Grievance List Last updated: 27 September 2018

No. Means of Date Subject Scope Stakeholder Progress Status Verification delivery Received Report G01 Letter to RSPO 10/14/2014 FPP complaint to RSPO alleging breaches of New planting, HCV Forest Peoples • October 2014: FPP submitted a complaint against GAR alleging a breach of the RSPO Principles and Criteria. Open the RSPO Principles and Criteria by GAR assessments, and Program (FPP) • July 2015: GAR and FPP agreed on a joint action plan to resolve the issues raised. including HCV, FPIC, smallholder schemes, FPIC • 24/8/15: The RSPO Complaints Panel ruled that GAR could resume plasma development. This would also allow GAR to fulfil its social obligations to the local community. and Indonesian law. In PT Kartika Prima Cipta • September 2015: FPP and GAR met the RSPO to discuss their joint action plan. The RSPO indicated that as FPP and GAR have entered into bilateral negotiations, the next step is to show clear progress in addressing the issues which will enable RSPO to move towards closing the case. (PT KPC) , West Kalimantan • October 2015: GAR held public consultations with the local community in PT KPC to address concerns related to land tenure. A second meeting involving the wider community and local authorities on this issue is planned for Q1 2016. • December 2015: GAR notified the FPP and the RSPO of its intention to submit New Planting Procedure (NPP) documents for plasma development in PT Paramitra Internusa Pratama (PT PIP) following public consultations. • February 2016: RSPO informed GAR that plasma development in PT PIP can proceed. GAR continues active dialogue with FPP. • All grievances submitted to the RSPO are being addressed in accordance with the RSPO grievance process. Updates can be found at the RSPO website. (http://www.rspo.org/members/complaints/status-of-complaints/view/75)

G02 Direct email to GAR 11/10/2014 Grievances related to land agreements, Land & Social Friends of Borneo • December 2014-April 2015: GAR completed an internal verification of the listed grievances. Open smallholder schemes, reduction of Conflict, Smallholders • January 2015: A joint agreement between PT AMNL and the local community was reached. A report was submitted to Friends of Borneo. environmental values and social conflicts in • 17/9/15: The National Stakeholder Engagement division in GAR would oversee the resolution of the grievances PTs AMNL, BNM, CNG, KGP. • As the grievances raised by FOB are similar to those raised by FPP in PT KPC, GAR would apply a similar approach to resolve the issues. • 16/1/16: GAR provided an update directly to Friends of Borneo • Refer to the FPP complaint update for more information.

G03 Public Report 11/11/2014 Allegations of forest clearance and impact on Forest/Peat Clearance Rainforest Initial Engagement Open biodiversity in the Leuser Ecosystem (LE) - And Social Action • 9/1/15: GAR contacted RAN about the report. from activities of plantations supplying to mills Exploitation Network • November 2014 to May 2015: GAR engaged 4 suppliers named in the report -PT Surya Panen Subur (SPS), PT Perkebunan Pati Sari (PSari), Ensem Sawita (ES) and PTPN 1. and later, to supplying PT SMART Belawan (RAN) - SPS made commitment not to develop any land before HCV study was completed. - A site visit was scheduled. refineries. - SPS issued a peat moratorium. - SPS and PSari agreed to work with GAR to develop action plans to achieve compliance with GAR policies - GAR would work with SPS on improving its HCV assessment of unplanted areas within SPS 2 concession. - PSari supplied GAR with supply chain data. GAR also studied details of a site assessment carried out by PSari’s customer, Musim Mas. GAR continued to engage PSari and support its efforts to address issues. - PTPN1 indicated that they require FFB suppliers to only source from legal sources. - Ensem Sawita initially said they were not in a position to know or tackle sources of FFB but subsequently invited GAR for a site visit. • GAR has identified other mills in its supply chain which are in close proximity to boundaries of the Leuser Ecosystem and will engage them to ensure they are compliant with GAR policies. • 18-22/1/16: GAR and TFT visited PTPN 1 (Cot Girek) and PTPN 2 (Sawit Seberang) mills. Reports and action plans were developed for improvements.

G03.a.1 PT.SPS2: https://goldenagr • 15/6/15: In meeting with GAR, RAN reported there was recent land clearing in SPS. • GAR followed up with SPS and sent a team to visit the site. i.com.sg/sustaina • SPS shared their internal findings which indicated that there was a major encroachment by an unidentified party. SPS said they would file a police report and take legal action. bility- • 7-11/9/15 GAR conducted a field verification visit to SPS2 mill, estate and surrounding areas dashboard/files/fi • 23/9/15: GAR shared findings with RAN. • GAR worked with SPS2 to finalize a field verification report which included an action plan to address RAN concerns. le_docs/XhgQIsps • 4/2/16: GAR and SPS met to discuss the draft of site visit reports and recommendations and agreed on an action plan. _summary_repor • The report was shared with RAN and is available on the Sustainability Dashboard. t.pdf • 4/2/16: GAR met SPS2 to discuss site visit report and action plan https://goldenagri.com.sg/sustainability-dashboard/files/file_docs/XhgQIsps_summary_report.pdf

G03.a.2 PT.SPS2 (cont'd) • 21/4/16: GAR met SPS2 to discuss RAN’s new report: http://www.ran.org/for_the_orangutan_capital_of_the_world_stop_the_bulldozers. • SPS2 reiterated that the clearance was committed illegally by external parties • 21/7/16: GAR met with SPS to discuss action plan progress and next steps, one of which is a plan to conduct Participatory Mapping. • 08/7/16: RAN started reviewing the report and discussing with GAR • 23/8/16: GAR, TFT and SPS2 had a meeting to discuss how the Participatory Mapping/Land Tenure Study would be conducted. The study is now ongoing. • 06/09/16: SPS2 updated GAR: a. SPS2 reported recent forest fire that took place near its concessions to the local government b. Police investigated and visited the area on 04/08/16 c. Environment and Forestry Ministry sent a team to evaluate the peat ecosystem in SPS2 concession d. In July 2016, SPS2 was found not guilty by Banda Aceh High Court for 2012 land burning case • 17/10/16: SPS2 sent a team to commence Participatory Mapping/Land Tenure Study at SPS2 concession. • 9/12/16: SPS2 LTS report was completed and presented to GAR a) SPS2 sent a letter to the Government Land Authority requesting enforcement of SPS2 HGU b) SPS2 also indicated they would welcome direct communication with RAN to inform them about their actions to address further encroachment of undeveloped areas in their estate. c) GAR would share its Desa Siaga Api programme with SPS2. • 21/12/16: GAR shared SPS2 LTS report with RAN and recommended RAN meet with SPS2 management. • 20/6/17: GAR launched CFT programme (Collaboration For Transformation) that aims to give intensive support to SPS2 to improve responsible palm oil practices on site.

G03.a.3 PT.SPS2 (cont'd) • 14/8/17: RAN published report on PT SPS 2: “PT. Surya Panen Subur II failing to stop illegal fires and destruction of Tripa peatland” claiming forest clearance continued inside the PT SPS 2 concession in the month leading up to June 9, 2017 (24 ha area) and numerous fire hotspots were identified. https://www.ran.org/pt_surya_panen_subur_ii_forest_loss?utm_medium=social&utm_campaign=eg_cpo&utm_source=twitter&utm_content=081417 • 14/8/17: GAR analysed report and asked PT SPS 2 to investigate • 31/8/17: SPS2 confirmed there was a new land clearing and burning in the east part of SPS 2 concession committed by external parties (encroachers) in Jun-Jul 2017 • 11-15/9/17: GAR is currently supporting SPS in a programme called “Collaboration for Transformation (CFT)”. This programme helps suppliers address problems in their supply chain such as implementing conflict resolution processes to address land tenure issues between SPS and local communities • 19-22/12/17: CFT programme at PT SPS 2 completed. G03.a.4 PT SPS2 (cont'd) •26/4/18: GAR internal team detected indications of new land clearing in SPS2 concession in the period of Dec 2017 and April 2018 specifically in east part of SPS2 HGU (near Kuala Seumayam Village). •7/5/18: By Foresthints: http://www.foresthints.news/violations-by-companies-in-tripa-peat-swamps-exposed. •7/5/18: SPS2 confirmed that the land clearing/encroachment had been carried out by an individual, Haji Sanusi, using an excavator. Actions taken by SPS2: a.12/3/18: SPS2 met Haji Sanusi and clarified the boundaries of SPS2 concession (HGU location) to him. Haji Sanusi stated that he understood and signed a document to that effect. b.13/3/18: SPS2 met the Head of Kuala Seumayam Village to report the encroachment, submit the copy of the acknowledgement signed by Haji Sanusi and asked for help to stop further land clearing by Haji Sanusi. c.15/5/18: SPS2 met Darul Makmur Camat (sub district head), Head of the Police Dept and Head of the Military Dept to report the encroachment; submit the copy of the acknowledgement by Haji Sanusi and to ask for help to stop further land clearing by Haji Sanusi. •14/5/18: GAR and SPS2 had a meeting to discuss the action plan to address the latest developments. SPS2 confirmed it did not commit any land clearing and stated that the land clearing mentioned in Foresthints report was conducted by a third party who encroached into SPS2 concession. SPS2 has initiated mediation and dialogue with the local communities in resolving this issue. SPS2 also told GAR that it had reported the case to the local authorities. •25/5/18 SPS2 sent a letter to the governor of Aceh update and report the encroachment/illegal action committed by Haji Sanusi inside the SPS2 concession. SPS2 also informed the governor that it would file a lawsuit against Haji Sanusi. In the letter, SPS2 asked for the governor’s guidance as the highest authority in Aceh for the best solution in resolving the issue. • 11/6/18: By Foresthints: http://m.foresthints.news/company-seen-doing-nothing-to-end-leuser-peat-violations and http://m.foresthints.news/minister-takes-next-move-to-stop-peat-violations-in-leuser • 30/7/18: As part of grievance handling process, GAR and Foresthints had a meeting to discuss next steps. GAR suggested a joint field verification visit and it was later agreed to be conducted in August 2018. • 3/8/18: By Foresthints: http://m.foresthints.news/minister-divulges-breaches-by-global-palm-oil-supplier • 14/8/18: By Foresthints: http://www.foresthints.news/minister-sanctions-palm-oil-company-in-leuser-ecosystem • 20/8/18: By Foresthints: http://www.foresthints.news/illegal-leuser-ecosystem-destruction-traced-back • 13-14/8/18: Foresthints and GAR conducted a joint verification visit to the areas relevant to the grievance in SPS2 concession • 21/8/18: Results and GAR recommendations from the verification visit are outlined below: Golden Agri-Resources (GAR) conducted a field visit to the estate of its supplier, PT Surya Panen Subur-2 (SPS-2), on 13 and 14 August 2018. This activity was carried out as a follow-up on a grievance re PT SPS-2 activities on peatlands within its palm oil estate in Nagan Raya, Aceh. The grievance was raised by Foresthints on its 11 June 2018 and 3 August 2018 articles. During the field visit, the following facts were observed: 1. The areas under investigation are located in Block OJ13 and Block OI11. The land area of the two blocks were developed before 2015, when SPS-2 made a commitment of No New Peatland Development. 2. Most of the planted palm trees in the above areas did not survive because of a number of reasons. Currently the unplanted areas are dominated by very tall ferns and bushes. 3. On-going activities in the areas including insertion plantings, maintenance of ditches and construction of a road present a threat to the existing peatlands and peat forests adjacent to the areas GAR recommends SPS-2 implement the following policies and programmes: 1. Stop all activities in the unplanted areas of the above blocks. 2. Conduct studies of peatland hydrology and other related issues to assess the impacts of agricultural activities in those blocks, including building ditches, road maintenance and insertion plantings. The outcome of those studies should be shared for feedback with the respective authorities at local and national levels. GAR supports SPS-2 policy to conserve the natural forests on peatlands within SPS-2 concession, and encourage full compliance with the government directives on AMDAL, water management and rehabilitation of the degraded peatlands. GAR appreciates the transparency demonstrated by SPS-2 in the field visit activity as this is a key element in achieving sustainable palm oil.

G03.a.5 PT SPS2 (cont'd) • 24/4/18: A media report claimed SPS2 was summoned by Nagan Raya Prosecutor Office for the execution of the 2012 forest fire case by Supreme Court verdict: https://www.acehtrend.co/kejaksaan-ingatkan-terpidana-pembakaran- lahan-pt-sps-nagan-raya-taat-hukum/ • 30/5/18: RAN issued: "PepsiCo and Others Connected to Ongoing Destruction of Critical Tripa Peatland" : https://d3n8a8pro7vhmx.cloudfront.net/rainforestactionnetwork/pages/19619/attachments/original/1527622021/PT_SPS_LW_Case_Study_May2018.pdf?1527622021 citing new evidence in January and March 2018 of ongoing deforestation in palm oil concession operated by PT.SPS2. • 5/6/18: GAR and SPS2 had a meeting. GAR and SPS2 discussed and agreed on the following: a. SPS2 stated it never received any letters and verdict from the court. SPS2 would ask the media and the relevant Prosecutor's Office for clarification. b. SPS2 has established a team responsible for handling conflict resolution; one of its tasks is to build and improve communication with local, provincial and international stakeholders, including RAN to get more comprehensive input in the resolution of PT SPS2 HGU encroachment problem. c. A rapid Land Tenure Study has been conducted to identify the party responsible for the recent illegal land clearing in the articles. SPS2 reiterated that the illegal land clearing was committed by an individual from another village (i.e. not Kuala Seumayam village) by the name of Haji Sanusi. Details on actions taken are in G03.a.4. d. In establishing communication with "the land clearing actors", SPS2 would run a more serious community empowerment programme by conducting a prior Social Impact Assessment. SPS2 will also organise a public consultation or a Focus Group Duscussion (FGD) with relevant stakeholders including government, NGOs and academia in the near future. This forum will also be involved in monitoring the progress of the community empowerment and conflict resolution programme • 11/7/18: A high level meeting was held between GAR and SPS2 management. GAR asked SPS2 for a more concrete solution for the ongoing deforestation caused by encroachment in SPS2 concession G03.b PT. Ensem Sawita/PT Ensem Lestari/PT Agra Bumi Niaga • 6-9/10/15: GAR and TFT visited ES. A site visit report with an action plan has been developed and shared with ES. • 18/5/16: GAR met with Ensem Sawita to discuss the site visit report and action plan. • 7/11/16: RAN issued report entitled “Protecting the Leuser Ecosystem” https://www.illegal-logging.info/sites/files/chlogging/RAN_Protecting_The_Leuser_2016.pdf • Deforestation was found after Governor of Aceh Circular Letter on June 17th 2016 in 12 palm oil concessions located within the threatened lowland rainforests and peatlands of the Leuser Ecosystem: TN, SPS2, ABN, TR, AT, DPL, PK, and others • There are 11 companies identified at risk of sourcing FFB from Singkil-Bengkung biodiversity region: ASN, GSS, PT Nafasindo, PT Singkil, PLB, ISP, SSN, Subulussalam, EL, DM PT.ABN, PT.DPL • GAR does not procure from ABN. There are 2 GAR suppliers within ABN’s 50km radius : PT.EL and PT.BS. • EL denied sourcing FFB from ABN while BS’s FFB source is 100% from its own estate. • 21/7/17: The Guardian newspaper published report titled “Pepsico, Unilever and Nestlé accused of complicity in illegal rainforest destruction” saying that PT. ABN reduced 420 ha of ‘protected’ forest cover to just 88 ha between June 2016 and April 2017. The palm oil reaches major brands via a twisting supply chain that stretches from the PT Agra Bumi Niaga (ABN) logging company, which delivers to a processing mill owned by PT Ensem Sawita (ES), which then sells the palm oil on to some of the world’s largest traders. https://www.theguardian.com/environment/2017/jul/21/pepsico-unilever-and-nestle-accused-of-complicity-in-illegal-rainforest-destruction. • In previous GAR engagement with PT.ES prior to the report, PT ES had initially stated they did not buy FFB from PT.ABN but later it acknowledged that there had been FFB from PT ABN entering its supply chain •2-4/8/17: GAR and TFT conducted site visit to PT ES and ABN •13/9/17: GAR and TFT had a meeting with owner of PT ES to discuss site visit report and agree on action plan • 22/9/17: GAR published PT ES/ PT ABN site visit report and recommendation/action plan https://goldenagri.com.sg/sustainability- dashboard/files/file_docs/qKT2Lpt_ensem_sawita_dan_pt_agra_bumi_niaga_field_visit_report_220917.pdf • 15-19 /1/18: GAR, MusimMas and TFT jointly conducted an evaluation visit to PT ES and provide assistance on TTP implementation.

