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Roundtable on Sustainable Palm Oil Re-certification Audit Report Report no.: RA1_82450216037 Re-certification assessment against the RSPO Principles & Criteria Generic Standard 2013, RSPO Supply Chain Certification System year 2014 and RSPO Scheme Smallholder Indonesia National Interpretation (INA-NI) year 2009 Name of client PT Aek Tarum – Belida Mill Head Office : Sumber Baru Village, Mesuji Raya Sub-district, Ogan Komering Ilir District South Sumatera Province, Indonesia Date of Re-certification Audit : April 18 th to 23 th , 2016 Report prepared by: Naik Monang Parlindungan Lingga (RSPO Lead Auditor) Certification decision by: Abdul Qohar (Director of TUV Rheinland Indonesia) Certification Body: PT TUV Rheinland Indonesia Menara Karya Lantai 10, Jl. H.R. Rasuna Said Block X-5 Kav.1-2 Setiabudi, Jakarta, Indonesia 12950 Tel: +62 21 579 44 579 Fax: +62 21 579 44 575 www.tuv.com

Re-certification Audit Report - RSPO

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Roundtable on Sustainable Palm Oil Re-certification Audit Report

Report no.: RA1_82450216037

Re-certification assessment against the

RSPO Principles & Criteria Generic Standard 2013, RSPO Supply Chain Certification System year 2014 and RSPO Scheme Smallholder Indonesia National Interpretation (INA-NI) year 2009

Name of client PT Aek Tarum – Belida Mill

Head Office :

Sumber Baru Village, Mesuji Raya Sub-district, Ogan Komering Ilir District South Sumatera Province, Indonesia

Date of Re-certification Audit : April 18th to 23th , 2016

Report prepared by: Naik Monang Parlindungan Lingga

(RSPO Lead Auditor)

Certification decision by: Abdul Qohar

(Director of TUV Rheinland Indonesia)

Certification Body: PT TUV Rheinland Indonesia

Menara Karya Lantai 10, Jl. H.R. Rasuna Said Block X-5 Kav.1-2

Setiabudi, Jakarta, Indonesia 12950 Tel: +62 21 579 44 579 Fax: +62 21 579 44 575

www.tuv.com

TABLE OF CONTENTS

1.0 SCOPE OF RECERTIFICATION ASSESSMENT ........... ....................................... 3

1.1 National Interpretation Used .................................................................................................................. 3

1.2 Type of Assessment ............................................................................................................................... 3

1.3 Location and Maps ................................................................................................................................. 3

1.4 Description of Supply Base .................................................................................................................... 8

1.5 Dates of Plantings and Replanting Cycles ............................................................................................. 9

1.6 Area of Plantation (Total, Planted and Mature) ................................................................................... 10

1.7 Organisational Information / Contact Person ....................................................................................... 11

1.8 Time Bound Plan for Other Management Units ................................................................................... 11

1. 9 Compliance to Rules for Partial Certification ...................................................................................... 12

1.10 Plan for certification of associated smallholders ............................................................................... 13

1.11 Approximate Tonnages Certified ....................................................................................................... 14

1.12 Recommendation for Certification ..................................................................................................... 14

1.13 Date of Certificate Issued and Scope of Certificate ........................................................................... 14

2.0 ASSESSMENT PROCESS .................................................................................. 15

2.1 Certification Body ................................................................................................................................. 15

2.2 Qualifications of Lead Assessor and Assessment Team .................................................................... 15

2.3 Assessment Methodology & Agenda ................................................................................................... 16

2.4 Stakeholder Consultation and Stakeholders Contacted ...................................................................... 18

2.5 Date of Next Surveillance Visit ............................................................................................................. 18

3.0 ASSESSMENT FINDINGS ................................................................................... 19

3.1 Summary of Findings ........................................................................................................................... 19

3.2 Status of Previously Identified Non-conformities ................................................................................. 71

3.3 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions.......................... 75

3.4 ............................................................................................................................................................... 82

Noteworthy Positive Components .............................................................................................................. 82

3. 5 Issues Raised by Stakeholders and Findings Pertaining to Issues.................................................... 82

4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INT ERNAL

RESPONSIBILITY..................................... ..................................................................87

4.1 Date of Next Surveillance Visit ............................................................................................................. 87

4.2 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client .................................... 87

APPENDICES .............................................................................................................88

Appendix 1: Certificate ............................................................................................................................... 89

Appendix 2: List of Abbreviations ............................................................................................................... 91

Appendix 3: List of Stakeholders Interviewed and Contacted ................................................................... 92

Appendix 4: Observations and Opportunities for Improvement ................................................................. 93

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1.0 SCOPE OF RECERTIFICATION ASSESSMENT

1.1 National Interpretation Used

The operations of the palm oil mill(s) and its supply base of FFB were assessed against RSPO Generic Stand-ard 2013 of the RSPO Principles & Criteria, RSPO Supply Chain Certification year 2014 and Scheme Small-holder year 2009.

1.2 Type of Assessment

The re-certification was carried out on 1 (one) mill, 2 (two) estates are Belida estate (under PT Aek Tarum) & Inti Permata Bunda Satu estate (under PT Mutiara Bunda Jaya owned by PT Sampoerna Agro) and main as-sessment for 3 (three) smallholder’s estate are village cooperative (KUD) of Tekad Mandiri, village cooperative (KUD) of Panca Sawit Makmur and village cooperative (KUD) of Jaya Bersama.

1.3 Location and Maps PT Aek Tarum location is in Sumber Baru Village, Mesuji Raya Sub-district, Ogan Komering Ilir District, and South Sumatera. This location is 100 km or 4 hours by drive from Palembang City the capital of South Su-matera. Table 1a: GPS locations for all estates and mill

Table 1b: GPS locations for all smallholders’ estat es

Name of mill / estates

Location GPS locations

Latitude Longitude Belida Mill Desa Sumber Baru C1, Kecamatan

Mesuji, Kabupaten Ogan Komering Ilir, Sumatera Selatan

03o 50’ 13.93” 104O 58’ 09.82”

Belida Estate Desa Sumber Baru C1, Kecamatan Mesuji, Kabupaten Ogan Komering Ilir, Sumatera Selatan

03O 49’ 4.27”. 105o 01’ 27.4”

IPBS Estate Desa Sumber Baru C1, Kecamatan Mesuji, Kabupaten Ogan Komering Ilir, Sumatera Selatan

03O 49’ 4.27”. 105o 01’ 27.4”

Name of estates Location GPS locations

Latitude Longitude

KUD Tekad Mandiri Desa Kemang Indah SP2, Kecamatan Mesuji raya, Kabupaten Ogan Komering Ilir, Sumatera Selatan

3° 46' 55.868" 105° 2'28.187"

KUD Panca Sawit Makmur

Desa Balian Makmur SP5, kecamatan Mesuji raya, kabupaten Ogan Komering Ilir, Sumatera Selatan

3° 48' 17.564” 105° 6'16.712"

KUD Jaya Bersama Desa Cahaya Mulya SP6, Kecamatan Mesuji Makmur, Kabupaten Ogan Komering Ilir, Su-matera Selatan

4° 0' 57.779" 104°56'24.821"

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Fi Figure 1: Location PT Aek Tarum & PT Mutiara Bunda Jaya in South Sumatera Province Indonesia.

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Figure 2: Location of PT Aek Tarum, Belida Palm Oil Mill, Belida Estate

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Figure 3: Location of Inti Permata Bunda Satu Estat e

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Figure 4: Location of Smallholder’s estate which su pply FFB to Belida Mill

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1.4 Description of Supply Base

Table 2: FFB Supply Information for Belida mill in year 2015 and 2016

FFB Contributors

FFB supplied year 2015 * FFB supplied year 2016 (projection) **

Tonnes % Tonnes %

Company owned (certified) estates :

Belida Estate 42,214.730 16.69 52,967.570 25.95

IPBS Estate 10,038.800 3.97 9,824.500 4.81

Sub Total 52,253.530 20.66 62,792.070 30.76

Other’s company estates :

Mesuji Estate 5,127.640 2.03 - -

Surya Adi Estate 898.740 0.36 - -

Sub Total 6,026.38 2.39 - -

Scheme Smallholder estates (include scope) :

KUD Tekad Mandiri 12,977.360 5.14 12,966.786 6.35

KUD Panca Sawit Makmur 17,831.440 7.06 14,219.232 6.97

KUD Jaya Bersama 8,908.030 3.53 7,119.935 3.49

Sub Total 39,716.830 15.73 34,305.953 16.81

Scheme Smallholder estates (out of scope) :

KUD Balian Sejahtera Abadi 3,843.900 1.53 - -

KUD Bina Sawit Utama 1,998.570 0.79 - -

KUD Citra Sawit Mandiri 516.710 0.21 - -

KUD Karya Makmur 19,491.320 7.71 17,631.829 8.64

KUD Marga Mulya 3,125.240 1.24 - -

KUD Mekar Sari 24,348.210 9.63 19,505.147 9.55

KUD Mekar Sawit 506.010 0.20 - -

KUD Mulya Jaya 22,205.680 8.78 17,475.468 8.56

KUD Permata Bunda 11,607.570 4.59 - -

KUD Rahayu Bhakti 19,908.770 7.87 12,984.500 6.37

JUD Sinar Jaya 3,522.310 1.39 - -

KUD Sedia Mukti 1,002.430 0.39 - -

KUD Subur Makmur 10,197.310 4.03 - -

KUD Sumber Rejeki 11,053.690 4.37 9,420.368 4.62

KUD Surya Adi 4,715.100 1.86 - -

KUD Surya Bhakti 1,138.720 0.45 - -

KUD Tunas Harapan 528.720 0.20 - -

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FFB Contributors

FFB supplied year 2015 * FFB supplied year 2016 (projection) **

Tonnes % Tonnes %

Sub Total 139,710.260 55.24 77,017.312 37.74

Independent Outgrower : 15,122.652 5.98 30,000.000 14.69

TOTAL 252,829.652 100.00 204,115.335 100.00

Note: *) Data from January to December 2015

**) Data from January to December 2016 (projection)

Table 3: Certified tonnages claimed, certified tonn ages purchased or sold, total and projected CPO and PK production from Belida Mill

1.5 Dates of Plantings and Replanting Cycles

Table 4: Age and year of plantings of company estat e supplying to Belida Mill

Age & Year of Plantings

Oil palm planted area at each estate(ha)

Belida

Estate

IPBS

Estate

KUD Tekad Mandiri

KUD Panca Sawit

Makmur

KUD Jaya Bersama

0 – 5 yrs (2012 – 2016) 0.00 0.00 0.00 0.00 0.00

5-10 yrs (2007 – 2011) 75.70 0.00 0.00 0.00 0.00

10-15 yrs (2002 – 2006) 74.90 0.00 0.00 0.00 0.00

Amount (MT)

CPO PK

Certified tonnages claimed 0 0

Previous certified tonnages claimed 20,937.00 5,457.00

Certified tonnages sold 0 0

Certified tonnages purchased 0 0

Actual Production for year 2015 51,728.94 14,082.61

Actual Certified Production for year 2015 10,691.07 2,978.45

Conversion Rate for year 2015 OER: 20.46 KER: 5.57

Projected output for year 2016 43,762.32 10,818.11

Projected certified production for year 2016 20,817.81 5,146.19

Projected certified FFB from scope of certified 97,098.023

Projected conversion rate for year 2016 OER: 21.44 KER: 5.30

Projected FFB for year 2016 204,115.335

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Age & Year of Plantings

Oil palm planted area at each estate(ha)

Belida

Estate

IPBS

Estate

KUD Tekad Mandiri

KUD Panca Sawit

Makmur

KUD Jaya Bersama

15-20 yrs (1997 – 2001) 0.00 0.00 0.00 0.00 0.00

20-25 yrs (1992 – 1996) 1,885.73 539.30 795.97 986.74 517.22

25-30 yrs (1986-1991) 710.30 0.00 0.00 0.00 0.00

TOTAL 2,746.63 539.30 795.97 986.74 517.22

Table 5: Planned and actual oil palm replanting act ivities for PT Aek Tarum

Year Total planned

replanting ar ea (ha)

Total planned replanting area for each estate (ha) Actual total area

replanted (ha) Belida Estate IPBS Estate

2016 - - - -

2017 - - - -

2018 600 600 - -

2019 833 833 - -

2021 - - - -

1.6 Area of Plantation (Total, Planted and Mature)

Table 6: Oil Palm Planted Area Summary, FFB Production and Average yield/ha for PT Aek Tarum & Small-holder

Estate Name

Total area (ha)

Oil Palm Planted

area (ha)

Mature (Produc-tion) area

(ha)

Immature (Non-

production) area (ha)

FFB Production (tonnes) Average yield year

2015

(tonnes/ha)

2015 2016*

Belida Estate 3,156.25 2,746.63 2,746.63 0.00 42,214.730 9,250.20 15.36

IPBS Estate 552.24 539.50 539.50 0.00 10,038.800 1,280.20 18.60

SUB TOTAL 3,708.49 3,286.13 3,286.13 0.00 52,253.530 10,530.45

KUD Tekad Mandiri

824.37 795.97 795.97 0.00 12,977.360 5,406.84 16.30

KUD Panca Sawit

Makmur 1,023.33 986.74 986.74 0.00 17,831.440 5,038.15 18.07

KUD Jaya Bersama

536.07 517.22 517.22 0.00 8,908.030 5,085.06 17.22

SUB TOTAL 2,383.77 2,299.93 2,299.93 0.00 39,716.830 15,530.05

GRAND TOTAL

6,092.26 5,586.06 5,586.06 0.00 91,970.36 26,060.50

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Note :

*) Production until year March 2016 for year 2016 is 26,060.50 tonnes;

Table 7: Other land use data for PT Aek Tarum & Sma llholder until March 2016

Estate Name Total ar-ea (ha)

Oil Palm Planted

Area (ha)

HCV/ Potential HCV areas (ha)

Land used for other purposes (ha)

Inside in the-planted

area

Outside planted

area

Office, Housing & Road

Nurse-ry

Other Land (Non Planta-

ble)

Company owned estate

Belida Estate 3,156.25 2,746.63 91.88 0.00 133.47 - 276.15

IPBS Estate 552.54 539.50 26.30 2.25 1.95 - 8.84

TOTAL 3,708.79 3,286.13 118.18 2.25 135.42 - 284.99

Smallholder estate KUD Tekad Mandiri 824.37 795.97 4.43 0.00 28.40 - -

KUD Panca Sawit Makmur 1,023.33 986.74 1.29 0.00 36.59 - -

KUD Jaya Bersama 536.07 517.22 5.49 0.00 18.85 - -

TOTAL 2,383.77 2,299.93 11.21 0.00 83.84 - -

1.7 Organisational Information / Contact Person

Contacts details of the company are as follows:

1.8 Time Bound Plan for Other Management Units The time frame laid out below is considered to be both challenging and realistic. The company will be using the experience of this recertification assessment to ensure that the other management units conform to the RSPO Principles & Criteria.

The audit team is satisfied that the company conforms to the RSPO requirements for partial certification as laid out in Clause 4.2.4 of the RSPO Certification Systems document.

Company Name: PT Aek Tarum - Belida Mill

Head office : Jl. Basuki Rachmat No. 788 Palembang 30127 Sumatera Selatan – Indonesia

Contact Person : Mrs. Yusi Rosalina

Telephone: +6281-271-238226

Email: [email protected]

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Name of Holding Location Time bound plan for certification

Status

PT Aek Tarum 1. Mesuji Smallholder 2. Belida Smallholder

South Sumatera 2015 Processing certification

PT Mutiara Bunda Jaya 1. Permata Bunda POM 2. Permata Bunda Satu Estate 3. Permata Bunda Dua Estate 4. Permata Bunda Smallholder 5. Harapan Dua Smallholder

South Sumatera 2016 2016 2015 2019 2019

Processing certification Certified

PT Gunung Tua Abadi 1. Sumber sawit Palm Oil Mill 2. Sumber Sawit Estate 3. KKPA Smallholder

South Sumatera 2015 2015 2018

Certified Certified Planned

PT Bina Sawit Makmur Surya Adi estate

South Sumatera 2016 Processing certification

PT Sampoerna Agro Selapan Jaya POM Gading Jaya Estate Limau Mungkur Smallholder Limau Manis Smallholder Limau Sundai Smallholder Sungai Indah Smallholder Sungai Pangeran Smallholder Gading Jaya Smallholder

South Sumatera 2016 2016 2019 2019 2019 2019 2019 2019

Processing certification

PT Telaga Hikmah Telaga Hikmah POM Hikmah 1 Estate Hikmah 2 Estate Hikmah 3 Estate Hikmah 4 Estate KKPA Smallholder

South Sumatera 2016 2016 2016 2016 2016 2019

Planned

PT Sungai Rangit Sungai Rangit Palm Oil Mill Baboti Estate Rauk Naga Estate Sungai Sagu Estate Waringin Estate Sukamara Estate Telaga Bintang Estate Sungai Rangit Smallholder

Central Kalimantan 2016 2016 2016 2016 2016 2016 2016 2019

Planned

1. 9 Compliance to Rules for Partial Certification

Compliance of the uncertified management units of PT Sampoerna Agro Tbk against the rules for partial certifi-cation according to RSPO Certification System clause 4.2.4 was assessed by Self Assessment and verification audit. A summary of findings is as stated below.

Partial Certification Requirements Audit Findings

(a) The parent organization or one of its ma-jorities owned and / or managed subsidiaries is a member of RSPO.

PT Aek Tarum and PT Mutiara Bunda Jaya (Inti Per-mata Bunda Dua Estate) are subsidiary of PT Sam-poerna Agro Tbk. Sampoerna Agro has been a mem-ber of RSPO since 10 January 2007 With member-ship no 1-0031-07-000-00.

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Partial Certification Requirements Audit Findings

(b-d) A challenging time-bound plan for certi-fying all its relevant entities is submitted to the Certification Body (CB) during the first certification audit. The time-bound plan should contain a list of subsidiaries, estates and mills.

Any revision to the time-bound plan or to the circumstances of the company shall cause the plan to be reviewed. for whether it is still appropriate, such that changes to the time-bound plan are permitted only where the or-ganisation can demonstrate that they are justified

A challenging time bound plan has been establish as determined by memorandum of PT Sampoerna Agro Management Commitment signed by CEO on June 01, 2015.

This is the 2nd revised time bond plan of PT Sam-poerna Agro Tbk. Considering the readiness of all subsidiaries palm oil mill and estates under PT Sampoerna Agro Tbk.

(e) No replacement of primary forest or any area identified as containing High Conserva-tion Values (HCVs) or required to maintain or enhance HCVs in accordance with RSPO criterion 7.3. Any new plantings since Janu-ary 1st 2010 must comply with the RSPO New Plantings Procedure

There is no evidence of replacement primary forest in subsidiaries under sampoerna Argo. Some new development area under subsidiaries of PT Sam-poerna Agro i.e.

PT Sungai Rangit, PT Mutiara Bunda Jaya; PTTel-aga hikmah and PT Sampoerna Agro are under verification process for New Planting procedure.

(f) Land conflicts, if any, are being resolved through a mutually agreed process, e.g. RSPO Grievance procedure or Dispute Set-tlement Facility, in accordance with RSPO criteria 6.4, 7.5 and 7.6.

There are identified ongoing land conflicts in several subsidiaries of PT Sampoerna Agro such as:

1. Mega Terang estate with community from Sungai Menang Village for 600 ha located in Block 14, 15 and 16 Mega Terang Estate.

2. PT Aek Tarum with Mataram Jaya dan Com-munity of Kemang Indah village

3. PT Mutiara Bunda Jaya with community of Sungai Menang and Rantau Durian I Village.

Some action has been taken to solve the conflict.

(g) Labour disputes, if any, are being re-solved through a mutually agreed process, in accordance with RSPO criterion 6.3.

In year 2015 there is no labour dispute in all sub-sidiaries PT Sampoerna Agro Tbk.

(h) Legal non-compliance, if any, are being resolved in accordance with the legal re-quirements, with reference to RSPO criteria 2.1 and 2.2.

Some of management units under Sampoerna Agro have not complied with certain legal require-ments, for example in PT Sungai Rangit, PT Muti-ara Bunda Jaya and others, there is an issue with the land area stated in the land use right certificate (HGU). However, the company is taking action by inviting the National Land Agency (BPN) to re-measure the land and resolve the issue. The pro-cess is still ongoing.

1.10 Plan for certification of associated smallhold ers Belida mill has 8 (eight) scheme smallholders and 10 (ten) independent outgrowers that supply FFB to their mill. For each smallholders certification was explained in time-bound plan for certification.

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1.11 Approximate Tonnages Certified

The approximate tonnages certified, based on production in year 2016 for company owned estates only are as follows:

Crude Palm Oil (CPO) : 20,817.81 tonnes Palm Kernel (PK) : 5,146.19 tonnes While the projection for FFB production for year 2016 is 97,098.023 tonnes from scope of certified FFB (com-panies’ owned estate and smallholders)

1.12 Recommendation for Certification

PT Aek Tarum (Belida Mill) its supply based estates has established and maintains an effective system to en-sure compliance with the RSPO principles and criteria. The audit team has confirmed through the audit pro-cess that the company’s practices complies with, adequately maintains and implements the requirements of RSPO Principles and Criteria Generic Standard. PT TUV Rheinland Indonesia recommends that Belida Mill and its supply bases are approved to renewal its certificate as a producer of RSPO Certified Sustainable Palm Oil.

1.13 Date of Certificate Issued and Scope of Certif icate

The scope of the certificate covers production of palm oil from Belida Mill and its supply base, which includes Belida estate, IPBS estate and smallholder (Tekad Mandiri, Jaya Bersama and Panca Sawit Makmur). The date of certificate issued is August 12, 2016. Further details of the certificate are as per Appendix 1.

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2.0 ASSESSMENT PROCESS

2.1 Certification Body PT TUV Rheinland Indonesia is member of Group TÜV Rheinland Group, a global leader in independent test-ing and assessment services. The TÜV Rheinland Group was established in 1872 with offices located in over 490 locations in 62 countries on all five continents. PT TUV Rheinland Indonesia offers certification for a wide range of management systems according to established international standards including ISO 9001, ISO 14001, OHSAS 18001, SA 8000, as well as CDM Validations and Verifications. PT TUV Rheinland Indonesia’s office is located in Jakarta, Indonesia.

2.2 Qualifications of Lead Assessor and Assessment Team

Name Position Qualifications / Experience

Naik Monang Parlin-dungan Lingga

Lead Auditor

Education: Bachelor of Forestry, Gadjah Mada University. Training attended : ISPO Auditor, Quality Management System (QMS) Auditor/Lead Auditor (ISO 9001:2008) by IRCA, Environmental Management Systems Auditor/Lead Audi-tor Conversion Training by IRCA (ISO 14001-2004), Lead Auditor RSPO Training, HCVA Training and RSPO SCCS Training (2016) Working experience: Field Assistant PT Sapta Karya Damai (2008-2013), Auditor in PT Sucofindo (2013-2015), and Auditor in PT TUV Rheinland Indonesia (2015-present).

Riswan Auditor

Education: Magister of Natural Resource and Environment Management – University of North Sumatera and Bachelors Degree in Forestry – Bogor Agriculture Univer-sity. Trainings attended : ISPO Auditor course, HCV training Working experience: Experienced as profesional consultant in environmental and conservation sec-tor and HCV assesor

Andi Lubis Auditor

Education: Bachelor of Agriculture, University of Padjajaran – West Java. Trainings attended : ISO 9001:2008 Series Auditor / Lead Auditor Training – TUV Rheinland Indo-nesia (Jakarta), ISO 14001:2009 Auditor / Lead Auditor Training Course – TUV Rheinland Indonesia (Jakarta), ISPO training - Comission of ISPO. Working experience : Experienced in Bakrie Sumatera Plantation, Tbk since 2007-2011, and Auditor for Quality Management System since 2011 – present. Auditor for Environ-mental Management System since 2014 – present. Auditor for ISPO since 2013 - present.

Doni Auditor

Education: Master in Rural Sociology, Graduate School of Bogor Agricultural University completed in 2005. Trainings Attended: GIS Training, Auditor Training of Indonesian Sustainable Palm Oil (ISPO), Training of Participatory Mapping, Training of Document Preparation HCV and SIA, Auditor Training of Sustainable Production Forest Management (SFM),

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Training and Up-Grading of SFM, Training of Mentoring technique for the Ru-ral Farmers, Conflict Resolution Training and Journalism Training. Work Experience : Frequently conducted certification audits of RSPO and ISPO for Palm planta-tion, the certification audit of SFM (Sustainable Production Forest Manage-ment) for HPH and HTI, worked as a consultant for the National Development Planning Agency, Ministry of Environment and Forestry, Indonesian People Bank (BRI), Ministry of Rural Development (KPDT) and the Ministry of Public Works, Director General of Cipta Karya, JICA and UN-HABITAT and UNDP, HCVF document drafting team for the company of HTI, HPH and constituent team for documents of HCV / SIA for oil palm plantations. Since March 2016 till now, work at PT. TUV Rheinland Indonesia.

2.3 Assessment Methodology & Agenda The recertification assessment was conducted between April 18th until 23th, 2016 as per the assessment pro-gram below. The assessment was carried out in accordance with’s RSPO audit procedure as well as the RSPO Certification Systems document. During assessment, the qualified TUV Rheinland assessors used the RSPO standard as endorsed for the country in which the assessment took place and recorded their findings.

Due to the location and proximity of the estates, combined with common management systems, it was possible to carry out both field and document assessments of all estates and the mill within the time frame without com-promising the integrity of the assessment in anyway.

All owned company’s estates (2 estates), 1 mill and 3 smallholder’s estate were visited and the assessment team carried out field and document assessments of compliance to all the RSPO principles and criteria. Com-mon systems were identified and specific evidence was recorded for individual estates. Interviews were con-ducted at all estates and the mill.

The company proposed the correction and corrective action for all identified non conformities raised to the certi-fication body 30 days after the closing meeting. Verification of closure of major non-conformances was con-ducted 2 months after the closing meeting of the recertification audit and implementation of corrective actions for minor non-conformities will be verified during the next suriveillance audit. The recertification assessment agenda is as explained below.

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Recertification Assessment Agenda

Location/ Main

sites Main activities

18.04.2016 Belida Mill Opening meeting • Introduction and background of estate and mill • Audit team introduction and audit plan finalization • Document Checking

19.04.2016 IPBS Estate Site Visit: • Interview with contracted FFB loaders • Interviews with harvesters and loose fruit pickers Block 28B/28C • EFB Application area • Chemical store

IPBS Estate office: Document Review Legal Requirements (OSH and Environment), OSH, Training, SOP’s of Legal requirements register and implementation, Field operations (spraying, harvesting, manuring), fertilizer application records, chemical application records, chemical stock inventory, worker interviews , visit of chemical stores, workshops, HIRARC, OSH Commit-tee and safety records, accident records,training and PPE issuance, waste storage also hazardous waste inventories and manifest.

20.04.2016 Belida Estate Site Visit: • Interviews with Sprayers for Belida Estate Block 18 • Interview with contracted FFB loaders • Interviews with harvesters and loose fruit pickers • EFB Application area Block 23C • Chemical store • Pillars of HGU No. 142, 12, 141

Belida Estate office: Document Review Legal Requirements (OSH and Environment), OSH, Training, SOP’s of Legal requirements register and implementation, Field operations (spraying, harvesting, manuring), fertilizer application records, chemical application records, chemical stock inventory, worker interviews , visit of chemical stores, workshops, HIRARC, OSH Commit-tee and safety records, accident records,training and PPE issuance, waste storage also hazardous waste inventories and manifest.

