SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES

RSPO Assessment Report PUBLIC SUMMARY

PT. Sumber Indah Perkasa – Sungai Merah Mill, ,

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

Prepared by: Tuti Suryani Sirait (Lead Assessor) Certification decision made by :Triyan Aidilfiitri

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

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List of Contents Page

A Scope of the Certification Assessment ...... 4

A.1. National Interpretation Used ...... 4

A.2. Assessment Type (Estate and Mill) ...... 4

A.3. Location Map ...... 4

A.3.1. Location Address of the Mill and Approximate Tonnages Certified

(CPO and Mill ) ...... 5

A.4. Description of Supply Base ...... 6

A.4.1. General Description ...... 6

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

A.4.3. Statistic of Supply Base ...... 7

A.5. Organizational Information and Contact Person ...... 8

A.5.1 Audit Against the Rules for Partial Certification ...... 9

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

B. Assessment Process ...... 13

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

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

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

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

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

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

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

B.5. Date of Next Surveillance Visit ...... 20

C. Assessment Findings ...... 21

C.1. Lead Assessor’s Summary and Recommendation for Certification ...... 21

C.2. Summary of the Findings by Criteria ...... 22

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D. Certified Organization’s Acknowledgement of Internal Responsibility...... 49

D.1. Formal Sign-Off the Assessment Findings ...... 49

D.2. Statement by the Certifier Body on Behalf of PT. Sucofindo SBU-SICS ...... 50

List of Abbreviation ...... 51

Attachment 1 - MAP ...... 53

Attachment 2 - NCR ...... 60

Appendix ...... 72

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

A. 2. Assessment Type (Estate and Mill) Certification Unit : PT. Sumber Indah Perkasa – Sungai Merah Mill located at Gedung Aji Baru, Tulang Bawang Regency – Lampung, INDONESIA

A.3. Location map Please see Appendix 1 : the details of estate maps of 1.Overlay Map of Sungai Merah Estate (SMRE) and KKPA Gedung Aji Baru (GABA) Estate, 2.Map of Rivers, 3. HCV, 4.Topography, 5. Planting Year Sumatera Island - Indonesia

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A. 3. 1. Location address of the mill and approximate tonnages certified (CPO and PK)

Annual Output (mt) No Name of Mill Location Address GPS Reference CPO PK

1. Sungai Merah Mill Desa Sidomukti Latitude: PT. Sumber Batu, Kecamatan 4o 13’ 06.40” LS Indah Perkasa Gedung Aji Baru, Longitude: 55.360,76 13.802,92 Kabupaten Tulang Bawang - Lampung 105o 35’ 19.57” BT

Note : This data (Annual output) exclude from non-certified suppliers) A.4. Description of Supply Base

A. 4. 1. General description

PT. Sumber Indah Perkasa operates 2 palm oil mills under PT Sumber Indah Perkasa, named PT Sumber Indah Perkasa - Sungai Buaya Mill (SBYM) and PT Sumber Indah Perkasa – Sungai Merah Mill (SMRM). The raw material/FFB for PT Sumber Indah Perkasa - Sungai Merah Mill (SMRM) is supplied from 1. Sungai Merah Estate (SMRE), and 2. KKPA Gedung Aji Baru (GABA) Estate - Smallholder. Totally supplied FFB from these two (2) estates are 257,332.29 MT. All estates are operated under one management of PT. Sumber Indah Perkasa. All estates located in Lampung, INDONESIA. PT. Sumber Indah Perkasa is a member of RSPO and they Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 5of 75

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are implementing a program to achieve RSPO Certified Palm Oil for all its production. There is no plan to expand the land holding and therefore Principles 7 is not applicable to this assessment.

A. 4. 2. Location of the supply base

GPS No. Estate Name Location Latitude Longitude

1 Sungai Merah Estate Desa Sidang Gunung Tiga, Kecamatan Rawa 4o 12’ 00.73” 105o 38’ 05.14” Jitu Utara, Kabupaten Mesuji – Lampung

2 Gedung Aji Baru KKPA Desa Sidoharjo, Kecamatan Penawartama, 4o 09’ 44.86” 105o 26’ 09.23” Kabupaten Tulang Bawang – Lampung

A. 4. 3. Statistic of supply base

No. Estate Planting Area/Planting Age/Planting Estimated Estimated Name Year Year Year FFB/Year CPO/Year

1 Sungai 1991 503,03 22 12.291,347 2.644,38 Merah 1992 513,19 21 7.825,289 1.683,55 Estate 1993 1.070,42 20 19.671,890 4.232,25

1994 741,68 19 14.657,714 3.153,49

1996 486,69 17 9.346,205 2.010,76

2000 111,77 13 2.392,419 514,71

2001 185,80 12 2.635,429 566,99

2004 483,61 9 9.052,357 1.947,54

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2 Gedung 1995 3.115,25 18 77.939,550 16.777,09 Aji Baru 1996 605,00 17 15.100,870 3.250,58 KKPA 1997 377,00 16 9.157,240 1.971,17

1998 71,00 15 1.865,420 401,55

1999 337,50 14 7.216,430 1.553,39

A. 5. Organizational Information and Contact Person

PT. SUMBER INDAH PERKASA – Sungai Merah Mill 1 Company Name (SMRM)

2 Personal Contact Ismu Zulfikar

3 Vice Management Humala Sinaga

Sinarmas Land Plaza Menara 2 Lantai 30, Jalan M. H. 4 Company Address Thamrin No. 51, Jakarta, Indonesia

5 Company Status PMDN

7 Phone/ Fax 021 50338899

8 E-mail [email protected]

9 Website www.smart-tbk.com

10 RSPO membership number 1-0096-11-000-00

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

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

2. Assessment agenda (partial Certification Audit)

Date Location Agenda

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

3. Audit Team Findings in Correlation to the Rules Partial Certifications a. The Organization is a member of RSPO PT Sumber Indah Perkasa has confirmed membership of the RSPO with no. 1- 0096-11-000-00 b. A Time Bound Plan for achieving certification within relevant entities Estimate Name of No Supply Base Company Location time of Mill Certification 1 Sungai Sungai Buaya PT. Sumber Lampung 2013 Buaya Mill Estate Indah Perkasa Gedung Aji Lama KKPA Mesuji KKPA 2 Sungai Sungai Merah PT. Sumber Lampung 2013 Merah Mill Estate Indah Perkasa Gedung Aji Baru KKPA Gedung Aji Lama KKPA 3 Pangkalan Sawit Mas Estate PT. Sawit Mas South 2014 Panji Mill Sejahtera 4 Bumi Sawit Bumi Sawit Estate PT. Bumi Sawit South 2014 Mill Permai Sumatra 5 Muara Muara Kandis PT. Djuanda South 2014 Kandis Mill Muara Tawas Sawit Lestari Sumatra Pandawa KKPA Pandawa Plasma

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6 Sungai Sungai Rungau PT. Sumber Central 2013 Rungau Mill Estate Indah Perkasa Kalimantan Sungai Seruyan Estate Terawan Estate Tangar Estate Bukit Tiga Estate 7 Bukit Perk Bukit Perak PT. Bumi Permai Bangka 2014 Mill Bukit Permata Lestari Belitung 8 Tanjung Tanjung Kembiri PT. Foresta Bangka 2013 Kembiri Mill Estate Lestari Dwikarya Belitung Tanjung Rusa 9 Sungai Sungai Kupang PT. Sinar South 2015 Kupang Mill Estate Kencana Inti Kalimantan Sungai Kupang Perkasa 10 Kasuari Mill Cendrawasih PT. Sinar Papua 2014 Nuri Estate Kencana Inti Rajawali Estate Perkasa Mambruk Estate 11 Senakin Senakin Estate PT. Purimas South 2014 Mill Sasmita Kalimantan 12 Pekawai Kayung Estate PT. Agrolestari West 2014 Mill Pekawai Estate Mandiri Kalimantan Sungai Kelik Nanga Tayap Kayung Kemitraan 13 Kenanga Kencana Estate PT. Kencana West 2014 Mill Cendana Estate Graha Permai Kalimantan Kenanga Estate Cempaka Estate Kencana Kenanga 14 Tanggar Manuhing Estate PT. Tapian Central 2015 Mill Kajuji Estate Nadenggan Kalimantan Sulin Estate Nahiyang Estate Katayang Estate Sungai Nusa Sako Estate Sungai Ayawan Estate 15 Perdana Perdana Estate PT. Binasawit Central 2015 Mill Lenggana Estate Abadi Pratama Kalimantan Semandau Estate Muara Dua Estate 16 Kuayan Mill Mentaya Estate PT. Agrokarya Central 2015 Kuayan Estate Prima Lestari Kalimantan Bukit Santuhai

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Estate Tajur Beras Seranau Estate Sapiri Estate 17 Belian Mill Gaharu Estate PT. Paramitra West 2015 Muara Tawang Internusa Kalimantan Estate Pratama Belian Estate Tengkawang Kapuas Hulu

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

a. Significant Conflicts The company has the SOP for Conlict Land Resolution refers to RSPO criteria 6.4, 7.5 and 7.6. All the conflicts so far has been resolved with mutual agreement. GAR also registerd as member of RSPO Dispute Settlement Facility Advisory Group as a representative of grower. Supporting document is DSF RSPO member as a grower dated 22 April 2013. b. No replacement of primary forest and or area with HCV’s since November 2005 or year 2007 (National Interpretation) PT. SMART Tbk, has been appointed to manage all companies under GAR Group. PT SMART Tbk has conducted Historical HCV Assesment (HHA) in collaboration with Faculty of Forestry, Institut Pertanian Bogor (IPB) April 2011. Historical HCV Assesment (HHA) Report has been submitted to RSPO on May 2011. As a follow up from the Historical HCV Assesment (HHA) Report, GAR has been proposed HCV Remediation Plan to RSPO. Revision of HCV Remediation Plan are on going process/ discussion with RSPO Biosdiversity and HCV Working Group (BHCV WG). Supporting documents is Historical HCV Assesment (HHA) report. c. No labor disputes that are not being resolved through an agreed The company has the SOP and menchanism to resolve dispute with union labour with mutually agreement. The latest resolution dispute document handled as evidence is dispute between a worker (Hanadi) with PT. Foresta Lestari Dwikarya for terminated employment. The worker has been assumed to be resigned as he has absent for 8 (eight) days in a month.The supporting document is available such as chronology of resolution Industrial Relation between worker and PT. Foresta Lestari Dwikarya, copy of legal verdict caseIndustrial Relations No. 08/G/2012/PHI. PN PKP from court of Industrial Relations at Court of District Pangkalpinang. Collective agreement PT. FLD with Mr. Hanadi No. 07/EM-pb/IV/2013 completed with the sign of each party.

d. No evidence of non-compliance with law in any of the non-certified holdings The company has comply with the applicable law and regulation refers to RSPO criteria

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2.1.which stated no evidence of non-compliance with the applicable regulation. Supporting documents are copies of SK AMDAL, SK HGU, IUP, IMB.

