rapid response report 28 · 2020. 6. 6. · table of contents additional cases identified using...

54
Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM 6/6/20, 9:18 PM Rapid Response Report 28 Rapid Response <[email protected]> Fri 6/5/2020 6:48 PM To: Laura.[email protected] <[email protected]> Cc: [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Phil Aikman <[email protected]>; Asha Sharma <[email protected]> | 1 attachments (775 KB) RR Report 28.pdf; Dear Laura - Today, we are releasing Mighty Earth's Rapid Response report 28, which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia. The following are new cases of deforestation and/or peatland development (in order of appearance in report 28) with known supply chain links. They are listed by Group, if known, then by concession name. Tunas Baru Lampung: PT Samora Usaha Jaya (A) The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 28) with known supply chain links: Tunas Baru Lampung: PT Samora Usaha Jaya (B) KPN Group: PT Sumatera Unggul Makmur QL Resources Bhd: PT Pipit Mutiara Indah The report also includes 39 repeat cases of deforestation that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because, for the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports. Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their no buylists. Please confirm this action will be taken. Please see attached a copy of the Rapid Response report for full information, including GPS coordinates, satellite imagery showing recent deforestation and peat development, and what we know regarding supply chain links and company ownership. The supply chain links, https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgwNWQtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQAA0XYdLUscxHIB4VL53qmno%3D Page 1 of 2 Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Upload: others

Post on 12-Sep-2020

3 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM6/6/20, 9:18 PM

Rapid Response Report 28

Rapid Response <[email protected]>Fri 6/5/2020 6:48 PM

To: [email protected] <[email protected]>Cc: [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Phil Aikman <[email protected]>; Asha Sharma <[email protected]>

| 1 attachments (775 KB)

RR Report 28.pdf;

Dear Laura -

Today, we are releasing Mighty Earth's Rapid Response report 28, which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia.

The following are new cases of deforestation and/or peatland development (in order of appearance in report 28) with known supply chain links. They are listed by Group, if known, then by concession name.

Tunas Baru Lampung: PT Samora Usaha Jaya (A)

The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 28) with known supply chain links:

Tunas Baru Lampung: PT Samora Usaha Jaya (B)KPN Group: PT Sumatera Unggul Makmur QL Resources Bhd: PT Pipit Mutiara Indah

The report also includes 39 repeat cases of deforestation that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because, for the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports.

Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their ‘no buy’ lists. Please confirm this action will be taken.

Please see attached a copy of the Rapid Response report for full information, including GPS coordinates, satellite imagery showing recent deforestation and peat development, and what we know regarding supply chain links and company ownership. The supply chain links,

https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgwNWQtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQAA0XYdLUscxHIB4VL53qmno%3D Page 1 of 2

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 2: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

6/6/20, 9:18 PM

which are based on mill disclosures and recent export data, are:

Tunas Baru Lampung appears to sell (directly or indirectly) to Itochu.KPN Group appears to sell (directly or indirectly) to AAK, ADM, Felda IFFCO, Fuji Oil, KLK,Louis Dreyfus, Olam, Sime Darby, and Wilmar.QL Resources Bhd appears to sell (directly or indirectly) to AAK, ADM, Cargill, ISF, Itochu, and Louis Dreyfus.

As mentioned in the cover email with Rapid Response report 13 and subsequent emails,Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. How palm oil traders and biofuel companies address such grievances will be assessed as part of our Rapid Response Trader Tracking’ grievance performance system.

Please provide us with an update on your engagement, or if your grievance tracker has been updated recently on these cases, let us know so we can review. We ask for your reply no later than June 19, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond.

Thanks, and stay safe!

Asha Sharma

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

MIGHTY EARTHI

ASHA SHARMA I DIRECTOR I mightvearth.org

[email protected] us: Facebook I Twitter

The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’ work on forest conservation is funded in part by

Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned

organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the

Department of Justice, Washington, D.C.

https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgw...WQtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQAA0XYdLUscxHIB4VL53qmno%3D Page 2 of 2

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 3: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

MIGHTY EARTH

/g\ RAPID RESPONSEvffiy Palm Oil Report

Report 28

June 2020

if%

.....

• I. \#--

vj*

\

• i • .• • •

Prepared with

MapHubs

Waxman

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 4: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Table of ContentsCases identified using Sentinel imagery

Indonesian Companies

New Case

Tunas Baru Lampung: PT Samora Usaha Jay a (A)

Unresolved Cases

Tunas Baru Lampung: PT Samora Usaha Jay a (B)

KPN Group: PT Sumatera Unggul Makmur

QL Resources Bhd: PT Pipit Mutiara Indah

Additional cases identified using filtered GLAD alerts

New Cases — No Known Supply Chain Links

Mukti Group: PT Asia Mukti Lestari

Repeat Cases — Known Supply Chain Links

PT Suryaborneo Mandiri: PT PermataSawit Mandiri

Salim/IndoGunta: PT Rimbun Sawit Papua

Mulia Sawit: PT Persada Era Agro Kencana

Makin Group: PT Mekar KaryaKahuripan

Salim/IndoGunta: PT Rimbun Sawit Papua

Widy a Corporation: PT Mulia Inti Perkasa

Starmas Sentosa Mandiri: PT Agrindo Sukses Sejahtera

Korompis Family: PT Berau Karetindo Lestari

Capitol Group: PT MedcopapuaHijau Selaras

Samling Group: PT Tunas Borneo Plantations

Bumitama Group: PT Damai Agro Sejahtera

Dharma SatyaNusantara: PT PutraUtama Lestari

Hay el Saeed Anam Group: PT Megakarya Jay a Raya

Samuel International Group: PT Bina Sarana Sawit Utama

Genting Plantations Bhd: PT Citra Sawit Cemerlang

Fangiono family companies: PT TirtaMadu Sawit Jaya

Pinehill Pacific Bhd: PT Makmur Jaya Malindo

Cilandry Anky Abadi Group: PT Citra Agro Abadi

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

5

7

9

n

13

13

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

15

15

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 5: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases — Known Supply Chain Links (continued) *5

Alas Kusuma Group: PT Kusuma Alam Sari *5

Green Yield Pte Ltd: PTTri Investama *5

CB Industrial Product Holding: PT Jay a JadiUtama 15

Henan Jiujiu Chemical Co Ltd & PT Citra Makmur Sentosa: PT Palem Segar Lestari 15

PundiGroup: PT Pinang Witmas Abadi *5

Dnist Sury a Nusantara:PTSabhantaraRawi Sentosa *5

PT Sawit Sumbermas Sarana Tbk: PT Sawit Mandiri Lestari 15

Indonusa Group: PTInternusa Jaya Sejahtera 15

Salim Group: PT Agro Subur Permai *5

Mulia Sawit Group: PT Persada Era Agro Kencana *b

Bukit Berlian Plantation Group: PTGinang Fohu Plantation *6

Salim/IndoGunta: PTRimbun Sawit Papua *b

Samling Group: LPF/0007 Samling Jelalong (OP) 16

Samling Group: LPF/o008Marudi&Batu Belah tb

Rimbunan Hijau Group: Timrest Sdn Bhd tb

Repeat Cases — No Known Supply Chain Links 17

17Unknown Group: PT Kay an Plantation

17Unknown Group: PT Kukar Commodities Worldwide

17Unknown Group: PT Ichiko Agro Lestari

17Unknown Group: PT Tualang Raya

17Unknown Group: PT Artanusa Agrindo

o 1Unknown Group: PT Sawit Berkat Sejahtera

17Unknown Group: PT Sebaung Sawit Plantation

17Unknown Group: PT Gapura Alas Lestari

17Unknown Group: PT Gapura Alas Lestari

17Unknown Group: PT Bhakti Usaha Dinamika

17Unknown Group: PT BanyanTumbuh Lestari

17Unknown Group: Koperasi Usaha Mandiri

17Unknown Group: Koperasi Bakung Agri

Supply chain information:

Supply chain information included in Rapid Response reports is based on the latest public versions of mill disclosures, recent export data and grievance logs. Mighty Earth encourages companies to send updated versions of mill disclosures as soon as they become available and to share any decision to suspend relations with a given group/company listed in those mill disclosures; please [email protected].

