ROGUE

TRADERKeeping deforestation in the family 31 March 2018, PT Agrinusa Persada Mulia, 7°33'23.35"S 140°46'43.78"E ©Ifansasti/Greenpeace

Wilmar International Board. Photo from Wilmar's 2017 Sustainability Report. ‘Never in Martua’s and my wildest dreams did we expect Wilmar to become what it is today.’ 1 KUOK KHOON HONG, CEO, WILMAR INTERNATIONAL contents WILMAR INTERNATIONAL: WILMAR INTERNATIONAL IS A SUSTAINABILITY LEADER? 3 HIDING GAMA FROM ITS CUSTOMERS 20 MARTUA SITORUS: THE MAN GAMA AND WILMAR’S BEHIND WILMAR AND GAMA 3 MARKET LINKS 21 GAMA: GANDA AND MARTUA WILMAR AND GAMA: SITORUS’S FAMILY BUSINESS 4 ONE GROUP WITH TWO FACES 23 THE TANGLED WEB OF THE GROUP RESPONSE 24 WILMAR/GAMA EMPIRE 6 TIME FOR ACTION 27 CONCESSION CASE STUDY: PT PERKEBUNAN ANAK NEGERI PASAMAN ANNEX ONE: FULL RESPONSE (PT PANP), WEST KALIMANTAN 7 TO GREENPEACE FROM KUOK KHOON HONG AND ANDY INDIGO 30 WILMAR’S HISTORY OF SOCIAL CONFLICT 8 APPENDIX ONE: SITORUS FAMILY CONCESSION CASE STUDY: LINKS TO PALM OIL COMPANIES 36 PT ASIATIC PERSADA (PT AP)/PT BERKAT SAWIT UTAMA (PT BSU), JAMBI, REFERENCES 38 BATANGHARI AND MUARO JAMBI DISTRICTS 9 ENDNOTES 41 WILMAR’S TRADE ENABLES GAMA’S BIBLIOGRAPHY 44 RAINFOREST DESTRUCTION 10 CONCESSION CASE STUDY: PT GRAHA AGRO NUSANTARA (PT GAN), WEST KALIMANTAN, KUBU RAYA DISTRICT 12 CONCESSION CASE STUDY: PT AGRIPRIMA CIPTA PERSADA(PT ACP), PAPUA, MERAUKE DISTRICT 15 CONCESSION CASE STUDY: PT AGRINUSA PERSADA MULIA (PT APM), PAPUA, MERAUKE DISTRICT 16

1 Wilmar International is the world’s largest palm oil trader. Gama is one of the world’s largest palm oil producers. The two companies were co-founded by the same man, Martua Sitorus, and members of his family control both Gama and Wilmar’s Indonesian operations. According to Indonesian government regulations and the membership criteria of the Roundtable on Sustainable Palm Oil (RSPO), they should be considered as one group, given the strong evidence of overlapping management and control. Although Wilmar adopted a ‘no deforestation, no peat, no exploitation’ (NDPE) policy in December 2013, Gama has no such policy and continues to clear rainforest and violate the rights of communities across Indonesia. Gama has cleared over 21,500ha of forests and peatland since Wilmar announced its NDPE policy – an area twice the size of Paris. Much of this clearing took place in Papuan concessions originally established by Wilmar managers. Wilmar’s Indonesian operations and Gama work as a family business. Wilmar protects Gama from market pressure and public scrutiny while trading its palm oil to companies all over the world – trade that funds Gama’s continuing expansion and deforestation.

26 March 2013, PT Agriprima Cipta Persada ©Rante/Greenpeace

2 ‘We can produce palm oil in a way that protects forests, clean air and local MARTUA SITORUS: THE MAN communities, all while contributing BEHIND WILMAR AND GAMA to development and prosperity in Kuok founded Wilmar in 1991 with his business partner, palm oil growing regions. We know Martua Sitorus.10 Indeed, ‘Wilmar’ is an amalgamation of its from our customers and other founders’ first names – WILliam and MARtua.11 stakeholders that there is a strong In addition to Wilmar, Kuok and Sitorus have collaborated and rapidly growing demand for on a number of other investments, notably in the fields of property and energy, either directly or through their traceable, deforestation-free palm respective offshore companies HPRY Holdings Ltd and oil, and we intend to meet it as a core Burlingham International.12 2 element of our growth strategy.’ Until very recently, Kuok and Sitorus ran Wilmar together. KUOK KHOON HONG, CEO, WILMAR INTERNATIONAL According to statements by the company, Kuok is ‘overall in charge of the management of the Group with a particular focus on new business developments’,13 while Sitorus was ‘instrumental in the development of the Group’s business WILMAR INTERNATIONAL: operations in Indonesia’.14 A SUSTAINABILITY LEADER? Martua Sitorus has been on Wilmar’s board since the company went public in 2006.15 He was Executive Director/ Wilmar International Limited is the world’s largest Chief Operating Officer until June 2013, when he stepped palm oil trader.3 In December 2013, it adopted an down to ‘focus more time on his family business’.16 He then NDPE policy that applied both to its own operations served as Executive Deputy Chairman in charge of Wilmar’s as a producer and to those of its suppliers.4 The operations in Indonesia and its plantation operations17 until policy’s comprehensiveness and ‘credible plan for he stepped down in March 2017, again to ‘focus his attention implementation’ were hailed by its implementation on his family business’.18 He remains on Wilmar’s board of partner, The Forest Trust.5 directors as a non-independent non-executive director. The public face of Wilmar International is its CEO and Wilmar is not the only business to bear Sitorus’s name. Chairman, Kuok Khoon Hong. Kuok, often known by his Together with his brother Ganda (who goes by this single nickname William,6 is one of the richest men in Singapore.7 name), Martua Sitorus established the Gama group – an At the end of 2017, Wilmar had a total planted area amalgamation of GAnda and MArtua – in 2011. Sitorus’s of 239,935ha of oil palm, around 68% of which was in profile on Wilmar’s website describes him as ‘the CEO of Indonesia, 24% in Malaysian Borneo and 8% in Africa.8 Gama Corp group of companies’,19 presumably the ‘family In November 2017, Wilmar became the first company business’ that was referred to each time his role changed. in the palm oil industry to take a loan with an interest rate Sitorus is not the only person to have a hand in both pegged to its sustainability efforts.9 Wilmar and Gama. In fact, members of Ganda’s and Martua Sitorus’s family20 control Wilmar’s Indonesian operations and decide which companies in Indonesia Wilmar International trades with. The same people and their close relatives also own or manage Gama companies.21 Gama appears to be pursuing a deliberate strategy of using Wilmar to advance the family’s business interests. Hendri Saksti, brother-in-law of Ganda and Martua Sitorus,22 is Wilmar International’s Country Head for Indonesia.23 Saksti is also the majority shareholder of oil palm plantation company PT Agro Alam Nusantara,24 reportedly managed by Gama,25 and is Commissioner of PT Tritunggal Sentra Buana,26 a plantation company that was 50% owned by Wilmar until it was sold to Gama in May 2018 (see below). He is also Commissioner of Katingan Timber Celebes,27 part of Katingan Timber Group, another Gama company. Darwin Indigo, Ganda’s son and Sitorus’s nephew,28 is another family member holding key management positions in Wilmar and Gama. He is Wilmar International’s Deputy Country Head for Indonesia and General Manager with responsibility for trading in Indonesia.29 Within Gama, he is a director of the group’s joint venture with Samsung C&T Corporation.30 Darwin’s brother, Andy Indigo,31 controls Gama’s Indonesian plantations.32

3 GAMA: GANDA AND MARTUA Map of operations from a July 2015 General Update by PT SITORUS’S FAMILY BUSINESS Agro Mandiri Semesta

