received by nsd/fara registration unit 05/09/2020 9:02:39 am · 5/9/2020  · received by nsd/fara...

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Received by NSD/FARA Registration Unit 05/09/2020 9:02:39 AM 5/9/20, 8:39 AM Rapid Response report 27 Rapid Response <[email protected]> Fri 5/8/2020 7:48 PM To: Bubniak, Mich' Cc: Taylor, Alison @adm.com> @adm.com>; [email protected] <[email protected]> | 1 attachments (3 MB) Rapid Response Report 27_final.pdf; Dear Michelle - Today, we are releasing Mighty Earth's Rapid Response report 27. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia (listed by Group, if known, then by concession name): The following are new cases of deforestation and/or peatland development (in order of appearance in report 27) with known supply chain links: Fangiono family companies: PT Agrindo Green Lestari The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 26) with known supply chain links: QL Resources Bhd: PT Pipit Mutiara Indah Wings Agro Group: PT Indopenta Sejahtera Abadi Samling: PT Tunas Borneo Plantations Samling: LPF/0007 Samling Jelalong (OP) The report also includes 59 repeat cases of deforestation that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because, for the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports. Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their no buy9 lists. Please confirm this action will be taken. Please see attached a copy of the Rapid Response report for full information, including GPS coordinates, satellite imagery showing recent deforestation and peat development, and what we know regarding supply chain links and company ownership. The supply chain links, which are based on mill disclosures and recent export data, are: Fangiono family companies appears to sell (directly or indirectly) to AAK, Itochu, KLK, Musim Mas, Neste, Olam, Sime Darby, and Wilmar. QL Resources Bhd appears to sell (directly or indirectly) to AAK, ADM, Cargill, ISF, Itochu, and Louis Dreyfus. https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgwNWQtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQAHz29SvoHkOljZ1IYd5yWrO%3D Page 1 of 2 Received by NSD/FARA Registration Unit 05/09/2020 9:02:39 AM

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Page 1: Received by NSD/FARA Registration Unit 05/09/2020 9:02:39 AM · 5/9/2020  · Received by NSD/FARA Registration Unit 05/09/2020 9:02:39 AM 5/9/20, 8:39 AM Wings Agro Group appears

Received by NSD/FARA Registration Unit 05/09/2020 9:02:39 AM5/9/20, 8:39 AM

Rapid Response report 27

Rapid Response <[email protected]>Fri 5/8/2020 7:48 PM

To: Bubniak, Mich' Cc: Taylor, Alison

■ @adm.com>@adm.com>; [email protected] <[email protected]>

| 1 attachments (3 MB)

Rapid Response Report 27_final.pdf;

Dear Michelle -

Today, we are releasing Mighty Earth's Rapid Response report 27. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia (listed by Group, if known, then by concession name):

The following are new cases of deforestation and/or peatland development (in order of appearance in report 27) with known supply chain links:

Fangiono family companies: PT Agrindo Green Lestari

The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 26) with known supply chain links:

QL Resources Bhd: PT Pipit Mutiara Indah Wings Agro Group: PT Indopenta Sejahtera Abadi Samling: PT Tunas Borneo Plantations Samling: LPF/0007 Samling Jelalong (OP)

The report also includes 59 repeat cases of deforestation that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because, for the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports.

Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their ‘no buy9 lists. Please confirm this action will be taken.

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

Fangiono family companies appears to sell (directly or indirectly) to AAK, Itochu, KLK, Musim Mas, Neste, Olam, Sime Darby, and Wilmar.QL Resources Bhd appears to sell (directly or indirectly) to AAK, ADM, Cargill, ISF, Itochu, and Louis Dreyfus.

https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgwNWQtNDBiMS1hYTVkLTM4ZWQwZjlzNjczNQAQAHz29SvoHkOljZ1IYd5yWrO%3D Page 1 of 2

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Wings Agro Group appears to sell (directly or indirectly) to AAK, Cargill, Fuji Oil, and Neste.Samling Group appears to sell (directly or indirectly) to AAK, BLD Plantation Bhd, IOI, Itochu, Lipsa, Neste, Olam, and Sarawak Oil Palms Bhd.

As Sarawak Oil Palms Bhd (SOPB) continues to source palm oil from the Samling Group, we request that palm oil traders that buy from SOPB ask the company to suspend the Samling Group, as many traders have already done (e.g. ADM, Bunge, Cargill, LDC, KLK, Sime Darby and Wilmar). Customers of SOPB include AAK, Cargill, KLK, Lipsa, Louis Dreyfus, Mewah, Neste and Sime Darby.

As mentioned in the cover email with Rapid Response report 13 and subsequent emails, Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. 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 May 22, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond.

Thanks, and stay safe!

SARAH BRICKMAN I SENIOR ASSOCIATE I miqhtvearth.org

[email protected] us: acebook I Twitter

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

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

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

Department of Justice, Washington, D.C.

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Received by NSD/FARA Registration Unit 05/09/2020 9:02:39 AM

MIGHTY EARTH

RAPID RESPONSEPalm Oil Report

$

\-w.;:

\ /£

T

Prepared with

MapHubs

Waxman

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/•> V

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Table of ContentsCases identified using Sentinel imagery

Indonesian Companies

New Case

Fangiono family companies: PT Agrindo Green Lestari 5

Unresolved Cases

QL Resources Bhd: PT Pipit Mutiara Indah 9

Wings Agro Group: PT Indopenta Sejahtera Abadi L3

Sanding: PT Tunas Borneo Plantations 1(5

Malaysian Companies

Unresolved Case

Samling: LPF/0007 Sanding Jelalong (OP) 22

Additional cases identified using filtered GLAD alerts

New Cases - No Known Supply Chain Links

PT Buana Pratama Cipta (formerly Provident Agro): PT Banyan Tumbuh Lestari 27

Unknown Group: PT Tualang Raya 27

Repeat Cases - Known Supply Chain Links. 28

Sepanjang Group: PT Permata Sawd Mandin28

Widya Corporation: PT Mulia Inti Perkasa

Indonusa Group: PT Internusa Jaya Sejahtera28

NPC Resources Bhd: PT Sumber Alam Selaras28

Mulia Sawit Group: PT Persada Era Agro Kencana 2g

Dharma Satya Nusantara: PT Putra Utama Lestari 2g

Capitol Group: PT Medcopapua Hijau Selaras 2g

Dhanistha Surya Nusantara: PT Sabhantara Rawi Sentosa 2g

Pinehill Pacific: PT Makmur Jaya Malindo 28

Global Enterprise Sdn Bhd: PT Bulungan Surya Mas Pratama 2 28

Bumitama Group: PT Damai Agro Sejahtera 28

Dharma Satya Nusantara: PT Putra Utama Lestari 29

Hayel Saeed Anam Group: PT Megakarya Jaya Raya 29

Samuel International Group: PT Bina Sarana Sawit Utama 29

Genting Plantations Bhd: PT Citra Sawit Cemerlang 29

Fangiono family companies: PT Tirta Madu Sawit Jaya 29

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Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases - Known Supply Chain Links (continued)

Mulia Sawit Group: PT Persada Era Agro Kencana

Global Enterprise Sdn Bhd: PT Bulungan Surya Mas Pratama

Asian Agri (RGE): PT Usaha Sawit Unggul

Makin Group: PT Mekar Karya Kahuripan

CB Industrial Product Holding: PT Jaya Jadi Utama

Anglo-Eastern Plantations: PT Kahayan Agro Plantation

Shin Yang Group: LPF/0018 Shin Yang OP Planting Area

KTS Holdings Sdn Bhd: BLD Plantation Bhd

Puncak Niaga Holdings Bhd: Danum Sinar Sdn Bhd

Shin Yang Group / Sarawak Oil Palms Bhd: Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum LD)

BBC Holdings Sdn Bhd: Almabumi Plantation Sdn Bhd

Rimbunan Hijau Group: Woodijaya Sdn Bhd (Lot 197)

Sanding Group: LPF/0006 Sanding Lana

Shin Yang Group: Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD)

Woodman Group: Baram Estate, part of LPF/0004

Rimbunan Hijau Group: Timrest Sdn Bhd

TH Plantations Bhd: Hydroflow Sdn Bhd

Woodman Group: Adong estate, part of LPF 0004

Rimbunan Hijau Group: Poh Zhen Sdn Bhd

Repeat Cases - No Known Supply Chain Links

Korompis family: PT Berau Karetindo Lestari

Green Yield Pte Ltd: PT Tri Investama

Unknown Group: PT Prasetya Mitra Muda (Block II)

Unknown Group: PT Marita Makmur Jaya

Unknown Group: PT Gapura Alas Lestari

JSK International Co Ltd (Korea): PT Future Agropia Indonesia

Unknown Group: PT Citrapermata Serundung

IMC Plantations: PT Perkebunan Inti Sendawar

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29

29

29

29

29

29

29

30

30

30

30

30

30

30

30

30

30

30

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

those mill disclosures; please send to [email protected].

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

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Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases - No Known Supply Chain Links (continued)

Unknown Group: PT Cipta Karya Sesayap 31

Unknown Group: PT Sumber Sawit Mitrajaya 31

Unknown Group: PT Pipit Citra Persada 31

Shanghai Xinjiu Chemical Co Ltd: PT Sebaung Sawit Plantation 31

Unknown Group: PT Barito Riau Jaya 31

Unknown Group: PT Triomas Forestry Development Indonesia 31

Henan Jiujiu Chemical Co. Ltd: PT Palem Segar Lestari 32

Unknown Group: PT Menthobi Mitra Lestari 32

Starmas Sentosa Mandiri: PT Agrindo Sukses Sejahtera 32

Unknown Group: Telliana Enterprise Sdn Bhd 32

Unknown Group: Formerly Ekran Bhd 32

Unknown Group: Titanium Management Sdn Bhd (Part 1) 32

Unknown Group: Titanium Management Sdn Bhd (Part 2) 32

Lee Ling Timber Sdn Bhd: Limba Jaya Timber Sdn Bhd (Limbang) 32

Lee Ling Timber Sdn Bhd: LPF/0038 Limba Jaya Timber Sdn Bhd (Part 2) 32

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

those mill disclosures; please send to [email protected].

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

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Group: Fangiono family companiesPT Agrindo Green LestariConcession location: (-1.691, 113.874)

Deforestation and/or peat development

Report

Report 27

Deforestation

(ha)

149

Peat Peat forest Clearance

development development prep/Stacking

(ha) (ha) lines(ha)

Time period

September 11,2019-

February 23, 2020

Satellite imagery (see below) shows that between September 11,2019 and February 23, 2020 a total

of 149 hectares of forest were cleared in the PT Agrindo Green Lestari concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

Vietnam Philippine^

Malaysia

tibonesia

PT Agrindo Green

Q.Lestari

PT Agnndo Grew Lestari

I

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Alert Imagery (before and after satellite images)

Clearance location: (-1.715, 113.889)

Date: September 11,2019 Date: February 23, 2020

Sk

itb

Clearance location: (-1.659, 113.867)

Date: September 11,2019 Date: February 23, 2020

i

yI WM

Iflr A ‘'m. -1 666726. M3 864314.J k

Ownership Information

PT Agrindo Green Lestari is part of the Ciliandry Anky Abadi Group (CAA),1 owned by the Fangiono

family. The Fangiono family also owns Fangiono Agro Plantation (FAP). l.

l. Notaiy deeds

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Supply Chain Information

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Supply Chain Links:

Traders and Biofuel

Companies

PT Agrindo Green

Lestari

Itochu Musim Mas

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

Supply Chain Links:

Traders and Biofuel

Companies

PT Agrindo Green

Lestari

Neste Olam Sime Darby Wilmar

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

X

Supply Chain Links:

Consumer Brands

PT Agrindo Green

Lestari

AvonColgate-

PalmoliveDanone FrieslandCampina

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

Supply Chain Links:

Consumer Brands

PT Agrindo Green

Lestari

General Mills HersheyJohnson &

JohnsonKellogg's

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

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Supply Chain Information (continued)

Supply Chain Links:

Consumer BrandsMondelez Nestle PepsiCo

PT Agrindo Green

Lestari

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

Supply Chain Links:

Consumer BrandsReckitt Benckiser Unilever Vandemoortele

PT Agrindo Green Lestari

Ciliandry Anky

Abadi/Fangiono Agro

Plantation

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Group: QL Resources Bhd

PT Pipit Mutiara IndahConcession location: (3.349, 117.220)

Deforestation and/or peat development

Report

Report 21

Deforestation

(ha)

50

Peat Peat forest Clearance

developme development prep/Stacking

nt(ha) (ha) lines(ha)

Time period

January 3-October

20, 2019

Report 27 25December 22, 2019-

March 16, 2020

Satellite imagery (see below) shows that between December 22, 2019 and March 16, 2020 a total of

25 hectares of forest were cleared in the PT Pipit Mutiara Indah concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

a)

VietnamPhilippines

PT Pipit Mutiara Indah g /

PT Pipit Mutiara Indah

Base Map - C Bing Maps. (31 Dae 2014 01

•• 'i . ~:t ' U'.V’,. ..

