training Attendee List of Restricted Pesticide Use, 18/10/2011 for SBYE and GABA. There are 64 attendees.

(6) Training for Sprayer (SOP and WI), evidence such as attendee List of on 27 /4/2013.

There is SOP on Plant Disease and Pest Control (SOP/SMART/MCAR/VII/TA-HPT, 1/9/2012).

Compliance status: Full Compliance

4.6 Agrochemicals are used in a way that does not endanger health or the environment. There is no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. Where agrochemicals are used that are categorized as World Health Organization Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented Handling of Pesticide Waste The registered company collected used pesticide packaging of jerry cans and plastic bottles

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made of Polymex material. Non polymex material is collected in a special warehouse after being handled in accordance with WIon Washing and Cleaning of Pesticide Packaging’s and Fertilizer Bags, SIP-SBYEIK/19, No. Revision: 00 approval dates 1 March 2012.Companyhas provided facilities for mixing pesticide, washing used pesticide packaging’s, washing used Fertilizer Bags, washing pesticide apron, and bathroom for sprayer personnel. SBYE, MSJA KKPA & GALA KKPA At the time of audit stage I there was still waste water from sprayer bathing activities flowing into public sewer at SBYE. The organization has repaired it and directed the effluent from sprayer bathing activities into a septic tank. Pesticide hazard warning signs have been displayed in washing facilities in all areas. Used pesticide packaging’s already washed are stored in a special warehouse (which also contains used paint and thinner cans) and picked up by Hazardous and Toxic waste collector service company PT Primandu Jaya. The company has obtained Hazardous and Toxic waste collector and transporter permit from the Ministry of Transportation, Directorate General of Land Transportation for transporting Hazardous Materials, No. AJ.309/50/019/DJPD/2012/36005114. Pesticide waste handling is already regulated in pesticide work instruction, WIon Washing and Cleaning of Used Pesticide Packaging’s and Fertilizer Bags, SIP-SBYEIK/19, No Revision: 00 with approval date of 1 March 2012. However, it is written in the WI that the collection place is in TPS Hazardous and Toxic, whereas in implementation not in TPS Hazardous and Toxic but in a warehouse in which there are also used paint and thinner cans. Company needs to provide hazardous waste warning signs in the warehouse. In the bathing room for sprayers after completing their tasks in MSJA, the water flows to a septic tank. In GALA, waste water from sprayer bathing room is flowing to a septic tank. Company already has a list of agricultural and forestry pesticide recommended by Pesticide Commission of the Republic of Indonesia both synthetic and natural for weeds and caterpillars such as, among others, synthetic herbicide Rolixon, Gromoxone, Roll up and natural insecticide Cordiceps for ulat api pest control. However, company should reduce the use of herbicide of paraquat active substance (restricted pesticide), and use herbicides for weeds that are powerful but safe for operators in the long run (observation). Compliance status: Observation no. 2

4.7 An occupational health and safety plan is documented, effectively communicated and implemented Company has established and implements occupational safety and health management system to fulfill the obligation as per government regulation. Evidence of implementation found as follows : - Has established Occupational Safety, Health and Hygiene Policy of PT. SIP – Lampung Region, dated 2/9/2011. The policy was signed by the officials of RC, PC, and PUKSPSI. The policy goal is continually seeking to reduce hazards leading to work accidents that result in injuries, work related diseases, goods damage, fire and explosion as well as production process disruption and environmental pollution. Socialization of OSH Policy is carried out in class, through training, meetings, morning calls, morning circles, as well as displayed in the

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workplace. - Company has had and established OSHAS documentation that includes OSHAS Manual, SOP/Procedures, Work instructions and forms that has been implemented per 1 July 2010. Currently, most of documentation has undergone revision once.

The company has the Organizational structure and personnel in charge of OSH aspects, i.e. OSH Officer. In order to comply with government regulatory, the Company has established P2K3 team in each Unit, consists of General OSH Expert (AK3U) who serves as the Team secretary and team leader which are the Unit’s Manager. All P2K3 Teams have obtained approval from local manpower agency. The approval data are as follows: SBYM :

P2K3 Team was established with SK No. 560/8/III.04/MSJ/P2K3/III/2013 dated 22/10/2010 by Mesuji Manpower and Transmigration Service. The Secretary is Hermawan Berliana with appointment letter No. SKP.1554/DJPPK/AK3-U/VII/2010, dated 26/7/2010.

SBYE :

Division II, Blok 14 - 15

P2K3 Team is valid for 2013-2015 period, with approval of SK No. 560/46/HIPK/II.TB/P2K3/IV/2013 dated 15/4/2013, from Social, Manpower and Transmigration Service of Tulang Bawang Regency. The Secretary is Piki Ardiansyah, as AK3U, with appointment letter No. KEP.4120/M/DJPPK/I/213 dates. 7/1/2013.

PPE has been equipped by the company such as: boat, helmet, glass for all harvesters.

GALA KKPA :

P2K3 Team has obtained approval from Social, Manpower and Transmigration Service of Tulang Bawang Regency with No. Kep:560/36/HIPK/II.TB/P2K3/IV/2013 with Secretary Ifriansyah as General OSHExpert.

MSJA KKPA :

P2K3 Team has obtained approval from Social, Manpower and Transmigration Service of Tulang Bawang Regency with No. Kep:560/45/III.04/MSJ/P2K3/6/2013 dated 10 June 2013 with Secretary Hendri Kustiwan. Appointment Letter No. Kep: 2266/M/DJPPK/X/2011 dated 6 October 2011.

P2K3 Team has been conducting routine monthly meetings, on a regular basis. Minutes of meeting are already listing the topics, description of meeting/discussion results, due date of settlement follow up (start, finish), and PIC. The completion status of each case complete with completion date, and if not yet completed then sit will be brought to the next meeting.

All work units under PT. Sumber Indah Perkasa has included its employees in the Social Security Program (Jamsostek), starting from daily wage workers (BHL), PKWT, and SKU. The program varies in package according to the employee status. Those with BHL status will be included after 3 consecutive months because their status rises to Daily-SKU (SKU-H). Employees with SKU-H and PKWT status are only included for ½ packages, i.e. only JKK and JKM, where as employees with Monthly-SKU (SKU-B) and SKU status up to staff get full

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package programs, namely: JKK, JKM, JHT, and JPK. List of Jamsostek membership is stored and recorded on manpower data base, and already has KPJ Number. But PKWT in particular, does not have KPJ number. The Jamsostek Insurance is not willing to give KPJ Number for reasons of non-permanent status.

The company has conducted worker health examination of BHL, PKWT, and SKU. Evidence of examination can be shown as follows: 1) There is a recapitulation of staff and employee health examination results in 2013: (a). SMRM, examination date: in stages from the 2nd to 5th month of 2013, for 168 workers (SKU+PKWT). (b). SBYM, examination date: in stages from 2nd to 4th month of 2013, for 88 workers. Those not yet examined are planned to be examined in July, 2013. (c). SMRE, examination date: in stages from 2nd to 4th month of 2013. And (d) SMRE, examination date: in stages from 2nd to 4th month of 2013. Company has issued a Policy for medical examination, on Lampung Region Worker Health Examination, approved by the Regional Controller and Production Controller, dated 1/6/2011, containing prior-employment, periodic, and specific examination. During preliminary audit, the examination of cholinesterase aspect has not been conducted for workers who work closely with Hazardous and Toxic, such as: sprayers, Hazardous and Toxic waste officers, chemical warehouse and laboratory officers. Application for this examination has just submitted. Also for personnel working in the noisy area, the audiometry measurement has not been conducted. At the time of the audit stage 2, company has been conducting cholinesterase and audiometry examination for these personnel. Spirometry examination should also be programmed for sprayers, Hazardous and Toxic waste, chemical warehouse and laboratory personnel. The company also provides health care service by establishing a Clinic located in the SBYE Central Office. The clinic had received permit from the Department of Health of Tulang Bawang with Private Health Care Service License No. 455/503/014/SIT-BP/DK-TB/III/2004, dated 19/3/2004 and valid until 01/4/2007. License reapplication is currently under process in connection with the regency expansion so that the status of the clinic becomes under the Mesuji Regency. The clinic is led by a company doctor and a paramedic, both are medical certified. Employees have medication in the clinic free of charge, for both PKWT and BHL status. The service also covers the employee’s family. There is a Procedure for Hazard Identification, Risk Assessment and Risk Control (HIRARC) (No. SOP/17/SMART/LH-02, Rev. 01). Company has conducted ISBPPR that covers the whole Estate and Mill. The IBPPR results are recorded in Risk Analysis Form (FP 11/17-SOP-02) and Risk Analysis Follow up Form (FP 11/17-SOP-02). The reference for preparation is the ASNZ method. Preparation of ISBPPR for Estates covers from maintenance (fertilizer, spraying, space between palm rows, OPT, roads), harvesting, emplacement maintenance, warehouse, workshop (all machinery), clinic, central office, washing place for keep and Fertilizer Bags (shower sprayers). As for Mills, it has covered the entire process from transport, security, weighbridge, TBS grading, loading ramp, transfer carriage, sterilizer, tippler, thresher, press, clarifier, boilers, kernel, engineering, effluent, workshop, warehouse, Hazardous and Toxic warehouse, diesel fuel tank, lab, office, CPO dispatch, machine unit installation, fire engines, and vehicle traffic. ISBPPR is reviewed annually to see the effectiveness of earlier risk control application. If deemed necessary, the additional control will be added until "low" (L) risk level is achieved. This activity is carried out together between the operating officials and the P2K3 Secretary and Chairman. In each Unit company has conducted a number of training related to safety and health (OSH) Sucofindo ICS FRM 14.05 32 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

aspects, some of which can be reported as follows: SBYE, MSJA and GALA Units: - First aid Training, 21/5/2013, by dr. Wiyangga, from the clinic. 6 participants (4 foreman and 2 assistant clerks), materials include simulations on how to deal with accidents. - Socialization of ISCC, ISPO, RSPO, OSH, P3K, APD, MSDS, on29/05/2013. There were 13 participants. The presenter was OSH officer. - Socialization of procedure for handling natural disaster and fire (KTD), on 16/03/2013. Participants were 7 security personnel. - First aid Training, combined participants of Regional level, totaling 75 participants, on 10/10/2011. - General OSH Expert for P2K3 secretary. - Restricted pesticide use training, on 18/10/.2011, participants from SMRE with a total of 67 participants, on 19/10/2011. There was “Restricted Pesticide User Certification” from the Department of Agriculture, Food Crops and Horticulture of Lampung Province. - Special skill training, including: welder and heavy equipment operator license.

