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PUBLIC SUMMARY REPORT

INITIAL RSPO CERTIFICATION ASSESSMENT

PT Agro Muko (SIPEF Group) Located in Province South West ,

Report Author Allan Thomas – Revised February 2011 [email protected] Tel: +61 412 492 353

BSI Group Singapore Pte Ltd (Co. Reg. 1995 02096-N) BSI Services Malaysia Sdn Bhd (Co.Reg. 804473 A) 3 Lim Teck Kim Road #10-02 Suite 19.05 Level 19 Wisma Goldhill Singapore Technologies Building 65, Jalan Raja Chulan SINGAPORE 088934 50200 Kuala Lumpur Tel +65 6270 0777 MALAYSIA Fax +65 6270 2777 Tel +03 2032 2252 Soon Leong Chia: [email protected] Fax +03 2032 2253 www.bsi-asia.com

TABLE of CONTENTS Page N o Abbreviations USED ...... 1 1.0 Scope of Certification Assessment ...... 1 1.1 National Interpretation Used ...... 1 1.2 Certification Scope ...... 1 1.3 Location and Maps ...... 1 1.4 Description of Supply Base ...... 1 1.5 Date of Plantings and Cycle ...... 3 1.6 Other Certifications Held ...... 3 1.7 Organisational Information / Contact Person ...... 3 1.8 Time Bound Plan for Other Management Units ...... 3 1.9 Area of Plantation...... 4 1.10 Approximate Tonnages Certified ...... 4 1.11 Date Certificate Issued and Scope of Certificate ...... 4 2.0 ASSESSMENT PROCESS ...... 4 2.1 Certification Body ...... 4 2.2 Qualifications of the Lead Assessor and Assessment Team ...... 4 2.3 Assessment Methodology, Programme, Site Visits ...... 5 2.4 Stakeholder Consultation and List of Stakeholders Contacted ...... 5 2.5 Date of Next Surveillance Visit...... 7 3.0 ASSESSMENT FINDINGS ...... 7 3.1 Summary of Findings ...... 7 3.2 Detailed Identified Nonconformities, Corrective Actions and Auditor Conclusions (Also included as Append D) ...... 27 3.3 Noteworthy Positive Components ...... 28 3.4 Issues Raised By Stakeholders and Findings with Respect To Each Issue ...... 28 3.5 Acknowledgement of Internal Responsibility and Formal Sign-off of Assessment Findgings .....29

LIST of TABLES

1 Mills GPS Locations ...... 1 2(a) Company Estate FFB Production (Includes KMD) ...... 3 2(b) Company and SG FFB Production (Includes KMD) ...... 3 3 Age Profile of Company Estate Planted Palms ...... 3 4(a) Estates and Areas Planted ...... 4 4(b) PT Agro Muko Indonesia hectares statement (Includes KMD) ...... 4 5 Approximate Tonnages Certified ...... 4

LIST of FIGURES 1&2 Location Maps ...... 2

List of Appendices A Agro Muko Indonesia RSPO Certificate Details B Certification Audit Programme C Continuous Improvement Plan D Nonconformities, Corrective Actions and Observations Summary E Record of all Stakeholder Comments in detail

RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 1

SUMMARY PMP Project Management Plan POME Palm Oil Mill Effluent BSi has conducted an assessment of PT Agro Muko PPE Personal Protective Equipment located in Bengkulu Province, South West Sumatra, PPKS Pusat Penelitian Kelapa Sawit (IOPRI Indonesia operations comprising two mills, eight oil palm Indonesian Oil Palm Research Institute) estates, support services and infrastructure. BSi PT AM PT Agro Muko Indonesia concludes that PT Agro Muko operations comply with PT TTI PT Tolan Tiga Indonesia the requirements of RSPO Principles & Criteria: QMS Quality Management System November 2007 and Indonesia National Interpretation RAB QSA Quality Society of Australia Working Group (INA NIWG) Indicators and Guidance: RKL Rencana Pengelolaan Lingkungan May 2008. (Environmental Management Plan)

RPL Rencana Pemantauan Lingkungan BSi recommends that PT Agro Muko be approved as a (Environmental Monitoring Plan) producer of RSPO certified sustainable palm oil. SBE Sungai Betung Estate SEIA Social & Environmental Impact Assessment ABBREVIATIONS USED SEL Studi Evaluasi Lingkungan (Evironmental ABE Air Buluh Estate Assessment) ABKE Air Bikuk Estate SEMDAL Studi Evaluasi Mengenai Dampak Lingkungan AMDAL Analisis Mengenai Dampak Lingkungan (Environmental Impact Evaluation (Environmental Impact Assessment) Assessment). AMTT Agro Muko Tank Terminal SKE Sungai Kiang Estate B3 Chemical waste store SPAM Serikat Pekerja Agro Mandiri (Agromuko BPDLD Provincial Environmental Agency Autonomous Labour Union) BOD Biological Oxygen Demand SOP Standard Operation Procedure BPN Badan Pertahanan Nasional (National Land TPE Talang Petai Estate Authority) TRE Tanah Rekah Estate BPS Badan Pusat Statistik Central Statistical Office TSS Total Suspended Solids BTE Bunga Tanjung Estate UKL-UPL Upaya Kelolalaan Lingkungan-Upaya BTM Bunga Tanjung Mill Pemantauan Lingkungan (Environment CD Community Development Management and Monitoring Measures) CLA Collective Labour Agreement COD Chemical Oxygen Demand 1.0 SCOPE OF CERTIFICATION ASSESSMENT CSR Corporate Social Responsibility EFB Empty Fruit Bunch 1.1 National Interpretation Used EM Estate Manager The operations of the mills and their supply bases of FFB EMS Environmental Management System were assessed against the RSPO INA-NIWG: May 2008 of ERT Endangered, Rare and Threatened the RSPO Principles and Criteria: 2007 ESIA Environmental Social Impact Assessment FFB Fresh Fruit Bunch FSC Forestry Stewardship Council 1.2 Certification Scope GMO General Managers Office The scope of Certification covers two (2) Palm Oil Mills HCV High Conservation Value and the supply base comprising eight (8) company HGU Hak Guna Usaha (Land) title for commercial owned oil palm Estates. use HO Head Office 1.3 Location and Maps IPM Integrated Pest Management IRCA International Registration of Certified Auditors The AGRO MUKO Estates and Mills are located in ISO International Standards Organisation Bengkulu Province, South West Sumatra, Indonesia ISPO Indonesia Sustainable Palm Oil Foundation (Figure 1). The GPS location of the mills is shown in IUCN International Union for Conservation of Nature Table 1. IUP Izin Usaha Perkebunan (Plantation Licence) KMD Kebun Masyarakat Desa (Village Estate) Table 1: Mills GPS Locations LPM Lembaga Pemberdayaan Masyarakat (Population Development Office) MILL EASTING NORTHING MME Mukomuko Estate MMM Mukomuko Mill Mukomuko E101º16' S02º36' MSDS Material Safety Data Sheet Bunga Tanjung E101º22' S02º43' NGO Non-Government Organisation NKT Nilai Konservasi Tinggi (HCV) OHS Occupational Health and Safety 1.4 Description of Supply Base PCD Pollution Control Device PKB Perjanjian Kerja Bersama (Collective Labour Oil palm fruit is sourced from company owned and Agreement) managed estates and KMD Projects.

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FIGURE 1 LOCATION OF PT AGRO MUKO ESTATES

FIGURE 2 LOCATION OF PT AGRO MUKO ESTATES IN RELATION TO SUMATRA

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Table 2(a): Company Estate FFB Production (Includes 1.7 Organisational Information / Contact Person KMD) PT Agro Muko Indonesia is wholly owned by the SIPEF

NV Group of Belgium. Estate FFB (tonnes) Bunga Tanjung Estate 44,000 PT Agro Muko Indonesia Air Bikuk Estate 30.000 Gedung Bank Sumut lt.7 Air Buluh Estate 40,000 Jl. Imam Bonjol 18 Mukomuko Estate 66, 000 20152 North Sumatra Tanah Rekah Estate 75,000 INDONESIA Sungai Kiang Estate 25,000 Talang Petai Estate 19,000 Contact Person: Olivier Tichit Sungai Betung Estate 39, 000 Environment & Conservation TOTAL 338,000 General Manager Phone:

Fax: +65 61 452 0908 Table 2(b): Company FFB Production (Includes KMD) Email: [email protected]

Year 2006 2007 2008 2009 1.8 Time Bound Plan for Other Management Units Total 299,525 301,855 310,566 338,000 Company FFB The other Majority owned Management Units are as 100% follows: - Hargy Oil Palms ltd., in PNG 1.5 Date of Plantings and Cycle - PT Tolan Tiga in Sumatra Utara - Jabelmalux group: PT Umbul Mas Wisesa, PT Toton Table 3: Age Profile of Company Estate Planted Palms Usaha Mandiri, and PT Citra Sawit Mandiri, in North Sumatra, and PT Melania in South Sumatra. % of Year Ha Ha Planted Hargy Oil Palms has been certified on 09 April 2009, and Planted Planted Area a surveillance audit was completed in April 2010 in Mature Immature which they retained certification, by BSi. 1988 419 2.29 1989 1491 8.16 The Sipef plan is to achieve RSPO certification for Sipef majority-owned Indonesian operations within 3 years of 1990 3478 19.03 Hargy Oil Palm certification. As described in the 1991 259 1.42 clarification letter sent to the RSPO in 2008, and 1992 142 0.78 confirmed in 2009, we have divided our Indonesian 1993 217 1.19 operations into three groups. 1994 872 4.77 1995 257 1.41 PT Tolan Tiga Indonesia, including 2 mills and 4 estates in 1996 496 2.71 North Sumatra, was certified to RSPO P & C Indonesian 1997 844 4.62 NI in May 2010. 1998 2293 12.44 1999 1608 9.19 PT Agro Muko is at this stage the final operation to be 2000 1034 5.56 certified that is eligible as they have mills and supply 2001 475 2.60 bases. Other areas will be included as mills are 2002 81 0.44 constructed and in operation. 2003 101 0.55 2004 696 3.81 Jabelmalux group, PT Umbul Mas Wisesa, PT Toton 2005 525 2.87 Usaha Mandiri and PT Citra Sawit Mandiri - 2006 1083 5.72 are 3 new estates under development. Sipef are 2007 149 251 2.19 currently placing these estates in the RSPO 2008 434 2.37 compensation mechanism based on a precautionary 2009 663 3.63 approach, while continuing to study all possible 2010 412 2.25 solutions. Sipef are complying with local laws and regulations in the development of these estates, and TOTAL 16,520 1,760 100 there are no unresolved disputes.

1.6 Other Certifications Held PT Melania in South Sumatra still has an area of 456ha of PT Agro Muko has achieved ISO 14001 and ISO 9001 for oil palms, currently being converted into rubber . its Palm Oil Mills.

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At this point Sipef has informed BSi that there are no 1.11 Date Certificate Issued and Scope of Certificate known legal non-compliances, land or unresolved labour disputes at its other operations. BSi considers Sipef’s Scope of the Certificate is for the production from the Time Bound Plan to conform to the RSPO requirements two palm oil mills and their supply base (refer Table 2(a) for Partial Certification. for tonnages). Certificate details are included as Appendix A. The 1.9 Area of Plantation Certificate issue date will be the date of the RSPO approval of the Assessment Report. The hectare statement for the company owned Estates is shown in Table 4(a), and Agro Muko Indonesia Inclusion of Smallholders Operations area Table 4(b). There are no small holders included in the Supply Base of Table 4(a): Estates and Areas Planted PT Agro Muko.

Estate Mature (ha) Immature (ha) 2.0 ASSESSMENT PROCESS Bunga Tanjung 2384 84 2.1 Certification Body Estate (BTE) Air Bikuk Estate 1149 71 BSI Group Singapore Pte Ltd (ABKE) 3 Lim Teck Kim Road #10-02 Air Buluh 2011 327 Singapore 119963 Estate(ABE) Product Manager: Mr Soon Leong Chia Mukomuko Estate 2799 Phone: +65 6270 0777 Ext 115 (MME) Fax: +65 6270 2777 Tanah Rekah 3086 9 Email: [email protected] Estate (TRE) Sungai Kiang Estate 1764 285 BSi is a leading global provider of management systems (SKE) assessment and certification, with more than 60,000 Talang Petai Estate 1215 918 certified locations and clients in over 100 countries. BSi (TPE) Standards is the UK’s National Standards Body. BSi provides independent, third-party certification of Sungai Betung 2112 66 Estate (SBE) management systems. BSi has a Regional Office in Singapore and an Office in Kuala Lumpur. TOTAL 16520 1760 2.2 Qualifications of the Lead Assessor and Assessment Team Table 4(b): PT Agro Muko Indonesia hectares statement (includes KMD) Allan Thomas Lead Assessor Allan Thomas holds a tertiary qualification in commerce Mature area 16520 and accounting from Wollongong University in 1973 and Immature 1760 has more than 19 years’ experience in systems Total area for oil palm 18280 management and auditing of large organisations in construction, forestry, agriculture, manufacturing and in Nurseries 41 private and Government sectors both in Australia, South Emplacement, Roads, Mills, Compounds etc 622 East Asia and the South Pacific. During the past 15 years, he has been the Manager of a large certification Unplanted reserve, incl underwater lease 2307 body based in Australia with responsibilities throughout SE Asia. He has performed over 120 comprehensive Total leased area 21250 audits of management systems throughout the Palm Oil industry including Occupational Health and Safety, Environmental and Quality Management Systems. He 1.10 Approximate Tonnages Certified has also advised companies on the implementation of OHS in the Oil Palm Industry. He has worked in Table 5: Approximate Tonnages Certified Indonesia, Malaysia and PNG in the Oil Palm industry. Allan has conducted over 2500 system audits in the last

14 years and controlled over 50 auditors when MILL CPO PK Certification Manager of SGS-ICS. MukoMuko 52,000 12,000 He is a Lead Environmental Auditor (ISO 14001) with IRCA, A Lead OHS Auditor (OHSAS 18001 & AS 4801) Bunga Tanjung 27,000 6,000 with IRCA, a Lead Quality Auditor (ISO 9001:2000) with RABQSA and also an accredited Heavy Vehicle Auditor. TOTAL 79,000 18,000 He has also implemented strategies for implementing and maintaining SA 8000. Allan has also been appointed

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 5 a Federal Safety Officer by the Australian report (as an attachment to the 2009 mine closure plan), Commonwealth Government. and provide advice on social and economic monitoring; He has conducted Integrated Management assessments In early 2009 Mike provided advice to the University of of a large number of palm and kernel oil mills and many Inner Mongolia (China) on the design and conduct of a oil palm plantations in Indonesia, Malaysia and Papua SIA to examine the impact of mining and petroleum New Guinea. He has worked closely with RSPO in operations on traditional herding activities; and developing an audit checklist for the Principles and In 2007 Mike conducted an economic analysis of the Criteria and developed an audit methodology. This was proposed Tampakan copper and gold mine in the carried out at the instigation of Dr. Simon Lord – in 2005 Southern Philippines. prior to RT3. Dr. Lord is a former member of the Executive Board – this audit checklist was bought by Mike aims to maximise sustainable development RSPO in early 2006 He also performed the first base line through the promotion of effective and practical assessment of the applications of the P&C. He is a strong solutions in large-scale resource industries by working advocate of environmental, safety and social with local consultants and local organisations while accountability. ensuring high quality outcomes in line with current international best practice. Mike is a member of the Iman Nawireja – Technical Expert- Social (audit) International Association for Impact Assessment (IAIA) and is familiar with, and has conducted studies in Iman Nawireja graduated with Bachelor of Agriculture accordance with the Equator Principles and Global Science from the Agricultural University in 1997 Reporting Initiative. and a Masters Degree in Communications from University of Indonesia. Currently, he is PhD Candidate in Mike is also a director of Project Design & Management Rural Sociology from Bogor Agricultural University. He Pty Ltd (PDM), a company specialising in development has a lecture in general sociology, intercultural assistance and humanitarian aid, with a long history in communications, and social statistic at the Bogor PNG. Agricultural University and has more than 10 years’ experience in conducting social impact assessments of agriculture, mining and forestry projects. He has 2.3 Assessment Methodology, Programme, Site assisted with field studies on the effect of resource Visits development projects on farmer and community incomes, health status and household division of labour. A pre-audit to RSPO Principles and Criteria was He has completed Lead Auditor training in ISO 9001 conducted between 19 th and 24 th July 2010 to determine Quality Management Systems. He has assisted in progress PT Agro Muko Indonesia has made towards conducting environmental and social assessments of oil certification. palm projects during the past 7 years. He has assisted with conducting audits of oil palm plantation companies The Initial Certification Audit was conducted between against the RSPO P&C in Indonesia and in Malaysia 27 th September and 3 rd October 2010. The audit programme is included as Appendix B. Mike Finlayson - Technical Expert Social Mike has 20 years’ experience as a development The approach to the audit was to treat each mill and its specialist in Australia, Asia and the Pacific and has supply base as an RSPO Certification Unit. Each mill was worked in PNG since 1985. Mike focuses on the social audited together with the plantations of its supply base. impact assessment (SIA) of large-scale resource projects A range of environmental and social factors were and has recent experience in Australia, Papua New covered. These included consideration of topography, Guinea, China and the Philippines: palm age, proximity to areas with HCVs, declared conservation areas and local communities. In 2009 Mike conducted a SIA of an expansion of oil palm for Hargy Oil Palms Limited, in West New Britain; The methodology for collection of objective evidence Mike has also now been involved in RSPO assessments in included physical site inspections, observation of tasks PNG, Solomon Islands and Indonesia since 2009. and processes, interviews of staff, workers and their In 2008 Mike provided advice and participated in the families, review of documentation and monitoring data. conduct of an SIA for the development of a large bauxite Checklists and questionnaires were used to guide the mine on traditionally-owned land in the Cape York area collection of information. The comments made by of northern Australia; external stakeholders were also taken into account in the assessment. Between 2007 and 2009 Mike led a team conducting a SIA of an oil & gas project in Gulf and Central Provinces of PNG; 2.4 Stakeholder Consultation and List of Since mid 2008 Mike has worked with Ok Tedi Mining Stakeholders Contacted Limited to prepare socio-economic data for mine- impacted communities, prepare a social and economic Stakeholder consultation involved external and internal stakeholders. External stakeholders were notified by placing an invitation to comment on the RSPO, SIPEF and