Unlike the formally structured Wilmar, the Gama Tjahjanto are Commissioner and Director of most of these side of Sitorus’s empire follows the loose structure holding companies;38 immediate family including Bertha, favoured by many Southeast Asian family-based Clement Zichri Ang, Clifford Herbert Theodore, Clifton corporations and corporate groups and does not have a Herbert Theodore, Darwin Indigo, Felix Vincent Ang, single parent entity. Ganda, Hendri Saksti, Jacqueline Sitorus, Mutiara and Tjhin Gama is a collection of plantation assets owned or Ten Chun all have senior management roles in at least one managed by members of Ganda’s and Martua Sitorus’s other. 39 This means the family and their employees remain family. Other names include the Ganda Group, Agro in control despite the restructuring. Mandiri Semesta (AMS) Ganda Group or AMS Group. Gama – via PT GSU and an offshore holding company Between late 2016 and late 2017 a comprehensive – also holds a 40% stake in two other plantation restructuring of the group took place, which saw companies in a joint venture with Samsung C&T the majority of Gama’s family-owned assets moved Corporation.40 Another Gama company, PT Sawit Unggul offshore. Prior to this, at least 21 plantation companies Agro Niaga, operates a palm oil mill in East Kalimantan.41 had been clearly controlled by the families of Ganda, Despite Gama not having a single ultimate holding Martua Sitorus and their three sisters Bertha, Mutiara company, it is important to stress that it is managed and and Thio Ida. Many of these plantation companies operated as a group. It has a group logo and personnel were owned by two key holding companies, PT Ganda recruitment takes place at the group level.42 Sawit Utama (PT GSU) and PT Agro Mandiri Semesta Reports in local newspapers state that a Gama-owned (PT AMS).33 Since the restructuring PT GSU’s role in company called PT Energi Unggul Persada has been in the group has been significantly reduced, with just negotiations to obtain land for refineries in three separate one working plantation subsidiary and three other locations in Indonesia – Bontang in East Kalimantan,43 concessions that are not believed to be currently Batam in the Riau Islands44 and Sungai Limau in West developing oil palm plantations; PT AMS retains only Kalimantan45 – although Gama is not known to have minority stakes in a few companies.34 made any public statement of its intent to build its own While a handful of concessions remain wholly owned by refineries. If these refineries are built without Gama the family,35 the majority of Gama’s plantation companies committing to an NDPE policy, they could represent a are now owned by one or more of ten holding companies significant new route to market for unsustainable palm oil. registered offshore, largely in the British Virgin Islands.36 Gama is also reportedly involved in negotiations for Their beneficial owners are therefore obscured. However, the purchase of a stake in FELDA Global Ventures (FGV),46 the immediate parents of nearly all the plantation the international trading division of the Malaysian companies are holding companies registered in Indonesia.37 government’s Federal Land Development Authority Ganda’s son Andy Indigo and Gama executive Riadi Didik (FELDA). FGV has denied these rumours.47

4 ‘Gama Group or Gama Corp is not a legal entity. It is a name given to a group of companies owned by Mr Ganda and his brother, Mr Martua Sitorus.’ FAX TO GREENPEACE FROM KUOK KHOON HONG, 20 JUNE 2018

Business partners

kuok Khoon Hong martua sitorus

UNCLE & BROTHERS NEPHEW -IN-LAW BROTHERS UNCLE & NEPHEW BROTHERBROTHERSS -IN--IN-LALAW

HENDRI SAKSTI GANDA FATHER & SON UNCLE & FATHER NEPHEWW & SON UNCLE & NEPHEW

BROTHERBROTHERS

DARWIN INDIGO ANDY INDIGO

5 13 September 2013, PT Jatimjaya Perkasa, 1°55'55.41"N 100°49'33.19"E ©Tambunan/Greenpeace

THE TANGLED WEB OF THE WILMAR/ GAMA EMPIRE

Wilmar and Gama are portrayed by the Sitorus family Martua Sitorus helped establish and manage PT Karya and company management as two entirely independent Prajona Nalayan (PT KPN).49 PT KPN subsequently entities. Yet the two groups are clearly enmeshed, at became part of Wilmar International. Other examples of least within Indonesia, to the point where it is difficult management crossover between Wilmar and Gama are to see where Wilmar’s Indonesian operations stop and considered below. Gama’s start (and vice versa). Several Gama companies Further, the Wilmar side of the business has a – and Wilmar’s Indonesian head office – were until history of avoiding dealing with serious human rights recently based in the same building, Multivision Tower or environmental violations in its concessions by selling in Jakarta, albeit on adjacent floors.48 the problematic concessions to Gama. For example, PT In addition to the very close family ties already Jatimjaya Perkasa, in northern Riau, started out as a Wilmar mentioned, executives from one side of the business concession;50 it was sold to Gama in 200551 following NGO often establish and/or manage companies and reports of deforestation.52 plantations belonging to the other. For example, As a result, Gama has been described as ‘a clearinghouse according to an audit by the World Bank Group’s for troublesome Wilmar subsidiaries that could be a threat to Compliance Advisor/Ombudsman, both Ganda and the publicly traded corporation’s reputation’.53

6 CONCESSION CASE STUDY: PT PERKEBUNAN ANAK NEGERI PASAMAN (PT PANP), WEST KALIMANTAN

INDONESIA

KALIMANTAN

Offshore ownership: HPR Investments Ltd (34%), Bonoto Investments Ltd (33.5%), Festive Investments Ltd (17.5%), Silvery Ltd (9%)

Current management: Andy Indigo, Chusnul Nurtjhaha, Hendri Saksti, Riadi Didik Tjahjanto

One example of the blurred lines between the two sides of the empire is PT PANP, a plantation company with two concessions in West Kalimantan. It was established in 2008 by Kuok Khoon Hong (Chairman), Martua Sitorus (Commissioner), Ganda (Director), Hendri Saksti (Director) and Wilmar’s Head of Plantations, Guh Ing Sing (President Director).54 From the outset PT PANP was majority- owned by four offshore holding companies, two of which together currently hold a majority stake: one of these, HPR Investments Ltd, is linked to and reportedly co-owned by Kuok55 and the other, Bonoto Investments Ltd, is linked to and reportedly co-owned by Sitorus.56 In 2009, Kuok, Guh, Saksti and Sitorus left the company (although Kuok’s and Sitorus’s offshore companies retained their majority stake); Ganda and his son Andy Indigo ran the business as Chairman and Director until December 2015, when there was a change of management.57 The board structure changed again in March 2018, when Andy Indigo, Hendri Saksti and Chusnul Nurtjhaha, 58 Head of Plantations at AMS Ganda Group, took control Summary registry documents of the company. Throughout these management changes, for PT Perkebunan Anak Negeri Pasaman show historic shared PT PANP has remained majority-owned by Kuok’s and management by members of 59 Martua Sitorus's family and Sitorus’s offshore companies. Kuok Khoon Hong. Silvery Ltd The company’s two Kalimantan concessions were remains one of the offshore holding companies, obscuring included on a 2015 AMS Ganda Group spreadsheet ultimate beneficial ownership. obtained by Greenpeace.60 LinkedIn profiles of staff working on the plantations in Kalimantan also refer to AMS Group.61 The facts seem clear: PT PANP is owned by Kuok and Sitorus and operated by Gama.

7 Wilmar’s history of social conflict

Despite being one of the first palm oil companies to adopt the police mobile brigade shot and wounded two an NDPE policy, Wilmar still has an unresolved legacy of farmers within the concession,65 after local people had exploitation and social conflict. gone to the company offices to demonstrate about PT Bumi Sawit Kencana II, a Wilmar concession the land issue.66 in Central Kalimantan, has reportedly been at the Wilmar also faces serious allegations of worker centre of a land conflict for more than a decade, with exploitation by its plantation companies. In November repeated violence towards local residents.62 In 2013 2016 Amnesty International reported systematic abuses clashes broke out with company security guards after in the North Sumatra estates of PT Perkebunan Milano residents protested against the construction of a canal and PT Daya Labuhan Indah, including unrealistic targets which would have cut off access to the disputed land. that resulted in excessive workloads and led to employees’ Four community members were injured.63 In June children helping with dangerous tasks on the plantation.67 2016, villagers submitted a formal complaint to the In April 2017, SOMO and CNV International investigated RSPO – so far unresolved – claiming that the company labour issues in PT Murini Sam Sam’s concession in Riau had taken 78ha of their land without compensation.64 and found many workers in insecure employment, along Most recently, on 19 December 2017, members of with evidence pointing to forced labour.68

15 January 2015, Jambi, 1°56'13.999"S 103°17'30"E: The Suku Anak Dalam community was forcibly evicted from its traditional lands by armed security forces, including police officers, security and staff of PT Asiatic Persada on 11 December 2013. ©Rante/Greenpeace