G03.c PT Dua Perkasa Lestari https://goldenagri.co • There are 5 GAR suppliers in PT.DPL’s 50km radius: PT.UND, PT.SNR, PT.BSP, PT.RM, PT.SPS 2 m.sg/sustainability- • The 5 companies denied sourcing FFB from PT.DPL dashboard/files/file_do Singkil-Bengkung biodiversity region: cs/WGQF4verification_ • 5 of 11 alleged mills are direct GAR suppliers: PT. Global Sawit Semesta (GSS), PT Perkebunan Lambah Bhakti (PLB), PT Samudera Sawit Nabati (SSN), PT Bangun Sempurna Lestari (BSL), PT Ensem Lestari (EL) visit_re_grievance_sub • In Feb 2017 GAR met PT.PLB, PT.SSN, PT.BSL & PT.EL: mitted_by_rainforest_ a. PT.PLB, PT.SSN, PT.BSL, PT.EL denied sourcing FFB from Singkil-Bengkung area action_network_ran_a b. PT.SSN, PT.BSL, PT.EL have engaged with GAR in a traceability to plantation (TTP) project to map their FFB source while PT.PLB is in the process of completing its own TTP project. gainst_pt_dua_perkas • GAR is planning to conduct Smart Seed workshop in Aug 2017 to raise awareness for 44 suppliers around Leuser of the need of protecting it as stated in the circular letter from Aceh governor. a_lestari_pt_dpl_in_ac • 2-5/10/17: GAR conducted a site visit at DPL and at five suppliers in 50km FFB catchment area (SPS2,SNRM,BSP,RM,UND) eh.pdf • 13-15/11/17: GAR met suppliers to discuss site visit report and agree on action plan • 12/12/17: GAR published site visit report and recommendations/action plan on DPL and the five suppliers in 50km FFB catchment area (SPS2,SNRM,BSP,RM,UND) https://goldenagri.com.sg/sustainability- dashboard/files/file_docs/WGQF4verification_visit_re_grievance_submitted_by_rainforest_action_network_ran_against_pt_dua_perkasa_lestari_pt_dpl_in_aceh.pdf G03.d PT Indo Sawit Perkasa • 31/03/17: RAN issued a report https://www.ran.org/pt_indo_sawit_perkasa_caught_destroying_the_lowland_rainforests_of_singkil_bengkung saying that PT Indo Sawit Perkasa (ISP) caught destroying the lowland rainforest of Singkil- https://goldenagri.co Bengkung. m.sg/sustainability- • GAR does not have any direct commercial relationship with PT. ISP. GAR has contacted its suppliers within 50 km radius of PT ISP to check if they have any commercial or other relationship with ISP. dashboard/files/file_do • GAR is also working with suppliers on improved transparency and traceability of their FFB supply including encouraging its suppliers to publish a list of their suppliers. cs/xprRQreport_on_ve • GAR is investigating if ISP is part of a larger business group. rification_of_grievance • GAR is preparing a multi-stakeholder event involving stakeholders from government, industry, academia and civil society to discuss how to develop responsible palm oil in Aceh. _pt_isp_.pdf • GAR is relaying the RAN report to its suppliers prioritising mills that are located within 50 km of the boundaries of KEL (Leuser Ecosystem) • 2/5/17: GAR conducted a FGD with NGOs in Aceh on their views concerning the Leuser Ecosystem (KEL). GAR is using this FGD to prepare for the Smart Seed workshop • 3-5/5/17: As part of its supplier development programme, GAR conducted a sustainable palm oil training for its 12 suppliers around Leuser (KEL). A mini FGD with the participants was also held. Details please visit https://www.youtube.com/watch?v=wCRIe73f6Dk • 9/2/18: Site visit report and action plan on ISP published on Sustainability Dashboard: https://goldenagri.com.sg/sustainability-dashboard/files/file_docs/xprRQreport_on_verification_of_grievance_pt_isp_.pdf

G04 Forest Peoples 5/5/2015 Allegations of planting along banks of Lake Riparian zones Forest Peoples • May 2015: GAR deployed a team to investigate Open Programme (FPP) Marsedan by PT Kartika Prima Cipta (PT KPC) Programme • Initial findings indicated that flooding in the Lake Marsedan catchment area has caused the lake to expand. presentation to GAR in West Kalimantan. • June 2015: GAR conducted Participatory Mapping (PM) and identified Lake Marsedan’s normal boundaries and riparian edges. • Following the PM with Lake Marsedan community in May-June 2015, GAR conducted public consultations on options for the management of the riparian zone at Lake Marsedan. • As it is defined as protected area, Company will enclave the area and return it to central government (in accordance with Indonesian law)

G05 Public Report 5/20/2015 Allegations of forest clearing by palm oil Forest Clearance Greenomics • 27/5/15: GAR met ANJ Open supplier PT Austindo Nusantara Jaya Agri (PT • ANJ did not provide enough information to show compliance with GAR’s polices. ANJ), in Sorong, West Papua, Indonesia. • 29/5/15: GAR encouraged ANJ to take steps to address issues but no action was taken. • GAR continues to encourage ANJ to present plans for its Papua development which includes a revised HCV report and land use plans for the Papua estate.

G06 Public Report 6/4/2015 Allegations of forest and orang-utan habitat Forest/Peat Greenomics • 15/6/15: GAR met SSMS. GAR suspended new purchases from SSMS and its subsidiaries, while continuing talks with SSMS on achieving compliance with GAR’s sustainability policy for all of SSMS subsidiaries. Open clearance by PT Kalimantan Sawit Abadi Clearance • 5/8/15: GAR’s verification team received evidence that indicated active clearance on KSA concession. (KSA), subsidiary of PT Sawit Sumbermas • 6/8/15: GAR sent letter to KSA to suspend all existing contracts. Sarana (SSMS) TBK. • 15/1/16: SSMS held a buyer gathering event in Jakarta to give its buyers a sustainability update. • 17/1/16: SSMS released an official statement in its website claiming KSA had complied with RSPO and government regulation • 10/3/16: Following meeting with FPP on 2/2/16, GAR submitted the revised cadastral map to the Ministry of Agrarian and Spatial Planning. • 3/9/16: In meeting with GAR, SSMS said that land clearing that had happened since 19th June 2015 was due to an internal miscommunication as well as plasma demand insisted by the local community. • 7/10/16: SSMS had a meeting with GAR presenting consultants it was commissioning to verify allegations related to KSA. (Daemeter, Remarks Asia, IPB, BOSF). • 20/10/16: GAR had a meeting with SSMS in Pangkalan Bun to get an update on its sustainability initiatives particularly on KSA: a. SSMS management claimed that it had decided to stop land clearing in KSA since November 2015. b. SSMS stated it would comply with recent government regulation that prohibits development on peat. c. An independent verification was carried out by Remark Asia dan Daemeter on 4-10 Dec 2015. The report confirmed that a forest and peat clearance had happened in KSA. It also confirmed Desa Kondang residents wanted to have a plasma area in KSA concession. Remark Asia and Daemeter acknowledged studies commissioned by KSA towards sustainable palm oil practices. d. SSMS also commissioned other studies/projects in KSA such as Carbon Study (Cerindo), orangutan population survey (BOSF) - MOU is ready to be signed for a two-year biodiversity study (Univ. Mulawarman), and HCV study (Aksenta). e. Other initiatives included Water Management at Batu Kotam, management decree on 26 Sep 2016 about KSA area of which 590 of the total of 1,800 hectares would be conserved for HCV, 1 million mangroves project in Desa Kubu and TWA Tanjung Kaluang and conservation of Owa & Tarsius. • In addition to verifications carried out by independent parties, SSMS agreed that GAR would conduct its own verification visit to KSA. • 5-7/12/16: GAR carried out a site visit at KSA • 13/9/17: SSMS launced new sustainability policy at a group level which includes identification and protection of HCV and HCS forests: http://www.ssms.co.id/New%20Sustainability%20Policy%20SSMS.pdf • 28/9/17: GAR had meeting with SSMS to discuss KSA site visit report and to give recommendations about SSMS new sustainability policy • 24/10/17: GAR conducted HCS training for SSMS team using the latest HSCA toolkit • Dec/17: GP’s report on Deforestation case studies mentioned PT.Sawit Mandiri Lestari committed land clearing of 4,800 ha of secondary forest between March 2016 and Oct 2017 in Central Kalimantan. PT.SML was alleged to be linked to CBI, the parent company of SSMS. • 13/2/18: GAR met SSMS to discuss progress of its sustainability implementation and action plan. • 11/4/18: GAR and SSMS had a meeting to discuss their progress and action plan. SSMS claimed that SML had been sold to another company that had no link to the group. GAR recommended SSMS make a public announcement in response to the allegations that were reported earlier by Chainreaction Research https://chainreactionresearch.files.wordpress.com/2017/06/ssms-supplying-the-palm-oil-leakage-market-170620.pdf • 26/4/18: By Foresthints : http://www.foresthints.news/company-behind-palm-oil-expansion-promises-ground-check & http://www.foresthints.news/tft-members-linked-to-palm-oil-expansion-in-burned-peatlands • 19/5/18: SSMS published its official response to the Foresthints report: https://ssms.co.id/en/media/detail/ssms-response-to-foresthintsnews-article-on-pt-bsg. • 23/5/18: By Foresthints: http://m.foresthints.news/public-response-by-palm-oil-company-raises-further-legal-questions.

G07 Email to 6/5/2015 Allegations of peatland clearance and social Forest/Peat Forest • 12/6/15: FR adopted Policy on Sustainable Palm Oil. FR has said they will take responsibility for addressing issues related to SAL in line with their policy commitments. GAR continues to Grievance conflict by PT Setia Agrindo Lestari (SAL), Clearance Heroes • 12/5/16: GAR met FR monitor Department which partly owned by First Resources (FR). and • FR clarified that they have a minority stake in SAL and asked SAL to agree to suspend land clearance. Social Exploitation G08 Public Report 6/17/2015 Allegations of HCS clearance in a concession Forest clearance Greenomics • 19/6/15: GAR began engaging with EH. EH shared HCV report on VMA and engaged HCS assessors. Open owned by PT Varia Mitra Andalan (VMA), a • 23/11/15: EH updated GAR on steps it has been taking to address VMA issues and agreed to share HCS study on VMA. subsidiary of PT Eagle High Plantation (EH). • In January 2016 EH launched its new website with a sustainability section and updated its RSPO profile with its commitments: http://www.rspo.org/members/225/PT.-Eagle-High-Plantations-Tbk • 22/2/16: Shared draft summary of HCS report on VMA conducted in January 2016. It does not plan to carry out any land clearing in 2016. •EH has begun the HCV compensation process with RSPO as part of its effort to get BLP RSPO certification in 2016. • EH management will report its progress to GAR on a monthly basis. • 5/8/16: GAR and TFT finished reviewing VMA's HCS report. • 20/9/16: EH attended HCSA Steering Committee meeting in Singapore • 30/9/16: GAR shared with EH HCS approach and experience in implementing long-term forest conservation in Kapuas Hulu District. • EH submitted VMA HCS study report to HCSA steering committee for peer review. The peer review is now in progress. http://highcarbonstock.org/registered-hcs-assessments/ • 23-26/10/17: GAR did joint site visit with IOI and Daemeter to observe progress on the ground • Dec 2017: Peer review of VMA HCS study is complete and can be seen at: http://highcarbonstock.org/wp-content/uploads/2017/12/HCSASS1.pdf http://highcarbonstock.org/wp-content/uploads/2017/12/HCSAPE1.pdf • 21-25/1/18: GAR provided VMA with training on FPIC and Participatory Mapping • 9/2/18: GAR shared our commitment to TTP to EH. • 8/3/18: By Foresthints: http://www.foresthints.news/gar-delivers-deforestation-free-supply-chains-to-papua • 14/3/18: EH and Greenomics met to discuss VMA updates

G09 Meeting 7/31/2015 HCS and HCV clearance in concession of PT Forest clearance & Greenomics • 31/7/15: GAR met Greenomics and PT Syaukath Sejahtera (SS) Closed as of Syaukath Sejahtera (SS) in Nanggroe Aceh encroachment on • An initial action plan was agreed on to address the following items: 24/5/16 Darussalam. water catchment area - Establish legality of concession; - Verify reported land clearance by burning; - HCV clearance; - Clearance of HCS Forest. • Following several meetings with SS and Greenomics conclusive findings could not be obtained. • GAR proposed SS agree to a site verification visit. SS has agreed to allow GAR and TFT to conduct a site visit of SS to address Greenomics' concerns. It will also work with GAR on policy implementation. •30/11/2015: Site visit was carried out and a report drafted. • This grievance is considered closed as SS has been included in GAR’s Agregator Refinery Transformation (ART) Programme for monitoring. G10 Email to GAR 9/15/2015 Request for information by Forest Heroes Forrest Fires/ Haze Forest Heroes • 15/9/15: An inquiry by Forest Heroes was filed through our Grievance Process regarding GAR’s relationship with three companies alleged to have caused fires: Provident Agro, Tempirai Palm Resources and Waymusi Agro Indah Closed as of 9/6/16 about GAR's action regarding media reports of • One of the 3, Provident Agro is a supplier of GAR. palm oil companies contributing to the haze • GAR contacted Provident Agro to obtain information about their subsidiary, PT. Langgam Inti Hibrindo (LIH) whom authorities have alleged is linked to causing fires crisis: Provident Agro, Tempirai Palm • 18/9/15: GAR met Provident Agro to get further clarification on cause of fires and efforts to prevent, monitor and combat fires. • 23/9/15: Due to the Indonesian government's reported suspension of LIH's license to operate , GAR halted purchases from LIH, pending further clarification Resources and Waymusi Agro Indah. • 9/10/15: GAR received confirmation that PT Langgam Inti Hibrindo's business license was suspended by Ministry of Environment and Forestry. Suspension of purchases remained in effect. • 25/1/16: LIH’s business license was reinstated by the government based on SK Menteri LH dan Kehutanan No SK39/2016.SK • 12/5/16: GAR and LIH held a meeting: a) LIH confirmed it had resumed operations and that the suspension of its Environmental Permit was lifted by the government on 21/1/16 b) LIH has disclosed the legal proceedings related to the forest fires in its 2015 annual report: (link: http://www.provident-agro.com/annual/Annual%20Report%202015.pdf ) c) LIH shared with GAR documents showing its efforts in anticipating the next dry season and in fire prevention including: i) Report and checklist of 100% readiness and availability of firefighting equipment as required by the government (based on DIRJENBUN 2010 and KEPDIRJEN PHPA No.247/kpts-VI/1994) ii) Reports of training of personnel in firefighting and fire prevention by the government’s firefighting agency. • 9/6/16: The Pelelawan Riau District Court found LIH was not guilty of causing forest fires • June 2016: Pelelawan District Attorney filed an appeal to the Supreme Court. • 22/2/17: LIH’s parent company, Provident Agro, published its 2016 annual report. Re the case of LIH, on page 126 it stated: “Legal proceeding against Mr. Frans Katihokang at the District Court of Pelalawan has obtained District Court of Pelalawan Decision on 9 June 2016 which discharged Mr. Frans Katihokang from all claims and reinstated his reputation. At present time, this legal case in the process of appealing investigation by Supreme Court. Meanwhile legal filing against PT LIH has been ceased by Riau District Police on 27 April 2016 due to insufficient evidence.” http://www.provident-agro.com/annual/Annual%20Report%202016.pdf • This confirms our decision to close this case.

