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RSPO PRINCIPLES & CRITERIA PUBLIC SUMMARY REPORT

Compañía Industrial Aceitera Coto Cincuenta y Cuatro S.A – Coto 54 Mill

South Pacific Region of .

Certificate number: CA5961/15 Lead Auditor: David Ogg FICFor.

Certification decision date: 29/06/2015 Certification expiry date: 28/06/2020

Main Audit report. 19/03/2015 Certification Audit report. 22/06/2015

IBD CERTIFICAÇÕES LTDA Rua Amando de Barros, 2275 CEP: 18.602-150 Botucatu – SP – Brasil Tel / fax: +55 14 3811-9800 www.ibd.com.br – [email protected]

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Contents

1. Scope of the Certification Audit 1.1 Normative references 1.2 Company and Contact Details 1.3 RSPO Membership Details 1.4 Audit type 1.5 Location of the Palm Oil Mill 1.6 Palm Oil Mill Output and Approximate Tonnages Certified 1.7 General Description of Supply Base 1.7.1 Location of the Supply Base 1.7.2 Statistics of the Supply Base and Estimated Tonnes of FFB/year 1.7.3 Biodiversity (Conservation & HCV Area for the respective Supply Bases) 1.7.4 Calculation of the Number of Production Units (N) to Sample for the Mill 1.7.5 Calculation of the number of subcontractors to be sampled 1.8 Progress of associated Smallholders or Out-growers towards compliance 1.9 Location Map for this Certification Unit

2. Partial Certification 2.1 Management Organization 2.2 Time-bound plan 2.3 Progress made on the time-bound plan 2.4 Non-conformities

3. Audit Process 3.1 IBD - The Certification Body 3.2 Audit Team 3.3 Audit Methodology 3.3.1 Audit Agenda 3.3.2 List of stakeholders consulted prior to and during the audit. 3.3.3 Outline of how stakeholder consultation was managed. 3.3.4 Issues that arose during stakeholder consultation and company responses.

4. Audit Findings 4.1 Summary of findings 4.2 Non conformity register 4.2.1 Verification of previous assessment non-compliances 4.2.2 New non-compliances raised at this audit 4.2.3 Observations 4.3 Lead Auditor Recommendations for the RSPO Principles & Criteria certification. 4.4 Comments for next audit.

5. Formal signing of audit findings 5.1 Acknowledgment of internal responsibility by the Client 5.2 Signing by the Lead Auditor.

6. Major non-compliances follow-up actions

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1. SCOPE OF THE CERTIFICATION AUDIT 1.1 Normative references The Palm Oil Mill and the supply base was audited against the following documents: RSPO International Principles and Criteria (April, 2013 version) National Interpretation (approved version XX/20XX) Local indicators (approved version 08/2011, updated by IBD) Module D and E of RSPO Supply Chain Certification Standard. New Planting Procedures (September, 2009 version) 1.2 Company and Contact Details Company name Compañía Industrial Aceitera Coto Cincuenta y Cuatro S.A. Finca Coto 54, Guaycara de , Provincia de Business address Costa Rica. The production and sale of RSPO Certified Sustainable Crude Palm Oil and Palm Scope Kernels through the Identity Preserved RSPO supply Chain Model. Products Crude Palm Oil and Palm Kernels. Contact person Alfredo Villavicencio Telephone +506 2284 1320 E-mail [email protected] Web site www.gruponumar.net Other certifications held Global Gap. 1.3 RSPO Membership Details 1-0112-12-000-00. RSPO membership number 12th January 2012. Palma Tica S.A. and Compañia Industrial Aceitera Coto Cincuenta y Cuatro S.A. Parent company as are both companies owned by Numar Group, RSPO membership number 2- applicable 0403-13-000-00. 1.4 Audit type Date of previous audit Date of this audit 16th March to 19th March 2015. Main or ASA (1 to 4) Main Date of next surveillance Within 12 months of date of RSPO P&C certification. audit 1.5 Location of the Palm Oil Mill Palm Oil Mill (POM) Mill Capacity GPS Reference Location Address Name MT/Hour Longitude Latitude Compañía Industrial Finca Coto 54, Guaycara de Golfito, 90mt FFB -83.002992 8.629799 Aceitera Coto Cincuenta y Provincia de Puntarenas, Costa Rica. Cuatro S.A. – Coto 54 Mill 1.6 Palm Oil Mill Output and Approximate Tonnages Certified The 12 month output is the average over any 12 month period and the actual production for the 12 months from the date of certification will be included in the annual summary. These figures exclude any output product from non-certified suppliers. For the 12 month period ending December 2014 the mill received 421.375 mt of FFB.  The estimate for the last 12 months is applicable to Annual Surveillance Audits and is the Projection for the next 12 months from the previous audit.  The actual production for the last 12 months is the audited quantity since the last audit.  The projection for the next 12 months is given by the company. FFB received and processed by the mill for the 12 months prior to this audit: Mt RSPO Certified FFB: Mt Conventional FFB: 421.375 Estimate for last 12 Months (MT) Actual Production for last 12 months Projection for next 12 Months (MT) [State of IP or MB] (ASA audits). (MT) Identity Preserved Non-certified. Prior to main audit. CPO PK PKO CPO PK PKO CPO/IP PK/IP PKO/IP 88.479 22.119 n/a 94.810 21.124 n/a Notes: Whilst the POM produced PKO, it is not possible for them to sell PKO under the new RSPO rules for the supply chain certification. The kernels are “transferred” to the internal kernel crushing plant and that plant is audited against the RSPO SCC and the PKO figures are applicable to that audit only.

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1.7 General Description of Supply Base History of the company. Palma Tica S.A is the principal palm oil producer in Costa Rica and considered being the original motor of palm oil cultivation in Central America. Palma Tica is operating in the Central Pacific ( and ) and South Pacific (Coto, Golfito, ) region. The company has always been known for its innovative character and benefits from that until today as not only modern techniques and best practices are used but also production rates are recognized all over the world. The company´s name exists since 1990 when the “Compañía Bananera de Costa Rica” (CBCR, subsidiary of the United Fruit Company in Costa Rica) decided to change names due to the total abandon of banana cultivation in the country in 1984. The first oil palms however were planted already in 1944 in Quepos division. In the beginning oil palms were cultivated for investigative purposes but when experiments and results turned out to be promising, palm oil cultivation took off and went hand in hand with the continuous abandon of banana cultivation.

In 1996 Palma Tica, owned by Chiquita Brands Int., decided to sell its oil palm branch to the present owners of the company. Despite Palma Tica’s independence from banana business nowadays, it is sometimes still associated with the famous United Fruit Company and its paternalism. Therefore, the company has been working with a strong focus on sustainability and its certification in order to strengthen and reinforce positive impacts that the company stands for, now and in the past.

A large supply base of 796 associated smallholders also provides the FFB to the mill. Although the company helps them with technical and management support, and they are considered as associated, these growers have autonomy to plant whatever crops they desire within their lands, however, concerning oil palm, they need to commit themselves with Palma Tica’s and RSPO’s requirements. The growers have a written contract to supply FFB, however the main intention is to include the requisites of RSPO, so Coto 54’s supply base, especially the associated growers, would comply with RSPO requirements as well.

Details of the unit of certification. RSPO membership is under Compañía Industrial Aceitera Coto Cincuenta y Cuatro S.A., which is also the company name under which all 3 mills operate.

 Palma Tica S.A. An agricultural company responsible for the growing of all Oil Palm and for the Associated Growers. There are 2 divisions for the management of Oil Palm.  Coto Division. (South Pacific Region).  Quepos Division. (Central Pacific Region).  An RSPO P&C audit was conducted for the Quepos Divison over the w/c 9th March, just prior to this audit.

 Compañia Industrial Aceitera Coto Cincuenta y Cuatro S.A. There are 3 mills (all of them going through certification):  CIA Coto 54 S.A. Main Mill. Located at Coto in the South Pacific Region of Costa Rica.  CIA Coto 54 S.A Secondary (Naranjo) Mill. Located at Quepos in the Central Pacific Region.  Latin America Agrialim. Located at Parrita in the Central Pacific Region about 40 km from Naranjo Mill.

 This audit is of the CIA Coto 54 S.A Main Mill – Coto Division – and its supply base. The Coto Division supply base comprises 3 Districts covering 14.743 ha of oil palm.  Palmar. 6.381 ha total area. 9 farms.  Coto North. 4.741 ha total area. 7 farms.  Coto South. 3.621 ha total area. 7 Farms.

In addition, the Coto Division supply base includes Associated Growers.  796 associated suppliers with a total area of 16.010 ha.  Their combined production of FFB is 198.509,08 per year.  The smallest area is 1ha and the largest is 327 ha of oil palm.  749 growers with less than 50ha of oil palm.  33 growers with 51 to 100 ha.  14 growers with over 100ha.

The average FFB yield per ha:  The 3 Districts: 15,69 mt FFB / ha/ yr.  The associated growers: 12,39 mt FFB / ha/ yr.  Includes young / immature plantations, hence the relatively low average yield FFB per ha.  Mature oil palm was shown to be yielding up to 30mt FFB per ha / yr.  The yields per ha have also been affected by the disease PC.

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Mill records show that for the 12 months ending December 2014:  421.375 mt of FFB were processed.  88.857 mt of CPO were produced.  FFB: CPO = 20,99% OER.  22.119 mt PK.  FFB: PK = 5,25%

The mill projected figures for 2015:  429.957,08 mt FFB (231.448 mt from owned plantations and 198.509,08 mt from associated growers).  94.810 mt CPO.  FFB: CPO = 21,28% OER  21.124 mt PK.  FFB: PK = 4,754% Palma Tica S.A. and Compañia Industrial Aceitera Coto Cincuenta y Cuatro S.A. are both companies owned by Numar Group, RSPO membership number 2-0403-13-000-00.