8 CONCESSION CASE STUDY: 12 January 2014, Jambi, 1°56'7.999"S 103°16'52.999"E: A father and his young daughter, members of the community evicted from its traditional lands within PT Asiatic Persada. PT ASIATIC PERSADA ©Rante/Greenpeace (PT AP)/PT BERKAT SAWIT UTAMA (PT BSU), JAMBI, BATANGHARI AND MUARO JAMBI DISTRICTS

INDONESIA

JAMBI, SUMATRA

Offshore ownership: Fullest Holdings process that had been ongoing between Wilmar and the Limited (53%), Rise Glory Interprises 78 Limited (10%), Silvery Limited (10%) community. Just eight months after the sale, hundreds of indigenous families were violently evicted from their Direct parent: PT Perkebunan Prima homes within the concession by police and military – action Manunggal (95%) allegedly paid for by PT AP to clear the land of people.79 Current management: Andy Indigo (PT PPM); After the 2013 sale, Wilmar claimed to ‘no longer Dinar, Halim Gozali, Djuaman purchase FFB or [crude palm oil]’ from PT AP/BSU.80 In 2016, it stated that it ‘would not accept oil from PT Asiatic Persada entering our supply chain’,81 indicating that it had PT AP, renamed PT BSU in December 2016,69 is a excluded the company, presumably because of the human plantation company in Jambi formerly owned by Wilmar70 rights violations that had started under Wilmar’s control and involved in a protracted land conflict with the Suku and continued under Gama’s. Anak Dalam indigenous group.71 Wilmar treated PT AP/BSU as an isolated plantation In February 2011, Forest Peoples Programme (FPP) company instead of one connected to Gama, whose oil it and community members brought a complaint against has continued to trade (despite claims to the contrary – Wilmar and PT AP to the RSPO.72 Later that year, FPP see below).82 reported that the Indonesian military, in partnership with PT BSU is now owned by PT Perkebunan Prima PT AP, had ‘systematically evicted people from three Manunggal (PT PPM – 95%) and PT AMS (5%).83 PT settlements, firing guns to scare them off and then using PPM is managed by Andy Indigo84 and currently owned heavy machinery to destroy their dwellings and bulldoze by offshore companies connected to the family; it was concrete floors into the nearby creeks’.73 owned by Andy Indigo and Jacqueline Sitorus through a In 2013, Wilmar sold PT AP to Prima Fortune complex shell structure until ownership was transferred International and PT AMS,74 both Gama companies.75 Wilmar, offshore in September 2017.85 however, was strangely coy, its Sustainability Report stating PT AP/BSU is not the most recent instance of Wilmar simply that it had ‘made a commercial decision to divest offloading a problematic plantation company to Gama. all shareholdings in PT Asiatic Persada to an Indonesian In 2013, the World Wildlife Fund documented Wilmar company, Prima Fortune International Limited’,76 with no subsidiary PT Citra Riau Sarana (PT CRS) receiving oil palm mention that that company was owned by Gama. The RSPO fresh fruit bunches (FFB) from illegally cleared land within rightly noted these companies were part of Gama, and that the Tesso Nilo National Park in Riau.86 because several Gama companies were RSPO members, The following year, Wilmar sold a majority stake in PT the group as a whole should abide by the RSPO’s Code of CRS to PT Wahana Agro Penjasakti, a Gama87 company Conduct. It wrote to PT AMS to request their continued with an offshore owner, Team Ventures Investments Ltd.88 involvement in the mediation process, acknowledging an Under Gama, PT CRS continued to purchase illegal FFB,89 apparent prior commitment by Gama to do so.77 and according to its most recent supply chain information Yet soon afterwards, Gama withdrew from the mediation Wilmar continued sourcing from PT CRS.90

9 'Although Mr Hendri Saksti and Mr Darwin Indigo are senior executives of the Wilmar Group …The fact that they are relatives of Mr Sitorus, does not mean that Gama Corp exercises management control over Wilmar.' FAX TO GREENPEACE FROM KUOK KHOON HONG, 20 JUNE 2018

In recent years, the broader Wilmar International group, led by Kuok, has focused on expansion into Wilmar’s trade new commodities and regions. Meanwhile, Sitorus and family – notably his brother-in-law Hendri Saksti and nephew Darwin Indigo – have assumed control enables Gama’s over Wilmar’s Indonesian operations, which are being run in the interests of Gama, their family business. rainforest Wilmar International continues trading palm oil from Gama’s plantations despite its violations of Wilmar’s NDPE policy, thereby ensuring a continued market destruction for Gama’s palm oil as the company expands into new areas. Over 21,500ha of rainforest have been destroyed in Gama concessions since Wilmar announced its NDPE policy at the end of 2013,91 more than half of it in the cases examined in this report. Not only has Wilmar helped provide Gama with the trade that bankrolled this destruction, but two of the three concessions in the cases outlined below were established by Wilmar employees.92 All three concessions were owned or managed by Andy Indigo or his father Ganda during the period in which much of the clearance took place.93

10 31 March 2018, PT Agrinusa Persada Mulia, 7°31'2.754"S 140°44'24.012"E ©Ifansasti/Greenpeace

31 March 2018, PT Agrinusa Persada Mulia, 7°32'31.655"S 140°47'52.596"E ©Ifansasti/Greenpeace

11 CONCESSION CASE STUDY: PT GRAHA AGRO NUSANTARA (PT GAN), WEST KALIMANTAN, KUBU RAYA DISTRICT

INDONESIA

KALIMANTAN

FEBRUARY 2014 SEPTEMBER 2017

Concession boundary based on March 2014 plantation 0 1 2 3 4 5KM Mosaic of satellite business permit (Izin Usaha Perkebunan; IUP) map from imagery: Landsat 8 (USGS), Kubu Raya district government and information from 0 1 2 3 4 5M Planet Labs Inc and local sources.94 Scale 1:300,000 GoogleEarth.

12 13 December 2013, PT Graha Agro Nusantara, 0°12'18.698"S 109°40'32.66"E: ©Ifansasti/Greenpeace

13 September 2015, West Kalimantan: A baby orang-utan rescued from Gama's PT GAN oil palm concession following extensive forest and peatland fires. ©Nanda/Greenpeace

Offshore ownership: Capital Ocean disorientated baby orangutan – its mother was not found.98 Ventures Ltd (95%) Between January 2016 and December 2016, Direct parent: PT Prima Panca Lestari PT GAN cleared and/or planted around 1,500ha of (95%), PT Wahana Agro Indonesia (5%) peatland forest. Between January and September 2017, plantation blocks were marked out over more than Current management: Andy Indigo (PT PPL); 1,200ha of peatland forest in preparation for clearance. Chusnul Nurtjahja, Soemanto Sastro, Aerial photos from March 2018 confirm that ditches Sri Sampurno (PT GAN) have been dug in peatland forest.99 The new plantation blocks have been cut in areas PT GAN has been clearing in the Kubu Raya district of West released from the Forest Estate by former Forestry Kalimantan since at least 2013. Since 2014 the company Minister Zulkifli Hasan on 29 September 2014, his has cleared over 7,000ha of forest and peatland.95 final day as minister. On that same day he signed a Until December 2016, PT GAN was ultimately whole sheaf of permits releasing State Forest land for owned by Andy Indigo and Jacqueline Sitorus through development by various plantation groups; many of PT GSU; it is currently a subsidiary of one of Gama’s these permits were problematic and several of them main offshore holding companies, Capital Ocean broke the ministry’s own regulations.100 Ventures Ltd.96 The Indonesian government is reportedly taking The PT GAN concession overlaps with some 4,500ha law enforcement action against PT GAN for developing on of orangutan habitat.97 While some of this habitat remains, peatland,101 according to ForestHints, widely regarded as most of these forests have already been cleared and a ‘semi-official mouthpiece’ of the Indonesian Ministry of plantation blocks have been marked for clearance in the Environment and Forestry.102 remaining areas (see below). In September 2015, plantation PT GAN has recently opened a new palm oil mill within its workers inside the PT GAN concession reported finding a concession.103 It is not yet known whom it supplies.