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BSi websites and an advertisement in each of the local • Kunaryo, Arief, Hamdani, Rauli, Dawan, Nes newspapers. Riyadi and Taufik (Bunga Tanjung Estate Male Sprayers) Letters were written to individual stakeholders and • Riswan, Sistar, Hendra, and Tunggal Jaya (Sei telephone calls were made to arrange meetings. As part Betung Estate Male Sprayers) of the audit, meetings were held with stakeholders to • Supriyadi, Misun, Miswanto, Sumadi, and Ali seek their views on the performance of the company Yanto (Sei Betung Estate Harvesters) with respect to the sustainability practices outlined in • SPAM committee members, including SPAM the RSPO and aspects where improvements could be branch committee members from Sei Betung made. Estate;

• Koperasi staff (Sei Betung Estate); Stakeholders included those immediately linked with the operation of the company such as employees and • Health Coordinator for PT Agro Muko and contractors. polyclinic staff in the Muko Muko, Tanar Rekah, Sungai Kiang, Talang Petai, Bunga External stakeholders included organizations such as Tanjung and Sei Betung estates/mills; Government, NGOs and Civil Societies, who have an • Emplacement residents (including members of interest in the PT Agro Muko area and resident women’s groups) in Tanar Rekah, Sungai Kiang, communities. Talang Petai, Bunga Tanjung and Sei Betung estates/mills; Stakeholder consultation took place in the form of • Managers or office staff at Tanar Rekah, Sungai meetings and interviews. Meetings with government Kiang and Bunga Tanjung estates and Bunga agencies and NGOs were held in their respective Tanjung mill, premises within local Kampongs. • Employees at Bunga Tanjung mill and Talang

Petai Estate; In all the interviews and meetings the purpose of the audit was clarified at the outset followed by an evaluation of the relationship between the stakeholder Contractors and the company before discussions proceeded in accordance with relevant RSPO principles, criteria and • Wagiran (Construction Contractor) indicators. In a number of interviews and meetings, the • Tukiman (Transport Contractor) presence of company representatives was discouraged • Jai Dahrim (L/C Contractor) so as not to restrict discussion of both the positive and negative aspects of PT Agro Muko’s operations. Local Community

The company representatives only introduced the team • Burhanuddin (Teluk Bayur Village and were requested to leave during meeting with Representative) stakeholders. For internal stakeholders the same • Atral (Tanah Rekah Village Head) procedure was followed and company representatives • Amminudin, Marusen, and Ririn Asmara left once the consultations started (Employees are (Lubuk Sadau Informal Leader) involved in consultation and committees). • Sumitro (KMD Lubuk Sadau)

• Dasriman (Talang Sepakat Village Head) There is a trade union at PT Agro Muko. The committee • Minsyahril (Bunga Tanjung Village Head) is elected through open elections and every year • Ali Khasan (Taruntung Village Head) elections are held to select representatives. During the • Amaran (Talang Medan Village Head) audit the committees have been interviewed . • Members of a KMD committee at Talang Petai Estate, along with the respective village head LIST OF STAKEHOLDERS CONTACTED and a sub-district government official. Workers and Staffs Government

• GMO staff, including the HR and KMD • managers Markidi (Cooperative and Trade Department) • • Tress Martin (AMTT Worker) Apriyandi Sihaloho – Environmental Monitoring Office • Leonardus Manurung, Fey Densi, Daman Sauri, • Berton Hasbulloh, Hotpen Manurung (Muko- Aman Jaya (Agriculture and Forestry Muko Mill Workers) Department) • • Jalinus, Fonazaro, Darman, Abdul Rohim, and Sudaryanto (National Land Agency) Surya (Tanah Rekah Estate Harvesters) • Samin and Sony (Sei Kiang Estate Harvesters) Non Government Organisations • Supriyadi, Misun, Miswanto, Sumadi, and Ali Yanto (Bunga Tanjung Estate Harvesters) • Darma (NGO – Genesis) • Berlian (NGO – Genesis)

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2.5 Date of Next Surveillance Visit 1.1.1 Observation: Government returns which are mandatory such as manpower reports should not be Approximately October 2011 treated as request for information as a reply to these

requests is non-negotiable.

3.0 ASSESSMENT FINDINGS On the whole documents that are not released are not related to environmental or social issues and are mainly 3.1 Summary of Findings of a confidential financial nature. As outlined in Section 2.3, objective evidence was Senior management has now decided which documents obtained separately for each of the RSPO Indicators for are to be made available to the public. These are in the the Mills and the Estates. The results for each indicator form of a register which can be updated as more from each of these operational areas have been documents are requested and made available. aggregated to provide an assessment of overall conformance of the Company’s operations with each The procedure now states clearly how long different Criterion. A statement is provided for each of the types of requests will be kept, where and in what Indicators to support the finding of the assessment medium. team. During the audit, two (2) Nonconformities were assigned This is generally from 3-5 years depending on the type of against Minor Compliance Indicators. PT Agro Muko record. Indonesia has prepared a Corrective Action Plan (Appendix D) for addressing the identified MMM: No verbal requests have been received; all nonconformities that was reviewed and accepted by BSi. information requests were made by letter. An example is on 26 April 2010 (received by mill on 06 May 2010) the Twelve (12) Observations/Opportunities for Provincial Department of Labour Number Improvement were identified. Details of the 1464/DKTTRANS-04/2010, requested evaluation data Nonconformities and Observations are given in Section and appointment of OHS expert for 2010. The Company 3.2 (Page 27). responded by sending the data on 11 May 2010. BSi’s assessment of PT Agro Muko Indonesia operations, Records held on file “Informasi Permintaan dan comprising two palm oil mills, estates, infrastructure and Jawaban”. support services, concludes that PT Agro Muko Indonesia operations comply with the requirements of TRE: The Estate prepared a book on requests for RSPO Principles & Criteria : 2007 and INA-NIWG information “Buku Permintaan dan Jawaban”. So far no Indicators and Guidance : May 2008. requests for information have been received.

BSi recommends that PT Agro Muko Indonesia be SKGE: The Estate has prepared a record of information approved as a producer of RSPO Certified Sustainable requests “Buku Permintaan Informasi dan Tanggapan”. Palm Oil. TPE: The Estate has prepared “Informasi Permintaan dan Criterion 1.1: Oil palm growers and millers provide Jawaban”, the records includes verbal requests. adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO BTE/SBE: No requests for information have been Criteria, in appropriate languages & forms to allow for received this year, records when received held on file effective participation in decision making. “Buku Permintaan Informasi dan Jawaban”.

Any requests for information that are received in a AMTT: There have been no requests for information suitable media are kept by the relevant department. If received in this estate. information cannot be made available by officers they must refer to a higher authority. With regards to verbal requests by either phone or in person these will be Criterion 1.2: Management documents are publicly asked to be made in writing. PT AM will maintain a available, except where this is prevented by commercial register of internal requests. confidentiality or where disclosure of information would result in negative environmental or social PT AM ensures that responses to information requests outcomes. are maintained if not already completed. Each request that is received is registered in the correct format and PT AM has made available the list of publicly available stamped and identified and sent to relevant person. documents - and these were listed on the company web site by August 2010. PT AM maintains a record of responses and the time taken to respond to each request. PT AM monitors the It is PT AM policy to make documents available in development and progress of all requests even if the accordance to government regulations. This commenced response is negative. They also give a reason why from August 2010, a special page in the company request was rejected. website is designed and devoted to requests for information at http://www.agromuko.co.id/v1/?page_id

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=431 where all stakeholders are able to request sarongs to Teruntung villagers on 27 August 2009. It was information on operation permits and SEIA documents confirmed that the records are available to interested such as Ijin Lokasi, HGU, IUP, AMDAL – UKL/UPL – parties. RKL/RPL Reports, Hazardous Waste Storage, CSR/CD Program, and other information. All requests and Another example of contribution to the local community grievances are considered confidential. PT AM will was made on 28 August 2010; the community requested provide feedback within a maximum of 15 days from donations for the Idul Fitri celebration. PT AM gave a date of receipt. donation on 03 September 2010. Records are held on file “Buku Permintaan Bantuan”. Copies of the four HGU's are held in each Estate and originals are in Medan HO. Information on land titles is The company OHS Policy is available on the web site and discussed in detail in 2.2.1. The HGU’s are available for is mounted on notice boards widely throughout the all estates and were sighted during this audit. These are company operations. long term leases on Government land and therefore land use titles are readily available. The policy which is now widely available so as to be accessible in all work areas and achieving the widest Even though the internet gives access to a wide possible circulation to all employees and contractors. audience not all stakeholders have access to or are knowledgeable in the use of the internet, so that hard There is a continuous improvement plan prepared as a copy is still made available in all mills and estates on result of all internal audits and inspections which are request. monitored to determine progress against set targets - All records of requests for information are kept for a ESIA has been conducted for estates and mills – and can minimum of three years. be made available on the discretion of a Senior company official. The information which will be made available PT AM have in place a register or matrix indicating the will depend on the sensitivity of the information with records to be kept and the period or retention times for regards to potential negative effects on the these records. All records are dated to allow times to be environment. kept to be determined accurately.

PT Agro Muko holds two environmental documents, an Documents pertaining to financial information can only approved AMDAL document and separate UKL/UPL be shared upon the discretion of the President Director documents for Sungai Buluh Estate. PT AM also holds an with approval from the SIPEF Board . approved UKL/UPL document, for “Depo Bongkar Muat Minyak Mentah Sawit (CPO)” No. 660/6.27/Pedal- The Equal Opportunities Policy is available and has been BPDL/VIII-2006 dated 10 August 2006. The AMDAL and approved by Management. It is widely available – and UKL/UPL also sufficiently cover social aspects as well, has been placed on the company’s web site and on and include both negative and positive impacts. notice boards throughout PT AM.

The AMDAL was approved on 11 January 2005, and is SKE: There was a verbal request for information of jobs available to the public. RKL-RPL report is submitted 3 vacancy and the application procedure made on 10 April monthly to the government and it is available on written 2010, PT AM responded on the same date with request at the discretion of a Senior Company officer. information with regards to applying formally to GMO or HO office Medan. There are records of requests for assistance and, if accepted, records are in place for any social activities in TPE: The last information request, the local community which PT AM gave assistance. There is a monthly report member requested information on the purchase of oil on Social Activities including Community Development, palm seed. Estate advised to proceed to GMO. Schools, Sports, etc. – and these are made available at the discretion of Senior Management. With regards to BTE/SBE: No request of information received this year. monetary considerations however copies of activities are freely available. AMTT: The Estate keeps record on information requests. For example, on 23 September 2010, an official of PT There is also an annual report on Social Activities Bank Mandiri came to request the company certificate including Community Development Programs, and of establishment. AMTT provided it the same day. donations (Schools donations, Sporting activities, Religious activities, etc.)—these are also made available at the discretion of Senior Management. Criterion 2.1 – There is compliance with all applicable local, national and ratified international laws and PT AM: Each Operating Unit (mills, estates, and GMO) regulations. receive requests for donations and CD from local communities. The units then forwarded the requests and There is a corporate affairs department. in Medan HO proposals to Medan HO for approval. If accepted records which is responsible for legal compliance – at present are in place for any social activities e.g. GMO donated there is no evidence available to show that PT AM is not

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 9 complying with legal and other requirements. There is Criterion 2.2 – The right to use the land can be no evidence of chronic non-compliance. demonstrated and is not legitimately contested by local communities with demonstrable rights. PT AM issued a new policy on 05 March 2010 to ensure the compliance of contractor workers payment to PT AM holds copies of all HGU's. Copies of HGU's are regional minimum wages. Previously an inspection of held in each estate and the originals are held in Medan the contractor’s documents found inconsistency of HO. In each estate there is a sign board (which is policy implementation where the contract provided by required by law) which states PT AM is a foreign Medan HO did not clearly state the contractor was to investment company and lists the number of the pay minimum wages. This has now been corrected and relevant HGU and the area of the operations and land contracts viewed all clearly state that workers will be title. paid at least the minimum wage. In most cases the workers actually get paid in excess of minimum wage. HGU’s were sighted for all concessions and all were

current and readily available showing area and length of PT AM complies with all environmental laws (AMDAL, land tenure. In all cases this was for a period of 30 years waste management), workers laws/regulations. and all expire from 2018 and beyond depending on the

date of original lease (HGU). PT AM ensures that all local laws from Bengkulu

Province are included in response to any legal This was demonstrated by the following: TPE: requirements. 31/HGU/BPN/1989 dated 27-06-1989; MME/TBE/MRE:

31/HGU/BPN/1989 dated 27-06-1989; ABKE: The corporate affairs dept receive a weekly update of 4/HGU/BPN/94 dated 02-02-1994; BTE: 4/HGU/BPN/94 any legal changes which may affect PT AM. dated 02-02-1994; SKGE/SBE/TRE: 9/HGU/BPN/93 dated

08-03-1993; ABE: 07/HGU/BPN/90 dated 03-05-1990; There are staff nominated in Medan HO to ensure any and SBE: 01/Tahun 1991 dated 18-02-1991. changes are noted and made known to PT AM

Management. PT AM gets information of changes in All legal boundaries are clearly demarcated and regulations from a number of sources. This includes maintained in the form of boundary pegs. These pegs company lawyers, forestry, Dept. of Agriculture and are photographed showing the number of the peg. The others. boundary markers are also indicated on maps of the

estates. Hard copies are received of any changes to regulations.

This is then circulated to relevant departments within PT The boundary pegs are also recorded giving the GPS AM who need to know of any changes. coordinates.

Head Office have prepared a SOP “Prosedure A large number of boundary pegs were sighted during Pemberitahuan Undang-Undang, Peraturan Pemerintah, this assessment and were easily located and Peraturan Daerah” to keep legal requirements current prominently displayed. and to make employees aware of any changes. This procedure is disseminated to operational units to ensure PT AM are now ensuring that all operating units that current regulations are implemented. consistently undertake monitoring of boundary stones

regularly and record the conditions of these markers. There is a list of legal requirements to which PT AM must comply. This includes national and local laws as well as There have been no major disputes with regards to land conventions to which PT AM subscribes such as RSPO. tenure in recent memory and there are no outstanding

disputes that PT AM is aware of. PT AM ensures staff attend workshops where applicable with regards to laws changes in each area - e.g. Labour MMM/TRE: It was confirmed during interviews with the laws, education and others. local community there are no land disputes in these

plantation areas. 2.1.3 Observation: The procedures for legal compliance have not yet developed into a formal SOP which has SKE: During a survey to reinstate the boundary carried been socialized to every operating unit. out by HO Medan on July 2010, it was found that an area

1 km long and 50 metres wide was occupied by the local There is a rigorous internal audit process which includes people of Talang Petai Village, district of V Koto. On 20 a review of laws and their compliance. September 2010, the people raised a disagreement with

regards to the boundary, and later on 28 September The latest internal audit was carried out on 6 August 2010 Talang Petai Village Head forwarded a letter 2010 by the GMO and it found Company Registration mentioning that the land area belongs to 35 people of (TDP) for MMM, BTM, and CRF due to expire on 31 Talang Petai village. The Estate will carry out a field August 2010. GMO received the extension of the license check to ensure the boundary is accurate and conducted on 25 August 2010. The record is held on the file “Daftar a follow up meeting with the local community on 01 Dokumen Khusus PT Agro Muko”.

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October 2010 at SKE office. The result will be recorded and forwarded to GMO for further action. PT AM development is wholly on Government land (or leased from other parties), which is leased under HGU's TPE: no land disputes. terms and conditions. It was confirmed during interviews with the local community there is no customary land in BTE/SBE: No land disputes. or around the PT AM . It was further confirmed during interviews with the local community that all of the land AMT: No land disputes. belongs to government. Some of the plots were acquired from local communities, following land release PT AM has not acquired any new land for the previous process. There were no disputes during land acquisition 15 years. process.

In several estates, a number of plots of company land PT AM development is 95% on Government land which are occupied by local settlers. A program is in place to is lease under HGU's – see above. take the land back. Records of all negotiations are maintained although all occupations are illegal with Under the KMD scheme PT AM have around 500 ha regards to HGU as the land is legally owned by PT AM. which they manage for the local villagers and assist in a number of ways. This includes low cost loans, undertaking of all agriculture and payment of returns to SBE: some plots of company land are occupied by local the local community. settlers. A program to take the land back is under way as it is legally owned by PT AM. Records of negotiated agreements are available at Medan HO. However, these need to be made available BTE: Had the HGU from the government, however, since on site. In all estates visited, it was confirmed during the planting did not take place at once some part of the interviews with the local community there are no major land was occupied by local people. PT AM has a land disputes within PT AM plantation. program to take back the land by paying compensation for any improvement of the land. Currently Maps are available in appropriate scale showing extent approximately 23 ha inside the boundary have not yet of all land developed under the KMD scheme. These are been compensated, but the “owner” is not willing to available for each agreement within each village. “sell”. This Estate has committed not to plant the land until the owner agrees to sell the land and the proper Copies of all agreements with KMD were available compensation process is carried out. including history of communication and all signed negotiated agreements. TRE: This was initially ä division of TPE, all of compensation record available at TPE. The local people have initial meetings with KMD representative which are minuted. These meetings TPE: Proof of initial land release and any compensation explain to the local people how the system works and paid is held at HO Medan, a copy is available on site. the benefits and any negatives associated with the Records are held on the appropriate file, the last land scheme. release process was carried out in 2005. Criterion 3.1: There is an implemented management Copy of land acquisition process is available in each plan that aims to achieve long-term economic and estate. financial viability.

