Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM 5/12/20, 4:14 PM
April/May Update - Trader Tracker
Rapid Response
We are hereby giving you the opportunity to review the latest version of Mighty Earth’s Trader Tracker’ table, which provides the status of grievances related to cases, highlighted in Rapid Response reports, that have been linked to your company’s supply chain. Please provide any update on your engagement, if applicable, no later than May 25, 2020. After this date, we will update the scores in the graphic on our website.
Bunge’s Trader Tracker’ table can be found here: https://airtable.com/shryFrbQYSI9KZpL4
Best,
SARAH BRICKMAN I SENIOR ASSOCIATE I miahtvearth.org [email protected] Follow us: -acebook I Twitter
The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’ work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.
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Bunge 5/12/20, 4:24 PM
Bunge
# Concession Name/Compa... Parent Company Reports Bunge LC
Condong Garut JA Wattie & Co. Report 4 Report ( ^
PT Kahayan Agro Plantation Anglo-Eastern Plantations Report 25 Report Filed
PT Permata Putera Mandiri... Austindo Nusantara Jaya Agri... Report 10 Report
BLD Plantation Bhd BLD Plantation Bhd Report 11 Report
PT Jaya Jadi Utama CB Industrial Product Holding Report 26 Report
Radiant Lagoon Sdn Bhd Double Dynasty Group Report 13
Mutiara Pelita Genaan Plan... Double Dynasty Sdn Bhd Report 15
PT Kapuasindo Palm Indust... Evershine Asset Corporation ... Report 12 Report
PT Ketapang Hijau Lestari Fangiono Agro Plantation group Report 9
10 PT Temila Agro Abadi Felda Global Ventures Holdin... Report 9 Filed
11 PT Agrinusa Persada Mulia GAMA Group Report 20 Report Monitoring Re-Entry
12 PT Agriprima Cipta Persada GAMA Group Report 3 Report' Monitoring Re-Entry
13 PT Citra Sawit Cemerlang Genting Plantations Bhd Report 16 Report I.WM/.MH.'.fc
14 PT Kartika Cipta Pratama Hayel Saeed Anam Group (HS. Report 13 Report
15 PT Megakarya Jaya Raya Hayel Saeed Anam Group (HS. Report 5
16 PT Sumatera Jaya Agro Le... Incasi Raya Group Report 10 Disputed
17 PT Internusa Jaya Sejahtera Indonusa Report 15 Report
18 Kwantas Pelita Plantation (... Kwantas Report 14 Filed
19 PT Persada Era Agro Kenca... Mulia Sawit Report 25 Report ^
20 PT Sumur Pandanwangi Musirawas Report 11 Report
21 PT Global Primatama Mandiri Palma Serasih Report 26 Report
22 PT Sawit Mandiri Lestari PT Metro Lestari Jaya Report 14 Report
23 PT Pinang Witmas Abadi PT Pundi Bhakti Khatulistiwa/. Report 12 Report
24 Jaya Tiasa Holdings Berhad Rimbunan Hijau Group Report 12 Disputed
https://airtable.com/app62ta laWgcFZ0WJ/viwlzbFpq9sVGVqgm/print...965f27380cc1d4069c156e6ad61c5030ade390f6af2c56111b02cce%22%7D Page 1 of 3
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Bunge 5/12/20, 4:24 PM
25 LPF/0008 Marudi & Batu B... Samling Report 26 Report ^
26 Shin Yang LPF 0018 Shin Yang Group / Sarawak Oi... Report 15
27 Ladang Selezu Sdn Bhd Ta Ann Group Report 15 CWMMlnl
28 Hydroflow Sdn Bhd TH Plantations Bhd Report 14 iJl.IWW.IAlc!
29 PT Harapan Rimba Jaya Tsani Hutani Abadi Group Report 9 Report i
30 PT Rayatama Jaya Tsani Hutani Abadi Group Report 14 Report
31 PT Kruing Lestari Jaya Tsani Hutani Abadi Group Report 9
32 PT Mulia Inti Perkasa Widya Corporation Report 25 Report Disputed
33 PT Arvenasepakat Incasi Raya Group Report 17
34 PT Kurun Sumber Rezeki CB Industrial Product Holding... Report 17 CHMBMt
35 PT Putra Katingan Pratama Kirana Megatara Report 17 Disputed
36 Poh Zhen Sdn Bhd Rimbunan Hijau Group Report 17 Disputed
37 Southwind Plantation Sdn... WTK Group Report 17 Filed
38 Adong estate, part of LPF ... Woodman Group Report 17 Filed
39 Liku estate, part of LPF 00... Woodman Group Report 17 Filed
40 Erajaya Synergy Sdn Bhd (... Rimbunan Hijau Report 18 Disputed
41 Woodijaya Sdn Bhd (Lot 197) Rimbunan Hijau Report 18 Disputed
42 Trans Kenyaland Sdn Bhd Tradewinds Report 18 Disputed
43 Woodman Group (Baram e... Woodman Group Report 18 Filed
44 PT Mekar Karya Kahuripan Makin Group Report 17 Disputed
45 PT Menthobi Mitra Lestari Bakrie Group Report 16 Disputed
46 PT Bonti Permai Jayaraya Lyman Agro Report 19 Filed
47 PT Bina Sarana Sawit Utama Samuel International Group Report 19 Filed
48 PT Bintang Sakti Lenggana NT Corp Report 19 Filed
49 Sime Darby Plantation Sdn ... Sime Darby Report 19
50 PT Putra Utama Lestari (ar... Dharma Satya Nusantara (DS... Report 20 Closed with Resolut...
PT Putra Utama Lestari (ar... Dharma Satya Nusantara (DS...
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Bunge 5/12/20, 4:24 PM
51 Report 20 Closed with Resolut..
52 PT Agrinusa Persada Mulia GAMA Group Report 20 Monitoring Re-Entry
53 PT Kalimantan Agro Kencana Surya Dumai Report 20 Filed
54 PT Sabhantara Rawi Sentosa Dhanistha Surya Nusantara Report 21
55 PT Ketapang Agro Lestari First Resources Report 21 Filed
56 PT Bulungan Surya Mas Pr... Global Enterprise Sdn Bhd Report 21
57 PT Cipta Karsa Kahuripan Makin Group Report 21 Disputed
58 Almabumi Plantation Sdn B... BBC Holdings Sdn Bhd Report 21
59 PT Arjuna Utama Sawit Borneo Pacific Report 23 Report Filed
60 PT Damai Agro Sejahtera Bumitama Group Report 22 Disputed
61 PT Arrtu Energie Resources Eagle High Plantations Tbk Report 22 Disputed
62 PT Andalan Sukses Makmur Bumitama Group Report 23 Disputed
63 PT Sawit Lamandau Raya CB Industrial Product Holding Report 26
https://airtable.com/app62talaWgcFZ0WJ/viwIzbFpq9sVGVqgm/print...965f27380cc1d4069c156e6ad61c5030ade390f6af2c56111b02cce%22%7D Page 3 of 3
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM 5/12/20, 4:14 PM
Grievance log for Olenex Sari? Rapid Response
We’d be grateful if you could clarify how grievances related to the supply chains of Olenex Sari, a joint venture between ADM and Wilmar, are addressed. The company’s website publishes mill lists, but there is no grievance mechanism or log.
Thank you,
SARAH BRICKMAN I SENIOR ASSOCIATE I miahtvearth.org [email protected] Follow us: Facebook I Twitter
The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies ’ work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.
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olenexSpecialists in Edible Oils
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM A FULE¥4RAC?AMT«0fLWm CMP0 4:39:05 PM
Traceability is an integral part of providing greater transparency in the supply chain. We have identified all mills supplying our refineries. The map displays the locations of our refineries and holds the traceability reports per refinery and their supplying mills.
Our customers have full insight in these reports. Please select a location to view its traceability report. The reports are updated on a biannual basis.
UNTRACEABLE? Suppliers can only be traceable by providing all the required information. Should any detail be incomplete or missing, we will treat that particular supplier as untraceable. Even when the origin of the product is known. The traceability values are based on the recorded volumes supplied to our refineries over a period of the last four calendar quarters.
ESSENTIAL INFORMATION We identify the location and name of the mills in our supply chain, including the certification status of their production. A mill is only considered traceable when the following information is known;
1. parent company name, 2. mill name, 3. address, 4. longitude and latitude coordinates, 5. certification status.
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM TRANSFORMATION read more
SUSTAINABILITY PROGRAMMES read more
NDPE POLICY read more
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM ABOUT OLENEX
Contact Mission & Vision Code of conduct UK Modern Slavery Act Privacy notice
We care about your data, and we'd love to use cookies to make your experience better and to analyse your use of our site to evaluate and improve site performance. Find out more by reading our Privacy Notice here
c No, thanks
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HANDS ELBOW FACE SPACE HOME X Wash often Cough into Don't touch Avoid crowds Stay inside
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM 5/12/20, 4:16 PM
Rogue Palm Oil Supplier Suspended by Major Brands Over Deforestation Concerns
Liviya James
Notorious tycoon-owned timber and palm oil conglomerate Samling scrambles to adopt sham "No Deforestation" policy to keep customers while continuing to destroy rainforests
Some of the world's largest consumer goods brands and their palm oil suppliers have suspended one of Malaysia's most notorious timber and palm oil conglomerates, Samling Group, due to its relentless deforestation. To date, major consumer brands including Unilever, Mars, and Hershey - as well as palm oil traders including ADM, Bunge, Cargill, IOI, KLK, Louis Dreyfus, Sime Darby, Fuji Oil, and Wilmar (the world's largest palm oil trader) - have suspended Samling from their supply chains.
As part of its Rapid Response deforestation monitoring program. Mighty Earth has documented at least 886 hectares of deforestation during the period September 201 8- March 2020 in Samling's timber plantation concessions in Sarawak, Malaysia.
Samling's palm oil operations cover around 40,000 hectares in Malaysia and Indonesia, whereas its industrial tree plantation licences in Sarawak cover over 200,000 hectares, an area over five times the size of Singapore.
"Unilever, Mars, Hershey and others have acted swiftly by instructing their palm oil suppliers to impose a procurement suspension of Samling for its global supply chain. Samling has responded to these suspensions with a desperate bid to keep its remaining palm oil customers - not by halting all its forest clearance, but by holding up a shiny policy with one hand to distract its customers while continuing deforestation with the other hand," said Mighty Earth Senior Campaign Director Deborah Lapidus.
A Samling-owned palm oil company - Glenealy Plantations - has declared a moratorium on further oil palm development and issued a no-deforestation policy. However, the new policy fails to stop Samling's largest source of ongoing deforestation - its continued expansion of monoculture timber plantations. In addition, Glenealy's oil palm land bank is mostly developed already, making the impact of the new policy minimal.