Mighty Earth is now including biofuel companies in the supply chain tables of Rapid Response reports, as these companies have both direct and indirect trading relationships with groups highlighted in these reports and should be filing grievances on these cases. These biofuel companies are listed in the “Traders and Biofuel Companies” tables.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 6: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

New Case

Group: Tunas Baru LampungPT Samora Usaha Jaya (A)Concession location: (-3.355969,105.440277)

Deforestation and/or peat development

Report

Report 28

Deforestationdevelopment

(ha)

Peatforest

developme nt

(ha)

Clearance

prep/Stacking

lines (ha)

Time period

April 2, 2020-May 6,

2020

Satellite imagery (see below) showsthat between April 2, 2020 and May 6, 2020 a total of 6 hectares of forest

was cleared in the PT Samora Usaha Jaya (A) concession. (Imagery: Contains modified Copernicus Sentinel data

2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brand

PT Samora Usaha Jaya (A)

Tunas Baru Lampung Itochu

Avon, Danone, FrieslandCampina,

General Mills, Hershey, Kellogg's, Nestle,

Unilever

Ownership Information

PT Samora Usaha Jaya (A) is part of Tunas Baru Lampung Tbk.1

i. Annual Report (2018), Tunas Bara Lampung Tbk, www.timasbaralampung.com/en/?wpfb_dl=ii9

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 7: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

vieumiii Phtop

Malaysia

Indonesia

: — *

Efi

Alert Imagery (before and after satellite images)

Clearance location: (-3.342740, 105.465633)

Date: April 2, 2020

4

Date: May 6 2020

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 8: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Unresolved Case

Group: Tunas Baru LampungPT Samora Usaha Jaya (B)Concession location: (-3.366088,105.244154)

Deforestation and/or peat development

Report

Report 19

Deforestation

216

development

(ha)

Peatforest

developme nt

(ha)

Clearance

prep/Stacking

lines (ha)

Time period

May 18, 2019-August

5, 2019

Report 28 683 49August 6, 2019-May 6,

2020

Satellite imagery (see below) showsthat between August 6, 2019 and May 6, 2020 a total of 683 hectaresof

forest were cleared and 49 hectares were prepared for clearing (stacking lines) in the PTSamora Usaha Jaya (B)

concession. (Imagery: Contains modified Copernicus Sentinel data 2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brands

PT Samora Usaha Jaya (B)

Tunas Baru Lampung Itochu

Avon, Danone, FrieslandCampina, General Mills, Hershey, Kellogg's, Nestle,

Unilever

Ownership Information

PT Samora Usaha Jaya (B) is part of Tunas Baru Lampung Tbk.2

2. Annual Report (2018), Timas Bam Lampung Tbk, mvw.tunasbarulampung.com /en/?wpfb_dl=ii9

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 9: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

VIClIlcflllPhltfp

Malaysia

Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (-3.337866, 105.215091)

Date: August6, 2019 Date: May 6, 2020

rp ~ s&j

_L - EL

. %

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 10: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Unresolved Case

Group: KPN GroupPT Sumatera Unggul MakmurConcession location: (1.137378,109.201124)

Deforestation and/or peat development

Report

Report 18

Deforestation

16

development

(ha)

Peatforest Clearance

development prep/Stacking

(ha) lines(ha)

Time period

May 27, 2019-July 1,

2019

Report 28 11March 10, 2020-May 4,

2020

Satellite imagery (see below) shows that between March 10, 2020 and May 4, 2020 a total of 11 hectares of forest

were cleared inthe PTSumatera Unggul Makmur concession. (Imagery: Contains modified Copernicus Sentinel

data 2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brand

PT Sumatera Unggul

Makmur

KPN Group

AAK, ADM, FeldalFFCO,

Fuji Oil, KLK, Louis

Dreyfus, Olam, Sime

Darby, Wilmar

Colgate-Palmolive, FrieslandCampina,

General Mills, Hershey's, Kellogg's, Mars,

Nestle, PepsiCo, Reckitt Benckiser

Ownership Information

PT Sumatera Unggul Makmur is part of the KPN Group. 3 3

3. KPN website, http: //kpiiplantatLQii.CQm/

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 11: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

VietnamPhilippin

Malaysia

Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (1.132709, 109.221850)

Date: March 10, 2020 Date: May 4, 2020

1

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 12: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Unresolved Case

Group: QL Resources Bhd

PT Pipit Mutiara IndahConcession location: (3.349026,117.220382)

Deforestation and/or peat development

Report

Report 21

Deforestation

50

Peat forest learance

development

(ha)

development prep/Stacking

(ha) lines(ha)

Time period

January 3, 2019-

0ctober20, 2019

Report 28December22, 2020-

April 20, 2020

Satellite imagery (see below) shows that between December 22, 2020 and April 20, 2020 a total of 7 hectares of

forestwere cleared inthe PTPipit Mutiara Indah concession. (Imagery: Contains modified Copernicus Sentinel

data 2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brand

PT Pipit Mutiara Indah Genting Neste

Avon, Colgate-Palmolive, Danone, General Mills, Hershey, Kellogg's, Mars,

Mondelez, Nestle, Nisshin OilliO, P&G, PepsiCo, PZCussons, Reckitt Benckiser, Unilever

QL Resources Bhd

AAK, Cargill, Fuji Oil,

Genting, Itochu, Mewah,

Wilmar

Neste

Avon, Colgate-Palmolive, Danone, FrieslandCampina, General Mills,

Hershey, ISF, Kellogg's, Mars, Mondelez, Nestle, Nisshin OilliO, P&G, PepsiCo, PZ Cussons, Reckitt Benckiser, Unilever, Upfield, Vandemoortele

Ownership Information

PT Pipit Mutiara Indah is part of QL Resources Bhd.4 4

4. Annual Report (2019), QLResources Blid, http://ql.listedcompany.com/misc/ar2019.pdf

Mir;uTV radtu 1 n

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 13: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

aj

VietnamPhilippines

alaysia

Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (3.402881, 117.242221)

Date: December22, 2020 Date: April 20, 2020

i

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 14: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PMhvi vi iviu i i«i vqjcj ivfldiui n= vi u Jing jwi cci i cv« vjLm/ a ici u

The following cases have been identified through screened GLAD alerts (see methodology below). As these cases are either repeat cases from previous Rapid Response reports or where Mighty Earth did not determine any supply chain links for these concessions/groups, no satellite image analysis was conducted for these cases to save resources.

Mighty Earth expects that palm oil traders and biofuel companies conduct their own

satellite image analysis of these cases and, if confirmed to be deforestation/peatland

development, conduct due diligence to determine if they are exposed to associated

companies/groups.

Methodology:For Indonesia, GLAD alerts are screened using the Indonesia Ministiy of Forestry and the Environment land cover dataset for 2017 which classifies existing palm oil plantations and primary and secondary forest. Hence, only GLAD alerts in primary and secondary forest according to that dataset are included.

For Malaysia, GLAD alerts are screened to exclude known plantation areas using the Global Forest Watch (GFW) plantations dataset. This automatically eliminates the most common false positives, i.e. the replanting of palm that existed prior to the year 2000.