As described above dispute resolution mechanisms are There is in place a working plan for at least three years – in place and the question of how to deal with new this includes crop projection for up to 10 years, Oil plantings when they arise will be in accordance to Extraction Rate, Cost of Production,. Price forecasts, legislation and the ongoing reconciliation process. financial indicators, includes running mean since inception which includes trend forecasts. The PT AM PT AM developed a generic SOP for dealing with land business plan was available for this assessment. claims “Prosedur Keluh Kesah dengan Pihak Internal & Eksternal” No. 01/HRAD/CIR/10 dated 01 January 2010 There is in place an annual replanting programme which which included a procedure to resolve issues that includes forecasts for the next ten years. This plan is emerge during new plantings. The procedure involved reviewed monthly. Any amendments are to the receiving and extracting relevant documents and, programme are evident. discussion with claimants. If this fails to resolve the issues then they will be referred to court system. Wherever possible PT AM makes attempts to improve practices based on any information on developments and improvements in the industry. Criterion 2.3 – Use of the land for oil palm does not The cost of production is reviewed and compared diminish the legal rights of other users without their against expenditure each year with projects in place for free, prior and informed consent.

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The plan is reviewed on a yearly basis at least. The latest Records of all inspections are maintained with copies review and update was completed in May 2010 . with actions being given to the respective Divisional

Managers. Areas of non-compliance are reported and followed up by the Estate Manager. Criterion 4.1: Operating procedures are appropriately documented and consistently implemented and Records of the results of monitoring of operations is monitored. captured in the monthly progress report (MPL) which is reported and includes all mills, estates and other There are Standard Operating Procedures for the estates support areas. This includes inspections undertaken, from land clearing to harvesting. This is in the form of extraction rates, tonnes per hectare, fertiliser applied, the “blue book” which includes all relevant SOP’s as areas harvested, FFB milled, CPO produced etc. required. This “blue book” is available to all managers and assistants in each estate office. Criterion 4.2: Practices maintain soil fertility at, or Records are maintained of implementation in the form where possible improve soil fertility, to a level that of upkeep records, pruning, fertiliser application, ensures optimal and sustained yield. harvesting method and all pertinent applications of these SOP’s. At least monthly a visual check is made of estates during

routine inspections during field operations. Leaf analysis There are Standard Operating Procedures (SOP’s) in is conducted annually and results are maintained by the place within all operational areas of the mills. They are Agronomy department. This analysis is used to strategically placed in the specific work areas. These determine fertiliser applications for the following year SOP’s include all operational areas from reception to and this includes the type of fertiliser, amount, block and dispatch of CPO. date of placement.

The SOP’s are further supported by routine regular Each estate of PT AM was included in this leaf analysis scheduled preventive maintenance. This is planned and carried out under the Mechanical and Electrical The most recent soil analysis of the plantations was in Engineering divisions to ensure on going production 2009. Records are available for this exercise. This was capability is maintained and that operating machinery is carried out by a recognised authority. Maps have been safe. Any deviation from standard procedures is to be produced indicating soil types on each estate reported and followed up to ensure documented practices are being followed. Any breakdowns, Further Soil Analysis is planned for 2011. stoppages or major services are recorded in both the log books for each area and in the maintenance records. There are records of fertiliser applications for all areas

including amounts and types as determined by There are records maintained of inspections and audits. agronomy based on leaf analysis and soil type. The record of actions taken place is also recorded and available. Inspection logs of Mill operations indicate the Cover crops are in place and checked during visual routine monitoring of performances within each area. inspection for coverage. PT AM also plans to use Land The EMS/QMS system requires that records of Application of POME from both mills in future. EFB is monitoring are kept. E.g. drain and PCD's as well as use also applied. This was the case in all estates visited. of PPE etc - any actions taken such as cleaning these areas is recorded. All palm by-products including fronds, EFB, compost, effluent and expeller are recycled. These are used as The estates are similar to the mills in that scheduled field nutrients and are put in place to improve organic matter inspections take place within an inspection programme. and to substitute or supplement inorganic fertiliser. These are further supported by an Internal Audit Fronds are also used to prevent erosion following Programme. pruning and after harvesting of FFB.

The estate managers carry out regular field inspections to ensure SOP’s are being followed and supervisors issue Criterion 4.3: Practices minimise and control erosion instructions at each morning muster and follow up to and degradation of soils. determine the quality of work and that procedures are being followed. This is further supported by the Director There have been no plantings since 2007 on slopes in of Estates (D-ESD), Senior Manager of Estates (SM-ESD) excess of 25 degrees. There is in fact only a small and Senior Field Manager (SFM), who carry out regular percentage of planting on sloped land throughout PT field inspections which are further supported by the AM. issuing and circulating of an inspection report to the

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There are no fragile soils apart from 200 ha planted on The company has a policy which includes dedicated peat in Tenah Rekah estate (see later) reported in the buffer zones and riparian areas - including establishing most recent soil survey carried out 2009 by a reputable buffers along rivers in accordance with Indonesian laws - specialist. Recent maps are available of all soils in all - a 50 metre buffer for rivers less than 30 metres wide. estates. The rivers and streams in all estates appear very clean and well managed and relatively free from pollution. In steeper areas for most recent plantings properly constructed terracing is used. In former plantings dated It is the policy of PT AM that all buffer zones as from 1998 and earlier planting was completed on areas stipulated by Indonesian law are re-established at re where terraces were not well formed. There is a plan to planting. There are some water courses which need to reform these terraces properly at replanting. be re-established to restore riparian areas at replant. A plan is in place for this. There is in place a road management plan which is completed for each estate. The programme is monitored There are in place practices to prevent run off of including the availability of road plant. The plan includes nutrients and chemicals throughout the plantation. roads throughout each estate. The plan indicates areas Chemical handlers are trained in the disposal of to be graded or have other work completed. Records are chemicals - waste chemicals containers are disposed of kept of the amount of metres maintained in each estate or are re-used for sprayers in field. and when this took place. PT AM has this area in hand and is compliant. A number of wetlands have been set aside as riparian zones and maintained in good condition. There are also The plans include also stoning programmes, drain a number of smaller wet lands set aside as reserves and placement and fixing road camber as well as grading. more signs have now been put in place to indicate the Grading and other road maintenance is completed on status of these areas. schedule however demand following heavy rain or other disruptions always takes precedence. This assessment There is one large lake of some 700 ha which crosses was conducted following recent heavy rains and all into Tanah Rekah estate. PT AM are attempting to keep roads were in surprisingly good condition given the this area in a pristine condition by preserving it and circumstances. preventing any hunting or miss use. However as a large number of banks and approaches are not on PT AM 4.3.3 Observation: There is a recommendation that PT property the placement of HCV and other signs to AM include the inspection of bridges and culverts in prevent miss use may not be enforceable. However the line with Road Maintenance plan following heavy rains. intent is good and would help educate local people who This will ensure any potential wash aways are noted use the area for leisure activities. and rectified prior to becoming an issue with regards to access. An implemented water management plan has now been fully implemented and formalised as required at the pre- audit. Sprayers must follow the spraying guidelines as set out in the Field Standards. These are constantly being PT AM are monitoring mill water use per tonne of FFB – monitored by the supervisors and divisional managers to however only have records going back to July 2007 when ensure pesticide spraying is effective. There was little a water meter was installed - this is the case for both evidence of over spraying of herbicides during this mills. The rate is less than 1:1. assessment. Estate harvest paths are mechanically slashed reducing total sprayed area. PT AM have taken action to ensure use of water does not have an adverse effect on downstream users by 4.3.4 Observation: There is around 200 ha of peat on checking water quality in the lab including checking for Tanah Rekah estate. There are some channels in place e.Coli as well as Ph and Oil and Grease in all however they do not appear to all be within the streams/rivers/water courses which pass through PT AM nominated required depth of between 50-75 CM and property into downstream users which they already need to be reviewed and some more effective water monitor. This is further supported by reports from gates constructed – it is acknowledged that there is a independent approved labs which are completed plan in place to complete this and this will be viewed in monthly for all major water ways running through PT the Continuous Improvement Plan. AM property.

The peat however is much less than 3 metres in depth These water quality tests which monitor river water with the deepest being 1.2 metres. quality both upstream and downstream are carried out regularly and results have indicated that water quality of other users has not been adversely affected. Criterion 4.4: Practices maintain the quality and availability of surface and groundwater. There is no POME land application at the present time with regards to mills in PT AM however if this does take place the application is to be recorded.

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Mill Effluent is treated appropriately and appears 4.5.2 Observation: There is a need to indicate that effective. The records of monitoring of effluent are in monitoring of all IPM components are continually place - testing is now following a controlled monitored – for example of two estates (BTE/TPE) after methodology to ensure results are consistent and are there were no rats for a month monitoring stopped – within allowable legal limits. this should be continued even though numbers are low to ensure the threat does not reappear. Water contamination is avoided for both surface and ground water during normal conditions – during The progress and success of the implantation of the IPM abnormal conditions (that is very heavy rain) it is not are now reported on a regular basis in a formal manner possible to avoid all contamination. to GMO.

PT AM have put in place a controlled contaminated AGRO MUKO are monitoring pesticide toxicity units (a.i. waste area in each estate (B3) for management of all x LD 50 / tonne of FFB). This is recorded from January containers and other pesticide waste, and are keeping 2007. The trend analysis of Glyphosate usage in the early records of containers destroyed and sent to a pesticide period indicated a tendency to increase but has recently pit. PT AM further ensure correct dilution of fertiliser is started to fall. At the same time the use of paraquat is used for field application and monitor ground water to starting to decline and continues to be monitored. ensure there is no contamination from septic tanks. The use of all chemicals is justified and a plan to reduce Control also includes improved and correct storage of usage has been presented. This includes chemicals used, bulk chemicals and fertiliser, control of hydrocarbons to dosages, and frequency of use. The reason for use of a prevent contamination. This is by the provision of bunds, particular pesticide is always recorded on the pesticide spill kits and drip trays. These are adequately controlled application records. This may include herbicide spraying and plans are in place to continually improve this in all of palm circles, chemical weeding and upkeep among areas – only one area was seen to be poorly managed at other reasons. the pre-assessment with evidence of stains etc on the floor. This was corrected by the time of this assessment. Criterion 4.6: Agrochemicals are used in a way that does not endanger health or the environment. There is Criterion 4.5: Pests, diseases, weeds and invasive no prophylactic use of pesticides, except in specific introduced species are effectively managed using situations identified in national Best Practice appropriate Integrated Pest Management (IPM) guidelines. Where agrochemicals are used that are techniques. categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam The Integrated Pest Management plan has been Conventions, growers are actively seeking to identify documented for all estates – this includes all Integrated alternatives and this is documented. Pest management techniques used in each estate. This includes use of barn owls for rat control, planting of There is evidence in place with regards to PT AM’s beneficial plants as well as use of pesticides. PT AM are documented justification for all Agrochemical use. There planning to minimise the use of chemicals and pesticides is a register which records product use, when required, by these biological methods. amounts to be used and frequency of use. Agrochemicals are used to target various pests and The main issue in the estates of PT AM is the number of diseases. It is demonstrated that only approved wild pigs in the area. These are numerous and there is chemicals are used. The PMP has documented what much evidence of the damage pigs do to both immature chemicals are used and where and in what situation. It palms and actual ground. The IPM includes traditional stipulates the maximum dose possible for each hunting of these pigs by local people. The numbers application. There are also plans in place to gradually captured in each estate per month are registered to reduce the use of Agrochemicals. There are time frames determine if eradication is effective. in place in the IPM whereby chemical use is reduced. All chemicals have to be approved for use in line with the An IPM Program is documented for relevant pests that application plan. set out techniques or chemicals to be used, locations and timeframe for implementation. All estates are recording pesticide use including active ingredients used, area treated, amounts used per ha and There are training records for training of staff in regards number of applications for each area. to IPM however and are formally recorded on all occasions. PT AM has a register of approved and registered agro chemicals – this has been distributed to each estate and There have been no large/major infestations of oryctes management are instructed that they are not allowed to at this stage. This will be monitored and is ongoing and use chemicals not on this list. There were no agro progress continues to be monitored through the IPM. chemicals being used which were not on this register during this assessment.

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Records are in place to clearly demonstrate that all PT AM has a policy in place which prevents pregnant or chemicals applied are by persons who have received breastfeeding women from working with pesticides and adequate training. This is mainly for the pesticide it is enforced. applicators. There is evidence that all pesticide handlers have received pesticide application training and records There is no aerial spraying of pesticides. were available in all estates. Records of training are kept in each estate of the The training course for the handling of chemical following: concentrates is conducted by the pesticide supplier. • Pesticide Mixers Records of this training are available. All pesticide • Pesticide Sprayers mixers are adequately trained and are aware of the requirements when handling hazardous chemicals. This These records are kept in each estate office. The training includes use of PPE, disposal of containers, storage of data is also maintained to show what the training chemicals and handling of any spills. covered.

PPE for sprayer is identified in Planting Manual as is PPE PPE for sprayers is supplied and use demonstrated in the for pesticide mixers. Correct PPE is provided and is used “blue book” and further demonstrated in training correctly by operators. material. The company supplies two sets of overalls so that one can always be considered clean. Overalls are At the pre-audit some fertiliser sheds had poor washed at the pesticide mixing areas in specially ventilation and this could affect workers health – plans constructed wash areas so that sprayers and mixers do are in place to improve ventilation where required as not need to take them home and therefore the risk of well as putting in practices that allow workers to cross contamination with family members is eliminated. ventilate closed areas before entering and commencing work. A number of improvements have already been Material Safety Data Sheets (MSDS) are obtained for all made since the pre-audit and ventilation has improved chemicals used and are available at the areas of mixing. overall. All fertilisers are now stocked with protection No concentrates are taken into the field as all spray from the ground and have space between the stacks and solutions are pre- mixed in a designated area. the wall to allow further ventilation. MSDS are translated into the local language. Waste materials are handled in accordance with applicable laws and are stored as per regulations in Storage of chemicals is in locked areas with limited secure areas. Empty pesticide containers can be re-used access. All areas where chemicals are stored appear to by sprayers once they have been properly treated and be adequately ventilated through cross flow ventilation. triple rinsed. Any empty pesticide containers not re-used This will be further improved as PT AM has designed a are stored in the designated storage area as prescribed standardised pesticide store which is to be in place in by Government regulations – this is the B3 store. each estate.

All chemicals being used are properly labelled. Criterion 4.7: An occupational health and safety plan is There is a list provided by the Indonesian Government of documented, effectively communicated and both allowable and prohibited chemicals - this is known implemented. as the green book and PT AM have a copy of this publication. There is a documented Occupational Safety and Health plan in place in all the following areas: Reduction in the use of paraquat is part of the IPM. • Estates However at this stage Paraquat is still used in immature • Mills areas and amounts monitored as there is no alternative • Workshops available. • Clinics • Stores There are health checks provided for pesticide handlers - this is conducted at least annually. Records are All areas have implemented and monitor the maintained by the company Doctor of all tests. Records Occupational Safety and Health plan to a high standard. of such health check-ups were sighted. This has improved considerably since the pre-audit. Control of Occupational Safety and Health has improved 4.6.6 Observation: As health checks for workers are not throughout each operational area and awareness of carried out for pesticide handlers until they have been safety and health requirements has risen considerably in employed for 1 year – records should indicate the start this period. Management and workers are to be date for each pesticide handler tested to confirm this is commended on reaching this high level of compliance. in place effectively. A responsible OHS person has been identified for PT AM and for each estate and each mill – these people are identified to all staff and workers.