Palm oil trader Sime Darby informed Mighty Earth that: "We would like to confirm that we have notified Samling that we will no longer be sourcing from them due to concerns raised by our key customers. Central to these concerns is the adoption of NDPE [No Deforestation, No Peat, and
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No Exploitation] commitments across the whole Sam ling Group, and not just for Glenealy Plantations." Fuji Oil, another palm oil trader, has also suspended Samling on the basis that its continued deforestation is not aligned with Fuji Oil's Palm Oil Sourcing Policy and group-level association.
Publicly available mill sourcing lists and other data indicate that companies including BLD Plantations (KTS Group), Sarawak Oil Palms (Shin Yang Group), Nestle, Mondelez, and PepsiCo have yet to take action to exclude Samling from their supply chains, despite having No Deforestation policies.
"In our outreach to Samling's palm oil buyers, many stated that they didn't need to take action because Samling's deforestation was for timber, not palm oil. But a rainforest being destroyed for timber plantations is just as bad as a rainforest being destroyed for palm oil, and the profits are going to the same shareholders of the Samling group. There is no excuse for a company with a No Deforestation policy to be buying from rogue deforesters like Samling, plain and simple," said Lapidus.
Founded by Datuk Yaw Teck Seng over 50 years ago, the Samling Group has a long track record of forest destruction and violations of the rights of indigenous peoples. In 201 7, a coalition of Burmese civil society groups published a report detailing land grabbing, indigenous rights violations, and environmental problems in Samling's palm oil operations in Myanmar. Findings included Samling's role in the pollution of local water sources and clear-cutting of forests inside a proposed national park that is home to endangered tigers. A February 2020 article by The Sarawak Report, a NGO run by a British investigative journalist, alleges that a Samling-related company in Papua New Guinea has failed to "pay four indigenous groups nearly USD$100 million in compensation for large-scale illegal logging, environmental destruction and serious human rights abuses related to the Kiunga - Aiambak road project inPapua New Guinea." This finding is based on a 201 1 Papua New Guinea court judgment. A 2002 Greenpeace International report on this 'road project' ('Partners in Crime') described it as an unlawful, destructive ploy to open up new areas of rainforest for logging.
LIVIYA JAMES I Senior Associate I miqhtyearth.org T+1-949-246-9808 [email protected] Follow Us: Facebook I Twitter I Linkedin
The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’ work on forest conservation is funded in part by the European Federation for Transport and Environment, the Center for International Policy, and AidEnvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.
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Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM 5/12/20, 4:17 PM
PT Arjuna Utama Sawit case Rapid Response
|) 2 attachments (2 MB) Rapid Response Report 23_final_b.pdf; Tableware Incorporated Pte Ltd.pdf;
Dear Ben,
We note from Bunge’s grievance log regarding the PT Arjuna Utama Sawit case:
“Feb-20: the Bunge team engaged with its trade-and intel partner and received the confirmation PT AUS is not connected to Borneo Pacific nor to Pactra Group, but to Tableware. ”
Tableware Incorporated Pte Ltd is a Borneo Pacific related company. Please find attached the corporate profile of Tableware Incorporated Pte Ltd., which shows that Alexander Thaslim, the Indonesian businessman that controls Borneo Pacific, owns 50% of the shares in Tableware Incorporated Pte Ltd. Further details of the ownership can be found in Rapid Response report 23 (attached).
Please update your grievance log and engage with your supplier (Borneo Pacific) to address this case accordingly.
We encourage Bunge to conduct its own due diligence on the group ownership of its suppliers’ holdings and not simply take the information provided by your suppliers at face value.
Best,
SARAH BRICKMAN I SENIOR ASSOCIATE I miahtvearth.org [email protected] Follow us: -acebook I Twitter
The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’ work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.
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Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
MIGHTY EARTH
Rapid Response Palm Oil, Report 23
ew
January 2020
Prepared with support from MapHubs
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Table of Contents Cases identified using Planet imagery
Indonesian Companies BEST Group: PT Menara Tunggal Perkasa 5 Borneo Pacific Group: PT Arjuna Utama Sawit 8 Bumitama Group: PT Andalan Sukses Makmur 11 Incasi Raya Group: PT Makmur Agro Lestari 14 NPC Resources Bhd: PT Sumber Alam Selaras 17 Puncak Niaga Holdings Bhd: Danum Sinar Sdn Bhd 20 Union Sampoerna Triputra Persada: PT Harapan Hibrida Kalbar 23
Additional cases identified using filtered GLAD alerts New Cases Unknown Group: PT Mundam Sijunjung Sakti Plantation 26 Unknown Group: PT Khaleda Prima Mandiri 26 Murad family: PT Kurnia Luwuk Sejati (Morowali Utara) 26 Murad family: PT Kurnia Luwuk Sejati (Banggai) 26 Kayu Lapis Group: PT Inti Kebun Sejahtera (Block II) 26 IMC Plantations: PT Perkebunan Inti Sendawar 26 Julong Group: PT Sanjung Makmur (Bulungan) 26 Julong Group: PT Sanjung Makmur (Tana Tidung) 27
Repeat Cases Unknown Group: PT Citrapermata Serundung 28 Green Yield Pte Ltd: PTTri Investama 28 HSA Group: PT Megakarya Jaya Raya 28 Bumitama Group: PT Damai Agro Sejahtera 28 Unknown Group: PT Gapura Alas Lestari 28 Unknown Group: PT Surya Buana Bersama 28 Salim/Indogunta: PT Rimbun Sawit Papua 28 Unknown Group: Koperasi Usaha Mandiri 28 Makin Group: PT Mekar Karya Kahuripan 28 Unknown Group: PT Barito Riau Jaya 28 Unknown Group: PTTriomas Fdi 28
Sources for supply chain information: Supply chain information included in Rapid Response reports is based on the latest public versions of mill disclosures, recent export data and grievance logs. Mighty Earth encourages companies to send updated versions of mill disclosures as soon as they become available and to share any decision to suspend relations with a given group/company listed in those mill disclosures; please send to [email protected].
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Table of Contents (cont.)
Additional Cases Identified Using Filtered GLAD Alerts Repeat Cases (continued) Indonusa Group: PT Internusa Jaya Sejahtera 28 Widya Corporation: PT Mulia Inti Perkasa 28 Mulia Sawit Group: PT Persada Era Agro Kencana 29 Dharma Satya Nusantara: PT Putra Utama Lestari 29 Unknown Group: PT Katingan Hijau Lestari 29 Agro Sarimas Group: PT Agro Sarimas Indonesia 29 Unknown Group: Koperasi Bakung Agri 29 Genting Plantations: PT Permata Sawit Mandiri 29 Unknown Group: PT Ichiko Agro Lestari 29 Cilandry Anky Abadi Group: PT Citra Agro Abadi 29 Unknown Group: PT Laot Bangko 29 Anglo-Eastern Plantations: PT Kahayan Agro Plantation 29 Mitra Jaya Group: PT Sumber Sawit Mitrajaya 29 Goodhope: PT Rim Capital 29 Makin Group: PT Krida Dharma Kahurpian 29 Unknown Group: PT Gapura Alas Lestari 30 Unknown Group: PTTani Subur Makmur 30 Unknown Group: PT Sentosa Kalimantan Jaya 30 Triputra Agro Persada Group: PT Gawi Bahandep Sawit Mekar 30 Unknown Group: PT Cipta Karya Sesayap 30 Felda Global Ventures: PT Citra Niaga Perkasa 30 Makin Group: PT Cipta Karsa Kahuripan 30 Bukit Berlian Plantation Group: PT Ginang Fohu Plantation 30 Dhanistha Surya Nusantara: PT Sabhantara Rawi Sentosa 30 Kalimantan Sawit Kusama: PT Fajar Saudara Lestari 30 Genting Plantations: PT Citra Sawit Cemerlang 30 Unknown Group: PT Kayan Plantation 30 Shanghai Xinjiu Chemical Co Ltd: PT Sebaung Sawit Plantation (Smallholder) 30 Salim/Indogunta: PT Rimbun Sawit Papua 30 Eagle High Plantations Tbk: PT Arrtu Energie Resources 31 Salim/Indogunta: PT Rimbun Sawit Papua 31 Hangzhou Jinjiang Group: PT Putra Sari Lestari 31 Alas Kusuma Group: PT Kusuma Alam Sari 31 Incasi Raya Group: PT Arvenasepakat 31
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Table of Contents (cont.)
Additional Cases Identified Using Filtered GLAD Alerts Repeat Cases (continued) Dharma Satya Nusantara: PT Putra Utama Lestari 31 TSH Resources Bhd: PT Bulungan Citra Agro Persada 31 Henan Jiujiu Chemical Co Ltd: PT Palem Segar Lestari (Smallholder) 31 Pipit Group: PT Nunukan Bara Sukses 31 CB Industrial Product Holding: PT Jaya Jadi Utama 31 Bumitama Group: PT Damai Agro Sejahtera 31 Kirana Megatara: PT Putra Katingan Pratama 31 Unknown: PT Ruta Jona Lestari 31 Samling Group: LPF/0007 Samiing Jelalong (OP) 32 Samling Group: LPF/0007 Jelalong OP (Glenealy) Part 3 32 Samling Group: LPF/0007 Jelalong OP (Glenealy) Part 1 32 Rimbunan Hijau: Rimbunan Sawit Bhd 32 Puncak Niaga Sdn Bhd: Danun Sinar Sdn Bhd 32 Shin Yang: Dataran Linau OP (SY) (Lot 1 Block 14 Murum LD) 32 Unknown Group: Formerly Ekran Plantation 32 TH Plantations Bhd: Hydroflow 32 Yuwang: OT/0351 Empresa (M) SB 32 Samling Group: LPF/0006 Samling Lana 32
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: BEST Group PT Menara Tunggal Perkasa Concession location: (-1.992, 113.518)
Deforestation and/or peat development
Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) August 22- December Report 23 102 24, 2019 Satellite imagery (see below) shows that between August 22, 2019 and December 24, 2019 a total of 102 hectares of forest were cleared in the PT Menara Tunggal Perkasa concession. (Imagery © 2019 Planet Labs Inc.)