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A.6. Date Certificate Issued and Scope of Certificate

Name of Client PT SUMBER INDAH PERKASA

Client Number RSPO 00004

Certificate Number RSPO 00004

Certification Decision Date

Issued by PT SUCOFINDO, SBU SICS

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

Telephone /Fax Tel.: +62-21-7983666 / Fax.: +62-21-7987015

Email [email protected]

Website www.sucofindo.co.id

Scope :

Mill PT. Sumber Indah Perkasa - Sungai Merah Mill (SMRM)

Estate 1. Sungai Merah Estate (SMRE) 2. Gedung Aji Baru Estate (GABA)

Projected mass balance CPO & PK CPO : 55.362,691 MT and PK : 13.802,92 MT

Certification Registration Code SICS-00004

Type of Certification Single site

Certifier Triyan Aidilfitri

Signed

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

B. 2. Qualifications of the Assessment Team

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

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WarsidSumarlin (Auditor) He graduated from Institute Agriculture of Bogor (IPB) majoring Economic and Social. He has more than 5 years audit experiences in OSHAS and SMK3. He has successfully completion from Lead auditor for SMK3, Lead Auditor for OHSAS and Lead Auditor for ISO 9001. He has successfully completion training RSPO by Komisi RSPO, Jakarta, ISPO Lead Auditor Training by Komisi ISPO, Jakarta. Rizky Qomaruzaman (Auditor) Lead Auditor SMK3 since year 1997 till now. Lead Auditor OHSAS 18001 since year 2000. Auditor ISO 14001 since 2002. Premises visited: many various industries, petrochemical, oil & gas, EPC, general contractor, Palm Oil Plantation and Mill, chemical, pulp & paper, coal mining, cement industries, and so on. Attended Green Company Training year 2008, He has successfully completion from ISPO lead auditor course year 2013, attended RSPO lead auditor Course at KL year 2013, attended environmental seminar (Environmental Audit) from Environmental Ministry Republic Of Indonesia year 2013. Yusuf Mu’arif (Auditor) He has graduated from Bogor Agriculture University (IPB Bogor) since March 1988. He has more than 10 years audit experiences in auditing (internal and external audit) of Australian Quarantine Scheme and Ministry of Agriculture of RI, ISPO, OHSAS and SMK3. He has successfully completion training of ISPO Lead Auditor Training by Komisi ISPO, Internal Auditor SMK3 from Ministry of Manpower and Transmigration RI that held by SICS – Sucofindo. Kind of audit scope such as various industries, petrochemical, general contractor, plantation of palm oil, chemical, electrical generator project, telecommunication etc. Ganjar Gumelar (Auditor): He graduated from University ofGadjahMada (UGM), Forestry Faculty, majoring in Forest Management, Yogyakarta. He has completed the training such as Indonesian Sustainable Palm Oil (ISPO) auditor training, Komisi ISPO – Ministry of Agriculture & Komisi Akreditasi Nasional (KAN), Bogor (West Java) & Pangkalan Bun (Kalimantan), Indonesia, 2013 ;ISO 9001 : 2000 Quality Management Systems (QMS) Auditor/Lead Auditor Training Course (IRCA),PT. SUCOFINDO (Persero), Jakarta, Indonesia, 2013 ; Awareness Hazard Analysis Critical Control Point (HACCP), PT. SUCOFINDO (Persero), Jakarta, Indonesia, 2013 ; Life Cycle AssessmentWorkshop Oil Palm Plantation and Oil Palm Milling, Life Cycle Sustainability Assessment Lab &State Minister for The Environment, Jakarta, Indonesia, 2013 ; Assessor Training High Conservation Value Forest – HCVF, Tropenbos International Indonesia Program, The Nature Conservancy (TNC), WWF Indonesia & Institut Pertanian STIPER (INSTIPER) Yogyakarta, Yogyakarta, Indonesia (2011).

B.3. Assessment Methodology

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

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

Phase I : Preliminary Audit Date/Time Functions / areas / Department / activities to be audited (include related requirements) 10 June 2013 Day 1st Audit 12.35 Departure from Jakarta – Lampung 13.00 Departure to Regional Office Sungai Buaya Estate 13.00 Break 15.00 Opening Meeting at Regional Office (All Team)

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17.00 End of the day 1 11 June 2013 Day 2nd Audit 08.00 Location: Sungai Buaya Estate (Division II blok 14-15) Environment Aspects : Water Management (water courses, water monitoring); Environment waste management, Environmental Impacts, Chemical store (RQ) HCV Aspect :HGU and Land Status Estates confirmation, Riparian Zone , HCV Confirmation (RQ) Plantation Aspects : Herbicide Application Programme, Integrated Pest management ); Harvesting Site, Fertilizing Operations, Land Preparation and Assessment (WS) 12.00 Break Sungai Buaya Mill & Sungai Merah Mill (All Team) 14.00 Document Review of Environmental, HCV, Social and Best Practices Aspects 17.00 End of the day 2 12 June 2013 Day 3rd Audit 08.00 Sungai Buaya Mill (All Team) Environment Aspect, Biodiversity, & HCV (RQ) OSHAS/SMK3, Worker Welfare, Training, & Best Practices (WS) Social, Legality, Management, & SCC System (TSS) 17.00 End of the day 3 13 June 2013 Day 4th Gedung Aji Baru Estate (blok B 13) 08.00 Document Review of Environmental, HCV, Social and Best Practices Aspects (TSS, WS, RQ) 12.00 Break 14.00 Environment Aspects : Water Management (water courses, water monitoring); Environment waste management, Environmental Impacts, Chemical store (RQ) HCV Aspect :HGU and Land Status Estates confirmation, Riparian Zone , HCV Confirmation (RQ) Plantation Aspects : Herbicide Application Programme, Integrated Pest management ); Harvesting Site, Fertilizing Operations, Land Preparation and Assessment (WS) 17.00 End of the day 4 14 June 2013 Day 5th Audit 08.00 Reporting 12.00 Break 15.00 Closing Meeting 19.00 Departure from Lampung to Jakarta Scope : 2 mills and 5 estates Number of assessor participating: 5 auditors Number of days spent for the assessment on site : 25 days Total number of person days used for the assessment on site :25 days

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

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Assessment. (YM) Social Aspects : Meeting Stakeholders, Kepala Desa and Confirmation of Local Contribution /CSR. (TSS) Worker Welfare:Housing, Clinic, Labor Union, Worker Welfare. (WS) 12.00 Break 14.00 Location : Sungai Merah Mill (SMRM) Best Practices & Environment Aspect. (RQ, YM & GGU) Worker Welfare, Training, Management (WS) OSHAS/SMK3 (WS & YM) Social Legality, & SCC System (TSS) 16.30 End of audit 19 Jul’13 5th Day 07.30 Reporting (All Team) 12.00 Break 14.00 Closing Meeting (All Team) 17.00 Back to Lampung 22.00 Arrive at Lampung 20 Jul’13 6th Day 06.50 Back to Jakarta

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

B. 4. 1. Summary of How Stakeholder Consultation was Organized

Stakeholders Consultation and Company Responses Issue Company Responses Assessor Findings

Sungai Merah Estate Company has in place a SOP Conform requiring contractors to TBS Contractor (Mr. Amri) comply with government - The contractor has 3 units of regulations with respect to K3 truck with 9 workers. Wages and other regulations. have conformed to UMR i.e. on average 70,000 rupiah/day. - The cooperation agreement has included K3 requirements. Sungai Merah Estate TBS pricing has met the Conform provisions of local plantation Mr. Suroto, Chief of Bogatama department. Village - There has been confirmation Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 18of 75

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that there is no air, water, and soil pollution. - There has been a transparent TBS pricing - Request for clean water and heavy equipment is always responded and fulfilled - There has been confirmation that there is no land conflict - There has been a priority in providing job opportunity Labor Union Company has the policy to Conform allow the worker to form the Union Leader : Mr. Sopuan union labor. The evidence is - Confirm that no child labor circulating letter from CEO-2 employed No. 094/CEO2/SE/12/2010 - Salary minimum for workers dated 14/12.2011. Only one have been complied (1) labor union registered in the company. - Regular Meeting has been conducted with supporting facility by management Cooperation Krida Sejahtera The company will set up the Minor program to ensure all Head of Cooperation : Mr. Miseri representative growers and AJ Aminanto staff will be adequate - The plasma member is totally socialize for sexual 17.062 member from 36 harassment issue. villages - There is not yet socialization conducted regarding sexual harassment to the growers. - The grading methods have been clearly defined and there are two (2) staffs present at the mill every day as a witness during grading process. - There is no conflict land among growers and company. - Payment from company conducted twice per month and the payment time is

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always on time

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

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

The audit is conducted jointly Roundtable on Sustainable Palm Oil (RSPO) Certification Scheme and Indonesian Sustainable Palm Oil (ISPO) Certification Scheme. There are 2 (two) mills and 5 (five) estates has been audited at the same time during preliminary (June, 10th-14th 2013) and certification audit (July, 15th-19th 2013). Some of the issues between ISPO and RSPO are mainly same such as commitment to transparency,compliance with applicable laws and regulations, commitment to long-term economic and financial viability, environmental requirements, social aspects, best practices of estates and mill and continuous improvement. The significant differences which is only for RSPO requirements such as term of findings, HCV’s issue, SIA, sexual harassment requirement, specific requirements of contractor (should be meet with manpower regulation and well trained), and NPP requirement. The audit conducted twice i.e. preliminary audit and certification audit. The scope of the audit for this unit is a mill (SMRM) and two (2) estates. One (1) of the two (2) estates are smallholder schemes KKPA Gedung Aji Baru (GABA) Estate and the own estate is Sungai Merah Estate (SMRE). The Mill and estates has been visited during preliminary and certification audit (no sampling). The management (Mill and estate) showed the commitment to the implementation of the principles and criteria of the RSPO NI-INA. The assessment has been carried out through field visit to head office, mill and estate. The public announcement for certification has published on RSPO website prior 30 days from the audit certification to give the opportunity to stakeholders for comments and feedback. There is no a grievance or complaints received from the stakeholders during 30 days of public consultation period. Team auditors also conducted separate meeting with village head, local community, union labor team, and government official representatives. There is some clarification received regarding the HCV issue, conflict land, Socialization of rare and endangered flora and fauna, transparencies, charity, etc. There is 1 NCR minor and 8 Observations issued during certification audit. There is commitment of management to make corrective action and for continuous improvement. There is also improved plan for social and environmental area. The audit team found that PT Sumber Indah Perkasa (Sungai Merah Mill (SMRM), Sungai Merah Estate (SMRE),KKPA Gedung Aji Baru (GABA) Estate, are comply against RSPO P & C approved for Indonesia. Therefore the recommendation of the Lead Auditor that Certificate of RSPO is awarded to PT Sumber Indah Perkasa, Sungai Merah Mill and its estates.

Signed :

Tuti Suryani Sirait Date : September 16, 2013

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C. 2. Summary Of The Findings by Criteria

1 COMMITMENT TO TRANSPARENCY

1.1 Palm oil growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages & forms to allow for effective participation in decision making.