SBYM Unit : - First aid Training, 21/5/2013, 11 participants (4 foremen, 1 security personnel, book keeper, 2 analysts, nurses, P2K3 secretary, cashier). - Socialization of MSDS on 14/5/2013 at SBYM to48 workers by OSH officer. - Special skill training, including: welder and heavy equipment operator license.

Company has developed and established SOP related to fire prevention and mitigation, i.e.: - SOP on Emergency Handling (SOP/SMK3/SMART/LH-09), applicable in Estates and Mills. - Technical guidelines for dealing with emergency situation in the form of Emergency Response Mechanism Diagram contained in form of FP 02/SMK3-SOP-10, according to conditions, i.e. : (1) Fire (2) Hazardous and Toxic Spill Handling (3) Earthquake (4) Chemical Poisoning through Ingestion.

These SOPs have been effective since 1 July 2010.Socialization has been carried out to all workers by means of displaying at strategic locations, such as: Estate office, division office, Mill office, workshop, and parking area in the form of banners or billboards.

Company has established Emergency Response Team by appointing its personnel. The capacity to prevent and mitigate fire is sought to by providing the following training :

- SBYM Unit, some of the Dry Powder Squad members have attended training in the use of portable extinguishers (Light Fire Extinguisher), dated 20/11/2010, but, only 2 out of the 7 squad members, i.e. Sudarso and Sugiarto. - GALA Unit, Light Fire Extinguisher training has been conducted as seen in the List of Attendees of Light Fire Extinguisher Training, dated 7/6/2013. But, out of the Light Fire Extinguisher Team members, there is one not yet attending the training i.e. Sulisiyanto. - SBYE Unit, some of the Light Fire Extinguisher Team members have attended Light Fire Extinguisher training on 29/05/2013 and 20/11/2011 in Division 1 office. But out of that number of Light Fire Extinguisher Team the TTD/ERP Structure has not received training. - MSJA Unit, Light Fire Extinguisher training has been delivered on 20 June 2013, which is attended by all Light Fire Extinguisher Team members. Sucofindo ICS FRM 14.05 33 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Company has provided fire control/mitigation facilities and infrastructures as follows: - SBYM Unit In the Checklist of KTD Equipment dated 3 June 2013, it is recorded : (1). 35 Light Fire Extinguishers in 35 locations; (2). 4 units of pillar hydrant and 4 boxes of corresponding equipment (hoses and nozzles) at 4 strategic locations at St. Sterilizer, St. Boiler, St. Kernel, and St. Clarification; (3). Sandbag along with spades at 4 locations; and (4) Eye washers and showers in 5 locations (lab, CaCO3 warehouse, LB-3, oil warehouse and WTP). Company also has developed Evacuation Map and Map of Fire Sensitive Area provided with location points of Light Fire Extinguisher, hydrant, eye washer/shower, direction arrow of evacuation route, and 2 assembly points. It is suggested the company completed the information on important telephone numbers to be contacted in the case of emergency. - SBYE, MSJA and GALA Units In the Summary Report of Light Fire Extinguisher checking dated 28 May 2013, it was found : (1). 41 Light Fire Extinguishers distributed in 41 locations in the entire estate area covering central office, fertilizer warehouse, diesel fuel warehouse, oil, spare part, LB3, division office, mess, staff housing. (2). 1 unit of water tanks, 1 portable water pump provided with hoses and nozzles/guns. Company has conducted routine inspection of Light Fire Extinguisher and hydrant and recorded the results using PMKS Patiware Light Fire Extinguisher and Hydrant Monitoring form, which that is carried out monthly. There is evidence of implementation for December 2012 and January 2013. This activity is carried out by workshop foreman, verified by assistance workshop and acknowledged by Mill Manager. In dealing with emergency situation, company has established Emergency Response and Preparedness (ERP) as follows: - Emergency Response and Preparedness Organizational Structure has been established for each Unit, covering SBYM, SBYE, Mesuji and GALA. The KTD structure was developed by P2K3Secretary and approved by P2K3 Chairman (Unit Manager). The structure is composed of Team Leader, Deputy Team Leader, General Assistant, Executive Chairman, Secretary, Fire Extinguishing Team (Dry Powder, Hydrant, Sand, Wet burlap, Hook), Evacuation Team, Security Team, Connecting team, Eliminating Team, and Health Team.

For SBYM mill area, company should have fire mitigation officers in accordance with the provisions of the Decree of the Minister of Manpower No. 186/MEN/1999. Based on Annex 1 and 3, a processing plant (Mill) is classified as vegetable oil mill with Moderate Fire Potential III. A factory with a total workforce of over 100 people should have fire mitigation officers: 1 for class A, 1 for class B, 5 for class C, and 12 for class D. At the time of the audit stage 2, the Company had carried out Fire Simulation Training, dated 05/07/2013 from the Department of Social, Manpower and Transmigration, Tulang Bawang, to 20 people. However, this is only a fulfillment for class D. Company is strongly encouraged to comply with these provisions and required to program it in subsequent years.

Company has conducted various efforts related to fire prevention and mitigation, and kept the recorded report properly. Activities carried out in various unit areas (Estates and Mills) are as follows: SBYM Unit: - Fire simulation was conducted on 5/6/2013. - Routine inspection of emergency response equipment such as: Light Fire Extinguisher,

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hydrant, and sand burlap from every two week to once a month. This activity is conducted by TTD members, or SPO Officer, or P2K3 secretary. SBYE, MSJA and GALA Units: - Wildfire simulation was conducted on 24/3/2012 and in mid July 2013, regional level participant unit, 68 participants. There is scenario, evaluation, photos, and attendee list. - In GALA, simulation was conducted for potential earthquake and fire emergency situation, dated 25/6/2013, in the location of Central Housing, complete with scenario and evaluation but simulation for chemical spill mitigation is not yet conducted. - Patrol activity is conducted by Security Team to monitor HCV and wildfire, recorded in the Patrol Book per 2 weeks. - Creating fire breaks in the area bordering the community plantations and or being fire potentials, in each division – Unit. - Develop Division’s Fire Vulnerable Area Map. - Provide list of phone number both internal and external including for local police, local military, hospital, fire brigade. - Routine inspection of emergency response equipment, such as: Light Fire Extinguisher, hydrant, and sand bag from 2 weekly to monthly. This activity is conducted by ERP members, or SPO Officer, or P2K3 Secretary. - Report fire prevention to the Department of Social, Manpower and Transmigration every 3 months, Company has provided equipment related to OSH aspect, including PPEfor the workers. Below are some data that can be reported through sampling: - SMRM Unit, there is certificate of acceptance for: (1) leather gloves (2) safety shoes-workshop for 25 people, on 9/2/2013, (3). Helmet on 15/1/2013, 5 people, (4 Boots on 4/2013, for 4 people, - SMRE and GABA Units, there is a list of name of PPE recipient in Div.4, certificate of acceptance dated 24/5/2013, of AP Boots (7 people), sprayers: rubber gloves, AP boots, mask (12 people), harvesters: AP boots, helmet, safety glasses, sickle covers (27 people).

Company has an effort to fulfill with P3K provisions. Work sites have been provided with first aid kits, though some of them are not complete in accordance with the regulatory requirements. In the field, every foreman such as harvest and sprayer foreman carry small first aid kits containing the required medicine. All foremen have received first aid training from company doctor. Also, in each Unit (both Estate and Mill), a number of first aid officers have been appointed based on the Letter of Decision on Appointment of First Aid Officer signed by P2K3 Chairman or Unit Manager.

Company has established SOP on Handling of Work Accident (SOP/SMK3/SMART/LH-10, 1/7/2010), starting from handling accident in a worksite, handling of mass accident, reporting, investigation and recovery. There are evidence of implementation of reporting and investigation for accident occurred, among others: (1). Work Accident Report 1/24 hours (FP 01/SMK3-SOP-10). For example, for SBYE, accident date is 29/05/2013, Paryanto (NIK 09018), reported on 30/5/2013. (2). Accident Investigation Report from the Assistant (FP 02/SMK3/-SOP-10).

Other records related to accident recording are: (1) Recapitulation of Accident Report Every Month (FP 03/SMK3-SOP-10), and (4). Recapitulation of SR and FR Counting (FP 04/SMK3- SOP-10).

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On Saturday 11 May 2013, an accident occurred to a plane of Fletcher type conducting air manuring on oil palms. According to the explanation of Mr. Humala Sinaga (Lampung Regional Controller), the results of investigation of accident of plane coming from Air Manuring Division could not be obtained because of PT. Sumber Indah Perkasa (SIP) is just as a lessee who provides fertilizer and aircraft runway. Investigation is immediately undertaken by the National Commission for Transportation Safety (KNKT) on Sunday 12 May 2013 or a day after the incident with a note that parties who want the result of the investigation are asked to contact KNKTdirectly. Compliance status: Observation no. 3, 4, & 8 4.8 All staff, workers, smallholders and contractors are appropriately trained. Company has established annual training programs. Training activities are based on SOP on HR Development Training (SOP/SPO/SMART/LH-10, 1/7/2010, rev.01), covering: preparation, implementation, and evaluation. There is Training Need Analysis set by Regional Training Center Coordinator (RTCC) and the results are in the form of Training Need Identification Matrix (FL/Estate/TRAD/10), prepared by SPO Officer, and approved by Estate Manager. The Matrixes developed by SBYM, GALA, and MSJA units.