New Cases - Unknown Supply Chain Links

Concession license area

PT Asia Mukti Lestari

Group/ownership

Mukti Group

Area covered byscreenedGLAD Time period alerts (ha)

5ha 4/21/20-5/21/20

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 15: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - Known Supply Chain Links

Concession license area

PT Permata Sawit Mandiri

Group/ownership

PT Suryaborneo Mandiri

Area covered

by screened

GLAD alerts

(ha)

484ha

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

15, 16, 17,19, 20, 23,24,27

PT Rimbun Sawit Papua Salim/IndoGunta 90ha 4/21/20-5/21/203, 10, 13 14, 16, 17,18, 20,23,25, 26

PT Persada Era Agro Kencana Mulia Sawit 83ha 4/21/20-5/21/209-12, 15-20,22-24. 25,27

PTMekar Karya Kahuripan Makin Group 66ha 4/21/20-5/21/20 17, 21-23, 26, 27

PT Rimbun Sawit Papua Salim/IndoGunta 56ha 4/21/20-5/21/203, 10, 13, 14, 16- 18, 20, 23, 25, 26

PT Mulia Inti Perkasa Widya Corporation 50ha 4/21/20-5/21/20 6, 15, 16, 20-26, 27

PT Agrindo Sukses SejahteraStarmas Sentosa Mandiri

48ha 4/21/20-5/21/20 8, 6,22,26,27

PTBerau Karetindo Lestari Korompis Family 47ha 4/21/20-5/21/202, 6, 9, 15,16, 19- 22,27

PTMedcopapua HijauSelaras Capitol Group 31ha 4/21/20-5/21/20 25,26,27

PTTunas Borneo Plantations SamlingGroup 26ha 4/21/20-5/21/20 18, 27

* Rapid Response reports available on Mighty Earth’s Rapid Response websitepage linked here.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 16: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - Known Supply Chain Links

Concession license area

PT Makmur Jaya Malindo

Group/ownership

Pinehill Pacific Bhd

Area covered

by screened

GLAD alerts

(ha)

22

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

18, 19,27

PT Citra Agro AbadiCilandry Anky Abadi Group

14. 4/21/20-5/21/20 17, 23, 25, 26

PT Kusuma Alam Sari Alas Kusuma Group 11 4/21/20-5/21/20 7, 17, 23, 26

PTTri Investama Green Yield Pte Ltd 11 4/21/20-5/21/20 20-25, 27

PT Jaya Jadi UtamaCB Industrial Product Holding

10 4/21/20-5/21/20 15, 20, 23, 26, 27

PT Pa I em Sega r Lesta riHenan Jiujiu Chemical Co Ltd & PT Citra Makmur Sentosa

4/21/20-5/21/205, 7, 12, 16, 18,20 23, 26, 27

PT PinangWitmas Abadi Pundi Group 4/21/20-5/21/20 10-12, 16, 18

PTSabhantara Rawi Sentosa DnistSurya Nusantara 4/21/20-5/21/20 21, 23, 26, 27

PTSawit Mandiri LestariPT Sawit Sumbermas Sarana Tbk

4/21/20-5/21/20 3,8,7, 9, 10, 14

PT Intern us a Jaya Sejahtera Indonusa Group 4/21/20-5/21/20 7, 10-12, 15, 22, 2£

PT Agro Subur Permai SalimGroup 4/21/20-5/21/20 20, 21

PT Persada Era Agro Kencana Mulia SawitGroup 4/21/20-5/21/209, 10, 11, 12, 15, 20,25,27

* Rapid Response reports available on Mighty Earth’s Rapid Response website page. linked here.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 17: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - Known Supply Chain Links

Concession license area

PTGinangFohu Plantation

Group/ownership

Bukit Berlian Plantation Group

Area covered

by screened

GLAD alerts

(ha)

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

17, 23

PT Rimbun Sawit Papua Salim/IndoGunta 4/21/20-5/21/20 3, 10, 13, 14, 16- 18,20,23,25,26

LPF/0007 SamlingJelalong(OP) SamlingGroup 307 4/21/20-5/21/20 18-21,23-27

LPF/0008 Marudi & Batu Belah SamlingGroup 119 4/21/20-5/21/2013, 17, 19, 20, 21, 24, 25, 26

Timrest Sdn Bhd Rimbunan Hijau Group 4/21/20-5/21/20 21, 27

* Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 18: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - No Known Supply Chain Links

Concession license area

PT Kayan Plantation

Group/ownership

Unknown Group

Area covered

by screened

GLAD alerts

(ha)

21

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

15-23

PT KukarCommodities Worldwide Unknown Group 15 4/21/20-5/21/20 21

PT Ichiko Agro Lestari Unknown Group 154/21/20-5/21/20 14, 16, 17, 19,20,

21, 23, 24, 26

PTTualang Raya Unknown Group 10 4/21/20-5/21/20 27

PT Artanusa Agrindo Unknown Group 4/21/20-5/21/20 18, 19, 21

PT Sawit Berkat Sejahtera Unknown Group 4/21/20-5/21/20 12, 15, 19

PTSebaung SawitPlantation Unknown Group 4/21/20-5/21/208,12, 13, 16, 20, 21,22,23,25,27

PTGapura Alas Lestari Unknown Group 12 4/21/20-5/21/2016, 19, 20,23,25, 26, 27

PT Gapura Alas Lestari Unknown Group 4/21/20-5/21/2016, 19, 20, 23, 25, 26

PT Bhakti Usaha Dinamika Unknown Group 4/21/20-5/21/20 14, 21

PT BanyanTumbuh Lestari Unknown Group 4/21/20-5/21/20 27

Koperasi Usaha Mandiri Unknown Group 4/21/20-5/21/20 17,19-24

Koperasi BakungAgri Unknown Group 4/21/20-5/21/20 22, 23

'Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here.

The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. §6i4to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is onfile with the Department of Justice, Washington, D.C.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 19: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM6/6/20, 9:19 PM

RR Report 28

Rapid Response <[email protected]>Fri 6/5/2020 7:11 PM

To: [email protected] <[email protected]>Cc: [email protected] <[email protected]>; [email protected] <[email protected]>; Asha Sharma <[email protected]>; Phil Aikman <[email protected]>

| 1 attachments (775 KB)

RR Report 28.pdf;

Dear Michelle -

Today, we are releasing Mighty Earth's Rapid Response report 28. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia.

The following are new cases of deforestation and/or peatland development (in order of appearance in report 28) with known supply chain links. They are listed by Group, if known, then by concession name.

Tunas Baru Lampung: PT Samora Usaha Jaya (A)

The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 28) with known supply chain links:

Tunas Baru Lampung: PT Samora Usaha Jaya (B)KPN Group: PT Sumatera Unggul Makmur QL Resources Bhd: PT Pipit Mutiara Indah

The report also includes 39 repeat cases of deforestation that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because, for the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports.

Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their ‘no buy’ lists. Please confirm this action will be taken.

Please see attached a copy of the Rapid Response report for full information, including GPS coordinates, satellite imagery showing recent deforestation and peat development, and what we know regarding supply chain links and company ownership. The supply chain links, which are based on mill disclosures and recent export data, are:

https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgw...MS1hYTVkLTM4ZWQwZjlzNjczNQAQAImSVT5gdDpMt%2BZ%2FPD7%2FoTc%3D Page 1 of 2

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 20: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM6/6/20, 9:19 PM

Tunas Baru Lampung appears to sell (directly or indirectly) to Itochu.KPN Group appears to sell (directly or indirectly) to AAK, ADM, Felda IFFCO, Fuji Oil, KLK, Louis Dreyfus, Olam, Sime Darby, and Wilmar.QL Resources Bhd appears to sell (directly or indirectly) to AAK, ADM, Cargill, ISF, Itochu, and Louis Dreyfus.