21.04.2016 Cooperative (Pan-ca Sawit Makmur, Tekad Mandiri and

Jaya Bersama)

Cooperative office: Document Review Legal Requirements (OSH and Environment), OSH, Training, SOP’s of Legal requirements register and implementation, Field operations (spraying, harvesting, manuring), fertilizer application records, chemical application records, chemical stock inventory, worker interviews , visit of chemical stores, workshops, HIRARC, OSH Commit-tee and safety records, accident records,training and PPE issuance, waste storage also hazardous waste inventories and manifest.

Stakeholder consultation

Stakeholder consultation meeting • Presentation on TUV Rheinland and RSPO • Introduction to purpose of the stakeholder consultation • Feedback and comments on from stakeholders.

22.04.2016 Cooperative (Pan-ca Sawit Makmur, Tekad Mandiri and

Jaya Bersama)

Site Visit: • Chemical store • Pillars of cooperative no. Kav 1578/1579 (Panca Sawit Makmur)

Belida Mill Mill visit

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2.4 Stakeholder Consultation and Stakeholders Conta cted The stakeholder consultation involved both external and internal stakeholders. External stakeholders were noti-fied to make comments on the certification assessment by placing an invitation to comment on the RSPO web-site. Stakeholders included those immediately linked with the operation of the company such employees, out-growers, the local government, NGO’s, trade and labour unions and local communities.

Stakeholder consultation took place in the form of meetings and interviews. Meetings with stakeholders were held to seek their views on the performance of the company with respect to the sustainability practices outlined in the RSPO Principles & Criteria, and to comment on aspects where improvements could be made. Meetings with local communities were held at their respective premises within and near the company’s area. A stake-holder consultation meeting was also held on Head office of Mulya Jaya Village on April 21, 2016. Letters invit-ing individual stakeholders to the stakeholder consultation meeting were prepared and sent to the individual stakeholders, while electronic mail and telephone calls were made to arrange the meetings.

In all the interviews and meeting, the objectives of the RSPO and the purpose of the assessment was clarified at the outset followed by an evaluation of the relationship between the stakeholders and the company before discussion proceeded to obtain the stakeholders feedback on the company’s compliance to different aspects of the RSPO Principles & Criteria. Although several stakeholders were not familiar with RSPO but they agreed with its objective and expressed their willingness to collaborate in the promotion of sustainable palm oil in South Sumatera province. In all interviews and meeting, the assessment team did not restrict discussion of both the positive and negative aspects of operations conducted by PT Aek Tarum estates and mill.

The stakeholder consultation meeting held with stakeholders during the audit was extensive and productive, with an attendance of more than 20 of attendees. This was followed by site inspections, including visits to the local communities, interviews with land claimants and contractors, and inspections of worker amenities and in-frastructure. All stakeholder issues raised were recorded and forwarded to the management for their written re-ponse, and this is summarized in Section 3.4.The list of stakeholders that attended the stakeholder consultation meeting and stakeholders interviewed during the assessment is included as Appendix 4.

2.5 Date of Next Surveillance Visit

The next surveillance visit is planned for April 2017

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3.0 ASSESSMENT FINDINGS

3.1 Summary of Findings RSPO Principle and Criteria During the certification assessment, a total of 13 nonconformities were identified against RSPO P&C and RSPO Smallholder these consisted of 7 major non-conformities and 6 minor non-conformities. The 21 observa-tions or opportunities for improvement were identified. Further explanation of the non-conformities raised and corrective actions taken by the company are provided in Section 3.2. The observations & opportunities for im-provement are listed in Appendix 5.

The following is a summary of findings made for the criteria listed in the RSPO Principles & Criteria Generic Standard 2013.

Criterion 1.1: Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages & forms to allow for effective participation in decis ion making.

Findings: PT Aek Tarum mill and estates still maintain the procedure to provide adequate information to relevant stakeholders on environmental, social and legal issues relevant to RSPO and how to respond to the re-quest of information. The procedure is Doc. No. P-SAG-HO-CA & L-08, Rev. No. 2 in Januari 1, 2016 Prosedur Komunikasi, Partisipasi dan Konsultasi (Communication, Participation and Consultation). This procedure mentioned the mechanisms on how the company would provide adequate information relevant to RSPO criteria to relevant stakeholders for effective participation in decision making such as environ-mental, social and legal issues. The information shared to the stakeholders was about RSPO: legal status of the company and free prior inform consent; plans and impact assessments relating to environmental and social impacts; positive and negative impact of company activities to the community; environmental protection and biodiversity conservation (HCV); pollution prevention and reduction plans; details of com-plaints, grievances and negotiation procedures; community social responsibility program; no gender dis-crimination, no human traficking, no children labor and human right policy. This procedure was communicated to the stakeholders during the stakeholder meeting last year dated in November 20, 2015. During the meeting PT Aek Tarum informed them about above issues. The aim of the meeting is to comunicate the issues and to get feedback from them to improve the RSPO’s implemen-tation in the company. The auditor checked the minutes of meeting and during public consultation the au-ditor noted that stakeholders received this information appropr iately.Records of the meeting were kept well in Notulensi Pertemuan dengan Stakeholder (Minutes of Stakeholder Meeting). The company has a list of stakeholders and it is updated yearly. PT Aek Tarum keeps the records of requests on information and assistantance/donation from related par-ties as well as its responses in the form Rekaman Penerimaan Informasi dan Tanggapan Stakeholder (Record of Information Request and Responses). The records contain information ofreferences of letter, date, name, organization/institution, information/donation/assistance requested, action taken to the re-quest, person in charge whom follows up and status of the request. For example, On March 23, 2016, Junior High School (SMPN I) Mesuji Raya requested assistant for vehicle operation, related to the re-quest, company helped by lending one unit bus on March 30, 2016. Compliance status: Full Compliance

Criterion 1.2: Management documents are publicly av ailable, except where this is prevented by commercial confidentiality or where disclosure of i nformation would result in negative environ-mental or social outcomes.

Findings: PT Aek Tarum mill and estates still maintain the procedure to provide adequate information to relevant stakeholders on environmental, social and legal issues relevant to RSPO and how to respond to the re-

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quest of information. The procedure is Doc. No. P-SAG-HO-CA & L-08, Rev. No. 2 in Januari 1, 2016 Prosedur Komunikasi, Partisipasi dan Konsultasi (Communication, Participation and Consultation). This procedure mentioned the mechanisms on how the company would provide adequate information relevant to RSPO criteria to relevant stakeholders for effective participation in decision making such as environ-mental, social and legal issues. The information shared to the stakeholders was about RSPO: legal status of the company and free prior inform consent; plans and impact assessments relating to environmental and social impacts; positive and negative impact of company activities to the community; environmental protection and biodiversity conservation (HCV); pollution prevention and reduction plans; details of com-plaints, grievances and negotiation procedures; community social responsibility program; no gender dis-crimination, no human traficking, no children labor and human right policy. Compliance status: Full Compliance Criterion 1.3. Growers and millers commit to ethica l conduct in all business operations and trans-actions. Findings:

The Company has a policy of business ethics code namely:

I. ANGGARDA PARAMITA (Towards Consummation)

Value 1: meritocratic System "Award system on individual performance in accordance with the compe-tence and achievement in organizational goals."

Value 2: Requisite Organization "Organizations that promote good conditions for all parties to be able to work together effectively and the maximally, in order to reach the goals.

II.THE THREE-HAND PHILOSOPHY (Sustainability of the relationship between the three parties that is mutually beneficial to each other)

Value 3: Teamwork & Flexibility "Cooperation between the employee, employer and both remain con-cerned with common interests than personal interests."

Value 4: Respect "Behavior of mutual respect, both inside and outside the organization."

Value 5: Integrity and Ethics "The consistency between the values adopted, the actions taken and the re-sults achieved."

Value 6: Community "Delivering value to the local community, as a stakeholder of the organization."

Policy of business ethic code had been communicated to all levels of employees at Inti Permata Bunda Satu (IPBS) Estate, on March 16, 2016. The location was in Block 31, Plot B (a morning assembly loca-tion), attended by 37 people. Then to all levels of POM Belida’ employees on March 8, 2016, that was at-tended by 27 people and Estate Belida on March 17, 2016.

Business ethics code policy is also installed and displayed at IPBS Estate office and the Office of Division I and POM office.

Compliance status: Full Compliance

Criterion 2.1: There is compliance with all applica ble local, national and ratified international laws and regulations.

Findings: The company has procedure of law and other requirement (No.P-SAG-RO-SUS-07 revision 2, effective date October 30, 2015). Procedure describes that law and legislation renewal conducted once a year. The

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company has distibuted copy of legal requirement to all units both of estate and mill.

The company has document system. Person incharge of document system is sustainibility. The company has been identified the legislation namely international, national, province and district accordance to legal reguirement of estate and mill.

The company has been conducted internal audit once a year to check company legality. The internal audit conducted by sustainibility. The company has system to check changes of legislation once a year. The source of information from internet browsing and also from CAS department and HRS department. Some of the the provisions of laws and regulations that has not fulfill by the company such as:

• Based on the mill visit on Belida Mill was found one engine room operator on behalf of Lukman which works in the risk of noise has not been conducted periodic health examinations as required Permenakertrans No. Per.02 / MEN / 1980 About the Health Workforce in the Implementation of Work Safety

• Can not show sufficient evidence that the Activity Report of Committee of Occupational Safety and Health (P2K3) for 2 (two) last quarter of 2015 and Quarter 1 (first) 2016 has been reported to the Minister through the Office of the Ministry of Manpower as required Permenaker No. PER.04 / MEN / 1987 About Committee of Occupational Health and Safety and Procedure for Appointment of Expert Safety

• Use of groundwater is not in accordance with the permit, which limit of maximum usage of is 100 liters / minute and also there is no evidence that there is a monthly reporting to the relevant agen-cies (the Department of Mines). Reference:

a. Decree of Head Mining and Energy agency Ogan Komering Ilir District No. 540.135.A/Kep/DPE/2013

b. Decree of Head Mining and Energy agency Ogan Komering Ilir District No. No. 540.33.A/Kep/DPE/2013

It was raised as Nonconformities (RSPO 00230). Compliance status: Non Compliance

NCR RSPO 00230 (Major non-conformity) Some of the the provisions of laws and regulations that has not fulfill by the company such as:

• Based on the mill visit on Belida Mill was found one engine room operator on behalf of Lukman which works in the risk of noise has not been conducted periodic health examinations as required Permenakertrans No. Per.02 / MEN / 1980 About the Health Workforce in the Implementation of Work Safety

• Can not show sufficient evidence that the Activity Report of Committee of Occupational Safety and Health (P2K3) for 2 (two) last quarter of 2015 and Quarter 1 (first) 2016 has been reported to the Minister through the Office of the Ministry of Manpower as required Permenaker No. PER.04 / MEN / 1987 About Committee of Occupational Health and Safety and Procedure for Appointment of Expert Safety

• Use of groundwater is not in accordance with the permit, which limit of maximum usage of is 100 liters / minute and also there is no evidence that there is a monthly reporting to the relevant agen-cies (the Department of Mines). Reference:

a. Decree of Head Mining and Energy agency Ogan Komering Ilir District No. 540.135.A/Kep/DPE/2013

b. Decree of Head Mining and Energy agency Ogan Komering Ilir District No. No. 540.33.A/Kep/DPE/2013

Criterion 2.2: The right to use the land can be dem onstrated, and is not legitimately contested by local communities with demonstrable rights.

Findings: The company has document of legality i.e:

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IPBS Estate • Head of national land agency decree No. 16/HGU/BPN/2002 dated April 29, 2002 about land use

rights on Ogan Komering Ilir District, South Sumatera Province as large as 552.24 ha for 35 years to PT Mutiara Bunda Jaya

• Certificate of Land use rights No.01 on Sumber Baru Village as large as 552.24 ha with effective date until May 14, 2037 accordance with head of national land agency decree No. 16/HGU/BPN/2002 dated April 29, 2002. This certificate issued on May 15, 2002 on Kayu Agung, Ogan Komering Ilir

Belida Estate

• Head of national land agency decree No. 10/HGU/BPN/2001 dated July 3, 2001 about land use rights on Mesuji sub district, Ogan Komering Ilir District, South Sumatera Province as large as 4,769.60 ha for 35 years to PT Aek Tarum that has describes on specific situation map dated March 19, 1992 No.02/1992 as large as 2,189.70 ha and dated April 29, 1992 No.04/1992 as large as 2,579.90 ha.

• Certificate of Land use rights No.02 on Sumbu Sari Village as large as 2,579.90 ha with effective date until August 22, 2036 accordance with head of national land agency decree No. 10/HGU/BPN/2001. This certificate issued on August 22, 2001 on Kayu Agung, Ogan Komering Ilir

• Head of national land agency decree No. 85/HGU/BPN/2005 dated July 5, 2005 about land use rights on Mesuji sub district, Ogan Komering Ilir District, South Sumatera Province as large as 825.70 ha for 35 years to PT Aek Tarum that has describes on land section map dated Decem-ber 17, 2004 with No.18/OKI/2004 as large as 87 ha, No.19/OKI/2004 as large as 181 ha, No.20/OKI/2004 as large as 67.50 ha, No.21/OKI/2004 as large as 95.60 ha, No.22/OKI/2004 as large as 78.20 ha, No.23/OKI/2004 as large as 51.30 ha and No.24/OKI/2004 as large as 265.10 ha

• Certificate of Land use rights No.23 on Ogan Komering Ilir Village as large as 181 ha with effec-tive date until July 6, 2040 accordance with head of national land agency decree 85/HGU/BPN/2005 dated July 5, 2005. This certificate issued on July 29, 2005 on Kayu Agung, Ogan Komering Ilir

• Certificate of Land use rights No.24 on Ogan Komering Ilir Village as large as 51.30 ha with ef-fective date until July 6, 2040 accordance with head of national land agency decree 85/HGU/BPN/2005 dated July 5, 2005. This certificate issued on July 29, 2005 on Kayu Agung, Ogan Komering Ilir

• Certificate of Land use rights No.25 on Ogan Komering Ilir Village as large as 78.20 ha with ef-fective date until July 6, 2040 accordance with head of national land agency decree 85/HGU/BPN/2005 dated July 5, 2005. This certificate issued on July 29, 2005 on Kayu Agung, Ogan Komering Ilir

• Certificate of Land use rights No.26 on Ogan Komering Ilir Village as large as 265.10 ha with ef-fective date until July 6, 2040 accordance with head of national land agency decree 85/HGU/BPN/2005 dated July 5, 2005. This certificate issued on July 29, 2005 on Kayu Agung, Ogan Komering Ilir

• Certificate of building use rights No.01 on Sumber Baru Village as large as 7,500 m2 with effec-tive date until September 24, 2021. This certificate issued on January 22, 2002 on Kayu Agung, Ogan Komering Ilir

The company has work instruction about making and maintenance of HGU pillars (WI-SAG-KBN-PML-0206 revision 0, issued date March 2, 2015. The work instruction stated that maintenance of HGU pillars conducted every once a year. The company has map of HGU pillars. Based on report of pillars checking on IPBS estate that has been conducted on March 2016, there are 36 pillars. Companies not yet have an official map of HGU pillars stone that can show the location of the concession pillars stone in the field. For example: during field visits in Block 28 B (IPBS), for pillars stone number 12 can not be found in the field and pillars stone in Belida HGU not yet maintenance. It was raised as Non-conformities (NCR RSPO 00232). Based on the data area statement in February 2016 and the result of interview with the Village Head of Mulya Jaya and Sumber Baru, note that no cases of land disputes in the company area. Compensation or the entire land acquisition has been completed in 2006. Until now there is no demand or the company's

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land claims by communities around the estate.

The company has the SOP for Technical Manual of Land Acquisition (No. Document: SOP 29 / BM / (0) 0409) dated 13 April 2009. The procedure is drafted and designated as a technical guide which is used to ensure that the decision, or action steps in the process of land acquisition for the benefit of the palm oil industry is done properly and correctly in accordance with the provisions and the applicable legislation, the principles and criteria of the RSPO, HCVF, and EFIC particularly for land which is related to commu-nal/customary land.

Participatory mapping of land conflicts was contained in SOP Technical Guidelines for Land Acquisition (No. Document: SOP 29 / BM / (0) 0409) dated April 13, 2009. Based on a review of documents on land compensation records (described in indicator 2.2.3) note that the parties participating in the implementa-tion stages of land acquisition or compensation, each document was witnessed by the village head and sub district head.

The policy has been disseminated to the workers in Estate I, 2 and 3 on 4 Februari 2016, and to workers in Pom 1 and 2 on February 8, 2016. Based on the results of interviews with community leaders and vil-lage officials of Sembuluh I and II, explained that the company has never used violence and intimidation in doing operations and not use mercenaries in land acquisition.

Compliance status: Non Compliance NCR RSPO 00232 (Minor non-conformity) Companies not yet have an official map of HGU pillars stone that can show the location of the concession pillars stone in the field. For example: during field visits in Block 28 B (IPBS), for pillars stone number 12 can not be found in the field and pillars stone in Belida HGU not yet maintenance.

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

Findings: The company has the SOP Free Prior and Informed Consent in prosedure Ganti Rugi Lahan dan/atau TanamTumbuh (Doc. No. P-SAG-RO-CAS-03) applies on December 2, 2013. Within the SOP described FPIC stages, those are: Identification of customary lands, Involving the community institutions, Delivering information, Ensure that the consent was given voluntarily, Guarantee that the approval was given before operations, Ensure that there is an agreement, Resolve conflicts, Negotiation, Finalization of the written agreement.

In interviews with the village head of Mulya Jaya and Sumber Baru, it was explained that there are no in-digenous land or customary rights in the area of the company. Since the beginning of land acquisition for the construction of the estate, there is no customary land or customary rights in the area of the company. Legality of land in the community is SKT document issued by the village and sub-district head, SHM (Ownership Certificate), inherited land and the deed of land sale and purchase.

Compliance status: Full Compliance

Criterion 3.1: There is an implemented management p lan that aims to achieve long-term eco-nomic and financial viability.

Findings: PT Aek Tarum has Business Plan produced on January 2015 valid for 5 years (2015 to 2019). The Busi-ness Plan include land area statement for planted area only, smallholder development, crop projection un-til 2019, OER trends, cost of production, forecast prices. The business plan is reviewed every five year; however annual budget could be modified subject to change of condition of activities.

Some observation has been made on additional information on land area statement whereis HCV area and other use area should be included as well map of concession area. On the cost section is also should

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expanded to allocation for social environmental cost and research and will be represented in totalcost per ton FFB/CPO production. PT Aek Tarum has a procedure to improve practises No. P-SAG-RO-RST-01 dated on January 1st, 2016 with R&D division responsible for the improvement. Planning Monitoring and Evaluation Research staff provides annual planning agenda, monitoring and evaluation on report and research dissemination, re-search development monitoring and research data preparation. Some improvement has been applied among as: Cordycept application for biopesticide as pasrt of Integration Pesticide Management, and ferti-lizing spreader. This improvement usually disseminated by R&D division to the field/estate staff. Neither in Belida estate nor IPBS estate, palm oil tree needed to be replanted since the eldest tree were planted in 1993 with area 408.2 ha in IPBS estate, so does in Belida estate the eldest tree were planted in 1990 with area 710.3 ha. Both of those areas will be replanted as soonest as year 2020, so the annual replanting is still not programmed in recent Business Plan. Compliance status: Full Compliance

Criterion 4.1: Operating procedures are appropriate ly documented and consistently implement-ed and monitored.

Findings: PT Aek Tarum has the Integrated Management System Manual that covers all activities of the company (Mill activity and Plantation activity). The procedures are appropriately documented, such as:

• The procedure related to activities of the Plantation, starting from land preparation, Nursery, Planting, Integrated Pest Management, Fertilization of Immature/Mature Palm, until POME appli-cation , with no. document, from P-SAG-KBN-PML-01 to P - SAG-KBN-PML-26

• The Procedures Related to production activity in the field includes forecasting Production proce-dures (P-SAG-KBN-PRD-01), Harvesting of FFB (P-SAG-KBN-PRD-02) and the Transportation of FFB to the mill

• The procedure related to Mill activity includes Recording and weighing of FFB, Loading Ramp, Sterilization, Press Station, Water Treatment and also Permit System, with no documents start to P-SAG-MCC-PRS-01 until P-SAG-MCC-PRS-16

• The procedure related to maintenance activity, including procedure of maintenance and Repair (P-SAG-PKS-MTC-01) and Manufacturing procedures (P-SAG-PKS-MTC-02)

• Additionally the procedures related to Supply Chain Requirements are also well-documented as procedures Traceability and Mass balance (P-SAG-MCC-PRS-14)

Some of the procedures were supported by working instructions and the monitoring of operational activi-ties was recorded in operational forms and also with the appropriate language and understood by the workers. During the field visit for some activity in Belida Estate and IPBS, for example in Block 06 A /Belida Estate (Thuride Application), Blok 32/ IPBS Estate (Harvesting activity), Division 3 Blok 18 Belida Estate (Wiping Weeds), all of workers have understood the related procedures.

Master list of all documents can be seen in Documents List Form (FM-SAG-RO-SUS-010004, Rev 01) and the document can be identified of historical revision of each procedures. The mechanism for control-ling the document refers to the Procedure of Document Control (P-SAG-RO-SUS-01). In order to support consistency of implementation procedures and competency gaps of the competency gap analysis which conducted and / or from job requirements, every year the company doing the training, such as Boiler Op-erator, Lifting equipment operator, Restricted pesticide for sprayers and Hyperkes Training for Paramed-ics. All the evidence related to the implementation of training are well documented

Besides that to checking the consistency implementation of procedures, the company establishes some control mechanisms, such as Plantation Management and Improvement (PM & I) to check harvesting quality. Another control mechanism is by the Internal Audit that conducted once a year and covering of all the SOPs and its implementation refers to the Internal Audit Procedures (P-SAG-RO-SUS-03). Last Inter-nal Audit was performed on 5 November 2015 for Mill and Estate. Internal auditors that appointed have been trained and competent. For example: Jenny Verawaty Siburian and Mr. Mika Asri who is the new auditors, has been trained in March 2015 and the evidence of training has been documented. In case, non-compliance is found, follow-up of non-compliance refer to the Corrective Action Procedure (P-SAG-RO-SUS-04) and Preventive Action (P-SAG-RO-SUS-05) for continuous improvement. Records of moni-

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toring and any actions taken has been maintained and available in “Laporan Audit ( FM-SAG-RO-SUS 030006) and “ Permintaan Tindakan Perbaikan (CAR) FM--SAG-RO-SUS 040001)”

There is FFB supplied by third parties. The regulated relating to Third- Parties FFB suppliers determined in the Contract which includes Price, Quality Assessment and Payment. This contract approved by the Di-rectors Mr. Lim King Hui. During the audit, one of the contract documents has been verified is “Perjanjian Pemasokan Kerjasama antara PT Aek Tarum dan KUD Tekad Mandiri No 005/AT/SPK/I/2015” and the implementation of the contract was consistent. Summary Records of volume and origins of third party FFB received were recapitulated every month. During the 2015, FFB received for Scheme Smallholder is 194.549.743 Kg Compliance status: Full Compliance

Criterion 4.2: Practices maintain soil fertility at , or where possible improve soil fertility to, a le vel that ensures optimal and sustained yield.

Findings: The company has procedure about palm oil fertilizer with document number P-SAG-KBN-PML-21 revision 01 dated March 16, 2012. In the palm oil fertilizer procedure include work instruction i.e:

• Work instruction with document number WI-SAG-KBN-PML-2102 revision 0 dated March 16, 2012 about application of an organic fertilize. The work instruction regulated about mechanism of fertilizer application, when the fertilize must be applied, how to applied, man power of fertilizer and doses of fertilize

• Work instruction with document number WI-SAG-KBN-PML-2103 revision 0 dated March 16, 2002 about application of organic fertilize. The work instruction describes about mechanism of EFB application namely must be a layer and doses of application as much as 20 ton/ha.

The company has implemented the procedure with well and conducted regularly monitoring for implemen-tation of procedure. The company has records of fertilizer for organic fertilizer and an organic fertilizer un-til December 2015 and January until March 2016. The records of fertilizer realization have been seen that fertilizer activity conducted based on fertilizer program and recommendation of doses fertilize.

The company has record of fertilzer usage per tonnes FFB production. The realization of fertilizer for each estate such as: IPBS Estate (Year 2015)

• Urea: total of realization until December 2015 as much as 173,100 kg with FFB production as much as 10,737 tonnes. So, fertilizer usage per tonnes FFB production as much as 16.12 kg/tonnes FFB

• RP: total of realization until December 2015 as much as 105,700 kg with FFB production as much as 10,737 tonnes. So, fertilizer usage per tonnes FFB production as much as 9.84 kg/tonnes FFB

• MOP: total of realization until December 2015 as much as 215,600 kg with FFB production as much as 10,737 tonnes. So, fertilizer usage per tonnes FFB production as much as 20.08 kg/tonnes FFB

• Borate: total of realization until December 2015 as much as 173,100 kg with FFB production as much as 9,100 tonnes. So, fertilizer usage per tonnes FFB production as much as 0.84 kg/tonnes FFB

Belida Estate (Year 2015)

• Urea: total of realization until December 2015 as much as 673,237 kg with FFB production as much as 57,508.94 tonnes. So, fertilizer usage per tonnes FFB production as much as 11.70 kg/tonnes FFB

• RP: total of realization until December 2015 as much as 512,217 kg with FFB production as much as 57,508.94 tonnes. So, fertilizer usage per tonnes FFB production as much as 8.90 kg/tonnes FFB

• MOP: total of realization until December 2015 as much as 893,946 kg with FFB production as much as 57,508.94 tonnes. So, fertilizer usage per tonnes FFB production as much as 15.54 kg/tonnes FFB

• Super Dolomite: total of realization until December 2015 as much as 135,161 kg with FFB pro-

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duction as much as 57,508.94 tonnes. So, fertilizer usage per tonnes FFB production as much as 2.35 kg/tonnes FFB

• Borate: total of realization until December 2015 as much as 34,237 kg with FFB production as much as 57,508.94 tonnes. So, fertilizer usage per tonnes FFB production as much as 0.59 kg/tonnes FFB

• ZA: total of realization until December 2015 as much as 74,000 kg with FFB production as much as 57,508.94 tonnes. So, fertilizer usage per tonnes FFB production as much as 1.28 kg/tonnes FFB

The company has procedure regulated about leaf and soil analysis which stated in the procedure with document number P-SAG-RST-ASE-01 revision 0 dated September 1, 2009 about palm oil fertilizer rec-ommendation. The procedure stated that the leaf analysis conducted every once a year and soil analysis conducted every 5 years. The company (IPBS estate and Belida estate) has been conducted leaf analysis on April 2015 by Research and Development PT Sampoerna Agro to get fertilizer recommendation for year 2016. The result of leaf analysis has been describes ingrident of nutrient i.e N, P, K, Ca, Mg, B. IPBS estate has been conducted soil analysis on March 31 until April 7, 2011 by Research and Development PT Sampoerna Agro and the company has schedule to put sampling soil analysis on April 2016. Belida estate has been conducted soil analysis on year 2014 and has been get the result of soil analysis that has been analyze by PT Bina Sawit Makmur Soil and Plant Analysis Laboratory.