History of Land Use It can be clearly shown that the land use of all the oil palm that makes up the supply base above was under banana cultivation in the 1950’s. There were many farmers providing small quantities of bananas to the company but due to economic changes, they were unable to sell small quantities and so converted to other agricultural crops. As oil palm became more popular at the end of the last century, those farmers turned to oil palm and Palma Tica offered financial support to help them develop the oil palm. The most recent conversion is as recent as early 2015. It is important to note that all NPP were informed and approved by RSPO on 17/12/2013. Photographic evidence and records show that the land use prior to conversion to oil palm included rice, pineapple, teak plantations, cattle grazing and abandoned land. Palm Tica has an environmental impact assessment for all their (similar) land and the HCV assessment has not revealed any HCV. RSPO Management. The corporate manager is Alfredo Villavicencio and he has a team headed by Carlos Playa for the Quepos Division and Huascar Blanco for the Coto Divison. Each division has a team of 5 people covering health and safety, social management, environmental management and 2 field managers. Specific manuals have been prepared for RSPO covering:  The policies and their implementation. The corporate policies are prepared by Alfredo and the teams then make the plans for their dissemination and implementation. They are published in many locations around the farm.  Quality manuals including, SOPs, Records, External documents and management plans. The teams work with the agronomists of the company to prepare very practical and instructive SOPs, which include photographs and diagrams. The 2 field managers make field observations and report any areas of concern to the head of their team who then reports to Alfredo and the General Manager of each division as appropriate. This work is complimentary to the supervision carried out by Palm Tica managers and supervisors.  Training of all workers and contractors. All the workers are trained and informed about the policies and SOPs as an induction and at least once a year. This is also in support of additional training by the Palma Tica managers – which is more intensive and over a longer period of time.  Regular internal audits for all working sites. The audit results are used to decide on future continual improvement (Principle 8). The financial and control department have an agronomist to do internal audits every 3 months. They audit both the sites and the work of the RSPO teams.  Social plan. The housing is managed in accordance with legal requirements. i.e. Cleanliness, secure and safe structure, water-tight, windows, doors, concrete or wooden floor, running water, energy and sanitary services.

Summary of the findings regarding management and RSPO compliance of the Associated Growers.

Open Stakeholder meeting. 38 Associated Growers attended the open stakeholder meeting on Tuesday 17th March.

Interviews were conducted on the farms of all the associated growers selected and observations made of oil palm operations such as herbicide applications, harvesting and fertilising. It is worthy of note that, almost without exception, oil palm is just one of many agricultural crops grown with other crops on the farms. Black Pepper, Cattle grazing, Rice and other crops were evident and interviews revealed that oil palm is just considered to be another crop. Best practice is being demonstrably implemented at all farms included in the audit and there Is no reason to suspect that this is not repeated at all farms.

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Recycling. Palma Tica collect all empty chemical containers, empty fertiliser bags and other waste and arranges for legal disposal.

Audit procedure. The following approach was used:

The following was required of Palma Tica: 1. Demonstration of sufficient resources to ensure that all associated growers are managing their oil palm plantations in accordance with the applicable indicators of this local interpretation. Findings:  Palma Tica has a Manager responsible for the associated Growers (Guillermo Faerrion) based at DCotoHead office. He has a team of two agronomists (Luis Borbon and Hilario Carrillo) and one assistant for payments and fertiliser supplies and claims. For sustainable advice, there are 5 inspectors to visit each grower at least 2 times per year.  The agronomists give advice on best practice, harvesting, fertilisers, pest controls and other agronomy as required to grow the oil palm as efficiently as possible in accordance with the SOPs that are provided.  The sustainable advisors have expertise in chemical use, health and safety, training, environmental management and produce a report for each visit to the grower and to Andres Quesada.  The team was interviewed and observed in the field and it is considered that the team is sufficient as the associated growers consider oil palm to be just another agricultural crop.  The relationship between the associated growers and the team was very positive.

2. A training matrix and training programme is in place for all Associated Growers. Findings:  There is a training matrix to ensure that all associated growers receive regular training.  Each Associated Grower is given training for all aspects of best management practice, including RSPO requirements, health and safety etc.,  Training is given in an annual basis but the agronomists always ensure that the growers are fully up to date with best practice and they help to ensure that it is implemented in the plantations.

3. Records are kept of all training. Findings:  Records are maintained of all training.  Interviews confirmed that training takes place as indicated and growers were able to demonstrate an understanding of the RSPO requirements.  Each grower is given an A5 size laminated signs that illustrate environmental and social imperatives. (Principles 5 and 6).

4. Records of all visits to the Associated Growers with any advice given are maintained. Findings:  A report is prepared for each visit from the agronomic engineers or agricultural technicians. A carbon copy is left with the grower.  These were available for each associated grower visited.

5. Provide documents to Associated Growers to include as a minimum:  Legal requirements and implementation.  SOPs for best management practice covering all applicable operations.  Fertiliser and herbicide regimes.  Integrated pest management.  Water management.  Health and safety.  Environmental criteria.  HCV and ERT species.  Social criteria.  New planting procedures.  Provide associated growers with copies of all relevant documents, policies and procedures. Findings:  A technical manual is given to all associated growers which include all best practice (Principle 4) and applicable laws (Principle 2).  These were seen at all associated growers interviewed and include all the requirements.

6. Demonstrate that prior to accepting FFB as being RSPO certified, that Palma Tica has conducted training and on site supervision and has verified and recorded that the Associated Grower is in compliance with the applicable indicators of the National Interpretation. Findings:

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 Palma Tica conduct full training prior to accepting the associated grower as a supplier of FFB.

7. Keep records of all Associated Growers that are included in the RSPO certified supply base and the dates that they became part of that supply base. Findings:  All FFB purchased is recorded according to the farm of origin and associated growers have copies of weighbridge tickets.  It is possible to print out full records of FFB delivered by farmer.

8. Inform the Certification Body on at least a 3 monthly basis as to any increase in the RSPO supply base with details of the new Associated Growers. Findings:  Palma Tica will inform IBD as to any expansion in numbers as required.

9. Provide agronomic support to all Associated Growers. Findings:  All associated growers are visited as explained above and agronomic advice is available at any time outside the normal planned cycle of visits.  It was explained by the associated growers that the agronomists and sustainability advisors often call in between the scheduled visits, and this is welcomed.

10. Ensure that there are records of any fertilisers, pesticides and herbicides that are applied. Findings:  Palma Tica gives a record book to record all use of fertilisers, pesticides and herbicides to all associated growers.  Review of books on site confirmed their use.  Fertiliser applications are made in accordance with the recommendations of the agronomist if the grower does not arrange their own foliar analysis.  About 25% of the associated growers do not use any herbicides or pesticides.

11. Have the authority to remove Associated Growers from the RSPO certified supply base if they do not comply with the RSPO requirements. Findings:  Palma Tica have a signed and written agreement with the Associated Growers which includes the understanding that they must manage in accordance with the RSPO and the implication is that failure to do so, will result in FFB not being purchased.  Palm Tica acknowledges that the first action to correct any non-compliance is to conduct more training and to increase the supervision.

12. Take responsibility for ensuring that any conditions on which certification is dependent, including any corrective actions raised by the certification body are fully implemented. Findings.  RSPO is of great importance to Palma Tica and they will ensure that any non-compliances raised will be implemented.

Associated Growers shall: 1. Have an agreement to manage their oil palm in accordance with the agronomic advice given by the Palm Oil Mill and in accordance with the applicable indicators of the National or Local Interpretation. Findings:  All associated growers have a written contract for the supply of FFB and the management of their farms in accordance with best practice.  This includes all contact details and an agreement to manage:  In compliance with national legislation.  To be a transparent and responsible grower.  To protect the environment.  To protect co-workers.  To implement best practices as given during training and in the hand book.  To keep a register of products used in the book provided.  To implement all technical recommendations as given by the agronomist to be an RSPO certified grower. I have read, I have understood, I have accepted and I agree to comply with the 7 pints stated above. Signed by the Associated Grower.  The agreement includes a summary of the farm and lot numbers with areas of oil palm.

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Findings:  All associated growers interviewed confirmed attendance of training and records show this has taken place.

3. Implement all requirements as directed by the Palm Oil Mill. Findings:  A copy of each and every visit report is left with the partner and observations and interviews confirmed that they all act on the advice given.

1.7.1 Location of the Supply Base Oil Palm Plantation (OPP) GPS Reference Location Address Name Longitude Latitude Finca Palmar 1 Palmar District -83.495431 8.939749 Finca Palmar 2 Palmar District -83.492886 8.92061 Finca Palmar 3 Palmar District -83.52984 8.917865 Finca Palmar 4 Palmar District -83.482569 8.880437 Finca Palmar 5 Palmar District -83.42114 8.9134 Finca Palmar 6 Palmar District -83.41032 8.88905 Finca Palmar 7 Palmar District -83.55661 8.96139 Finca Jimenez Palmar District -83.4304 8.600683 Finca Pipa Palmar District -82.95316 8.591701 Finca 49 Coto Norte Coto Norte District -82.969345 8.63242 Finca 50 Coto Norte Coto Norte District -82.982808 8.60622 Finca 52 Coto Norte Coto Norte District -82.988274 8.935562 Finca 54 Coto Norte Coto Norte District -83.006901 8.629894 Finca 57 Coto Norte Coto Norte District -83.00763 8.642071 Finca 58 Coto Norte Coto Norte District -83.03505 8.624492 Finca 59 Coto Norte Coto Norte District -83.0322 8.647667 Finca 42 Coto Sur Coto Sur District -82.928057 8.60591 Finca 45 Coto Sur Coto Sur District -82.948366 8.595611 Finca 47 Coto Sur Coto Sur District -82.966246 8.598817 Finca Celajes 1 Coto Sur District -82.890362 8.501803 Finca Celajes 2 Coto Sur District -82.912416 8.52297 Finca Celajes 3 Coto Sur District -83.019189 8.499843 Finca Celajes 4 Coto Sur District -82.88103 8.567969 Associated Growers. Complete records as above are available for each and every Associated Grower. Due to the number of entries, it does not seem sensible to include all, as par to of the main text. However, a sample are included here: Acevedo Venegas Teodulo LAUREL -82.988455 8.4194011 Agrícola Almau S.A LAUREL -82.991889 8.4343441 Obando Obando Carlos Luis LAUREL -83.025735 8.4845947 Orozco Salas Efrain LAUREL -82.979558 8.4710118 Agrícola Mariana S.A. COTO -83.064831 8.6667575 Zuñiga Fonseca José COTO -82.94249 8.531904 Acuña Rojas Pedro PIEDRAS -83.166967 8.7185137 Zuñiga Zuñiga Manuel PIEDRAS -83.273377 8.8086021 Agrícola Tibidabo S.A PALMAR -83.46588 8.9295129 Zeron Morales Reyes JIMENEZ -83.470996 8.6623246