13 31 March 2018, PT Agriprima Cipta Persada, 7°30'25.84"S 140°29'30.919"E: ©Ifansasti/Greenpeace

14 CONCESSION CASE INDONESIA STUDY: PT AGRIPRIMA CIPTA PERSADA (PT ACP), PAPUA, MERAUKE PAPUA DISTRICT

DECEMBER 2015 AUGUST 2017

Satellite Image December 2015 Satellite image August 2017 sources: source: Google Earth Google Earth and (Landsat 8) USGS Boundary concession: BPN-HGU

Offshore ownership: Fullest Holdings and Forestry gave permission to release a portion of its Limited (53%), Rise Glory Interprises concession that still lay within the Forest Estate.111 By October Limited (10%), Silvery Limited (10%) 2017, PT ACP had started cutting new plantation blocks in that Direct parent: PT Perkebunan Prima area. Forest clearance has continued in 2018.112 Manunggal (95%), PT Karya Agung Megah The concession, in the Muting area of Merauke district Utama (5%) in southern Papua province, is situated close to the Trans- Papua road which runs along the border with Papua New Current management: Andy Indigo (PT PPM); Chusnul Nurtjahja, Dani Mudoko (PT ACP) Guinea, an area with a heavy military presence. It lies within the ancestral land of the Marind ethnic group. Land conflict PT ACP appears to have originally been destined to be a Wilmar between PT ACP and the Mahuze Besar clan is reportedly company. It was established on 11 June 2008 by two men who ongoing,113 with claims that the company has not obtained were at that time managers of Wilmar subsidiary PT Wilmar the free, prior and informed consent (FPIC) of the whole Cahaya Indonesia.104 Furthermore, in April 2009, Wilmar clan for its clearing of the forest. PT ACP reportedly executives and the Governor of Jambi province reportedly signed claims to have obtained consent for development of the a memorandum of understanding to build a port in Tanjung Jabung collectively owned clan land based on the signature of Timur district, which was to be operated by PT ACP.105 one man, who has since died;114 significant areas of forest Less than a year later, plans had evidently changed: the belonging to the clan have already been cleared. company was issued with a location permit in Merauke,106 In 2015, the clan began erecting notices to signify that and four months later a majority stake in PT ACP was it had placed the land under sasi, a form of customary transferred to Fullest Holdings Ltd.107 Ganda was briefly law prohibition. Nevertheless, the company reportedly Commissioner of PT ACP in June 2010.108 continued to clear the land, removing the signs.115 In PT ACP now operates as a subsidiary of Gama holding company 2016, a representative of the military visited the clan PT PPM, which is owned by four different offshore companies, leader, who opposed the plantation, to inform him that a including Fullest Holdings Ltd, and managed by Andy Indigo.109 military cooperative was taking over the contract for land Between 2015 and 2017, PT ACP cleared 3,190ha of clearing.116 The clan refused to back down, however, and as of forest.110 In July 2017, the Indonesian Minister of Environment September 2017 no agreement had been reached.117

15 CONCESSION CASE STUDY: PT AGRINUSA PERSADA MULIA (PT APM), PAPUA, MERAUKE DISTRICT INDONESIA

PAPUA

Offshore ownership: Fullest Holdings DECEMBER 2015 Limited (53%), Rise Glory Interprises Limited (10%), Silvery Limited (10%)

Direct parent: PT Perkebunan Prima Manunggal (95%), PT Karya Agung Megah Utama (5%)

Current management: Andy Indigo (PT PPM); Chusnul Nurtjahja, Dani Murdoko (PT APM)

The ownership history for PT APM is almost identical to that of PT ACP. It was established on the same day in 2008 by the same two Wilmar managers.118 Ganda was also Commissioner for the same few weeks in June 2010. Like PT ACP, PT APM is currently a subsidiary of PT PPM, which is managed by Andy Indigo and controlled by Gama through a network of offshore companies.119 Between January 2016 and August 2017, PT APM cleared 2,500ha of forest. Forest clearing has continued in 2018.120 Concession boundary based December 2015 source: The PT APM concession is located on the land of the on location permit (Izin Google Earth Lokasi), reference SK No. Yei ethnic group, and there are clear indications that the 4, tgl 13-01-2010. company has not engaged in a responsible FPIC process with them. Several clans own land in Bupul village; when JANUARY 2018 the company approached them, some clans agreed to a concession while others rejected the company’s offer.121 The company reportedly continued to press individual members of these latter clans for signatures that it could use to claim consent has been given, without obtaining the consent of the whole clan. In the case of the Mandaljai clan, the company reportedly obtained the signature of the brother of the clan chief, who was himself opposed to development. In another case, a clan leader was reportedly pressured to sign a letter by two police officers who approached him while he was at Sunday mass.122 Such actions would be neither honest and open nor respectful of clans’ right to decide collectively whether to accept or reject a company’s offer. Nor would they be legal: the Papuan Special Autonomy Law (UU21/2001) states that any decision about customary land must be made by a decision-making council (musyawarah), in

recognition of the fact that customary rights (ulayat Satellite image rights) belong to the clan, in accordance with customary January 2018 source: Planet Labs Inc. law in the area, not to individuals.123

16 19 December 2017, PT Agrinusa Persada Mulia, 7°30'33.978"S 140°46'23.615"E ©Sukarno/Greenpeace

Detail image August 2017 source: Planet Labs Inc.

17 18 18 January 2014, PT Agriprima Cipta Persada, 7°24'30.821" S 140°30'41.652" E ©Ifansasti/Greenpeace

19 ‘With regard to the purchase of palm oil WILMAR INTERNATIONAL from companies suspected to be affiliated IS HIDING GAMA FROM with Gama Corp, we acknowledge that there should have been more stringent oversight ITS CUSTOMERS on the ownership verification process in respect of these companies by Wilmar. FAX TO GREENPEACE FROM KUOK KHOON HONG, 20 JUNE 2018

Wilmar International is Gama’s principal route to market and Plantations (Mauritius) Ltd. This means that Wilmar was trades its palm oil to companies all over the world. Gama passing on information that it must have known was false. mills124 – ie those owned or managed by Ganda and Martua Greenpeace wrote to Wilmar in May 2018 requesting an Sitorus and other members of their family – appear throughout explanation. By the time Wilmar replied, some two weeks the supply chains of Wilmar International and its customers, later, it claimed to have sold its stake in the company to including major brands and other palm oil traders. Achieve Goals Ltd,127 a company registered in the British However, Wilmar International insists that it ‘does not source Virgin Islands and nominally run by a procurement manager from Gama Plantations’.125 of PT AMS – at least according to his LinkedIn profile.128 Wilmar has chosen largely to ignore group-level Official registry profiles for PT TSB do not mention Achieve ownership in its supply chain data. It thus classifies the Gama Goals Ltd, but indicate that Wilmar’s share in the company mills from which it buys as unconnected to each other (and was transferred to Gama holding company PT PPM on 17 to Wilmar), even though Wilmar’s senior staff in Indonesia May 2018 – six days after Greenpeace’s inquiry. are members of Ganda and Martua Sitorus’s family and must Wilmar’s refusal to acknowledge that it sources palm know otherwise. oil from Gama leaves its customers unwitting recipients of Wilmar appears to be following Gama’s direction when dirty palm oil unless they or their implementation partners reporting ownership of the Gama companies from which it perform some modicum of due diligence. For example, buys. This approach allows Gama to hide in plain sight and evade Bunge Loders Croklaan’s traceability data (admittedly market pressure. wrongly) identifies Wilmar as the parent company of PT Greenpeace has obtained a copy of a letter from PT GSU to Citra Riau Sarana,129 even though Wilmar’s own data lists PT Wilmar dated 3 August 2015, which claims that PT Patiware, PT CRS as both the mill name and company name.130 Similarly, Alam Jaya Persada (PT AJP) and PT Jatim Jaya Perkasa [sic] are in their most recent mill lists Bunge Loders Croklaan and part of PT GSU. Wilmar has shown Greenpeace another letter Olam both list PT Patiware and PT Jatimjaya Perkasa from PT GSU dated 19 October 2017, which lists PT AJP, PT as suppliers; they both identify ‘Ganda’ as the parent Jatimjaya Perkasa, PT Tritunggal Sentra Buana (PT TSB) and PT company,131 even though Wilmar’s own traceability data TH Indo Plantations as subsidiaries of the company. fails to include accurate parent company information.132 However, of the companies mentioned in PT GSU’s letters, Indeed, when Greenpeace International wrote to brands in only PT AJP and PT Patiware were subsidiaries of PT GSU at the April 2018 to confirm which producers were in their supply time the relevant letters were written.126 chains, many failed to identify Gama at all. One company that Wilmar presented as being owned by PT When a supplier is neither transparent nor honest, GSU, on the basis of a letter from PT GSU itself, was not owned consumer companies seeking to implement their NDPE by PT GSU at all: in fact, PT TSB was 50% owned by Wilmar policies face additional, unnecessary challenges.