The company has records of EFB application.IPBS estate has records of EFB application until December 2015 as large as 109.80 ha with total EFB applied as much as 4,421.70 tonnes and January until March 2016 as large as 49 ha with total EFB applied as much as 1,016 tonnes. Belida estate has records of EFB application until December 2015 as large as 519 ha with total EFB applied as much as 21,088 tonnes and January until March 2016 as large as 345 ha with total EFB applied as much as 7,374 tonnes.

Compliance status: Full Compliance

Criterion 4.3: Practices minimise and control erosi on and degradation of soils.

Findings: The company has soil map with scale 1:25,000. Based on soil maps can seen that the type of soil in IPBS estate and Belida estate namely Lithic hapludlts, Plinthic kanhapludults, Aquic dystrudepts and Arenic plinthaquic kandiudults. Based on filed visit and topography map, the location of IPBS estate and Belida estate is flat (0-8%).

The company has road maintenance program that stated on annual budget. The company has records of road maintenance, drain maintenance and box culvert for year 2015. Realization for each program for IPBS estate namely road maintenance as long as 84,123 meters, drain maintenance as long as 13,140 meters and box culvert maintenance as much as 14 units. For year 2016 (until March), realization for each program namely road maintenance as long as 28,850 meters, drain maintenance as long as 675 meters and box culvert maintenance as much as 8 units. Realization for each program for Belida estate for year 2015 namely road maintenance as long as 185,465 meters.

The company does not have peat land so this indicator not aplicable for this company. The company does not have fragile soil (sandy, low organic matter, acid sulphate soils) so the company has not management plan of fragile soils. Compliance status: Full Compliance

Criterion 4.4: Practices maintain the quality and a vailability of surface and ground water.

Findings: There is no specific water management available, but PT Aek Tarum has implemented the identification of water source, water use recording, and effluent management to avoid water source contamination, and water testing. In Belida estate, water is consumed as 379,388 m3 in 2015 for domestic use. In 2016 per January was 5,050 m3, February was 4,672 m3 and March was 5,076 m3. The water source for domestic

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use comes from well/borehole, whilst for mill operation is taken from Lempuing river. PT Aek Tarum has a permit to use surface water resource for mill namely SIPA PKS No. 540/069/KEP/DPE/2014 dated on June 23rd, 2014 valid for 2 years. Water use efisiency for mill was 1.2 m3/ton FFB, and for the whole op-eration including domestic use was 1.6m3/ton. Workers and staffs in Belida estate are using water from the boreholes, and the company should ensure the water quality meets the safety standard quality for domestic use. There is no evidence that the groundwater quality testing is done where the groundwater used by the employee is not contaminated with dangerous substances. It was raised as Nonconformities (NCR RSPO 00234).

Dabuk Hitam river is an important river spans across both estate and use by surround community. This river is also categorized as HCV area with total area of 28.55 ha. Rivers is protected by riparian zone maintenance and prohibition of chemical and fertilizing. Evidence of non fertilizing application along river side has been verified through monthly fertilizing reporting and ground check. Based on March 2016 fertil-zing report in Belida estate block 14 and 15 whereas part of Dabuk Hitam river laid on, NPK fertilizer ap-plied was 5,296 kg (block 14) and 5612 kgs (block 15). There are 3,049 trees in block 14 and 2,859 trees in block 15, with dose of 2kg/tree is known that all the trees on those blocks are not fertilized. Realization of fertilizing in block 14 was applied for 2,648 trees, and 2,806 trees in block 15, and the rest was not ferti-lized since they are laid on riparian zone. In similar, in IPBS estate is also implemented non fertilizing pol-icy on the riparian zone. In block 28 of IPBS estate, there is 486 trees on the riparian zone and separated from fertilizing activity. In addition to water source maintenance, PT Aek Tarum also applied annual water quality test, the latest test is conducted on May 9th, 2015 with evidence of SHU No. 660/764/SHU-LAB/V/2015 dated on May 28th, 2015 include pH, BOD and COD and TSS parameters. Restoration of riparian buffer zone is maintained well with bamboo and other trees (Terminalia catappa). Total rehabilitated area is 18.9 Ha with 6.9 km in IPBS, whilst 11 ha with 19.89 km in Belida. A 25 m buffer zone at both side of river is applied for riparian zones completed with signpost at IPBS, whilst 50 m buffer area is applied in Belida. In Belida estate riparian zones covered 2 blocks (14 and 15) and have been planted with bamboo with total of 561 clumps since 2011, and started on 2015 onward Terminalia catappa was introduced as restoration trees to enrich the diversity of vegetation. Totally 4 kms of riparian zones has been planted with bamboo in Belida and IPBS estate. Some of riparian zones are already veg-etated with some forest patches and rubber. SOP for protection riparian and buffer zone is included in SOP HCV management and monitoring No. P-SAG-KBN-NKT-02 issued on December 1st, 2015. The procedure regulates PIC, signpost, HCV pillar in-stallation, patrol and revegetation on bare land.

In the SOP mentioned there is a special conservation person who is responsible for supervise manage-ment and monitoring of HCV areas at the field, and reporting the activities. Mr. Gianti assigned as Con-servation Foreman with decree of assignment No. 011/BL/V/20115 dated on May 27th, 2015.

Based on ground verification, the implementation of SOP is quite good; there is found a signmark at the trees for forbidden chemical and fertilizing activity, maintained HCV signpost for riparian management, and HCV pillars, and there is also smester monitoring report.

To avoid watet pollution caused by mill operation, PT Aek Tarum has effluent management system with effluent processing installation come with some cooling pond, aerobic and anaerobic ponds to produce ef-fluent with BOD below 5000 mg. Effluent quality has been tested in every month, some results are :

• Certification (SHU) No. 660/1101/SHU-LAB/VII/2015 with testing date on 8-13 July 2015 by Provin-cial Environmental Agency of South Sumatera. Parameters tested are BOD5, COD, TSS, Fat and oil, N Total, pH debit max with result below the standard as South Sumatra Government regulation No. 08 year 2012 on Effluent Standard.

• Certification (SHU) No. 660/1243/SHU-LAB/VIII/2015 with testing date on 5-13 August 2015 by Pro-vincial Environmental Agency of South Sumatera. Parameters tested are BOD5, COD, TSS, Fat and oil, N Total, pH debit max with result below the standard as South Sumatra Government regulation No. 08 year 2012 on Effluent Standard.

• Certification (SHU) No. 660/1449/SHU-LAB/IX/2015 with testing date on 15-20 September 2015 by Provincial Environmental Agency of South Sumatera. Parameters tested are BOD5, COD, TSS, Fat and oil, N Total, pH debit max with result below the standard as South Sumatra Government regula-tion No. 08 year 2012 on Effluent Standard.

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• Certification (SHU) No. 660/1587/SHU-LAB/X/2015 with testing date on 8-13 October 2015 by Pro-vincial Environmental Agency of South Sumatera. Parameters tested are BOD5, COD, TSS, Fat and oil, N Total, pH debit max with result below the standard as South Sumatra Government regulation No. 08 year 2012 on Effluent Standard.

• Certification (SHU) No. 660/1723/SHU-LAB/XI/2015 with testing date on 4-8 November 2015 by Provincial Environmental Agency of South Sumatera. Parameters tested are BOD5, COD, TSS, Fat and oil, N Total, pH debit max with result below the standard as South Sumatra Government regula-tion No. 08 year 2012 on Effluent Standard.

• Certification (SHU) No. 660/1994/SHU-LAB/X/2015 with testing date on 8-13 November 2015 by Provincial Environmental Agency of South Sumatera. Parameters tested are BOD5, COD, TSS, Fat and oil, N Total, pH debit max with result below the standard as South Sumatra Government regula-tion No. 08 year 2012 on Effluent Standard.

• Certification (SHU) No. 660/0341/SPPC_ALC/III/2016 with testing date on 3-8 March 2016 by Pro-vincial UPTB Laboratory of South Sumatera. Parameters tested are BOD5, COD, TSS, Fat and oil, N Total, pH debit max with result below the standard as South Sumatra Government regulation No. 08 year 2012 on Effluent Standard.

PT Aek Tarum has a extension permit to discharge effluent to the river issued by Regent of Ogan Komer-ing Ilir District, No. 660.1/28/Kep/BLH/2014 dated on June 30th, 2014 valid for three years. Allowed limit to discharge effluent is 3000 m3 a day in maximum, and based on daily effluent debit monitoring from flow-meter it was still under the limit.

PT. Aek Tarum has a Water Treatment Procedure No. P-SAG-PKS-PRS-10 dated on September 1st, 2009. Processing of palm oil using water from the River Lempuing and its use is recorded on monthly. By 2015, some 241,742 m3 water used to process 252,829.65 tons of FFB or 0.96 m3 per ton TBS. Water is used not for processing only, but also for the needs of domestic and mill cleanlines. In total there are 381,147 m3 of water used during the year 2015 m3, or in average 1.51 m3/ton FFB. Water consumption in 2016 (up to March) was 72,130 m3 in total to process 25,707.943 tons FFB or 2.80 m3/ton FFB. Compliance status: Non Compliance NCR RSPO 00234 (Minor non-conformity) There is no evidence that the groundwater quality testing is done where the groundwater used by the em-ployee is not contaminated with dangerous substances

Criterion 4.5: Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques.

Findings: The company has IPM plan that has been stated on monthly program. The IPM program including monitor-ing and census of pest and controling of pest. The company techniques used such as biological (Turnera surbulata), chemical (performed if conditions of attacks have been above threshold) and also with the owl (Tyto alba). The company has integrated pest management procedures such as:

1. Pest monitoring procedures with the document number PT-SAG-KBN-PML-15 revision 1 dated March 16, 2012. This procedure is followed by work instructions include:

• Work Instructions marking of census lines with the document number WISAG-KBN-PML-1501 revision 01 dated March 16, 2012

• Work Instruction census of leaves pest the document number WISAG-PML-KBN-1502 revision 01 dated March 16, 2012

• Work Instruction Census of Rats Pest in Immature - Mature 3 with the document number WI-SAG-KBN-PML-1503 revision 01 dated March 16, 2012

• Work Instruction Census of Rats Pest in Mature ≥ 4with the document number WI-SAG-KBN-PML-1504 revision 01 dated March 16, 2012

• Working Instruction Census of Tirathaba pest with the document number WI-SAG-KBN-PML-1505 revision 01 dated March 16, 2012

2. Leaf pest control procedures with the document number PT-SAG-KBN-PML-16 revision 1 dated March 16, 2012. This procedure is followed by work instructions include:

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• Work Instruction leaves pest spraying with the document number WISAG PML-KBN-1601 revi-sion 01 dated March 16, 2012.

• Work Instruction Planting of beneficial plant with the document number WISAG-PML-KBN-1602 revision 01 dated March 16, 2012.

• Work Instructions picking of leaves pest with the document number WISAG-PML-KBN-1603 re-vision 01 dated March 16, 2012.

3. Tirathaba pest control procedures with the document number PT-SAG-KBN-PML-17 revision 1 dated March 16, 2012. This procedure is followed by work instructions include:

• Work Instructions spot Marking of Tirathaba with the document number WISAG-PML-KBN-1701 revision 01 dated March 16, 2012

• Work Instruction blanket spraying of Tirathaba pest with the document number WIE-SAG-KBN-PML-1702 revision 01 dated March 16, 2012.

• Work Instructions spot Spraying of Tirathaba pest with the document number WIE-SAG-KBN-PML-1703 revision 01 dated March 16, 2012.

4. Rat’s pest control Procedure in Immature - Mature with the document number P-SAG-KBN-PML-18 revision 1 dated March 16, 2012. This procedure is followed by work instructions include:

• Work Instructions Installation Rat Toxic with the document number WISAG-PML-KBN-1801 revi-sion 01 dated March 16, 2012.

IPBS Estate has a record of pest census starting in January to October 2015. Based on the results of the census records of pests that have been conducted, in April 2015 there is a rat attack rate above 25% and should be controlled by using Ratgone. IPBD estate has a pest census records starting in January to Oc-tober 2015. Based on the results of the census records of pests that have been conducted, in February 2015 there is a fire caterpillar attack rate above 5 piece / midrib and should be controlled by using Thu-riside. IPBS Estate has conducted training on pest officers involved in integrated pest management. Training provided, among other handling of pest, pest monitoring and census, the introduction of other types of pests. Training the last training was conducted in 27 November 2015.

Compliance status: Full Compliance

Criterion 4.6: Agrochemicals are used in a way that does not endanger health or the environ-ment. There is no prophylactic use of pesticides, e xcept in specific situations identified in na-tional Best Practice guidelines. Where agrochemical s are used that are categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternativ es, and this is documented.

Findings:

The company is committed that pesticide use does not endanger health or the environment. This com-mitment is declared in the company policy which is signed by the Sampoerna Agro Group Chief Executive Officer in July 2015. The company has SOPs for use of selective products that are specific to target pests, weeds, or diseases and which have minimal effect on non-target species. For example: Round-Up (active ingredient glyphosate isopropyl amine 486g / L) for control of narrow-leaved weed and Metsullindo 20 WP (Active Ingredients Methyl metsulfuron) for control of Clidemia Hirta (CH) Weeds. Furthermore, the company also did measures to avoid the development of resistance with pesticide rotation. Rotation of pesticide use can be seen in the work program, including the dosage of pesticide according to the rec-ommendations of the pesticide. Related justification of pesticide use can be seen in the document of ““Justifikasi Penggunaan Pestisida Kebun Belida & IPBS Tahun 2016” including the identification of active ingredients used, LD 50, categorized of pesticide as WHO Class refer to The WHO Recommended Clas-sification of Pesticides by Hazard and Guidelines to Classification 2009. When the field observation by auditor, for sample : Division 3/Belida Estate Block 18, for activity of weeds wiping, the implementation of SOP consistently done

The use of pesticide, during 2015 and 2016 (to date March 2016) has been provided, either in IPBS es-

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tate and Belida Estate. For example, the use of Prima Up (active ingredient isopropyl glyphosate 480g / L) and Metsulindo (Active Ingredients Methyl metsulfuron) during 2015 in IPBS Estate of each 47.80 Li-ters and 7.10 liter, meanwhile in Belida Estate, for example, the use of pesticides in Division 1 until March 2016 for GARLON 480 EC (the active ingredient trichlopyr butoksil ethyl ester 480g / L) and Elang 480 SL (the active ingredient glyphosate isopropyl amine 480g / L) respectively 20.89 Liter and 223.10 Li-ter. Records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) are recorded in “Pesticide Toxicity Units Monitored Report” and the records are maintained at estate division offices. The example of the record in IPBS Estate such as per January 2016, Elang ( active ingredient isopropyl glyphosate)with active ingredient 42% and LD 50 5000, the pesticide usage in January 2016 12.60 Liters, total active ingredient 21.672 Liters, total area applied was 2746.63 Ha, FFB Produce was 827.61 MT, Pesticide toxicity Units (Kg/LD50/FFB) was 0.000005237

As PT. Aek Tarum has implemented integrated IPM comprising physical and biological control along with chemical control to minimize the use of chemicals. Census of rats pets and census of leaf eating pests was consistently done once per month, for example the result of census of rats pests in March and April 2016 is rat attack rate respectively 5.7% and 6.1%, and there is no prophylactic use of pesticides which are done, the company consistent with the related SOP, (for more detail, please see 4.5.1) As discussed previously, the company has summarized list of pesticides that are categorized as WHO class 1A or 1B, or by Stockholm and Rotterdam Convention and according to “Peraturan Menteri Per-tanian No. 07/Permentan/SR.140/2007 or Regulation No. 07/ Permentan /SR.140/ 2/2007 Ministry of Ag-riculture Republic of Indonesia). Related to the use of Paraquat dichloride, the company committed to re-ducing/minimize of pesticides usage, no more purchases in 2016 and the use of paraquat in 2016 only to spend the stock in 2015. Recently the use of Paraquat, for example in IPBS Estate are Topzone (Active Ingredients Paraquat dichloride), in February 2015, Ha applied was 95.3 Ha, the use of paraquat was 14.2 Liter. The workers who apply or handle pesticide (Mumun, Mesinem, Winarsih and Eni R ) has been certified in accordance with related regulations

Physical verification in Warehouse consistently done and during warehouse visit, the result of verification that inventory in the chemical store agrees back to the inventory records.

Handling of pesticides in the Field, all the SOPs that there are use of chemical activity on the field, the SOP covering aspects of the K3 and Environment. For example, SOP Weed Control of mature oil palms (P-SAG-KBN-PML-22) or Work instruction Spraying Circle (P-SAG-KBN-PML-1204). Aspect of Relating to the environment, such as handling of waste container which categorized hazardous waste. Training for workers who apply or handle pesticide (for example: restricted Pesticides in accordance to Regulation of “Permentan No. 24 Tahun 2011”) has been conducted (as the previous discussion) and the auditors have been verified the evidence and all evidence well documented. In addition, the training is carried out by a competent person by Pesticide Committee Body and also in accordance with the appropriate language understood by the worker. However, the auditors recommended that the company should be reviewed re-lated suitability of working hours of pesticide operator with “Permanakertrans No.03 of 1986 regarding Tentang Syarat – syarat K3 di Tempat Kerja yang mengelola Pestisida “, (For more detail, please see in 4.5.2)

When auditor visit to the field, both in Belida Estate and IPBS Estate, all implementation in accordance with the related SOPs, especially related providing of MSDS for pesticide used, use of appropriate PPEs and also understanding of workers is good enough . In SOP Handling of Hazardous Materials (B3) (P-SAG-RO-PCR-05), regulated starting to incoming material receipt, material storage, until the outgoing ma-terial. Additionally, the organization is committed to comply with the related regulations, for example PP 74 Year 2001 regarding Management of Hazardous and Poisonous Substances or PER-03 / MENLH / 2008 regarding Symbols and labels on hazardous and Poisonous Substances.

Based on objective evidence and field observation, there were no pesticides applied aerially in Belida and IPBS Estate

Meanwhile, related disposal of hazardous waste material is regulated in “SOP Handling of Waste Mate-rial in Field” (P-SAG-KBN-LMB-01 ), however the evidence of socialization of SOP should be ensured was documented

Annual Medical checkup consistently done, especially for pesticide operators. One of that checked is Cholinesterase (poisoning by organic material / pesticides) and recording of implementation of annual medical checkup has been maintained and documented. PT. Aek Tarum has a policy that pregnant and

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breast-feeding women are prohibited from working with pesticides. Records of socialization of the policy to the female workers were available. If any pregnant or breast-feeding women workers were found, there were follow-up letters showing that they had been transferred to a job without pesticides contact.

Compliance status: Full Compliance

Criterion 4.7: An occupational health and safety pl an is documented, effectively communicated and implemented.

Findings: PT. Aek Tarum has always been committed Related to Occupational Health and Safety , which also stat-ed in the Company policy dated 01 July 2015 which is signed by the Sampoerna Agro Group Chief Exec-utive Officer. The policy includes documented objectives and targets i.e. comply with the company’s OSH procedures, committed to wearing of Personal Protective Equipment (PPE) at work sites, and manage po-tential work risks at the site. Some of the work program to achieve the target has been done, such as so-cialization of MSDS and related evidence has been maintained and documented in accordance with the “SOP Identification of Environmental Aspects & K3, Objective, Target and Environment Program & K3 (P-SAG-RO-SUS-08)”

Mill and Estate has identified and documented Occupational Health and Safety (OHS) risks for mill activi-ties and Estate activities and last review of Risk assessment was conducted on 2 February 2016 including environmental aspects and impacts register. However, environmental risk assessment not cover some of the operational activities at the Mill and the Estate

• Activities transfer / filling POME to the tank truck and transport / transporting POME to the place of destination

• Harvester activities that bring tool of harvesting by used motorbike at the time of going to harvest-ing location,switch of location or back to home

• Use of Gasoline (petrol) when the pest control of fire worms with fogging methods It was raised as Nonconformities (RSPO 00236). Furthermore, the result of risk assessments should be documented in the Mill and the Estate, and should ensure that control measures which are set to address the risks has been identified, due to found some of determination control are not available

Related to Accidents, there is no accident from 2015 until during audit conducted for Mill, while in Estate there are accidents. If any accidents occurred, Reviews These were included in the risk assessments with action plans to Prevent further recurrence.

All workers involved in the operation appropriately trained in safe working practices. Some of training among restricted pesticides training, Safety driving, Hyperkes, Lifting Equipment Operator, Boiler Opera-tor (Please see 4.8). But when auditor visited to Estate and Mill, still found inconsistencies in this regard, for example, one of Excavator Operator in Mill, Edi Syahputra, do not have a license K3 and Workbook as required in “Permenakertrans No. PER.09 / MEN / VII / 2010 Regarding Operator dan Petugas Angkat dan Angkut” (Please see 2.1.1) and also in Estate, found almost all harvesters in IPBS Estate does not use safety googles, over more than 8 (eight) months. It was raised as Nonconformities (RSPO 00237).

All pesticide sprayers are provided with proper PPE, such as a mask, hand gloves, safety shoes and body cover coat (apron). The company provides facilities for cleaning up after the sprayer work and stor-age spaces for keeping PPE after use. Workers who work at noisy areas are provided with ear muff and ear plug. The monitoring of noise levels was done at the mill every 6 months. This exceeds the limit so usage of ear muff is mandatory to prevent hearing loss of mill’s workers exposed to noise. Notification of noise levels and warning of using the ear muffs are available at site. The workers who worked in high risk areas such as boiler house, engine room, electrician, and chemical sprayer have specific licenses to work. However, When the auditor visit to the mill, Found one of engine room operator who work at noisy areas has not been conducted annual medical check-up as required by “Permenakertrans No. Per.02/MEN/1980 regarding Pemeriksaan Kesehatan Tenaga Kerja Dalam Penyelenggaraan Kesela-matan Kerja” (Please see 2.1.1). Chemical storekeeper, is provided with helmets, boots and goggles and

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look much aware to the visitor that need to wear the PPE while entering his area as it was already ar-ranged in related procedure, The auditor checked that the licenses for chemical applicators are still valid. Panitia Pembina Keselamatan dan Kesehatan Kerja / P2K3 (OHS Team) in Belida Mill has been estab-lished and validated by the Head of Manpower Department No. 45/D.Naker-trans/BW/2015, on May 2015, and Secretary of P2K3 is Justin R H Sitohang with competence “AK3 Umum” (Certificate for General OHS Expert) as required by the relevant regulations. As OHS Team in Estate has been established also on May 2015 by the Head of Manpower Department No. 40/D.Naker-trans/BW/2015, and Asrul Nur Arif was secretary of OHS Team and he has been “AK3 Umum” certified. However, if there is any change of struc-ture team, OHS team should be confirmed immediately in accordance regulated in “Permenaker No. PER.04/MEN/1987 Regarding “Panitia Pembina Keselamatan dan Kesehatan Kerja serta Tata Cara Penunjukan Ahli Keselamatan Kerja” (Please see 2.11). Regular meeting of P2K3 team (OHS team) was performed, last meeting both for Mill and Estate was conducted on 5 April 2016 and the report of OHS implementation shall be submitted to Head of Manpower Department at least per 3 (three) months as re-quired by related regulation. Furthermore, the last meeting on 5 April 2016 did not include issues related to accidents, while refer to the accident report during the month of January - March 2016 in Belida Estate and IPBS Estate, number of accidents that occurred is 11 accident. It was raised as Nonconformities (RSPO 00238). As mentioned in procedure P-SAG-RO-SUS-08, HIRAC (Hazard Identification and Risk Assessment Con-trol), the company has a list of activities which are indicated as the emergency conditions to be controlled by the site operators. To handle the emergency operations there are the procedure Emergency Respond (P-SAG-PKS-DRR-01) for Mill and the procedure Emergency Respond (P-SAG-KBN-DRR-01) for Estate. Both SOPs are available in Bahasa Indonesia and clearly understood by all workers. The records of im-plementation of these SOPs such as: List of HIRAC, Emergency and First Aid Training, Emergency Drill and Emergency Equipment Maintenance and Inspection are available and adequate. Fire Emergency drill trainings for mill were conducted on 9 April 2015 and for estate were conducted on 22 April 2015. Notes of the training results are maintained, including the steps of the accident & emergency response proce-dure. The Emergency Equipment Maintenance and Inspection is available. First aid equipment was avail-able at work sites and regularly checked by the OHS team. However, First aid box contents in Work-shop/Maintenance area (Mill) not accordance with required by “Permenakertrans No. PER.15/MEN/VIII/2008 Regarding Pertolongan Pertama Pada Kecelakaan” (please see 2.1.1). Records of other OSH training, i.e. for first aid and management of hazardous waste, are available as described under CR4.8

The accident records were available Every accident was recorded in the forms of accident and investiga-tion report. During the period of January – March 2016 it was reported 11 (eleventh) occupational inci-dents in Belida Estate and IPBS Estate. But not all of them caused loss time injury. The auditor checked and verified all records and noted all of them are well maintained. It is recommended that accident inves-tigation should be include actions taken to prevent recurrences accident and should be defined in a pro-cedure

Estates and Mill provide National Employee Social Security (Jamsostek) to permanent employees, and it is verified with interview (for more detail, please see 6.5.3) As for contract workers, company deducts the amount required for their insurance against payment to the respective contractors, and pays this insur-ance amount directly to the relevant authority to ensure that all contract workers are covered with insur-ance.

Compliance status : Non Compliance

NCR RSPO 00236 (Major non-conformity) Risk assessment and environmental not cover some of the operational activities at the Mill and the Estate

• Activities transfer / filling POME to the tank truck and transport / transporting POME to the place of destination

• Harvester activities that bring tool of harvesting by used motorbike at the time of going to harvest-ing location,switch of location or back to home

• Use of Gasoline (petrol) when the pest control of fire worms with fogging methods NCR RSPO 00237 (Major non -conformity)

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During a visit to the field found almost all harvester in IPBS Estate does not use protective glasses, and it has been going on more than 8 (eight) months NCR RSPO 00238 (Major non-conformity) The last meeting on 5 April 2016 made by the responsible person associated OSH in this case is the P2K3, not cover issues related to occupational accidents, while based on the accident report for January - March 2016 identified the total of workplace accidents that occur in Belida Estate and IPBS estate is 11 accidents

Criterion 4.8: All staff, workers, smallholders and contractors are appropriately trained.

Findings: The company has training procedure (P-SAG-HO-HR-12, effective date August 1, 2015 revision 1). The company has training plan for year 2016 and realization of training year 2015. Some of training realization year 2015 namely:

• Training of limited pesticides • Training of pest and diseasesin palm oil plantation • Calibration, maintenance and repairing of spray tools • Control of pest and diseases of palm oil plantation • Management of pesticides and spray tool

The company has records of each training realization. Human resources has responsibility to keep the records for each employee that has been conduct training. Compliance status: Full Compliance

Criterion 5.1: Aspects of plantation and mill manag ement, including replanting, that have environ-mental impacts are identified, and plans to mitigat e the negative impacts and promote the positive ones are made, implemented and monitored, to demons trate continuous improvement.