As mentioned in the cover email with Rapid Response report 13 and subsequent emails, Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. How palm oil traders and biofuel companies address such grievances will be assessed as part of our Rapid Response Trader Tracking’ grievance performance system.

Please provide us with an update on your engagement, or if your grievance tracker has been updated recently on these cases, let us know so we can review. We ask for your reply no later than June 19, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond.

Thanks, and stay safe!

Asha Sharma

ASHA SHARMA I DIRECTOR I [email protected] us: Facebook I Twitter

The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’ work on forest conservation is funded in part by

Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned

organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the

Department of Justice, Washington, D.C.

https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgw...MS1hYTVkLTM4ZWQwZjlzNjczNQAQAImSVT5gdDpMt%2BZ%2FPD7%2FoTc%3D Page 2 of 2

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 21: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

MIGHTY EARTH

/g\ RAPID RESPONSEvffiy Palm Oil Report

Report 28

June 2020

if%

.....

• I. \#--

vj*

\

• i • .• • •

Prepared with

MapHubs

Waxman

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 22: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Table of ContentsCases identified using Sentinel imagery

Indonesian Companies

New Case

Tunas Baru Lampung: PT Samora Usaha Jay a (A)

Unresolved Cases

Tunas Baru Lampung: PT Samora Usaha Jay a (B)

KPN Group: PT Sumatera Unggul Makmur

QL Resources Bhd: PT Pipit Mutiara Indah

Additional cases identified using filtered GLAD alerts

New Cases — No Known Supply Chain Links

Mukti Group: PT Asia Mukti Lestari

Repeat Cases — Known Supply Chain Links

PT Suryaborneo Mandiri: PT PermataSawit Mandiri

Salim/IndoGunta: PT Rimbun Sawit Papua

Mulia Sawit: PT Persada Era Agro Kencana

Makin Group: PT Mekar KaryaKahuripan

Salim/IndoGunta: PT Rimbun Sawit Papua

Widy a Corporation: PT Mulia Inti Perkasa

Starmas Sentosa Mandiri: PT Agrindo Sukses Sejahtera

Korompis Family: PT Berau Karetindo Lestari

Capitol Group: PT MedcopapuaHijau Selaras

Samling Group: PT Tunas Borneo Plantations

Bumitama Group: PT Damai Agro Sejahtera

Dharma SatyaNusantara: PT PutraUtama Lestari

Hay el Saeed Anam Group: PT Megakarya Jay a Raya

Samuel International Group: PT Bina Sarana Sawit Utama

Genting Plantations Bhd: PT Citra Sawit Cemerlang

Fangiono family companies: PT TirtaMadu Sawit Jaya

Pinehill Pacific Bhd: PT Makmur Jaya Malindo

Cilandry Anky Abadi Group: PT Citra Agro Abadi

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

5

7

9

n

13

1314

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

15

15

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 23: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases — Known Supply Chain Links (continued) *5

Alas Kusuma Group: PT Kusuma Alam Sari *5

Green Yield Pte Ltd: PTTri Investama *5

CB Industrial Product Holding: PT Jay a JadiUtama 15

Henan Jiujiu Chemical Co Ltd & PT Citra Makmur Sentosa: PT Palem Segar Lestari 15

PundiGroup: PT Pinang Witmas Abadi *5

Dnist Sury a Nusantara:PTSabhantaraRawi Sentosa *5

PT Sawit Sumbermas Sarana Tbk: PT Sawit Mandiri Lestari 15

Indonusa Group: PTInternusa Jaya Sejahtera 15

Salim Group: PT Agro Subur Permai *5

Mulia Sawit Group: PT Persada Era Agro Kencana *b

Bukit Berlian Plantation Group: PTGinang Fohu Plantation *6

Salim/IndoGunta: PTRimbun Sawit Papua *b

Samling Group: LPF/0007 Samling Jelalong (OP) 16

Samling Group: LPF/o008Marudi&Batu Belah tb

Rimbunan Hijau Group: Timrest Sdn Bhd tb

Repeat Cases — No Known Supply Chain Links 17

17Unknown Group: PT Kay an Plantation

17Unknown Group: PT Kukar Commodities Worldwide

17Unknown Group: PT Ichiko Agro Lestari

17Unknown Group: PT Tualang Raya

17Unknown Group: PT Artanusa Agrindo

o 1Unknown Group: PT Sawit Berkat Sejahtera

17Unknown Group: PT Sebaung Sawit Plantation

17Unknown Group: PT Gapura Alas Lestari

17Unknown Group: PT Gapura Alas Lestari

17Unknown Group: PT Bhakti Usaha Dinamika

17Unknown Group: PT BanyanTumbuh Lestari

17Unknown Group: Koperasi Usaha Mandiri

17Unknown Group: Koperasi Bakung Agri

Supply chain information:

Supply chain information included in Rapid Response reports is based on the latest public versions of mill disclosures, recent export data and grievance logs. Mighty Earth encourages companies to send updated versions of mill disclosures as soon as they become available and to share any decision to suspend relations with a given group/company listed in those mill disclosures; please [email protected].

Mighty Earth is now including biofuel companies in the supply chain tables of Rapid Response reports, as these companies have both direct and indirect trading relationships with groups highlighted in these reports and should be filing grievances on these cases. These biofuel companies are listed in the “Traders and Biofuel Companies” tables.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 24: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

New Case

Group: Tunas Baru LampungPT Samora Usaha Jaya (A)Concession location: (-3.355969,105.440277)

Deforestation and/or peat development

Report

Report 28

Deforestationdevelopment

(ha)

Peatforest

developme nt

(ha)

Clearance

prep/Stacking

lines (ha)

Time period

April 2, 2020-May 6,

2020

Satellite imagery (see below) showsthat between April 2, 2020 and May 6, 2020 a total of 6 hectares of forest

was cleared in the PT Samora Usaha Jaya (A) concession. (Imagery: Contains modified Copernicus Sentinel data

2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brand

PT Samora Usaha Jaya (A)

Tunas Baru Lampung Itochu

Avon, Danone, FrieslandCampina,

General Mills, Hershey, Kellogg's, Nestle,

Unilever

Ownership Information

PT Samora Usaha Jaya (A) is part of Tunas Baru Lampung Tbk.1

i. Annual Report (2018), Tunas Bara Lampung Tbk, www.timasbaralampung.com/en/?wpfb_dl=ii9

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 25: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

vieumiii Phtop

Malaysia

Indonesia

: — *

Efi

Alert Imagery (before and after satellite images)

Clearance location: (-3.342740, 105.465633)

Date: April 2, 2020

4

Date: May 6 2020

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 26: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Unresolved Case

Group: Tunas Baru LampungPT Samora Usaha Jaya (B)Concession location: (-3.366088,105.244154)

Deforestation and/or peat development

Report

Report 19

Deforestation

216

development

(ha)

Peatforest

developme nt

(ha)

Clearance

prep/Stacking

lines (ha)

Time period

May 18, 2019-August

5, 2019

Report 28 683 49August 6, 2019-May 6,

2020

Satellite imagery (see below) showsthat between August 6, 2019 and May 6, 2020 a total of 683 hectaresof

forest were cleared and 49 hectares were prepared for clearing (stacking lines) in the PTSamora Usaha Jaya (B)

concession. (Imagery: Contains modified Copernicus Sentinel data 2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brands

PT Samora Usaha Jaya (B)

Tunas Baru Lampung Itochu

Avon, Danone, FrieslandCampina, General Mills, Hershey, Kellogg's, Nestle,

Unilever

Ownership Information

PT Samora Usaha Jaya (B) is part of Tunas Baru Lampung Tbk.2

2. Annual Report (2018), Timas Bam Lampung Tbk, mvw.tunasbarulampung.com /en/?wpfb_dl=ii9

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 27: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