Annual training program is prepared and established by respective Unit. For 2013, it is:

- SBYM and SBYE: P2K3 Training Program of PT Sumber Indah Perkasain 2013, prepared and established by P2K3 Secretary, and P2K3 Chairman. Also, there is P2K3 Training Program (for Sustainability areas) covering: OSH, Environment, social, HCV, greenhouse gas emission, sexual harassment, and PHT.

- GALA and MSJA: Training Program 2013, signed by person in charge of SPO Unit and approved by Unit Head as per 05/01/2013. Training materials include: P3K, proper, socialization/training of ISCC, ISPO-RSPO, PHT, harvesting, HCV, Kompes, procedures & WI, PPE, Hazardous and Toxic waste control, GHG mitigation, GHG emission calculation, prevention of sexual harassment, socialization of communication and consultation, socialization of SOP on contractor control, socialization of jamsostek to contractors.

All records showing evidence of training implementation, such as: attendee list and photographs, and certificate are kept by KTU, while training records for sustainability are also kept by SPO Officer. Each Unit records training realization. For example, in GALA as well as MSJA Units. It is recorded in Training Recapitulation form that includes information: name of training, instructor, participant, implementation time, and training location.

Company is deal with trained contractor personnel. As mentioned in the above training program, each contractor of SBYM Mill, SBYE Estate, as well as GALA and MSJA Unit has been provided with related to RSPO, which includes :

- Socialization on appeal to include their workers in jamsostek, to care with environmental sustainability, protect biodiversity, implement OSH in the form of PPE use, encouragement to comply with OSH regulations, and being in harmony with the community. - Socialization on wage system and worker’s age that must not be <18 years old and minimum wage regulations. - Socialization on PPE: PPE mandatory, PPE benefit, encouragement to always follow OSH regulations—especially drivers and loading personnel. - For TBS transport contractors, evidence of being trained is demonstrated by driving license possession. Sucofindo ICS FRM 14.05 36 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

- Some contractors for road maintenance and housing have been selected in a strict manner through pre-bidding process from the aspect of willingness to comply with OSH aspect, employment aspect, as well as technical aspect according to type of work to be done. In GALA, two SPKs are found not expresivvely specifying the provisions of PPE mandatory use. They are SPK no. 027/GALA/JKTO/04/2013-Box Culvert and SPK no. KUD-KS/GALA/SPKL- L/January-12-/010-FFB Transportation and Loading.

Compliance status: Observation no. 9

5 ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY

5.1 Aspects of estate 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 Company conducted impact analysis in the Revised ANDAL document of AMDAL of Oil Palm Plantation and Oil Palm Processing into of CPO PT Sumber Indah Perkasa with an land area of 9,254 Ha and MILL with the capacity of 60 ton FFB/Hour No. Document is 16/KOMDAL/11.04/IV/2008 dated 14 April 2008. In ANDAL document the scope of environmental impact analysis is oil palm plantation activity and processing into crude palm oil (CPO). The scope of environmental impact analysis is Sungai Buaya Estate, Sungai Merah Mill and Estate, Geng Aji Baru Plasma, Gedung Aji Lama Plasma, Mesuji Estate, Sungai Buaya Mill, and Sungai Merah Mill. In ANDAL document, the environmental impact analysis is still scoping company current activity and condition. Environmental impact management is contained in RKL and monitoring plan is contained in RPL. The RKL and RPL is implemented every 6 months and report every 6 months to BLH of Mesuji Regency (SBYE, GABA, MSJE, SBYM), Tulang Bawang Regency (SMRM, SMRE, GALA, GABA) ANDAL Document also covers land biodiversity in the form of flora and fauna (biological aspect), social cultural aspect to the population of villages around unit and division. Compliance status: Full Compliance 5.2 The status of rare, threatened or endangered species and high conservation value habitats, if any, that exist in the estate or that could be affected by estate or mill management, shall be identified and their conservation taken into account in management plans and operations Company has had SOP on Identification and Management of HCV No.: SOP/NP/SMART/IV/LH 001 No. Revision 01 effective date 1 July 2010. Company has had the revised ANDAL document of AMDAL of Oil Palm Plantation and Oil Palm Processing into CPO of PT Sumber Indah Perkasa with a total area of 9,254 Ha and Mill with a capacity of 60 ton FFB/hour that scopes environmental conditions related to flora and fauna. Information in ANDAL document prior to planting, the flora identified is commercial crops such as meranti wood and there is no identification of fauna prior to planting. In ANDAL document there is flora and fauna identification after the land becomes oil palm plantation and oil palm mill, for flora it is palms and bushes, for fauna it is buaya, ular sendok, tikus, landak, babi hutan, macan

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akar, etc. The land’s baseline condition is a secondary forest. There is no information in ANDAL document about flora and fauna condition when it was still a secondary forest. Company has performed identification of areas with high conservation value along with a team that has obtained approval from RSPO Board and the report of identification of high conservation value area has been peer reviewed by Resin Sözer, an independent body approved to do peer review of high conservation value (HCV) area. Company has the Final Report of Identification and Analysis of the Existence of High Conservation Value Area (HCV) of each unit. At the stage I and stage II, the Final Report of Identification and Analysis of the Existence of High Conservation Value Area (HCV) of Sungai Buaya Estate, KKPA Gedung Aji Lama (GALA) Estate and KKPA Mesuji (MSJA) Estate is shown. In Sungai Buaya Estate it covers the border area of Sungai Buaya, the border area of Sungai Tapak, Lake Dasiem, reptile fauna, mammals, Aves, and so on. Protection of river border is to clear it from oil palms with a clearance space of 50 meter from the river edge, and the river banks are planted with bamboo and vertiver grass to prevent erosion. For fauna protection, company places communication boards of hunting prohibition in several areas where fauna occurrence is identified though through footprints (macan akar and babi hutan). HCV identification was conducted in the oil palm plantation area of SBYE unit (4°5’ - 4°17’ S and 105°26’ - 105°39’ E).The working area of PT. Sumber Indah Perkasa is 5,058.82 Ha with planting years of 1991, 1992,1993 and 2000. GALA Unit has the area of 5,005.25 Ha with planting years of 1995, 1996, 1997 and 1998. MSJA Unit has the area of 5,209.63 Ha with planting years of 1995, 1996, 1997 and 1999. Data of flora and fauna prior to planting are contained in Initial Environmental Examination of (PIL) Document of Oil Palm Plantation Project of PT. Sumber Indah Perkasa, Mesuji District and District, which is prepared by PT. Mulia Consultants. Data of flora diversity consists of: Cover Crops (Base Vegetation), among others: - Alang – alang (Imperata cylindrical) - Rumput Bendera (Eleucine indica) - Putri Malu (Mimosa invisia) - Pakis (Alsophila sp) - Rumput Merdeka (Paspalum sp) Trees, among others:  Pala Hutan (Myristica sp)  Beringin Hutan (Ficus benyamina)  Karet (Hevea brasiensis)  Bambu (Bambusa sp)  Pule (Gudrania sp) Aquatic Flora around the project location of PT. Sumber Indah Perkasa, among others:  Ganggang Hijau (Chlorophyta)  Enceng Gondok (Eichornia grassipes)  Palam (Corypha sp)  Teratai Putih (Nelumbium sp)  Pakis Air (Ceratopteris sp)  Lumut (Bryophyta) Data of terrestrial fauna diversity in the project location of PT. Sumber Indah Perkasa prior to planting includes: Aves Sucofindo ICS FRM 14.05 38 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

 Manyar (Ploceus manyar)  Tekukur (Streptopelia sp)  Jalak (Strurnus contra)  Emprit (Lanchura sp)  Cucak Rowo (Pycmonotus sp)  Elang (Bustantur sp) Mammals  Gajah (Elephan sp)  Kijang (Cervis timorensis)  Babi (Sus vitatus)  Beruang (Urus sp) Reptilia  Ular Piton (Phyton sp)  Kadal (Mobvia multifaciata)  Ular Sawah (Phyton molurus) Insect  Kupu-kupu (Papilio sp)  Capung (Gomphus sp)  Kumbang (Aryetes sp) In the Gedung Aji Lama (GALA) KKPA there is HCV 6, i.e. old cemetery such as Bangunrejo old cemetery, Rejomulyo public cemetery, and also HCV 1.2 of protected animal species. In the Mesuji (MSJA) KKPA there is HCV 6, i.e. old cemetery such as old cemetery Block B11, and also HCV 1.1, 1.3, 4.1 of Lake Dasiem, but there are still oil palm stands less than the clearance space of 50 meter from river banks, because the KKPA Mesuji (MSJA) Estate is the community plasma but Agrochemical use is restricted to 50 meter from the lake Dasiem shoreline. The following is details of Identification and Analysis of the Existence of High Conservation Value Area (HCV) of Sungai Buaya Estate, Gedung Aji Lama KKPA and Mesuji KKPA: 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) 1.2 - Government Regulation No. 7/1999 (Protected) and KKPAEstate and

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IUCN LC ver 3 (2010), include : surrounding 1. Raja Udang Biru (Alcedo coerulescens) areas 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) 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 2. Cekakak Belukar (Halycon smyrnensis) areas 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 HCV monitoring is conducted every 2 weeks. Document used is Patrol Log Book which is summarized into HCV Monitoring Form No. Document F/SMART/LH003/09 every 6 months. In addition, there are documents:  Erosion Control Crop Planting Report  HCV Area Patrol Report  Boundary Peg Maintenance Report  Water Level Report  Socialization Invitation  HCV Socialization Report