PT Menara Tunggal £ Kt Vietnam £ Perkasa Philippines
Malaysia
IfKonesia
Mr
W c
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Alert Imagery (before and after satellite images) Clearance location: (-2.103, 113.52)
Date: August 22, 2019 Date: December 24, 2019
Date: August 22, 2019 Date: December 24, 2019 Clearance location: (-1.957, 113.492)
its
A
&
Ownership Information PT Menara Tunggal Perkasa is part of the BEST Group.1 1
1. Notary Act for PT Menara Tunggal Perkasa.
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Supply Chain Information
Supply Chain Links: Traders Felda IFFCO Louis Dreyfus
PT Menara Tunggal Perkasa
BEST Group
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: Borneo Pacific Group PT Arjuna Utama Sawit Concession location: (-2.357, 113.375)
Deforestation and/or peat development
Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) September 2 - Report 23 70 39 December 24, 2019 Satellite imagery (see below) shows that between September 2, 2019 and December 24, 2019 a total of 70 hectares of forest were cleared and 39 hectares were prepared for clearance in the PT Arjuna Utama Sawit concession. (Imagery © 2019 Planet Labs Inc.)
Vietnam Hak Guna Usaha Philippi
Malaysia X Indonesia
Vi
,113.4
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Alert Imagery (before and after satellite images) Clearance location: (-2.357, 113.375)
Date: September 2, 2019 Date: December 24, 2019
'A
Ownership Information PT Arjuna Utama Sawit is part of Borneo Pacific Group,2 which is controlled by Indonesian businessman Alexander Thaslim.3
Borneo Pacific Group owns PT Arjuna Utama Sawit through Premier Palmoil Energy Pte Ltd (63.3%), which is in turn wholly owned by Tableware Incorporated Pte Ltd, and which is owned by Alexander Thaslim (50%) and Chan Lucille Caroline (50%).4
2. Notary Act for PT Arjuna Utama Sawit 3. https://bit.ly/3crPDz4 4. Notary Act for PT Arjuna Utama Sawit; Company profiles for Premier Palmoil Energy Pte Ltd and Tableware Incorporated Pte Ltd Notary Act for pt Arjuna 4
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Supply Chain Information
Supply Chain ADM Bunge Fuji Oil Itochu Links: Traders
PT Arjuna Utama Sawit
Borneo Pacific Group
Supply Chain Sime Mewah Musim Mas Olam Wilmar Links: Traders Darby
PT Arjuna Utama Sawit
Borneo Pacific Group
Supply Chain Links: Colgate- Friesland Avon General Mills Hershey Consumer Brands Palmolive Campina
PT Arjuna Utama Sawit
Borneo Pacific Group
Supply Chain Links: Johnson & Kellogg's Mars Mondelez Neste Oil Consumer Brands Johnson
PT Arjuna Utama Sawit
Borneo Pacific Group
Supply Chain Links: Reckitt Nestle PepsiCo PZ Cussons Unilever Consumer Brands Benckiser
PT Arjuna Utama Sawit
Borneo Pacific Group
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: Bumitama Group PT Andalan Sukses Makmur Concession location: (-2.791, 111.824)
Deforestation and/or peat development
Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) September 4 - Report 23 129 December 24, 2019 Satellite imagery (see below) shows that between September 4, 2019 and December 24, 2019 a total of 129 hectares of forest were cleared in the PT Andalan Sukses Makmur concession. (Imagery © 2019 Planet Labs Inc.)
PT Andalan Sukses Philippines Makmur
Malaysia
Indonesia
i .
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Alert Imagery (before and after satellite images) Clearance location: (-2.774, 111.881)
Date: September 4, 2019 Date: December 24, 2019
Date: September 4, 2019 Date: December 24, 2019 Clearance location: (-2.711, 111.888)
Ownership Information
PT Andalan Sukses Makmur is part of the Bumitama Group.6
6. Bumitama Agri Ltd, 2018 annual report, http://ir.bumitama-agri.com/static-files/2e0c8a3e-f0fc-4b78-838f-e043b6543237
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Supply Chain Information
Supply Chain ADM Apical Bunge Cargill Fuji Oil GAR Links: Traders
PT Andalan Sukses Makmur
Bumitama Group
Supply Chain Musim PIL (via Sime Itochu Olam Wilmar Links: Traders Mas ICOF) Darby
PT Andalan Sukses Makmur
Bumitama Group
Supply Chain Links: Colgate- Friesland Avon General Mills Hershey Consumer Brands Palmolive Campina
PT Andalan Sukses Makmur
Bumitama Group
Supply Chain Links: Johnson & Kellogg's Mars Mondelez Neste Oil Consumer Brands Johnson
PT Andalan Sukses Makmur
Bumitama Group
Supply Chain Links: PZ Reckitt Nestle PepsiCo Unilever Consumer Brands Cussons Benckiser
PT Andalan Sukses Makmur
Bumitama Group
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: Incasi Raya Group PT Makmur Agro Lestari Concession location: (-0.964, 115.272)
Deforestation and/or peat development
Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) August 30 - Report 23 61 December 4, 2019 Satellite imagery (see below) shows that between August 30, 2019 and December 4, 2019 a total of 61 hectares of forest were cleared in the PT Makmur Agro Lestari concession. (Imagery © 2019 Planet Labs Inc.)
PT Makmur Agro £ Vietnam £ Lestari Philippines
Malaysia
InC&nesia
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Alert Imagery (before and after satellite images) Clearance location: (-0.948, 115.276)
Date: August 30, 2019 Date: December 4, 2019
Ownership Information PT Makmur Agro Lestari is part of the Incasi Raya Group, which is owned by the Gunawan family.7
7. Notary Act for PT Makmur Agro Lestari
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Supply Chain Information
Supply Chain Links: ADM Cargill Fuji Oil Itochu Traders
PT Makmur Agro Lestari
Incasi Raya Group
Supply Chain Links: Musim Mas Olam Sime Darby Wilmar Traders
PT Makmur Agro Lestari
Incasi Raya Group
Supply Chain Links: Colgate- Friesland Avon General Mills Hershey Consumer Brands Palmolive Campina
PT Makmur Agro Lestari
Incasi Raya Group
Supply Chain Links: Johnson & Kellogg's Mars Mondelez Neste Oil Consumer Brands Johnson
PT Makmur Agro Lestari
Incasi Raya Group
Supply Chain Links: PZ Reckitt Nestle PepsiCo Unilever Consumer Brands Cussons Benckiser
PT Makmur Agro Lestari
Incasi Raya Group
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Group: NPC Resources Bhd PT Sumber Alam Selaras Concession location: (0.203, 116.627)
Deforestation and/or peat development
Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) September 2 - Report 23 1047 November 27, 2019 Satellite imagery (see below) shows that between September 2, 2019 and November 27, 2019 a total of 1047 hectares of forest were cleared in the PT Sumber Alam Selaras concession. (Imagery © 2019 Planet Labs Inc.).
I PT Sumber Alam Selaras Vietnam PT Sumber Alam Selaras Philippines Base Map - C Mapco> lalaysia
Indonesia
V
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Alert Imagery (before and after satellite images) Clearance location: (0.233, 116.594)
Date: September 2, 2019 Date: November 27, 2019
Ownership Information PT Sumber Alam Selaras is part of NPC Resources Bhd.8
8. NPC Resources Bhd group structure, December 2018. www.npc.com.my/Group%20Structure_31%2012%202018.pdf
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information
Supply Chain Links: ADM Cargill Fuji Oil Traders
PT Sumber Alam Selaras
NPC Resources
Supply Chain Links: Itochu Mewah Olam Wilmar Traders
PT Sumber Alam Selaras
NPC Resources
Supply Chain Links: Colgate- Friesland Avon General Mills Hershey Consumer Brands Palmolive Campina
PT Sumber Alam Selaras
NPC Resources
Supply Chain Links: Johnson & Louis Kellogg's Mars Consumer Brands Johnson Dreyfus
PT Sumber Alam Selaras
NPC Resources
Supply Chain Links: PZ Reckitt Neste Oil PepsiCo Unilever Consumer Brands Cussons Benckiser
PT Sumber Alam Selaras
NPC Resources
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: Puncak Niaga Holdings Bhd Danum Sinar Sdn Bhd Concession location: (2.672, 114.758)
Deforestation and/or peat development
Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) March 25 - Report 23 283 720 December 25, 2019 Satellite imagery (see below) shows that between March 25, 2019 and December 25, 2019 a total of 283 hectares of forest were cleared and 720 hectares were prepared for clearance in the Danum Sinar Sdn Bhd concession. (Imagery © 2019 Planet Labs Inc.)
ma) Danum Java SB (Danum Sinar OPP) Q. IV Danum Java SB (Danum Sinar Vietnam I Philippines
Malaysia jf*
Indonesia
113.9
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Alert Imagery (before and after satellite images) Clearance location: (2.814, 114.587)
Date: April 9, 2019 Date: December 25, 2019
ft Sk
%
Date: March 25, 2019 Date: November 27, 2019 Clearance location: (2.668, 114.741)
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Ownership Information Danum Sinar Sdn Bhd is part of Puncak Niaga Holdings Bhd (Puncak Niaga Group).9
9. Corporate profiles for Danum Sinar Sdn Bhd and its shareholders. Companies Commission Malaysia.
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Supply Chain Information
Supply Chain Links: Traders Sarawak Oil Palms (SOP)
Danum Sinar Sdn Bhd
Puncak Niaga Holdings Bhd
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: PT Union Sampoerna Triputra Persada PT Harapan Hibrida Kalbar Concession location: (-2.504, 111.083)
Deforestation and/or peat development
Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines (ha) August 6 - Report 23 42 December 24, 2019
Satellite imagery (see below) shows that between August 6, 2019 and December 24, 2019 a total of 42 hectares of forest were cleared in the PT Harapan Hibrida Kalbar concession. (Imagery © 2019 Planet Labs Inc.)
Vietnam PT Harapan Hibrida * Kalbar Philipp PT Harapan Hibrida Kalbar
Map -Bum Maps (31 Dec 2014 0
Malaysia
Indonesia
XiL
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Alert Imagery (before and after satellite images) Clearance location: (-2.481, 111.071)
Date: August 6, 2019 Date: December 24, 2019
*
Ownership Information PT Harapan Hibrida Kalbar is part of PT Union Sampoerna Triputra Persada.10 11
11. Notary Act for PT Harapan Hibrida Kalbar. 2
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
Supply Chain Information
Supply Chain Sime ADM Olam Wilmar Links: Traders Darby
PT Harapan Hibrida Kalbar
Union Sampoerna Triputra Persada
Supply Chain Links: Colgate- Friesland Avon General Mills Hershey Consumer Brands Palmolive Campina
PT Harapan Hibrida Kalbar
Union Sampoerna Triputra Persada
Supply Chain Links: Johnson & Kellogg's Mars Mondelez Neste Oil Consumer Brands Johnson
PT Harapan Hibrida Kalbar
Union Sampoerna Triputra Persada
Supply Chain Links: Reckitt Nestle PepsiCo Unilever Consumer Brands Benckiser
PT Harapan Hibrida Kalbar
Union Sampoerna Triputra Persada
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Additional cases identified using screened GLAD alerts
The following cases have been identified through screened GLAD alerts (see methodology below). As these cases are either repeat cases from previous Rapid Response reports or where Mighty Earth did not determine any supply chain links for these concessions/Groups, no Planet image analysis was conducted for these cases to save resources.