VIClIlcflllPhltfp

Malaysia

Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (-3.337866, 105.215091)

Date: August6, 2019 Date: May 6, 2020

rp ~ s&j

_L - EL

. %

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 28: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Unresolved Case

Group: KPN GroupPT Sumatera Unggul MakmurConcession location: (1.137378,109.201124)

Deforestation and/or peat development

Report

Report 18

Deforestation

16

development

(ha)

Peatforest Clearance

development prep/Stacking

(ha) lines(ha)

Time period

May 27, 2019-July 1,

2019

Report 28 11March 10, 2020-May 4,

2020

Satellite imagery (see below) shows that between March 10, 2020 and May 4, 2020 a total of 11 hectares of forest

were cleared inthe PTSumatera Unggul Makmur concession. (Imagery: Contains modified Copernicus Sentinel

data 2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brand

PT Sumatera Unggul

Makmur

KPN Group

AAK, ADM, FeldalFFCO,

Fuji Oil, KLK, Louis

Dreyfus, Olam, Sime

Darby, Wilmar

Colgate-Palmolive, FrieslandCampina,

General Mills, Hershey's, Kellogg's, Mars,

Nestle, PepsiCo, Reckitt Benckiser

Ownership Information

PT Sumatera Unggul Makmur is part of the KPN Group. 3 3

3. KPN website, http: //kpiiplantatLQii.CQm/

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 29: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

VietnamPhilippin

Malaysia

Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (1.132709, 109.221850)

Date: March 10, 2020 Date: May 4, 2020

1

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 30: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Unresolved Case

Group: QL Resources Bhd

PT Pipit Mutiara IndahConcession location: (3.349026,117.220382)

Deforestation and/or peat development

Report

Report 21

Deforestation

50

Peat forest learance

development

(ha)

development prep/Stacking

(ha) lines(ha)

Time period

January 3, 2019-

0ctober20, 2019

Report 28December22, 2020-

April 20, 2020

Satellite imagery (see below) shows that between December 22, 2020 and April 20, 2020 a total of 7 hectares of

forestwere cleared inthe PTPipit Mutiara Indah concession. (Imagery: Contains modified Copernicus Sentinel

data 2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brand

PT Pipit Mutiara Indah Genting Neste

Avon, Colgate-Palmolive, Danone, General Mills, Hershey, Kellogg's, Mars,

Mondelez, Nestle, Nisshin OilliO, P&G, PepsiCo, PZCussons, Reckitt Benckiser, Unilever

QL Resources Bhd

AAK, Cargill, Fuji Oil,

Genting, Itochu, Mewah,

Wilmar

Neste

Avon, Colgate-Palmolive, Danone, FrieslandCampina, General Mills,

Hershey, ISF, Kellogg's, Mars, Mondelez, Nestle, Nisshin OilliO, P&G, PepsiCo, PZ Cussons, Reckitt Benckiser, Unilever, Upfield, Vandemoortele

Ownership Information

PT Pipit Mutiara Indah is part of QL Resources Bhd.4 4

4. Annual Report (2019), QLResources Blid, http://ql.listedcompany.com/misc/ar2019.pdf

Mir;uTV radtu 1 n

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 31: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

aj

VietnamPhilippines

alaysia

Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (3.402881, 117.242221)

Date: December22, 2020 Date: April 20, 2020

i

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 32: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PMhvi vi iviu i i«i vqjcj ivfldiui n= vi u Jing jwi cci i cv« vjLm/ a ici u

The following cases have been identified through screened GLAD alerts (see methodology below). As these cases are either repeat cases from previous Rapid Response reports or where Mighty Earth did not determine any supply chain links for these concessions/groups, no satellite image analysis was conducted for these cases to save resources.

Mighty Earth expects that palm oil traders and biofuel companies conduct their own

satellite image analysis of these cases and, if confirmed to be deforestation/peatland

development, conduct due diligence to determine if they are exposed to associated

companies/groups.

Methodology:For Indonesia, GLAD alerts are screened using the Indonesia Ministiy of Forestry and the Environment land cover dataset for 2017 which classifies existing palm oil plantations and primary and secondary forest. Hence, only GLAD alerts in primary and secondary forest according to that dataset are included.

For Malaysia, GLAD alerts are screened to exclude known plantation areas using the Global Forest Watch (GFW) plantations dataset. This automatically eliminates the most common false positives, i.e. the replanting of palm that existed prior to the year 2000.

New Cases - Unknown Supply Chain Links

Concession license area

PT Asia Mukti Lestari

Group/ownership

Mukti Group

Area covered byscreenedGLAD Time period alerts (ha)

5ha 4/21/20-5/21/20

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 33: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - Known Supply Chain Links

Concession license area

PT Permata Sawit Mandiri

Group/ownership

PT Suryaborneo Mandiri

Area covered

by screened

GLAD alerts

(ha)

484ha

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

15, 16, 17,19, 20, 23,24,27

PT Rimbun Sawit Papua Salim/IndoGunta 90ha 4/21/20-5/21/203, 10, 13 14, 16, 17,18, 20,23,25, 26

PT Persada Era Agro Kencana Mulia Sawit 83ha 4/21/20-5/21/209-12, 15-20,22-24. 25,27

PTMekar Karya Kahuripan Makin Group 66ha 4/21/20-5/21/20 17, 21-23, 26, 27

PT Rimbun Sawit Papua Salim/IndoGunta 56ha 4/21/20-5/21/203, 10, 13, 14, 16- 18, 20, 23, 25, 26

PT Mulia Inti Perkasa Widya Corporation 50ha 4/21/20-5/21/20 6, 15, 16, 20-26, 27

PT Agrindo Sukses SejahteraStarmas Sentosa Mandiri

48ha 4/21/20-5/21/20 8, 6,22,26,27

PTBerau Karetindo Lestari Korompis Family 47ha 4/21/20-5/21/202, 6, 9, 15,16, 19- 22,27

PTMedcopapua HijauSelaras Capitol Group 31ha 4/21/20-5/21/20 25,26,27

PTTunas Borneo Plantations SamlingGroup 26ha 4/21/20-5/21/20 18, 27

* Rapid Response reports available on Mighty Earth’s Rapid Response websitepage linked here.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 34: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - Known Supply Chain Links

Concession license area

PT Makmur Jaya Malindo

Group/ownership

Pinehill Pacific Bhd

Area covered

by screened

GLAD alerts

(ha)

22

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

18, 19,27

PT Citra Agro AbadiCilandry Anky Abadi Group

14. 4/21/20-5/21/20 17, 23, 25, 26

PT Kusuma Alam Sari Alas Kusuma Group 11 4/21/20-5/21/20 7, 17, 23, 26

PTTri Investama Green Yield Pte Ltd 11 4/21/20-5/21/20 20-25, 27

PT Jaya Jadi UtamaCB Industrial Product Holding

10 4/21/20-5/21/20 15, 20, 23, 26, 27

PT Pa I em Sega r Lesta riHenan Jiujiu Chemical Co Ltd & PT Citra Makmur Sentosa

4/21/20-5/21/205, 7, 12, 16, 18,20 23, 26, 27

PT PinangWitmas Abadi Pundi Group 4/21/20-5/21/20 10-12, 16, 18

PTSabhantara Rawi Sentosa DnistSurya Nusantara 4/21/20-5/21/20 21, 23, 26, 27

PTSawit Mandiri LestariPT Sawit Sumbermas Sarana Tbk

4/21/20-5/21/20 3,8,7, 9, 10, 14

PT Intern us a Jaya Sejahtera Indonusa Group 4/21/20-5/21/20 7, 10-12, 15, 22, 2£

PT Agro Subur Permai SalimGroup 4/21/20-5/21/20 20, 21

PT Persada Era Agro Kencana Mulia SawitGroup 4/21/20-5/21/209, 10, 11, 12, 15, 20,25,27