G11 Media Report 9/17/2015 Local media report on Ketapang District police Forrest Fires/ Haze Media • 29/9/15: GAR contacted PT Cipta Usaha Sejati (CUS) and they stated the report was false. Closed as of investigating 4 companies suspected of • 19/10/15: CUS submitted its fire fighting SOP and documents regarding its fire preparedness 14/7/16 burning to clear land including PT Cipta Usaha •10/3/16: GAR met CUS. They reiterated that the fire was started outside its concession by a person from the local community Sejati. •22/3/16: CUS submitted the police report on the incident which alleged that a person from the local community caused the forest fire at Gunung Badung conservation area which subsequently spread to the CUS concession. •26/4/16: Following the investigation, the local Police Department has stated that the suspect from the local community was arrested in September 2015 with the help of CUS. They also confirmed that PT.CUS had proactively helped the Link: http://suarapemred.co.id/polres- authorities in anticipating, fighting and putting out fires. ketapang-periksa-4-perusahaan-perkebunan- • Based on the latest developments, GAR considers the grievance closed. kelapa-sawit-terkait-dugaan-bakar-lahan/

G12 Media Report 9/18/2015 Media report alleging two companies Forest Fires/ Haze Media •One of the companies, PT Ricky Kurniawan Kertapersada (RKK) is a GAR supplier. Closed as of operating in Jambi carried out burnings and • 18/9/15: GAR contacted RKK to clarify the issue 29/7/16 were being investigated by Jambi Provincial • 23/9/15: RKK issued a circular to its customers concerning the forest fire and stated that the company has a zero burning policy. The fire had started on 26 August 2015 outside their concession area. It spread into RKK area and was Police Department. eventually put out by RKK working together with the local fire department. • RKK acknowledged they were under police investigation. • 30/9/15: GAR requested a meeting with RKK Link: • 6/10/15: GAR met RKK management who shared information, documents and photographs on RKK's zero burning policy, firefighting SOPs and fire suppression plans. www.infosawit.com/mobile/index.php/news/d 1. RKK acknowledged that one of their employees was summoned as a suspect on 7/10/15 and a lawyer has been appointed by the Company. etail/dua-perusahaan-sawit-di-jambi- 2. RKK agreed to a site verification visit by GAR and TFT. terindikasi-bakar-lahan 3. GAR studied documents submitted and continued to monitor the progress of official investigations. • 14-18/11/15: GAR and TFT conducted a site visit • April 2016: TFT completed compiling the verification report. GAR and RKK management are planning to meet to discuss findings and recommendations and to agree on action plans. • 15/4/16: GAR met RKK to discuss the fire and haze report and action plan • 25/4/16: RKK management approved GAR-proposed action plan and began implementation • 29/7/16: PT RKK updated GAR on progress. GAR considers this grievance is closed and continues to monitor the action plan progress.

G13 Media Report 10/4/2015 Report on website on incident between Social Conflict Media • 7/10/15: PT Campang Tiga (CT) explained to GAR that the incident was related to a land dispute with another company. Closed as of community and company which resulted in • The incident was reported to the police. A mediation process was also initiated by the South Sumatera Provincial Government. GAR requested further information and documents from CT. GAR also checked other sources to verify the 21/1/16 the burning of a company excavator. information. • 21/1/16: GAR met CT and was told that it is pursuing mediation with the local community. It had also started legal proceedings against the company which is alleged to be involved in the incident. The case is now with the court. • Further actions such as a site visit was considered unnecessary due to the ongoing legal process. Link: • CT will make a public announcement when the verdict is issued by court. http://m.okezone.com/read/2015/10/04/340/ • GAR continues to monitor the case and engage with CT. 1225919/Warga-Bakar-Alat-Berat-Perusahaan- • 18-21/10/16: GAR conducted a site visit to CT. Sawit-di-Banyuasin • Given the law proceeding for the case has taken place and the fact that CT has been included in GAR ART programme, we consider this grievance is closed for monitoring.

G14 Media Report 9/14/2015 Media article on GAR supplier PT Bahari Forest Fires/ Haze Media • 9/10/15: GAR contacted BGR and received the following clarification: Closed as of Gembira Ria (BGR), having high incidents of • On 3/9/15, fire was detected outside BGR areas. It eventually spread to within 150 metres of BGR’s boundary. 12/11/15 fires based on Global Forest Watch info. • The fire was put out by BGR and local community. • PT BGR teams verified the hotspots and found that they were located outside the areas controlled by BGR. BGR is not replanting or carrying out new plantings. • GAR requested further supporting documents from BGR. Link: • 12/11/15: GAR met BGR who handed over documents to show that the fires occurred outside BGR concessions. http://www.pressreader.com/indonesia/the- • After examining the information provided and as there have been no further media reports referring to BGR, GAR considers this grievance closed. jakarta-post/20150914 G15 Media Report 10/6/2015 Media report related to fire and haze involving Forest Fires/Haze Media • 6/10/15: GAR contacted PT Kayung Agro Lestari for clarification Open GAR supplier: PT Kayung Agro Lestari (KAL) • KAL is a subsidiary of ANJ Agri which is involved in another matter that is being addressed (see G05) • KAL denied reports and stated the fires occurred outside of their concession. Link: • GAR continues to engage ANJ Agri on these issues. http://www.smh.com.au/world/company-with- australian-link-investigated-over-indonesian- fires-20151005-gk1br7?skin=dumb-phone

G16 Direct email to GAR 11/16/2015 Email from Greenpeace alleging that two HCV Clearance Greenpeace • 17/11/15: GAR contacted Bumitama for a meeting. GAR also asked Greenpeace for further details. Open companies PT Andalan Sukses Makmur • 19/11/15: GAR received further information from Greenpeace (ASMR), a subsidiary of Bumitama and PT • Bumitama met and gave GAR the following information: Bumi Sawit Sejahtera (BSS), a subsidiary of • PT ASMR concession's IUP (Izin Usaha Perkebunan) was granted by the Government of Indonesia and the peat moratorium revision was also issued by the government. • Less than 4,000 hectares will be planted out of the 7,000-hectare concession granted in PT ASMR’s IUP. HCV, HCS studies and Participatory Mapping has been conducted for this concession. There is also a land use plan. IOI are clearing forest peatlands. Bumitama is • Bumitama is committed to its sustainability policy and a large part of the ASMR concession area will be conserved. The conservation area consists of peatlands, HCV and HCS forests. (refer also to Bumitama’s announcement dated a supplier of GAR. 12/9/14) FOE also released a similar report: • Bumitama is engaging with local communities on the conservation of areas. It has also prepared nurseries of plants to be used in this conservation effort. http://www.foe.org/projects/oceans-and- • The local District Head had asked Bumitama to clear 200 hectares for smallholder plasma development. This area is located in low lying mineral soil and a non-peat area. forests/forests/up-in-smoke • Areas to the north of the concession are already planted with oil palm trees owned by other companies. • Re allegations of fires, the fires started outside PT ASMR including from the adjacent Tanjung Puting National Park. The fires were eventually put out. • 24/11/15: GAR shared above information to Greenpeace. • 4/1/16: FOE released similar report “Up in Smoke’ on Bumitama • 11/1/16: GAR met Bumitama and they shared their response to the issues in the FOE report: • Bumitama has issued report on AMSR which has been shared with GAR. • On peat, BGA has hired a third party to conduct a survey. The survey identified new areas of peat. These areas will not be developed. The survey also shows that there is no peat in the central region of ASMR as mentioned in Greenpeace report (page 16). • On fire, Bumitama has taken steps to prevent and supress forest fire including fire monitoring, prevention and suppression and working with local community and authorities • On the issue of HCS/HCV clearance, Bumitama announced the results of HCS assessment and peat in PT ASMR in 2014 which indicated that there were 94 hectares of HCV, 2,469 hectares of HCS and 1,756 hectares of peat. This is to show that it remains committed to not developing these areas as defined in the report. • A Rapid Biodiversity (RBD) assessment was conducted in 2015 with a local NGO Yayasan Pendidikan Konservasi Alam. The RBD assessment concluded that the area under review (462 hectares) consists of old scrub, most of which have been logged or used by the community in the past. The study revealed that there are no Critically Endangered plants in and only two species classified as Endangered. The area has limited capacity for wildlife, including orangutan because of its limited size and threats of hunting and community logging. • Social Impact and HCV Assessments were carried out on the area under review (refer above). Bumitama would open an area of 234 ha due to the demand from the local community and government based on a public consultation conducted on 16 June 2015. The other 222 ha would be conserved as potential HCS area. • GAR offered to conduct a verification visit as part of GAR’s support to BGA. BGA said the verification visit from GAR to ASMR would not be viable but has agreed to provide GAR with information in response to further queries. • 16/8/16: GAR updated Greenpeace on ASMR grievance handling progress. • BGA uploaded its first NDPE policy implementation report (Mar-Sept 2016): http://files.shareholder.com/downloads/AMDA-WWON6/2003302154x0x920620/CC961FD1-4AF3-44F8-8C9B- C8DABB502E20/Sustainability_Policy_Progress_Update_Mar-Sep_2016.pdf • 5/4/17: By Foresthints: http://m.foresthints.news/legal-measures-taken-against-palm-oil-company-fragmenting-peat-forests • 23/3/17: BGA released 2016 annual report which highlighted progress of PT.ASMR on page 25: ASMR began gradual reforestation of 107 ha previously burnt in 2015. http://www.bumitama- agri.com/asset/upload/storage/report/Bumitama_Agri_AR2016.pdf • 18/4/17: GAR had meeting with BGA to ask clarification re PT.DAS • 6/6/17: BGA published clarification on PT.DAS: http://www.bumitama-agri.com/asset/upload/storage/report/News%20Release%20-%20PT%20DAS%20clarification.pdf • 10-13/7/18: GAR conducted a site visit to PT RSI Riau on ART programme • 19/9/18: GP published report “Final Countdown” https://www.greenpeace.org/international/publication/18455/the-final-countdown-forests-indonesia-palm-oil/ • 19/9/18: GAR requested clarification from BGA • 25/9/18: BGA published its official response http://ir.bumitama-agri.com/static-files/4272c98a-16e2-4856-80be-a58782702d98

G17 Public Report 12/2/2015 Report by Chain Reaction Research on fire Forest Fires/Haze Chain Reaction • August 2015: Fires set by unidentified individuals were detected in PT AMNL conservation area. Emergency Response Teams could not reach the fires as the area has no access roads. Closed as of 9/5/16 damage in GAR's concessions in PT Agro Research • GAR's fire management measures at PT AMNL include: Lestari Mandiri (PT AMNL) in West - Ensuring GAR staff and affiliates were trained in fire management and suppression Kalimantan. - Engaging with local communities to increase awareness of no burning practices - Preparation of infrastructure and implementing fire prevention practices including: o Over 60 Emergency Response Team personnel stationed at PT AMNL Link: o 11 fire monitoring towers http://chainreactionresearch.com/2015/12/01 o Fire buffers created /indonesia-fires-analysis/ o Involving local community in fire management practices and fire patrols o Rewetting the peat area • End-Sep 2015: Fires extinguished after continuous heavy rain. GAR filed police reports on the fires. GAR will improve its fire management based on lessons learnt. • Based on GAR's investigations and satellite monitoring from September – October 2015, 590 hectares within conservation area were affected by fire. GAR is unable to verify the 1300 hectares mentioned by Chain Reaction Research in its report. •The area does not contain orangutan habitats as noted in previous 2011 HCV report by IPB and 2015 Biodiversity report by Malaysian Environmental Consultants (MEC) • 16/11/15: GAR launched a Peat Ecosystem Rehabilitation Project in PT AMNL with MEC involving an area of approximately 2600 hectares which includes land affected by fires. • GAR is working together with MEC on steps to rehabilitate the area including: - The restoration of the peatland’s hydrology and water-table to prevent further drainage and reduce its fire risk - Consultation and involvement of local communities in the conservation of the area • 9/5/16: Author of the report acknowledged receipt of GAR’s report on the rehabilitation of the area. As such GAR considers the grievance closed.