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HCV Monitoring Form has specified recommendations for improvement as well as recommendations based on routine monitoring carried out every 2 weeks, but Person in Charge (PIC) and a due date for the completion of recommendation should be determined to see the progress of follow up to HCV monitoring results. Compliance status: Observation no. 6 & 7 5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner Company performs impact analysis in the revised ANDAL document of AMDAL of Oil Palm Plantation and Oil Palm Processing into CPO of PT Sumber Indah Perkasa with a total area of 9,254 Ha and 2 Mills with a capacity of 60 ton FFB/Hour. SOP of Waste Management, SOP/SPO/SMART/LH-09, revision: 00 approval date: 1 July 2010, covering mill waste: solid, liquid, gas (including LB3). Plantation : ex pesticide packaging’s, land application, ex agrochemicals (such as fertilizer bags) Current practice of waste flow rate measurement is only on waste that flows out directly from the mill to Land Application recorded using flow meter every 7o’clock in the morning and at the time when pumping is finished. Company has Extension Decree of Permit to Utilize Oil Palm Industrial Effluent on Soil with the Decree of the Regent of Mesuji No.: B/161/I.02/HK/MSJ/2011, dated 29 July 2011 with validity period of 3 years. Effluent managed in the waste water treatment installation is directed to the land for land application Company performs ambient air and emission quality measurements (mobile and non-mobile sources). None of the measurement results exceeds the BML. Company reports the measurement results every 6 months to BLH of Mesuji Regency (SBYM), BLH of Lampung Province, and Jakarta KLH, with evidence of their receipt. Liquid and Hazardous and Toxic Substance waste results are reported every 3 months. In SBYM the Company has 4 effluent ponds. SBYM internal daily measurement covers the parameters of pH, Alkalinity, and VFA. Compliance status: Full Compliance 5.4 Efficiency of energy use and use of renewable energy is maximized

Company has performed identification of GHG emission sources of estate and mill activities. Company has calculated GHG emission of the SBYM, which includes calculation of respective GHG of estates supplying the fruit. Diesel fuel efficiency at SBYM in 2010 was 27.46%, 2011 was 44.32%, and 2012 was 33.94%, so that on average the efficiency was 35.92%. Diesel fuel use in 2010 was 1.88 liter/ton CPO, in 2011 was 1.51 liter/ton CPO, in 2012 was 1.12 liter/ton CPO. SBYM use of palm shell and fiber as fuel substitutes in 2012 was 10,916,000 kg and 37,891,121 kg, respectively, with the total energy used /ton CPO of 1,288,881 KKAL. GALA used diesel fuels in 2010 = 0.00068 Ltr/Ton FFBwith a total of 113,292,860 Ton FFB and 76,982 Liter of Diesel fuels. 2011 = 0.00073 Ltr/Ton FFB with a total of 134,171,830 Ton FFB and 97,589 Liter of Diesel fuels. Sucofindo ICS FRM 14.05 41 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

2012 = 0.00074 Ltr/Ton FFB with a total of 135,833,910 Ton FFB and 99,839 Liter Solar. 2013 (until June) = 0.00114 Ltr/Ton FFB with a total of 35,473,620 Ton FFB and 40,272 Liter of Diesel Fuels Company has SOP on Calculation of Green House Gas Emission at SBYM of PT-SBYM/SOP/02 The use of empty fruit bunches at SMRE in January – April 2013 was 21,763 ton with total application land area of 382.89 hectares. Target area to be applied with empty bunches for 2 years is 668 hectares. In 2012 it is 63,634 ton of empty bunches 1,155.74 hectares of land, with target of 672 hectares and 49,915 ton of empty bunches. Company has SOP on GHG Emission Mitigation of PT SIP – SBYM/SOP/22 No. Revision: 00, date approved: 02 January 2013, and performs calculations of GHG emission reduction from diesel fuel efficiency, shell efficiency in the process/mill where in 2012 the total GHG reduction from processing was 186.73 kg CO2/ton CPO. Compared with 2011 there is a rise due to the effect of low crop and huge crop during harvest. There is no peat land at SBYE Estate, so that peat land management is not required. The Estate GHG calculation is as follows: SBYE = 74.75 kgCO2eq/Ton FFB; MSJA = 95.19 KgCO2eq/Ton FFB; GALA = 81.77KgCO2eq/Ton FFB. SOP of GHG emission mitigation for PT SIP – SBYE/SOP/35 (SBYE), PT SIP – MSJA/SOP/35 (MSJA), and PT SIP – GALA/SOP/35. Compliance status: Full Compliance 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. Company does not burn wastes and there are no replanting activities. Company already bans the use of fire for replanting. Also, Company has instructed its workers and encouraged local people not to burn domestic garbage. Compliance status: Full Compliance

5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented, and monitored. Management through RKL and RPL implementation. Organization has RKL and RPL covering environmental impacts on river and drilled well water quality, ambient air, noise, air quality. RKL and RPL are reported to the BLH of Tulang Bawang and Mesuji Regency every 6 months starting from 2012, and there are receipts of RKP and RPL document submission. SOP of Waste Management, SOP/SPO/SMART/LH-09, revision: 00 date approved: 1 July 2010, covering mill wastes: solid, liquid, gas. SOP/WI is not yet available to handle stationary sources nuisance, such as noise that exceeds the BML At the stage 1 the results of measurement of vibration, odor, and noise did not come out due to the environmental testing laboratory’s equipment problems. Organization has followed up by Sucofindo ICS FRM 14.05 42 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

performing measurement on 20 May 2013 by the Government of South Sumatera Province, Environmental Body, UPTB Environmental Laboratory, covering odor at effluent ponds, noise at the gensets and boilers, also emission at the gensets and boilers. The measurement results are not departing from the requirements of the Regulation of the Minister of Environment No. 21/2008 for Genset emission and No. 07/2007 for Boiler emission. Organization controls vibration, odor, and noise nuisance through job work instruction for nuisance in the Mill, such as noise disturbance, the work instruction of the genset job has incorporated controls using silencer in the genset room and use of ear protection devices (ear plug and ear muff). Relating to environment outside the perimeter of mill and in employee/population residential area there is description on control in the RKL and RPL Report every six months, such as control using trees to repress odor, noise, and dust. The result of 20 May 2013 measurement does not depart from the BML requirements (50 dBA at residential area, 70 dBA at mill surrounding environment). Organization needs to establish SOP/work instruction to deal with stationary sources impacting beyond the mill (the location of stationary source disturbance is in the Mills. In the Estates, only GALA has gensets as stationary source nuisance which is potentially not yet meeting the BML requirements of the applicable regulations. Compliance status: Full Compliance 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 Company has conducted Social Impact Assessment internally in 2012. Based on the results of SIA it is identified that there are 14 villages around PT SIP affected by the social impact of estate and mill operations. SIA report says that the area of main estate is 9102.2 Ha and plasma estate is less than 15,000 Ha with total KUD member of 17,254 KK Company has had the list of stakeholders of all units. Based on the results of SIA and input from the units, company has established a strategic plan for CSR Program of 2014-2018: period (5 years). The program has included the short-term and long-term plans covering the aspects of education, health, infrastructure, sport, religion, arts, culture and micro business. The existing program does not include specific efforts made by company to preserve the native culture of indigenous people living around the company environment. Based on the SIA report, Company has conducted road improvement activities in 2009-2011 for 21 villages around the company site. Educational assistance is given to areas in the location of main estate and plasma estates. Religious assistance given in 2010 period already represents Islam and Christian religions and in 2013 it is for Hindu in the form of pura Talang Batu Village construction. Based on the SIA report there is negative perception because of jealousy felt by villages from not receiving social assistance (Batu Ampar Village and Tri Rejomulyo Village). Company responded by launching Cheap Oil Market Operation in 2012 in Batu Ampar Village and Sucofindo ICS FRM 14.05 43 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

educational assistance in the form of building materials for the development of local primary school in SDN 01 Tri Rejomulya in 2013. Compliance status: Full Compliance

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 has had SOP on Responding to Request and Information (SOP/SPO/SMART/LH-01). List of information is already available to be accessed by relevant stakeholders. Request for information outside the list will require the consideration and approval from the Top management. List of stakeholders of each unit is already available consisting of customary/community leaders, Muspida and village chief, company trade union, Contractors and suppliers. Any incoming requests for information is recorded in KTU and passed to relevant Manager. All requests for information are recorded in information book. Each unit maintains information request and response book. Routine requests are recorded in a routine information granting book and non-routine information requests are recorded in a separate book. In addition, Sinar Mas Group has SOP on Communication and Consultation (SMART/XIV/MCAR003) where any information requests will be responded the longest in 5 weeks (1 month). Sampling an information request dated 19 May 2012 related to complaints on the issues of road and village head incentive. The letter in question as well as the response to the complaining party (Bp Ikhwanudin) from Sumber Jaya Village has been maintained. Compliance status: Full Compliance

6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties Company has SOP on Complaint and grievances (SOP/NP/SMART/XII/MCAR001). Any complaint will be recorded in the log book of complaint and grievances. The source of complaints may be internally, externally and female workers. Sampling was conducted on employee’s complaint on 10 December 2012 concerning poor quality of . Company passed the complaint to KUD as the supplier of the rice. The response from KUD dated 20 December 2012 states that they will supply better quality rice. The officer informed that the employee has received better rice so that the complaint is closed. Compliance status: Full Compliance 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 There is SOP on Land Conflict Settlement (SOP/SPO/SMRT/LH-04). So far the company and KUD give information that there is no dispute in the period from 2010 until now in the company’s surrounding areas. The SOP says to give first priority to deliberation for consensus over legal action. Sampling conducted on the Mesuji stakeholders (Religious Leaders and District Chief) ensure that no conflict exists in the area of Sungai Buaya Mill. Compliance status: Full Compliance

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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 Company maintains SKU Detailed Payroll (sample, May 2013), for SKU-H, SKU-B, as well as PKWT, while for BHL and BHB such list is contained in BHL Detailed Payroll (sample, May 2013). For BHL the salary is paid twice per month, from 26th to 10th day of subsequent month, and from 11th to 25th of ongoing month, so the payroll is made twice. Company has company rules in the form: (1). Collective Labor Agreement between PT. SIP of Tulang Bawang Regency, Lampung: BH.NO: 182/PT.SIP/1989 and PUK.SPPP-SPSI Trade Union of Tulang Bawang, with Registration No.: 063/KPTS/PC/SPPP.SPSI/TB/XII/2005, for period of 2011-2013, and (2). Company Regulations of PT. SMART Tbk, version 2013-2014. For 2013 payment system, company refers to the Decree of the Governor of Lampung No G/30/III.05/HK/2013 concerning Stipulation on Tulang Bawang Regency Minimum Wage (UMK) in 2013 of Rp. 1,155,000.-, effective as per 01/01/2013. This provision has been socialized based on SK No. 036/CEO 2/HR PSM 2/01/2013 concerning the Wage of Daily Labor (BHL) PT. SIP-Lampung. In consideration of the above Governor Decree then decide to adjust the wage of daily workers (BHL) to become Rp. 46,200/day. This decision comes into force from 01/01/2013.