1.7.2 Statistics of the Supply Base and Estimated Tonnes of FFB produced per year Name Area of Oil Palm (Ha) Estimated Planting and Re- Cycle Total Production Tonnes planting Years (Years) FFB/Yr Finca Palmar 1 618 561,42 13.831 1988-1989, 1991-1992 30 años Finca Palmar 2 712 648,31 16.524 1995-1997 30 años Finca Palmar 3 583 529,39 15.411 1998-2006, 2008 30 años 1999-2000, 2004-2006 Finca Palmar 4 887 805,79 14.996 30 años 2007-2008, 2009-2014 Finca Palmar 5* 596 542,34 0 2014 30 años Finca Palmar 6* 538 488,18 0 2014 30 años Finca Palmar 7* 804 731,35 0 2014 30 años Finca Jimenez 966 877,99 20.248 1998-1999, 2001 30 años Finca Pipa 677 616,36 8.615 2006-2008, 2010 30 años 1983-2002, 2003-2004 Finca 49 Coto Norte 667 605,59 11.645 30 años 2013 Finca 50 Coto Norte 796 723,97 18.108 1994-2005, 2006-2007 30 años

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2009-2010 Finca 52 Coto Norte 727 661,70 13.830 1990-1991, 1992-1997 30 años 1990-1991, 1993-1994 Finca 54 Coto Norte 544 495,77 11.577 30 años 1999 1988-1989, 1990-1993 Finca 57 Coto Norte 699 635,34 13.787 30 años 1994-2000 Finca 58 Coto Norte 687 626,16 6.668 2000-2010, 2012-2014 30 años Finca 59 Coto Norte 621 564,54 13.950 1989-1991, 1993 30 años Finca 42 Coto Sur 655 594,52 13.963 2001-2008, 2009-2012 30 años Finca 45 Coto Sur 533 485,03 7.476 1982-1983, 2006 30 años 1983-1984, 1997-2007 Finca 47 Coto Sur 536 487 5.971 30 años 2009-2013, 2014 1987-1988, 1989-1990 Finca Celajes 1 648 591,21 7.020 1991-1996, 1997-2005 30 años 2009 Finca Celajes 2 524 475,39 5.883 1996-1997 30 años Finca Celajes 3 223 203,18 4.449 1993-1997, 2000 30 años Finca Celajes 4 502 456,21 7.496 1998-1999, 2000 30 años Total 14.743 12.790,38 231.448 - - Associated Growers. Complete records as above are available for each and every Associated Grower. Due to the number of entries, it does not seem sensible to include all, as part of the main text. Total for the Associated 16.010 15.396,36 198.509,08 - - Growers (796) TOTAL 30.753 28.186,74 429.957,08 - - *For the mentioned plantations, there was a NPP process announced on RSPO website on 17/12/2013, and approved afterwards.

Considering then, the Total Oil Pam Areas and the Conservation Areas, the Total Certified Area is 32.181 ha.

Percentage (%) of Planted Oil Palm by different Age Ranges. Planting Years by 5 year Ranges Name of Oil Palm Plantation Prior-1995 1996- 2001 -2005 2006 – 2010 2011 – 2015 2000 Finca 42 Coto Sur 0 0 8,77 515,62 70,13 Finca 45 Coto Sur 0 477,5 0 7,53 Finca 47 Coto Sur 0 341,01 0 23,49 122,5 Finca Celajes 1 0 522,67 53,8 14,74 0 Finca Celajes 2 0 475,39 0 0 0 Finca Celajes 3 0 203,18 27,59 0 0 Finca Celajes 4 0 456,21 54,63 0 0 Finca 49 Coto Norte 0 224,36 465,64 0 108,39 Finca 50 Coto Norte 0 161,55 143,95 418,47 0 Finca 52 Coto Norte 0 661,7 0 0 0 Finca 54 Coto Norte 0 495,77 0 0 0 Finca 57 Coto Norte 0 635,34 218,72 0 0 Finca 58 Coto Norte 0 163,63 163,63 24,76 437,77 Finca 59 Coto Norte 0 564,54 0 0 0 Finca Palmar 1 0 561,42 0 0 0 Finca Palmar 2 0 648,31 0 0 0 Finca Palmar 3 0 514,17 0 15,22 0 Finca Palmar 4 0 260,31 100,44 181,17 286,91 Finca Palmar 5* 0 0 0 0 542,34 Finca Palmar 6* 0 0 0 0 488,18 Finca Palmar 7* 0 0 0 0 731,35 Finca Jimenez 0 865,50 12,49 0 0 Finca Pipa 0 0 0 203,5 0 Associated Growers. Complete records as above are available for each and every Associated Grower. Due to the number of entries, it does need seem sensible to include as par to of the main text. However, a sample are included here: Acevedo Venegas Teodulo 0 0 0 4 0 Agrícola Almau S.A 0 0 0 0 0 Agricola Papilli y Gómez S.A. 0 0 99 18 0 Agropecuaria Río Conte S.A. 0 0 0 37 0 Agropecuaria Río La Vaca S.A. 17 0 7 0 0 Aguilar Alvarez Xinia 0 0 10 3 0 Aguilar Mora Dennis 0 31 0 0 0 *For the mentioned plantations, there was a NPP process announced on RSPO website on 17/12/2013, and approved afterwards.

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1.7.3 Biodiversity (Total Conservation & HCV Area for the respective Supply Bases) Oil Palm Plantation Biodiversity.(Total Conservation & HCV Area) Hectares. Name Conservation HCV Comments Finca Palmar 1 0 0 The riparian zones are all designated as HCV Finca Palmar 2 0 0 under Costa Rican Law. Finca Palmar 3 0 0 Finca Palmar 4 2 2 All riparian zones have been identified within the Finca Palmar 5 4 4 Palm Tica plantations and evidence was shown to Finca Palmar 6 917 917 the audit team of re-instated riparian zones at Finca Palmar 7 498 498 the time of replanting. The gross area of oil palm Finca Jimenez 0 0 shown in table 1.7.2 above does not include the Finca Pipa 0 0 HCV.

Finca 49 Coto Norte 2 2 The banana plantations and agricultural planting Finca 50 Coto Norte 0 0 of the past, included the planting of the riparian Finca 52 Coto Norte 0 0 zones and farmers simply replaced that Finca 54 Coto Norte 0 0 agricultural crop with oil palm. Finca 57 Coto Norte 0 0 Finca 58 Coto Norte 2 2 Palma Tica is now actively ensuring that no Finca 59 Coto Norte 0 0 additional replacement is carried out in riparian Finca 42 Coto Sur 0 0 zones and, at the time of re-planting, all riparian Finca 45 Coto Sur 0 0 zones will be re-instated. Finca 47 Coto Sur 3 3 Finca Celajes 1 0 0 Finca Celajes 2 0 0 Finca Celajes 3 0 0 Finca Celajes 4 0 0 All associated growers. 0 0

1.7.4 Calculation of the Number of Production Units (N) to Sample for the Mill N = 0.8√Y, where “Y” is the number of units, with the result always to be rounded “up” to the next whole integer. Where only a sample of the supply base is assessed, units not previously assessed, or assessed earlier in the certification program, are to be preferred over those more recently assessed. For the Mill, how many units make up the production base? Owned estates (Y) N = 0.8√Y Associated Growers. N = 0.8√Z 23 N = 4 Z=796. N = 23 Explanation as to the selection of estates sampled The Palmar District was driven through on the way down from Quepos to Coto on Sunday March 15th. The manager from Palma Tica explained which plantations were owned and managed by Palma Tica and whilst there were no field operations to inspect, it was possible to observe the general maintenance of the plantations and to appreciate why there is such a high area of HCV; due to the major rivers and tributaries that are a feature. Cultural sites were visited in the region. It is suggested that at the time of the ASA the audit team stops over- night in the Palmar District on the way from Quepos to Coto and to spend at least one day in the District.

It is fully understood that the same management procedures are implemented in all Districts and the same SOPs and policies are applicable. The SEIA for the whole of Coto included the Palmar District and so all the management documents, policies and their communication and implementation etc., inspected were also applicable to that district. The Palmar District manager was interviewed as part of the audit as well to confirm how his operations compare with the other 2 districts as well as with those audited at Quepos the week before. The sample of 4 management units was well exceeded as the audit team divided to visit field operations in both of the other 2 districts. In addition to field operations, conservation (HCV) areas, replanting sites and young plantations were included in the audit.

The open stake holder meeting was attended by about 72 stakeholders and they were asked to remain behind so the audit team could discuss with them as a group their experiences with Palma Tica. No managers were allowed to be present and so information was freely passed over the audit team. To carry out field inspections and on- site interviews, the audit team divided into 3 and the lead auditor arranged for associated growers to be visited using the collection points for FFB as a focus. The larger growers were identified and representative samples were included. It was also ensured that at least 50% of the sample had not attended the open stakeholder meeting. The table below shows the oil palm plantations that were included in this audit, with the operations reviewed in the field, the number of sample sites within the plantation and the number of worker interviews. Comments are added as applicable. See also the record of interviews 3.3.2. Oil palm plantation. Operation No of sample No of Comments. sites Interviews Finca 47 Coto Sur Harvesting and 6 5 First aider on site and extraction. interviewed. Harvesting crew of IPM. 11. Two harvesters interviewed

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of which one was the Trade Union representative. The manager of the district and the supervisor interviewed. Finca 58 Riparian zones 4 2 Interview also with Fernando Mata, District medical director from Ministry of health Finca 59 Riparian zones 3 3 Managers. Finca 49 Herbicide applications. 1 3 Worker interviews. Only one herbicide team so only 1 location possible. Finca 54 Harvesting. 2 4 Worker interviews. Finca 45 Harvesting. 1 6 Worker interviews. Finca 42 Fruit picking 3 9 Worker interviews.

1.7.5 Calculation of the Number of Sub Contractors to be sampled. N = 0.8√Y, where “Y” is the number of contractors, with the result always to be rounded “up” to the next whole integer. Where only a sample of the sub-contractors not previously assessed, or assessed earlier in the certification program, are to be preferred over those more recently assessed. The table below shows the number of approved sub-contractors who may be contracted to be directly employed in the work of the certification unit. The number of sub-contractors actually contracted at the time of the audit is used to calculate the sample. Number of sub-contractors. Mill and workshops Farms Approved: 6 Approved: 10 On site during audit: Y 2 On site during audit: Y 5 Number to audit: = 0.8√Y 1 Number to audit: = 0.8√Y 3 Names Activity Audi Names Activity Audi ted ted Transportes Balsar S.A Transport of FFB from Transportes Bladimir S.A collection points for Cubero Lobo S.A Associated Growers to mill. Yes Gerardo Marin Calderon Gerardo Barrera Ortega Jomathon Mora Badilla Gomez Villalobos Minor Guillerm Brenes Brenes Yes Jose Maria Camacho Madrigal. Haulage of CPO, Yes Allan Cespeded Ocampo. PKO and RBD to the Transportes Internacionales port at Goldolfo. Chinchilla S.A. Transportes Doyle TD S.A. Norman Alberto Ramireaz Chacon. Victor Julio Ramirez Chacon. Transportes Doyle TD S.A. Drainage work Yes Agropecuaria Tierra y Agua

Explanation as to the selection of sub-contractors sampled: Contracts are in place with all contractors, which include 10 regulations relating to the law, use of PPE and reporting procedures. Each contract is 8 pages long and is signed by the contractor. They were interviewed as opportunities arose and therefore random. 1.8 Progress of associated Smallholders or Out-growers towards Compliance with relevant Standards - should be in accordance to the 3 year implementation plan All smallholders were included within this very certification audit, and a sample was taken in accordance to RSPO standard.