G18 Media Report 3/10/2016 Report against PT Anugerah Energitama (AE) HCV/Protecting Rare Centre for Orangutan • Local NGO, Centre for Orangutan Protection (COP) found 13 orangutans trapped in the AE concession in small areas of fragmented forests. They claimed this was due to land clearing activities for palm oil. COP also identified a number Open concerning orangutans trapped in the and Endangered Protection (COP) of other endangered wild animals in the area. concession Species • 16/3/16: RSPO received a copy of a letter sent by COP to the Environmental Office (BKSDA) East Kalimantan regarding this issue. The letter also mentioned that AE is supplying FFB to GAR and another company. http://www.mongabay.co.id/2016/03/11/kala- • GAR held meeting with AE: a) AE started land clearing in 2009 belasan-orangutan-terjebak-dalam- b) AE stated their estate is on land zoned as "APL" which is Land zoned for other uses, hence not zoned as a forest area. perkebunan-sawit-palma-serasih/ c) AE acknowledged that orangutans have been spotted in the area but denied COP’s allegations. d) AE produced an HCV report issued by Sonokeling in 2016 (surveyed in 2015) based on the HCV Indonesia 2008 toolkit. e) AE stated it was engaging with COP and BKSDA f) GAR asked AE to share further documentation • 18/3/16: GAR met COP. COP showed evidence of eight orangutan spots, five of which are located in AE concession. COP said it would come up with an action plan for AE. It was also agreed that a joint verification visit should be carried out immediately. • 19-22 March 2016: a verification visit was carried out by BKSDA, COP and AE • At end of March 2016, BKSDA issued a report on the tripartite verification explaining that: a) No orangutans were directly spotted during the verification process b) There were indications of orangutan presence in the form of nests and damaged young oil palm trees. c) AE has set aside a conservation area for protected plants and animals d) AE needs to be proactive in saving protected animals in its concession and in areas that are affected by its operations. • 27/4/16 – 13/5/16 BOSF (Borneo Orangutan Survival Foundation) appointed by AE to conduct an orangutan population survey in its concession • 3/5/16: GAR held meeting with AE and agreed to provide technical support on orangutan protection. • BOSF found food remnants and old nests in the AE concession. New nests were also found in the customary forest outside the AE concession. • BOSF recommended that AE preserve its current conservation area as well as riparian zones, conserve forest corridors and develop an SOP for orangutan habitat conservation. AE agreed to sign an MOU on orangutan conservation with BOSF. • 5/8/16: GAR held update meeting with AE. • 2/9/16 AE met BKSDA to present results of the orangutan population survey and conservation management. AE and BKSDA would work together on orangutan conservation. • 19/12/16: COP sent a letter to East Kalimantan BKSDA reporting orangutan appearance in PT. Global Primatama Mandiri (GPM) concession. • PT.GPM like AE, is a company in Palma Serasih group. GAR procures from AE but does not procure from PT.GPM • 9/3/17: GAR had a meeting with GPM to ask for clarification: a. 6-8/2/17 East Kalimantan BKSDA conducted a site visit to GPM to verify COP’s finding. b. GPM stated it had been aware of the presence of orangutan in its concession before COP sent the letter to BKSDA. c. That is why on 19/8/16 GPM signed a partnership with BOSF to protect orangutan in its concession. GAR has confirmed this partnership with BOSF. d. GPM has also set aside a total area of 4700 ha in its concession for HCV conservation.

G19.a. Public Report 4/5/2016 Report claims GAR and other companies Forest Eyes on the Forest No One is Safe Report Open with GAR purchased FFB illegally grown and harvested, clearance/illegal (EoF) • 13/1/16: EoF sent a letter to GAR with the enclosed draft of a report entitled “No One is Safe”. continuing to monitor CPO contaminated by such FFB, and/or CPO encroachment of • EoF asked GAR to comment on its claim that GAR and other companies purchased illegally grown and harvested FFB, CPO contaminated by such FFB, and/or CPO products contaminated by such CPO. SRJ case as of products contaminated by such CPO. national park • EoF listed 19 CPO mills purchasing illegally grown FFB, four of which are GAR’s suppliers: 7/11/16 1) PT. Berlian Inti Mekar (BIM) http://www.eyesontheforest.or.id/attach/EoF 2) PT. Makmur Andalan Sawit (MAS) %20(06Apr16)%20No%20One%20is%20Safe 3) PT. Peputra Supra Jaya (PSJ) %20English%20FINAL.pdf 4) PT. Sugih Riesta Jaya (SRJ) • GAR sent a response to EoF stating that : a) with the publication of its original Forest Conservation Policy in 2011, GAR sought to focus on its own operations first by changing practices in plantations and mills it owns and manages directly. In 2014, it expanded those commitments to its entire supply chain. In 2015, GAR further revised and updated its sustainability policy, publishing the GAR Social and Environmental Policy (GSEP) which applies to its entire supply chain and business. b) GAR achieved traceability to the mill level at the end of 2015. Traceability to the plantation level is the next step and an ongoing process. GAR is committed to engagement and not exclusion. This commitment to transforming the sector, is by its nature, complex and requires time. It requires collaboration, persuasion and capacity building as well as a long term vision and commitment to resourcing these efforts for years to come. c) GAR agreed in principle with many of the recommendations within the EoF report but emphasised the scale and time required to bring about the industry change EOF is seeking. • 5/4/16: EoF published “No One is Safe” report on its website. • 25-29/4/16: GAR conducted a verification visit to MAS and PSJ. • 16/5/16: GAR met SRJ to discuss the site visit report and action plan. SRJ management is reviewing the proposed action plan. • BIM was not visited by GAR as Musim Mas had conducted a site visit on August 10th-14th 2016. • In mid-October 2016 site visit reports were completed and sent to PSJ and MAS for review. •13/10/16: BIM shared its verification report conducted by an independent party; CORE (Consortium of Resource Experts); hired by Musim Mas. A time-bound action plan is being developed. • 7/11/16: GAR and SRJ agreed on the action plan and started monitoring and evaluation process. As such, grievance on SRJ has been closed for monitoring. • 9/12/16: GAR had a meeting with PSJ and MAS to discuss verification reports and action plan. • 13/02/17: GAR and TFT updated EOF, PT.PSJ and PT.MAS on grievance handling : • PT.PSJ and PT.MAS agreed to develop a traceability system and allow GAR to have a traceability to plantation pilot project at their mills. • It was verified that the fire stated in EOF’s report took place outside PT.PSJ concession. Despite this, PT.PSJ agreed to enhance its fire prevention and management as required by Dirjenbun to fight fire in the future. • GAR conducted site visit at SRJ mill. • Apr-Dec ’17 GAR and SRJ engaged in CFT (Collaboration for Transformation) programme. CFT is a development programme especially designed for assisting GAR suppliers for a specific need. https://goldenagri.com.sg/case_study/helping-suppliers-solve-sustainability-challenges-one-step-time/

G19.b. Enough is Enough Report • 8/6/18: EOF issued a report alleging a number of companies source FFB from Tesso Nilo National Park, Bukit Tigapuluh National Park and Bukit Betabuh Tiger Corridor. https://www.eyesontheforest.or.id/reports/investigative-report- enough-is-enough-jun-2018 • 8/6/18: GAR does not source FFB from Teso Nilo National Park, Bukit Tiga Puluh National Park or Bukit Betabuh Tiger Corridor mentioned in the report. However, GAR identified 7 supplier mills mentioned in the report: PT BIM, PT TBS, PT SRJ, PT PSJ, PT MAS, PT SMN, and PT PAJ. GAR has conducted site visits to 5(change to 4) mills under the Aggregate Refinery Transformation programme (TBS, SRJ, SMN, SMN(delete), PAJ) and 2 mills under grievance handling support process (PSJ, MAS) in the period from 2015 to 2018. • GAR sent a response letter on the EOF report in the following week. • GAR plans to discuss the report with EOF in early July 2018 and engage TBS, PSJ, MAS, SMN, PAJ for 2018 Collaboration for Transformation (CFT) programme focusing on Traceability to Plantation. • SRJ has been involved in the CFT programme since April 2017. The report can be found here: https://goldenagri.com.sg/case_study/helping-suppliers-solve-sustainability-challenges-one-step-time/ • For PT BIM please see G19.a. • 4-6/7/18: GAR had meetings with SMN, MAS, PSJ and Sarimas to duscuss EOF report and GAR offered support via CFT programme. • 24/7/18: GAR and EOF had a meeting to discuss “Enough is Enough” report and action plan on landscape approach G20 Public Report 19/11/2015 Various reports on HCV clearances HCV Clearance Greenpeace, Chain • 28/1/2016: GAR sent an email to IOI requesting information Closed as of 3/3/2016 and RSPO violations on IOI Reaction Research • 4/2/2016: IOI sent extracts of documents confirming an administrative sanction has been served by PT BSS by the Indonesia Ministry of Forestry and Environment (MFE) including 6 mandatory actions 28/4/17 subsidiaries in Ketapang, Indonesia • 17/2/2016: IOI sent several documents to show efforts it is undertaking to fulfil MFE requirements http://www.greenpeace.org/interna • 4/4/2016: RSPO confirms IOI RSPO certification is suspended • 9/5/2016: IOI announces it is challenging RSPO suspension tional/Global/international/publication • 13/5/2016 GAR meets Aidenvironment to get latest updates. ns/forests/2015/Under-Fire-Eng.pdf • In letters dated 14 March and 28 April 2016, the RSPO Complaints Panel stated the conditions for lifting IOI Group’s RSPO certification suspension https://chainreactionresearch.files. • 2/6/2016: IOI issued a statement letter claiming saying it has met CP conditions and is developing more robust sustainability policy wordpress.com/2016/02/crr-ioisuspension- • 6/6/2016: IOI announced it would withdraw the legal challenge against the RSPO. analysis-final-revised may- • 17/6/2016: another report from Greenpeace was issued entitled “Why IOI’s Destruction in Ketapang is a Burning Issue” 2-2016.pdf • 23/6/2016: GAR held conference call with IOI: • IOI has taken steps to address conflict with Long Teran Kanan Longhouse community. A meeting with the community will be held at the end of June with a proposal to offer land to the communities. IOI will help the Long Teran Kanan community if they choose to plant oil palm. • Global Environment Centre has liaised on behalf of IOI with the Peat Restoration Agency • On the issue of fire, GAR will help IOI contact Asia Pulp and Paper to learn more about fire management as both their concessions in Ketapang are adjacent. • IOI is looking into the mistakes in Ketapang and taking steps to ensure they are not repeated • 25-26/7/16: IOI met Aidenvironment • 28/7/16: IOI and Aidenvironment issued joint statement: http://www.aidenvironment.org/wp-content/uploads/2016/07/Joint-Statement-on-Progress-Regarding-Ketapang-Complaint-29-July-2016.pdf • 5/8/16: RSPO lifted suspension on IOI group. http://www.rspo.org/news-and-events/announcements/update-on-the-status-of-ioi-groups-certification • 8/8/16: IOI met with GAR to give latest update on the grievance. • 15/8/16: IOI shared its new sustainability palm oil policy and sustainability implementation plan. • 16/8/16: GAR updated Greenpeace on the IOI grievance handling progress. • 27/9/16 GAR received a report from Greenpeace titled “A Deadly Trade-Off” http://www.greenpeace.org/switzerland /Global/Switzerland/de/publication/Fores ts/20160927_greenpeace_crimefile_ind onesien_ioi_engl.pdf • 4/10/16 GAR continued to engage with IOI concerning the GP report. IOI updated GAR re its official statement: http://www.ioigroup.com/Content/NEWS/NewsroomDetails?intNewsID=817 • 7/10/16 IOI issued a six-page statement explaining its actions and engagement with regards to the indirect and direct sourcing from the alleged suppliers in the GP report. • IOI released a detailed response to Greenpeace report http://www.ioigroup.com/Content/NEWS/NewsroomDetails?intNewsID=819 09/01/17: IOI publicised First Quarterly Sustainability Progress Update: http://www.ioigroup.com/Content/NEWS/NewsroomDetails?intNewsID=828 reporting on the Lidar project in Ketapang and the peat management implementation progress at PT.BSS, BNS & SKS. • 28/4/17 GP suspended its active campaign to give IOI time to show it is serious about reform http://m.greenpeace.org/international/en/high/press/releases/2017/Palm-oil-giant-IOI-moves-to-eliminate-deforestation-and-human-rights- abuses-from-supply-chain/ • Based on this, we consider the grievance closed. G21 Media Report 9/5/2016 1. Media report that PT APSL carried out land Forest Fire/Haze Media • 5/9/16: GAR halted purchases from PT APSL while Environment and Forestry Ministry and police investigate incident DAP clearing using fire • 6/9/16: GAR contacted PT APSL to ask for a meeting http://m.cnnindonesia.com/nasional/2016090 • 8/9/16: In the meeting with APSL: 4203531-20-156019/klhk-apsl-bakar-lahan- • APSL stated that the plantation where the fires occurred was not in its concession but in the plantations owned by independent farmer groups. The fires originated from outside their plantations and then spread into their area. The fires affected 2,000 hectares 2000-hektare-di-riau/ • APSL said it has an agreement with the farmer groups to develop and manage the plantation on their behalf. 2. Media report that PT APSL was allegedly • APSL denied the allegation that APSL instigated the incident involving KHLK personnel by the farmers involved in hostage situation in Rokan Hulu • APSL shared with GAR copies of farmer groups reports to the local police (Kelompok Tani Melayu Terpadu and Kelompok Tani Nelayan Andalan), chronology report (Kelompok Tani Nelayan Andalan) and other relevant documents district, Riau province and that employees of • 21/9/16: KLHK issued a letter stating that it has stopped investigating the case involving PT APSL and Kelompok Tani Nelayan Andalan as the case is now being handled by the police the Environment and Forestry Ministry were • 10-12/4/18: GAR conducted a site visit to PT APSL and confirmed that the forest fire case had been handled by the police and a suspect has been arrested for arson abducted while investigating last year's forest • In light of the above development, we consider this grievance closed for monitoring fires. http://jakartaglobe.beritasatu.com/news/envir onment-minister-condemns-hostage-situation- involving-palm-oil-company/

G22 Public Report 6/9/2016 RAN, OPPUK, and ILRF published a public Labour RAN, OPPUK and ILRF • 20/6/16: GAR grievance handling team held a meeting with GAR's HR Operation Head to discuss the report. Additional meetings held on 28/6/16 and 9/8/16 Open report titled: “The Human Cost of Conflict • 28/6/16: Indofood sent letter to RAN stating that RAN had not provided supporting facts and evidence to substantiate its claims in the report. Palm Oil”; alleging Indofood (PP Lonsum) was • 29/6/16: GAR held conference call with RAN. It was agreed that GAR and RAN would meet in August to discuss the findings directly with OPPUK. involved in labour/exploitation issues • 22/7/16: RAN replied to Indofood’s letter stating that the authors of the report had chosen not to share the transcripts of interviews with individual workers, workers’ documents, nor the GPS coordinates of photos taken, in order to protect the identities of the workers interviewed. RAN and its partners said they remained open to initiating a formal and constructive dialogue to discuss the ways in which Indofood can address the issues https://d3n8a8pro7vhmx.cloudfront.net/rainfo • 25/7/16: In view of confidentiality concerns, GAR asked RAN/OPPUK to allow GAR to have a look at documentation, transcript of interviews and/or listen to them without recording any details restactionnetwork/pages/15889/attachments/ • 29/8/16: GAR, RAN and OPPUK had a meeting. OPPUK said it would not share with GAR details of its methodology in order to protect the identity of workers for safety reasons original/1465330857/RAN_The_Human_Cost_ • 15/9/16: RAN shared ASI's recent report with GAR and claimed that the report corroborated many of its findings and broadened the scope of violations, as ASI's assessment was done on a another Indofood plantation. of_Conflict_Palm_Oil.pdf?1465330857 http://www.accreditation-services.com/resources/document-library/download-info/asi-rspo-sai-pc-compliance-indonesia-2016 • 27/9/16: GAR received a new public report from Greenpeace titled “A Deadly Trade-Off” alleging Indofood involvement in deforestation, peat, fires and exploitation. • 28/9/16: GAR sent a letter to Indofood asking for a meeting. • 7/10/16 RSPO Secretariat had a meeting with Indofood. • 11/10/16 The case of Indofood/Lonsum was filed by RAN to RSPO • 20/11/16: GAR’s announced a collaboration with industry peer Wilmar and global non-profit organization Business for Social Responsibility (BSR) to find solutions to Indonesian Palm Oil Sector Labour Challenges. http://goldenagri.com.sg/pdfs/News%20Releases/2016/News%20Release%207%20Nov%2016%20-%20GAR_WIL_BSR_Joint_Collaboration%20-%20Final.pdf • 28/11/16 GAR had meeting with Indofood: a) Indofood said there were 2 ASI assessments carried out: one in June 2016 and one in Nov 2016 , all corrective actions have been accepted by ASI. b) Indofood also said that they were currently waiting for reply from RSPO Complaint Panel and would follow RSPO requests. c) GAR recommended a joint BSR study on labour practices. • 2/12/16 GAR sent BSR study TOR to Indofood for review.