alaysia q

Indonesia

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Alert Imagery (before and after satellite images)

Clearance location: (3.388, 117.236)

Date: December 22, 2019 Date: March 16, 2020

1*

&Ownership InformationPT Pipit Mutiara Indah is part of QL Resources Bhd.2

2. QL Resources Bhd Annual Report 2019: http://ql.listedcompany.com/misc/ar2019.pdf.

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Supply Chain Information

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Supply Chain

Links: Traders

and Biofuel

Companies

PT Pipit Mutiara

Indah

AAK ADM Cargill

Louis

Itochu Dreyfus

QL Resources

Bhd

Supply Chain Links:

Consumer BrandsAvon

Colgate-

PalmoliveDanone FrieslandCampina

PT Pipit Mutiara

Indah

QL Resources Bhd

Supply Chain Links:

Consumer BrandsGeneral Mills Hershey Kellogg's

PT Pipit Mutiara Indah

QL Resources Bhd

Supply Chain Links:

Consumer BrandsMars Mondelez Nestle Nisshin Oillio

PT Pipit Mutiara

Indah

QL Resources Bhd

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Supply Chain Information (continued)

Supply Chain Links:

Consumer BrandsPepsiCo PZ Cussons

Reckitt

Benckiser

PT Pipit Mutiara

Indah

QL Resources Bhd

Supply Chain Links: Consumer

BrandsUnilever Upfield

PT Pipit Mutiara Indah

QL Resources Bhd

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Group: Wings Agro GroupPT Indopenta Sejahtera AbadiConcession location: (-2.110, 114.952)

Deforestation and/or peat development

Report

Report 19

Deforestation

(ha)

54

Peat Peat forest Clearance

developme development prep/Stacking

nt(ha) (ha) lines(ha)

Time period

May 12-August 21,

2019

Report 20 43 (GLAD alerts)August 15-

aeptember 15,2019

Report 21 12 (GLAD alerts)September 16-

October 15, 2019

Report 27 11October 11,2019-

Ma 'H 02i

Satellite imagery (see below) shows that between October 11,2019 and March 18, 2020 a total of 11

hectares of forest were cleared in the PT Indopenta Sejahtera Abadi concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

Vietnam 1/Philippines

Malaysia

Indonesia

PT Indopenta Sejahtera Abadi

PT Indopenta Sejahtera Abadi

V'

n

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Alert Imagery (before and after satellite images)

Clearance location: (-2.110, 114.952)

Date: October 11,2019 Date: March 18, 2020

Ownership InformationPT Indopenta Sejahtera Abadi is part of the Wings Agro Group.3

3. Wings Agro website: www.wingsagro.com/eng/ourbusines.

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Supply Chain Information

Supply Chain Links:

Traders and Biofuel

Companies

PT Indopenta

Sejahtera Abadi

Cargill Fuji Oil Neste

Wings Agro Group

Supply Chain Links:

Consumer BrandsGeneral Mills Hershey Kellogg's Nestle

PT Indopenta

Sejahtera Abadi

Wings Agro Group

Supply Chain Links:

Consumer BrandsPepsiCo PZ Cussons Unilever

PT Indopenta

Sejahtera Abadi

Wings Agro Group

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Group: SamlingPT Tunas Borneo PlantationsConcession location: (2.591, 117.522)

Deforestation and/or peat development

Report

Report 18

Deforestation

(ha)

13

Peat Peat forest Clearance

development development prep/Stacking

(ha) (ha) lines(ha)

Time period

May 3-August 3,

2019

Report 27 85February 22-April 27,

2020

Satellite imagery (see below) shows that between February 22, 2020 and April 27, 2020 a total of 85

hectares of forest were cleared in the PT Tunas Borneo Plantations concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

aj

VietnamPhilippines

PT Tunas Borneo q , Plantations

PT Tunas Borneo Plantations Ban Map - O Bing Maps; (31 Dac 2014 QMT)

alaysia

Indonesia

m % i* * vV' '/*i-. -f

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Alert Imagery (before and after satellite images)

Clearance location: (2.688, 117.552)

Date: February 22, 2020 Date: April 27, 2020

r

Lft

r

Ownership Information

PT Tunas Borneo Plantations is part of the Samling Group.4

4. www.samling.com/contact.php

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Case Notes

Since February 2020, ADM, Cargill, Fuji Oil, KLK, LDC, Sime Darby and Wilmar - as well as Hershey’s, Mars, P&G, and Upfield - have all informed Mighty Earth that they have suspended Samling from their supply chains.

Sime Darby informed Mighty Earth that: “We would like to confirm that we have notified Samling

that we will no longer be sourcing from them due to concerns raised by our key customers. Central

to these concerns is the adoption ofNDPE commitments across the whole Samling Group, and not

just for Glenealy Plantations.”

On 15 April 2020, Samling responded to these suspensions - not by halting all Samling group-wide deforestation, but by offering up the smallest fig leaf: Glenealy Plantations Sdn Bhd announced an NDPE policy and a memo issuing a “group-wide moratorium on any land clearing for all greenfield

development on mineral soil andpeatland regardless of depth with immediate effect until further

notice.’”

Several traders and biodiesel companies - AAK, BLD, IOI, Neste, Olam, Sarawak Oil Palms Bhd (SOPB) - and consumer brands, including Mondelez, Nestle, and PepsiCo, have yet to take action to suspend Samling from their supply chains.

Glenealy has also been circulating information to traders claiming that ‘Glenealy holds all the oil

palm estates and mills’ and that the company owns 100% of the shares in Timor Enterprise Sdn Bhd (through Puncak Selasih Sdn Bhd) which owns the Jelalong, Lana and Belaja palm oil operations, Samling Plantations Sdn Bhd and other entities (see left graphic below).

Based on this information, it would be assumed that the moratorium applies to all Glenealy-owned plantation areas. However, according to shareholder ownership data obtained from the Companies Commission of Malaysia, Glenealy Plantations only owns 15.31% of Timor Enterprise Sdn Bhd. The majority shareholder (84.68%) in Timor Enterprise Sdn Bhd is Lingui Developments Sdn Bhd, which is 100% owned by Samling Malaysia Incorporated, registered in the British Virgin Islands (see right graphic below).

*GLENEALY PLANTATIONS SDN BHD

PUNCAK SELASIH SDN BHD

TIMOR ENTERPRISES SON BHD

Opoibon of ol plmUtiom wd d nit in S1W11 SvimL

(ttAttUtn-fotiarmori (AOEtUItt

Strand EsMn - Im, kiiloni)

|0i Mis - TP0M in Sibih, IP0M <nd IP0M in Wmdl

rm

SAMUNG PLANTATION SON BHD

Opera ef oil pom owe ■ tap E«*f

* MU-VON

SHARIKO SON BHD

Opera oFdpJmaSra

FFB protod 0 Skrito EttttfctpKM

MINN________________

TIUEIAND DEVELOPMENT SON BHD

OperatfdpUmaSra

(ft nara ■ notM fun onpittM

MlNM_________________

Name

Registration No.

IC/Passport/ Registration No.

SHAREHOLDERS/MEMBERS

: TIMOR ENTERPRISES SDN BHD : 196801000390 (7998-H)

196701000630 (7S74-D) LINGUI DEVELOPMENTS SDN BHD

199801012243 (468371-D) PUNCAK SELASIH SDH. BHD.

141,567

25,600

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Supply Chain Information

Supply Chain Links:

Traders and Biofuel

Companies

PT Tunas Borneo Plantations

BLD Plantation

BhdItochu

Samling

Supply Chain

Links: Traders

and Biofuel

Companies

PT Tunas Borneo Plantations

Lipsa Neste Olam Sarawak Oil Palms

Samling

Supply Chain Links:

Consumer BrandsAvon

Colgate-

PalmoliveDanone FrieslandCampina

PTTunas Borneo

Plantations

Samling

Supply Chain Links:

Consumer BrandsGeneral Mills

Johnson &

JohnsonKellogg's Mondelez

PT Tunas Borneo Plantations

Samling

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Supply Chain Information (continued)

Supply Chain Links:

Consumer BrandsNestle Nisshin Oillio PepsiCo PZ Cussons

PT Tunas Borneo Plantations

Samling

Supply Chain Links:

Consumer BrandsReckitt Benckiser Vandemoortele

PT Tunas Borneo Plantations

Samling

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Supply Chain Information (continued)

Although SOPB published an NDPE policy in January 2019, the company has not published a mill list disclosing its suppliers and sources of palm oil. While SOPB has listed several of Mighty Earth’s Rapid Response cases on Samling in its grievance list, the company has failed to address these grievances or suspend Samling.

Several traders, biofuel companies and consumers brands are sourcing palm oil originating from SOPB (see tables below). These companies should file grievances with SOPB, requesting that it acts on the Samling case and suspends them.

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Cargill Lipsa

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Louis Dreyfus Mewah Neste Sime Darby

Supply Chain Links:

Consumer Brands

Sarawak Oil Palms

AvonColgate-

Palmolive

Friesland

CampinaHershey

Johnson &

Johnson

Supply Chain Links:

Consumer Brands

Sarawak Oil Palms

Kellogg's Mars PepsiCo

Supply Chain Links: PZ Reckitt

Consumer Brands Cussons BenckiserUnilever Upfield Vandemoortele

Sarawak Oil Palms

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Group: SamlingLPF/0007 Samling Jelalong (OP)Concession location: (3.313, 113.885)

Deforestation and/or peat development

Report

Report 18

Deforestation

(ha)

33 (via GLAD)

Peat Peat forest Clearance

development development prep/Stacking

(ha) (ha) lines(ha)

Time period

June 15-July 15,

2019

Report 19 95 (via GLAD)July 15-August 15,

2019

Report 20 96 (via GLAD)August 15-

?eptember 15, 2019

Report 21 38 (via GLAD)September 16-

October 15, 2019

Report 23 131 (via GLAD)November 15-

December 6, 2019

Report 240.15 (via

GLAD)

December 15, 2019-

January 15, 2020

Report 25 68 (via GLAD)January 1 5-February

17, 2020

Report 26 72 (via GLAD)February 1 7-March

16, 2020

Report 27 91May 24, 2019-April

17, 2020

Satellite imagery (see below) shows that between May 24, 2019 and April 27, 2020 a total of 91

hectares of forest were cleared in the LPF/0007 Samling Jelalong (OP) concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

rma)

VietnamPhilippines

Malaysia

Indonesia

LPF/0007 Samling Jela- $ 0. I'Song (OP)

VA

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Alert Imagery (before and after satellite images)Clearance location: (3.31 7, 113.844)

Date: May 24, 201 9 Date: April 17, 2020

Ownership Information

LPF/0007 Samling Jelalong (OP) is part of the Samling Group.5

Case NotesSee case notes for previous Samling case (PT Tunas Borneo Plantations) on page 17.

5. www.samling.com/

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Supply Chain Information

Supply Chain Links:

Traders and Biofuel

Companies

LPF/0007 Samling

Jelalong (OP)

BLD Plantation

BhdItochu

Samling

Supply Chain

Links: Traders

and Biofuel

Companies

LPF/0007

Samling Jelalong

(OP)

Lipsa Neste Olam Sarawak Oil Palms

Samling

Supply Chain Links:

Consumer Brands

LPF/0007 Samling

Jelalong (OP)

AvonColgate-

PalmoliveDanone FrieslandCampina

Samling

Supply Chain Links:

Consumer BrandsGeneral Mills

Johnson &

JohnsonKellogg's Mondelez

LPF/0007 Samling

Jelalong (OP)

Samling

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Supply Chain Information (continued)

Supply Chain Links:

Consumer Brands

LPF/0007 Samling

Jelalong (OP)

Nestle Nisshin Oillio PepsiCo PZ Cussons

Samling

Supply Chain Links:

Consumer BrandsReckitt Benckiser Vandemoortele

LPF/0007 Samling

Jelalong (OP)

Samling

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Supply Chain Information (continued)

Although SOPB published an NDPE in January 2019, the company has not published a mill list disclosing its suppliers and sources of palm oil. Although, SOPB has listed several Mighty Earth cases on Samling in its grievance list, the company have failed to address these grievances or suspend Samling.

A number of traders, biofuel companies and consumers brands are sourcing palm oil originating from SOPB (see tables below). These companies should file grievances with SOPB, requesting that it acts on the Samling case and suspends them.

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Cargill Lipsa

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Louis Dreyfus Mewah Neste Sime Darby

Supply Chain Links:

Consumer BrandsAvon

Colgate-

Palmolive

Friesland

CampinaHershey

Johnson &

Johnson

Sarawak Oil Palms

Supply Chain Links:

Consumer Brands

Sarawak Oil Palms

Kellogg's Mars PepsiCo

Supply Chain Links: PZ Reckitt

Consumer Brands Cussons BenckiserUnilever Upfield Vandemoortele

Sarawak Oil Palms

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

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

due diligence to determine if they are exposed to such companies/Groups and conduct their own satellite image analysis of these cases.