Company has in place a SOP on Information Request and Response (SOP/SPO/SMART/LH- 01). There is list of information that can be accessed by relevant stakeholders. Any request for information outside the list will require Top management consideration and approval. A list of stakeholder has been available in each unit that consist of Customary/community leaders, Muspida and village chief, Company’s trade union, Contractors and suppliers. Confidential documents are documents outside the list of information for Stakeholders. Sampling I is conducted on a Letter no 95/SIP-SMRE/P/IV/2013 dated 16 April 2013 in the form of application for assistance to build a mosque. Company has responded and realized the assistance on 23 May 2013 as evidenced by acceptance certificate. Sampling II, no records are found on request for assistance applied by Ibu Nurhayati on 18 May 2013 i.e. application for educational and playing equipment assistance for TK Dharma Batu Ampar. It is advised that company ensures responses to any information request as required by related SOP where responses are to be given within 1 month at the latest. It is issued as an observation. Records of information request and response are maintained with retention time specified by Company based on their importance. Compliance status: Observation no.9 1.2 Management documents are publicly available except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes

Company has in place a list of information that can be accessed by relevant stakeholders. Any request for information outside the list will require Top management’s consideration and approval. Confidential documents are documents outside the list of information to Stakeholder, such as commercial data and data causing negative impacts that are accessible only upon management’s approval, e.g. conflict data. In general, data may be accessed /asked by relevant stakeholders as long as relevant. In addition there are data that can be given only to relevant agencies, for example production data is given to the Regency and Provincial Plantation Service. Compliance status: Full Compliance 2 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

2.1 There is compliance with all applicable local, national and ratified international laws and regulations.

Company has in place evidence of its compliance with regulations related to permits, employment, and environment. Evidence of updates to new regulations is a periodic evaluation conductedSucofindo ICS by the unit’s HO and SPO officers. The last revision is dated 01 AprilFRM 2013 3.04 for Issue 04 Rev. 6 22of 75

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permits, environment, social and employment. Company does not have a letter of release of forested areas and or letter of allocation with APL status for the plantation area of PT Sumber Indah Perkasa. Company previously has operating permit of one (1) millfor the capacity of 30 ton/hour. At the time of preliminary audit, a nonconformity was found in which the company had two (2) Milswith a capacity of 60 ton/hour each, totalled 120 ton/hour. At the time of certification audit, the company had been following it up by processing the IUP for Mills of 120 ton FFB/hour capacity. The company already has a letter from the Board of Investment and Regional Integrated Permit Service with No. 800/200/BID.V/II.06/2013 dated 1 July 2013 for the management of mills with a capacity of 120 ton FFB/hour. Compliance status: Full Compliance

2.2 The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights

Company has a Decree of Governor No. C/202/DA/HK /1989 on Land /Site permit and land use totaling 9,000 Hander the name of PT Sumber Indah Permai. After that, there are site permit changes no. C/309/BPH/HK/1990 to become 9,522.11 Ha. Company previous name is PT Sumber Indah Permai and then changes name to become PT Sumber Indah Perkasa. Change in the company name has been notarized by a Notary Deed dated 20 September 1990 (Benny Kristianto and associate) and secured in the Decree of the Minister of Justice no. C2-5826 HT.01.01.Th90./HK/1990. Companyalready has a certificate of HGU from BPN with no. 1/HGU/BPN/93 totaling 9,522.11 Ha dated 30 January 1993. Companyalready has a certificate of HGU that consists of : HGU issued by the Regency of North Lampung with no. 08.04.2.00037 dated 26November 1993 totaling 2,088.13 Ha and No 08.04.2.00038 dated 26 November 1993 totaling 1,899,68 Ha for the location of SMRE All HGUswill expire in 2027. HGB for SMRM Mill no. 08.06.02.17.2.00062 totaled 58.20 Ha issued by Tulang Bawang Regency dated 21 July 1999. Valid until 2029. Company has in place a Plantation Business License (IUP) no. 956/Menhutbun-VII/2000 dated 8 August 2000 for MILL 1 unit with a capacity of 30 ton TBS/hour for a total land area of 9046.63 Ha. Company previously has operating permit of one (1) mill for the capacity of 30 ton/hour. At the time of preliminary audit, nonconformity was found in which the company had two (2) mills with a capacity of 60 ton/hour each, totaled 120 ton/hour. At the time of certification audit, the company had been following it up by processing the IUP for Mills of 120 ton FFB/hour capacity. The company already has a letter from the Board of Investment and Regional Integrated Permit Service with No. 800/200/BID.V/II.06/2013 dated 1 July 2013 for the management of mills with a capacity of 120 ton FFB/hour. Companyalready has IMB no. 503/600/XI/MB/1999 and no. 642/540/PUK-LU/94 for MillSMRM. Compliance status: Full Compliance

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2.3 Use of land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent.

Companyis a takeover from earlier company in 1990. Company states that during the period from 1990 until the time of the audit there was no purchasing of land. There is SOP of Land Conflict Settlement (SOP/SPO/SMRT/LH-04). So far the company and KUD inform that there was no dispute during the period from 2010 to the present time in the area around company site. It is said in the SOP to prioritize deliberation over legal action. At the time of audit the Location Map of PT. Sumber Indah Perkasa No. Reg: 948/214/PMNP/VI/12 with the scale of 1: 250,000 were showed. The map should have a sufficient scale of minimum 1: 100,000 in accordance with Decree of the Ministry of Forestry No. 48/menhut-II/2004. Compliance status:Observation no.4

3 COMMITMENT TO LONG-TERM ECONOMIC AND FINANCIAL VIABILITY

3.1 There is an implemented management plan that aims to achieve long-term economic and financial viability

PT SIP long term replanting program up to 2020 has been established. The replanting plan will commence in 2017 up to 2020 covering 5 estates with a total area of 23,443.87 Ha.For plantations under the SMRE Estate, including GABA, replanting area is determined as follows: - 2017 (planting year (TT) 1991) is 503.03 ha; - 2018 (TT.1992) is 513.19 ha; - 2019 (TT.1993) is 1,230.45 ha; and - 2020 (TT.1994) is 834.23 ha Companyhas financial statement that has been audited by the public accountant office of Tanubrata Sutanto Fahmi & Rekan, in 2011. Tax report data for 2012 was not available yet but there is a statement letter dated 16 April 2013 issued by the public accountant office that it is under audit completion process. Compliance status: Full Compliance 4 USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS

4.1 Operating procedures are appropriately documented and consistently implemented and monitored

- SOP and WI related to new planting, issued 1/7/2010. - SOP on New Land Opening (SOP/SMART/MCAR/IV/TA-PLB), rev.0, issued 1/9/2012. Point 2.2.6 Preparation regulates on: terracing and horseshoe shaping (tapak kuda). - There is IK /SMARTR/MCAR/TA-PPA/01 on Drainage - Records of nursery maintenance are not available since there is no longer nursery activity. - SOP/SMART/MCAR/V/TA-TNM, 1/9/2012. SOP on Planting - There is IK/SMART/MCAR/V/TA-TNM/01- Lining Flat to Wavy Area and also guidance (table)

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

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

There is no TBM maintenance because the youngest is the planting year 2000 - TM maintenance includes: (1) Tree census, (2) Maintenance of weeded circle, harvest path, control path, and collection path (3) Maintenance of space between palm rows (4) Weeding (5) Road and bridge maintenance (6) Pest and Disease Control (7) Pruning and Stacking of Fronds Maintenance activities are recorded in: - Foreman Activity Log (BKM)– daily - Work Outcome Log (BHK) – wholesale. - For main estate, the content of BKM and BHK is inputted into Check roll program (SAP), while for Plasma, the BKM is summarized in the Report of Plant Maintenance.

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Compliance status: Full Compliance

4.3 Practices minimize and control erosion and degradation of soils

Company has protected river border area by clearing free from oil palms with clearance space of 50 meter from river edge, and the river banks are planted with bamboo and fertifer grass to prevent erosion. The document is SOP of PT. SIP-GALA/SOP/34 Revision 00 dated 1 March 2012. The details of rivers location and condition is described in Criteria 5.2 (HCV) Compliance status: Full Compliance

4.4 Practices maintain the quality and availability of surface and groundwater.

Revised ANDAL Document of AMDAL of Oil Palm Plantation and Oil Palm Processing into CPO, sources of water from Sungai Buaya and Sungai Merah. There are 3 drilled wells. The depth of drilled wells are 10-15 meter Water needs for Mill 1 ton TBS are 1.5 m3 of water, for domestic needs are 100 m3/day,so with mill with a capacity of 60 ton TBS per hour, the total use of river water is 2,800 m3/day. The efficiency of water use for processing in the SMRM in 2013 from January to April is 0.705 m3 per ton TBS. The efficiency of water use for processing in the SMRM in 2012 from Januaryto Decemberis 0.479 m3 ton TBS, where the target of 1.5 m3 per ton TBS has been achieved. River area has been planted with bamboo to prevent erosion. The organization conduct a surface water quality monitoring program utilized by plantation communities through RKL and RPL activities that conduct surface water and groundwater quality measurement periodically. The report sends to the BLH of Mesuji/Tulang Bawang Regency, the BLH of Lampung Province, and the Ministry of Environment Jakarta every six months. The results of surface water measurement can be found in RKL and RPL that cover Sungai Buaya, Sungai Merah mill, and 4 resident wells. Organization has measured the quality of clean water in the resident wells with 4 resident well sampling points. The results of clean water quality measurement of resident well number 3 is below the Environmental Quality Standard=50 for coliform biological factor, for pH the resident well number 1 and 4 are below the Environmental Quality Standard =6.5–9. Routine measurements and reporting are carried out every 6 months based on RKL and RPL activities to undertake measurements and reporting to the BLH of Tulang Bawang Regency, the BLH of Lampung Province, and KLH Jakarta. Organization conducted environmental measurement during the period of Semester I of 2013 that covers surface water and groundwater. For the SMRM area it covers Tapa River. The regulatory references are the Regulation of the Governor of South Sumatera No. 16/2005 (Attachment I). The measurement results meet with the Environmental Quality Standard requirements.The results will be reported to the government in accordance with RKL and RPL requirements. . Compliance status: Full Compliance

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4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated

The company has the SOP on Plant Disease and Pest Control (SOP/SMART/MCAR/VII/TA- HPT, 1/9/2012) The data found for IPM program at SMRE,and KKPA GABA:

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

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

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

(4) Sprayers, for GABA there are 1 group @10 personnel. There is evidence of Training Attendee List of Restricted Pesticide Use, 18/10/2011 for GABA. There are 64 attendees.

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

Compliance status: Full Compliance

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

Handling of Pesticide Waste The registered company collected used pesticide packaging of jerry cans and plastic bottles made of Polymex material. In Sungai Merah Estate (SMRE) and KKPA Gedung Aji Baru (GABA) Estate The effluent from sprayer bathing activities flowing into a septic tank. Non polymex material is collected in a special warehouse after being handled in accordance with WIon Washing and Cleaning of Pesticide Packaging’s and Fertilizer Bags, SIP-GABAIK/19, No. Revision:00 approval dates 1 March 2012.Companyhas provided facilities for mixing pesticide, washing used pesticide packaging’s, washing used Fertilizer Bags, washing pesticide apron, and bathroom for sprayer personnel. Used pesticide packaging’s already washed are stored in a special warehouse (which also contains used paint and thinner cans) and picked up by Hazardous and Toxic waste collector service company PTPrimandu Jaya. The company has obtained Hazardous and Toxic waste collector and transporter permit from the Ministry of Transportation, Directorate General of LandTransportationfor transporting Hazardous Materials, No. AJ.309/50/019/DJPD/2012/36005114. Pesticide hazard warning signs have been displayed in washing facilities in all areas. Pesticide waste handling is already regulated in pesticide work instruction, WIon Washing and Cleaning of Used Pesticide Packaging’s and Fertilizer Bags, SIP-SMREIK/19, No Revision: 00 with approval date of 1 March 2012. However, it is written in the WI that the collection place is in

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TPS Hazardous and Toxic, whereas in implementation not in TPS Hazardous and Toxicbut in a warehouse in which there are also used paint and thinner cans. Company needs to provide hazardous waste warning signs in the warehouse. Companyalready has a list of agricultural and forestry pesticiderecommended by PesticideCommission of the Republic of Indonesia both synthetic and natural for weeds and caterpillars such as, among others, synthetic herbicide Rolixon, Gromoxone, Roll up and natural insecticide Cordiceps for ulat api pest control. However, company should reduce the use of herbicide of paraquat active substance (restricted pesticide), and use herbicidesfor weeds that are powerful but safe for operators in the long run (observation). Compliance status: Observation no. 2

4.7 An occupational health and safety plan is documented, effectively communicated and implemented

Company has established and implements occupational safety and health management system to fulfill the obligation as per government regulation. Evidence of implementation found as follows : - Has established Occupational Safety, Health and Hygiene Policy of PT. SIP – Lampung Region, dated 2/9/2011. The policy was signed by the officials of RC, PC, and PUKSPSI. The policy goal is continually seeking to reduce hazards leading to work accidents that result in injuries, work related diseases, goods damage, fire and explosion as well as production process disruption and environmental pollution. Socialization of OSHPolicy is carried out in class, through training, meetings, morning calls, morning circles, as well as displayed in the workplace. - Company has had and established OSHAS documentation that includes OSHAS Manual, SOP/Procedures, Work instructions and forms that has been implemented per 1 July 2010. Currently, most of documentation has undergone revision once.