• 16/2/17: Indofood Agri launched its Sustainable (NDPE) Palm Oil Policy 2017 http://www.indofoodagri.com/misc/Sustainable_Palm_Oil_Policy_2017.pdf • 11/4/17: GAR and Indofood had meeting to discuss how Indofood implements its sustainable palm oil policy esp. re labour practices and human rights. GAR asked Indofood for a clear time-bound action plan on implementation of 2017 sustainability policy. • 26 /4/17: Indofood Agri published Sustainability Report 2016 which mentioned: http://indofoodagri.listedcompany.com/misc/sr2016.pdf a) Targets and timeline for its sustainability implementation (page 17-18) b) Labour practices related to allegations raised by RAN/OPPUK/ILRF (page 46-49) • 23/5/17: GP published Palm Oil Alert Bulletin about Indofood http://www.greenpeace.org/seasia/Global/seasia/2017/20170523_GP_PalmAlert_IndofoodSalim.pdf • 24/5/17: GAR had a meeting with Indofood to discuss Greenpeace Palm Oil Alert Bulletin. • Indofood denied its relationship with PT Gunta Samba Jaya, PT Malisya Sejahtera and PT Aneka Reksa International (companies mentioned by GP) • GAR obtained Indofood’s consent to conduct site visit In July 2017 at one of its sites in Riau (PT.SIP) to see its sustainable palm oil practices including labour. Prior to this, GAR will engage with OPPUK to get their advice on the checklist. • SAI Global Conducted a special audit at PP Lonsum Indonesia: file:///C:/Users/hero%20sanjaya/Downloads/SAI%20Global%20Audit%20Report%20(3).pdf. • 6/7/17: PT SAI no longer suspended by RSPO: http://www.accreditation-services.com/archives/certification_bodies/pt-sai-global-indonesia • 17-19/7/17: GAR conducted site visit to PT.SIP, another mill managed by Indofood Agri in Riau to check compliance with GAR Social and Environmental Policy especially re labour practices. GAR senior officers including Sustainability Implementation Head and Sustainability Human Resources Head joined the visit. • 18/9/17: GAR and PT.SIP met to discuss site visit report. No major non-compliance was found. However areas for improvement identified and GAR has helped PT SIP on a time-bound action plan. • 2-3/11/17: SAI carried out ground verification at PT PP London Sumatera Indonesia Tbk, Gunung Malayu Mill and its supply bases operations. • 16-27/12/17: Follow up audit. Recommended that PT. PP London Sumatera Indonesia Tbk. Gunung Malayu Mill can continue as a producer of RSPO Certified Sustainable Palm Oil and Palm Kernel Model Identity Preserved. • RAN issued a "revisit" report on Lonsum: https://d3n8a8pro7vhmx.cloudfront.net/rainforestactionnetwork/pages/19325/attachments/original/1511801724/Human_Cost_Revisited_vWEB.pdf?1511801724 • 16/1/18: GAR and Indofood had a meeting to discuss the incentive system for harvest workers • 1/3/18: GAR met Indofood: a. GAR emphasised the importance of effective communication with stakeholders as well as an independent assessment in parallel with the RSPO complaint process against Lonsum. b. GAR also discussed a study on workload and target-settings for harvesters. • 5/3/18: Indofood published a letter detailing chronology of events and actions taken in the grievance involving RAN, OPPUK and ILRF against Lonsum. http://indofoodagri.listedcompany.com/newsroom/Update_on_RAN_Labour_issues_website_FINAL_5_March_2018.pdf

• 12/4/18: RAN published a new report entitled “Palm oil sustainability assessment of Salim-related companies in Borneo peat forests” alleging PT DRM and PT SKL of committing peat clearance in Ketungau Forest https://d3n8a8pro7vhmx.cloudfront.net/rainforestactionnetwork/pages/19575/attachments/original/1523418189/Salim_Peat_Report_04102018.pdf?1523418189. On page 27, the report also mentioned five GAR supplier mills with high risk of sourcing FFB from DRM and SKL: PT. RAP, BPJ, Simba, ASL, BHA. Sejahtera mill, KSP and Belian mill were also mentioned as companies in the region that have potential risk of sourcing FFB from DRM and SKL. • 12/4/18: GAR asked Indofood/Salim for clarification: it denied any relationship with the two alleged companies. • 27/4/18: GAR engaged the five supplier mills as well as the other mills mentioned and asked for confirmation of whether they sourced from DRM and SKL. They all confirmed they did not source from DRM and SKL. • 11/5/18: GAR plans to engage with KLHK on this issue and conduct a site visit to verify the suppliers’ claims of not sourcing from DRM and SKL.

PT DRM and PT SKL • 12/4/18: RAN published a report entitled “Palm oil sustainability assessment of Salim-related companies in Borneo peat forests” alleging PT DRM and PT SKL of clearing peat in Ketungau Forest https://d3n8a8pro7vhmx.cloudfront.net/rainforestactionnetwork/pages/19575/attachments/original/1523418189/Salim_Peat_Report_04102018.pdf?1523418189. On page 27, the report also mentioned five GAR supplier mills with high risk of sourcing FFB from DRM and SKL: PT RAP, BPJ, Simba, ASL, BHA. Sejahtera mill, KSP and Belian mill were also mentioned as companies in the region have potential risk of sourcing FFB from DRM and SKL. • 12/4/18: GAR asked Indofood/Salim for clarification: it denied any relationship with the two alleged companies. • 27/4/18: GAR engaged the five supplier mills and the other mills mentioned and asked them to confirm if they sourced from DRM and SKL. They all confirmed they did not source from DRM and SKL. • 11/5/18: GAR plans to engage with KLHK on this issue and conduct a site visit to verify the suppliers’ claims of not sourcing from DRM and SKL at end July or early August 2018. • 30/5/18: GAR had a meeting with KLHK. They confirmed that the peat moratorium map (PIPPIB) is indicative and does not apply retroactively. • 6-11/8/18: GAR and TFT conducted a site visit to the mentioned suppliers.

G23.a. Public Report 9/27/2016 In a report titled “A Deadly Trade-Off”, Forest clearance/fire, Greenpeace 1. PT Austindo Nusantara Jaya - GAR does not buy from ANJ group - refer to no. G05 on grievance list. Closed as of Greenpeace reports that the IOI Group Peat, Labour, Human 2. Indofood/Salim Group 28/4/17 continues to buy palm oil from third-party rights • Please refer to grievance G22 for process of engagement with Indofood suppliers linked to environmental destruction 3. Korindo - GAR does not buy from Korindo. 4. TH Plantation/Lembaga Tabung Haji and exploitation (Austindo Nusantara Jaya, • 5/10/16: In meeting between GAR and Trurich (a JV between Felda and Lembaga Tabung Haji) Trurich explained PKP was not managed by Trurich but managed directly by TH Plantations in Malaysia. It also stated that Nyato and Eagle High Plantation/Rajawali, Pulai mills were sold in 2013. Goodhope/Carson Cumberbatch, Korindo, • GAR does not have current commercial relationship with Tabung Haji Plantations. Indofood, Tabung Haji Plantations): http://www.greenpeace.org/switzerland/Glob al/switzerland/de/publication/Forests/2016092 7_greenpeace_crimefile_indonesien_ioi_engl. pdf

G23.b. 5. Eagle High Plantation/Rajawali https://goldenagri.co • 30/9/16: In meeting with GAR, Eagle High said the areas where deforestation and fires happened in PT Arrtu Energi Resources concession are currently not under their control and that local communities are involved in the m.sg/sustainability- deforestation. GAR requested documentation and recommended a land tenure study. dashboard/files/file_do • On PT Tandan Sawita Papua, they briefly outlined their version of events on the labour dispute and the shooting incident. GAR requested supporting documentation. cs/OGwVNtsp_summa • 28/12/16: EHP met GP to share its response and said it was willing to share HCV study with GP. ry_report100418.pdf • EHP agreed with GAR’s recommendation to conduct a land tenure study. • GAR will provide training on this for the Eagle High team in Jan/Feb 2017 • GAR also recommended that PT AER to be involved in the Landscape Project in Ketapang, West Kalimantan. An initial meeting between EHP and Aidenvironment was planned for Jan 2017 • 23/01/17: GAR facilitated a meeting between Aidenvironment and Eagle High in Bogor to discuss the Kalbar Landscape project. Eagle High is studying the possibility of taking part in the project. • 25/01/17: Eagle High agreed that GAR conduct a site visit to PT TSP in April 2017. • 28/2-2/3/17: GAR and TFT conducted sustainable palm oil training for Eagle High which included Land Tenure Study • 7/2/17: AER shared its HCV assessment report. The report is being reviewed by GAR and TFT. • 17-21/4/17: GAR and TFT conducted a site visit at TSP. The report and action plan can be downloaded here: https://goldenagri.com.sg/sustainability-dashboard/files/file_docs/OGwVNtsp_summary_report100418.pdf

G23.c. 6. Goodhope/Carson Cumberbatch • 30/9/16: GAR contacted Goodhope to arrange a meeting • 24/10/16: In meeting with GAR, GH refuted GP’s allegations, explaining that: a. Deforestation: land clearing was carried out based on 2011 permit as EIA process was delayed due to local government regulation changes. b. Exploitation: GH claimed that state security forces (BRIMOB) presence at PT Nabire Baru was not on the company’s behalf; they were there in order to anticipate trouble caused by OPM. c. FPIC: Goodhope has hired consultant to review its implementation against the FPIC guidelines. d. Flood: Flood in Sima village was due to heavy rainfall and not land clearing. GH proactively offered logistic support to help the village. • GH agreed to share with GAR relevant documents including its environmental & social policy. • GH stated that a verification by RSPO is ongoing and would share results with GAR. • 19/10/16 – 8/11/16: GH had a meeting with Yayasan Pusaka and its affiliate FPP. Also had meetings with GP sharing updates with them, agreeing to share HCS/HCV assessment and agreeing to perform soil survey • 2/12/16: GH published update: http://www.goodhopeholdings.com/images/easyblog_articles/31/Status-Update-on-Greenpeace-report----Letter-from-COO---2-Dec-2016.pdf. • 28/12/16: GH updated GAR: a) GH updated GAR on its meeting with GP (see above) b) GH reiterated PT.NB land clearing had been carried out since 2011 in ex logging area. NPP was submitted before the clearing despite the fact that GH was not RSPO member at that time. (GH registered as RSPO member in 2014). c) Verifications on NPP were done twice by BSI in 2011 and 2016 but there was no response from RSPO on the NPP proposal. d) GH also stated PT.NB did not overlap with the latest government peat moratorium map e) On the alleged recent land clearing, GH explained that it was due to the regrown vegetation after the earlier land clearing since 2011. Some parts are likely plasma area (to be checked by GH). f) GH already has a Conservation and New Development Policy since May 2013 which includes HCS and HCV assessment prior to development and also no development on peat. GAR recommended GH develop SOPs. g) GAR recommended GH submit PT.NB HCS study for peer review to HCSA and consider joining HCSA. • Action plan agreed: a) Continue to work with Yayasan Pusaka to address the complaints through engagement with local community groups and PT. NB b) Share report of FPIC implementation assessment by LINKS c) Undertake reassessment of HCS for PT. NB d) Undertake detailed soil survey for PT. NB e) Provide shape files of all GH’s concessions in Papua to GP • 1/12/16 IOI and Aidenvironment made a joint statement: http://www.aidenvironment.org/wp-content/uploads/2016/12/Joint-statement-on-Ketapang-Complaint-Aidenviroment-IOI-Final-20161201.pdf • 2/12/16 Greenpeace publicized an update for palm oil buyers and customers / former customers of the IOI Group: http://www.greenpeace.org/seasia/Global/seasia/20161202%20IOI%20consumer%20company%20update.pdf • 14/12/16 IOI Loders had a conference call with GAR to discuss grievance handling process of the alleged third-parties (Eagle High, Indofood, Goodhope) • In Dec 2016 IOI launched its sustainability dashboard http://www.ioigroup.com/Content/S/S_Dashboard G23.d. • 26/01/17: GAR updated IOI Loders on engagement with Eagle High, Goodhope and Indofood. GAR showed maps that showed there had been no new land clearing in alleged areas in 2016. • 31/3/17L GP published Palm Oil Alert Report concerning GH: http://www.greenpeace.org/seasia/Global/seasia/2017/20170331_GP_PalmAlert_Goodhope.pdf • 5/4/17: GH responded to GP’s Palm Oil Alert Report http://www.goodhopeholdings.com/images/easyblog_articles/31/Response-on-Greenpeace-Palm-Oil-Alert.pdf • 18/4/17: GAR had update meeting with GH and provided inputs for draft GH sustainability policy. • 28/4/17 Greenpeace suspended its active campaign to give IOI time to show it is serious about reform http://m.greenpeace.org/international/en/high/press/releases/2017/Palm-oil-giant-IOI-moves-to-eliminate-deforestation-and- human-rights-abuses-from-supply-chain/ • 5/5/17: GH announced its sustainability policy http://www.goodhopeholdings.com/images/policies/Covering-letter-SustainabilityPolicy-5-5-17.pdf; http://www.goodhopeholdings.com/images/policies/GOODHOPE-SustainabilityPolicy-5-5- 17.pdf • 28/4/17: Precautionary measures (Stop Work Order) adopted by the RSPO Complaints Panel for developments at GH’s 7 PT’s: https://www.rspo.org/members/complaints/status-of-complaints/view/94 • 15/5/17: GH responded to the RSPO’s Precautionary measures (Stop Work Order) http://www.goodhopeholdings.com/images/policies/Goodhope-Sustainability-Journey-15052017.pdf • 22/5/17: GH submitted application for membership of High Carbon Stock Approach Steering Group (HCSA) as well as peer review proposals for its 7 concessions http://highcarbonstock.org/registered-hcs-assessments/ • 8/6/17: GH with Ata-Marie and Ekologika organized a public consultation on HCS and HCV. This consultation was attended by 45 participants from various stakeholders such as government bodies, NGOs, media, university, customary body, religious body, and others. • 15/6/17: More GH sustainability updates can be seen at: http://www.goodhopeholdings.com/images/policies/Sustainability-Journey-Updates-June-2017.pdf • PT NB and PT SAP are undergoing 1st round of HCSA reviews: http://highcarbonstock.org/registered-hcs-assessments/ • 27/2/18: GH held a stakeholder meeting in Sampit (Central Kalimantan) to share GH’s sustainability policy: http://www.goodhopeholdings.com/images/policies/GOODHOPE-SustainabilityPolicy-5-5-17.pdf http://www.goodhopeholdings.com/images/policies/ImplementationPlan-SP-5-5-17.pdf • GH monthly sustainability update can be found here: http://www.goodhopeholdings.com/sustainability/sustainability-journey

G23.e. Update on IOI group • See G20 for details • 2/12/16: Greenpeace published an update for palm oil buyers and customers / former customers of the IOI Group: http://www.greenpeace.org/seasia/Global/seasia/20161202%20IOI%20consumer%20company%20update.pdf • 14/12/16: IOI Loders had a conference call with GAR to discuss grievance handling process of the third-parties (Eagle High, Indofood, Goodhope) in the report • Dec 2016: IOI launched its sustainability dashboard - http://www.ioigroup.com/Content/S/S_Dashboard • 1/12/16: IOI and Aidenvironment made a joint statement: http://www.aidenvironment.org/wp-content/uploads/2016/12/Joint-statement-on-Ketapang-Complaint-Aidenviroment-IOI-Final-20161201.pdf • 26/01/17: GAR updated IOI Loders on engagement with Eagle High, Goodhope and Indofood. GAR showed maps indicating there had been no new land clearing in the areas reported by GP in 2016. • 28/4/17: GP suspended its active campaign to give IOI time to show it is serious about reform http://m.greenpeace.org/international/en/high/press/releases/2017/Palm-oil-giant-IOI-moves-to-eliminate-deforestation-and-human-rights- abuses-from-supply-chain/ • Based on this, we consider the grievance closed.