At MSJA Unit, although located in the region of Mesuji Regency, the wage stipulation refers to the same Governor Regulation to follow the Tulang Bawang UMK, i.e. Rp. 1,155,000.-. This is because in the Mesuji Regency (as expansion regency) there is no APINDO so as not to stipulate by itself. Company stipulates the same as that of SIP prevailing in Tulang Bawang Regency.

With respect to the UMK (regency minimum wage) provisions the workers in the field have know it precisely. This is known from the interviews with a number of BHB workers (taken by sampling) of harvesting personnel. They inform that daily wages are Rp. 46.200,- working fulltime for 25 working days per month they will receive basic wages of Rp. 1.155.000,-,. On the wage payment receipt of June 2013, under the name of NIK: 09004/Suryaningsih (SKU-H status) from MSJA Unit it is written Rp. 1.172.500,- and on the payment receipt of NIK : 13007 /Toni Yanto a worker of GALA Unit (SKU-H status) the wages are written Rp. 1.155.000,-. The UMK provisions are imposed to the workers with BHL and PKWT status, and the first year SKU-H.

Company maintains company rules in the form of: (1). Collective Labor Agreement (PKB) between PT. SIP of Tulang Bawang Regency, Lampung: BH.No: 182/PT.SIP/1989 and PUK.SPPP-SPSI Trade Union of Tulang Bawang with Registration No.: 063/KPTS/PC/SPPP.SPSI/TB/XII/2005, for 2011-2013 period, and (2). Company Regulation of PT. SMART Tbk, version 2013-2014.

Company provides facilities and infrastructures to support and ensuring decent life. The following is the List of Existing Welfare Facilities in PT. Sumber Indah Perkasa, SBYE Estate, GALA KKPA and MSJA KKPA per June 2013.

No. Type of Structures Unit Location Total

SBYE GALA MSJA

1. Staff Housing Unit 31 12 11 54

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2. Employee Housing Unit 437 14 20 471 3. Mosque Unit 4 1 1 6 4. Church Unit - - - - 5. Kindergarten Unit 1 - - 1 6. Primary School Unit 1 - - 1 7. Smart House Unit 1 - - 1 8. Clinic Unit 1 - 1 2 9. Employee Rest House Unit 2 - - 2 10. Day Care Unit 4 - - 4 11. Cooperative Unit 2 - - 2 12. Soccer Field Unit 3 - - 3 13. Badminton Court Unit 4 2 1 7 14. Volley Court Unit 4 - 1 5 15. Tennis Court Unit 1 - - 1 16. School Children Transport Unit 1 1 - 2

The provisions on the rights to have housing facilities are regulated in PKB. It is also regulated in a circular issued by each Unit Manager. For example, Circulars concerning SKU Workers’ Rights, issued by the Unit Manager of GALA No. Reff: 001/MSJA/01/201. It is stated that when an employee is promoted to be SKU employee either Daily SKU (SKU-H) or Monthly SKU (SKU- B) he will be given his rights. Points 4, 7, and 8 say that they will have a housing facility without furniture, but with free water and lighting. For staff employee, housing facility will be furnished with furniture as stipulated in Remuneration – Housing Facility document (no.doc: NOM F- 017/02-00 approved by MD Strategic officials, valid from 01/05/2006. This provision applies to employee of category H/G, F, D/E, to C/B. Company has entered into a contract with contractor that requires the contractors to comply with applicable regulations on employment. Evidence can be seen in the contract or SPK (Working Order) : 1). SPK No. KUD-KS/GALA/SPKL-L/January-12-/010-FFB Transportation & Loading between Gala Manager vs Nurohim (contractor), as follows : - Article 5 on Terms and Specification of Work, paragraph 4 the requirements to be furnished with Vehicle Holder Book, Vehicle Registration Card, Inspection Certificate, and First Aid Kit. - Article 4, the requirements to include in worker’s insurance and pay the premium by the 2nd party. - Article 5 paragraph 20, stressed that the contractor shall comply with the Department of Manpower and Transmigration’s laws and regulations. - Article 7, concerning Work Accident, where the second party (Nurohim) shall pay the wage of workers according to the UMK and include his workers in jamsostek program.

2). SPK No. 027/GALA/JKTO/04/2013 – Box Culvert dated 22/04/2013, between Director (The Biao Leng, and Pedy Harianto) and Arifin (PT. Citra Kurnia Waway), contractor, i.e.: - Article 8 concerning liabilities in the case of Work Accident, the second party (contractor) shall pay the worker compensation. - Article 4 concerning the mandatory Jamsostek registration

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However, both SPKs do not expressly specify about work accident prevention, i.e. the use of PPE. This is established as observation.

Compliance status: Full Compliance 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 Company already has a Trade Union. The policy concerning permission to establish a trade union is contained in the Circular Letter from the CEO-2 concerning Trade Union Freedom, No. 094/CEO2/SE/12/2010, dated 14/12/2010, that the freedom of association in a trade union is the worker or employee’s fundamental rights as regulated in Act No. 21/2000 on Trade Union or Labor Union.

The existing trade unions are only one and covering all Units both Estates and Mills. The union has been registered as in the Decree of Branch Board of Agricultural and Plantation Trade Union Federation of SPSI of Tulang Bawang Regency No. 026/Kpts/PC/SP.PP-SPSI/TB/VI/2007, dated 5/06/2007 concerning Endorsement of Work Unit Leaderships of SP.PP SPSI PT. SIP for 2007-2012 service period and has a Collective Labor Agreement (PKB) book with a registration number according to the Decree of the Head of Department of Manpower of Lampung Province No. KEP.188.4/4811/III.05/03/I/2011. The applicable PKB is that of 2011-2013 periods.

The Trade Union Leadership terms are now extended in accordance with SK No. 100/Kpts/PC/SP.PP-SPSI/TB/VI/2012 concerning Stipulation on Work Unit Executive Board of SP.PP-SPSI PT SIP, dated 11/06/2012, in the third dictum: “to give a full mandate to PLT PUK SPSI PT SIP to organize the work unit meeting (Musnik)in November 2013. The second dictum: to endorse executive boards of PUKSPSI PT SIP (there are 6 workers being endorsed).

Currently the total number of PT SIP Trade Union members, data of May 2013, is 1,102 people. This membership is automatic in nature, when one becomes a worker of minimum SKU-H status. Currently, the member card as proof of membership is not produced yet. The names of members are registered in the List of Trade Union Member of respective work unit.

Bipartite Cooperation Body (LKS) has also been established in each Unit and is already approved by local Department of Manpower. For example, the LKS of PT. SIP (MSJA), 2013- 2015 Period, No.: KEP 560/24/III.04/MSJ/LKS-BP/V/2013 dated 8/05/2013 by Head of Department of Manpower and Transmigration of Mesuji Regency. The membership is composed of 11 company representatives to 10 worker representatives.

Company provides facilities to smooth Trade Union activities, in the form: - A room for Trade Union office - Desks, chairs, stationery, - File cabinet - A meeting table and chairs - Water dispenser - Uniforms clothing for the trade union board members totaling 16 pieces. - A freedom to use office administration facility.

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- Fostering the treasury by KTU relating to bookkeeping

Records of meeting both internal and external, as sample some can be reported as follows: - Minutes of SPSI meeting with the Management of PT SIP Lampung dated 31/01/2013, with subject “Discussion on workers’ aspiration and request”, attended by 17 workers at TT by PUK SPSI-Sopuan, EM Gala, and HRD Jakarta. - Letter of Acknowledgement of PT. SIP Gala LKS Bipartite meeting, dated 23/02/2103, to discuss the payment of back pays based on Lampung Governor Decree. - Letter of Acknowledgement of PT. SIP MSJA LKS Bipartite meeting, dated 13/4/2013, to discuss the payment of back pay of harvesting personnel that should refer to Circular Letter of Dept. Agro. No. PSM II/SE/187/III/2013, effective date 1/01/2013. - Minutes of PT SIP Gala Bipartite meeting, dated 15/4/2013, discussion on harvesting personnel wages 2013 and fines of production foreman. Compliance status: Full Compliance 6.7 Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programs. Children are not exposed to hazardous working conditions Company is very stringent in selecting the candidate employee in order to prevent under age workers, the minimum should be 18 years old. This provision is regulated in: - PKB article 7 concerning new employee recruitment, paragraph 4, at the minimum 18 years old. - Government Regulation Chapter II Work Relations, Article 5, paragraph 2 that candidate worker should be the minimum 18 years old. - Circular Letter from HR Director to all Unit Head, No. 002/SE-HRDV/03/09, date 31/3/2009 with subject: Minimum Age Limitation, swehubu. Act No. 13, article 68, concerning child employment prohibition, so the minimum age of employee recruitment is 18 years old.