1.9 Location Maps for this Certification Unit Note: Individual maps of the group members are available from the co-operatives but it is not practical to reproduce them here. Each area of oil palm is individually managed as an integral part of a farm holding and the adjacent crops are all agricultural.

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MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 12 de 33

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MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 13 de 33

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MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 14 de 33

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2. PARTIAL CERTIFICATION The rules for partial certification allow organizations that have a majority holding in and / or management control of more than one autonomous company growing oil palm to certify individual management units and / or subsidiary companies subject to certain rules. 2.1 Management Organization Item Criteria (Yes/No Description (if applicable) Is the operation conducting a partial 2.1.1 No n/a certification? Is any company of the group, member of 2.2.2 n/a the RSPO? Which one? Is there a clear relationship between the companies, where one company has the 2.2.3 n/a majority ownership or the management control of others? Is there a clear and achievable time- 2.2.4 n/a bound plan prepared and in place? 2.2.5 Does the plan include all subsidiaries? n/a 2.2 Time-bound plan Description: n/a Initial (mention sites and years proposed for the certification):

Alterations:

Justifications:

Acquisitions:

2.3 Progress made on the time-bound plan Please report upon adherence or deviation: n/a 2.4 Non-compliances on the partial certification rules n/a

3. AUDIT PROCESS 3.1 IBD - The Certification Body IBD takes pride in being the largest certifier in Latin America and the only Brazilian certifier of organic products with accreditation through IFOAM (international market), ISO Guide 65 (European market regulation CE 889/07), Demeter (international market), USDA/NOP (North-American market), COR (Canadian market) and INMETRO/MAPA (Brazilian market), making its certificate global.

Located in Botucatu-SP, Brazil, IBD has been in operation since 1992. Initially focused exclusively on the certification of organic product, after 2004, IBD began including certification services in the social-environmental area through the EcoSocial, Integra, RSPO and UEBT (Union for Ethical BioTrade) programs. Today, IBD certifies over 5,000 producers, covering an area of approximately 520 thousand hectares in cultivation and 3 million hectares under wild harvest management, throughout 16 countries.

For more information regarding IBD Certificações, access www.ibd.com.br. RSPO Membership No: 8-0090-08- 000-00. RSPO accredited by ASI on November 4th, 2014, worldwide (accreditation code RSPO-ACC-020).

3.2 Audit Team Lead auditor David Ogg FICFor. Assistant Assessor: Ana Maria Uribe Has experience with quality system management under ISO 9000, internal quality audit, fertilizers and inputs for agriculture.

Assistant Assessor: Cuauhtemoc Cedillo Has experience with management of natural resources, productive projects in rural areas, environmental laws and regulations. Audit team

Assistant Assessor: Kurt Schneider Has 25 years of experience in programs management, human resources management and cooperation projects in Latin America. Expertise in Postharvest handling of grains. Proficiency in the use of conflict management instruments and gender equity.

Expert: Ingrid Ayub MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 15 de 33

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Has experience as an auditor leader to the rules of the Sustainable Agriculture Network (SAN), auditor leader in Integrated Management Systems ISO 19011: 2011 certified inspector organic farms.

CVs for all auditors are available at IBD. 3.3 Audit Methodology 3.3.1 Audit Agenda Date Time Location Program Auditor(s) En route from the Quepos Region to the 15th 1100 Coto Region of the same company the oil March to Palmar District. All palm and associated riparian zones were 2015 1430 reviewed. 16th 0800 Coto Opening meeting All March 16th Review field operations. Environmental 0900 Field visits All March management. 16th Review of operations. Workshop. Stores. 1330 Palm Oil Mill audit. All March POME. Office records. 16th POM Kernel crushing plant audit for SCC. 1400 Palm oil mill. David and Kurt. March 17th Open meeting with the stakeholders. 0830 Open stake holder meeting All March 17th Interviews and observations. 1230 Visits to associated farmers. March 18th RSPO SCC audit of refinery and Kernel 0700 Tank farm Godolfo. David and Kurt. March crushing plant. 18th 1030 Refinery at POM RSPO SCC audit. David and Kurt. March 18th Ana and 0715 Field visits. Herbicide applications. March Cuhautemoc. 18th Chemical store and Ana and 1030 Audit. March workshops. Social. Cuhautemoc. 18th 1300 Office. Audit of documents. P1 to P8. All March 19th 0730 Office Continuation of document audit. All March 19th 1600 Office Closing meeting All March

3.3.2 List of stakeholders consulted prior to and during the audit. Prior to the audit, a one month period of stakeholder consultation took place on the RSPO web site. The company circulated details of the audit and an invitation to attend the open stakeholder meeting to 114 individuals and organisations included in their stakeholder list. No issues arose during the consultation. During the audit the following persons were interviewed by the audit team. Name Type of activity Site Interviewed by Jaime Sequiera Cortes Fruit Bunch Cutter Field, Lote 110,C 277 Kurt Osiris Lazo Pacheco Farm Administrator Farm 47 Kurt Michael Esteves Aguirre Poker / Data Registration in the field Farm 47 Kurt Daniel Ramírez Superindente, Coto Norte Coto Norte ( Lote 102, Farm 47 Kurt Erick Carillo Operator / Escavator Drainage Kurt Jorge García Sanchez Supervisor, Poker, First Aid Lote 62, C27 Kurt Henry Rodriguez Bolaños Fruit Bunch Cutter Lote 62, C27 Kurt Jimmy Saldaño Fruit Bunch Cutter Lote 62, C27 Kurt Nestor Sequiero Chavez Poker / Data Registration in the field Lote 62, C27 Kurt Carlos Rodriguez Fruit Bunch Cutter Lote 54, C86, Farm 58 Kurt Fernando Mata Castro Director medical Center, Min. Of Farm office 58 & 59 Kurt Health, Golfito Fabricio Ulzigray Responsable of process Mill Kurt Otoniel Nolori Responsaible Envornment and Mill Kurt Social aspects Delfi Ramírez Process Supervisor mill Mill & POMES Kurt

Mirtha Ortega Vazquez School director, Coto 50 Stakeholder meeting, Rio Claro Kurt Stevi Pérez Trade Union secretary Stakeholder meeting, Rio Claro Kurt & Ana SINAC ( Sistema Nacional de Areas Stakeholder meeting, Rio Claro Kurt & Ana de Conservación) José Eduardo Cerdos Gomez Associated producer (37 has) Villa Bonita Kurt & David MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 16 de 33

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Edwin Loria Oares, 57 Associated producer (30 has) Villa Bonita Kurt & David Jorge Ruíz Duarte Associated producer (10 has) Finca Guanacaste Kurt & David Cesar Augusto Reyes Nieto, Associated producer (20 has) Finca Guanacaste Kurt & David 43 Trinidad Ramírez Altizar, 60 Associated producer (5 has) Finca Alajuela, Piedra Blanca Kurt & David Maria Cecilia Hernandez Associated producer (8 has) Piedra Blanca Kurt & David Marin, viuda Sabino Gomez Briceño, 66 Associated producer (12 has) Florida, Piedra Blanca Kurt & David Edwin Moya Castro, 58 Associated producer (4 has/3 has) Florida, Piedra Blanca Kurt & David Gerardo Leal Enriquez (only Associated producer (11 has) Lagamba Kurt & David site visit) Gonzalo Mena Agüero, Associated producer (180 has) Kurt & David manager farm Agro Arenales SA Miguel Madrigal Rosales, 32 Superviser herbicide application, Finca 49, Lote 25 Kurt, Cuauhtémoc, Ana Victor Hugo Salas Sprayer Finca 49, Lote 25 Kurt, Cuauhtémoc, Ana Raúl Chavez Sánchez, 63 Operator tractor Finca 49, Lote 25 Kurt, Cuauhtémoc, Ana Raymundo Sánchez Pests, Deseases and Fertilizer Finca 49 Kurt, Cuauhtémoc, Ana Liliane Moscas Laundry Finca 49 Kurt, Cuauhtémoc, Ana Walter Medina, 49 Workshop Finca 49 Kurt, Cuauhtémoc, Ana Roque Caballero Vigil cortero Finca 47 Cuauhtémoc Michael Aguirre Hernández Toma datos o poquero Finca 47 Cuauhtémoc Nelson Cárdenas Porras Cortero Finca 45 Cuauhtémoc Berny Espinoza Solórzano Cortero Finca 45 Cuauhtémoc Jorge Luis Calderón Sánchez Cortero Finca 45 Cuauhtémoc Juan José Gómez Chavarría Toma datos o poquero Finca 45 Cuauhtémoc Jaime Bejarano Sánchez Evacuador Finca 45 Cuauhtémoc Amador Navarro Administrador de la finca Finca 42 Cuauhtémoc Carlos Alberto Leal Leal Supervisor de chapea Finca 42 Cuauhtémoc Rodrigo Jiménez Rojas Associated grower 1 km Ciudad Neily Cuauhtémoc Armando Venegas Associated grower Golfito, Corredores Cuauhtémoc Porfirio Sánchez Marenko Associated grower Viquilla, Río Claro Cuauhtémoc Juan Catalino Chávez Associated grower Bambul 1, Granjas Campesinas Cuauhtémoc Catalino Guaycará, Golfito Oliva Gamboa Badillo Associated grower Bambul 1 Cuauhtémoc Fredy Guerrero Sánchez Associated grower Bambul 1 Cuauhtémoc Natividad Barquero Associated grower Caracol Norte, Finca Güicho Cuauhtémoc Granados Jenny Núñez Noroña Associated grower Caracol Norte Cuauhtémoc Maikel Gerardo Sánchez Associated grower Caracol Norte Cuauhtémoc Núñez Geovanni Rosales Gómez Associated grower Coto 63, Río Claro de Golfito Cuauhtémoc Miguel Gamboa Vadilla Associated grower Coto 63, Río Claro de Golfito Cuauhtémoc José Luis Chacón Garro Associated grower Coto 63, Río Claro de Golfito Cuauhtémoc Roger caballero Vigil Cortador (campo) Finca 47,lote 110 centro 272 Ana Maria Osiris lazo Pacheco Administrador (campo) Finca 47,lote 110 Ana Maria Centro 272 Maickol Aquimes Poquero (campo) Finca 47,lote 110 centro 272 Ana Maria Josue Agüero valencio Cortador(campo) Finca 45,lote 96 Ana Maria Centro 265 Armando Torres Administrador (campo) Finca 45, lote 96 centro 265 Ana Maria

