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PUBLIC SUMMARY REPORT

INITIAL RSPO CERTIFICATION ASSESSMENT

PT HINDOLI South Sumatra Indonesia

Report Author

Charlie Ross – October 2008 [email protected]

Tel: +61 417609026

BSi Management Systems Singapore Pte Ltd (Co. Reg. 1995 02096‐N) Malaysia Branch (Co.Reg. 9942MX)

460 Alexandra Road 9 Jalan 16/11 Off Jalan Damansara #08‐01/02 PSA Building 1005 Block B Level 10, Phileo Damansara 1 SINGAPORE 119963 46350 Petaling Jaya Tel +65 6270 0777 Selangor Darul Ehsan, MALAYSIA Fax +65 6270 2777 Tel +03 7662 3311/3322 www.bsi‐asia.com Fax +03 7662 3300 Soon Leong Chia: [email protected] Teo Chin Siong: [email protected]

ii

TABLE of CONTENTS Page No SUMMARY ............................................................................................................................................................... 1

ABBREVIATIONS USED ............................................................................................................................................. 1

1.0 SCOPE OF CERTIFICATION ASSESSMENT ..................................................................................................... 1–6 1.1 National Interpretation Used .................................................................................................................... 1 1.2 Certification Scope .................................................................................................................................... 1 1.3 Location and Maps .................................................................................................................................... 1 1.4 Description of Supply Base ........................................................................................................................ 1 1.5 Date of Plantings and Cycle ....................................................................................................................... 5 1.6 Other Certifications Held .......................................................................................................................... 5 1.7 Organisational Information/Contact Person ............................................................................................. 5

1.8 Time Bound Plan for Other Management Units ........................................................................................ 5 1.9 Area of Plantation ..................................................................................................................................... 5 1.10 Approximate Tonnages Certified ............................................................................................................... 6 1.11 Date Certificate Issued and Scope of Certificate ........................................................................................ 6

2.0 ASSESSMENT PROCESS .............................................................................................................................. 6–7 2.1 Certification Body ..................................................................................................................................... 6 2.2 Assessment Methodology, Programme, Site Visits .................................................................................... 6 2.3 Qualifications of Lead Assessor and Assessment Team ............................................................................. 6 2.4 Stakeholder Consultation and List of Stakeholders Contacted .................................................................. 7 2.5 Date of Next Surveillance Visit .................................................................................................................. 7 3.0 ASSESSMENT FINDINGS .......................................................................................................................... 7 – 26 3.1 Summary of Findings ................................................................................................................................. 7 3.2 Detailed Identified Nonconformities, Corrective Actions and Auditor Conclusions ...................................................................................... 23 3.3 Noteworthy Positive Components .......................................................................................................... 25 3.4 Issues Raised by Stakeholder and Findings with Respect to Each Issue ................................................................................................................ 25 3.5 Acknowledgement of Internal Responsibility .......................................................................................... 26 3.6 Formal Sign‐off of Assessment Findings .................................................................................................. 26 LIST of TABLES

1 Mill GPS Locations ................................................................................................................................................ 1 2 Estates FFB Production ........................................................................................................................................ 1 3 Age Profile of Planted Palms ................................................................................................................................ 5 4 Estates and Areas Planted .................................................................................................................................... 5 5 Approximate Tonnages Certified .......................................................................................................................... 6 LIST of FIGURES

1 Location Map ....................................................................................................................................................... 2 2 Estates, Mills and Smallholders ............................................................................................................................ 3 3 Tanjung Dalam Estate .......................................................................................................................................... 4 4 Mukut New Development .................................................................................................................................. 20 5 Summary of Accident Statistics for Sungai Lilin Mill 1999‐2008 ......................................................................... 25 LIST of PLATES

1 Barn Owl (Tyto alba) .......................................................................................................................................... 25 2 Vegetable Gardens at rear of Houses ................................................................................................................. 25 List of Appendices

A PT Hindoli RSPO Certificate Details B Certification Assessment Plan

RSPO Certification Assessment – Sungai Lilin and Tanjung Dalam Mills and Supply Base Page 1

Prepared by BSi Management Systems Singapore Pte Ltd for PT HINDOLI

SUMMARY

BSi has conducted an assessment of PT Hindoli (Hindoli) operations comprising two mills, three oil palm estates, support services and infrastructure. BSi concludes that Hindoli operations comply with the requirements of RSPO Principles & Criteria : November 2007 and Indonesian Indicators and Guidance (INA NIWG) : 2008.

BSi recommends that Hindoli be approved as a producer of RSPO certified sustainable palm oil.

ABBREVIATIONS USED

AMDAL Environmental Impact Assessment Report B Boron BOD Biological Oxygen Demand BPN Badan Pertanahan Nasional (National Land

Agency) Ca Calcium COD Chemical Oxygen Demand CPO Crude Palm Oil EFB Empty Fruit Bunch EHS Environment Health and Safety FFB Fresh Fruit Bunch FPIC Free, Prior and Informed Consent GPS Global Positioning System GIS Global Information System ha Hectare HCVs High Conservation Values HGB Hak Guna Bangunan (Land Use Title for factory) HGU Hak Guna Usaha (Land Use Title) HR Human Resources INA NIWG: 2008 Indonesian National Interpretation of the

RSPO P&C IPM Integrated Pest Management K Potassium KKB Kesepakatan Kerja Bersama (Collective Labour

Agreement) KUD Koperasi Unit Desa (Village Cooperative Unit) LTA Lost Time Accident MA Medical Aid (medical treatment of a workplace

injury and worker is able to continue duties) MSDS Material Safety Data Sheet N Nitrogen OMP Oil Palm Management Program OSH Occupational Safety and Health P Phosphorus PCD Pollution Control Device pH Hydrogen ion concentration PK Palm Kernel ppm Parts Per Million QMS Quality Management System SPH Surat Pengakuan Hak (Letter of Land Right

Declaration) SOPs Standard Operating Procedures

1.0 SCOPE OF CERTIFICATION ASSESSMENT

1.1 National Interpretation Used

The operations of the mills and their supply bases of FFB were assessed against the Indonesian Indicators and

Guidance (INA NIWG) : 2008 of the International RSPO Principles and Criteria : 2007.

1.2 Certification Scope

The scope of certification includes the production from two (2) palm oil mills that is sourced from their supply base of three (3) company owned oil palm estates and Smallholders.

1.3 Location and Maps

Hindoli oil palm estates are located in Musi Banyuasin District of South Sumatra Province, Indonesia (Figure 1). More detailed information on the estate locations is shown in Figures 2 and 3. The GPS locations of the mills are shown in Table 1.

Table 1: GPS Location of Mills

MILL LONGITUDE LATITUDE

Sungai Lilin E 104° 7’ 41∙67” S 2° 36’ 46”

Tanjung Dalam E 103° 56’ 38∙4” S 2° 32’ 58∙56”

1.4 Description of Supply Base

Oil palm fruit is sourced from three company owned estates and Smallholders. The FFB production from company owned estates is listed in Table 2.

Table 2: Estates FFB Production

Estate FFB Production (t)

Sungai Pelepah 65,558

Tanjung Dalam/Sri Gunung 90,617

Sungai Tungkal 78,214

TOTAL 234,389

Smallholders supplied 468,717 t (approximately 67%) of the total FFB processed by the Mills during 2007/2008. The smallholder scheme was developed as a condition of Hindoli project approval. The scheme comprises thirteen cooperatives whose smallholder members number 8,797 and have 17,594 ha planted to oil palm.

The smallholder scheme originated from a government transmigration project (PIR‐Trans Scheme) that was set up in the early 1980s for growing soybean. The soybean scheme comprising inti and plasma failed. In 1991, a local company received government approval for development of an oil palm project comprising inti, plasma and a mill. The smallholder oil palm was planted in the early 1990s. Hindoli employed a team of extension workers to train the smallholders. Cargill continued to support the smallholders after it acquired Hindoli in May 1995.



Figure 1: Location Map



Figure 2: Estates, Mills and Smallholders



Figure 3: Tanjung Dalam Estate



Hindoli has socialised information on RSPO to each of the 13 cooperatives. BSi visited a sample of the cooperatives during the Assessment and checked field conditions at a sample of smallholders. The BSi audit team concluded that at the time of the audit the schemed smallholders did not meet the RSPO Certification requirements.

Hindoli operates a Farmer Development Department whose role is to support the smallholders. Hindoli has developed an RSPO implementation plan to achieve certification of its schemed smallholders within three years of the initial certification.

The production from the schemed smallholders is not included in the Certificate.

1.5 Date of Plantings and Cycle

The Hindoli owned estates were planted between 1996 and 2001. The palms are mature and half way through the first cycle. Replanting would not be required for another 10 years. The age profile of the planted palms is shown in Table 3.

Table 3: Age Profile of Planted Palms

AGE (years) % of Planted Area

6 0∙3

7 7∙9

8 14∙5

9 25∙6

10 26∙4

11 21∙4

12 3∙9

1.6 Other Certifications Held

Hindoli has implemented an integrated Environmental and Quality Management System and was awarded ISO 9001 and ISO 14001 Certification on 28 July 2008.

The Ministry of Environment has awarded Hindoli the Blue Standard under the “PROPER” programme in June 2008.

In 2003 the President of Indonesia awarded one of the Hindoli smallholder cooperatives the “Best Plasma in Indonesia”.

Both Hindoli Mills were awarded the Cargill President’s Gold Award for Safety Excellence in 2006, 2007 and 2008.

In 2007 the Labour Ministry awarded Sungai Lilin Mill the “Zero Accidents Award” for achieving 5,000,000 hours LTA free.

1.7 Organisational Information / Contact Person

The company contact details are as follows:

PT Hindoli Jl Palembang – Jambi Desa Teluk Kemang Kekamantan Sungai Lilin MUBA Sumatera Selatan PALEMBANG 30755 INDONESIA

Contact Person: Mr Anthony Yeow General Manager Phone: +62 21 52896408 Fax: +62 21 52896407 CTP Holdings Pte Ltd is a subsidiary of Cargill, the global food company. Cargill is a member of RSPO and has been involved in the Roundtable process from inception.

1.8 Time Bound Plan for Other Management Units

CTP Holdings Pte Ltd owns and operates two plantation locations in Indonesia (Hindoli and Harapan Sawit Lestari) and three in Papua New Guinea (Higaturu Oil Palms, Milne Bay Estates and Poliamba).

CTP Holdings Pte Ltd is implementing a programme to achieve RSPO Certified Sustainable Palm Oil for all of its production by late‐2009. BSi has carried out pre‐assessments against the RSPO P&C at each of the CTP Holdings Pte Ltd operating locations. CTP Holdings Pte Ltd is committed to addressing the issues identified by BSi in this pre‐assessment process. The pre‐assessment process did not identify any unresolved significant land or labour disputes or any loss of HCVs at any area of new development since November 2005

CTP Holdings Pte Ltd Time Bound Plan consists of Certification Audits of the 3 Papua New Guinea properties in May 2009 and at Harapan Sawit Lestari in the third quarter of 2009. In view of the remoteness and the different cultural and environmental settings of the properties, BSi considers this Plan to be challenging, and to conform to the RSPO requirements for partial certification.

1.9 Area of Plantation and Approximate Tonnages Certified

The areas of planted palms at company owned estates are listed in Table 4.

Table 4: Estates and Area Planted

Estate Mature (ha) Immature (ha)

Sungai Pelepah 3030 0

Tanjung Dalam/ Sri Gunung

3659 0

Sungai Tungkal 2866 0

TOTAL 9555 0



1.10 Approximate Tonnages Certified

The approximate tonnages certified on the basis of 2007/08 production from Hindoli owned estates are detailed in Table 5. NB: The production from Smallholders is excluded from the Certificate.

Table 5: Approximate Tonnages Certified

MILL CPO PK

Sungai Lilin 31,544 7,519

Tanjung Dalam 19,800 4,603

TOTAL 51,344 12,122

1.11 Date Certificate Issued and Scope of Certificate

The scope of the Certificate includes the production from the company owned and managed estates processed at the Sungai Lilin and Tanjung Dalam Palm Oil Mills. Certificate details are included as Appendix B. The Certificate issue date will be the date of the RSPO approval of the Assessment Report.