20 GAMA AND WILMAR’S MARKET LINKS

Wilmar International supplies palm oil to many of the General Mills reports sourcing from ADM (a Wilmar- world’s palm oil traders. Many brands buy palm oil related company).158 directly from Wilmar, as well as being supplied with Ferrero had been supplied by Olenex (an ADM-Wilmar it by these traders. joint venture) at least as recently as the second half of 2017, Greenpeace analysed the supply chain data133 of traders but has since ended that supply relationship.159 with publicly available traceability dashboards: AAK,134 Apical/Asian Agri,135 Bunge Loders Croklaan (previously BRANDS RECEIVING PALM IOI Loders Croklaan),136 Cargill,137 Golden Agri-Resources OIL FROM GAMA MILLS (GAR),138 Musim Mas,139 Olam,140 Sime Darby141 and Wilmar.142 According to public reporting, Colgate-Palmolive, General Greenpeace also analysed the most recent traceability Mills, Hershey, Kellogg’s, Mars, Mondelēz, Nestlé, PepsiCo, information that major brands have disclosed publicly: Procter & Gamble, PZ Cussons, Reckitt Benckiser and Colgate-Palmolive,143 Ferrero,144 General Mills,145 Hershey,146 Unilever all received palm oil from Gama mills in 2017. Kellogg’s,147 Mars,148 Mondelēz,149 Nestlé,150 PepsiCo,151 Procter & Gamble,152 PZ Cussons,153 Reckitt Benckiser154 TRADERS SUPPLIED BY and Unilever155 all make this information available.156 WILMAR INTERNATIONAL160 Analysis by Greenpeace revealed that almost all companies with Wilmar International as a supplier were being Traders that report sourcing from Wilmar include AAK, supplied palm oil from Gama mills, though some brands also Bunge Loders Croklaan, Cargill, IOI, KLK, Louis Dreyfus received palm oil from Gama mills via other traders/suppliers. Corporation, Mewah, Olam and Sime Darby. Brands that did not fully disclose their suppliers or mills First Resources, HSA/PIL and Keck Seng did not and thus whose relationship to Wilmar and Gama mills cannot respond to Greenpeace’s request for confirmation be confirmed include Danone, Johnson & Johnson, Kraft of their trading relationships. 157 Heinz, L’Oréal and Smucker’s. TRADERS RECEIVING PALM BRANDS SUPPLIED BY OIL FROM GAMA MILLS WILMAR INTERNATIONAL Of the traders with publicly available dashboards Brands that report sourcing from Wilmar include Colgate- containing supply mill information, AAK, Apical, Bunge Palmolive, Hershey, Kellogg’s, L’Oréal, Mars, Mondeléz, Loders Croklaan, Cargill, GAR, Musim Mas, Olam, Sime Nestlé, PepsiCo, Procter & Gamble, PZ Cussons, Reckitt Darby and Wilmar are identified as receiving palm oil Benckiser and Unilever. from Gama mills in 2017.

21 19 December 2017, PT Agriprima Cipta Persada, ‘A corporate group is a set of 7°31'3.618" S 140°30'36.264" E individuals or legal entities in the ©Sukarno/Greenpeace plantation sector that are connected to each other through ownership, management and/or financial links.’ 161 INDONESIAN MINISTRY OF AGRICULTURE, 2013 REGULATION ©Sukarno/Greenpeace

22 Wilmar and Gama: one group with two faces

Wilmar and Gama are two sides of the same coin – at least ‘Control means: within Indonesia. Sitorus has extensive investment ventures with both Kuok and Ganda. The very close family ties and (a) having management control management overlap make Gama and Wilmar’s Indonesian which includes the ability to direct, operations, and arguably Gama and Wilmar International, related parties,163 in the legal as well as the familial sense. The instruct or manage business activity pairing also satisfies the definition of a group enshrined in both or administration of an Entity whether Indonesian law164 and the RSPO’s membership rules.165 by having the ability to influence the Accordingly, brands, traders and the RSPO should board, management of an Entity through hold Wilmar accountable for what happens in Gama’s shareholding, stock ownership or by concessions. Indeed, it is the artificial gap between the two contractual or operational arrangement; that allows Sitorus and his family to continue profiting from deforestation without getting Wilmar’s hands dirty. (b) in accordance with whose directions, Wilmar International is keeping its customers in the dark instructions or wishes an Entity is about their exposure to deforestation by Gama, which accustomed or is under an obligation, is itself intimately connected to Wilmar. This deception whether formal or informal, to act undermines the efforts of Wilmar’s customers to implement their own NDPE policies properly. Meanwhile, for Sitorus in relation to a Parent’s direction, 162 and his family, it ensures that trade – and money – instructions or wishes.’ continues flowing from the global market to the Gama side RSPO MEMBERSHIP RULES 2016 of the empire. The question Wilmar must answer is whether this policy is being pursued with the full approval of Wilmar International CEO Kuok Khoon Hong – or whether Wilmar’s Indonesian operation, under the influence of Kuok’s longtime business partner, Martua Sitorus, has gone rogue and is being used by Sitorus and his relatives to further their own business interests. Either way, companies trading with Wilmar cannot let this deceit go unchallenged. The palm oil industry in general – and consumer brands in particular – continues to treat instances of deforestation as the exception, not the norm. But as this case shows, the industry is rotten at the core. If companies are to comply fully with their NDPE policies by 2020, there must be radical reform of the global palm oil trade.

23 Group response Prior to publishing this report, Greenpeace wrote to Gama, Wilmar International and named individuals to offer them an opportunity to comment on these findings. Full copies of the responses received can be found in Annex 1.

KUOK KHOON HONG, Indeed, Kuok admits that Wilmar failed to identify the WILMAR CEO extent of Gama operations, that ‘there should have been more stringent oversight on the ownership verification It is clear from his response that Wilmar CEO Kuok process’ and that Wilmar still does not know which companies Khoon Hong wishes to dissociate Wilmar from Gama, but are part of Gama: ‘we are still awaiting the specific list of remains unaware (or in denial) of the gulf between what companies within Gama’. Wilmar is doing and what needs to happen to finally break Given that Gama is not the only problematic producer the group’s ties to deforestation – something he first group in Wilmar’s supply chain, it is reasonable to fear that promised to do in 2013. Wilmar has similarly failed to perform due diligence on many Kuok acknowledges that ‘Gama’ is the informal name other suppliers. given to the group of companies controlled by Sitorus and Kuok’s claim that ‘we purchased oil only from companies family. He acknowledges that senior executives within who are in compliance with our [NDPE] policy’ is factually Wilmar are members of the Sitorus family and also control incorrect. It suggests Wilmar’s CEO remains unaware of the Gama palm oil companies. scale of the problem his company faces and reluctant to He does not acknowledge that this overlap poses a conflict implement the profound supply chain reforms needed to of interest – even though individual senior executives within meet market demand for NDPE palm oil by 2020. Wilmar hold positions with responsibility for deciding which Kuok concludes with a commitment that Wilmar will not Indonesian companies supply the oil Wilmar trades. ‘buy from any company that cannot prove to our satisfaction Kuok helpfully acknowledges that Wilmar’s failure to that they do not belong to Gama’. While this action is implement its NDPE policy led it to trade palm oil from Gama necessary, it is inadequate. despite Gama’s involvement in deforestation. He commits to If Wilmar is serious about sustainability, it must not establish and chair an NDPE Action Committee ‘to take and buy from any producer group that cannot prove it is not review decisions about suppliers’. destroying forests. The first step is to require full disclosure However, as this case shows, Wilmar still fails to monitor from all suppliers of which companies are under their its suppliers across all of their operations – especially control, including publication of maps for every one of concessions in frontier areas from which it does not yet their concessions, and to exclude those that refuse to be source – to determine whether they comply with its policy or transparent. are destroying forests. Greenpeace stands by the findings of this report.

24 ‘In order to be absolutely sure that that [sic] there is no violation of Wilmar’s NDPE policy, we have decided to cease sourcing from all the companies that we have a commercial relationship with that are allegedly associated with Gama Corp as listed in your letter, with immediate effect, until we receive satisfactory confirmation of ownership information. Wilmar will commit not to buy from any company that cannot prove to our satisfaction that they do not belong to Gama Corp.’