The evidence of implementation of this policy can be seen in the following data: - In the Summary Data of GALA SKU Employee, the youngest work entry age is 18.31 years old, under the name of Burhan Hidayat, born 4/2/1993, entry into work on 20/7/2011, - In the Summary Data of MSJA SKU Employee, the youngest work entry age is 20 years old, under the name of Eli Nurwanto, born 26/03/1986, entry into work on 01/10/2006. Compliance status: Full Compliance 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited Company gives equal opportunities to everyone to work in Company. The documents: (1). HR Policy No. A-001-00, effective 1/9/2005, issued by Managing Director Strategic, point 2, states that in principles Organization employs competent individuals in accordance with position requirements without discrimination by ethnic, race, and religion”. (2). Employment Recruitment Policy: Provision on Recruitment and Selection Outside Jakarta (no. SDM A-006-00, dated 1/9/2005), regulates that recruitment of manpower does not define particular ethnic, sex, as well as religion as requirements. It is also mention minimum age of 18 years old.” As evidence, worker composition in each Unit can be seen in the data as per May 2013, from data sampling as follows:

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Data of GALA Estate BHL: - Sex: Male 364, Female 2. - Religion: Islam 365, Christian 1 - Ethnic: Javanese 360, Ogan 1, Lampung 4, and Sundanese 1. Data of MSJA Estate SKU: - Sex: Male 51, Female 2 - Religion: Islam 50, Christian 2, and Hindu 1. - Ethnic: Javanese 49, Palembang 2, Bali 1, and Sundanese 1. As evidence, worker composition in each Unit can be seen in the data as per May 2013, from data sampling as follows: - Data of BHL, GABA Estate - Sex: Male 269, Female 114. - Religion: Islam 378, Hindu 4, Christian 1 - Ethnic: Javanese 375, Palembang 1, Balinese 4, and Sundanese 1. - Data of BHB, GABA Estate: - Sex: Male 16, Female 276 - Religion: Islam 291, and Hindu 1 17. Ethnic: Javanese 286, Palembang 2, Lampung 1, Balinese 1, and Sundanese 2. The plantation and mill is located in the transmigration area where the majority of transmigrant is Javanese and Moslem. Job vacation format also does not mention sex, ethnic, or religion for job in general—that can be worked on by men or women. For example, in GALA Unit, Job Vacation for Office Administration (Agronomical Clerk), dated 26/8/2012, the listed requirements: male/female, and over 18 years old. Compliance status: Full Compliance

6.9 A policy to prevent sexual harassment and other forms of violence against women and to protect the reproductive rights is developed and applied Company has established a policy related to prevention of sexual harassment in a circular letter Socialization on Harassment Sexual Issues, No. 003/CEO2-SE/01/2011, dated 10/01/2011. There should be socialization to all employees concerning prevention and handling of sexual harassment issues, so as to increase legal awareness and respect norms and ethics in the plantation work units of Sinar Mas II. Samples of evidence of the implementation of prevention of sexual harassment activities of socialization in GALA and MSJA Units are as follows: - GALA Unit, there is the Letter of Acknowledgement of Socialization on Sexual Harassment carried out on 15/06/2013, to 25 K3T representatives, and on 13/7/2013, to 29 staff’s wife’s and male workers. - MSJA Unit, there is the Letter of Acknowledgement of Socialization on How to Deal With Sucofindo ICS FRM 14.05 49 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Sexual Harassment held on 14/03/2013, there are 13 participants for the staff’s wife’s and male workers.

Nevertheless, in GALA Unit, this socialization has been made only to 23 representative of K3T personnel and 29 staff’s wives and male workers. There is no evidence that it is made to 366 PKWT workers and 486 BHL personnel. In MSJA Unit, there is no evidence that socialization has been made to BHL/BHB workers, only to 13 staff’s wives and male workers. This is established as minor nonconformity.

Company policy on protection of reproductive rights and documented has been included in: - Government Regulation chapter IV, article 23 concerning Annual Leave, Article24 Long Rest Period, Article 25 Maternity or Miscarriage. - Memorandum No. 001/Memo/VPA PSM2/04/2011 dated 8/4/2011, concerning prohibition of pregnant and breast feeding workers to work as sprayers. - Circular Letter No. 095/CEO2-SE/12/2010, dated 14/12/2010, concerning Menstrual Period Permit Granting, where working is not permitted in the first and second day.

Record evidence of the policy implementation of reproductive rights protection is: - Sick Leave Certificate under the name of Wiji Astuti, 31 years old, (GALA Unit), No. 0012/PKM-GRS/EX/SKS/VI/2013, H2 (pregnant) leave and there is filled in Employee Leave Application Form from 4/7/2013 to 1/10/2013 (90 days), signed by Manager. Company has had a policy relating to employee grievances, i.e.: (1). PKB Article 26 Grievance Settlement, and (2). SOP on Grievance and Dissatisfaction Handling (No. SOP/NP/SMART/XII/MCAR/001, issued date 1/7/2010).

Records of worker complaints and grievance are kept and followed up. Each Unit maintains a log book to record worker’s grievance. For example, in GALA as well as MSJA Unit there is a Grievance Log Book that specifies information : Date, Place, Name, Contact details, Issue (s), Registration, Response (Date, Action, Current status, PIC), and Target Finish. If a worker wants to convey his grievance, he should write a letter, may or may not be official, addressed to the management. Furthermore, the management will read, record, and follow up. From sampling of some of recorded grievances, the management has sought to follow up. Grievance status will be written “Close” when finished. Compliance status: Minor no. 1 Non-conformity Growers and mills deal fairly and transparently with smallholders and other 6.10 local businesses. For Mesuji, there has been a letter of FFB price stipulation from local Plantation Department of Lampung Province on 7 May 2013 stating that on average the FFB price is Rp. 1,136.27/Kg and the price company sets to the KUD Krida Sejahtera is Rp. 1,243.00 based on the planting year >10 year and higher. For July, Lampung Province sets Rp. 1,320.61/kg as the price for the crops of 10-20 years old. There is SOP for FFB Grading Guidelines and FFB Grading WI No PT SIP-SBYM/IK/04-1. It contains sorting criteria and penalty provisions for FFB out-of-specification. Company has established the grading system and penalty provisions and has conformed to the provisions stipulated by the Government. Based on the grading system, unripe and less ripe fruits and over ripe fruits will be subject to penalty 50%, empty fruit bunches 100%. The grading outcome and the percent of fruit subjected to penalty are sent to the KUD in the form of hardcopy and softcopy so that the KUD’s data is updated daily. Sucofindo ICS FRM 14.05 50 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Sampling of sorting outcome per January 2013 results in 9,446,020 Kg FFB and 13,202 kg penalty from over ripe fruits (50% penalty) and empty fruit bunches (100% penalty). The grading determination has conformed to the provisions of the regulation of the Minister of Agriculture No. 395/Kpts/OT.140/11/2005 The setting up of FFB purchasing price follows the prevailing provisions, and the summary of FFB price stipulation from authorized agency is available. Payment has been settled in a timely manner both to cooperatives and contractors. Company should ensure the cooperative’s efforts to communicate pricing methods and price cutting related to costs imposed to plasma members for maintenance and transportation. This is to ensure that all parties understand the contract agreement they entered into, and that the contracts are fair, legal and transparent. Compliance status: Observation no. 11 6.11 Growers and millers contribute to local sustainable development wherever appropriate Company has in place a policy in the form of company memorandum to perform CSR program throughout the company group in order to comply with Act of RI No. 40/2007. CSR plan in 2013 covers the aspects of education (scholarships), health (hospital rehabilitation, posyandu activities, fogging, mass medication), economic empowerment (FFB transportation by local contractors, purchasing local materials), infrastructure (road improvement, surfacing) and social assistance for religious purpose and celebration of day of an important event. Company has a program of prioritizing local contractors to have jobs. Jobs given include printing materials for administration purposes and rice procurement by KUD, FFB transportation, harvesting ladder construction. Samples taken are SPK 001-GABA/SPK-L/I/2013- FFB Transport. The SPK has a validity period and terms of payment which is twice a month under the name of Bp. Suradi, May 2013 period. Compliance status: Full Compliance 7 RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS

7.1 A comprehensive and participatory independent social and environmental impact assessment is undertaken prior to establing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management, and operations Not Applicable 8 COMMITMENT TO CONTINUOUS IMPROVEMENT IN KEY AREAS OF ACTIVITY

8.1 Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations Company has conducted evaluation regularly to ensure ‘continuous improvement’ through the mechanism of regular management meeting and internal audit activities. SOP no. SOP/SPO/SMART/LH-16 lists audit internal which is conducted at least once a year. In addition, the management conducts routine meetings both regionally and corporately. Company has conducted internal audit with different objects, such as called Mill Audit Advisory which is performed twice a year. For ISPO/RSPO, Internal Audit is scheduled at least once a

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year. ISPO/RSPO internal audit was carried out by personnel who have had Internal Auditor training, i.e. Maman Surahman, Baby F Nurainy and Hendra Setiawan on 19-26 March 2013. There were 13 findings and all have been closed. Company has developed CSR program for respective units and for the communities in the neighborhood of plasma and main estates. Some of the short-term programs have been implemented for the period of 2013. Company should develop a specific method to evaluate the effectiveness of CSR programs done as input to future program improvement. Compliance status: Observation No. 10

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

Name Ismu Zulfikar

Position Head of Environment and CSR Coordination

Signature

Date

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

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

Verified and Reviewed by:

Name Nuzwardy Sjahwil

Position SLA / LA / Auditor

Signature

Date December, 16th 2013

Approval:

Name Triyan Aidilfitri

Position HSE Audit and Certification Department Head

Signature

Date December, 16th 2013

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List of Abbreviation

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

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

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ATTACHMENT-1 MAP

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1.1. Overlay Map of Sungai 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 Gedung Aji Lama Estate

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ATTACGMENT - 2

NCR

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Non Conformity / Observation Report Organization Audit 14-06-2013 (TSS, RQ, No. No. Standard. Audit Date : WS, AMR, ) RSPO 00003 1 (1) RSPO (Preliminary) ATL / Auditor :

Organization Rep. :