Mighty Earth expects that palm oil traders conduct their own due diligence to determine if they are exposed to such companies/Groups. Further, traders without supply chain links to these cases should put them on their 'no buy' lists.
Methodology:
For Indonesia, GLAD alerts are screened using the Indonesia Ministry of Forestry and the Environment land cover dataset for 2017 which classifies existing palm oil plantations and primary and secondary forest. Flence, only GLAD alerts in primary and secondary forest according to that dataset are included.
For Malaysia, GLAD alerts are screened to exclude known plantation areas using the Global Forest Watch (GFW) plantations dataset. This automatically eliminates the most common false positives, i.e. the replanting of palm that existed prior to the year 2000.
New Cases
Area covered Supply by screened chain Concession/ license area Group ownership Time period GLAD alerts connection (ha) identified
November 15- None PT Mundam Sijunjung Sakti December 6, 2019 Plantation Unknown Group TOha
November 15- None December 6, 2019 PT Khaleda Prima Mandiri Unknown Group ■13ha
November 15- None PT Kurnia Luwuk Sejati (Morowali December 6, 2019 Utara)______Murad family -14ha
November 15- None December 6, 2019 PT Kurnia Luwuk Sejati (Banggai) Murad family ’15ha
November 15- None December 6, 2019 PT Inti Kebun Sejahtera (Block II) Kayu Lapis Group '27ha
November 15- None December 6, 2019 PT Perkebunan Inti Sendawar IMC Plantations '28ha
October 15- None November 14, 2019 PT Sanjung Makmur (Bulungan) Julong Group T6ha
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM
New Cases (continued)
Area covered Supply by screened chain Concession/ license area Group ownership Time period GLAD alerts connection (ha) identified
November 15- None December 6, 2019 PT Sanjung Makmur (Tana Tidung) Julong Group -44ha
Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases
Area covered Rapid Response by screened Concession license area Group/ownership Time period reports related GLAD alerts to each case* (ha)
November 15- PT Citrapermata Serundunq Unknown j20ha December 6, 2019 Report 20
November 15- PT Tri In vesta ma Green Yield Pte Ltd ■189ha December 6, 2019 Reports 20, 21, 22
November 15- PT Meqakarya Java Raya HSA Group ■162ha December 6, 2019 Report 5
November 15- PT Damai Aqro Sejahtera Bumitama Group -136ha December 6, 2019 Report 22
November 15- PT Gapura Alas Lestari Unknown -107ha December 6, 2019 Reports 16, 19, 20
November 15- PT Surya Buana Bersama Unknown ■100ha December 6, 2019 Report 22
November 15- Reports 3, 10, 13, PT Rimbun Sawit Papua Salim/Indoqunta '97ha December 6, 2019 14, 16, 17, 18, 20
November 15- Reports 17, 19, 20, November 15- PT Mekar Karya Kahuripan Makin Group '88ha December 6, 2019 Reports 17, 21, 22 November 15- PT Barito Riau Java Unknown '87ha December 6, 2019 Report 22 November 15- PT Triomas Fdi Unknown '86ha December 6, 2019 Reports 17 and 22 Reports 7, 10, 11, November 15- 12, 15, 16, 17, 20, PT Internusa Jaya Sejahtera Indonusa Group '82ha December 6, 2019 22 November 15- Reports 6, 15, 16, PT Mulia Inti Perkasa VVidya Corporation '74ha December 6, 2019 20, 21, 22______ *Rapid Response reports available on Mighty Earth's Rapid Response website page, linked here. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases (continued) Area covered Rapid Response by screened Concession license area Group/ownership Time period reports related GLAD alerts to each case* (ha) Reports 9, 10, 11, November 15- 12, 15, 16, 17, 18, PT Persada Era Aqro Kencana Mulia Sawit Group '64ha December 6, 2019 19, 20, 22______ November 15- PT Putra Utama Lestari Pharma Satya Nusantara '61ha December 6, 2019 Report 20 November 15- PT Katinqan Hijau Lestari Unknown '56ha December 6, 2019 Reports 17 and 19 November 15- PT Aqro Sarimas Indonesia Aqro Sarimas Group '53ha December 6, 2019 Report 22 November 15- Coperasi Bakunq Aqri Unknown '51ha December 6, 2019 Report 22 November 15- Reports 15, 16, 17, PT Permata Sawit Mandiri Gentinq Plantations '50ha December 6, 2019 19, 20______ November 15- Reports 14, 16, 17, PT Ichiko Aqro Lestari Unknown '48ha December 6, 2019 19, 20, 21 Cilandry Anky Abadi November 15- PT Citra Aqro Abadi Group______'46ha December 6, 2019 Report 17 November 15- PT Laot Banqko Unknown '44ha December 6, 2019 Reports 16 and 17 Anglo-Eastern November 15- Reports 1, 14, 15, PT Kahayan Aqro Plantation Plantations '37ha December 6, 2019 18, 19, 20______ November 15- PT Sumber Sawit Mitrajaya Mitra Java Group 32ha December 6, 2019 Reports 15 and 17 November 15- PT Rim Capital Goodhope '27ha December 6, 2019 Report 22 November 15- Reports 5, 6, 11, PT Krida Pharma Kahurpian Makin Group '26ha December 6, 2019 12, 16, 17, 19, 22 *Rapid Response reports are available on Mighty Earth's Rapid Response website page, linked here. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases (continued) Area covered Rapid Response by screened Concession license area Group/ownership Time period reports related GLAD alerts to each case* (ha) November 15- PT Gapura Alas Lestari Unknown '26ha December 6, 2019 Reports 16, 19, 20 November 15- PT Tani Subur Makmur Unknown '22ha December 6, 2019 Report 17 November 15- PT Sentosa Kalimantan Java Unknown '21ha December 6, 2019 Peport 21 friputra Agro Persada November 15- PT Gawi Bahandep Sawit Mekar Group______'21ha December 6, 2019 Peport 21 November 15- PT Cipta Karya Sesayap Unknown '20ha December 6, 2019 Reports 17 and 22 November 15- PT Citra Niaqa Perkasa Felda Global Ventures -19ha December 6, 2019 Peport 20 November 15- PT Cipta Karsa Kahuripan Makin Group 49ha December 6, 2019 Reports 21 and 22 Bukit Berlian Plantation November 15- PT Ginanq Fohu Plantation jroup______-18ha December 6, 2019 Peport 17 Dhanistha Surya November 15- PT Sabhantara Rawi Sentosa Nusantara -17ha December 6, 2019 Peport 21 Kalimantan Sawit November 15- PT Fajar Saudara Lestari Kusama -16ha December 6, 2019 Peport 22 November 15- Reports 14, 15, 16, PT Citra Sawit Cemerlanq Gentinq Plantations 44ha December 6, 2019 17, 19 November 15- Reports 15, 16, 17, PT Kayan Plantation Unknown -14ha December 6, 2019 18, 20, 21, 22 PT Sebaung Sawit Plantation Shanghai Xinjiu Chemical November 15- Reports 8, 12, 13, (Smallholder)______Co Ltd -13ha December 6, 2019 16, 20, 21, 22 November 15- Reports 3, 10, 13, PT Rimbun Sawit Papua alim/Indoqunta 43ha December 6, 2019 14, 16, 17, 18, 20 *Rapid Response reports are available on Mighty Earth's Rapid Response website page, linked here. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases (continued) Area covered Rapid Response by screened Concession license area Group/ownership Time period reports related GLAD alerts to each case* (ha) Eagle High Plantations November 15- PT Arrtu Enerqie Resources Tbk -12ha December 6, 2019 Peport 22 November 15- Reports 3, 10, 13, PT Rimbun Sawit Papua >alim/Indoqunta 42ha December 6, 2019 14, 16, 17, 18, 20 November 15- PT Putra Sari Lestari Hangzhou Jinjianq Group -llha December 6, 2019 Peport 22 November 15- PT Kusuma Alam Sari Alas Kusuma Group 'llha December 6, 2019 Reports 7 and 17 November 15- PT Arvenasepakat Incasi Raya Group -llha December 6, 2019 Peport 17 November 15- PT Putra Utama Lestari Pharma Satya Nusantara 'llha December 6, 2019 Peport 20 November 15- PT Bulunqan Citra Aqro Persada TSH Resources Bhd -llha December 6, 2019 Peport 21 PT Palem Segar Lestari Henan Jiujiu Chemical Co November 15- Reports 5, 7, 12, (Smallholder)______Ltd -llha December 6, 2019 16, 18, 20, 21, 22 November 15- PT Nunukan Bara Sukses Pipit Group 'llha December 6, 2019 Peport 20 CB Industrial Product November 15- PT Java Jadi Utama Holding______'llha December 6, 2019 Peports 15 and 20 November 15- PT Damai Aqro Sejahtera Bumitama Group '10ha December 6, 2019 Peport 22 November 15- PT Putra Katinqan Pratama Kirana Meqatara '10ha December 6, 2019 Peport 17 November 15- PT Ruta Jona Lestari Unknown -lOha December 6, 2019 Peports 17 and 22 *Rapid Response reports are available on Mighty Earth's Rapid Response website page, linked here. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases (continued) Area covered Rapid Response by screened Concession license area Group/ownership Time period reports related GLAD alerts to each case* (ha) November 15- Reports 15, 16, 18, LPF/0007 Samlinq Jelalonq (OP) Samlinq Group 431 ha December 6, 2019 19, 20, 21______ LPF/0007 Jelalong OP (Glenealy) November 15- Reports 18, 19, 20, Part 3 Samlinq Group '59 ha December 6, 2019 21 LPF/0007 Jelalong OP (Glenealy) November 15- Reports 18, 19, 20, Part 1 Samlinq Group 49 ha December 6, 2019 21 November 15- Rimbunan Sawit Bhd Rimbunan Hijau '9 ha December 6, 2019 Report 21 November 15- Danun Sinar Sdn Bhd Puncak Niaqa Sdn Bhd '7 ha December 6, 2019 Report 21 Dataran Linau OP (SY) (Lot 1 Block November 15- Reports 17, 18, 19, 14 Murum LD) Shin Yang '7 ha December 6, 2019 20, 21______ November 15- Formerly Ekran Plantation Unknown Group '7 ha December 6, 2019 Reports 19, 20, 21 November 15- Hydroflow TH Plantations Bhd '7 ha December 6, 2019 Report 14 November 15- QT/0351 Empresa (M) SB Yuwanq '7 ha December 6, 2019 Reports 17 and 18 November 15- Reports 16, 18, 19, LPF/0006 Samlinq Lana Samlinq Group '6 ha December 6, 2019 20 *Rapid Response reports are available on Mighty Earth's Rapid Response website page, linked here. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM EVERY ENDEAVOR IS MADE TO ENSURE THAT INFORMATION PROVIDED IS UPDATED AND CORRECT. THE AUTh MS ANY LIABILITY FOR ANY DAMAGE OR LOSS THAT MAY BE CAUSED AS A RESULT OF ANY ERROR OR OMISS ss Profile (Company) of TABLEWARE INCORPORATED PTE LTD Date: 06, I868G) wing Are The Brief Particulars of: ion No. 199403868G / Name. TABLEWARE INCORPORATED PTE LTD (w.e.f. 13/12/2000) Jame if any SUMMEDIA.COM SINGAPORE PTE LTD ation Date. 01/06/1994 /Type EXEMPT PRIVATE COMPANY LIMITED BY SHARES Live Company ate 01/06/1994 I Activities (I) OTHER HOLDING COMPANIES (64202) on INVESTMENT HOLDING COMPANY (ID WHOLESALE TRADE OF A VARIETY OF GOODS WITHOUT A DOMINANT PRODUC (46900) on GENERAL TRADING Capital lumber of Shares Share Type SINGAPORE, DOLLARS ORDINARY of Shares includes number of Treasury Shares Capital Number of Shares rrency Share Type IT) SINGAPORE, DOLLARS ORDINARY IY HAS THE FOLLOWING ORDINARY SHARES HELD AS TREASURY SHARES Of Shares Currency Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM EVERY ENDEAVOR IS MADE TO ENSURE THAT INFORMATION PROVIDED IS UPDATED AND CORRECT. THE AUTh MS ANY LIABILITY FOR ANY DAMAGE OR LOSS THAT MAY BE CAUSED AS A RESULT OF ANY ERROR OR OMISS ss Profile (Company) of TABLEWARE INCORPORATED PTE LTD Date: 06, I868G) d Office Address 101 UPPER CROSS STREET #04-43 PEOPLE'S PARK CENTRE SINGAPORE (058357) ddress 29/01/2019 ast AGM 29/08/2019 ast AR 26/09/2019 ^ Date of Last AR 31/12/2018 ■ Date Registered Currency Amount Secured Chargee(s) »ed Representative(s) Nationality Source of Date of Appoii Address Position Held vIDER THASLIMX216544 INDONESIAN ACRA 09/12/2017 i SERANGOON CENTRAL DRIVE #03-277 Director SINGAPORE UCILLE CAROLINE S1611549E SINGAPORE CITIZEN OSCARS 30/09/2002 LY PLACE Director OCK PARK ’ORE (267201) /I THASLIM X138492 INDONESIAN ACRA 09/12/2017 j SERANGOON CENTRAL DRIVE #03-277 Director SINGAPORE EE HWA S1437147H SINGAPORE CITIZEN ACRA 01/11/2003 HAN STREET 23 Secretary ’ORE (570224) Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM EVERY ENDEAVOR IS MADE TO ENSURE THAT INFORMATION PROVIDED IS UPDATED AND CORRECT. THE AUTh MS ANY LIABILITY FOR ANY DAMAGE OR LOSS THAT MAY BE CAUSED AS A RESULT OF ANY ERROR OR OMISS ss Profile (Company) of TABLEWARE INCORPORATED PTE LTD Date: 06, I868G) lder(s) Nationality/Place of Source of Address Char incorporation/Origin Address DHAN LUCILLE CAROLINE S1611549E SINGAPORE CITIZEN OSCARS 15/07/2019 A NAMLY PLACE SHAMROCK PARK SINGAPORE (267201) winary(Number) SINGAPORE, DOLLARS \LEXANDER THASLIM X216544 INDONESIAN ACRA 30/04/2019 3LK 265 SERANGOON CENTRAL DRIVE #03-277 >50265 SINGAPORE dinary(Number) jrrency SINGAPORE, DOLLARS * il tion il Entity not registered with ACRA ign Entity not registered with ACRA jal Return inual General Meeting ncial Statements ancial Year End - One Stop Change of Address Reporting Service by Immigration & Checkpoint Authority. rmation contained in this Business Profile is extracted from lodgements filed by this entity with ACRA. of officers for this entity is available for online authentication within 30 days from the date of purchase of this Business Profile. Pie )de available on the last page of this profile to access the authentication page. For more information, please visit www.acra.gov.si Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM EVERY ENDEAVOR IS MADE TO ENSURE THAT INFORMATION PROVIDED IS UPDATED AND CORRECT. THE AUTh MS ANY LIABILITY FOR ANY DAMAGE OR LOSS THAT MAY BE CAUSED AS A RESULT OF ANY ERROR OR OMISS ss Profile (Company) of TABLEWARE INCORPORATED PTE LTD Date: 06> I868G) 3ISTRAR OF COMPANIES AND BUSINESS NAMES )RE 'NO. : ACRA200506164418 : 06/05/2020 mputer generated. Hence no signature required. s Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM 5/12/20, 4:18 PM Rapid Response report 27 + introducing new colleague Sarah Brickman | 1 attachments (3 MB) Rapid Response Report 27_final_v2.pdf; Dear JP, First, I’d like to introduce you to Asha Sharma who is joining us as the new Rapid Response program director. Asha recently completed a master’s in International Agricultural Development at UC Davis and previously worked for the Union of Concerned Scientists tropical forests program. My last day with Mighty Earth is this Friday, May 15, and Asha will be taking over all of my responsibilities. We’re excited to welcome her to the team! Next, please find below the email that we recently sent to NDPE palm oil traders regarding Mighty Earth'sRapid Response report 27. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia. Unfortunately, all of these traders are not taking the necessary action to address Rapid Response cases and are not updating their grievance logs in a timely fashion. Since Hershey has its own grievance mechanism, we kindly request that you formally lodge the relevant cases from this report as grievances. Please confirm by email that this action will be taken. Thank you! ********** Today, we are releasing Mighty Earth's Rapid Response report 27. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia (listed by Group, if known, then by concession name): The following are new cases of deforestation and/or peatland development (in order of appearance in report 27) with known supply chain links: Fangiono family companies: PT Agrindo Green Lestari The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 27) with known supply chain links: QL Resources Bhd: PT Pipit Mutiara Indah Wings Agro Group: PT Indopenta Sejahtera Abadi Samling: PT Tunas Borneo Plantations https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgw...QtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQACZcYr0yYEOLoWmtwPUDwiA%3D Page 1 of 3 Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM 5/12/20, 4:18 PM Samling: LPF/0007 Samling Jelalong (OP) The report also includes 59 repeat cases of deforestation that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because, for the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports. Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their ‘no buy’ lists. Please confirm this action will be taken. Please see attached a copy of the Rapid Response report for full information, including GPS coordinates, satellite imagery showing recent deforestation and peat development, and what we know regarding supply chain links and company ownership. The supply chain links, which are based on mill disclosures and recent export data, are: Fangiono family companies appears to sell (directly or indirectly) to AAK, Itochu, KLK, Musim Mas, Neste, Olam, Sime Darby, and Wilmar. QL Resources Bhd appears to sell (directly or indirectly) to AAK, ADM, Cargill, ISF, Itochu, and Louis Dreyfus. Wings Agro Group appears to sell (directly or indirectly) to AAK, Cargill, Fuji Oil, and Neste. Samling Group appears to sell (directly or indirectly) to AAK, BLD Plantation Bhd, Itochu, Lipsa, Neste, Olam, and Sarawak Oil Palms Bhd. As Sarawak Oil Palms Bhd (SOPB) continues to source palm oil from the Samling Group, we request that palm oil traders that buy from SOPB ask the company to suspend the Samling Group, as many traders have already done (e.g. ADM, Bunge, Cargill, LDC, KLK, Sime Darby and Wilmar). Customers of SOPB include AAK, Cargill, KLK, Lipsa, Louis Dreyfus, Mewah, Neste and Sime Darby. As mentioned in the cover email with Rapid Response report 13 and subsequent emails, Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. Flow palm oil traders and biofuel companies address such grievances will be assessed as part of our Rapid Response Trader Tracking1 grievance performance system. Please provide us with an update on your engagement, or if your grievance tracker has been updated recently on these cases, let us know so we can review. We ask for your reply no later than May 22, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond. Thanks, and stay safe! SARAH BRICKMAN I SENIOR ASSOCIATE I miahtvearth.org [email protected] Follow us: Facebook I Twitter https://outlook.off ice.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgw...QtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQACZcYr0y YE OLoWmtwPUDwiA%3D Page 2 of 3 Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM 5/12/20, 4:18 PM The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’ work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the Department of Justice, Washington, D.C. https://outlook.off ice.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgw...QtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQACZcYr0y YE OLoWmtwPUDwiA%3D Page 3 of 3 Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM MIGHTY EARTH RAPID RESPONSE Palm Oil Report Report 27 May 2020 SHF;-.- '*•**,, * •• # . s\ ...... , • . .. * • . ••. -•••. •% '^w. f • • . * • »*• \t .*• V -4 Prepared with MapHubs Waxman Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Table of Contents Cases identified using Sentinel imagery Indonesian Companies New Case Fangiono family companies: PT Agrindo Green Lestari 5 Unresolved Cases QL Resources Bhd: PT Pipit Mutiara Indah 9 Wings Agro Group: PT Indopenta Sejahtera Abadi 13 Sanding: PT Tunas Borneo Plantations Malaysian Companies Unresolved Case Sanding: LPF/0007 Sanding Jelalong (OP) 22 Additional cases identified using filtered GLAD alerts New Cases - No Known Supply Chain Links PT Buana Pratama Cipta (formerly Provident Agro): PT Banyan Tumbuh Lestari 27 Unknown Group: PT Tualang Raya 27 Repeat Cases - Known Supply Chain Links . 