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

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

New Cases - Unknown Supply Chain Links

Concession license area Group/ownership

Area covered by

screened GLAD Time period

alerts (ha)

PT Banyan Tumbuh Lestari PT Buana Pratama Cipta (formerly Provident Agro) 14.02

March 16-April 15, 2020

PTTualang Raya Unknown Group 27.32March 16-April 15, 2020

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Repeat Cases - Known Supply Chain Links

Concession license area

PT Citra Agro Abadi

Group/ownership

Cilandry Anky AbadiGroup

Areacovered by screened GLAD alerts (ha)

160.70

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 17, 23, 25, 26

PT Permata Sawit MandiriSepanjang Group (PT PSM formerly owned by Genting Group)

484.40March 16-Apri 15, 2020

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

PT Mulia Inti Perkasa Widya Corporation 134.66March 16-Apri 15, 2020

Reports 6, 15, 16,20,21,22, 23, 24,25,26

PT Internusa Jaya Sejahtera Indonusa Group 111.11March 16-Apri 15, 2020

Reports 7, 10,11, 12, 15, 16, 17,20, 22,23,25

PT Sumber Alam Selaras NPC Resources Bhd 101.69March 16-Apri 15, 2020

Reports 23, 25, 26

PT Persada Era Agro Kencana Mulia Sawit Group 83.56March 16-Apri 15, 2020

Reports 9, 10, 11, 12, 15, 16, 17, 18, 19, 20, 22,23,24,25

PT Putra Utama LestariDharma Satya Nusantara

37.33March 16-Apri 15, 2020

Reports 20 and 23

PT Medcopapua Hijau Selaras Capitol Group 35.08March 16-Apri 15, 2020

Reports 25 and 26

PT Sabhantara Rawi SentosaDhanistha Surya Nusantara

25.79March 16-Apri 15, 2020

Reports 21,23, 26

PT Makmur Jaya Malindo Pinehill Pacific 22.30March 16-Apri 15, 2020

Reports 18 and 19

PT Bulungan Surya Mas Pratama 2

Global Enterprise Sdn Bhd 22.19

March 16-Apri 15, 2020

Report 21

PT Damai Agro Sejahtera Bumitama Group 20.90March 16-Apri 15, 2020

Reports 22, 23, 26

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

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Repeat Cases - Known Supply Chain Links

Concession license area

PT Putra Utama Lestari

Group/ownership

Dharma Satya Nusantara

Areacovered by screened GLAD alerts (ha)

20.14

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 20 and 23

PT Megakarya Jaya RayaHayel Saeed Anam Group

19.78March 16-Apri 15, 2020

Reports 5, 23, 26

PT Bina Sarana Sawit UtamaSamuel International Group

18.28March 16-Apri 15, 2020

Reports 19, 20, 24, 26

PT Citra Sawit CemerlangGentinq Plantations Bhd 17.65

March 16-Apri 15, 2020

Reports 14, 15, 16, 17, 19, 23, 24

PTTirta Madu Sawit Jaya Fangiono family 16.38March 16-Apri 15, 2020

Reports 22, 24, 25

PT Persada Era Agro Kencana Mulia Sawit Group 14.08March 16-Apri 15, 2020

Reports 9, 10, 11, 12, 15, 16, 17, 18, 19, 20, 22,23,24,25

PT Bulungan Surya Mas Pratama

Global Enterprise Sdn Bhd 13.38

March 16-Apri 15, 2020

Report 21

PT Usaha Sawit Unggul Asian Agri (RGE) 12.31March 16-Apri 15, 2020

Reports 17, 18, 20, 24, 26

PT Mekar Karya Kahuripan Makin Group 12.00March 16-Apri 15, 2020

Reports 17, 21, 22, 23, 26

PT Jaya Jadi UtamaCB Industrial Product Holding 11.93

March 16-Apri 15, 2020

Reports 15, 20, 23, 26

PT Kahayan Agro PlantationAnglo-EasternPlantations 10.30

March 16-Apri 15, 2020

Reports 1,14, 15, 18, 19, 20, 23, 24, 25

LPF/0018 Shin Yang OP Planting Area

Shin Yang Group 101.11March 16-Apri 15, 2020

LPF/0018 Shin Yang OP Planting Area

BLD Plantation BhdKTS Holdings Sdn Bhd 54.86

March 16-Apri 15, 2020

BLD Plantation Bhd

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

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Repeat Cases - Known Supply Chain Links

Concession license area

Danum Sinar Sdn Bhd

Group/ownership

Puncak Niaga Holdings Bhd

Areacovered by screened GLAD alerts (ha)

52.99

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Danum Sinar Sdn Bhd

Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum LD)

Shin Yang Group / Sarawak Oil Palms Bhd

47.19March 16-Apri 15, 2020

Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum

ID)______________

Almabumi Plantation Sdn BhdBBC Holdings Sdn Bhd 19.72

March 16-Apri 15, 2020

Almabumi Plantation Sdn Bhd

Woodijaya Sdn Bhd (Lot 197)Rimbunan Hijau Group

16.84March 16-Apri 15, 2020

Woodijaya Sdn Bhd (Lot 197)

LPF/0006 Samling Lana Samling Group 13.54March 16-Apri 15, 2020

LPF/0006 Samling Lana

Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD)

Shin Yang Group 13.23March 16-Apri 15, 2020

Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD)

Baram Estate, part of LPF/0004 Woodman Group 9.96March 16-Apri 15, 2020

Baram Estate, part of LPF/0004

Timrest Sdn BhdRimbunan Hijau Group

9.74March 16-Apri 15, 2020

Timrest Sdn Bhd

Hydroflow Sdn Bhd TH Plantations Bhd 9.60March 16-Apri 15, 2020

Hydroflow Sdn Bhd

Adong estate, part of LPF 0004 Woodman Group 8.26March 16-Apri 15, 2020

Adong estate, part of LPF 0004

Poh Zhen Sdn BhdRimbunan Hijau Group

7.89March 16-Apri 15, 2020

Poh Zhen Sdn Bhd

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

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Repeat Cases - No Known Supply Chain Links

Concession license area Group/ownership

PT Berau Karetindo Lestari Korompis family

Areacovered by screened GLAD alerts (ha)

100.06

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 2, 6, 9, 15, 16, 19, 20, 21,22

PT Tri Investama Green Yield Pte Ltd 11.07March 16-Apri 15, 2020

Reports 20, 21, 22,23, 24,25

PT Prasetya Mitra Muda (BlockUnknown Group 14.17

March 16-Apri 15, 2020

Reports 6, 17, 19

PT Marita Makmur Jaya Unknown Group 14.24March 16-Apri 15, 2020

Reports 12, 15, 17, 19,22,24,26

PT Gapura Alas Lestari Unknown Group 14.87March 16-Apri 15, 2020

Reports 16, 19, 20,23,25,26

PT Future Agropia IndonesiaJSK International Co Ltd (Korea) 15.78

March 16-Apri 15, 2020

Reports 17 and 20

PT Citrapermata Serundung Unknown Group 15.88March 16-Apri 15, 2020

Reports 20, 23, 26

PT Perkebunan Inti Sendawar IMC Plantations 17.81March 16-Apri 15, 2020

Reports 23 and 26

PT Cipta Karya Sesayap Unknown Group 19.55March 16-Apri 15, 2020

Reports 17, 22, 23, 25

PT Sumber Sawit Mitrajaya Unknown Group 20.06March 16-Apri 15, 2020

Reports 15, 17, 23, 25, 26

PT Pipit Citra Persada Unknown Group 22.03March 16-Apri 15, 2020

Reports 6, 17, 20

PT Sebaung Sawit PlantationShanghai Xinjiu Chemical Co Ltd 22.87

March 16-Apri 15, 2020

Reports 8, 12, 13, 16,20,21, 22, 23, 25

PT Barito Riau Jaya Unknown Group 24.01March 16-Apri 15, 2020

Reports 22, 23, 26

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

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Repeat Cases - No Known Supply Chain Links

Concession license area

PTTriomas Forestry Development Indonesia

Group/ownership

Unknown Group

Areacovered by screened GLAD alerts (ha)

43.99

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 17, 22, 23, 24

PT Palem Segar Lestari Henan Jiujiu Chemical Co. Ltd 57.88

March 16-Apri 15, 2020

Reports 5, 7, 12, 16, 18,20,21, 22,23,25,26

PT Menthobi Mitra Lestari

Unknown Group (PT MML formerly owned by PT Bakrie Sumatra Plantations Tbk)____

64.25March 16-Apri 15, 2020

Reports 16, 17,20, 22

PT Agrindo Sukses Sejahtera Starmas Sentosa Mandiri 95.34

March 16-Apri 15, 2020

Reports 8, 16, 22, 26

Telliana Enterprise Sdn Bhd Unknown Group 37.09March 16-Apri 15, 2020

Reports 18, 19, 20, 26

Formerly Ekran Bhd Unknown Group 27.30March 16-Apri 15, 2020

Reports 19, 20, 21,23,25,26

Titanium Management Sdn Bhd (Part 1)

Unknown Group 26.03March 16-Apri 15, 2020

Reports 18, 19, 21,26

Titanium Management Sdn Bhd (Part 2)

Unknown Group 17.39March 16-Apri 15, 2020

Reports 18, 19, 21,26

Limba Jaya Timber Sdn Bhd (Limbang)

Lee Linq Timber Sdn Bhd 7.95

March 16-Apri 15, 2020

Reports 18, 21, 26

LPF/0038 Limba Jaya Timber Sdn Bhd (Part 2)

Lee Linq Timber Sdn Bhd 7.88

March 16-Apri 15, 2020

Reports 18, 21, 26

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

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

in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf

of the aforementioned organization, working under grant from theNorwegian Agency for Development

Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.

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Rapid Response report 27

Rapid Response <[email protected]>Fri 5/8/2020 7:50 PM

To: 'Gruijter, Laura-de1 |@bunge.com>Cc: Sarah Brickman <[email protected]>;Conry @bunge.com>; jaideep.bedi

@bunge.com' @bunge.com>; [email protected]>; Phil Aikman <[email protected]>

| 1 attachments (3 MB)

Rapid Response Report 27_final.pdf;

Dear Laura -

Today, we are releasing Mighty Earth's Rapid Response report 27. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia (listed by Group, if known, then by concession name):

The following are new cases of deforestation and/or peatland development (in order of appearance in report 27) with known supply chain links:

Fangiono family companies: PT Agrindo Green Lestari

The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 26) with known supply chain links:

QL Resources Bhd: PT Pipit Mutiara Indah Wings Agro Group: PT Indopenta Sejahtera Abadi Samling: PT Tunas Borneo Plantations Samling: LPF/0007 Samling Jelalong (OP)

The report also includes 59 repeat cases of deforestation that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because, for the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports.

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

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

Fangiono family companies appears to sell (directly or indirectly) to AAK, Itochu, KLK,Musim Mas, Neste, Olam, Sime Darby, and Wilmar.QL Resources Bhd appears to sell (directly or indirectly) to AAK, ADM, Cargill, ISF, Itochu, and Louis Dreyfus.

https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgw...BiMS1hYTVkLTM4ZWQwZjlzNjczNQAQAD51ED%2FNmERLqt6fHuK%2BzPw%3D Page 1 of 2

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Wings Agro Group appears to sell (directly or indirectly) to AAK, Cargill, Fuji Oil, and Neste.Samling Group appears to sell (directly or indirectly) to AAK, BLD Plantation Bhd, IOI, Itochu, Lipsa, Neste, Olam, and Sarawak Oil Palms Bhd.

As Sarawak Oil Palms Bhd (SOPB) continues to source palm oil from the Samling Group, we request that palm oil traders that buy from SOPB ask the company to suspend the Samling Group, as many traders have already done (e.g. ADM, Bunge, Cargill, LDC, KLK, Sime Darby and Wilmar). Customers of SOPB include AAK, Cargill, KLK, Lipsa, Louis Dreyfus, Mewah, Neste and Sime Darby.

As mentioned in the cover email with Rapid Response report 13 and subsequent emails, Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. 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 May 22, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond.

Thanks, and stay safe!

SARAH BRICKMAN I SENIOR ASSOCIATE I miqhtvearth.org

[email protected] us: acebook I Twitter

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

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

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

Department of Justice, Washington, D.C.