Audit No Root Cause Corrective Action & Team . Category Clause Std Auditor Description Investigation* Evidence* Review (1) (2) (3) (4) (5) (6) (7) (8) (9) 1 Major 2.1 1 TSS The company has a 1. Letter of the Corrective Action 1: Closed letter of permit of the Regional Forestry Document the letter of release of forested Office of Lampung the Regional Forestry areas and or a letter of Province No. Office of Lampung designation with the 1052/KANWIL- Province No. APL status for the 6/TGH-134/90 is 1052/KANWIL-6/TGH- plantation area of PT undocumented in 134/90 at the estate Sumber Indah Perkasa. the estate office so office.Evidence 1:Letter The company does not that at the time of of the Regional Forestry have permits/IUP for Mill pre audit it could Office of Lampung with a capacity of 120 not be shown to Province No. tons of TBS/hour. So far the auditor 1052/KANWIL-6/TGH- the company only has a 2. The IUP does not 134/90 has been letter of specify a mill with a available.Corrective recommendation from capacity of 120 Action 2:Confirmation to the Provincial Service tons/hour, but with the relevant agencies for the management of respect to relating to IUP.Evidence mills with a capacity of production 2:The company has had 120 tons TBS/hour. capacity, there has SPUP that is valid as been an approval IUP, while for production from the State capacity there has been Minister of an approval from the Sucofindo ICS FRM 14.05 68 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Investment / Head State Minister of of BKPM. Investment / Head of BKPM No 46/II/PMDN/1998 dated 01 July 1998 concerning Letter of approval for expanding domestic capital investment stating that the production capacity becomes 120 Tons of FFB per hour. This was confirmed by the letter of the Head of Capital Investment Coordinating Board and Integrated Permit Service of Lampung Province No 800/200/BID. V/II.06/2013 dated 01 July 2013 that the Business Permit of PT SIP issued by BKPM / Agency for capital investment is equal to the estate business license (IUP) issued by sectoral technical agency due to the authority granted by the Minister of Agriculture. 2 Major 4.6 ; 1 RQ At GABA, waste water Waste water come Corrective Action : Closed 5.3 comes from bathing from bathing activity of To repair the bathroom's activity of sprayer sprayer personnel at sewer so that used personnel flows into the SBYE does not water from the sprayer the septic tanks, but at enter into the septic bathing activities will not Sucofindo ICS FRM 14.05 69 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

SBYE it flows to public tanks or a catchment go to public ditches. ditches. This is and still flows into potentially to public ditches. contaminate water that Evidence: will poison flora, fauna, Used water from the and human. sprayer personnel bathing activities has been directed to the septic tanks (Photo documentation is available). 3 Major 5.6 1 RQ Vibration and odor Corrective Closed The measurement tests have been carried Action:Perform vibration results for vibration, out but the results are and odor tests in odor, and noise are not not obtained yet. collaboration with an obtained because there accredited is a problem with the laboratory.Evidence:The environmental testing results of vibration and laboratory's equipment. odor tests have been available. 4 Major 5.4 1 RQ The company does not Document of land use Corrective Action: Closed have a record of land trajectory cannot be Document of land use use trajectory from shown because the plan prior to the secondary forest into prior status of land is plantation opening will palm land. APL be searched for. The company does not have a record of land Evidence: use a minimum 2 years The document is before the land is available in the form of cleared for plantation land satellite image business. 1988 – 1989. The company does not have a record of land use trajectory from secondary forest into Sucofindo ICS FRM 14.05 70 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

palm land. The company does not have a record of land use a minimum 2 years before the land is cleared for plantation business. 5 Major 4.1 1 WS The SOP on Seed SOP does not include Corrective Action: Closed Nursery sentences requiring the Develop a mechanism (SOP/SMART/MCAR/II use of certified seeds. that requires the use of I/TA-BBT, rev.00, certified seeds. 1/9/2012) and IK/SMART/MCAR/III/T Evidence: A-BBT/06 on Seedling The mechanism to use Acceptance and certified seeds has been Planting does not yet available in the form of explicitly regulate the SE from VPA PSM2. "obligation to use a certified seed". 6 Major 4.1 1 WS There is no SOP/Work SOP of planting on Corrective Action: Closed Instruction that peat land is unable to Develop a SOP that explicitly and in details be shown because the regulates planting in regulates planting on company has peat land replanting peat land committed not to make area. a new planting in peat land area. Evidence: There has been a SOP regulating on planting in peat land replanting area. 7 Major 4.7 1 WS The company, for Fire warden training is Corrective Action : Closed SBYM and SMRM not already conducted Deliver fire mitigation Mills, currently does at SBYM and SMRM training to fire warden in not have fire mitigation units. collaboration with officers as regulated in relevant Sucofindo ICS FRM 14.05 71 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

Kepmenaker No. agencies.Evidence :Fire 186/MEN/1999. warden training has been conducted by Local Manpower and Transmigration Service & Disaster Mitigation Body of Tulang Bawang Regency on 5 July 2013 8 Major 4.7 1 WS There are some At the implementation Corrective Action: Closed officers of fire fighter of fire mitigation Conduct training in squad in the training, some of the using Apar for fire Emergency Response emergency response fighter squad that has Team Structure without team's members were registered in the evidenced of fire not present so that not structure of emergency mitigation training. all the people have fire response team. They are: SBYE, 1 mitigation training. people, SMRM 5 out of Evidence: 7 people, and SMRE 5 Officers of fire fighter out of 8 people. squad registered in the emergency response team have received fire mitigation training. 9 Major 4.7 1 WS Simulation on dealing Fire simulation has not Corrective Action: Closed with fire emergency conducted in each Conduct fire emergency situation has not been work unit of estate and response simulation. carried out in SBYE mill, because to date and GABA units. fire simulation is Evidence: carried out jointly Documentation of the (Estate and Mill) at simulation SBYE. implementation has been available. 10 Major 4.7 1 WS Data of worker health Periodic health Corrective Action: Closed showed that there is no examination has been Conduct Cholinesterase examination of conducted routinely, examination for cholinesterase aspect but the examination of chemical warehouse Sucofindo ICS FRM 14.05 72 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

on workers touching Cholinesterase has not officers and sprayer B3, such as: sprayers been conducted yet on personnel. and chemical the sprayer personnel warehouse officers. and chemical Evidence: warehouse officers. Chemical warehouse officers and sprayer personnel have their cholinesterase examined (The test results from Prodia Laboratory have been available). 11 Major 4.7 1 WS During a visit to Mill Noise test value at St. Corrective Action: Risk Closed area, some workers Sterilizer and Nut analysis has been were found not using Kernel is 84 - 85 dBA. reviewed based on PPE, sampling: (1) at . suggestion from the SMRM, in the area of Auditor by providing ear St. Sterilizer, and Nut- plug/muff in ST Kernel, not using Sterilizer and Nut earplug/muff. (2). No Kernel.Evidence apron was available for :Minutes of ear plug / workers in boiler area. ear muff supply / acceptance have been available. 12 Minor 6.9.1 1 WS There is no evidence Sexual harassment Corrective Action: Not that sexual harassment socialization in MSJA Document the evidence Closed socialization has been has been conducted to of sexual harassment (This conducted in MSJA the staff's wives and socialization. NCR unit. In addition from some female workers will be the evidence of but the documentation Evidence: seen in socialization records is kept in the MSJA Evidence of sexual certifica available is still SPO secretariat so that harassment tion extremely small in it was unable to be socialization is available audit) number. shown during and documented. document checking by Sucofindo ICS FRM 14.05 73 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

auditor in the Lampung Regional office. 13 Observati 6.1 1 TSS It would be better that The short-term CSR Corrective Action: Closed on CSR plans developed plan has been Finalize 5 year CSR are capable of ensuring available in the form of strategic plans. welfare/skill Annual CSR Program. improvement. The The Five Year CSR Evidence: method of need Strategic Plan of 2014 The draft CSR strategic identification is – 2018 periods along plan of 2014 – 2018 employed as a basis to with the performance period along with determine priorities of indicator for evaluating performance indicator the CSR program in CSR activities are for evaluating CSR villages outside the under preparation activities has been company area. process. available. It is suggested the company establishes a short- and long-term plan and a method of evaluation to ensure that the CSR program is effective and successful as an indicator of improvement.

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Non Conformity / Observation Report Organization 19-07-2013 (TSS, RQ, GGU, YSF, Audit No. Standard. Audit Date : WS, ) RSPO 00003 No. 02 (1) RSPO (Certification) ATL / Auditor : RSPO 0004 Organization Rep. :

Audit Root Cause Corrective Action & Team No. Category Clause Std Auditor Description Investigation* Evidence* Review (1) (2) (3) (4) (5) (6) (7) (8) (9) 1 Minor 6.9 1 WS The implementation of Sexual harassment To completed the Closed sexual harassment socialization has been documentation of sexual socialization to employees is conducted to the workers, harassment socialization. limited compared to the but the documentation Evidence : number of workers. Data was cannot be showed at Documentation of sexual showed : the time of audit. harassment socialization is -In GALA Unit, the number available at SPO of workers has been secretariat. socialized to 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 The company still apply The management has Closed herbicide registered in restricted pesticide i.e. issued memo to reduce Pesticide Commission of the paraquat. the paraquat No. Republic of Indonesia but 002/MEMO-VPA the use of restricted PSM2/04/2011. The pesticide should be reduced restricted pesticide will be gradually and substituted by monitored yearly to see a more environmentally the trend of paraquat friendly herbicide and safer reduced. to field operators. Evidence : Graphic of restricted 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 Head of P2K3 Closed Extinguisher in diesel fuel the fire extinguisher retraining the personal warehouse and KKPA GALA inaccurately. who responsible to check warehouse should be the fire extinguisher. To inspected more carefully to ensure the monitore result ensure the content and of fire extinguisher meet pressure of the extinguisher with the actual condition. so that they can be used Evidence : 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 To conduct identification Closed workers health examination exposure to chemical the workers with risks of covering cholinesterase and material hazard were not chemical exposure and audiometry but for those checked for spirometry. gradually will conduct working with risks of spirometry checking. chemical exposure should Evidence : be added with spirometry 1. List of worker who examination to ensure their needs to be checked lung health. for spirometry. 2. Medical check program for spirometry.