2.0 ASSESSMENT PROCESS

2.1 Certification Body

BSI Management Systems Singapore Pte Ltd 460 Alexandra Road #08–01/02 PSA Building Singapore 119963 Product Manager: Mr Soon Leong Chia Phone: +65 6270 0777 Ext 115 Fax: +65 6270 2777 Email: [email protected]

BSi is a leading global provider of management systems assessment and certification, with more than 60,000 certified locations and clients in over 100 countries. BSi Standards is the UK’s National Standards Body. BSi Management Systems provides independent, third‐party certification of management systems. BSi has a Regional Office in Singapore and a Branch Office in Kuala Lumpur.

2.2 Assessment Methodology, Programme, Site Visits

The assessment was conducted in 2 stages. Stage I Assessment was conducted between 28 January and 01 February 2008 against the Indonesian Indicators and Guidance INA NIWG : November 2007. The Stage I audit assessed the company’s readiness for Certification. It focussed on review of internal procedures, management systems and field inspections to identify any significant environmental or social issues. External stakeholders were not consulted in the Stage I Assessment.

Stage II Assessment was conducted between 01 and 06 September 2008 against the RSPO Principles & Criteria :

November 2007 and Indonesian Indicators and Guidance (INA NIWG) : 2008. The Assessment Plan is included as Appendix B. Stage II assessed in detail the company’s conformance with the RSPO P&C. The scope included Estates, Mills, support services, infrastructure and external stakeholder consultation.

The approach was to audit the mills together with an estate chosen from the supply base for each mill, such that a range of environmental and social factors were covered. These factors included consideration of topography, soils, age of palms and proximity to local communities and areas with HCVs.

The methodology for collection of objective evidence included physical site inspections, observation of tasks and processes, interview of staff, workers and their families and external stakeholders, review of documentation and monitoring data. Checklists and questionnaires were used to guide the collection of information.

The assessment was based on random samples and therefore nonconformities may exist which have not been identified.

Mr Allan Thomas, BSi Lead Auditor EMS, QMS and OHSAS has reviewed this report for conformance with RSPO Certification System requirements and technical content.

Mr Soon Leong Chia, BSi Product Manager RSPO, has reviewed this report for conformance with BSi Procedures and the RSPO Certification System requirements.

2.3 Qualifications of the Lead Assessor and Assessment Team

BSi Management Systems Singapore holds copies of educational qualifications, certificates and audit logs for each of the audit team members. BSi has evaluated the qualifications and experience of each audit team member and has registered the following designations for conducting RSPO Assessments:

Charlie Ross – Lead Assessor B.App.Sc. M.Sc (Env.Studies) Lead Auditor EMS RABQSA Cert No 012364 Iman Nawireja – Social Assessor B.Ag.Sc. M.Sc. (Comm)

Robyn Ross – Social Assessor

Charlie Ross is an independent environmental auditor who has extensive fieldwork experience in conducting environmental and social assessments of oil palm projects over the past 16 years in Indonesia, Malaysia, Nigeria, Papua New Guinea and Solomon Islands. He has completed lead auditor training in ISO 9001 Quality Management Systems, lead auditor training in OSHAS 18001 Occupational Health and Safety Assurance Systems, auditor training in Environmental Management, in SA8000 Social Accountability and in RSPO P&C. He has been involved in the RSPO process



since RT1 and has conducted audits of oil palm plantation companies (total of 139 audit days) against the RSPO P&C in Indonesia, Malaysia and PNG. Iman Nawireja has a background in the socio‐economic aspects of agriculture, and has assisted with field studies on the effect of resource development projects on farmer and community incomes, health status and household division of labour. He has completed Lead Auditor training in ISO 14001 Environmental Management Systems. He has assisted in conducting environmental and social assessments of 8 oil palm projects (total of 95 consulting days) during the past 5 years. He has assisted with conducting audits of oil palm plantation companies (total of 61 audit days) against the RSPO P&C in Indonesia and Malaysia. Robyn Ross has a background in company administration and supporting women with mental health and physical disabilities by assisting them to develop skills for living independently in the community. She has assisted with fieldwork in conducting environmental and social assessments of oil palm projects over the past 5 years in Indonesia and Nigeria. She has completed auditor training in SA8000 Social Accountability. She has assisted with conducting audits of oil palm plantation companies (total of 119 audit days) against the RSPO P&C in Indonesia, Malaysia and Papua New Guinea. Dini Harmita holds a BSc in Agriculture from Bogor Agricultural University and is fluent in English. Ms Harmita assisted Robyn Ross as an interpreter during interview of female staff and workers and families.

2.4 Stakeholder Consultation and a List of

Stakeholders Contacted

Stakeholder consultation involved external and internal stakeholders. External stakeholders were notified by placing an invitation to comment on the RSPO and BSi websites. Letters were written to individual stakeholders and telephone calls were made to arrange meetings to discuss Hindoli’s environmental and social performance. BSi did not receive any responses in writing from stakeholders in relation to Hindoli. Meetings were held with local stakeholders to seek their views on the performance of the company with respect to the RSPO requirements and aspects where they considered that improvements could be made. Stakeholders included those immediately linked with the operation of the company such as employees, smallholders and contractors, as well as those organisations including NGOs, whose activities cover the same geographical area as the estates. Stakeholder consultation took place in the form of meetings and interviews. The interviewer explained the purpose of the audit at the outset followed by an evaluation of the relationship between the stakeholder and the company before discussions proceeded. The interviewer recorded comments made by stakeholders

and these have been incorporated into the assessment findings. Male and female workers and staff were interviewed in private at each estate and mill. Fieldworkers were interviewed informally in small groups in the field. In addition, the wives of workers and staff were interviewed at the housing areas in informal group meetings in the late afternoons. Company officials were not present at any of the interviews.

List of Stakeholders Contacted

Contractors

5 General Contractors Transport Contractor

Smallholders

14 Smallholders Smallholder Cooperatives

Local Communities

Berlian Makmur Village Dusun II Penuguan Village Dusun I Penuguan Village Mukut Village Penuguan Village Linggosari Village Head Penuguan Village Secretary Mukut Village Head

Government Departments

District BPN (National Land Agency) Office District Forestry and Agriculture Office District Labour Office District Cooperative Office District Bapedalda

NGOs Sawit Watch WWF Indonesia

2.5 Date of Next Surveillance Visit

The next surveillance visit is planned within 12 months of the date of RSPO approval of the Initial Certification.

3.0 ASSESSMENT FINDINGS

3.1 Summary of Findings

As outlined in Section 2.3, objective evidence was obtained separately for each of the RSPO Indicators for Sungai Lilin Mill and for its associated Sungai Pelepah Estate; and Tanjung Dalam Mill and its associated Tanjung Dalam Estate. The results for each indicator from each of these operational areas were evaluated to provide an assessment of conformance of the Company’s operations with each Criterion. A statement



is provided for each of the RSPO Indicators to support the finding of the assessment team.

Two (2) Nonconformities were identified against Minor Compliance Indicators. Eleven (11) Observations / Opportunities for improvement were identified. Details of the Nonconformities are given in Section 3.2 (Page 22).

Hindoli has prepared a Corrective Active Plan that was reviewed and accepted by BSi.

BSi has conducted an assessment of the Hindoli operations comprising 2 mills, oil palm estates, support services and infrastructure. BSi concludes that Hindoli operations comply with the requirements of RSPO Principles & Criteria : November 2007 and Indonesian Indicators and Guidance (INA NIWG) : 2008.

BSi recommends that Hindoli be approved as a producer of RSPO Certified Sustainable Palm Oil. 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 decision making.

Hindoli has implemented a system whereby all requests received by individual departments are forwarded to the Public affairs Department who scans the document and emails the copy to the relevant department for a response. Copies of requests for information are held on the email system as well as on hard copy files at each department (1.1.1). The review of records confirmed that Public Affairs Department also stores copies of responses to requests for information (1.1.2). Public affairs Department retains records for an indefinite period, while individual departments retain records for three years (1.1.3). Checks of the files showed that Hindoli has responded appropriately to requests for information. Criterion 1.2: Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes.

Hindoli Policy is to make documents available upon request and in accordance with Government regulations. Information on land titles is discussed in detail in Criterion 2.2. Land Titles and user rights documents are made publicly available upon request. (1.2.1)

Hindoli has an AMDAL that was approved 14 May 2005 that covers the scope of the project. UPL Monitoring reports are forwarded six‐monthly to Government. Inspection confirmed copies are available, eg most recent report January–June 2008. (1.2.2)

Reports are available on Mill EHS Committee socialisation of information to local communities (more than 106 adults) on awareness for Malaria and Dengue Fever prevention. A Report also is available on staff and workers’ voluntary participation in a community service programme involving projects such as digging wells for

clean drinking water supplies and recent construction of a three classrooms for an elementary school in Plasma C4 Village. (1.2.3)

The Health and Safety Plan is a core component of the Hindoli Program Assurance Three Year Plan (2008–2010). The Plan provides details of strategic objectives and an Action Plan for their implementation and achievement. (1.2.4)

The Continuous Improvement Plan is documented in the ISO 14001 EMS and also in the Hindoli Program Assurance Three Year Plan (2008–2010) which covers Health and Safety, Environment, RSPO Implementation and ISO 9001 Quality Management. (1.2.5)

Individual department records are kept active for three years and then archived on site. Legal records are held indefinitely. (1.2.6) Criterion 2.1 – There is compliance with all applicable local, national and ratified international laws and regulations.

At the time of the audit there were no known legal actions against Hindoli. Legal compliance is one of Cargill's Guiding Principles and all endeavours are made to comply with labour, land titles, environmental and OSH Laws. Inspection of a sample of relevant records confirmed compliance with regulatory requirements. The recent (2008) third party ISO14001 Certification Audit confirmed legal compliance. Inspection confirmed housing is well above the minimum standard and the treated water supplies to housing meet minimum quality standard for domestic use.

Hindoli holds a certificate for mill boiler operation inspected by Government 01 December 2007. Boiler emissions were tested 19 June 2008, together with mobile plant and ambient air quality and were fully compliant with licence. (2.1.1)

Hindoli has implemented an ISO 14001 Procedure "HIN/MGT/002" for periodic checks of changes to regulations and disseminating that information within the company. For example, in March 2007 the regulatory requirement for boiler emission monitoring parameters and frequency changed from annually to twice yearly. This has been fully implemented. The EHS Coordinators are responsible for keeping Estates and Mills up to date with any changes. (2.1.2)

Hindoli has documented legal requirements as part of the ISO 14001 Environmental Management System. This includes a list of the legislation, regulations and licences, together with a description of the compliance requirements. (2.1.3)

Hindoli has a documented EMS procedure for conducting ISO 14001 Internal Audits six monthly that specifically evaluate legal compliance, most recent assessment 23‐26 June 2008. In addition, mills assess compliance with licences progressively as monitoring results are received. (2.1.4) Criterion 2.2 – The right to use the land can be demonstrated and is not legitimately contested by local communities with demonstrable rights.



Hindoli holds a Land Use Title Hak Guna Bangunan (HGB) for Sungai Lilin Mill and housing areas ‐ reference "HGB No 19" (Mill) 19 September 1997 and "HGB 20" (Housing) 14 July 1997. The HGB for Tanjung Dalam mill and housing area is in the final process with the National Land Agency in Jakarta. Hindoli holds an Izin Lokasi, a plantation operation permit Izin Usaha Perkebunan and has applied for a Site Permit Land Use Title Hak Guna Usaha (HGU). The HGU approval process has been protracted by negotiations over a land boundary, which was resolved in early 2008. The HGU is in the final process following preparation of the Cadastral Survey and recommendation of the Provincial Government Departments to the National Land Agency in Jakarta. (2.2.1) Observation 1 ‐ refer Section 3.2 Page 24 for details.

Hindoli has prepared a map showing the location of BPN Boundary Stones. Field inspection confirmed boundaries are demarcated by trenches and the concrete BPN Boundary Stones. Hindoli has implemented an annual programme for physical inspection and maintenance of boundary stones. (2.2.2)

At Sungai Pelepah Estate a group of people are claiming compensation for 27 ha of land, for which Hindoli has already paid compensation. The original owner to whom compensation was paid is now deceased and there is a new claim for the same land. Hindoli is negotiating with the claimants to settle the dispute by payment of an agreed amount of compensation. An amount was negotiated at a meeting with community representatives on 27 August 2008 and has been referred to Hindoli Management for consideration. (2.2.3) Observation 2 – refer section 3.2 Page 24 for details.