FAX TO GREENPEACE FROM KUOK KHOON HONG, 20 JUNE 2018

ANDY INDIGO, GAMA PLANTATION Andy Indigo’s response on 20 June 2018, on behalf of Gama, is less revealing. The letter, on ‘Gama Plantation’ headed paper, represents Gama as a group. However, Andy Indigo ignores Greenpeace’s request for a complete list and maps of Gama’s palm oil operations. Andy Indigo appears to commit to an NDPE policy, but provides no substance. He lists 20 plantation companies that will adhere to a ‘moratorium on land clearing and NDPE policy.’ This is only just over half of the Gama plantation companies and other operations that Greenpeace has identified. Notably, the list does not include the two Papuan concessions where Greenpeace documented clearance in April 2018, PT Agriprima Cipta Persada and PT Agrinusa Persada Mulia. In fact, while the 20 concessions make up three- quarters of Gama’s identified landbank (some 280,000ha), they contain just 11,000ha of forest. By contrast, the concessions not covered by the ‘moratorium’ or NDPE policy, covering approximately 100,000ha, contain almost 30,000ha of forest. In other words, Andy Indigo is offering to end deforestation – but mainly in concessions that have no forest left to clear. Greenpeace stands by the findings of this report.

25 10 November 2008, Dumai: Greenpeace activists block a tanker loaded with 27,000 metric tonnes of crude palm oil destined for Wilmar's refineries in The Netherlands. The action calls for an end to deforestation and peatland destruction for palm oil. ©Novis/Greenpeace

20 October 2013, PT Agrindo Indah Persada, 1°53'53.5"S 102°4'31.3"E: Greenpeace activists challenge Wilmar after documenting deforestation of tiger habitat in its PT AIP concession in Jambi. ©Hilton/Greenpeace

26 Companies must start by taking control of their supply chains, with robust monitoring of producer groups and a clear protocol for handling non-compliant suppliers. A fuller description of the actions companies must take is contained in Greenpeace’s Moment of Truth report.166 TImE Given the scale of deception outlined in this report, traders and brands have no choice but to suspend all trade with companies controlled by Martua Sitorus and his family, including Wilmar, Gama and the various mills and plantations under their control. Trade should remain suspended until Wilmar addresses the for violations of its NDPE policy, by:

• taking responsibility for all deforestation and peatland clearance in Gama concessions after 5 aCtiOn December 2013; • publishing a timebound plan to restore all areas developed in violation of Wilmar’s NDPE policy;

• assuming operational control of the relevant Gama concessions to ensure compliance with this restoration plan and Wilmar’s NDPE policy;

• publishing concession maps for all producer groups within its supply chain, as a first step towards only trading palm oil from producer groups that have been independently verified as compliant with its NDPE policy by 2020.

27 19 December 2017, PT Agrinusa Persada Mulia, 7°28'24.024"S 140°45'35.273"E: ©Ifansasti/Greenpeace 28 29 Annex one: full response to Greenpeace from Kuok Khoon Hong and Andy Indigo

30 KUOK KHOON HONG'S RESPONSE

31 32 33 33 34 ANDY INDIGO'S RESPONSE

35

ULTIMATE HOLDING Family Family Family Family Family Family Family Family Family Family Prime Ltd Track Prime Ltd Track Family Capital Ocean Ventures Fullest Ltd, Interprises Glory Ltd,Rise Holdings Ltd, Silvery Ltd Family Family Capital Ocean Ventures Ltd Family Athena City Holdings Ltd Family Family Family Capital Ocean Ventures Ltd, VenturesTeam Investments Ltd' Ltd Silvery Family Gama Xs Family Capital Ocean Ventures, Family Family Family Capital Ocean Ventures Fullest Ltd, Holdings Rise Ltd, Glory Interprises Family Silvery Ltd, Ltd, Capital Ocean Ventures Fullest Ltd, Holdings Rise Ltd, Glory Interprises Ltd, Silvery Ltd Family Other (minority) Family, Gama Xs Family, Family

X X HENDRI HENDRI SAKSTI THIO IDA

X CLIFTON HERBERT THEODORE

X CLIFFORD HERBERT THEODORE

X BERTHA

X X X FELIX VINCENT ANG

X X X X CLEMENT CLEMENT ANG ZICHRI

X TJHIN TEN CHUN

X MUTIARA X DARWIN INDIGO

X X X X X X X X X X X X X X X X X X ANDY INDIGO X X X X X X X X X GANDA X X X SITORUS FAMILY LINKS TO PALM OIL HOLDING COMPANIES OIL HOLDING PALM TO LINKS FAMILY SITORUS ACKNOWLEDGED BY ASANDY PART INDIGO OF THE GAMA GROUP FAMILY LINKS TO PLANTATION AND OTHER OPERATIONAL COMPANIES OPERATIONAL OTHER AND PLANTATION TO LINKS FAMILY COMPANY PT Agri Indigo Pratama PT Agro Ganda Indigo PT Agro Mandiri Semesta PT Ganda Indigo Nusantara PT Ganda Sawit Utama PT Ganda Tambang Pratama PT Ganda Wahana Cakrawala PT Ganda Wahana Dinamika PT Indigo Dinamika PT Indigo Sawit Utama Indopalm Plantation Pte Ltd PT Nusa Prima Energi Nusantara PT Adiperkasa PT Perkebunan Prima Manunggal PT Prakarsa Cakrawala Internusa PT Prima Panca Lestari S&G Biofuel Pte Ltd PT Semesta Buana Gemilang SumateraPT Teknindo PT Wahana Agro Indonesia PT Wahana Agro Pancasakti PT Wahana Gemilang PT Wahana Indigo PT Wahana Karya Agrinusa PT Wahana Perkebunan Indonesia PT Agri Sentosa Gandadigo ASG) (PT Persada Agrinusa PT Mulia APM) (PT PT Agriprima Cipta Persada ACP) (PT PT Agro Alam Nusantara PT Agro Lintas Nusantara PT Alam Jaya Persada APPENDIX ONE: SITORUS

36

Capital Ocean Ventures Fullest Ltd, Holdings Rise Ltd, Glory Interprises Family Silvery Ltd, Ltd, Capital Ocean Ventures Family Ltd, Capital Ocean Ventures Fullest Ltd, Holdings Rise Ltd, Glory Interprises Ltd, Silvery Ltd Family Capital Ocean Ventures Team Ltd, Ventures Investments Ltd, FamilySilvery Ltd, Capital Ocean Ventures Family Ltd, Athena City Holdings, Family Other (JV) Capital Ocean Ventures Family Ltd, FamilySilvery Ltd, Athena Other City Holdings, Family, (JV) Capital Ocean Ventures Family Ltd, Capital Ocean Ventures Family Ltd, Capital Ocean Ventures Fullest Ltd, Holdings Rise Ltd, Glory Interprises Ltd, Silvery Ltd Family Athena City Holdings Limited Family Family Capital Ocean Ventures Fullest Ltd, Holdings Rise Ltd, Glory Interprises Family Silvery Ltd, Ltd, Capital Ocean Ventures Ltd Gama Xs Family, Capital Ocean Ventures Family Ltd, Family Bonoto Investment Ltd Ltd Investments Festive HPR Investments Ltd Ltd Silvery (minority) Other Capital Ocean Ventures Ltd Family Family Family (minority) Other Capital Ocean Ventures Ltd Family Family Family Other (JV) Family (minority) Other Capital Ocean Ventures Ltd Family Prime Ltd Track Capital Ocean Ventures Ltd Fullest Holdings Ltd Rise Glory Interprises Ltd Ltd Silvery Family Other (JV) Capital Ocean Ventures Ltd Fullest Holdings Ltd Rise Glory Interprises Ltd Ltd Silvery Family Capital Ocean Ventures Ltd Family X X X X X

X X X

X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X PT Berkat Sawit AsiaticUtama (ex-PT Persada) PT Bumi Alam Sentosa PT Citra Mahkota PT Citra Riau Sarana PT Energi Unggul Persada GandaerahPT Hendana PT Graha Agro Nusantara PT Indokebun Unggul PT Inecda PT Intitama Berlian Perkebunan Intitama PT Perkebunan Prima PT Jammer Tulen PT Jatimjaya Perkasa PT Karya Agung Megah Utama PT Karya Palmalindo Abadi PT Maju Perkasasawit PT Nusa Jaya Perkasa PT Patiware PT Patiware Satu PT Perkebunan Anak Pasaman Negeri PT Putralirik Domas PT Rajawali Jaya Perkasa PT Sawit Unggul Agro Niaga PT Sentosa Asih Makmur SerdangPT Hulu PT Subur Sawit Platinum PT Swadaya Indopalma SumateraPT Unggul Makmur PT TH Indo Plantations PT Tritunggal Sentra Buana PT Wahana Karya MandiriSejahtera PT Wawasan Kebun Nusantara