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

P2K3 Team was established with SK No. 560/37/HIPK/II.TB/P2K3/IV/2013 dated 14/10/2010 byTulang Bawang Manpower and Transmigration Service. The Secretary is M. Hasan Noor with appointment letter No. KEP. 986/M/DJPPK/III/2012, dated 22/03/2013.

SMRE :

SMRE Unit, the P2K3 Team has been set up without decree from Manpower Department, but there is a letter from an employee in the Manpower and Transmigration Service of in the name of Drs. Rozali, MH, dated 11/01/2013. This letter explains that PT. SIP MRE has established P2K3, and has been approved, as per 2/01/2013. However, the document is not found in SMRE, whereas the Secretary in the name of Indra Kurniawan has received assignment with Decree No. Kep.4118/M/DJPPK/I/2013. This issue has been raised as an observation.

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GABA:

P2K3 Teamhas obtained approval from Social, Manpower and Transmigration Service of Tulang Bawang Regencywith No. 560/35/HIPK/II.TB/P2K3/IV/2013 with Secretary Dwi asGeneral OSHExpert.

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

All work units under PT. Sumber Indah Perkasahas included its employees in the Social Security Program (Jamsostek), starting from daily wage workers (BHL), PKWT, and SKU. The program varies in package according to the employee status. Those with BHL status will be included after 3 consecutive months because their status rises to Daily-SKU (SKU-H). Employees with SKU-H and PKWT status are only included for ½ packages, i.e. only JKK and JKM, whereas employees with Monthly-SKU (SKU-B) and SKU status up to staff get full package programs, namely: JKK, JKM, JHT, and JPK. List of Jamsostek membership is stored and recorded on manpower data base, and already has KPJ Number. But PKWT in particular, does not have KPJ number. The Jamsostek Insurance is not willing to give KPJ Number for reasons of non-permanent status.

The company has conducted worker health examination of BHL, PKWT, and SKU. Evidence of examination can be shown as follows: 1) There is a recapitulation of staff and employee health examination results in 2013: (a). SMRM, examination date: in stages from the 2nd to 5th month of 2013, for 168 workers (SKU+PKWT). (b). SMRE, examination date: in stages from 2nd to 4th month of 2013. and (c) SMRE, examination date: in stages from 2nd to 4th month of 2013. Company has issued a Policy for medical examination, on Lampung Region Worker Health Examination, approved by the Regional Controller and Production Controller, dated 1/6/2011, containing prior-employment, periodic, and specific examination. During preliminary audit, the examination of cholinesterase aspect has not been conducted for workers who work closely with Hazardous and Toxic, such as: sprayers, Hazardous and Toxic waste officers, chemical warehouse and laboratory officers. Application for this examination has just submitted. Also for personnel working in the noisy area, the audiometry measurement has not been conducted. At the time of the audit stage 2, company has been conducting cholinesterase and audiometry examination for these personnel. Spirometry examination should also be programmed for sprayers, Hazardous and Toxic waste, chemical warehouse and laboratory personnel. The company also provides health care service by establishing a Clinic located in the SBYE Central Office. The clinic had received permit from the Department of Health of Tulang Bawang with Private Health Care Service Licence No. 455/503/014/SIT-BP/DK-TB/III/2004, dated 19/3/2004 and valid until 01/4/2007. License reapplication is currently under process in connection with the regency expansion so that the status of the clinic becomes under the Mesuji Regency. The clinic is led by a company doctor and a paramedic, both are medical certified. Employeeshave medication in the clinic free of charge, for both PKWT and BHL status. The service also covers the employee’s family. There is a Procedure for Hazard Identification, Risk Assessment and Risk Control (HIRARC) (No. SOP/SMK3/SMART/LH-02, Rev. 01). Company has conducted ISBPPR that covers the

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whole Estate and Mill. The ISBPPR resultsare recorded in Risk Analysis Form (FP 02/SMK3- SOP-02) and Risk Analysis Follow up Form (FP 03/SMK3-SOP-02). The reference for preparation is the ASNZ method. Preparation of ISBPPR for Estates covers from maintenance (fertilizer, spraying, space between palm rows, OPT, roads), harvesting, emplacement maintenance, warehouse, workshop (all machinery), clinic, central office, washing place for keep and Fertilizer Bags (shower sprayers). As for Mills, it has covered the entire process from transport, security, weighbridge, TBS grading, loading ramp, transfer carriage, sterilizer, tippler, thresher, press, clarifier, boilers, kernel, engineering, effluent, workshop, warehouse, Hazardous and Toxicwarehouse, diesel fuel tank, lab, office, CPO dispatch, machine unit installation, fire engines, and vehicle traffic. ISBPPR is reviewed annually to see the effectiveness of earlier risk control application. If deemed necessary, the additional control will be added until "low" (L) risk level is achieved. This activity is carried out together between the operating officials and the P2K3 Secretary and Chairman. In each Unitcompany has conducted a number of trainingrelated to safety and health (OSH)aspects, some of which can be reported as follows: SMRE and GABA Units: - First aid Training, 21/5/2013, by dr. Wiyangga, from the clinic. 6 participants (4 foreman and 2 assistant clerks), materials include simulations on how to deal with accidents. - Socialization of ISCC, ISPO, RSPO, OSH, P3K, APD, MSDS, on29/05/2013. There were 13 participants. The presenter was OSH officer. - Socialization of procedure for handling natural disaster and fire (KTD), on 16/03/2013. Participants were 7 security personnel. - First aid Training, combined participants of Regional level, totaling 75 participants, on 10/10/2011. - General OSH Expert for P2K3 secretary. - Restricted pesticide use training, on 18/10/.2011, participants from SMRE with a total of 67 participants, on 19/10/2011. There was “Restricted Pesticide User Certification” from the Department of Agriculture, Food Crops and Horticulture of Lampung Province. - Special skill training, including: welder and heavy equipment operator license.

SMRM Unit: - First aid Training, 21/5/2013, 11 participants (4 foremen, 1 security personnel, book keeper, 2 analysts, nurses, P2K3 secretary, cashier). - Socialization of MSDS on 14/5/2013 at SMRM to 38 workers by OSH officer. - Special skill training, including: welder and heavy equipment operator license.

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

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

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Companyhas established Emergency Response Team by appointing its personnel. The capacity to prevent and mitigate fireis sought to by providing the following training:

- SMRM Unit, some of the Dry PowderSquad members have attended training in the use of portable extinguishers (Light Fire Extinguisher), dated 20/11/2010, but, only 2 out of the 7 squad members, i.e. Sudarso and Sugiarto. - GABA Unit, Light Fire Extinguishertraining has been conductedas seen in the List of Attendees of Light Fire Extinguisher Training, dated 7/6/2013. But, out of the Light Fire Extinguisher Team members, there is one not yet attending the training i.e. Sulisiyanto. - SMRE Unit, some of the Light Fire Extinguisher Team membershave attended Light Fire Extinguisher training on 29/05/2013 and 20/11/2011 in Division 1 office. But out of that number of Light Fire Extinguisher Team the TTD/ERP Structure has not received training.

Companyhas provided fire control/mitigation facilities and infrastructures as follows: - SMRM Unit In the Checklist of KTD Equipment dated 3 June 2013, it is recorded : (1). 35 Light Fire Extinguishersin 35 locations; (2). 4 units of pillar hydrant and 4 boxes of corresponding equipment (hoses and nozzles) at 4 strategic locations at St. Sterilizer, St. Boiler, St. Kernel, and St. Clarification; (3). Sandbag along with spades at 4 locations; and (4) Eye washers and showers in 5 locations (lab, CaCO3 warehouse, LB-3, oil warehouse and WTP). Companyalso has developed Evacuation Map and Map of Fire Sensitive Area provided with location points of Light Fire Extinguisher, hydrant, eye washer/shower, direction arrow of evacuation route, and2 assembly points. It is suggested the company completed the information on important telephone numbers to be contacted in the case of emergency. - SMRE and GABA Units In the Summary Report of Light Fire Extinguisher checking dated 28 May 2013, it was found : (1). 41 Light Fire Extinguishersdistributed in 41 locations in the entire estate area covering central office, fertilizer warehouse, diesel fuel warehouse, oil, spare part, LB3, division office, mess, staff housing. (2). 1 unit of water tanks, 1 portable water pump provided with hoses and nozzles/guns. Companyhas conducted routine inspection of Light Fire Extinguisher and hydrant and recorded the results using PMKS Patiware Light Fire Extinguisher and Hydrant Monitoring form, which that is carried out monthly. There is evidence of implementation for December 2012 and January 2013. This activity is carried out by workshop foreman, verified by assistance workshop and acknowledged by Mill Manager. In dealing with emergency situation, company has established Emergency Response and Preparedness (ERP) as follows: - Emergency Response and Preparedness Organizational Structure has been established for each Unit, covering SMRM, SMRE and GABA. The KTD structure was developed by P2K3Secretary and approved by P2K3 Chairman (Unit Manager). The structure is composed of Team Leader, Deputy Team Leader, General Assistant, Executive Chairman, Secretary, Fire Extinguishing Team (Dry Powder, Hydrant, Sand, Wet burlap, Hook), Evacuation Team, Security Team, Connecting team, Eliminating Team, and Health Team.

For SMRM mill area, company should have fire mitigation officers in accordance with the provisions of the Decree of the Minister of Manpower No. 186/MEN/1999. Based on Annex 1 and 3, a processing plant (Mill) is classified as vegetable oil mill with Moderate Fire Potential III. A factory with a total workforce of over 100 people should have fire mitigation officers: 1 for Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 32of 75

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class A, 1 for class B, 5 for class C, and 12 for class D. At the time of the audit stage 2, the Company had carried out Fire Simulation Training, dated 05/07/2013 from the Department of Social, Manpower and Transmigration, Tulang Bawang, to 20 people. However, this is only a fulfillment for class D. Company is strongly encouraged to comply with these provisions and required to program it in subsequent years.

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

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

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

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

On Saturday 11 May 2013, an accident occurred to a plane of Fletcher type conducting air maturing on oil palms. According to the explanation of Mr. Humala Sinaga (Lampung Regional Controller), the results of investigation of accident of plane coming from Air Manuring Division could not be obtained because of PT. Sumber Indah Perkasa (SIP) is just as a lessee who provides fertilizer and aircraft runway. Investigation is immediately undertaken by the National Commission for Transportation Safety (KNKT) on Sunday 12 May 2013 or a day after the incident with a note that parties who want the result of the investigation are asked to contact KNKTdirectly.

Compliance status: Observation no 3 & 6 4.8 All staff, workers, smallholders and contractors are appropriately trained.

Companyhas established annual training programs. Training activities are based on SOP on HR Development Training (SOP/SPO/SMART/LH-10, 1/7/2010, rev.01), covering: preparation, implementation, and evaluation. There is Training Need Analysis set by Regional Training Center Coordinator (RTCC) and the results are in the form of Training Need Identification Matrix (FL/Estate/TRAD/10), prepared by SPO Officer, and approved by Estate Manager. The Matrixes developed by SMRM, SMRE, and GABA units.

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

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

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

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

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participant, implementation time, and training location.