In May 1995, Cargill completed the acquisition of Pt Hindoli, a local company that had developed smallholder oil palm on a previously failed PIR‐TRANS Scheme that was originally set up in 1980 for growing soy bean. Hindoli started land acquisition for company estates in 1997 within an Ijin Lokasi granted by the Government. At that time the land was occupied by local people as well as relatives of the transmigrants from the PIR‐Trans Scheme. The land acquisition process involved a Government led team with involvement of local people to identify customary and legal rights and to assess the amount of compensation. The individual blocks of land were assessed for compensation by means of an inventory of improvements and all payments were duly witnessed.

Hindoli holds detailed records of all compensation assessments and the payments made for each block of land (including photographs of recipients). The acquisition of 9,000 ha of land took five years to complete due to Cargill’s requirement to adhere to its procedures and to settle all claims through consultation and negotiation before land handover. Since the completion of land acquisition in 2002 there have been individual land claims but these have been resolved through consultation and negotiation. The Audit Team concluded that the land acquisition process was consistent with the principles of FPIC. (2.2.4)

Hindoli has a documented dispute resolution procedure, which involves receiving and registering a claim, extraction of relevant documents and discussion with the claimant. If agreement cannot be reached through discussion and negotiation then it will be referred to an independent District Monitoring and Control Team. If this fails to resolve the issue it is then referred to the court system. The dispute resolution SOP is in the form of a flow chart. The Procedure is consistent with the requirements of the District Monitoring and Control Team. (2.2.5) Criterion 2.3 – Use of the land for oil palm does not diminish the legal rights of other users without their free, prior and informed consent.

The audit team confirmed Hindoli holds detailed records for the land acquisition process: Mapping, identification of occupiers of land, inventory of improvements, land document preparation in conjunction with Kepala Desa and Camat, negotiation between landowner and company witnessed by Kepala Desa for compensation Ganti Rugi, invoice for the acquisition and then payment by the company. Records are available for all land acquired by the company. (2.3.1)

Hindoli holds detailed maps of the land occupied by local people, transmigrants and relatives of transmigrants. These maps record the occupiers of each block of land and the land area. (2.3.2)

Hindoli has detailed records of the land inventory process, assessment of compensation for land improvements and payment of the agreed compensation to the landowner. The compensation payment process was witnessed and a photographic record made of the landowner receiving payment. (2.3.3)

Criterion 3.1: There is an implemented management plan that aims to achieve long‐term economic and financial viability. Hindoli has a five year plan ‐ 2007 ‐ 2012 that includes key performance measures for individual departments. The implementation of the plan is aimed at improving productivity and financial viability. (3.1.1)

The oldest palms at Hindoli estates were planted in 1997. As replanting is not due for another 10 years, Hindoli has not yet prepared a replanting Plan. (3.1.2) Criterion 4.1: Operating procedures are appropriately documented and consistently implemented and monitored.

Hindoli Agriculture SOPs have recently been revised (2007) and new issues are controlled documents under the integrated ISO 9001 and ISO 14001 Management. The SOPs cover all aspects of oil palm management from land development through to maintenance and harvesting. (4.1.1)

Hindoli has prepared SOPs specific to each mill to form an integrated ISO 9001/14001 Management System. SOPs are held for individual mill departments (Ref: SL/PROD/09/SOP, Issue 11 Jun 2008). SOPs are in Bahasa and copies are held at each workstation. The



SOPs describe the mill operations from loading ramp through processing to dispatch of CPO and palm kernel. SOPs will be reviewed annually as a requirement of ISO 9001/14001 Management System. Inspection of work stations indicated SOPs were being consistently implemented. (4.1.2)

The performance of each mill work station is monitored on a shift basis and recorded on a Production/Record Logsheet. General condition inspections are carried out monthly. Milling Director (Top Management) conducts quarterly inspections. Internal ISO 9001 QMS audits are carried out twice yearly plus annual external third party audit. Inspection during the audit confirmed log sheets at mill work stations were filled in accurately and consistently.

The Estate Manager carries out daily checks on SOP implementation of field practices. The General Manager (monthly) and Agriculture Advisor (twice yearly) carry out inspections of field conditions and practices. The Technical Services Department monitors the operations in conjunction with the Estate Manager monthly. Monthly records were available and presented as a graphical field audit against the performance standards. Inspection of a sample of field practices and field conditions indicated that SOPs were being implemented consistently. (4.1.3)

Mill shift records are supplemented with a daily production report, called “Daily Crush Report” which compares actual results against targets for quality, quantity and efficiency. Monthly performance reported as "Technical Balance Scorecard", which compares actual results against targets. Estate operational results, eg yield, number of bunches, labour input are recorded on Oil Palm Monitoring Programme (OMP) on a per block (25 ha) basis. Monthly estate performance also is reported as "Technical Balance Scorecard". (4.1.4) Criterion 4.2: Practices maintain soil fertility at, or where possible improve soil fertility, to a level that ensures optimal and sustained yield.

Hindoli has implemented a programme of soil sampling every five years and leaf analysis yearly. At the time of collection of the annual leaf sample, the palm is inspected and any observations of nutritional deficiency symptoms are recorded. One leaf sample is taken from each 25ha block and analaysed for major and minor elements (N, P, K, Mg, Ca and B). The frond stem also is analysed for NPK. Data are stored on the GIS database Oil Palm Monitoring Programme "OMP". (4.2.1)

Crop yield and foliar analysis have been used to identify priority areas for soil nutrition improvement. The Crop Residue Application Programme details the blocks within each estate that are to receive EFB and decanter cake application. Records of nutrient inputs are stored on a GIS database. (4.2.2) Criterion 4.3: Practices minimise and control erosion and degradation of soils. Hindoli soils have been mapped. Dominant soil is a red‐yellow podsolic or ultisol. There is no peat soil at the estates. (4.3.1)

The topography of the estates is flat to gently rolling. There is one location at Tanjung Dalam Estate where terracing has been carried out but the area is small (< 20ha). Inspection of field conditions confirmed that Hindoli has implemented appropriate practices for minimising soil erosion. These include “T” staking of pruned palm fronds, stop bunds on terraces and maintenance of adequate groundcover vegetation. (4.3.2) Observation 3 – refer Section 3.2 Page 24 for details.

There is a company operated road maintenance programme that includes road surfaces, culverts and bridges. Inspection during the audit confirmed road maintenance was being carried out, roads have been surfaced with a durable cover of crushed gravel and roadside drains were well maintained for management of rainfall runoff. (4.3.3)

There are no fragile soils (sandy, low organic matter or acid sulphate) at the estates. (4.3.4)

A water management strategy has been implemented for preventing inundation of lowlying areas using a system of watergates. Approximately 30% of Sungai Pelepah estate is low‐lying and these areas have been mapped. A dedicated operator monitors water levels daily and adjusts floodgates as required. Inspection of both estates confirmed that areas previously subject to waterlogging are growing palms successfully. (4.3.5) Criterion 4.4: Practices maintain the quality and availability of surface and groundwater

A 50m wide buffer zone has been maintained along Sungai Tungkal, the main river that drains the estates, since the development of the estate 10 years ago. However at the other smaller streams within the estates, riparian buffer zones were not set‐aside during the land development process.

CTP Holdings has developed a Buffer Strip Policy that includes a strategy for reinstatement of buffer zones. Hindoli has carried out GPS survey of all permanent streams and demarcated the areas to be set‐aside as buffer zones. These are shown on Figure 3 for Tanjung Dalam Estate. Hindoli’s immediate actions are the marking of buffer zone boundaries with poles painted red and ceasing the application of herbicides within the future buffer zone. Inspection confirmed the Sungai Tungkal, Sungai Dawas and Sungai Malebekan buffer zones have been measured and boundaries marked to show the adjustment required at replant.

The water‐gate operator inspects the existing buffer zone twice weekly and checks for disturbance. Hindoli has installed signboards and socialised information to workers and local communities on the need to protect buffer zones. (4.4.1) Observation 4 – refer section 3.2 Page 24 for details.

Hindoli has documented its Water Management Plan in the ISO 14001 Environmental Objectives and Targets and Program. An example is to reduce the 2006 mill water consumption by 2% in 2010. The Objectives and Targets identify the sources of wastewater and methods of



treatment for prevention of pollution. For example, silt traps and oil traps have been installed at all workshops throughout the Estates and Mills. At Sungai Lilin Mill all drainage is treated in sediment and oil traps before transfer to the effluent treatment pond system. Mill effluent monthly sampling results showed compliance for previous 12 months for pH, BOD, COD, TSS, Total N and Oil and Grease, except for one exceedance in December 2007 for Oil and Grease.

A site specific Water Management Plan was developed in 2002 to improve management of flood prone areas at Sungai Pelepah, Sungai Tungkal and Tanjung Dalam Estates. The plan has been effective for preventing inundation of lowlying areas using a system of watergates. A dedicated operator monitors water levels daily and adjusts floodgates as required. (4.4.2)

The mill treated effluent is sampled weekly at each mill and tested by the mill laboratory. In addition an independent laboratory samples and tests the effluent discharge monthly for compliance. Review of the results for the previous 12 months confirmed both mills have complied with discharge licence limits, including BOD. (4.4.3)

Water usage is metered and reported daily against the target of 1.2 m

3/t FFB. The ytd average is 1.13 t/t FFB at

Sungai Lilin Mill and 1.33 m3/t FFB at Tanjung Dalam Mill. The mill boiler is run for extended operating hours to reduce diesel fuel consumption and this is reflected in increased water consumption. (4.4.4) Criterion 4.5: Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate integrated Pest Management (IPM) techniques.

Hindoli has documented an Integrated Pest Management Plan (2007) that describes the strategy for IPM management of each of the main palm pests. It includes a flow chart describing trigger points for actions to be taken for pest outbreaks. This is linked to "Procedure for Early Warning System Census" ‐ reference SOP_CensusEWS.doc (4.5.1)

Hindoli maintains maps showing implementation on a per block basis of various IPM techniques, such as Barn Owls and establishment of beneficial plants Turnera subulata and Cassia cobanensis. Field inspection confirmed extensive use of beneficial plants. Early warning census monitoring is carried out by sampling each block monthly. Records are held on a per block basis for IPM control of Nettle Caterpillars and Bag Worm. Hindoli’s Technical Services Department has carried out training in relation to early warning census and Barn Owls. IPM training was conducted 30/1/2008 for 23 participants and more recently 28 August 2008 for 32 participants, to Mandor level. (4.5.2)

Data are available for pesticides usage per block since 2003. Trend information shows reduction in toxicity units between 2006 and 2007 due to phasing out the use of paraquat and 2,4D Amine. (4.5.3)

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

Inspection of stores and check of records confirmed Hindoli uses only six chemicals, all of which are registered and approved by the Department of Agriculture ‐ reference "Pestisida Pertanian Dan Kehutanan" (Pesticides for Use in Agriculture and Forestry) – Centre for Permit and Investment General Secretariat, Agriculture Department, 2007. (4.6.1)

The quantities of chemicals used and location are recorded on a daily report and input to computer by the Estate Clerk using online access to the OMP database. TSD produces reports on the quantities, active ingredients and locations where pesticides have been used. Records are available since 2003. (4.6.2)

Sprayer training was conducted by Nufarm Chemicals for 34 Assistants, Operators and Mandors in Aspects of Pesticide Safety, Equipment Calibration and Equipment Maintenance on 31 January 2008. Inspection of spray‐mix preparation and spray application confirmed that pesticides were measured accurately and used in accordance with the product label. Pesticides were measured within a concreted area with spill containment. Pre‐mixed chemicals were transported to the field in clearly marked containers. Observations and interview of sprayers indicated the operators have been adequately trained. Pesticides were stored in purpose built buildings that were secure, have adequate natural ventilation and lighting, spill containment and safety signage. (4.6.3)

Empty pesticide containers are triple rinsed and stored in a B3 hazardous waste store. Hazardous waste is removed by a licenced contractor PT Nirmala Tipar Sesama – licence number 612 of 2007. Records are held on file of the Hazardous Waste Manifests for Mills and Estates. (4.6.4)

Hindoli has ceased using paraquat, rat baits and 2,4D Amine. Inspection of stock records and chemical store confirmed no Type 1 chemicals were being used. (4.6.5)

Hindoli has implemented annual health checks for sprayers, most recently conducted by a Government Doctor July 2008 and included physical examination and laboratory analysis of haemoglobin and cholinesterase. (4.6.6)