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MIGHTY EARTH

RAPID RESPONSEPalm Oil Report

$

\-w.;:

\ /£

T

Prepared with

MapHubs

Waxman

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V

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Table of ContentsCases identified using Sentinel imagery

Indonesian Companies

New Case

Fangiono family companies: PT Agrindo Green Lestari 5

Unresolved Cases

QL Resources Bhd: PT Pipit Mutiara Indah 9

Wings Agro Group: PT Indopenta Sejahtera Abadi L3

Sanding: PT Tunas Borneo Plantations 1(5

Malaysian Companies

Unresolved Case

Samling: LPF/0007 Sanding Jelalong (OP) 22

Additional cases identified using filtered GLAD alerts

New Cases - No Known Supply Chain Links

PT Buana Pratama Cipta (formerly Provident Agro): PT Banyan Tumbuh Lestari 27

Unknown Group: PT Tualang Raya 27

Repeat Cases - Known Supply Chain Links. 28

Sepanjang Group: PT Permata Sawd Mandin28

Widya Corporation: PT Mulia Inti Perkasa

Indonusa Group: PT Internusa Jaya Sejahtera28

NPC Resources Bhd: PT Sumber Alam Selaras28

Mulia Sawit Group: PT Persada Era Agro Kencana 2g

Dharma Satya Nusantara: PT Putra Utama Lestari 2g

Capitol Group: PT Medcopapua Hijau Selaras 2g

Dhanistha Surya Nusantara: PT Sabhantara Rawi Sentosa 2g

Pinehill Pacific: PT Makmur Jaya Malindo 28

Global Enterprise Sdn Bhd: PT Bulungan Surya Mas Pratama 2 28

Bumitama Group: PT Damai Agro Sejahtera 28

Dharma Satya Nusantara: PT Putra Utama Lestari 29

Hayel Saeed Anam Group: PT Megakarya Jaya Raya 29

Samuel International Group: PT Bina Sarana Sawit Utama 29

Genting Plantations Bhd: PT Citra Sawit Cemerlang 29

Fangiono family companies: PT Tirta Madu Sawit Jaya 29

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Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases - Known Supply Chain Links (continued)

Mulia Sawit Group: PT Persada Era Agro Kencana

Global Enterprise Sdn Bhd: PT Bulungan Surya Mas Pratama

Asian Agri (RGE): PT Usaha Sawit Unggul

Makin Group: PT Mekar Karya Kahuripan

CB Industrial Product Holding: PT Jaya Jadi Utama

Anglo-Eastern Plantations: PT Kahayan Agro Plantation

Shin Yang Group: LPF/0018 Shin Yang OP Planting Area

KTS Holdings Sdn Bhd: BLD Plantation Bhd

Puncak Niaga Holdings Bhd: Danum Sinar Sdn Bhd

Shin Yang Group / Sarawak Oil Palms Bhd: Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum LD)

BBC Holdings Sdn Bhd: Almabumi Plantation Sdn Bhd

Rimbunan Hijau Group: Woodijaya Sdn Bhd (Lot 197)

Sanding Group: LPF/0006 Sanding Lana

Shin Yang Group: Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD)

Woodman Group: Baram Estate, part of LPF/0004

Rimbunan Hijau Group: Timrest Sdn Bhd

TH Plantations Bhd: Hydroflow Sdn Bhd

Woodman Group: Adong estate, part of LPF 0004

Rimbunan Hijau Group: Poh Zhen Sdn Bhd

Repeat Cases - No Known Supply Chain Links

Korompis family: PT Berau Karetindo Lestari

Green Yield Pte Ltd: PT Tri Investama

Unknown Group: PT Prasetya Mitra Muda (Block II)

Unknown Group: PT Marita Makmur Jaya

Unknown Group: PT Gapura Alas Lestari

JSK International Co Ltd (Korea): PT Future Agropia Indonesia

Unknown Group: PT Citrapermata Serundung

IMC Plantations: PT Perkebunan Inti Sendawar

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29

29

29

29

29

29

29

30

30

30

30

30

30

30

30

30

30

30

31

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3i

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3i

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3i

29

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

those mill disclosures; please send to [email protected].

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

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Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases - No Known Supply Chain Links (continued)

Unknown Group: PT Cipta Karya Sesayap 31

Unknown Group: PT Sumber Sawit Mitrajaya 31

Unknown Group: PT Pipit Citra Persada 31

Shanghai Xinjiu Chemical Co Ltd: PT Sebaung Sawit Plantation 31

Unknown Group: PT Barito Riau Jaya 31

Unknown Group: PT Triomas Forestry Development Indonesia 31

Henan Jiujiu Chemical Co. Ltd: PT Palem Segar Lestari 32

Unknown Group: PT Menthobi Mitra Lestari 32

Starmas Sentosa Mandiri: PT Agrindo Sukses Sejahtera 32

Unknown Group: Telliana Enterprise Sdn Bhd 32

Unknown Group: Formerly Ekran Bhd 32

Unknown Group: Titanium Management Sdn Bhd (Part 1) 32

Unknown Group: Titanium Management Sdn Bhd (Part 2) 32

Lee Ling Timber Sdn Bhd: Limba Jaya Timber Sdn Bhd (Limbang) 32

Lee Ling Timber Sdn Bhd: LPF/0038 Limba Jaya Timber Sdn Bhd (Part 2) 32

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

those mill disclosures; please send to [email protected].

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

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Group: Fangiono family companiesPT Agrindo Green LestariConcession location: (-1.691, 113.874)

Deforestation and/or peat development

Report

Report 27

Deforestation

(ha)

149

Peat Peat forest Clearance

development development prep/Stacking

(ha) (ha) lines(ha)

Time period

September 11,2019-

February 23, 2020

Satellite imagery (see below) shows that between September 11,2019 and February 23, 2020 a total

of 149 hectares of forest were cleared in the PT Agrindo Green Lestari concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

Vietnam Philippine^

Malaysia

tibonesia

PT Agrindo Green

Q.Lestari

PT Agnndo Grew Lestari

I

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Alert Imagery (before and after satellite images)

Clearance location: (-1.715, 113.889)

Date: September 11,2019 Date: February 23, 2020

Skitb

Clearance location: (-1.659, 113.867)

Date: September 11,2019 Date: February 23, 2020

i

yI WM

Iflr A ‘'m. -1 666726. M3 864314.J k

Ownership Information

PT Agrindo Green Lestari is part of the Ciliandry Anky Abadi Group (CAA),1 owned by the Fangiono family. The Fangiono family also owns Fangiono Agro Plantation (FAP).

l. Notaiy deeds

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Supply Chain Information

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Supply Chain Links:

Traders and Biofuel

Companies

PT Agrindo Green

Lestari

Itochu Musim Mas

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

Supply Chain Links:

Traders and Biofuel

Companies

PT Agrindo Green

Lestari

Neste Olam Sime Darby Wilmar

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

X

Supply Chain Links:

Consumer Brands

PT Agrindo Green

Lestari

AvonColgate-

PalmoliveDanone FrieslandCampina

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

Supply Chain Links:

Consumer Brands

PT Agrindo Green

Lestari

General Mills HersheyJohnson &

JohnsonKellogg's

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

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Supply Chain Information (continued)

Supply Chain Links:

Consumer BrandsMondelez Nestle PepsiCo

PT Agrindo Green

Lestari

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

Supply Chain Links:

Consumer BrandsReckitt Benckiser Unilever Vandemoortele

PT Agrindo Green Lestari

Ciliandry Anky

Abadi/Fangiono Agro

Plantation

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Group: QL Resources Bhd

PT Pipit Mutiara IndahConcession location: (3.349, 117.220)

Deforestation and/or peat development

Report

Report 21

Deforestation

(ha)

50

Peat Peat forest Clearance

developme development prep/Stacking

nt(ha) (ha) lines(ha)

Time period

January 3-October

20, 2019

Report 27 25December 22, 2019-

March 16, 2020

Satellite imagery (see below) shows that between December 22, 2019 and March 16, 2020 a total of

25 hectares of forest were cleared in the PT Pipit Mutiara Indah concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

a)

VietnamPhilippines

PT Pipit Mutiara Indah g /

PT Pipit Mutiara Indah

Base Map - C Bing Maps. (31 Dae 2014 01

•• 'i . ~:t ' U'.V’,. ..

alaysia q

Indonesia

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Alert Imagery (before and after satellite images)

Clearance location: (3.388, 117.236)

Date: December 22, 2019 Date: March 16, 2020

1*

&Ownership InformationPT Pipit Mutiara Indah is part of QL Resources Bhd.2

2. QL Resources Bhd Annual Report 2019: http://ql.listedcompany.com/misc/ar2019.pdf.

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Supply Chain Information

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Supply Chain

Links: Traders

and Biofuel

Companies

PT Pipit Mutiara

Indah

AAK ADM Cargill

Louis

Itochu Dreyfus

QL Resources

Bhd

Supply Chain Links:

Consumer BrandsAvon

Colgate-

PalmoliveDanone FrieslandCampina

PT Pipit Mutiara

Indah

QL Resources Bhd

Supply Chain Links:

Consumer BrandsGeneral Mills Hershey Kellogg's

PT Pipit Mutiara Indah

QL Resources Bhd

Supply Chain Links:

Consumer BrandsMars Mondelez Nestle Nisshin Oillio

PT Pipit Mutiara

Indah

QL Resources Bhd

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Supply Chain Information (continued)

Supply Chain Links:

Consumer BrandsPepsiCo PZ Cussons

Reckitt

Benckiser

PT Pipit Mutiara

Indah

QL Resources Bhd

Supply Chain Links: Consumer

BrandsUnilever Upfield

PT Pipit Mutiara Indah

QL Resources Bhd

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Group: Wings Agro GroupPT Indopenta Sejahtera AbadiConcession location: (-2.110, 114.952)

Deforestation and/or peat development

Report

Report 19

Deforestation

(ha)

54

Peat Peat forest Clearance

developme development prep/Stacking

nt(ha) (ha) lines(ha)

Time period

May 12-August 21,

2019

Report 20 43 (GLAD alerts)August 15-

aeptember 15,2019

Report 21 12 (GLAD alerts)September 16-

October 15, 2019

Report 27 11October 11,2019-

Ma 'H 02i

Satellite imagery (see below) shows that between October 11,2019 and March 18, 2020 a total of 11

hectares of forest were cleared in the PT Indopenta Sejahtera Abadi concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

Vietnam 1/Philippines

Malaysia

Indonesia

PT Indopenta Sejahtera Abadi

PT Indopenta Sejahtera Abadi

V'

n

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Alert Imagery (before and after satellite images)

Clearance location: (-2.110, 114.952)

Date: October 11,2019 Date: March 18, 2020

Ownership InformationPT Indopenta Sejahtera Abadi is part of the Wings Agro Group.3

3. Wings Agro website: www.wingsagro.com/eng/ourbusines.

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Supply Chain Information

Supply Chain Links:

Traders and Biofuel

Companies

PT Indopenta

Sejahtera Abadi

Cargill Fuji Oil Neste

Wings Agro Group

Supply Chain Links:

Consumer BrandsGeneral Mills Hershey Kellogg's Nestle

PT Indopenta

Sejahtera Abadi

Wings Agro Group

Supply Chain Links:

Consumer BrandsPepsiCo PZ Cussons Unilever

PT Indopenta

Sejahtera Abadi

Wings Agro Group

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Group: SamlingPT Tunas Borneo PlantationsConcession location: (2.591, 117.522)

Deforestation and/or peat development

Report

Report 18

Deforestation

(ha)

13

Peat Peat forest Clearance

development development prep/Stacking

(ha) (ha) lines(ha)

Time period

May 3-August 3,

2019

Report 27 85February 22-April 27,

2020

Satellite imagery (see below) shows that between February 22, 2020 and April 27, 2020 a total of 85

hectares of forest were cleared in the PT Tunas Borneo Plantations concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

aj

VietnamPhilippines

PT Tunas Borneo q , Plantations

PT Tunas Borneo Plantations Ban Map - O Bing Maps; (31 Dac 2014 QMT)

alaysia

Indonesia

m % i * * vV' '/*i-. -f

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Alert Imagery (before and after satellite images)

Clearance location: (2.688, 117.552)

Date: February 22, 2020 Date: April 27, 2020

r

Lft

r

Ownership Information

PT Tunas Borneo Plantations is part of the Samling Group.4

4. www.samling.com/contact.php

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Case Notes

Since February 2020, ADM, Cargill, Fuji Oil, KLK, LDC, Sime Darby and Wilmar - as well as Hershey’s, Mars, P&G, and Upfield - have all informed Mighty Earth that they have suspended Samling from their supply chains.

Sime Darby informed Mighty Earth that: “We would like to confirm that we have notified Samling

that we will no longer be sourcing from them due to concerns raised by our key customers. Central

to these concerns is the adoption ofNDPE commitments across the whole Samling Group, and not

just for Glenealy Plantations.”

On 15 April 2020, Samling responded to these suspensions - not by halting all Samling group-wide deforestation, but by offering up the smallest fig leaf: Glenealy Plantations Sdn Bhd announced an NDPE policy and a memo issuing a “group-wide moratorium on any land clearing for all greenfield

development on mineral soil andpeatland regardless of depth with immediate effect until further

notice.’”

Several traders and biodiesel companies - AAK, BLD, IOI, Neste, Olam, Sarawak Oil Palms Bhd (SOPB) - and consumer brands, including Mondelez, Nestle, and PepsiCo, have yet to take action to suspend Samling from their supply chains.

Glenealy has also been circulating information to traders claiming that ‘Glenealy holds all the oil

palm estates and mills’ and that the company owns 100% of the shares in Timor Enterprise Sdn Bhd (through Puncak Selasih Sdn Bhd) which owns the Jelalong, Lana and Belaja palm oil operations, Samling Plantations Sdn Bhd and other entities (see left graphic below).