G24 Email to RSPO by 10/3/2016 Demands by members of Nanga Suhaid Community/smallhold FPP • 3/10/16: FPP forwarded letter to RSPO saying that the Nanga Suhaid community in PT KPC is demanding various actions by the company regarding land tenure, plasma revenues and water pollution. Open FPP community(as represented by FPP) in PT KPC ers/environmental • 10/10/16: GAR sent letter to RSPO detailing initial findings: that company takes action regarding return of management • GAR was informed by the KOPSA (smallholders cooperative) concerned that the views expressed in the letter are those of the individual signatories and do not represent the views of the KOPSA or the community. Out of the 22 land after end of HGU period; plasma signatories, only 4 of them are still KOPSA members, 11 have sold their land and left the KOPSA and 7 have never been members. The original plasma members numbered 493. • GAR is looking into each and every one of the demands and is addressing each appropriately through existing mechanisms and with stakeholders including the community and KOPSA. revenue; and water pollution allegations • Meeting with signatories will be facilitated by NGO LINKS to address complaints of each individual after 24 Oct. • Signatories will also be invited to meeting on plasma and on analysis of a three-month water quality study

G25 Public Report 11/28/2016 Alleged peatland violations by Tunas Baru Peat clearance Chainreaction, • Nov-Dec 2016: Tunas Baru Lampung (TBL) alleged to have cleared peat areas at its subsidiaries PT SJP (West Kalimantan) and PT DGS (South Sumatera). DGS was also accused of conducting new planting on burned peatland ex Open Lampung (TBL) Foresthints 2015 forest fire, most of which falls within BRG restoration map. https://chainreactionresearch.com/reports/20 • 2/12/16: TBL issued a letter to stakeholders denying the allegations : 16-sustainability-benchmark-indonesian-palm- a. TBL had sent a letter to Ministry of Environment and Forestry asking for time to explain the matter. b. TBL said PT.DGS’s location permit was for sugar plantation while PT SUJ location permit was for oil palm plantation. oil-growers/pt-tunas-baru-lampung-tbk-tblaij/ c. TBL never opened its area by burning and there was no plantation on ex-forest fire area. The oil palm plantation was located in PT SUJ concession, not in PT DGS concession. http://www.foresthints.news/top-officials- d. TBL claimed the alleged burnt area in 2015 as mentioned in the report was not in its concessions but on local community paddy fields. investigate-extent-of-palm-oil-company- • 9/1/17: GAR had meeting with TBL to seek clarification and explain GSEP. peatland-violations a. TBL stated that SJP (West Kalimantan) had stopped land development and no further land clearing. b. TBL agreed to share PT SUJ map (South Sumatera) to be further analysed by GAR c. GAR shared the PIPPIB map version 10 (indicative peat map) with TBL • 2/2/17: GAR sent letter to TBL to share the result of analysis on PT SUJ and indicative peat restoration map based on Letter of Peat Restoration Agency (BRG) no. 05/BRG/KPTS/2016. GAR recommended: a. Conduct a soil study for SUJ concession b. Based on the soil study, TBL to offer the map to BRG for verification c. Temporarily halt land development at PT SUJ until verification process by BRG is complete. • 27/3/17: GAR had a meeting with TBL to share how GAR engaged with BRG for the verification process of GAR’s concessions. • 12/10/17: GAR sent second letter to TBL reiterating recommendations in previous letter as our internal monitoring found further indication of land clearing at SUJ (Jul-Sep 2017) and SJP (Mar-Jul 2017). • 18/10/17: TBL sent letter denying any further land clearing at SUJ and SJP. It also stated that a soil study conducted at PT SUJ had been completed and the report was now being prepared. TBL also told GAR that it had sent a letter to BRG on 23 June 2017. • 15/3/18: By Chainreaction : “Tunas Baru Lampung: Contested land and peat clearing could drive substantial value loss” https://chainreactionresearch.files.wordpress.com/2018/03/tunas-baru-lampung-report.pdf • 23/3/18: TBL responded: http://www.tunasbarulampung.com/tblas-clarification/ • 28/3/18: By Chainreaction Network : https://chainreactionresearch.com/report/chain-reaction-research-response-to-tbla-rebuttal/ • 29/3/18: TBL published its second response: http://www.tunasbarulampung.com/tblas-clarification-2nd/ • 3/8/18: GAR internal monitoring and information from stakeholder indicates that land clearing in PT SUJ concession is still taking place as of July 2018 G26 Media Report 6/17/2017 PT Ivo Mas Tunggal accused of various Environmental Kompas Riau, Dewan 17/6/17: Kompas Riau published an article claiming PT IMT has not paid bonus to their contract workers (http://www.kompasriau.com/2017/06/17/pt-ivomas-tunggal-diminta-membayar-hak-karyawan/) The head of Dewan Pimpinan Open environmental and labour issues by Kompas Riau management/Industri Pimpinan Pusat Pusat Serikat Pekerja Perjuangan Indonesia (DPP-SPPI) union, Indra Gunawan, demanded PT IMT to pay the bonus of all their employees al relations & labour Serikat Pekerja • 20/6/17: PT IMT emailed Kompas Riau to clarify the bonus payment issue(http://www.kompasriau.com/2017/06/20/pt-ivomas-tunggal-klarifikasi-soal-pemberian-bonus-karyawan-rkwt/) Perjuangan Indonesia • As of 3/9/17 3 more articles have been published regarding PT IMT operations: (DPP-SPPI) o 12/7/17: PT IMT has provided bad quality rice to their workers (http://www.kompasriau.com/2017/07/12/beras-catu-buruh-pt-ivomas-tunggal-tak-layak-konsumsi/) o 20/7/17: Top Management of PT Ivo Mas Tunggal is still “silent” re allegations of land grabbing(http://www.kompasriau.com/2017/07/20/oknum-petinggi-pt-ivo-mas-tunggal-masih-tutup-mulut-soal-dugaan-penyerobotan-tanah- negara/) o 28/7/17: Owner of PT Ivo Mas Tunggal is “untouchable” (http://www.kompasriau.com/2017/07/28/pemilik-pt-ivo-mas-tunggal-disebut-sebut-kebal-hukum/) o 20/8/17: Management of PT Ivo Mas Tunggal has not clarified wastewater and state land issues (http://www.kompasriau.com/2017/08/20/petinggi-pt-ivo-mas-tunggal-belum-mengklarifikasi-soal-air-limbah-dan-tanah-negara/) o 30/8/17: SPPI will demonstrate against PT Ivo Mas Tunggal’s fraudulent behaviour (http://www.kompasriau.com/2017/08/30/sppi-bakal-unjuk-rasa-terkait-pt-ivo-mas-tunggal-diduga-gelapkan-uang-beras-buruh/) o 3/9/17: Anas Barus on allegations that PT Ivo Mas Tunggal dumped wastewater into the river (http://www.kompasriau.com/2017/09/03/anas-barus-asbun-soal-pt-ivo-mas-tunggal-diduga-masih-buang-air-limbah-ke-sungai/) o 3/9/17: Authorities should not turn blind eye towards allegations that PT Ivo Mas Tunggal is dumping wastewater into the river (http://www.kompasriau.com/2017/09/03/aparat-jangan-tutup-mata-terhadap-pt-ivo-mas-tunggal- diduga-buang-air-limbah-ke-sungai/) • 8/9/17: PT IMT Communications Team sent a letter to Bapak Sitompul, Chief Editor of Kompas Riau, with the following clarifications: o Re PKS waste contamination in the Kandis River, Kandis district: On 6/9/17 a team from the Siak Regency Environmental Agency came to investigate the allegations by kompasriau.com. o Based on the site visit, the team stated that the condition of drainage channel of tangkos water leachate and leachate ponds of PT IMT are clean and the pipes in bagwark that are used as rain water channels to the river are clean and permanently closed. Therefore, the allegations by kompasriau.com are not true. o On Caltex land: PT IMT and PT CPI have signed a Memorandum of Understanding (MoU) dated 8th January 1996 which was amended through Addendum I in 2007 and Addendum II in 2009. It was made and agreed in accordance with applicable procedures and with the approval and recommendation of the Directorate General of Oil and Gas, Ministry of Mines and Energy (currently Ministry of Energy and Mineral Resources. o PT IMT refutes the allegations of violation of workers’ rights and embezzlement of workers’ wages. PT IMT has operated in accordance with applicable regulations. Wages paid to workers are based on the Riau Province Minimum Wage (UMSP). The workers’ wages of PT IMT have been agreed to and stated in the Joint Working Agreement of the Cooperation Agency of Sumatran Plantation Company (PKB BKS-PPS). In the PKB it is stipulated that the total wage of workers consists of wages and an allowance of 15kg of good quality rice acceptable to the parties. o Based on the Minutes of the Joint Agreement, the nominal Province Minimum Wage (UMSP) in 2017 is IDR 2.516.812, - this includes allowance of 15kg of rice. PT IMT does not deduct wages in payroll for the purchase of rice as reported by kompasriau.com as the wage amount was set at the beginning of the year according to the agreement and is valid for the entire year. The value of rice (BKS-PPS) is announced and to be used as a guideline for BKS-PPS members to calculate overtime wages, severance pay or when allowances are given in the form of money. In the event that the rice received is not of good quality, there is a procedure to return the rice. Trade union representatives acting with the knowledge of company representatives can return the rice which will be exchanged in accordance with applicable procedures. o If the rice is not of acceptable quality then the rice is directly returned to the vendor according to the applicable procedure. o As part of the company’s good faith, PT IMT also provides similar quality rice for the dependents of the workers. The worker’s spouse receives 9 kg and each child gets 7.5 kg rice (with a maximum limit of 3 children) • The Communications Team requested Kompas Riau to issue a retraction of the above articles and to be more independent, balanced, unbiased, and accurate with their news. • To date, there has been no response from Kompas Riau and the grievance is still considered open.

G27 Public Report 7/15/2017 PT Sawit Mas Sejahtera (SMS) accused of not Industrial FPP, SBPKS-GSBI • 15/7/17: FPP published story about PT SMS saying it was not complying with labour laws and regulations. The article included a joint statement from SBPKS-GSBI labour union Closed as of complying with labour laws and regulations Relations/Labour labour union • The NGOs demanded that GAR comply with the relevant labour laws and regulations, make good on overdue payments for overtime, and reinstate unfairly dismissed workers 26/7/17 http://www.forestpeoples.org/en/private- • Their statement was filed with the Ministry of Labour and Transmigration, the National Human Rights Commission (KomNasHAM), and with the RSPO sector-palm-oil-rspo/news- • 26/7/17: a statement from GAR management was sent to all related stakeholders stating the dispute between PT SMS and SBPKS-GSBI labour union has been settled • The grievance is considered closed article/2017/plantation-workers-golden-agri- resources-estates

G28 Email/Public Report 7/24/2017 Greenpeace published its third palm oil alert Deforestation, peat Greenpeace • GAR does not source from FGV but acknowledges procurement from Trurich Resources; a joint venture between FGV and LTH (Lembaga Tabung Haji). GAR continues to bulletin: FGV (Felda Global Ventures) allegedly and labour • 1/8/17: GAR engaged with Trurich Resources asking for clarification about who is controlling Trurich Resources. monitor cleared natural forest and peat (PT.CNP and • 3/8/17: Trurich Resources confirmed that there was no controlling shareholder in this venture. Day-to-day operation decision is made by management independently without any interference by both shareholders. PT.TAA), and is in violation of Malaysian • 10/8/17: GAR had a meeting with Greenpeace and explained the matter. • 14-17/11/17: GAR conducted a site visit as part of our supplier transformation programme to one of Trurich subsidiaries: PT Teknik Utama Mandiri in Kalimantan Utara. labour law and exploiting workers. http://www.greenpeace.org/seasia/Global/sea sia/2017/20170726_GP_PalmAlert_Felda.pdf

G29 Media Report 8/14/2017 PT Dian Anggara Persada (PT.DAP) allegedly Labour Konfederasi Serikat • 24/8/17: GAR meeting with owner and senior management of PT DAP re the issue GAR continues to https://goldenagri.co violated worker’s freedom of association Buruh Sejahtera • PT DAP confirmed there was a labour dispute and was being addressed in labour (industrial relations) court monitor as of 12/2/18 m.sg/sustainability- http://pekanbaru.tribunnews.com/2017 Indonesia (KSBSI) • The company disputed the labour union’s (KSBSI) account of events, i.e. that arrest of union member was a result of illegal action that was reported to the police. dashboard/files/file_do Riau • GAR has asked PT DAP to provide documents to support their version of events cs/NvYnJdap_executiv /02/21/diduga-langgar-kebebasan- • 6/9/17: GAR met organisations who are monitoring and reporting on the case : Ms. Amalia Falah Alam, The National Federation of Christian Trade Unions in the Netherlands (CNV); Mr. Edward Marpaung, Secretary General of KSBSI e_summary_english.p berserikat-pt-dian-anggara-persada- (The Confederation of Indonesia Prosperity Trade Unions); Mr Haris Manalu, Legal Aid FKUI (Federation of Public Construction and Informal Unions) a union member of KSBSI who is overseeing the case in PT DAP; Mr. Mohamad Firma, df diadukan-ke-komnas-ham-dan-polda-riau Secretary General of Central Executive Board of FKUI; Ms. Rosmina Pakphanan, Chairman of the Central Executive Board of FKUI. Important points from the meeting: • CNV, KSBSI and FKUI are the organisations which sent a complaint on PT DAP to one of GAR’s customers who then forwarded it to GAR • They presented facts that were stated in their written complaint • They want reestablishment of negotiation and social dialogue with the company to resolve the matter •11/9/17: GAR met owner and management of PT DAP, Mr. Dian Anggara and Mr Samosir, in which they agreed to meet with representatives of CNV, KSBSI, and FKUI to explore reestablishment of negotiation and social dialogue between DAP and unions. •12/9/17: GAR met Ms Amalia and Karen Bouwsma of CNV and Mathias Mehan SH of Hukatan another union under the FKSBI and updated them that management of DAP has agreed to meet up with KSBSI before the end of Sept. • 5/10/17: GAR facilitated dialogue between KSBSI and DAP in Medan to find alternative win-win solutions • 26-27/10/17: GAR conducted a verification visit at PT DAP to gain more information and develop recommendations for DAP management 12/1/18: GAR had update meeting with CNV: •Both civil and industrial courts have issued a verdict. Re the industrial court case, FKUI/KSBSI will lodge appeal •DAP management is committed to implement the courts’ rulings •During a site visit our team found that there were no longer any current FKUI-KSBSI union members at PT DAP • 2/2/18:GAR and DAP had a conference call to discuss the site visit report and agree on action plan • 9/2/18:GAR published the site visit report and action plan. The executive summary can be found on the GAR Sustainability Dashboard: https://goldenagri.com.sg/sustainability- dashboard/files/file_docs/NvYnJdap_executive_summary_english.pdf • 12/2/18:In light of developments, GAR and CNV agreed that this grievance would be closed for monitoring