Sungai Pelepah Estate employs 40 women sprayers and Tanjung Dalam 20, who undergo quarterly medical checks for pregnancy. Records confirmed health checks of sprayers were carried out at Sungai Purun on 28/08/08 (25 women) and Tanjung Dalam on 14/08/08 (18 women). The Doctor confirmed the Company policy for women sprayers to be transferred to other duties if confirmed pregnant. (4.6.7)



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

Hindoli has an Environment Health and Safety Quality Policy signed by Top Management 21 July 2007 that is displayed prominently (in English and Bahasa) on Notice Boards at Mill and Estate Offices and Muster locations. The Company has implemented a Safety Management System that is integrated with the ISO 9001 and ISO 14001 Management Systems. Detailed safe working practices are documented for all areas of significant hazards and include a Permit to Work System prior to commencement of hazardous tasks. Inspection during the audit confirmed the policy is consistently implemented, as evidenced by the mill’s excellent safety record – 1,503 days since LTA (20 July 2004) at Sungai Lilin Mill and at Tanjung Dalam Mill since commissioning in March 2005, 1,280 days. Inspection of work areas at the estates also indicated consistent implementation of the safety policy. (4.7.1)

Hindoli employs a full‐time EHS Coordinator for the mills and for the estates. The EHS Coordinator and the full time EHS Officer at each mill hold a Government National Safety Certificate (AK3). At each mill and estate there is an EHS Committee, comprising 50 percent non‐staff members and 50 percent management members. Committees meet monthly and records are held on file Inspection of records confirmed meetings discuss health related and welfare issues, eg sanitation and community malaria/dengue awareness programme. Safety topics discussed include Near Misses, General Conditions, Housing, Electricity, Security, Clinic, Workshop and School. (4.7.2)

All workers are covered by JAMSOSTEK and an additional Company benefit is available if needed. (Receipt Number GG001004 – June 2008.) (4.7.3)

Hindoli has implemented, since 1998, annual physical medical check‐ups of all workers and staff (blood, urine, lungs, respiratory, hearing) and are conducted by a National Government Labour Department Doctor. Most recent checks carried out 14‐18 July 2008. (4.7.4)

Hindoli EHS Coordinator and EHS Committee have conducted a risk assessment for all tasks associated with each work station throughout the mill and estate operations. The Assessment includes the identification of appropriate controls for minimising risk. The assessment was carried out initially in 1998 and has been reviewed annually (most recent 22 October 2007). (4.7.5)

Hindoli has implemented an Annual EHS Training Plan for workers, staff and contractors. A check of records confirmed training has been carried out to schedule. Records are held for individual workers, staff and contractors of participation in safety training as well as results of comprehension test. Mill records are held electronically. Participants who fail the comprehension test are re‐trained and re‐tested – if fail again they do not receive a “Safety Incentive”. The Estates hold comprehensive records in hard copy files for individual staff and workers. (4.7.6)

Hindoli has developed and implemented an Emergency Action Plan that covers the main emergencies that possibly may occur, including fire/explosion, natural disasters (flood and earthquake) and personal injury. The Plan includes an “Emergency Call Out List” and a “Site Evacuation Plan”. Most recent issue of Emergency Plan was 13 August 2008. Emergency Response Drills have been conducted recently at the mills and covered earthquake, first aid and chemical spill and at estates for fire. (4.7.7)

There are three first aid stations at each Mill that were adequately stocked when inspected. First Aid Kits are checked monthly and records are held on file. The clinic is on call twenty‐four hours, which is staffed by a Doctor and Paramedics. The Estates have first aid stations at the Office and Workshop. Mandors have been issued with first aid kits for use in the field. (4.7.8)

Red Cross Palembang has conducted formal First Aid training for 53 Mill employees in September 2007. The Company Doctor conducts refresher First Aid Training with most recent February 2008. Hindoli has provided first aid training for 107 Estate staff and workers on 27‐28 December 2007. Records are held for individual trainees. (4.7.9)

Hindoli maintains records of work related accidents. Sungai Lilin Mill has achieved zero LTAs for 1,503 days. Tanjung Dalam Mill has had zero LTAs for employees and contractors since start of construction as well as since commissioning in March 2005. Both mills were awarded Cargill Presidents Gold Award for Safety Excellence years 2006, 2007, 2008. Labour Ministry has awarded Sungai Lilin Mill "Zero Accidents Award" for 2007 for achieving 5,000,000 hours LTA free. At Sungai Pelepah Estate during 2008, one accident was recorded for a worker on 7 July 2008. Tanjung Dalam Estate has had zero LTAs during the previous twelve months. (4.7.10) Criterion 4.8: All staff, workers, smallholders and contractors are appropriately trained.

Hindoli has prepared an annual training plan (Training Master Plan FY08/09) for each Mill department that includes competency based training for staff, workers and contractors. The estates also have a documented Annual Training Plan 2008‐2009 for staff to Mandor level. Topics include all technical aspects of oil palm that are covered in SOPs. Hindoli has a documented programme for training of Estate workers, which is "on‐the‐job" instruction by Supervisors in the field with records held on file.

Hindoli has a Farmer Development Department that provides extension training to farmers on field practices, upkeep, pesticides and harvesting. Hindoli also provides training on scheme cooperative management. Records are held on file. Recent training was carried out between 24‐26 July for Best Management Practices with 89 smallholder attendees. (4.8.1)

Inspection confirmed up‐to‐date records were held of training and competency assessment of knowledge and skill held on file "SOP Test". Records held for individual operators and HR Dept on Personal Files. The estates



hold records of Technical Services Department training of staff to Mandor level. Records include Course Material and signature of Attendees. (4.8.2)

Hindoli’s Contractor selection process includes evaluation of competence and skill. Records of pre‐qualification checks are held on file.

All Contractors are required to undergo an induction process that includes safety training. Contractors used for transport of FFB are required to pass a safety checklist. Inspection of records confirmed the most recent training was held on 4 April 2008 for 5 contractors. (4.8.3) Criterion 5.1: Aspects of plantation and mill management, including replanting, that have environmental impacts are identified and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored to demonstrate continuous improvement.

Hindoli holds an approved AMDAL for the original scope of the project comprising a mill at Sungai Lilin, company owned estates and smallholder scheme. In 2004 a new AMDAL was prepared for the construction of an additional processing line at Sungai Lilin Mill and a new mill at Tanjung Dalam Estate.

The AMDAL public consultation process was held in March 2004 and included meetings at three local villages and with smallholders. The AMDAL preparation and consultation process was consistent with Government guidelines. The AMDAL for the expanded scope of Hindoli was approved on 14 May 2005 Number 285/KPTS/BAPEDALDA/2005. (5.1.1)

In March 2007, Hindoli prepared an Environmental Aspects and Impacts Register for implementation of an ISO 14001 Environmental Management System. This involved a review of all Hindoli’s existing operations and included consultation with local stakeholders for identification of environmental impacts. A risk assessment process was used to determine the significance of impacts within the property and externally, such as for transport of FFB and palm products. Environmental management programmes have been prepared and implemented for control and reduction of the significant impacts as part of continuous improvements.

Hindoli reports monthly to Senior Management on environmental performance. Hindoli reports bi‐annually to Government on AMDAL monitoring. The most recent RKL & RPL report was January‐June 2008. Review of documents confirmed reporting complies with AMDAL RPL requirements. (5.1.2)

In 2004 a new AMDAL was prepared for the construction of an additional processing line at Sungai Lilin Mill and a new mill at Tanjung Dalam Estate. (5.1.3) Criterion 5.2: The status of rare, threatened or endangered species and high conservation value habitats if any, that exist in the plantation or that could be affected by plantation or mill management, shall be

identified and their conservation taken into account in management plans and operations.

An appropriately qualified and experienced Ecologist from the Department of Forest Resources Conservation, Bogor Agricultural University (who conducted the HCV assessment at Hindoli Mukut area) has made an assessment of the possible presence of HCVs using the guidance of the Indonesian HCV Toolkit (2008).

Within the company owned estates, all of the land has been cleared, except for riparian buffer zones along the main rivers. This vegetation has previously been heavily logged and consists of secondary regrowth. HCV4 was assigned for the riparian buffer zones. The land adjacent to the estates is a mixture of smallholder oil palm, subsistence agriculture, small scale rubber and secondary regrowth. The assessment did not identify HCVs adjacent to the estates.

During the HCV assessment, 2 species of mammals, 23 species of birds and 1 reptile were recorded within and near the riparian buffer zones. Eight of the bird species are protected under Indonesian Law. Fieldwork observations have not recorded the presence of any endangered, rare or threatened species of fauna (IUCN or CITES) within or adjacent to the estates. (5.2.1)

Hindoli has implemented appropriate measures to protect the riparian reserves, such as awareness training and regular inspections to prevent hunting or disturbance. Hindoli initiated Awareness Training to all staff and workers on protecting fauna and riparian reserves commencing in January 2008 with further follow‐up training in August 2008. (5.2.2)

The actions taken to date are consistent with regulatory requirements. (5.2.3)

Hindoli has posted notices prohibiting the capture or hunting of fauna within the Estates, such as at muster areas. This requirement has been socialised to all staff and workers. Hindoli has posted signboards at public access points to the Estates and at the riparian buffer zones. (5.2.4)

The EHS Coordinator role includes responsibility for management of the riparian reserves and fauna protection. Regular monitoring has been implemented and is carried out by the Watergate operator during his inspection rounds. (5.2.5) Criterion 5.3: Waste is reduced recycled, re‐used and disposed of in an environmentally and socially responsible manner.

Hindoli has identified all waste and pollution sources and has set Waste Management Objectives and Targets that are detailed in the ISO 14001 Aspects and Impacts Register. (5.3.1)

Hindoli has implemented best practices for waste management and disposal. Rainfall runoff from the mill is separated from mill effluent, treated in sediment and oil traps and transferred to the final effluent ponds for settlement of suspended solids before discharge. Inspection confirmed significant improvements have been implemented since the Stage I Audit for the control



of solid wastes. For example, covers have been placed over drains to prevent material from affecting water quality. Solid wastes are separated at source into organic, inorganic, recyclables and B3 Hazardous Waste. EFB appears to be removed effectively from the mill area and applied to the field. Spill containment has been installed and there is good control of hazardous waste, such as spent lubricating oils. (5.3.2)

Hindoli has documented a Waste Management SOP for identification, separation, storage and disposal of wastes including hazardous materials (B3). A Work Instruction was displayed at each estate pesticide store for the cleaning (triple rinsing) of empty pesticide containers, storage and disposal. Inspection confirmed adequate supplies of labelled bins were available at all waste generation locations. Hindoli has built hazardous waste stores at each estate and mill and holds a Licence for the storage of hazardous waste, issued by Ministry for Environment, Jakarta, 15 August 2005 Licence No IZIN KEPMEN.175. Hazardous waste is removed by a licenced contractor PT Nirmala Tipar Sesama – licence number 612 of 2007. Records of the Hazardous Waste Manifests for Mills and Estates are held on file. (5.3.3)

Hindoli monitors the mill effluent discharge weekly, internally as well as by an external laboratory monthly for compliance. Records are held since the start of mill operation. The volumes of treated effluent are measured by flow meter and recorded daily. The Government has approved a 12 month trial for land application of treated mill effluent on 50 ha. If the trial is successful, Hindoli will apply for a permit for land application of treated effluent on 475 ha. This will enable cessation of effluent discharge off site. The mills record quantities of solid wastes that are recycled to the field or sold (EFB, nutshell, fibre and boiler ash). Records are maintained by means of a monthly stock take of the quantities of hazardous waste, such as spent lubricating oil and oil contaminated solid wastes generated by workshops and used pesticide containers. (5.3.4) Criterion 5.4: Efficiency of energy use and use of renewable energy is maximised.

Renewable and non‐renewable energy use are reported monthly as a Key Performance Indicator. A six year trend is available for Sungai Lilin Mill and a four year trend is available for Tanjung Dalam Mill. At Sungai Lilin Mill, 88% of energy consumption (Year to Date) is from renewable energy sources and the balance is from diesel fuel. The energy consumption rate at Sungai Lilin Mill was 19∙1 kwh/t FFB for renewable energy and 2∙51 kwh/t FFB for non‐renewable energy. (5.4.1)

Fossil fuel consumption is reported monthly as a Key Performance Indicator. The boiler is being used for longer operating times, eg Sundays to generate electricity and substitute renewable for fossil fuel. Diesel consumption has been reduced by 50% at Sungai Lilin Mill and 39% at Tanjung Dalam Mill since mid 2007 when this new policy commenced. (5.4.2) Criterion 5.5: Use of fire for waste disposal and for preparing land for replanting is avoided except in

specific situation, as identified in the ASEAN guidelines or other regional best practice.