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There are regular safety meetings held in all operational 4.7.5 Observation: Risk control requires improvement areas – they are using the same agenda for each as a number of unsafe acts and Unsafe Conditions were meeting – and includes discussion of any noted including but not limited to the following: accidents/incidents as well as any potential issues. A workplace health and safety inspection takes place • All pesticide mixers to be included in health before any meetings to ensure meetings are worthwhile checks and meaningful. Any requirements are made known to • One stairway in one mill was blocked workers during pre-shift musters and records are kept in • Large hole in drain cover which could cause the assistants diaries. serious injury • Contractors on housing project not using PPE All workers are covered by Accident Insurance – this is company policy and a legal requirement. In many areas since the pre assessment a number of improvements in regards to safety have been made. Not Regular Health checks are performed of workers who least the use of Tyre Cages to protect workers from handled pesticides and records are maintained by the exploding tyres and rims and also the use of flash back company doctor – these checks are carried out at least arrestors on gas bottles when welding.. See positive annually – records of health checks have been sighted. comments below:

It appears all operations where health and safety is an • Chemical mixing areas were clean, secure and well issue have been risk assessed and procedures and ventilated. They had adequate signage and well actions documented and implemented to address the stocked first aid kits. identified issues. All precautions attached to products • Health checks are undertaken by the Company are being properly observed and applied to the workers. Doctor for sprayers and other labourers in high risk The risk assessment matrix is consistently applied across jobs. This includes all employees who are involved in the board and high risk issues are clearly identified and the mixing of chemicals. not mixed in with less risky areas. Management and all workers are involved in work place safety. The method • The incidence of HIV is low and awareness activities of risk /hazard control is documented applying the are undertaken by polyclinic staff. hierarchy of control. This appears to be effective. • Medical waste from the polyclinics is placed in separate, clearly labelled bins (sharps are separated Procedures and plans are in place to address all from other waste) and disposed of by government operations. These have been distributed to all areas and medical authorities on a periodic basis. Records are to the respective managers and supervisors. All hazard maintained recording the disposal of waste. and risk assessments have been updated at least • The incidence of different types of illness is annually and at times more often. systematically recorded in each polyclinic and

aggregated for PT Agro Muko. A summary of the Employees are made aware of precautions attached to results are available on the Agro Muko website, refer all products including hazardous substances, plant, http://www.tolantiga.co.id/v1/?page_id=320 . machinery, equipment, tools, and vehicles through provision of MSDS, training and experience. • There is a high level of cooperation between government health officials and the polyclinics (for Therefore all potentially hazardous operations, such as example, government officials visit each polyclinic pesticide application, land preparation, harvesting has each month to immunise children). been included in hazard/risk assessments. • Malaria remains a health issue in Muko Muko. PT AM undertakes fogging in the emplacements. Bed Therefore overall risk control has improved markedly in nets have been issued by government in some if not the following areas highlighted at the pre-audit. This is all emplacements. an example only and is not complete. • Each emplacement sorts green waste from other

household rubbish. Waste collection is undertaken 2 • All sprayers now using appropriate PPE to 3 times per week. • Correct signage in place

• Chain guards missing now in place There is evidence in place that all workers have been • No guard rails missing in Mills adequately trained in safe working practices as complete • The company supplies 2 pair of boots (rubber) records are in place for all training. • Signage now being followed

• Welders now using protection There are in place emergency procedures and these are • Gas bottles restrained mainly with regards to fires and evacuation drills. There • Open drains covered are phone numbers listed in each estate and mill of emergency contact numbers. Also includes training in use of spill kits. It was noted that the estates are also Improvement is such that only a few issues were noted undertaking fire emergency accident drills and records and an observation made: are being kept.

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and safety aspects, health and hygiene promotion, etc. The results of any emergency drills are evaluated to In addition to direct company employees (commonly ensure that activities are effective. referred to as estate or mill labour ) the morning muster includes the employees of many of the contractors (who The control and management of fire extinguishers is for example, work in the nursery or undertake weeding, excellent throughout all areas. Fire pumps start and are commonly referred to as free labour ). immediately when tested and all fire hydrants tested were operational with impressive water pressure The field/mill assistants are required to provide maintained. induction training for new staff. The induction includes information on company policies and regulations. Many employees have been trained in the use of Fire Following induction training new staff are placed under Fighting equipment. Records are maintained of all close supervision of foremen until the foreman are Emergency response training. satisfied with their competency.

First Aid equipment is largely available in all operational It appears that training is supplied to all employees and areas including first aid kits which are strategically contractors when appropriate and records of this placed and subject to regular inspection to ensure that training are maintained. they are adequately stocked. There are formal training programmes in place as well as There is evidence of workers being trained in First Aid in there being a regular assessment of training needs for all all areas – records are available of first aid training by operations. This formal training requirements and outside body – training certificates were sighted. assessment of need takes place in plantations and mills.

PT AM ensure that First Aid trained workers are known A training programme is in place for 2010 for all areas. to all staff by placing photographs of first aiders in work areas. They have also introduced a system whereby Specialised training courses are also planned as the need trained First Aiders are also identified by wearing an arises and this includes group or in house training. Some emblem on shirts which shows a recognised First Aid training is carried out on demand. logo. There are also formal training records for all supervisory There are in place records of all accidents which are staff up to the level of Senior management. This includes reported – there is evidence of work accidents being recording of external courses attended or skills attained fully investigated to prevent recurrence. A report is – these records are maintained by the Human Resources prepared and forwarded to the relevant Government & Administration Department (HRAD). department of all accidents on a monthly basis. There are training records in place at each operational site recording skills and training and these were sighted Criterion 4.8: All staff, workers, smallholders and at all estates and mills visited as well as other areas such contractors are appropriately trained. as workshops and clinics.

PT AM prepares an annual training program which Some of these records are in the form of attendance at includes both internal and external training. Internal training which is given in the field or formal skills such as training is generally identified and delivered by the plant operators, driver’s licenses, boiler operators and estate/mill managers and field/mill assistants, while Red Cross First Aid. external training is generally prepared and organised by the HR Manager, in consultation with Head Office (Medan), including the Company Doctor, and Criterion 5.1: Aspects of plantation and mill government officials, as well as the Department of management, including replanting, that have Manpower and Transmigration. Internal training focuses environmental impacts are identified and plans to on basic skills and safety. External training focuses on a mitigate the negative impacts and promote the positive wider range of health, safety and labour topics, including ones are made, implemented and monitored to for example, safe handling of chemicals. demonstrate continuous improvement.

All internal environmental impact assessments have In addition to first aid and safety training provided to been carried when and where appropriate. Records of all health staff (nursing officers and midwives), the impact assessments carried out are readily available. The Company Doctor meets with health staff twice a year latest review was undertaken in early September 2010 and provides information and training on new medicines and will be again reviewed at least annually. This was or medical practices. part of PT AM EMS programme for mills which were audited for certification in April 2010. In addition to periodic training, the morning muster is All environmental impact assessments (AMDAL, used as an opportunity to provide awareness to UKL/UPL) have been carried out and approved by employees on topics such as company policies, health appropriate government body. In 2005, the company

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 17 took a step to unite several estates into one area during this assessment. The improvement in management and prepared the AMDAL document to appearance of the area is considerable. cover overall operating units (oil palm mills and their supply base and rubber mill and rubber estate), which 5.1.1 Observation: There are Environmental impact was approved by Government of Bengkulu Province on assessments carried out for all operational areas. 14 November 2005 (letter No. 425/2005). Inspection However some impacts were not documented or found that a copy of the report was available in each assessed including impacts on flora and fauna, sacred operating unit. All environmental impact assessments sites, contractors. cover both on site and off site activities. All environmental impact assessments cover both on site Details of chronology on the environmental document and off site activities. Whenever there are changes made were readily available. Information on chronology of to operations and changed impacts are updated to previous environmental documents such as AMDAL, reflect these changes UKL/UPL was also available. Impact assessments have included all environmental Initially there are two environmental documents for PT components: AM properties.  Building new roads, processing mills or other (1) Studi Evaluasi Lingkungan (SEL) for Oil Palm, Rubber, infrastructure. and Cacao Plantation and its processing unit of PT  Putting in drainage or irrigation systems. Bengkulu Plantation (Tanah Rekah Project) approved by Department of Agriculture on 06 July 1992  Replanting or expansion of planting area. (RC.220/986/B/VII/92). This SEL covers Tanah Rekah  Disposal of mill effluents (see criterion 4.4). Estate (2,244.36 ha) — (1988 – 2003); Sei Jerinjing (2,198.33 ha) and Lubuk Pinang Estate (1,336.81 ha) are currently divided into three estate: Sei Betung Estate; There are regular reports with regards to environmental Talang Petai Estate (1997-2006), and Sei Kiang (Estate management as required by regulatory authorities. This 1996 – 2007). includes the RKL-RPL reports which are submitted 3 monthly. There is also reporting and testing smoke (2) SEL of PT AM (Muko-Muko Estate), for Oil Palm, emissions on a 6 monthly basis. Rubber, and Cacao Plantation and its processing unit totalling 14,755 ha on 24 September 1999 No. Inspection of the document found that GMO has RC.220/1601/B/IX/92, Department of Agriculture, prepared and submitted a report to the appropriate currently divided into Muko-Muko Estate 3,731 ha government agency on 15 September 2010. Any (planting 1988 – 2007), Talang Petai Estate (2,270 ha – revisions are evident. The next report will be due on 15 planting 1997 – 2006), Air Bikut Estate (1,140 ha planted December 2010. 1991 – 1998), and Bunga Tanjung Estate 2,903 ha (planting 1998 – 2006). 5.1.2 Observation: PT AM to ensure that when mill or estates submit RKL/RPL reports that all sections are Following company expansion plans from initial planting completed. of 11,830 ha and conversion of crops from cacao as covered by the two SELs into 22,928 hectare of estate, a new revised AMDAL was prepared in replacement for Criterion 5.2: The status of rare, threatened or both SEL’s in 2005. Company has an approved AMDAL endangered species and high conservation value document to cover overall operating units (oil palm mills habitats if any, that exist in the plantation or that could and their supply base and rubber mill and rubber be affected by plantation or mill management, shall be estate), approved by Government of Bengkulu Province identified and their conservation taken into account in on 14 November 2005 (letter No. 425/2005). management plans and operations.

PT Agro Muko also hold an approved UKL/UPL document A survey of PT AM has been undertaken. A number of for Air Buluh Estate (2,500 ha) approved on 16 January HCV areas have been identified however there have 1999 (planting year 1998 – 2007) by Bupati of Bengkulu been no rare, threatened or endangered species Utara and UKL/UPL for the Bulking station (AMTT) identified. However some protected species were approved by BPDLD . There are three identified (see below). environmental documents in effect, that are an approved AMDAL document and a separated UKL/UPL HCV assessment of PT AM has been undertaken by documents for Sungai Buluh Estate and AMTT. appropriately qualified and experienced expert from Yayasan Sawit Berkelanjutan (Indonesia Sustainable Improved control was observed with regards to the Palm Oil Foundation – ISPO Foundation) using the activities of the contractors working at the Quarry in guidance of Indonesia HCV Toolkit 2008 to monitor the Bunga Tanjung Estate. This included control of possible extent of HCV inside the estates as well as area hydrocarbons and the management of waste. The area adjacent to it. All HCV’s are mapped and identified. has been cleaned up and there is no waste around this

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ISPO Foundation concluded that PT AM has already set aside conservation areas of a total of 2,304.9 ha 5.2.5 Minor NCR. There is no regular monitoring of HCV consisting of natural vegetation in between palm areas in each estate by the delegated conservation planting to provide habitat and corridors for wildlife. officers. Inspection of the buffer zone and conservation During the assessment HCV 1 identified in PTAM area found some spots of Mucuna bracteata invading totalling an area of 2,169.47 ha (9.47%) in all estates, the buffer zone and conservation area. Review of the HCV 2 of 200.78 ha (0.88%) in SBE, SKGE, and BTE; HCV 3 monitoring checklist found that the Mucuna bracteata of 494.73 ha (2.16%) in TRE; HCV 4 of 1,529.96 ha was not considered as a threat to buffer zone and (6.68%) in TRE, SBE, SKGE, TPE, BTE, ABKE, and ABE; no conservation area; as such it was not monitored. HCV 5, and 1.56 ha of HCV 6 in TRE, MME, SBE, SKGE, ABKE, and ABE. Criterion 5.3: Waste is reduced recycled, re-used and Indications from the report (as above) indicates that a disposed of in an environmentally and socially number of HCV areas were identified including HCV 1, 2, responsible manner. 3, 4 and 6 in some Estates. All HCV are mapped and identified. The map is detailed and supported by a There is a waste management plan in place and it is management plan developed by the Estate. The HCV current. There are formal rubbish collections in all areas report identified HCV areas and the proposed at least weekly. This is monitored to make sure it management plan. happens as planned. The waste management plan is covered in the EMS and includes pesticide contaminated The assessment also found 32 species of birds 7 of them waste. are protected species, 18 mammals (7 of them are protected species), and 9 reptiles (1 of them is protected There are plans in place to recycle where possible. species). Including batteries, aluminium, waste oil, chemical containers, half drum is used for spill kits and rubbish PT AM established the conservation status, legal bins. Green waste is recycled wherever possible. protection, population status and habitat requirements Recycling includes information as to types of wastes, of rare, threatened or endangered species that could be prohibited wastes, recycling guides, re-use of nutrients, significantly affected by the grower or miller. management of effluent ponds, increasing the efficiency of mill extraction etc. HCV areas identified are sign posted and this is effective and more signs are being erected to clearly identify All waste streams have been identified in the waste areas as HCV’s – there are signs on all boundaries of HCV management plan and they are now handled stating the type of HCV and status. Measures taken appropriately in all areas. Waste control at present is currently include the exclusion of HCV’s from plantation compliant with household waste being controlled activities. There are already sign posts in place warning adequately in all emplacements. outsiders that hunting, logging and fire use are prohibited and inform others about the HCV areas. The The following waste streams have been identified and signs are informative about what is designated as HCV. are controlled through the EMS:

The management of sensitive HCV areas including some • Office Waste – segregated, recycled where historical grave sites is well controlled although not possible with rest to the landfill. identified in the environmental aspects/impact register. • Household waste – segregated, recycled where The management are aware of these areas and need to possible with the rest to the landfill. Drainage add them to the environmental aspects register. from housing, waste to landfill. PT AM has established appropriate measures to protect • Human waste – Septic Mill Effluent – through riparian reserves, such as conducted awareness training effluent ponds and land application (none at for “conservation cadets”, socialization to field workers, present). and regular inspection by security to prevent hunting • Fibre – Fuel for furnace. and disturbance. • EFB – Fertiliser. • Oils and Hydrocarbons (including containers) HCV management plans are available in each estate. to Hydrocarbon pit. • Pesticides (including containers which are PT AM have appointed a Manager who amongst other triple rinsed, punctured and disposed of at a responsibilities is responsible for RSPO- and also have in pesticide pit. place a dedicated Conservation auxiliaries team which • Pesticide spills – cleaned with spill kits used supports the implementation of RSPO P&C kits sent to pesticide pit. requirements. • Hydrocarbon spills treated with sawdust. Burnt However no officer is yet nominated to monitor the plan in boiler. • and activities to manage HCV specifically. Overall Estate Used oil – recycled, Stored in B3 storage. managers are responsible for ensuring the Estate protects HCVs in their respective estates.

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The control of hydrocarbons has been addressed elsewhere in this report. The collection of household There has not been any sanitary burning at PT AM at this waste is well controlled. Landfill sites are in place and stage. improvement has been made in the management of these areas since the pre-audit. There was no sighting of the burning of domestic waste by workers and families of PT AM during this All Land fill sites have no odour and waste is within the assessment. Burning of domestic waste is against pit and not spreading. Most are fenced and could company policy and is strictly monitored to ensure this consider fencing all to restrict access to authorised remains the case and is part of the inspection regime. people only. PT AM has a procedure in place with regards to land Landfill sites are now included in monthly estate burning emergencies and records are maintained of inspections. Waste collectors have been trained to be training in response to fire. Records are kept if at any more efficient in the use of the landfills – for example fill time PT AM has to respond to illegal fires or outbreaks. from one end and compact as they go rather than fill in all areas and also exclude green waste from landfills. Fire Extinguishers are regularly checked and inspected and are widely available in all areas and are appropriate. PT AM also have in place treatment system for POME in All fire hydrants checked worked effectively. There is the form of effluent ponds. evidence of regular routine checking of all fire fighting equipment. Records of the disposal of pesticide drums are kept.

Medical waste from clinics is managed properly. All Criterion 5.6: Plans to reduce pollution and emissions, clinic officers said the clinic waste was collected by including greenhouse gases are developed, regular waste collector. In all clinics the clinical waste is implemented and monitored. well managed. Assessments have been carried out on all recognised polluting activities and include gas and smoke emissions, Criterion 5.4: Efficiency of energy use and use of particulate and soot emissions, effluent control, renewable energy is maximised. treatment and discharge. Any significant pollutants and emissions have been identified. There is a plan in place PT AM uses fibre which powers the boiler which to reduce pollution – this is included in the produces steam which drives the turbine which electrify environmental aspects/impacts register. - the use of renewable energy in this case would be almost 90% under normal operating conditions, AGRO Stack emissions are measured by a 6 monthly check as MUKO provides records of both monitoring of kilowatt required by Government regulations – evidence of these hours per tonne of palm product and Kilogram of steam inspections is available for both mills. per tonne FFB. PT AM also identified POME which is used for land A large number of sheds including pesticide and application (although not at the present time) and BOD fertilisers stores are relying on natural light (translucent is monitored. Records indicate the results are well below roof panels) and therefore use of electricity for lighting is thresholds as set by government. reduced. This is now in virtually every enclosed storage area which has considerable roof areas. PT AM also monitor any water courses which could be affected by operations to ensure there are no pollution PT AM monitors the use of non-renewable energy effects from the operations of the mill. (diesel) and this is monitored in the form of data which records use of diesel per tonne of FFB. PT AM are also checking the purity of drinking water including testing for e.coli and faecal coli forms. These The fuel used for all operations is measured and are completed at an outside lab and confirm ongoing monitored with a view to reducing use of non-renewable water quality is acceptable. energy. The strategies to reduce pollution are documented in the EMS documentation. Records are in place for all reports which are received from analysis at independent Criterion 5.5: Use of fire for waste disposal and for labs. Results indicate if PT AM are reducing pollution and preparing land for replanting is avoided except in any emissions are within allowable limits. specific situation, as identified in the ASEAN guidelines or other regional best practice.