37 References

38 Clockwise from opposite:

1 April 2018, Papua: Rainbow near the river Digul in southern Papua. ©Ifansasti/Greenpeace

26 March 2018, Merauke, 8°10'56.02"S 138°40'50.54"E: Primary forest near the river Digul in southern Papua. ©Ifansasti/Greenpeace

14 September 2013, Pangkalan Bun:Orphaned baby orang-utans at the Orangutan Foundation International Care Center in Central Kalimantan. ©Ifansasti/Greenpeace

39 40 Endnotes

1 Kuok KH (2016) ‘Who we are: Kuok Khoon Hong’ 26 Corporate registry profile 2 Wilmar International 14 Wilmar International website 27 Corporate registry profile Ltd (2013d) p1 ‘Who we are: Martua Sitorus’ 28 Infosawit (2017); see also 3 TFT Transparency Hub 15 Wilmar International website Singapore Exchange (2015b) website ‘Wilmar’ ‘Who we are: Martua Sitorus’ 29 Singapore Exchange (2015b) 4 Wilmar International Ltd (2013b) 16 See Wilmar International 30 S&G Biofuel Ltd. Source: 5 Wilmar International Ltd (2013d) annual reports, available at h t t p:// corporate registry profile. 6 Wealth-X website ‘Khoon Hong Kuok’ www.wilmar-international.com/ 31 Suara Pusaka (2018) 7 Forbes website ‘Profile: library/corporate-information/ 32 Corporate registry profiles Kuok Khoon Hong’ accordion-annual-reports/, and 33 Corporate registry profiles of PT 8 Wilmar International Wilmar International Ltd (2013a). Agro Alam Nusantara, PT Agro Lintas Ltd (2018b) p26 17 Wilmar International Nusantara, PT Alam Jaya Persada, 9 See Wilmar International Ltd & Ltd (2017a) p16 PT Berkat Sawit Utama, PT Bumi Alam ING Bank (2017). In June 2018 Wilmar 18 Sitorus was redesignated as Sentosa, PT Graha Agro Nusantara, announced a second loan linked to a non-independent non-executive PT Intitama Berlian Perkebunan, its sustainability performance: director on the Wilmar board as PT Intitama Perkebunan Prima, PT see Straits Times (2018). of 1 April 2017. Source: Wilmar Jammer Tulen, PT Karya Agung Megah 10 Wilmar International International Ltd (2017b). Utama, PT Maju Perkasa Sawit, PT Ltd (2017a) p3 19 Wilmar International website Nusa Jaya Perkasa, PT Patiware, PT 11 Suhendra (2016) ‘Who we are: Martua Sitorus’ Patiware Satu, PT Putra Lirik Domas, 12 For example, in 2011 Kuok and 20 Notably Hendri Saksti and PT Rajawali Jaya Perkasa, PT Sentosa Sitorus bought the Aviva Tower in Darwin Indigo; see below. Asih Makmur, PT Serdang Hulu, PT London (see White A (2015)), and as 21 Source: corporate registry Subur Sawit Platinum, PT Sumatera of 2012 both Kuok and Sitorus, along profiles. Citations in this report Unggul Makmur, PT Wawasan Kebun with HPRY Holdings and Burlingham refer to documents obtained by Nusantara and their parent companies International, were substantial Greenpeace in early June 2018. 34 Corporate registry profiles shareholders in Yanlord Land Group, a 22 Wilmar International Ltd (2011) p2 35 Corporate registry profiles Shanghai-based property development 23 Wilmar International 36 Corporate registry profiles list company (see Yanlord Land Group Ltd Ltd (2018b) p24 Athena City Holdings Ltd, Bonoto (2013) p123). As of 2012, both Kuok and 24 Corporate registry profiles Investments Ltd, Capital Ocean Sitorus were involved in Australia’s show Hendri Saksti owns 95% of PT Ventures Ltd, Festive Investments Ltd, Whitehaven coal mine through their Semesta Buana Gemilang, which owns Fullest Holdings Ltd, HPR Investments holding companies (see Conde J (2012)). 65% of PT Agro Alam Nusantara. Ltd, Prime Track Ltd, Rise Glory 13 Wilmar International website 25 Pontianak Post (2016) Interprises Ltd, Silvery Ltd and Team

41 Ventures Investments Ltd. Wilmar also 55 Kuok Khoon Hong has declared period January to December 2017: Wilmar refers to Achieve Goals Ltd as the new an interest in HPR Investments Ltd, International Ltd (2018c,d,e,f,g). owner of one company (PT Tritunggal which holds a 34% stake in PT PANP. 83 SOMO (2017) p13 Sentra Buana; see Wilmar International Source: Singapore Exchange (2018). 84 Corporate registry profile Ltd (2018a) p2), though this is not Bloomberg records Kuok Khoon Hong as 85 PT Perkebunan Prima Manunggal’s reflected in the registry profiles. co-owner of HPR Investments Ltd; see main shareholder was PT Wahana Karya 37 Corporate registry profiles Bloomberg website ‘Company overview Agrinusa, whose main shareholder was PT 38 Corporate registry profiles of HPR Investments Limited’. Agro Ganda Indigo. This company had as 39 Corporate registry profiles 56 Martua Sitorus has declared its main shareholders PT Wahana Indigo 40 Corporate registry profiles of PT an interest in Bonoto Investments (50%) and PT Ganda Indigo Nusantara Gandaerah Hendana and PT Inecda and Ltd, which owns 33.5% of PT PANP. (50%), both of which were jointly their parent companies, and Samsung C&T Source: Singapore Exchange (2015a). owned by Andy Indigo and Jacqueline Corporation and Subsidiaries (2017) p23 Bloomberg records Martua Sitorus as Sitorus. Source: SOMO (2017) p13. 41 The mill has not been able to co-owner of Bonoto Investments Ltd; see 86 WWF Indonesia (2013) obtain a plantation business licence Bloomberg website ‘Company overview 87 At the time of the sale, Gama (IUP). Indonesian plantation law of Bonoto Investments Limited’. was known as Ganda Group. requires mill owners to source at least 57 Corporate registry profiles 88 Wilmar International Ltd (2014a) 20% of their palm fruit from their 58 According to his Facebook profile; 89 As revealed by a November 2017 own plantations. A presentation from see https://www.facebook.com/chusnul. investigation by Tempo and Eyes on the January 2018 that appears to have been nurtjahja (accessed 14 June 2018). Forest, which followed a truck carrying written by a company official explains 59 Corporate registry profiles palm fruit from the national park to the the situation from the company’s 60 See https://docslide.net/ PT CRS mill. Source: Trianita L (2018). perspective; see https://prezi.com/ documents/general-information- 90 Wilmar International Ltd (2018g) vynbsn9-zzf2/ptsuan/?webgl=0. up date-1-juli-2015.ht ml. 91 Greenpeace mapping analysis 42 See eg Hadi S (2018), an example 61 See eg https://id.linkedin.com/ 92 Benny Djuarsa and Johannes, both of a letter used in recruitment on in/jefri-siagian-4408a011b, h t t p s:// managers of Wilmar subsidiary PT university campuses, which states id.linkedin.com/in/marbuono-abu- Wilmar Cahaya Indonesia at the time that ‘Gama Plantation is an oil palm 91a31ab1 and https://id.linkedin. the concessions were established; plantation and processing group, com/in/khairuddin-simatupang- see case studies below. located in Riau, Jambi, Palembang, West 4813b753 (accessed 14 June 2018). 93 Corporate registry profiles Kalimantan, East Kalimantan and Papua’. 62 Kurniati D (2017) 94 Krisno O (2017) 43 Times Indonesia (2017) 63 Saturi S (2013) 95 Greenpeace mapping analysis 44 Batam News (2018) 64 RSPO website ‘Case tracker: of satellite imagery 45 Tribun Pontianak (2017) BT Bumi Sawit Kencana II’ 96 Corporate registry profiles 46 Together with representatives 65 Forest Peoples Programme (2018) 97 Greenpeace mapping analysis of Peter Sondakh’s Rajawali Group and 66 Kurniati D (2017) 98 Irawan Y (2015) and Arlinus Z (2015) a Malay-owned conglomerate. Source: 67 Amnesty International 99 foresthints.news (2018) International Palm Oil Monitor (2016); see also Joshi S (2017) 100 awasMIFEE (2018) (2018). See also Barrock J (2017). 68 Kiezebrink V (2017) 101 foresthints.news (2018) 47 The Edge Malaysia (2018) 69 Corporate registry 102 Wright S & Karmini N (2017) 48 PT Wilmar Cahaya Persada and profiles, SOMO (2017) p13 103 Tribun Pontianak (2018) PT Wilmar Nabati Indonesia are both 70 SOMO (2017) pp12–4 104 Benny Djuarsa is described on this located on floor 12 of Multivision 71 SOMO (2017) pp22–35 site as management of PT Wilmar Cahaya: Tower. Corporate registry profiles 72 RSPO website ‘Case tracker: http://pupukmahkota.co.id/news/temu- show that several Gama holding and PT Asiatic Persada’ tani-brebes-092017.html. Johannes (his plantation companies, including 73 Forest Peoples Programme (2011) full name) is described on this site PT AMS, occupy floors 10 and 11. 74 SOMO (2017) p12 as management: http://britama.com/ 49 Compliance Advisor/ 75 At the time of the sale, Gama index.php/2012/10/sejarah-dan-profil- Ombudsman (2009) p17 was known as Ganda Group. singkat-ceka/. Ownership information 50 The concession is also known 76 Wilmar International was found in corporate registry profiles. as PT Jatim Jaya Perkasa. See Wilmar Ltd (2014b) p41 105 Redaksi (2009) International Ltd (2013c). 77 Krishnan R (2013) 106 SK No. 42, tgl 22-02-2010 51 Greenpeace International 78 SOMO (2017) pp26–9 107 Corporate registry profiles (2013) p18 79 SOMO (2017) pp29–31 108 Corporate registry profiles 52 Wakker E, Miettinen 80 Wilmar International 109 Corporate registry profiles O & Zulfahmi (2004) Ltd (2014b) p41 110 Greenpeace mapping analysis based 53 Klawitter N (2014) 81 SOMO (2017) p15 on official Ministry of Environment 54 Corporate registry profile 82 See supply chain data for the and Forestry land cover data