Hindoli has implemented a Zero Burn Policy since the start of development. Replanting has not been carried out. The company has stated commitment to adhere to its Zero Burn Policy during future replant. (5.5.1)

No land preparation or replanting has been carried out at the Estates for at least 6 years. (5.5.2)

Hindoli has a documented Emergency Response Procedure for land burning. Records of fire outbreak are maintained in the Accident and Incidents Reporting System. (5.5.3)

Inspection during the audit confirmed adequate fire‐fighting equipment is located throughout the mill and at estate offices, stores and workshops and also at housing and is maintained in serviceable condition. Hindoli inspects fire‐fighting equipment monthly. (5.5.4) Criterion 5.6: Plans to reduce pollution and emissions, including greenhouse gases are developed, implemented and monitored.

All emissions have been identified and documented in the ISO 14001 Environmental Aspects and Impacts Register. Performance objectives and targets for control of emissions were revised 30 June 2008. (5.6.1)

Gaseous emissions to air and ambient air quality are measured twice yearly by Government Bapedalda Laboratory. Records of monitoring at Sungai Lilin Mill (19 June 2008) and Tanjung Dalam Mill (18 June 2008) show compliance with emission and ambient air quality limits. Mill effluent discharges are monitored weekly, internally as well as monthly sampling for compliance and analysis by both the internal and an external laboratory. Emissions from mobile plant and equipment and vehicles were measured on 20 June 2008. The results show all vehicles complied with the Government regulation for opacity (No 5 of 2006). Both mills measure river water quality quarterly both upstream and downstream of the mills. The results indicate no significant difference in measured water quality parameters between upstream and downstream samples. (5.6.2)

Inspection confirmed spill containment has been upgraded at petroleum hydrocarbon storage and use areas and operator training to take care and avoid spillage during refueling. Sungai Lilin Mill boiler automatic control system was repaired in July 2008. This controls automatic feeding of fuel to the boiler and overcomes variations caused by manual feeding. At both mills measures have been implemented to prevent solid wastes (boiler ash, fibre, nutshell and EFB) from entering mill drains and contaminating clean stormwater. Concrete bunkers have been constructed for storage of boiler ash and a protective strip concreted to prevent ingress to the monsoon drain. At the estates, sediment traps and oil traps have been installed on all point source discharges from workshops, refueling areas and diesel gensets. Inspection confirmed these were maintained in good operating condition. (5.6.3)



Hindoli has an SOP that describes the process for effluent treatment in anaerobic/aerobic pond system. The SOP also includes a description of effluent sampling procedure, recording and reporting of results. Hindoli carries out weekly sampling of mill effluent and an independent laboratory collects samples monthly for compliance. (5.6.4) Criterion 6.1: Aspects of plantation and mill management, 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.

Hindoli prepared a new AMDAL in 2004 for the expanded scope of the project (construction of a mill at Tanjung Dalam Estate). The AMDAL preparation included consultation with local communities in March 2004. Hindoli has supplemented the AMDAL information on positive and negative social impacts with information from a survey carried out by Hindoli Estate Department in April 2008 of stakeholders in surrounding communities involving a total of 510 respondents. (6.1.1)

Hindoli monitors and manages social impacts and issues at local communities through weekly meetings of its Farmer Development Department with smallholder cooperatives. When social issues arise they are discussed in this forum. Hindoli has compiled a social aspects and impacts register from the AMDAL, stakeholder survey and issues raised at Farmer Development Department meetings with smallholders.

Hindoli is involved in the "PROPER" programme conducted by Bapedalda annually for assessment of environmental and social impacts of oil palm on local communities. The company has been awarded "Blue" level of performance. Recent certification to ISO 14001 will take the company to the "green" level. (6.1.2)

There has been no significant change to the operational scope since expansion of the mill at Sungai Lilin and the new Tanjung Dalam mill that was commissioned in March 2005. (6.1.3)

EHS Department includes information from HR, Public Affairs and Farmer Development Departments on Community Development Programme as part of six monthly environmental report to Government.

Hindoli reports monthly to Top Management on environmental management and monitoring issues as part of the EHS Report (Mill Environmental Report). Review of documents confirmed Hindoli reports twice yearly the results of environmental monitoring of AMDAL requirements to Provincial Government and Ministry of Environment, Jakarta. (6.1.4)

Impacts related to the smallholders are included in the ISO 14001 Social Impacts Register. (6.1.5) Criterion 6.2: There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties.

Hindoli has a documented ISO 14001 Communication Procedure that has been socialised to staff. Local communities are involved in smallholder oil palm and Hindoli communicates regularly with their representatives through weekly meetings with the cooperatives. Hindoli maintains records of these meetings. Inspection of files confirmed records are held of communications. (6.2.1)

Hindoli has a list of Stakeholders that was updated 28/01/2008 and includes National, Provincial and Local Government contacts, Village Heads and Smallholder Cooperatives (KUD). (6.2.2)

Hindoli maintains records of requests for assistance from communities and the company’s responses. An example of an important issue being addressed is a request from the local community for assistance with control of dust on the main access road between Sungai Lilin Village and the Sungai Lilin Mill. Hindoli has used tankers to water the road during dry conditions but a more permanent solution is required. Hindoli has requested assistance from the District Government for sealing of the road but without success. Hindoli has approved a contractor to start the project by the end of October 2008, with completion scheduled for the end of the year. (6.2.3)

Hindoli has a dedicated Public Affairs and General Affairs Dept. for communication with local communities. (6.2.4) Criterion 6.3: There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties.

Hindoli has a documented system for dealing with complaints and grievances. This includes a Land Dispute Procedure, which has been implemented since the start of development. The Grievance Procedure has been communicated to all staff and workers. Interview of staff, workers and community representatives indicated awareness of the dispute resolution process. Smallholder Cooperatives indicated the weekly meetings with Hindoli were important for discussing and settling any issues. (6.3.1)

Hindoli Human Resources Department maintains records of complaints together with responses. Review of records confirmed issues are resolved locally by explaining the rules and regulations. Hindoli Public Affairs Department maintains records of complaints and grievances raised by external parties. (6.3.2)

Hindoli has an SOP “Ganti Rugi” for assessment and payment of compensation. The procedure requires involvement of local government and community representatives for identification and assessment for compensation and witnessing of payment. Information on compensation is publicly available. (6.3.3) Criterion 6.4: Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions.



The company has an SOP "PROSEDUR PEMBEBASAN LAHAN" for release of land. This is based on and is consistent with "Land Release Procedure of Team of Government". The procedure requires the involvement of local community and government representatives for identification of persons eligible to receive compensation, assessment of compensation and witnessing of payments. (6.4.1)

Hindoli holds records on "Ganti Rugi" file for all land acquired by the company since the commencement of the Hindoli development. The records include the identification of people eligible to receive compensation. (6.4.2)

The Procedure used for negotiating and the details of compensation settlements are held on file "Ganti Rugi" for all land acquired since the commencement of the Hindoli development. (6.4.3)

Hindoli holds records of all compensation payments including amounts, details of witness and photograph of recipient. (6.4.4) Criterion 6.5: Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages.

Human Resources Dept notifies all Mill and Estate Managers at the beginning of each year on the rate for "daily rate" work. Workers are advised verbally of the daily or piece rate at time of hiring. When a daily rated person moves to permanent employment, pay rates are advised in a letter of appointment. Staff are similarly advised of salary rates in letters of appointment. All new hires are provided with a copy of their employment contract. (6.5.1) Observation 5 – refer Section 3.2 Page 24 for details.

Working regulations are detailed in Collective Labour Agreement (CLA) and published in KKB booklet, a copy of which is provided to all permanent employees. Inspection of records and a sample of pay slips confirmed pay and conditions, such as overtime, are in accordance with, for example, Minister of Manpower Decree No Kep‐102/MEN/Year 2004 and the Agreement between Hindoli and the Labour Union (01 June 2008). (6.5.2) Observations 6&7–refer Section 3.2 Page 24 for details.

Interview of workers indicated the wages were sufficient to allow some savings to be made. However, they pointed out that being able to grow vegetables in small gardens near their houses was important for keeping living expenses down.

Inspection confirmed Hindoli provides a very good standard of housing for staff and workers as well as free electricity, water, elementary schooling, crèche, places of worship, medical facilities and additional benefit if treatment is needed at hospital. Water quality tests confirmed the treated water supplied to housing is suitable for domestic use. Recreation facilities at each estate include sports field and community hall. (6.5.3)

Contracts include a requirement to abide by labour laws (Government Regulation No 13 2003) and include a clause that Hindoli has a right to check contract compliance and to terminate the contract for failure to comply with labour laws. Clause 2 of the Attachment to the Contract includes a condition for termination of a Contractor "for violation of or failure to enforce applicable laws, rules, regulations, codes, ordinances". (6.5.4) Criterion 6.6: The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel.

Freedom of Association Statement is included in the KKB Agreement (October 2004) and the Company HR Policy 2006. All permanent workers are provided with a copy of the Collective Labour Agreement which details pay and conditions. (6.6.1)

Union Meetings are held at the General Office and represent all Departments. A Meeting was held in March 2008. Inspection of files confirmed Minutes of meetings are recorded. (6.6.2) Criterion 6.7: Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision and when not interfering with education programmes. Children are not exposed to hazardous working conditions.

Government legal minimum age is 18 years. Hindoli HR Department has issued a Policy Circular dated 15 May 2008 that prohibits the employment of any person under the age of 18 years. (6.7.1)

Details of new hires are forwarded to HR Department for screening/approval. Inspection confirmed records are held on file. Age is checked against National Identity Card. Children were not present at any of the field or mill workplaces inspected during the audit. (6.7.2) Criterion 6.8: Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation or age is prohibited.

An Equal Opportunities Statement is included in both the Cargill Corporate Policy (21 May 2007) and the KKB dated October 2004. (6.8.1)

Women employees confirmed during interview that they have equal opportunities for employment. For example, at the Estates women are employed as mini tractor drivers. Interview of three Labour Union Representatives indicated that discrimination has not been experienced. (6.8.2) Criterion 6.9: A Policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied.



A statement is included in the Global Cargill Policy available on website www.cargill.com that refers to prevention of all forms of discrimination. There is also a Cargill "Violence in the Workplace" Policy. In the Collective Labour Agreement (CLA) Chapter IX on work discipline there is a procedure for disciplinary action related to sexual harassment. (6.9.1)

A Policy is documented in CLA under the sub‐heading of maternity leave. Three months leave with full pay ‐ 1.5 months prior and following birth. Women are given a two hour paid breastfeeding period each day for a maximum of 12 months. Female employees are not obliged to work on day 1 & 2 of their menstruation. Women who are pregnant or breastfeeding are not permitted to work as sprayers but are transferred to alternative duties. Interview of staff and workers confirmed knowledge of the Policy and its implementation. (6.9.2)

Interview of women on staff confirmed they understood the Policy. Female fieldworkers were aware of the Policy and understood what action they should take if an instance of harassment occurred. (6.9.3)

Female staff and permanent workers fully understood the conditions relating to maternity leave and paid breaks for nursing infants. Fieldworkers interviewed indicated that they did not wish to carry on working in another job but to stay at home during the pregnancy. (6.9.4)

There is a documented Grievance Procedure ‐ Section 14.1 of the "Managers Guide on HR Policies and Procedures" 2004. Human Resources Department has provided training and socialisation to Managers and all permanent workers. Daily rated workers were aware of the Procedure. (6.9.5)

Hindoli does not have a specific Gender Committee. The audit team concluded that gender issues were well managed and female union representatives are able to raise issues of concern to Hindoli management. Criterion 6.10: Growers and mills deal fairly and transparently with smallholders and other local businesses.