Criterion 6.1: Aspects of plantation and mill There is no burning in new developments or at management, including replanting, that have social replanting. Burning is not allowed by PT AM and there is impacts are identified in a participatory way and plans no evidence of burning. to mitigate the negative impacts and promote the

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 20 positive ones are made, implemented and monitored, to demonstrate continuous improvement. The company has budgeted CD and CSR activities without any programmatic plan/advanced plan of Social impact assessments are undertaken by both PT activities. All CD/CSR activities are dependent on the AM and independent consultants depending on the community requests. Most of the requests related to situation. Items considered which could have potential the road improvement, contribution to schools, social impacts include: Building of new roads, new mills, mosques/churches, and village administration facilities. planting expansions, mill effluent disposal and clearing of natural vegetation. Criterion 6.2: There are open and transparent methods In all EIA documents the major emphasis is on the for communication and consultation between growers physical/environment impact such as soil, air, water, and/or millers, local communities and other affected or wastes, fauna, flora and human activities). interested parties.

PT AM has an approved AMDAL document to cover PT AM has documented a procedure of communication overall operating units (oil palm mills and their supply with internal and external stakeholders on “Prosedur base and rubber mill and rubber estate), approved by Keluh Kesah dengan Pihak Internal” (SOP/025/HRA date Government of Bengkulu Province on 14 November 23 December 2009) for all operating unit within PT AM 2005 (letter No. 425/2005). The AMDAL also sufficiently that has been socialized to workers and “Prosedur Keluh covers social aspects, including both negative and Kesah dengan Pihak Eksternal” available publicly in positive impacts. company website http://www.tolantiga.co.id/v1/wp- content/uploads/2010/03/Prosedur-Keluh-Kesah-Pihak- All mills and estates have a copy of an approved revised Eksternal.pdf . Interviews with local communities AMDAL document and UKL/UPL documents depending confirmed effective communication with PT AM. on the requirement of each operating unit. In May 2010, Inspection of PT AM documents confirmed that all PT AM in line with the RSPO certification preparation, operating units have already socialized the procedures has supplemented the AMDAL and UKL/UPL information and maintained a record of communication with with regards to negative and positive impacts with external stakeholders, including actions taken in additional Social Impact Assessment carried out response to input from stakeholders. These records between 15 April and 5 May 2010 by ISPO foundation were available at audit for the Social Auditor. which included consultation with the local community in form of Focused Group Discussion (FGD) with Inspection of PT AM record found prompt responses to stakeholders including government representatives, the aspirations of the local community. For example, in mills and estates, and surrounding local communities (38 25 January 2010, people of Taruntung village raised villages overall). It was confirmed with local verbal complaints against MMM. During interview it was communities that they were involved during the AMDAL revealed there was a complaint against the company in preparation. relation to Muko-Muko overflow of mill effluents polluting the bathing area of local Teruntung village, The Management of PT AM has taken into account a around 1.2 km away from the pond outlet. PT AM number of social impacts and these include: Access and responded by providing free medical treatment for the use rights, economics, subsistence activities, cultural local people. Inspection of the laboratory tests values, Health and education. These have been confirmed all applicable indicator results are compliant thoroughly documented through the Social Impact with local government requirements. Assessments. Further interviews found that the problem has emerged The criteria specifically required that unit’s management since the government water supply to the village was review documented environmental and social impacts. broken and people were forced to bathe in the river. It Currently all estates have prepared RKL (environmental is seems that main reason behind the complaint is for management plan and UPL (environmental monitoring company to provide domestic water supply to plan). These documents are applied as environmental supplement unreliable government supply, and not impact assessment (EIA). because company polluted their river. PT AM responded on 19 February 2010. Record held on file “Keluh Kesah”. Regular RKL/RPL reports are available. PT AM submit BTE: socialization has been carried out on 26 September Environmental Monitoring Report / Environmental 2010, attended by 16 village heads, LPPM, informal Management (RKL/RPL) every three months. Inspection leaders, KMD and workers union, records held on file of the document found the GMO has prepared and “prosedur keluh kesah”. submitted the report to appropriate government agency on 15 September 2010. Any revisions are evident. The All stakeholders consulted during the audit commented next report will be due on 15 December 2010. favourably on their relationship with PT AM. The labour union, emplacement residents, KMD committees and In all EIA documentation the major emphasis is on the company employees indicated that they had good access physical/environment impact such as soil, air, water, to managers when they wished to raise or discuss issues, wastes, fauna, flora and human activities. and generally received a quick response. The only

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 21 negative comment, which was made by only one kept in all estate and mill offices. Items are dealt with on employee, concerned a delayed response in dealing with a local level unless they cannot be resolved and then an apparent commitment to review the salary levels of referred to more Senior Management for further polyclinic staff. consideration.

Records are kept of all community requests/proposals of The procedure includes land dispute handling activities and management unit responses which include procedures. An external grievance procedure was follow up to ensure actions are complete. The responses issued on 23 December 2009 and is available to the to the community responses/requests need to be public in http://www.tolantiga.co.id/v1/wp-content/ consistent throughout estates. uploads/2010/03/Prosedur-Keluh-Kesah-Pihak-Eksterna lpdf . 6.2.3 Observation: When any grievance or request for assistance is resolved to the satisfaction of both parties Another procedure dealing with internal stakeholders the records in place should be updated accordingly. has also been issued. Inspection of all operating units confirmed the procedure is already in effect and has All community/stakeholders communication is been socialized to staff and workers. Interviews with responded to by Estate Managers - who nominates a workers and external stakeholders indicated responsible person to undertake the task if he is not understanding of grievance process. Each operating unit available. is responsible for the record keeping of grievances and outcomes. MMM: A stakeholder list was prepared on 03 March 2010, to include local government body, local Any disputes which are resolved and are agreed are community leaders, workers union, contractors, and signed off by the grieving party. suppliers. All are complete with contact address and phone numbers “Daftar Pemangku Kepentingan/Stakeholders”. 6.3.3 Observation: TRE: Complaints on housing raised by harvesters was not recorded in the log book, of file TRE: The stakeholder list was updated on 05 August “keluh kesah”. 2010 included local government body, local community leaders, workers union, contractors, suppliers, and NGO. TPE: “Rekaman Komplain, Baik Internal / Eksternal”. On SKE 19 May 2010, a complaint was raised by the transport contractors who were unable to transport FFB from 17 TPE: There is a need to add NGO and government May 2010. The problem was solved immediately on 19 representatives such as agriculture office, forestry office, May 2010. etc. to the stakeholder list. BTE: “Buku Keluh Kesah”, there is a case where the local BTE: There is a full list of stakeholders including local farmers of Pondok Baru village, who owned land in the government body, local community leaders, workers vicinity of the estate, in Block AA1 OP 2001 Divisi F1 had union, contractors, suppliers, and NGO; updated on 01 used company access road without permission. PT AM August 2010. “Daftar Pemangku Kepentingan”. dug a channel to prevent unauthorized persons from entering its premises on 22 September 2010. SBE: The stakeholder list was updated on 01 September 2010. On 24 September 2010 four persons complained to the estate. A meeting was then held between the villagers 6.2.2. Observation: There is a list of stakeholders, and estate on 25 September 2010. During the meeting it which is amended as required when new stakeholders was agreed that company will install and lock the are introduced, or others leave. While most of the nominated gate. PT AM will give access to authorised operating units have prepared a complete list of persons who are to report to security who will give external stakeholders, such as local government body, permission to enter if appropriate. Records are held on local community leaders, workers union, contractors, file “Buku Keluh Kesah”. suppliers, and NGO, however with several operating units a number of stakeholders were not on the list. SBE: There have been no complaints from external stakeholders. Internal stakeholders made a complaint Criterion 6.3: There is a mutually agreed and on 15 February 2010 regarding a broken genset. SBE documented system for dealing with complaints and responded on 16 February 2010 by fixing the genset. grievances, which is implemented and accepted by all “Buku Rekaman Komplain”. parties. PT AM has a procedure “Prosedur Tata Cara Perolehan Hak atas Tanah”. The procedure requires involvement A procedure is available for handling complaints. of local communities and government officials for Records of the handling of complaints is documented identification and assessment for compensation and and managed. Each unit manager is responsible for the witnessing payment. Information on compensation is management of complaints. There is a documented publicly available. system aimed to resolve disputes. A grievance book is

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Criterion 6.4: Any negotiations concerning compensation for loss of legal or customary rights are To enhance the transparency of the KMD program, PT dealt with through a documented system that enables AM is publicising the payments to all KMD committees in indigenous peoples, local communities and other a local newspaper, and in all future agreements, will stakeholders to express their views through their own stipulate that regular reports must be submitted to PT representative institutions. AM summarising expenditure from the KMD account.

Records of people identified and entitled to compensation are in place. Records of all compensation Criterion 6.5: Pay and conditions for employees and for issues are retained. The process and outcome of any employees of contractors always meet at least legal or negotiated agreements and compensation claims are industry minimum standards and are sufficient to documented and publicly available. However records will provide decent living wages. not be made publicly available unless agreed by affected parties. The outcomes to any settlements are not made PT AM has approximately 100 staff (managers and other public although information quickly becomes known. senior positions) and 2,200 direct employees. 2 Pay rates for estate/mill employees are agreed to annually in Although PT AM is not acquiring or utilising land which is consultation with the labour union, after considering the legally or customary owned by other entities, it is minimum wage set by government. The minimum wage planting oil palm on village land for the benefit of the is currently R.780, 000/month (approximately US$88). PT village. The Kebun Masyarakat Desa (KMD) or mini- AM has a basic wage of R.840, 000/month (US$94), but estate program is one in which PT AM establishes and often adds overtime and includes the provision of a manages a 10 to 15 hectare mini-estate on village land range of other benefits (housing, water, electricity, etc.). for the benefit of the village. At present, the KMD Over the past three years PT AM has increased the basic income greatly surpasses other sources of income wage from R.732, 000 (2008) to R.780, 000 (2009) to available to the village. R.840, 000 (2010). This represents an increase of 6.6% and 7.7% respectively. 1 While the land is usually provided by the village , all inputs and management are provided by PT AM, Employment conditions are specified in the Perjanjian although the inputs are recorded and valued and a debt Kerja Bersama (PKB) or collective labour agreement, incurred (although only ‘on paper’). Once the palms which is again finalised in consultation with the labour commence production, a proportion of the value of FFB union and reviewed every second year. produced is deducted from the outstanding debt (usually 15% of the value of FFB each month) while the GMO advised pay rates every new fiscal year to every remaining value of FFB produced is paid to the village. operating unit in accordance to the regional minimum Each participating village establishes a committee to wage. The company is applying The Decision of manage the KMD and establishes a bank account in their Minimum Wage set by Provincial Government. name. Company and Serikat Pekerja Agro Mandiri (SPAM) later held meetings to negotiate minimum wages. As per 01 The first KMD site was established in 2001, and of the 51 March 2010, it was agreed that the minimum wage established to date, 12 have repaid the initial debt, 20 agreed is IDR 780.000 for daily workers (or 31,200 per are repaying their debt, and 6 are yet to commence day, 4,457 per hour and 17,828 per four hours). Workers production. In addition, PT AM has entered agreements are advised verbally of the daily or piece rate at time of or has commenced discussions with another 21 villages hiring. When a daily rated person moves to permanent for additional mini estates. This will bring the total KMD employment, pay rates are advised in a letter of villages to 72 (or around 48% of villages in Muko Muko appointment. Staffs are similarly advised of salary rates sub-district). Not surprisingly, the KMD program is now in letters of appointment. All new hires are provided very popular and PT AM regularly receives requests for with a copy of their employment contract. Health and new or expanded sites. safety is also documented. Housing and public facilities condition has been documented well. Payment and The villages appear to be using the benefits for a range conditions include - working hours, deductions, of purposes: paying the salaries of teachers, improving overtime, sickness, holiday entitlement, maternity leave, roads, buying land on which to build public dismissal reasons, period of notice and these were facilities/officers, and building or renovating mosques or viewed at audit and were clearly indicated in Collective other public buildings. Labour Agreement (CLA).

1 PT Agro Muko purchased land on which to establish 2 Contractors are also used to provide labour for a range 13 oil palm blocks under the KMD program in 2010, but of services on the estates, including for example, nursery this practice will be discontinued in favour of the village operations, weeding, fertilizer application, emplacement providing the land. The primary reason for buying land in upkeep and housing maintenance. The employees of 2010 was the problem that villages had in identifying a these contractors are referred to as ‘free labour’ rather suitable, contiguous area in which to plant oil palm. than estate or mill labour, and number around 1,800.

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Each estate/mill emplacement has a regular Wage levels exceed the minimum government maintenance program (generally targeting around 1/3 of requirement. In addition, PT AM provides a range of the houses each year). Other requests for more additional benefits, free of charge, including housing and immediate repairs are made to the foreman and passed utilities (water, electricity and garbage collection), onto the estate/mill managers. The response to these medical support, a kindergarten in each estate/mill, and requests are said to be adequate. school buses for children to get to and from primary and secondary school. PT AM provided SPAM with a loan of approximately R1.1 billion. While the loan is to be repaid over a 20 year While salaries are paid into bank accounts, pay slips are period, it has been used to help SPAM provide services provided to each employee every fortnight. Pay slips are to its members. This includes the establishment of the generated by each estate/mill and provide adequate Koperasi Serba Usaha – Agro Muko (a cooperative run by detail, including the basic wage, the value of rice the labour union). The Koperasi buys goods in bulk and provided (as required by law), overtime and any other sells to the members at comparably low prices. In allowances, tax and any other deductions, and the net addition, the Koperasi maintains a schedule of visits to pay. Workers interviewed said that the pay slips were all estate/mill emplacements to sell the goods (avoiding clear and easy to understand. Furthermore, a local bank the need to travel to buy store goods), and members can visits each estate/mill every fortnight to enable deduct the cost of goods from their salary for the next employees to withdraw some cash, as needed. fortnight. A receipt for all sales is printed electronically and provided to the buyer (employee), with a copy kept PT AM has less than 1% annual turnover among staff and on file by the Koperasi. The Koperasi informs the estate/mill labour. Given the rapid development of oil estate/mill pay officers of the amount of goods bought palm in Sumatra, this is a reasonable indication that on credit and deductions are made from the following employment conditions at PT AM are relatively good. wage payment.

Working conditions have been agreed with the labour The Company currently has agreements with 37 union (refer Criterion 6.6) and are specified in the PKB. contractors. The agreements stipulate that contractors The PKB is reviewed by SPAM and PT AM every two must abide by the law, including wage rates and years. The previous review, conducted in late 2008, employment conditions for staff. PT AM undertook resulted in changes to a range of working conditions and socialisation of this requirement in February 2010. Any entitlements, including, for example, scholarships for contractor not participating is required to complete children to attend school, travel allowance rates, rice socialisation prior to the commencement of work. allowance eligibility, the quantity of safety shoes issued, 6.5.4 Minor NCR: Contractors working at the quarry did etc. Therefore working conditions are documented in not appear to be getting one day off in seven as the Collective Labour Agreement (CLA). CLA is the required by the labour laws of Indonesia and this needs document of agreement between workers represented to be monitored by company management to ensure by Labour Union (Pengurus Serikat Pekerja Agro Mandiri these laws are adhered to. (SPAM)) and the company dated 21 October 2008, for period of 21 October 2008 to 20 October 2010. The CLA While most contractors appeared to meet or exceed is produced in a form of booklet which is currently minimum wages and basic conditions, one contractor distributed to employee representatives only, but appeared to have staff working long hours for extended accessible to all workers. The CLA is in line with periods. This occurred at a rock crusher, where 12 men regulatory requirements approved by the Manpower resided for periods of two months at a time, after which District Agency. Inspection of record and sample of pay they returned to their homes for a short visit. While on slips confirmed pay and conditions are in accordance site, the men indicated that they exceeded both the with the Minister of Manpower Decree No Kep maximum length of work in any one day, and the 102/MEN/Year 2004 and CLA agreement between number of days worked without time off. While the Labour Union and PT AM. contractors were not complaining, PT AM should provide

routine checks of contractors to ensure they are The Company provides housing, water, electricity, complying with labour laws. medical support, kindergarten and school bus services for all 2,300 staff and employees and some free labour. PT AM has decided to directly employ sprayers and The houses are relatively spacious and have electricity some other positions rather than engage them as free (generally from 5 pm and 7 am), plus water, showers, labour. This will increase the benefits provided to these toilets, etc. The houses and surrounding areas appear employees and give PT AM more direct control of the clean and tidy. Each estate/mill generally has a workplace. kindergarten and polyclinic. Both provide free services for the employees and their families. The polyclinics Criterion 6.6: The employer respects the right of all provide a range of inpatient and outpatient services and personnel to form and join trade unions of their choice are staffed by qualified personnel. The Company and to bargain collectively. Where the right to freedom provides a free bus service for children to attend school. of association and collective bargaining are restricted under law, the employer facilitates parallel means of

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 24 independent and free association and bargaining for all sexual orientation, union membership, political such personnel. affiliation or age is prohibited.

The Pengurus Serikat Pekerja Agro Mandiri (SPAM) is an PT AM has an equal opportunities employment policy. independent union for all estate/mill labour and free The policy is clearly displayed on notice boards (e.g. in labour working for PT AM. SPAM was established in polyclinics, offices, other work areas). The awareness of 2006. Prior to this time workers were represented by a the equal opportunities policy has been raised during national union. SPAM has around 2,200 members, who meetings at the GMO and with the estate/mill pay a monthly membership fee of R.7,000 (of which managers. R.2,000 is allocated to union operations and R.5,000 is There was no evidence or allegations of discrimination allocated to the Koperasi). during the audit. Males and females have equal opportunity and receive equal wages, although male SPAM branches have been established in each employment far exceeds female employment. estate/mill. The union committees generally meet each Employment preference is given to local people, when month, while they meet with the estate/mill they have similar qualifications and/or experience to management every 2 or 3 months. candidates from other areas .