Based on this information, it would be assumed that the moratorium applies to all Glenealy-owned plantation areas. However, according to shareholder ownership data obtained from the Companies Commission of Malaysia, Glenealy Plantations only owns 15.31% of Timor Enterprise Sdn Bhd. The majority shareholder (84.68%) in Timor Enterprise Sdn Bhd is Lingui Developments Sdn Bhd, which is 100% owned by Samling Malaysia Incorporated, registered in the British Virgin Islands (see right graphic below).

*GLENEALY PLANTATIONS SDN BHD

PUNCAK SELASIH SDN BHD

TIMOR ENTERPRISES SON BHD

Opoibon of ol plmUtiom wd d nit in S1W11 SvimL

(ttAttUtn-fotiarmori (AOEtUItt

Strand EsMn - Im, kiiloni)

|0i Mis - TP0M in Sibih, IP0M <nd IP0M in Wmdl

r mSAMUNG PLANTATION SON BHD

Opera ef oil pom owe ■ tap E«*f

* MU-VON

SHARIKO SON BHD

Opera oFdpJmaSra

FFB protod 0 Skrito EttttfctpKM

MINN________________

TIUEIAND DEVELOPMENT SON BHD

OperatfdpUmaSra

(ft nara ■ notM fun onpittM

MlNM_________________

Name

Registration No.

IC/Passport/ Registration No.

SHAREHOLDERS/MEMBERS

: TIMOR ENTERPRISES SDN BHD : 196801000390 (7998-H)

196701000630 (7S74-D) LINGUI DEVELOPMENTS SDN BHD

199801012243 (468371-D) PUNCAK SELASIH SDH. BHD.

141,567

25,600

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Supply Chain Information

Supply Chain Links:

Traders and Biofuel

Companies

PT Tunas Borneo Plantations

BLD Plantation

BhdItochu

Samling

Supply Chain

Links: Traders

and Biofuel

Companies

PT Tunas Borneo Plantations

Lipsa Neste Olam Sarawak Oil Palms

Samling

Supply Chain Links:

Consumer BrandsAvon

Colgate-

PalmoliveDanone FrieslandCampina

PTTunas Borneo

Plantations

Samling

Supply Chain Links:

Consumer BrandsGeneral Mills

Johnson &

JohnsonKellogg's Mondelez

PT Tunas Borneo Plantations

Samling

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Supply Chain Information (continued)

Supply Chain Links:

Consumer BrandsNestle Nisshin Oillio PepsiCo PZ Cussons

PT Tunas Borneo Plantations

Samling

Supply Chain Links:

Consumer BrandsReckitt Benckiser Vandemoortele

PT Tunas Borneo Plantations

Samling

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Supply Chain Information (continued)

Although SOPB published an NDPE policy in January 2019, the company has not published a mill list disclosing its suppliers and sources of palm oil. While SOPB has listed several of Mighty Earth’s Rapid Response cases on Samling in its grievance list, the company has failed to address these grievances or suspend Samling.

Several traders, biofuel companies and consumers brands are sourcing palm oil originating from SOPB (see tables below). These companies should file grievances with SOPB, requesting that it acts on the Samling case and suspends them.

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Cargill Lipsa

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Louis Dreyfus Mewah Neste Sime Darby

Supply Chain Links:

Consumer Brands

Sarawak Oil Palms

AvonColgate-

Palmolive

Friesland

CampinaHershey

Johnson &

Johnson

Supply Chain Links:

Consumer Brands

Sarawak Oil Palms

Kellogg's Mars PepsiCo

Supply Chain Links: PZ Reckitt

Consumer Brands Cussons BenckiserUnilever Upfield Vandemoortele

Sarawak Oil Palms

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Group: SamlingLPF/0007 Samling Jelalong (OP)Concession location: (3.313, 113.885)

Deforestation and/or peat development

Report

Report 18

Deforestation

(ha)

33 (via GLAD)

Peat Peat forest Clearance

development development prep/Stacking

(ha) (ha) lines(ha)

Time period

June 15-July 15,

2019

Report 19 95 (via GLAD)July 15-August 15,

2019

Report 20 96 (via GLAD)August 15-

?eptember 15, 2019

Report 21 38 (via GLAD)September 16-

October 15, 2019

Report 23 131 (via GLAD)November 15-

December 6, 2019

Report 240.15 (via

GLAD)

December 15, 2019-

January 15, 2020

Report 25 68 (via GLAD)January 1 5-February

17, 2020

Report 26 72 (via GLAD)February 1 7-March

16, 2020

Report 27 91May 24, 2019-April

17, 2020

Satellite imagery (see below) shows that between May 24, 2019 and April 27, 2020 a total of 91

hectares of forest were cleared in the LPF/0007 Samling Jelalong (OP) concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

rma)

VietnamPhilippines

Malaysia

Indonesia

LPF/0007 Samling Jela- $ 0. I'Song (OP)

VA

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Alert Imagery (before and after satellite images)Clearance location: (3.31 7, 113.844)

Date: May 24, 201 9 Date: April 17, 2020

Ownership Information

LPF/0007 Samling Jelalong (OP) is part of the Samling Group.5

Case NotesSee case notes for previous Samling case (PT Tunas Borneo Plantations) on page 17.

5. www.samling.com/

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Supply Chain Information

Supply Chain Links:

Traders and Biofuel

Companies

LPF/0007 Samling

Jelalong (OP)

BLD Plantation

BhdItochu

Samling

Supply Chain

Links: Traders

and Biofuel

Companies

LPF/0007

Samling Jelalong

(OP)

Lipsa Neste Olam Sarawak Oil Palms

Samling

Supply Chain Links:

Consumer Brands

LPF/0007 Samling

Jelalong (OP)

AvonColgate-

PalmoliveDanone FrieslandCampina

Samling

Supply Chain Links:

Consumer BrandsGeneral Mills

Johnson &

JohnsonKellogg's Mondelez

LPF/0007 Samling

Jelalong (OP)

Samling

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Supply Chain Information (continued)

Supply Chain Links:

Consumer Brands

LPF/0007 Samling

Jelalong (OP)

Nestle Nisshin Oillio PepsiCo PZ Cussons

Samling

Supply Chain Links:

Consumer BrandsReckitt Benckiser Vandemoortele

LPF/0007 Samling

Jelalong (OP)

Samling

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Supply Chain Information (continued)

Although SOPB published an NDPE in January 2019, the company has not published a mill list disclosing its suppliers and sources of palm oil. Although, SOPB has listed several Mighty Earth cases on Samling in its grievance list, the company have failed to address these grievances or suspend Samling.

A number of traders, biofuel companies and consumers brands are sourcing palm oil originating from SOPB (see tables below). These companies should file grievances with SOPB, requesting that it acts on the Samling case and suspends them.

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Cargill Lipsa

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Louis Dreyfus Mewah Neste Sime Darby

Supply Chain Links:

Consumer BrandsAvon

Colgate-

Palmolive

Friesland

CampinaHershey

Johnson &

Johnson

Sarawak Oil Palms

Supply Chain Links:

Consumer Brands

Sarawak Oil Palms

Kellogg's Mars PepsiCo

Supply Chain Links: PZ Reckitt

Consumer Brands Cussons BenckiserUnilever Upfield Vandemoortele

Sarawak Oil Palms

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

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

due diligence to determine if they are exposed to such companies/Groups and conduct their own satellite image analysis of these cases.

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

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

New Cases - Unknown Supply Chain Links

Concession license area Group/ownership

Area covered by

screened GLAD Time period

alerts (ha)

PT Banyan Tumbuh Lestari PT Buana Pratama Cipta (formerly Provident Agro) 14.02

March 16-April 15, 2020

PTTualang Raya Unknown Group 27.32March 16-April 15, 2020

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Repeat Cases - Known Supply Chain Links

Concession license area

PT Citra Agro Abadi

Group/ownership

Cilandry Anky AbadiGroup

Areacovered by screened GLAD alerts (ha)

160.70

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 17, 23, 25, 26

PT Permata Sawit MandiriSepanjang Group (PT PSM formerly owned by Genting Group)

484.40March 16-Apri 15, 2020

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

PT Mulia Inti Perkasa Widya Corporation 134.66March 16-Apri 15, 2020

Reports 6, 15, 16,20,21,22, 23, 24,25,26

PT Internusa Jaya Sejahtera Indonusa Group 111.11March 16-Apri 15, 2020

Reports 7, 10,11, 12, 15, 16, 17,20, 22,23,25

PT Sumber Alam Selaras NPC Resources Bhd 101.69March 16-Apri 15, 2020

Reports 23, 25, 26

PT Persada Era Agro Kencana Mulia Sawit Group 83.56March 16-Apri 15, 2020

Reports 9, 10, 11, 12, 15, 16, 17, 18, 19, 20, 22,23,24,25

PT Putra Utama LestariDharma Satya Nusantara

37.33March 16-Apri 15, 2020

Reports 20 and 23

PT Medcopapua Hijau Selaras Capitol Group 35.08March 16-Apri 15, 2020

Reports 25 and 26

PT Sabhantara Rawi SentosaDhanistha Surya Nusantara

25.79March 16-Apri 15, 2020

Reports 21,23, 26

PT Makmur Jaya Malindo Pinehill Pacific 22.30March 16-Apri 15, 2020

Reports 18 and 19

PT Bulungan Surya Mas Pratama 2

Global Enterprise Sdn Bhd 22.19

March 16-Apri 15, 2020

Report 21

PT Damai Agro Sejahtera Bumitama Group 20.90March 16-Apri 15, 2020

Reports 22, 23, 26

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

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Repeat Cases - Known Supply Chain Links

Concession license area

PT Putra Utama Lestari

Group/ownership

Dharma Satya Nusantara

Areacovered by screened GLAD alerts (ha)

20.14

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 20 and 23

PT Megakarya Jaya RayaHayel Saeed Anam Group

19.78March 16-Apri 15, 2020

Reports 5, 23, 26

PT Bina Sarana Sawit UtamaSamuel International Group

18.28March 16-Apri 15, 2020

Reports 19, 20, 24, 26

PT Citra Sawit CemerlangGentinq Plantations Bhd 17.65

March 16-Apri 15, 2020

Reports 14, 15, 16, 17, 19, 23, 24

PTTirta Madu Sawit Jaya Fangiono family 16.38March 16-Apri 15, 2020

Reports 22, 24, 25

PT Persada Era Agro Kencana Mulia Sawit Group 14.08March 16-Apri 15, 2020

Reports 9, 10, 11, 12, 15, 16, 17, 18, 19, 20, 22,23,24,25

PT Bulungan Surya Mas Pratama

Global Enterprise Sdn Bhd 13.38

March 16-Apri 15, 2020

Report 21

PT Usaha Sawit Unggul Asian Agri (RGE) 12.31March 16-Apri 15, 2020

Reports 17, 18, 20, 24, 26

PT Mekar Karya Kahuripan Makin Group 12.00March 16-Apri 15, 2020

Reports 17, 21, 22, 23, 26

PT Jaya Jadi UtamaCB Industrial Product Holding 11.93

March 16-Apri 15, 2020

Reports 15, 20, 23, 26

PT Kahayan Agro PlantationAnglo-EasternPlantations 10.30

March 16-Apri 15, 2020

Reports 1,14, 15, 18, 19, 20, 23, 24, 25

LPF/0018 Shin Yang OP Planting Area

Shin Yang Group 101.11March 16-Apri 15, 2020

LPF/0018 Shin Yang OP Planting Area

BLD Plantation BhdKTS Holdings Sdn Bhd 54.86

March 16-Apri 15, 2020

BLD Plantation Bhd

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

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Repeat Cases - Known Supply Chain Links

Concession license area

Danum Sinar Sdn Bhd

Group/ownership

Puncak Niaga Holdings Bhd

Areacovered by screened GLAD alerts (ha)

52.99

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Danum Sinar Sdn Bhd

Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum LD)

Shin Yang Group / Sarawak Oil Palms Bhd

47.19March 16-Apri 15, 2020

Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum

ID)______________

Almabumi Plantation Sdn BhdBBC Holdings Sdn Bhd 19.72

March 16-Apri 15, 2020

Almabumi Plantation Sdn Bhd

Woodijaya Sdn Bhd (Lot 197)Rimbunan Hijau Group

16.84March 16-Apri 15, 2020

Woodijaya Sdn Bhd (Lot 197)

LPF/0006 Samling Lana Samling Group 13.54March 16-Apri 15, 2020

LPF/0006 Samling Lana

Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD)

Shin Yang Group 13.23March 16-Apri 15, 2020

Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD)

Baram Estate, part of LPF/0004 Woodman Group 9.96March 16-Apri 15, 2020

Baram Estate, part of LPF/0004

Timrest Sdn BhdRimbunan Hijau Group

9.74March 16-Apri 15, 2020

Timrest Sdn Bhd

Hydroflow Sdn Bhd TH Plantations Bhd 9.60March 16-Apri 15, 2020

Hydroflow Sdn Bhd

Adong estate, part of LPF 0004 Woodman Group 8.26March 16-Apri 15, 2020

Adong estate, part of LPF 0004

Poh Zhen Sdn BhdRimbunan Hijau Group

7.89March 16-Apri 15, 2020

Poh Zhen Sdn Bhd

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

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Repeat Cases - No Known Supply Chain Links