* Rapid Response reports available on Mighty Earth’s Rapid Response website page. linked here.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 35: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - Known Supply Chain Links

Concession license area

PTGinangFohu Plantation

Group/ownership

Bukit Berlian Plantation Group

Area covered

by screened

GLAD alerts

(ha)

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

17, 23

PT Rimbun Sawit Papua Salim/IndoGunta 4/21/20-5/21/20 3, 10, 13, 14, 16- 18,20,23,25,26

LPF/0007 SamlingJelalong(OP) SamlingGroup 307 4/21/20-5/21/20 18-21,23-27

LPF/0008 Marudi & Batu Belah SamlingGroup 119 4/21/20-5/21/2013, 17, 19, 20, 21, 24, 25, 26

Timrest Sdn Bhd Rimbunan Hijau Group 4/21/20-5/21/20 21, 27

* Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 36: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - No Known Supply Chain Links

Concession license area

PT Kayan Plantation

Group/ownership

Unknown Group

Area covered

by screened

GLAD alerts

(ha)

21

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

15-23

PT KukarCommodities Worldwide Unknown Group 15 4/21/20-5/21/20 21

PT Ichiko Agro Lestari Unknown Group 154/21/20-5/21/20 14, 16, 17, 19,20,

21, 23, 24, 26

PTTualang Raya Unknown Group 10 4/21/20-5/21/20 27

PT Artanusa Agrindo Unknown Group 4/21/20-5/21/20 18, 19, 21

PT Sawit Berkat Sejahtera Unknown Group 4/21/20-5/21/20 12, 15, 19

PTSebaung SawitPlantation Unknown Group 4/21/20-5/21/208,12, 13, 16, 20, 21,22,23,25,27

PTGapura Alas Lestari Unknown Group 12 4/21/20-5/21/2016, 19, 20,23,25, 26, 27

PT Gapura Alas Lestari Unknown Group 4/21/20-5/21/2016, 19, 20, 23, 25, 26

PT Bhakti Usaha Dinamika Unknown Group 4/21/20-5/21/20 14, 21

PT BanyanTumbuh Lestari Unknown Group 4/21/20-5/21/20 27

Koperasi Usaha Mandiri Unknown Group 4/21/20-5/21/20 17,19-24

Koperasi BakungAgri Unknown Group 4/21/20-5/21/20 22, 23

'Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here.

The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. §6i4to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is onfile with the Department of Justice, Washington, D.C.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 37: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM6/6/20, 9:20 PM

RR Report 28

Rapid Response <[email protected]>Fri 6/5/2020 7:12 PM

To: [email protected] <[email protected]>Cc: [email protected] <[email protected]>; [email protected] <nick_martell- [email protected]>; Phil Aikman <[email protected]>; Asha Sharma <[email protected]>

| 1 attachments (775 KB)

RR Report 28.pdf;

Dear Nasuha -

Today, we are releasing Mighty Earth's Rapid Response report 28. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia.

The following are new cases of deforestation and/or peatland development (in order of appearance in report 28) with known supply chain links. They are listed by Group, if known, then by concession name.

Tunas Baru Lampung: PT Samora Usaha Jaya (A)

The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 28) with known supply chain links:

Tunas Baru Lampung: PT Samora Usaha Jaya (B)KPN Group: PT Sumatera Unggul Makmur QL Resources Bhd: PT Pipit Mutiara Indah

The report also includes 39 repeat cases of deforestation that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because, for the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports.

Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their ‘no buy’ lists. Please confirm this action will be taken.

Please see attached a copy of the Rapid Response report for full information, including GPS coordinates, satellite imagery showing recent deforestation and peat development, and what we know regarding supply chain links and company ownership. The supply chain links, which are based on mill disclosures and recent export data, are:

https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgwNWQtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQABLvlh68TkREpKvraYloV2c%3D Page 1 of 2

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 38: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM6/6/20, 9:20 PM

Tunas Baru Lampung appears to sell (directly or indirectly) to Itochu.KPN Group appears to sell (directly or indirectly) to AAK, ADM, Felda IFFCO, Fuji Oil, KLK, Louis Dreyfus, Olam, Sime Darby, and Wilmar.QL Resources Bhd appears to sell (directly or indirectly) to AAK, ADM, Cargill, ISF, Itochu, and Louis Dreyfus.

As mentioned in the cover email with Rapid Response report 13 and subsequent emails, Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. How palm oil traders and biofuel companies address such grievances will be assessed as part of our Rapid Response Trader Tracking’ grievance performance system.

Please provide us with an update on your engagement, or if your grievance tracker has been updated recently on these cases, let us know so we can review. We ask for your reply no later than June 19, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond.

Thanks, and stay safe!

Asha Sharma

MIGHTY EARTH

ASHA SHARMA I DIRECTOR I [email protected] us: Facebook I Twitter

The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’ work on forest conservation is funded in part by

Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf of the aforementioned

organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is on file with the

Department of Justice, Washington, D.C.

https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgwNWQtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQABLvlh68TkREpKvraYloV2c%3D Page 2 of 2

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 39: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

MIGHTY EARTH

/g\ RAPID RESPONSEvffiy Palm Oil Report

Report 28

June 2020

if%

.....

• I. \#--

vj*

\

• i • .• • •

Prepared with

MapHubs

Waxman

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 40: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Table of ContentsCases identified using Sentinel imagery

Indonesian Companies

New Case

Tunas Baru Lampung: PT Samora Usaha Jay a (A)

Unresolved Cases

Tunas Baru Lampung: PT Samora Usaha Jay a (B)

KPN Group: PT Sumatera Unggul Makmur

QL Resources Bhd: PT Pipit Mutiara Indah

Additional cases identified using filtered GLAD alerts

New Cases — No Known Supply Chain Links

Mukti Group: PT Asia Mukti Lestari

Repeat Cases — Known Supply Chain Links

PT Suryaborneo Mandiri: PT PermataSawit Mandiri

Salim/IndoGunta: PT Rimbun Sawit Papua

Mulia Sawit: PT Persada Era Agro Kencana

Makin Group: PT Mekar KaryaKahuripan

Salim/IndoGunta: PT Rimbun Sawit Papua

Widy a Corporation: PT Mulia Inti Perkasa

Starmas Sentosa Mandiri: PT Agrindo Sukses Sejahtera

Korompis Family: PT Berau Karetindo Lestari

Capitol Group: PT MedcopapuaHijau Selaras

Samling Group: PT Tunas Borneo Plantations

Bumitama Group: PT Damai Agro Sejahtera

Dharma SatyaNusantara: PT PutraUtama Lestari

Hay el Saeed Anam Group: PT Megakarya Jay a Raya

Samuel International Group: PT Bina Sarana Sawit Utama

Genting Plantations Bhd: PT Citra Sawit Cemerlang

Fangiono family companies: PT TirtaMadu Sawit Jaya

Pinehill Pacific Bhd: PT Makmur Jaya Malindo

Cilandry Anky Abadi Group: PT Citra Agro Abadi

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

5

7

9

n

13

13

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

15

15

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 41: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases — Known Supply Chain Links (continued) *5

Alas Kusuma Group: PT Kusuma Alam Sari *5

Green Yield Pte Ltd: PTTri Investama *5

CB Industrial Product Holding: PT Jay a JadiUtama 15

Henan Jiujiu Chemical Co Ltd & PT Citra Makmur Sentosa: PT Palem Segar Lestari 15