Findings:

PT. Aek Tarum has obtained approval of Environmental Impact Assessment in the form of Environmental Management and Monitoring Plan or “Rencana Pengelolaan Lingkungan – Rencana Pemantauan Ling-kungan” (RKL-RPL) based on the Minister of Agriculture Decree on 28.10.2005. The AMDAL/EIA includes the mitigation of negative impacts and improves the positive impact. The negative impacts for the envi-ronment such as water pollution caused by waste water discharged to river/drainage; air pollution caused by emission from boiler and generator set. This water pollution impact was managed by regular monitor-ing of the quality of waste water to make sure the waste water discharged to river/ drainage was below permitted maximum limit. The air pollution was managed by maintaining boiler and generator set and reg-ular monitoring and measurement of emission generated by them to make sure their emission were below permitted maximum limit. Negative social impact as identified during monitoring SIA was dust from trucks carrying FFB passing through communities housing. This impact was managed by watering the roads in the dry seasons regularly. These impacts were specifically mentioned in the EIA report as well as in the activity of Aspect and Impact Assessment. To control both negative and positive impacts the company has provided a comprehensive management plan and written in the other document namely Rencana Kelola dan Pemantauan Lingkungan / RKL-RPL (Monitoring Report of Environmental Management Plan). This document was available at mill and estates. The monitoring report of RKL-RPL was performed twice a year as Laporan Rencana Pengelolaan Ling-kungan – Rencana Pemantauan Lingkungan (RKL-RPL) (Monitoring Report of Environmental Manage-ment and Monitoring Program). The Report includes monitoring and analysis result, for example : Monitor-ing of river water quality, certificate No. 660/1850/SHU-LAB/XI/2015 dated 20-25 November 2015 and Monitoring of waste water quality, certificate No. 660/1243/SPPC-ALC/VIII/2015, dated 5 August 2015.

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The document shall be submitted to Badan Pengendali Dampak Lingkungan Daerah/BAPEDALDA or Lo-cal Environmental Impact Assessment Agency every semester (6 months). Auditor team found that the RKL-RPL monitoring report for first and second semester 2015 were available. Auditor also noted that the report of second semester 2015 has been submitted to the local Environmental Agency of South Su-matera Province on 21 March 2016 However, regarding Monitoring Report of Environmental Management and Monitoring Program (RKL/RPL) it is recommended to review and ensure related :

• Guidelines of Environmental Management/Monitoring Report (UKL/UPL) in accordance with “Kepmen LH No. 45 Tahun 2005 regarding Pedoman Penyusunan Laporan Pelaksanaan RKL/RPL“

• Evaluation results not in line with the final conclusions of the report due to there was found con-tradictory things related to threshold value

• Certificate of Enviromental Monitoring test that conducted should be ensured to attached in Report of RKL/RPL

Compliance status: Full Compliance

Criterion 5.2: The status of rare, threatened or en dangered species (ERTs) and high conserva-tion value habitats, if any, that exist in the plan tation or that could be affected by plantation or mill management, shall be identified and their cons ervation taken into account in management plans and operations.

Findings: PT Aek Tarum (Belida estate) and PT Mutiara Bunda Jaya (IPBS estate) has conducted an assessment and identification of protected, rare and endangered species and HCV habitats within their area. HCV as-sessment and identification of flora and fauna for PT Aek Tarum has been carried out on 2010 by a com-bination of independen consultan and internal staff which responsible for HCV consist of RSPO regis-tered team leader (Mr Siswoyo) and 2 registered team members and 2 non registered and supported by a GIS expert. HCV document is also already peer reiewed by accredited independent consultant (Mr. Kresno Santosa) on April 2014. HCV assessment for PT Mutiara Bunda Jaya (MBJ) was conducted by Faculty of Forestry IPB lead by RSPO registered assessor namely Mr. DR. Nyoto Santoso and peer re-viewed by accredited independent consultant (Mr. DR Jarwadi Budi Hernowo in November 2012. HCV assessments was performed in consultation with villagers during the data gathering and the results is al-so disseminated through stakeholder consultation meeting on August 14th 2015 involved 61participants from surrounding villages and related sub-dictrict institutions. Methodology used for both HCV assessments refers to HCV toolkit Indonesia 2008. The results of these assessments are documented in HCV assessment report. Since Belida and IPBS estate under different management, then there are two assessments. HCV assessment for PT Aek Tarum (Belida Estate) con-ducted on 6-8 may 2010 (fielf/ground assessment) proceeded by desktop study for assessment scoping on April 2010. Field assessment with 4 sample plots in rivers zone s and 5 villages. Coverage area 2891.15 ha (nucleus) and plasma. Meanwhile HCV assessment for PT MBJ has been conducted on 11-18 September 2012 which is also preceded by pre-assessment activities in the form of secondary data collection such as maps, satellite imagery, spatial plan information, forest status, and statistical figure of the related district and sub district. HCV assesment for PT MBJ covered 17,386.47 ha which is IPBS in-cluded to it and expanded to 13 villages.

Landcape condition on forest status over both estates has been analysed with updated data, namely SK No. 866/Menhut-II/2014, there is no presence of protected areas/forest in and around the concession. Re-fers to the national law on protected areas there is identified local protect areas such as riparian zone i.e Lempuing river and Dabuk Hitam river. Fauna and botani aspect surveyed and some protected species was found with RTE status. There are 44 plants species and 17 fauna with details mammals 4 species, birds 10 species and reptile 3 species found in PT Aek Tarum. Combretocarpus rotundatus (local name: prepat) is VU species in IUCN Redlist, whilst Cratoxylum formosum and Cratoxylum arborescens with LC status. A total of 17 wildlifes found and 15 species listed in IUCN Redlist as LC status. Based on national law (PP n 7 tahun 1999) there is a mammal and a bird species categorized as protected animals, whilst 3 species listed in CITES Appx . List of IUCN registered flora fauna found in Belida estate is presented in

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below table. Meanwhile for PT MBJ (IPBS estate) at the time of study HCV successfully recorded 88 spe-cies of plants, 5 species of mammals, 38 species of birds, and 4 species of reptiles. List of IUCN regis-tered flora fauna found in Belida estate and PT MBJ is presented in table below.

List of registered status of Flora Fauna found in B elida Estate.

No. Species Conservation status

Govt. Regulation No. 7/1999

CITES IUCN

A. Mammal 1 Tupaia javanica NP - LC 2 Rattus norvegicus NP - LC 3 Felis bengalensis NP App. II - 4 Macaca fascicularis NP App. II LC B. Bird 1 Streptopelia tranquebarica NP - LC 2 Pycnonotus aurigaster NP - LC 3 Prinia atrogularis NP - LC 4 Ardeola speciosa NP - LC 5 Dendrocygna arcuata NP - LC 6 Alcedo meninting NP - LC 7 Macropygia unchal NP - LC 8 Copsychus malabaricus NP - LC 9 Lonchura leucogastroides NP - LC

10 Tyto alba NP - LC C. Reptile 1 Phyton reticulatus NP App. II LC 2 Naja sp. NP - - 3 Eutropis multifasciata NP - LC D Plant 1 Combretocarpus rotundatus NP - VU 2 Cratoxylum formosum NP - LC 3 Cratoxylum arborescens NP - LC

List of registered status of Flora Fauna found in P T MBJ (IPBS).

No. Species Conservation status

Govt. Regula-tion No. 7/1999

CITES IUCN

A. Mammal 1 Tupaia javanica NP - LC 2 Rattus norvegicus NP - LC 3 Felis bengalensis NP App. II - 4 Macaca fascicularis NP App. II LC 5 Sus scrofa NP - LC 6 Tragulus napu P - LC 7 Muntiacus muntjak P - LC B. Bird

1 Orthotomus ruficeps NP - LC

2 Pycnonotus simplex perplexus NP - LC

3 Centropus bengalensis NP - LC

4 Macronous gularis bornensis NP - LC

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5 Amaurornis phoenichurus NP - LC

6 Streptopelia chinensis NP - LC

7 Prinia flaviventris NP - LC

8 Caprimulgus affinis NP - LC

9 Dendrocygna arcuata NP - LC

10 Gerygone sulphurea NP - LC

11 Pycnonotus aurigaster NP - LC

12 Merops philippinus NP - LC

13 Ixobrychus cinamomeus NP - LC

14 Pycnonotus goivaier NP - LC

15 Rhipidura javanica NP - LC

16 Anthus novaeseelandiae NP - LC

17 Halcyon smyrnensis NP -- LC

18 Ardea purpurea NP - LC

19 Passer montanus NP - LC

20 Hirundo rustica NP - LC

21 Egretta garzeta P - LC

22 Egretta alba P - LC

23 Artamus leucorynchus NP - LC

24 Porphyrio porphyrio NP - LC

25 Alcedo meninting P - LC

26 Butorides striatus NP - LC

27 Ardeola speciosa P - LC

28 Coturnix chinensis NP - LC

29 Gallus gallus NP - LC

30 Porzana pusilla NP - LC

31 Treron olax NP - LC

32 Loriculus galgulus NP - LC

33 Picoides moluccensis NP - LC

34 Aegithina tiphia NP - LC

35 Dicrurus paradiseus NP - LC

36 Copsychus saularis NP - LC

37 Anthreptes singalensis P - LC

38 Lonchura maja NP - LC

C. Reptile 1 Naja sumatrana NP - LC

2 Eutropis multifasciata NP - LC

3 Varanus salvator NP App.II LC 4 Coura amboinensis NP - LC D Plant 1 Alstonia scholaris NP - LC 2 Nepenthes Sp. P App.II LC

P = Protected, LC = Least Concern

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NP = Non VU = Vulnerable

Rare and threatened ecosystem is studied on HCV 3 anaysis, through Repprot Land System and refers to HCV toolkit there is no rare or threatened ecosystem, moreover there is no forested area and dense vege-tation found in the estates. In addition, landscape context has been analysed include: Important Bird Ar-ea (IBA) and EBA ( Endemic Bird Area), land system, soil and geology, topography, rainfall, hydrology and catchment areas, and biodiversity aspect, demografi social ecomnomyand cultural aspect.

HCV area in Belida estate is 91.8 ha consist of HCV 1.1, 1.3, and 4.1 in form of riparian zone of Dabuk Hitam river or 3.18% of Belida estate area. There are 2 types of HCV in PT MBJ, namely HCV 1.3 and HCV 4.1 with total area of 631.49 ha. Specifically for IPBS estate there is only one type of HCV has been identified, HCV 4.1on Dabuk Hitan river riparian zone with total HCV area is 28.55 ha or 5.17% of IPBS area.

Figure 5: HCV area in Belida estate (PT Aek Tarum) overlaid with planted area.

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Figure 6: HCV area in Inti Permata Bunda Satu estat e (PT MBJ) overlaid with planted area.

HCV Management and Monitoring in Belida and IPBS estate has been constructed and implemented partly following recommendations from HCV assessment. Restoration of riverbank, signpost installation, patrol inspection, flora and fauna monitoring is an implementation of the management and monitoring of HCV. Every year HCV areas management and monitoring is reported. Flora and fauna is monitored regu-lary every year, in 2015 there was 44 plants, 4 mammals, 16 birds and 4 reptile identified in PT Aek Ta-rum, whilst 75 plants, 3 mammals, 42 birds, and 4 reptiles was identified in PT MBJ. Measuring of flora and fauna conducted by special HCV team of PT Sampoerna Argo Group and referring to a SOP No. P-SAG-KBN-NKT-02 on HCV management and monitoring. There is a weekly field inspection to ensure the existence of HCV area / vegetation and wildlife as well carried out by a special officer. The inspection in-cludes the condition of vegetation cover on riparian zone, occassional disturbance, signpost and markers and wildlife hunting monitoring. Conservation foremen Mr. Gianto was assigned officialy to inspect HCV and wildlife monitoring in Belida estate, whilst Mr. Firman assigned for IPBS estate. Result from weekly inspection is reported to Estate Maneger to get feed back on HCV maintain. For example in March 2016 was reported a bamboo theft disturbance that taken by irresponsible person, management dealing with the insertion of plants by planting Terminalia catappa (ketapang). HCV awareness as a form of education to parties carried ou through socialization on HCV including information on protected species. Internal socialization was carried out on February 22nd, 2016 and March 31st, 2016 proved by list of attendance and documentation. HCV was also socialized for external party especially the community live on sur-round concession on August 14th, 2015. The condition of HCV management is shown in some figures below:

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Figure 7: Vegetation enrichment along riparian zone and signpost as implementation of HCV man-agement.

Eventhough PT AT (and also PT MBJ) has a plan and impemented wildlife monitoring, yet specific poli-cy or rule to protect RTE species is absent. There is no company policy on the protection of endangered species including the case of of hunting and the keeping of wildlife. It was raised as Nonconformities (RSPO 00240). Compliance status: Non Compliance NCR RSPO 00240 (Minor non-conformity) There is no company policy on the protection of endangered species including the case of of hunting and the keeping of wildlife

Criterion 5.3: Waste is reduced, recycled, re-used and disposed of in an environmentally and so-cially responsible manner

Findings: The company has identified and record all generated waste from mill and estate activities. The waste is classified by domestic waste and hazardous waste. Sources of waste and pollution are fertilizing pro-cesses, spraying, transportation, boiler operation, effluent ponds, power plant, bunch processing and ac-tivities in emplasment. An Environment Management Program was created on ISO 14000 bases to list and identifiy impacts/ aspects caused by activity stations and necessary mitigation measures to reduce the impact. Pollution and emission source from mill and estate has been identified consist of location source (station), pollution and emission source, impact to human, machine and equipment, environment and impact management. List of hazardous waste is listed in Hazardous and Toxic Waste (HTW) balance sheet and form FM-SAG-RO-HRS-050001; they were grease, rope, bulb, medical waste, cartridge, leather gloves, oil filter, paint cans, chemical containers, oil/chemical barrel container, and battery. Chemical con-tainers was inventoried well and stored in a warehouse in a neat, by March 2016 there was some chemi-cal containers kept in mill warehouse, among as medical waste container, fertilizer sack, and paint cans and it is is in accordance with the balance of HTW. The company has a procedure (SOP) on harzardous and toxic waste handling in mill No. P-SAG-PKS-LMB-01 issued on October 30th, 2015. This procedure regulated mechanism to manage waste,PIC, ad-ministration and recording, waste handling in station and warehouse and disposal to the authorized trans-porter party. Hazardous waste was kept less than 90 days, as permit No. 680KEP/BLH/2015 dated on September 10th, 2015 and will be collected by licenced collector to proceed to processor and end user. This procedure also contains mechanism to dispose hazardouse waste and agrochemical container. Haz-ardous and toxic waste collection, storage and transportation is recorded very well. Regulary, Belida mill sent the hazardous waste to PT Dame Alam Sejahtera, an authorized hazardous waste transpoter, based on agreement No. 412/SA/SPK/X/2015 dated on October 1st, 2015. PT Dame Alam Sejahtera has a li-cense to transport hazardous and toxic waste from the Ministry of Transportation Decree No. SK.616/AJ.309/DJPD/2013/320150052BB valid until February 8th, 2018, and also hold recommendation

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issued by Ministry of Environment and Forestry No. S.2892/PSLB3/2015 valid until November 12th, 2020. Collection and disposal records of chemical container and other hazardous waste were maintained very well. Balance sheet, logbook (daily note), handover and disposal manifest are kept tidy. A warehouse clerk records the waste in hazardous waste balance which containt data about incoming and outcoming waste completed with note and transportation manifestation and minutes of the hazardous waste handover. For example on December 28th, 2015 there is 550 kgs contaminated drums from Belida mill collected and transported by PT Dame Alam Sejahtera with manifest no. 0001713, and completed with minutes of waste disposal signed by both party as shown in minutes No. 558/PKS BL/XII/2015 dated on December 28th, 2015. The minutes described type of hazardous waste, ID of vehicle, kind of waste and weight. As an observation, the company should ensure the vehiclle ID is shown in manifest, not only in minute. Besides agreement with authorized transporter to dispose hazardous waste, PT Aek Tarum also has contract/agreement with another company to utilize and process hazardous waste. There are some partner companies to utilize hazardous waste namely:

• PT Dame Alam Sejahtera has permit issued by Minister of Enviromental and Forestry, No. 173/Menlhk/Setjen/PSLB.3/3/2016 valid for five years;

• PT Tenang Jaya Sejahtera has permit issued by Minister of Enviromental, No 30 year 2012 valid for five years;

• CV. Sinerga Indonesia has permit issued by Minister of Enviromental, No.07.69.10 year 2014 valid for five years;

• PT. Berkah Anugrah Ilahi has permit issued by Minister of Enviromental No. 89 year 2011, valid for five years until May 4th,2016;

• CV. Lut Putra Solder has permit No. 30 year 2011, but has expired on 20 February 20th, 2016 • PT. Triguna Pratama Abadi. Permit has expired since 2010 ago.

As a contract partner for disposal hazardous waste, there are two users of hazardous materials and toxic wastes that have agreements with PT Aek Tarum namely Lut Putra Solder and Triguna Pratama Abadi had expired license. Lut Putra Solder with license No. 30 in 2011 has been expired on February 20, 2016 and Triguna Pratama Abadi, with the permission of the Decree No. 238 of 2010 has long been expired. It was raised as Nonconformities (RSPO 00241). The company also recorded solid waste from mill processing such as empty fruit bunch, shell, fibre and solid. This side waste reused for various needs, EFB and solid for plant nutrient in the field, shell and fibre for non fossil fuel in the mill. In 2015, it was 4421.7 tons of EFB applied to the field, and on January to March 2016 it was 1016 EFB applied as well.

Mechanism for domestic waste handling in estate is set up in SOP P-SAG-KBN-LMB-01, wherein organic and anorganic waste is set to be separated in collection and disposal. Based on field checking in the housing, there is no separation of organic and non-organic, and there is no socialization in the estate. Waste management in the final disposal in the Belida estate has not been good where the drain holes filled with water and causing overflow of waste. It was raised as Nonconformities (RSPO 00242). Compliance status: Non Compliance NCR RSPO 00241 (Major non-conformity) There are two users of hazardous materials and toxic wastes that have agreements with PT Aek Tarum namely Lut Putra Solder and Triguna Pratama Abadi had expired license. Lut Putra Solder with license No. 30 in 2011 has been expired on February 20, 2016 and Triguna Pratama Abadi, with the permission of the Decree No. 238 of 2010 has long been expired. NCR RSPO 00242 (Minor non-conformity)

1. Waste management in housing estates is not accordance with the procedures, there is no sepa-ration of organic and non-organic, and there is no socialization in the estate

2. Waste management in the final disposal in the Belida estate has not been good where the drain holes filled with water and causing overflow of waste

Criterion 5.4: Efficiency of energy use and use of renewable energy is maximized.

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Findings: Plan for improving efficiency of the fossil fuels use is set up in annual Environmental Management Pro-gram. Fiber and shell as a waste of CPO production were used as a renewable energy source to operate the boiler and it already been implemented and monitored day to day. It is 27,000.246 tons fibre and 12,169.440 tons shell was used for boilers fuel in 2015 for processing 252,289.65 tons FFB. Shell usage for boiler fuel in 2016 (by April) is 3,079 tons, whilst fibre is 9,236 tons to process 60,514 tons FFB. PT Aek Tarum monitored fuel used for processing both of fossil and non fossil annualy. Data monitoring in 2015 shows the rasio of fuel type used to process FFB as follows :

• Fibre : 0.11 tons/FFB • Shell : 0.05 tons/FFB • Fossil fuel for boiler generator:0.22 tons/FFB • Fossil fel for transportation and heavy equipment : 0.18 tons/FFB

In total there was 0.15 tons non fossil fuel and 0.41 tons fossil fuel used for FFB processing. Ratio be-tween non fossil and fossil fuel to FFB process was 15.49%: 40.95%, so then reduction in fossil fuel effi-ciency by 2.35%. In order to save fossil fuel to produce electricity power and reduction of GHG emissions, PT Aek Tarum has conducted a feasibility study of collecting and using biogas with methane capture construction. This study was carried out in 2013 by ProSympac, an energy consultant who has intensive experience in me-thane capture construction .Based on that study; PT Aek Tarum has an intension to build a methane cap-ture in Belida mill in the future. That is biogas potential as 2,290,790 – 4,581,580 m3/year and power generation potential as 0.93 – 1.87 MW of 70% capacity. Compliance status: Full Compliance

Criterion 5.5: Use of fire for waste disposal and f or preparing land for replanting is avoided except in specific situations, as identified in the ASEAN guidelines or other regional best practice.

Findings: The company have a zero burning policy that explicit stated in Group Company Policy signed by Chief Execuitve Officer on July 20th, 2015. The statement is: To prevent environment pollution and land clearing without fires (zero burning). A procedure for zero burning on Land Clearing, SOP No P-SAG-KBN-PML-03, is available. This procedure is referring to national law regarding controlling on damage and Environ-ment Pollution caused by land fire and forest fire. The SOP mentioned that land clearing must be carried out with controlling and zero burning, and also prhobition of HCV areas disturbance. Land clearing meth-od used is the uprooting and stacking of the wood to rotten. There is evidence that prove land clearing was not use fire, some minutes of land clearing activity in block 14 and 15 on August and September 2008 showed land clearing activity was uprooting, chipping and stacking on the non used gap, and it was accordance with the SOP. Compliance status: Full Compliance

Criterion 5.6: Plans to reduce pollution and emissi ons, including greenhouse gases, are devel-oped, implemented and monitored.

Findings:

The company has identified of activities that produce greenhouse gas emissions either in the estate or mill. At the estate some of identified activities are: FFB production, fertilizing application, pesticide and herbicide application, electronic usage, and fossil fuel, meabwhile at the mill the activities are electricity for powerplant, fossil fuel, CPO transportation, effluent (POME), and chemical usage. Identification of pol-lutant and GHG emission is describe in details in Environment Management Program 2015 (EMP). EMP contains objective, target, time frame and action plan to be implemented in frame of GHG emission and

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pollution reduction. In addition there is also available the inventory of GHG emission source either in es-tate or mill and w ISCC 200ill be input for GHG calculation which is refers to the RSPO GHG Calculator toolkit Version 2.1.1.

The compant has a plan to reduce GHG emission among as : • Methane capture construction that preceeded by feasibility study • Research on dried decanter solid and composting • Electricity saving • Feasibility study of ISO 50001 implementation in entire process and activity • Utilize non fossil material fuel to reduce fossil fuel with fibre and shell • Substitute gasoline with bio-diesel for transportation • Tree planting to increase carbon sequestration • Routine maintenance of vehicles and heavy equipments. • Subsitute anorganic fertilizing with EFB and decanter solid • Subsitute chemical pesticide with bio pesticide (bio cordycept)

Some of plans has been implemented such as study for methance capture carried in 2103 by consultant Prosympac, fibre and shell utilize as renewable energy for boiler operation, FFB application to the field, electricity saving with power outage on hours of inactivity, tree planting along Dabuk Hitam riverbank, maintenance of vehicle and heavy equipmet in central workshop and bio cordycept application to substi-tute chemical pesticide. The company has records POME/effluent quality testing which is conducted regu-lary as described in Criterion 4.4. All the paramaters tested particulary BOD5 is still below the allowed na-tional standard.

The company conducted a routine air quality testing every six month proved by certification of testing re-sult. In November 3 rd , 2015 air quality tested by Hiperker of South Sumatra Province with certificate No. 070/123/UPTD/BHP/2015.Ambient air quality is below the standard accordance with Decree of Work-er and Transmigration Minister No.13 year 2011. Parameters testes include: CO, SO2, NO2, NH3 ad H2S. Ambient air quality tested in inside and outside mill. Emission air quality from fixed station was also tested with parameters SO2, NO2, HCL, CL2, NH3, HF and Opacity. All the tested parameters are below the standard of Governor of South Sumatra No. 6 year 2012 on standard of emission quality.

The company has SOP on GHG Inventory No.P-SAG-RO-SUS-15 that regulates a mechanism to identifi-cation of GHG emission source, recording, GHG calculation procedure in each activities source both in mill and estates. GHG calculator toolkit version 2.1.1 developed by RSPO is used for monitoring and re-porting GHG emission. Data inputs comes from the identification of GHG source from various activities that listed in special form as part of the procedure. Final GHG emissions value per product calculated in 2015 was 1.47 tCO2e/ton CPO and 1.47 tCO2e/ton PK. Overall emission summary from field emission was 13818.76 tCO2e from own crop, 15125.78 tCO2e from group and 22314.28 tCO2e from outgrowers. A total emission from mill to produce CPO/PK was 35620.99 tCO2e. Compliance status: Full Compliance

Criterion 6.1: Aspects of plantation and mill manag ement including replanting that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement. Findings: PT. Aek Tarum already has prepared a Social Impact Assessment (SIA) report. The assessment was done by third party namely Faculty of Forestry, Bogor Agricultural University in 2012. The assessment in-cludes details of positive and negative social effects that may be caused by plantations and mills and documents participation of affected parties and local communities.

During the assessment the company conducted several consultation and communication with relevant stakeholders. All records of communication and public consultation are available and Properly document-ed incorporated in the report. Based on the photos and attendant lists available in the SIA report, it can be seen that the preparation of the social impact has involved community participation around the estate, such as community leaders and local village officials.

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The Company has some plans to decrease negativeand to increase positive impacts of company exist-ence.Those plans are documented in PT. Aek Tarum Social Managing Plan (Rencana Kelola Sosial PT. Aek Tarum). The company also monitors the social impact. Implemented from this social plan in CSR ac-tivit ies. There were records of Corporate Social Responsibility (CSR) activities for year 2015. The pro-gram covered different aspects such as training on best practices for palm oil to farmer and smallholder, contribution given to community, such as road repair, school contribution. Moreover, the company also helps community around mills and estate to sprinkle water on the road that is traversed by trucks, be-cause of dust. There was regular monitoring and management of social impact recorded in Laporan Moni-toring Aspek Social (Social Aspect Monitoring Report). Result of SIA monitoring report was discussed with their stakeholders during stakeholder meeting conducted on July 18, 2015 to get the feedback from stakeholders.

Company has reviewed the social impact plan taking into account the social problems occurring usually around company. Reviewing has occurred through stakeholder meeting. Company also has given its con-cern to the farmers which were done by counseling activity about how tocultivate palm oil. Those out-grower farmers were incorporated in KUD Plasma Farmer. Besidethat, Company also has to visit plasma estate. Activities were documented well.

Compliance status: Full Compliance

Criterion 6.2: There are open and transparent metho ds for communication and consultation be-tween growers and/or millers, local communities and other affected or interested parties.

Findings: PT. Aek Tarum have an effective Communication and Consultation Procedure, P-SAG-HO-CA&L-08 Rev. 02 in February 1, 2016 (Communication, Participation and Consultation Procedure. The procedure covers the scope, purpose of the procedure, internal and external communication method, documentation and follow-up action. This Procedure has been arranged and communicated to stakeholder through stake-holder meeting.

Company has special officer whois responsible to handle social issues, he is Mr. Teuku Rahadian.

List of stakeholders including the local communities, NGOs, labour union, contractors and local govern-ment were available, maintained and updated. The auditor has checked the minutes of meeting of the last stakeholder held on March 20, 2016 in Belida Estate and found the detail of it. All feedback from stakeholders and record (attendance list and MoM) were available.

Compliance status: Full Compliance Criterion 6.3: There is a mutually agreed and docum ented system for dealing with complaints and grievances, which is implemented and accepted by al l parties. Findings: PT. Aek Tarum still maintains and implement a procedure integrated in the procedure Communication, Participation and Counsultation, P-SAG-RO-CAS-08 dated 1.4.2012 (Komunikasi, Partisipasi dan Kon-sultasi) for handling complaints, grievance and dispute. Particularly for handling complaint and land dis-pute, there is procedure SOP No. P-SAG-RO-CAS-09 (Penanganan Klaim dan Sengketa Lahan). Internal complaints and grievances are resolved according to the Mutual Working Agreement (Perjanjian Kerja Bersama 2015-2017). Company also has policy to protect identity reporter as mentioned in policy reporter violation PT. Sampoerna Agro dated on September 27 th, 2013. On point no. 5.2 stated: “Identity Reporter will be confidential. These procedures have been communicated to all stakeholders at each mill and es-tates. It was noted that the responses from stakeholders have been positive. During public consultation, the audit team confirmed that there were no serious complaints, grievances, and disputes at the moment. Local communities and stakeholders obey and respect the company legal rights, reciprocated by the company’s respect for their traditional rights. Company has special officer who is responsible to handle social issues, including responsible to receive complaints and grievances, he is Mr. Teuku Rahadian.