Concession license area Group/ownership

PT Berau Karetindo Lestari Korompis family

Areacovered by screened GLAD alerts (ha)

100.06

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 2, 6, 9, 15, 16, 19, 20, 21,22

PT Tri Investama Green Yield Pte Ltd 11.07March 16-Apri 15, 2020

Reports 20, 21, 22,23, 24,25

PT Prasetya Mitra Muda (BlockUnknown Group 14.17

March 16-Apri 15, 2020

Reports 6, 17, 19

PT Marita Makmur Jaya Unknown Group 14.24March 16-Apri 15, 2020

Reports 12, 15, 17, 19,22,24,26

PT Gapura Alas Lestari Unknown Group 14.87March 16-Apri 15, 2020

Reports 16, 19, 20,23,25,26

PT Future Agropia IndonesiaJSK International Co Ltd (Korea) 15.78

March 16-Apri 15, 2020

Reports 17 and 20

PT Citrapermata Serundung Unknown Group 15.88March 16-Apri 15, 2020

Reports 20, 23, 26

PT Perkebunan Inti Sendawar IMC Plantations 17.81March 16-Apri 15, 2020

Reports 23 and 26

PT Cipta Karya Sesayap Unknown Group 19.55March 16-Apri 15, 2020

Reports 17, 22, 23, 25

PT Sumber Sawit Mitrajaya Unknown Group 20.06March 16-Apri 15, 2020

Reports 15, 17, 23, 25, 26

PT Pipit Citra Persada Unknown Group 22.03March 16-Apri 15, 2020

Reports 6, 17, 20

PT Sebaung Sawit PlantationShanghai Xinjiu Chemical Co Ltd 22.87

March 16-Apri 15, 2020

Reports 8, 12, 13, 16,20,21, 22, 23, 25

PT Barito Riau Jaya Unknown Group 24.01March 16-Apri 15, 2020

Reports 22, 23, 26

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

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Repeat Cases - No Known Supply Chain Links

Concession license area

PTTriomas Forestry Development Indonesia

Group/ownership

Unknown Group

Areacovered by screened GLAD alerts (ha)

43.99

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 17, 22, 23, 24

PT Palem Segar Lestari Henan Jiujiu Chemical Co. Ltd 57.88

March 16-Apri 15, 2020

Reports 5, 7, 12, 16, 18,20,21, 22,23,25,26

PT Menthobi Mitra Lestari

Unknown Group (PT MML formerly owned by PT Bakrie Sumatra Plantations Tbk)____

64.25March 16-Apri 15, 2020

Reports 16, 17,20, 22

PT Agrindo Sukses Sejahtera Starmas Sentosa Mandiri 95.34

March 16-Apri 15, 2020

Reports 8, 16, 22, 26

Telliana Enterprise Sdn Bhd Unknown Group 37.09March 16-Apri 15, 2020

Reports 18, 19, 20, 26

Formerly Ekran Bhd Unknown Group 27.30March 16-Apri 15, 2020

Reports 19, 20, 21,23,25,26

Titanium Management Sdn Bhd (Part 1)

Unknown Group 26.03March 16-Apri 15, 2020

Reports 18, 19, 21,26

Titanium Management Sdn Bhd (Part 2)

Unknown Group 17.39March 16-Apri 15, 2020

Reports 18, 19, 21,26

Limba Jaya Timber Sdn Bhd (Limbang)

Lee Linq Timber Sdn Bhd 7.95

March 16-Apri 15, 2020

Reports 18, 21, 26

LPF/0038 Limba Jaya Timber Sdn Bhd (Part 2)

Lee Linq Timber Sdn Bhd 7.88

March 16-Apri 15, 2020

Reports 18, 21, 26

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

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

in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf

of the aforementioned organization, working under grant from theNorwegian Agency for Development

Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.

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Rapid Response report 27

Rapid Response <[email protected]>Fri 5/8/2020 7:51 PM

Nasuha ThahaCc: [email protected]

@cargill.com>@cargill.com>;| @cargill.com

@cargill.com>; Phil Aikman <[email protected]>; Sarah Brickman <[email protected]>; AlexandraExperton @cargill.com>

| 1 attachments (3 MB)

Rapid Response Report 27_final.pdf;

Dear Nasuha -

Today, we are releasing Mighty Earth's Rapid Response report 27. which documents recent deforestation and/or peatland development in concessions in Indonesia and Sarawak, Malaysia (listed by Group, if known, then by concession name):

The following are new cases of deforestation and/or peatland development (in order of appearance in report 27) with known supply chain links:

Fangiono family companies: PT Agrindo Green Lestari

The following are unresolved cases of deforestation and/or peatland development (in order of appearance in report 26) with known supply chain links:

QL Resources Bhd: PT Pipit Mutiara Indah Wings Agro Group: PT Indopenta Sejahtera Abadi Samling: PT Tunas Borneo Plantations Samling: LPF/0007 Samling Jelalong (OP)

The report also includes 59 repeat cases of deforestation that were identified using filtered GLAD alerts, but for which we did not conduct satellite image analysis because, for the new cases, we could not determine any supply chain links, and for the repeat cases, satellite analysis was already included in previous Rapid Response reports.

Mighty Earth expects that palm oil traders and biofuel companies conduct their own due diligence to determine if they are exposed to the companies/Groups for which we could not determine supply chain links. Further, traders and biofuel companies without supply chain links to these cases should put them on their ‘no buy9 lists. Please confirm this action will be taken.

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

Fangiono family companies appears to sell (directly or indirectly) to AAK, Itochu, KLK, Musim Mas, Neste, Olam, Sime Darby, and Wilmar.QL Resources Bhd appears to sell (directly or indirectly) to AAK, ADM, Cargill, ISF, Itochu,

https://outlook.office.com/mail/inbox/id/AAQkADIyYzk4NDcyLTgw...tNDBiMS1hYTVkLTM4ZWQwZjIzNjczNQAQAMgp55tkk0upvb%2FLvMnKX68%3D Page 1 of 2

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and Louis Dreyfus.Wings Agro Group appears to sell (directly or indirectly) to AAK, Cargill, Fuji Oil, and Neste.Samling Group appears to sell (directly or indirectly) to AAK, BLD Plantation Bhd, IOI, Itochu, Lipsa, Neste, Olam, and Sarawak Oil Palms Bhd.

As Sarawak Oil Palms Bhd (SOPB) continues to source palm oil from the Samling Group, we request that palm oil traders that buy from SOPB ask the company to suspend the Samling Group, as many traders have already done (e.g. ADM, Bunge, Cargill, LDC, KLK, Sime Darby and Wilmar). Customers of SOPB include AAK, Cargill, KLK, Lipsa, Louis Dreyfus, Mewah, Neste and Sime Darby.

As mentioned in the cover email with Rapid Response report 13 and subsequent emails, Mighty Earth is including cases where any plantation group is found to be involved in deforestation and/or peatland development, regardless of whether the activities are for oil palm or any other plantation. How palm oil traders and biofuel companies address such grievances will be assessed as part of our Rapid Response Trader Tracking1 grievance performance system.

Please provide us with an update on your engagement, or if your grievance tracker has been updated recently on these cases, let us know so we can review. We ask for your reply no later than May 22, 2020, but if you need to delay your response due to the ongoing pandemic, please let us know when you will able to respond.

Thanks, and stay safe!

SARAH BRICKMAN I SENIOR ASSOCIATE I 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.

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MIGHTY EARTH

RAPID RESPONSEPalm Oil Report

$

\-w.;:

\ /£

T

Prepared with

MapHubs

Waxman

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/•> V

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Table of ContentsCases identified using Sentinel imagery

Indonesian Companies

New Case

Fangiono family companies: PT Agrindo Green Lestari 5

Unresolved Cases

QL Resources Bhd: PT Pipit Mutiara Indah 9

Wings Agro Group: PT Indopenta Sejahtera Abadi L3

Sanding: PT Tunas Borneo Plantations 1(5

Malaysian Companies

Unresolved Case

Samling: LPF/0007 Sanding Jelalong (OP) 22

Additional cases identified using filtered GLAD alerts

New Cases - No Known Supply Chain Links

PT Buana Pratama Cipta (formerly Provident Agro): PT Banyan Tumbuh Lestari 27

Unknown Group: PT Tualang Raya 27

Repeat Cases - Known Supply Chain Links. 28

Sepanjang Group: PT Permata Sawd Mandin28

Widya Corporation: PT Mulia Inti Perkasa

Indonusa Group: PT Internusa Jaya Sejahtera28

NPC Resources Bhd: PT Sumber Alam Selaras28

Mulia Sawit Group: PT Persada Era Agro Kencana 2g

Dharma Satya Nusantara: PT Putra Utama Lestari 2g

Capitol Group: PT Medcopapua Hijau Selaras 2g

Dhanistha Surya Nusantara: PT Sabhantara Rawi Sentosa 2g

Pinehill Pacific: PT Makmur Jaya Malindo 28

Global Enterprise Sdn Bhd: PT Bulungan Surya Mas Pratama 2 28

Bumitama Group: PT Damai Agro Sejahtera 28

Dharma Satya Nusantara: PT Putra Utama Lestari 29

Hayel Saeed Anam Group: PT Megakarya Jaya Raya 29

Samuel International Group: PT Bina Sarana Sawit Utama 29

Genting Plantations Bhd: PT Citra Sawit Cemerlang 29

Fangiono family companies: PT Tirta Madu Sawit Jaya 29

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Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases - Known Supply Chain Links (continued)

Mulia Sawit Group: PT Persada Era Agro Kencana

Global Enterprise Sdn Bhd: PT Bulungan Surya Mas Pratama

Asian Agri (RGE): PT Usaha Sawit Unggul

Makin Group: PT Mekar Karya Kahuripan

CB Industrial Product Holding: PT Jaya Jadi Utama

Anglo-Eastern Plantations: PT Kahayan Agro Plantation

Shin Yang Group: LPF/0018 Shin Yang OP Planting Area

KTS Holdings Sdn Bhd: BLD Plantation Bhd

Puncak Niaga Holdings Bhd: Danum Sinar Sdn Bhd

Shin Yang Group / Sarawak Oil Palms Bhd: Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum LD)

BBC Holdings Sdn Bhd: Almabumi Plantation Sdn Bhd

Rimbunan Hijau Group: Woodijaya Sdn Bhd (Lot 197)

Sanding Group: LPF/0006 Sanding Lana

Shin Yang Group: Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD)

Woodman Group: Baram Estate, part of LPF/0004

Rimbunan Hijau Group: Timrest Sdn Bhd

TH Plantations Bhd: Hydroflow Sdn Bhd

Woodman Group: Adong estate, part of LPF 0004

Rimbunan Hijau Group: Poh Zhen Sdn Bhd

Repeat Cases - No Known Supply Chain Links

Korompis family: PT Berau Karetindo Lestari

Green Yield Pte Ltd: PT Tri Investama

Unknown Group: PT Prasetya Mitra Muda (Block II)

Unknown Group: PT Marita Makmur Jaya

Unknown Group: PT Gapura Alas Lestari

JSK International Co Ltd (Korea): PT Future Agropia Indonesia

Unknown Group: PT Citrapermata Serundung

IMC Plantations: PT Perkebunan Inti Sendawar

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29

29

29

29

29

29

29

30

30

30

30

30

30

30

30

30

30

30

31

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3i

3i

3i

3i

3i

3i

29

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

those mill disclosures; please send to [email protected].

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

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Table of Contents

Additional cases identified using filtered GLAD alerts (continued)

Repeat Cases - No Known Supply Chain Links (continued)

Unknown Group: PT Cipta Karya Sesayap 31

Unknown Group: PT Sumber Sawit Mitrajaya 31

Unknown Group: PT Pipit Citra Persada 31

Shanghai Xinjiu Chemical Co Ltd: PT Sebaung Sawit Plantation 31

Unknown Group: PT Barito Riau Jaya 31

Unknown Group: PT Triomas Forestry Development Indonesia 31

Henan Jiujiu Chemical Co. Ltd: PT Palem Segar Lestari 32

Unknown Group: PT Menthobi Mitra Lestari 32

Starmas Sentosa Mandiri: PT Agrindo Sukses Sejahtera 32

Unknown Group: Telliana Enterprise Sdn Bhd 32

Unknown Group: Formerly Ekran Bhd 32

Unknown Group: Titanium Management Sdn Bhd (Part 1) 32

Unknown Group: Titanium Management Sdn Bhd (Part 2) 32

Lee Ling Timber Sdn Bhd: Limba Jaya Timber Sdn Bhd (Limbang) 32

Lee Ling Timber Sdn Bhd: LPF/0038 Limba Jaya Timber Sdn Bhd (Part 2) 32

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

those mill disclosures; please send to [email protected].