David Lopez Poquero Poquero (campo) Finca 45, lote 96 Ana María Centro 265 Mainor Suñiga Cortador (campo) Finca 45, lote 96 Ana Maria Centro 265 Juan Gabriel Gómez Acarrea fruta –mulero (campo) Finca 42 lote 85, centro 249 Ana maria

Carlos Sánchez Evacuador fruta (campo) Finca 42 lote 85 Ana Maria Centro 249 Otoniel Rojas Legado Chapiador(campo) Finca 42 lote 84 Ana maria Centro 204 Emanuel navarro Administrador (campo) Finca 42 lote 84, centro 204 Ana Maria José Mauricio vega Fiscaliza el peso romana (planta) Planta coto 54 Ana Maria Shirleni Castro Villareal Encargada del personal Planta coto 54 Ana Maria Yordi Álvarez Operador del área de prensado Planta coto 54 Ana María Heiner Cortes Operador caldera Planta coto 54 Ana María Jhony Enrique Baltodano levantar el vapor Planta coto 54 Ana Maria

Cristian Mena Mena Operador de esterilizaciones Planta coto 54 Ana maria MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 17 de 33

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Stevi Pérez mena sindicato Golfito Ana Maria Elicinio Anchia Blanco Propietario asociado Agrojo Norte Ana Maria Edwin García Matarrita Propietario Agrojo norte Ana Maria asociado Marcial Valdez Propietario Ceibo Ana Maria asociado Fernando Matamoros Propietario La mariposa Ana Maria asociado Álvaro Fernández Propietario La mariposa Ana Maria asociado Juan Pablo Lara Propietario coloradito Ana Maria asociado David caballero Propietario coloradito Ana María asociado

3.3.3 Outline of how stakeholders consultation was managed. During the field audits, individual interviews were conducted of workers and managers. They were interviewed by the Spanish speaking members of the team with the lead auditor present on some occasions to help with any queries. The Palma Tica managers remained at least 50m away from the interviewee.

An open stakeholder meeting was held on Tuesday 17th March. This was advertised and promoted by Palma Tica and 72 stakeholder attended. Associated Growers: 38. Environmental organizations: 4 Local Municipality Government: 7 National Government: 14. Producer Associations: 8. Trade Union: 1 David Ogg (lead auditor) made an introduction to the meeting in English with immediate translation to Spanish by one of the auditors, in which the objective of the meeting was explained to the participants. Following, there was an invitation for the participants to openly comment their perception about Palma Tica company regarding any positive and / or negative impacts in social aspects, environmental aspects and health aspects. The participants started to comment on different aspects. The subjects raised are summarized below. After the meeting an individual interview were held with the Environmental organizations and a group meeting of the Associated Growers. i. Issues that arose during stakeholder consultation and company responses. Subject raised Company response and Audit team findings proposed action to be taken. In general a big majority of stakeholders express their Confirmed during other interviews with appreciation of the work that Positive stakeholder input. workers, growers and contractors. the company Palma Tica Coto No further action. 54 developed in the region. The company provides support and technical assistance that Confirmed during other interviews with includes funding for herbicides, Positive stakeholder input. workers, growers and contractors. fertilizer and some other No further action. production requirements. There are partnerships with Confirmed during other interviews with educational institutions to Positive stakeholder input. workers, growers and contractors. campaign for recycling and No further action. environmental improvements. Everyone appreciates the ease Confirmed during other interviews with of credit and favorable interest Positive stakeholder input. workers, growers and contractors. rate. No further action. Associated producers appreciate decentralized collection point Confirmed during other interviews with which also means reduction of Positive stakeholder input. workers, growers and contractors. costs as well as energy savings No further action. in transport fuel. The company gives the opportunity to employee to Confirmed during other interviews with become enterpreneur and be a Positive stakeholder input. workers, growers and contractors. producer of palm tree, giving No further action. them assistance. The rapid response in terms of Positive stakeholder input. Confirmed during other interviews with

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Doc_2_2_30_1_3_En training and / or assistance workers, growers and contractors. when a producer request it. No further action. This single opinion was not repeated A single opinion, that the The company is involved with all and the audit team has seen the company does not sufficiently the schools and records of all the evidence of all the work the company support local social donations made are kept. des with the local development, development. No further action. In the region there are few jobs for young people and the price paid is very low. That forces All wages are in excess of the Workers interviewed were content with some families of small minimum salary required by law. the pay. producers to involve the entire Opportunities are for field workers Jobs in offices cannot be formed if they family at work. It is thought as there are limited office places. are not required. that the company should pay Not everyone wants to work in the No further action. more attention to regions with field. few job opportunities and especially for young people. The company pays their own 1.5% tax. Their approach to PC is to do nothing given that there’re no specific actions that could be done to solve the PC. Very upsetting but nothing that Associated producers complain problem efficiently and in a sustainable can be done. of three aspects that strongly manner. The associated growers have Low price for FFB due to low affects them are: been fortunate that they have not International price of CPO. Pc disease been wiped out – probably thanks to The company does not charge the Low Price of fruit the advice given by the company. 1.5% tax – each grower must go to The municipility tax (1.5% of World price of oil is affecting the municipality and pay the value of fruit sold). everybody. themselves. The company understands the pressures put on growers as the CPO price drops and they will discuss this on an individual basis. The municipality is not transparent in the use of the Nothing the company can do. No further action. money received to improve roads. Some participants felt that Communication is through the communication is good, while sustainability team. Thoughts are others think that the public No further action. being given to producing a news- communication should be more letter on a regular basis constant. One opinion expressed that the All work is in compliance with best company should be aware of the In the opinions of others, the practice and local laws. Significant impact on the landscape of oil landscape is improved! reductions in the use of pesticides. palm plantations. No further action.

4. AUDIT FINDINGS 4.1 Summary of findings. Principle 1: Commitment to Transparency. Summary for Principle 1: Criterion 1.1: Oil Palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO criteria, in appropriate languages and forms to allow for effective participation decision making. Findings: Comments: Compliance There is a list of stakeholders with contact details for direct There is a file that all requests for information (and Yes and effective communication. complaints etc.,) are recorded. There is sheet prepared for An annual official stakeholder meeting is held once a year each request which includes: and they are informed as to the procedures to request Date. Time. Name of person raising the issue. Name of information and to raise complaints and grievances. It was company person receiving the request. confirmed during the audit that stakeholders understand Description of request. Action taken to respond and copies and approved the procedure which is prepared by the of the information provided are also attached as applicable. sustainability department. Request for information: 23rd Feb 2015. Request for information regarding emergency procedures and points for Signs are displayed around the farms giving the phone everyone to gather. The company responded by sending an number to call to contact the company: 2785-9176. email on 25th Feb 2015 informing the stakeholder that the Each farm has a large sign showing the name of the farm, documents are available for collection at the Coto office. emergency contact phone numbers, a schematic diagram of the farm and the phone number to request information or to raise a complaint.

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Criterion 1.2: Management documents are publicly available except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes. Summary of the findings for 1.2: Findings: Comments: Compliance Documents are publicly available as required by the RSPO. The procedure for making documents available is PTG-PR- Yes 15-02-02. This includes a list of all the documents that are available. This is also the procedure for informing stakeholders as to how to request information.

It includes a statement in confidential documents but the list includes all the RSPO requirements. Criterion 1.3 Growers and millers commit to ethical conduct in all business operations and transactions. Summary of the findings for 1.3: Findings: Comments: Compliance The policy is Codigo de Conducta Empresarial. PTC-FR-27- This is given to all administrators and supervisors and they Yes 04-01. sign acknowledgment of the policy. The policy is then It covers all RSPO requirements: passed onto the workers through training. • Respect for fair conduct of business; • Prohibition of all forms of corruption, bribery and fraudulent use of funds and resources; • Proper disclosure of information in accordance with applicable regulations and accepted industry practices.

Principle 2: Compliance with applicable laws and regulations. Summary of Principle 2: Criterion 2.1: There is compliance with all applicable local, national and ratified international laws and regulations Summary of the findings for 2.1: Findings: Comments: Compliance Compliance with the applicable laws and regulations was This includes, between others, land titles and land use, Yes evidenced through observations, document review and operational permits, licenses, labour law, environmental interviews. and social assessments and health and safety related aspects. There is a file containing all the permits required in the mill. SETENA is the organisation that gives permission to carry For example: Boilers. Ministry De Trabajo Y Seguritad out ground works in Costa Rica. If a company is going to Social. Permit number: 231. Dated 15 Feb 2015 valid for 12 excavate more than 1,000 cu of soil, or plant an area months. greater than 50ha with a new crop, then permission is required. (There are other minimum criteria requiring There is a file for all permits required in the plantations. For permission). For the 2,000ha planted in 2014, blueprints example a licence to keep fertiliser in a warehouse. Bodeg showing the location, roads and drains were sent in De Fertilizantes Palmatica S.A. November 2012. There are three areas comprising the No RB-ARS-C0-017-2015. 5 year permit to 20th Jan 2020. 2,000ha and separate submissions made. Confirmation of There is a procedure to identify all the applicable laws: approval was given for all 3 sites. Example: Area Webb: th Identificacion Requisitos Legales y otros. PTG-PR-12-01-02. 200ha. Permission granted 29 November 2019.

Every law and regulation has a summary sheet prepared by Internal audits are conducted at least annually with Health the company which details the law and who is responsible and safety being monthly. This check includes compliance for its implementation. This includes action to be taken to with applicable laws and regulations. th comply and new procedures may be developed. For example: Verification Integrada de Sostenibilidad. 15 March 2014. Palmar 4. Audit done by an environment There is a spreadsheet record of all the laws and engineer. The results are satisfactory. There are records of regulations to have an overall control and to ensure that all audits. any new procedures and updates are provided to the correct person(s).