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Compliance status: Full Compliance

Criterion 6.4: Any negotiations concerning compensa tion for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through t heir own representative institutions. Findings: Company has a procedure to identify the legal right, tradition and the people who has right to get the compensation SOP No. P-SAG-RO-SUS-14, dated 1-8-2012 about Evaluation and Acquisition Land Es-tate. And also has SOP No. P-SAG-RO-CAS-03 about implementation of land compensation and or crops grows.

That procedure has taken into account the gender differences in the ability to claim rights, ownership and access to land; the difference between migrants and communities that had long existed; and the differ-ence between the proof of legal ownership and communal ownership of ethnic groups or indigenous peo-ples.The procedure has been communicated to the stakeholders during the stakeholdermeeting. Checks on the records and interviews with the local communities during public consultation confirmed that there is no current claim on any land. Based on HCV studies and ANDAL report there are no customary rights of local community. An interview with the Chief of Local Community confirmed that they have no customary rights disputes.

Compliance status: Full Compliance

Criterion 6.5: Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are s ufficient to provide decent living wages.

Findings: It was available Memorandum No. 010 / MD / II / 2016 on February 25, 2016 concerning the adjustment of the basic wage of monthly employees and daily permanent employees in 2016. Adjustment of the daily permanent employee's (KHT) basic wages in 2016 is set at the Provincial Sectoral Minimum Wage (UMSP) Prov. South Sumatra (No. 117 / KPTS / LABOUR AND TRANSMIGRATION AGENCY / 2016) that is IDR. 2,250,000. It is available memorandum No. 011 / MD / II / 2016 on February 25, 2016 regard-ing basic wages for casual employees in 2016, which amounted to IDR. 90,000 per day. Copies of these rules were stored by HRD in mill and estate.

The Company had a Collective Labour Agreement for period of 2015-2017 that was registered in Labor and Transmigration Agency Province. South Kalimantan No. 15 / C / CLA/ DTKP / XI / 2015 on November 19, 2015. CLA have included: facilities and assistance to the labour union, recruitment, remuneration, dai-ly working hours, exemption from the obligation to work, health care, social security and workers' welfare, health and safety, order and discipline, complaints and settlement, termination of employment.

PT Aek Tarum has a list of employee wages. Wages document well-documented. Salary structures of employees are listed in the memorandum No. 027/MD/III/2015 dated March, 27 2015. Wage payment is the common term that the company needs to follow as it is compulsory required by South Sumatera Gov-ernor’s Decree in SK Gubernur No. 217/KPTS/Disnakertrans/2015, with Minimum Salary of South Su-matera Province in 2015, dated February 27 th, 2015 is amount 2.100.000 IDR,-. Standars wage is de-termined by South Sumatera Province Indicator.

There was also the There Labour Agreement between PT Sampoerna Agro Tbk, Sampurna Agro Union, established by decree of Manpower and Transmigration No. province of South Sumatra. 146/Nakertrans/2010 (in accordance with Law 13 in 2003) which contains the rights and obligations of employees.

Auditor assessed the list of workers, complete with the wage amount, date of birth, date of joining SMM, basic salary, fringe benefit or premi, additional, overtime, allowance, gross, deduction, nett), dan signa-ture, payment slip, detailed with all allowance and deduction is available. The receipt of payment was giv-en to all workers on the payment day.Each worker has their contract, based on Decree of Working

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Agreement (so called Surat Keputusan Penetapan Perjanjian Kerja Bersama) oleh Kepala Dinas Sosial, Tenaga Kerja dan Transmigrasi about registration of Perjanjian Kerja Bersama PT AekTarum Sampoerna Agro (ATSA), dated November 17, 2011 which was signed by ATSA and Labour Union (PUK FSP Kep Migas dan Umum PT ATSA), and approved by The Officer of Worker Affair. A labor policy containing sub-jects such as non discrimination and forced labor for both employee and contractors are socialized in agreement with those people. Worker and contractor are required by the terms of their con-tract/agreement to have their fair compensation.

All employees even contractor have been provided with suitable housing, water supplies, medical care (clinic, including doctor, nurses and medicines and bed) and welfares by the company. Worker housing receive piped potable water which is tested regularly to ensure that it is safe for human use. The facility provided the huge water jar to store the rainfall for being used as drinking water. It is also tested regularly to ensure it is always safe for human consumption. All workers housing are also provided with free elec-tricity. Meanwhile, there’s a new facility for employees, day care for their kids forfree. The parents are recommended to bring groceries and vegetable for their kids then it is cooked by the nanny in day care.

For labour law, this company has a socket book about agreement between company and labor union re-fers to Law No 13/2003 about Labour. In this socket book, there was rules about contract between com-pany and labour, working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, rea-sons for dismissal, period of notice, etc.

There are some facilities from the Company to its workers, such as housing, water supplies, educational and medical. All workers, if heads of families are provided with a housing unit, equipped with electricity and piped clean water for washing and bath. There are other facilities for workers, such as policlinic, baby day care, kindergarten, school bus and sport facilities.

The company also facilitated the provision of basic food needs of workers. Many efforts were done by company:

• There is a monthly salary market which supplies many basic and other needs.

• In every camp (housing) there is small shop/stall which sell some needs.

• There is a daily itinerant vegetable seller.

Based on interviews with some workers, they get basic food (such as rice, flour, etc) easily. The existence of that facility ensures the access of employees to the food was decent, fairly and reasonably priced.

Compliance status: Full Compliance Criterion 6.6: The employer respects the right of a ll personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bar-gaining are restricted under law, the employer faci litates parallel means of independent and free association and bargaining for all such personnel. Findings: PT Aek Tarum has policy regarding the recognition of freedom of association under policy: “Visi, Misi, dan Kebijakan PT. Sampoerna Agro”. The policy includes freedom of association, respect for every worker to have the right to form and to be a member of labour union. The Union and management of ATSA negoti-ate the Perjanjian Kerja Bersama, or Mutual Working Agreement, every 2 years, according Surat Kepu-tusan Dinas Tenaga Kerja dan Transmigrasi No. 146/Nakertrans/2011 dated 01.01.2011. This Agreement allows them to establish a labour union in accordance with national legislation UU No.13 2003. There was a regular meeting between representative of worker union and representative of management company. Minutes of some meetings were checked and the meetings found to be properly conducted.

On September 12, 2015, it has been already conducted meetings between SPSA and the company, discussion agenda was about renewal plan of CLA material and discussion of urgent issues in the work unit.

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According to the statement expressed by the chairman of SPSA, it was explained that company has given the rights of employees, wages are in accordance with the Province Minimum Wages( UMP), providing infrastructure, providing training to workers and so on. All workers are already registered as participants of BPJS health (Health Assurance). No child labor, no discrimination against workers. In order to avoid child labor company asks Personal Identity Card (KTP) and Family Card (KK).

Compliance status: Full Compliance Criterion 6.7: Children are not employed or exploit ed. Work by children is acceptable on family farms, under adult supervision, and when not interf ering with education programmes. Children are not exposed to hazardous working conditions. Findings: PT. Aek Tarum has a policy on child and female workers (Memorandum No. 0016/DMD/XII/2010” in 9.12.2010) signed by a Director and socialized in agreements with suppliers/contractors No one under 18 years of age is to be employed. Records of personal data of employees-age, marital status, position and rank, location of work, date of commencing employment-are kept. Checking the records per January 2016 confirmed that no one under 18 years old has been employed-in compliance with Indonesian national leg-islation UU RI No.13 Tahun 2003, article 68.

The Company has a policy of working age, drafted on July 21, 2015, that is the protection of women workers in working place by preventing sexual harassment and violence, as well as the protection of re-productive rights. Do not employ minors and facilitate the care of children. The policy has been dissemi-nated to all levels of employees on January 5, 2016. The Company was also displayed the policy in the office and housing area.

Based on the verification results of documents of employees list in January 2016 in mind that no employ-ees in the company were less than 18 years of age at the time of admission to work.

Compliance status: Full Compliance

Criterion 6.8: Any form of discrimination based on race, caste, national origin, religion, disabil-ity, gender, sexual orientation, union membership, political affiliation, or age, is prohibited.

Findings: The Company has a policy of equal opportunities to obtain employment that was drafted on July 21, 2015. It was about respecting human rights, including the right of all workers to organize and conferred collec-tively as well as provides opportunities for equal treatment in employment.

The policy has been disseminated to all levels of employees on January 5, 2016. The Company also put these policies in offices and housing. Based on the interview results with unions, it was noted that there is no discrimination against workers. Company is not discriminatory in treating workers since acceptance till work in all types of jobs.

Company also has policy of opportunity similarity (include local community) which can be accessed by public, through announce board in estate office, mill office and division office. Moreover that policy is also socialized during stakeholder meeting. Policy in writing about this casse stated in document “Viission, Mission and Policy of PT. Sampoerna Agro”. Further, company also has SOP No. P-SAG-RO-HRS-01 dated on March 16 th, 2012 about recruitment the new employee. In the procedure stated to open the op-portunity for every worker after passing selection process based on the capacity and capability new em-ployee.

PT. Aek Tarum is also committed to provide jobs for the locals, even though they are reluctant to accept. They prefer to choose the job like security. Jobs like harvester are mostly carried out by external commu-nity. Vacancies are posted on notice boards in the mill/estates, and also advertised in the local news pa-per. A policy on equal rights regardless of race, caste, national origin, religion has been established and also socialized in agreements with suppliers/ contractors.I.e in recruiting process is open to public, no re-

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quirements of ethnic, religion, caste and gender.

In addition, based on the book of Mutual Working Agreement, the company must provide religious leave allowance to their workers to celebrate religious holidays. There is a transparent system of holiday for workers, if they need to take their leave (as stated in Chapter V, Article 20), and to get permission to take their leave related to the religious event (as stated in Chapter V, Article 21).

Through interview with workers, it was confirmed that there was no discrimination on working opportuni-ties, all workers were treated equally. Records of employee’s recruitment and their contract agreement were available. In PT. Aek Tarum there was no migrant worker.

Appraisal the worker’s performance referred to SOP No. P-SAG-RO-HRS-03 dated March 16 th 2012. PT. Aek Tarum is an equal opportunity employer, through promotion method based on performance. The Hu-man Resources Regional Head identifies and recommends candidates for promotion to a selection board at ATSA Head Office.

Compliance status: Full Compliance

Criterion 6.9: A policy to prevent sexual harassmen t and all other forms of violence against women and to protect their reproductive rights is d eveloped and applied.

Findings: The Company has a policy of preventing sexual harrasment, drafted on July 21, 2015, that is the protec-tion of women workers in working place by preventing sexual harassment and violence, as well as the protection of reproductive rights. Do not employ minors and facilitate the care of children. The policy has been disseminated to all levels of employees on January 5, 2016. The Company was also displayed the policy in the office and housing area.

Results of interviews with women workers in residential of Belida Estate, it was stated that there was never any incident of sexual harassment that afflicts women workers.

The Human Resources Regional Head of PT. Aek Tarum has established a policy on prevention of sex-ual harassment and protection of reproductive rights of its female workers (Kebijakan Pencegahan Pelecehan Seksual, Perlindungan Hak Reproduksi dan MekanismePenanganan Keluhan dated 13.7.2010). The policy is displayed at various locations in the mill/estate offices and socialized to the

Workers in each unit. The rules have been explained to all workers to ensure their understanding. Based on the result of interview women employees, it is confirmed that that they understood the policy and knew the grievance mechanism for complaints.

The company protects the reproductive rights of all women workers, by providing maternity leave and prohibition for breastfeeding women to work as chemical sprayer. Female employees are entitled to be pregnant and childbirth leave of 3 months and also allowed to breastfeed for up to 6 months at least 30 minutes everyday.

Based on the Collective Bargaining Agreement Book (Article 20 of Chapter V) about maternity leave, menstruation leave, pregnancy and miscarriage. While menstruation leave is suspended based onresult of meetings, this is due to some workers who use this excuse to not work.

Checks in the field concluded no pregnant and breast-feeding women were working with agrochemicals. Interviews with female workers confirmed that they understood the policy. Company has policy to protect claim identity. Based on complaint records, no written complaints have been submitted by employees.

The Company issued a policy report about complaints of SGRO on whistle blowing system dated October 24, 2013 which is in line with the company's commitment to hold open communication and to enhance good corporate governance), the policy is intended to provide a forum for internal employees and exter-nal parties associated with the group of companies to submit a report about the alleged of violations, vio-lations and obstruction of the company group while they aware of the incident. Provide security guaran-

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tee for those who report the violations, then he/she will be protected from acts of retaliation or victimiza-tion caused by violation reporting that was done in good faith without intention to do harm.

Compliance status: Full Compliance

Criterion 6.10: Growers and mills deal fairly and t ransparently with smallholders and other local businesses.

Findings: It was available pricing document of FFB on April 2016 (Period II) established by the Palnataion Agency of South Sumatra Province, through Letter No. 525/303-VI.3 / BUN, on April 18, 2016. The price of FFB per kg of plant at the age of 3rd year was IDR 1,496.81; at the age of 10-20 year was IDR. 1,739.95 year, its 25th year was IDR 1,562.34.

FFB price is determined by a meeting, attended by the parties, such as representatives of the Company, Cooperative Management and Plantation Agency.

FFB Price that was used now and previously has been known by the farmer / Committee of Village Coop-erative Unit. Cooperatives are involved in setting the price of FFB. FFB pricing mechanism was agreed by the parties every two weeks.

Price of FFB from smallholders refers to the price set by the Department of Plantation, South Sumatra Province that was issued twice in a month. Smallholders get the FFB price information directly from the Plantation Office South Sumatra Province and POM of PT. Aek Tarum.

TBS yang diterima di PKS Belida dari 8 KUD yaitu: KUD Jaya Bersama, Karya Makmur, Mekar Sari, Mul-ya Jaya, Panca Sawit Makmur, Rahayu Bhakti, Sumber Rejeki, Tekad Mandiri.

PKS Belida membeli TBS dari pihak ke 3 atau suplier. Hanya satu supplier yang melakukan penjualan TBS kepada PKS Belida yaitu CV Bambu Kuning Sejahtera alamat Desa Sungai Belida Kampung I RT 003 Lempuing, Kota Kayu Agung. Tersedia Perjanjian Pemasoka Tandan Buah Segar (TBS) Kelapa Sawit antara PT Aek Tarum dengan CV Bambu Kuning Sejahtera No. 001/AT/SPK/I/2016 tanggal 2 Jan-uari 2016.

PT. Aek Tarum maintains fair, legal and transparent agreements with its suppliers/subcontractors and in-dependent farmers. Even though there are no purchase contracts to bind the smallholders they will be in-formed by the mill on the daily FFB price through phone and the daily price of FFB will be posted at the mill gate. A list of FFB smallholders is kept and updated for the purpose of informing the daily FFB price. The smallholders are free to decide where to sell their FFB. The price of FFB is determined by the pur-chasing department, based on to the procedure FFB price calculation. There was no complaint record of FFB Price found during audit. PT. Aek Tarum has fair, legaland transparent agreements with its suppliers/contractors and plasma smallholders. There are transactions and purchase contracts with contractors and local companies on sale and purchase of FFB, FFB transport and service, maintenance and repair of mill equipmet. The price for FFB is determined by the Head of Regional Plantation Section, Agriculture Department of Province South Sumatera via a mechanism based on the CPO price, kernel price (index K) from all palm oil producers and palm oil estates in South Sumatra every two weeks. The FFB price is set at a meeting attended by the representatives of KUDs, or of the plasma smallholders themselves. Checks with KUD Panca Sawit Makmur and KUD Mulya Jaya confirmed that they had copies. Information of FFB price is available in front of the Mill Office. Interviews during public consultation, with some contractors confirmed that they understood the terms of their contracts well and thought them fair, legal and transparent and found no grievance about the price. (Indicator 6.10.3. Auditorr checked and verified the payment to the contarctor and found it was compliant to the contract agreement. During the public consultation which was attended by FFB’s suppliers, it was noted that the payment was transparent and as per applicable agreement terms of payment.

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Mutual Agreement Letter No. 003/BL/SPK/XII/2014 dated on December 15th, 2014 about working agree-ment for tiding houses type G.6 R1/900 VA amount 66 units (10 units) between local contractor (Pandi Saputra) and Belida Estate Manager. The payment of this project was appropriated to Mutual Agreement Letter. Compliance status: Full Compliance

Criterion 6.11: Growers and millers contribute to l ocal sustainable development wherever appro-priate.

Findings: The management of PT. Aek Tarum has strong commitment to contribute to community development and documented in Quality, Safety and Health Environmental, for Sustainable Policy (QSHES Policy), signed by the President Director. The Social Impact Assessment Report was issued. The activities planned were varied, such as socialization of shareholders program for the locals, aids for local teachers, free medical treatment for the locals, making a well for locals, etc.

Contribution of sustainable development to local contractor through is based on annual stakeholder meet-ings. At this meeting, all stakeholders are given the discretion to exclude ideas and the problem about im-pact of the existence of the company. Some contribution has been awarded by companythrough CSR. Then, if there is a problem, it can be resolved by win win solution.

The assistance from PT. Aek Tarum to the community such as renovation for some items are schools, roads, bridges, e.g., Posyandu (integrated healthcare service post and health education to Promote hu-man hygiene), sanitation, fogging, agricultural skills training for the locals (estate workers and smallhold-ers), skills training for school teachers, scholarships available, tree planting, waste treatment for land ap-plication such as EFB for plasma estates.

PT Aek Tarum has built partnerships with 8 Village Cooperative Unit, smallholders area of 6,554.10 ha, 3,169 households .The company provides regular guidance to farmers, for example: coaching for nursing and harvesting determination in Mandiri Village Cooperative Unit on October 10, 2015, the socialization of stalk bunches cutting on September 8, 2015 in Village Cooperative Unit of Panca Sawit Makmur.

Examples of CSR in 2015: Rehabilitation Sukasari Village offices, rehabilitation Kertamukti village mosque, Safari Ramadan in the village of Tanjung Makmur, procurement of furniture in Elementary School (SDN 2) Tanjung Makmur.

According to interviews with the Department of CD, it was explained that CSR program was annually evaluated in order to measure the level of success and its benefits. It was commonly carried out in De-cember each year. CSR program in the next year is arranged based on CSR evaluation results and based on input from Musrembang activities at the level of all Sub-District, attended by village leaders who was included in Company’ Guidance. Compliance status: Full Compliance

Criterion 6.12: No forms of forced or trafficked la bour are used.

Findings: Policy of commitments not to recruit labor-traded and do not employ labor by force, it was contained in the policy of meet all customer requirements, legal requirements and other relevant legislation, which is appli-cable in local, national and ratified international. Results of interviews with HR Department and unions, it is known that all the company's workers is legal, there is no recruitment of illegal traded labor. Results of search on the list of workers in February 2016, it was noted that no trafficked labor found. The company employs a permanent worker and a daily worker. Employment contract agreement between the company and workers is in Indonesian language that is easily understood. Bsed on the human resources department, public consultation and interviews with several workers, there

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occurred never any labor trafficking. The audit team has verified and checked the letter of agreement be-tween workers and the company. It was confirmed that the agreements were signed by both parties with-out any coercion and force, the worker entered into employment voluntarily and freely, without the threat of a penalty, and he has freedom to terminate employment without penalty if there is a reasonable notice available or as per agreement. Based on interviews with workers, there was no deduction from the com-pany, unless the deduction of the loan that worker asked to the Company’s Cooperative. 1). The audit team also confirmed that no contract substitution occured. There are no migrant workers and temporary workers in PT. Aek Tarum. Compliance Status: Full Compliance

Criterion 6.13: Growers and millers respect human r ights.

Findings: The company has a policy to respect human rights. The policy is stated in Visi Misi Kebijakan Sampoerna Agro, dated 2 Mei 2015. Point 4: “Respecting Human Rights issue, included Rights of all workers to asso-ciation and negotiate collectively and give same opportunity in working. This policy has been communi-cated to workers. Documentary evidence of socialization and communication of the policy on May 16 th, 2015 is available and stored properly. Compliance Status: Full Compliance Criterion 7.1: A comprehensive and participatory in dependent social and environmental impact assessment is undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, m anagement and operations. Findings: There was new planting, but only for optimize land that is in Belida Estate planted in 2009, and 2010 which included in concession the area. Drainages were built to remove the excess water. Social and envi-ronmental impact assessment had been made prior to land clearing along with other area in the same concession area. Compliance status: Not Applicable

Criterion 7.2: Soil surveys and topographic informa tion are used for site planning in the estab-lishment of new plantings, and the results are inco rporated into plans and operations.

Findings: The company has soil map with scale 1:25,000. Based on soil maps can seen that the type of soil in IPBS estate and Belida estate namely Lithic hapludlts, Plinthic kanhapludults, Aquic dystrudepts and Arenic plinthaquic kandiudults. Based on filed visit and topography map, the location of IPBS estate and Belida estate is flat (0-8%).

The company not has peat land so this indicator not aplicable for this company. The company not has fragile soil (sandy, low organic matter, acid sulphate soils) so the copnay not has management plan of fragile soils. Compliance status: Full Compliance

Criterion 7.3: New plantings since November 2005, h ave not replaced primary forest or any area required to maintain or enhance one or more High Co nservation Values.

Findings: IPBS estate is old plantation, oil palm was planted in year 1993 and 1996 with total developed area is 552.24 Ha. Based on Land use change analysis and satellite imagery data 2004, it is prove no primary

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forest even secondary forest before 2005. Belida estate generally consist of old palm oil from 1991 to 2009, but there is small waterlogged lower area about 7.70 has opened in 2009 and planted in 2010. De-veloping this area is intende for optimizing land allocation for oil palm. Based on satellite imagery taken on August 2005, the landcover of that area was a shrubs and bushes. Satellite imagery landcover type before year 2005 is presented in figures below:

Figures 8: Land cover type over Belida estate on Au gust 2005 is dominated by palm oil

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Figures 9: Land cover type over IPBS estate on June 2004 is already planted with palm oil

The company has conducted HCV assessment in 2010 and 2012 as existing plantation as described in Criterion 5.2 above. The company implemented HCV management and monitored regulary as recom-mended in HCV document. Compliance status: Not Applicable

Criterion 7.4: Extensive planting on steep terrain, and/or on marginal and fragile soils, is avoided.

Findings: The company has soil map with scale 1:25,000. Based on soil maps can seen that the type of soil in IPBS estate and Belida estate namely Lithic hapludlts, Plinthic kanhapludults, Aquic dystrudepts and Arenic plinthaquic kandiudults. Based on filed visit and topography map, the location of IPBS estate and Belida estate is flat (0-8%).

The company does not have peat land so this indicator not aplicable for this company. The company does not have fragile soil (sandy, low organic matter, acid sulphate soils) so the copnay not has management plan of fragile soils. Compliance status: Full Compliance Criterion 7.5: No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a document ed system that enables indigenous peo-ples, local communities and other stakeholders to e xpress their views through their own repre-sentative institutions.

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Findings: In 2012 the company planted new oil palm plantations covering an area of 4 ha. The Company has estab-lished Document Study of Social Environment Assessment (SEI) which includes IPBS Estate and Belida Estate and POM Belida in 2012 by the Faculty of Forestry in 2012. The social studies include: physical condition, socio-cultural, community characteristics, strategic issues, social activities and impact analysis, employment, stakeholder analysis and social management plan. To increase the positive impact and re-duce the negative impact, companies implemented the monitoring and evaluation of SEI over once a year. The scope of the study of SEI included the location of cropland in 2012 covering an area of 4 ha where the location is still within the existing LUT. Against an area of 4 ha, there were no land acquisition. Compliance status: Full compliance.

Criterion 7.6: Local people are compensated for any agreed land acquisitions and relinquish-ment of rights, subject to their free, prior and in formed consent and negotiated agreement

Findings: There is no new planting established on the local people land; no local people are compensated for the land. Compliance status: Not Applicable

Criterion 7.7: Use of fire in the preparation of ne w plantings is avoided other than in specific sit-uations, as identified in the ASEAN guidelines or o ther regional best practice.

Findings: Since both estates are an old plantation which is planted before 2010, than this criterion is Not Applica-ble. For the small area (7.7 Ha) that opened in 2009 there is a minute of activity No. 01/BL/VIII/2009 that described land clearing was not using fire, except uprooting, chipping and stakcing only.The company and group also has zero burning policy . Compliance status: Not Applicable

Criterion 7.8: New plantation developments are desi gned to minimise net greenhouse gas emis-sions.

Findings: PT Aek Tarum has no new plantation development area nor proposed any new area to develop. PT AT only manage the existing plantation area within the concesession right Compliance status: Not Applicable

Criterion 8.1: Growers and millers regularly monito r and review their activities and develop and implement action plans that allow demonstrable cont inuous improvement in key operations.

Findings: The estate and mill have a monitoring action plan and implementation report based on their Environmen-tal Management and Monitoring plan (UPL/UKL), and regular evaluations of plantation and mill opera-tions. As PT Aek Tarum estate and the mill prepares a report of their implementation of the RKL/RPL once every 6 months as required by the environmental department, which covers aspects required to be monitored in the RKL/RPL. For the estate, this includes ambient air quality, groundwater quality, waste collection, water biota sampling and analysis, road damage, social economic aspects such as hiring of workers and FFB and EFB transport (which can impact water and air quality), as well as impacts to com-munity health due to fertilizer application, and FFB and EFB transport. While for the mill, the implementa-tion report includes results ambient air quality, boiler emission quality, palm oil mill effluent quality, soil

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quality of land application area, noise levels, and scheduled waste production records. In addition, PT Aek Tarum estate has a documented Environmental Improvement Plan for year 2016, which covers activities to reduce domestic waste separation, and HCV management and monitoring. The program is updated monthly to indicate status of activities carried out and the estate also has a form for monitoring of achievement of objectives and targets. The estates has program to reduce pesticide usage and other restricted agrochemical materials. PT Aek Tarum has kept its commitment to produce FFB and CPO with some improvement. The existence of Research and Development Division make a possibility the continous improvement. For example, Cordycept usage in subsitute chemical pesticide and fertilize spreader for effectiveness of fertilizing. The availability of SOPs as an operational guidance is very important to support sustainabilty system. The companys and staff in the future should folllow the whole procedure and mechanism which is set up in SOPs. Compliance status: Full Compliance

• RSPO Scheme Smallholder

Principle 1: Commitment to transparency

Criteria 1.1 : Scheme manager provide adequate info rmation to other stakeholders on environ-mental, social and legal issues relevant to RSPO Cr iteria, in appropriate languages & forms to al-low for effective participation on decision making

Findings :

Information request and provision is recorded in book of incoming and outgoing letter. The book is availa-ble in KUD Tekad Mandiri and KUD Panca Sawit Makmur. The book of incoming and outgoing letter peri-od of 2016 contains information of date, letter number, subject, response or follows up action taken.

For example, on January 15, 2016, on behalf of Sujianto, member of Village cooperative Unit of Tekad Mandiri, ask for clarification on the cost of FFB harvesting. The shelf life of information requests and re-sponses are stored for 5 years. For instance, on January 15, 2016 on behalf of Sujianto, member of Vil-lage cooperative Unit of Tekad Mandiri, ask for clarification on the cost of FFB harvesting.