The Smallholders FFB price is set twice monthly by a Committee consisting of Government, Palm Oil Producers and Smallholder Cooperative Representatives. Records are available on FFB prices and are held on file "Penetapan Harga TBS" for two years. Archived records are held indefinitely. (6.10.1)

The process for setting FFB prices is documented as a flow chart ‐ "Penetapan Harga TBS". KUD representatives participate in the team for determining prices, which meets twice monthly. (6.10.2)

Hindoli has an SOP for engagement of contractors that includes a pre‐qualification program, selection criteria and explanation of contract terms and conditions. Contracts are explained during pre‐qualification and the contractor signs acceptance of terms and conditions. Prior to commencing work contractors are required to undergo an induction process, which includes safety

requirements, emergency action plan, PPE and labour laws. Hindoli has contracts with individual KUDs that are signed by all members. (6.10.3)

Records of payments are held for the fruit supplied by individual farmer members of each KUD, based on deliveries to the Mills. Interview of contractors at the mills and KUDs confirmed that payments are made in a timely manner. (6.10.4) Criterion 6.11: Growers and millers contribute to local sustainable development wherever appropriate.

Hindoli has a requirement that all employees contribute 7 hours per year of their own time to work on community development projects. EHS Committee socialises information to local communities (more than 106 adults) on awareness for Malaria and Dengue Fever prevention. Community Development projects include construction of a market for three villages and donation of goats and an enclosure for a local orphanage. Another project involved building of 3 classrooms at C4 Plasma Village School. Estate staff provided labour to assist with construction and Hindoli provided all materials. (6.11.1)

Principle 7 – Assessed for Mukut Development

Criterion 7.1 A comprehensive and participatory independent social and environmental impact assessment is undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management and operations.

Hindoli commenced work in January 2008 on a new development of oil palm at a location known as Mukut (Figures 1 and 4) that is situated approximately 40km by river downstream from Sungai Lilin. The development will comprise approximately 9,800 ha of company estates, 2,204 ha of smallholder oil palm, a mill and support infrastructure. The development area is bordered by a transmigration area to the north‐east, recently planted oil palm to the north, and land used for small scale agriculture to the west and the south.

Hindoli commissioned the preparation of an AMDAL in 2005 and received government approval in May 2006. The AMDAL was prepared by an accredited AMDAL consultant and included consideration of both negative as well as positive social and environmental impacts. The scope of the AMDAL included assessment of impacts associated with land development, infrastructure, road access, mill operations and transportation. The AMDAL included assessment of the suitability of soils, topography and drainage and analysis of the landcover vegetation. The AMDAL assessed the impacts on natural ecosystems and water resources. Although the AMDAL did not assess HCVs, Hindoli carried out a separate HCV assessment study in March 2007 by an appropriately qualified and experienced team comprising an Ecologist and a Social Scientist from Department of Forest Resources Conservation, Bogor Agricultural University. The HCV assessment collected additional information from local communities on environmental and social



aspects related to their use of resources of the Mukut development site.

The AMDAL preparation process involved a social survey at the communities likely to be directly affected by the project. The survey involved the interview of local people to collect information on the background of the respondent and also to seek the respondents’ views on the project as well as respondents’ suggestions.

The AMDAL included assessment of current land resources use, land ownership and user rights and potential social impacts. Subsequent to the preparation of the AMDAL, Hindoli has commenced a programme to socialise information to the local communities on the project and to receive feedback. This started with a meeting in November 2007 between Government, 21 representatives of local villages and Hindoli, prior to land development. Hindoli staff have held follow‐up public meetings at each of the villages. Hindoli recorded information on meeting attendees, topics discussed and issues raised. Hindoli has used information from the AMDAL, the HCV assessment and information from stakeholder meetings to prepare a list of social and environmental aspects and impacts. This is included in the scope of the ISO 14001 Environmental Management System and will be updated annually. (7.1.1)

Hindoli’s AMDAL consultant prepared an RKL/RPL that was approved by the Government in May 2006. The RKL/RPL is considered appropriate for the project. Hindoli has documented SOPs for implementing the new development that draw upon the collective experience of Cargill’s group of oil palm companies in Indonesia and Papua New Guinea. Inspection of field conditions confirmed that the land development was being carried out in accordance with the management plan. Observation of tasks and interviews of staff and workers during the audit confirmed that the SOPs for new land development were being implemented. (7.1.2)

Hindoli has not yet commenced land development for the Mukut smallholders. Hindoli has stated its commitment to a smallholder scheme and that it will maintain detailed records, as required by relevant laws. Hindoli has experience in development and operation of a very successful smallholder scheme associated with its existing estates and will implement the same scheme at Mukut. (7.1.3) Criterion 7.2: Soil surveys and topographic information are used for site planning in the establishment of new plantings, and the results are incorporated into plans and operations.

Hindoli engaged JH Agricultural Services in March 2005 to conduct a soil survey and assess the suitability of the land for oil palm. The land at the Mukut development area is flat. The soil survey involved soil examinations at 200 m intervals along a pre‐determined sampling grid. In addition, the soil profile was sampled at 150mm intervals to 900mm depth at 2km intervals along the sampling grid.

Three soil types occur in the expansion area – marine clay, brackish water deposit and peat. The dominant soil

is marine clay that occurs mainly on the eastern half of the expansion area. It has dark brown organic rich topsoil underlain by deep brown to greyish‐brown subsoil with a silty clay texture to a depth of more than 600 mm. The subsoil changes to structureless, silty clay below 600 mm depth. The marine clay is acidic with mean soil pH of 4∙38 for the topsoil, 4∙08 for the subsoil and 3∙85 below 600 mm depth.

The soil derived from brackish water deposit occurs on most of the remainder of the expansion area and is underlain by marine clay. The topsoil consists of black to dark reddish‐brown clay loam overlying dark brown‐brown subsoil with clay to silty clay texture. Below 600 mm greyish‐brown, structureless silty marine clay occurs. Both the topsoil and subsoil are acidic with pH ranging from 3∙94 near the surface to 3∙09 at depth.

Shallow peat soils occur in the north‐west portion of the expansion area. Peat soil to a depth of 2 m occurs on an estimated 87 ha, adjacent to shallow peat soil to a depth of 500 mm overlying marine clay that occupies approximately 462 ha. Hindoli will not develop the land where peat soils occur, but will set aside all of this area as a conservation reserve.

The soils of the expansion area are rich in plant nutrients with high levels of total nitrogen ranging from 0∙17% to 0∙56%. Exchangeable potassium and magnesium are very high with typical values of 0∙5 meq/100 g. Soil available phosphorous is moderate to high with values up to 40 ppm. The survey concluded that the soils are well suited to oil palm, although the land would need to be drained and the water levels managed.

Potentially Problematic Soils

The soil survey reported that approximately 25% of the sampling sites in the southern half of the area exhibited salinity in the 300–450mm interval of the depth profile (subsoil). The report stated that drainage in the southern half of the development area will need to be carefully managed in order to reduce surface soil salinity. This will involve allowing rainfall to flush salt from the soil profile immediately following rainfall and to prevent tidal inflow of saline water.

The soil survey also included laboratory tests of soil samples to assess the presence of potential acid sulphate soils. The results showed the upper half of the soil profile had low sulphur content. The sulphur content was elevated only at the bottom of the soil profile (in the 750–900mm interval) in the samples at the south‐east corner of the property. The survey concluded there was a low risk of oxidation of sulphides, provided that water levels were managed using the practices that have been implemented for similar soils in Malaysia.

Hindoli has prepared a land development plan that takes into account the information on soil suitability and drainage of the land. The plan includes the progressive installation of watergates for controlling the water level and flow of drainage from the cleared land. The plan has excluded the area of peat soils from development for set aside as conservation reserve. (7.2.1)



Inspection of plans and a walkover of the site during the audit confirmed that development carried out to date has been in accordance with the land development plan. This includes progressive installation of drainage and watergates to control water flows and water table depth. (7.2.2)

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

The land which Hindoli is developing to oil palm was originally planned as a transmigration project. Canals were excavated to provide access and to drain the land. After the initial development in the early 1980s, the land was abandoned due to the low pH of the soil. Fieldwork by Hindoli staff and the team that prepared the AMDAL reported that the original forest of the development area had been heavily degraded and that Gelam (Melaleuca leucadendron) covered most of the land.

The AMDAL preparation process did not include a formal assessment of HCVs. As stated for Indicator 7.1, in March 2007, Hindoli arranged for an appropriately qualified and experienced Ecologist and a Social Scientist from the Department of Forest Resources Conservation, Bogor Agricultural University, to assess the presence of HCVs at and near the new development site. The assessment followed the guidance of the Indonesian HCV Toolkit (2003) and used a 2005 Satellite image to provide information on land use and landcover. The preliminary assessment using published information, maps of the area and satellite images indicated that Biological HCVs were unlikely to be present at the proposed Mukut development site.

Fieldwork was carried out to collect site‐specific information for assessment of the presence of biological and social HCVs at or adjacent to the Mukut site. At the start of fieldwork, meetings were held with representatives of the two local communities Penuguan and Mukut. In addition, households were surveyed and information was collected on local peoples’ use of the natural resources of the Mukut site, sources of income, knowledge of fauna and the possible presence of sites of cultural significance. Local people were hired as guides and assistants during fieldwork.

The field survey found that Gelam covered approximately 80% of the development area. The condition of the gelam forest was poor, with very few trees, but many in the pole and sapling sizes. Dense stands of gelam occur in the wetter areas, as indicated by the “dark green” areas on Figure 4 and sparse open areas are indicated by “light green”. Secondary regrowth and heavily degraded swamp forest affected by fire occurred on the remainder of the area. Local people indicated that sections of the forest were burned during the dry season.

A narrow strip of Nipah Palm (Nypha fruticans) dominates the tidal reaches of Sungai Mukut and a mixture of secondary regrowth and degraded swamp forest occur immediately inland from the streambank.

Local people harvest Nipah Palm fronds for use as roofing for houses. There has been significant disturbance of the riparian vegetation along Sungai Mukut.

Fauna were surveyed by direct observation along transects and during habitat searches. Information on fauna also was obtained by interview of local people. The total number of species of wildlife recorded at the Mukut site was 5 mammals, 35 birds and 9 herpetofauna. The low numbers of individuals of species and the low diversity were concluded as due to the heavily degraded condition of the habitat. Species numbers were least at the gelam habitat and comprised 4 mammals, 19 birds and 7 herpetofauna. The survey recorded ten species protected under Indonesian Law within the Mukut development site (1 mammal and 9 birds) but none was classified as endangered, rare or threatened by the IUCN Red List. The exceptions were the Sambar deer Cervus unicolour and the Bearded wild boar Sus barbatus, which are classified as vulnerable (IUCN, 2007) due to population trends decreasing.

The land neighbouring the Mukut development site consists of a transmigration area along the eastern boundary, new oil palm development along the northern boundary and rice paddy to the south near Sungai Calik. The land immediately west of Sungai Mukut has been cleared for subsistence agriculture. Although the 2005 satellite image (Figure 4) shows vegetation immediately to the north of the Mukut site, this was cleared and developed to oil palm in 2006. The survey concluded that HCVs were not present at areas adjacent to the Mukut site. The survey assigned HCV4 to riparian vegetation along Sungai Mukut and at the peat soil area.

Consultation with local residents of Penuguan and Mukut dusuns did not identify the presence of any cultural sites within the Mukut development site. Local peoples’ main sources of income are rice paddy and fishing along Sungai Calik.

The survey concluded local people made limited use of and were not dependent on the natural resources within the concession and that social HCVs were not present. However it noted that protection of water quality was an important issue for minimising impact on the downstream fishery and tidal wetlands that occur in the lower reaches of Sungai Calik.

The HCV Management Plan included a number of specific actions for maintenance and possible enhancement of the riparian HCVs. The main threats to the HCVs were identified as: damage caused by inadequate control during land clearing; hunting associated with improved access to the development area, and outbreak of fire.

The management strategy included: careful measurement, marking of boundaries and control of contractors during land clearing; prevention of hunting; awareness training of Hindoli staff, workers and contractors; consultation and awareness of local communities and local government.



Figure 4: Mukut New Development



The HCV Monitoring Program recommended periodic inspections of the buffer zone boundaries to check for any disturbance or encroachment; keeping records of fauna observations; recording any incidents of fire; and water quality sampling of the drainage from the site and Sungai Mukut. Follow‐up visits by the ecologist also were recommended to collect additional site‐specific data. (7.3.1)

Hindoli has prepared a map (Figure 4) that identifies the Sungai Mukut riparian buffer zone and the area of peat soil that will be set aside from development. Field inspections during the audit confirmed that Hindoli land development to date was consistent with the plan. Checks confirmed that the 50 m wide riparian buffer strip was greater than that required for the size of the stream(<10 m width). Signs were posted at the estate boundary and access points through the buffer zone to prohibit hunting, felling of trees and lighting of fire.