The main SPAM committee, which is elected for a two There is no indication of discrimination. Female and year period, meets monthly and has meetings with the male has the same opportunity in job and payments. HR Manager of PT AM every quarter. The union and its Local people also have opportunity for employment. estate/mill branches appear to have maintained a good relationship with PT AM since establishment in 2006 Criterion 6.9: A Policy to prevent sexual harassment PT AM has a policy on Freedom of Association. The and all other forms of violence against women and to policy is clearly displayed on notice boards. The vast protect their reproductive rights is developed and majority of estate/mill employees are members of applied. SPAM. The policy has been socialised during morning muster. There is a policy in place on Sexual Harassment and is ` documented and available to Managers, assistants and Minutes of each meeting between SPAM and PT AM are all stakeholders via notice boards although could be documented; signed by both parties; and recorded on more widely distributed. file by SPAM and the HR Manager (on behalf of PT AM). Minutes between SPAM and the estate/mill managers There is a documented policy in the CLA on the also appear to be well documented, signed by both protection of reproductive rights available on parties and records kept on file. subheading of Maternity Leave. Women who are pregnant or breastfeeding are not allowed to work in a dangerous environment. It is PT AM policy not to assign Criterion 6.7: Children are not employed or exploited. pregnant or breast feeding workers as sprayers, and will Work by children is acceptable on family farms, under be transferred to other duties once confirmed pregnant adult supervision and when not interfering with by the company doctor. Meetings with workers education programmes. Children are not exposed to confirmed their understanding and implementation of hazardous working conditions. the policy.

PT AM does not knowingly employ workers under the PT AM provides 3 months paid maternity leave and national legal age limit. pregnant women or breastfeeding mothers are not permitted to undertake jobs which may put their babies The policy does not allow for any employees under 18. in danger, such as spraying or anything involving heavy The policy is clearly displayed on notice boards (e.g. in lifting. In addition breastfeeding mothers are permitted polyclinics, offices, other work areas). a 30 minute break each morning and each afternoon to breast feed their babies. If the mothers are not in close Each direct employee has an individual contract with PT proximity to the emplacement, the company provides AM. The contract records the date of birth, which is transport and additional time, if necessary, to allow the taken from the employee’s identify card. The awareness mother to breast feed. of the minimum age requirement has been raised during meetings at the GMO and with the estate/mill There is documented procedure of the grievance managers. mechanism, which included internal and external stakeholders. Management has provided training to This minimum age policy is also reflected in all manager and staff. Women’s groups were established agreements with contractors. to facilitate grievance of women.

A sexual harassment grievance mechanism has also been Criterion 6.8: Any form of discrimination based on race, established – there have been no reports received or caste, national origin, , disability, gender, documented of sexual harassment.

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 25

on time – there have been no complaints of late There is proof implementation of reproductive rights payments received or recorded and it is written in detail in the PKB documents to guarantee leave and medical treatment. There is an induction process carried out which includes contractors prior to work commencement, which includes safety and PPE. Interviews with contractors Criterion 6.10: Growers and mills deal fairly and confirmed that all contractors understand the transparently with smallholders and other local contractual agreements they enter into, and consider businesses. that contract agreements are fair, legal and transparent.

PT AM does not buy FFB from smallholders but has entered into agreements with 51 local villages for the Criterion 6.11: Growers and millers contribute to local establishment of KMD (mini-estates) on their land. Each sustainable development wherever appropriate. KMD varies from 10 to 15 hectares in size, but provides a long term source of income for the village. PT AM provides regular financial and in-kind assistance to government agencies, NGOs, other organisations and The price of FFB used in the calculation of payments to local communities. Requests for assistance are recorded, villages under the KMD scheme is calculated by PT AM in along with the Company’s response. Detailed records Medan and publically displayed at each mill. According are maintained showing the amount (or value) of each to several KMD committees, the price is generally higher contribution. The most common types of assistance are than that paid by other mills in the Muko Muko area. materials for the construction of public buildings The prices paid are also sent to the KMD committees (classrooms, village offices, mosques, etc.) and grants to each month. help celebrate festivals or public holidays. The Marketing Department of Medan HO advised FFB In addition, PT Agro Muko: price to the GMO every week by email according to the agreed formula. The GMO later advised the FFB price to • Provides a top-up salary for approximately 30 Estates, Mills, and KMD officials, who are handed a copy teachers in nearby public schools; of latest information which is made available to KMD • Provides workplace training for approximately 15 representative. An example was that on 29 September vocational students each year (generally for a period 2010, GMO received FFB price from Medan HO. GMO of 3 months); later issued letter to inform the price to Estates, Mills, and KMD and advised the KMD on the same day. A • Provides workplace training for around 50 local record of FFB price is publicly available in each estate people in the workshop, mills or estates, generally office and publicly accessible. It is sighted on the for a period of 6 months; and noticeboard close to the weighbridge • Constructed two primary schools which were Agreements for the KMD specify the need for inputs, but subsequently taken over by government. the cost is not estimated in the KMD agreements. Women’s groups have been formed in each Rather, the quantity of inputs and cost are recorded by emplacement and receive support from both PT Agro PT AM, along with deductions and the outstanding debt, Muko and the sub-district women’s group, headed by and this information is sent to each KMD committee the wife of the Bupati. The sub-district women’s group periodically but a least monthly. provides training and awareness while PT Agro Muko PT AM uses a range of contracted services, including the provides assistance in materials and supplies. Some of provision of labour for some field activities (e.g. the more recent activities have included emplacement spraying, fertilizing, nurseries), building construction and beautification, which will in some cases help limit dust maintenance, production of gravel, etc. [Truck drivers problems, promotion of hygiene and sanitation, and are contracted by PT Agro Muko]. Contracted services training in sewing, embroidery and production of are clearly documented and the cost of inputs or handicrafts, which can provide opportunities to services clearly stated generate additional income. Therefore GMO coordinates PT AM contributions to PT AM have a template for contractual agreement of local development – records of all consultative contractors indicating term and condition of the arrangements are clear and open. Contributions to local contract. Engagement of contractors follows certain development take place in the following sequence: steps, e.g. pre-qualification program, selection criteria firstly community requests for donation to mills or and explanation of contract terms and conditions. estates. Then, the requests will be decided by management (HO). The contribution among others KMD villages and contractors appear to have a full includes sporting activities, religious activities, understanding of the contracts they enter and the education, and other donation. contracts appear to be fair, legal and transparent. KMD villages and contractors appear to be paid on time. The most notable company contribution is KMD (Kebun Sub-contractors also appear to be paid adequately and Masyarakat Desa (Village Estate) Program where company developed 10 to 15 hectare of oil palm estate

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 26 per village in its surrounding (as of July 2010, company already run KMD program in 38 villages and 501 ha). There are no new plantings included in PT Agro Muko Additional 12 villages planned until end of 2010 totalling plantation and supply base areas 124 hectare.

Under this program, company firstly approached the Criterion 7.5 No new plantings are established on local village. Village head later held a general meeting to peoples’ land without their free, prior and informed decide company’s offer and provide the requested land. consent, dealt with through a documented system that Company later developed and maintains estate under enables indigenous peoples, local communities and KMD program. A committee was established in each other stakeholders to express their own representative village to monitor KMD estate program. The committee institutions. also manages money from FFB selling. Most of the money was used for village development or other usage There are no new plantings included in PT Agro Muko decided by village meeting. plantation and supply base areas

SGE: File: SKE forwarded a request for a donation and CSR program to GMO for approval. Record held on file Criterion 7.6 Local people are compensated for any “Rekaman Bantuan ke Masyarakat”. agreed land acquisitions and relinquishment of rights, subject to their free, prior and informed consent and TRE: It is company policy to make the social activities negotiated agreements. report available to the public in accordance with GMO letter of 23 September 2010. Record held on file There are no new plantings included in PT Agro Muko “Monthly Estate Account”. plantation and supply base areas

Above are examples and there are records in each operating unit of all contributions made to local Criterion 7.7 Use of fire in the preparation of new communities including mosques, police, army, villages plantings is avoided other than in specific situations as and many others. identified in the ASEAN guidelines or other regional best practices. Some plantation activities such as building housing complex, road maintenance and plantation maintenance There are no new plantings included in PT Agro Muko are contracted to the local contractors. plantation and supply base areas

Criterion 7.1 A comprehensive and participatory social Criterion 8.1: Growers and millers regularly monitor and environmental impact assessment is undertaken and review their activities and develop and implement prior to establishing new plantings or operations, or action plans that allow demonstrable continuous expanding existing ones, and the results incorporated improvement in key operations. into planning, management and operations. The company has implemented an environmental There are no new plantings included in PT Agro Muko Management System that is certified to the ISO plantation and supply base areas 14001:2004 Standard.

Objectives and Targets have been developed and an Criterion 7.2 Soil surveys and topographic information improvement plan prepared. The third party ISO 14001 are used for site planning in the establishment of new Certification Audit checks the achievement of the plantings, and the results are incorporated into plans objectives and targets annually for continuous and operations. improvement. The main focus of continual improvement to date has been environmental performance, while less There are no new plantings included in PT Agro Muko attention has been given to social impacts. plantation and supply base areas A continuous improvement plan has been prepared which contains a number of social activities (e.g. Criterion 7.3 New plantings since November 2005 have improving housing conditions and health levels in the not replaced primary forest or any area containing one emplacements, raising the awareness of company or more high Conservation Values. policies, providing support to women for home industries in the emplacements). The plan has not been There are no new plantings included in PT Agro Muko widely discussed with management at this stage, but plantation and supply base areas appears relatively comprehensive and an effective means on which to focus on key social issues. Quantifiable indicators, to monitor improvement on a Criterion 7.4 Extensive plantings on steep terrain, periodic basis (e.g. annually), should be added. It will and/or on marginal and fragile soils, is avoided. also be important, in time, to ensure wide stakeholder

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 27 input to the continuous improvement plan, both in line with Road Maintenance plan following heavy rains. terms of its focus and content, and in monitoring This will ensure any potential wash aways are noted achievements over time. and rectified prior to becoming an issue with regards to access.

A Continuous Improvement Plan is attached (Appendix 4.3.4 Observation: There are around 200 ha of peat on C). Tanah Rekah estate. There are some channels in place

however they do not appear to all be within the nominated required depth of between 50-75 CM and 3.2 Detailed Identified Nonconformities, Corrective need to be reviewed and some more effective water Actions and Auditor Conclusions (Also included gates constructed – it is acknowledged that there is a as Appendix D) plan in place to complete this and this will be viewed in the Continuous Improvement Plan MAJOR NONCONFORMITIES 4.5.2 Observation: There is a need to indicate that Nil Major Nonconformities were assigned monitoring of all IPM components are continually monitored – for example of two estates (BTE/TPE) after MINOR NONCONFORMITIES there were no rats for a month monitoring stopped – Two (2) Nonconformities were assigned against Minor this should be continued even though numbers are low Compliance Indicators. Details of these Nonconformities to ensure the threat does not reappear. are provided below: 4.6.6 Observation: As health checks for workers are not carried out for pesticide handlers until they have been 5.2.5 Minor NCR. There is no regular monitoring of HCV employed for 1 year – records should indicate the start areas in each estate by the delegated conservation date for each pesticide handler tested to confirm this is officers. Inspection of the buffer zone and conservation in place effectively. area found some spots of Mucuna bracteata invading the buffer zone and conservation area. Review of the 4.7.5 Observation: Risk control requires improvement monitoring checklist found that the Mucuna bracteata as a number of Unsafe acts and Unsafe Conditions were was not considered as a threat to buffer zone and noted including but not limited to the following: conservation area; as such it was not monitored. • All pesticide mixers to be included in health 6.5.4 Minor NCR: Contractors working at the quarry did checks • not appear to be getting one day off in seven as One stairway in one mill was blocked required by the labour laws of Indonesia and this needs • Large hole in drain cover which could cause to be monitored by company management to ensure serious injury these laws are adhered to. • Contractors on housing project not using PPE

PT AM has prepared a Corrective Action Plan (Appendix 5.1.1 Observation: There are Environmental impact D) that has been reviewed and accepted by BSi. Progress assessments carried out for all operational areas. on Corrective Action will be checked during the However some impacts were not documented or Surveillance Audit. assessed including impacts on flora and fauna, sacred sites, contractors.

OBSERVATIONS / OPPORTUNITIES FOR IMPROVEMENT 5.1.2 Observation: PT AM to ensure that when mill or estates submit RKL/RPL reports that all sections are The assessment identified twelve (12) Observations/ completed. Opportunities for Improvement. The progress with the Observations/Opportunities for Improvement will be 6.2.3 Observation: When any grievance or request for checked during the Surveillance Assessment visit assistance is resolved to the satisfaction of both parties scheduled for twelve months following certification. the records in place should be updated accordingly.

1.1.1 Observation: Government returns which are 6.2.2. Observation: There is a list of stakeholders, mandatory such as manpower reports should not be which is amended as required when new stakeholders treated as request for information as a reply to these are introduced, or others leave. While most of the requests is nonnegotiable. operating units has prepared a complete list of external stakeholders, such as local government body, local 2.1.3 Observation: The procedures for legal compliance community leaders, workers union, contractors, have not yet developed into a formal SOP which has suppliers, and NGO, however with several operating been socialized to every operating unit. units a number of stakeholders were not in the list.

4.3.3 Observation: There is a recommendation that PT AM include the inspection of bridges and culverts in

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 28

6.3.3 Observation: TRE: Complaints on housing raised several estates this policy is not yet well socialized. by harvesters was not recorded in the log book, of file Company will socialize this policy accordingly. “keluh kesah”. Issues raised by two of the harvesters, of Tanah Rekah Estate where their roofs are leaking. Several complaints 3.3 Noteworthy Positive Components have been made to mandors and assistants but with no result so far. 1. There is an appreciation of the company due to the existence of the company facilities and Company response: There is a program to repair houses infrastructure that can be used by the local in place, and an ongoing process of tendering by local communities. The facilities such as health contractors is under way and is expected to commence clinics, basic education, school bus by the end of the year (2010). transportation, and sports facilities are open the for local community around the plantation. Bunga Tanjung Estate workers are complaining that a In addition some company infrastructures such lack of water pressure has made water with sufficient as road access and bridges are also used by pressure unavailable to several houses. local community in connecting between villages. Company response: The Company will check, and make repairs as required to improve water pressure for 2. There is an appreciation related to the company affected houses. contribution to the local communities such as mosque renovation, village infrastructures, As polyclinic staff is on 24 hour call, special consideration sporting activities, etc. There are two kinds of should be given to salary levels, particularly those company aid: first, routine aid such as polyclinics that are manned by one person and serve a contributions towards local communities basic number of relatively distant emplacements. While needs (“ sembako ”) on the eve of Islamic emplacement residents commented favourably on the holidays; second, the contribution based on services provided at the polyclinics, the polyclinic staff proposals projected by local communities. In require supervisory visits (to check facilities and general, local communities are also satisfied equipment, gain a better understanding of the health with the management and staff in responding and operational issues being addressed at each to proposals. polyclinic, and provide technical support/advice when required). 3. There are new job and business opportunities Company Response: PT AM will review the status of the for local communities. In order to support the production, PT AM needs third parties to one person posts with a view to either paying an on call handle some work that cannot be done by the fee or getting more resources. The company provides company itself. For example harvesting, inspections of polyclinics by the Doctor from Medan on a maintaining the plants, spraying, etc. In regular basis and during this time clinic staff are made addition, business opportunity is also available aware of any changes and given support. for local businessmen such as becoming

business partners (contractors). • External stakeholders 4. The company has set up women’s groups to better represent their needs. There are regular • Contractors and suppliers meetings held where the women are encouraged to state their views. This is Contractors and suppliers contacted did not raised any encouraged by PT AM Management. issues of concern.

3.4 Issues Raised By Stakeholders and Findings with Respect To Each Issue • Government officials

Several field workers complained about rubber boots Cooperative Office KMD should be managed by the that are worn out after three to four months of use. cooperative. Company was only providing one pair of free rubber Company Response: The company will continue to be boots each year. This is considered insufficient; as they managed by PT AM however they will include members need about three to four pairs of rubber boots per year. of the cooperative. Company response: It is company policy to provide two pairs of rubber boots to every field worker. However, in

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group RSPO Certification Assessment Agro Muko Indonesia Mills and Supply Base Page 29

• NGO 3.5 Acknowledgement of Internal Responsibility A NGO contacted raised an issue where native species, and Formal Sign-off of Assessment Findings such kepayang trees should be planting in the buffer Please sign below to acknowledge receipt of the zone. assessment visit described in this report and confirm the acceptance of the assessment report contents including Company Response: PT AM will always favour native assessment findings. species when planting trees in buffer zones

• Local communities

Signed for on behalf of Tanah Rekah Village head raised an issue on the PT Agro Muko Indonesia management of Danau Lebar, a lake inside the PTAM’s HGU concession area. The management of the lake should be given to villagers since it will provide more income to the village.

Company Response: This is the responsibility of the local Bupati and outside the jurisdiction of PT AM...... Mr Olivier Tichit Villagers of Lubuk Balau are unclear about HGU status of Environment and Conservation General Manager the estate, after expiration of the permit in the next 25 Date: 10.10.2010 years.

Company Response: The company explained that the HGU can be continued after 25 years following renewal of the HGU before the previous lease expires.