G30 GAR internal 10/20/2017 GAR found indication of deforestation through Deforestation GAR • 20/10/17: Through our internal monitoring/due diligence system, we found indications of a recent deforestation at PT Flora Nusa Perdana (FNP) in Central Kalimantan. PT FNP is a subsidiary of Sumber Tani Agung (STA) group. Open monitoring process internal monitoring process at PT Flora Nusa • 2/11/17: GAR made initial contact with STA Perdana, part of Sumber Tani Agug (STA) • 14/11/17: GAR had meeting with STA in Medan: group in Central Kalimantan • STA confirmed the land clearing activity stated in the report • GAR reiterated and stressed our commitment on “no development of and the conservation of HCS/HCV forests” to STA and recommended PT FNP to conduct an HCS/HCV study before continuing the land clearing. • STA said it would discuss internally and revert asap • 27/11/17: GAR sent official letter to STA management requesting that it stop the land clearing at FNP and conduct HCV/HCS studies • 14/12/17: STA management sent letter stating it would stop land clearing at FNP and conduct HCV/HCS studies • 12-17/3/18: TFT carried out scoping activity at FNP in order to give recommendations for the HCS/HCV conservation. G31 GAR internal 10/20/2017 GAR found indication of deforestation through Deforestation GAR • 20/10/17: Through our internal monitoring/due diligence system, we found indications of ongoing forest clearing taking place at PT MIP in East Kalimantan. PT MIP is a subsidiary of Widya Corp. Open monitoring process internal monitoring process at PT MIP, part of • 20/10/17: GAR made initial contact with Widya Corp to ask for clarification Widya Corp. in East Kalimantan • 27/11/17: Widya Corp sent a clarification letter to GAR explaining that PT MIP had fulfilled all legal requirements and is not located in a legally forest area. • 5/12/17: GAR had a meeting with Widya Corp management to socialise GSEP and discussed the ongoing forest clearing at PT MIP. In this meeting Widya Corp confirmed the deforestation. • 12/12/17: GAR sent a letter to Widya Corp management requesting they stop further land clearing at PT MIP and conduct HCV/HCS studies • 5/1/18: GAR and Widya management had meeting - GAR stressed once again that its supply chain has to be sustainable in line with the GSEP • 3/8/18: GAR internal monitoring and information from stakeholder indicates that land clearing in PT MIP concession is still taking place as of July 2018. • 28/8/18 GAR had a meeting with PT.MIP. PT MIP told GAR that the management had issued a stop work order for PT MIP: No.001/VIII/MIP/2018 dated 20 August 2018. PT MIP also updated GAR that HCV and HCS studies had been conducted since mid August 2018 by registered assessors (Siswoyo for HCS and Iksal Yanuarsyah for HCV) and peer reviews would be conducted for the studies (HCSA for HCS and HCVRN for HCV).

G32 Media Report 11/13/2017 Allegations of land grab by Sinar Mas Group Social Conflict James Watt • 13/10/17: Mongabay published article about a farmer, James Watt who claimed his land was taken over by Sinar Mas Group Closed https://news.mongabay.com/2017/10/the- • The case is considered closed based on findings by a multi-stakeholder fact-finding team in 2006: palm-oil-fiefdom/ - James Watt initially made a claim against PT Binasawit Abadi Pratama (formerly PT Agro Mandiri Perdana) together with another group led by Yohanes Hariwung in 2005 - Yohanes Hariwung laid claim to an area of 31,000 hectares of land and James Watt claimed that his land was in addition to and separate from that area - Both claims exceeded PT AMP’s area considerably, as the company was only given an Ijin Lokasi for 17,000 hectares of land - In 2006, a fact-finding team launched an investigation on-site. The team comprised representatives from the Regional Police of Central Kalimantan and the Seruyan Subregional Police, officers from the National Land Agency (BPN) of Seruyan Regency, Danau Sembuluh District Head, Terawan Village Head and related agencies at regency level as well as representatives from PT AMP and YH’s group - The fact-finding team found that the area that could legitimately be laid claim to by the complainants was about 2,000 hectares. However, the company had already paid compensation to the owners for that area - The case regarding the claims in excess of that area was closed as the complainants could not prove their legitimate claim to the area.

G33.a. Email/Public Report 11/17/2017 4 companies alleged to have carried out Deforestation Mighty Earth Mighty Earth Rapid Response Report No. 1 Open deforestation: PT Bintuni Agro Prima Perkasa, • 17/11/17: GAR contacted Indofood , Sumber Tani Agung (STA), and Anglo Eastern Plantation (AEP) requesting clarification. PT MAS is not part of GAR supply chain. PT Guntur Madu Agrotama,PT Kahayan Agro • Indofood denied any links to PT BAP. Plantation, PT Mustika Agung Sentosa. Raw • 18/5/18: AEP management announced the HCS study at KAP, declared to cease land clearing, and that it would follow the result of the study: http://www.angloeastern.co.uk/~/media/Files/A/Anglo- Eastern/documents/HCV%20and%20Scared%20Tribal%20Sites.pdf. materials from at least one of these • AEP denied any business links/FFB procurement from PT GMA. On PT KAP, AEP said it had conducted HCV study for PT KAP in 2013 and has shared it with GAR for further review. companies is allegedly entering GAR supply • STA denied any business links/FFB procurement between PT TPA and PT KAP. chain. http://www.mightyearth.org/wp- • 16/1/18: GAR and AEP had a meeting to discuss allegations and to share GSEP especially on “no deforestation” commitment content/uploads/2017/11/Mighty-Earth-Rapid- • 1/2/18: GAR wrote a letter asking AEP to conduct HCS study at KAP and to announce a moratorium until the study is complete. GAR requested the announcement to be made public. Response-Report-1.pdf • 5/2/18: AEP management notified GAR that it is in the process of appointing a consultant for the HCS study at KAP and drafting an announcement for its website about the moratorium. • 2/3/18: AEP appointed PT Meganesia Tirta Foresta to conduct HCS study at KAP. MTF team leader (Adi Wijoyo) is a registered HSCA practitioner: http://highcarbonstock.org/hcs-approach-quality-review-process/hcs-approach- registered-organisations/ • 21/5/18: AEP management published a public statement in its website: https://www.angloeastern.co.uk/~/media/Files/A/Anglo-Eastern/documents/HCV%20and%20Scared%20Tribal%20Sites.pdf stating the following: a. PT Kahayan Agro Plantation (“KAP”), a member of the Anglo Eastern Plantation Group, has always been committed to protecting High Conservation Value (“HCV”) areas including the habitat of orang utans and to respecting the tribal beliefs of the indigenous Dayak Communities. b. As a commitment to the concept of sustainable plantation development, KAP has appointed PT. Meganesia Tirta Foresta, whose team and personnel have been registered at High Carbon Stock (“HCS”) Network to conduct High Carbon Stock Assessment. Subsequent land clearing activities will be based on the results and recommendation of the independent High Carbon Stock Assessment.

G33.b. Mighty Earth Rapid Response Report No. 2 • Dec 2017: Mighty Earth published Report no.2 http://www.mightyearth.org/wp-content/uploads/2018/03/Mighty-Rapid-Response-Report-2_Dec.-17.pdf • Companies allegedly carrying out deforestation: PT Berau Karetindo Lestari, PT Rimba Karya Rayatama, PT Harapan Rimba Raya and PT Simpi Indai. • PT.Rayatama Jaya and PT Harapan Rimba Jaya are subsidiaries of Tsani Hutani Abadi group. RJ and HRJ are not GAR’s direct suppliers. Nevertheless, GAR buys from another subsidiary of Tsani Hutani Abadi group. • 24/1/18: GAR had a meeting with Tsani Group to discuss the allegation. Tsani Group asked for time to confirm with its management and team on the ground about the land clearing at PT RJ and HRJ. • 2/2/18: GAR wrote a letter to Tsani Group asking them to conduct HCS study at RJ and HRJ and to announce a moratorium until the study is complete • 2/5/18: Due to an unsatisfactory response from the Tsani Group, GAR sent a second letter to Tsani Group management repeating the same request

G33.c. Mighty Earth Rapid Response Report No. 3 • Feb 2018: Mighty Earth published Report No.3 http://www.mightyearth.org/wp-content/uploads/2018/03/Mighty-Earth-Rapid-Response-Report-3-Final-2.pdf • Companies alleged of carrying out deforestation are PT Rimbun Sawit Papua, PT Sawit Mandiri Lestari, PT Agriprima Cipta Persada, PT Agrinusa Persada Mulia, PT Permata Putera Mandiri (Blok I), PT Citra Palma Pertiwi 2 & PT Borneo Citra Palma Abadi. • RSP, SML (see G06), PPM (See G05), CPP2, BCPA are not GAR suppliers. GAMA Group • PT ACP is a subsidiary of GAMA group. GAR last procured from a subsidiary of GAMA in Q1 2017. • 11/5/18: GAR received feedback from stakeholders that two companies GAR were buying from i.e. Gandaerah and Inecda are part of Ganda Group. GAR sent a letter to Samsung C&T which manages Gandaerah and Inecda to ask for clarity over its relationship with Ganda group • 14/5/18: Samsung C&T states that Gandaerah and Inecda are fully managed by Samsung C&T and are not part of Ganda group, as alleged by Mighty Earth in its report • 19/7/18: GAR met management of PT Gandaerah and PT Inecda. They once again confirmed that both companies are under Samsung C&T management and not under GAMA/Ganda group. They agreed to GAR request for site visit to PT Inecda under the ART programme. • 27/7/18: Gandaerah and Inecda management sent an official letter stating that PT Gandaerah and Inecda has been solely operated by Samsung C&T since 2008 and Ganda group has no management control of their operation. • Based on official notarised documents, GAR verified that Ganda Sawit Utama owns only 5% shares in PT Gandaerah and PT Inecda. • GAR engaged with Aidenvironment as GAMA’s sustainability implementation partner on the issue of links between GAMA and PT Gandaerah/PT Inecda. Aidenvironment confirmed that PT Gandaerah and PT Inecda are not controlled by GAMA and both companies are not under GAMA. • On its website http://www.gamaplantation.com/ GAMA announced a list of 26 companies it manages which did not include PT Gandaerah and PT Inecda. The 27 companies are PT. Agri Sentosa Gandadigo, PT. Agro Alam Nusantara, PT. Alam Jaya Persada, PT. Berkat Sawit Utama, PT. Bumi Alam Sentosa, PT. Citra Mahkota, PT. Citra Riau Sarana, PT. Ganda Sawit Utama, PT. Graha Agro Nusantara, PT. Indo Kebun Unggul, PT. Intitama Berlian Perkebunan, PT. Jatim Jaya Perkasa, PT. Karya Agung Megah Utama, PT. Nusa Jaya Perkasa, PT. Patiware, PT. Perkebunan Anak Negeri Pasaman, PT. Putra Lirik Domas, PT. Sawit Unggul Agro Niaga, PT. Sentosa Asih Makmur, PT. Sumatera Unggul Makmur, PT. Swadaya Indopalma, PT. TH Indo Plantation, PT. Tritunggal Sentra Buana, PT. Wahana Karya Sejahtera Mandiri, PT. Wawasan Kebun Nusantara, PT. Agrinusa Persada Mulia, PT. Agriprima Cipta Persada • 18/9/18: GAMA launched its Group Sustainability policy which included a stop work order http://gamaplantation.com/assets/gama-files/page/5ba77c75a7841.pdf. GAMA stated that “GAMA Plantation, together with its subsidiaries - commits to adhere to the Sustainability Policy that is based on "No Deforestation, No Peat, No Exploitation" (NDPE) principles” • GAR and GAMA will have a meeting to discuss progress and workplan on Oct 12th, 2018. This meeting will be facilitated by Aidenvironment.

G33.d. Mighty Earth Rapid Response Report No. 4 • 12/6/18: Mighty Earth sent GAR a Rapid Response Report No.4 http://www.mightyearth.org/wp-content/uploads/2018/06/Mighty-Rapid-Response-Report-41.pdf • Companies alleged of carrying out deforestation: BLD Plantation Bhd , PT Permata Putera Mandiri (Blok I) , Licensed to Plant Forests LPF/0039 Zedtee SB , PT Agriprima Cipta Persada , and PT Condong Garut. • GAR does not source from those five alleged companies. • JA Wattie is GAR’s supplier, however, GAR is not aware that PT Condong Garut is an oil palm plantation managed by JA Wattie & Co as the report claims. • 20/7/18: GAR met JA Wattie management to request clarification about whether they had any relationship/control over PT Condong Garut. GAR also sent formal letter on the matter. • 25/7/18: JA Wattie management issued a letter to GAR stating that PT Condong Garut management had not been under PT JA Wattie anymore since 1970 based on letter from Indonesia Finance Ministry.