Company is deal with trained contractor personnel. As mentioned in the above training program, each contractorof SMRM Mill, SMRE Estate, as well as GABA Unit has been provided with related to RSPO, which includes :

- Socializationon appeal to include their workers in jamsostek, to care with environmental sustainability, protect biodiversity, implement OSH in the form of PPE use, encouragement to comply with OSH regulations, and being in harmony with the community. - Socializationon wage system and worker’s age that must not be <18 years old and minimum wage regulations. - Socialization on PPE: PPE mandatory, PPE benefit, encouragement to always follow OSH regulations—especially drivers and loading personnel. - For TBS transport contractors, evidence of being trained is demonstrated by driving license possession. - Some contractors for road maintenance and housing have been selected in a strict manner through pre-bidding process from the aspect of willingness to comply with OSH aspect, employment aspect, as well as technical aspect according to type of work to be done. Compliance status: Full Compliance

5 ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY

5.1 Aspects of estate and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate

Companyconducted impact analysis in the Revised ANDAL document ofAMDAL of Oil Palm Plantation and Oil Palm Processing into of CPO PT Sumber Indah Perkasa with an land area of 9,254 Ha and MILL with the capacity of 60 ton FFB/Hour No. Document is 16/KOMDAL/11.04/IV/2008 dated 14 April 2008. In ANDAL document the scope of environmental impact analysis is oil palm plantationactivity and processing into crude palm oil (CPO). The scope of environmental impact analysis is Sungai Buaya Estate, Sungai Merah Mill and Estate, Gedung Aji Baru Plasma, Gedung Aji Lama Plasma, Mesuji Estate, Sungai Buaya Mill, and Sungai Merah Mill. In ANDAL document, the environmental impact analysis is still scoping company current activity and condition. Environmental impact management is contained in RKL and monitoring plan is contained in RPL. The RKL and RPL is implemented every 6 months and report every 6 months to BLH of Mesuji Regency (SBYE, GABA, MSJE, SBYM), Tulang Bawang Regency (SMRM, SMRE, GALA, GABA) ANDAL Document also covers land biodiversity in the form of flora and fauna (biological aspect), social cultural aspectto the population of villages around unit and division. Compliance status: Full Compliance

5.2 The status of rare, threatened or endangered species and high conservation value habitats, if any, that exist in the estate or that could be affected by estate or mill management, shall be identified and their conservation taken into

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account in management plans and operations

Companyhas had SOP on Identification and Management of HCVNo.: SOP/NP/SMART/IV/LH 001 No. Revision 01 effective date 1 July 2010. Company has had the revised ANDAL document of AMDAL of Oil Palm Plantation and Oil Palm Processing into CPO of PT Sumber Indah Perkasa with a total area of 9,254 Ha and Mill with a capacity of 60 ton FFB/hour that scopes environmental conditions related to flora and fauna. Information in ANDAL document prior to planting, the flora identified is commercial crops such as meranti woodand there is no identification of fauna prior to planting. In ANDAL document there is flora and fauna identification after the land becomes oil palm plantation and oil palm mill, for flora it is palms and bushes, for fauna it is buaya, ular sendok, tikus, landak, babi hutan, macan akar, etc. The land’s baseline condition is a secondary forest. There is no information in ANDAL document about flora and fauna condition when it was still a secondary forest. Companyhas performed identification of areas with high conservation value along with a team that has obtained approval from RSPO Board and the report of identification of high conservation value area has been peer reviewed by Resin Sözer, an independent body approved to do peer review of high conservation value (HCV) area. Companyhas the Final Report of Identification and Analysis of the Existence of High Conservation Value Area (HCV) of each unit. At the stage I and stage II, the Final Report of Identification and Analysis of the Existence of High Conservation Value Area (HCV) of Sungai Merah Estate (SMRE), KKPA Gedung Aji Baru (GABA) Estate is shown. In Sungai Merah Estate it covers the border area of Sungai Buaya, the border area of Pidada River, Putuk River and Camp River, reptile fauna, mammals, Aves, and so on. Protection of river border is to clear it from oil palms with a clearance space of 50 meter from the river edge, and the river banks are planted with bamboo andvertiver grass to prevent erosion. For fauna protection, companyplaces communication boards of hunting prohibition in several areaswhere fauna occurrence is identified though through footprints (macan akar and babi hutan). HCV identification was conducted in the oil palm plantation area of SMRE unit (4°5’ - 4°17’ S and 105°26’ - 105°39’ E).The working area of PT. Sumber Indah Perkasa - SMRE is 4,046.01 Ha with planting years of 1991, 1992,1993, 1994, 1996, 2000, 2001 and 2004. GABA Unit has the area of 5,005.25 Ha with planting years of 1995, 1996, 1997, 1998 and 1999. Data of flora and fauna prior to planting are contained in Initial Environmental Examination of (PIL) Document of Oil Palm Plantation Project of PT. Sumber Indah Perkasa, Mesuji District and District, which is prepared by PT. Mulia Consultants. Data of flora diversity consists of: Cover Crops (Base Vegetation), among others: - Alang – alang (Imperata cylindrical) - Rumput Bendera (Eleucine indica) - Putri Malu (Mimosa invisia) - Pakis (Alsophila sp) - Rumput Merdeka (Paspalum sp) Trees, among others:  Pala Hutan (Myristica sp)  Beringin Hutan (Ficus benyamina)  Karet (Hevea brasiensis)  Bambu (Bambusa sp)  Pule (Gudrania sp)

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Aquatic Flora around the project location of PT. Sumber Indah Perkasa, among others:  Ganggang Hijau (Chlorophyta)  Enceng Gondok (Eichornia grassipes)  Palam (Corypha sp)  Teratai Putih (Nelumbium sp)  Pakis Air (Ceratopteris sp)  Lumut (Bryophyta) Data of terrestrial fauna diversity in the project location of PT. Sumber Indah Perkasa prior to plantingincludes: Aves  Manyar (Ploceus manyar)  Tekukur (Streptopelia sp)  Jalak (Strurnus contra)  Emprit (Lanchura sp)  Cucak Rowo (Pycmonotus sp)  Elang (Bustantur sp) Mammals  Gajah (Elephan sp)  Kijang (Cervis timorensis)  Babi (Sus vitatus)  Beruang (Urus sp) Reptilia  Ular Piton (Phyton sp)  Kadal (Mobvia multifaciata)  Ular Sawah (Phyton molurus) Insect  Kupu-kupu (Papilio sp)  Capung (Gomphus sp)  Kumbang (Aryetes sp) The following is details of Identification and Analysis of the Existence of High Conservation Value Area (HCV) of Sungai Merah Estate andKKPA Gedung Aji Baru(GABA) Estate:

Type Divisi/Blok/ Area Hasil Identifikasi Lapangan HCV Lokasi Temuan (Ha)

Sungai Merah Estate (SMRE) There are protected animal species : (Block D20-D23; 1. Elang Hitam (Ictinaetus malayensis) E20-E23; B26- 2. Elang Tikus (Elanus caeruleus) B29; C26-C30; 1.2 3. Cangak Abu (Ardea sumatrana) - D26-D30; E30) 4. Raja Udang (Alcedo meninting) and surrounding areas There are protected animal species : Pidada river 1. Buaya Muara (Crocodytus porosus) 2. Kuntul Kerbau (Bubulus ibis) -

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KKPA Gedung Aji Baru (GABA) Estate - Plasma

There is area of river border or riparian ecosystem of Putuk river 17,42 Putuk River and Camp River which functions to 1.1 ; 4.1 Camp river support local protected areas, water sources and 10,06 flood control. Endangered/protected species in the list of Gedung Aji Baru Government Regulation No. 7/1999 (Protected) and (GABA) KKPA IUCN LC ver 3 (2010), include : Estate,Division 6 1. Raja Udang Biru (Alcedo coerulescens) Peringgan and 2. Cekakak Belukar (Halycon smyrnensis) Pidada river 3. Blekok Sawah (Ardeola speciosa) 1.2 4. Kuntul Kerbau (Bubulcus ibis) - 5. Raja Udang (Alcedo meninting) 6. Cangak Laut (Ardea purpurea) 7. Cangak Merah (Ardea sumatrana) 8. Pekakak Emas (Pelargopsis capensis) 9. Cekakak Sungai (Todirhamphus chloris) 10. Macan Akar (Felis bengalensis)

HCVmonitoring is conducted every 2 weeks. Document used is Patrol Log Book which is summarized into HCVMonitoring Form No. Document F/SMART/LH003/09 every 6 months. In addition, there are documents:  Erosion Control Crop Planting Report  HCV Area Patrol Report  Boundary Peg Maintenance Report  Water Level Report  Socialization Invitation  HCV SocializationReport HCV Monitoring Form has specified recommendations for improvement as well as recommendations based on routine monitoring carried out every 2 weeks, but Person in Charge (PIC) and a due date for the completion of recommendation should be determined to see the progress of follow up to HCV monitoring results. (Observation) Compliance status:Observation no.5 5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner

Companyperforms impact analysis in the revised ANDAL document of AMDAL of Oil Palm Plantation and Oil Palm Processing into CPO of PT Sumber Indah Perkasa with a total area of 9,254 Ha and 2 Mills(SMRM and SBYM) with a capacity of 60 ton FFB/Hour. SOP of Waste Management, SOP/SPO/SMART/LH-09, revision: 00 approval date: 1 July 2010, covering mill waste: solid, liquid, gas (including LB3). Plantation: expesticide packaging’s, land application, ex agrochemicals (such as fertilizer bags)

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Current practice of waste flow rate measurement is only on waste that flows out directly from the mill to Land Application recorded using flow meter every 7o’clock in the morning and at the time when pumping is finished. Company performs ambient air and emission quality measurements (mobile and non-mobile sources). None of the measurement results exceeds the Environmental Quality Standard. Company reports the measurement results every 6 months to BLH of Tulang Bawang Regency (SMRM), BLH of Lampung Province, and Jakarta KLH, with evidence of their receipt. Liquid and Hazardous and Toxic Substance waste results are reported every 3 months. SMRM has 8 liquid waste ponds. Internal daily measurement in SMRM covers pH, Alkalinity, and VFA parameters. In SMRM, company has external parties (Health Polytechnic of Tanjung Karang Health Department) carried out the measurement of waste water, which is used for land application, and with reference to the Decree of the Minister Environment No 29/2003. The result showed the BOD and COD concentrations have meet with the Environmental Quality Standard. The organization has in place a SOP of Waste Management, SOP/SPO/SMART/LH-09, with revision: 00, approval date: 1 July 2010, covering plant wastes: solid, liquid, gas that includes the utilization of empty fruit bunch, shell, and fiber wastes. The organization has Waste Processing Work Instruction of LA and Empty Fruit Bunch (EFB), SIP-SMRE/IK/09. The organization has in place an extended permit of liquid waste utilization for SMRM in the form of Certificate of Extension of Permit to Utilize Waste Water on Soil (Land Application) to PT Sumber Indah Perkasa – Sungai Merah Mill Number: 660/322/III.7/TB/XI/2012. The letter issued from Government of Tulang Bawang Regency, Regional Environmental Agency, Menggala, Dated 23 November 2012, which is valid for 2 years. The utilization of empty fruit bunches at SMRE in January – April 2013 was 21,763 tons with a total land application area of 382.89 hectares. The targeted land area for empty fruit bunch (EFB) application for 2 years is 668 hectares. In 2012 it was 63,634 tons of EFB on 1,155.74 hectares of land, with the target of 672 hectares and 49,915 tons of EFB. Compliance status: Full Compliance 5.4 Efficiency of energy use and use of renewable energy is maximized

Company has performed identification of GHG emission sources of estate and mill activities. Company has calculated GHG emission of the SMRM, which includes calculation of respective GHG of estates supplying the fruit. Diesel fuel efficiency at SMRM in 2010 was 27.46%, 2011 was 44.32%, and 2012 was 33.94%, so that on average the efficiency was 35.92%. Diesel fuel use in 2010 was 1.88 liter/ton CPO, in 2011 was 1.51 liter/ton CPO, in 2012 was 1.12 liter/ton CPO. SMRM use of palm shell and fiber as fuel substitutes in 2012 was 10,916,000 kg and 37,891,121 kg, respectively, with the total energy used /ton CPO of 1,288,881 KKAL. Company has SOP on Calculation of Green House Gas Emission at SMRM of PT- SMRM/SOP/02 The use of empty fruit bunches at SMRE in January – April 2013 was 21,763 ton with total application land area of 382.89 hectares. Target area to be applied with empty bunches for 2 years is 668 hectares. In 2012 it is 63,634 ton of empty bunches 1,155.74 hectares of land, with Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 39of 75

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target of 672 hectares and 49,915 ton of empty bunches. Company has SOP on GHG Emission Mitigation of PT SIP – SMRM/SOP/22 No. Revision: 00, date approved: 02 January 2013, and performs calculations of GHG emission reduction from diesel fuel efficiency, shell efficiency in the process/mill where in 2012 the total GHG reduction from processing was 186.73 kg CO2/ton CPO. Compared with 2011 there is a rise due to the effect of low crop and huge crop during harvest. The Estate GHGcalculation is as follows: SMRE = 74.81 kgCO2eq/Ton FFB; GABA = 87.95 KgCO2eq/Ton FFB. SOP of GHGemission mitigation for PT SIP – SMRM/SOP/02, PT SIP. Compliance status: Full Compliance 5.5 Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN guidelines or other regional best practice.