Compliance status: Full Compliance

Criteria 1.2 : Management documents are publicly av ailable, except where this is prevented by commercial confidentiality or where disclosure of i nformation would result in negative environ-mental or social outcomes

Findings :

There are communication mechanisms, consultation and complaints, which is approved by the Chairman of Village Cooperative Unit on March 14, 2016; the general procedure explains: All data information of all stakeholders were addressed to the Chairman of Village Cooperative Unit, then the response given by the chairman of Village Cooperative Unit, if necessary response will be discussed with members.

It means that other documents listed before can be accessed by external stakeholders. However, the listed information above can be given if there is any communal decision based on member and Gapoktan Kopau Jaya board decision.

Auditees have identification document of social and environmental impacts that were prepared in early 2015. The social and environmental management was conducted once a year that includes the positive

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and negative impacts. Document identification of social and environmental impact and other documents were stored in filing cabinets of Village Cooperative Unit of Tekad Mandiri and Panca Sawit Makmur. Compliance status : Full Compliance

Principle 2: Compliance with applicable laws and re gulations

Criteria 2.1 : There is compliance with all applica ble local, national and ratified international laws and regulations

Findings : Auditee has put an effort to obey the important and relevant regulation on palm oil plantation, for example land legal (SKT, SKGR, grant and private ownership), having list of protected species, the availability of regulation on palm oil plantation sector. However, there is not enough evidence that the organization has obeyed the applied regulation, for example there is no available copy of minimum regional wage decree for 2015 and 2016. There was a list of rules derived from national legislation of the Republic of Indonesia, which related to the legality of the land, the cultivation of oil palm plantations, social and environmental. Cooperative has not been fulfilling the laws and regulations among others:

• Can not shown evidence of legalisir Business License (SIUP) every year • Can not shown evidence of re-registration Bussiness Location Permit Letter (SITU) every year

and evidence of the cooperative business activity report each semester to the Licensing and In-vestment Agency

• Can not shown re-registration of nuisance permit every year as stated in the provisions of the third (3) on the license.

It was raised as Nonconformities (NCR RSPO 00230). Compliance status : Non Compliance

NCR RSPO 00230 (Major non-conformity) Cooperative has not been fulfilling the laws and regulations among others:

• Can not shown evidence of legalisir Business License (SIUP) every year • Can not shown evidence of re-registration Bussiness Location Permit Letter (SITU) every year

and evidence of the cooperative business activity report each semester to the Licensing and In-vestment Agency

• Can not shown re-registration of nuisance permit every year as stated in the provisions of the third (3) on the license.

Criteria 2.2 : The right to use land can be demonst rated, and is not legitimately contested by local communities with demonstrable rights

Findings : Some of legal non conformity in cooperative such as:

1. Legality of cooperative members is still not available in completely in the cooperative office. For example: Koperasi Jaya Bersama member not yet have a legal land as much as 20 SHM

2. The area of statement is not in accordance with the area listed in SHM

It was raised as Nonconformities (NCR RSPO 00231).

Auditee has put an effort to obey the important and relevant regulation related to palm oil plantation, for example land legal status (land status letter (SKT/Surat Keterangan Tanah), compensation letter (SKGR), grant and private owned land title (SHM)), own list of protected species and the availability of related palm oil plantation regulation.

According to interviews with officials and members of Village Cooperative Unit of Tekad Mandiri and Pan-ca Sawit Makmur, it was known that in the area of smallholdings, no cases of land disputes. Oil palm

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plantation boundaries between members were clear, which was made from pipes.

Compliance status : Non Compliance

NCR RSPO 00231 (Major non-conformity) Some of legal non conformity in cooperative such as:

1. Legality of cooperative members is still not available in completely in the cooperative office. For example: Koperasi Jaya Bersama member not yet have a legal land as much as 20 SHM

2. The area of statement is not in accordance with the area listed in SHM

Criteria 2.3 : Use of the land for oil palm does no t diminish the legal rights, or customary rights, o f other users, without their free, prior and informed consent

Findings :

Interview with Independent Smallholder’s Organization explains that the palm oil plantation area is not originated from traditional right. The area is ex-public transmigration and ex-transmigration area of inde-pendent transmigration that is private own based on private title ownership (self ownership right/SHM) and SKT (Surat Keterangan Tanah/land title status) that is issued by Village Level Government).

Compliance status : Full Compliance

Principle 3: Commitment to long-term economic and f inancial viability

Criteria 3.1 : There is an implemented management p lan that aims to achieve long-term economic and financial viability

Findings : Two smallholder farmers groups, Tekad Mandiri and Panca Sawit Makmur has created their own Bussines Plan that described workplan for the next 3 years (2016-2018) completed with timeline and budgeting. Special for Tekad Mandiri palm oil plants will be replanted in 2018 (plant year 1991), projection cost for replanting also have been budgeted. The bussines plan includes some activity needed for cultivation pro-gram, among as: routine maintenance for plants and roads, transportation, fertilizing and spraying, and al-so include allocation for social/community cost and training, especially for RSPO system implementaion preparation. Replanting budget covers: land clearing, cover crops, seeds, palmoil planting, immature maintenance, roads and bridge maintenance, cencus, pruning, pest and desease, castration, and fertiliz-ing. Panca Sawit Mandiri will also take replanting program in 2010 for plants year 1992, 1993 and 1994. Administration cost for cooperation officer and other management cost is also included. As an observation, the smallholder groups should include projection of yield and profit for 3 years. Compliance status: Full Compliance

Principle 4: Use of appropriate best practices by g rowers and millers

Criteria 4.1 : Operating procedures are appropriate ly documented and consistently implemented and monitored

Findings: KUD Jaya Bersama already have Standard Operating Procedures (SOPs) and Work Instruction that co-vers key activities. SOPs have been well documented and tracebiltiy of any document changes are identi-fied in each procedure. Some of are listed below :

• SA-PLASMA-PP-KS-01, dated 1 Oktober 2015, re : Nursery • SA-PLASMA-PP-KS-02, dated 1 Oktober 2015, re : IPM techniques

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• SA-PLASMA-PP-KS-03, dated 1 Oktober 2015, re : Fertilization • SA-PLASMA-PP-KS-04, dated 1 Oktober 2015, re : Harvesting • SA-PLASMA-PP-KS-05, dated 1 Oktober 2015, re : Pruning • SA-PLASMA-PP-KS-06, dated 1 Oktober 2015, re : Weeding Control • Work Instruction Circle Weeding • Work Instruction Chemical Weeding

Socialization of SOPs and Work Instructions has been conducted on April 8, 2016 and its evidence is maintained and documented.

Evidences of implemented of key activities have been recorded in each form and the form are identified activity dated, Group, total labour, material usage, Ha Applied and others. For Example :

• Chemical Weeding activity was recorded in Form ““Realisasi Penyemprotan KUD Jaya Bersama” • Fertilizer Activity was recorded in Form “Laporan Realisasi Pemupukan/Kelompok Tani (KT)” • Census of rat pests activity concistenly done once per month and was recorded in Form ““Ring-

kasan Sensus Hama Tikus”

Cooperatives Jaya Bersama has Pest and Disease Control Procedure (SA-Plasma-PP-KS-02 effective date of October 1, 2015). In the procedure stated that the cooperatives are required to conduct a census of owls every three months but the cooperative not yet conducted a census of owl since the procedure applied. It was raised as Nonconformities (NCR RSPO 00233).

Compliance status : Non Compliance

NCR RSPO 00233 (Major non-conformity) Cooperatives Jaya Bersama has Pest and Disease Control Procedure (SA-Plasma-PP-KS-02 effective date of October 1, 2015). In the procedure stated that the cooperatives are required to conduct a census of owls every three months but the cooperative not yet conducted a census of owl since the procedure applied

Criteria 4.2 : Practices maintain soil fertility at , or where possible improve soil fertility to, a le vel that ensures optimal and sustained yield

Findings :

Jaya Bersama Cooperative has recommendation of fertilizer year memiliki rekomendasi pemupukan 2015 and 2016.

Year 2015, Jaya Bersama Cooperative has conduct fertilizer i.e:

No Type of Fertilizer Realization (kg)

1 ZA 75.794

2 MOP 78.300

3 RP 17.100

4 Dolomite 131.000

5 HGFB 12.750

Year 2016 (until March), Jaya Bersama Cooperative has conduct fertilizer i.e:

No Type of Fertilizer Realization (kg)

1 ZA 128.000

2 Dolomite 192.000

Jaya Bersama Cooperative has productivity 3 years i.e:

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No Year Planted (Ha)

Production (ton)

Productivity (ton/ha)

1 2015 524.50 8,908.030 16.98

2 2014 524.50 8,172.130 15.58

3 2013 524.50 10,305.971 19.64

Compliance status : Full Compliance

Criteria 4.3 : Practices minimise and control erosi on and degradation of soils

Findings :

The cooperative not has peat soil and swamp so this criteria not applicable

Compliance status : Not Applicable

Criteria 4.4 : Practices maintain the quality and a vailability of surface and ground water

Findings :

In order to implement best practise in cultivation technique, some farmer leaders has been trained in soil and water conservation for two times. PT Aek Tarum as a farmer’s group partner provided trainer and les-son material. Evidence of training is list of attendance and photograph, the latest training was conducted in November 11th, 2015 attended by 24 farmers. Based on interview with the participant s, they were quite understand about the importance of soil and water conservation, included water source maintenance. As an observation, the smallholder group should provide a strong evidence for trainings conducted, such as material lesson, sign of trainer in list of attendance, and also evidence for group dissemination in order tospread the lesssn to other farmers.

Generally, land morphology in Tekad Mandiri and Panca Sawit Makmur is flat with slope 0-8%. In Tekad MAndiri block 28C, 17A, 30B and 32 D, there is a small river which is also been HCV areas. Cooperation unit of Tekad Mandiri has provided an agreement between the members to protect the riparian zone com-pleted with signpost instalment informs chemist and fertilizing prohibition. In additional, a special clerk is assigned to monitor HCV area / riparian zone. A minute of agreement is available dated on April 11th, 2016 signed by the Cooperation Committee and member representaives. Mr Dawuh is assigned for HCV/riparian management and monitoring for Panca Sawit Mandiri, whilst Mr Pranoto is assigned for Tekad Mandiri. To maintenance palm oil production, farmers applied NPK Phonska fertilizer usually two times a year. Based on fertilizing report, Tekad MAndiri applied fertilizer in March 2015 and March /April 2016. Fertiliz-er used was 200,000 kgs for 824.10 ha contains 107,893 trees. In Panca Sawit Makmur, fertilizer was ap-plied in March 2015 with 246,500 kgs for 1013.3 ha, and November 2015 with 248,000 kgs., the latest fer-tilizing happened on March 2016 with 97,000 kgs and April 142,000 kgs. Smallhodler group were also used herbicide for plants maintenance with Glifosat and Metil. Herbicide usage was recorded well. In 2015 Tekad Mandiri applied 759 litre glifosat and 11,600 litre metil for 352 ha and GAserol for the plan circle, while PSM used Roun-up. The cooperation unit reported fertilizing realization in every six month. For example in smester 2, Group 1 dated on March 26, 2016 received 15,000 kgs and for Group 2 re-ceived 12,500 kgs. The Cooperation kept delivery record of fertilizing and herbicide to farmer groups. There was some delivery receipts from Cooperation Manager to Farmer Group leader. Eventhough Co-operation unit shown realization report, however there is no documented evidence of fertilization and spraying in the field where there is only proof of delivery evidence from cooperative to the group. (Coop-erative Tekad Mandiri and Panca Sawit Makmur). It was raised as Nonconformities (NCR RSPO 00235).

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Compliance status : Non Compliance

NCR RSPO 00235 (Minor non-conformity) There is no documented evidence of fertilization and spraying in the field where there is only proof of de-livery evidence from cooperative to the group. (Cooperative Tekad Mandiri and Panca Sawit Makmur)

Criteria 4.5 : Pests, diseases, weeds and invasive introduced species are effectively managed us-ing appropriate Integrated Pest Management (IPM) te chniques

Findings :

Cooperative has pest and disease control procedure (SA-Plasma-PP-KS-02 effective date of October 1, 2015). Cooperative of Jaya Bersama has conducted a census of the rat. Based on rat recordings that has been conducted in March 2016, conducted a census at 261 TPH with the total of bunches is 1,949 bunch. Based on these data can be seen that the rat attack rate is 18 bunch (0.92%) so do not be controlled be-cause it is still below from the threshold (> 10%).

Cooperative Jaya Bersama has been conducted IPM training on October 12, 2015 by Mr. Nurbiyanto from PT Bina Sawit Makmur that equipped with attendant list and photo documentation.

Compliance status : Full Compliance

Criteria 4.6: Agrochemicals are used in a way that does not endanger health or the environment. There is no prophylactic use, and if agrochemicals, which were categorised as World Health Or-ganisation Type 1A or 1B, or are listed by the Stoc kholm or Rotterdam Conventions, were used, growers are actively seeking to identify alternativ es, and this is documented

Findings : KUD Jaya Bersama always ensure that agrochemical are used have been registered and permitted by the Minister of Agriculture and also do not use agrochemicals categorized as WHO Type 1A or 1B or are listed by Stockholm or Rotterdam conventions. For example: Herbicides Elang (Active Ingredients isopro-pyl glyphosate) with no registration RI.01030119941170 issued by PT Inti Everspring Indonesia and the permit is still valid until September 1, 2017. There are also GARLON 480 EC (the active ingredient Trichlophyr) with no registration is RI.0103011984695 by PT Dow Agri Sciences Indonesia and permit val-id until 24 September 2018.

PT Aek Tarum is committed that agrochemicals are used does not endanger health or the environment. Refer to record of herbicide used ( Report of “Rencana dan Realisasi Semprot Gawangan maupun Piringan”) and during field visit, pesticide used in accordance with targeted species, appropriate dosage, method and time of application so that minimal effect on non-target species. For example, Elang/Round-Up (active ingredient glyphosate isopropyl amine) for control of narrow-leaved weed. Related to IPM, dur-ing Second Semester 2015 until audit is performed, no use of pesticide, due to refer to census result is still below the economic threshold.

KUD Jaya Bersama and KUD Panca Sawit Makmur already have procedures related to handling of Haz-ardous ,material (B3) and Hazardous waste (LB3) that is SOP M Penanganan B3 dan Pengendalian Limbah di KUD (SA-PLASMA-PP-LMB-01, dated 1 April 2016).SOP has been in accordance with applica-ble regulations. SOP has been socialized, for example in KUD Jaya Bersama on 8 April 2016. Hazardous material (B3) and Hazardous waste (LB3) storage already provided the specified place , but for a while, the place has not have license from relevant authorities.However, t’s recommended to re-ensure related symbol and label conformance with PermenLH No. 3 Tahun 2008 regarding Simbol dan Label B3 dan “PermenLH No. 14 Tahun 2013 regarding Simbol dan Label Limbah B3”.Handling of waste domestic for both KUD Jaya Bersama and KUD Panca Sawit Makmur, especially for trashcan (dustbins), should be ensured in accordance with SOPs, where waste segregation must be 3 (there) bins, due to actual segre-gation only 2 (two) bins. Pesticide operators for both KUD, each has its own sprayer team, for Medical Treatment, KUD in coop-eration with Puskesdes, and so far, there was no treatment for pesticide operator.

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Foreman of sprayer in KUD Jaya Bersama is Mr. Jajat with 12 pesticide operator, while in KUD Panca Sawit Makmur; the foreman of Sprayer is Mr. Putu Dauh with 7 pesticide operator. Training of Limited pesticide/Restricted pesticide was performed, for example in KUD Panca Sawit Makmur, according to ob-jective evidence (certificate) and interview, personnel who joined the training among others are Mr. Nengah B, Mr. Kadek Sartane, Mr. Kadek Agus Mulyadi, and Mr. Permana Hati. Type and volume of pesticide supplied to the smallholder was well documented every month. For example in KUD Jaya Bersama, during 2015, Type and volume of pesticide supplied to 10 Group smallholder for Elang (active ingredient glyphosate) was 105.47 Liters, while for Garlon (active ingredient Trichlophyr ) was 210.94 Liter. Sufficient working safety equipment is available for both KUD KUD (Jaya Bersama dan Panca Sawit Makmur), during field visit, there was no spraying activity, but auditor visit to PPE storage and rinse room for sprayer team, working safety has been stored properly in accordance with number of operator.

Compliance status : Full Compliance

Criteria 4.7 : An occupational health and safety pl an is documented, effectively communicated and implemented

Findings : K3 Program was available for period 2016, it can be seen in “Program Penerapan Sistem Kesehatan dan Keselamatan Kerja (K3) Periode Tahun 2016 di KUD Jaya Makmur”, example K3 program are provision of PPE, First aid equipment, build the rinse room for sprayer team

Regarding training on safe working practice as discussion previously was conducted on 8 April 2016

Besides training on safe working practices, both KUD have SOP related emergency procedure and han-dling of possible accident that is SOP Handling Accident and Emergency Procedure (SA-PLASMA-PP-DRR-01, dated 1 April 2016). Within SOP including Fire emergency, Earthquake, windstorm and also hurly-burly. Emergency drill was conducted in Kemang (KUD Tekad Mandiri) on 3 November 2015, and the evidence has been documented

KUD Jaya Bersama, always identify Work accidents every month, which is poured into the form " Rekaman Kejadian Kecelakaan Kerja (Record of Accident)", refer to “Records of Accident” obtained in-formation that during the period from September to December 2015 there were 10 Accidents identified, and all accidents are caused of pierced by a thorn of oil plam during harvest activity. However, KUD should always ensured consistency of recording, because found some accidents that happen in the month from January to March 2016 were not recorded (according to medical claim from Puskesdes) so the issue of accidents not discussed on K3 meeting dated May 5, 2016

OHS team of KUD Jaya Bersama was formed on 1 January 2016 and meetings regarding occupational health and safety (K3) regularly done, at least once per month. Evidence of meeting has been well docu-mented. Working equipment is available

Compliance status : Full Compliance

Criteria 4.8 : All staff, workers, smallholders and contractors are appropriately trained

Findings :

The cooperative has training plan year 2016 and also realization of training year 2015. Based on records, year 2015 has been conducted RSPO training of smallholder farmers, IPM training, HCV training, limited pesticides training, emergency first aid training, soil and water conservation training, OSH training and SIA and Amdal socialization.

The cooperative has a training plan in 2016 but there is a training plan fertilization which have not been implemented according to schedule (March 2016). It was raised as Nonconformities (NCR RSPO 00239).

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Compliance status : Non Compliance

NCR RSPO 00239 (Minor non-conformity) The cooperative has a training plan in 2016 but there is a training plan fertilization which have not been implemented according to schedule (March 2016)

Principle 5: Environmental responsibility and conse rvation of natural resources and biodiversity

Criteria 5.1 : Aspects of plantation and mill manag ement, including replanting, that have environ-mental impacts are identified, and plans to mitigat e the negative impacts and promote the positive ones are made, implemented and monitored, to demons trate continuous improvement

Findings : Documents EIA / AMDAL of KUD Jaya Bersama incorporated in the Environmental Impact Assessment in the form of Environmental Management and Monitoring Plan or Environmental Management Plan - Envi-ronmental Monitoring Plan (RKL-RPL) PT Aek Tarum, and this document have been documented in the office KUD Jaya Bersama

Last Review Environmental Aspect-Impact and also Risk Assesment that involved smallholder participa-tion was conducted on 2 February 2016

The monitoring report of RKL-RPL was performed twice a year as Laporan Monitoring Rencana Pengel-olaan Lingkungan – Rencana Pemantauan Lingkungan (RKL-RPL) (Monitoring Report of Environmental Management and Monitoring Program). The Report has been documented in office of KUD Jaya Bersama

Compliance status : Full Compliance

Criteria 5.2 : The status of rare, threatened or en dangered species and high conservation value habitats, if any, that exist in the plantation or t hat could be affected by plantation or mill manage -ment, shall be identified and their conservation ta ken into account in management plans and op-erations

Findings : Tekad Mandiri and Panca Sawit Makmur as partner of PT Aek Tarum is included in HCV assessment car-ried out in 2010 by a combination of independen consultan and internal staff which responsible for HCV consist of RSPO registered team leader (Mr Siswoyo) and 2 registered team members and 2 non regis-tered and supported by a GIS expert. HCV document is also already peer reiewed by accredited inde-pendent consultant (Mr. Kresno Santosa) on April 2014. The assessment has successfully recorded 44 plants species and 17 fauna with details mammals 4 species, birds 10 species and reptile 3 species and some RTE species. The list of flora and fauna is available in the cooperation unit office, and HCV staff from PT Aek Tarum conducted some training/socialization to farmers. Smallholder farmers are able to list and mention flora and fauna exist in their local areas including protected/RTE with local name. In addi-tion, a special clerk has been assigned for HCV and flora fauna management and monitoring. As an ob-servation, task and responsibility of HCV clerck should be expanded to guide and train the farmer mem-bers, and also create training program. HCV assessment document has been kept in the Cooperation office including the HCV management and monitorig recommendations. There are 4.43 ha HCV areas was identified in Tekad Mandiri and 1.29 Ha located in Panca Sawit Makmur in form of HCV 1.1, 1.3 and 4,.1 located at riparian zone of Dabuk Hitam river branch. Map oh HCV area is presented in Figure 10 and 11below:

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Figure 10: HCV area in Panca Sawit Makmur smallhol der

Figure 11: HCV area in Tekad Mandiri smallholder

Compliance status: Full Compliance

Criteria 5.3 : Waste is reduced, recycled, re-used and disposed off in an environmentally and so-cially responsible manner

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Findings : Smallholder groups has provided agrochemical waste management, a procedure No. Sa-Plasma-PP-LMB on hazardous and toxic waste handling and domestic waste controlling has been etablished on April 1st, 2016. The SOP covers:

• Hazardous and toxic waste storage in according with national regulation No. KEP-01/Bappedal/09/1995.

• Hazardous waste identicaton will be respnsibility of Cooperation Secretary • MSDS Providing on single agrochemical mateerial • Controlling chemical container waste, storage and recording

A warehouse has been constructed as well waste room with tidy and clean. Domestic waste was also dis-pose properlyon non organic and organic waste. The smallholder is doing organizing permit of process are conducting B3 waste storage organizing permit for storage of hazardous and toxic waste.

Stock and usage of pesticide and herbicide is still not recorded well, there is no found evidence handover residual herbicide used wholly returned to the warehouse and also stock the chemicals not yet recorded is well, so it can not be compared with the chemicals used. It was raised as Nonconformities (NCR RSPO 00241). Smallholder also prepares a plan to dispose hazardous waste to an authorized transporter and can make cooperation with Aek Tarum.

Compliance status : Non Compliance

Non-conformance: RSPO 00241 (Major non-conformity) Has not been found evidence handover residual herbicide used wholly returned to the warehouse and al-so stock the chemicals not yet recorded is well, so it can not be compared with the chemicals used.

Criteria 5.4 : Efficiency of energy use and use of renewable energy is maximized

Findings :

Smallholder understand about efficiency of energy and renewable energy, but the context is limited only on FFB transportion since they has no mill and other intensive station that use high energy. Generally, operational in smallholder follows the Enviromental Management Program established by PT Aek Tarum as guidance on energy efficiency. Manager of Panca Sawi Makmur has created guidance on energy source efficiency that covers water, fuel, and electricity. Howeever, as an observation smallholder man-ager of Tekad Mandiri shoul create their own guidance.

Compliance status : Full Compliance

Criteria 5.5 : Use of fire for waste disposal and f or preparing land for replanting is avoided except in specific situations, as identified in the ASEAN Guidelines or other regional best practice

Findings :

There is a SOP No. SA-Plasma-PP-DRR-01 on incident handling and emergency controlling. In the SOP describe handling on fire and land fire. SOPs set up a mechanism and steps when land fire occurred.

Emergency fire hazard controlling equipment is prepared in the warehouse such as extinguisher, hoe, jute, shovel, water pump and sandbox. Farmers have also been trained on emergent and fire hazard controlling on November 3rd, 2015 and attendant by all the farmers.

The smallholder has a zero burning policy that explicit stated in Coopeartion Policy signed by all small-holder manager and PT Aek Tarum on September 14th, 2015. The statement is: To prevent environment pollution and land clearing without fires (zero burning). This policy is followed by SOP on Land Prepara-tion/ Lan Clearing which refers to PT Aek Tarum SOP No. No P-SAG-KBN-PML-03. The SOP mentioned that land clearing must be carried out with controlling and zero burning, and also prohobition of HCV areas disturbance.

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Compliance status : Full Compliance

Criteria 5.6 : Plans to reduce pollution and emissi ons, including greenhouse gases, are devel-oped, implemented and monitored

Findings :

Smallholder Cooperation provided a Pollution Source Identification and Plan to Reduce Pollution Year 2016. This document contains type of activity, pollution type, impact, reduction mitigation plan, and PIC. Activity source identified is: 1) Crops activity such as harvesting, fertilizing and spraying, and 2). Office ac-tivity.

Plan to reduce pollution is : emission test of vehicle and generator, road watering, optimize transporta-tion , modification on direction of FFB transportation and FFB ponds, substitute fossil fuel with bio diesel, socialization on best agriculture practice, and generator usage efficiency.

Compliance status : Full Compliance

Principle 6: Responsible consideration of employees and of individuals and communities af-fected by growers and mills

Criteria 6.1 : Aspects of plantation and mill manag ement that have social impacts are identified in a participatory way and plans to mitigate the negat ive impacts and promote the positive ones are made, implemented and monitored, to demonstrate con tinuous improvement

Findings : Auditee has conducted a study to identify its social effects of plantation activities incorporated in the doc-ument o main estate namely Studies Document o Social Environment Assessment (SEI) which includes Forestry Faculty IPB, Belida Estate and POM Belida in 2012 by the Faculty of Forestry , IPB 2012. The Board and all members of Village Cooperative Unit participate in the drafting process of identification studies of social impact assessment. The methods used were structured interviews through question-naires which were distributed to the farmers, in-depth interviews and focus group discussions. The study showed no negative impact of the opening of oil palm estates. While the positive impacts include generat-ing incomes (previously only depend on rubber), job opportunities for the local population, an improve-ment in infrastructure, such as roads and housing. There were reports on the implementation of social governance in Village Cooperative Unit of Tekad Mandiri and Belian Makmur in 2015; It was done once a year.

Compliance status : Full Compliance

Criteria 6.2 : There are open and transparent metho ds for communication and consultation be-tween growers and/or millers, local communities and other affected or interested parties

Findings :

Communication and consultation with communities were recorded in the Farmer Log Book o Village Co-operative Unit of Tekad Mandiri and Belian Makmur on 2015 that contains elements of the date of the let-ter, letter number, name, address / institutions, subject, information / status, response or follow-up. For example, on December 21, 2015, Village Cooperative Unit of Tekad Mandiri attended Musrembang in the village.

There were decision letter No. 08 / KPKS-TM / III / 2016 on March 10, 2016, addressed to Village Coop-erative Unit of Tekad Mandiri; it was about communications officer, on behalf of Turiman. The main task is to inform every activity and the latest news to the members and communication with the stakeholders.

There were decision letter No. 181 / SKP / KUU-PSM / MESRA / IV-2016 on March 24, 2016, addressed to Village Cooperative Unit of Panca Sawit Makmur, it was about appointing of communications officer, on behalf of Dedi Rudianto. The main task is Receive all forms of communication, handle, and notes; provide feedback and directing the parties to communicate directly.