G33.e. Mighty Earth Rapid Response Report No. 5 • 17/7/18: Mighty Earth published Rapid Response Report No.5. Palm oil comapnies alleged of committing deforestations are PT Palem Segar Lestari, PT Megakarya Jaya Raya, PT Kartika Cipta Pratama, PT Krida Dharma Kahuripan, PT Kapuasindo Palm Industry, PT Rimba Karya, PT Rayatama, PT Harapan Rimba Jaya, and PT Persada Kencana Prima. Of those, companies linked to GAR supply chain at group level are PT KPI, PT RJ (indirect), PT HRJ (indirect), and PT KDK (indirect). http://www.mightyearth.org/mighty-earth-rapid-response-report-5/ • PT Kapuasindo Palm Industry: see G39 • PT Rayatama Jaya & PT Harapan Rimba Jaya (Tsani group): see G33.b. • Tabung Haji Plantation (case: PT.Persada Kencana Prima): see G23 and G28. Ladang Pasir and Kota Bahagia mills are not linked to GAR suppy chain. • PT Krida Dharma Kahuripan (claimed as MAKIN group): • 17/7/18: GAR contacted PT KDK and asked for clarification • 17/7/18 PT KDK management shared with GAR its official letter to Katingan Regent dated 11 July 2017 stating that PT KDK’s ILOK (location permit) was returned to the local government as the land was categorised as forest area and could not be converted to non-forest area • 10/8/18: A detailed chronology was sent to GAR for review (about the PT KDK ILOK return to the local government). G33.f. Mighty Earth Rapid Response Report No 6 • 24/8/18 Mighty Earth published Rapid Response Report No.6 http://www.mightyearth.org/wp-content/uploads/Rapid-Response-Report-6.pdf • Palm oil companies alleged of committing deforestation are as follows: a. PT Permata Putera Mandiri (Blok I), PT Berau Karetindo Lestari, PT Pipit Citra Persada, PT Subur Karunia Raya, BLD Plantation Bhd are not GAR suppliers b. PT Rayatama Jaya (Ex. PT Rimba Karya Rayatama) 8: see G33.b. c. PT Condong Garut: see G33.d. d. PT Kapuasindo Palm Industry: see G39 e. PT Sumur Pandanwangi: PT.Sumur Pandanwangi is not a GAR supplier, but GAR buys from PT.Asam Jawa. GAR will engage with PT AJ f. PT Mulia Inti Perkasa: see G31 g. PT Prasetya Mitra Muda Blok II: PT PMM is not A GAR supplier, but GAR buys from PT Nusantara Sawit Persada which is allegedly linked to Samuel International group. GAR will engage with PT.NSP. • 3/9/18: GAR had a meeting with PT.NSP and asked for a clarification. GAR is preparing a formal letter to PT.NSP management. h. PT Krida Dharma Kahuripan: see G33.e. G33.g. Mighty Earth Rapid Response Report No.7 • 22/9/18: Mighty Earth published Mighty Earth Rapid Response No.7 http://www.mightyearth.org/wp-content/uploads/Rapid-Response-Report-7-August-2018.pdf • Palm oil companies allegedly committing deforestation are PT Internusa Jaya Sejahtera, PT Kusuma Alam Sari, PT Palem Segar Lestari, PT Sawit Mandiri Lestari, PT Kartika Cipta Pratama, and BLD Plantation • None of the above palm oil companies are linked to GAR supply chain

G34.a. Email to GAR 12/13/2017 Deforestation Case studies of 16 group HCS/HCV/Peat Greenpeace • 13/12/17: GAR received an email from GP re Deforestation Case studies of 16 group companies: Anglo Eastern Plantation, Austindo Nusantara Jaya, Central Cipta Murdaya (Murdaya Family), Ciliandra Fangiono Martias and Family, Citra Open companies. clearance Borneo Indah, Djarum, DTK Opportunity, Felda/FGV, GAMA (Formerly Ganda), Hayel Saeed Anam, IJM Corporation, Indonusa, Lembaga Tabung Haji, NPC Resources, Salim, Sungai Budi. • 15/12/17: GAR conducted an internal analysis and engaged with respective suppliers. 1. AEP: See G32 2. ANJ: see G05 3. Central Cipta Murdaya (Murdaya Familiy): not GAR's supplier, 4. Ciliandra Fangiono Martias and Familiy: GAR's last purchase was in Q3 2017, 5. CBI: see G06 6. DTK Opportunity: not GAR's supplier • However, GAR identified two supplier companies as part of the flow chart shown in the report i.e. PT.Aditya Agroindo and PT.Kemilau Indah Nusantara. • 10/7/18: GAR had a meeting with PT AAI and PT KIN to discuss the grievance and ask for clarification. • 25/7/18: GAR sent official letters to both companies requesting clarification on links to DTK Opportunity. 7. Felda/FGV: see G23 and G28 8. GAMA(Formerly Ganda): see G33; GAR's last purchase was in Q1’2017, 9. Hayel Saeed Anam: not GAR's supplier 10. IJM Corporation: not GAR's supplier 11. Indonusa: not GAR's supplier 12. Lembaga Tabung Haji: see G23 and G28 13. Salim: See G22 14. Sungai Budi: See G25 15. Djarum/HPI • 2/2/18: GAR and Djarum/HPI had a meeting to share GSEP, discuss GP report and ask for clarification on PT GSK. • 25/1/18: Djarum/HPI sent a letter to GAR, explaining that PT GSK had already fulfilled all prevailing legal requirements for its operations. • 5/2/18: GAR sent a letter to Djarum/HPI management to request for confirmation of its moratorium and HCS/HCV/peat studies. • 16/5/18: Due to unsatisfactory response, GAR sent a second letter to Djarum/HPI management. • 31/5/18: In a letter HPI stated that it was committed to implement a No Deforestation, No Peat and No Exploitation Policy as recommended by GAR 16. NPC Resources: • Apr/17: GAR received feedback from a stakeholder that NPC was committing forest and peat clearance at PT Sumber Alam Selaras (East Kalimantan). Some parts of the concession also overlapped with KLHK - Kawasan Hidrologis Gambut map (Hrydology Peat Area). • 12/4/17: GAR and NPC had a meeting to share GSEP, and discuss the issue. NPC confirmed the allegations and GAR requested a moratorium and HCS/HCV/peat studies at PT SAS. • 5/9/17: GAR sent a letter requesting confirmation of moratorium, HCS/HCV/peat studies at PT SAS, and engagement with KLHK on the overlapped area. • 5/6/18: GAR sent a reminder letter to NPC. • 5/6/18: NPC responded to GAR stating it had appointed Aksenta team to do HCV and HCS studies at PT SAS and was in the midst of finalising the report. In the meantime, NPC also stated it had stopped all land clearing activities at PT SAS while waiting for recommendations from Aksenta team.

G34.b. • 19/9/18: Greenpeace published a report “Final Countdown” https://www.greenpeace.org/international/publication/18455/the-final-countdown-forests-indonesia-palm-oil/ • Of the 26 group companies mentioned in the report, GAR is currently buying from : 1. Anglo Eastern Plantation (see G32) 2. Bumitama Agri (see G16) 3. Djarum/HPI (see G34.a.15) 4. DTK Opportunity (See G34.a.6.) 5. Felda/FGV (see G23 and G28) 6. GAMA - Formerly Ganda (see G33.c.) 7. IOI (see G20) 8. Lembaga Tabung Haji (see G23 and G28)

G35 Letter to GAR 43086 Complaint by Desa Lidung against PT Kresna Social & Desa Lidung • 17/12/17: Desa Lidung sent a letter of complaint against KDA and Tiga Serumpun Co-op: Open Duta Agroindo (KDA) and Tiga Serumpun Community a. KDA and Tiga Serumpun did not implement the cooperative credit system transparently Cooperative re local community development b. Clarification re community land which had been released; the community had given up 800 ha but the company only indicated there was 670 ha under management c. Lake Biaro has not been cleaned d. Road closure by KDA • 26/2/18: the company sent a statement to the Village Head of Desa Lidung with a copy to Jambi government, National Commission of Human Rights, several ministries and local institutions stating: a. KDA through the Tiga Serumpun co-op runs the cooperative credit system transparently b. Through Location Permit No 176 issued on 8/12/00 Tiga Serumpun Co-op was granted permission to manage an area of 2000 hectares which includes an area of 670 ha belonging to Desa Lidung. The local government and the Agricultural Ministry carried out initial inventory showing that the land has around 800 ha in the form of shrubs and the available land that can be developed is 670 ha. c. The cleaning of Biaro Lake is a large-scale effort and discussions need to be conducted with the District Government on a feasibility study. The parties involved can consider alternative CSR programmes in the meantime. d. The company did not close the road. This was done by a group of Lidung villagers in protest over alleged non-compliance of agreement to develop palm oil. G36 Letter to RSPO & 1/22/2018 PT Ivo Mas Tunggal (IMT) alleged to be Social Conflict LBH Sakai Riau (Sakai • 18/1/18: LBH Sakai Riau sent a letter to RSPO about PT IMT regarding alleged land clearing outside HGU, operating on community land without compensation (± 6,500 Ha), and lack of appropriate permits (IUP and AMDAL, and forest Open ISPO operating on community land without Legal Aid Bureau) release) compensation • LBH Sakai Riau has asked RSPO to note their grievance and revoke certification based on the grievance • 14/2/18: ISPO which also received the similar complaint asked the company to verify the complaint • 21/2/18: Complaint was discussed in RSPO Complaints Panel Meeting • 8/3/18: PT IMT sent a letter responding to LBH Sakai’s complaints in which they refuted the allegations and explained the situation: - the land had been acquired legally by the company and this had been explained and clarified to LBH Sakai in a meeting facilitated by the local government in Siak on 17/11/17 -The area of 6,505, 42 Ha is entirely within the location permit and the disposal of forest area or HGU PT. Ivomas Tunggal. This is corroborated by Ministry of Forestry Decree No: 036 / Kpts / II / 90 dated January 20, 1990). The Company has also provided compensation for the community's land. • 25/4/18: PT IMT sent a letter to RSPO stating it is aware of the complaint and is handling it in accordance with its Grievance Handling procedure • As of Sept 2018, PT IMT is still awaiting response from RSPO re the case

G37 Email to GAR 4/9/2018 Complaint about damaged road at PT Sumber Social & Community Hendi Apriyadi, Village • 9/4/18: GAR received an email from Mr Hendi Apriyadi, Village Head of Desa Batu Ampar, Tulang Bawang, Lampung. The email was a forwarded copy of an email to RSPO. Open Indah Perkasa (PT SIP) Head, Desa Batu • He complained that there had been no response from SMRE unit of PT SIP, to a grievance that he submitted on 20/3/18 concerning the maintenance of the connecting street between Kampung Suka Bhakti and Kampung Batu Ampar Ampar, Tulang which he believes is the responsibility of the company. Bawang, Lampung • The street is in SMRE’s area and was previously used as an access road by the Company. Currently the road is no longer used by SMRE which prefers to use an access road inside the estate. • The road is frequently damaged by the many vehicles transporting sand from the village which has not taken part in repairing the road. In addition, many planted rubber trees along the road prevent the roads from drying quickly when they are wet leading to more damage. SMRE has appealed to the villagers to help trim the rubber trees, but they have not taken any action. • Mr Hendi Apriyadi is aware that the street has often been repaired by SMRE and witnessed repair works on 23/3/18. Previous repair also took place in December 2017. These repair works were documented. • PT SIP is committed to helping the local community and will repair the road concerned in accordance to a schedule which includes maintenance and repair of other village and public infrastructure. • SMRE is involved in fixing and maintaining other roads and the heavy equipment needed for the repair works is in high demand in other areas and villages, including for the repair of public roads. • 3/5/18: A response on this issue was sent to Mr Hendi.

G38 Email to GAR and 5/14/2018 COP alleged PT Fairco Agro Mandiri; a supplier HCV clearance COP (Centre for • 14/5/18: GAR received a report from COP alleging PT Fairco Agro Mandiri (a supplier of GAR) sourced FFB from four farmers in Kutai National Park who allegedly killed an orangutan Open letter to RSPO of GAR’s; to source FFB from four farmers in Orangutan Protection) • 14/5/18: GAR engaged with COP and scheduled a meeting in late May 2018. Kutai National Park Kalimantan Timur who • 15/5/18: GAR contacted PT FAM to ask for clarification. PT FAM denied that it sourced FFB from those four farmers via Samurai Trasport (the alleged FFB agent/dealer). GAR and FAM agreed to discuss this case in a meeting in the allegedly killed an orangutan. last week of May 2018. • 22/5/18: GAR, TFT and COP had a meeting to discuss the report and learn more about the issue. • 30/5/18: GAR and Fairco had a meeting. Fairco once again denied the allegation. Both sides agreed on a site visit scheduled for 2-6 July 2018. The visit will be conducted jointly by GAR, TFT and COP. • 6/8/18: RSPO sent a letter to COP ccing GAR re “Notification of Rejection of Complaint” relating to COP’s complaint filed on 9/5/18 stating the following reasons: a) There is no nexus between PT Sinar Mas and the four (4) suspects; b) PT Sinar Mas are not the growers involved in this Complaint; c) PT Sinar Mas are not the millers involved in this Complaint; and d) PT Fairco Agro Mandiri who are the owners of the mill is not RSPO certified or a member of RSPSO • 2-6/7/18: GAR and TFT conducted a site visit to FAM. COP was scheduled to join the visit but COP personnel did not turn up. • 7/8/18 : GAR, TFT and FAM had a meeting to discuss site visit report, action plan and support GAR will provide for PT FAM. • 4/9/18: GAR, TFT and COP had a meeting to discuss site visit report and time-bound action plan agreed with PT FAM.

G39 GAR internal 5/23/2018 GAR internal monitoring team found HCS/HCV clearance GAR • 28/5/18: GAR contacted KPI and BTS management about the findings and requested clarification. Open monitoring process indications of potential HCS/HCV clearance in • 13/6/18: GAR sent official letter asking KPI and BTS management to stop land clearing activities and conduct HCS/HCV studies. the period between Jan/Feb and Apr 2018 in • 17/7/18: GAR contacted PT KPI and PT BTS to share Mighty Earth Rapid Response No.5 and request an open dialogue but did not receive feedback from their management. PT Kapuasindo Palm Industry and PT Buana • 6/8/18: Due to the unsatisfactory engagement as required in GAR grievance handling procedure, GAR is preparing a second letter • 21/8/18 A second letter was sent to KPI and BTS management repeating the same request. Tunas Sejahtera concessions, Kalbar. Both are GAR third-party suppliers. G40 Public report 7/5/2018 “High Risk in the Rainforest” report published Deforestation, Land Milieudefensie • Early July ’18: “High Risk in the Rainforest” report published by Milieudefensie (Friends of the Earth Netherlands) and Friends of the Earth USA alleging that GVL (Golden Veroleum Liberia) “has faced consistent and well-documented Open by Milieudefensie (Friends of the Earth rights, Human rights (Friends of the allegations of human rights violations, environmental degradation and disregard for communities’ land rights. New findings indicate that GVL has failed to reform its operations, despite numerous complaints filed with the Roundtable on Netherlands), Friends of the Earth USA and Earth Netherlands), Sustainable Palm Oil (RSPO) since 2012.” https://1bps6437gg8c169i0y1drtgz-wpengine.netdna-ssl.com/wp-content/uploads/2018/07/GVL-Report_FINAL.compressed.pdf Sustainable Development Institute alleging Friends of the Earth • The report further claims that as GAR is the main investor in GVL and its Forest Conservation Policy applies to GVL, GAR’s financiers may face reputational and financial risks • 5/7/18: GAR has obtained satisfactory explanations from GVL when it was alerted to earlier, similar allegations via other reports. GAR understands that GVL is investigating new allegations about forest clearance contained in the latest that GVL (Golden Veroleum Liberia) alleging USA and reports. GAR has asked GVL for a detailed response to all the claims made in the latest report failure to reform behaviour re human rights Sustainable • 20 July 2018: GVL announced voluntary, time-bound suspension of its RSPO membership and action plan to review and strengthen its sustainability practices within 12-18 months violations, environmental degradation and Development • GAR will monitor GVL performance to ensure full compliance with GAR Social and Environmental Policy (GSEP) disregard for communities’ land rights. Institute