42 111 Asrida E (2018) 134 A AK (2018) current disclosures cover the first 112 Greenpeace mapping analysis; 135 Apical website ‘Supply chain map’ half of 2017, Mars’s current disclosure see also Suara Pusaka (2018) 136 Bunge Loders Croklaan website represents 2016 and Nestlé’s current 113 Suara Pusaka (2018) ‘List of mills’. Note that the mill disclosure states only ‘Snapshot: 114 Basik-Basik M (2016) lists used in this trader dashboard November 2017’ (likely referring to all 115 Ngelia Y (2016) analysis reflect material entering of 2017, as of November). In addition, 116 Koalisi Organisasi refineries in the year 2017, when the these brands also publicly report the Masyarakat Sipil (2016) refineries were still operating as IOI traders who supply their palm oil, 117 awasMIFEE (2017) Loders Croklaan. When Bunge completed palm kernel oil, and derivatives. 118 Benny Djuarsa and Johannes. its acquisition in February 2018 157 L’Oréal has disclosed Source: corporate registry profiles. (see Bunge (2018)) it retroactively some suppliers but no mills. 119 Corporate registry profiles rebranded the 2017 mill lists as Source: L’Oréal (2016) 120 Greenpeace mapping analysis Bunge Loders Croklaan; however, 158 ADM had a 24.9% stake in Wilmar as of satellite imagery; see the current mill lists that are of August 2017. Source: Reidy S (2017). also Suara Pusaka (2018) available have been reformatted and 159 Correspondence with 121 Interview with a community leader no longer indicate direct suppliers Greenpeace, 8 June 2018 from Bupul village (name withheld or time period of receipt. 160 Trader dashboard analysis was for security reasons), August 2017 137 Cargill/FoodReg website based on the most recently available 122 Paino C (2017) ‘Supply chain map and mill list’ data, which for this group of traders 123 Government of Indonesia (2001) 138 GAR website ‘Traceability extends from January 2017 through 124 These include PT Berkat Sawit & supplier support’ the end of the first quarter of 2018. Utama (Sei Kandang), PT Citra Riau 139 Musim Mas website ‘Supply 161 Unofficial translation. The Sarana (Teso 1, 2, 3), PT Graha Agro chain map’ and ‘List of suppliers’ original reads ‘Kelompok (group) Nusantara, PT Intitama Perkebunan 140 Olam (2018) Perusahaan Perkebunan adalah kumpulan Prima, PT Karya Agung Megah Utama, 141 Sime Darby website ‘Open orang atau badan usaha perkebunan PT Patiware, PT Perkebunan Anak palm traceability dashboard’ yang satu sama lain mempunyai kaitan Negeri Pasaman, PT Sawit Unggul 142 Wilmar International dalam hal kepemilikan, kepengurusan, Agro Niaga, PT Swadaya Indopalma, website ‘Supply chain map’ dan/atau hubungan keuangan’. Source: PT TH Indo Plantations (Nyato, 143 Colgate-Palmolive (2018a,b) Minister of Agriculture (2013) p4. Pulai), PT Tritunggal Sentra Buana 144 Ferrero (2018) and 162 RSPO (2017) (Salo Bandang) and PT Wawasan Kebun Ferrero (2017) p193 163 Under the International Nusantara, as well as PT Gandaraeh 145 General Mills website ‘Global Accounting Standards (IAS), ‘a related Hedana (Ukui II) and PT Inecda, both direct palm oil suppliers’, General party is a person or entity that is part of the business’s joint venture Mills (nd) and General Mills (2018) related to the entity that is preparing with Samsung C&T Corporation. 146 Hershey (nd) and Hershey its financial statements (referred to 125 Email to Greenpeace from Wilmar website ‘Palm oil facts’ as the ‘reporting entity’) [IAS 24.9]. International, 14 March 2018 147 Kellogg’s (2018a) p5 (a) A person or a close member of 126 The majority shareholder of PT and Kellogg’s (2018b) that person’s family is related to a Patiware changed from PT GSU to PT 148 Mars (2018a) and Mars (2018b) p5 reporting entity if that person: Prima Panca Lestari, a subsidiary of 149 Mondelēz (2018a,b) (i) has control or joint control PT AMS, on 22 December 2016. Source: 150 N e s t lé (20 18 a,b) over the reporting entity; corporate registry profiles. 151 PepsiCo (2018a) p2 (ii) has significant influence 127 Wilmar International and PepsiCo (2018b) over the reporting entity; or Ltd (2018a) p2 152 Procter & Gamble website (iii) is a member of the key management 128 See LinkedIn profile of Ivan ‘P&G’s direct palm suppliers – 2017’ personnel of the reporting entity or Chandra https://www.linkedin.com/ and Procter & Gamble (2018) of a parent of the reporting entity. in/1vanchandra/ accessed 14 June 2018. 153 PZ Cussons website ‘CSR policies’ (b) An entity is related to a 129 Bunge Loders Croklaan (2018) 154 Reckitt Benckiser (2018a); see reporting entity if any of the 130 Wilmar International Ltd (2018g) also Reckitt Benckiser (2018b) p1 for a following conditions applies: 131 Bunge Loders Croklaan list of their ‘direct suppliers of palm ... (2018) and Olam (2018) oil-derived soap noodles’ for 2017. (vi) The entity is controlled 132 Wilmar International 155 Unilever (nd a,b) or jointly controlled by a Ltd (2018e,f,g) 156 Mill disclosure analysis was person identified in (a).’ 133 The analysis represents performed using the most recently Source: Deloitte/IAS Plus website collectively January 2017 through available data. The time period ‘IAS 24 – Related party disclosures’. March 2018, though some traders’ disclosed for all brands was January 164 Minister of Agriculture (2013) p4 reporting periods differed to December 2017, with the following 165 RSPO (2017) within that time period. exceptions: Ferrero’s and Hershey’s 166 Greenpeace International (2018)

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