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

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Group: Fangiono family companiesPT Agrindo Green LestariConcession location: (-1.691, 113.874)

Deforestation and/or peat development

Report

Report 27

Deforestation

(ha)

149

Peat Peat forest Clearance

development development prep/Stacking

(ha) (ha) lines(ha)

Time period

September 11,2019-

February 23, 2020

Satellite imagery (see below) shows that between September 11,2019 and February 23, 2020 a total

of 149 hectares of forest were cleared in the PT Agrindo Green Lestari concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

Vietnam Philippine^

Malaysia

tibonesia

PT Agrindo Green Q.Lestari

PT Agnndo Grew Lestari

I

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Alert Imagery (before and after satellite images)

Clearance location: (-1.715, 113.889)

Date: September 11,2019 Date: February 23, 2020

Skitb

Clearance location: (-1.659, 113.867)

Date: September 11,2019 Date: February 23, 2020

i

yI WM

Iflr A ‘'m. -1 666726. M3 864314.J k

Ownership Information

PT Agrindo Green Lestari is part of the Ciliandry Anky Abadi Group (CAA),1 owned by the Fangiono family. The Fangiono family also owns Fangiono Agro Plantation (FAP).

l. Notaiy deeds

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Supply Chain Information

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Supply Chain Links:

Traders and Biofuel

Companies

PT Agrindo Green

Lestari

Itochu Musim Mas

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

Supply Chain Links:

Traders and Biofuel

Companies

PT Agrindo Green

Lestari

Neste Olam Sime Darby Wilmar

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

X

Supply Chain Links:

Consumer Brands

PT Agrindo Green

Lestari

AvonColgate-

PalmoliveDanone FrieslandCampina

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

Supply Chain Links:

Consumer Brands

PT Agrindo Green

Lestari

General Mills HersheyJohnson &

JohnsonKellogg's

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

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Supply Chain Information (continued)

Supply Chain Links:

Consumer BrandsMondelez Nestle PepsiCo

PT Agrindo Green

Lestari

Ciliandry Anky

Abadi/Fangiono

Agro Plantation

Supply Chain Links:

Consumer BrandsReckitt Benckiser Unilever Vandemoortele

PT Agrindo Green Lestari

Ciliandry Anky

Abadi/Fangiono Agro

Plantation

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Group: QL Resources Bhd

PT Pipit Mutiara IndahConcession location: (3.349, 117.220)

Deforestation and/or peat development

Report

Report 21

Deforestation

(ha)

50

Peat Peat forest Clearance

developme development prep/Stacking

nt(ha) (ha) lines(ha)

Time period

January 3-October

20, 2019

Report 27 25December 22, 2019-

March 16, 2020

Satellite imagery (see below) shows that between December 22, 2019 and March 16, 2020 a total of

25 hectares of forest were cleared in the PT Pipit Mutiara Indah concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

a)

VietnamPhilippines

PT Pipit Mutiara Indah g /

PT Pipit Mutiara Indah

Base Map - C Bing Maps. (31 Dae 2014 01

•• 'i . ~:t ' U'.V’,. ..

alaysia q

Indonesia

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Alert Imagery (before and after satellite images)

Clearance location: (3.388, 117.236)

Date: December 22, 2019 Date: March 16, 2020

1*

&Ownership InformationPT Pipit Mutiara Indah is part of QL Resources Bhd.2

2. QL Resources Bhd Annual Report 2019: http://ql.listedcompany.com/misc/ar2019.pdf.

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Supply Chain Information

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Supply Chain

Links: Traders

and Biofuel

Companies

PT Pipit Mutiara

Indah

AAK ADM Cargill

Louis

Itochu Dreyfus

QL Resources

Bhd

Supply Chain Links:

Consumer BrandsAvon

Colgate-

PalmoliveDanone FrieslandCampina

PT Pipit Mutiara

Indah

QL Resources Bhd

Supply Chain Links:

Consumer BrandsGeneral Mills Hershey Kellogg's

PT Pipit Mutiara Indah

QL Resources Bhd

Supply Chain Links:

Consumer BrandsMars Mondelez Nestle Nisshin Oillio

PT Pipit Mutiara

Indah

QL Resources Bhd

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Supply Chain Information (continued)

Supply Chain Links:

Consumer BrandsPepsiCo PZ Cussons

Reckitt

Benckiser

PT Pipit Mutiara

Indah

QL Resources Bhd

Supply Chain Links: Consumer

BrandsUnilever Upfield

PT Pipit Mutiara Indah

QL Resources Bhd

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Group: Wings Agro GroupPT Indopenta Sejahtera AbadiConcession location: (-2.110, 114.952)

Deforestation and/or peat development

Report

Report 19

Deforestation

(ha)

54

Peat Peat forest Clearance

developme development prep/Stacking

nt(ha) (ha) lines(ha)

Time period

May 12-August 21,

2019

Report 20 43 (GLAD alerts)August 15-

aeptember 15,2019

Report 21 12 (GLAD alerts)September 16-

October 15, 2019

Report 27 11October 11,2019-

Ma 'H 02i

Satellite imagery (see below) shows that between October 11,2019 and March 18, 2020 a total of 11

hectares of forest were cleared in the PT Indopenta Sejahtera Abadi concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

Vietnam 1/Philippines

Malaysia

Indonesia

PT Indopenta Sejahtera Abadi

PT Indopenta Sejahtera Abadi

V'

n

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Alert Imagery (before and after satellite images)

Clearance location: (-2.110, 114.952)

Date: October 11,2019 Date: March 18, 2020

Ownership InformationPT Indopenta Sejahtera Abadi is part of the Wings Agro Group.3

3. Wings Agro website: www.wingsagro.com/eng/ourbusines.

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Supply Chain Information

Supply Chain Links:

Traders and Biofuel

Companies

PT Indopenta

Sejahtera Abadi

Cargill Fuji Oil Neste

Wings Agro Group

Supply Chain Links:

Consumer BrandsGeneral Mills Hershey Kellogg's Nestle

PT Indopenta

Sejahtera Abadi

Wings Agro Group

Supply Chain Links:

Consumer BrandsPepsiCo PZ Cussons Unilever

PT Indopenta

Sejahtera Abadi

Wings Agro Group

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Group: SamlingPT Tunas Borneo PlantationsConcession location: (2.591, 117.522)

Deforestation and/or peat development

Report

Report 18

Deforestation

(ha)

13

Peat Peat forest Clearance

development development prep/Stacking

(ha) (ha) lines(ha)

Time period

May 3-August 3,

2019

Report 27 85February 22-April 27,

2020

Satellite imagery (see below) shows that between February 22, 2020 and April 27, 2020 a total of 85

hectares of forest were cleared in the PT Tunas Borneo Plantations concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

aj

VietnamPhilippines

PT Tunas Borneo q , Plantations

PT Tunas Borneo Plantations

Ban Map - O Bing Maps; (31 Dac 2014 QMT)

alaysia

Indonesia

m % i* * vV' '/*i-. -f

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Alert Imagery (before and after satellite images)

Clearance location: (2.688, 117.552)

Date: February 22, 2020 Date: April 27, 2020

r

Lft

r

Ownership Information

PT Tunas Borneo Plantations is part of the Samling Group.4

4. www.samling.com/contact.php

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Case Notes

Since February 2020, ADM, Cargill, Fuji Oil, KLK, LDC, Sime Darby and Wilmar - as well as Hershey’s, Mars, P&G, and Upfield - have all informed Mighty Earth that they have suspended Samling from their supply chains.

Sime Darby informed Mighty Earth that: “We would like to confirm that we have notified Samling

that we will no longer be sourcing from them due to concerns raised by our key customers. Central

to these concerns is the adoption ofNDPE commitments across the whole Samling Group, and not

just for Glenealy Plantations.”

On 15 April 2020, Samling responded to these suspensions - not by halting all Samling group-wide deforestation, but by offering up the smallest fig leaf: Glenealy Plantations Sdn Bhd announced an NDPE policy and a memo issuing a “group-wide moratorium on any land clearing for all greenfield

development on mineral soil andpeatland regardless of depth with immediate effect until further

notice.’”

Several traders and biodiesel companies - AAK, BLD, IOI, Neste, Olam, Sarawak Oil Palms Bhd (SOPB) - and consumer brands, including Mondelez, Nestle, and PepsiCo, have yet to take action to suspend Samling from their supply chains.

Glenealy has also been circulating information to traders claiming that ‘Glenealy holds all the oil

palm estates and mills’ and that the company owns 100% of the shares in Timor Enterprise Sdn Bhd (through Puncak Selasih Sdn Bhd) which owns the Jelalong, Lana and Belaja palm oil operations, Samling Plantations Sdn Bhd and other entities (see left graphic below).

Based on this information, it would be assumed that the moratorium applies to all Glenealy-owned plantation areas. However, according to shareholder ownership data obtained from the Companies Commission of Malaysia, Glenealy Plantations only owns 15.31% of Timor Enterprise Sdn Bhd. The majority shareholder (84.68%) in Timor Enterprise Sdn Bhd is Lingui Developments Sdn Bhd, which is 100% owned by Samling Malaysia Incorporated, registered in the British Virgin Islands (see right graphic below).

*GLENEALY PLANTATIONS SDN BHD

PUNCAK SELASIH SDN BHD

TIMOR ENTERPRISES SON BHD

Opoibon of ol plmUtiom wd d nit in S1W11 SvimL

(ttAttUtn-fotiarmori (AOEtUItt

Strand EsMn - Im, kiiloni)

|0i Mis - TP0M in Sibih, IP0M <nd IP0M in Wmdl

r mSAMUNG PLANTATION SON BHD

Opera ef oil pom owe ■ tap E«*f

* MU-VON

SHARIKO SON BHD

Opera oFdpJmaSra

FFB protod 0 Skrito EttttfctpKM

MINN________________

TIUEIAND DEVELOPMENT SON BHD

OperatfdpUmaSra

(ft nara ■ notM fun onpittM

MlNM_________________

Name

Registration No.

IC/Passport/ Registration No.

SHAREHOLDERS/MEMBERS

: TIMOR ENTERPRISES SDN BHD : 196801000390 (7998-H)

196701000630 (7S74-D) LINGUI DEVELOPMENTS SDN BHD

199801012243 (468371-D) PUNCAK SELASIH SDH. BHD.

141,567

25,600

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Supply Chain Information

Supply Chain Links:

Traders and Biofuel

Companies

PT Tunas Borneo Plantations

BLD Plantation

BhdItochu

Samling

Supply Chain

Links: Traders

and Biofuel

Companies

PT Tunas Borneo Plantations

Lipsa Neste Olam Sarawak Oil Palms

Samling

Supply Chain Links:

Consumer BrandsAvon

Colgate-

PalmoliveDanone FrieslandCampina

PTTunas Borneo

Plantations

Samling

Supply Chain Links:

Consumer BrandsGeneral Mills

Johnson &

JohnsonKellogg's Mondelez

PT Tunas Borneo Plantations

Samling

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Supply Chain Information (continued)

Supply Chain Links:

Consumer BrandsNestle Nisshin Oillio PepsiCo PZ Cussons

PT Tunas Borneo Plantations

Samling

Supply Chain Links:

Consumer BrandsReckitt Benckiser Vandemoortele

PT Tunas Borneo Plantations

Samling

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Supply Chain Information (continued)

Although SOPB published an NDPE policy in January 2019, the company has not published a mill list disclosing its suppliers and sources of palm oil. While SOPB has listed several of Mighty Earth’s Rapid Response cases on Samling in its grievance list, the company has failed to address these grievances or suspend Samling.

Several traders, biofuel companies and consumers brands are sourcing palm oil originating from SOPB (see tables below). These companies should file grievances with SOPB, requesting that it acts on the Samling case and suspends them.

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Cargill Lipsa

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Louis Dreyfus Mewah Neste Sime Darby

Supply Chain Links:

Consumer Brands

Sarawak Oil Palms

AvonColgate-

Palmolive

Friesland

CampinaHershey

Johnson &

Johnson

Supply Chain Links:

Consumer Brands

Sarawak Oil Palms

Kellogg's Mars PepsiCo

Supply Chain Links: PZ Reckitt

Consumer Brands Cussons BenckiserUnilever Upfield Vandemoortele

Sarawak Oil Palms

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Group: SamlingLPF/0007 Samling Jelalong (OP)Concession location: (3.313, 113.885)

Deforestation and/or peat development

Report

Report 18

Deforestation

(ha)

33 (via GLAD)

Peat Peat forest Clearance

development development prep/Stacking

(ha) (ha) lines(ha)

Time period

June 15-July 15,

2019

Report 19 95 (via GLAD)July 15-August 15,

2019

Report 20 96 (via GLAD)August 15-

?eptember 15, 2019

Report 21 38 (via GLAD)September 16-

October 15, 2019

Report 23 131 (via GLAD)November 15-

December 6, 2019

Report 240.15 (via

GLAD)

December 15, 2019-

January 15, 2020

Report 25 68 (via GLAD)January 1 5-February

17, 2020

Report 26 72 (via GLAD)February 1 7-March

16, 2020

Report 27 91May 24, 2019-April

17, 2020

Satellite imagery (see below) shows that between May 24, 2019 and April 27, 2020 a total of 91

hectares of forest were cleared in the LPF/0007 Samling Jelalong (OP) concession. (Imagery: Contains

modified Copernicus Sentinel data 2020)

rma)

VietnamPhilippines

Malaysia

Indonesia

LPF/0007 Samling Jela- $ 0. I'Song (OP)

VA

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Alert Imagery (before and after satellite images)Clearance location: (3.31 7, 113.844)

Date: May 24, 201 9 Date: April 17, 2020

Ownership Information

LPF/0007 Samling Jelalong (OP) is part of the Samling Group.5

Case NotesSee case notes for previous Samling case (PT Tunas Borneo Plantations) on page 17.