PundiGroup: PT Pinang Witmas Abadi *5

Dnist Sury a Nusantara:PTSabhantaraRawi Sentosa *5

PT Sawit Sumbermas Sarana Tbk: PT Sawit Mandiri Lestari 15

Indonusa Group: PTInternusa Jaya Sejahtera 15

Salim Group: PT Agro Subur Permai *5

Mulia Sawit Group: PT Persada Era Agro Kencana *b

Bukit Berlian Plantation Group: PTGinang Fohu Plantation *6

Salim/IndoGunta: PTRimbun Sawit Papua *b

Samling Group: LPF/0007 Samling Jelalong (OP) 16

Samling Group: LPF/o008Marudi&Batu Belah tb

Rimbunan Hijau Group: Timrest Sdn Bhd tb

Repeat Cases — No Known Supply Chain Links 17

17Unknown Group: PT Kay an Plantation

17Unknown Group: PT Kukar Commodities Worldwide

17Unknown Group: PT Ichiko Agro Lestari

17Unknown Group: PT Tualang Raya

17Unknown Group: PT Artanusa Agrindo

o 1Unknown Group: PT Sawit Berkat Sejahtera

17Unknown Group: PT Sebaung Sawit Plantation

17Unknown Group: PT Gapura Alas Lestari

17Unknown Group: PT Gapura Alas Lestari

17Unknown Group: PT Bhakti Usaha Dinamika

17Unknown Group: PT BanyanTumbuh Lestari

17Unknown Group: Koperasi Usaha Mandiri

17Unknown Group: Koperasi Bakung Agri

Supply chain information:

Supply chain information included in Rapid Response reports is based on the latest public versions of mill disclosures, recent export data and grievance logs. Mighty Earth encourages companies to send updated versions of mill disclosures as soon as they become available and to share any decision to suspend relations with a given group/company listed in those mill disclosures; please [email protected].

Mighty Earth is now including biofuel companies in the supply chain tables of Rapid Response reports, as these companies have both direct and indirect trading relationships with groups highlighted in these reports and should be filing grievances on these cases. These biofuel companies are listed in the “Traders and Biofuel Companies” tables.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 42: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

New Case

Group: Tunas Baru LampungPT Samora Usaha Jaya (A)Concession location: (-3.355969,105.440277)

Deforestation and/or peat development

Report

Report 28

Deforestationdevelopment

(ha)

Peatforest

developme nt

(ha)

Clearance

prep/Stacking

lines (ha)

Time period

April 2, 2020-May 6,

2020

Satellite imagery (see below) showsthat between April 2, 2020 and May 6, 2020 a total of 6 hectares of forest

was cleared in the PT Samora Usaha Jaya (A) concession. (Imagery: Contains modified Copernicus Sentinel data

2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brand

PT Samora Usaha Jaya (A)

Tunas Baru Lampung Itochu

Avon, Danone, FrieslandCampina,

General Mills, Hershey, Kellogg's, Nestle,

Unilever

Ownership Information

PT Samora Usaha Jaya (A) is part of Tunas Baru Lampung Tbk.1

i. Annual Report (2018), Tunas Bara Lampung Tbk, www.timasbaralampung.com/en/?wpfb_dl=ii9

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 43: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

vieumiii Phtop

Malaysia

Indonesia

: — *

Efi

Alert Imagery (before and after satellite images)

Clearance location: (-3.342740, 105.465633)

Date: April 2, 2020

4

Date: May 6 2020

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 44: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Unresolved Case

Group: Tunas Baru LampungPT Samora Usaha Jaya (B)Concession location: (-3.366088,105.244154)

Deforestation and/or peat development

Report

Report 19

Deforestation

216

development

(ha)

Peatforest

developme nt

(ha)

Clearance

prep/Stacking

lines (ha)

Time period

May 18, 2019-August

5, 2019

Report 28 683 49August 6, 2019-May 6,

2020

Satellite imagery (see below) showsthat between August 6, 2019 and May 6, 2020 a total of 683 hectaresof

forest were cleared and 49 hectares were prepared for clearing (stacking lines) in the PTSamora Usaha Jaya (B)

concession. (Imagery: Contains modified Copernicus Sentinel data 2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brands

PT Samora Usaha Jaya (B)

Tunas Baru Lampung Itochu

Avon, Danone, FrieslandCampina, General Mills, Hershey, Kellogg's, Nestle,

Unilever

Ownership Information

PT Samora Usaha Jaya (B) is part of Tunas Baru Lampung Tbk.2

2. Annual Report (2018), Timas Bam Lampung Tbk, mvw.tunasbarulampung.com /en/?wpfb_dl=ii9

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 45: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

VIClIlcflllPhltfp

Malaysia

Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (-3.337866, 105.215091)

Date: August6, 2019 Date: May 6, 2020

rp ~ s&j

_L - EL

. %

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 46: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Unresolved Case

Group: KPN GroupPT Sumatera Unggul MakmurConcession location: (1.137378,109.201124)

Deforestation and/or peat development

Report

Report 18

Deforestation

16

development

(ha)

Peatforest Clearance

development prep/Stacking

(ha) lines(ha)

Time period

May 27, 2019-July 1,

2019

Report 28 11March 10, 2020-May 4,

2020

Satellite imagery (see below) shows that between March 10, 2020 and May 4, 2020 a total of 11 hectares of forest

were cleared inthe PTSumatera Unggul Makmur concession. (Imagery: Contains modified Copernicus Sentinel

data 2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brand

PT Sumatera Unggul

Makmur

KPN Group

AAK, ADM, FeldalFFCO,

Fuji Oil, KLK, Louis

Dreyfus, Olam, Sime

Darby, Wilmar

Colgate-Palmolive, FrieslandCampina,

General Mills, Hershey's, Kellogg's, Mars,

Nestle, PepsiCo, Reckitt Benckiser

Ownership Information

PT Sumatera Unggul Makmur is part of the KPN Group. 3

3. KPN website, http: //kpiiplantatLQii.CQm/

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 47: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

VietnamPhilippin

Malaysia

Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (1.132709, 109.221850)

Date: March 10, 2020 Date: May 4, 2020

1

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 48: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Unresolved Case

Group: QL Resources Bhd

PT Pipit Mutiara IndahConcession location: (3.349026,117.220382)

Deforestation and/or peat development

Report

Report 21

Deforestation

50

Peat forest learance

development

(ha)

development prep/Stacking

(ha) lines(ha)

Time period

January 3, 2019-

0ctober20, 2019

Report 28December22, 2020-

April 20, 2020

Satellite imagery (see below) shows that between December 22, 2020 and April 20, 2020 a total of 7 hectares of

forestwere cleared inthe PTPipit Mutiara Indah concession. (Imagery: Contains modified Copernicus Sentinel

data 2020)

Supply Chain Information

Company/Group TraderBiofuel

Company Consumer Brand

PT Pipit Mutiara Indah Genting Neste

Avon, Colgate-Palmolive, Danone, General Mills, Hershey, Kellogg's, Mars,

Mondelez, Nestle, Nisshin OilliO, P&G, PepsiCo, PZCussons, Reckitt Benckiser, Unilever

QL Resources Bhd

AAK, Cargill, Fuji Oil,

Genting, Itochu, Mewah,

Wilmar

Neste

Avon, Colgate-Palmolive, Danone, FrieslandCampina, General Mills,

Hershey, ISF, Kellogg's, Mars, Mondelez, Nestle, Nisshin OilliO, P&G, PepsiCo, PZ Cussons, Reckitt Benckiser, Unilever, Upfield, Vandemoortele

Ownership Information

PT Pipit Mutiara Indah is part of QL Resources Bhd.4

4. Annual Report (2019), QLResources Blid, http://ql.listedcompany.com/misc/ar2019.pdf

Mir;uTV radtu 1 n

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 49: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Mapping analysis

aj

VietnamPhilippines

alaysia

Indonesia

Alert Imagery (before and after satellite images)

Clearance location: (3.402881, 117.242221)

Date: December22, 2020 Date: April 20, 2020

i

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 50: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PMhvi vi iviu i i«i vqjcj ivfldiui n= vi u Jing jwi cci i cv« vjLm/ a ici u

The following cases have been identified through screened GLAD alerts (see methodology below). As these cases are either repeat cases from previous Rapid Response reports or where Mighty Earth did not determine any supply chain links for these concessions/groups, no satellite image analysis was conducted for these cases to save resources.