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5 Obs 2.3 1 TSS/GG Organization has made a The company has the Map will be adjusted to be Closed U map but the map should different scale for all scale 1 : 100.000 have a sufficient scale, at maps. Evidence : least 1 : 100.000 in Map with the scale accordance with Decree of 1:100.000 the Ministry of Forestry No. 48/menhut-II/2004. 6 Obs 5.2 1 TSS/GG Organization had SOP on KKPA GALA Estate has HCV monitoring and patrol Closed U HCV Management, it no data for monitoring will be conducted every 2 specifies that monitoring or HCV for July 2013. weeks. patrol is carried out every Evidence : two weeks but in GALA the HCV Monitoring and patrol last monitoring is on 24 June is available. 2013. 7 Obs 5.2 1 TSS/GG Organization has performed There is no column for Completed the form with Closed U monitoring and contained in PIC and Action Plan at edit PIC and Action Plan. HCV Monitoring Report, but Form HCV Monitoring. Column. it should establish Person in Evidence : Charge (PIC) and due date Revision of Form HCV of the recommendation Monitoring. specified 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 fighter to meet with the of the Ministry of Manpower but the number of the fire Kepmenaker No. 186 No. 186/1999 related to the fighter was not meet with Tahun 1999. number of fire mitigation the government Evidence : personnel in mill area. But it regulation (Kepmenaker Documentation of fire only trained 20 personnel for No. 186 Tahun 1999). fighter 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 During tender process, In every MoU, the safety Closed found not expresivvely the requirement of safety standard should be stated specifying the provisions of aspect has been informed mandatory. PPE mandatory use. They to the contractor, but Evidence : are SPK No. when the MoU issued The revision of MoU. 027/GALA/JKTO/04/2013 – there is no safety Box Culvert, and SPK No. 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 been setup for each unit, identification the existing the effectiveness of CSR but not yet covered the indigenous people. If there program done as input to culture program. For the is then the company will future program strategic planning year setup the CSR to develop improvement. 2014-2018 has and maintain the culture of addressed the vision and indigenous people. mission to develop and Evidence : maintain the culture of Revise CSR Program. local people. 11 Obs 6.10 1 TSS Company should ensure The company has The company will conduct Closed cooperative’s efforts to conducted the monthly meeting and to socialize aspects that socialization to the socialized the factor in become a factor in price cooperation staff and price cutting related to cutting related to costs coordinator staff, costs imposed to plasma imposed to plasma members regarding the factor in members for maintenance for maintenance and price cutting related to and transportation costs. transportation costs. Proof costs imposed to plasma Evidence : that all parties understand members for The documentation of the contract agreement they maintenance and meeting schedule between entered to, and that the transportation costs. But company and cooperation contracts are fair, legal and the socialization was not is available. transparent. sufficient some of the members were found well not understand for the subject.

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APPENDIX

PT. SUMBER INDAH PERKASA – SUNGAI BUAYA MILL RSPO SUPPLY CHAIN CHECKLIST – MASS BALANCE MODUL

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

A. Documented Procedures 1.1 Complete and up to date procedures covering the implementation of all the elements in these requirements.

Records/Evidence: There is procedure SOP Identifikasi dan kemampuan-telusuran (SOP Identification and Traceability) PT SIP SBYM/SOP/01, issued : 02/01/2012 The name of the person having overall responsibility for and authority over the implementation of these requirements and compliance with ‐all applicable requirements. This person shall be able to demonstrate awareness of the facilities procedures for the implementation of this standard.

Records/Evidence: Management Representative related to RSPO-SCCS implementation Traceability Officer related to RSPO SCCS implementation SBYM: Decree No. 006/PC SBYM/III/2013 ‐ Document Controller – SPO‐ Officer related to RSPO SCCS implementation SBYM: Decree No. 003/FM SBYM/III/2013 1.2 The facility shall have documented procedures for receiving and‐ processing certified and non- certified FFBs. ‐

Records/Evidence:  SOP Identifikasi dan kemampuan-telusuran (SOP Identification and Traceability) PT SIP SBYM/SOP/01, issued : 02/01/2012  Surat Pengantar Buah (Fruit Delivery Letter) (SBYE, GALA & MSJA) with ‘’Mass Balance’’ mark‐ SBYM: Form Rekap Penerimaan TBS Per Unit (FFB Receiving Resume Form each Unit)  CPO Production Report SBYM = 66,926.180 Ton/Year (with average OER : 22.08) Recapitulation data of FFB certified received/process & CPO production from January to December 2012  PK Production Report SBYM = 16,420.640 Ton/Year (with average KER : 5.42) Recapitulation data of FFB certified received/process & PK production from January to December 2012  CPO Dispatch Report SBYM= 65,285.310 Ton/Year  PK Dispatch Report

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SBYM= 16,056.510 Ton/Year B. Purchasing and goods in 2.1 The facility shall verify and the document the volumes of certified and non-certified FFBs received.

Records/Evidence:  There is procedure SOP Identifikasi dan kemampuan-telusuran (SOP Identification and Traceability) PT SIP SBYM/SOP/01, issued : 02/01/2012  There is a database system called Weightbridge Computerized Program which has been designed to separate certified and non‐-certified incoming FFB from own estate, Scheme small holders and independent small holders with the specific code in database. 2.2 The facility shall inform the CB immediately if there is a projected overproduction. Records/Evidence:  SOP Identifikasi dan kemampuan-telusuran (SOP Identification and Traceability) PT SIP SBYM/SOP/01, issued : 02/01/2012 has been stated if there is a projected over production then the acion will be taken as belows:  Inform related RSPO certification‐ body and RSPO IT System.  Re-analyze production data and mass balance report.  Calibrated and recheck for the bridge and supporting equipments.  To define the projection of certified product considering the error rate (contamination) for maximum 5% from the total projection data.

C. Record keeping 3.1 The facility shall maintain accurate, complete, up-to-date and accessible records and reports covering all aspects of these requirements.

Records/Evidence:  Surat Pengantar Buah (Fruit Delivery Letter) (SBYE) with “Mass Balance” mark Form rekap Penerimaan TBS per Unit (FFB Receiving Resume from each Unit)  CPO Production Report (daily, three-monthly, and annual)

All documents and records have been in controlled according to SOP Pengendalian Dokumen dan Rekaman (SOP Document Control and Record Control) SOP Pengendalian Dokumen (SOP Document Control) PT. SIP-SBYM/SOP/18 Rev.00, dated 02/01/2012 SOP Pengendalian Catatan, dated 02/01/2012 PT. SIP-SBYM/SOP/12 Rev.00, dated 02/01/2012 3.2 Retention times for all records and reports shall be at least five (5) years.

Records/Evidence: Retention times of all records have been determined in SOP Pengendalian Dokumen dan Rekaman (SOP Document Control and Record Control) Retention time for all records and reports of PT. Sumber Indah Perkasa is 10 years. 3.3 The facility shall record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO, PKO and palm kernel meal on a three-monthly basis.

Records/Evidence: The company has the monthly, three-monthly, and annual report which contain record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO and PK. (SBYM Mass Balance Monthly Report, SBYM Mass Balance Three-Monthly Report, and SBYM Mass Balance Annual Report) All volumes of palm oil and palm kernel oil that are delivered are deducted from the material Sucofindo ICS FRM 14.05 80 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

accounting system according to conversion ratios stated by RSPO.

Records/Evidence: There is a database system called Weightbridge Computerized Program which has been designed to align and integrate from the material accounting system according to conversion ratios stated by RSPO. The supporting data such as:  Massa Balance Report ; Daily, Monthly, Three-Monthly, and Annually CPO Production Report  Surat Pengiriman CPO dengan Cap ‘’ Massa Balance’’ (CPO Dispatch Letter with “Mass Balance” Mark)  Tiket Timbang Pengiriman CPO dengan Cap ‘’Mass Balance’’ (CPO Dispatch Weight Ticket with “Mass Balance” Mark) The facility can only deliver Mass Balance sales from a positive stock. However, a facility is allowed to sell short.

Records/Evidence: Can be trace down in CPO Stock Report and in CPO Dispatch Report 3.4 The following trade names should be used and specified in relevant documents, e.g. purchase.

Records/Evidence: Can be trace down in Sales Contract D. Sales and good out 4.1 The facility shall ensure that all sales invoice issued for RSPO certified products delivered include the following information: a) The name and address of the buyer; b) The date on which the invoice was issued; c) A description of the product, including the applicable supply chain model (Segregated); d) The quantity of the products delivered; e) Reference to related transport documentation.

Records/Evidence: The available evidence is the invoice of oil delivery in form of Delivery Order (DO) document issued for every oil delivery. The information written on the Delivery Order document are: delivery no, delivery date, reference no, reference date, name and address of buyer, ordered product details, and the transportation system for product transportation.

The customer of SBYM for CPO and PK products are PT. SIP Bulking Tarahan. The transporter of SBYM are: - PT. Satrindo Jaya Agropalma (for PK and CPO) - PT. Abadi Wijaya Utama (for CPO) - PT. Lima Adil Makmur (for CPO) E. Training 5.1 The facility shall provide the training for all staff as required to implement the requirements of the Supply Chain Certification Systems. Records/Evidence: The facility shall provide the training for all staff as required to implement the requirements of the Supply Chain Certification Systems. Records/Evidence:  SOP Training dan Kompetensi Sumber Daya Manusia (SOP Training and Human Resources Competency) Document No.: PT SIP SBYM/SOP/19, issued 02/01/2012  RSPO – SCCS Training material is available in Identification Matrix‐ Needs  Invitation, Attendance List, Socialization Training Material RSPO–SCCS,dated 08 May 2013 Sucofindo ICS FRM 14.05 81 of 82 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

F. Claims 6.1 The facility shall only make claims regarding the use of or support of RSPO certified palm oil that are in compliance with the RSPO Rules for Communication and Claims.

Records/Evidence: SBYM have 7 Declaration of RSPO SCCS 1. Deklarasi RSPO SCCS (RSPO SCCS Declaration) 2. Deklarasi Prosedur RSPO SCCS Mass Balance (RSPO-SCCS Mass Balance Procedure) ‐ 3. Deklarasi Penilaian RSPO ‐(RSPO Valuation Declaration) 4. Deklarasi Penjualan dan Pengeluaran Produk (Sale and Product Output Declaration) 5. Deklarasi Penyimpanan dan dokumentasi rekaman (Retention and Record Documentation Declaration) 6. Deklarasi Nama Produk (Product Name Declaration) 7. Deklarasi Klaim/Pernyataan (Claim Declaration)

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