Companydoes not burn wastes and there are no replanting activities. Companyalready bans the use of fire for replanting. Also, Company has instructed its workers and encouraged local people not to burn domestic garbage. Compliance status: Full Compliance

5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented, and monitored.

Management through RKL and RPL implementation. Organization has RKL and RPL covering environmental impacts on river and drilled well water quality, ambient air, noise, air quality. RKL and RPL are reported to the BLH of Tulang Bawang andMesuji Regency every 6 months starting from 2012, and there are receipts of RKL and RPL document submission. SOP of Waste Management, SOP/SPO/SMART/LH-09, revision: 00 date approved: 1 July 2010, covering mill wastes: solid, liquid, gas. SOP/WIis not yet available to handle stationary sources nuisance, such as noise that exceeds the Environmental Quality Standard. At the stage 1 the results of measurement of vibration, odor, and noise did not come out due to the environmental testing laboratory’s equipment problems. Organization has followed up by performing measurement on 20 June 2013 by the Government of South Sumatera Province, Organization controls vibration, odor, and noise nuisance through job work instructionfor nuisance in the Mill, such as noise disturbance, the work instructionof the genset job has incorporated controls using silencer in the gensetroom and use of ear protection devices (ear plug and ear muff). Compliance status: Full Compliance 6 RESPONSIBLECONSIDERATION OF EMPLOYEES AND OF INDIVIDUALS AND COMMUNITIES AFFECTED BY GROWERS AND MILLS

6.1 Aspects of estate and mill management that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 40of 75

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the positive ones are made, implemented and monitored, to demonstrate continuous improvement

Companyhas conducted Social Impact Assessment internallyin 2012. Based on the results of SIA it is identified that there are 14 villages around PT SIP affected by the social impact of estate and mill operations. SIA report says that the area of main estate is 9102.2 Ha and plasma estate is less than 15,000 Ha with total KUD member of 17,254 KK Company has had the list of stakeholders of all units. Based on the results of SIA and input from the units, companyhas established a strategic plan for CSR Program of 2014-2018:period (5 years). The program has included the short-term and long-term plans covering the aspects of education, health, infrastructure, sport, religion, arts, culture and micro business. The existing program does not include specific efforts made by company to preserve the native culture of indigenous people living around the company environment. Based on the SIA report, Company has conducted road improvement activities in 2009-2011 for 21 villages around the company site. Educational assistance is given to areas in the location of main estate and plasma estates. Religious assistance given in 2010 period already represents Islam and Christian religions and in 2013 it is for Hindu in the form of pura Talang Batu Village construction. Based on the SIA report there is negative perception because of jealousy felt by villages from not receiving social assistance (Batu AmparVillage and Tri Rejomulyo Village). Company responded by launching Cheap Oil Market Operation in 2012 in Batu Ampar Village and educational assistance in the form of building materialsfor the development of local primary school in SDN 01 Tri Rejomulya in 2013. Compliance status: Full Compliance

6.2 There are open and transparent methods for communication and consultation between growers and/or mills, local communities and other affected or interested parties

Companyhas had SOP on Responding to Request and Information (SOP/SPO/SMART/LH-01). List of information is already available to be accessed by relevant stakeholders. Request for information outside the list will require the consideration and approval from the Top management. List of stakeholders of each unit is already available consisting of customary/community leaders, Muspida and village chief, company trade union, Contractors and suppliers. Any incoming requests for information is recorded in KTU and passed to relevant Manager. All requests for information are recorded in information book. Each unit maintains information request and response book. Routine requests are recorded in a routine information granting book and non-routine informationrequests are recorded in a separate book. In addition, Sinar Mas Group has SOP on Communication and Consultation (SMART/XIV/MCAR003) where any informationrequests will be responded the longest in 5 weeks (1 month). Compliance status: Full Compliance 6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 41of 75

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Company has SOP on Complaint and grievances (SOP/NP/SMART/XII/MCAR001). Any complaint will be recorded in the log book of complaint and grievances. The source of complaints may be internally, externally and female workers. Sampling was conducted on employee’s complaint on 10 December 2012 concerning poor quality of . Company passed the complaint to KUD as the supplier of the rice. The response from KUD dated 20 December 2012 states that they will supply better quality rice. The officer informed that the employee has received better rice so that the complaint is closed. Compliance status: Full Compliance

6.4 Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stake holders to express their views through their own representative institutions

There is SOP on Land Conflict Settlement (SOP/SPO/SMRT/LH-04). So far the company and KUD give informationthat there is no dispute in the period from 2010 until now in the company’s surrounding areas. The SOP says to give first priority to deliberation for consensus over legal action. Compliance status: Full Compliance

6.5 Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages

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

With respect to the UMK (regency minimum wage) provisions the workers in the field have know it precisely. This is known from the interviews with a number of BHB workers (taken by sampling) of harvesting personnel. They inform that daily wages are Rp. 46.200,- working fulltime for 25 working days per month they will receive basic wages of Rp. 1.155.000,-,. On the wage payment receipt of May 2013, under the name of NIK: 12003/Abdul Majid (SKU-H status) and on the payment receipt of NIK: 12004 /Kadek Artawan a worker of GABA Unit (SKU-H status) the wages are written Rp. 1.155.000,-. The UMK provisions are imposed to the workers with BHL and PKWT status, and the first year SKU-H.

Company maintains companyrules in the form of: (1). Collective Labor Agreement (PKB) Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 42of 75

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

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

No. Jenis Bangunan Sat Lokasi Total SMRE GABA*) SMRM 1. Perumahan staf Unit 14 - 10 24 2. Perumahan Karyawan Unit 375 - 136 511 3. Masjid Unit 4 - 1 5 4. Gereja Unit - - - - 5. TK Unit - - - 1 6. SD Unit - - - 1 7. Rumpin (Rumah Pintar) Unit - - - 1 8. Policlinic Unit 1 - - 1 9. Balai Karyawan Unit 4 - - 4 10. Balai Penitipan Anak Unit 2 - - 2 11. Kedai ransum/ Koperasi Unit 2 - 2 12. Lap.Sepak Bola Unit 2 - 1 3 13. Lap. Bulutangkis Unit 4 - 1 5 14. Lap. Voley Unit 4 - 2 6 15. Lap. Tennis Unit 1 - - 1 16. Angkutan Anak Sekolah Unit 1 - 1 1 Remarks: *) Facilities for GABA are all shared with SBYE because they are located close to each other. The provisions on the rights to have housing facilities are regulated in PKB. It is also regulated in a circular issued by each Unit Manager. For example, Circulars concerning SKU Workers’ Rights, issued by the Unit Manager of GABA No. Reff: 082/SIP-GABA/04/2012. It is stated that when an employee is promoted to be SKU employee either Daily SKU (SKU-H) or Monthly SKU (SKU-B) he will be given his rights. Points 4, 7, and 8 say that they will have a housing facility without furniture, but with free water and lighting. For staff employee, housing facility will be furnished with furniture as stipulated in Remuneration – Housing Facility document (no.doc : NOM F-017/02-00 approved by MD Strategic officials, valid from 01/05/2006. This provision applies to employee of category H/G, F, D/E, to C/B.

Companyhas entered into a contract with contractor that requires the contractorsto comply with applicable regulations on employment. Evidence can be seen in the contract or SPK (Working Order) : 1). SPK No. 001-GABA/SPK-L/I/2013 -FFB Transportation & Loading between GABA Manager vs Supradi (contractor), as follows: - Article 5 on Terms and Specification of Work, paragraph 4 the requirements to be furnished with Vehicle Holder Book, Vehicle Registration Card, Inspection Certificate, and First Aid Kit.

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- Article 5 paragraph 19, use of PPE for Worker. - Article 5 paragraph 20, stressed that the contractor shall comply with the Department of Manpower and Transmigration’s laws and regulations. - Article 7, concerning Work Accident, where the second party (Nurohim) shall pay the wage of workers according to the UMK and include his workers in jamsostek program.

Compliance status: Full Compliance 6.6 The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel

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

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

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

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

Bipartite Cooperation Body (LKS)has also been established in each Unit and is already approved by local Department of Manpower. For example, the LKS Bipartite KUD Krida Sejahtera of KKPA GABA, 2013-2015 Period, No.: 560/HIPK/II.TB/BP/IV/2013 dated 15/04/2013 by Head of Department of Manpower and Transmigration of Tulang Bawang Regency. The membership is composed of 8 company representatives to 8 worker representatives.

Currently, the total number of PT SIP trade union members based on May 2013 data is 1,102 members. The membership is automatic once they become an employee with a minimum status of SKU-H. Names of members are registered in the Trade Union Member List of each work unit.

Companyprovides facilities to smooth Trade Union activities, in the form:

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- A room for Trade Union office - Desks, chairs, stationery, - File cabinet - A meeting table and chairs - Water dispenser - Uniforms clothing for the trade union board members totaling 16 pieces. - A freedom to use office administration facility. - Fostering the treasury by KTU relating to bookkeeping

Recordsof meeting both internal and external, as sample some can be reported as follows: - Minutes of SPSI meeting with the Management of PT SIP Lampung dated 31/01/2013, with subject “Discussion on workers’ aspiration and request”, attended by 17 workers at TT by PUK SPSI-Sopuan, EM Gala, and HRD Jakarta. - Minutes of PT SIP GABA Bipartit meeting, dated 15/4/2013, discussion on harvesting personnel wages 2013 and fines of production foreman, attended by 17 workers. - Minutes of coordination meeting between PUK and a delegation from PT. SIP Lampung SPSI on 8/01/2013 with the agenda: discussion on various issues, among other things, working day, employee’s (family member) death, socialization on how to establish SPSI in the units, harvesting tools, hand tractor, request for copies of any circulars from the management, format of expected payroll, bonus. The minutes are signed by the chairman and secretary. Compliance status: Full Compliance 6.7 Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programs. Children are not exposed to hazardous working conditions Companyis very stringent in selecting the candidate employee in order to prevent underage workers, the minimum should be 18 years old. This provision is regulated in: - PKB article 7 concerning new employee recruitment, paragraph 4, at the minimum 18 years old. - Government Regulation Chapter II Work Relations, Article 5, paragraph 2 that candidate worker should be the minimum 18 years old. - Circular Letter from HR Director to all Unit Head, No. 002/SE-HRDV/03/09, date 31/3/2009 with subject: Minimum Age Limitation, swehubu. Act No. 13, article 68, concerning child employment prohibition, so the minimum age of employee recruitment is 18 years old.

The evidence of implementation of this policy can be seen in the following data: - In the Summary Data of GABABHL Employee, the youngest work entry age is 19 years old, under the name of Ari Madela, born 24/09/1993, entry into work on 01/01/2013, for PKWT Employee , the youngest work entry age is 20 years old, under the name of Dedi Erik, born 12/12/1991, , entry into work on 07/03/2013 Compliance status: Full Compliance 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited

Companygives equal opportunities to everyone to work in Company.The documents: (1). HR Policy No. A-001-00, effective 1/9/2005, issued by Managing Director Strategic, point 2, states that in principles Organizationemploys competent individualsin accordance with position

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requirements without discrimination by ethnic, race, and religion”. (2). Employment Recruitment Policy: Provision on Recruitment and Selection Outside Jakarta (no. SDM A-006-00, dated 1/9/2005), regulates that recruitment of manpower does not define particular ethnic, sex, as well as religion as requirements. It is also mention minimum age of 18 years old.” As evidence, worker composition in each Unit can be seen in the data as per May 2013, from data sampling as follows: Data ofGABA Estate BHL: - Sex: Male 260, Female 114. - Religion: Islam 378, Hindu 4, Christian 1 - Ethnic: Javanese 375, Palembang 1, Balinese 4, and Sundanese 1.