Mighty Earth expects that palm oil traders and biofuel companies conduct their own

satellite image analysis of these cases and, if confirmed to be deforestation/peatland

development, conduct due diligence to determine if they are exposed to associated

companies/groups.

Methodology:For Indonesia, GLAD alerts are screened using the Indonesia Ministiy of Forestry and the Environment land cover dataset for 2017 which classifies existing palm oil plantations and primary and secondary forest. Hence, only GLAD alerts in primary and secondary forest according to that dataset are included.

For Malaysia, GLAD alerts are screened to exclude known plantation areas using the Global Forest Watch (GFW) plantations dataset. This automatically eliminates the most common false positives, i.e. the replanting of palm that existed prior to the year 2000.

New Cases - Unknown Supply Chain Links

Concession license area

PT Asia Mukti Lestari

Group/ownership

Mukti Group

Area covered byscreenedGLAD Time period alerts (ha)

5ha 4/21/20-5/21/20

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 51: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - Known Supply Chain Links

Concession license area

PT Permata Sawit Mandiri

Group/ownership

PT Suryaborneo Mandiri

Area covered

by screened

GLAD alerts

(ha)

484ha

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

15, 16, 17,19, 20, 23,24,27

PT Rimbun Sawit Papua Salim/IndoGunta 90ha 4/21/20-5/21/203, 10, 13 14, 16, 17,18, 20,23,25, 26

PT Persada Era Agro Kencana Mulia Sawit 83ha 4/21/20-5/21/209-12, 15-20,22-24. 25,27

PTMekar Karya Kahuripan Makin Group 66ha 4/21/20-5/21/20 17, 21-23, 26, 27

PT Rimbun Sawit Papua Salim/IndoGunta 56ha 4/21/20-5/21/203, 10, 13, 14, 16- 18, 20, 23, 25, 26

PT Mulia Inti Perkasa Widya Corporation 50ha 4/21/20-5/21/20 6, 15, 16, 20-26, 27

PT Agrindo Sukses SejahteraStarmas Sentosa Mandiri

48ha 4/21/20-5/21/20 8, 6,22,26,27

PTBerau Karetindo Lestari Korompis Family 47ha 4/21/20-5/21/202, 6, 9, 15,16, 19- 22,27

PTMedcopapua HijauSelaras Capitol Group 31ha 4/21/20-5/21/20 25,26,27

PTTunas Borneo Plantations SamlingGroup 26ha 4/21/20-5/21/20 18, 27

* Rapid Response reports available on Mighty Earth’s Rapid Response websitepage linked here.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 52: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - Known Supply Chain Links

Concession license area

PT Makmur Jaya Malindo

Group/ownership

Pinehill Pacific Bhd

Area covered

by screened

GLAD alerts

(ha)

22

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

18, 19,27

PT Citra Agro AbadiCilandry Anky Abadi Group

14. 4/21/20-5/21/20 17, 23, 25, 26

PT Kusuma Alam Sari Alas Kusuma Group 11 4/21/20-5/21/20 7, 17, 23, 26

PTTri Investama Green Yield Pte Ltd 11 4/21/20-5/21/20 20-25, 27

PT Jaya Jadi UtamaCB Industrial Product Holding

10 4/21/20-5/21/20 15, 20, 23, 26, 27

PT Pa I em Sega r Lesta riHenan Jiujiu Chemical Co Ltd & PT Citra Makmur Sentosa

4/21/20-5/21/205, 7, 12, 16, 18,20 23, 26, 27

PT PinangWitmas Abadi Pundi Group 4/21/20-5/21/20 10-12, 16, 18

PTSabhantara Rawi Sentosa DnistSurya Nusantara 4/21/20-5/21/20 21, 23, 26, 27

PTSawit Mandiri LestariPT Sawit Sumbermas Sarana Tbk

4/21/20-5/21/20 3,8,7, 9, 10, 14

PT Intern us a Jaya Sejahtera Indonusa Group 4/21/20-5/21/20 7, 10-12, 15, 22, 2£

PT Agro Subur Permai SalimGroup 4/21/20-5/21/20 20, 21

PT Persada Era Agro Kencana Mulia SawitGroup 4/21/20-5/21/209, 10, 11, 12, 15, 20,25,27

* Rapid Response reports available on Mighty Earth’s Rapid Response website page. linked here.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 53: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - Known Supply Chain Links

Concession license area

PTGinangFohu Plantation

Group/ownership

Bukit Berlian Plantation Group

Area covered

by screened

GLAD alerts

(ha)

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

17, 23

PT Rimbun Sawit Papua Salim/IndoGunta 4/21/20-5/21/20 3, 10, 13, 14, 16- 18,20,23,25,26

LPF/0007 SamlingJelalong(OP) SamlingGroup 307 4/21/20-5/21/20 18-21,23-27

LPF/0008 Marudi & Batu Belah SamlingGroup 119 4/21/20-5/21/2013, 17, 19, 20, 21, 24, 25, 26

Timrest Sdn Bhd Rimbunan Hijau Group 4/21/20-5/21/20 21, 27

* Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Page 54: Rapid Response Report 28 · 2020. 6. 6. · Table of Contents Additional cases identified using filtered GLAD alerts (continued) Repeat Cases — Known Supply Chain Links (continued)

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM

Repeat Cases - No Known Supply Chain Links

Concession license area

PT Kayan Plantation

Group/ownership

Unknown Group

Area covered

by screened

GLAD alerts

(ha)

21

Time period

4/21/20-5/21/20

Rapid Response

reports related

to each case*

15-23

PT KukarCommodities Worldwide Unknown Group 15 4/21/20-5/21/20 21

PT Ichiko Agro Lestari Unknown Group 154/21/20-5/21/20 14, 16, 17, 19,20,

21, 23, 24, 26

PTTualang Raya Unknown Group 10 4/21/20-5/21/20 27

PT Artanusa Agrindo Unknown Group 4/21/20-5/21/20 18, 19, 21

PT Sawit Berkat Sejahtera Unknown Group 4/21/20-5/21/20 12, 15, 19

PTSebaung SawitPlantation Unknown Group 4/21/20-5/21/208,12, 13, 16, 20, 21,22,23,25,27

PTGapura Alas Lestari Unknown Group 12 4/21/20-5/21/2016, 19, 20,23,25, 26, 27

PT Gapura Alas Lestari Unknown Group 4/21/20-5/21/2016, 19, 20, 23, 25, 26

PT Bhakti Usaha Dinamika Unknown Group 4/21/20-5/21/20 14, 21

PT BanyanTumbuh Lestari Unknown Group 4/21/20-5/21/20 27

Koperasi Usaha Mandiri Unknown Group 4/21/20-5/21/20 17,19-24

Koperasi BakungAgri Unknown Group 4/21/20-5/21/20 22, 23

'Rapid Response reports available on Mighty Earth’s Rapid Response website page, linked here.

The work of Mighty Earth is supported by Waxman Strategies. Waxman Strategies’work on forest conservation is funded in part by Aidenvironment. Waxman is required under 22 U.S.C. §6i4to disclose that this material is distributed on behalf of the aforementioned organization, working under grant from the Norwegian Agency for Development Cooperation. Additional information is onfile with the Department of Justice, Washington, D.C.

Received by NSD/FARA Registration Unit 06/06/2020 9:40:07 PM