The company subscribes to Master Lex, which is a web based serviced to give all updates of laws that are gazetted by law. Every day an email may arrive with updates or changes. The laws and regulations are divided into 9 files covering subjects such as Health and Safety, Environment. Social responsibility etc., Criterion 2.2: The right to use the land can be demonstrated and is not legitimately contested by local communities with demonstrable rights Summary of the findings for 2.2: Findings: Comments: Compliance There is a file containing all 64 titles applicable. There is a For example: Finca 42. Yes map for each farm and the title is included. Title number: Escritura 6-0078049-000. The title deed has a detailed Cadastralmap of the area The original field boundaries, rivers and roads are all visible. covered by the title and the exact area. Cadastral number: MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 20 de 33

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This was observed during the filed audits and confirmed P-74660-92. with the company. It was verified that all of the associated growers have title No disputes noted or raised by stakeholders. deeds to their properties. Criterion 2.3: Use of land for oil palm does not diminish the legal or customary rights of other users without their free, prior and informed consent. Summary of the findings for 2.3: Findings: Comments: Compliance The land has been under company ownership for decades No stakeholder comments were received and this subject Yes and there is no evidence of any customary or user rights was not raised at the open stakeholder meeting. being diminished.

No land conflicts noted or raised by stakeholders or associated growers.

Principle 3: Commitment to long-term economic and financial viability. Summary of Principle 3: Criterion 3.1: There is an implemented management plan that aims to achieve long-term economic and financial viability. Summary of the findings for 3.1: Findings: Comments: Compliance The company has an actualised Business plan with a There is a replanting programme in place with a production Yes projection period from 2015 to 2019. The plan covers: projection to 2032. By 2018, all older palms should be Production of fruits (mt), productivity (mt/ ha), area replaced. The production area should increase to 28,998 ha planted (ha), Industrial productivity (mt oil / ha), Oil by 2019, with the main increase by associated growers. production (mt), Operational costs: Agriculture (plantation), Mill and Administration. There is a comparative table analysing cost – benefit with different oil prices taking as reference the last 15 years.

Principle 4: Use of appropriate best practices by growers and mills. Summary of Principle 4: Criterion 4.1 Operating procedures are appropriately documented and consistently implemented and monitored. Summary of the findings for 4.1: Findings: Comments: Compliance For the mill, the SOPs are contained within a file and cover SIG has, for example, separate file for: Yes every work station. They are also displayed within the mill. Policies. The file includes procedures as to how the SOPs are Procedures. communicated. Registration instruction manuals. For the plantations, an electronic document management External documents. system is used and is known as SIG. All operations have SOPs. The applicable SPOs are given to the associated growers as reported in the pubic summary. Daily supervision of all workers takes place and associated growers are regularly visited to ensure best practice.

Monitoring of implementation of best practice takes place in an on-going way and records maintained.

The system for recording FFB into the mills ensures that only FFB from approved suppliers is accepted. Print outs can be generated on a daily basis to show FFB by third party. Criterion 4.2: Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield Summary of the findings for 4.2: Findings: Comments: Compliance Soils are predominantly alluvial with a clay content. FFB extraction by oxen and buffalo to reduce soil Yes Good practices includes a standard fertilization procedure. compaction, compost spreading over the piles of fronds to reduce soil compaction by the back hoe, and reduced Fertiliser records are maintained for all applications and the herbicide applications. The harvesting of ripe crop to ensure associated growers have their own special books for best practice and optimized yields. The compost is applied records. All confirmed during the field and office audits. at 25 - 30 mt / ha.

Annual foliar and soil analysis are conducted by Associated growers may do their own sampling and send it agronomists and the results analysed in the Investigation to analysis in the Investigation Unit or the company Unit of the company. This results in a fertiliser regime extrapolates their results to give them a recommendation. tailored to the needs of each batch of palms.

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POME is mixed with shredded FFB and fibre to produce a compost. The compost is analysed for elements. It is then applied at 25 - 30 mt per ha. Criterion 4.3: Practices minimise and control erosion and degradation of soils. Summary of the findings for 4.3: Findings: Comments: Compliance Soil maps are available for all farms and no fragile soils, by It was observed the company land does not include steep Yes definition, are present, according to the study : Modal slopes. All have slopes less than 3° according to the study profile description and physical and chemical characteristics and field observations. of soil study of the Coto Division. Company Palma Tica. Research Program Palm Oil, Department of Agronomy Coto There are analysis and inspection records that show the 47, Costa Rica, June 1992. Compiled by: Norberto Durán, improvement of soil organic matter by aggregating compost Guido Monge and Ruben Ortiz. and / or waste fibre from the FFBE the extraction plant. Road maintenance is carried out using the company No peat soils. machinery and is on a general maintenance basis.

Criterion 4.4: Practices maintain the quality and availability of surface and ground water. Summary of the findings for 4.4: Findings: Comments: Compliance A Program for the Protection of Water Resources (PTC -PG- There is a reference document: Quantification of buffer Yes 28-04 ) that provides for the protection of watercourses zones in Palma Tica properties in the Lower Basin Coto. and water protection , protection of groundwater, a fee to Based on this study, the company considers the use water ( licenses and permits ) laboratory analysis and implementation of measures for 175 ha of land for banks to monitoring and tracking . recover as conservation areas in the coming crop renewal cycles. There is a compost plant where mill fibre is mixed with Riparian zones were visited in all districts and evidence seen POME. About 25% of all POME is used, with the balance in the field that they are being re-instated at the time of being treated in ponds prior to discharge. The BOD is replanting. It is also evident that there is a survey being measured and reports sent to the Government. All records conducted of all associated growers to identify riparian show that the BOD levels are within legal parameters zones to ensure that no planting takes place and that they are restored at the time of replanting.

Records for mill show an average of 0.59 mt water / mt FFB. Monitoring is on a daily basis. Criterion 4.5: Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate integrated Pest Management (IPM) techniques Summary of the findings for 4.5: Findings: Comments: Compliance IPM is carried out throughout all plantations. The use of Direct interviews were conducted with applicators of Yes pheromone traps and the planting of beneficial plants are pesticides in field work, their supervisor and those evident throughout the plantations. responsible for providing training in IPM. Materials and There is a specialist team that conduct regular inspections. record sheets training received was also checked. The company has a small laboratory where produce fly pupae parasitized by a species of wasp (Pachyquepoides ) that distributes specific batches and sends subsidiary Quepos for biological control of this insect . Criterion 4.6: Agrochemicals are used in such a way that does not endanger health or the environment. There is no prophylactic use, and where agrochemicals are used that are categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented. Summary of the findings for 4.6: Findings: Comments: Compliance Justification for the use of pesticides is given in the SOPs. Records are maintained of all pesticide use that includes the NC 001 active ingredients and area treated. The associated growers relating to The use of pesticides are minimised. Very small weed free also keep records. 4.6.4 areas are maintained around the palms for harvesting purposes. There are no prophylactic uses of pesticide as confirmed by observations and interview. The herbicide application process and product application was observed in the field. Preparation records and control Paraquat is being eliminated and its use is covered by the of litres of herbicide applied per ha were reviewed. SOPs.

All operators receive applicable training as described in the The chemical store is well designed and all PPE is washed risk assessment and SOPs. Field observations confirmed and stored there. best practice and all mixing takes place at the chemical All containers are triple rinsed and punctured prior to store in a 2,000 litres tank, which is taken into the field and collection by a licenced operator. See so P5. Containers MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 22 de 33

Doc_2_2_30_1_3_En knapsacks are filled form tow hoses in an environmentally form the associated growers are collected for disposal. friendly way. Access to treated areas is restricted for 24hrs after No mist spraying. Only low volume application by knapsack. application. Washing facilities and fresh water is available for all workers in the field. No aerial application.

The whole operation herbicide application and measures of All associated growers are trained in the same way that occupational health and safety were observed in the field. Palma Tica workers are trained. See also public summary.

Proper disposal of waste material. Waste management plan Each 6 month a medical check is required. Medical records PALMATICA. Prepared May 2013. Document approved and were seen as evidence. received by the ministry Health and social development on May 28, 2013. Registration is evident and Training dated No use of pesticides by female workers. August 21, 2013.

Criterion 4.7: An occupational health and safety plan is documented, effectively communicated and implemented Summary of the findings for 4.7: Findings: Comments: Compliance There is a plan of occupational health which includes the The Zero Accident Program consists of the following Yes Health and Safety Policy and contains three programs: 1. activities: Evaluation of legal and other requirements, Zero Accidents (PTC-PP-01/29/05) 2. Health Surveillance for Occupational Risk Analysis, Blackboard "Zero Accidents" manipulating Personal Agrochemicals ((PTC-PP-5.3.29) and Five Minutes for the Prevention, Measurement and the Program for Emergency Care (PTC-PP-2.5.29). Monitoring Monthly Performance Incentive Group for Zero Accidents, Training, Study Cases of High rates of Accident, In the plantations like mills they have a Health and Safety Rating Personal Protective Equipment (PPE) Safety Committee in each crew or work unit, which meets Instructions. monthly. There is an emergency team within each group, at least 2 people to provide basic first aid. OHS in agriculture operations Security includes inspection of all machines to ensure that There is a procedure (PTG-PR-29-02-01) where the way to sharp edges are covered and all risks are considered. build the risk matrix (PTC -AR - 29-01 ) where , for the agricultural part records of 76 risks identified, assessed and There is a risk assessment for the agricultural part (FR - 16- detailed classified numerically and with a colour code that 01) and one for the industrial part (extractor) ( FR- 16-02 ) identifies dangerous. where is concentrated and rate the information on the risks of accident activity. It is updated every six months or when OHS in the mill. a change occurs in the operation. There is a protocol for workers and visitors and suppliers that the prevention, precaution, prohibition and obligation There is a health and safety manager with overall indicated. responsibility. Each workspace is the respective labelling for machinery and equipment indicating the risks in their operation. Training and advice is given to the associated growers. Technical instructions for use, maintenance and cleaning Information boards are provided on Fruit Production are communicated to the workers and are also visible signs. Responsible Palm Oil where risks , emergency measures to In the riskier use are highest security protocols. take and contact details to meet them include, which includes compliance with national laws and the correct PPE The emergency procedures are available in local language that should be worn and protective equipment should be and are well communicated to all workers. used. Based on interviews and information gathered in the field it The Health and Safety Committees meet on a monthly basis was found that at least two people trained in basic first aid and records maintained. in each work crew, which has a portable first aid kit. First aid boxes are located throughout the mill and supervisors There is an emergency procedure for the mill (CIA-PR-29- carry them in the plantations. Fire extinguishers are well 01) and for agriculture operations (PTC-PR-29-01), called: identified and applicable to the work station. Accident Procedure and Occupational Diseases. Accident records are given each week to the General For the mill It details procedures in case of fire, explosions, Manager and all heads of department. There is close earthquakes, flooding, bush fires and medical emergencies. collaboration between the medical centre and the OHS manager. Records are maintained by month for all workers For agriculture operations it is very focused on natural in the plantations and mills. The records are very detailed events and the type of work being carried out in the field. and always considered at a committee meeting.