Signed for on behalf of The same village representative also raised concerns in BSi Group Singapore Pte Ltd regards to the first entrance gate to the estate. Location of the first bridge is between local peoples land and company land. Sometimes local people carry out FFB from their plots after 5 pm and cannot pass the gate, and have to wait until next day...... Mr Allan Thomas Company Response: The company will now have the Lead Auditor gate open until 9 pm and security will allow genuine Date: 10.10.2010 farmers to move their FFB until this time.

Prepared by BSi Management Systems Singapore Pte Ltd for PT Agro Muko Indonesia / SIPEF Group

Appendix “A”

RSPO Certificate Details

PT Agro Muko Gedung Bank Sumut lt.7 Jl. Imam Bonjol 18 20152 MEDAN NORTH SUMATRA INDONESIA Certificate Number: SPO 556042

Website: www.tolantiga.co.id Applicable Standards: RSPO Principles & Criteria : 2007; RSPO INA-NIWG May 2008

Mukomuko Palm Oil Mill and Supply Base Teruntung, kec.Teras Terunjam, kab.Mukomuko, Location Address Bengkulu, Indonesia GPS Location E101º16' – S02º36' CPO Tonnage Total 52 000mt PK Tonnage Total 12 000mt Own estates FFB Tonnage 224 000mt Non-company Suppliers FFB Tonnage 0mt Immature Total land-use titles Annual FFB SIPEF estates Mature (ha) (ha) (ha) Production (mt) Mukomuko Estate 2 799 0 3 731 66 000 Tanah Rekah Estate 3 086 9 3 849 75 000 Sungai Kiang Estate 1 764 285 2 171 25 000 Talang Petai Estate 1 215 918 2 270 19 000 Sungai Betung Estate 2 112 66 4 080 39 000 TOTAL 4 996 415 5 411 224 000

Bunga Tanjung Palm Oil Mill and Supply Base Location Address Berangan Jaya, kec.Teramang Jaya, kab.Mukomuko, Bengkulu, Indonesia GPS Location E101º22' – S02º43' CPO Tonnage Total 27 000mt PK Tonnage Total 6 000mt Own Estates FFB Tonnage 114 000mt Non-company Suppliers FFB Tonnage 0mt Annual FFB Total land-use SIPEF Estate Mature (ha) Immature (ha) Production titles (ha) (mt) Bunga Tanjung Estate 2 384 84 2 903 44'000 Air Bikuk Estate 1 149 71 1 410 30'000 Air Buluh Estate 2 011 327 2 500 40'000 TOTAL 5 544 482 6 026 114 000

Appendix “B”

Certification Audit Programme

Assessment Plan Monday 26 September – Saturday 2 October 2010

Sunday 26 September • Allan, Mike and Iman arrive from at Padang Airport 17.15 – meet and pick up at airport • OT arriving Padang • Overnight Padang

Monday 27 Sept Time Activity Allan Iman Mike Action 09h00 AMTT X X X 13h00-13h45 flight Susi Air PDG-MUK X X X 14h30-15h00 Opening Meeting X X X 14h30-15h00 General Documentation X X 15h00-16h00 Central Workshop, Central warehouse X 15h00-17h00 Review records of land title, leases, etc ? HCV/KMD X X 16h00-17h00 Continue review of RSPO documentation X

Tuesday 28 Sept Time Activity Allan Iman Mike Action 8:00am – 11:00am MM Mill - Inspect mill, mill records, laboratory and effluent ponds X 8:00am – 9:00am Inspect Mill Emplacement, Landfill X X 9:00am – 12:00noon Review Environmental and Social Reports X X 12:00noon – 1:00pm Lunch X X X 1:00pm – 4:45pm Tanah Rekah Estate documentation, Estate Operations X X X 1:00pm – 3:45pm Social issues/HCV reports X 3:45pm –4:30pm Meet with NGO Representatives? X

Wednesday 29 Sept Time Activity Allan Iman Mike Action 7 am – 9am Travel to Sungai Kiang Estate 9:00am – 12:00noon Sungai Kiang Estate (Office, Clinic, Landfill, Gravel Extraction, Chemical store X and mixing, Fertiliser, buffers, reserves, field spraying & harvesting) 9:00am – 12:00noon Inspect area around Sungai –Kiang – Social issues etc X X 12:00noon – 1:00pm Lunch X X X 1:00pm – 2:30pm Talang Petai Estate (Office, Clinic, Landfill, Chem ical store and mixing, X X 2:30pm – 5:00pm Fertiliser, buffers, reserves, field spraying & harvesting) X 2:30pm – 5:00pm KMD and community next to TPE?

Thursday 30 Sept Time Activity Allan Iman Mike Action 8:00am – 12:00noon Bunga Tajung E state (Office, Clinic, Landfill, Gravel Extraction, Chemical X X store and mixing, Fertiliser, buffers, reserves, field spraying & harvesting) Review Aspects/Hazard - Risks x 8:00am – 12:00noon Mill Housing/ Personnel X X Clinic x X Review Documentation X X 12:00noon – 1:00pm Lunch X X X 1:00pm – 3:00pm Inspect Bunga Tanjung Mill and relevant areas X X X 3:00pm – 4:00pm Includes Documentation and Inspection

Friday 1st Oct Sept

Time Activity Allan Iman Mike Action 8:00am – 12:00noon Sei Betung Estate (Office, Clinic, Landfill, Chemical store and mixing, Fertiliser, buffers, reserves, field spraying & harvesting) x X X 8:00am – 12:00noon Meeting with stakeholders - documentation X X 10:00am – 12:00noon Review Documentation - ongoing X X X 12:00noon – 1:00pm Lunch X X X 1:00pm – 3:00pm Auditors meeting X 3:00pm – 4:00pm Exit Meeting – X X

Saturday 2 nd Oct Sept

Time Activity Allan Iman Mike Action 09h30-10h15 Flight MUK-PDG x X X 5.45 pm Depart Padang for Jakarta X X X

Appendix “C”

Continuous Improvement Plan

PT TOLAN TIGA INDONESIA (SIPEF) CONTINUOUS IMPROVEMENT PLAN - PT AGRO MUKO

Last update : 05 october 2010. Distribution : PD / D-ESD / D-ENG / D-FAD / GM-AM / GM-HRA / GM-IAD / Cpy.Doctor / SFM-AM / SMA-AM / E M / MM. By : GM-ENC Updates by ENC.

ACTIVITY LOCATION IN CHARGE SUPPORT TIME TARGET STATUS CIPAM2010-A Improve maintenance/cleanliness of the h ousing areas (emplacements) 1-Repair rainwater and used water drains, septic ta nks, gutters. all GMO ENC continuous in progress GMO / 2-Support women groups for involvement in emplaceme nts management, provide all ENC continuous in progress awareness in sanitation, capacity building ; monito r activity Co.Doctor 3-Increase "green areas" in emplacements all GMO ENC continuous in progress (EM-MM) 4-Monthly monitoring of emplacements (included in m onthly P2K3LHS meeting) all ESD/ENG ENC continuous in progress CIPAM2010-B Improve management of HCV areas 1-Install and maintain sufficient number of signs all GMO ENC continuous in progress 2-Continue training of "Kader Konservasi" from empl oyees and local people estates ENC GMO continuous planned 3-Monthly review of situation/incidents at P2K3LHS meeting estates GMO ENC continuous in progress 4-Pay specific attention to invasiveness of Mucuna b. in protected areas. estates GMO ENC continuous budgetted CIPAM2010-C Conduct regular tenders of industrial wa ste (limbah B3) to licenced companies all ENC GMO october 2010 in progress Upcoming tender during FH 2010. CIPAM2010-D Conduct internal legal audits all SMA-AM ENC end 2010 planned CIPAM2010-E Reduce pollution by spills/leaks from ve hicles operation/maintenance 1-improve maintenance levels through improved train ing and monitoring all CWS ENC continuous in progress 2-provide spill kits and training in proper use/dis posal of soiled material all CWS ENC continuous in progress 3-modify SBE HSD shed : place filling station on a flat area SBE EM GMO/ENC end 2010 planned CIPAM2010-F Improve OHS situation 1-increase awareness/training of workers on OHS iss ues all GMO ENC/HRA continuous in progress 2-improve signs on risk areas and PPE all GMO ENC end 2010 in progress 3-conduct regular training sessions for staff at an d above assistant level all ENC GMO continuous in progress 4-revise OHS self-assessment yearly all GMO ENC continuous in progress 5-Reduce use of Free Labour and favour SKU for all field work estates GMO ESD year 2011 in progress GMO/Co.Doct 6-Review LTI, severity and frequency rates all managers year 2011 planned. or/ENC

CIPAM2010-G Improve availability/use of clean water in workers housing 1-Test water quality all ENC GMO september 2010 completed 2-Prepare action plan based on tests results all GMO / ENC - september 2010 in progress / Co.Doctor 3-Implement action plan all GMO / ENC - end 2011 planned / Co.Doctor 4-Recommend systematic boiling of water for consump tion, using posters & all GMO / ENC - immediate in progress information campaign through medical personnel and women groups. / Co.Doctor CIPAM2010-H Improve assessment of environmental impa ct. 1-Revise environmental impact assessments to includ e positive impacts all ESD / ENG ENC FH 2011 planned 2-Collate pesticides use data (in particular paraqu at) for 2010, based on current estates estates / ENC january 2011 planned records, and prepare regular comparisons for 2011 ESD CIPAM2010-I Increase awareness of free labour/contra ct workers on the grievance and all GMO ENC / GCo continuous in progress sexual harassment company procedures. CIPAM2010-J Review WI in mills to include risks take n mills MM ENC end 2010 in progress CIPAM2010-K Improve gender issues management 1-Improve work of the Gender Committee and create G Co contact groups at MU all GCo / ENC GMO end 2010 in progress level 2-Improve reporting of gender situation all GCo/GCCC GMO / ENC end 2010 planned CIPAM2010-L Improve monitoring of emissions.

1-Replace smoke-density meters mills ENG ENC / GMO end 2010 in progress 2-Improve monitoring of emissions mills GMO ENC end 2010 planned 3-Improve reporting and corrective actions mills GMO ENC continuous planned

CIPAM2010-M Improve reporting of RKL/RPL. all SMA-AM ENC Q3 2010 in progress

CIPAM2010-N Improve accidents investigations. 1-Improve training on accidents reporting all ENC GMO end 2010 in progress 2-Monitor proper reporting all ENC GMO end 2010 in progress

CIPAM2010-O Improve implementation of minimum working age. all GMO ENC immediate completed

Remind all managers of company policy and rules on minimum working age

CIPAM2010-P Consider building primary schools in Bunga Tanjung and Air Buluh to improve ABE/BTE/BTM GMO - budget year 2011 under consideration access to education for employees children.

CIPAM2010-Q Improve monitoring of health for workers at risk.

1-Design and communicate definition of "high risk" workers, with guidelines for all Co.Doctor/ HRA end october 2010 planned, working group formed managers ESD/ENG/ ENC 2-Revise list of "high risk" workers based on new definition all managers Co.Doctor / end 2010 planned ENC

CIPAM2010-R Improve health situation in company emplacements. 1-Provide training to medical personnel on community public health issues and all Co.Doctor GMO year 2011 planned outreach techniques 2-Ensure good dissemination of information on health issues through women groups all ENC GMO / continuous in progress Co.Doctor

CIPAM2010-S Support the creation of home industries for women in the emplacements. emplacements GMO ENC year 2011 planned PTAM will provide stitching machines to women groups, and will contract the women groups to supply uniforms and uniform alterations.

CIPAM2010-T Improve efficiency of pesticide use. 1-Create "spraying gangs" of permanent employees, not free labour estates GMO ESD year 2011 in progress (see CIPAM2010-F/5) 2-Compare pesticides use every three months, from previous year estates EM GMO/ENC year 2011 planned

CIPAM2010-U Improve monitoring of natural resources in the mills. 1-calculate monthly the total use of renewable sources of energy (fibre, shells) mills GMO ENG/ENC immediate planned 2-review use of water, diesel and renewable energies at P2K3LHS meetings mills GMO ENG/ENC immediate planned 3-display water and diesel use ratios (per mt FFB processed), and ratio of use of mills GMO ENG/ENC immediate planned renewable energies (converted to diesel-equivalent per mt FFB processed)

GMO : General Manager Office ; SMA-AM : Senior Manager Administration, PTAM ; GCo : Gender Committee ; ENC : Environment & Conservation dpt.; ESD : Estates dpt.; ENG : Engineering dpt.

Appendix “D”

Nonconformities, Corrective Actions and Observations Summary

2 Nonconformities against Minor Compliance Indicators 12 Observations/Opportunities for Improvement

Minor Nonconformities (Detail) RSPO Indicator NCR Ref Details 5.2.5 AT 01 There is no regular monitoring of HCV areas in each estate by the delegated conservation officers. Inspection of the the buffer zone and conservation area found some spots of Mucuna bracteata invading the buffer zone and conservation area. Review of the monitoring checklist found that the Mucuna bracteata was not considered as a threat to buffer zone and conservation area; as such it was not monitored. Corrective Action: In the monthly safety/social/environmental management meeting, the company has introduced an additional item on the monitoring of HCVA, which is included in the guidance document for this meeting. The Environment and Conservation department will be checking that all monthly meeting are addressing the monitoring of HCVA properly. A separate memo will be sent to request specific control of Mucuna B This memo will be included in the next revision of the guidance document.

6.5.4 AT 02 6.5.4 Minor NCR: Contractors working at the quarry did not appear to be getting one day off in seven as required by the labour laws of Indonesia and this needs to be monitored by company management to ensure these laws are adhered to. Corrective Action: PTAM is changing the contract terms with the company operating the quarry to include the obligation to grant one rest day after six working days. This is effective in 2011. The estate manager is also instructed to monitor compliance with this requirement, and the EHS officers will review monitoring data.

12 OBSERVATIONS / OPPORTUNITIES FOR IMPROVEMENT

1. 1.1.1 Observation: Government returns which are mandatory such as manpower reports should not be treated as request for information as a reply to these requests is nonnegotiable.

2. 2.1.3 Observation: The procedures for legal compliance have not yet developed into a formal SOP which has been socialized to every operating unit.

3. 4.3.3 Observation: There is a recommendation that PT AM include the inspection of bridges and culverts in line with Road Maintenance plan following heavy rains. This will ensure any potential wash aways are noted and rectified prior to becoming an issue with regards to access.

4. 4.3.4 Observation: There are around 200 ha of peat on Tanah Rekah estate. There are some channels in place however they do not appear to all be within the nominated required depth of between 50-75 CM and need to be reviewed and some more effective water gates constructed – it is acknowledged that there is a plan in place to complete this and this will be viewed in the Continuous Improvement Plan

5. 4.5.2 Observation: There is a need to indicate that monitoring of all IPM components are continually monitored – for example of two estates (BTE/TPE) after there were no rats for a month monitoring stopped – this should be continued even though numbers are low to ensure the threat does not reappear.

6. 4.6.6 Observation: As health checks for workers are not carried out for pesticide handlers until they have been employed for 1 year – records should indicate the start date for each pesticide handler tested to confirm this is in place effectively.

7. 4.7.5 Observation: Risk control requires improvement as a number of Unsafe acts and Unsafe Conditions were noted including but not limited to the following:

• All pesticide mixers to be included in health checks • One stairway in one mill was blocked • Large hole in drain cover which could cause serious injury • Contractors on housing project not using PPE

8. 5.1.1 Observation: There are Environmental impact assessments carried out for all operational areas. However some impacts were not documented or assessed including impacts on flora and fauna, sacred sites, contractors.

9. 5.1.2 Observation: PT AM to ensure that when mill or estates submit RKL/RPL reports that all sections are completed.

10. 6.2.3 Observation: When any grievance or request for assistance is resolved to the satisfaction of both parties the records in place should be updated accordingly.

11. 6.2.2. Observation: There is a list of stakeholders, which is amended as required when new stakeholders are introduced, or others leave. While most of the operating units has prepared a complete list of external stakeholders, such as local government body, local community leaders, workers union, contractors, suppliers, and NGO, however with several operating units a number of stakeholders were not in the list.

12. 6.3.3 Observation: TRE: Complaints on housing raised by harvesters was not recorded in the log book, of file “keluh kesah”.