28 Sepanjang Group: PT Permata Sawit Mandin 28 Widya Corporation: PT Mulia Inti Perkasa Indonusa Group: PT Internusa Jaya Sejahtera 28 NPC Resources Bhd: PT Sumber Alam Selaras 28 Mulia Sawit Group: PT Persada Era Agro Kencana ^ Dharma Satya Nusantara: PT Putra Utama Lestari 2g Capitol Group: PT Medcopapua Hijau Selaras 2g Dhanistha Surya Nusantara: PT Sabhantara Rawi Sentosa 2g Pinehill Pacific: PT Makmur Jaya Malindo 28 Global Enterprise Sdn Bhd: PT Bulungan Surya Mas Pratama 2 28 Bumitama Group: PT Damai Agro Sejahtera 28 Dharma Satya Nusantara: PT Putra Utama Lestari 29 Hayel Saeed Anam Group: PT Megakarya Jaya Raya 29 Samuel International Group: PT Bina Sarana Sawit Utama 29 Genting Plantations Bhd: PT Citra Sawit Cemerlang 29 Fangiono family companies: PT Tirta Madu Sawit Jaya 29 Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases - Known Supply Chain Links (continued) Mulia Sawit Group: PT Persada Era Agro Kencana 29 Global Enterprise Sdn Bhd: PT Bulungan Surya Mas Pratama 29 Asian Agri (RGE): PT Usalia Sawit Unggul 29 Makin Group: PT Mekar Karya Kahuripan 29 CB Industrial Product Holding: PT Jaya Jadi Utama 29 Anglo-Eastern Plantations: PT Kahayan Agro Plantation 29 Shin Yang Group: LPF/0018 Shin Yang OP Planting Area 29 KTS Holdings Sdn Bhd: BLD Plantation Bhd 29 Puncak Niaga Holdings Bhd: Danum Sinar Sdn Bhd 30 Shin Yang Group / Sarawak Oil Palms Bhd: Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum LD) 30 BBC Holdings Sdn Bhd: Almabumi Plantation Sdn Bhd 30 Rimbunan Hijau Group: Woodijaya Sdn Bhd (Lot 197) 30 Samling Group: LPF/0006 Sanding Lana 30 Shin Yang Group: Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD) 30 Woodman Group: Baram Estate, part of LPF/0004 30 Rimbunan Hijau Group: Timrest Sdn Bhd 30 TH Plantations Bhd: Hydroflow Sdn Bhd 30 Woodman Group: Adong estate, part of LPF 0004 30 Rimbunan Hijau Group: Poh Zhen Sdn Bhd 30 Repeat Cases — No Known Supply Chain Links Korompis family: PT Berau Karetindo Lestari 31 Green Yield Pte Ltd: PTTri Investama 31 Unknown Group: PT Prasetya Mitra Muda (Block II) 31 Unknown Group: PT Marita Makmur Jaya 31 Unknown Group: PT Gapura Alas Lestari 31 JSK International Co Ltd (Korea): PT Future Agropia Indonesia 31 Unknown Group: PT Citrapermata Serundung 31 IMC Plantations: PT Perkebunan Inti Sendawar 31 Supply chain information: Supply chain information included in Rapid Response reports is based on the latest public versions of mill disclosures, recent export data and grievance logs. Mighty Earth encourages companies to send updated versions of mill disclosures as soon as they become available and to share any decision to suspend relations with a given group/company listed in those mill disclosures; please send to [email protected]. Mighty Earth is now including biofuel companies in the supply chain tables of Rapid Response reports, as these companies have both direct and indirect trading relationships with groups highlighted in these reports and should be filing grievances on these cases. These biofuel companies are listed in the “Traders and Biofuel Companies” tables. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases - No Known Supply Chain Links (continued) Unknown Group: PT Cipta Karya Sesayap 31 Unknown Group: PT Sumber Sawit Mitrajaya 31 Unknown Group: PT Pipit Citra Persada 31 Shanghai Xinjiu Chemical Co Ltd: PT Sebaung Sawit Plantation 31 Unknown Group: PT Barito Riau Jaya 31 Unknown Group: PT Triomas Forestry Development Indonesia 31 Henan Jiujiu Chemical Co. Ltd: PT Palem Segar Lestari 32 Unknown Group: PT Menthobi Mitra Lestari 32 Starmas Sentosa Mandiri: PT Agrindo Sukses Sejahtera 32 Unknown Group: Telliana Enterprise Sdn Bhd 32 Unknown Group: Formerly Ekran Bhd 32 Unknown Group: Titanium Management Sdn Bhd (Part 1) 32 Unknown Group: Titanium Management Sdn Bhd (Part 2) 32 Lee Ling Timber Sdn Bhd: Limba Jaya Timber Sdn Bhd (Limbang) 32 Lee Ling Timber Sdn Bhd: LPF/0038 Limba Jaya Timber Sdn Bhd (Part 2) 32 Supply chain information: Supply chain information included in Rapid Response reports is based on the latest public versions of mill disclosures, recent export data and grievance logs. Mighty Earth encourages companies to send updated versions of mill disclosures as soon as they become available and to share any decision to suspend relations with a given group/company listed in those mill disclosures; please send to [email protected]. Mighty Earth is now including biofuel companies in the supply chain tables of Rapid Response reports, as these companies have both direct and indirect trading relationships with groups highlighted in these reports and should be tiling grievances on these cases. These biofuel companies are listed in the “Traders and Biofuel Companies” tables. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM u r=iTiTj Group: Fangiono family companies PT Agrindo Green Lestari Concession location: (-1.691, 113.874) Deforestation and/or peat development Peat Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines(ha) September 11,2019- Report 27 149 February 23, 2020 Satellite imagery (see below) shows that between September 11,2019 and February 23, 2020 a total of 149 hectares of forest were cleared in the PT Agrindo Green Lestari concession. (Imagery: Contains modified Copernicus Sentinel data 2020) Vietnam \£ PT Agrindo Green Lestari Philippines PT Agrindo Greon Lettan Malaysia lid onesia I Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Alert Imagery (before and after satellite images) Clearance location: (-1.715, 113.889) Date: September 11,2019 Date: February 23, 2020 rifl, m k. >1 Mflift'"'' Jiifi m -i- _: __ Clearance location: (-1.659, 113.867) Date: September 11,2019 Date: February 23, 2020 t «r as*.* 4. I M M A. -1.666726.113 Ownership Information PT Agrindo Green Lestari is part of the Ciliandry Anky Abadi Group (CAA),1 owned by the Fangiono family. The Fangiono family also owns Fangiono Agro Plantation (FAP). l. Notary deeds Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information Supply Chain Links: Traders and Biofuel Itochu Musim Mas Companies PT Agrindo Green Lestari Ciliandry Anky Abadi/Fangiono Agro Plantation Supply Chain Links: Traders and Biofuel Neste Olam Sime Darby Wilmar Companies PT Agrindo Green Lestari Ciliandry Anky Abadi/Fangiono X Agro Plantation Supply Chain Links: Colgate- Avon Danone FrieslandCampina Consumer Brands Palmolive PT Agrindo Green Lestari Ciliandry Anky Abadi/Fangiono Agro Plantation Supply Chain Links: Johnson & General Mills Hershey Kellogg's Consumer Brands Johnson PT Agrindo Green Lestari Ciliandry Anky Abadi/Fangiono Agro Plantation Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information (continued) Supply Chain Links: Mondelez Nestle PepsiCo Consumer Brands PT Agrindo Green Lestari Ciliandry Anky Abadi/Fangiono Agro Plantation Supply Chain Links: Reckitt Benckiser Unilever Vandemoortele Consumer Brands PT Agrindo Green Lestari Ciliandry Anky Abadi/Fangiono Agro Plantation Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: QL Resources Bhd PT Pipit Mutiara Indah Concession location: (3.349, 117.220) Deforestation and/or peat development Peat Peat forest Clearance Deforestation Report developme development prep/Stacking Time period (ha) nt(ha) (ha) lines(ha) January 3-October Report 21 50 20, 2019 December 22, 2019- Report 27 25 March 16, 2020 Satellite imagery (see below) shows that between December 22, 2019 and March 16, 2020 a total of 25 hectares of forest were cleared in the PT Pipit Mutiara Indah concession. (Imagery: Contains modified Copernicus Sentinel data 2020) a) PT Pipit Mutiara Indah q , □ □ PT Pipit Mutiara Indah Vietnam Base Map - C Bing Maps: (Si D«c 2014 OMT) 3>*i ..'7 i*/' Philippines ■ \ ■ alaysia * Indonesia * t • A . Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Alert Imagery (before and after satellite images) Clearance location: (3.388, 117.236) Date: December 22, 2019 Date: March 16, 2020 * Ownership Information PT Pipit Mirtiara Indah is part of QL Resources Bhd.2 2. QL Resources Bhd Annual Report 2019: http://ql.listedcompany.com/misc/ar2019.pdf. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information Supply Chain Louis Links: Traders AAK ADM Cargill Itochu Dreyfus and Biofuel Companies PT Pipit Mutiara Indah QL Resources Bhd Supply Chain Links: Colgate- Avon Danone FrieslandCampina Consumer Brands Palmolive PT Pipit Mutiara Indah QL Resources Bhd Supply Chain Links: General Mills Hershey Kellogg's Consumer Brands PT Pipit Mutiara Indah QL Resources Bhd Supply Chain Links: Mars Mondelez Nestle Nisshin Oillio Consumer Brands PT Pipit Mutiara Indah QL Resources Bhd Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information (continued) Supply Chain Links: Reckitt PepsiCo PZ Cussons Consumer Brands Benckiser PT Pipit Mutiara Indah QL Resources Bhd Supply Chain Links: Consumer Unilever Upfield Brands PT Pipit Mutiara Indah QL Resources Bhd Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: Wings Agro Group PT Indopenta Sejahtera Abadi Concession location: (-2.110, 114.952) Deforestation and/or peat development Peat Peat forest Clearance Deforestation Report developme development prep/Stacking Time period (ha) nt(ha) (ha) lines(ha) May 12-August 21, Report 19 54 2019 August 15- Report 20 43 (GLAD alerts) aeptember 15,2019 September 16- Report 21 12 (GLAD alerts) October 15, 2019 October 11,2019- Report 27 11 Ma 'H 02i Satellite imagery (see below) shows that between October 11,2019 and March 18, 2020 a total of 11 hectares of forest were cleared in the PT Indopenta Sejahtera Abadi concession. (Imagery: Contains modified Copernicus Sentinel data 2020) PT Indopenta Se- £ Vietnam ^ jahtera Abadi Philippines PT Indopenta Sejahtera Abadi Malaysia Indonesia ri r 22E Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Alert Imagery (before and after satellite images) Clearance location: (-2.110, 114.952) Date: October 11,2019 Date: March 18, 2020 I Ownership Information PT Indopenta Sejahtera Abadi is part of the Wings Agro Group.3 3. Wings Agro website: www.wingsagro.com/eng/ourbusines. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information Supply Chain Links: Traders and Biofuel Cargill Fuji Oil Neste Companies PT Indopenta Sejahtera Abadi Wings Agro Group Supply Chain Links: General Mills Hershey Kellogg's Nestle Consumer Brands PT Indopenta Sejahtera Abadi Wings Agro Group Supply Chain Links: PepsiCo PZ Cussons Unilever Consumer Brands PT Indopenta Sejahtera Abadi Wings Agro Group Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: Samling PT Tunas Borneo Plantations Concession location: (2.591, 117.522) Deforestation and/or peat development Peat Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines(ha) May 3-August 3, Report 18 13 2019 February 22-April 27, Report 27 85 2020 Satellite imagery (see below) shows that between February 22, 2020 and April 27, 2020 a total of 85 hectares of forest were cleared in the PT Tunas Borneo Plantations concession. (Imagery: Contains modified Copernicus Sentinel data 2020) aj PT Tunas Borneo q , Plantations PT Tunas Borneo Plantations OwVPi Vietnam Bass Map - O Bing Maps: (31 Dac 2014 QMT) Philippines alaysia Indonesia ■ * > ip i * ’• Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Alert Imagery (before and after satellite images) Clearance location: (2.688, 117.552) Date: February 22, 2020 Date: April 27, 2020 LI L A bOUm Ownership Information PT Tunas Borneo Plantations is part of the Samling Group.4 4. www.samling.com/contact.php Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Case Notes Since February 2020, ADM, Cargill, Fuji Oil, IOI, KLK, LDC, Sime Darby and Wilmar - as well as Hershey’s, Mars, P&G, and Upfield - have all informed Mighty Earth that they have suspended Samling from their supply chains. Sime Darby informed Mighty Earth that: “We would like to confirm that we have notified Samling that we will no longer be sourcing from them due to concerns raised by our key customers. Central to these concerns is the adoption ofNDPE commitments across the whole Samling Group, and not just for Glenealy Plantations.” On 15 April 2020, Samling responded to these suspensions - not by halting all Samling group-wide deforestation, but by offering up the smallest fig leaf: Glenealy Plantations Sdn Bhd announced an NDPE policy and a memo issuing a “group-wide moratorium on any land clearing for all greenfield development on mineral soil andpeatland regardless of depth with immediate effect until further notice.’” Several traders and biodiesel companies - AAK, BLD, Neste, Olam, Sarawak Oil Palms Bhd (SOPB) - and consumer brands, including Mondelez, Nestle, and PepsiCo, have yet to take action to suspend Samling from their supply chains. Glenealy has also been circulating information to traders claiming that ‘Glenealy holds all the oil palm estates and mills’ and that the company owns 100% of the shares in Timor Enterprise Sdn Bhd (through Puncak Selasih Sdn Bhd) which owns the Jelalong, Lana and Belaja palm oil operations, Samling Plantations Sdn Bhd and other entities (see left graphic below). Based on this information, it would be assumed that the moratorium applies to all Glenealy-owned plantation areas. However, according to shareholder ownership data obtained from the Companies Commission of Malaysia, Glenealy Plantations only owns 15.31% of Timor Enterprise Sdn Bhd. The majority shareholder (84.68%) in Timor Enterprise Sdn Bhd is Lingui Developments Sdn Bhd, which is 100% owned by Samling Malaysia Incorporated, registered in the British Virgin Islands (see right graphic below). * cAtLlVll GLENEALY PLANTATIONS SDN BHD SHAREHOLDERS/MEMBERS PUNCAK SELASIH SDN BHD Marne : TIMOR ENTERPRISES SDN BHD Registration No. : 196801000390 (7998-H) TIMOR ENTERPRISES SON BHD IC/Passport/ Registration No. 196701000630 (7574-D) LINGUI DEVELOPMENTS SDN BHD 141,567 Optntion ot oB pjfm pUnteiom mo oi mk in Sibth l toitak [ttahEiUtttfcrt»n,riwi itUBBUln 199801012243 (468371-D) PUNCAK SELASIH SDN. BHD. 25.600 Sir wtk MDn - Im. kUo«(] |0i Mil - TPOM in Sibih i IPOM tnd IPOM in SirWit| low SAMLING PLANTATION SON BHD SHARIKO SON BHD RTIBANO DEVELOPMENT SON BHD OpendonefoKpHronsiie .MptM Owm* *«<»*"■>$** OR'iMofalNininSiM * OUH. tfOM in S«W* IFB trcJwM n SMnis ftwrfctpKcM FIB (Wtert ■ TfeM (AM DnpitcM •mu______ID 1B0M______ Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information Supply Chain Links: BLD Plantation Traders and Biofuel Itochu Lipsa Bhd Companies PT Tunas Borneo Plantations Samling Supply Chain Links: Traders and Biofuel Neste Olam Sarawak Oil Palms Companies PT Tunas Borneo Plantations Samling Supply Chain Links: Colgate- Avon Danone FrieslandCampina Consumer Brands Palmolive PT Tunas Borneo Plantations Samling Supply Chain Links: Johnson & General Mills Kellogg's Mondelez Consumer Brands Johnson PT Tunas Borneo Plantations Samling Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information (continued) Supply Chain Links: Nestle Nisshin Oillio PepsiCo PZ Cussons Consumer Brands PT Tunas Borneo Plantations Samling Supply Chain Links: Reckitt Benckiser Vandemoortele Consumer Brands PT Tunas Borneo Plantations Samling Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information (continued) Although SOPB published an NDPE policy in January 2019, the company has not published a mill list disclosing its suppliers and sources of palm oil. While SOPB has listed several of Mighty Earth’s Rapid Response cases on Samling in its grievance list, the company has failed to address these grievances or suspend Samling. Several traders, biofuel companies and consumers brands are sourcing palm oil originating from SOPB (see tables below). These companies should file grievances with SOPB, requesting that it acts on the Samling case and suspends them. Supply Chain Links: Traders and Biofuel Cargill Lipsa Companies Sarawak Oil Palms Supply Chain Links: Traders and Biofuel Louis Dreyfus Mewah Neste Sime Darby Companies Sarawak Oil Palms Supply Chain Links: Colgate- Friesland Johnson & Avon Hershey Consumer Brands Palmolive Campina Johnson Sarawak Oil Palms Supply Chain Links: Kellogg's Mars PepsiCo Consumer Brands Sarawak Oil Palms Supply Chain Links: PZ Reckitt Unilever Upfield Vandemoortele Consumer Brands Cussons Benckiser Sarawak Oil Palms Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Group: Samling LPF/0007 Samling Jelalong (OP) Concession location: (3.313, 113.885) Deforestation and/or peat development Peat Peat forest Clearance Deforestation Report development development prep/Stacking Time period (ha) (ha) (ha) lines(ha) June 15-July 15, Report 18 33 (via GLAD) 2019 July 15-August 15, Report 19 95 (via GLAD) 2019 August 15- Report 20 96 (via GLAD) /eptember 15, 2019 September 16- Report 21 38 (via GLAD) October 15, 2019 November 15- Report 23 131 (via GLAD) December 6, 2019 0.15 (via December 15, 2019- Report 24 GLAD) January 15, 2020 January 1 5-February Report 25 68 (via GLAD) 17, 2020 February 1 7-March Report 26 72 (via GLAD) 16, 2020 May 24, 2019-April Report 27 91 17, 2020 Satellite imagery (see below) shows that between May 24, 2019 and April 27, 2020 a total of 91 hectares of forest were cleared in the LPF/0007 Samling Jelalong (OP) concession. (Imagery: Contains modified Copernicus Sentinel data 2020) I LPF/0007 Samling Jela- * rma) I long (OP) LPF/0007 Si ii - H^a mk» Malaysia Indonesia ■< -¥ri ------' m f L. V, 4m - - y Map Hubs Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Alert Imagery (before and after satellite images) Clearance location: (3.31 7, 113.844) Date: May 24, 201 9 Date: April 17, 2020 K Ownership Information LPF/0007 Samling Jelalong (OP) is part of the Samling Group.5 Case Notes See case notes for previous Samling case (PT Tunas Borneo Plantations) on page 17. 5. www.samling.com/ Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information Supply Chain Links: BLD Plantation Traders and Biofuel Itochu Lipsa Bhd Companies LPF/0007 Samling Jelalong (OP) Samling Supply Chain Links: Traders and Biofuel Neste Olam Sarawak Oil Palms Companies LPF/0007 Samling Jelalong (OP) Samling Supply Chain Links: Colgate- Avon Danone FrieslandCampina Consumer Brands Palmolive LPF/0007 Samling Jelalong (OP) Samling Supply Chain Links: Johnson & General Mills Kellogg's Mondelez Consumer Brands Johnson LPF/0007 Samling Jelalong (OP) Samling Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information (continued) Supply Chain Links: Nestle Nisshin Oillio PepsiCo PZ Cussons Consumer Brands LPF/0007 Samling Jelalong (OP) Samling Supply Chain Links: Reckitt Benckiser Vandemoortele Consumer Brands LPF/0007 Samling Jelalong (OP) Samling Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Supply Chain Information (continued) Although SOPB published an NDPE in January 2019, the company has not published a mill list disclosing its suppliers and sources of palm oil. Although, SOPB has listed several Mighty Earth cases on Samling in its grievance list, the company have failed to address these grievances or suspend Samling. A number of traders, biofuel companies and consumers brands are sourcing palm oil originating from SOPB (see tables below). These companies should file grievances with SOPB, requesting that it acts on the Samling case and suspends them. Supply Chain Links: Traders and Biofuel Cargill Lipsa Companies Sarawak Oil Palms Supply Chain Links: Traders and Biofuel Louis Dreyfus Mewah Neste Sime Darby Companies Sarawak Oil Palms Supply Chain Links: Colgate- Friesland Johnson & Avon Hershey Consumer Brands Palmolive Campina Johnson Sarawak Oil Palms Supply Chain Links: Kellogg's Mars PepsiCo Consumer Brands Sarawak Oil Palms Supply Chain Links: PZ Reckitt Unilever Upfield Vandemoortele Consumer Brands Cussons Benckiser Sarawak Oil Palms Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM r^viuiii^iiai vaoco iu^iium^u uoiiivj ov.i cci icu vj lt\i^ aiu 10 The following cases have been identified through screened GLAD alerts (see methodology below). As these cases are either repeat cases from previous Rapid Response reports or where Mighty Earth did not determine any supply chain links for these concessions/groups, no satellite image analysis was conducted for these cases to save resources. Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to such companies/Groups and conduct their own satellite image analysis of these cases. Methodology: For Indonesia, GLAD alerts are screened using the Indonesia Ministry of Forestry and the Environment land cover dataset for 2017 which classifies existing palm oil plantations and primary and secondary forest. Hence, only GLAD alerts in primary and secondary forest according to that dataset are included. For Malaysia, GLAD alerts are screened to exclude known plantation areas using the Global Forest Watch (GFW) plantations dataset. This automatically eliminates the most common false positives, i.e. the replanting of palm that existed prior to the year 2000. New Cases - Unknown Supply Chain Links Area covered by Concession license area Group/ownership screened GLAD Time period alerts (ha) PT Buana Pratama Cipta March 16-April PT Banyan Tumbuh Lestari 14.02 (formerly Provident Agro) 15, 2020 March 16-April PTTualang Raya Unknown Group 27.32 15, 2020 Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases - Known Supply Chain Links Area Rapid covered by Response Concession license area Group/ownership screened Time period reports related GLAD alerts to each case* (ha) Cilandry Anky Abadi March 16-Apri Reports 17, 23, PT Citra Agro Abadi 160.70 Group 15, 2020 25, 26 Sepanjang Group (PT March 16-Apri Reports 15, 16, PT Permata Sawit Mandiri PSM formerly owned 484.40 15, 2020 17, 19,20,23, 24 by Genting Group) Reports 6, 15, March 16-Apri PT Mulia Inti Perkasa Widya Corporation 134.66 16,20,21,22, 15, 2020 23, 24,25,26 Reports 7, 10, March 16-Apri PT Internusa Jaya Sejahtera Indonusa Group 111.11 11, 12, 15, 16, 15, 2020 17,20, 22,23,25 March 16-Apri Reports 23, 25, PT Sumber Alam Selaras NPC Resources Bhd 101.69 15, 2020 26 Reports 9, 10, March 16-Apri 11, 12, 15, 16, PT Persada Era Agro Kencana Mulia Sawit Group 83.56 15, 2020 17, 18, 19, 20, 22,23,24,25 Dharma Satya March 16-Apri Reports 20 and PT Putra Utama Lestari 37.33 Nusantara 15, 2020 23 March 16-Apri Reports 25 and PT Medcopapua Hijau Selaras Capitol Group 35.08 15, 2020 26 Dhanistha Surya March 16-Apri Reports 21,23, PT Sabhantara Rawi Sentosa 25.79 Nusantara 15, 2020 26 March 16-Apri Reports 18 and PT Makmur Jaya Malindo Pinehill Pacific 22.30 15, 2020 19 PT Bulungan Surya Mas Global Enterprise March 16-Apri 22.19 Report 21 Pratama 2 Sdn Bhd 15, 2020 March 16-Apri Reports 22, 23, PT Damai Agro Sejahtera Bumitama Group 20.90 15, 2020 26 •Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases - Known Supply Chain Links Area Rapid covered by Response Concession license area Group/ownership screened Time period reports related GLAD alerts to each case* (ha) Dharma Satya March 16-Apri Reports 20 and PT Putra Utama Lestari 20.14 Nusantara 15, 2020 23 Hayel Saeed Anam March 16-Apri PT Megakarya Jaya Raya 19.78 Reports 5, 23, 26 Group 15, 2020 Samuel International March 16-Apri Reports 19, 20, PT Bina Sarana Sawit Utama 18.28 Group 15, 2020 24, 26 Gentinq Plantations March 16-Apri Reports 14, 15, PT Citra Sawit Cemerlang 17.65 Bhd 15, 2020 16, 17, 19, 23, 24 March 16-Apri Reports 22, 24, PTTirta Madu Sawit Jaya Fangiono family 16.38 15, 2020 25 Reports 9, 10, March 16-Apri 11, 12, 15, 16, PT Persada Era Agro Kencana Mulia Sawit Group 14.08 15, 2020 17, 18, 19, 20, 22,23,24,25 PT Bulungan Surya Mas Global Enterprise March 16-Apri 13.38 Report 21 Pratama Sdn Bhd 15, 2020 March 16-Apri Reports 17, 18, PT Usaha Sawit Unggul Asian Agri (RGE) 12.31 15, 2020 20, 24, 26 March 16-Apri Reports 17, 21, PT Mekar Karya Kahuripan Makin Group 12.00 15, 2020 22, 23, 26 CB Industrial Product March 16-Apri Reports 15, 20, PT Jaya Jadi Utama 11.93 Holding 15, 2020 23, 26 Reports 1,14, Anglo-Eastern March 16-Apri PT Kahayan Agro Plantation 10.30 15, 18, 19, 20, Plantations 15, 2020 23, 24, 25 LPF/0018 Shin LPF/0018 Shin Yang OP March 16-Apri Shin Yang Group 101.11 Yang OP Planting Area 15, 2020 Planting Area KTS Holdings Sdn March 16-Apri BLD Plantation BLD Plantation Bhd 54.86 Bhd 15, 2020 Bhd ■Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases - Known Supply Chain Links Area Rapid covered by Response Concession license area Group/ownership screened Time period reports related GLAD alerts to each case* (ha) Puncak Niaga March 16-Apri Danum Sinar Danum Sinar Sdn Bhd 52.99 Holdings Bhd 15, 2020 Sdn Bhd Dataran Linau Shin Yang Group / Dataran Linau Sdn Bhd (Lot 1 March 16-Apri Sdn Bhd (Lot 1 Sarawak Oil Palms 47.19 Block 14 Murum LD) 15, 2020 Block 14 Murum Bhd ID)______Almabumi BBC Holdings Sdn March 16-Apri Almabumi Plantation Sdn Bhd 19.72 Plantation Sdn Bhd 15, 2020 Bhd Rimbunan Hijau March 16-Apri Woodijaya Sdn Woodijaya Sdn Bhd (Lot 197) 16.84 Group 15, 2020 Bhd (Lot 197) March 16-Apri LPF/0006 LPF/0006 Samling Lana Samling Group 13.54 15, 2020 Samling Lana Linau Sinar Sdn Linau Sinar Sdn Bhd (Metalon March 16-Apri Bhd (Metalon OP Shin Yang Group 13.23 OP Estate, Lot 2, Danum LD) 15, 2020 Estate, Lot 2, Danum LD) March 16-Apri Baram Estate, Baram Estate, part of LPF/0004 Woodman Group 9.96 15, 2020 part of LPF/0004 Rimbunan Hijau March 16-Apri Timrest Sdn Bhd 9.74 Timrest Sdn Bhd Group 15, 2020 March 16-Apri Hydroflow Sdn Hydroflow Sdn Bhd TH Plantations Bhd 9.60 15, 2020 Bhd March 16-Apri Adong estate, Adong estate, part of LPF 0004 Woodman Group 8.26 15, 2020 part of LPF 0004 Rimbunan Hijau March 16-Apri Poh Zhen Sdn Poh Zhen Sdn Bhd 7.89 Group 15, 2020 Bhd ' Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases - No Known Supply Chain Links Area Rapid covered by Response Concession license area Group/ownership screened Time period reports related GLAD alerts to each case* (ha) Reports 2, 6, 9, March 16-Apri PT Berau Karetindo Lestari Korompis family 100.06 15, 16, 19, 20, 15, 2020 21,22 March 16-Apri Reports 20, 21, PT Tri Investama Green Yield Pte Ltd 11.07 15, 2020 22,23, 24,25 PT Prasetya Mitra Muda (Block March 16-Apri Unknown Group 14.17 Reports 6, 17, 19 15, 2020 March 16-Apri Reports 12, 15, PT Marita Makmur Jaya Unknown Group 14.24 15, 2020 17, 19,22,24,26 March 16-Apri Reports 16, 19, PT Gapura Alas Lestari Unknown Group 14.87 15, 2020 20,23,25,26 JSK International Co March 16-Apri Reports 17 and PT Future Agropia Indonesia 15.78 Ltd (Korea) 15, 2020 20 March 16-Apri Reports 20, 23, PT Citrapermata Serundung Unknown Group 15.88 15, 2020 26 March 16-Apri Reports 23 and PT Perkebunan Inti Sendawar IMC Plantations 17.81 15, 2020 26 March 16-Apri Reports 17, 22, PT Cipta Karya Sesayap Unknown Group 19.55 15, 2020 23, 25 March 16-Apri Reports 15, 17, PT Sumber Sawit Mitrajaya Unknown Group 20.06 15, 2020 23, 25, 26 March 16-Apri PT Pipit Citra Persada Unknown Group 22.03 Reports 6, 17, 20 15, 2020 Reports 8, 12, Shanghai Xinjiu March 16-Apri PT Sebaung Sawit Plantation 22.87 13, 16,20,21, Chemical Co Ltd 15, 2020 22, 23, 25 March 16-Apri Reports 22, 23, PT Barito Riau Jaya Unknown Group 24.01 15, 2020 26 ■Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM Repeat Cases - No Known Supply Chain Links Area Rapid covered by Response Concession license area Group/ownership screened Time period reports related GtAD alerts to each case* (ha) PTTriomas Forestry March 16-Apri Reports 17, 22, Unknown Group 43.99 Development Indonesia 15, 2020 23, 24 Reports 5, 7, 12, Henan Jiujiu March 16-Apri PT Palem Segar Lestari 57.88 16, 18,20,21, Chemical Co. Ltd 15, 2020 22,23,25,26 Unknown Group (PT MML formerly owned March 16-Apri Reports 16, 17, PT Menthobi Mitra Lestari 64.25 by PT Bakrie Sumatra 15, 2020 20, 22 Plantations Tbk)_____ Starmas Sentosa March 16-Apri Reports 8, 16, PT Agrindo Sukses Sejahtera 95.34 Mandiri 15, 2020 22, 26 March 16-Apri Reports 18, 19, Telliana Enterprise Sdn Bhd Unknown Group 37.09 15, 2020 20, 26 March 16-Apri Reports 19, 20, Formerly Ekran Bhd Unknown Group 27.30 15, 2020 21,23,25,26 Titanium Management Sdn Bhd March 16-Apri Reports 18, 19, Unknown Group 26.03 (Part 1) 15, 2020 21,26 Titanium Management Sdn Bhd March 16-Apri Reports 18, 19, Unknown Group 17.39 (Part 2) 15, 2020 21,26 Limba Jaya Timber Sdn Bhd Lee Linq Timber Sdn March 16-Apri Reports 18, 21, 7.95 (Limbang) Bhd 15, 2020 26 LPF/0038 Limba Jaya Timber Lee Linq Timber Sdn March 16-Apri Reports 18, 21, 7.88 Sdn Bhd (Part 2) Bhd 15, 2020 26 •Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here. The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’ work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the Department of Justice, Washington, D.C. Received by NSD/FARA Registration Unit 05/12/2020 4:39:05 PM