Pesticide operators have a medical check-up every six All workers are covered by the Professional Risk Policy of months and records are kept by the doctor in the medical the Instituto Nacional de Seguros (INS) that attends the centre on site. Before any workers start, they have a accidents occurred at work or going and/or coming back medical check-up. The clinic is provided by the company from work. All of the workers are covered by the socialized MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 23 de 33

Doc_2_2_30_1_3_En and offers free treatment to all workers. medicine of the Caja Costarricense del Seguro Social (C.C.S.S). Noise levels are checked in the mill and the workers must wear ear protectors as identified in the risk assessment. The company has a medical office established in 1999, located in Coto 54 Mill. The medical office is open only on All workers are covered by insurance – regardless if they Thursday from 8 a.m. to 12 p.m. It attends mill workers and are part time, seasonal or full time. agriculture workers that manipulate agrochemical.

There are accident records recording with Lost Time Workers handling agrochemicals have individual pre- Accidents. Occupational Health and Safety Office receives employment medical and annual follow-up examination. copies of the notices of accident investigations and Which includes thorax X rays, hepatic enzimes, renal recorded in the database. Injured workers receive basic function, complete hemogram, urine analysis, time of first aid by the competent person and then go to medical prothrombin y thromboplastin and cholinesterase exams in care in the dispensaries of the National Insurance Institute. compliance with national laws. It was verified, through a sample of files that medical exams were done.

Criterion 4.8: All staff, workers, smallholders and contractors are appropriately trained Summary of the findings for 4.8: Findings: Comments: Compliance A formal training program is in place: Training program, Records of all training for employees is recorded in digital Yes training and awareness (FR - 18-02), reviewed by Human and print and maintained. Training records were inspected Resources and approved by the Management Division. It for workers interviewed in the field and found to be in also covers the RSPO requirements. order.

Principle 5: Environmental responsibility and conservation of natural resources and biodiversity. Summary of Principle 5: Criterion 5.1: Aspects of plantation and mill management 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 continuous improvement Summary of the findings for 5.1: Findings: Comments: Compliance There is an independent Environmental Impact The scope of the assessment included the farms (fincas) Yes assessement (EIA) made by BioTerra, date: August 2013. owned and managed directly by Coto Palma Tica and the Conducted by a team of 7 persons under the leadership of Associated Growers in the cantons of Corredores, Golfito MSc. Marisol Zumbado Bustillos, Biologist specialist in Audit and . The EIA was reviewed by the audit team and and Environmental Management. She is an approved RSPO confirmed that it contains the information required by the assessor. indicator. The assessment covers fiscal, social and environmental aspects, which can derive from the companies activities and responds to the norms of RSPO standard.

Within the EIA, Chapter 7 (Integrated Environmental Impact), identifies and assesses all environmental impacts - both positive and negative - arising from the activities of the Division Cotos.

Monitoring plans are included in the EIA.  Identified positive environmental impacts and actions to enhance.  Negative Environmental Impacts and mitigation measures.  Related Documents. For each aspect the company established a programme to follow up the impact and the improvements, such as contamination of superficial and underground water, see procedures in SOP 2015 Volume I and Water protection program 2014, volume I. Criterion 5.2: The status of rare, threatened or endangered species and high conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations. Summary of the findings for 5.2: Findings: Comments: Compliance The following natural parks and reserves are adjacent to oil An HCV assessment was conducted by Bioterra in May NC 002 palm: 2012. relating to - Corcovado (National Park, 7km of distance from “Identifying Areas of High Conservation Value - HCV , and 5.2.3 plantation) rare , threatened and endangered species associated with - Forest Reserve Golfo Dulce (Biodiversity the Company Palma Tica SA, Division Coto, May – 2012”. NC 003

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corridor, distance 1 km from plantation) The specific objective was: relating to - Swamp Lands (Palmar region) To identify areas of high conservation value present within 5.2.4 - Boruca (Indigenouis Reserve, distance from the African oil palm plantation company Palma Tica SA palms 3.5km) (Division Coto) and within plantations of associated - Abrojo Montezuma (Indigenous Reserve, producers associated with it, and within their areas of distance from palm trees 2.5km) Direct Influence (AID). All these areas are classified as HCV. Samples were taken at 30 sites (the geographical The company developed a protection programme (2015) coordinates of each point included), 4 of which were with the objective: Maintain and/ or improve the state of associated producers. art of endangered and threatened species and areas with HCV. There is an actualised map with the HCV areas and riparian Zones. There is also a spread sheet with 158 indicators on different environment issues actualized on an annual base. See also 5.1.3.

Training of all workers takes place relating to HCV awareness. Criterion 5.3: Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner. Summary of the findings for 5.3: Findings: Comments: Compliance There is a programme for integral management of waste There are written procedures for handling and disposing of Yes from date: 2015. All sources of waste products and all chemical containers. The company collects empty pollution are identified and documented. containers from the Associated Growers and has a central industrial waste store. It is disposed of by an independent Palma Tica and the associated growers use a triple rinse licenced operator: Dow and Inquisa. procedure to clean all empty containers. All containers are punched and properly disposed. Rinse water is channelled into a septic tank, See Finca 49. The chemical boxes are collected by external companies: Dow and Inquisa.

The Manual of integrated pest management mention in Chapter 8: Inventory of waste and pollutants includes indication such as: activity, waste, reduction, recycling, treatment and disposal.

Criterion 5.4: Efficiency of energy use and use of renewable energy is maximised. Summary of the findings for 5.4: Findings: Comments: Compliance Use of fossil fuels is monitored. Due to a system change of transporting Fruit Bunches by Yes bigger trucks, 30 mt instead of 8 mt, from the associated In the data base, following statistics in fuel consumption growers, the company could reduce the fuel consumption were observed: as follows: 2013: 0.497 l / mt FFB 2012: 335,765 l ( 1.91l/tm FFB) 2014: 0.46 l / mt FFB 2013: 401,963 l (1.77l / tm FFB) 2014: 399,59 l (1.75l / tm/FFB) Which result in a reduction of almost 9%. Criterion 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 Summary of the findings for 5.5: Findings: Comments: Compliance No use of fire is allowed and this is also applicable to the Confirmed by observation and interview. Yes associated growers, who are simply cultivating land for the replanting with oil palm. See document Replanting procedures (PTC-PR-02-01-02) from date: 4.11.2014 Criterion 5.6: Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and monitored. Summary of the findings for 5.6: Findings: Comments: Compliance Outcome Indicators for Environmental Management. Palma These data are produced by Chemical Laboratory of the Yes Tica SA, an assessment of all polluting activities is National University and sent to the Ministry of Health. presented, including gas emissions, emissions of particulate / soot and effluents. These were measured by operational The effluents of the mill are drained to a pool for cleaning. indicators in order to set performance targets for reduction The area visited of the pool represents a surface of and improvement. 100,000ms. 25 % of the effluents are used for the composting of the vegetable fibre. As average the company A new boiler is being built in the mill, which will reduce the produces around 1000m3 of effluent per day. emissions. The company analyses samples every day and an external MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 25 de 33

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The monitoring system was implemented with the control is made every three months and sent to the Health methodology Palm GHG. It is calculated on an annual base Ministry. starting from 2012

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Principle 6: Responsible consideration of employees and of individuals and communities affected by growers and mills. Summary of Principle 6: Criterion 6.1: Aspects of plantation 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 Summary of the findings for 6.1: Findings: Comments: Compliance A Social Impact Assessment (SIA) was conducted over the The expert preparing the SIA was Mario Antonio Piedra Yes last quarter of 2012 and was completed in December 2012. González. The following chapters are included: - Methodology: Approach, document revision, Visit The SIA did not high light any significant impacts that communities and focus groups required mitigation - Context of the area (history, demography, social, economic, Housing Perception of impact) - Conclusions. - References. Management aspects of the plantation and processing plant that have social impacts are evaluated and monitored in order to mitigate negative impacts and promote the positive showing. Annexed , there are records of meetings, list of persons interviewed 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 Summary of the findings for 6.2: Findings: Comments: Compliance There’s a procedure for external communication: PTG-PR- There is a list of over 110 stakeholders. They are Yes 15-02-02 categorised with contact details.

There is a manager responsible for all external communications, who is also responsible for the communications with the stakeholders. Criterion 6.3: There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties Summary of the findings for 6.3:

Findings: Comments: Compliance Procedures for complaints defined in internal document, There is a procedure in place for complaints adjusted to the Yes agreed with the stakeholders. Time for resolution should law 7476 and its change for the law 8805. In its art. 3 there not exceed than 10 days. is a guaranteed protection for whistleblower. The procedure includes the use of Public Law 7727 if there is no internal solution: Ley sobre resolución alterna de There are records of documented disputes and the resolved Conflictos y promoción de la paz social (Ley RAC). process with the outcomes.

Criterion 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 Summary of the findings for 6.4: Findings: Comments: Compliance Procedures document EXTERNAL COMMUNICATION The land has been on company ownership for many Yes evidenced code decades. PTG-PR-15-02-02The land has been on company ownership No legal or customary rights. for many decades. Criterion 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. Summary of the findings for 6.5: Findings: Comments: Compliance All workers have a contract which includes pay and Payroll for National Security (INS) are documented as well Yes conditions. This is made in conjunction with the Trade as Costa Rican Health Security (CCSS). Unions and so accepted by all workers by association. There is a daily report, which includes extra hours worked and signed by supervisor for each employee. Some workers get free housing in the company’s houses Interviews confirmed that workers are well informed about near the plantation and the mill. They are connected with their contractual conditions. water supply and electricity. There is a medical service in each mill plant and the company organizes medical control Compulsory yearly or 6 monthly Medical checks, depending

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Doc_2_2_30_1_3_En once a year. The company supports public schools with on work to determine general health of all employees. financial support and school equipment. The labour union supports the employees with school material. Criterion 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 Summary of the findings for 6.6: Findings: Comments: Compliance The company is committed to ethical standard ETI. It is Minutes are kept of all meetings with trade unions. Yes publicly mentioned: There is no discrimination against being member of labour union. ETI expresses no limitation of freedom of association and negotiation. Included in training of personnel. The findings were confirmed through interviews with employees. Criterion 6.7: Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programmes. Children are not exposed to hazardous working conditions. Summary of the findings for 6.7: Findings: Comments: Compliance No child labour is tolerated. The company accepts people Interviews in the field with fruit pickers and supervisors Yes to work above 18 years old. See: Politica de Relaciones confirmed same information. laborales, 2011. Criterion 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. Summary of the findings for 6.8: Findings: Comments: Compliance The company is certified by ETI (Ethical standard). It The company has a policy of industrial relations MSIG 5.3 - Yes includes freedom of association and equal opportunity in 02. all its expression. It’s publicly made visible with a Poster. Recruit staff without any discrimination if they comply with the skills required for the job and current labor legislation.