5. www.samling.com/

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Supply Chain Information

Supply Chain Links:

Traders and Biofuel

Companies

LPF/0007 Samling

Jelalong (OP)

BLD Plantation

BhdItochu

Samling

Supply Chain

Links: Traders

and Biofuel

Companies

LPF/0007

Samling Jelalong

(OP)

Lipsa Neste Olam Sarawak Oil Palms

Samling

Supply Chain Links:

Consumer Brands

LPF/0007 Samling

Jelalong (OP)

AvonColgate-

PalmoliveDanone FrieslandCampina

Samling

Supply Chain Links:

Consumer BrandsGeneral Mills

Johnson &

JohnsonKellogg's Mondelez

LPF/0007 Samling

Jelalong (OP)

Samling

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Supply Chain Information (continued)

Supply Chain Links:

Consumer Brands

LPF/0007 Samling

Jelalong (OP)

Nestle Nisshin Oillio PepsiCo PZ Cussons

Samling

Supply Chain Links:

Consumer BrandsReckitt Benckiser Vandemoortele

LPF/0007 Samling

Jelalong (OP)

Samling

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Supply Chain Information (continued)

Although SOPB published an NDPE in January 2019, the company has not published a mill list disclosing its suppliers and sources of palm oil. Although, SOPB has listed several Mighty Earth cases on Samling in its grievance list, the company have failed to address these grievances or suspend Samling.

A number of traders, biofuel companies and consumers brands are sourcing palm oil originating from SOPB (see tables below). These companies should file grievances with SOPB, requesting that it acts on the Samling case and suspends them.

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Cargill Lipsa

Supply Chain Links:

Traders and Biofuel

Companies

Sarawak Oil Palms

Louis Dreyfus Mewah Neste Sime Darby

Supply Chain Links:

Consumer BrandsAvon

Colgate-

Palmolive

Friesland

CampinaHershey

Johnson &

Johnson

Sarawak Oil Palms

Supply Chain Links:

Consumer Brands

Sarawak Oil Palms

Kellogg's Mars PepsiCo

Supply Chain Links: PZ Reckitt

Consumer Brands Cussons BenckiserUnilever Upfield Vandemoortele

Sarawak Oil Palms

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

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

due diligence to determine if they are exposed to such companies/Groups and conduct their own satellite image analysis of these cases.

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

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

New Cases - Unknown Supply Chain Links

Concession license area Group/ownership

Area covered by

screened GLAD Time period

alerts (ha)

PT Banyan Tumbuh Lestari PT Buana Pratama Cipta (formerly Provident Agro) 14.02

March 16-April 15, 2020

PTTualang Raya Unknown Group 27.32March 16-April 15, 2020

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Repeat Cases - Known Supply Chain Links

Concession license area

PT Citra Agro Abadi

Group/ownership

Cilandry Anky AbadiGroup

Areacovered by screened GLAD alerts (ha)

160.70

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 17, 23, 25, 26

PT Permata Sawit MandiriSepanjang Group (PT PSM formerly owned by Genting Group)

484.40March 16-Apri 15, 2020

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

PT Mulia Inti Perkasa Widya Corporation 134.66March 16-Apri 15, 2020

Reports 6, 15, 16,20,21,22, 23, 24,25,26

PT Internusa Jaya Sejahtera Indonusa Group 111.11March 16-Apri 15, 2020

Reports 7, 10,11, 12, 15, 16, 17,20, 22,23,25

PT Sumber Alam Selaras NPC Resources Bhd 101.69March 16-Apri 15, 2020

Reports 23, 25, 26

PT Persada Era Agro Kencana Mulia Sawit Group 83.56March 16-Apri 15, 2020

Reports 9, 10, 11, 12, 15, 16, 17, 18, 19, 20, 22,23,24,25

PT Putra Utama LestariDharma Satya Nusantara

37.33March 16-Apri 15, 2020

Reports 20 and 23

PT Medcopapua Hijau Selaras Capitol Group 35.08March 16-Apri 15, 2020

Reports 25 and 26

PT Sabhantara Rawi SentosaDhanistha Surya Nusantara

25.79March 16-Apri 15, 2020

Reports 21,23, 26

PT Makmur Jaya Malindo Pinehill Pacific 22.30March 16-Apri 15, 2020

Reports 18 and 19

PT Bulungan Surya Mas Pratama 2

Global Enterprise Sdn Bhd 22.19

March 16-Apri 15, 2020

Report 21

PT Damai Agro Sejahtera Bumitama Group 20.90March 16-Apri 15, 2020

Reports 22, 23, 26

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

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Repeat Cases - Known Supply Chain Links

Concession license area

PT Putra Utama Lestari

Group/ownership

Dharma Satya Nusantara

Areacovered by screened GLAD alerts (ha)

20.14

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 20 and 23

PT Megakarya Jaya RayaHayel Saeed Anam Group

19.78March 16-Apri 15, 2020

Reports 5, 23, 26

PT Bina Sarana Sawit UtamaSamuel International Group

18.28March 16-Apri 15, 2020

Reports 19, 20, 24, 26

PT Citra Sawit CemerlangGentinq Plantations Bhd 17.65

March 16-Apri 15, 2020

Reports 14, 15, 16, 17, 19, 23, 24

PTTirta Madu Sawit Jaya Fangiono family 16.38March 16-Apri 15, 2020

Reports 22, 24, 25

PT Persada Era Agro Kencana Mulia Sawit Group 14.08March 16-Apri 15, 2020

Reports 9, 10, 11, 12, 15, 16, 17, 18, 19, 20, 22,23,24,25

PT Bulungan Surya Mas Pratama

Global Enterprise Sdn Bhd 13.38

March 16-Apri 15, 2020

Report 21

PT Usaha Sawit Unggul Asian Agri (RGE) 12.31March 16-Apri 15, 2020

Reports 17, 18, 20, 24, 26

PT Mekar Karya Kahuripan Makin Group 12.00March 16-Apri 15, 2020

Reports 17, 21, 22, 23, 26

PT Jaya Jadi UtamaCB Industrial Product Holding 11.93

March 16-Apri 15, 2020

Reports 15, 20, 23, 26

PT Kahayan Agro PlantationAnglo-EasternPlantations 10.30

March 16-Apri 15, 2020

Reports 1,14, 15, 18, 19, 20, 23, 24, 25

LPF/0018 Shin Yang OP Planting Area

Shin Yang Group 101.11March 16-Apri 15, 2020

LPF/0018 Shin Yang OP Planting Area

BLD Plantation BhdKTS Holdings Sdn Bhd 54.86

March 16-Apri 15, 2020

BLD Plantation Bhd

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

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Repeat Cases - Known Supply Chain Links

Concession license area

Danum Sinar Sdn Bhd

Group/ownership

Puncak Niaga Holdings Bhd

Areacovered by screened GLAD alerts (ha)

52.99

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Danum Sinar Sdn Bhd

Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum LD)

Shin Yang Group / Sarawak Oil Palms Bhd

47.19March 16-Apri 15, 2020

Dataran Linau Sdn Bhd (Lot 1 Block 14 Murum

ID)______________

Almabumi Plantation Sdn BhdBBC Holdings Sdn Bhd 19.72

March 16-Apri 15, 2020

Almabumi Plantation Sdn Bhd

Woodijaya Sdn Bhd (Lot 197)Rimbunan Hijau Group

16.84March 16-Apri 15, 2020

Woodijaya Sdn Bhd (Lot 197)

LPF/0006 Samling Lana Samling Group 13.54March 16-Apri 15, 2020

LPF/0006 Samling Lana

Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD)

Shin Yang Group 13.23March 16-Apri 15, 2020

Linau Sinar Sdn Bhd (Metalon OP Estate, Lot 2, Danum LD)

Baram Estate, part of LPF/0004 Woodman Group 9.96March 16-Apri 15, 2020

Baram Estate, part of LPF/0004

Timrest Sdn BhdRimbunan Hijau Group

9.74March 16-Apri 15, 2020

Timrest Sdn Bhd

Hydroflow Sdn Bhd TH Plantations Bhd 9.60March 16-Apri 15, 2020

Hydroflow Sdn Bhd

Adong estate, part of LPF 0004 Woodman Group 8.26March 16-Apri 15, 2020

Adong estate, part of LPF 0004

Poh Zhen Sdn BhdRimbunan Hijau Group

7.89March 16-Apri 15, 2020

Poh Zhen Sdn Bhd

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

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Repeat Cases - No Known Supply Chain Links

Concession license area Group/ownership

PT Berau Karetindo Lestari Korompis family

Areacovered by screened GLAD alerts (ha)

100.06

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 2, 6, 9, 15, 16, 19, 20, 21,22

PT Tri Investama Green Yield Pte Ltd 11.07March 16-Apri 15, 2020

Reports 20, 21, 22,23, 24,25

PT Prasetya Mitra Muda (BlockUnknown Group 14.17

March 16-Apri 15, 2020

Reports 6, 17, 19

PT Marita Makmur Jaya Unknown Group 14.24March 16-Apri 15, 2020

Reports 12, 15, 17, 19,22,24,26

PT Gapura Alas Lestari Unknown Group 14.87March 16-Apri 15, 2020

Reports 16, 19, 20,23,25,26

PT Future Agropia IndonesiaJSK International Co Ltd (Korea) 15.78

March 16-Apri 15, 2020

Reports 17 and 20

PT Citrapermata Serundung Unknown Group 15.88March 16-Apri 15, 2020

Reports 20, 23, 26

PT Perkebunan Inti Sendawar IMC Plantations 17.81March 16-Apri 15, 2020

Reports 23 and 26

PT Cipta Karya Sesayap Unknown Group 19.55March 16-Apri 15, 2020

Reports 17, 22, 23, 25

PT Sumber Sawit Mitrajaya Unknown Group 20.06March 16-Apri 15, 2020

Reports 15, 17, 23, 25, 26

PT Pipit Citra Persada Unknown Group 22.03March 16-Apri 15, 2020

Reports 6, 17, 20

PT Sebaung Sawit PlantationShanghai Xinjiu Chemical Co Ltd 22.87

March 16-Apri 15, 2020

Reports 8, 12, 13, 16,20,21, 22, 23, 25

PT Barito Riau Jaya Unknown Group 24.01March 16-Apri 15, 2020

Reports 22, 23, 26

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

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Repeat Cases - No Known Supply Chain Links

Concession license area

PTTriomas Forestry Development Indonesia

Group/ownership

Unknown Group

Areacovered by screened GLAD alerts (ha)

43.99

Time period

March 16-Apri 15, 2020

Rapid

Responsereports related

to each case*

Reports 17, 22, 23, 24

PT Palem Segar Lestari Henan Jiujiu Chemical Co. Ltd 57.88

March 16-Apri 15, 2020

Reports 5, 7, 12, 16, 18,20,21, 22,23,25,26

PT Menthobi Mitra Lestari

Unknown Group (PT MML formerly owned by PT Bakrie Sumatra Plantations Tbk)____

64.25March 16-Apri 15, 2020

Reports 16, 17,20, 22

PT Agrindo Sukses Sejahtera Starmas Sentosa Mandiri 95.34

March 16-Apri 15, 2020

Reports 8, 16, 22, 26

Telliana Enterprise Sdn Bhd Unknown Group 37.09March 16-Apri 15, 2020

Reports 18, 19, 20, 26

Formerly Ekran Bhd Unknown Group 27.30March 16-Apri 15, 2020

Reports 19, 20, 21,23,25,26

Titanium Management Sdn Bhd (Part 1)

Unknown Group 26.03March 16-Apri 15, 2020

Reports 18, 19, 21,26

Titanium Management Sdn Bhd (Part 2)

Unknown Group 17.39March 16-Apri 15, 2020

Reports 18, 19, 21,26

Limba Jaya Timber Sdn Bhd (Limbang)

Lee Linq Timber Sdn Bhd 7.95

March 16-Apri 15, 2020

Reports 18, 21, 26

LPF/0038 Limba Jaya Timber Sdn Bhd (Part 2)

Lee Linq Timber Sdn Bhd 7.88

March 16-Apri 15, 2020

Reports 18, 21, 26

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

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

in part by Aidenvironment. Waxman is required under 22 U.S.C. § 614 to disclose that this material is distributed on behalf

of the aforementioned organization, working under grant from theNorwegian Agency for Development

Cooperation. Additional information is on file with the Department of Justice, Washington, D.C.

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