Data of GABA Estate BHB : - Sex: Male 16, Female 276 - Religion: Islam 291, Hindu 1. - Ethnic: Javanese 286, Palembang 2, Lampung 1, Bali 1, and Sundanese 2.

The location of the estates and mills is in fact within transmigration areas which are mostly inhabited by people from Muslim Javanese ethnic. The forms of job application do not mention sex group, ethnicity, or religion for general occupation, means that any job can be performed by men or women. Compliance status: Full Compliance 6.9 A policy to prevent sexual harassment and other forms of violence against women and to protect the reproductive rights is developed and applied

Company has established a policy related to prevention of sexual harassment in a circular letter Socialization on Harassment Sexual Issues, No. 003/CEO2-SE/01/2011, dated 10/01/2011. There should be socialization to all employees concerning prevention and handling of sexual harassment issues, so as to increase legal awareness and respect norms and ethics in the plantation work units of Sinar Mas II. Samples of evidence of the implementation of prevention of sexual harassment activities of socialization in GABA Units are as follows: - GABA Unit, there is the Letter of Acknowledgement of Socialization on How to Deal With Sexual Harassment held on 15/03/2013, there are 12 participants for the staff’s wife’s and male workers. - GABA Unit, there is the Letter of Acknowledgement of Socialization on Sexual Harassment carried out on 15/06/2013, to 23 K3T representatives and 30 BHL Harvester. - In front of the GABA office there is a campaign poster saying “STOP..!!! Woman and Child Abuse”.

Nevertheless, in GABA Unit, this socializationhas been made only to 30 representative workers. There is no evidence that it is made to 276 workers personnel. This is established as minor nonconformity.

Company policy on protection of reproductive rights and documentedhas been included in: - Government Regulation chapter IV, article 23 concerning Annual Leave, Article24 Long Rest Period, Article 25 Maternity or Miscarriage. - Memorandum No. 001/Memo/VPA PSM2/04/2011 dated 8/4/2011, concerning prohibition of

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pregnant and breast feeding workers to work as sprayers. - Circular Letter No. 095/CEO2-SE/12/2010, dated 14/12/2010, concerning Menstrual Period Permit Granting, where working is not permitted in the first and second day.

Record evidence of the policy implementation of reproductive rights protection is: - There is Sick Letter Form, in the name of Ema Ratnasari NIK 10017, remarks:dysmenorrhea (H1 = Menstruation), dated 2-3 April 2012, from a clinic’s doctor. - Sick Letter Form, in the name of Ny. Latifatul F, NIK 12008, subject on maternity leave, 35 days, dated 28/122012 - 31/01/2013, from Wiyangga Saputro. The second: dated 08/11/2012 – 28/12/2012 (before and after giving birth). Records of employee’s complaints and grievances have already been maintained and followed up. For example, at SMRM Unit. There is an Internal Grievance Log Book, which contains: date, Place, Name, Contact details, Issue(s), Registrar, Response (Date, Action, Current status, PIC), and Target Finish. Sample records are a letter of grievance in the name of M. Tamzis, SKU-B, Workshop, residence at Blok C No. 16, (2) and Pasto Utomo, SKU-B, Office, Blok C No. 15. They are both complaining about the condition of septic tank that overflows in their house. The grievance letter was made on 10/6/2013, by both of them, and acknowledged by Asst M&R and KTU on 10 June 2013. A follow up action has been made accordingly. Compliance status: Minor Non-conformity no. 1 Growers and mills deal fairly and transparently with smallholders and other 6.10 local businesses. For Mesuji Regency, there has been a letter of FFB price stipulation from local Plantation Department of Lampung Provinceon 7 May 2013 stating that on average the FFB price is Rp. 1,136.27/Kg and the price company sets to the KUD Krida Sejahtera is Rp. 1,243.00 based on the planting year >10 year and higher. For July, Lampung Province sets Rp. 1,320.61/kg as the price for the crops of 10-20 years old. There is SOP for FFB Grading Guidelines and FFBGrading WI No PT SIP-SMRM/IK/04-1. It contains sorting criteria and penalty provisions for FFB out-of-specification. Company has established the grading system and penalty provisions and have conformed to the provisions stipulated by the Government. Based on the grading system, unripe and less ripe fruits and over ripe fruits will be subject to penalty 50%, empty fruit bunches 100%. The grading outcome and the percent of fruit subjected to penalty are sent to the KUD in the form of hardcopy and softcopy so that the KUD’s data is updated daily. Sampling of sorting outcome per January 2013 results in 9,446,020 Kg FFB and 13,202 kg penalty from over ripe fruits (50% penalty) and empty fruit bunches (100% penalty). The grading determination has conformed to the provisions of the regulation of the Minister of Agriculture No. 395/Kpts/OT.140/11/2005 The setting up of FFB purchasing price follows the prevailing provisions, and the summary of FFB price stipulation from authorized agency is available. Payment has been settled in a timely manner both to cooperatives and contractors. Company should ensure the cooperative’s efforts to communicate pricing methods and price cutting related to costs imposed to plasma members for maintenance and transportation. This is to ensure that all parties understand the contract agreement they entered into, and that the contracts are fair, legal and transparent. Compliance status: Observation no. 8

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6.11 Growers and millers contribute to local sustainable development wherever appropriate

Company has in place a policy in the form of company memorandum to perform CSR program throughout the company group in order to comply with Act of RI No. 40/2007. CSR plan in 2013 covers the aspects of education (scholarships), health (hospital rehabilitation, posyandu activities, fogging, mass medication), economic empowerment (FFB transportation by local contractors, purchasing local materials), infrastructure (road improvement, surfacing) and social assistance for religious purpose and celebration of day of an important event. Company has a program of prioritizing local contractors to have jobs. Jobs given include printing materials for administration purposes and rice procurement by KUD, FFB transportation, harvesting ladder construction. Samples taken are SPK 001-GABA/SPK-L/I/2013- FFB Transport. The SPK has a validity period and terms of payment which is twice a month under the name of Bp. Suradi, May 2013 period. Compliance status: Full Compliance 7 RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS

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

8.1 Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations

Company has conducted evaluationregularly to ensure ‘continuous improvement’ through the mechanism of regular management meeting and internal audit activities. SOP no. SOP/SPO/SMART/LH-16 lists audit internal which is conducted at least once a year. In addition, the management conducts routine meetings both regionally and corporately. Company has conducted internal audit with different objects, such as called Mill Audit Advisory which is performed twice a year. For ISPO/RSPO, Internal Audit is scheduled at least once a year. ISPO/RSPO internal audit was carried out by personnel who have had Internal Auditor training, i.e. Maman Surahman, Baby F Nurainy and Hendra Setiawan on 19-26 March 2013. There were 13 findings and all have been closed. Company has developed CSR program for respective units and for the communities in the neighborhood of plasma and main estates. Some of the short-term programs have been implemented for the period of 2013. Company should develop a specific method to evaluate the effectiveness of CSR programs done as input to future program improvement. Compliance status: Observation no. 7

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

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

Verified and Reviewed by:

Name Nuzwardy Sjahwil

Position SLA / LA / Auditor

Signature

Date December, 16th 2013

Approval:

Name Triyan Aidilfitri

Position HSE Audit and Certification Department Head

Signature

Date December, 16th 2013

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List of Abbreviation

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

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

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ATTACHMENT-1 MAP

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1.1. Overlay Map of Sungai Merah Estate (SMRE) and KKPA Gedung Aji Baru (GABA) Estate

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1.2. Map of Rivers

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1.3. Map of HCV Gedung Aji Baru Estate

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1.4. Map of Topography

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1.5. Map of Planting Year Sungai Merah Estate (SMRE)

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1.6. Map of Planting Year Gedung Aji Baru (GABA) Estate

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ATTACHMENT-2

NCR

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Non Conformity / Observation Report Organization Audit 14-06-2013 (TSS, RQ, No. No. Standard. Audit Date : WS, AMR, )

RSPO 00003 1 (1) RSPO (Preliminary) ATL / Auditor :

RSPO 00004 Organization Rep. :

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

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Office of Lampung an approval from the Province No. State Minister of 1052/KANWIL-6/TGH- Investment / Head of 134/90 is BKPM No undocumented in the 46/II/PMDN/1998 dated estate office so that at 01 July 1998 concerning the time of pre audit it Letter of approval for could not be shown to expanding domestic the auditor.2. The IUP capital investment stating does not specify a mill that the production with a capacity of 120 capacity becomes 120 tons/hour, but with Tons of FFB per hour. respect to production This was confirmed by capacity, there has the letter of the Head of been an approval from Capital Investment the State Minister of Coordinating Board and Investment / Head of Integrated Permit Service BKPM. of Lampung Province No 800/200/BID. V/II.06/2013 dated 01 July 2013 that the Business Permit of PT SIP issued by BKPM / Agency for capital investment is equal to the estate business license (IUP) issued by sectoral technical agency due to the authority granted by the Minister of Agriculture.

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2 Major 4.6 ; 1 RQ Waste water come Corrective Action : Closed 5.3 from bathing activity of To repair the bathroom's sprayer personnel at sewer so that used At GABA, waste water the SBYE does not water from the sprayer comes from bathing enter into the septic bathing activities will not activity of sprayer tanks or a catchment go to public ditches. personnel flows into and still flows into the septic tanks, but at public ditches. SBYE it flows to public Evidence: ditches. This is Used water from the potentially to sprayer personnel contaminate water that bathing activities has will poison flora, fauna, been directed to the and human. septic tanks (Photo documentation is available). 3 Major 5.6 1 RQ Vibration and odor Corrective Closed The measurement tests have been carried Action:Perform vibration results for vibration, out but the results are and odor tests in odor, and noise are not not obtained yet. collaboration with an obtained because there accredited is a problem with the laboratory.Evidence:The environmental testing results of vibration and laboratory's equipment. odor tests have been available. 4 Major 5.4 1 RQ The company does not Document of land use Corrective Action: Closed have a record of land trajectory cannot be Document of land use use trajectory from shown because the plan prior to the secondary forest into prior status of land is plantation opening will palm land. APL be searched for. The company does not have a record of land Evidence: use a minimum 2 years The document is before the land is available in the form of

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cleared for plantation land satellite image business. 1988 – 1989. The company does not have a record of land use trajectory from secondary forest into palm land. The company does not have a record of land use a minimum 2 years before the land is cleared for plantation business. 5 Major 4.1 1 WS The SOP on Seed SOP does not include Corrective Action: Closed Nursery sentences requiring the Develop a mechanism (SOP/SMART/MCAR/II use of certified seeds. that requires the use of I/TA-BBT, rev.00, certified seeds. 1/9/2012) and IK/SMART/MCAR/III/T Evidence: A-BBT/06 on Seedling The mechanism to use Acceptance and certified seeds has been Planting does not yet available in the form of explicitly regulate the SE from VPA PSM2. "obligation to use a certified seed". 6 Major 4.1 1 WS There is no SOP/Work SOP of planting on Corrective Action: Closed Instruction that peat land is unable to Develop a SOP that explicitly and in details be shown because the regulates planting in regulates planting on company has peat land replanting peat land committed not to make area. a new planting in peat land area. Evidence: There has been a SOP regulating on planting in