Interview of staff, workers and contractors indicated awareness and understanding that their employment would be terminated if they contravened Hindoli environment policy. Interview of local people at Penuguan and Mukut Villages confirmed that Hindoli had conducted awareness meetings in relation to protection of fauna habitat and prevention of fire. Hindoli has implemented water sampling to check the quality of drainage from the development site. The audit team concluded Hindoli actions are consistent with the HCV Management Plan (7.3.2) Observation 8 – refer Section 3.2 Page 24 for details.

The Ecologist from the Department of Forest Resources Conservation, Bogor Agricultural University who conducted the HCV Assessment in March 2007, made a follow‐up visit to the Mukut new development site in the first week of October 2008. His site visit report recorded that he inspected the vegetation along the boundaries of the land development carried out to date and confirmed the presence of gelam throughout the area. He interviewed staff and workers at the site and concluded they were aware of the Hindoli policies on fauna and flora protection and prevention of fire.

The Bogor Agriculture University Ecologist also inspected the peat soil area at the north‐west of the Mukut site. Secondary Swamp Forest occurs on part of the 549 ha peat soil area that will be set‐aside for conservation. The Ecologist observed the presence of Lesser adjutant (Leptoptilos javanicus) (IUCN Vulnerable), which appeared to be attracted by the opening up of the area and were feeding at recently constructed drainage canals at the development area.

The Bogor Agriculture University Ecologist has updated the Mukut HCV Management Plan to include additional measures related to the peat soil conservation areas. These include:

Field survey to map the boundaries of the Secondary Swamp Forest at the peat soil area;

Detailed field survey of fauna populations at the Secondary Swamp Forest and; and

Planting of trees to enhance the riparian buffer zone.

Observation 9 – refer Section 3.2 Page 24 for details.

Criterion 7.4: Extensive planting on steep terrain, and/or on marginal and fragile soils, is avoided. The soil survey identified the occurrence of shallow peat soil at the north‐west area of the property (Figure 4). Hindoli will not develop any peat area to oil palm but will set aside this area as a conservation reserve. The peat soil area occurs as a strip adjacent to Sungai Mukut and is subject to tidal influence. The peat soil area will remain hydraulically connected to Sungai Mukut and the daily high tides will maintain water levels. In addition, Hindoli will construct an earthen bund along the eastern boundary of the peat area to provide separation from the new development area and in order to maintain the natural hydraulic gradient and drainage towards Sungai Mukut. Hindoli considers that these actions should maintain water levels at the peat soil area.

The soil survey identified the occurrence of salinity in subsoil (300‐450 mm depth) of approximately 25 % of samples in the southern half of the property. The soil survey also identified the occurrence of potential acid sulphate soil at the bottom of the soil profile (750‐ 900 mm) at the south‐eastern portion of the property. The identification of potential acid sulphate soil was based on laboratory analysis of the total sulphur content of the soil. Hindoli has prepared maps identifying the location of these potentially problematic soils. (7.4.1)

Hindoli has prepared a water management plan including details of drainage and the locations of watergates for controlling water levels. The plan aims to maintain the water level in drains at between 500mm and 600 mm below the ground surface, in order to enable rainwater infiltrating the soil to flush salinity from the upper section of the soil profile. At the same time this also would maintain a water cover over the bottom of the soil profile and minimise the oxidation of potential acid sulphate soil that occurs at depth (750 ‐ 900 mm).

Inspection during the audit confirmed the development work carried out to date at the south‐western portion of the property was consistent with the water management plan. Drains had been excavated and Watergates were being constructed. As an interim measure, the water levels of drains were controlled by means of earthen bunds. Hindoli Technical Services Department has implemented a water sampling program for testing the quality of drainage discharged from the site. Review of water sampling results showed the average pH of water draining from the development area was pH 4.9 and was similar to baseline sampling of Sungai Mukut (pH 5.1) in October 2007, prior to development. (7.4.2)

A Nonconformity was assigned against Minor Compliance Indicator 7.4.2 – refer Section 3.2 for details. Criterion 7.5: No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a documented



system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions.

As detailed for Criterion 7.1, the AMDAL included assessment of both negative as well as positive social and environmental impacts. The AMDAL preparation process involved a social survey at each of the two communities affected by the project. The survey involved the interview of local people to collect information on the background of the respondent and also to seek the respondents’ views on the project as well as respondents’ suggestions. In addition to the AMDAL, Hindoli carried out a separate HCV assessment in March 2007. The HCV assessment collected complementary information from local communities on environmental and social aspects related to their use of resources of the Mukut development site, as well as potential impacts.

Hindoli initiated a programme for socialisation of information on the proposed oil palm development on 13 November 2007 at a meeting that was led by local government and involved 21 representatives of Desa Mukut and Desa Penuguan. Follow up public meetings were held at Desa Mukut on 7 March 2008 and at Desa Penuguan on 14 April 2008. Hindoli has made records of the meetings including list of attendees, points of discussion and issues raised.

Hindoli has used information from the AMDAL and the stakeholder meetings to prepare a list of social and environmental aspects and impacts. This is included in the scope of the ISO 14001 Environmental Management System and will be updated annually. The audit team concluded the SEIA meets the participatory requirement. (7.5.1)

When interviewed during the audit, local people remembered clearly the socialisation meeting on the EIA and the oil palm development, especially Hindoli policy at the development area of no burning and no cutting of wood along Sungai Mukut. (7.5.2) Observation 10 – refer Section 3.2 for details. Hindoli has recently paid for the acquisition of community land owned by Desa Penuguan and Desa Mukut. The payment process involved payments as follows: (1) payments to individual persons eligible for compensation; (2) payments to the authorised agents of persons eligible for compensation; and (3) payments from the authorised agent to persons eligible for compensation. Hindoli made detailed records of the payment process including documents signed by the recipient and witnessed by the Village Secretary and a photograph of the person receiving the money, together with the Village Secretary as witness. The records include payments from the authorised agents to the individuals eligible to receive compensation. (7.5.3) Observation 11 – refer Section 3.2 Page 24 for details. Criterion 7.6: Local people are compensated for any agreed land acquisitions and relinquishment of rights, subject to their free, prior and informed consent and negotiated agreements.

The land at the Mukut development site is classified as government land that is controlled by the village. A Government Officer at the BPN Banyuasin Office confirmed that since the issuance of the Decree of Local Government in 1979 all land including that at Mukut is regarded as government land.

Prior to the acquisition by Hindoli, the land within the Mukut development site was not occupied as it was unsuitable for crops and local people used arable land closer to the village.

Hindoli holds records of the process carried out for identification and assessment of customary and legal rights. The land survey was carried out by a Government Team of Banyuasin Regency, comprising representatives from Forestry and Plantation Office, BPN Banyuasin, Bapedalda District Office, District Government Secretary, District Transmigration Office, Sub‐district Head and Village Head. The team visited the Mukut development site and Penuguan and Mukut villages on three occasions for public meetings with local people. (7.6.1)

Hindoli has a documented SOP “SOP Pembebasan Lahan” that includes a process for identifying people eligible to receive compensation. This SOP was implemented for the compensation assessment process at Mukut. (7.6.2)

Inspection during the audit confirmed Hindoli holds records of the meetings involving the Government Team and Village representatives for the process of negotiation and settlement of compensation for the land acquisition. (7.6.3)

The Government Team that identified and assessed customary and legal rights to the land also calculated the amount of compensation for the land. Inspection of records during the audit confirmed Hindoli holds documentation for the calculation of compensation and records of the payments, as described for Indicator 7.5.3. (7.6.4)

Hindoli gives preference to local people for employment at the Mukut development. Hindoli will develop a Plasma Scheme comprising 2,204 ha of oil palm for “eligible” local community residents. When interviewed during the audit, Penuguan Village Head stated that only persons holding a SPH Certificate will be eligible to receive Plasma oil palm. However, interview of long‐term local residents indicated they are unable to afford the fee for issue of an SPH and were concerned that they would not receive an allocation of plasma. (7.6.5) A Nonconformity was assigned against this minor compliance indicator – refer Section 3.2 P23 for details

Hindoli has not yet received any claims for compensation related to the Mukut development. Hindoli Policy is to document compensation claims and to make the information publicly available. (7.6.6) Criterion 7.7: Use of fire in the preparation of new plantings is avoided other than in specific situations, as identified in the ASEAN guidelines or other regional best practice.



Hindoli has a documented zero burn policy that is stated in the SOP Land Development. Inspections during the audit confirmed that fire has not been used for land clearing. (7.7.1)

Hindoli has implemented a system of monthly inspection of the development area and reporting to senior management. (7.7.2)

Hindoli has implemented a site specific emergency response procedure for responding to land burning. If a fire outbreak was to occur, this would be recorded and reported through the Accident/Incident Reporting System. (7.7.3)

Inspection during the audit confirmed that Hindoli has implemented appropriate facilities for controlling fire outbreaks. These include the construction of watchtowers and use of lookouts to provide early warning of fire outbreak. Fire fighting equipment includes several water tankers and portable pumps. (7.7.4) Criterion 8.1: Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations.

Hindoli’s Program Assurance three year plan describes an Action Plan for reduction in waste, pollution and emissions to the environment and improvements of environmental and social impacts. The Plan is an important component of the ISO 14001 EMS and will be reviewed and updated annually. Examples of improvements are outlined below.

Environment has seven actions for improvements, such as, the Sungai Lilin Mill effluent pond system is being extended to provide increased retention time and improvement of water quality of the discharge.

There are eighteen action items related to waste reduction, such as, land application system is being implemented for disposal of treated mill effluent from Tanjung Dalam mill.

There are five action items related to reduction of greenhouse gas emissions, such as, application of smoke opacity meter to detect incomplete combustion of fuel in boiler.

There are four action items related to minimising social impacts, such as, to undertake three yearly survey and assessment of social impacts among local communities. (8.1.1)

Significant improvements have been made since the Stage I Assessment carried out in February 2008. For example, management of EFB has been improved by better communication between the Mills and Estate Department for scheduling of transport. (8.1.2)

3.2 Detailed Identified Nonconformities, Corrective Action and Auditor Conclusions

Two (2) Nonconformities were assigned to Minor Compliance Indicators. The Nonconformities are summarised below:

Indicator 7.4.2: A soil survey has identified potential acid sulphate soil to occur at the Mukut new development area. The location of this potentially problematic soil is at the south‐eastern portion of the Mukut property, which has not yet been disturbed, but is planned for development in 2012/13.

The soil tests carried out used the total sulphur content of the soil samples to identify the possible presence of acid sulphate soil. Further testing has not been carried out to determine whether the soil contains reactive sulphides, or a benign form of sulphur. Although this potentially problematic soil occurs at depth and a Water Management Plan has been prepared that is based on proven practice in Malaysia, the available information indicates this soil type occurs on approximately 2,000 ha of land at Mukut. A Nonconformity was assigned against this minor compliance indicator as the development of 2,000 ha of potential acid sulphate soil is considered as “extensive” and contravenes the Guidance “Planting on extensive areas of peat soils or other fragile soils should be avoided.” Corrective Action Hindoli has prepared a Corrective Action Plan for addressing the identified nonconformity and is detailed below. The 2000ha area concerned is located in the South East of Mukut which has not been disturbed and won’t be scheduled for clearing until 2012/2013. Hindoli will leave this area untouched until more detailed and concrete information on the soil are obtained.

Hindoli will carry out additional new sampling and testing on the soil to determine whether or not the contained sulphur is reactive.

Hindoli will conduct a more detailed soil sampling grid to provide better definition and information on the location and boundaries of this potential problematic soil.

BSi has reviewed and accepted the Corrective Action Plan. BSi will check progress at the Surveillance Audit scheduled within 12 months of the RSPO approval of the initial certification.

Indicator 7.6.5: Hindoli gives preference to local people for employment at the Mukut development. Hindoli will develop a Plasma Scheme comprising 2,204 ha of oil palm for “eligible” local community residents. The Village Head has stated that only persons holding a SPH Certificate will be eligible to receive Plasma oil palm. However, interview of local residents indicated they are unable to afford the fee for issue of an SPH.