Appendix “E”

Record of all Stakeholder Comments in detail

DATE LOCATION INTERVIEWEE

Burhanuddin (Village Monday, 27 September 2010 Teluk Bayur Village Representative) • Native people of Teluk Bayur village, head of Community Development Body—Lembaga Pemberdayaan Masyarakat (in other villages known as “Community Representative”, which is basically its role is similar to local level People Representatives Assembly. • Teluk Bayur village, sub-district of Padang Selatan, Padang • The village is inhabit by approximately 750 households, make up of population around 3,000 persons • Most of the (80%) worked as laborer in the port, farmers, and fishermen • Company donation including public counseling for children following earthquake • Also rehabilitation of mosque, which was damaged during earthquake • The port is established dated back to 1883, close to Krakatau eruption, where at that time the government invite laborers to settled in this area • However, currently, following the need of port expansion, they are supposed to move since the land inhabited is belong to port authority • The people welcome the government policy on this, since it will broaden working opportunity for local, however, proper and adequate ex-gratia compensation is requested; the relocation should be close to port to avoid costly transport • Good relationship between AM and local people, there was public socialization prior to the development of bulking station—no serious issues raised by local people • More donation is sought from company operated in Teluk Bayur port, community need more donation for education of labourers children • Currently he run, free of charge education initiatives, from pre-school, elementary school, junior high school, and senior high school • There is also an agreement between company and local community, 20% of the employee must came from local community—60% of AM workers originated from locals

Monday, 27 September 2010 IMT Office Tress Martin (Worker) • Have worked with the company for more than 6 years • Good relationship with managers and colleagues • Copy of contract provided, said understand term and conditions of the contract • Said understand term and conditions of the contracts • Salary above minimum wage standard (2.2 – 2.5 million rupiahs per months)—UMR 940,000 rupiah per month • Better working condition than other company in Teluk Bayur • Medical service is free for staffs, workers, and their family members • No discrimination, SPAM member, equal opportunity

Leonardus Manurung, Fey Densi, Tuesday, 28 September 2010 Muko-Muko Mill Daman Sauri, Berton Hasbulloh, Hotpen Manurung (Mill Workers) • The gentlemen are long time workers have work for MMM for 10, 17, 8, 19, and 17 years respectively • Said to have good relationship with company, if not why work up to 20 years? • Contract agreement provided, term and conditions was explained by supervisor • BHL (Buruh Harian Lepas)  Persyaratan Kerja Waktu Tertentu (PKWT)  Syarat Kerja Umum (SKU) Harian  SKU Bulanan • Total monthly earning at 1.5 – 2,0 million Rupiah per months. However it is difficult to save, especially for those who have many children at school. • Six days worked, but in Friday only work half day • All said understand term and conditions of the contract • There is two normal shift; the first shift is from 0700am to 0300pm (with 1 hour OT), second shift 0300pm to 0100pm—just on peak seasons only • OT for almost every day, always claimed, discrepancy will be paid in the next months • Sometime worked on Sunday, at OT rate • All are member of SPAM (workers union)—no restriction to join union • No discrimination, all workers (male and female) have the same opportunity to work with PT TTI • Holiday leave at 12 days per year • PPE and housing is provided, free electricity and water supply • Housing is provided by the company • Allowed to plant vegetable garden in housing area • Electricity provided and water supply (24/7) provided by mill • School transportation provided from housing complex • Company provide training for the jobs, safe work practice (EHS) training • Free medical treatment for workers and the family member (wife and three children) • Good relationship with local people • No issues raised, if they have issue will complaint to manager

Jalinus, Fonazaro, Darman, Abdul Tuesday, 28 September 2010 Tanah Rekah Estate Rohim, and Surya (Harvesters) • Duration of the tenure varied from just 10 days to more than 10 years—Jalinus ( < 1 year) , Fonazaro (11 years), Darman (1 year), Abdul Rohim (3 years), and Surya (10 days) • Four of them are daily workers (who less than a year) and two others are permanent workers (who more than 3 years) • Daily target is 1 ton per day per harvester. If target is met, harvesters are eligible for premium. If not met the target, then harvesters will paid basic at 31,200 rupiah per day. • Income fluctuate in accordance to number of FFB, however, at least the harvesters will be able to take home 1,008,000 per months, minimum regional price. • On average, monthly salaries of harvester is around 1,500,000 per months which is considered relatively good salaries, much above the minimum wages, as long as the fruit is plenty, especially during peak crops.

• Started work at 0700 am to 0200 pm, sometime up to 0500 pm during peak crops • Payment equated the FFB, discrepancies will be paid next payment—they said no problem with the pay slip understanding • Said understand pay slip, supervisors already brief them on this or they also can asked to other harvesters • No overtime for harvesters, but premium and double price at Sunday and triple price during public holiday • Injured from torn sometime, but never happened any serious one, no snake bite • Training provided, including OSH, safe work practices, and all company policy (sexual harassment policies, freedom of association, equal opportunity policy, etc) • Good housing, subsidized electricity and water supply provided for free • Free medical treatment (for daily laborers at company clinic) and for permanent workers medical treatment even free to larger hospital • Issues raised by two of the harvesters, where their roofs are leaked. Several attempts have been made several months ago to complaint mandor and assistants but with no result.

Tuesday, 28 September 2010 Tanah Rekah Village Office Atral (Village Head) • The first village head after split from main village • Inhabit by approximately 406 households and 1,674 persons • Around 50% of them are migrant, mostly Javanese under government sponsored transmigration program to add up number of population • Local people mostly originated from West Sumatra (Minang ethnic), which is famous of their matriarchy, women is highly respected • Majority are moslems • Majority make living as farmers, planting oil palm or rubber estate: currently around 60% are planting oil palm, 40% planted rubber—reversed from initially that more farmer prefer rubber to oil palm. Even though the planting of rubber gave more income, however, high rainfall hampered local farmer ability to tap rubber • Besides that, rubber need more labour than oil palm, which later help increase oil palm popularity among farmers • No complaint raised to company, good relationship so far • However, several concerns raised: (1) seem that less local employed by company, (2) less local engaged as contractors, (3) Management of Danau Lebar, a lake inside the PTAM’s HGU concession area should be given to locals, since it will give more income to village, and (4) PTAM should repair access road along estate boundary, to help local people transported their FFB easier

Amminudin, Sumitro, Marusen, Wednesday, 29 September 2010 Lubuk Sadau Village and Ririn Asmara • Lubuk Sadau village, Subdistrict of V Koto, Muko-Muko, just split from main village of Lalang Luas, a years ago • Majority of ethnic is Minang, and small number of them is transmigrant from • Good and close relationship between company and community, several community development programme carried out by company in the village, most notably KMD program

• Total population 150 households and 540 persons • Majority of local people make living from agriculture, with paddy field (20%), rubber planting (20%), and oil palm planting account for 55%—even though the oil palm planting relatively new but soon able to win local people heart, since it is easier to manage and need less labour • Paddy planting was mostly carried out by Javanese transmigrant • No land conflict or land issue arise, initially land was forest belong to government, and if there is any community land, company already compensate them during the estate development date back to 1986 • KDM prove to benefited local people, so since the KMD estate now belong to old villages, they proposed a new plot to be developed into oil palm • Several issues raised by informants: • Working opportunity seem to be limited to local, please give more access to local people • HGU status, in village, many people expected that after the HGU expired, the land would be distributed to local people—is this correct? • Access to their estate, especially after five pm. PTAM installed two gates, the first one, close to settlement was to protect bridge otherwise local people will carry load above capacity and endanger the bridge lifespan. Location of the first bridge is between local people land and company land. However, sometimes local people carry out FFB from their plots after 5 pm and cannot pass the gate—have to wait until next day • Farmer along Sangkil River was complaining the estate, since current HO boundary survey found out a large number of farmers encroaching estate HGU’ land, total number of farmer are 25 persons. The farmers questioned why the survey just carried out by now, after many farmers occupied and planted those land • Need more communication and visit to local village, so that to make community relationship and estate getting closer each other

Wednesday, 29 September 2010 Sei Kiang Estate Samin and Sony (Harvesters) • All are permanent workers, have been working to company for 6 and 1 years respectively. • Said to have a good relationship with company • When promoted to permanent workers, they are provided with letter of assignment • Copy of contract provided, said understand term and conditions of the contract • Term and condition of the contract, explained by assistant manager • Basic salary of 850,000 rupiah per month; total earning per months 1,400,000 but during peak crops his salaries up to Rp 2,500,000 per month • Daily FFB target is 0,75 ton (depend on planting years) or equivalent to 44 FFBs. • Salaries advised by manager should there is new standard issued by company • Detail of salary given at pay slips, said understand pay slips • Working time: 0700 to 0200, during peak season up to 05 pm (sometimes) • Company provides free PPE e.g. rubber booth, however, only one pair of booth provided per year; they said required around two pair of shoes per year • Safe work practice training and training of the jobs is provided by company • Holiday leave for 12 days per years • Medical treatment is free for permanent workers and their family members (one wife and three children • For those who is in daily labourer status, medical available up to estate clinic only

Wednesday, 29 September 2010 Talang Sepakat Village Dasriman (Village Head) • Talang Sepakat village, subdistrict of V Koto, Muko-Muko • Majority of people is Minang ethnic; total population approximately 777 persons and 313 households • Having good relationship with company in general • Most of the population make up living by rubber planting (75%) and other 25% planting oil palm • People accustomed to take a bath in rivers, currently as the upstream area are cleared for planting by AM, causing water to be cloudy • As such, he requested PTAM to provided public bathing facility or public well for local community, he has raised this issue during meeting with GMO • Other issue raised was about access road to estate (3 km), that according to village head initially not yet being paid. No update yet form estate (estate manager stated that company has offered local people to compensate access road, however, they are refuse due to worrying estate will limit access to the road)

Supriyadi, Misun, Miswanto, Thursday, 30 September 2010 Bunga Tanjung Estate Sumadi, and Ali Yanto (Harvesters) • Those gentlemen are already work for the estate for 1.5; 20; 2; 3 and 10 year respectively • Said all are permanent workers, paid on monthly basis • In contrary to daily labourers, which paid based on the number of working days, permanent workers paid based on number of days in a month • Basic salary of 840,000 per month, monthly salary (after deduction) around 1.5 million rupiah, which is considered relatively good salaries, as long as the fruit is plenty, especially during peak crops • Daily target is 1,050 kg or 60 FFBs, they only harvest and transported to access road • Fruit loose collectors usually workers wife, per day a fruit loose collector are able to collect around 150 kg time 120 rupiah per kg • 0700 am to 0200 pm, sometimes they have a lengthier works hour during peak crop sometimes up to 05pm • Payment equated the FFB, discrepancies will be paid next payment • Said understand pay slip, assistant socialized the pay slip • Injured from torn sometime, but not serious one—free medical treatment in clinic or other hospital if necessary • Training provided, including OSH, safe work practices, and sexual harassment policies • Good housing, subsidized electricity and water supply provided for free • No and Never complaint, should there is complaint it will be directed to mandor and so on, but they are insisted if possible company provide harvesters more shoes, currently they are provided one pairs of free shoes per year. In fact, a shoe is worn out after a month, so 3 to 4 pair of shoes will help them • Inspection to workers shoes found out most of the harvesters used worn out shoes, which the base is broken down—and need replacement • Management clarify, that it is a policy to provide two pairs of shoes every year, however, the policy might need to be socialized to all workers in every operating unit

Thursday, 30 September 2010 Bunga Tanjung Village Minsyahril (Village Head) • Bunga Tanjung village, Teramang Jaya sub-district, Muko-Muko regeceny • Majority of ethnic is Minang, most of them are moslem • Total 393 households and 1,739 persons consist of male 954 persons and female 839 persons • Majority of people own oil palm around 2 ha per household • The village have a KMD program, from which able to build relatively multipurpose large village office (office and sporting facilities) two years ago at 375 million rupiah • The KMD program itself already around for 10 years in a month it provide village with around 35 million rupiah • The KMD is managed by four family representative (rajo lelo, rajo mantaro, rajo seri, and temenggung), elected every year • Income from KMD mostly used for social activities, such as mosque, roads, or other religious ceremony activities • Stated there is no customary land, as the case of typical Minang custom • No land or boundary issue arise • However, estate now becoming more bureaucratic in giving donation, e.g. there is a case during an emergency it is difficult for estate to lend car for SAR. Even though finally the estate gave the car but local people already angry with the procedure

Kunaryo, Arief, Hamdani, Rauli, Thursday, 30 September 2010 Bunga Tanjung Estate Dawan, Nes Riyadi and Taufik (Male Sprayers) • The gentlemen have worked for the company for 8 months, 2 years, 1 years, 5 months, 8 months, 1.5 years, and 5 months • Company is ongoing programme to promote sprayers into permanent employee. All of the sprayers will become permanent employee since 01 October 2010—all are nervous during interview, possibly only express the good one to the interviewer • All said to have good relationship with company • Salaries advised by manager should there is new standard issued by company • Daily salary is at provincial minimum regional wages of Rp 31,200 per day • In a month average salary was between 700,000 to 800,000. It is smaller as compared to harvester since they are have only occasional overtime • Detail of salary given at pay slips, said understand pay slips • Company provides free PPE e.g. apron, goggle, rubber glove, rubber boot, and mask. If lost or damaged, company will replace the PPE, but normally only two pair of PPE provided, said it is enough for them • Two pair of rubber boots every year, should be enough for them • Clean water in field is provided. Mixing done in store, done by one of the most senior worker. • Monthly medical check-up in clinic, annual CHRA in hospital, no female sprayers. • Medical check-up did not found any serious problems, so far, they will be notified if there is any problem found • Safe work practice training and training of the jobs is provided by company • Holiday leave for 12 days per years

Markidi (Cooperative and Trade Thursday, 30 September 2010 Phone Interview Department) • Having good relationship with AM and its staffs • As compared to other estate operated in Muko-Muko, AM is one of the best. • He acknowledge company contribution to local development through the development of “Kebun Masyarakat Desa – KMD – Village Community Estate” • The programme make village possible to carried out daily village governance on themselves, and not frequently requested donation to other parties • However, the management of KMD is not professional, e.g. no SOP, unclear authority, in some village money spent depend on the decision of KMD committee and no represent the whole community • He suggested, in the future KMD should be managed in form of cooperative, with clear line of authority, SOP, etc

Thursday, 30 September 2010 Phone Interview Apriyandi Sihaloho - BPLH • Said to have good relationship with PTAM, both with its staffs and workers • PTAM is open to government, gave every information requested by BPLH • Generally PTAM environmental performance is better than other company in Muko-Muko regency • No serious environment issues in PTAM, community usually will complaints to PTAM should there any issue arise • Last month he carried out environmental monitoring in PTAM, all of indicators generally good, however, one indicator e.g. pH is 9.0 just below maximum limit permitted 9.2. So, she warned PTAM to be careful and keep an eye on this indicator • He also found incorrect labelling on the scheduled was which is need to be fixed up

Aman Jaya (Agriculture and Thursday, 30 September 2010 Phone Interview Forestry Department) • Good relationship with PTAM • No much comment or issues raised • Said that the management is have better knowledge on their environmental impact than himself, please asked them

Thursday, 30 September 2010 Phone Interview Sudaryanto (BPN) • Good relationship with PTAM • No much comment or issues raised • No significant land issues, since the company already hold HGB • The problem mostly, company land encroachment by villagers. In this case, then local people doing something wrong, the land should be given back to company • In general, local people still respected local government and police, so should there is any land issue government can be involved to mediate the case

Riswan, Sistar, Hendra, and Friday, 01 October 2010 Sei Betung Estate Tunggal Jaya (Male Sprayers) • The gentlemen have worked for the company for 5 months, 6 months, 5 months, and 5 months respectively • All said to have good relationship with company, manager and staffs as well • Salaries advised by manager should there is new standard issued by company • Daily salary is at provincial minimum regional wages of Rp 31,200 per day • In a month average salary was between 700,000 to 800,000. It is smaller as compared to harvester since they are have only occasional overtime • Detail of salary given at pay slips, said understand pay slips • Company provides free PPE e.g. apron, goggle, rubber glove, rubber boots, and mask. If lost or damages, company will replace the PPE, but normally only two pair of PPE provided, said it is enough for them • Two pair of rubber boots every year, should be enough for them • Clean water in field is provided. Mixing done in store, done by one of the most senior worker. • Monthly medical check-up in clinic, annual CHRA in hospital, no female sprayers. • Medical check-up did not found any serious problems, so far, they will be notified if there is any problem found • Safe work practice training and training of the jobs is provided by company • Holiday leave for 12 days per years

Supriyadi, Misun, Miswanto, Thursday, 30 September 2010 Bunga Tanjung Estate Sumadi, and Ali Yanto (Harvesters) • Those gentlemen are already work for the estate for 13; 12; and 2 years respectively • Said all are permanent workers, paid on monthly basis • Basic salary of 840,000 per month, monthly salary (after deduction) around 1.5 million rupiah, which is considered relatively good salaries, as long as the fruit is plenty, especially during peak crops • Daily target is 1,050 kg or 60 FFBs, they only harvest and transported to access road • 0700 am to 0200 pm, sometimes they have a lengthier works hour during peak crop sometimes up to 05pm • Payment equated the FFB, discrepancies will be paid next payment • Said understand pay slip, assistant socialized the pay slip • Training provided, including OSH, safe work practices, and sexual harassment policies • Good housing, subsidized electricity and water supply provided for free • No and Never complaint, should there is complaint it will be directed to mandor and so on, but they are insisted if possible company provide harvester more shoes, currently they are provided one pairs of free shoes per year. In fact, a shoe will worn out after for month, so 3 to 4 pair of shoes will help them • Inspection to workers shoes found out most of the harvesters used worn out shoes, which the base is broken down—and need replacement • Management clarify, that it is a policy to provide two pairs of shoes every year, however, the policy might need to be socialized to all workers in every operating unit

Wagiran, Tukiman, and Jai Dahrim Tuesday, 16 March 2010 Phone Interview (Contractors) • Good relationship with PT AM, Serving company for more than ten five years! (17, 5, and 20 years! All said they are comfortable to work with company • Contract agreement provided, contractor explained the contract, understands the contract before signing it • Company provide training on PPE, OSH, and emergency procedures but contractors need to buy the PPE themselves • HCV socialization as well as company policy also socialized to contractors and supplier • Good and timely payment, never delay • Dispute resolution mentioned in the contracts, contractors and suppliers aware of its • No complaint so far, if any, contractors will speak to manager should there is any complaints • Implementing good community development initiative such as build school building etc, good relationship between company and village

Ali Khasan (Taruntung), Amaran Friday, 23 July 2010 Taruntung Village (Talang Medan), Darma (NGO – Genesis), Berlian (NGO) • Said they have good relationship to PTAM • Muko-Muko regency, majority of its population originated from West Sumatra, , and Gresik (Java) most of them are moslems • NGO raised concern regarding the planting of native species along the buffer zone, such as kepayang trees • Local people raised issues regarding Muko-Muko Mill effluent ponds, polluted the river