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peat land replanting area. 7 Major 4.7 1 WS The company, for Fire warden training is Corrective Action : Closed SBYM and SMRM not already conducted Deliver fire mitigation Mills, currently does at SBYM and SMRM training to fire warden in not have fire mitigation units. collaboration with officers as regulated in relevant Kepmenaker No. agencies.Evidence :Fire 186/MEN/1999. warden training has been conducted by Local Manpower and Transmigration Service & Disaster Mitigation Body of Tulang Bawang Regency on 5 July 2013 8 Major 4.7 1 WS There are some At the implementation Corrective Action: Closed officers of fire fighter of fire mitigation Conduct training in squad in the training, some of the using Apar for fire Emergency Response emergency response fighter squad that has Team Structure without team's members were registered in the evidenced of fire not present so that not structure of emergency mitigation training. all the people have fire response team. They are: SBYE, 1 mitigation training. people, SMRM 5 out of Evidence: 7 people, and SMRE 5 Officers of fire fighter out of 8 people. squad registered in the emergency response team have received fire mitigation training. 9 Major 4.7 1 WS Simulation on dealing Fire simulation has not Corrective Action: with fire emergency conducted in each Conduct fire emergency situation has not been work unit of estate and response simulation. carried out in SBYE mill, because to date and GABA units. fire simulation is Evidence:

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carried out jointly Documentation of the (Estate and Mill) at simulation SBYE. implementation has been available. 10 Major 4.7 1 WS Data of worker health Periodic health Corrective Action: Closed showed that there is no examination has been Conduct Cholinesterase examination of conducted routinely, examination for cholinesterase aspect but the examination of chemical warehouse on workers touching Cholinesterase has not officers and sprayer B3, such as: sprayers been conducted yet on personnel. and chemical the sprayer personnel warehouse officers. and chemical Evidence: warehouse officers. Chemical warehouse officers and sprayer personnel have their cholinesterase examined (The test results from Prodia Laboratory have been available). 11 Major 4.7 1 WS During a visit to Mill Noise test value at St. Corrective Action: Risk Closed area, some workers Sterilizer and Nut analysis has been were found not using Kernel is 84 - 85 dBA. reviewed based on PPE, sampling: (1) at . suggestion from the SMRM, in the area of Auditor by providing ear St. Sterilizer, and Nut- plug/muff in ST Kernel, not using Sterilizer and Nut earplug/muff. (2). No Kernel.Evidence apron was available for :Minutes of ear plug / workers in boiler area. ear muff supply / acceptance have been available. 12 Minor 6.9.1 1 WS There is no evidence Sexual harassment Corrective Action: Not that sexual socialization in MSJA Document the evidence Closed

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harassmentsocializatio has been conducted to of sexual harassment (This n has been conducted the staff's wives and socialization. NCR in MSJA unit. In some female workers will be addition from the but the documentation Evidence: seen in evidence of is kept in the MSJA Evidence of sexual certifica socialization records SPO secretariat so that harassment tion available is still it was unable to be socialization is available audit) extremely small in shown during and documented. number. document checking by auditor in the Lampung Regional office. 13 Observas 6.1 1 TSS It would be better that The short-term CSR Corrective Action: Closed i CSR plans developed plan has been Finalize 5 year CSR are capable of ensuring available in the form of strategic plans. welfare/skill Annual CSR Program. improvement. The The Five Year CSR Evidence: method of need Strategic Plan of 2014 The draft CSR strategic identification are – 2018 periods along plan of 2014 – 2018 employed as a basis to with the performance period along with determine priorities of indicator for evaluating performance indicator the CSR program in CSR activities are for evaluating CSR villages outside the under preparation activities have been company area. process. available. It is suggested the company establishes a short- and long-term plan and a method of evaluation to ensure that the CSR program is effective and successful as an indicator of improvement.

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Non Conformity / Observation Report Organization 19-07-2013 (TSS, RQ, GGU, YSF, Audit No. Standard. Audit Date : WS, )

RSPO 00003 No. 02 (1) RSPO (Certification) ATL / Auditor :

RSPO 00004 Organization Rep. :

Audit Root Cause Corrective Action & Team No. Category Clause Std Auditor Description Investigation* Evidence* Review (1) (2) (3) (4) (5) (6) (7) (8) (9) 1 Minor 6.9 1 WS The implementation of Sexual harassment To completed the Closed sexual harassment socialization has been documentation of sexual socialization to employees is conducted to the workers, harassment socialization. limited compared to the but the documentation Evidence : number of workers. Data was cannot be showed at Documentation of sexual showed : the time of audit. harassment socialization is -In GABA Unit, the number available at SPO of workers has been secretariat. socialized to 30 workers. For BHL and PKWT personnel are30 out of 276 workers (only 10.9 %). 2 Observasi 4.6 1 YSF Company has used The company still apply The management has Closed herbicide registered in restricted pesticide i.e. issued memo to reduce Pesticide Commission of the paraquat. the paraquat No. Republic of Indonesia but 002/MEMO-VPA the use of restricted PSM2/04/2011. The pesticide should be reduced restricted pesticide will be gradually and substituted by monitored yearly to see a more environmentally the trend of paraquat friendly herbicide and safer reduced. to field operators. Evidence : Graphic of

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restrictedpesticide use year 2011-2013 showed the reduce of paraquat used. 3 Observasi 4.7 1 YSF Company has undertaken The workers with To conduct identification Closed workers health examination exposure to chemical the workers with risks of covering cholinesterase and material hazard were not chemical exposure and audiometry but for those checked for spirometry. gradually will conduct working with risks of spirometry checking. chemical exposure should Evidence : be added with spirometry 1. List of worker who examination to ensure their needs to be checked lung health. for spirometry. 2. Medical check program for spirometry. 4 Observasi 2.3 1 TSS/GG Organization has made a The company has the Map will be adjusted to be Closed U map but the map should different scale for all scale 1 : 100.000 have a sufficient scale, at maps. Evidence : least 1: 100.000 in Map with the scale accordance with Decree of 1:100.000 the Ministry of Forestry No. 48/menhut-II/2004. 5 Observasi 5.2 1 TSS/GG Organization has performed There is no column for Completed the form with Closed U monitoring and contained in PIC and Action Plan at edit PIC and Action Plan. HCV Monitoring Report, but Form HCV Monitoring. Column. it should establish Person in Evidence : Charge (PIC) and due date Revision of Form HCV of the recommendation Monitoring. specified in the HCV monitoring report to see the follow up and progress of such recommendation.

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6 Observasi 4.7 1 WS Company already complete The simulation of fire To fulfill the number of fire Closed with the provisions of Decree fighting has conducted fighter to meet with the of the Ministry of Manpower but the number of the fire Kepmenaker No. 186 No. 186/1999 related to the fighter was not meet with Tahun 1999. number of fire mitigation the government Evidence : personnel in mill area. But it regulation (Kepmenaker Documentation of fire only trained 20 personnel for No. 186 Tahun 1999). fighter training. both mills (it should be 12 personnel for each mill). It should ensure to gradually conduct training to cover the remainder in class D, C, B and A. 7 Observasi 8.1 1 TSS Companyshould develop a Yearly CSR Program has The company will re- Closed specific method to evaluate been setup for each unit, identification the existing the effectiveness of CSR but not yet covered the indigenous people. If there program done as input to culture program. For the is then the company will future program strategic planning year setup the CSR to develop improvement. 2014-2018 has and maintain the culture of addressed the vision and indigenous people. mission to develop and Evidence : maintain the culture of Revise CSR Program. local people. 8 Observasi 6.10 1 TSS Company should ensure The company has The company will conduct Closed cooperative’s efforts to conducted the monthly meeting and to socialize aspects that socialization to the socialized the factor in become a factor in price cooperation staff and price cutting related to cutting related to costs coordinator staff, costs imposed to plasma imposed to plasma members regarding the factor in members for maintenance for maintenance and price cutting related to and transportation costs. transportation costs. Proof costs imposed to plasma Evidence : that all parties understand members for The documentation of the contract agreement they maintenance and meeting schedule between entered to, and that the transportation costs. But company and cooperation contracts are fair, legal and the socialization was not is available. transparent. sufficient some of the members were found well

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not understand for the subject. 9 Observasi 1.1 1 TSS It is advised that company Obs ensures responses to any information request as required by related SOP where responses are to be given within 1 month at the latest. Sampling II, no records are found on request for assistance applied by Ibu Nurhayati on 18 May 2013 i.e. application for educational and playing equipment assistance for TK Dharma Batu Ampar.

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APPENDIX

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

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

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

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

Records/Evidence: Management Representative related to RSPO-SCCS implementation Traceability Officer related to RSPO‐SCCS implementation SMRM: Decree No. 010/PC‐SMRM/III/2013

Document Controller – SPO Officer related to RSPO‐SCCS implementation SMRM: Decree No. 005/FM‐ SMRM/III/2013 1.2 The facility shall have documented procedures for receiving and processing certified and non-certified FFBs.

Records/Evidence:  SOP Identifikasi dan kemampuan-telusuran (SOP Identification and Traceability) PT SIP‐SMRM/SOP/01  Surat Pengantar Buah (Fruit Delivery Letter) (SMRE & GABA) with ‘’Mass Balance’’ mark SMRM: Form Rekap Penerimaan TBS Per Unit (FFB Receiving Resume Form each Unit)  CPO Production Report SMRM = 55,362.691 ton/Year (with average OER : 21.51) Recapitulation data of FFB certified received/process & CPO production from January to December 2012  PK Production Report SMRM = 13,802.922 ton/Year (with average KER : 5.37) Recapitulation data of FFB certified received/process & PK production from January to December 2012  CPO Dispatch Report SMRM = 54,631.570 ton/Year (Addition of Initial Stock, Carry over Last Year)  PK Dispatch Report SMRM = 13,466.250 ton/Year B. Purchasing and goods in Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 72of 75

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2.1 The facility shall verify and the document the volumes of certified and non-certified FFBs received.

Records/Evidence:  There is procedure SOP Identifikasi dan kemampuan-telusuran (SOP Identification and Traceability) PT SIP‐SMRM/SOP/01  There is a database system called Weightbridge Computerized Program which has been designed to separate certified and non-certified incoming FFB from own estate, Scheme small holders and independent small holders with the specific code in database. 2.2 The facility shall inform the CB immediately if there is a projected overproduction. Records/Evidence:  SOP Identifikasi dan kemampuan-telusuran (SOP Identification and Traceability) PT SIP‐SMRM/SOP/01  Inform related RSPO certification body and RSPO IT System.  Re-analyze production data and mass balance report.  Calibrated and recheck for the bridge and supporting equipments.  To define the projection of certified product considering the error rate (contamination) for maximum 5% from the total projection data. C. Record keeping 3.1 The facility shall maintain accurate, complete, up-to-date and accessible records and reports covering all aspects of these requirements.

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

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

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

Records/Evidence: The company has the monthly, three-monthly, and annual report which contain record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO and PK. (SBYM Mass Balance Monthly Report, SBYM Mass Balance Three-Monthly Report, and SBYM Mass Balance Annual Report) All volumes of palm oil and palm kernel oil that are delivered are deducted from the material accounting system according to conversion ratios stated by RSPO.

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

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

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

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

The customer of SBYM for CPO and PK products are PT. SIP Bulking Tarahan. The transporter of SBYM are: - PT. Satrindo Jaya Agropalma (for PK and CPO) - PT. Abadi Wijaya Utama (for CPO) - PT. Lima Adil Makmur (for CPO) E. Training 5.1 The facility shall provide the training for all staff as required to implement the requirements of the Supply Chain Certification Systems. Records/Evidence: The facility shall provide the training for all staff as required to implement the requirements of the Supply Chain Certification Systems. Records/Evidence:  SOP Training dan Kompetensi Sumber Daya Manusia (SOP Training and Human Resources Competency) Document No.: PT SIP‐SMRM/SOP/19, issued 02/01/2012  RSPO – SCCS Training available in Identification Matrix Needs  Invitation, Attendance List, Socialization Training Material RSPO –SCCS, 07 May 2013 F. Claims Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 74of 75

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

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

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