Workers were interviewed for confirmation of no discrimination Criterion 6.9: A policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied. Summary of the findings for 6.9: Findings: Comments: Compliance There is a clear statement in the company rules of Evidenced in policy of labour relation: specifies the Yes prevention, prohibition and sanction in case of sexual reproductive rights. Also the company sticks to the Human harassment and discrimination in the work place which rights. refers also to the state law 7476 and 8805. On many places in the company this information is visible and also explains how to proceed in case of a complaints.

The company established a complaint system with reception boxes in different places. They accept also anonymous complaints. Procedure is established and contains approaches, sites of reception, forms, who empty boxes, phone communication, option of complaint forms, procedures of analysis. Criterion 6.10: Growers and mills deal fairly and transparently with smallholders and other local businesses. Summary of the findings for 6.10: Findings: Comments: Compliance Associated farmers are aware about the prices as per Farmers are fully informed about pricing systems. Yes interview acknowledged. They also understand the Interviews confirmed. mechanism. All growers interviewed confirmed an understanding of the contract. Contractors also confirmed understanding. Interviews were also held with contractors supplying labour as mentioned above. Criterion 6.11: Growers and mills contribute to local sustainable development wherever appropriate. Summary of the findings for 6.11: Findings: Comments: Compliance Local communities are consulted with and evidence shown The company has extensive records of their work with Yes by way of records of meetings and photographs of those schools and local communities. meetings.

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Criterion 6.12: No forms of forced or trafficked labour are used. Summary of the findings for 6.12: Findings: Comments: Compliance Interviews shows no forced labour. All employees are No temporary or migrant workers. Yes informed about the contractual condition and sign a contract. Criterion 6.13: Growers and millers respect human rights. Summary of the findings for 6.13: Findings: Comments: Compliance Human right policy in place. It says Palma Tica is required to The policy is communicated on boards and included in Yes respect all aspects related to HHRR exposed in the training. Universal Declaration of HHRR from International Labour Organization relative to the fundamental Principals of work.

Principle 7: Responsible development of new plantings. Summary of the findings for principle 7: Criterion 7.1: A comprehensive and participatory social and environmental impact assessment is undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management and operations Summary of the findings for 7.1: Findings: Comments: Compliance NPP for replanting rice with oil palm. The NPP was announced NPP was prepared in accordance with RSPO Yes on RSPO website on 17/12/2013, and approved afterwards. requirements. The SEIA was conducted by Bioterra and the consultant is an RSPO approved assessor. Meetings are all recorded. Criterion 7.2: Soil surveys and topographic information are used for site planning in the establishment of new plantings, and the results are incorporated into plans and operations Summary of the findings for 7.2: Findings: Comments: Compliance Alluvial soils predominate. Surveys were carried out and Level ground. No steep slopes. Yes recorded. Criterion 7.3: New plantings since November 2005 have not replaced primary forest or any area containing one or more high Conservation Values Summary of the findings for 7.3: Findings: Comments: Compliance Previous land use, bananas to rice for 40 years plus. All HCV identified was left untouched. Yes Only positive effect for employment opportunities. Criterion 7.4: Extensive plantings on steep terrain, and/or on marginal and fragile soils, are avoided. Summary of the findings for 7.4: Findings: Comments: Compliance No marginal or peat soils. Yes Criterion 7.5: No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their own representative institutions Summary of the findings for 7.5: Findings: Comments: Compliance Company land but local people were consulted and advised as Yes to the work planned. 7.6 Local people are compensated for any agreed land acquisitions and relinquishment of rights, subject to their free, prior and informed consent and negotiated agreements. Summary of the findings for 7.6: Findings: Comments: Compliance Company land but local people were consulted and advised as No legal, customary and user rights. Yes to the work planned. Criterion 7.7: Use of fire in the preparation of new plantings is avoided other than in specific situations as identified in the ASEAN guidelines or other regional best practices Summary of the findings for 7.7: Findings: Comments: Compliance No fire was used. Yes Criterion 7.8: New plantation developments are designed to minimise net greenhouse gas emissions. Summary of the findings for 7.8:

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Findings: Comments: Compliance Low carbon stock land. Alluvial soils. The company ensures good road maintenance and Yes endeavours to minimise the use of diesel fuel by planning roads for maximum efficiency. The replacement of rice with oil palm reduces the quantities of pesticides required significantly.

Principle 8: Commitment to continual improvement in key areas of activity. Summary of the findings for principle 8: Criterion 8.1: Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continual improvement in key operations Summary of the findings for 8.1: Findings: Comments: Compliance Continual improvement in the company is ensured by a system There is a yearly report by area indicating results. As an Yes composed of several documents and actions. There are weekly example there is the document denominated Informe meetings where all department managers and superintendents Anual de Coto 54. The document covers the following attend to analyse the productive indicators, monthly meetings to indicators: efficient consume of pesticides, reduction of review and discuss financial indicators and annual meetings to solid pollutants, diesel consumption (operational), review and discuss productive, financial and sustainability diesel consumption in irrigation, efficient energy indicators. During yearly meetings the new goals for indicators consumption, efficient water consumption, reduction are established. Responsibilities are established to monitor of gaseous pollutants, reduction of liquid pollutants, indicators and the responsibility relays on different positions strategic reforestation. Most of the mentioned depending on the indicator. indicators above show slight improvements in the last years. The following indicators had a positive performance: reduction of solid pollutants, reduction of gaseous contaminants and water consumption. The following indicators had a negative performance comparing 2014 to 2013 but shows values according to the goal value parameters: efficient consume of pesticides

RSPO Supply Chain Certification Supply Chain Module Module D – Identity Preserved Findings: Comments: Compliance Description Processing of FFB and the production of CPO and PK. The Mill manager has overall responsibility and was able to Yes demonstrate a full understanding of the SC requirements. As the entire supply base of oil palm has been audited for RSPO P&C compliance, it is expected that 100% of all FFB is RSPO certified, thus all PK will be 100% RSPO Identity Preserved. Stocks, inputs and outputs are reconciled in real time. Weekly, monthly and period reports are produced and a 3 month report is included. Internal audits are conducted every 12 months and an annual audit is reviewed by top management. Procedure: CIA-PR-23-01. Documented Procedures The General written procedures for the whole mill are Individual SOPs for all stations and specifically for PK Yes covered in a series of documents pre-fixed with: CIA-PR- crushing: CIA-PR-02-01 XX-XX. This SOP includes photographs and all procedures to produce This includes all practices in the mill including the PKO from PK. production of PKO. Purchasing and goods in Only FFB from approved suppliers. All FFB is from the supply base described above. Yes Record keeping Detailed records of daily production. One report, every day, for records of production: Yes CIA-FR-01-06 The FFB input. The oil extraction rate. The quality of the oil. Processing In accordance with SOPs. FFB in. CPO and PK out. The wholly integrated kernel Yes crushing plant was subject to a separate RSPO SCC audit, in accordance with the RSPO SCC Standard November 2014 requirements. Claims & Trademark use No use of Trademark. The RSPO claim on the CPO and PK is / will be IP in Yes accordance with the rules. MQ III IBD Revisão 16.03.2015 GED/DOCUMENTOS/MODELOS E REFERENCIAS/2-SETOR DE INSPEÇÕES/2_2-RELATÓRIOS DE INSPEÇÃO/2_2_30_1_3_En – RSPO P&C Public Summary Report Página 30 de 33

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4.2 Non conformity register. This section gives an over view of new or revised non-conformities raised during this assessment and of action taken to close out non-conformities raised during the previous assessments. Major non-conformities raised during a main assessment will prevent the certification body from making a positive certification decision for the concerned units/products. The NC number is comprised of 2 parts to include the year in which the NC is raised as well as a sequential number. 4.2.1 Verification of previous assessment non-compliances Non-compliance N/A. Date raised Major or Minor Reference of standard Full Correction at this audit Partial Not Corrected

4.2.2 New non-compliances raised at this audit NC number 2015/001 Date raised 18th March 2015. Major or Minor Minor. Reference of standard 4.6.4 Pesticides that are categorised as World Health Organisation Class 1A or 1B, or that are listed by the Stockholm or Rotterdam Conventions, and paraquat, are not used, except in specific Standard requirement situations identified in national Best Practice guidelines. The use of such pesticides shall be minimised and eliminated as part of a plan, and shall only be used in exceptional circumstances. Evidence of non-compliance The reduction plans for the use of paraquat needs a definitive target date. Date of closing:

NC number 2015/002 Date raised 18th March 2015. Major or Minor Minor. Reference of standard 5.2.3. There shall be a programme to regularly educate the workforce about the status of these RTE species, and appropriate disciplinary measures shall be Standard requirement instigated in accordance with company rules and national law if any individual working for the company is found to capture, harm, collect or kill these species. Evidence of non-compliance No Company rules relating to disciplinary measures. Date of closing:

NC number 2015/003 Date raised 18th March 2015. Major or Minor Minor. Reference of standard 5.2.4. Where a management plan has been created there shall be ongoing monitoring: Standard requirement • The status of HCV and RTE species that are affected by plantation or mill operations shall be documented and reported; • Outcomes of monitoring shall be fed back into the management plan. Evidence of non-compliance There is no specific monitoring plan for HCV. Date of closing:

4.2.3 Observations Date raised None raised.

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4.3 Lead Auditor Recommendations for the RSPO Principles & Criteria certification.

Grant/ Renewal/ Extension*

Maintenance*

Suspension Refuse / Withdrawal

Certificate * Grant / Renewal / Extension / Maintenance, in the case of open Minor nonconformities, assumes that the nonconformities will be cleared as agreed OBS: The final decision whether the company will be granted with the RSPO P&C certification or not, shall rely upon the certification body, after reviewing the audit documentation and taking in account the lead auditor’s recommendation.

4.4 Comments for next audit. Stay overnight between Quepos and Coto to review oil palm operations in Palmer.

5. FORMAL SIGNING OF AUDIT FINDINGS

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6. Major non-compliances follow-up actions (exclusive use of IBD decision maker) Verification of effectiveness by:

Follow-up on-site audit: On-site review and evaluation of the introduction, implementation and effectiveness of non- compliance(s) correction and corresponding corrective actions.

Desktop audit: Document assessment of root cause analysis and evidence of corrections and corrective actions submitted to the certification body.

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