A Nonconformity was assigned against this minor compliance indicator as this situation discriminates against those long‐term residents who are unable to afford the fee being charged by the Village Head for an SPH.



Corrective Action

Hindoli has prepared a Corrective Action Plan for addressing the identified nonconformity and is detailed below.

To ensure no discrimination against those long‐term residents who are unable to afford the fee for an SPH:

1. Hindoli will work together with local authorities (Camat, Kades, Disbun) to define the ‘eligibility’ of residents of Mukut and Penuguan that potentially participate in Plasma project and also devise a plan to ensure it is affordable to eligible residents. (Target Completion November 30 2008)

2. Socialisation of the eligibility and the benefit of Plasma scheme to local ‘eligible’ residents. (Target Completion January 31 2009)

3. To prepare a record / list of interested eligible residents of the Plasma project. (Target Completion April 30 2009)

4. To submit a proposal and the complete list of eligible long‐ term residents to Govt. authorities (Bupati) for development of the Plasma scheme. The Bupati will have the final decision on who is ‘eligible’ to participate in accordance with existing regulations. (Target Completion May 31 2009)

BSi has reviewed and accepted the Corrective Action Plan. BSi will check on progress at the Surveillance Audit scheduled within 12 months of the RSPO approval of the initial certification.

Observations/Opportunities for Improvement

Eleven (11) Observations/Opportunities for Improvement were identified:

1. (2.2.1) The Hindoli HGU is still in process. Hindoli has followed the correct administrative processes and has met all legal requirements for granting of an HGU but as yet is still waiting for the process to be completed.

2. (2.2.3) Hindoli is attempting a negotiated settlement of the land claim at Sungai Pelepah Estate that is described at Indicator 2.2.3 on Page 10. The claimants and Hindoli have met and agreed (27 August 2008) on a settlement that has yet to be approved by Hindoli Head Office. If settlement of the amount agreed upon at the 27 August meeting does not proceed, the dispute will be referred to an independent Government body on land dispute resolution.

3. (4.3.2) Groundcover vegetation needs improving on harvesting roads at some areas where mechanical infield collection is used. This appears be related to unnecessary spraying of vegetation on harvesting roads.

4. (4.4.1) Sungai Dawas buffer zone is on local people’s land and Hindoli does not have control over activities within the buffer zone. There is an opportunity for Hindoli to socialise information on buffer zone protection to the local communities for encouragement of buffer zone protection.

5. (6.5.1) Interview of female field workers indicated that the loose fruit collectors do not understand the deductions from their pays as they do not receive individual pay slips.

6. (6.5.2) In December 2007during peak crop at Sungai Lilin Mill there were three instances of overtime worked in excess of the allowable limit

7. (6.5.2) Long term contracted female fieldworkers are not aware they have to carry out the same duties for three months before being offered permanent positions. Hindoli is in the process of implementing a programme to promote long term daily rated workers to permanent status.

8. (7.3.2) The water quality sampling program provides detailed information on the composition of drainage from the land development site but does not include a “Reference or Control Site” on Sungai Mukut that is unaffected by the Hindoli activities. Additional sampling sites should be located on Sungai Mukut upstream of the land development (near the peat soil area) and downstream near the junction with Sungai Calik. Samples should be collected at low tide to ensure the water being sampled is unaffected by tidal inflow.

9. The Bogor Agriculture University Ecologist has discussed the updated HCV Management Plan with Hindoli Senior Management who have agreed with the following recommendations:

Field survey to map the boundaries of the Secondary Swamp Forest at the peat soil area;

Detailed field survey of fauna populations at the Secondary Swamp Forest and; and

Planting of trees to enhance the riparian buffer zone.

10. (7.5.2) Interview of local community members indicated that the understanding of the Plasma scheme by Desa Penuguan people was relatively good but at Desa Mukut the scheme was not well understood. Hindoli has stated its commitment to conduct additional socialisation at Desa Mukut to improve local people’s understanding of the oil palm development and the Plasma Scheme.

11. (7.5.3) Hindoli had made records of the payments for acquisition of community land as follows: (1) payments to individual persons eligible for compensation; (2) payments to the authorised agents of persons eligible for compensation; and (3) payments from the authorised agent to persons eligible for compensation. The records were found to be incomplete for some of the agents, as the payments from the agent to the individuals had not been documented. Hindoli has stated its commitment to contact each of the individual eligible persons to confirm that they have received payment in full for the land that was released and to complete the documentation.



3.3 Noteworthy Positive Components

Hindoli’s IPM program has resulted in the reduction of use of chemicals for pest control. The Barn Owl population has been built up to a level where it now provides effective control of rats and the use of rodenticides was ceased in early 2008.

Plate 1: Barn Owl (Tyto alba)

Hindoli has an excellent safety record at Mills and Estates with zero LTAs at both Mills since 2004. The graph below shows the number of Medical Aids (MA), Lost Time Accidents (LTA) and Lost Days (LD) at Sungai Lilin Mill. This is an outstanding achievement and provides leadership for the industry on the implementation of safe work practices and management systems.

0

20

40

60

1999/00 2001/02 2003/04 2005/06 2007/08

MA LTA LD

Figure 5: Summary of accident statistics for Sungai Lilin Mill 1999 – 2008.

Hindoli has a very good standard of housing for its staff and workers, including community and recreational facilities.

The company allows residents to have vegetable gardens at the rear of their houses provided they are kept neat and tidy. This is beneficial in providing a supplement to family incomes.

Plate 2: Vegetable Gardens at rear of Houses

Hindoli has developed highly successful Smallholder oil palm under PIR‐Trans Scheme with overall average yield of 26∙9 t/ha in 2007. One Cooperative won the Indonesian President’s Award for the best Smallholders in Indonesia in 2003. Hindoli partnership program has made Smallholder oil palm successful and profitable ‐ most have built brick houses and some have purchased trucks for transporting FFB to the mills.

3.4 Issues Raised by Stakeholders and Findings with Respect to Each Issue

Stakeholders did not provide any comments in writing in relation to Hindoli’s environmental and social performance. Stakeholders interviewed had mostly positive comments about Hindoli.

Contractors

Some contractors had worked with Hindoli for more than 10 years and did not raise issues.

Smallholders

Smallholders did not raise any issues of concern.

KUD Cooperatives Office

Cooperatives did not raise any issues of concern.

Local Communities

Residents along the access road to Sungai Lilin Mill complained about dust and the poor state of the road.

Hindoli Response: Although this is a government road, Hindoli is prepared to repair and resurface the road, but have been waiting for the government to agree to carry out regular road maintenance. Hindoli has funding approved in the 2008/09 budget and will proceed with repair and resurfacing of the road irrespective of whether the government agrees to regular maintenance. In the interim, Hindoli uses a water tanker control the dust during dry periods.



The BSi Audit Team considered this to be an appropriate response and will check on progress at the surveillance audit.

Government Departments

The Bapedalda and the Labour Office confirmed there were no outstanding compliance issues.

The District Agriculture and Forestry Office and the District BPN confirmed the HGU application was in the final stage of the process and waiting for Jakarta BPN Office to issue approval.

NGOs

The NGOs contacted did not raise any issues in relation to PT Hindoli.

3.5 Acknowledgement of Internal Responsibility

PT Hindoli acknowledges and confirms acceptance of the Assessment Report contents, including assessment findings. PT Hindoli accepts the responsibility for implementing the corrective actions and addressing the opportunities for improvement detailed in the Assessment Report.

3.6 Formal Sign‐off of Assessment Findings

Signed for on behalf of BSi Management Systems Singapore Pte Ltd

.............................................................. Mr Charlie Ross Lead Auditor Date: 15/10/2008

Appendix “A”

Hindoli RSPO Certificate Details

PUBLIC SUMMARY REPORT CERTIFICATE DETAILS


PT Hindoli Certificate Number : SPO 537874

Po Box 1071 Certificate Issue Date: (RSPO Approval Date) Palembang 30755 Sumatera Selatan INDONESIA

Website: www.Cargill.com Standards: RSPO Principles & Criteria : 2007; Indonesian National Interpretation : 2008

Sungai Lilin Palm Oil Mill and Supply Base

Location Sg Lilin, Muba , Sumatera Selatan. INDONESIA

Address PT Hindoli, PO Box 1071, Palembang 30755, Sumatera Selatan, INDONESIA

GPS E 104° 7’ 41∙67” S 2° 36’ 46”

CPO Tonnage Total Production 101505

PK Tonnage Total Production 25481

Company Estate FFB Tonnage Sg Tungkal 78214 t, Sg Pelepah 65558 t

Smallholders FFB Tonnage* 318626 t

CPO Tonnage Claimed** 31544 t

PK Tonnage Claimed** 7519 t

Tanjung Dalam Palm Oil Mill and Supply Base

Location Tanjung Dalam, Muba, Sumatera Selatan, INDONESIA

Address PT Hindoli, PO Box 1071, Palembang 30755, Sumatera Selatan, INDONESIA

GPS E 103° 56’ 38∙4” S 2° 32’ 58∙56”

CPO Tonnage Total Production 52616

PK Tonnage Total Production 15769

Company Estate FFB Tonnages Tanjung Dalam/Sri Gunung 90,617 t

Smallholders FFB Tonnage* 150091 t

CPO Tonnage Claimed** 19800 t

PK Tonnage Claimed** 4603 t

* Smallholders Tonnage not included in Certificate

** The tonnage claimed is the proportion of the total production from Company Estates

Appendix “B”

Certification Assessment Plan

PUBLIC SUMMARY REPORT CERTIFICATION ASSESSMENT PLAN


AUDIT TEAM – CR: Charlie Ross RR: Robyn Ross IN: Iman Nawireja

(Miss Dini Harmita to accompany Robyn Ross as Interviewer)

DATE TIME ACTIVITY CR RR IN

Sunday Aug 31

Travel Jakarta – PalembangTravel Palembang Airport to Hindoli Team Prepare for Audit

√

√

√

Monday Sep 01

AM

Prepare for Opening Meet/Opening MeetingPhysical Inspection Sungai Lilin Mill, Interview Mill Workers, Contractors Inspect Housing, Interview Residents and Clinic Staff

√ √ √

√

√ √

PM Documentation Review, Monitoring DataInterview Female Office Staff Interview Smallholders

√

√ √

√

Tuesday Sep 02

AM

Pick‐up from GuesthousePhysical inspection Sungai Lilin Estate & Work Tasks (ie Harvesting, Spraying, Upkeep, Fertiliser Application, Buffer Zones, Stores, Workshop, etc) Interview Female Field Workers Inspect Housing, Interview Residents and Clinic Staff Documentation Review (ie Worker Contracts, Pay & Conditions, External Stakeholders Communications)

√ √

√ √ √

√ √

PM Documentation ReviewInterview Female Office Staff Interview External Stakeholders, Local Community

√

√

√

Wednesday Sep 03

AM

Pick‐up from Guest House travel Tanjung Dalam EstatePhysical Inspection Tanjung Dalam Estate & Work Tasks (ie Harvesting, Spraying, Upkeep, Fertiliser Application, Buffer Zones, Stores, Workshop, etc) Interview Female Field Workers Inspect Housing, Interview Residents and Clinic Staff Interview External Stakeholders ‐ Local Communities

√ √

√ √ √

√ √

PM Documentation ReviewInterview Female Office Staff Interview Workers, Staff

√

√ √

√

Thursday Sep 04 AM

Travel to Mukut (New Development)Inspection/Consultation/Interviews at Mukut Summarise Information collected to date (at G’House)

√ √

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√√

PM Mukut Documentation Review (at Guest House)Identification of Issues for Follow‐up and Clarification Travel back to Hindoli Guest House

√ √

√ √

Friday Sep 05

AM

Pick‐up from Guest House travel Tanjung Dalam MillPhysical Inspection Tanjung Dalam Mill, Interview Mill Workers, Contractors Inspect Housing, Interview Residents and Clinic Staff

√ √

√ √

√√

PM Documentation Review, Monitoring DataInterview Female Office Staff Interview Smallholders

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√

Saturday Sep 06 AM

Pick‐up from Guest HousePrepare for Closeout Meeting Closeout Meeting

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PM Prepare IAV ReportTravel to Guest House

√ √ √

Sunday Sep 07

0700 Travel Hindoli – Palembang Airport – Jakarta √ √ √

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