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Compliance status : Full Compliance

Criteria 6.3 : There is a mutually agreed and docum ented system for dealing with complaints and grievances, which is implemented and accepted by al l parties

Findings :

System to receive complaints mechanism was set out in the guidelines for communication, consultation and complaints. Stakeholders submit a complaint in writing to the chairman and the secretary of Village Cooperative Unit will receive, record and identify and clarification from stakeholders, direct response can be provided by Village Cooperative Unit but if necessary, conducted meeting first with members, the chairman of Village Cooperative Unit submit responses to stakeholders at least 14 days after the infor-mation is received. Communications officer noted until a response was received by the stakeholders.

It was available formats of complaints, handling and reporting include: the date, number of letters, the name, address, destination, the complaints / issues / aspirations, answer / handling, status was still being processed / finished, signature. For Example, Village Cooperative Unit of Panca Sawit Mandiri on January 15, 2016 on behalf of Suji, complained about mixed up in plot numbers; it was already resolved by con-sensus.

Compliance status : Full Compliance

Criteria 6.4 : Any negotiations concerning compensa tion for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through t heir own representative institutions

Findings :

The interview with board and member of KUD Tekad Mandiri and Panca Sawit Makmur Mandiri informs that the palm oil plantation area is not originated from traditional right. Palm oil area is private owned land based on legal private owned status (SHM) and SKT (land declaration letter). Community plantation area is ex-public transmigration and independent smallholder. The interview with board and member of Mandiri Association informs that the palm oil plantation is not derived from traditional right; therefore there is no land compensation.

The interview with the KUD Tekad Mandiri and Panca Sawit Makmur and member informs that there is no palm oil area is derived form traditional right. Therefore, the system of identification and compensation payment calculation is not necessary.

Compliance status : Full Compliance

Criteria 6.5 : Wage and conditions for employees an d for employees of contractors always meet at least legal or minimum industry standards and are s ufficient to meet basic needs of personnel and to provide some discretionary income

Findings :

The interview result with the board and member of KUD Tekad Mandiri and Panca Sawit Makmur Mandiri known that the palm oil upkeeing is conducted by the smallholder of land owner and some is outsourced. The wage of daily worker is IDR 100,000/day and the wage of harvester is IDR 120,000/day.

Compliance status : Full Compliance

Criteria 6.6: The employer respects the right of al l personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bar-gaining are restricted under law, the employer faci litates parallel means of independent and free association and bargaining for all such personnel

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Findings :

The interview with the member and board KUD Tekad Mandiri and Panca Sawit Makmur reveals that the non permanent daily worker is free to join worker union. KUD does not forbide the worker to join the un-ioin. Up to date, there is no non-permanent daily worker who joins or develops worker union.

Compliance status : Full Compliance

Criteria 6.7: Child labour is not used. Children ar e not exposed to hazardous working conditions. Work by children is acceptable on family farms, und er adult supervision, and when not interfering with education programmes

Findings : Interview with the board and member of KUD Tekad Mandiri and Panca Sawit Makmur informs that there is no underage worker (under 18 years old). Based on the profile list of the workers in December 2015, it was known that no worker under the age of 18 when he started working on smallholdings.

Compliance status : Full Compliance

Criteria 6.8 : The employer shall not engage in or support discrimination based on race, caste, na-tional origin, religion, disability, gender, sexual orientation, union membership, political affiliati on, or age

Findings :

Based on interviews with officials and members of Village Cooperative Unit of Tekad Mandiri and Panca Sawit Makmur, It was known that no discrimination between male and female workers in hiring, no dis-crimination regards to ethnicity, religion and race of each worker, a treat with no discrimination against workers and no foreign labor.

Compliance status : Full Compliance

Criteria 6.9 : A policy to prevent sexual harassmen t and all other forms of violence against women and to protect their reproductive rights is develop ed and applied

Findings :

It was available documents or appeal to members not to commit sexual harassment and acts of violence against women and respect for women's reproductive rights. It was written and attached to the wall in the office of Village Cooperative Unit and printed correctly, and then it was installed in smallholdings.

Based on interviews with officials and members of Village Cooperative Unit of Tekad Mandiri and Panca Sawit Makmur, it was noted that there was no violence against women and Village Cooperative Unit pro-vided reproductive rights for women workers.

Compliance status : Full Compliance

Criteria 6.10: Scheme managers deal fairly and tran sparently with smallholders and other local businesses.

Findings :

There was a Decree of the Chairman of Village Cooperative Unit of Tekad Mandiri and Panca Sawit Makmur, regard to policy to do business with other parties in a fair and open. Explained that the coopera-tion activities or the contract proposed will be delivered openly and fairly in the process, which was in ac-cordance with applicable regulations. Type of the contracted work was transport and trading of FFB and FFB sales purchase with community members who have truck.

It was available pricing document of FFB on April 2016 (Period II) established by Plantation Office of

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South Sumatra Province through Letter No. 525/303-VI.3 / BUN April 18, 2016. The price of FFB per kg of plant at age of 3rd year was IDR. 1,496.81, 10-20 year: IDR. 1,739.95 year, in its 25th year was IDR. 1,562.34.

FFB price is determined by a meeting attended by the parties; those were representatives of the Compa-ny, Cooperative Management and Plantation Office. Price of FFB that was used now and previously has been known by the farmer / committee of Village Cooperative Unit. Cooperatives are involved in setting the price of FFB.

FFB pricing mechanism was agreed by the parties in every two weeks. Smallholders FFB price referred to the price set by the Department of Plantation, South Sumatra Province that was issued twice in one month. Smallholders obtained FFB price information directly from the Plantation Office, South Sumatra province and POM PT Aek Tarum.

Compliance status : Full Compliance

Criteria 6.11 : Scheme manager contribute to local sustainable development wherever appropriate

Findings :

Village Cooperative Unit of Tekad Mandiri and Panca Sawit Makmur was participated in regional devel-opment, for Example tax payments, opening of new jobs, especially for the villagers who do not have a estate of palm and rubber, open access so the isolated location, the construction of mosques, helping to organize sports activities etc.

Compliance status : Full Compliance

Principle 7: Responsible development of new plantin gs

Criteria 7.1 : A comprehensive and participatory in dependent social and environmental impact as-sessment is conducted prior to establishing new pla ntings or operations, or expanding existing ones, and the results incorporated into planning, m anagement and operations

Findings : Documents EIA / AMDAL of KUD Jaya Bersama incorporated in the Environmental Impact Assessment in the form of Environmental Management and Monitoring Plan or Environmental Management Plan - Envi-ronmental Monitoring Plan (RKL-RPL) PT Aek Tarum, and this document have been documented in the office KUD Jaya Bersama

Last Review Environmental Aspect-Impact and also Risk Assesment that involved smallholder participa-tion was conducted on 2 February 2016

The monitoring report of RKL-RPL was performed twice a year as Laporan Monitoring Rencana Pengel-olaan Lingkungan – Rencana Pemantauan Lingkungan (RKL-RPL) (Monitoring Report of Environmental Management and Monitoring Program). The Report has been documented in office of KUD Jaya Bersama

Compliance status : Full Compliance

Criteria 7.2 : Soil surveys and topographic informa tion are used for site planning in the establish-ment of new plantings, and the results are incorpor ated into plans and operations

Findings :

During audit, new planting activity not available in smallholder. The smallholder has topography / slope map in existing smallholder areas. Based on draft environmental document that peat soil not available in smallholder areas.

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Compliance status : Full Compliance

Criteria 7.3 : New plantings since November 2005 (w hich was the date of adoption of these criteria by the RSPO membership), have not replaced primary forest or any area containing one or more High Conservation Values

Findings : Smallholder land is old plantation planted around 1990 and 1991, based on HCV documnts assessment that interpret satellite imager before 2005 there was no primary forest .

Compliance status : Full Compliance

Criteria 7.4 : Extensive planting on steep terrain, and/or on marg inal and fragile soils, is avoided

Findings :

During audit, new planting activity not available in smallholder. Existing land in smallholder, based on slope map is flat to undulating so that terrain available.

Compliance status : Full Compliance

Criteria 7.5 : No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a documented s ystem that enables indigenous peoples, lo-cal communities and other stakeholders to express t heir views through their own representative institutions

Findings :

Based on interviews with officials and members of Village Cooperative Unit of Tekad Mandiri and Panca Sawit Makmur and area statement in February 2016 that was no new planting of oil palm plantations in the area of smallholders.

Interview with the board and member of Smallholder shows that the plantation area is not derived from traditional right. Palm Oil Plantation area is private owned land based on private land use title (SHM) and Land Status Statement (SKT) issued by Village Government.

Compliance status : Full Compliance

Criteria 7.6 : Local people are compensated for any agreed land ac quisitions and relinquishment of rights, subject to their free, prior and informe d consent and negotiated agreements

Findings :

Interview with board and member of KUD Tekad Mandiri and Panca Sawit Makmur explains that palm oil area is not derived from traditional right. Plantation area is private owned land based on private land use title (SHM) and Land Status Statement (SKT) issued by Village Government.

Interview with board and member of Independent Smallholder Association explains that palm oil area is not derived from traditional right. Plantation area is private owned land based on private land use title (SHM) and Land Status Statement (SKT) issued by Village Government.

Compliance status : Full Compliance

Criteria 7.7 : Use of fire in the preparation of new plantings is avoided other than in specific situa-tions, as identified in the ASEAN guidelines or oth er regional best practice

Findings :

Since both estates are an old plantation which is planted before 2010, than this criterion is Not Applicable.

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Compliance status : Not Applicable

Principle 8: Commitment to continuous improvement i n key areas of activity

Criteria 8.1 : Scheme managers regularly monitor and review their activities and develop and im-plement action plans that allow demonstrable contin uous improvement in key operations

Findings:

There is a mechanism of internal audit carried out by a team formed originating from the Head office, the plasma core. All activities in the oil plam management audit, management system adapted to quality, en-vironment, K3, RSPO and other quality management systems.

Smallholder cooperation of Panca Sawit Makmur and Tekad Mandir has demontrated their commitment to establish a sustainabiity system acknowledge by RSPO. Some SOP and best practises on HCV/water source has been implemented in the field. A waste warehouser aslo been constructed very well and tidy. Compliance status : Full Compliance

• RSPO SCCS

E.1. Definition

Findings: Belida Palm Oil Mill is one of mill under Sampoerna Group. Located in Sumber Baru village, Mesuji Raya district, OKI Regency, South Sumatera. Belida palm oil mill will implement the RSPO SCCS MB. This model will allowed the mill mix the certified and uncertified FFB, CPK and PK with control by mass balance record and will evaluate in every three months. In 2015, Belida Palm Oil Mil has received FFB is about 52,253.530 tonne from owned estate (IPBS and Belida Estate), from sister company (Mesuji and Surya Adi estate) is about 6,026.380 tonne, from compa-ny smallholder is about 179,427.090 tonne, and 15,122.653 tonne from out grower. While in 2016 (until March 2016), Belida Palm Oil Mill has received the FFB from owned estate is about 8,805.250 tonne, then from sister company (Mesuji Estate) is about 6.960 tonne. FFB received from smallholders is about 16,737.2500 tonne and is about 357.036 received from out grower. Based on Mass Balance report started from October 2015 until March 2016, Belida Palm Oil Mill has pro-duced the certified palm oil product is about 4,302.443 tonne of CPO and 1,028.145 tonne PK in 2015 (October – December periode). Then in 2016 (January – March) certified CPO and PK produced is about 1,906.336 tonne CPO and 385.945 tonne PK. Then, for uncertified product (CPO and PK) with same time periode (October – December 2015) is about 12,806.921 tonne of CPO and 3,926.121 tonne of PK, and in 2016 (January – March) is about 3,793.621 tonne of CPO and 896.456 tone of PK. Latest stock certified product of CPO per three month evaluated is 917.107 tonne of CPO and 385.945 tonne on PK (from January 2016 until March 2016). The certified palm oil product during the recertification audit is still positive. Compliance status : Full Compliance

E.2. Explanation

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Findings : Estimated of tonnage CPO and PK products has been recorded in to the public summary of the P&C cer-tification report.

Belida Palm Oil Mill registered in RSPO IT Platform (e-Trace) with the RSPO e-Trace member ID RSPO_ PO1000000284. Belida Palm Oil Mill also registered in RSPO Green Palm with the RSPO Green Palm member ID P0072 Compliance status : Full Compliance

E.3. Documented procedures

Findings: Belida palm oil mill has established the procedure for RSPO SCCS MB implementation, such as: 1. P-SAG-PKS-PRS-01 Rev01 dated on August 1, 2012 about recording and weighing and FFB

incoming. 2. WI-SAG-PKS-PRS-0101 Rev01 dated on August 1, 2012 about recording of tranposrtation unit for

FFB, CPO and PK loading. 3. P-SAG-PKS-PRS-14 Rev0 dated on April 1, 2016 about traceability and mass balance. This

procedure has explained about identification of certified FFB, traceability process for FFB certified, identification for certified product (CPO dan PK), handling incoming FFB certified and unceritified from truck, weighing, loading ramp until storage tank and transportation process, and others. Handling incoming FFB was set in that procedure i.e weighing operator will ensure the FFB document (FM-SAG-KBN-PRD-020005) for sustainable and unsustainable FFB, while the sustainable FFB will record in mass balance record and will reported. This procedure also has set the CPO and PK sustainable and unsustainable (RSPO SCCS MB), such as in sales contract and document, delivery order and others related document should state the CPO and/or PK Sustainable certified SCCS MB. And all document related the RSPO SCCS MB will keep in 10 years.

The company has letter of decree of Managing Director No. 005/AT/MD/IV/2016 dated April 15, 2016 about appointed of IMS RSPO, ISPO, and ISCC team. The personal in charge to implement of SCCS Mass Balance is quality control assistant. Belida Mill has been conducted RSPO SCCS Mass Balance training for person in charge to implement SCCS Mass Balance. Evidence of training has been conducted such as training certificate. Training has been conducted on 11 until 15 September 2012. Compliance status : Full Compliance

E.4. Purchasing and good in

Findings : Belida Palm Oil Mill has separate between certified FFB and non-certified FFB; also include the certified and un-certified palm oil product (CPO and PK) through the mass balance record control. Especially for FFB certified and un-certified will marked use stamp in form slip FFB in weighbridge. And for FFB from outside that estate not marked this is mean the FFB is not certified. Amount of FFB and palm oil product certified and un-certified was explained in principle and criteria 1 above. Belida mill has procedure and mechanism to inform the over production into the CB by document number P-SAG-PKS-PRS-14 Rev01 date issue April 1, 2016, mentioned “if over production projected, the marketing unit will inform to the CB related that over production”, Compliance status : Full Compliance

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E.5. Record keeping

Findings : Belida mill has record of mass balance template, with mass balance template was consist of certified and uncertified FFB incoming information, FFB production, CPO and PK production, OER and KER, delivery information, and stock condition in every three months.

Belida mill also has established the procedure about three months evaluation, when the mill will carry out sell activity when the stock was positive, in document number P-SAG-PKS-PRS-14 Rev01 dated on October 1, 2015.

During the recertification audit, palm oil still consistent to record and control the mass balance stock. Stock in March 2016, certified palm oil product for CPO is about 917.107 tonne and PK is about 385.945 tonne Compliance status: Full Compliance

3.2 Status of Previously Identified Non-conformitie s

During 4th surveillance audit, a total of 11 nonconformances were identified for RSPO P&C. These consisted of 5 major non-conformities and 6 minor non-conformities. Where as, total of non-conformance of RSPO SCCS is 0 non-conformities.

The following is a description of the evidence of action taken to close the non-conformities raised during the previous assessment, as well as auditor’s conclusions on the status of the non-conformities.

• RSPO P&C

Criterion 4.1. (Minor indicator 3) Records of monitoring and any actions taken shall b e main-tained and available, as appropriate.

Non-conformance 2015-01 of 11 (Minor non-conformit y)

• No conclusion of calibration results based on type of sprayer and nozel

• Calibration only conducted once a month, while the WI-SAG-KBN-PML-0306 Kalibrasi alat semprot knapsack dan CDA indicates twice a month.

Verification result :

• PT Aek Tarum has been identified the type and characteristic of the spraying nozzle and poured in-to “Identifikasi Penggunaan Alat Aplikasi Pestisida (The identification of use pesticide application equipment) ”

• Calibration of spraying equipment every 2 weeks consistently done Auditor Conclusions : Closed Principle 4.4. (Major indicator 2) Protection of wa ter courses and wetlands, including maintaining and restoring appropriate riparian and other buffer zon es (refer to national best practice and national guidelines) shall be demonstrated.

Non-conformance 2015-02 of 11 (Major non-conformit y)

• There were no delineation marks and no sign boards to prohibit the use of agrochemical along ripar-

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ian area in Division I Block 20 that has been identified as HCV area. • It was found in this HCV area in Division I Block 20 there was evidence of agrochemical application

such as: dolomite fertilizer and the rest of weeds that had been eradicated by herbisides. Verification result : The company has submitted evidence: • Photographs of HCV sign board and delineation marks along riparian buffer zone. • Attendant list of HCV socialization for agrochemical applicator on May 30, 2015 The auditor team has checked and verified the evidence of corrective action and approved so the NC can be closed

Auditor Conclusions : Closed

Principle 4.5. (Minor indicator 2) Training of thos e involved in IPM implementation shall be demon-strated.

Non-conformance 2015-03 of 11 (Minor non-conformit y) There was no evidence that the new pest census worker (Mr. Nardo) had been trained properly, during inter-view he could not explain the species and symptons of caterpillar attack comprehensively.

Verification result : The company has submitted evidence:

• Attendant list of pest control and census training on May 26, 2015 by Mrs. Lilis Suryani, the Mesuji Estate Manager, attended by14 workers including Mr. Oksinardo Ginatama (Nardo).

The auditor team has checked and verified the evidence of corrective action and approved so the NC can be closed

Auditor Conclusions : Closed Principle 4.6 (Major indicator 5) Pesticides shall only be handled, used or applied by persons who have completed the necessary training and shall alw ays be applied in accordance with the product label. Appropriate safety and application equipment shall be provided and used. All precautions at-tached to the products shall be properly observed, applied, and understood by workers (see Criterion 4.7). NCR No. 2015-04 of 11 (Major non-conformity)

Mr. Simanjuntak the foreman of sprayer and sprayers Umi, Sriyatun, Fitriani, Mujiati, Luluk had never been trained on restricted pesticides that not comply with the Decree of Agriculture Ministry No. 434.1/Kpts/TP.270/2001.

Verification result : According to objective evidence and during field visit, PT Aek Tarum always consistent that workers who apply or handle pesticide only by person who have completed the necessary training (certified) especially for restricted pesticide Auditor Conclusions: Closed

Criterion 4.6. (Minor indicator 7) Application of pesticides shall be by proven method s that minimise risk and impacts.

NCR No. 2015-05 of 11 (Minor non-conformity)

Warningsign for pesticides application area was not installed for 2 x 24 hours after pesticides application as stated in WI-SAG-KBN-PML-0307:

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• Division III Block 25 on 18.05.2015 there was herbicides application, but on 19.05.2015 there was harvesting activity.

• Division III Block 16 on 19.05.2015 herbicidas application, but on 20.05.2015 there was soil sam-pling activity.

• Division II Block 21 on 20.05.2015 herbicides application, but on 21.05.2015 pada area there were harvesting and caterpillar cencus activities.

Verification result : During field observation to Division 3 Belida Estate, Corrective Action has been verified by auditor that Warn-ing sign for pesticides application area was installed for 2 x 24 hours after pesticides application and when interviewed all workers involved in chemicsl handling or application understanding of the hazards and risk re-lated chemical used

Auditor Conclusions : Closed Criterion 4.6. (Major indicator 11) Specific annual medical surveillance for pesticide operators, and documented action to treat related health condi tions, shall be demonstrated. Non-conformance 2015-06 of 11 (Major non-conformit y) Medical examination for workers had been done in September 2014, only cover height, weight, Hb level, blood pressure (mmHg), urine (pH, protein, glucose), however the specific medical examination such as cholinesterase was not conducted as required by the Decree of The Minister of Manpower and Transmigration RI No.3/1986. Verification result :

According to Report of Annual Medical surveillance on August 2015 in Belida Mill and Estate, Cholinesterase test was conducted. The person who took Cholinesterase test in Mill was 78 workers, while in Estate was 17 workers Auditor Conclusions: Closed Criterion 5.2. (Major indicator 2) Where rare, thre atened or endangered (RTE) species, or HCVs, are present or are affected by plantation or mill opera tions, appropriate measures that are expected to maintain and/or enhance them shall be implemented t hrough a management plan. Non-conformance 2015-07 of 11 (Major non-conformit y) Annual HCV management program 2014 and 2015 was not available on site. Verification result : The company has submitted evidence namely HCV Management and Monitoring Program from 2014 – 2020. The auditor team has checked and verified the evidence of corrective action and approved so the NC can be closed Auditor Conclusions : Closed Criterion 5.2. (Minor indicator 3) There shall be a programme to regularly educate the workforce about the status of these RTE species, and appropriate di sciplinary measures shall be instigated in accord-ance with company rules and national law if any ind ividual working for the company is found to cap-ture, harm, collect or kill these species. Non-conformance 2015-08 of 11 (Major non-conformit y)

• Mr. Wagino, the foreman I in Division II Mesuji who has been assigned as HCV foreman had never beed trained for HCV aspects.

• No job description of HCV foremen that clearly explained the follow up action if any violation occurs in HCV area.

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Verification result : The company has submitted evidences:

• Assignment letter to Mr. Ayoeb as new HCV foreman in Mesuji replacing Mr. Wagino. • Attendant list of HCV training for foremen that appointed as HCV foremen on May 29, 2015. • New Job description for HCV foremen had been established.

The auditor team has checked and verified the evidence of corrective action and approved so the NC can be blosed. Auditor Conclusions : Closed Criterion 5.2. (Major indicator 4) Where a manageme nt plan has been created there shall be ongoing monitoring:

• The status of HCV and RTE species that are affected by plantation or mill operations shall be documented and reported

• Outcomes of monitoring shall be fed back into the m anagement plan. Non-conformance 2015-09 of 11 (Major non-conformit y)

• Weekly HCV inspection report by foremen did not explain the detail location of monitoring area, HCV type and monitoring parameter according HCV type

• HCV monitoring report only conducted annually, this was not complying with Prosedure P-SAG-KBN-NKT-02 Pengelolaan dan Pemantauan KBKT that needs three monthly reports.

Verification result : The company has submitted evidences:

• Revised form for HCV Monitoring with detail location of monitoring area. • Revised HCV Management & Monitoring Procedure that evaluation of HCV program and RTE status

will be conducted 6 monthly. The auditor team has checked and verified the evidence of corrective action and approved so the NC can be closed Auditor Conclusions : Closed

Criterion 5.3. (Minor indicator 3) A waste manageme nt and disposal plan to avoid or reduce pollution shall be documented and implemented.

Non-conformance 2015-10 of 11 (Minor non-conformit y) The hazardous and toxic wastes as the Government Regulation No. 18/199 and the Ogan Komering Iir Re-gent Permit for the Hazardous and Toxic Waste Storage No. 660.I/14/KEP/B.LH/2012 shall be kept in the waste storage not more than 90 days. However the hazardous and toxic wastes kept in the Belida Mill and Estate’s waste storage was kept for more than 90 days as the last disposal was in October 16, December 11, and December 31, 2014 and no more till now . Verification result : A warehouse clerk records the waste in hazardous waste balance which containt data about incoming and outcoming waste completed with note and transportation manifestation and minutes of the hazardous waste handover. For example on December 28th, 2015 there is 550 kgs contaminated drums from Belida mill col-lected and transported by PT Dame Alam Sejahtera with manifest no. 0001713, and completed with minutes of waste disposal signed by both party as shown in minutes No. 558/PKS BL/XII/2015 dated on December 28th, 2015. Auditor Conclusions : Closed

Partial Certification

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Non-conformance 2015-11 of 11 (Minor non-conformit y) There are isolated lapses in implementation of a time-bound plan for PT Mutiara Bunda Jaya and PT Sungai Rangit mill, plantations, and smallholders which are delayed for certification. In time-bond for certification of 2013 these units were planned to be audited in 2014 but so far they are not audited yet and are to be planned for certification in 2016. The cause of the delay is that there was a change of management struc-ture. Verification result : The company has been revised the time bound plan for PT Mutiara Bunda Jaya dan PT Sungai Rangit Mill where both of the company will conduct certification on 2016 Auditor Conclusions : Closed

3.3 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions During recertification audit, a total of 13 nonconformances were identified against RSPO P&C and RSPO Smallholder these consisted of 7 major non-conformities and 6 minor non-conformities. For the major non-conformances, the company has taken the necessary corrective action to close these non-conformances within 60 days of completion of the assessment, and this was verified by the audit team through documents submitted by the company. For the minor non-conformances, the company has taken corrective action against these as well, and for those which could not be verified as closed through document checks, the closure of these minor non-conformities will be assessed during the next surveillance audit. A summary of all identified non-conformances, corrective actions taken and auditor conclusions is as below:

• RSPO P&C

Criterion 2.1.1 Evidence of compliance with relevan t legal requirements shall be available.

Non-conformance: RSPO 00230 (Major non-conformity) Some of the the provisions of laws and regulations that has not fulfill by the company such as:

• Based on the mill visit on Belida Mill was found one engine room operator on behalf of Lukman which works in the risk of noise has not been conducted periodic health examinations as required Permenakertrans No. Per.02 / MEN / 1980 About the Health Workforce in the Implementation of Work Safety

• Can not show sufficient evidence that the Activity Report of Committee of Occupational Safety and Health (P2K3) for 2 (two) last quarter of 2015 and Quarter 1 (first) 2016 has been reported to the Minister through the Office of the Ministry of Manpower as required Permenaker No. PER.04 / MEN / 1987 About Committee of Occupational Health and Safety and Procedure for Appointment of Expert Safety

• Use of groundwater is not in accordance with the permit, which limit of maximum usage of is 100 liters / minute and also there is no evidence that there is a monthly reporting to the relevant agen-cies (the Department of Mines). Reference:

a. Decree of Head Mining and Energy agency Ogan Komering Ilir District No. 540.135.A/Kep/DPE/2013

b. Decree of Head Mining and Energy agency Ogan Komering Ilir District No. No. 540.33.A/Kep/DPE/2013

Correction :

• Conducting periodic health examinations on behalf Lukman to Hiperkes UPTD Occupational Safety and Health

• Make a report of the P2K3 meeting and reported to the Manpower and Transmigrasion Agency • Controlling the use of water flow to each home to 200 liters / day, so it does not exceed the water

consumption of over 100 liters / minute and make calculations of water use in accordance hours used.

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Corrective Action :

• Ensure all employees has been conducted checkup periodically • Make a schedule for reporting monitoring program of P2K3 to Manpower and Transmigrasion

agency • Reported the daily use of water that flowed into the housing and water machine operational hours.

Auditor Conclusions: Closed

Date of closure: May 10, 2016

Verification result : The Company has submitted evidence of improvement such as:

1. Report of medical checkup result on behalf Lukmanul Hakim from Hiperkes South Sumatera Province with number 070/048/UPTD/BHP/2016 dated on April 29, 2016. Based on the results of that hearing were concerned in normal condition

2. The company has sent P2K3 activity report to Manpower and Transmigrasion agency on May 12, 2016 with letter number 025/AT/HRS/V/2016 and evidence of receipt that has been sign by Man-power and Transmigrasion agency on May 12, 2016

3. Memorandum from IPBS Estate Manager to all staff and employee of IPBS Estate with letter number 794/BL/V/2016 dated on May 30, 2016 aboutefficiency of water usage.

Criterion 2.2.2 Legal boundaries shall be clearly d emarcated and visibly maintained.

Non-conformance: RSPO 00232 (Minor non-conformity) Companies not yet have an official map of HGU pillars stone that can show the location of the concession pillars stone in the field. For example: during field visits in Block 28 B (IPBS), for pillars stone number 12 can not be found in the field and pillars stone in Belida HGU not yet maintenance. Correction :

• Conducting monitoring of existence HGU pillars stones in accordance with the HGU map. • Completing the less of HGU pillars stone / lost / damaged in the field • Checking that all the pillars stone of the concession has been installed / completed in accordance

with the HGU map • Conducting cleanup of weeds maintenance around the HGU pillars stone

Corrective Action : Conduct monitoring HGU pillars stone regularly in accordance with the planned schedule of monitoring pillars stone. Auditor Conclusions: Closed

Date of closure: May 15, 2016 Auditor Conclusions: Corrective action plan accepte d. Effectiveness of implementation to be veri-fied during next audit

Criterion 4.4.1 An implemented water management pla n shall be in place.

Non-conformance: RSPO 00234 (Minor non-conformity) There is no evidence that the groundwater quality testing is done where the groundwater used by the em-ployee is not contaminated with dangerous substances Correction : Sending water samples in accordance with the standards of packaging samples and conduct water quali-ty testing

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Corrective Action : Make a schedule for water testing monitoring every year Auditor Conclusions: Closed

Date of closure: May 10, 2016

Auditor Conclusions: Corrective action plan accepte d. Effectiveness of implementation to be veri-fied during next audit Criterion 4.7.2 All operations where health and saf ety is an issue shall be risk assessed, and pro-cedures and actions shall be documented and impleme nted to address the identified issues. All precautions a ttached to products shall be properly observed and a pplied to the workers. Non-conformance: RSPO 00236 (Major non-conformity) Risk assessment and environmental not cover some of the operational activities at the Mill and the Estate

• Activities transfer / filling POME to the tank truck and transport / transporting POME to the place of destination

• Harvester activities that bring tool of harvesting by used motorbike at the time of going to harvest-ing location,switch of location or back to home

• Use of Gasoline (petrol) when the pest control of fire worms with fogging methods

Correction : Entering to HIRAC and associated environmental impacts related transfer / filling POME activity, bringing harvesting tool activity, and the fogging mthods Corrective Action : Ensure all work in the unit are identified HIRAC and its environmental impacts Auditor Conclusions: Closed

Date of closure: May 10, 2016

Verification result : The company has submitted evidence of improvement namely revision of HIRAC for estate and mill. The revision of HIRAC was submitted activities such as transfer / filling POME to the tank truck and transport / transporting POME to the place of destination, harvester activities that bring tool of harvesting by used motorbike at the time of going to harvesting location,switch of location or back to home and use of Gaso-line (petrol) when the pest control of fire worms with fogging methods Criterion 4.7.3 All workers involved in the operati on shall be adequately trained in safe working practices (see Criterion 4.8). Adequate and appropr iate protective equipment shall be available to all workers at the place of work to cover all poten tially hazardous operations, such as pesticide application, machine operations, and land preparati on, harvesting and, if it is used, burning. Non-conformance: RSPO 00237 (Major non-conformity) During a visit to the field found almost all harvester in IPBS Estate does not use protective glasses, and it has been going on more than 8 (eight) months Correction : Submitted evidence of PR (purchase request) and a follow-up to the management to the availability of PPE namely sunglasses Corrective Action : Monitoring the use of goods and extra for stocks of goods warehouse 10% of the amount of goods exist-ing. Auditor Conclusions: Closed

Date of closure: May 15, 2016

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Verification result : The company has submitted evidence of improvement namely purchase request No.PR/0416/EPB/0004 dated March 31, 2016 for safety glasses as much as 42 pieces, purchase request No.PR/0416/EPB/0005 dated March 31, 2016 for safety helmet as much as 42 pieces and purchase request No.PR/0416/EPB/0006 dated March 31, 2016 for gloves as much as 42 pieces. Criterion 4.7.4 The responsible person/persons shal l be identified. There shall be records of regu-lar meetings between the responsible person/s and w orkers. Concerns of all parties about health, safety and welfare shall be discussed at these meet ings, and any issues raised shall be recorded. Non-conformance: RSPO 00238 (Major non-conformity) The last meeting on 5 April 2016 made by the responsible person associated OSH in this case is the P2K3, not cover issues related to occupational accidents, while based on the accident report for January - March 2016 identified the total of workplace accidents that occur in Belida Estate and IPBS estate is 11 accidents Correction : Conducting P2K3 meeting with regularly and make the result of P2K3 meeting to discuss workplace acci-dent and the others Corrective Action : Conduct P2K3 meeting regularly and by schedule Auditor Conclusions: Closed

Date of closure: May 10, 2016

Verification result : The company has submitted evidence of improvement namely minutes of meeting for Belida estate and IPBS estate has has been conduct on April 30, 2016 at meeting room. Meeting of P2K3 attending 14 em-ployees. The material of P2K3 meeting such as statistic of accident on Belida estate, PPE usage on loca-tion, socialization of dangerous and impact and also preventive action.

Criterion 5.2.3 There shall be a programme to regul arly educate the workforce about the status of these RTE species, and appropriate disciplinary mea sures shall be instigated in accordance with company rules and national law if any individual wo rking for the company is found to capture, harm, collect or kill these species. Non-conformance: RSPO 00240 (Minor non-conformity) There is no company policy on the protection of endangered species including the case of of hunting and the keeping of wildlife Correction : Creating a policy such as memorandum of wildlife protection Corrective Action : Running the contents of the policy memorandum is protected protection of wildlife Auditor Conclusions: Closed

Date of closure: May 4, 2016 Auditor Conclusions: Corrective action plan accepte d. Effectiveness of implementation to be veri-fied during next audit

Criterion 5.3.2 All chemicals and their containers shall be disposed of responsibly.

Non-conformance: RSPO 00241 (Major non-conformity) There are two users of hazardous materials and toxic wastes that have agreements with PT Aek Tarum

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namely Lut Putra Solder and Triguna Pratama Abadi had expired license. Lut Putra Solder with license No. 30 in 2011 has been expired on February 20, 2016 and Triguna Pratama Abadi, with the permission of the Decree No. 238 of 2010 has long been expired. Correction : Request permission has already been renewed / valid to PT. Lut Putra Solder and Triguna Pratama Abadi

Corrective Action : Ensuring the transporter license of users when transporting is still valid. Auditor Conclusions: Closed

Date of closure: May 10, 2016

Verification result : The company has submitted evidence of improvement such as:

1. Decree of Environment and Forestry Minister No.SK.415/Menlhk-Setjen/2015 dated on October 5, 2015 about permission management of hazardous wastes and toxic for utilization activities of hazardous and toxic waste. This permit valid until September 28, 2020.

2. Progress of obtaining the license PT Lut Putra Solder such as technical meeting invitation from Environment and Forestry Minister No.UN-53D/VPLB3-1/2016 dated January 21, 2016 and fol-low-up of field verification result with letter number S.1421/VPLB3-1/2016 dated February 24, 2016.

Criterion 5.3.3 A waste management and disposal pla n to avoid or reduce pollution shall be docu-mented and implemented.

Non-conformance: RSPO 00242 (Minor non-conformity)

3. waste management in housing estates is not accordance with the procedures, there is no separa-tion of organic and non-organic, and there is no socialization in the estate

4. Waste management in the final disposal in the Belida estate has not been good where the drain holes filled with water and causing overflow of waste

Correction : • Socialization on separation of organic and anorganic waste. • Creating dumpster into two parts, organic and anorganic • Creating landfill into two parts, organic and anorganic.

Corrective Action :

• Creating a program the transport of organic and anorganic waste at other times its transportation (not simultaneously).

• Monitor the condition of a landfill so that the waste does not fill with water and overflow.

Auditor Conclusions: Closed

Date of closure: May 10, 2016 Auditor Conclusions: Corrective action plan accepte d. Effectiveness of implementation to be veri-fied during next audit

• RSPO Smallholder

Criterion 2.1.1 Evidence of compliance with essenti al regulations relevant and related to oil palm cultivation.

Non-conformance: RSPO 00230 (Major non-conformity) Cooperative has not been fulfilling the laws and regulations among others:

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• Can not shown evidence of legalisir Business License (SIUP) every year • Can not shown evidence of re-registration Bussiness Location Permit Letter (SITU) every year

and evidence of the cooperative business activity report each semester to the Licensing and In-vestment Agency

• Can not shown re-registration of nuisance permit every year as stated in the provisions of the third (3) on the license.

Correction :

• The cooperative will administer the Business License (SIUP) • The cooperative will re-registration Bussiness Location Permit Letter (SITU) and reporting evi-

dence of of cooperative business • The cooperative will administer the re-registration of nuisance permit

Corrective Action :

• Make a list of the licensing fulfillment and validity

Auditor Conclusions: Closed

Date of closure: May 10, 2016

Verification result : The Company has submitted evidence of improvement such as Business License (SIUP), Bussiness Lo-cation Permit Letter (SITU) and nuisance permit that has been re-registration every year for each coop-erative (Tekad Mandiri, Panca Sawit Makmur and Jaya Bersama)

Criterion 2.2.1 Smallholders are able to show legal ownership of the land or land-use rights

Non-conformance: RSPO 00231 (Major non-conformity) Some of legal non conformity in cooperative such as:

1. Legality of cooperative members is still not available in completely in the cooperative office. For example: Koperasi Jaya Bersama member not yet have a legal land as much as 20 SHM

2. The area of statement is not in accordance with the area listed in SHM Correction :

• Collecting all the certificates for farmers who are outside the domicile of plasma and conducting administer of there is a lost cerfticiate and coordinate with the legal Sampoerna Agro.

• Customizing the total area statements in accordance with the extent of the certificate

Corrective Action : • Collecting all the copies of the certificates and submit the list of certificate to companies and each

cooperative • Documenting and updating list of available certificates in each cooperative

Auditor Conclusions: Closed

Date of closure: May 15, 2016

Verification result : The Company has submitted evidence of improvement such as:

1. Summary of total area in accordance with land certificate (SHM) for each member of cooperative 2. Hectar statement for each cooperative in accordance with land certificate (SHM)

Criterion 4.1.1 A documented procedure or manual of Good Agriculture Practices (GAP) in key ac-tivities (use of superior seeds, fertilizer applica tion, IPM techniques and harvesting) is available.

Non-conformance: RSPO 00233 (Major non-conformity) Cooperatives Jaya Bersama has Pest and Disease Control Procedure (SA-Plasma-PP-KS-02 effective date of October 1, 2015). In the procedure stated that the cooperatives are required to conduct a census

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of owls every three months but the cooperative not yet conducted a census of owl since the procedure applied Correction : Conduct a census of Disease Control in accordance with the procedure Corrective Action : Running census Disease Control in accordance with the procedure

Auditor Conclusions : Closed

Date of closure: May 10, 2016

Verification result : The company has submitted evidence of improvement namely census recapitulation of Tyto alba. The company has been conduct census Tyto alba on April 2016 for Jaya Bersama and Tekad Mandiri cooper-ative. Based on the record can be seen that Tekad Mandiri cooperative has 10 cages with total of owl is 7 and Jaya Bersama cooperative has 10 cages with total of owl is 11

Criterion 4.4.2 Records of fertiliser and pesticide s application

Non-conformance: RSPO 00235 (Minor non-conformity) There is no documented evidence of fertilization and spraying in the field where there is only proof of de-livery evidence from cooperative to the group. (Cooperative Tekad Mandiri and Panca Sawit Makmur) Correction : Make the format proof of delivery and fertilizer application in all groups Corrective Action : Fill in the form and proof of delivery and fertilizer application in all groups Auditor Conclusions: Closed

Date of closure: May 4, 2016 Auditor Conclusions: Corrective action plan accepte d. Effectiveness of implementation to be veri-fied during next audit

Criterion 4.8.2 Records of implementation of traini ng

Non-conformance: RSPO 00239 (Minor non-conformity) The cooperative has a training plan in 2016 but there is a training plan fertilization which have not been implemented according to schedule (March 2016) Correction : To coordinate again to the trainer to provide training and conduct training fertilization in May 2016. Corrective Action : Conduct training in accordance with the planned schedule Auditor Conclusions: Closed

Date of closure: May 4, 2016 Auditor Conclusions: Corrective action plan accepte d. Effectiveness of implementation to be veri-fied during next audit

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Criterion 5.3.2 Smallholders can explain measures t o dispose hazardous chemicals and their con-tainers in accordance to instruction labels as stat ed by the manufacturer.

Non-conformance: RSPO 00241 (Major non-conformity) Has not been found evidence handover residual herbicide used wholly returned to the warehouse and al-so stock the chemicals not yet recorded is well, so it can not be compared with the chemicals used. Correction : Creating balance of hazardous and toxic wastes and evidence of delivery to a clerk of temporary storage warehouse of hazardous and toxic waste.

Corrective Action : Monitor the implementation filling the form / minutes of return back for pesticides containers that has been issued. Auditor Conclusions: Closed

Date of closure: May 10, 2016

Verification result : The company has submitted evidence of improvement such as data of herbicide stock and balance of hazardous and toxic waste for each cooperative (Tekad Mandiri, Jaya Bersama and Panca Sawit Makmur)

• RSPO SCCS

In this recertification audit results that there is no non-conformance of RSPO SCCS

3.4 3.4 3.4 3.4 Noteworthy Positive Components

There is no new positive component by stakeholder’s recertification audit

3. 5 Issues Raised by Stakeholders and Findings Per taining to Issues A) Issues Raised during Stakeholder Consultation Me eting

No. Issues Raised Management Response Audit Verification

1 • The boundry with Suriadi village with a nucleus remeasured

• Concern to community is less where the roads which passed in the Suriadi village to be repaired

• Surya Adi estate has land title that has been approved by National Land Agency

• Committee for main road development block C makes proposal on 9 February 2015 and submitted to Mesuji es-tate on 12 March 2015. CSR team along with estate team on 30 April 2015 conducted field verification along with verification of Nurul Fa-lah mosque develop-ment but can not make

Company explaination is accepted, will be verified on the next audit.

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result of verification and filling the form to follow up for main road devel-opment because from discussion with team from village and com-mitte, needs for all par-ties that use the road like other company, co-operative, and neigh-bour village to meet and discuss plans for their respective contributions. Point of follow up from the meeting on 30 April 2016 that the commite of road development will invite the parties to a meeting in the Mesuji district. But until now there is no invitation or further information from the committee of road development of Surya Adi village

2 • Roads as long as ± 2 KM which passes residential and market need repairs

• There is no physically realization of CSR

• Part of estate and CSR has been conduct road watering regularly dur-ing the dry season.

• CSR has been con-ducted any activity eve-ry year in the Kemang Indah village such as in-frastructure, health, ed-ucation and local socie-ty. The head of the vil-lage who presently served is newly ap-pointed official at the end of 2015 so that the possibility do not know the CSR programs that have been realized. Some of programs that has been realize such as sponsorship for Sa-fari Ramdhan for Head District of Ogan Komer-ing Ilir, village main road repairs, suplementary food for breast milk. In year 2016, team of CSR collaborate with Mesuji senior high school in the Kemang Indah vil-lage is preparing for a flagship program name-ly CLC (Community Learning Center). The program aims to facili-

Company explaination is accepted, will be verified on the next audit.

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tate community in Ke-mang Indah Village and its surroundings for the workshop courses, computer and palm oil development. Related to transparency, any in-formation program can be accessed at CSR Forum in the district. On Stakeholder Meeting August 14, 2015 which attended by Head of Kemang Indah village, explained that the re-porting of the work plan and the realization of CSR to the Government of Ogan Komering Ilir submitted through the Regional Development Planning Board (Bappeda) and the fo-rum CSR - PKBL OKI.

3 • Report of manpower obligatory re-port smoothly

• The rude workers most of local labor

• Positive comment • The company always

open recruitment for staff and worker to local community with our specificly competency which needs and many of local worker was em-ploying in the company

Company explaination is accepted, will be verified on the next audit.

4 • Reporting to agency smoothly • Until the audit takes place there were

no reports of pollution in writing

• Positive comment • Positive comment and

the company has been conducted quality test-ing of groundwater eve-ry once a year

The compnay has been report to agency periodi-cally and has been con-ducted quality testing of groundwater

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5 • Collaborate between company and police running smoothly

• The company provides aid 4 units of patrol car

• Request an aid of Handy Talky (HT) and HT signal connection between the company and the village

• It should be reviewed on the con-struction of security post to antici-pate criminal acts

• Positive comment • Positive comment • Until now there is no of-

ficial submission by the police to the manage-ment, as a basis to cre-ate an action plan and follow up on the re-quest.

• Request the security post was delivered by the two villages namely Sumber Baru village and Mulya Jaya village and known by police and the sub district. Of-ficial response letter from management per 14 September 2015 was submitted directly to the Head of Mulya Jaya village on behalf Amroni as Forum Coor-dinator of Head village of Mesuji Raya Subdis-trict on September 29, 2015. The company an-swered not yet be able to realize the request, consider the effective-ness of the postal facili-ties, because some se-curity posts previous similar constructed by the company neglected condition, not used, and no one cared. The committee also not yet agreed on a mechanism picket guard with others village, including the al-location of operational activities. Other consid-erations that CSR has been prioritizing pro-grams that have been planned. Mr. Amroni understands and can accept the clarification and the response letter.

Company explaination is accepted, will be verified on the next audit.

6 The company regularly reports about pro-gress plantation business

Positive comment

Company explaination is accepted, will be verified on the next audit.

7 • PT Aek Tarum is located in Pema-tang Panggang village but in the land title certificate located in the Tegal Sari village. This is has been for-warded by the companies public re-lationship will be revised, but until now has not completed

• The company currently revising the location of land title administration and will be targeted to be completed before the concession expires.

• The company in han-

Company explaination is accepted, will be verified on the next audit.

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• Land title period of PT Aek Tarum is extended prior to the expiration and without intermediary head of District

• There is no clarity about the land on behalf Tabroni (250 hectares) in the Mesuji estate

dling the concession ex-tension following the ex-isting regulations

• Entire area on Mesuji estate has been com-pensated, there is no disputed area in the land consession of PT. Aek Tarum

8 Lately price of FFB is down The price of FFB has been set by plantation agency by agreement between the vari-ous parties

Company explaination is accepted, will be verified on the next audit.

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4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INT ERNAL RESPONSIBILITY 4.1 Date of Next Surveillance Visit

The next surveillance visit is planned for April 2017

4.2 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client

It is acknowledged that the assessment visit was carried out as described in this report and we accept the as-sessment findings and report content. Signed on behalf of PT Aek Tarum

Yusi Rosalina Manager System Certification Date: July 25, 2016

Signed on behalf of Naik Monang Parlindungan Lingga Lead Auditor Date: July 25, 2016

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APPENDICES

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Appendix 1: Certificate

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Appendix 2: List of Abbreviations AMDAL AT

Analisis Dampak Lingkungan & Sosial (Social & Environmental Impacts Assessment) Aek tarum

BLHD Balai Lingkungan Hidup Daerah (local environmental officer) CPO Crude Palm Oil EIA Environmental Impact Assessment ERTs ERP

Endangered, Rare & Threatened species Emergency response procedure

ESH Environmental Safety & Health FFB Fresh Fruit Bunches EFB Empty Fruit Bunches HCV Hyperkes IFC-CAO

High Conservation Value Hygiene Perusahaan & Kesehatan Kerja (Company Hygiene and Occupational Health) International Finance Corporation - Compliance Advisor/Ombudsman.

IPM Integrated Pest Management KUD Koperasi Unit Desa (Village of Unit Cooperative) LTA Lost Time Accident MSDS MBJ

Material Safety Data Sheets Mutiara Bunda Jaya

NPP New Planting Procedure NGO Non-Government Organization OSH Occupational Safety & Health PKO Palm Kernel Oil POME Palm Oil Mill Effluent PPE Personal Protective Equipment RKL Rencana Pengelolaan Lingkungan (Environmental Management Plan) RPL Rencana Pemantauan Lingkungan (Environmental Monitoring Plan) SIA Social Impact Assessment SOP SPPI SPSI SP

Standard Operating Procedure Serikat Pekerja Perkebunan Indonesia (Indonesian Plantation Labour Union) Serikat Pekerja Seluruh Indonesia (Indonesia Labour Union) Satuan Pemukiman (emplasment unit)

UKL Upaya Pengelolaan Lingkungan (Environmental Management Efforts) UPL Upaya Pengelolaan Lingkungan (Environmental Management Efforts)

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Appendix 3: List of Stakeholders Interviewed and Co ntacted

No. Name of Stakeholder

Institution / Position Remarks

Stakeholders Interviewed during Public Consultation Meeting 1 Marwa Environmental Agency OKI 2 Rozali Forestry Agency OKI 3 Irwan Sidik Mesuji Sector Police 4 M. Denin Subdistrict Head of Mesuji Raya 5 Yosep Ketut Suci Mataram Jaya village 6 Andreas Sugito Mataram Jaya village 7 Triono Mataram Jaya village 8 A. Khoiri Mataram Jaya village 9 Alimin SP Secretary of Pematang Panggang village

10 Ahmad Rosidi Panca Sawit Makmur Cooperative 11 M. Sodik Panca Sawit Makmur Cooperative 12 Suparyono Jaya Bersama Cooperative 13 Muslimin Jaya Bersama Cooperative 14 Dedy Permata Secretary of SPSA 15 Alek Sander Head of SPSA 16 Ramilin Tekad Mandiri Cooperative

Stakeholders Interviewed during on site 1 Yusi Rosalina Sustainibility 2 Mika Asni Sustainibility 3 Anita Widiawati Sustainibility 4 M. Khomarudin Sustainibility 5 Anis Qomariah QC Belida Mill 6 Arif Hendrawan CSR 7 Antonius Mill Manager 8 Wayan Saren Plasma Manager 9 M. Husni Daulay KTU Belida Mill

10 M. Robani KTU Belida 11 Nurhandari CSR 12 Muslimin Jaya Bersama Cooperative 13 Ahmad Rosidi Panca Sawit Makmur Cooperative 14 M. Sodik Panca Sawit Makmur Cooperative 15 Turiman Tekad Mandiri Cooperative 16 Muslimin Jaya Bersama Cooperative 17 Nur Kosin Tekad Mandiri Cooperative 18 Mumun Sprayer IPBS Estate 19 Mesinem Sprayer IPBS Estate 20 Winarsih Sprayer IPBS Estate 21 Eni R Sprayer IPBS Estate 22 Mulianto EFB Worker Belida Estate 23 Paini EFB Worker Belida Estate 24 Muji EFB Worker Belida Estate 25 Asmudin Lubis EFB Foremen Belida Estate

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Appendix 4: Observations and Opportunities for Impr ovement

No. Observations / Opportunities for Improvement Criteria

1

• Responsible of health and safety in this case P2K3 team ascertained to be re-registration to relevant agencies if there is a change of structural; it is also related to regulato-ry compliance Permenaker No. PER.04 / MEN / 1987 about Committee of Occupational Health and Safety as well as the procedure for appointment of expert safety

• To ensure granting a symbol and labels in accordance with relevant regulations, namely PermenLH No. 3 of 2008 to the symbols and labels of hazardous and toxic materials and PermenLH No. 14 year 2013 for Symbols and Labels of hazardous and toxic waste

2.1.1

2

• Business plan equipped with the appropriate information that stated on RSPO standards by entering the details of activities without the operating (general strategies and allo-cation for the management of environmental and social), including environmental costs, research, social economy and is reflected in the overall cost of production per tonne of FFB or CPO and also include a complete statement of hectares of planted and equipped with maps.

• Complete the work plan for 3 years with the production / profits and sum the cost per tonne of FFB produced.

• Special to cooperative of Panca Sawit Makmur include the cost of RSPO implementation plan

3.1.1

3

Recommend that the company (IPBS estate) ensuring the soil analysis conducted once every five years in accordance with the procedures of leaf and soil analysis (P-SAG-RST-ASE-01 Rev 0 dated September 1, 2009) in which companies conduct the last soil analysis March 2011.

4.1.1

4 Recommend that the company conduct the application of fertilizer according to the fertilizer recommendations that have been issued (the execution time of fertilization)

4.2.3

5 Training must be clear who the speaker and demonstrable by the attendance list, also complete with material

4.4.1

6

Companies should provide training to new employees assigned to perform a specific job. For example: IPM officials on behalf of M. Arif and Dwi (previously as empty bunch officers) have not provid-ed training in the IPM but assigned to work IPM. However, the company has proposed training for HRS with the number: 705 / BL / IV / 2016 dated April 21, 2016.

4.5.2

7 Records of treatment for pesticide applicators should be ascer-tained consistently performed

4.6.1

8 Recommend that ascertained suitability of working hours pesticide operator with Permanakertrans No.03 of 1986 about the terms of Health and Safety at Work who manage Pesticides

4.6.5

9 Evidence socialization procedures of control waste in the estate (PT-SAG-KBN-LMB-01) about the correct waste disposal should be available to workers

4.6.10

10

• Documented risk assessment should be confirmed to have been assessed and include about the control measures are set to address the risks that have been identified

• Always ascertained the consistency of recording in the form for occupational accidents because there is found several accidents that happen in January to March 2016 were not recorded, causing the issue of workplace accidents was not discussed at the meeting OSH dated 5 April 2016

4.7.2

11 Recommend that work accident investigation that has been con-duct include an actions to be taken to prevent the accident recur

4.7.5

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and preferably set out in a procedure

12

Related the semester report of RKL / RPL should be confirmed again due to some things, namely:

• The preparation report of RKL / RPL refers to Decree Envi-ronmenr and Forestry Minister No. 45 of 2005, as stated on the company's compliance evaluation

• Evaluation results in line with the final conclusions of the report, because it found contradictory about the quality standards that has passes of provision

• Test results certificates of monitoring should be attached as evidence the monitoring results

5.1.1

13 Provide coaching program members of cooperatives about HCV that has responsibility by HCV officers

5.2.1

14 Provide list of existing flora and fauna in the plasma 5.2.2

15 Preferably prepared a regular program for educate the presence and status RTE (protected species)

5.2.3

16 Conduct recording of HCV weekly inspection with the specified form

5.2.4

17 Make a real plan of disposal of hazardous waste with the third par-ty

5.3.1

18

Please make sure in the manifest listed the identification number of transport vehicle. Examples dated December 14, 2015 the transport of oil drums, accu etc. Example: No. 001 963 0,001,968 s.d

5.3.2

19 Make record the handover of hazardous wastes and toxic accord-ing to procedure form 2

5.3.3

20 Partnerships founder create guidelines for improving the efficiency of energy use in the plantations of their farmers.

5.4.1

21

• Companies needs to ensure that the work overtime can be conduct at most three (3) hours in one (1) day and 14 (four-teen) hours in one (1) week.

• Reevaluated of Memorandum No.0039 / MD / X / 2012 dat-ed October 18, 2012 regarding the provision of supplemen-tary food (extra fooding) for mill employees stated that the extra fooding for mill employees that is extra fooding only given to all employees who work extra hours for 3 (three ) hour especialally for night shift or who carry out duties re-lated to hazardous materials (B3), radiation, and special of-ficers.

6.5.1